How Do Sites Get On or Off the Superfund List?
Potential sites for cleanup under CERCLA are collected in a national database by the EPA. A preliminary assessment and possibly a site investigation are conducted by the Agency.
The preliminary assessment (PA) involves gathering historical and other available information about site conditions to evaluate whether the site poses a threat to human health and the environment and/or whether further investigation is needed. The preliminary assessment also helps identify sites that may need immediate or short-term response actions.
The site investigation (SI) tests air, water, and soil at the site to determine what hazardous substances are present and whether they are being released to the environment and are a threat to human health.
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Information about the site that is collected in the PA/SI phase helps the EPA evaluate the risks posed by the site using its Hazard Ranking System (HRS). Some of these sites may be listed by the EPA on the National Priorities List (NPL). The NPL is a list of the most serious sites identified for long-term cleanup in the United States. The NPL is intended primarily to guide the EPA in determining which sites warrant further investigation and possibly cleanup (remedy) under CERCLA.
Sites may be added to the NPL if the release of the hazardous substance at the site:
- Scores sufficiently high on the HRS;
- Has been designated by a state as its highest priority; or
- Triggers the Agency for Toxic Substances and Disease Registry to recommend people stay off the site, and the EPA determines the site poses a significant threat to the public.
Investigation and Study
Once a final decision has been made to list the disposal site on the NPL, the Agency begins the process of determining the appropriate remedy. This Record of Decision (ROD) follows the formal Remedial Investigation and Feasibility Study (RI/FS) phase. The specific remedy must:
- Adequately protect human health and the environment;
- Attain Applicable or Relevant and Appropriate Regulations (ARARs);
- Be cost effective; and
- Utilize permanent solutions, treatment technologies, or resource recovery to the maximum extent possible.
Cleanup and Deletion
After all the cleanup activity has been completed at the site and all cleanup goals have been achieved, the EPA publishes a notice of its intention to delete the site from the NPL in the Federal Register. This opens a period for public comment. If, after the formal comment period, the EPA feels that the site still qualifies for deletion, the Agency will publish a formal deletion notice in the Federal Register. A final deletion report is placed in the Information Repository for the site. Currently, the EPA reports that there are 391 sites that have been delisted from the NPL list.
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Now that OSHA fines have skyrocketed 78%, effective training is crucial to make sure managers and employees know what it takes to maintain compliance with OSHA's complex HAZWOPER standards.
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