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How does a site become a "Superfund" site?

Liquid Disposal Superfund Site - Macomb County
Environment, Great Lakes, and Energy

How does a site become a "Superfund" site?

Sites become "Superfund" sites through an evaluation process called "Superfund Site Assessment."  In Michigan, these assessments are conducted by EGLE's Site Assessment Group in the Superfund Section.  Superfund Site Assessment work consists of discovery, evaluation, and nomination of contamination sites to the Superfund National Priorities List (NPL) as defined in the Comprehensive Environmental Remediation, Compensation, and Liabilities Act (CERCLA). 

Discovery is the official entry point for contamination sites into the Superfund NPL process.  Sites can be discovered into the process through requests by the USEPA; state agencies; local, state, or federal health departments; or by private citizens.  Once a site is discovered, it must be evaluated to determine whether it qualifies for listing on the NPL.  The first step in the traditional Site Assessment process is the Preliminary Assessment (PA).  PAs are typically non-sampling information searches used to determine whether the site has the potential to qualify for the NPL. If this evaluation determines that the site does not qualify for the NPL, it will be given No Further Remedial Action Planned (NFRAP) status and archived in the U.S. EPA Superfund Enterprise Management System (SEMS) database.  NFRAP status means the U.S. EPA no longer plans any action toward NPL listing on the site.  If it is determined that the site may qualify for NPL listing, a recommendation will be made as to whether the site can be immediately nominated to the NPL, whether it needs further evaluation, or if it can be deferred to another state or federal agency and designated as having Other Cleanup Authority (OCA).

If the recommendation of the PA is to continue in the process, the next step is the Site Inspection (SI).  During the SI, additional data, including sampling of source areas, soils, groundwater, surface water, sediments, soil gas, etc. are gathered to further evaluate the site.  These data are collected in such a manner that they can be used in preparing a Hazard Ranking System (HRS) nomination package for the site.  Recommendations from the SI could be to designate the site as NFRAP, to perform an Expanded SI (ESI) to collect additional data for scoring purposes, to prepare an HRS scoring package and nominate the site to the NPL, or to defer the site as OCA.

The HRS is the U.S. EPA's tool for scoring sites for the NPL.  If the recommendation of the PA/SI/ESI is to nominate the site to the NPL, an HRS scoring package and documentation record is prepared for the site.  Once the HRS package/documentation record is prepared, the site is proposed to the NPL in the Federal Register. If, after public comment on the proposal and HRS package, the site still qualifies for the NPL, the NPL decision is made final in a subsequent Federal Register. The site then moves into the remedial process of the Superfund program.

Additional work can be performed in the Site Assessment process in working with the U.S. EPA on Time-Critical and Non Time-Critical Removal Actions (TCRA & NTCRA). Work on TCRAs includes assisting the U.S. EPA Emergency Removal Branch with site investigations and integrating assessments of contamination sites. NTCRA work includes participating in Site Assessment Teams to determine appropriate actions at a site, performing Engineering Evaluation/Cost Analyses for determining remedial options, and performing removal actions.

Additional information is available on the Site Assessment process through the U.S. EPA Headquarters home page or through the U.S. EPA Region 5 home page.  

All sites discovered into the Superfund process, and their associated activities, are tracked by the U.S. EPA on SEMS for CERCLA sites in Michigan and may be found on the SEMS “Search Superfund Site Information” web page.



Keith Krawczyk