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This Congressional Budget Office (CBO) memorandum presents new data on the average time required to complete cleanup work at Superfund sites and explores the factors responsible for making some sites take much longer than others. Perry Beider of CBO's Natural Resources and Commerce Division wrote the memorandum, under the direction of Jan Paul Acton and Roger Hitchner, with research assistance from Aaron Zeisler. Mike Cullen, Dave Evans, lisa Feller, and Edward Ziomkoski of the Environmental Protection Agency cooperated with the author, and Elizabeth Pinkston of CBO and Dave Evans provided valuable comments. Angela Z. McCollough produced the memorandum.

Questions about the memorandum may be addressed to Perry Beider.
 
 

INTRODUCTION AND SUMMARY

DEFINING AND ESTIMATING THE DURATION OF CLEANUP

ESTIMATES OF AVERAGE DURATION

VARIABILITY AROUND THE AVERAGE DURATION

WHY DOES DURATION VARY AMONG SITES?

• RPM Explanation for Fast and Slow Sites
• Effects of Individual Site Characteristics
• Multiple Regression Analysis of Site Duration

INTRODUCTION AND SUMMARY

Since its creation in 1980, the federal Superfund program to clean up the nation's worst hazardous waste sites has been subject to many criticisms, not all of them consistent.¹ One criticism on which widespread agreement exists is that sites on Superfund's National Priorities List (NPL) take too long to be cleaned up. The Environmental Protection Agency (EPA), which administers the program, places sites on the NPL after it has determined that they pose large enough threats to human health and the environment and are too complex or costly to be cleaned up under Superfund's "removal" authorities.²

Heretofore, however, the high level of concern over the time required to clean up Superfund sites has not produced much systematic analysis of the problem. EPA's reported statistics on the average duration of cleanups have suffered from problems of consistency and interpretation, and discussions of possible underlying causes have relied primarily on anecdotal evidence from individual sites.³

This memorandum by the Congressional Budget Office (CBO) analyzes the time required to clean up NPL sites. The analysis relies primarily on data EPA collected in August 1993 by interviewing remedial project managers (RPMs), the EPA regional employees who oversee the cleanup efforts. The memorandum also discusses and interprets EPA's existing estimates of the average duration of cleanup.

The 1993 interviews asked the RPMs about land use, waste management activities, parties involved, cleanup decisions, and costs at all 1,249 sites on the NPL. The RPMs' answers represent a mixture of hard data and personal judgments. EPA has conducted checks to verify that the data derived from the interviews accurately reflect the answers. CBO has not independently validated the data, but believes that they represent an important addition to the information available about Superfund sites.⁴

The main findings of the analysis concern the average cleanup time for all NPL sites and the deviations of individual sites from the average; the RPMs' assessments of the problems that lead to slow cleanups as well as the advantages that promote fast cleanups; and finally, specific site characteristics that seem to be associated with the problems at sites with slow cleanups (henceforth, "slow sites").

• National Average. The best available data indicate that the average time between proposed listing on the NPL and "construction completion" (loosely, completion of principal cleanup work) will be at least 12 years for the first 1,249 sites. Given the limitations of the data, the true average is more likely to lie between 13 and 15 years.
  
  
• Early and More Recent Sites. EPA's cleanup managers expect that sites proposed for the NPL after 1983 (almost 60 percent of the total) will be completed much more quickly than those proposed during the 198M983 period (roughly 40 percent). This expectation may reflect improvements made in the Superfund program since its early years and a reduction in complexity among the sites listed more recently. It may also, however, reflect more limited knowledge about the recent sites and insufficient consideration of budget constraints and other sources of future delays.
  
  
• Variability. The durations of cleanups vary widely. Because of early actions taken by EPA, the states, or responsible parties, some sites are finished by the time they are formally listed or shortly thereafter. At the other end of the spectrum, RPMs expect a few sites to take as long as 30 or 40 years to reach construction completion. Sites owned or operated by the federal government are much more likely than nonfederal sites to be among those requiring the most time; federal sites also require more time on average--probably at least three years more.
  
  
• Main Explanations. RPMs find the major causes of slow cleanups to be intrinsic site difficulties (such as size and complexity of contamination) and enforcement and legal problems (such as delays in negotiations with potentially responsible parties--PRPs--and shifts in the management of cleanup projects between EPA and the PRPs). Conversely, sites with simple contamination problems and few PRP problems predominate among the cases of fast cleanups.
  
  
• Other Explanations. RPMs view constraints on funding and staffing as important secondary contributors to slow cleanups. Other contributing factors that they cite less frequently include problems with achieving the remedy, state governments, and local communities. State problems include objections to remedies chosen by EPA, coordination problems between the states and the federal government, and delays at sites where a state has taken the lead role.
  
  
• Characteristics Associated with the Length of Cleanup. According to preliminary analysis, specific site characteristics that appear to be associated with the duration of cleanup at nonfederal sites include the site's size (area) and waste quantity, the existence and number of financially viable PRPs, and the use of part or all of the site by chemical manufacturers.
  
  
• Characteristics of Intrinsically Difficult Slow Sites. Specific factors that appear to be associated with intrinsic difficulties at slow nonfederal sites include size exceeding 200 acres, land use that includes chemical manufacturing, and waste disposal to a lake or river. RPMs did not identify mixed-waste landfills as particularly difficult.
  
  
• Characteristics of Slow Sites with Enforcement Problems. Characteristics that appear to be associated with enforcement problems at slow sites include the presence of more than 10 PRPs that contributed under 1 percent of the waste, a large waste share from parties that cannot be located or are not financially viable, a large share of municipal solid waste, land use that includes mixed-waste landfills or chemical manufacturing, and expected PRP costs exceeding $15 million. Often, many of these characteristics are found together at the same sites.

This document is available in its entirety in PDF.

1. More background on the Superfund program and iu areas of controversy can be found in Chapter 1 of Congressional Budget Office, The Total Costs of Cleaning Up Nonfederal Superfund Sues (January 1994).

2. By law, removal action* financed by the federal government are generally limited to one year in length and $2 million in cost Removal actions may be taken at both NPL and non-NPL sites.

3. In 1990 and 1991, EPA collected and analyzed data on the proximate explanations for sites that failed to pass certain milestones by the expected dates. This effort did not examine the underlying explanations for fast or slow cleanup of an entire site from start to finish.

4. The data analyzed here are no exception to the rule that any large data set contains some errors. For example, the information CBO obtained from EPA indicates that 125 of the 1,249 NPL sites are federal facilities; reports produced by EPA, however, give the number of federal facilities as 123. The results of the analysis are not sensitive to minor discrepancies such as these.