|
The
Comprehensive Environmental Response, Compensation and Liabilities Act
(CERCLA) provides for the creation of a National Priorities List (NPL)
of sites that pose the greatest threat to people or the environment. A
special fund ("Superfund") was developed for rapid cleanup
of sites placed on the list. |
The
Superfund process involves the separate stages of Remedial Investigation,
Feasibility Study, Record of Decision, Remedial Design and actual cleanup. The
Remedial Investigation is a data collecting stage for determining amounts and
types of chemical constituents of concern. Feasibility Studies
(FS) use Remedial Investigation (RI) data to determine which of the
available treatments is best suited for a cleanup operation. The Record of
Decision (ROD) is the legal agreement between the EPA and the Responsible Party
stating the cleanup goals. The Remedial Design is a data collection and planning
stage for the actual cleanup.
During
the Remedial Investigation the site is mapped to find all toxic chemicals.
Chemicals of Concern (COC's) are examined for their sources and methods of
movement. The impact of the site on the environment is determined, along with
influences of the environment on the site. The site's effects on groundwater are
monitored, as are surface and airborne erosion. The RI is meant to be a
quantitative study with all possible controls taken to ensure the study's
validity.
|
While oversight responsibility falls to the
Environmental Protection Agency many other government agencies are
involved. For instance, the Agency for Toxic Substance and Disease
Registry (ATSDR) regulates human exposure; the U.S. Fish and Wildlife
Service is involved when endangered species or protected habitat are
threatened; and the National Oceanic and Atmospheric Agency (NOAA)
must comment on waterborne threats. State and local regulations also
must be observed. Cleanup options can be dropped due to permitting
problems that limit feasibility. |
The
Feasibility Study uses the RI data to formulate cleanup options. This places a
high demand on the quality of the data collected. Poorly conducted studies can
bias the choice for remediation leading to an unsafe cleanup, or a cleanup that
is too costly. During the FS several different cleanup options are distilled
down to a single choice. In addition to the RI data the EPA uses input from
engineering firms, manufacturers of cleanup technologies, and EPA SITE
(technology evaluation) reports. The criteria for feasibility include:
 |
Overall
protection of human health, |
|
Compliance
with all laws, |
|
Cost, |
|
Implementability, |
|
Short
and long term effectiveness, |
|
Reduction
of toxicity, mobility and volume, and |
|
State
and community acceptance |
The
feasibility choice is inevitably a compromise between these conflicting
criteria. However, cleanups always serve the first criteria-- overall protection
of human health and the environment.
Page 5