The Universe of Potential Contaminated Sites|
The Limits of the Superfund Program
RCRA Corrective Action Sites
State Cleanup Programs
THE UNIVERSE OF POTENTIAL CONTAMINATED SITES IN THE U.S.
The Superfund program only addresses a small fraction of the contaminated sites in the United States. Indeed, there is no comprehensive list of how many sites are contaminated, much less an analysis of the degree of contamination at various locations. In 1985 and 1987, the Government Accounting Office (GAO) issued two reports which estimated the universe of potential toxic waste sites in the United States to be in the range of 130,000 to 425,000 sites. In 1985, the Office of Technology Assessment (OTA) took a broader and more pessimistic view, estimating that there are more than 600,000 active or former waste disposal facilities in the U.S. that could pose threats to health and the environment. OTA estimated that perhaps as many as 10,000 of these would require federal attention to clean up. In addition, the National Research Council (NRC) has reported that as of September 1990, there were 17,482 contaminated sites at 1,855 Department of Defense military installations and 3,700 sites at 500 Department of Energy facilities.
There are a wide variety of types of contaminated sites, including:
- Current and former factories, mines, smelters, power plants, and other production facilities that use toxic materials or generate toxic waste
- Current and former landfills and other facilities that dispose of, treat, or store of toxic industrial waste and/or municipal garbage
- Current and former military and nuclear-weapons facilities
- Current and former above-ground tanks and underground tanks for petroleum and toxic chemicals
- Current and former transportation pipelines for petroleum and toxic chemicals
THE LIMITS OF THE SUPERFUND PROGRAM
Although Superfund's legal authorities extend to most types of sites and contaminants (with the notable exception of petroleum products, which are statutorily excluded), long-term cleanups under Superfund are conducted only at sites that have been placed on the National Priorities List (NPL). To determine which sites to list, EPA uses the Hazard Ranking System. However, sites that rank above the cutoff score for NPL listing are not automatically added; rather, EPA generally awaits concurrence of the state's Governor before adding a site. Where the Governor does not concur, there is no specific mechanism for assuring that the site is addressed on a timely basis, either by Superfund or by a state program. For these and other non-NPL sites, the Federal government's role is typically nonexistent, although sometimes it undertakes short-term emergency removal activities.
EPA's national reporting system on potentially contaminated sites, CERCLIS, currently contains information on 40,000 sites. Fewer than 1,300 are now listed on the NPL, with at most about 40 sites expected to be added annually. Many sites that are entered into CERCLIS await NPL decisions for many years. In 1998, the Government Accounting Office (GAO) found that of the 1,789 sites potentially eligible for the NPL and awaiting decisions, 30% had already contaminated drinking water sources, another 56% could contaminate drinking water sources in the future, and 73% had been in EPA's inventory for over a decade. GAO also surveyed state and federal officials to determine their views on which of these 1,789 sites were likely to be added to Superfund, which need additional cleanup, and whether they pose a current risk to health or the environment. Finally, some sites are not brought to EPA's attention, and thus never enter CERCLIS.
RCRA CORRECTIVE ACTION SITES
Although Superfund is the best-known federal program for addressing contaminated sites, another program currently covers a larger number of sites: namely, the Correction Action program for hazardous waste facilities under the Resource Conservation and Recovery Act (RCRA). The RCRA program only addresses sites that have permits to treat, store, or dispose of wastes that are regulated as "hazardous" waste under RCRA; other wastes can also be toxic, but not now regulated as hazardous waste.
There are 3,700 RCRA Corrective Action sites; under RCRA Cleanup Reforms launched in 1999, EPA is focusing on 1,712 of these sites because of the potential for unacceptable exposure to pollutants and/or for groundwater contamination. Some RCRA sites are as contaminated as Superfund sites, while others are significantly less so. (EPA generally addresses sites that are eligible for cleanup under both Superfund and RCRA Corrective Action under the latter.)
STATE CLEANUP PROGRAMS
Sites not addressed by Superfund and RCRA are the responsibility of the states. State cleanup programs vary significantly. Most states have a state Superfund program. Some states also have "voluntary cleanup" programs that address other contaminated sites (sometimes termed "brownfields"), though these vary in scope and quality. There are no comprehensive databases on state voluntary cleanup programs.