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Superfund: Problems With the Completeness and Consistency of Site Cleanup Plans

RCED-92-138 Published: May 18, 1992. Publicly Released: Jun 25, 1992.
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Highlights

Pursuant to a congressional request, GAO compared hazardous waste site cleanups managed by the Environmental Protection Agency (EPA) with those managed by potentially responsible parties (PRP) to evaluate: (1) similarities between remedies at EPA- and PRP-managed cleanups; (2) the completeness and consistency of selected cleanup plans and Records of Decisions (ROD) documenting cleanup decisions and remedies; and (3) the effectiveness of EPA Superfund Program management information systems in monitoring and evaluating cleanups.

Recommendations

Recommendations for Executive Action

Agency Affected Recommendation Status
Environmental Protection Agency To improve the consistency and completeness of ROD and ensure that ROD guidance is followed and that ROD changes are publicized and documented, the Administrator, EPA, should direct regional administrators to approve only cleanup plans that adequately specify the cleanup goals and remedy, and provide justification for cleanup goals not set.
Closed – Implemented
EPA issued new guidance for developing Records of Decision (ROD) on July 30, 1999. The new guidance requires RODs to specify cleanup goals and the remedy selected. However, despite similar requirements in EPA's prior guidance and regulations, GAO found that RODs did not always include such goals, justify the remedy chosen, or in some cases identify the eventual cleanup remedy. EPA's issuance of new guidance by itself is not fully resposive to the recommendation, because EPA headquarters still does not oversee the regions to ensure that they are following the guidance and are accountable for approving complete and consistent RODs.
Environmental Protection Agency To improve the consistency and completeness of ROD and ensure that ROD guidance is followed and that ROD changes are publicized and documented, the Administrator, EPA, should set deadlines for documenting changes to the cleanup selected in ROD.
Closed – Implemented
EPA does not believe that deadlines should be set for documenting changes to the cleanup remedies selected in the ROD. EPA believes such a requirement is unnecessary if the ROD change is fundamental, because such changes require a proposed plan that is issued for public comment and review. EPA believes that such a deadline may be needed for less significant ROD changes that do not now require a new proposed plan and public comment. EPA will emphasize in its revised ROD guidance the importance of timely notification.
Environmental Protection Agency Because of the importance cleanup remedy selection has to the Superfund Program in protecting human health and the environment, the Administrator, EPA, should establish a cleanup remedy database incorporating the key elements in the agency's ROD to allow EPA management to quickly and thoroughly analyze the EPA remedy selection process and to assist the agency in its development and implementation of the standardization of remedies to speed cleanups.
Closed – Implemented
EPA implemented its new Superfund information system--CERCLIS 3--in all headquarters and regional offices in May 1997. CERCLIS 3 includes key ROD cleanup and remedy information previously collected for the Decision Document Database previously cited as a response to this recommendation.

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Topics

Comparative analysisData integrityFederal records managementHazardous substancesInformation systemsManagement information systemsPollution controlSystems compatibilityWaste managementWaste treatmentContaminants