Types of Response Actions

Once a potential release has been discovered, the information is entered into the Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS), a computerized database used to track hazardous substance sites. After being entered into CERCLIS, each site undergoes a preliminary assessment (PA) to determine whether the site poses a potential hazard and whether further action is necessary. If the threat is immediate, a removal action may be conducted.

Removal actions are short-term cleanup actions that usually address problems only at the surface of a site. They are conducted in response to an emergency situation (e.g., to avert an explosion, to clean up a hazardous waste spill, or to stabilize a site until a permanent remedy can be found). Removal actions are limited to 12 months duration or $2 million in expenditures, although in certain cases these limits may be extended. Removals may occur at any point in time after the PA has been conducted.

Remedial actions are longer-term response actions that ultimately represent the final remedy for a site and generally are more expensive and of a longer duration than removals. This is because the remedial actions are intended to provide permanent solutions to hazardous substance threats. It is possible that both removal and remedial actions may be taken at the same site. In the event that longer-term cleanup is necessary, the site is referred to the remedial program for further investigation and assessment.

If the PA reveals that a contamination problem exists, but does not pose an immediate threat that warrants a removal, U.S. EPA will continue to study the site during a site inspection (SI). Based on data collected during the PA and the SI, U.S. EPA will evaluate the site using the hazard ranking system (HRS), a model and scoring system that determines the relative risk to public health and the environment posed by hazardous substances in groundwater, surface water, air, and soil. Only those sites with a score of 28.5 (on a scale from 0 to 100) are eligible for placement on the National Priorities List (NPL), U.S. EPA's priority hazardous substance sites for cleanup. U.S. EPA only funds remedial actions at hazardous waste sites on the NPL. As of May 2002, there are over 1200 sites either on the NPL or are proposed for inclusion. The majority of sites are placed on the NPL based on their HRS score. Under some circumstances, sites may also be placed on the NPL by the state in which the site is located or by the Agency for Toxic Substances and Disease Registry (ATSDR).

Once a site is placed on the NPL, the remedial process begins. The remedial process requires U.S. EPA to design a community involvement plan that will inform citizens of all remedial activities and provide opportunities for public comment. A remedial response has two main phases. The first phase, the remedial investigation/feasibility study (RI/FS), involves evaluating site conditions at the site, defining any problems, and comparing alternative site cleanup methods. After the remedy has been selected, the decision is documented in the record of decision (ROD). The second phase, the remedial design/remedial action (RD/RA), involves designing the chosen cleanup and beginning construction.

Following the implementation of the remedy, the state or the potentially responsible party (PRP) assumes responsibility for the operation and maintenance (O&M) of the site, which may include activities such as groundwater pump and treat, and cap maintenance. Once U.S. EPA has determined that all appropriate response actions have been taken and cleanup goals have been achieved, the site is deleted from the NPL through a formal rulemaking process.

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