U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Results and Benefits 

Information Is Needed to 

Support Impacts of EPA’s 

Superfund Removal Program 

Report No. 13-P-0176 March 11, 2013 

Scan this mobile code 

to learn more about 

the EPA OIG. 
 

 

Report Contributors: Carolyn Copper 

 Steve Hanna 

 Roopa Batni 

 Tapati Bhattacharyya

 Brooke Shull 

 Chad Kincheloe 

Abbreviations 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CERCLIS Comprehensive Environmental Response, Compensation, and Liability 

Information System 

EPA U.S. Environmental Protection Agency 

GAO U.S. Government Accountability Office 

GPRA Government Performance and Results Act 

NPL National Priorities List 

OEM Office of Emergency Management 

OIG Office of Inspector General 

ORCR Office of Resource Conservation and Recovery 

OSC On-Scene Coordinator 

OSWER Office of Solid Waste and Emergency Response 

POLREP Pollution Report 

PRP Potentially Responsible Party 

SPIM Superfund Program Implementation Manual 

Cover photo:	 The River Road Drum Site, a 2010 Superfund emergency removal in 

Morgantown, West Virginia. (EPA photo) 

Hotline 

To report fraud, waste, or abuse, contact us through one of the following methods: 

e-mail: OIG_Hotline@epa.gov write: EPA Inspector General Hotline 

phone: 

fax: 

1-888-546-8740 

202-566-2599 

1200 Pennsylvania Avenue, NW 

Mailcode 2431T 

online: http://www.epa.gov/oig/hotline.htm Washington, DC 20460 
 

 

U.S. Environmental Protection Agency 13-P-0176 

March 11, 2013 Office of Inspector General 

At a Glance
 

Why We Did This Review 

We conducted this review to 

determine the environmental 

benefits and impact of the 

U.S. Environmental Protection 

Agency’s (EPA’s) Superfund 

removal program, and the 

Agency’s plan to achieve its 

future program goal. Superfund 

removals are used to respond 

to emergencies or accidental 

releases of hazardous 

substances and mitigate 

damage to the public or the 

environment from hazardous 

substance releases. EPA has 

established an annual 

Superfund removal goal of 170 

EPA-lead and 170 potentially 

responsible party-lead 

removals each fiscal year 

through 2015. 

This report addresses the 

following EPA Goal or 

Cross-Cutting Strategy: 

Cleaning up communities 

and advancing sustainable 

development. 

For further information, contact 

our Office of Congressional and 

Public Affairs at (202) 566-2391. 

The full report is at: 

www.epa.gov/oig/reports/2013/ 

20130311-13-P-0176.pdf 

Results and Benefits Information Is Needed to Support 

Impacts of EPA’s Superfund Removal Program 

What We Found 

EPA does not measure the environmental impact and benefits of the Superfund 

removal program. The goals of the program are measured by determining the 

number of removals completed rather than how removals protect human health and 

the environment. This measurement limitation can diminish the perceived value of the 

program and be an obstacle to a management focus on how removals contribute to 

protection of human health and the environment. Information on removal program 

impacts will allow EPA to better inform the public on the benefits of the program and 

provide a strong foundation for budget requests. EPA’s current numeric removal goal 

appears to be attainable based on past performance, although reductions in funding 

or changes in state needs or capabilities may impact EPA’s ability to meet its goal. 

EPA’s information on removals—such as the type of removal, start and completion 

dates, contaminant, and volume—is maintained in the Comprehensive Environmental 

Response, Compensation, and Liability Information System (CERCLIS). However, 

EPA’s system controls do not adequately monitor the completion of required removal 

actions in CERCLIS. For example, an action memo should be completed within 

5 business days of each removal start, but these were missing or late for about half of 

all removals completed in 2007–2011. Further, CERCLIS does not monitor approval 

of the required exemptions to ensure EPA is in compliance with Superfund law. Much 

of the missing or inaccurate CERCLIS data may be in pollution reports that track 

removal actions. However, although EPA staff said they were working on a process 

to ensure that pollution report data are accurately transferred to CERCLIS, no such 

process currently exists. Accurate CERCLIS information is needed to ensure removal 

actions are justified, completed on time, and address threats to human health and the 

environment. 

 Recommendations and Planned Agency Corrective Actions 

We recommend that EPA identify environmental results and benefits of the removal 

program, communicate those results along with existing program results, and 

implement system controls to ensure required CERCLIS data are entered and 

completed. EPA agreed with the recommendations and provided acceptable 

corrective actions to enhance communications of program accomplishments and to 

control removals data integrity. CERCLIS is expected to be integrated into the 

Superfund Enterprise Management System by September 2013. 
 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

March 11, 2013 

MEMORANDUM 

SUBJECT:	 Results and Benefits Information Is Needed to Support Impacts of EPA’s 

Superfund Removal Program 

 Report No. 13-P-0176 

FROM: Arthur A. Elkins Jr. 

TO:	 Mathy Stanislaus, Assistant Administrator 

Office of Solid Waste and Emergency Response 

This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) 

of the U.S. Environmental Protection Agency (EPA). This report contains findings that describe 

the problems the OIG has identified and corrective actions the OIG recommends. This report 

represents the opinion of the OIG and does not necessarily represent the final EPA position. 

Action Required 

In responding to the draft report, the Agency provided a corrective action plan for addressing the 

recommendations with milestone dates. Because you have provided a corrective action plan with 

milestone dates, you are not required to provide a written response to this final report. Should 

you choose to provide a response, your response will be posted on the OIG’s public website, 

along with our memorandum commenting on your response. The Agency should track corrective 

actions not yet fully implemented in the Management Audit Tracking System. We have no 

objections to the further release of this report to the public. This report will be available at 

http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact Carolyn Copper at 

(202) 566-0829 or copper.carolyn@epa.gov, or Tina Lovingood at (202) 566-2906 or 

lovingood.tina@epa.gov. 
 

 

 

Results and Benefits Information Is Needed to 13-P-0176 

Support Impacts of EPA’s Superfund Removal Program 

Table of Contents 

Chapters 

1 Introduction ........................................................................................................ 1

 Purpose ....................................................................................................... 1 

Background ................................................................................................. 1 

Scope and Methodology.............................................................................. 2 

Prior Evaluation Coverage .......................................................................... 3 

2 Removal Goal Appears Attainable But Does Not 

Communicate Environmental Results and Benefits ....................................... 4
 

EPA’s Removal Goal Appears Attainable If Resources Are Maintained ..... 4 

Environmental Results and Benefits Are Not Communicated by Goal ........ 7 

Conclusions................................................................................................. 7 

Recommendation ........................................................................................ 8 

Agency Response and OIG Evaluation ....................................................... 8 

3 System Controls Do Not Monitor Required Removal Information ................ 9
 

Missing or Inaccurate Removal Information Is Not Corrected ..................... 9 

Conclusions................................................................................................. 13 

Recommendation ........................................................................................ 13 

Agency Response and OIG Evaluation ....................................................... 14 

Status of Recommendations and Potential Monetary Benefits.............................. 15
 

Appendices 

A Agency Response to Draft Report and OIG Comment ................................... 16 

B Distribution ......................................................................................................... 19 
 

Chapter 1

Introduction 

Purpose 

The purpose of this review was to determine whether there are opportunities for 

improved management in the U.S. Environmental Protection Agency’s (EPA’s) 

Superfund removal program, and whether resources could be better directed to 

meet the current program goal. We asked the following questions: 

 What are the environmental results and benefits achieved through 

Superfund removals? 

 What is EPA’s plan to maintain its targeted level of Superfund removals 

through 2015? 

Background 

The Superfund removal program provides responses to immediate threats to 

public health and the environment from releases of hazardous substances, 

pollutants or contaminants. The program is authorized under the 1980 

Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA). CERCLA was reauthorized in 1986 by the Superfund Amendments 

and Reauthorization Act. Superfund removal actions are guided by the National 

Oil and Hazardous Substances Pollution Contingency Plan, commonly referred to 

as the National Contingency Plan. 

Superfund removals are intended to prevent, minimize, or mitigate damage to the 

public or the environment at sites where hazardous substances have been released 

or are threatened to be released. If a site presents a relatively time-sensitive, 

non-complex problem that should be addressed inexpensively, EPA will normally 

address the problem by use of removal authority. However, even expensive and 

complex response actions may be removal action candidates if they are relatively 

time-sensitive. Removals are characterized as either fund-lead or potentially 

responsible party (PRP)-lead actions. Fund-lead removals are paid for by EPA, 

while PRP-lead removals are paid for by PRPs. 

To make a clear distinction between long-term remedial actions and removals, 

Congress placed limits on the time and money available to conduct a removal 

response. An EPA-lead (i.e., “fund-lead”) removal may not exceed $2 million in 

spending or 12 months in duration. The limits may be extended if required to 

address an emergency that will cause an immediate risk to public health or the 

environment. The limits may also be extended if the removal is consistent with 

remedial actions taken at proposed or final NPL sites. A regional administrator 

13-P-0176 1 
 

must approve fund-lead removals that exceed the statutory limits of $2 million or 

12 months. Fund-lead removal actions exceeding $6 million must be approved by 

the Assistant Administrator for the Office of Solid Waste and Emergency 

Response (OSWER). 

Removals are placed in one of three categories: 

	 Classic emergencies – Action required within minutes or hours. 

	 Time-critical – Less than 6 months available before the removal action 

must be initiated. Specific community relations and administrative record 

actions are required. 

	 Non-time-critical – A planning period of more than 6 months is available 

before removal actions must begin. An engineering analysis and cost 

evaluation are required. 

Classic emergencies and time-critical removals are managed by OSWER’s Office 

of Emergency Management (OEM). Non-time-critical removals are managed by 

OSWER’s Office of Superfund Remediation Technology and Innovation. OEM’s 

top priority is to eliminate any danger to the public and the environment posed by 

hazardous substance releases and oil spills. OEM provides funding to EPA 

regional offices for management of removals. Regional on-scene coordinators 

(OSCs) document the status of removals in pollution reports (POLREPs). 

Information on removals, such as the type of removal, start and completion dates, 

contaminant, and volume, is captured and maintained in the Comprehensive 

Environmental Response, Compensation, and Liability Information System 

(CERCLIS). According to the 2012 Superfund Program Implementation Manual 

(SPIM), CERCLIS will be integrated into the Superfund Enterprise Management 

System by September 2013. 

EPA has developed a national goal of 170 fund-lead removals and 170 PRP-lead 

removals each fiscal year through 2015. 

Scope and Methodology 

We conducted our work from March 2012 to November 2012 in accordance with 

generally accepted government auditing standards. Those standards require that 

we plan and perform the evaluation to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based on our 

objectives. We believe the evidence obtained provides a reasonable basis for our 

findings and conclusions based upon our objectives. 

We interviewed OSWER staff, including staff in OEM and the Office of 

Superfund Remediation and Technology Innovation; and staff of EPA Regions 3, 

4, 5, and 9. Regions selected included those with both high and low numbers of 

removals per year. 

13-P-0176 2 
 

 

We reviewed EPA programs, regulations, and guidance documents related to 

removals including relevant sections of CERCLA, the National Contingency Plan, 

SPIM, OSC website guidance documents, and OEM’s Strategic Direction for 

Emergency Management Programs Fiscal Years 2010-2014. We also reviewed 

performance goals and program measures of the OEM removal program. 

Our review focused on fund-lead removals. We reviewed removals data from 

CERCLIS for all 10 EPA regions to assess how program requirements are 

tracked. We also reviewed POLREPs for selected removal sites to compare 

information with CERCLIS and to review data not available in CERCLIS. 

Prior Evaluation Coverage 

The following Office of Inspector General (OIG) and U.S. Government 

Accountability Office (GAO) reports addressed issues related to the scope of our 

review: 

 OIG Report No. 09-P-0144. EPA Needs to Improve Internal Controls to 

Increase Cost Recovery, April 27, 2009. 

 GAO Report No. GAO-08-841R, Superfund: Funding and Reported Costs 

of Enforcement and Administration Activities, July 18, 2008. 

 OIG Report No. 2006-P-00013, EPA Can Better Manage Superfund 

Resources, February 28, 2006. 

13-P-0176 3 
 

 

Chapter 2

Removal Goal Appears Attainable But Does Not 

Communicate Environmental Results and Benefits 

OEM’s annual Superfund removal goal appears to be attainable based on past 

performance. However, there are factors that can impact EPA’s ability to achieve 

its goal, such as possible decreases in program funding or changes in state 

capabilities to respond to removals. In addition, the goal does not demonstrate the 

environmental results and benefits of the removal program. The goal simply 

counts removal completions and thus does not reflect the impact of removal 

actions. Consequently, the environmental results and benefits of EPA’s Superfund 

removal program are not measured or communicated, which could diminish the 

perceived value of the program and be an obstacle to effective management 

focused on program results and impact. 

EPA’s Removal Goal Appears Attainable If Resources Are Maintained 

EPA’s 2011-2015 Strategic Plan establishes a Government Performance and 

Results Act (GPRA) goal to complete 1,700 removals by 2015. Annual targets are 

170 each for fund-lead and PRP-lead removal completions. EPA reported that it 

has exceeded its removal goal since fiscal year 2007 (figure 1). The goal of 170 

fund-lead and 170 PRP-lead removals began in 2010 and was met in fiscal years 

2010 and 2011. Therefore, EPA’s ability to maintain this goal through 2015 

appears attainable. However, staff in one regional office expressed concern about 

the long-term viability of the goal. Staff stated that state removal response 

capabilities in the region had improved, so EPA assistance was only requested for 

larger and more expensive removals.1 

Figure 1: Removals – target goal and actual 

Source: EPA 2013 budget justification 

1

 Results and benefits from fewer EPA removals cannot yet be measured. 

13-P-0176 4 
 

 

We identified issues that could impact EPA’s ability to continue to meet the fundlead removal goal: 

1.	 Basing the goal on historical trends – EPA’s removal goal is based on 

past trends in removal actions conducted. Because removals are responses 

to immediate threats, an estimate of the number that will occur in future 

years may be inaccurate. 

2.	 Decreases in program funding – Annual funding for the emergency 

response and removal program has historically been about $200 million. 

However, in recent years funding for removals has declined (figure 2). If 

program funding continues to decrease, the Agency’s ability to respond to 

both emergency and long-term, expensive removals may be impacted. 

Figure 2: EPA removals budget 

Source: OEM. (Note – numbers represent the enacted budget for each year 

except 2013, which represents the projected amount.) 

3.	 Changes in state capabilities or funding – If a state’s capacity to 

respond to removals diminishes due to funding reductions or other impacts 

on resources, this could create an increased demand for EPA’s response 

resources. On the other hand, if state response capabilities improve and 

EPA’s assistance is needed less, EPA could have fewer removals to count 

toward itsgoal. 

4.	 Impact of large removals – EPA recognizes that some removals require 

more resources or time than others. EPA’s Fiscal Year 2013 Justification 

of Appropriation Estimates for the Committee on Appropriations states, 

“In recent years, emergency response and removal activities have grown 

more complicated, such as large lead and asbestos cleanups, requiring 

13-P-0176 5 
 

more resources and time to complete.” Examples of such removals 

include: 

	 Lead – One removal in Alabama required more than $6 million 

and 4 years, from 2002-2006. The contaminants were lead and 

polychlorinated biphenyls present in residential yards. EPA 

sampled more than 2,000 properties and removed soil from 175 of 

them. 

	 Asbestos – This time-critical removal in New York cost more than 

$8 million and lasted about 16 months in 2010-2011. EPA 

determined that the 14.5-acre site contained asbestos and 

hazardous materials that presented direct contact threats to the 

public. EPA removed 14,500 tons of asbestos-contaminated 

demolition debris from the site. 

Fund-lead removals that exceed the statutory limits of $2 million in 

removal costs or 12 months duration represent a significant amount of 

removal resources. OIG analysis of data on removals completed from 

2007 through 2011 indicates that sites exceeding these limits account for 

approximately 72 percent of the funding obligations (figure 3). In contrast, 

these sites represent only 15 percent of the total sites, indicating that a 

relatively small number of sites represents a large portion of the costs 

during the time period we reviewed. The impact of these removals is not 

reflected in the current goal that simply counts the total number of 

removals. For example, the two removals described above would count the 

same as small removals requiring only a few days and several thousand 

dollars. Because removals such as these require more resources and time 

than other removals, they could affect EPA’s ability to meet its current 

numeric goals. 

Figure 3: Obligations for sites exceeding statutory removal limits 

Source: OIG analysis of CERCLIS data. 

13-P-0176 6 
 

Environmental Results and Benefits Are Not Communicated by Goal 

OEM’s overall mission is the protection of human health and the environment 

from exposure to accidental releases of hazardous substances, pollutants or 

contaminants. Various strategic planning, annual performance planning, guidance, 

and budget documents reflect the importance of the removal program to protect 

the public from exposure to accidental releases of harmful substances. The current 

removal goal of conducting 170 fund-lead and 170 PRP-lead removals each fiscal 

year does not reflect this mission and does not describe the removal program’s 

environmental results and benefits. 

In response to a 2005 Office of Management and Budget assessment of the 

removal program’s performance, OEM committed to developing measures that 

track the program’s impact on human health and the environment. OEM 

management stated that they have attempted to develop a goal more directly 

related to their mission but acknowledged that they have not yet succeeded. This 

was attributed to the GPRA requirement for a goal that could be easily counted, 

resulting in the existing goal that tallies all removal completions irrespective of 

their impact, duration, or cost. 

In the past, OEM provided information on the impact of removals in annual 

reports, but it no longer reports this information. For example, in a 2009 report, 

OEM stated that EPA removals prevented an estimated 1,900,000 human 

exposures, identified the major contaminants, and provided additional detail on 

3 large removals. This type of information can convey the impact and benefits of 

the Superfund removal program, but this type of information is not included in the 

Agency’s removal goals. 

Conclusions 

The effectiveness, impact, and value of EPA’s removal program is not measured 

or communicated. Although EPA’s numeric removal goal appears to be attainable 

based on past performance, changes in funding or state needs or capabilities may 

impact EPA’s ability to meet its goal. EPA’s Superfund removal program appears 

likely to provide significant environmental benefits and human health protection. 

However, the program’s inability to convey those benefits could diminish the 

perceived value of the removal program and impede management that is focused 

on program results and impact. 

13-P-0176 7 
 

Recommendation 

We recommend the Assistant Administrator for Solid Waste and Emergency 

Response: 

1.	 Define environmental results and benefits of the removal program, 

and communicate these results and outcomes with the existing 

removal goal outcomes. 

Agency Response and OIG Evaluation 

OSWER agreed with our recommendation and provided a corrective action plan 

with goals and milestone dates. The plan includes reporting on the top 10 

contaminants of concern each fiscal year, reporting on total contaminant volumes 

for removals, highlighting program accomplishments in OSWER publications 

such as the annual OSWER Accomplishments Report, and working with EPA 

regions to document success stories. OSWER has also committed to continue 

working with the regions to better define the environmental results and benefits of 

the removal program. Based on the Agency’s response, this recommendation is 

open with corrective actions underway. Appendix A contains OSWER’s response 

to our draft report and planned actions to address our recommendation. We 

reviewed OSWER’s technical comments and made revisions to the report as 

appropriate. 

13-P-0176 8 
 

 

Chapter 3

System Controls Do Not Monitor 

Required Removal Information 

CERCLIS – EPA’s Superfund performance accomplishment planning and 

tracking system – does not adequately track key data that EPA has determined to 

be a requirement for removals. While CERCLIS contains almost all data elements 

necessary, data were missing or incomplete in approximately half of the removals 

we reviewed. Interviews with EPA regional staff confirmed that data were 

available in POLREPs but had not been entered into CERCLIS. However, in 

some instances statutory exemptions were not met. Without consistent and 

complete data, EPA cannot effectively monitor removals to ensure all removal 

actions are justified and approved, are completed on time, and address the threat 

to public health and the environment. 

Missing or Inaccurate Removal Information Is Not Corrected 

Specific Data Required by EPA 

CERCLIS is the Superfund program’s data management system.2 EPA uses 

CERCLIS data to track, manage, and report on program performance. Data are 

entered into CERCLIS by EPA regional staff. CERCLIS data entry requirements 

are specified in the annual SPIM and are implemented through data entry control 

plans established by each EPA region. 

The fiscal year 2012 SPIM includes specific planning and reporting requirements. 

For example, it requires that “Upon completion of a removal, an action qualifier 

must be recorded to identify whether the removal resulted in the site being 

Cleaned Up or Stabilized. This is both a Government Performance and Results 

Act (GPRA) annual performance goal and GPRA measure.” In addition, it 

required the following removal program data elements to be entered into 

CERCLIS; if these fields are left blank the removal will not count toward the 

GPRA annual performance goal: 

2

 According to the 2012 SPIM, CERCLIS will be integrated into the Superfund Enterprise Management System by 

September 2013. 

13-P-0176 9 
 

 Removal Action Name  Media Name 

 Removal Lead  Media Type 

 Removal Action Critical  NPL/Non-NPL 

Indicator  Site Type 

 Action Qualifier  Volume (estimate) 

 Start Date  Contaminant 

 Completion Date  Contaminant of Concern 

In addition to these requirements, we have identified other requirements for 

removals specified in Superfund statutes, regulations, or guidance documents. 

These additional requirements include: 

	 Action memorandum – An action memo should be completed as soon as 

practicable or within 5 business days of a removal start date. EPA’s 

September 2009 action memo guidance illustrates the importance of the 

action memo for a removal. According to this guidance, the action memo 

is the primary decision document that: 

- Determines the need for a CERCLA removal action. 

- Authorizes the removal action. 

- Identifies the applicable action and cleanup levels. 

- Explains the rationale for the removal response. 

	 12 month or $2 million exemption – An exemption approved by a 

regional administrator is required for fund-lead removals exceeding 

$2 million or 12 months. 

	 $6 million exemption – An exemption approved by the OSWER assistant 

administrator is required for fund-lead removals exceeding $6 million. 

	 Community involvement – EPA’s 1992 “Public Participation Guidance 

for On-Scene Coordinators: Community Relations and the Administrative 

Record” specifies community involvement requirements for all removals, 

and additional requirements for removals longer than 120 days. 

	 POLREP – A POLREP is required at the start (initial POLREP) and 

completion (final POLREP) of a removal action. In some instances, 

response activities require only one POLREP, which serves as both an 

initial and final POLREP. 

Entry of Required CERCLIS Data Not Monitored 

We reviewed CERCLIS data for 1,079 fund-lead removals in all regions 

completed from 2007 through 2011. We identified the following problems with 

required data: 

	 Removal completion –We found completed removal actions in 

CERCLIS that appeared to be incomplete simply because staff had not 

entered the completion date into CERCLIS. 

13-P-0176 10 
 

   

	 Action memo completion – Approximately 26 percent of the removals 

we reviewed had no action memo associated with the removal in 

CERCLIS (figure 4). An additional 23 percent had late action memos.3 

Figure 4: Completion of action memos in CERCLIS 

Missing

26%

Late

23%

Timely

51%

Action Memo Completion

Source: OIG analysis of CERCLIS data. 

	 Exemption approval for fund-lead removals longer than 12 months or 

more than $2 million – CERCLIS contains specific flags to identify 

approval of each exemption, but the flags are not routinely used. 

CERCLIS could readily be used to monitor the completion of the 

exemption approvals using the existing flags, and generate reports to 

inform EPA management and staff of the need for the exemption 

approvals. Without such monitoring there is no assurance that the 

exemption approvals are being completed as required by statute. 

Completion of the exemption approvals is important for EPA compliance 

with Superfund law, and also ensures EPA management is aware of large 

expenditures that account for well over half of the removal costs. 

	 Exemption approval for fund-lead removals more than $6 million – 

CERCLIS does not utilize any reporting mechanisms to monitor the 

completion of the exemption approvals. Regions we interviewed 

confirmed that these exemption approvals were obtained as appropriate. 

	 Start of time-critical removals within 6 months – We found 33 

removals identified as time-critical that had not begun within 6 months. 

A time-critical removal is defined as a removal that needs to be started 

within 6 months, as measured from the date of the initial action memo. We 

also observed some CERCLIS entries for time-critical removals that had 

3

 “Late” action memos were identified as more than 7 calendar days from the removal start, to account for the 

requirement for completion of the initial action memo as soon as practicable or within 5 business days. 

13-P-0176. 11 
 

not yet started with planned start dates either more than 6 months in the 

future or more than 6 months in the past. These observations raise the 

question of why these are classified as time-critical removals instead of 

non-time-critical. 

 Missing data – We found three removals that did not have an entry to 

indicate if the removal was emergency, time-critical, or non-time-critical. 

We also found one instance of a removal that was completed, based on the 

presence of a completion date, but was missing a removal start date. While 

these represent a small portion of the removals, they demonstrate the 

absence of system controls to require the entry of mandatory data. 

Based on the above issues, we believe CERCLIS is not being adequately utilized 

by EPA to monitor removals. These data entry issues identify problems with 

monitoring the completion of required entries for removals, and indicate missing 

controls that could readily identify possible issues as they occur. Following 

interviews with the regions, we requested additional information on the 

completion of 17 specific 12-month or $2-million exemptions. The responses 

indicated that 4 of the 17 exemptions had not been completed. This emphasizes 

the need to use CERCLIS as a management control to ensure that time-sensitive 

actions are completed as required. Reports from CERCLIS could identify timesensitive actions that are overdue, such as the start of time-critical removals. 

Reports could also identify time-sensitive actions that are pending in the near 

future to provide assistance to program managers. 

Regional staff we interviewed generally expressed frustration about the 

difficulties with using CERCLIS, which could explain some of the missing or 

incorrect data we observed. This may be addressed by the pending redesign of 

CERCLIS. According to the 2012 SPIM, CERCLIS will be integrated into the 

Superfund Enterprise Management System by September 2013. 

Data Entered in POLREPs May Not Be Consistent with CERCLIS 

The National Contingency Plan requires the OSC to submit pollution reports to 

the Regional Response Team and other appropriate agencies as significant 

developments occur during response operations. OSCs prepare POLREPs at the 

initiation and completion of a removal action and at regular intervals in between. 

The POLREP serves as the OSC’s record of response actions, notifications, and 

decisions made to support the response action. POLREPs address: 

 The source and circumstances of the release. 

 The identity of PRPs. 

 The removal activities performed. 

 The costs incurred for the removal activities. 

 The impact and potential impact of the release on public health and 

welfare, and on the environment. 

13-P-0176. 12 
 

The final POLREP documents that all proposed tasks have been completed as 

outlined in the action memo, thereby establishing the completion date for the 

removal. The final POLREP also summarizes the results achieved by the removal 

or response action, including a summary of the wastes disposed of throughout the 

course of the response or cleanup, as well as providing the basis for information 

needed by EPA to measure the progress of the removal program. 

Regional OSCs use POLREPs as the primary tool to document removal response 

actions occurring at a site. Information regarding sites is also entered into the 

CERCLIS database. Both POLREPs and CERCLIS can be accessed by OEM to 

track removal response actions at sites; therefore, information from the two data 

sources should be accurate, updated, and consistent. 

During our review of regional removal sites we identified information, such as 

removal completion dates, that was present in POLREPs but not CERCLIS. As a 

result, the data entered may be inaccurate or missing in CERCLIS but accurate 

and included in the site POLREP. The inconsistencies in data entry and 

transmission between POLREPs and the CERCLIS database present a problem by 

allowing differing data to reside in two locations. This could lead to incorrect 

conclusions about the status of removals. During our discussions with OEM and 

OSWER–CERCLIS staff, we were informed that CERCLIS staff, with OEM and 

regional staff participation, are creating a mechanism to synchronize the 

information documented in POLREPs with CERCLIS. 

Conclusions 

A review of removals data in CERCLIS showed that system controls were 

missing. As a result, information requirements – such as removal completion 

dates, action memos, timely start of time-critical removals, and exemptions for 

removal duration and cost – were not met for some removals. We also found that 

information entered by OSCs in POLREPs may differ or be absent from 

CERCLIS. Accurate information is necessary to assure removals are justified and 

are monitored for timely completion. Timely completion of removal actions is 

critical to provide assurance that the public and environment are protected from 

exposure to harmful substances. 

Recommendation 

We recommend the Assistant Administrator for Solid Waste and Emergency 

Response: 

2. Implement system controls to: 

a. Ensure required CERCLIS data are entered and completed. 

b. Synchronize data between POLREPs and CERCLIS. 

13-P-0176. 13 
 

Agency Response and OIG Evaluation 

OSWER agreed with the recommendation and provided a corrective action plan 

with goals and milestone dates. OSWER is working to develop a report to inform 

managers as to which removals need additional data in CERCLIS. OSWER is 

also working to connect the final POLREP with CERCLIS in the implementation 

of the Superfund Enterprise Management System, which is expected to replace 

CERCLIS in fiscal year 2014. Based on the Agency’s response, this 

recommendation is open with corrective actions underway. Appendix A contains 

OSWER’s response to our draft report and planned actions to address our 

recommendation. We reviewed OSWER’s technical comments and made 

revisions to the report as appropriate. 

13-P-0176. 14 
 

 

 

 

 

 

 

 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed-To 

Amount 

1 8 Define environmental results and benefits of the 

removal program, and communicate these results 

and outcomes with the existing removal goal 

outcomes. 

O Assistant Administrator 

for Solid Waste and 

Emergency Response 

9/30/2014 

2 13 Implement system controls to: 

a. Ensure required CERCLIS data are entered 

and completed. 

b. Synchronize data between POLREPs and 

CERCLIS. 

O Assistant Administrator 

for Solid Waste and 

Emergency Response 

9/30/2013 

O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is unresolved with resolution efforts in progress 

13-P-0176. 15 

1 
 

 

Appendix A 

Agency Response to Draft Report 

and OIG Comment 

MEMORANDUM 

SUBJECT: Response to OIG’s draft report entitled: “Results and Benefits Information Is 

Needed to Support Impacts of EPA’s Superfund Removals Program.” Project No. 

OPE-FY12-0012, dated November 28, 2012 

FROM: Mathy Stanislaus 

 Assistant Administrator 

TO: Carolyn Copper 

Assistant Inspector General for Program Evaluation 

Thank you for the opportunity to respond to the issues and recommendations in the subject audit 

report. Following is a summary of the agency’s overall views, along with its views on each of the 

report recommendations. The agency generally agrees with the report recommendations which 

parallel efforts we have been addressing. Accordingly, we have provided high-level intended 

corrective actions and estimated completion dates. For your consideration, we have included a 

Technical Comments Attachment to supplement this response. 

AGENCY’S OVERALL VIEWS 

In response to the OIG’s Draft Report, “Results and Benefits Information Is Needed to Support 

Impacts of EPA’s Superfund Removals Program,” EPA generally agrees with the 

recommendations in this report and describes our efforts as discussed with your staff. With 

respect to Chapter 3, System Controls Do Not Monitor Required Removals Information, we are 

primarily concerned that the draft report does not truly take into account discussions about 

moving away from CERCLIS towards the Superfund Enterprise Management System (SEMS). 

For example, we will not be adding a data element to track the $6 million exemption or any other 

enhancements; those will not be implemented in CERCLIS, but could be added to SEMS 

requirements, if the program determines those elements are needed in the database. 

In addition, there are areas of the report that need clarification. Those areas are specifically 

described in the Technical Comments Attachment. 

13-P-0176. 16 
 

Agreements 

No. Recommendation High-Level Intended 

Corrective Action(s) 

Estimated Completion by 

Quarter and FY 

1 Define environmental results and 

benefits of the removals 

program, and communicate these 

results and outcomes with the 

existing removals goal outcomes. 

a. OEM will continue to 

report the top ten 

contaminants of 

concern each fiscal 

year, and will begin 

reporting on total 

volume for removals 

beginning FY13. 

b. OEM will continue to 

highlight program 

accomplishments in 

OSWER publications, 

including the annual 

OSWER 

Accomplishments 

Report. 

c. OEM will continue to 

work with the Regions 

and Special Teams to 

build a repository of 

removal success 

stories, which we will 

use to communicate 

program benefits on 

the EPA web site and 

other channels. 

d. OEM will continue 

looking into 

delineating different 

types of removal 

completions to 

communicate impacts 

a. FY13 and ongoing 

b. Ongoing 

c. Beginning FY 13 and 

once per quarter 

throughout the fiscal 

year 

d. Complete by 4th 

quarter FY2014 

2 Implement system controls to: 

a. Ensure required 

CERCLIS data are 

entered and completed. 

b. Synchronize data 

between POLREPs and 

CERCLIS. 

a. OEM will notify the 

Region(s) of any 

discrepancies in 

CERCLIS. 

b. Synchronize data 

fields in the final 

POLREP to fields in 

the Superfund 

Enterprise 

Management System 

a. Ongoing 

b. 4th Quarter FY2013 

13-P-0176. 17 
 

(SEMS). SEMS will 

replace CERCLIS in 

FY 2014. 

Disagreements 

While OSWER generally agrees with the recommendations, there are some nuances (for 

example, the program needs to determine whether all data elements need to be synched between 

POLREPS and SEMS, the replacement for CERCLIS) and ongoing efforts as well as technical 

corrections that are provided in the attached technical comments. 

OIG Response: The OIG acknowledges the ongoing efforts of OSWER to address the 

synchronization of the appropriate data elements between POLREPS and SEMS. The OIG 

reviewed the technical comments and made revisions to the report as appropriate. 

Should you have any questions regarding this memorandum, please contact Dana Tulis, Deputy 

Director, Office of Emergency Management at 202-564-8600. 

13-P-0176. 18 
 

Appendix B 

Distribution 

Office of the Administrator 

Assistant Administrator for Solid Waste and Emergency Response 

Deputy Assistant Administrator for Solid Waste and Emergency Response 

Agency Follow-Up Official (the CFO) 

Agency Follow-Up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for External Affairs and Environmental Education 

Director, Office of Emergency Management, Office of Solid Waste and 

Emergency Response 

Audit Follow-Up Coordinator, Office of Solid Waste and Emergency Response 

13-P-0176. 19