Page 104 - Pipeline Pigging Technology

Environmental considerations and risJc assessment

COMPREHENSIVE ENVffiONMENTAL
RESPONSE, COMPENSATION, AND LIABILITY
ACT OF 1980 (CERCLA)

Synopsis: CERCLA was designed to provide a response for the immediate
clean-up of hazardous substance contamination resulting from accidental or
non-permitted releases or from abandoned waste disposal sites. The goal of
CERCLA is to require those parties responsible for a non-permitted release to
pay for the clean-up of that release. If the responsible party cannot be
identified quickly enough to address an imminent and substantial endanger-
ment, the federal government will respond. If a settlement cannot be reached
with the responsible party, the federal government also will take action and
seek to recover - from the responsible party - the cost of the release.
NCP contained in CWA was revised by CERCLA. It was revised to include
methods for identifying facilities at which hazardous substances have been
disposed; methods for evaluating and remedying releases of hazardous
substances and for analysis of relative costs; methods and criteria for deter-
mining the appropriate extent of clean-up; methods for determining federal,
state, and local roles; and a means of assuring the cost-effectiveness of
remedial actions.
CERCLA provides for the establishment of a National Priorities List (NPL)
of abandoned waste sites that present the greatest danger to public health and
the environment. The list is established by EPA in CERCLA Section 105(aX8).
Using the Hazard Ranking System, the sites on the list are ranked according
to their potential threat to human health and the environment. In theory,
those sites scoring highest under this system are deemed to possess the
greatest environmental threat and therefore will be addressed first.
All responses taken under CERCLA by the federal government, state
government, or responsible party must follow the investigative and remedial
procedures set forth in NCP, which is the central regulation outlining
response authority and responsibilities under CERCLA.

Impacts on the pipeline industry: Because the thrust of CERCLA is
directed toward abandoned waste sites, CERCLA generally has had little
impact on actively-operating pipeline facilities. However, there have been
numerous instances where members of the pipeline industry have had to pay
for the clean-up of waste sites that received waste products from the pipeline
company. Unfortunately, when multiple companies have dumped waste
products at a site that is undergoing a CERCLA-derived investigation and

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