Superfund: Integrated Site Assessments May Expedite Cleanups (Letter
Report, 07/24/97, GAO/RCED-97-181).
Pursuant to a congressional request, GAO reviewed the efficiency of the
Superfund process, focusing on: (1) whether integrated site assessments
have the potential to expedite hazardous waste cleanups, reduce their
costs, and improve coordination among various Superfund units; (2) the
Environmental Protection Agency's (EPA) implementation of this approach;
and (3) any factors that could limit the use of integrated site
assessments.
GAO noted that: (1) integrated site assessments have the potential to
expedite the Superfund process; (2) in pilot tests conducted from about
1991 to 1995 in seven EPA regions, integrated assessments made data
collection significantly more efficient, reducing the time for
processing and study by 3 months to 4 years; (3) three of the pilot
tests also quantified cost savings, which ranged from almost $3,000 to
$300,000; (4) EPA has not fully evaluated the effects of integrated
assessments on its cleanup operations, but an internal agency study
concluded that certain integrated assessments produced 20 percent time
savings; (5) in addition, according to regional officials GAO
interviewed, the integrated approach, though not suited to all sites,
can improve the Superfund process by reducing sampling, duplication of
effort, and inactive periods between steps in the process; (6) the
officials also reported that the approach promotes coordination among
EPA's cleanup units, thereby improving decisions on the selection and
timing of cleanup actions and focusing resources on the sites that pose
the greatest risks to human health and the environment; (7) despite the
potential benefits of the integrated approach, EPA's regions have not
yet fully or consistently implemented it; (8) some regions have used it
extensively, while others have very little experience with it; (9) the
regions have also varied in their implementation of the approach,
consolidating different data collection steps and reorganizing their
programs to varying degrees to improve coordination and streamline data
collection; (10) in addition, some regions have developed written
guidance on implementing integrated assessments, while others have not;
(11) two principal factors may be impeding the wider, more consistent
use of integrated site assessments; (12) EPA headquarters has not
followed through to ensure the effectiveness of the regions'
implementation of the approach; (13) for example, although the agency
developed initial implementing guidance and published summaries of the
regional pilot tests' findings, it has not systematically measured the
impact of the approach on the time and costs of Superfund cleanups or
examined differences in the regions' use of the approach to identify
best practices that could be implemented elsewhere; (14) according to
EPA headquarters officials, the agency has not had the resources to
provide more extensive oversight; and (15) the integration of site
assessments can be difficult because of varying data requirements and
operating methods among the separate Superfund units that conduct
assessments.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-97-181
TITLE: Superfund: Integrated Site Assessments May Expedite Cleanups
DATE: 07/24/97
SUBJECT: Waste disposal
Environment evaluation
Environmental policies
Hazardous substances
Cost control
Inspection
Intergovernmental relations
Federal agency reorganization
IDENTIFIER: Superfund Program
Superfund Accelerated Cleanup Model
EPA National Priorities List
EPA Preremedial Program
EPA Remedial Program
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Cover
================================================================ COVER
Report to Congressional Requesters
July 1997
SUPERFUND - INTEGRATED SITE
ASSESSMENTS MAY EXPEDITE CLEANUPS
GAO/RCED-97-181
Superfund
(160380)
Abbreviations
=============================================================== ABBREV
EPA - Environmental Protection Agency
NPL - National Priorities List
Letter
=============================================================== LETTER
B-277186
July 24, 1997
Congressional Requesters
The Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 created the Superfund program to clean up the nation's
most severely contaminated hazardous waste sites. Since the program
began, the Environmental Protection Agency (EPA) has identified
thousands of sites that need to be evaluated for possible cleanup.
As we discussed in our recent report on the duration of Superfund
cleanups,\1 these evaluations, typically conducted in several phases
over several years, have lengthened the time required to complete
cleanups.
To expedite its cleanups of hazardous waste sites, EPA introduced the
Superfund Accelerated Cleanup Model in 1992. According to EPA
headquarters officials, this model was fully assimilated into the
agency's regional structure by 1995. One component of the model, the
integrated site assessment, was designed to streamline the evaluation
of selected sites by merging assessments of their conditions and
risks. Previously, these assessments were performed separately and
often sequentially by various Superfund units in EPA's regional
offices. Through this approach, EPA expected to shorten the duration
of cleanups by years and to improve coordination among cleanup units.
Interested in the efficiency of the Superfund process, you asked us
to (1) determine whether integrated site assessments have the
potential to expedite hazardous waste cleanups, reduce their costs,
and improve coordination among various Superfund units; (2) assess
EPA's implementation of this approach; and (3) identify any factors
that could limit the use of integrated site assessments.
--------------------
\1 Superfund: Times to Complete the Assessment and Cleanup of
Hazardous Waste Sites (GAO/RCED-97-20, Mar. 31, 1997).
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
Integrated site assessments have the potential to expedite the
Superfund process. In pilot tests conducted from about 1991 to 1995
in seven EPA regions, integrated assessments made data collection
significantly more efficient, reducing the time for processing and
study by 3 months to 4 years. Three of the pilot tests also
quantified cost savings, which ranged from almost $3,000 to $300,000.
EPA has not fully evaluated the effects of integrated assessments on
its cleanup operations, but an internal agency study concluded that
certain integrated assessments produced 20 percent time savings. In
addition, according to regional officials we interviewed, the
integrated approach, though not suited to all sites, can improve the
Superfund process by reducing sampling, duplication of effort, and
inactive periods between steps in the process. The officials also
reported that the approach promotes coordination among EPA's cleanup
units, thereby improving decisions on the selection and timing of
cleanup actions and focusing resources on the sites that pose the
greatest risks to human health and the environment.
Despite the potential benefits of the integrated approach, EPA's
regions have not yet fully or consistently implemented it. Some
regions have used it extensively, while others have very little
experience with it. The regions have also varied in their
implementation of the approach, consolidating different data
collection steps and reorganizing their programs to varying degrees
to improve coordination and streamline data collection. In addition,
some regions have developed written guidance on implementing
integrated assessments, while others have not.
Two principal factors may be impeding the wider, more consistent use
of integrated site assessments. First, EPA headquarters has not
followed through to ensure the effectiveness of the regions'
implementation of the approach. For example, although the agency
developed initial implementing guidance and published summaries of
the regional pilot tests' findings, it has not systematically
measured the impact of the approach on the time and costs of
Superfund cleanups or examined differences in the regions' use of the
approach to identify best practices that could be implemented
elsewhere. According to EPA headquarters officials, the agency has
not had the resources to provide more extensive oversight. Second,
the integration of site assessments can be difficult because of
varying data requirements and operating methods among the separate
Superfund units that conduct assessments.
BACKGROUND
------------------------------------------------------------ Letter :2
After discovery, a potential hazardous waste site may proceed through
one or more of three Superfund programs. If the site may need
long-term cleanup, it goes through the preremedial program, which
evaluates and ranks sites to determine whether they should be placed
on the National Priorities List (NPL), EPA's list of sites presenting
the greatest threats to human health and the environment. After
being placed on the NPL, a site proceeds through the remedial
program, where it is further evaluated and, if necessary, cleaned up
in a process that often lasts for several years or more. Sites that
require cleanups under the remedial program typically are
contaminated by many different types of chemicals, have contamination
in more than one medium (e.g., soil, surface water, or groundwater),
and may encompass acres or even square miles. A third Superfund
program, the removal program, is used at sites with hazardous waste
problems that do not require long-term cleanup and can be addressed
with quicker, more limited actions.\2
For example, the removal program can be used to quickly dispose of
leaking hazardous waste containers at sites. In EPA's regions, each
of these programs may operate in a separate organizational unit with
separate staff. The state in which a site is located may also take
responsibility for cleaning up the site, either on its own authority
or under an agreement with EPA. When the preremedial program
determines that the risks at a site are not serious enough to warrant
placement on the NPL, the site may be referred to the state for
possible action.
The preremedial program begins with a preliminary assessment--a
limited-scope investigation that includes the collection of readily
available information about a site and a site reconnaissance. The
preliminary assessment is designed to distinguish between sites that
pose little or no threat to human health and the environment and
sites that require further investigation. If the assessment shows no
evidence of hazardous substances at the site or no likelihood of
off-site injury, the site may not proceed further in the preremedial
program. If the preliminary assessment indicates that the site may
contain hazardous substances that could threaten human health or the
environment, EPA proceeds with a site inspection--a more in-depth
examination of the site and its surroundings that may include the
sampling of soil or water to test for contamination. In some
instances, EPA may need to continue with a more detailed
investigation--an expanded site inspection--that may also involve
sampling. Using this information, EPA then applies a numerically
based scoring system to evaluate the site's potential risk to public
health and the environment. This system uses information from the
preliminary assessment, site inspection, and expanded site inspection
(if performed) to assign the site a score ranging from 0 to 100,
depending on the severity of the threat posed by the site's
contamination. A site with a score of 28.5 or higher is considered
for placement on the NPL. As of December 1996, this list included
1,210 sites, and thousands more remained to be evaluated for possible
listing.
After being listed, a site is assigned to the remedial program, which
is responsible for conducting long-term cleanups. A remedial cleanup
starts with a remedial investigation, which assesses in detail the
contamination and related environmental and health risks, and a
feasibility study, which determines and evaluates the alternatives
for cleaning up the site. After EPA selects an alternative, EPA or
the parties responsible for contaminating the site design and
implement the cleanup remedy.
In addition to, or instead of, going through the remedial program, a
site may go through the removal program.\3 This program, which is
designed to mitigate immediate threats, may use some of the same
cleanup methods as the remedial program but is typically faster
because it uses a simpler site assessment and remedy selection
process. For example, compared with the remedial program--which
selects a remedy through a multiyear analysis of a site's conditions
and cleanup alternatives (the remedial investigation/feasibility
study) and publishes the proposed remedy for public comment (in the
record of decision), the removal program performs a shorter study of
the site (the engineering evaluation/cost analysis) and explains the
selection of a particular removal action in an action memorandum.
Table 1 shows the key steps for site evaluation and cleanup in the
remedial and removal programs.
Table 1
Key Steps in Site Evaluation and Cleanup
Phase Key steps
------------------------------ --------------------------------------
Preremedial
Evaluation Removal program program
------------------------------ ------------------ ------------------
Preliminary Preliminary
assessment assessment
Site inspection if Site inspection
necessary
Expanded site
inspection if
necessary
Application of
hazard ranking
system
Proposal for
placement on the
NPL
Placement on the
NPL
======================================================================
Cleanup Remedial program
Engineering Remedial
evaluation/cost investigation
assessment
Feasibility study
Action memorandum Record of decision
Remedial design
Removal action Remedial action
----------------------------------------------------------------------
To streamline the assessment of sites, in 1992, EPA introduced the
integrated site assessment as part of a larger initiative, the
Superfund Accelerated Cleanup Model. EPA developed guidance for the
regions on integrating site assessments (1) within the preremedial
program, (2) between the preremedial and remedial programs, and (3)
between the preremedial and removal programs. For example, under the
integrated approach, the preliminary assessment and site inspection
may be combined; any of the preremedial steps may be combined with
the removal program's assessment; and the expanded site inspection
may be combined with the site inspection, remedial investigation, or
both. The object of this new approach was to collect the data needed
for two or more assessments at one time, rather than at several
different times.
EPA anticipated that, by using the integrated approach, the regions
could reduce the amount of sampling needed, avoid the rework and
delays often associated with sequential site assessments, break down
institutional barriers by bringing together officials from different
units of the Superfund program, and shorten the time from discovery
to cleanup by years. In addition, through better coordination among
different units, EPA hoped to identify early the sites that could
benefit from removal actions.
--------------------
\2 The hazardous waste problems at a site can require both remedial
and removal cleanups.
\3 EPA may perform a removal action at a site regardless of whether
it has been placed on the NPL. Under EPA's regulations, the agency
may perform a remedial action only at a site that has been placed on
the NPL.
INTEGRATED APPROACH HAS THE
POTENTIAL TO IMPROVE THE
ASSESSMENT PROCESS
------------------------------------------------------------ Letter :3
Pilot tests conducted by 7 of EPA's 10 regions have shown that using
integrated site assessments can streamline Superfund cleanups. The
tests indicate that by consolidating the collection of data for
evaluations within and across separate EPA programs, the integrated
approach eliminates unnecessary sampling and inactive periods between
steps in the process. In addition, most of the pilot tests indicate
that using integrated site assessments can reduce cleanup costs.
Apart from the results of the pilot tests, data on the results of
integrated assessments are limited. However, a 1997 EPA headquarters
analysis of some integrated assessments, as well as the experience of
several regional officials, indicates that the assessments have been
effective. Furthermore, several regional officials told us that
using the integrated approach can improve coordination between or
among programs, allowing for the more effective screening of sites.
Better screening, in turn, allows EPA to focus its limited resources
on the sites that present the greatest risks to human health and the
environment.
PILOT TESTS INDICATE THAT
INTEGRATED APPROACH CAN
EXPEDITE ASSESSMENTS
---------------------------------------------------------- Letter :3.1
From about 1991 to 1995, seven EPA regions performed nine pilot tests
that focused on combining various assessment steps. These tests
showed that, compared with the traditional approach, the integrated
approach can reduce the time required to evaluate contamination at
sites. In one of the pilot tests, a region integrated the first two
steps in the preremedial program--the preliminary assessment and site
inspection--and saved almost 2 years, on average, from the time the
tested sites were discovered through the end of the site
inspections.\4 In other pilot tests, six regions integrated the
preremedial program with the remedial investigation, reducing
processing and study time by between 3 months and 4 years. Three
more regional pilot tests combined evaluations for the removal and
preremedial programs and concluded that the approach can save time.
One of these pilot tests documented savings of between 3 and 18
months.
According to regional officials and the documentation we obtained,
these savings are due primarily to the following factors:
-- By meeting multiple sampling needs at one time early in the
process, the integrated approach can eliminate the need for
sampling later in the process. Under the traditional approach,
samples are collected at many steps, often by different
contractors. In some instances, the additional sampling is
redundant; in other instances, updated information is needed to
offset the effects of delays. When the process itself moves
faster, additional sampling may not be necessary.
-- By meeting multiple sampling needs at one time early in the
process, integrated site assessments can reduce or eliminate
delays between steps in the process. The available data suggest
that a substantial portion of the time between a site's
discovery and placement on the NPL--which can be several years
or more--elapses while the site is awaiting the next step in the
assessment process.
-- By improving coordination between the preremedial and removal
programs, integrated assessments avoid the duplication of effort
that often occurs when staff from the two programs work at the
same site.
--------------------
\4 Many of the time savings reported for the pilot tests are
estimated on the basis of assumptions about how long the tested sites
would have taken to move through the traditional assessment process.
PILOT TESTS INDICATE THAT
INTEGRATED SITE ASSESSMENTS
CAN REDUCE COSTS
---------------------------------------------------------- Letter :3.2
Seven of the pilot tests concluded that the integrated approach has
the potential to reduce costs. But only three of these pilot tests
quantified cost savings. First, a test in Region IV, which
integrated certain preremedial activities with the remedial
investigation at three sites, indicated savings ranging between
$100,000 and $300,000. Second, a test in Region V, which combined
the removal and preremedial assessments at four sites, showed average
savings of almost $3,000 per site. Third, a test in Region IX, which
integrated the preliminary assessment and site inspection at 15
sites, showed average savings of almost $8,000 per site. Another
test combined the preremedial evaluation and remedial investigation
at three sites in Region VI. This test produced estimated savings of
30 percent, even though, by moving forward sampling and other work,
it required up to twice as many resources initially. The estimate of
long-term savings assumed subsequent reductions in the time required
for remedial investigations.
EXPERIENCE WITH INTEGRATED
ASSESSMENTS HAS GENERALLY
BEEN POSITIVE
---------------------------------------------------------- Letter :3.3
Although EPA has not comprehensively measured the impact of
integrated site assessments on its operations, a 1997 EPA
headquarters analysis concluded that the use of certain integrated
assessments was saving time. According to this analysis, the
assessments completed between October 1992 and December 1996 that
combined the first two steps of the preremedial assessment process
resulted in 20 percent time savings compared with the traditional
sequential assessments that took place during the same period.
Officials in several regions indicated that their experience with the
integrated approach outside the pilot tests supported the test's
results. They said that using integrated site assessments can
significantly streamline the Superfund process and cut projects'
overall costs. However, data on these benefits were not available.
Region VI officials cited their experience at the Stoller Chemical
site in Texas as proof of the integrated approach's benefits. At
this site, the use of a comprehensive assessment integrating the
preremedial and removal assessments showed that a removal action was
necessary because 20 drums of contaminated material were found at the
site. The assessment also found that the removal action could
satisfactorily manage the contamination so that the site would not
need to be placed on the NPL, as expected. As a result, EPA stopped
the preremedial assessment and began a removal action. Under the
traditional approach, a Region VI official said, the region would
have completed the preliminary assessment and site inspection
separately and in sequence; only after completing these steps, at an
estimated cost of about $40,000, would the region have decided not to
place the site on the NPL. In addition, by improving communication
between the preremedial and removal programs, the integrated approach
may have enabled EPA to remove the 20 drums of contaminated material
sooner.
While generally supporting the use of integrated assessments, the
regional and headquarters EPA officials we interviewed agreed that
integrated assessments are not always appropriate. For example, they
said that assessments that integrate preremedial and removal steps
should take place only at sites that have both remedial and removal
characteristics--not at sites that are obvious candidates for only
one program or the other. They also noted that combining a
preliminary assessment with a site inspection would make sense only
for a site that was likely to undergo a site inspection. In
addition, EPA headquarters officials said that merging a preliminary
assessment with a site inspection for one site might delay the start
of a site inspection at another site where a preliminary assessment
had already been completed.
INTEGRATED APPROACH CAN
IMPROVE COORDINATION
---------------------------------------------------------- Letter :3.4
Regional officials told us that the use of integrated site
assessments can foster cooperation among representatives of the
preremedial, remedial, and removal programs, as well as between
federal and state officials. For example, officials in most regions
said that representatives of the various Superfund units review
common lists of potential hazardous waste sites to decide on a course
of action for each site. Under the traditional approach, each
program maintained its own list of new sites and did not share its
list with other programs. Under the integrated approach, closer
working relationships can improve the screening of sites, resulting
in their earlier assignment to the removal or remedial program or to
a state program, as appropriate. EPA can then focus its remedial
resources on the worst sites and try to expedite cleanup actions.
For example, Region V and its states used the integrated approach to
jointly screen the region's backlog of sites that were awaiting
evaluation. As a result of the cooperative effort, the region was
able to eliminate from its backlog about 1,400 low-risk sites not
requiring EPA cleanup before investing resources in unnecessary
assessments. Similarly, Region IX is working with its states to
integrate assessment efforts. For example, the region expected to
sign an agreement with Hawaii to integrate assessments for all newly
identified hazardous waste sites in the state. In the past, the
region and the state ran parallel screening efforts, but under this
agreement, potential sites will be evaluated using criteria that
reflect both the Superfund program's and the state's requirements.
As the sites move through the assessment process, EPA officials
expect that most will be removed from consideration for the Superfund
program.
In addition, through the coordinated consideration of sites made
possible by the integrated approach, sites that could benefit from
early removal actions can be identified. At such sites, the nature
and extent of the contamination may be fairly clear, and extensive
evaluation may not be required. By assigning these sites to the
removal program, EPA can either clean them up completely without
going through the lengthier remedial program or clean them up
partially and then assign the remainder of the cleanup to the
remedial program. This strategy can not only cut the costs of
cleaning up these sites but also reduce their risks sooner.
REGIONS' USE OF INTEGRATED
APPROACH HAS BEEN LIMITED AND
UNEVEN
------------------------------------------------------------ Letter :4
Despite the integrated approach's potential for streamlining the
Superfund process, EPA's regions have not fully or consistently
implemented it. Although some regions adopted the approach as soon
as EPA introduced it and have acquired a fair amount of experience
with it, others still have very limited experience. The regions have
also implemented the integrated approach in different ways, choosing
different assessment steps to integrate. Finally, the regions vary
in the extent to which they have developed written guidance and made
organizational changes to accommodate integration.
REGIONS' IMPLEMENTATION HAS
BEEN LIMITED AND VARIED
---------------------------------------------------------- Letter :4.1
According to EPA's data, the regions have used the integrated
approach at only a small portion of their sites. From fiscal year
1994 through fiscal year 1996, the regions reported that they
combined the preliminary assessment and site inspection in 196 cases,
while the total numbers of preliminary assessments and site
inspections completed during the same period were 2,284 and 1,447,
respectively.\5 Two EPA regions (V and IX) performed almost 60
percent of these integrated assessments, while three regions (I, III,
and VIII) together performed under 4 percent of the total.
Additionally, the regions reported combining the preremedial
assessment with the removal assessment in 266 instances. Two regions
(IV and V) performed over 80 percent of these integrated assessments.
The integration of the expanded site inspection with other assessment
steps was the least frequently reported combination. Table 2
presents the numbers and types of assessments reported by each EPA
region.
Table 2
Regions' Use of Integrated Site
Assessments, Fiscal Years 1994-96
Region
----------------------------------------------------------
Assessment phase I II III IV V VI VII VIII IX X Nation
------------------- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- --------
Preliminary 78 116 312 503 148 256 281 173 310 107 2,284
assessment
Site inspection 181 154 59 302 210 140 122 88 134 57 1,447
Preliminary 1 32 3 15 59 6 17 3 56 4 196
assessment/site
inspection
Expanded site 7 14 41 82 141 24 22 4 18 4 357
inspection
Site inspection/ 0 1 0 1 0 5 0 0 0 0 7
expanded site
inspection
Expanded site 0 0 1 1 0 0 1 0 0 0 3
inspection/
remedial
investigation
Integrated removal 21 0 0 61 158 0 0 0 25 1 266
and preremedial
assessment
-----------------------------------------------------------------------------------------
EPA regional officials commented on the apparently limited use of
integrated assessments reflected in the table. According to
officials from regions VI and VIII, the data from EPA headquarters
may understate their use of integrated assessments because they often
report integrated assessments as traditional assessments, since such
reporting is simpler. However, the officials said that data on the
number of unreported integrated assessments were not readily
available. Officials from Region III said that their numbers of
integrated assessments were low because they did not have many new
sites. Specifically, they said that they seldom combined the
preliminary assessment and site inspection because they had already
started or completed traditional assessment steps at most of their
sites.
--------------------
\5 Not every preliminary assessment completed during fiscal years
1994-96 could have been combined with a site inspection. For
example, a combined study could not have been done at a site where
the preliminary assessment indicated that no further action was
necessary. Similarly, a combined study could not have been done at a
site where the preliminary assessment was started before EPA
introduced the integrated approach. Because of the limitations of
EPA's data, the exact number of sites that would have been eligible
for a combined preliminary assessment/site inspection is not known.
REGIONS' EFFORTS TO DEVELOP
GUIDANCE AND MAKE
ORGANIZATIONAL CHANGES VARY
---------------------------------------------------------- Letter :4.2
EPA's regions differ in the extent to which they have developed
written implementation procedures and made organizational changes to
promote the use of integrated site assessments. While EPA
headquarters issued general written guidance on the integrated
approach, it provided the regions with considerable flexibility to
implement integrated assessments as they saw fit. More than 4 years
after EPA introduced the integrated approach, only 4 of its 10
regions (IV, V, VII, and IX) have developed comprehensive written
guidance on their own policies for integrating assessments. Four
other regions (I, II, III, and VI) reported being in the preliminary
stages of formulating formal integration policies. Two regions (VIII
and X) had not begun drafting written policies.
The regions have also reorganized their programs to varying degrees
to promote integration. According to regional officials, three
regions merged the preremedial and removal programs, two regions put
the two programs in the same division, and one region merged its
preremedial and remedial programs. In addition, most regions have
established a "one-door" policy for screening new sites instead of
screening some sites through the removal program and others through
the remedial program. For example, in Region I, the preremedial
program will screen all new sites, and in Region V, the removal
program is responsible for this task. This consolidated approach
will enable the regions to establish a single list of sites needing
assessment instead of maintaining separate lists of remedial and
removal sites. The approach should also facilitate proper action
earlier in the program.
TWO PRINCIPAL FACTORS MAY LIMIT
THE USE OF INTEGRATED SITE
ASSESSMENTS
------------------------------------------------------------ Letter :5
Two principal factors are limiting the wider, more consistent use of
integrated site assessments. First, EPA headquarters has not
followed up to ensure that the regions implement the integrated
approach. Second, differences between the data needs and operational
methods of the removal and preremedial programs may make removal and
preremedial assessments difficult to integrate effectively.
EPA HAS NOT FOLLOWED UP ON
THE REGIONS' IMPLEMENTATION
---------------------------------------------------------- Letter :5.1
Although EPA introduced the integrated approach to the regions, it
has not followed up to ensure successful implementation. EPA
headquarters organized a number of conferences on the Superfund
Accelerated Cleanup Model and published several documents that
described regional pilot tests of the model and summarized the tests'
results. However, EPA has not taken steps such as the following to
foster the use of integrated assessments or to evaluate the regions'
implementation:
-- EPA has not determined whether the regions are using integrated
assessments effectively or could use them more extensively.
Also, the agency has not established goals for the regions' use
of these assessments. In addition, beyond developing limited
information through pilot tests, the agency has not formally
studied the impact these assessments may have had on the length
and costs of Superfund cleanups.
-- EPA has not investigated differences in the regions' use of
integrated assessments. For example, it has not formally
evaluated why different types of assessments (e.g., preliminary
assessments, site inspections, expanded site inspections, or
removal assessments) have been merged in different regions. In
addition, some regions have eliminated the regional decision
team, a tool that EPA introduced in its guidance to ensure
better coordination between the removal and remedial programs.
By examining such regional differences, EPA might identify best
practices that could be implemented elsewhere.
-- EPA has not updated its training to promote the use of
integrated assessments and to encourage regional officials in
the preremedial, remedial, and removal programs to work
together.
A headquarters Superfund official acknowledged that even though the
regions should be able to adapt the integrated approach to their
individual needs, closer headquarters oversight and management would
probably promote wider use of the approach. He added, however, that
EPA has reduced its budget for preremedial activities in recent years
by over 50 percent as its focus has switched to other areas,
particularly to completing cleanups at sites already in the remedial
program. He further noted that a headquarters reorganization
eliminated the section responsible for monitoring preremedial
activities. Currently, according to this official, EPA headquarters
has not assigned the resources needed to adequately oversee the
regions' implementation of the integrated approach because of
competing demands by other parts of the Superfund program.
DIFFERENCES BETWEEN PROGRAMS
INHIBIT INTEGRATION
---------------------------------------------------------- Letter :5.2
Officials from most regions told us that historical differences
between the preremedial and removal programs inhibit the full
integration of the two programs' assessments. They said that
officials in the two programs are trained to respond to different
problems. As noted, removal program officials deal with sites posing
imminent threats and needing quick responses, while preremedial
program officials deal with sites requiring longer-term cleanups.
Also, the two programs time their work differently. Removal
officials visit their sites and start sampling as soon as they become
aware of contamination, while preremedial officials do not start
sampling until they have developed work plans and completed other
tasks. These differences affect the types and quality of the data
that the two programs require. Whereas the preremedial program
requires extensive data for use in applying the hazard ranking
system, the removal program has less demanding data requirements.
Because of these differences, preremedial officials may often regard
the removal program's data as inadequate and removal officials may
regard the preremedial program's data collection process as excessive
and inefficient. These conflicts, according to EPA officials, can
discourage the integration of preremedial and removal assessments.
Several regions have taken steps to address the differences between
the two programs. As mentioned, some regions have reorganized to
bring the removal and preremedial programs closer together. Regions
I and VI, for example, have set up training programs to bring
officials from the two programs together. In Region I, officials
from the preremedial program are also expected to shadow removal
program officials to obtain a better understanding of the removal
process. Region VI has established a cross-training program that
trains preremedial officials to perform removal tasks and vice versa.
In addition, several regions have developed forms for use in
performing assessments to make sure that integrated assessments meet
both programs' needs.
CONCLUSIONS
------------------------------------------------------------ Letter :6
Preliminary results from EPA's regions suggest that integrated site
assessments have the potential to streamline and expedite Superfund
cleanups and reduce costs. However, the regions' implementation has,
overall, been limited and uneven, and EPA headquarters has not done
enough to guide, assess, and follow up on the efforts that the
regions have made. Additional experience with the approach is
needed, and additional data are required to demonstrate the impact of
the approach on the Superfund process. Furthermore, because EPA has
not satisfactorily followed up on the regions' implementation of
integrated site assessments, the regions may not be able to take
advantage of "best practices." Specifically, the regions with limited
experience may be missing out on valuable lessons that other regions
with more experience have already translated into comprehensive
guidance on the integrated approach.
RECOMMENDATIONS
------------------------------------------------------------ Letter :7
To encourage the full, appropriate use of integrated site
assessments, we recommend that the Administrator, EPA, evaluate the
regions' implementation of the integrated approach to determine why
some regions have made little use of it and how its use has affected
the time and costs of the Superfund process. If the assessment shows
that the integrated approach has improved the Superfund process, then
the Administrator should
-- consider establishing goals for the wider use of integrated
assessments;
-- identify best practices in regional offices and share them with
all of the regions so that the other regions can incorporate the
best practices in their own guidance and policies; and
-- provide regional officials with updated training on the
integrated approach to ensure its effective use and to improve
coordination among regional officials in various programs.
AGENCY COMMENTS
------------------------------------------------------------ Letter :8
We provided a draft of this report to EPA for its review and comment.
EPA provided written comments, which are reproduced in appendix I.
Overall, EPA observed that this report has the potential to provide
useful information for managing the Superfund program. EPA said that
it strongly supported the use of integrated site assessments as a
means of making the Superfund program more efficient. However, EPA
said that over the past several years, the agency has been unable to
invest resources for its headquarters office to oversee the regions'
implementation of the integrated approach because it has focused on
sites that were ready for cleanup work and on new initiatives
involving state cleanup programs. EPA said that it intended to
increase its oversight resources to better determine what is needed
in this area.
In addition, EPA thought that the statistics from its Superfund
database that we presented in our report may understate the number of
instances in which integrated assessments have been used. EPA
indicated that as many as 9 of its 10 regions use integrated
assessments. As we noted in our report, officials in two regions
said that EPA's Superfund database may understate their use of this
approach. However, these regions could not readily provide data on
any additional use. In addition, we supplemented our analysis of
information from the database with interviews of officials in all 10
regions. In these discussions, officials in several regions said
that their regions have had very limited experience with integrated
assessments.
EPA also provided some technical and editorial changes to the report,
which we incorporated where appropriate.
SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :9
Our objectives for this assignment were to (1) determine whether
integrated site assessments have the potential to expedite hazardous
waste cleanups, reduce their costs, and improve cleanup decisions;
(2) assess EPA's implementation of this approach; and (3) identify
any factors that could limit the use of integrated site assessments.
To determine the potential benefits of the integrated approach, we
reviewed EPA's original guidance on and documentation of the regions'
pilot tests of the Superfund Accelerated Cleanup Model. We then
talked to officials in all 10 EPA regions to obtain more information
on the results of the pilot tests and on the regions' experiences
with integrated assessments beyond the pilot tests. We also examined
sites where integrated assessments had been used and discussed with
regional and headquarters officials the limitations on their use. In
addition, we obtained an analysis from an EPA official of the time
savings achieved by combining certain steps of the preremedial
process.
To assess the regions' implementation of the integrated approach, we
obtained Superfund data from EPA headquarters and analyzed
information on the regions' use of both integrated and traditional
assessments at nonfederal sites. We also contacted officials in all
10 EPA regions to obtain their views on the regions' use of
integrated assessments. We visited four EPA regions (III, IV, V, and
IX) to obtain detailed information on their use of the integrated
approach and on differences in their use of it. In addition, we
obtained and analyzed documents on integrated assessments from EPA
headquarters and the regions.
To identify barriers to using integrated assessments more often or
more effectively, we interviewed officials in all 10 EPA regions and
studied documentation on the pilot tests. We also interviewed EPA
headquarters officials in the Office of Emergency and Remedial
Response.
We conducted our review in accordance with generally accepted
government auditing standards from January through August 1997.
As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 30 days after the date of this letter. At that time, we will
send copies of the report to other congressional committees; the
Administrator, EPA; the Director, Office of Management and Budget;
and other interested parties. We will also make copies available to
others upon request.
Should you need further information, please call me at (202)
512-9692. Major contributors to this report are listed in appendix
II.
Lawrence J. Dyckman
Associate Director, Environmental
Protection Issues
List of Requesters
The Honorable John H. Chafee
Chairman
Committee on Environment and
Public Works
United States Senate
The Honorable Robert C. Smith
Chairman
Subcommittee on Superfund, Waste
Control, and Risk Assessment
Committee on Environment and
Public Works
United States Senate
The Honorable Christopher Bond
Chairman
Subcommittee on VA, HUD, and
Independent Agencies
Committee on Appropriations
United States Senate
The Honorable Tom Bliley
Chairman
Committee on Commerce
House of Representatives
The Honorable Michael G. Oxley
Chairman
Subcommittee on Finance and
Hazardous Materials
Committee on Commerce
House of Representatives
The Honorable Dan Burton
Chairman
Committee on Government Reform
and Oversight
House of Representatives
The Honorable David McIntosh
Chairman
Subcommittee on National Economic
Growth, Natural Resources, and
Regulatory Affairs
Committee on Government Reform
and Oversight
House of Representatives
The Honorable Bud Shuster
Chairman
Committee on Transportation
and Infrastructure
House of Representatives
The Honorable Sherwood L. Boehlert
Chairman
Subcommittee on Water Resources
and Environment
Committee on Transportation and
Infrastructure
House of Representatives
The Honorable Jerry Lewis
Chairman
Subcommittee on VA, HUD, and
Independent Agencies
Committee on Appropriations
House of Representatives
(See figure in printed edition.)Appendix I
COMMENTS FROM THE ENVIRONMENTAL
PROTECTION AGENCY
============================================================== Letter
(See figure in printed edition.)
MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II
James F. Donaghy, Assistant Director
Pauline Seretakis Lichtenfeld, Evaluator-in-Charge
Robert J. Tice, Evaluator
Larry D. Turman, Evaluator
Bess Eisenstadt, Communications Analyst
*** End of document. ***