oversight

Superfund: Integrated Site Assessments May Expedite Cleanups

Published by the Government Accountability Office on 1997-07-24.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                  United States General Accounting Office

GAO               Report to Congressional Requesters




July 1997
                  SUPERFUND
                  Integrated Site
                  Assessments May
                  Expedite Cleanups




GAO/RCED-97-181
                   United States
GAO                General Accounting Office
                   Washington, D.C. 20548

                   Resources, Community, and
                   Economic Development Division

                   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.


                   Integrated site assessments have the potential to expedite the Superfund
Results in Brief   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


                   1
                    Superfund: Times to Complete the Assessment and Cleanup of Hazardous Waste Sites
                   (GAO/RCED-97-20, Mar. 31, 1997).



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             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.


             After discovery, a potential hazardous waste site may proceed through one
Background   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



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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

2
 The hazardous waste problems at a site can require both remedial and removal cleanups.



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                                        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
                                        Evaluation                         Removal program                   Preremedial program
                                                                           Preliminary assessment            Preliminary assessment
                                                                           Site inspection if necessary      Site inspection
                                                                                                             Expanded site inspection if
                                                                                                             necessary
                                                                                                             Application of hazard
                                                                                                             ranking system
                                                                                                             Proposal for placement on
                                                                                                             the NPL
                                                                                                             Placement on the NPL
                                        Cleanup                                                              Remedial program
                                                                           Engineering evaluation/cost Remedial investigation
                                                                           assessment
                                                                                                             Feasibility study
                                                                           Action memorandum                 Record of decision
                                                                                                             Remedial design
                                                                           Removal action                    Remedial action




                                        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.



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                            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.


                            Pilot tests conducted by 7 of EPA’s 10 regions have shown that using
Integrated Approach         integrated site assessments can streamline Superfund cleanups. The tests
Has the Potential to        indicate that by consolidating the collection of data for evaluations within
Improve the                 and across separate EPA programs, the integrated approach eliminates
                            unnecessary sampling and inactive periods between steps in the process.
Assessment 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   From about 1991 to 1995, seven EPA regions performed nine pilot tests that
Integrated Approach Can     focused on combining various assessment steps. These tests showed that,
Expedite Assessments        compared with the traditional approach, the integrated approach can



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                                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.


Pilot Tests Indicate That       Seven of the pilot tests concluded that the integrated approach has the
Integrated Site                 potential to reduce costs. But only three of these pilot tests quantified cost
Assessments Can Reduce          savings. First, a test in Region IV, which integrated certain preremedial
                                activities with the remedial investigation at three sites, indicated savings
Costs                           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,


                                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.



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                         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          Although EPA has not comprehensively measured the impact of integrated
Integrated Assessments   site assessments on its operations, a 1997 EPA headquarters analysis
Has Generally Been       concluded that the use of certain integrated assessments was saving time.
                         According to this analysis, the assessments completed between
Positive                 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



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                          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   Regional officials told us that the use of integrated site assessments can
Improve Coordination      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



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                          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.


                          Despite the integrated approach’s potential for streamlining the Superfund
Regions’ Use of           process, EPA’s regions have not fully or consistently implemented it.
Integrated Approach       Although some regions adopted the approach as soon as EPA introduced it
Has Been Limited and      and have acquired a fair amount of experience with it, others still have
                          very limited experience. The regions have also implemented the integrated
Uneven                    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   According to EPA’s data, the regions have used the integrated approach at
Has Been Limited and      only a small portion of their sites. From fiscal year 1994 through fiscal year
Varied                    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.




                          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.



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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 assessment            78     116        312    503    148        256   281   173    310     107         2,284
Site inspection                  181     154         59    302    210        140   122    88    134      57         1,447
Preliminary assessment/site        1       32        3      15     59         6     17     3     56       4          196
inspection
Expanded site inspection           7       14        41     82    141         24    22     4     18       4          357
Site inspection/expanded site      0        1        0      1       0         5     0      0      0       0            7
inspection
Expanded site                      0        0        1      1       0         0     1      0      0       0            3
inspection/remedial
investigation
Integrated removal and            21        0        0      61    158         0     0      0     25       1          266
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.


Regions’ Efforts to                       EPA’s regions differ in the extent to which they have developed written
Develop Guidance and                      implementation procedures and made organizational changes to promote
Make Organizational                       the use of integrated site assessments. While EPA headquarters issued
                                          general written guidance on the integrated approach, it provided the
Changes Vary                              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.




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                              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 are limiting the wider, more consistent use of
Two Principal Factors         integrated site assessments. First, EPA headquarters has not followed up to
May Limit the Use of          ensure that the regions implement the integrated approach. Second,
Integrated Site               differences between the data needs and operational methods of the
                              removal and preremedial programs may make removal and preremedial
Assessments                   assessments difficult to integrate effectively.


EPA Has Not Followed Up       Although EPA introduced the integrated approach to the regions, it has not
on the Regions’               followed up to ensure successful implementation. EPA headquarters
Implementation                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



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                          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       Officials from most regions told us that historical differences between the
Programs Inhibit          preremedial and removal programs inhibit the full integration of the two
Integration               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.




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                      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.


                      Preliminary results from EPA’s regions suggest that integrated site
Conclusions           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.


                      To encourage the full, appropriate use of integrated site assessments, we
Recommendations       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




                      Page 13                                             GAO/RCED-97-181 Superfund
                      B-277186




                  •   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.


                      We provided a draft of this report to EPA for its review and comment. EPA
Agency Comments       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.

                      EPAalso provided some technical and editorial changes to the report,
                      which we incorporated where appropriate.


                      Our objectives for this assignment were to (1) determine whether
Scope and             integrated site assessments have the potential to expedite hazardous
Methodology           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’



                      Page 14                                               GAO/RCED-97-181 Superfund
B-277186




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
Page 15                                               GAO/RCED-97-181 Superfund
B-277186




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




Page 16                            GAO/RCED-97-181 Superfund
B-277186




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




Page 17                              GAO/RCED-97-181 Superfund
Contents



Letter                                                                                            1


Appendix I                                                                                       20

Comments From the
Environmental
Protection Agency
Appendix II                                                                                      22

Major Contributors to
This Report
Tables                  Table 1: Key Steps in Site Evaluation and Cleanup                         4
                        Table 2: Regions’ Use of Integrated Site Assessments, Fiscal             10
                          Years 1994-96




                        Abbreviations

                        EPA        Environmental Protection Agency
                        NPL        National Priorities List


                        Page 18                                            GAO/RCED-97-181 Superfund
Page 19   GAO/RCED-97-181 Superfund
Appendix I

Comments From the Environmental
Protection Agency




             Page 20              GAO/RCED-97-181 Superfund
Appendix I
Comments From the Environmental
Protection Agency




Page 21                           GAO/RCED-97-181 Superfund
Appendix II

Major Contributors to This Report


               James F. Donaghy, Assistant Director
               Pauline Seretakis Lichtenfeld, Evaluator-in-Charge
               Robert J. Tice, Evaluator
               Larry D. Turman, Evaluator
               Bess Eisenstadt, Communications Analyst




(160380)       Page 22                                              GAO/RCED-97-181 Superfund
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