EP 1110-1-19
30 Jun 01
CHAPTER 2
BACKGROUND
2-1.
Superfund Process.
a.
General
Lead Agencies
(1)
Section 105 of CERCLA, as
amended by SARA, requires the U.S.
At or prior to the time a site is placed on the
Environmental Protection Agency (EPA) to
NPL, a determination of the lead agency is made.
The lead agency, represented by a remedial
maintain the NPL, which is a record of
project manager (RPM), has the primary
uncontrolled hazardous waste sites that have
responsibility for coordinating response action.
released or that pose a threat to release
EPA, a State environmental agency, or another
hazardous substances into the environment.
Federal agency can serve as the lead agency.
Pursuant to the National Oil and Hazardous
However, EPA retains final remedy selection
authority for all "Fund-financed" actions, and for
Substances Pollution Contingency Plan (NCP),
all Federal facility (FF)-led actions at NPL sites.*
Title 40 Code of Federal Regulations Part 300
Generally, the lead agency RPM is responsible
(40 CFR 300), sites on the NPL are eligible to
for overseeing all technical, enforcement, and
receive CERCLA trust fund (Superfund)
financial aspects of a remedial response.
financing for RAs. Funding can only be
The following terms are typically used to
provided for RAs at sites that are listed as final
*
designate which government entity serves as the lead
on the NPL.
agency in the Superfund remedial response process:
"EPA-lead," "State-lead," and "Federal facility-lead."
(2)
Prior to a site being listed on the
In addition, the following terms refer to the source of
remediation/cleanup monies: "Fund-financed" (i.e.,
NPL, a preliminary assessment/site inspection
remediation or cleanup money from the Superfund trust
(PA/SI) is typically completed to collect the
fund) and "potentially responsible party (PRP)-lead"
data necessary to develop a score for the site
(i.e., remediation or cleanup money derived from
enforcement action taken by lead agency).
using the hazard ranking system (HRS). The
HRS score ultimately determines the site's
eligibility for inclusion on the NPL.
(3)
Sites on the NPL are addressed by the Superfund process through a combination
of removal and remedial authority. Removal actions are short-term responses, usually to address
immediate threats.1 Remedial actions achieve long-term permanent responses to risk. The
Superfund pipeline (Exhibit 2-1) illustrates the major phases and decision points of the
Superfund remedial response process. The various phases of this process are briefly described in
the following paragraphs.
1
Removal authority cleanup actions achieve prompt risk reduction through activities categorized as emergency (response
required within hours/days), time-critical (response required within 6 months), or non-time-critical (more than 6 months is
available before action must be taken). Non-time-critical removal alternatives are analyzed in an engineering evaluation/cost
analysis (EE/CA), which is considered the equivalent of a remedial investigation/feasibility study. An action memorandum is the
primary decision document, which is considered the equivalent of a record of decision.
2-1
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