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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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.

GAO found that: (1) EPA believed that PRP-managed cleanups used waste treatment, rather than containment, methods in about the same percentage of cleanups as in EPA-managed cleanups; (2) analysis of ROD for fiscal years 1987 through 1990 showed that PRP contained waste in 43 percent of cleanups, while EPA contained waste in about 25 percent of its cleanups, regardless of site characteristics; (3) ROD based on PRP-conducted site studies consistently included more waste containment techniques than did ROD based on EPA-conducted site studies; (4) ROD frequently lacked key information detailing cleanup plan objectives, proposed cleanup levels, and selected cleanup remedies and cleanup goals that were specified in ROD varied considerably; (5) ROD frequently did not adequately explain and justify remedy selection and approval and did not always specify the selected remedy; (6) EPA regional offices do not consistently follow EPA guidance on documenting changes to ROD; (7) EPA has begun initiatives to decrease variations in cleanup goals, improve the consistency of risk assessments, develop new ROD guidance, and implement ROD quality reviews; (8) EPA has several information systems containing some Superfund cleanup data, but the systems are not automated and no one system contains all of the information needed for EPA to monitor trends or analyze ROD; and (9) EPA information systems also contain inaccurate, incomplete, and unreliable data.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: 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.

    Recommendation: 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.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: 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.

    Recommendation: 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.

    Agency Affected: Environmental Protection Agency

  3. Status: Closed - Implemented

    Comments: 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.

    Recommendation: 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.

    Agency Affected: Environmental Protection Agency


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