Operation and Maintenance, along with Long-Term Responses: Actions for Superfund Sites
The United States Environmental Protection Agency (EPA) plays a crucial role in maintaining the effectiveness of remedies at Superfund sites during the Long-Term Response Actions (LTRAs) and Operation and Maintenance (O&M) phases.
LTRAs, a period defined as the 10-year interval between the 'operational and functional' determination of a remedy and the start of O&M, provide valuable information about the transfer of systems to the states for O&M after a decade. A remedy becomes 'operational and functional' either one year after construction is complete, or when the remedy is determined concurrently by EPA and the state to be functioning properly and is performing as designed, whichever is earlier.
During LTRAs, the EPA ensures that the work is performed adequately and retains funding and operating responsibility for certain groundwater restoration systems. Activities during this period may include operation, maintenance, monitoring, introduction of substrates into the subsurface, monitoring of affected groundwater or surface water, remedy optimization, and planning for the transfer of the remedy to the state for the O&M phase.
The operation of fund-financed groundwater restoration systems for up to 10 years prior to transferring these systems to the states for O&M is considered part of the remedial action, as stated by the National Contingency Plan (NCP), 40 CFR 300.435(f)(3). This responsibility includes overseeing contractors or potentially responsible parties who conduct and maintain the remedy after the initial cleanup phase.
O&M is an essential part of a Superfund response, ensuring the remedy continues to perform as intended and remains protective of human health and the environment. O&M activities may include remedy operation, maintenance, monitoring, and monitoring of impacted media and implemented ICs. Typically, O&M is the responsibility of potentially responsible parties (PRPs), states, or other federal agencies.
The EPA's role in O&M is not limited to supervision. The agency also ensures that the O&M work is performed adequately. EPA may grant extensions to the one-year period, as appropriate. The NCP, 40 CFR 300.435(f)(2), describes 'operational and functional' in detail.
PCC activities, which include O&M and LTRAs, are critical components at Superfund remedial actions to ensure remedies are properly maintained and perform as intended to protect human health and the environment. The EPA's commitment to these activities underscores its dedication to the long-term protection of our nation's environment and public health.
