Superfund: Times to Complete Site Listing and Cleanup (Testimony,
02/04/98, GAO/T-RCED-98-74).
GAO discussed two of its recent reports on the pace of cleanup in the
Superfund program, focusing on the: (1) time taken to evaluate hazardous
waste sites for possible placement on the National Priorities List (NPL)
and the time to clean them up after the listing; and (2) status of
cleanup for sites listed from 1986 to 1994.
GAO noted that: (1) GAO's March 1997 report stated that the
Environmental Protection Agency (EPA) took an average of 9.4
years--calculated from the date of each site's discovery--to evaluate
and process the nonfederal sites it added to the NPL in 1996; (2) this
evaluation and processing time was generally longer than for prior
years; (3) the 1986 Superfund Amendments and Reauthorization Act (SARA)
requires EPA to evaluate nonfederal sites for listing, when warranted,
within 4 years of their discovery; (4) listing decisions were made
within 4 years of their discovery for 43 percent of the 8,931 nonfederal
sites discovered in 1987 through 1991--the last year for which an
analysis could be done at the time of GAO's review; (5) a number of
factors contributed to the increased time to list a site, including a
backlog of sites awaiting evaluation and a reduction in the annual
number of sites being added to the NPL; (6) GAO's March report also
stated that cleanup times have also lengthened for completed projects;
(7) nonfederal cleanup projects completed in 1986 through 1989 were
finished, on average, 3.9 years after the sites were placed on the NPL;
(8) by 1996, however, nonfederal cleanup completions averaged 10.6
years; (9) although SARA did not set deadlines for completing cleanups
within a certain number of years, EPA set an expectation for 1993 for
its regions to complete a cleanup within 5 years of a site's listing;
(10) much of the time to complete cleanups is attributable to the early
planning phases of the cleanup process when the decision is made on the
selection of cleanup remedies; (11) actual construction work at sites is
being done quicker than the selection of cleanup remedies; (12) EPA
officials attributed the increased completion times for cleanups to the
growing complexity of sites, efforts to reach settlements with parties
responsible for site contamination, and resource constraints; (13) GAO's
September report stated that because a large portion--87 percent--of the
sites listed on the NPL in fiscal years 1986 through 1994 were still in
the Superfund cleanup process as of July 1, 1997, the average cleanup
time for this group of listed sites will exceed 8 years, possibly by a
substantial margin; (14) EPA stated that the methodology used in GAO's
March 1997 report was biased in favor of showing increasing completion
times and that the report was inconsistent with GAO's earlier Superfund
reports; (15) it claimed to have recently speeded up the Superfund
process; and (16) GAO believes that its March 1997 report fairly
portrays trends in the program and is consistent with its earlier
reports.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: T-RCED-98-74
TITLE: Superfund: Times to Complete Site Listing and Cleanup
DATE: 02/04/98
SUBJECT: Hazardous substances
Site selection
Waste disposal
Environmental monitoring
Environmental policies
Environment evaluation
Pollution control
Environmental law
IDENTIFIER: EPA National Priorities List
Superfund Program
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Cover
================================================================ COVER
Before the Subcommittee on Finance and Hazardous Materials, Committee
on Commerce, House of Representatives
For Release
on Delivery
Expected at
10:30 a.m. EST
Wednesday
February 4, 1998
SUPERFUND - TIMES TO COMPLETE SITE
LISTING AND CLEANUP
Statement of Peter F. Guerrero, Director,
Environmental Protection Issues,
Resources, Community, and Economic
Development Division
GAO/T-RCED-98-74
GAO/RCED-98-74T
(160428)
Abbreviations
=============================================================== ABBREV
EPA - Environmental Protection Agency
SARA - Superfund Amendments and Reauthorization Act of 1986
CERCLA - Comprehensive Environmental Response, Compensation, and
Liability Act
CERCLIS - Comprehensive Environmental Response, Compensation, and
Liability
Information System
NPL - National Priorities List
RI/FS - remedial investigation and feasibility study
============================================================ Chapter 0
Mr. Chairman and Members of the Committee:
Thank you for the opportunity to discuss two recent GAO reports on
the pace of cleanup in the Superfund program. The first of these is
our March 1997 report, which discusses the time taken to evaluate
hazardous waste sites for possible placement on the National
Priorities List (NPL)--the Superfund program's list of the nation's
worst hazardous waste sites--and the time to clean them up after the
listing.\1 The second report is our September 1997 report on the
status of cleanup for sites listed from 1986 to 1994. The pace of
Superfund cleanups has been a long-standing concern of the Congress
and the Environmental Protection Agency (EPA).\2 In the 1986
Superfund Amendments and Reauthorization Act (SARA), the Congress set
time goals for EPA to (1) evaluate sites for placement, when
warranted, on the NPL and (2) begin various cleanup actions. EPA has
also established targets for processing Superfund sites for budget
and planning purposes. I would like to outline the findings of these
reports and briefly respond to EPA's comments on our March report.
In summary,
-- Our March 1997 report said that EPA took an average of 9.4
years--calculated from the date of each site's discovery\3 --to
evaluate and process the nonfederal sites it added to the NPL in
1996.\4 This evaluation and processing time was generally longer
than for prior years. For example, listing took an average of
5.8 years after discovery for the nonfederal sites added to the
NPL in 1986 through 1990. SARA requires EPA to evaluate
nonfederal sites for listing, when warranted, within 4 years of
their discovery. Listing decisions were made within 4 years of
discovery for 43 percent of the 8,931 nonfederal sites
discovered in 1987 through 1991--the last year for which an
analysis could be done at the time of our review. A number of
factors contributed to the increased time to list a site,
including a backlog of sites awaiting evaluation and a reduction
in the annual number of sites being added to the NPL.
-- Our March report also said that cleanup times have also
lengthened for completed projects. Nonfederal cleanup projects
completed in 1986 through 1989 were finished, on average, 3.9
years after the sites were placed on the NPL. By 1996, however,
nonfederal cleanup completions averaged 10.6 years. Although
SARA did not set deadlines for completing cleanups within a
certain number of years, EPA set an expectation for 1993 for its
regions to complete a cleanup within 5 years of a site's
listing. Ten percent of the cleanup projects at nonfederal
sites listed in 1986 through 1990 were finished within 5 years
of the site's listing. Much of the time to complete cleanups is
attributable to the early planning phases of the cleanup process
when the decision is made on the selection of a cleanup remedy.
Actual construction work at sites is being done quicker than the
selection of cleanup remedies. EPA officials attributed the
increased completion times for cleanups to the growing
complexity of sites, efforts to reach settlements with parties
responsible for site contamination, and resource constraints.
-- Our September report said that because a large portion--87
percent--of the sites listed on the NPL in fiscal years 1986
through 1994\5
were still in the Superfund cleanup process as of July 1, 1997, the
average cleanup time for this group of listed sites will exceed 8
years, possibly by a substantial margin. EPA has estimated that
recently listed sites will be cleaned up within an average of 8
years.
-- EPA said that the methodology used in our March 1997 report was
biased in favor of showing increasing completion times and that
the report is inconsistent with our earlier Superfund reports.
It claimed to have recently speeded up the Superfund process.
We believe that our March 1997 report fairly portrays trends in
the program and is consistent with our earlier reports. In its
comments to us, EPA did not adequately support its claim of
faster processing times.
--------------------
\1 Superfund: Times to Complete the Assessment and Cleanup of
Hazardous Waste Sites (GAO/RCED-97-20, Mar. 31, 1997).
\2 Superfund: Duration of the Cleanup Process at Hazardous Waste
Sites on the National Priorities List (GAO/RCED-97-238R, Sept. 24,
1997).
\3 In this statement, the date of "site discovery" is the date that a
site is entered into EPA's Superfund database.
\4 This statement focuses on nonfederal sites, since they make up
almost 90 percent of all Superfund sites. However, our March 1997
report presented cleanup times for both federal and nonfederal sites.
\5 We chose fiscal years 1986 through 1994 for our analysis because
the last major legislative changes were made to the program in fiscal
year 1986 and because few cleanups would have been completed for the
sites listed after 1994.
BACKGROUND
---------------------------------------------------------- Chapter 0:1
In 1980, the Congress passed the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), commonly known as
Superfund, to clean up highly contaminated hazardous waste sites.
The act gave EPA the authority to clean up the sites and to compel
the parties responsible for the contamination to perform or pay for
the cleanups. As of September 30, 1997, there were 1,353 sites on
the NPL, and another 52 had been proposed for listing; 159 of the
currently listed sites are federal sites. As of the end of fiscal
year 1997, EPA had begun constructing cleanup remedies at 477 sites.
It has completed constructing cleanup remedies at 504 sites. EPA's
goal is to complete the construction of remedies at 650 sites by the
end of the year 2000, assuming level funding.
Cleanup actions fall into two broad categories: removal actions and
remedial actions. Removal actions are usually short-term actions
designed to stabilize or clean up a hazardous site that poses an
immediate threat to human health or the environment. Remedial
actions are usually longer-term and more costly actions aimed at a
permanent remedy. The sites that are referred to EPA for Superfund
consideration are screened in a number of evaluations leading to a
decision on whether to list the site on the NPL. Once listed, the
sites are further studied for risks, and cleanup remedies are chosen,
designed, and constructed. (See app. I for a more detailed
description of the steps to place a site on the NPL and the time
taken to accomplish those steps. See app. II for a similar
discussion of the steps to clean up a site.)
The Superfund Amendments and Reauthorization Act of 1986 (SARA)
provided that facilities discovered after the act was passed should
be evaluated for placement on the NPL within 4 years of the site's
discovery if EPA determines on the basis of a site inspection or
preliminary assessment that such an evaluation is warranted. In
1992, EPA developed techniques to speed up the evaluation and cleanup
of sites. These techniques included the expanded use of removal
actions and the merging of certain site evaluations. EPA
pilot-tested these techniques in 1992 and declared them operational
in 1994. In 1995, EPA initiated its final round of administrative
reforms, intended to make the program faster and achieve other
improvements. In planning its Superfund activities in 1993, EPA set
an expectation that sites would be cleaned up within 5 years from
listing. More recently however, EPA has estimated that newly listed
sites will be cleaned up within 8 years.
For our reviews, we asked EPA to provide us with data on the length
of time taken (l) to evaluate sites for possible placement on the NPL
and (2) to complete cleanups of listed sites. The source of the data
was EPA's Comprehensive Environmental Response, Compensation, and
Liability Information System (CERCLIS), which is the official
repository of Superfund data. To measure the time taken to evaluate
sites for listing, we identified sites that were added to the NPL
each year and calculated the time between their listing and their
"discovery," i.e., their entry into CERCLIS. To measure the time for
the cleanup process following listing, we identified the "operable
units"\6 at which remedial actions had been completed each year and
calculated the time between the end of the remedial action and the
date the site was added to the NPL. We also measured the time it had
taken operable units to complete various phases of the Superfund
process. For example, we calculated how long it took for cleanup
remedies to be selected and designed.
--------------------
\6 EPA may divide a site into two or more "operable units"
corresponding to different physical areas at a site or different
environmental media (such as soil or groundwater) to be cleaned up.
Nonfederal Superfund sites have an average of 1.8 operable units.
SITES HAVE TAKEN LONGER TO BE
LISTED ON THE NPL
---------------------------------------------------------- Chapter 0:2
Generally, the average time between discovering a site and placing it
on the NPL has increased over the life of the Superfund program.
(See fig. 1.)
Figure 1: Average Time From
Nonfederal Site Discovery to
Placement on the NPL
(See figure in printed
edition.)
Note: No sites were placed on the NPL in fiscal years 1988 and 1992.
Data for fiscal year 1996 exclude three sites that were added to the
NPL without undergoing the usual evaluation because they posed
imminent public health risks.
As indicated by figure 1, sites listed in fiscal year 1996 had been
discovered an average of 9.4 years earlier, down from 11.4 years in
fiscal year 1995. The average site listing time has not met SARA's
4-year goal since 1986.
Although average listing times have generally lengthened, it should
be understood that EPA can move quickly to list some sites if
circumstances warrant. For example, in 1996, it listed three sites
within 9 to 12 months after discovery when the Public Health
Service's Agency for Toxic Substances and Disease Registry issued a
public health advisory concerning the sites. EPA used an expedited
process that bypassed its normal evaluation process to list these
sites. In addition, EPA may undertake removal actions at sites to
deal with imminent threats before they are listed. However, listing
is necessary before the full range of problems presented by many
sites can be addressed under Superfund.
The increase in the time to complete site listing is primarily a
result of delays in processing sites in the end stage of the listing
process, that is, after the sites have been inspected and the final
analysis needed to evaluate their eligibility is done. (See app. I
for a description of the Superfund process for evaluating sites for
listing.) The time to complete this end stage for sites that were
listed on the NPL rose from about 2 years in fiscal year 1986 to
about 6 years in fiscal year 1996. A substantial portion of this
time is accounted for by periods in which sites were in backlogs
awaiting processing.
CLEANUP COMPLETION TIMES HAVE
LENGTHENED
---------------------------------------------------------- Chapter 0:3
For sites with completed cleanups, the average time between the
sites' placement on the NPL and the completion of the cleanup
increased in 1986 to 1996.\7 Figure 2 shows the average time between
listing a site on the NPL and the completion of cleanup at the
operable units at the site.
Figure 2: Average Time From
Placing a Nonfederal Site on
the NPL to Completion of
Cleanup at Its Operable Units
(See figure in printed
edition.)
As the figure shows, completion times for cleanups of operable units
have become progressively longer. In 1996, cleanup completions
averaged 10.6 years for nonfederal operable units. As mentioned
earlier, in 1993 EPA set an expectation for its regions to complete a
cleanup within 5 years of a site's listing. More recently, EPA said
it expected that the sites listed in fiscal years 1993 through 1996
would be cleaned up in an average of 8 years.
The increase in overall cleanup times was accompanied by a marked
increase in the time to select cleanup remedies--the study phase of
the cleanup process and the time during which attempts are made to
reach settlements with the parties responsible for site
contamination. This study phase was completed on average in about
2-1/2 years in 1986 but took an average of about 8 years in 1996.
(See app. II for data on times to complete the remedy selection and
design phases of the Superfund cleanup process.)
--------------------
\7 Cleanup completion is defined as the end of the remedial action
phase, that is, the date when, under EPA's procedures, an official
document is signed indicating that the physical construction is
complete for all remedial and removal work required at the site.
Additional time may be required for the operation of long-term
remedies. For example, the pumping and treating of groundwater to
remove contaminants can take decades.
AVERAGE CLEANUP TIMES FOR SITES
LISTED IN FISCAL YEARS 1986
THROUGH 1994 WILL EXCEED 8
YEARS
---------------------------------------------------------- Chapter 0:4
Our September 1997 report compared EPA's estimate of future cleanup
times with the program's historical performance. We calculated, for
the sites that began the cleanup process in fiscal years 1986 through
1994, (1) how long it took to clean up completed sites and (2) how
long the uncompleted sites have been in the cleanup process. We
found that, as of July 1, 1997, remedial action had been completed\8
at 13 percent (95) of the 752 sites placed on the NPL in fiscal years
1986 through 1994. These remedial actions were completed in an
average of 6.3 years after the sites were listed. As of the same
date, remedial action had not been completed at 87 percent (657) of
the sites listed in fiscal years 1986 through 1994. These
uncompleted sites had been in the cleanup process an average of 8.1
years, that is, they had been listed on the NPL an average of 8.1
years earlier. Assuming that all remedial actions at these "in
process" sites had been completed on July 1, 1997, the average
cleanup duration for all sites listed on the NPL during the 9-year
period would have been 7.9 years, almost as long as EPA's 8-year
estimate of the cleanup time for recently listed sites. But because
such a large proportion of the sites are still in process, the
average cleanup time for these sites will exceed 8 years, possibly by
a substantial margin. EPA can reach its 8-year cleanup estimate for
recently listed sites only through much faster cleanup times than
have been achieved in the past.
--------------------
\8 At all operable units.
FACTORS INFLUENCING THE SITES'
LISTING AND CLEANUP TIMES
---------------------------------------------------------- Chapter 0:5
The Superfund database, which was the primary source for the data
presented in this statement, does not contain all the information
needed to fully explain the reasons for the changes in study and
cleanup completion times over the history of the program. However,
our past reviews and discussions with EPA officials have identified
some of the factors that have lengthened listing and cleanup times.
The time from discovery to listing has increased over the years for a
number of reasons. A major factor was that the Superfund program
started with a backlog of sites awaiting evaluation.\9 In addition,
program changes caused other delays. These changes included
revisions to eligibility standards requiring the reevaluation of many
sites, the need to seek states' concurrence for site listings, and
reductions in the annual number of sites that EPA added to Superfund.
Furthermore, between 1994 through 1996, EPA's budget for assessing
sites was cut by some 50 percent and, according to EPA officials,
EPA's current priority is to finish cleaning up sites that have
already been listed. The probability of long time frames for future
site listings is indicated by the large number of sites that are
awaiting a listing decision (about 3,000) and the small number of
sites that have been admitted to the Superfund program in recent
years (an average of 16 per year in fiscal years 1992 through 1996).
EPA officials said that the upward trend in cleanup times for
completed sites might be linked to the completion of more difficult
cleanups. Our work supports this explanation. In September 1994, we
reported that EPA's data revealed longer average cleanup times for
ongoing projects than for those already completed.\10 In that report,
we said that despite EPA's efforts to expedite cleanups, cleanup
times might grow longer because of the greater complexity of these
ongoing projects. Also, EPA officials said that the effort to find
the parties responsible for contaminating sites and reach cleanup
settlements with them can increase cleanup times. They also thought
that funding had affected the pace of cleanup. For example, they
said that because of budget constraints, EPA was not able to fund
$200 million to $300 million in cleanup projects in fiscal year 1996.
In addition, EPA has shifted funding away from selecting remedies and
toward the design and construction phases of the cleanup process. As
indicated, remedy selection times have increased greatly over the
years.
--------------------
\9 Of the 40,665 sites referred to EPA for Superfund evaluation
through 1996, 14,697 had entered the program by 1982.
\10 Superfund: Status, Cost, and Timeliness of Hazardous Waste Site
Cleanups (GAO/RCED-94-256, Sept. 21, 1994).
EPA'S REACTION TO OUR FINDINGS
---------------------------------------------------------- Chapter 0:6
In responding to a draft of our March 1997 report and in a December
letter to GAO, EPA objected to our portrayal of the program's
completion times. EPA challenged the fairness of our methodology,
said that our report was inconsistent with earlier GAO reports, and
said that it had recently accelerated the cleanup process. We have
responded to these objections in our final March 1997 report and in a
letter to the Administrator of EPA.\11 We would like at this time to
reemphasize a few of the points we made in our response to EPA's
comments:
-- Our methodology accurately and fairly presents information on
various trends in the Superfund program. This methodology shows
increasing cleanup times for sites completing the Superfund
cleanup process, not because it was "programmed" to produce this
result, as EPA claimed, but because these times have, in fact,
increased.
-- Our reports and testimony over the last several years that have
discussed the slow progress of site cleanups in the Superfund
program are entirely consistent with our March 1997 report. For
example, in 1994 we reported\12 that EPA's data indicated a
trend toward longer cleanup times for projects still under way,
even though the agency had initiated several major efforts to
expedite the process. In fact, some of these "in process" sites
are now reaching the end of cleanup and are reflected in the
March 1997 report's data on recent longer cleanup completion
times.
-- The data we presented in our March 1997 report are most relevant
for judging the program's performance for those sites that have
completed the entire assessment and cleanup process or the
segments of it--such as remedy selection--that we measured. Our
work does not foreclose the possibility that process times have
recently improved. EPA claims that such improvement has
occurred, but in its comments to GAO, the agency has not
provided data to adequately support its claim.
--------------------
\11 Superfund: Response to EPA's Letter Concerning Recent GAO
Reports (GAO/RCED-98-55R, Jan. 28, 1998).
\12 Superfund: Status, Costs, and Timeliness of Hazardous Waste Site
Cleanups (GAO/RCED-94-256, Sept. 21, 1994).
OBSERVATIONS
---------------------------------------------------------- Chapter 0:7
Increasing completion times for listing and cleanup are important
because the Superfund program still has to deal with a large number
of hazardous waste sites. While EPA has made progress at many NPL
sites--completing the construction of remedies at more than 500 sites
and starting construction at close to another 500 sites--construction
has not yet been completed for most sites currently on the NPL, and
thousands of additional sites remain in EPA's inventory of
potentially hazardous waste sites. Shortening the time required for
future listings and cleanups will require (1) EPA and the states to
come to grips with the large number of sites awaiting an NPL decision
and (2) EPA to expedite the remedy selection process.
-------------------------------------------------------- Chapter 0:7.1
Mr. Chairman, this concludes my prepared statement. I will be happy
to respond to your questions or the questions of committee members.
TIME TAKEN TO ACCOMPLISH THE
PRINCIPAL STEPS IN THE PROCESS OF
PLACING SITES ON THE NPL
=========================================================== Appendix I
We examined the time taken to accomplish the principal steps in the
process of placing a site on the National Priorities List (NPL)--the
preliminary assessment, the site inspection, and the proposal to list
the site as a national priority.
STEPS IN THE PROCESS OF LISTING
A SITE
--------------------------------------------------------- Appendix I:1
The Environmental Protection Agency's (EPA) regulation implementing
the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) outlines a formal process for placing hazardous
waste sites on the NPL (see fig. I.1).
Figure I.1: How a Site Gets on
the NPL
(See figure in printed
edition.)
Source: EPA.
The listing process starts when EPA receives a report of a
potentially hazardous waste site. A state government or private
citizen most often reports a nonfederal site. EPA enters a
potentially contaminated site into a database known as the
Comprehensive Environmental Response, Compensation, and Liability
Information System (CERCLIS). EPA or the state in which the
potentially contaminated nonfederal site is located then conducts a
preliminary assessment to decide whether the site poses a potential
threat to human health and the environment.
If the site presents a serious, imminent threat, EPA may take
immediate action--called a removal action--to deal with the acute
problems. If the preliminary assessment shows that the site warrants
further study, EPA may proceed to the next step of the evaluation
process, the site inspection, which takes a more detailed look at
possible contamination. If at any point the site is found not to
pose a potential threat serious enough to warrant federal attention,
the site can be eliminated from further consideration under CERCLA.
If warranted by the results of the site inspection, EPA applies the
hazard ranking system to evaluate the site's potential risk to public
health and the environment. The hazard ranking system is a
numerically based scoring system that uses information from the
preliminary assessment and the site inspection to assign each site a
score ranging from 0 to 100. This score is used as a screening tool
to determine whether a site should be considered for further action
under CERCLA. A site with a score of 28.5 or higher is considered
for placement on the NPL. EPA first proposes a site for placement on
the NPL and then, after receiving public comments, either places it
on the NPL or removes it from further consideration. The hazardous
waste sites on the NPL represent the highest priorities for cleanup
nationwide.
PRELIMINARY ASSESSMENTS
--------------------------------------------------------- Appendix I:2
Figure I.2 shows, for nonfederal sites, the average time taken to
complete a preliminary assessment of conditions at a site following
its discovery.
Figure I.2: Average Time From
Site Discovery to Completion of
the Preliminary Assessment at
Nonfederal Sites
(See figure in printed
edition.)
Figure I.2 shows that in 1987 through 1989, EPA sharply reduced the
average time between the discovery of a site and the completion of
the preliminary assessment at nonfederal sites. EPA officials
attributed this decrease to EPA's effort to reduce the time for
completing preliminary assessments following the passage of the
Superfund Amendments and Reauthorization Act of 1986 (SARA).
After SARA's passage, EPA adopted a policy of completing a
preliminary assessment within 1 year of a site's discovery. The
preliminary assessment was completed within a year of discovery at
about two-thirds of the sites that were discovered after fiscal year
1987 and were preliminarily assessed by the end of fiscal year 1995.
The officials said that EPA's efforts to complete assessments within
1 year had reduced the backlog of sites needing assessments and
shortened the time required for the assessments. However, since
1989, the time from the discovery of a site to the completion of the
preliminary assessment has gradually increased.
SITE INSPECTIONS
--------------------------------------------------------- Appendix I:3
Figure I.3 shows, for nonfederal sites, the average time between
discovery of the site and completion of the site inspection.
Figure I.3: Average Time From
Site Discovery to Completion of
the Site Inspection at
Nonfederal Sites
(See figure in printed
edition.)
As figure I.3 shows, the average time from the discovery of the site
to the completion of the site inspection has declined in recent
years. EPA has made progress over the past 5 years in reducing the
time from discovery to completion of the site inspection for
nonfederal sites. In 1991, EPA took an average of 6.6 years to
complete the site inspection, whereas in 1996, it brought this
average down to 4.1 years. EPA officials told us that the time for
completing site inspections increased until 1991 because EPA
concentrated its resources on completing preliminary assessments
within 12 months, an effort that created a backlog of site
inspections. They said that after reducing the backlog of
preliminary assessments, EPA focused on reducing the backlog of site
inspections, bringing about the recent improvement in the time for
completing site inspections.
PROPOSING A SITE AS A NATIONAL
PRIORITY
--------------------------------------------------------- Appendix I:4
Figure I.4 shows, for nonfederal sites, the average time between
completing the site inspection and proposing to place the site on the
NPL.
Figure I.4: Average Time From
Completion of Site Inspection
to Proposal for Listing at
Nonfederal Sites
(See figure in printed
edition.)
As figure I.4 shows, the average time required to propose a site for
placement on the NPL generally increased for nonfederal sites in 1986
through 1996. For nonfederal sites proposed for listing in 1986, the
proposal took 20 months from the completion of the site inspection,
compared with 6 years in 1996.
According to EPA officials, the increases in the time required to
propose sites for listing are partly attributable to revisions in the
hazard ranking system mandated by SARA. SARA directed EPA to obtain
additional data so that the system could more accurately assess the
relative risk to human health and the environment posed by sites and
facilities nominated to the NPL. EPA officials said that the agency
decided to limit listings while it was revising the hazard ranking
system. EPA announced in April 1987 that it was considering
revisions to the system, and in December 1988 it requested comments
on proposed revisions. In December 1990, EPA promulgated final
revisions to the hazard ranking system.
EPA officials said that the revisions to the hazard ranking system
led EPA to seek additional data on 5,275 nonfederal sites in 1992
through 1996. For these sites, EPA developed a temporary
intermediate step--referred to as a site inspection
prioritization--to gather the additional information needed on the
sites' risks to human health. EPA officials also said that the time
taken to assess sites has grown because of the large backlog of sites
at the start of the Superfund program, enforcement activities, and
the need to seek a state's concurrence for listing a site. In
addition, the number of sites placed on the NPL has declined in
recent years.
DURATION OF EVALUATION STEPS
--------------------------------------------------------- Appendix I:5
We attempted to obtain data from CERCLIS showing the duration of some
of the major steps in the process of evaluating sites for placement
on the NPL: the preliminary assessment, the site inspection, and the
site inspection prioritization. However, the starting date for many
of these steps is not recorded in the database. For example, the
beginning and ending dates are available for only 27 percent (4,693
of 17,469) of the site inspections completed at nonfederal sites
through fiscal year 1995.
TIME TAKEN TO ACCOMPLISH THE
PRINCIPAL STEPS IN THE PROCESS OF
CLEANING UP SITES
========================================================== Appendix II
In addition to measuring the total time taken from the placement of a
site on the National Priorities List (NPL) to the completion of its
cleanup, we examined the time taken to complete two of the principal
intermediate steps: (1) the preparation of the record of decision,
which documents the final remedy selected after the completion of the
remedial investigation and feasibility study (RI/FS), and (2) the
preparation of the remedial design, which includes the technical
drawings and specifications for the selected remedy. We also
obtained data on the duration of the RI/FS, the remedial design, and
the remedial action.
STEPS IN THE PROCESS OF
CLEANING UP A SITE
-------------------------------------------------------- Appendix II:1
The Environmental Protection Agency's (EPA) regulation implementing
the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) outlines the remedial process for cleaning up
sites on the NPL (see fig. II.1).
Figure II.1: How Sites Are
Cleaned Up
(See figure in printed
edition.)
Source: EPA.
The remedial responses to an NPL site consist of several phases. If
a site is divided into discrete cleanup projects, known as operable
units, each of the operable units may pass through these phases.
First, through the RI/FS, the conditions at a site are studied,
problems are identified, and alternative methods to clean up the site
are evaluated. Then, a final remedy is selected, and the decision is
documented in a record of decision. Next, during an engineering
phase called the remedial design, technical drawings and
specifications are developed for the selected remedy. Finally, in
the remedial action phase, a cleanup contractor begins constructing
the remedy according to the remedial design. Once EPA, in
consultation with the state in which the site is located, determines
that the work at a site has achieved all of the desired cleanup
goals, the site can be removed (deleted) from the NPL.
SELECTING A REMEDY
-------------------------------------------------------- Appendix II:2
Figure II.2 shows, the average time taken from the placement of a
nonfederal site on the NPL to the selection of a remedy for cleanup
of its operable units.
Figure II.2: Average Time From
Placing a Nonfederal Site on
the NPL to Selecting a Remedy
for the Site's Operable Units
(See figure in printed
edition.)
Figure II.2 shows that the average time taken to select a remedy at
nonfederal sites has steadily increased over the years. In 1986,
selecting a remedy after a site was listed took an average of 2.6
years, compared with an average of 8.1 years in 1996.
The cleanup phase that ends with the selection of a remedy comprises
two periods: the time between listing and the start of the RI/FS and
the time for the RI/FS. Both of these periods add significantly to
the total time taken to complete cleanups. For nonfederal sites at
which RI/FSs were begun from 1991 through 1996, an average of 4.5
years had elapsed since the sites were proposed for listing. For the
nonfederal sites at which RI/FSs were completed in 1995 (the last
year for which complete data were available), the RI/FS took an
average of 4.4 years to complete, or about 2 years more than in 1986.
DESIGNING A REMEDY
-------------------------------------------------------- Appendix II:3
Figure II.3 shows the average time taken to develop the remedial
design--the technical drawings and specifications for the selected
remedy--for nonfederal operable units. The elapsed time is measured
from the date of a nonfederal site's placement on the NPL.
Figure II.3: Average Time From
Placing a Nonfederal Site on
the NPL to Developing a
Remedial Design for the Site's
Operable Units
(See figure in printed
edition.)
DURATION OF CLEANUP STEPS
-------------------------------------------------------- Appendix II:4
EPA's records indicate that the actual time taken recently to
complete the latter phases of the cleanup process--the remedial
design and the remedial action--is less than one-half of the total
time taken, from listing, to complete recent remedial actions.
Nonfederal remedial designs took 2.3 years to complete in 1996, up
from 1.6 years in 1991. Nonfederal remedial actions took about 2
years in 1996, essentially as long as they took in 1991.
*** End of document. ***