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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
14-P-0364
September 29, 2014
Why We Did This Review
The purpose of this evaluation
was to determine whether the
U.S. Environmental Protection
Agency's (EPA's) designation
of sites that have achieved the
"protective for people" and/or
"ready for anticipated use"
(RAU) performance measures
include effective controls to
ensure long-term protection to
human health and the
environment.
A primary goal of the EPA's
Office of Solid Waste and
Emergency Response
(OSWER) is to ensure that the
cleanup of contaminated sites
is protective of human health
and the environment. OSWER
developed the Cross-Program
Revitalization Measures
(CPRM) to promote and
communicate its cleanup
accomplishments and benefits
of restoring contaminated
properties to environmental and
economic vitality.
This report addresses the
following EPA goal or
cross-agency strategy:
• Cleaning up communities
and advancing sustainable
development.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
The full report is at:
www.epa.aov/oia/reports/2014/
20140929-14-P-0364.pdf
EPA Needs to Improve Its Process for Accurately
Designating Land as Clean and Protective for Reuse
What We Found
The EPA has limited controls for verifying or
testing the accuracy of CPRM information that
states and grantees provide to show sites are
protective for people and RAU. The EPA also
does not have adequate controls to verify that
these designations continue to be valid and the
sites remain protective in the long term.
The EPA's lack of controls
over designating sites as
protective and ready for reuse
calls into question the
reliability and value of the
designations for protecting
human health.
The Resource Conservation and Recovery Act Corrective Action (RCRA CA)
program does not require documentation to support the designations. The EPA
could not obtain supporting documentation for six of the 16 reuse designations
we reviewed. While the Brownfields program does receive the supporting
documentation, it does not sufficiently review the documentation to verify
accuracy. We could not verify the accuracy of the reuse designation for 10 of 32
Brownfields sites we examined. Three of these Brownfields sites were
prematurely designated as RAU. These sites had asbestos contamination
cleaned up after they were designated as RAU.
The Underground Storage Tank (UST) program has the fewest EPA controls for
accurate RAU site designations, even though UST sites represent 99 percent of
the more than 400,000 sites the EPA has designated as RAU. States submit the
number of UST RAU sites to EPA, but not names or supporting documentation.
Further, states do not provide information on whether institutional controls are
needed at the sites, but the EPA's definition of RAU indicates it is improper to
provide an RAU designation without knowing if institutional controls are needed.
Given that nearly all the EPA's RAU designations are at UST sites and that the
EPA inaccurately designated sites as RAU or failed to support some of the
Brownfields and RCRA CA designations, the reliability and value of the RAU
measure are marginal. This creates the risk that the designations may not be
sufficiently protective of human health, which is even more important when
considering some of these sites may be reused as playgrounds, schools or child
care facilities. Also, the EPA's public reports may contain unreliable information
on site conditions.
Recommendations and Agency Corrective Actions
We recommend that the OSWER Assistant Administrator improve controls over
its guidance, review and reporting of the CPRM measures. The agency agreed
with two recommendations but disagreed with the remaining three
recommendations, and resolution efforts are in progress.

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