United States Office of Superfimd April 14, 2011
Environmental Protection Remediation and Technology
Agency Innovation (OSRTI)
Environmental Protection
Agency
vvEPA
Superfund Alternative Approach
Baseline Assessment
Section 1: Purpose
This baseline assessment provides a summarized description of the Superfund Alternative
Approach (SAA), including a brief history of its evolution, its current use, recent SAA
evaluation findings, the current practice on seeking state concurrence on National Priorities List
(NPL) listings, NPL-listing factors, and recommendations for the future use of SAA.
Section!: History
The "polluter pays" principle is a fundamental tenet of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA, commonly known as "Superfund").
Starting in 1989, EPA initiated its "Enforcement First" policy and began to first look to
potentially responsible parties (PRPs) to investigate and clean up Superfund sites before using
Fund money. Under this policy, PRPs conduct the majority of remedial actions.
In the 1990s, situations arose where PRPs or communities preferred that a site be addressed
without listing on the NPL. At some of these sites eligible for, but not listed on, the NPL, PRPs
were willing to perform a site cleanup with EPA oversight and enter into CERCLA agreements
to ensure work would be completed. This concept became known as the "NPL-equivalent"
approach, and by 2000, the Superfund Program Implementation Manual (SPEVI) had formally
incorporated the concept of an "NPL-equivalent" approach to site remediation.
In 1997, EPA issued the "State Coordination" memo, which confirmed EPA's intent to consult
and coordinate with states governments prior to proposing a site be included on the NPL in their
state. In practice, EPA has only proposed (never finalized) one site without state agreement.
Starting in 1999, and continuing through the early part of the following decade, EPA began to
place fewer sites on the NPL. For example, in 1999, 2000, and 2001, EPA listed 43, 38, 29 sites,
respectively, on the NPL, and by 2006 and 2007, EPA only listed 11 and 12 sites, respectively.
As noted in the SPEVI and congressional testimony, listing sites on the NPL became an "option
of last resort." Further, as many other cleanup programs (e.g., state voluntary cleanup programs,
state Superfund programs, and various state and federal Brownfields programs) evolved over the
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Superfund Alternative Approach Baseline Assessment
April 2011
prior two decades, the need for NPL listing somewhat decreased as these other programs' ability
to address contaminated sites became available.
In 2002, the practice of entering into remedial agreements at NPL-equivalent sites was captured
in the guidance, "Response Selection and Settlement Approach for Superfund Alternative Sites"
as an alternative to NPL listing. This SAA guidance supports a continued focus on listing sites
on the NPL. Prior to the 2002 SAA guidance, EPA entered into CERCLA agreements for
remedial-action work at more than 46 non-NPL sites in nine regions. The SAA guidance, which
was revised in 2004, promotes national consistency among agreements by ensuring that
CERCLA settlements at sites not listed on the NPL:
-4- achieve cleanups equivalent to those at NPL sites;
4- place EPA in the same enforcement posture as at NPL sites; and
4- provide the states, natural resource trustees, tribal governments and communities
opportunities for involvement as equivalent to that provided for NPL sites.
The threshold criteria for considering SAA are whether:
4- the site would qualify for listing on the NPL;
4- the site is expected to need long-term remedial action; and
4- there is viable, capable, and cooperative PRPs willing to enter into an enforceable
agreement with EPA and conduct the remedial work.
EPA routinely seeks out the best way to accomplish cleanups at NPL-caliber sites. While this
often calls for placement of the site on the NPL, sites are also often directed toward other federal
or state approaches—SAA is one of those alternative approaches.
When discussing the SAA we refer to SAA agreements, rather than SAA sites. The SAA is
agreement based. Sites with SAA agreements may also have other non-SAA agreement activity.
Section 3: Current SAA Use
In the nine years since the 2002 SAA guidance was issued, there have been 51 SAA agreements
addressing 66 sites (see Figure 1, Sites with SAA Agreements Since 2002). These SAA
agreements account for about 2% of all Superfund enforcement actions during that time period.
In this same time period, there have been 136 sites proposed to the NPL and 149 sites finalized
on the NPL.
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Figure 1, Sites with SAA Agreements and SAA Agreements Since 2002
# of sites with SAA
# of SAA agreements
Rl
0
0
R2
0
0
R3
2
2
R4
22
22
R5
34
19
R6
2
2
R7
1
1
R8
1
1
R9
2
2
RIO
2
2
Total
66
51
When were the SAA agreements been finalized?
Figure 2 shows the total number of SAA agreements that were reached in all Regions in the
years since the SAA guidance was issued. The number of SAA agreements peaked at nine in
2004, and has averaged six/year since 2007.
Figure 2, Number of SAA Agreements by Year
# of SAA agreements
'01
1
'02
5
'03
6
'04
9
'05
4
'06
2
'07
7
'08
6
'09
6
'10
5
Total
51
How are sites with SAA agreements distributed among regions?
Since 2002, Region 4 (with about 33% of SAA agreement sites) and Region 5 (with about 52%
of SAA agreement sites) have used SAA agreements to address sites in their Regions more than
all other Regions combined (see Figure 1, Sites with SAA Agreement?, Since 2002).
The two regions' use of the approach is best evaluated within the context of the work conducted
at each of the Region's Superfund programs. Since the SAA guidance was issued, Region 4
Superfund completed 834 non-SAA actions, and Region 5 completed 796 non-SAA actions.
Also, these two Regions continue to be the most active in listing sites on the NPL since 2002
(see Figure 3, Sites Proposed and Finalized on the NPL Since 2002), demonstrating that they
continue to use all available routes to cleanup.
Figure 3, Sites Proposed and Finalized on the NPL Since 2002
Proposed
Finalized
Rl
5
7
R2
22
29
R3
13
13
R4
25
25
R5
23
22
R6
16
17
R7
13
15
R8
8
9
R9
5
6
RIO
6
6
Total
136
149
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Aside from SAA, what have been other avenues taken to clean up sites?
Since 2002, of sites entered into the Comprehensive Environmental Response, Compensation,
and Liability Information System (CERCLIS), over 858 sites have been deferred to states for
further evaluation and cleanup, 146 sites have been deferred to Resource Conservation and
Recovery Act (RCRA) programs, and 405 sites have been deferred to other federal programs.
Figure 4, Avenues to Site Evaluation and Cleanup Since 2002
Deferral to State Programs
Deferral to other Federal Programs
NPL Listing (final)
Deferral to RCRA corrective action
Sites with SAA agreements
858
405
149
146
66
Where are SAA agreement sites in the remedial process?
Many of the sites with SAA agreements currently are in the initial stages of the remedial process.
See Figures 5 and 6 for a detailed look, by region, at where SAA agreement sites are in the
remedial process, and where PRP-lead sites listed on the NPL since the enactment of SAA are in
the remedial process.
Figure 5, SAA Agreement Sites in the Remedial Process
RI/FS
RD/RA
Rl
n/a
n/a
R2
n/a
n/a
R3
2
0
R4
11
9
R5
29
5
R6
1
1
R7
1
0
R8
0
1
R9
2
0
RIO
2
0
Total
48
16
641
1 Note: For the Region 4 site, Lyman Dyeing and Finishing, a "No Action" Record of Decision was issued. In
addition, the Kerr McGee-Navassa SAA site was listed on the NPL in April 2010, so it was not included in the
count. Kerr McGee-Navassa is, however, included in the counts for the total number of sites with SAA agreements
(66) and the total number of SAA agreements (51).
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Figure 6, PRP-leadNPL Sites (since 2002) in the Remedial Process
RI/FS
RD/RA
Post. Const.2
Rl
1
1
0
R2
15
0
0
R3
3
1
0
R4
2
4
1
R5
6
1
0
R6
5
0
0
R7
1
5
1
R8
1
2
0
R9
4
1
0
RIO
3
0
0
Total
41
15
2
58
How are SAA agreement sites tracked?
Similar to NPL sites, information on sites with SAA agreements is put into CERCLIS by
regional programs. EPA tracks most of the same key site and operating unit (OU)-level SAA
agreement events as those that are tracked for NPL agreements.
As of 7/13/10, the following measures were currently being tracked in CERCLIS for sites with
SAA agreements:
4- Remedial Investigation/Feasibility
Study Start
4 Record of Decision (ROD) Completed
4- ROD Amendments Completed
4- Remedial Design (RD) Start
4- RD Completion
•i- Remedial Action (RA) Start
4- Final Site Assessment Decisions
4- PRP Removal Completions
~4- RA Completions
4- Construction Completions
4~ Human Exposure Environmental
Indicator (El) Under Control
<4 Groundwater Migration El Under
Control
•4* Site-wide Ready for Anticipated Use
Further, all CERCLIS site status indicators are included for sites with SAA agreements (e.g.,
"Proposed to the NPL," "Native American Interest").
Has there been any congressional interest in SAA?
Since fiscal year (FY) 2008, EPA has reported annually to the House Appropriations Committee
(HAC) fiscal year intramural and extramural expenditures at sites with SAA agreements (see
Attachment 1 for FY09 report). In the FY09 annual report, it is noted that approximately
$10 million was spent at all SAA agreement sites in FY09. Direct site expenditures at sites with
2 Refers to the stage of EPA's remedial process known as "Post Construction Completion." Post Construction
Completion activities involve optimizing remedies to increase effectiveness and/or reduce cost without sacrificing
long-term protection of human health and the environment.
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SAA agreements include both intramural and extramural expenses. As of FY10, cumulative
direct site expenditures at all SAA agreement sites were approximately $80 million. By
comparison, since its inception, EPA's Superfund program has spent approximately $14 billion
in direct site expenditures atNPL sites (current and deleted).
In the FY09 HAC report, EPA also responded to the committee's request for additional
information on why Regions 4 and 5 have a large share of the sites with SAA agreements
(approximately 85%). For EPA's full response to the HAC, please see Attachment 1. As at
NPL sites, EPA costs at sites with SAA agreements are recoverable.
Do SAA agreements differ from agreements at NPL sites?
Agreements at NPL sites and SAA agreements start with the same model document. Depending
on the work involved (RI/FS, RD, RA) there are two or three additional provisions added to SAA
agreements to help keep EPA, communities, and natural resource trustees in a position
equivalent to that they would be in if the sites were listed on the NPL.
The Technical Assistance Plan (TAP) provision makes technical assistance available to local
communities. As Technical Assistance Grants (TAGs) are only available to sites proposed to or
listed on the NPL, TAPs are used to facilitate an equivalent level of community involvement at
sites with SAA agreements. A TAP is funded by the PRP pursuant to EPA oversight and is
available to a qualified community group upon application.
The Agreement Not to Challenge Listing after Partial Cleanup, or "Listing" provision helps
ensure human health and the environment are not jeopardized by an inadequate cleanup or an
interruption in response actions caused by unforeseen events. This provision places EPA in a
position equivalent to that it has at sites already proposed for listing or listed on the NPL with
respect to EPA policy on rescoring sites after partial cleanup, and prevents a PRP from
challenging the listing of a site after a partial cleanup. A partial cleanup may result in an HRS
score that would not qualify the site for inclusion on the NPL. This provision is included in
agreements for RA, where changing site conditions are expected, and generally is not included in
RI/FS agreements unless there is work in those agreements that may lead to changed site
conditions.
The Financial Assurance (FA) provision places EPA in a position roughly equivalent to that it
would be in if the site were listed on the NPL and PRP(s) stopped work. If PRP-financed work
at a NPL site stopped, EPA would have immediate access to the Fund to ensure there was no
stoppage of work. The FA provision is designed to provide a similar level of immediate access
to funds in the event a PRP stopped work at an SAA agreement site. The provision provides
quick-access "bridge-funding" to continue site work until EPA lists the site on the NPL and the
Fund is available for use. EPA only negotiates for this provision in RA settlements because the
Fund can be accessed prior to RA without listing the site.
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The natural resource damages (NRD) provision clarifies that sites with SAA agreements for
RI/FS are considered to have a ROD scheduled for purposes of bringing NRD claims. A general
statute of limitations (SOL) provision for NRD claims at NPL sites is that a claims action must
start within three years after the discovery of the loss and its connection with the release. The
exception to this SOL period is that an action for NRD claims at an NPL site, or any facility "at
which an [RA]... is otherwise scheduled"., must start within three years after completion of the
RA. As EPA anticipates a RA will be performed at any site using SAA, the NRD provision
clarifies that the SOL exception applies to sites under SAA agreements. The provision should be
included in RI/FS agreements regardless of whether NRD claims are known at the time.
How does community involvement at SAA agreements sites vary from NPL sites?
The community involvement process at sites with SAA agreements and NPL sites is similar. As
at NPL sites, Regions will assign a community involvement coordinator to each site under a
SAA agreement to respond to community concerns and explain EPA activities at a site, and the
public is invited to participate and provide comments at various stages of the remedial process
(e.g., commenting on a proposed remedy), with EPA responding to such comments in a manner
consistent with that at NPL sites.
However, there are some positive variations to the community involvement process at sites
where the technical assistance plan (TAP) provision is used in lieu of Technical Assistance
Grants (TAGs)3, such as sites with SAA agreements, and there are two steps that are unique to
NPL sites only. Community groups receiving TAPs do not have to provide matching funds, as
they do for TAGs, nor do they necessarily have to incorporate like groups receiving TAGs, or
submit an equivalent level of paperwork. Finally, the TAP provision requires the PRP, rather
than EPA, to provide technical assistance funds if a qualified community group applies. Just as
with TAGs, a qualified community group can receive up to $50,000 (in some cases, more) to hire
a technical advisor to assist in explaining the process and reviewing documents, and to keep the
rest of the community informed.
Community involvement processes unique to NPL sites are the opportunity for the public to
comment on the proposed site listing and the proposed "deletion" of a site from the NPL. The
site is first proposed to the NPL in the Federal Register. EPA then accepts public comments on
the site, responds to the comments, and may place the site on the NPL if it continues to meet the
requirements for listing. After the cleanup is completed, EPA publishes a notice of intent to
delete in the Federal Register and in a major newspaper near the community involved. A public
comment period is provided during prior to the deletion as well.
TAGs are available at sites proposed to, or listed on, the NPL. EPA may also negotiate for TAPs at NPL sites.
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Does the Agency for Toxic Substances and Disease Registry (ATSDR) perform
public health assessments (PHAs) at sites with SAA agreements?
CERCLA requires ATSDR to perform a health assessment for each site proposed for listing on
the NPL. ATSDR has also performed PHAs or health consultations (HCs) at 29 sites with SAA
agreements. ATSDR has recently agreed to perform PHAs and HCs at all forthcoming sites
under SAA agreements. Further, it will evaluate sites with SAA agreements from FY09-10 to
determine whether performing PHAs or HCs is feasible.
For more detail on SAA sites without ATSDR PAHs or HCs by Region, please see Attachment
2.
What are some of the characteristics of sites with SAA agreements?
The Office of Policy (OP) study (further discussed in Section 5), albeit based on a limited site
universe, found no significant differences between the demographics of sites with SAA
agreements and those on the NPL. Sites with SAA agreements address a similar range of issues
seen at NPL sites, including: groundwater, sediment and soil contamination, active community
groups and no community groups, NRD issues and no NRD issues, single PRPs and multiple
PRPs, large/complex cleanups, and relatively straightforward cleanups. There are SAA
agreements at landfills, dumps, manufacturing plants, mines, sediments, residential areas, and
refineries.
A unique application of SAA in Region 5 has resulted in multiple sites with the same history and
PRP being addressed under a few RI/FS agreements.4 Nineteen former manufactured gas plant
sites (in Wisconsin and Illinois) are being addressed under three SAA agreements with two PRPs
for RI/FS work. There is time and cost savings for the listing, negotiation, and oversight
processes as a result of addressing these sites together.
Section 4: Factors Effecting Listing Decisions & Use of Alternatives
A variety of factors, regulatory, policy and practice, are considered in making listing decisions.
Decisions not to list sites eligible for listing may be a result of combinations of these factors:
4- State concurrence on listing
4- Eco risk vs. human health risk
4 Presence of EJ community
4- Deferral to other programs
4- Federal property
4- International issues
4- Available funding
~4- Community involvement
4- Size/complexity of site problems
4- Presence of viable, capable PRPs
4- Redevelopment concerns
4- Likelihood of litigation
4 Specifically, one agreement for six WPSC sites, one agreement for two Illinois manufactured gas plant sites, and
one agreement for 11 other Illinois manufactured gas plants were reached.
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State concurrence on NPL listing
EPA's 1997 memo addressing state coordination on NPL-listings contains the flexibility for EPA
to list a site without a state's concurrence. In practice, however, EPA has only once proposed a
site without the state's concurrence.
The lack of state concurrence for site listing, however, is not always the reason Regions use
SAA. The two Regions with the highest use of SAA—Regions 4 and 5 (85% of sites with SAA
agreements)—both have noted that a lack of state concurrence is not a universal reason for using
SAA. For both these regions, the decision to use SAA was based on a variety of factors,
including community input. In contrast, some other Regions' use of SAA has been driven by the
lack of state concurrence (see Figure 7 for more detail.) Regions 7 and 10, for instance, have
used SAA because of the lack of state concurrence, while Region 6 uses SAA on a "case-by-
case" basis, having decided to use SAA at one site because of a lack of state concurrence, but, at
its other SAA agreement site, because of community concerns.
Figure 7, Response to Question: "Is the lack of state concurrence for listing a site the
main reason your region used the Superfund Alternative Approach? "
Response
#SAA
Rl
n/a
0
R2
n/a
0
R3
N
2
R4
Y&
22
R5
Y&
34
R6
Y&
2
R7
Y
1
R8
N
1
R9
Y&
2
RIO
Y
2
Section 5: 2010 Office of Policy (OP) Study on SAA Sites in Region 4
In 2009-2010, OP funded a program evaluation of the use of SAA in Region 4. The evaluation's
goals were to "examine the factors influencing the use of the SA approach; assess the
effectiveness of the SA approach in achieving the goals of the Superfund program; assess the
efficiency of the SA approach in terms of potential time and cost savings; [and] identify
strategies to improve the implementation, efficiency and effectiveness of the SA approach."
In its evaluation, OP evaluated 11 SAA agreements, and interviewed 11 Region 4 staff and
managerial personnel, two EPA HQ staff members, representatives of three PRPs, one developer,
and three community representatives in two communities. OP's research on Region 4 sites with
SAA agreements produced the following general findings:
4t Existing data do not reveal a significant difference between NPL and SAA sites with
regard to the time the negotiations or work take and/or monetary savings.
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«4 PRPs are willing to negotiate with EPA to avoid the "stigma" of listing and enter a more
cooperative process than NPL listing (though respondents noted PRP cooperation varies
among sites on the NPL and those under SAA.)
«4 To community members, SAA is viewed as positive or neutral.
4t- Data do not reveal any significant difference between NPL sites and sites with SAA
agreements with regard to future land use options.
While based on a limited data set, the study found no obvious trends that distinguished SAA sites
from NPL sites—including any significant time or cost savings related to the remedial process
(apart from the listing process) — and the overall sense from the community members, EPA
community involvement coordinators (CICs), remedial project managers (RPMs), PRPs, and
lenders interviewed, was that the general response to SAA is positive.
The one facet of the study that was comprehensive in its sample size was the analysis of minority
and low-income populations and their geographic distance to NPL and SAA agreement sites.
OP's analysis found no difference in the concentration of minority or low-income populations
near NPL and SAA sites.
The "Effectiveness Assessment of the Region 4 Superfund Alternative Approach" is available on
the Agency's website at http://www.epa.gOv/evaluate/pdf/SAA_evaluation_report.pdf. A fact
sheet on the report is available at http://www.epa.gov/evaluate/pdf/SAA_evaluation_
factsheet.pdf.
Section 6: Summary of Regional Perspectives on SAA
In discussions, EPA regions have described the benefits and the proper caution that should be
exercised when using SAA.
Benefits
There is a regional view that the benefit of having the approach available for use where
appropriate has clear advantages. Overall, the availability of SAA as a viable option has allowed
for some sites to be addressed by EPA when listing was a source of contention. Regions have
worked closely to ensure state support for utilizing the SAA, noting that in some instances states
will be unwilling to bring sites to federal attention if the SAA were not available. Several
regions believe SAA is a critical component of their site assessment process. The regions also
believe there are benefits of using SAA for communities. In the regional experience of using
SAA when working with communities, the advantages include the ability to: address a site
sooner, provide a seamless EPA presence, and offer more flexible technical support.
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Cautions
The Regions believe SAA should be used only in limited circumstances. Regions noted that the
SAA process does not provide the public with a formal opportunity to participate in the decision
about whether to place the site on the NPL. Also, some regions feel that the decision of whether
and when to manage a site using one of the alternatives to listing (e.g., deferral, SAA) is not
based on any predictable or verifiable independent criteria—rather, it is sometimes based on the
interests of the PRP(s) or communities.5 Some Regions are concerned that the availability of
SAA as an option creates the likelihood that there may be procedural inconsistencies among
otherwise similarly situated sites. Whether those procedural inconsistencies also translate
into substantive inconsistencies or inequities is harder to predict, but some regions believe there
is at least the potential for such substantive inconsistencies.6
Although it has not happened to date, there is concern about the possibility of: 1) a PRP
defaulting on its responsibilities during the remediation phase at a site under an SAA agreement
when the liquid FA provision in the agreement was not properly monitored to keep funds
available, resulting in a delay in immediately accessing remedial funding to keep the work going
while the site is listed; and 2) a PRP performing under a SAA agreement doing substandard work
when the FA provision was not adequately monitored to keep funds available, the agency being
unwilling to remove the PRP and take over the work because of the inability to immediately
access remedial funds at a non-NPL site. These concerns can be mitigated by properly
negotiating and monitoring liquid financial assurance that EPA can access to continue work
while EPA proceeds to place the site on the NPL.
Another area of regional concern is that SAA can relieve a community from the "stigma" of
having a Superfund site. In the instances where the Regions have been asked to consider
managing a site through SAA, avoiding the purported stigma has often been key part of the
discussion. Without conceding that NPL listing in fact creates a stigma, there is concern about
an inherent unfairness in allowing the stigma argument to be a factor in a community where,
there happens to be a willing, capable PRP, while at a similarly situated community where there
is no such PRP the NPL listing would proceed and the purported stigma would attach. Regions
caution that EPA should monitor the situation to ensure that this possibly unfair outcome does
not occur more frequently in environmental justice (EJ) communities.7 Finally, there is also
regional concern that the more common it becomes to address a site using an SAA agreement,
the more "uncommon" and undesirable it may appear to address a site through listing on the
NPL.
5 The SAA guidance includes threshold criteria that must be met before a site can even be considered for an SAA
agreement.
6 The OP evaluation was unable to identify any statistically significant substantive inconsistencies to date, based on
a limited data set.
7 The OP evaluation found no statistical difference in the minority and low-income populations surrounding NPL
sites and sites with SAA agreements.
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Section 7: Integrated Cleanup Initiative (ICI) SAA Workgroup
In February 2010, the ICI SAA Workgroup evaluated the current use of SAA, reviewed current
sites with SAA agreements to determine if they were better suited for listing on the NPL, and
identified areas of SAA that could be improved.
The following general findings were generated from the workgroup meetings:
«t Regions 4 and 5, the two regions with the largest number of sites with SAA agreements,
generally use SAA as a last resort and the number of SAA agreements/year is relatively
steady.
*4 No current site within the workgroup's SAA universe (aside from the Kerr-McGee,
Navassa site, which was listed on the NPL in April 2010, is viewed by Regions 4 or 5 as
a candidate for upcoming NPL rulemakings.
*4 There are RPMs assigned to SAA agreements to ensure the terms of administrative order
on consent (AOC) and/or consent decree (CD) are being implemented consistent with the
National Contingency Plan (NCP).
«4 The use of the SAA is small in comparison to the total number of other Superfund
actions.
4> Eliminating alternatives to NPL listing may increase the risk of states choosing not to
disclose information on sites to the regional offices.
«4 Multiple PRPs being involved with an SAA agreement does not impede successful
negotiations with EPA. (As at NPL sites, a single representative from a PRP group often
serves as a liaison for communication among the parties.)
The workgroup members also reviewed "regionally-identified" NPL-equivalent agreements at
non-NPL sites (agreements that pre-date the guidance or are not consistent with the SAA
guidance) to determine whether any of these sites are candidates for addition to NPL. After
evaluating these agreements for potential site listing, it was found that in Regions 2, 4, and 5
such sites were:
"4 past the stage in which a more formal SAA agreement would be useful for cleaning up
the site;
«t planned to be managed under an SAA agreement consistent with the national guidance in
the next few years; or
»t in the process of being prepared for NPL listing.
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Workgroup Recommendations to Improve SAA Process
«4 Develop agreement between EPA and ATSDR for ATSDR to perform public health
assessments—equivalent to those performed for NPL sites—at all current and future
SAA agreement sites.
4- Develop new "Attainment of Remedial Action Objectives" site status (analogous to site
"deletion").
4- Develop intermediate steps for tracking progress of remedial work under SAA.
4- Bring potential SAA agreement sites to NPL listing panel for discussion regarding site
characteristics and planned use of SAA.
4 Update SAA guidance.
4- Continue to review universe of non-NPL, "regionally-identified" sites with CERCLA
agreements pre-dating the 2002 SAA guidance.
Section 8: SAA Case Studies
The following are a few recent examples of how SAA has been used to facilitate site cleanup.
The first example, in Region 4, reveals how the bankruptcy of a party to an SAA agreement did
not hinder listing the site on the NPL so remediation could proceed. The second example in
Region 5 shows how a single SAA agreement can effectively address multiple sites. The final
example provides insight into how an SAA agreement was used to best accommodate one of
Region 9's tribal communities.
Region 4: Kerr-McGee Navassa site (Navassa, N.C.)
Under a 2004 SAA agreement for an RI/FS, Kerr-McGee (PRP) completed an expanded site
investigation (ESI) in 2005 and began a RI in 2006. To manage site remediation efforts at the
site, Kerr-McGee established a subsidiary company, Tronox. Tronox filed for Chapter 11
bankruptcy protection in January 2009. As bankruptcy proceedings and associated lawsuits
could take years to be resolved, Region 4, in the interest of starting remedial work at the site after
the ROD is signed, listed the site on the NPL so work could continue under fund-lead action until
the bankruptcy was settled and site trustees resumed responsibility for the work. The site was
listed on the NPL in April 2010.
Region 5: Wisconsin Public Service Sites (Wis.) and Peoples Gas Sites (111.)
EPA was approached by Wisconsin Public Service Corp. (WPSC) in 2005, about investigating
and cleaning-up seven former manufactured gas plant sites (MGPs) in Wisconsin using SAA.
EPA entered into two agreements with WPSC for RI/FS work at the seven sites (one agreement
addresses six sites).
Page 13 of 15
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Superfund Alternative Approach Baseline Assessment
April 2011
When WPSC merged with Peoples Energy to form Integrys Energy Group (Integrys), EPA was
approached by Peoples Energy in 2007, to address thirteen former MGPs in Illinois using SAA.
EPA and Integrys entered into an agreement for an RI/FS at two sites and another agreement for
Engineering Evaluations and Cost Analyses (EE/CAs) at 11 more sites.
Since the 20 sites have similar conditions and contaminants, and Integrys is responsible for each,
the agreements allowed a streamlined approach to site investigation and remedy development.
Some benefits of the agreements include the use of multi-site documents, a mechanism to review
the adequacy of past work, and scheduling flexibility to allow progress on the worst problems
first. By the end of 2008, all of the multi-site documents had been approved, and site-specific
work had begun at several of the sites. In October 2008, EPA and Integrys entered into an SAA
RI/FS AOC for the 11 former MGP sites where the EE/CAs had been completed.
Region 9: Cyprus Tohono Mine (North Komelik, Ariz.)
At the request of the Tohono O'odham Nation, EPA performed a PA/SI and EE/CA at this
mining site located within the Tohono O'odham Nation in Arizona. The Tohono O'odham
Nation started the NRD process with the Department of the Interior, Cyprus Tohono Corp.
(CTC), and Phelps Dodge Corp. In 2006, CTC signed an agreement to perform removal actions
addressing surface contamination and source materials. EPA determined that an RI/FS was
needed to further characterize groundwater contamination. The Tohono O'odham Nation, which
owns the site and leases it to CTC, requested in writing that the RI/FS proceed without listing the
site on the NPL. Taking into consideration the tribe's request and the PRP's willingness to work
cooperatively with EPA and the tribe on previous site work, in 2009 Region 9 negotiated an
SAA agreement for RI/FS with the CTC. The RI/FS, focused on uranium contamination in
groundwater, is proceeding under the agreement.
Section 9: Conclusion
This assessment shows SAA to be an effective tool for getting private parties to conduct site
assessments and remedial activities.
It can also be noted from this assessment:
«t The number of sites with SAA agreements, when compared to other EPA enforcement
activities, is small (2%).
«4» Comparing the number of sites Regions 4 and 5 have listed on the NPL with the number
of sites with SAA agreements in those regions and the total number of non-SAA actions
in both those regions, reveals the use of SAA is limited in both regions.
4t- SAA gives regions an approach that allows for several sites to be managed under one
agreement (e.g., Wisconsin Public Service Sites and Peoples Gas sites in Illinois).
Page 14 of 15
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Superfund Alternative Approach Baseline Assessment
April 2011
«4 The number of sites that have been deferred to other programs (state, federal, RCRA,
NPL listing) demonstrates that many site clean-up options are considered in addition to
SAA.
«4 The community involvement process at sites with SAA agreements is equivalent to that
at NPL sites.
«4 Funding for community technical assistance is available for SAA site communities as it
would be for those at NPL sites.
4*- Key provisions in SAA agreements (i.e., listing, financial assurance, and NRD) protect
EPA, the trustees and community from the possibility of a PRP reneging on its
commitments.
«t There are ways the approach can be improved (e.g., performing ATSDR PHAs at sites
with SAA agreements) to better parallel the NPL process.
«t No SAA agreement sites in Regions 4 and 5 (85% of total sites with SAA agreements)
are at a point to be evaluated for the NPL.
4t- There are a variety of factors that account for regions deciding to use SAA (e.g.,
community involvement, redevelopment concerns).
4*- State concurrence is not a universal reason for regions choosing to use SAA.
4- Regions 4 and 5 rarely use SAA because of a lack of state concurrence; among the other
regions, lack of state concurrence is not a primary reason for using SAA.
Further, OP's research findings on sites with SAA agreements in Region 4, albeit based on a
limited data set, have shown SAA to be a sound tool for use in certain situations to address sites
that are not listed on the NPL. OP's research also revealed community sentiment toward SAA is
nearly equivalent to that for NPL sites, suggesting communities are more concerned with seeing
a site cleaned up than with the cleanup vehicle. However, as OP's quantitative analysis of the
remedies selected at sites with SAA agreements was based on limited data, additional research
on remedies selected at SAA sites should be conducted as many of the SAA agreements mature
to ensure equivalency with the NPL process. It may also be beneficial to expand OP's research
to include sites with SAA agreements in Region 5.
For information on this report, contact David Yogi, OSRTI, yogi.david@epa.gov.
Page 15 of 15
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Attachment 1
Fiscal Year 2009 Report to U.S. House Appropriations Committee on
Direct Site Expenditures at Sites with SAA Agreements
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to Appropriations Committee (HAC) FY
Alternative Approach: for FY 2009
On page 112 of the House Appropriations Committee Report 110-187 accompanying the FY 2008 Department of the Interior, Environment,
and Related Agencies Appropriations Bill (H.R. 2643), the Committee has requested the Agency "to report, at the end of each fiscal year,
the number of sites using the Superfund Alternative approach funded, by Region; the intramural and extramural costs associated with those
sites; and information on site listed including the risk posed by each site." On 108 of the House Appropriations Committee
Report 111-180 accompanying the FY 2010 Department of the Interior, Environment, and Related Agencies Appropriations Act (P.L. 111-
80), the Committee continued "to direct the Agency to report annually, by region, on the using the Superfund Alternative Approach
Agreements, including intramural and extramural costs." In addition, the Committee noted *4that in fiscal year 2009 over 75 percent of the
funds attributed to the alternative approach were used by only two EPA regions and questioned why two regions rely so heavily on the
alternative approach and the Administrator to review this program." In May 2009, EPA provided the second annual report with
cumulative information through the end of FY 2008. This document updates that report with cumulative information through the end of FY
2009 and responds to the Committee's question regarding why two regions use the Alternative (SA) approach.
EPA uses the SA approach as an administrative alternative to listing sites on the National Priorities List (NPL). By EPA definition, the SA
approach is used at where; 1) site contaminants are significant enough that the site would be eligible for listing on the NPL, 2) a long-
term response (i.e., a is anticipated at the site, and 3) there is a willing, potentially-responsible party (PRP) who
will sign an agreement with EPA to perform the investigation or cleanup consistent with the National Contingency Plan (NCP). Since the
June 2002 -guidance "Response and Enforcement Approach for Superfund Alternative Sites" was issued, EPA has negotiated 45
SA approach agreements addressing the 61 in the table below.
The NCP (40 CFR 300.425(b)(l)) limits the use of federal Superfund remedial action funds to sites listed on the NPL, While some
Superfund response funds may be at these sites for the initial identification and screening work, these costs are included in the terms
of SA agreements for recovery from the PRP. Any Superfund response funds spent on early removal actions or oversight are also cost-
recoverable.
SA sites may pose risks to human health and the environment which require further investigation and possible remediation. EPA has listed
the nature of threat1 at each site in the table below.
There is no requirement for to use the SA approach; rather, it is a tool that regions may choose to use in appropriate circumstances
to encourage responsible parties to and fund Superfund actions with EPA oversight. Since 2002? EPA Regions 4 and 5 have used
' The nature of threat presents the hazardous substances, pollutants or contaminants identified at each site.
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to House Appropriations Committee (HAC) FY 2009
Alternative Approach; for FY 2009
the SA approach more than other regions; however, these Regions do not rely heavily on the approach relative to other Superfund actions in
their regions. To help put these Regions* use of the SA approach in perspective, from FY 2002 through FY 2009: Region 4 Superfund had
20 SA approach agreements and 466 other Superfund PRP-Iead actions' and 368 fund-lead actions (834 non-SAA actions); Region 5
Superfund had 15 new SA approach agreements, 415 other PRP-lead actions and 381 fund-lead actions (796 non-SAA actions). Further,
Region 4 and 5 together proposed as many sites to the NPL during FY 2009 (11) as all other regions combined. Due in part to the
willingness of Regions 4 5 to try the SA approach early and their large number of Superfund (the two largest Superfund regions in
the country), they now have the most experience using the SA approach. Additionally, many of the States and PRPs within those Regions
have become familiar with the approach, making it easier to use in appropriate circumstances. In Region 5, the circumstance of PRP's
committing to perform Superfund investigations at 19 sites under only 3 agreements (one each for 2 sites, 6 sites, and 11 sites),
greatly increased the number of under S A approach agreements, but not the number of agreements.
1 In this report, actions include removals, remedial investigations/feasibility studies (RI/FS), remedial designs (ED), and remedial actions (RA).
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to House Appropriations Committee (If AC) FY
Superfund Alternative Approach: for FY 2009
SiteswithSupeifund 9/30/09
CERCL1S Site Name
City,
EPA Site ID
Nature of Threat
Cumulative
Direct Site
Expenditures
Through FY
2008
(A)
FY 2009
Intramural
Costs2
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to Appropriations Committee (HAC) FY
Alternative Approach: Update for FY 2009
CERCLiS Site Name
Gurley Pesticide Burial
(New)
Henry's Knob
Holtra Chem/Honeywell Inc.
Illinois Central Railroad
Company's Johnston Yard
Jacksonville Ash
Kerr-McGee
Lyman Dyeing and Finishing
National Fireworks
Orlando Gasification Plant
Sanford Gasification Plant
(New)
Sixty One Industrial Park
Solitron Devices, Inc.
Sprague Electric
Weyerhaeuser Co / Plymouth
Wood Treating Plant
Region 4 Totals
City,
Sclma. NC
Clover, SC
Riegelwood, NC
Memphis, TN
Jacksonville, FL
Navassa, NC
Lyman, SC
Cordova, TN
Orlando, FL :
Sanford, FL
Memphis, TN
West Palm Beach,
FL
Longwood, PL
Plymouth, NC
EPA Site ID
NCD986 172526
SCNGOG4G7376
NCD991278631
TNP073540783
FLSFN0407002
NCD980557805
SCD987584653
TNSFN0407047
FLD984 169235
FLD984169193
TND98779Q3GQ
FLD032845778
FLDOG407265S
NCD991278540
Nature of Threat
Pesticides, organics,
inorganics, heavy metals,
VOCs
Metals
Mercury, PCBs
Metals, solvents, pesticides
Lead, arsenic
Organics
Dye residues, solvents,
hydraulic liquids
TCE, DCA, pcrchlorate
Organics, inorganics
Metals, VOCs, PAHs;
dioxins/dibenzofiwans
Metals, pesticides, PAHs,
PCBs
Volatile organics, metals,
1-4 dioxane
TCE
Mercury
Cumulative
Direct
Expenditures
Through FY
2008
(A)
n/a
5439,348
$1,279,566
$128,222
$1,013,290
$227,101
$681,901
$433,870
$286,305
n/a
$637,794
$771,762
$139,577
$3,079,044
$33,839,515
FY
Intramural
Costs1
(B)
S21L632
$14,377
$41,369
$17,736
$38,201
$12,597
522,916
$17,498
$34,879
$598,682
$38,779
$12,213
$41,852
542,877
$1,755,284
FY 2009
Extramural
Costs2
(C)
$294,127
$70,917
$29,568
$2,317
$34,496
58,316
$3,949
$151,545
$21,477
$766,440
$38,040
SO
S2,027
$31,047
$3,201,665
Cumulative
Direct Site
Expenditures
Through FY
200S
(A) + (B) + CC»
$505,759
$524,642
SI, 350,503
$148,275
$1,085,987
5248,014
$708,766
$602,913
$342,661
$1,365,122
$714,613
$783,975
5183,456
$3,152,968
$38,796,464
1 Intramural Costs include the information provided in the Integrated Financial Management System (IFMS) for Compensation and Benefits," "Expenses,"
and "Travel."
2 Extramural Costs include "Contracts,** "Grants/loans,*' and "Interagency agreements (f AGsV
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to House Appropriations Committee (HAQ FY
Alternative Approach: for FY
CERCLIS Site Name
EPA Site ID
Nature of Threat
REGION 5
Alcoa Properties
Bumfaam Canal- Miller
Compressing
Cedar Creek
Ellsworth Industrial Park
Evergreen Manor
Ford Road Landfill (New)
North Shore Gas (North)
North Shore Gas (South)
Old American Zinc Plant
Peoples Gas Former
Manufactured Gas Plant,
Crawford Station (New)
Peoples Gas Former
Manufactured Gas Plant,
Hawthorne Ave (New)
Peoples Gas Former
Manufactured Gas Plant,
Hough Place Station (New)
East St. Louis, 1L
Milwaukee, Wl
Cedarburg, WI
Downers Grove, IL
Winnebago. IL
Elyria, OH
Waukegan, IL
Waukegan, IL
Fairmont City, IL
Chicago, IL
Chicago, IL
Chicago, IL
ILSFN0508010
WINOOG5 10222
WID98 8590261
ILN000508246
ILD984836734
OHD988590261
ILD9S480799G
ILD98480922S
IL0000034355
ILN000510192
1LN0005I0195
10190
Metals, cyanide
Inorganics, PAHs, asbestos
containing material,
benzene, other or§anics
PCBs in sediment
TCE, PCE
TCE, PCE
PAHs, PCBs, benzene,
vinyl chloride, metals,
pesticides
PAHs, volatiles, metals
(One agreement for both
•sites)
Metals, pesticides
Cyanide, metals, VOCs
(including TCE), PAHs,
PCBs, tar, oil, grease,
metals
(11 sites under one
agreement)
Cumulative
Direct Site
Expenditures
Through FY
2008
(A)
FY 2008
Intramural
Costs1
(B)
FY 2009
Extramural
Costs2
(C)
Cumulative
Direct Site
Expenditures
Through FY
2009
(A) + (B» + (C)
$451,467
SI 2,987
$716,679
$3,651,463
$3,543,113
n/a
$87,223
$10,206
$556,440
n/a
n/a
n/a
$2 1, 06 1
$28,044
$22,488
$39, 1 53
$13,071
$203,392
$3,296
SI, 454
$15,065
$7,090
$2,826
$9,166
$30,561
$9,724
$56,784
$182,775
$2,049
5263,940
$4,323
$21,626
$69,437
$9,060
$3,973
$87,062
$503,089
$50,755
$795,951
$3,873,391
$3,558,233
$467,332
$94,842
$33,286
1640,942
S16,i50
$6,799
$96,228
1 Intramural Costs include the provided in the Integrated Financial Management System (IFMS) for Compensation and Benefits," "Expenses,"
and "Travel."
2 Extramural Costs Include "Contracts," "Grants/loans,™ and "Interagency agreements (IAGs),"
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to Appropriations Committee (HAC) FY
Alternative Approach: for FY 2009
CERCLIS Site Name
Peoples Gas Light & Coke,
22nd St. (New)
Peoples Gas Light & Coke,
Division St. (New)
Peoples Gas Light & Coke,
North Station (New)
Peoples Gas Light & Coke,
Willow St. Station (New)
Peoples Gas Former
Manufactured Gas Plant,
North Shore Ave, Station
(New)
Peoples Gas Former
Manufactured Gas Plant,
Piracy Court (New)
Peoples Gas Former
Manufactured Gas Plant,
South Station (New)
Peoples Gas Former
Manufactured Gas Plant,
Tliroop St. (New)
Peters Cartridge Factory
Solvay Coke & Gas Co.
City,
Chicago, IL
Chicago, IL
Chicago, IL
Chicago, IL
Chicago, IL
Chicago, IL
Chicago, IL
Chicago, IL
Kings Mills, OH
Milwaukee, WI
EPA Site ID
JLD982074767
ILD982074783
1LD982074775
ILD9S2D74759
ILN0005I0193
ILN000510196
1LN000510191
ILN0005 10194
OHD987051083
WTN000508215
Nature of Threat
Cyanide, metals, VOCs
(including TCE), PAHs,
PCBs, tar, oil, grease,
metals
(I I sites under one
agreement)
Metals
Metals
Cumulative
Direct Site
Expenditures
Through FY
2008
(A)
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
$409,699
$697,210
FY 2009
Intramural
Costs1
(B)
S3 1,306
S8,177
$8,752
55,300
$4,184
S2S.952
$18,324
$1,344
$49,756
$28,268
FY 2009
Extramural
Costs2
(C)
$158,171
$5,585
$3,879
$4,435
$7,374
$103,845
$4,748
$3,067
$120,194
$2 17,068
Cumulative
Direct Site
Expenditures
Through FY
2009
(A) + (B) + (C)
$189,477
SI 3,762
$12,631
$9,735
$11,558
$132,797
$23,072
$4,411
$579,649
$942,546
1 Intramural Costs include the information provided in the Integrated Financial Management System (IFMS) for "Personnel Compensation and Benefits," "Expenses,"
and "Travel."
: Extramural Costs include "Contracts," "Grants/loans," and "Interagency agreements (IAGs),"
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to Appropriations Committee (If AC) FY
Superfund Alternative Approach: Update for FY 2009
Site
South Dayton Dump and
Landfill
Town of Pines Groundwater
Plume
Treraont City Landfill
WPSC Camp Marina MGP
WPSC Green Bay MGP
WPSC Manitowoc MGP
WPSC Marinette MGP
WPSC Oshkosh MGP
WPSC Stevens Point
WPSC Two Rivers MGP
Dayton, OH
Town of Pines, FN
Tremonf City, OH
Sheboygan, WI
Green Bay, W!
Manitowok, WI
Marinette, WI
Oshkosh, WI
Stevens Point, Wi
Two Rivers, WI
EPA Site ID
OHD980611388
INN000508071
OHD98Q6I2188
WINOG05 10058
W1N000509948
WINQQQ509949
W1N000509952
WINOOOS09947
WIN000509983
WM000509953
Nature of Threat
Lead, copper, antimony,
arsenic, barium, beryllium,
cadmium, mercury, PCBs,
organic compounds, vinyl
chloride, ICE, other VOCs
Molybdenum, boron
Metals, organics
Benzene, toluene, xylene,
PAHs, metals, cyanide
Benzene, toluene, xylene,
PAHs, metals, cyanide
(Six sites under one
agreement)
Region 5 Totals
Cumulative
Direct
Expenditures
Through FY
2008
W
$561,926
$723,742
$2,729,810
$116,773
$12,100
$50,788
$12,600
$59,230
$70,659
$12,305
$14,486,42(1
FY 2009
intramural
Costs1
(B)
$37,807
$34,492
$67,713
$23,917
$832
$2,481
$1,022
$10,491
$8,193
S208
S737,62S
FY 2009
Extramural
Costs2
(C)
SI 16,772
$40,881
$89,833
$45,201
$943
$9,521
S3,435
$3,058
$6,463
S559
$1,686,346
Cumulative
Direct Site
Expenditures
Through FY
2009
(A) + (B) + {C}
$716,505
$799,115
$2,887,356
$185,891
$13,875
$62,790
$17,057
$72,779
$85,315
SI 3,072
SI6,flt,J91
REGION 6
Falcon Refinery
Highway 71/72 Refiner)'
Region 6 Totals
Ingleside, TX
Bossier City, LA
TXD086278058
LAD98 1054075
Tank wastes
Lead, hydrocarbons,
benzene
$419,067
$4,605,722
$5,024,789
$37,073
$25,600
562,637
$22,337
$91,195
§113,532
$478,477
$4,722,517
1 Intramural Costs include the information provided in the Integrated Financial Management System (1FMS) for "Personnel Compensation and Benefits," "Expenses,"
and "Travel."
2 Extramural Costs include "Contracts," "Grants/loans," and "Interagency agreements (IAGs)."
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to Appropriations Committee (HAC) FY
Alternative Approach: for FY 2009
CERCLIS Site Name
City,
EPA Site ID
Nature of Threat
Cumulative
Direct Site
Expenditures
Through FY
2008
-------
Attachment 2
Analysis of Public Health Assessments and Health Consultations at
Sites with SAA Agreements
-------
FY10 SAA Sites with ATSDR Public Health Assessments or Health Consultations
Prepared by: Office of Superfund Remediation and Technology Innovation (OSRTI)
Contact: David Yogi, OSRTI, yogi.david@epa.gov
April 14, 2011
• In total, 29 of 65 sites with SAA agreements have either PHAs, HCs, or both
• Of these 29 sites, 14 have PHAs only, 12 have HCs only, and 3 have both
• There are 11 new sites from FY09 & FY10 (Peoples counting as one) - 5 of these do not have a PHA or HC
CERCLIS Site Name
City, State
EPA Site ID
Nature of Threat
Public Health
Assessment
(PHA)
Health
Consultation
(HC)
PHA&
HC
Region 3
68th Street Dump
Foster Wheeler Energy
Corporation/Church Road TCE
(New-FY09)
Rosedale, MD
Mountain Top, PA
MDD980918387
PAD003031788
VOCs, semi-volatile organic
compounds, PCBs, metals
TCE
Nov. 2009
HC2010
Region 4 (21 sites total, 11/21 w/PHA or HC) - 5/21 PHA only; 5/21 HC only; 1/21 PAH & HC
Admiral Home Appliances
Anniston PCB Site
Brown's Dump
Copper Basin Mining District
Coronet Industries
Ecusta Mill
Williston, SC
Anniston, AL
Jacksonville, FL
Copper Hill, TN
Plant City, FL
Pisgah Forest, NC
SCD047563614
ALD000400123
FLD980847016
TNOOO 189083 9
FLDOO 1704741
NCD003 166675
Heavy metals, mercury
PCBs
Lead, arsenic, other
inorganics, organics,
pesticides/PCBs,
dioxins/furans
Metals, acid mine drainage,
PCBs
Inorganic constituents and
organic compounds, acidic
groundwater, radionuclides
Mercury
Nov. 2006
June 2000
Jan. 2007
PHA 20 10
Draft
Oct. 2006
May 2005;
HC 20 10 Draft
2003-2005
X
-------
Gurley Pesticide Burial (New-
FY09)
Henry's Knob
Holtra Chem/Honeywell Inc.
Illinois Central Railroad Company
Johnston Yard
ITT Thompson (New-FYlO)
Jacksonville Ash
Lyman Dyeing and Finishing
National Fireworks
Nocatee Hull Creosote (New-
FYlO)
Orlando Gasification Plant
Sanford Gasification Plant (New-
FY09)
Sixty One Industrial Park
Solitron Devices, Inc.
Sprague Electric
Weyerhaeuser Plymouth Wood
Treating Plant
Selma, NC
Clover, SC
Riegelwood, NC
Memphis, TN
Madison, FL
Jacksonville, FL
Lyman, SC
Cordova, TN
Hull, FL
Orlando, FL
Sanford, FL
Memphis, TN
West Palm Beach, FL
Longwood, FL
Plymouth, NC
NCD986 172526
SCN000407376
NCD99 1278631
TND073 540783
FLD043047653
FLSFN0407002
SCD987584653
TNSFN0407047
FLD980709398
FLD984169235
FLD984169193
TND987790300
FLD032845778
FLD004072658
NCD99 1278540
Pesticides, organics,
inorganics, heavy metals,
VOCs
Metals
Mercury, PCBs
Metals, solvents, pesticides
TCE, DCE, vinyl chloride,
lead, zinc, chromium
Lead, arsenic
Dye residues, solvents,
hydraulic liquids
TCE, DCA, perchlorate
PAHs, BTEX, aluminum, iron
Organics, inorganics
Metals, VOCs, PAHs,
dioxins/dibenzofurans
Metals, pesticides, PAHs,
PCBs
Volatile organics, metals, 1-4
dioxane
TCE
Mercury
May 2000
May 2001
PHA 20 10
Draft
Sept. 2002
July 2003
Aug. 2008
(most recent)
Region 5 (34 sites total, 10/34 w/PHA or HC) - 3/34 PAH only; 5/34 HC only; 2/34 PHA & HC
Alcoa Properties
Burnham Canal- Miller
Compressing
Cedar Creek
Chemical Recovery Systems
(New-FYlO)
East St. Louis, IL
Milwaukee, WI
Cedarburg, WI
Elyria, OH
ILSFN0508010
WIN0005 10222
WID988590261
OHD057001810
Metals, cyanide
Inorganics, PAHs, asbestos
containing material, benzene,
other organics
PCBs in sediment
Toluene, TCE, PCBs,
cadmium, copper, arsenic,
PAHs
Sept. 2009
HC 20 10 Draft
-------
Dow - Tittabawassee River/
Saginaw River/Saginaw Bay
(New-FYlO)
Bay City, Carrollton,
Essexville, Freeland,
Midland, Saginaw,
Shields and
Zilwaukee, MI
MID000724724
Dioxin, PCBs
June 2004
Feb. 2008
Ellsworth Industrial Park
Downers Grove, IL
ILN000508246
TCE, PCE
Evergreen Manor Groundwater
Contamination
Winnebago, IL
ILD984836734
TCE, PCE
Dec. 1999
Mar. 2002
Ford Road Landfill (New-FY09)
Elyria, OH
OHD988590261
PAHs, PCBs, benzene, vinyl
chloride, metals, pesticides
Jan. 2002
North Shore Gas (North)
Waukegan, IL
ILD984807990
PAHs, volatiles, metals
(One agreement for both sites)
North Shore Gas (South)
Waukegan, IL
ILD984809228
Old American Zinc Plant
Fairmont City, IL
IL0000034355
Metals, pesticides
June 2003
Feb 1996
Peoples Gas Former Manufactured Chicago, IL
Gas Plant, Crawford Station (New-
FY09)
Peoples Gas Former Manufactured Chicago, IL
Gas Plant, Hawthorne Ave (New-
FY09)
Peoples Gas Former Manufactured Chicago, IL
Gas Plant, Hough Place Station
(New-FY09)
Peoples Gas Light & Coke, 22nd Chicago, IL
St. (New-FY09)
Peoples Gas Light & Coke, Chicago, IL
Division St. (New-FY09)
Peoples Gas Light & Coke, North Chicago, IL
Station (New-FY09)
Peoples Gas Light & Coke, Chicago, IL
Willow St. Station (New-FY09)
Peoples Gas Former Manufactured Chicago, IL
Gas Plant, North Shore Ave.
Station (New-FY09)
Peoples Gas Former Manufactured Chicago, IL
Gas Plant, Pitney Court (New-
FY09)
ILN000510192
ILN000510195
ILN000510190
ILD982074767
ILD982074783
ILD982074775
ILD982074759
ILN000510193
ILN000510196
Cyanide, metals, VOCs
(including TCE), PAHs,
PCBs, tar, oil, grease, metals
(11 Peoples Gas sites under
one agreement)
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Peoples Gas Former Manufactured Chicago, IL ILN000510191
Gas Plant, South Station (New-
FY09)
Peoples Gas Former Manufactured Chicago, IL ILN000510194
Gas Plant, Throop St. (New-FY09)
Peters Cartridge Factory
Solvay Coke & Gas Co.
South Dayton Dump
Town of Pines Groundwater Plume
Tremont City Barrel Fill Site
WPSC Camp Marina MGP
WPSC Green Bay MGP
WPSC Manitowoc MGP
WPSC Marinette MGP
WPSC Oshkosh MGP
WPSC Stevens Point
WPSC Two Rivers MGP
Kings Mills, OH
Milwaukee, WI
Dayton, OH
Town of Pines, IN
Tremont City, OH
Sheboygan, WI
Green Bay, WI
Manitowok, WI
Marinette, WI
Oshkosh, WI
Stevens Point, WI
Two Rivers, WI
OHD987051083
WIN000508215
OHD980611388
INN000508071
OHD980612188
WIN0005 10058
WIN000509948
WIN000509949
WIN000509952
WIN000509947
WIN000509983
WIN000509953
Metals
Metals
Lead, copper, antimony,
arsenic, barium, beryllium,
cadmium, mercury, PCBs,
organic compounds, vinyl
chloride, TCE, other VOCs
Molybdenum, boron
Metals, organics
Benzene, toluene, xylene,
PAHs, metals, cyanide
Benzene, toluene, xylene,
PAHs, metals, cyanide
(Six WPSC sites under one
agreement)
March 2006
Sept. 2008
June 2002
Jan. 2003
August 2008
Region 6
Falcon Refinery
Highway 71/72 Refinery
Ingleside, TX
Bossier City, LA
TXD086278058
LAD981054075
Tank wastes
Lead, hydrocarbons, benzene
April 2004
June 2000
Region 7
Iowa City FMGP
Iowa City, IA
IAD984591172
Benzene, PAHs
Sept. 2006
(most recent)
Region 8
Kennecott (South Zone)
Copperton, UT
UTD000826404
Lead, arsenic
Aug. 1996
Region 9
Asarco-Hayden Plant
Hayden, AZ
AZD008397127
Arsenic, lead, copper,
cadmium, chromium
Sept. 2002
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Cyprus Tohono Mine (New-FYlO)
Tohono O'odham
Nation, AZ
AZD094524097
Sulfate, uranium, perchlorate
Region 10 (2 sites total, 1/2 w/PHA or HC) - 1/2 PAH only; 0/2 HC only; 0/2 PHA & HC
Alaska Railroad /Anchorage Yard
Boeing Company Tulalip Test Site
(New-FYlO)
Anchorage, AK
Marysville/Tulalip,
WA
AKD980983241
WAD98063956
Metals, benzene, toluene,
ethyl benzene xylene, TCE
TCE, PCBs
June 1993
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