Determining EPA Superfund Sites
On September 18, 2012, U.S. EPA added twelve new “Superfund” sites to the National Priority List (NPL) and proposed eight further additions.
The NPL is a list of U.S. sites affected by “uncontrolled hazardous substance releases…that are priorities for long-term remedial action and response” [40 CFR 300.5, emphasis added]
There is a multi-step process for EPA to add sites to the NPL. Before this process even begins, the first question that usually must be asked is whether an “immediate response” is needed to a spill or release. Once EPA determines that the site needs longer-term care, the following steps are taken:
- Preliminary Assessment (PA) and Site Inspection (SI): The site is inspected and subjected to a thorough preliminary assessment. Pathways of exposure, exposure targets, and the source and nature of the release are all investigated. Samples are taken and analyzed.
- Hazard Ranking System (HRS): Based on the results of the PA and SI, sites are classified in terms of the HRS. Due to limited Superfund Trust Fund resources, EPA focuses on the worst problems at the worst sites first. However, a site scoring high on the HRS does not necessarily mean immediate commencement of remedial work; current remediation work is not halted at one site just because a new site scores higher on the HRS.
- Remedial Investigation (RI) and Feasibility Study (FS): A Remedial Investigation is conducted to determine the appropriate clean-up alternatives for the site that would be protective of human health and the environment. This might include project scoping, data collection, risk assessment, treatability studies, and assessment of alternatives. The FS is conducted at the same time, to analyze the remedial actions themselves in light of technical, public health, institutional, economic and environmental considerations.
- Remedial Action Plan (RAP) and Record of Decision (ROD): A RAP is developed based on the results of the RI and FS and is documented in an ROD. The purpose of the ROD is to support the decision to implement the RAP by documenting factors such as the degree of protection to human health and cost-effectiveness.
- Remediation Once the RAP is developed, it is implemented and a number of technologies are implemented to clean up the site. Less pressing aspects of the RAP will not get immediate attention. Remediation can take years to complete.
- Deletion from the NPL: Once all activities and levels of treatment identified in the RAP have been completed and the site is determined to pose no further threat to human health and the environment along all pathways of exposure, a close-out report is submitted to U.S. EPA and the site is removed from the NPL. Once the site is removed from the list, a Final Deletion Notice is published in the Federal Register.
- Site Reuse/Redevelopment: US EPA’s goal is to make Superfund sites usable again. To this end, the Agency have set up an entire section on its website aimed at explaining how they partner with state and local organizations to ensure future use of a cleaned-up site is consistent with the remedy in place.
Including the September 18 additions, the NPL now includes 1313 sites across the U.S. The oldest Superfund sites in the nation have been on the NPL since 1983.
Are there any Superfund sites near you? The EPA maintains a complete list of NPL sites on its Web site here.
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