*. U.S. Environmental Protection Agency	10-P-0133
f	\ Office of Inspector General	June 2 2010

\ w °
At a Glance
Why We Did This Review
Prior studies have identified
weaknesses in the Superfund
5-year review process. We
evaluated how the U.S.
Environmental Protection
Agency (EPA) identifies and
monitors issues and
recommendations in Reviews
conducted at federal facility
Superfund sites. We also
examined how EPA achieves
compliance with unimplemented
recommendations and
nonconcurrence issues.
Background
EPA's Superfund 5-year review
is a required process that
examines the clean-up remedies
at Superfund sites where
hazardous substances remain at
levels that may pose unacceptable
risks. The Reviews are required
every 5 years. They determine
whether remedies adequately
protect human health and the
environment. Federal facility
Superfund sites (e.g., military
sites) complete their own
Reviews and submit them to
EPA. EPA is required to report
to Congress on these Reviews.
For further information, contact
our Office of Congressional,
Public Affairs and Management at
(202) 566-2391.
To view the full report,
click on the following link:
www.epa.qov/oiq/reports/2010/
20100602-10-P-0133.pdf.
Catalyst for Improving the Environment\
EPA Should Improve Its Oversight of
Federal Agency Superfund Reviews
What We Found
EPA does not have effective management controls to monitor the completion of
Review recommendations at federal government Superfund sites. For Reviews
signed since 2006, 84 percent of Review recommendations were overdue as of
April 28, 2009. EPA regional staff do not consistently follow Superfund 5-year
review process guidance and policies for updating the status of Review issues
and recommendations in the Comprehensive Environmental Response,
Compensation, and Liability Information System (CERCLIS). Overdue or
unimplemented recommendations to improve underperforming or
nonperforming clean-up remedies may increase the risk to human health and
the environment.
Federal facilities are responsible for their own Reviews, and EPA states in a
letter its concurrence or nonconcurrence with these Reviews. However, EPA's
management of the concurrence process has resulted in some Reviews being
conducted more than 5 years apart and some issues not being addressed. EPA
has no management controls or policy for communicating, following up on, or
resolving issues it does not agree with or it believes need improvement.
Enforcement options are not clearly documented in EPA guidance or policy
statements, and are not consistently understood or followed by staff.
We also identified data quality problems. Discrepancies in the presentation of
issues and recommendations exist between the Reviews and CERCLIS, some
data in CERCLIS are logically inconsistent, and recommendations from prior
Reviews are not always closed out.
What We Recommend
We recommend that EPA implement improved management controls to
monitor the completion of federal facility Review recommendations, ensure
Reviews are submitted every 5 years, improve the management of the
nonconcurrence process, clarify and describe enforcement options to achieve
completion of recommendations, and improve data quality. EPA initially
agreed with all recommendations, except for recommendation 3-1. After
additional discussions, EPA agreed with all recommendations and proposed
actions to address them. All recommendations are open with agreed-to actions
pending. In its final response to this report, EPA should provide estimated or
actual completion dates for all recommendations.

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