Faster Cleanup at Lower Costs: A Streamlined Superfund
Quick, economical cleanup of hazardous wastes decreases risks to people and the environment, stimulates the economy, and minimizes the stigma contamination can bring to properties and communities.
In pursuit of this "win-win" situation, EPA has made unprecedented, deliberative efforts over the past five years to streamline the Superfund cleanup process.
Successes have been achieved in three key areas:
- Addressing immediate threats through early cleanup actions;
- Increasing the pace of long-term cleanups; and
- Providing protective cleanups at lower costs.
Addressing Immediate Threats Through Early Cleanup Actions
Fires, explosions, contaminated drinking water, and toxic fumes are just some of the time-critical situations the Superfund program regularly confronts. Regional and headquarters technical teams are on call 24 hours a day to respond to hazardous waste emergencies. Calls may come in from Superfund inspection efforts, state and local agencies, the public, or other Federal personnel, including EPA employees.
The strength of Superfund's early action program lies in its ability to mobilize expertise and resources to respond to immediate, critical, hazardous substance threats. Upon notification or site discovery, EPA specialists are on the scene within hours, addressing immediate threats to human lives and the environment. Superfund's early action program prevents many deaths and injuries every year by forestalling fires, explosions, or toxic vapor clouds. Early actions often prevent acute contamination from developing into the need for long-term cleanups.
The Superfund early action program is characterized by close cooperation among Federal, state, and local government agencies and between government and industry. Usually EPA takes the lead on cleanup, but often encourages responsible parties to shoulder the effort. Of the 4,400 removal actions completed at 3,400 sites since Superfund's inception, 3,100 have been EPA-led, another 970 have been led by responsible parties monitored by EPA or the U.S. Coast Guard, and the rest have been managed by the U.S. Coast Guard (responsible for discharges or releases into coastal water), or by state and other Federal agencies. In FY 97 alone, 252 early actions were begun.
Superfund's early action activities have been a key contributor to the program's overall success. These actions reduce acute health threats, curtail environmental damage, return land to beneficial use, protect property values, and safeguard drinking water. Typical Superfund early actions include:
- Sampling contaminated materials and the surrounding soil, air, and water;
- Installing security measures;
- Disposing of contaminated containers and debris;
- Excavating and disposing of contaminated soil, wastes, and debris;
- Pumping contaminated liquids from overflowing lagoons;
- Draining or skimming off contaminants;
- Controlling detonation of explosions or ordnance;
- Applying alternative treatment technologies;
- Restoring the site;
- Relocating threatened individuals or finding them temporary shelter;
- Providing alternate water supplies; and
- Installing decontamination devices.
When appropriate, EPA considers early cleanup options that recycle or treat hazardous substances. Cleanup technologies that reduce the toxicity, mobility, or volume of wastes are used with, or as alternatives to, land disposal. In all cases, early cleanup actions contribute to the efficient performance of any subsequent long-term cleanup actions that are needed.
When EPA Arrived...
... further explosions were imminent. The lab contained several hundred pounds of shock- and heat-sensitive explosives, including hundreds of nitroglycerin vials. All laid 100 feet from an apartment complex, restaurant, and shopping mall.
|Radium Leasing Firm
...flamable liquids, corrosives, poisons, and oxidizers were piled in with leaking casings containing radioactive needles. A fire at the warehouse could have spread over a 5 mile radius and affected thousands of people.
|Abandoned Waste Handling Facility
...explosives, poisons, corrosives, oxidizers, reactives, asbestos, biologicals, pesticides, and radionuclides were stored in the midst of a densely populated neighborhood. Immediate fires and explosions threatened.
Increasing the Pace of Long-Term Cleanups
In FY 92, EPA set a goal of achieving 395 toxic waste site cleanups (called construction completions) by the end of FY 96. In October 1996, the EPA Administrator announced that the Agency had exceeded its goal by completing the 410th cleanup. By the end of FY 97, 498 NPL sites had completed cleanup construction and 477 more were under construction.
What is a Construction Completion Site?
|A Construction Completion Site is a former hazardous waste area where physical construction of all cleanup remedies is complete, all immediate threats have been addressed, and all long-term threats are under control.|
EPA has set a record pace for cleaning up Superfund sites — more sites have been cleaned up in the past 5 years than were completed in the previous 12 years. Through its concerted efforts, EPA has accelerated the pace of cleanup by more than 20% since the inception of the program. Furthermore, the average duration of long-term cleanups has been reduced by more than a year. Superfund reforms are the reason.
INCREASING THE PACE
CLEANING UP AT LOWER COSTS
Since 1992, EPA has introduced the Superfund Accelerated Cleanup Model (SACM) and three rounds of Administrative Reforms, consisting of more than 60 initiatives. Initiatives targeted to increase the pace of cleanup include:
- SACM, which streamlines and integrates Superfund activities, enabling earlier decision-making;
- Presumptive Remedy Guidance, which applies experience gained from similar sites to develop cleanup approaches with wide-spread utility; and
- Soil Screening Guidance, which sets contamination thresholds below which Federal cleanup actions are no longer necessary.
EPA has accelerated the pace of cleanup by more than 20% since the inception of the program.
As a result of these Superfund reforms, the program is saving time and money and moving faster than ever to clean up hazardous waste sites in communities all around the country.
The Framework for a Faster Superfund: SACM
Introduced in April 1992, SACM dramatically streamlined Superfund site characterization and cleanup. SACM: (1) combined overlapping assessment activities; (2) established Regional Decision Teams to prioritize remedial response activities; (3) enabled early actions to address immediate risks while simultaneously assessing long-term cleanup needs; (4) defined presumptive remedies; and (5) encouraged earlier initiation of enforcement activities.
Successes soon followed:
- Early actions quickly reduced risks and sped the pace of cleanup;
- Streamlined site assessments and remedial investigation/feasibility studies (RI/FS) saved time and money; and
- New technologies reduced contaminants at a faster pace.
In addition, several regions integrated the traditionally
distinct cultures of "immediate" and "long-term" cleanup. These
regions rotated personnel and developed new operating procedures. These changes maximized
resources and created more efficient assessment and cleanup programs consistent with SACM.
The Kearsarge Metallurgical site demonstrates SACM's effectiveness. Successes like this have made SACM the new "way of doing business" at Superfund sites over the last five years. SACM has substantially accelerated the movement of sites through the construction pipeline.
Measuring the Progress of Site Cleanup
SACM SAVES TIME AND MONEY AT KEARSARGE METALLURGICAL SITE
Description: The Kearsarge Metallurgical Superfund site in New Hampshire contained waste piles, contaminated catch basins, and a leach field. Contamination was detected in the upper aquifer underlying the site, a potential drinking water source.
Action: EPA Region 1 implemented a SACM pilot, undertaking simultaneous early and long-term actions. Cleanup of the waste pile, catch basins, and leach field moved directly to construction, minimizing remedial design activities. Long-term cleanup of the aquifer was accelerated as a result of freed-up resources.
Experience to Work: Presumptive Remedies
As Superfund worked through thousands of cleanups, similarities in site types and remedies gradually revealed themselves. Some types of sites have similar chemicals and characteristics, therefore standard remedies (called "presumptive") can be applied. Presumptive remedies are based on historical patterns of remedy selection and EPA's scientific and engineering evaluation of performance data on technology implementation. EPA put this concept into action over the past five years, conducting pilot studies to evaluate its benefits and developing guidance for its application. EPA now expects presumptive remedies to be used when appropriate.
Presumptive remedies reduce the technology evaluation phase by helping site managers focus data collection efforts during site investigations. EPA developed presumptive remedy guidance for four kinds of sites: (1) municipal landfills; (2) sites with volatile organic compounds in the soil; (3) wood treater sites; and (4) contaminated groundwater sites. Presumptive remedies save a substantial amount of time and money. For municipal landfill sites alone, presumptive remedies have cut cleanup durations by 36% to 56%, and costs by up to 60%. The pilot at the BFI/Rockingham site provides one example of such savings.
EPA also developed a groundwater presumptive response strategy, including an approach to addressing one of Superfund's most difficult cleanup issues: dense nonaqueous phase liquids (DNAPLs) in groundwater. Presumptive remedy guidance is in progress for a number of additional categories of sites and contaminant conditions. In an independent evaluation of the use of presumptive remedies, the EPA's Office of Inspector General stated that the use of "presumptive remedies is expected to create greater consistency, certainty, and quality of remedy decisions in the near term. Time and cost savings are expected to increase over time..."
Focusing the Process Early: Soil Screening Guidance
In May 1996, EPA issued final soil screening guidance that enhances the current Superfund investigation process. Established screening levels are compared to data obtained at the early stages of the remedial investigation. No further Federal attention will be required for those exposure pathways, chemicals of potential concern, or contaminated areas where concentrations in soil fall below the established screening thresholds.
This guidance helps site managers and technical experts limit the scope of field investigations and risk assessment early in the process. Such actions save time and resources without compromising environmental integrity.
STREAMLINE ASSESSMENT AT
Description: EPA initiated a pilot
project to determine the effectiveness of applying a presumptive remedy to municipal
landfill wastes. Among the sites evaluated during the pilot project was the BFI/Rockingham
municipal landfill site in Vermont.
Action: Studies at BFI/Rockingham clearly indicated a risk to groundwater existed. EPA applied a presumptive remedy (a cap along with leachate and gas collection system) and, as a result, was able to avoid spending time and resources conducting extensive investigations to characterize the waste at the site.
Cleaning Up at Lower Costs
Faster cleanups and targeted Administrative Reforms have resulted in significant progress in reducing cleanup costs over the past five years. In the last four fiscal years, the average cost of cleanup construction has dropped by an average of $3.9 million per project, or more than 20%. In FY 97 alone, nearly $400 million in future cleanup costs will be saved through the review of high-cost cleanup decisions and updates of past remedy decisions to reflect new science and technology. These successes resulted from Administrative Reforms involving:
- Cleanup decisions at complex, high-cost sites;
- Remedy decision updates;
- Risk-based priority setting;
- Innovative cleanup technologies; and
- Guidance on risk assessment, land use, and remedy selection.
Targeting these areas has reduced cleanup costs, while assuring long-term protection of human health and the environment. Key reforms are summarized and highlighted in the following section; they reflect the importance EPA places on creating a more efficient and cost-effective Superfund program.
National Remedy Review Board
EPA created the National Remedy Review Board (NRRB) to assess proposed high-cost cleanup decisions at Superfund sites. The purpose of the board is to assure that these cleanup decisions are consistent with Superfund law, regulations, and guidance. The Board is composed of both headquarters and regional technical experts, who bring a cross-regional management-level perspective to its review.
By January 1998, the group reviewed a total of 23 site decisions. Overall, Board recommendations may have reduced total estimated cleanup costs by more than $37 million. Its reviews have contributed to a more cost effective, consistent Superfund program, improved the quality of several high-cost cleanup decisions, and contributed to human health and environmental protection.
Remedy Decision Updates
Recognizing advances in the science and technology of Superfund site cleanup, EPA encourages updates to remedy decisions made in the early years of the Superfund program. Recent guidance focuses on three areas:
- Changes in cleanup technologies, where a new technology would be more cost-effective;
- Modifications of remedial objectives based on new understanding of the physical limitations of cleanup technologies; and
- Modification of monitoring programs, where appropriate.
Remedy updates during FY 97 resulted in total estimated future cost savings of more than $360 million at over 60 sites. Of these, over $270 million was saved due to Reform guidance. (In FY 96 and FY 97 combined, approximately $597 million in estimated savings resulted from Reform guidance).
REMEDY UPDATE REDUCES
CLEANUP COSTS AT
Description: Originally, pump-and-treat
technology was selected as the approach to cleaning up groundwater contamination at the
Western Processing site in Washington. Costs for groundwater cleanup were estimated at
Action: The original remedy was modified to reflect new information gained during remedy implementation. The existing containment barrier was extended, the pumping system was automated, and an Explanation of Significant Differences (ESD) was signed to implement the changes.
Results: Costs of the modified remedy are estimated to be $118 million, resulting in an $82 million reduction in costs.
Risk-Based Priority Setting
The National Risk-Based Priority Panel surveys sites and ranks them for cleanup on the basis of "worst problems first." The Panel, established in August 1995, evaluates proposed cleanup actions for risks to humans and the environment; stability and characteristics of contaminants; and economic, social, and program management considerations. Except for emergencies and the most critical removal actions, cleanup projects are funded in rank order. By early 1997, the Panel had set priorities for nearly $1 billion worth of projects. Previously, regions ranked cleanup projects and funded them on a first-come, first-served basis.
in Innovative Technologies
EPA has taken advantage of its unique position as a Government regulator to intervene in the market for cleanup technologies and promote technological progress. Technological innovation continues to be one of the keys to higher productivity in Superfund cleanups, as it can provide more cleanup for the money. While the market for remediation technologies is large, many responsible parties are unwilling to try new cleanup approaches. Thus, it has been difficult for innovative technologies to break into this market.
EPA is helping to lower these barriers to technological progress by "underwriting" the use of certain promising technologies for appropriate projects, and expanding indemnification coverage to prime and innovative technology contractors.
Risk Assessment, Land Use, and Remedy Selection
EPA enhanced Superfund cleanup decisions and reduced costs by providing guidance in the areas of risk assessment, land use, and the role of cost in remedy selection.
Guidance on Risk Assessments
These national criteria for the regions ensure risk assessments that are well scoped, well designed, standardized, and easy to review. Consistent, reasonable risk assessments mean cost-effective cleanup actions.
EPA also initiated a dialogue within and outside of the Agency to update parts of the 1989 Risk Assessment Guidance for Superfund. Areas targeted for improvement include exposure assessment, human health toxicity assessment, risk characterization, ecological damage assessment, risk management decision making, and risk communication. Changes will improve the technical quality and application of Superfund risk assessments, standardize certain aspects of the risk assessment process, and develop reasonable default exposure assumptions for land uses and activities. These improvements will further assure risk assessments are consistent, reasonable, and reduce cleanup costs.
Directive on Land Use in Remedy Selection
A May 1995 EPA directive is improving Superfund cleanup decisions by requiring more consistent application of reasonable land use assumptions. The directive emphasized that, for certain sites, it may be appropriate to assume a future land use other than residential. Such assumptions result in more targeted risk assessments and less expensive remedies. EPA is maximizing the cost-saving potential of this guidance by working with local land use planning authorities, other local government officials, and communities as early in the site investigation process as possible to determine how the land will be used once it is cleaned up.
Guidance on the Role of Cost in Remedy Selection
EPA developed guidance to clarify the role of cost in the Superfund program as established in existing law, regulation, and policy. The guidance provides stakeholders with a better understanding of the role of cost as a key criterion in remedy selection. This emphasis will help ensure that cleanup decisions consider cost on a more consistent basis.
In addition to these initiatives, EPA made progress in reducing the cost of Superfund cleanups by reforming the way it administers the Superfund liability program through enforcement. These reforms encourage parties to settle rather than litigate, substantially reducing transaction costs. Enforcement initiatives are discussed in the next section.
HOW SUPERFUND REDUCED CLEANUP COSTS
National risk-based priority setting: EPA
established a National Risk Based Priority Panel to evaluate and rank sites for funding
according to the principle of "worst problems first" to ensure available funds
are allocated efficiently.
Risk assessment, land use, and remedy selection guidance: EPA initiated risk assessment reforms and provided guidance on land use and remedy selection to assure cleanup decisions are based on consistent and reasonable information and, as a result, are cost effective.
National Remedy Review Board: EPA created the National Remedy Review Board to review cleanup decisions at complex, high-cost sites to help control remedy costs and to promote cost-effective decisions.
Remedy decision updates: EPA developed remedy reform guidance to encourage appropriate, dynamic changes to past cleanup decisions in response to advances in remediation science and technology, resulting in substantial remedy cost reductions.
Innovative technologies: EPA encouraged the use of potentially cost-effective innovative technologies by "underwriting" certain promising technologies, and extending indemnification coverage to innovative technology contractors to get more cleanup for the money.
This report is divided into 5 sections:
- Superfund: Taking on the Nation's Hazardous Waste Challenge
- Faster Cleanup at Lower Costs: A Streamlined Superfund
- Superfund Enforcement: Success in Enhancing Fairness and Expediting Settlements
- We're in This Together: Better Decisions Through Continuous Community Involvement
- Success in Forging Partnerships