Sunday, May 22, 2011

CERCLA's Overlooked Cleanup Program: Emergency Response and Removal - NCEE Working Paper Series | Publications | NCEE | US EPA

Abstract: Over the past five decades, the federal government has enacted laws and developed regulations to manage actual and threatened hazardous releases. This paper describes a relatively understudied component of the nation’s response capability – the Superfund Emergency Response and Removal (ERR) Program. Drawing on a new dataset of 121 recent removal actions on 88 sites in the Mid-Atlantic region, we find a great deal of diversity across sites, from the discovery and cause of contamination to the types of risks and the cleanup strategy. The program addresses traditionally studied media such as soil, water, and air contamination, as well as risks from not-yet-released contained contaminants and potential fire or explosion. One of the program’s major strengths is its ability to address this wide range of threats, even though this very heterogeneity complicates research efforts to assess its net benefits. We describe the involvement of potentially responsible parties and EPA expenditures on removal actions. Finally, we consider future challenges for research into the net benefits of the program.
Within the past 20 years the nominal budget for the Superfund program to address both removal and remedial activities has remained fairly constant, resulting in a significant decline in real dollars. The Superfund tax expired at the end of 1995. Since then, Superfund program funding has been financed primarily from General Revenue transfers to the Superfund Trust Fund. Reinstatement of the Superfund tax has been considered and rejected several times and is currently under consideration (U.S. EPA 2010f)....Expenditures on the ERR Program averaged about one-third of expenditures on the Remedial Program during the 2000s.
Funding for EPA’s Homeland Security Preparedness, Response, and Recovery Program, which builds on the ERR Program to support EPA’s capacity to respond to catastrophic incidents through activities such as OSC training and laboratory work, has averaged about $45 million since 2002, suggesting that some additional resources have helped support the expanded role of the program in responding to homeland security incidents.
At present, EPA has conducted or overseen more than 14,000 removal actions at about 7,700 sites. Threats at a majority of those sites (64 percent) were addressed with only one removal action, but complex sites can require multiple removal actions. The annual number of EPA-led removal actions increased through the 1980s, held steady during the 1990s averaging 319 per year, then decreased to an annual average of 226 during the 2000s. The number of removal actions that were not EPA-led, including those led by other federal agencies or PRPs, averaged 242 annually during the 1990s and 344 during the 2000s
Under CERCLA section 106(b)(1) any party that violates a unilateral order without cause may be subject to fines of up to $25,000 a day during the period of the violation. Such unilateral orders provide a credible threat to encourage settlement and cooperation.
The median EPA spending at a site was $338,000 (2008 dollars) while the average was much higher due to a number of outliers including the Capitol Hill Anthrax Site, which required expenditures of over $52 million. The median cost to EPA of sites with multiple removal actions was almost twice as much as those with only one action. For sites where all removal actions were PRP-led and financed, median EPA expenditures were $111,000 per site for payroll, travel, assessment, and other costs. Median costs to EPA at sites with soil and groundwater contamination and contained contaminants were higher than those with surface water or air contamination or the risk of fire or explosion.
The full paper is available free of charge at

by Robin R. Jenkins, Heather Klemick, Elizabeth Kopits and Alex L. Marten
U.S. Environmental Protection Agency (EPA) National Center for Environmental Economics (NCEE)
Working Paper Number: 2011-04;Document Date: May 18, 2011
Subject Areas: Hazardous Waste; Cross-media pollution

Keywords: hazardous waste sites; land revitalization; Superfund emergency response and removal

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