Site
Types
Work
Group
Update
NACEPT
Superfund
Subcommittee
Meeting
January
7,
2003
Work
Group
Objectives
Consider
options
for
the
future
role
of
the
NPL
given
the
number
and
types
of
cleanup
sites
that
may
be
expected
in
the
future.
For
example:

 
What
types
of
sites
belong
on
the
NPL?

 
What
criteria
should
be
used
to
list
them
considering
the
universe
of
sites
that
need
attention?

 
Who
should
be
involved
in
the
listing
process.
Core
Questions
The
following
questions
relevant
to
mega
sites
are
identified
in
the
Subcommittee's
Charge
and
were
discussed
at
the
Subcommittee's
September
23­
24,
2002
meeting.

1.
Should
costs
be
the
determining
factor
when
designating
sites
as
mega
sites
or
should
other
factors
such
as
complexity
or
geographic
size
be
considered?

2.
What
are
the
reasonable
policy
options
for
addressing
mega
sites?
Are
there
viable
alternatives
to
placing
mega
sites
on
the
NPL
and/
or
ways
of
containing
their
costs?
Core
Questions
(
cont'd)

3.
What
are
the
unique
aspects
of
mega
sites
that
might
require
a
different
decision
making
process
for
NPL
listing?

a.
Large
geographical
distribution
(
e.
g.
river
basins)

b.
Slow
rate
of
progress
c.
Risk
management
challenges
d.
Factors
specifically
relevant
to
Federal
Facilities
e.
Recalcitrant
or
non­
existent
PRP's
f.
No
significant
differences
other
than
cost
g.
Mix
of
public
health
and
ecological
impacts
but
the
ecological
impact
is
the
primary
driver.
Overlapping
Questions
with
the
Cleanup
Program
Work
Group
°
How
do
we
prioritize
sites
if
we
can't
do
everything
on
the
NPL?

°
What
about
"
smaller"
sites
 
sites
with
less
contamination
and
with
PRP'sthat
have
less
money
than
mega
sites?
How
can
other
programs
help?

°
How
do
we
do
more
with
what
we
have
(
resources,

efficiency)?
Information
Considered
In
working
toward
its
objectives,
the
work
group
considered
the
following
information:

°
Current
NPL
Universe:
characteristics/
numbers
of
sites
(
size,
complexity
­
various
indices,
cost,
origin)

°
Future
NPL
Universe
(
consider
what
is
coming
through
the
"
pipeline")

°
Explore
"
mega
site"
definitional
issues
and
the
number
and
types
of
sites
that
may
become
mega
site
cleanups.

°
Key
questions
in
the
charge/
work
plan
relating
to
Mega
sites
and
NPL.
ASSUMPTIONS
In
order
to
frame
its
discussion
of
policy
alternatives,
the
work
group
developed
several
assumptions:

1.
Timeframe
assumption:
The
group
agreed
to
consider
a
10­
year
time
frame.

2.
Funding
Assumptions:
Two
general
assumptions
were
considered
regarding
funding.
In
response
to
the
request
from
the
Agency,
one
scenario
will
be
to
assume
level
funding.
A
second
scenario
will
be
to
assume
that
funding
is
not
limited
to
the
current
($
1.3
billion)
funding
(
greater
than
level
funding).

3.
Program
Operations
Assumptions:
To
what
extent
should
the
group
consider
administrative
and
operational
functions?
Site
Type
Issues
and
Corresponding
Policy
Options
The
work
group
is
in
the
process
of
exploring
policy
options
to
address
the
"
NPL
listing"
and
"
Mega
Site"
issues
related
to
site
types.

°
Issues
were
identified
by
individuals
and
were
discussed
at
the
November
20thwork
group
meeting.

°
Preliminary
discussions
resulted
in
the
generation
of
policy
options
to
address
those
issues.

°
The
options
considered
to
date
do
not
necessarily
reflect
all
of
the
options
that
can
be
considered,
nor
do
they
reflect
the
consensus
of
the
work
group.
Categories
of
Issues
Considered
°
NPL
Listing
Issues
°
Mega
Site
Issues
°
NPL
Site
Management
Issues
NPL
Listing
Issues
Base
Issues:

Any
site
presenting
imminent
and
substantial
endangerment
should
be
addressed.

Do
we
agree
that
the
NPL
should
be
an
option
of
last
resort?

Policy
Options
were
identified
within
the
following
categories:

A.
Can
the
NPL
listing/
screening
process
be
modified
so
that
Superfund
resources
can
be
more
effectively
applied?
NPL
Listing
Issues
(
Cont'd)

°
Policy
Options
(
cont'd):

°
B.
Does
the
HRS
process
prevent
the
listing
of
high­
risk
sites
because
of
factors
relating
to
the
density
of
populations
at
risk
and
if
so,
should
the
process
be
altered
to
address
this
situation?

°
C.
Does
the
requirement
of
Governors'concurrence
prevent
the
listing
of
high­
risk
sites
that
should
be
on
the
NPL
and,
if
so,

how
can
such
sites
be
funded
in
the
absence
of
state
matching
funds?

°
D.
Are
there
pro­
active
options
for
limiting
the
number
of
sites
coming
into
the
NPL
pipeline
(
both
internal
and
external
to
the
Superfund
Program)?
Conversely,
should
the
NPL
be
expanded
and
bolstered
to
add
more
sites?
Mega
Site
Issues
Can
any
categorical
sites
be
managed
in
such
a
way
so
that
funds
can
be
allocated
better
to
non­
mega
sites
that
pose
a
greater
risk?

1.
Status
Quo
Option
2.
Create
a
"
list
within
the
NPL
list"
for
categorical
sites
(
such
as
mining
or
sediment
sites)
within
the
NPL.

3.
Remove
these
categorical
sites
from
the
NPL
and
transfer
them
to
alternate/
existing
programs.

4.
Alter
the
NPL
listing
process
to
limit
listing
of
these
sites.

5.
Create
a
new/
different
program(
s)
to
address
this
set
of
sites.
NPL
Site
Management
Issues
Can
the
management
of
sites
that
have
been
added
to
the
NPL
be
modified
so
that
Superfund
resources
can
be
more
effectively
applied?

°
Expand
the
Superfund
Removal
Program
°
Evaluate
the
funding
prioritization
(
What
are
the
impacts
of
spending
80%
of
the
funds
on
20
%
of
the
sites?)

°
Evaluate
Presumptive
Remedies,
Analysis
of
Legal
Costs,
Other
Reforms
°
Increase
Emphasis
on
Enforcement
and
Cost
Recovery
at
both
the
state
and
federal
level
°
Increase
Efficiencies
in
the
Program
Information
Still
Needed
A
matrix
has
been
developed
to
track
the
status
of
the
information
requests
relevant
to
the
Site
Types
Work
Group.

 
NPL
related
information
requests
 
Mega
site
related
information
requests
