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Enforcement

PRP Search Training Videos

Searches for potentially responsible parties (PRPs) are the cornerstone of the Superfund enforcement program and of EPA’s “enforcement first” policy. PRP searches:

  • track down the parties responsible for contamination and determine their ability to conduct or pay for cleanup work at Superfund sites. 
  • are vital to EPA, states, tribes, and other federal agencies whose enforcement programs relay on this expertise.

Training Videos

The eight-part video training is intended to help you conduct thorough and accurate PRP searches. The videos cover the major steps and considerations in performing PRP searches in relation to Superfund's cleanup response process. The videos, along with accompanying resource materials, will guide you through the process of gathering information, conducting interviews, compiling data, and contacting PRPs. Quizzes are provided for several of the training sessions to help you gauge what you have learned.

Video Welcome Message and Training Evaluation Form

Message from Cyndy Mackey, Office Director, Office of Site Remediation Enforcement.

image of OSRE Office Director Cynthia L MackeyOSRE Office Director, Cynthia L. Mackey


Session 1 - Introduction to CERCLA

The video introduces the enforcement professional to the basics of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Topics covered include CERCLA’s legal foundation, important definitions, types of response actions, and CERCLA’s liability provisions.

Cover page image for session 1 video training course

  1. Executive Order 12580 - Superfund Implementation 
  2. Executive Order 13016 - Amendment to E.O. 12580 (PDF) (2 pp, 146 K, About PDF)

Session 2 - Liability Overview

The video introduces viewers to some of the defenses and exemptions to liability under CERCLA. Intended for non-legal professionals, topics covered include defining PRP and establishing liability under CERCLA. Discussion includes statutory defenses to liability, innocent landowners, bona fide prospective purchasers, EPA’s enforcement discretion, and settlement options. 

Cover page image for session 2 video training course on PRP searches


Session 3 - Gathering Information

The video discusses the many avenues available when looking for information regarding PRPs and the site property. Examines the various issues that can influence the challenges you may encounter when trying to gather information and includes a review of the type of databases that are maintained by the counties, states, EPA, and private entities, which can enhance the information gathering process.

Cover page image for session 3 video training course on PRP searches


Session 4 - Issuing Information and Site Access Request

The video discusses some of the tools used to gather information about parties and their relationship to a site.  Specifically, the CERCLA § 104(e) request for information letter and the request for physical access to a site. 

Cover page image for session 4 video training course on PRP searches

  1. Request for Access to Property (DOCx)(6 pp, 834 K) - Sample form letter to a property owner requesting access to her property for purposes of performing a preliminary assessment and site investigation (PA/SI) and to documentation concerning materials generated, treated, stored, or disposed of at the site.  
  2. Request for Information Pursuant to CERCLA § 104(e): San Fernando Valley Area 2 Superfund Site - Glenda Chromium Operable Unit (DOCx)(9 pp, 7 MB) - Sample information request letter sent to major corporation, describing site; citing and discussing EPA’s CERCLA authority to seek information; and providing instructions, definitions of CERCLA terminology, and types of information requested. 
  3. Request for Information Pursuant to CERCLA § 104(e) for Sutton Lane Plating Site, Worcester, Mass. (DOCx)(21 pp, 5 MB) - Sample information request letter sent to corporation, identifying the site, describing information sought, citing EPA’s CERCLA authority, advising of penalties for non-compliance, and providing instructions.
  4. Request for Information Pursuant to CERCLA § 104(e) Follow Up Questions for Sutton Lane Plating Site, Worcester, Mass. (DOCx)(3 pp, 771 K) - Sample follow-up information request letter requesting clarification of previous responses and submission of specified documentation.  The letter also describes the penalties for non- or unsatisfactory compliance with EPA information requests.
  • Questions Contact: Martha Bosworth (bosworth.martha@epa.gov) (Region 1)

Session 5 - Performing Title Searches

The video discusses the terminology and steps to complete a title search, and the type of documents you may find in your search. Discussion includes initial steps, beginning with the information you need to gather from your site team to going to the county offices to collect the title deeds for the site.  Also includes examples of methods to compile all the title information.

Cover page image for session 5 video training course on PRP searches

  1. Example of a General Warranty Deed (DOCx) (7 pp, 1.82 MB). Referred to as “Deed 10 23 1975” in training session 5.
  • Questions Contact: Courtney Kudla (kudla.courtney@epa.gov) (Region 6)

Session 6 - Business Entities as PRPs

The video covers business entities as PRPs under CERCLA and addresses the differences between sole proprietorships, partnerships and corporations and what that means in term of CERCLA liability. Discussion also covers what to look for in building a successor liability case.

Cover page image for session 6 video training course on PRP searches

  1. U.S. v. Best Foods (PDF) 524 U.S. 51 (1998)(20 pp, 68 K, About PDF) Exit
  • Questions Contact: Andrea Madigan (madigan.andrea@epa.gov) (Region 8)

Session 7 - Compiling PRP Data & Organizing Records

The video discusses strategies for dealing with records gathered in a PRP search. Discussion will focus on some of the types of documents that will be useful to your search, compiling data from documents, and organizing records to ensure an effective PRP search.

Cover page image for session 7 video training course on PRP searches

  1. Sample Uniform Hazardous Waste Manifest Form
  2. Information on the hazardous waste manifest system.
  • Questions Contact: Martha Bosworth (bosworth.martha@epa.gov) (Region 1)

Session 8 - PRP Search Documentation

The video explains how to compile all of the information that has been gathered during the PRP search into one report and discusses where the information may be used. Explains the time frames in which all of your research needs to be completed in order to support enforcement and cost recovery efforts.

cover page image for session 8 video training course on PRP searches

  1. Sample Enforcement Addendum (Region 3) (DOCx)(2 pp, 18 K)
  2. Enforcement First Report (Region 6) (DOCx)(3 pp, 21 K) Document is for demonstration purposes only.
  3. Sample Baseline Investigation Report (Region 10) (DOCx) (1 page, 18 K) 
  4. Sample Cost Recovery Decision Document (Region 6) (DOCx) (3 pp, 20 K) 
  5. PRP Search Documentation Summary Requirements for Decision Documents to Not Pursue Cost Recovery Where Unaddressed Past Costs are Greater Than $200,000 (3/8/2011)

We are interested in your feedback! Please complete the PRP Search Basic Training Evaluation Form (DOCx) (1 page, 26 K) to provide us feedback and request additional information for each of the sessions. You can email your completed evaluation forms to spice.nadya@epa.gov.

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