Allocating Remedial Costs at Superfund Sites with Commingled Groundwater Contaminant Plumes

Remedial efforts at Superfund sites across the country focus on groundwater contaminant plumes that have been produced by contributions from multiple parties. Allocating cleanup costs between the parties in a fair and equitable manner can be a problem of substantial complexity. Considerable time and money may be spent determining the amount of contamination attributable to each party in order to apportion liability. Contaminant plumes that have evolved over long periods of time may affect large volumes of groundwater and require extensive remediation. Pump and treat remedial costs are driven by both the volume of water extracted and the mass of contaminants removed. Allocation methods based solely on the mass of contaminants contributed by each party are inadequate in this setting since they do not account for both components of the remedial costs. This paper presents an approach for equitably allocating remedial costs when addressing overlapping or commingled groundwater plumes. The method accounts for the major elements driving the costs of remediating dispersed contaminant plumes.     

Allocating Remedial Costs at Superfund Sites with Commingled Groundwater Contaminant Plumes

Remedial efforts at Superfund sites across the country focus on groundwater contaminant plumes that have been produced by contributions from multiple parties. Allocating cleanup costs between the parties in a fair and equitable manner can be a problem of substantial complexity. Considerable time and money may be spent determining the amount of contamination attributable to each party in order to apportion liability. Contaminant plumes that have evolved over long periods of time may affect large volumes of groundwater and require extensive remediation. Pump and treat remedial costs are driven by both the volume of water extracted and the mass of contaminants removed. Allocation methods based solely on the mass of contaminants contributed by each party are inadequate in this setting since they do not account for both components of the remedial costs. This paper presents an approach for equitably allocating remedial costs when addressing overlapping or commingled groundwater plumes. The method accounts for the major elements driving the costs of remediating dispersed contaminant plumes.     

Determination of the applicability of CERCLA's petroleum exclusion at contaminated sites – focus on metals

Areas impacted by petroleum refining and handling operations may become subject to CERCLA enforcement. Because of CERCLA's petroleum exclusion clause, determining whether contamination in a CERCLA Site originated from petroleum products or hazardous wastes becomes important. Because certain metals are typically enriched in wastes relative to petroleum products and background soils, knowledge of metal contents in these potential end member metal sources is an important step towards contaminant source identification in soils and sediments. In LNAPL plumes, metal content, particularly lead, may be claimed to be the result of wastes mishandling and not due only to the presence of leaded gasoline in the plume. Analysis of the percent gasoline in the plume and accounting for weathering are steps to determining whether the lead content in an LNAPL plume is within the historical lead concentration ranges in gasolines. In addition to metals analyses, understanding of operational parameters such as the history of petroleum refining and handling operations, leaks, spills, and cleanup activities are needed for successful conclusion of the applicability of the petroleum exclusion.     

Performance Audit Results for Volatile POHC Measurements

Audit materials containing principal organic hazardous constituents (POHCs) have been developed by EPA for use by federal, state, and local agencies or their contractors to assess the accuracy of measurement methods used during RCRA trial burn tests. Audit materials are currently available for 27gaseous organics in five, six, seven, and nine-component mixtures at parts-per-billion levels (7 to 10,000 ppb) in compressed gas cylinders in a balance gas of nitrogen. The criteria used for the selection of 27 gaseous organic compounds is described.

Stability studies indicate that all of the organics tested (with the exception of ethylene oxide and propylene oxide below 10 ppb levels) are stable enough to be used as reliable audit materials.

Subsequent to completion of the stability studies, 89 performance audits have been conducted with the audit materials to assess the accuracy of the Volatile Organic Sampling Train (VOST) and bag measurement methods during or prior to RCRA trial burn tests. A summary of the audits conducted for each POHC and the measurement system audited is shown in this paper. The audit results obtained with audit gases during RCRA trial burn tests are generally within ±50 percent of the audit concentrations.     

Guidelines and Resources for Conducting an Environmental Crime Investigation in the United States

Common environmental crimes in the United States include the illegal disposal of hazardous waste, unpermitted discharges to sewer systems or surface water, discharge of oil by vessels to waters within United States jurisdiction, the misapplication of pesticides, the illegal importation of ozone-depleting substances, data falsification, and laboratory fraud. Federal, state, and sometimes local statutes and regulations are in place to protect the water, air, land, and human health. From a federal perspective, these include the Resource Conservation and Recovery Act (RCRA) for hazardous wastes, the Toxic Substances Control Act (TSCA) for toxic substances, the Clean Air Act (CAA), the Clean Water Act (CWA), the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) for abandoned waste sites, and the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) for pesticides. Each of these laws contains some standard methods for sampling and analyses to prove environmental crimes. The Code of Federal Regulations (CFR) contains the specific requirements of the laws. Within the United States Environmental Protection Agency (USEPA), the Criminal Investigation Division (CID) of the Office of Criminal Enforcement, Forensics and Training (OCEFT) has the responsibility to investigate criminal offenses.Criminal offenses are more serious in nature than civil violations in the United States. To successfully prosecute an environmental criminal case, the government has to prove, beyond a reasonable doubt, that a corporation or person knowingly violated an environmental statute containing criminal sanctions. The same environmental forensic techniques used to provide scientifically defensible data prevail in both civil and criminal cases; the only distinction between the two types of cases is legal.     

Contamination potential of nitrogen compounds in the heterogeneous aquifers of the Choushui River alluvial fan, Taiwan

This study aimed to analyze the contamination potential associated with the reactive transport of nitrate-N and ammonium-N in the Choushui River alluvial fan, Taiwan and to evaluate a risk region in developing a groundwater protection policy in 2021. In this area, an aquifer redox sequence provided a good understanding of the spatial distributions of nitrate-N and ammonium-N and of aerobic and anaerobic environments. Equiprobable hydraulic conductivity (K) fields reproduced by geostatistical methods characterized the spatial uncertainty of contaminant transport in the heterogeneous aquifer. Nitrogen contamination potential fronts for high and low threshold concentrations based on a 95% risk probability were used to assess different levels of risk. The simulated result reveals that the spatial uncertainty of highly heterogeneous K fields governs the contamination potential assessment of the nitrogen compounds along the regional flow directions. The contamination potential of nitrate-N is more uncertain than that for ammonium-N. The high nitrate-N concentrations (> or =3 mg/L) are prevalent in the aerobic environment. The low concentration nitrate-N plumes (0.5-3 mg/L) gradually migrate to the mid-fan area and to a maximum distance of 15 km from the aerobic region. The nitrate-N plumes pose a potential human health risk in the aerobic and anaerobic environments. The ammonium-N plumes remain stably confined to the distal-fan and partial mid-fan areas.     

Perchlorate: Problems,Detection, and Solutions

The perchlorate anion (ClO 4 m ) is produced when the solid salts of ammonium, potassium, and sodium perchlorate, and perchloric acid dissolve in water. Ammonium perchlorate, used in solid rocket engine fuels, has a limited shelf life and must periodically be replaced. Before 1997, perchlorate could not be readily detected in groundwater at concentrations below 100 µg/L, until the California Department of Health Services developed an acceptable analytical method that lowered the detection limit to 4 µg/L. Subsequently, groundwater containing perchlorate were soon encountered in several western states, and contamination became apparent in Colorado River water. Most perchlorate salts have high water solubilities; concentrated solutions have densities greater than water. Once dissolved, perchlorate is extremely mobile, requiring decades to degrade. Health effects from ingesting low dosage perchlorate-contaminated water are not well known: it interferes with the body's iodine intake, causing an inhibition of human thyroid production. Contaminated surface and groundwater treatment may require bio- and/or phytoremediation technologies. Perchlorate in groundwater is relatively unretarded; it probably travels by advection. Therefore, it may be used as a tracer for hydrocarbon and metal contaminants that are significantly more retarded. Possible forensic techniques include chlorine isotopes for defining multiple or commingled perchlorate plumes.     

Use of principal component analysis to profile temporal and spatial variations of chlorinated solvent concentration in groundwater

This work aims at evaluating spatial distribution patterns of concentration variations for chlorinated solvents in groundwater, based on principal component analysis and geographic information system (GIS) tools. The study investigates long-time series of chlorinated solvent concentrations in groundwater measured for 18 contaminated industrial sites. The characterization of contaminant plumes and delineation of pollutant sources are essential for choosing appropriate monitoring and remediation strategies, as contaminated groundwaters are characterized by complex patterns of spatial and temporal concentration variability, with wide unpredictable fluctuations over time. The present work describes the results of a new exploratory statistical method called the Variability Index Method (VIM) applied to environmental data to assess the performance of using concentration variations as molecular tracers to reveal aquifer dynamics, industrial impacts, and point sources for contamination plumes. The application of this method provides a useful assessment of controls over contaminant concentration variations as well as support for remediation techniques.     

A History of Dry Cleaners and Sources of Solvent Releases from Dry Cleaning Equipment

Approximately 25, 000-35, 000 dry cleaning facilities currently operate in the U.S. The release of perchloroethylene and other solvents from these establishments represents a major source of soil and groundwater contamination. The manner in which dry cleaning solvents escape from dry cleaning plants is, for all practical purposes, identical for chlorinated and petroleum hydrocarbon solvents and is related to one of the following events: the catastrophic failure of a component of the dry cleaning system, the improper installation, operation or maintenance of the dry cleaning equipment or a combination of all of these causes. Acceptable customs, codes and regulations can also dictate what is authorized for operation of a dry cleaning facility in a particular community, geographic area during a particular time frame. Environmental litigation dealing with the origin of a solvent release from dry cleaners tends to focus on the design and manufacture of dry cleaning industry machines such as washers, washer extractors, tumblers, solvent filters, water separators, stills and spotting boards. A thorough analysis of the daily operations of dry cleaners often reveals that poor maintenance, failure to follow the manufacturer's instructions and the actions of the operator are the most likely causes of soil and groundwater pollution. In order to forensically evaluate the most probable origins of a solvent release and to examine issues regarding liability, a thorough understanding of the history of dry cleaning and a detailed analysis of the operation and maintenance of the dry cleaning equipment are necessary. The discovery of solvent plumes in the vicinity of dry cleaning plants may suggest that the solvent source is the dry cleaning plant; however, the presence of these plumes does not necessarily indicate that the dry cleaning equipment was defectively designed or manufactured. A thorough review of the type of equipment used over the life of the dry cleaning plant and verifiable solvent mileage records frequently indicates that operators of the plant have disposed of solvent and contaminated solids into the municipal sewer or on ground surfaces.     

A History of Dry Cleaners and Sources of Solvent Releases from Dry Cleaning Equipment

Approximately 25, 000–35, 000 dry cleaning facilities currently operate in the U.S. The release of perchloroethylene and other solvents from these establishments represents a major source of soil and groundwater contamination. The manner in which dry cleaning solvents escape from dry cleaning plants is, for all practical purposes, identical for chlorinated and petroleum hydrocarbon solvents and is related to one of the following events: the catastrophic failure of a component of the dry cleaning system, the improper installation, operation or maintenance of the dry cleaning equipment or a combination of all of these causes. Acceptable customs, codes and regulations can also dictate what is authorized for operation of a dry cleaning facility in a particular community, geographic area during a particular time frame. Environmental litigation dealing with the origin of a solvent release from dry cleaners tends to focus on the design and manufacture of dry cleaning industry machines such as washers, washer extractors, tumblers, solvent filters, water separators, stills and spotting boards. A thorough analysis of the daily operations of dry cleaners often reveals that poor maintenance, failure to follow the manufacturer's instructions and the actions of the operator are the most likely causes of soil and groundwater pollution. In order to forensically evaluate the most probable origins of a solvent release and to examine issues regarding liability, a thorough understanding of the history of dry cleaning and a detailed analysis of the operation and maintenance of the dry cleaning equipment are necessary. The discovery of solvent plumes in the vicinity of dry cleaning plants may suggest that the solvent source is the dry cleaning plant; however, the presence of these plumes does not necessarily indicate that the dry cleaning equipment was defectively designed or manufactured. A thorough review of the type of equipment used over the life of the dry cleaning plant and verifiable solvent mileage records frequently indicates that operators of the plant have disposed of solvent and contaminated solids into the municipal sewer or on ground surfaces.     

1990 Thermal Remediation Industry Contractor Survey

The treatment of soil contaminated with organics and inorganics is becoming a major industry in the United States and Europe. The soil cleanup bill for the United States could run as high as $200 to $300 billion over the next 30 to 40 years. European soil cleanup costs could run as high as $130 billion.¹

The types of sites in the United States that will require soil treatment can be broken down into the following categories: ? CERCLA (Superfund) Actions

? RCRA Corrective Actions

? RCRA Closures

? Underground Storage Tanks

? Real Estate Transfers

? Spill Clean-ups.

The cleanup of sites in each of these categories, with the exception of the Real Estate Transfer category, is being driven by different sets of Federal regulations. Real Estate Transfer type regulations were first instituted in New Jersey and have now been promulgated in a number of other states.

The eventual cleanup cost for the Superfund sites will be close to $200 billion. Estimated costs for the industrial sector Superfund are $25 to $50 billion and the estimated cost for the Department of Energy sites is over $150 billion.2 An early RCRA Corrective Action cleanup estimate is $25 billion.3 This estimate may well be low, however, since the permitting, cleanup and delisting criteria are still not clearly defined. The EPA’s RCRA Corrective Action cost estimate is $7.4 billion. However, the Office of Management and Budget feels that this estimate is low.⁴

The potential magnitude of the cleanup costs has resulted in the development and implementation of many technologies for the decontamination of soils. Of the available remedial technologies, thermal treatment has perhaps had the most field testing. The purpose of this paper is to focus on the full scale site remediations which have been or are being conducted using thermal processing equipment. Projects which have been completed, are on-going, or have been contracted for, through January of 1990 are described.     

Numerical experiments and field results on the size of steady state plumes

Contaminated groundwater poses a serious risk for drinking water supplies. Under certain conditions, however, groundwater contamination remains restricted to a tolerable extent because of natural attenuation processes. We present an innovative approach to evaluate the size of these so-called steady-state plumes by 2-D and 1-D modelling in homogeneous aquifers. If longitudinal mixing is negligible, scenarios can be modelled in a simplified way using a 1-D domain vertical to the direction of flow. We analysed the sensitivity of the plume length with respect to biodegradation kinetics, flow velocity, transverse vertical dispersivity alphat, the source and aquifer geometry and reaction stoichiometry. Our findings indicate that for many readily biodegradable compounds transverse-dispersive mixing rather than reaction kinetics is the limiting factor for natural attenuation. Therefore, if alphat, aquifer and source geometry and concentrations of electron acceptors and donors are known, the length of the steady state contaminant plume can be predicted. The approach is validated under field conditions for an ammonium plume at a former landfill site in SW Germany.     

Comment on "Analysis of groundwater contamination using concentration-time series recorded during an integral pumping test: Bias introduced by strong concentration gradients within the plume" by Allelign Zeru and Gerhard Schäfer

We consider the results of a recent paper in this journal [Zeru, A. and Sch?fer, G., 2005. Analysis of groundwater contamination using concentration-time series recorded during an integral pumping test: Bias introduced by strong concentration gradients within the plume. Journal of Contaminant Hydrology 81 (2005) 106-124], which addresses the field-scale characterisation of contaminant plumes in groundwater. There, it is concluded that contaminant concentration gradients can bias Integral Pumping Test (IPT) interpretations considerably, in particular if IPTs are conducted in advective fronts of contaminant plumes. We discuss implications of this setting and also argue that the longitudinal and transverse dispersivities used in the examples of Zeru and Sch?fer (2005) of up to 30 m and 3 m, respectively, are generally very high for the here relevant capture zone scale (<20 m). However, regardless of both longitudinal and transverse concentration gradients, we further show through a counter-example that IPT results are unbiased as long as the concentration attenuation along the flow direction is linear over the capture zone extent.     

The variability and intrinsic remediation of a BTEX plume in anaerobic sulphate-rich groundwater

Data from long-term groundwater sampling, limited coring, and associated studies are synthesised to assess the variability and intrinsic remediation/natural attenuation of a dissolved hydrocarbon plume in sulphate-rich anaerobic groundwater. Fine vertical scale (0.25- and 0.5-m depth intervals) and horizontal plume-scale (>400 m) characteristics of the plume were mapped over a 5-year period from 1991 to 1996. The plume of dissolved BTEX (benzene, toluene, ethylbenzene, xylene) and other organic compounds originated from leakage of gasoline from a subsurface fuel storage tank. The plume was up to 420 m long, less than 50 m wide and 3 m thick. In the first few years of monitoring, BTEX concentrations near the point of leakage were in approximate equilibrium with non-aqueous phase liquid (NAPL) gasoline. NAPL composition of core material and long-term trends in ratios of BTEX concentrations in groundwater indicated significant depletion (water washing, volatilisation and possibly biodegradation) of benzene from residual NAPL after 1992. Large fluctuations in BTEX concentrations in individual boreholes were shown to be largely attributable to seasonal groundwater flow variations. A combination of temporal and spatial groundwater quality data was required to adequately assess the stationarity of plumes, so as to allow inference of intrinsic remediation. Contoured concentration data for the period 1991 to 1996 indicated that plumes of toluene and o-xylene were, at best, only partially steady state (pseudo-steady state) due to seasonal groundwater flow changes. From this analysis, it was inferred that significant remediation by natural biodegradation was occurring for BTEX component plumes such as toluene and o-xylene, but provided no conclusive evidence of benzene biodegradation. Issues associated with field quantification of intrinsic remediation from groundwater sampling are highlighted. Preferential intrinsic biodegradation of selected organic compounds within the BTEX plume was shown to be occurring, in parallel with sulphate reduction and bicarbonate production. Ratios of average hydrocarbon concentrations to benzene for the period 1991 to 1992 were used to estimate degradation rates (half-lives) at various distances along the plume. The estimates varied with distance, the narrowest range being, for toluene, 110 to 260 days. These estimates were comparable to rates determined previously from an in situ tracer test and from plume-scale modelling.     

Comment on “Analysis of groundwater contamination using concentration-time series recorded during an integral pumping test: Bias introduced by strong concentration gradients within the plume” by Allelign Zeru and Gerhard Schäfer

We consider the results of a recent paper in this journal [Zeru, A. and Schäfer, G., 2005. Analysis of groundwater contamination using concentration–time series recorded during an integral pumping test: Bias introduced by strong concentration gradients within the plume. Journal of Contaminant Hydrology 81 (2005) 106–124], which addresses the field-scale characterisation of contaminant plumes in groundwater. There, it is concluded that contaminant concentration gradients can bias Integral Pumping Test (IPT) interpretations considerably, in particular if IPTs are conducted in advective fronts of contaminant plumes. We discuss implications of this setting and also argue that the longitudinal and transverse dispersivities used in the examples of Zeru and Schäfer (2005) of up to 30 m and 3 m, respectively, are generally very high for the here relevant capture zone scale (< 20 m). However, regardless of both longitudinal and transverse concentration gradients, we further show through a counter-example that IPT results are unbiased as long as the concentration attenuation along the flow direction is linear over the capture zone extent.     

Chloride/bromide ratios in leachate derived from farm-animal waste

Ratios of conservative chemicals have been used to identify sources of groundwater contamination. While chloride/bromide ratios have been reported for several common sources of groundwater contamination, little work has been done on leachate derived from farm-animal waste. In this study, chloride/bromide ratios were measured in leachate derived from longhorn-cattle, quarterhorse, and pygme-goat waste at a farm in Abilene, Texas, USA. (Minimum, median, and maximum) chloride/bromide ratios of (66.5, 85.6, and 167), (119, 146, and 156), and (35.4, 57.8, and 165) were observed for cattle, horses, and goats, respectively. These ratios are below typical values for domestic wastewater and within the range commonly observed for oilfield brine. Results of this study have important implications for identifying sources of contaminated groundwater in settings with significant livestock and/or oil production.     

Characterization of redox conditions in groundwater contaminant plumes

Evaluation of redox conditions in groundwater pollution plumes is often a prerequisite for understanding the behaviour of the pollutants in the plume and for selecting remediation approaches. Measuring of redox conditions in pollution plumes is, however, a fairly recent issue and yet relative few cases have been reported. No standardised or generally accepted approach exists. Slow electrode kinetics and the common lack of internal equilibrium of redox processes in pollution plumes make, with a few exceptions, direct electrochemical measurement and rigorous interpretation of redox potentials dubious, if not erroneous. Several other approaches have been used in addressing redox conditions in pollution plumes: redox-sensitive compounds in groundwater samples, hydrogen concentrations in groundwater, concentrations of volatile fatty acids in groundwater, sediment characteristics and microbial tools, such as MPN counts, PLFA biomarkers and redox bioassays. This paper reviews the principles behind the different approaches, summarizes methods used and evaluates the approaches based on the experience from the reported applications.     

Salem Revisited: Updating the MTBE Controversy

This article provides background information regarding the emerging controversies involving methyltert -butyl ether (MTBE) and litigation involving leaking underground storage tanks (USTs) in general. It examines (1) the administrative, legislative and litigation history of MTBE in the context of the Clear Air Act and state environmental statues; (2) the importance of applicable RCRA (Resource Conservation and Recovery Act) deadlines regarding UST compliance in these cases; (3) the question of MTBE toxicity for personal injury claims; and (4) the scope of damages available in cases filed by plaintiffs who are not physically impacted by contamination. The authors conclude that the MTBE controversy does not appear to be a legitimate public health or environmental crisis, but rather is yet another speculative product of the American legal industry.     

Natural attenuation of a plume from an emplaced coal tar creosote source over 14 years

An emplaced source of coal tar creosote within the sandy Borden research aquifer has documented the long-term (5140 days) natural attenuation for this complex mixture. Plumes of dissolved chemicals were produced by the essentially horizontal groundwater flowing at about 9 cm/day. Eleven chemicals have been extensively sampled seven times using a monitoring network of approximately 280, 14-point multilevel samplers. A model of source dissolution using Raoult's Law adequately predicted the dissolution of 9 of 11 compounds. Mass transformation has limited the extent of the plumes as groundwater has flowed more than 500 m, yet the plumes are no longer than 50 m. Phenol and xylenes have been removed and naphthalene has attenuated from its maximum extent on day 1357. Some compound plumes have reached an apparent steady state and the plumes of other compounds (dibenzofuran and phenanthrene) are expected to continue to expand due to an increasing mass flux and limited degradation potential. Biotransformation is the major process controlling natural attenuation at the site. The greatest organic mass lost is associated with the high solubility compounds. However, the majority of the mass loss for most compounds has occurred in the source zone. Oxygen is the main electron acceptor, yet the amount of organics lost cannot be accounted for by aerobic mineralization or partial mineralization alone. The complex evolution of these plumes has been well documented but understanding the controlling biotransformation processes is still elusive. This study has shown that anticipating bioattenuation patterns should only be considered at the broadest scale. Generally, the greatest mass loss is associated with those compounds that have a high solubility and low partitioning coefficients.