The active role of state laws in superfund cleanups

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) did not ignore the fifty individual states when establishing responsibility, authority, and liability for cleaning up hazardous waste sites. Although CERCLA gives EPA the ultimate authority to select a remedy for a contaminated site, the law was drafted not only to allow for state activity without EPA, but also for significant state input when EPA is involved. The relationship between a state (and its environmental laws) and EPA can help decide the remedial and financial interests of any potentially responsible party (PRP). This article discusses the relevant CERCLA provisions, recent court decisions, and resolved and unresolved issues in federal-state Superfund involvement, and recommends several common-sense strategies for PRPs when working with a state in a Superfund cleanup.     

Effects of cosolvency in the fate and transport of PCBs in soil

Under the purview of EPA's Remedial Engineering Management (REM III) Superfund contract, a CERCLA RI/FS was performed at the Pinettes Salvage Yard site located in Washburn, Maine (EPA Region I). The purpose of the RI/FS was to fully characterize the nature, extent, and fate and transport of PCB contamination resulting from an alleged surface spill of transformer dielectric fluid containing Arochlor 1260 (a polychlorinated biphenyl) and various volatile and semivolatile organic constituents. The RI/FS was performed subsequent to both an immediate removal action (IRA) and a deletion remedial investigation (DRI) performed by EPA contractors. Results of both efforts indicated that the site was unsuitable for deletion from the National Priorities List (NPL) because the site soils contained elevated levels of PCBs. This article presents a case history of the extensive field investigations performed to characterize the contaminant source and evaluate the fate and transport of PCBs in site soils. These investigations included on-site mobile laboratory gas chromatograph (GC) analytical techniques for PCBs and targeted volatile and semivolatile organic compounds; confirmatory Contact Laboratory Program (CLP) laboratory analyses of soils, sediments, surface water, and groundwater samples; statistical analyses and correlation of field mobile laboratory GC data with CLP laboratory analytical results; and an evaluation of the potential effects of cosolvency in the fate and transport of PCBs in subsurface soils.     

Defining a successful superfund clean-up: A community representative's perspective

The successful use of the Superfund program involves developing partnerships with all of the stakeholders early in the process. Citizens living near Superfund sites are the primary stakeholders, falling victim to many health risks and economic costs. When equipped with technical advisors, citizens can play a primary role in the remediation decisions being made at hazardous waste sites. This article illustrates the important role and impact of concerned citizens living near the Niagara Mohawk Power Corporation Superfund site in Saratoga Springs, New York. The Superfund program was used successfully at this site in a number of ways, mainly in that it provided technical advisors through a technical assistance grant (TAG) for the citizens, which resulted in a thorough and conclusive remedial investigation.     

Successful UV/oxidation of VOC-contaminated groundwater

Ultraviolet light/oxidation has proven its effectiveness in destroying volatile organic chemicals (VOCs) found in groundwater during a U.S. Environmental Protection Agency (EPA) field study. Under the Superfund Innovative Technology Evaluation (SITE) program, PRC Environmental Management, Inc., and EPA monitored the performance of a system employing advanced oxidation techniques at the Lorentz Barrel & Drum (LB&D) Superfund site in San Jose, California. The firm of Ultrox International (Santa Ana, CA) demonstrated its technology for combining ultraviolet light, hydrogen peroxide and ozone to oxidize toxic organic chemicals found in water. All evaluation criteria were successfully met in the study's results. Greater than 90% of the VOCs were removed. The applicable discharge standards (National Pollution Discharge Elimination System) were attained, and there were no emissions.     

Remediation and future land use: Incorporating reuse considerations into Superfund activities

The U.S. Environmental Protection Agency (US EPA) is placing increased emphasis on the selection and implementation of remedies that accommodate the reasonably anticipated future use of contaminated land. These remedies result in the long‐term protection of human health and the environment. Postconstruction reuse of the land can significantly benefit communities in other ways as well. The launching of the Superfund Redevelopment Initiative in 1999 and the Return to Use Initiative in 2004 reflects an evolution in the US EPA's understanding of what actions can be taken to support the reuse of Superfund sites from discovery through long‐term stewardship. Through these initiatives, the US EPA has increased its understanding of site reuse and continues to explore and implement reuse assessment, reuse planning, and other tools effective in integrating reuse considerations with response activities throughout the remedial process. © 2005 Wiley Periodicals, Inc.     

Cost estimating of the closure/post-closure phase

The U.S. Department of Energy (DOE) is beginning major environmental restoration projects of both active and inactive sites throughout the United States. The problems at the sites include contaminated soils, groundwater and surface waters, structures, and old waste disposal areas. IT Corporation, under the direction of the Office of Independent Cost Estimating (OICE) for DOE, developed a list of environmental problems at the sites and probable cleanup technologies and techniques that could be used. Estimated unit costs were then developed for these cleanup technologies, using available data and references. Some procedures developed were common to many or all cleanup projects. These included site characterization, remedial investigation (RI), feasibility studies (FS), and the closure/post-closure phase. The article will focus on cost estimating of the closure/post-closure phase of a cleanup project. The cost data provided are for budget level or check estimates. Site-specific conditions as well as items peculiar to the environmental industry, such as governmental regulations and community relations, can influence both the cost and duration of a cleanup project.     

A risk-based approach to how clean is clean

Clearly defined remedial action objectives are a key factor in successful remediation programs. Chemical-specific cleanup criteria are critical components of remedial action objectives. A common risk-based approach can be applied for developing cleanup criteria for remediations under CERCLA, RCRA, and TSCA. This approach involves four steps: identify regulatory requirements; identify chemical-specific cleanup guidelines from previous cleanups; evaluate site-specific risk considering mitigating factors for a given site; select the final cleanup criteria based on information from the first three steps. To describe this approach, this paper presents a case study on a PCB cleanup conducted under TSCA. An objective risk-based approach was used to capitalize on the flexibility built into EPA's PCB cleanup guidelines. EPA granted an exemption to the stated policy on the basis of competing risk factors using a comparative risk-assessment approach. Similarly, risk assessment can be used to take advantage of regulatory flexibility in the selection of applicable or appropriate and relevant requirements (ARARs) under CERCLA, or in the selection of media protection standards under RCRA.     

Making the CERCLA Criteria Analysis of Remedial Alternatives More Objective

This article shows how decision analysis techniques assisted decision makers in the critical RI/FS task of technology selection at a specific Superfund site. Each remediation alternative's performance was quantified by creating a set of objective evaluation measures tied to the criteria mandated in the comprehensive Environmental Response, Compensation and Liability Act of 1980. The evaluation measure scores were input into a quantitative decision analysis model used to rank alternatives based on their performance relative to the CERCLA criteria, and to provide insight to the sensitivity of the results to changes in decision maker preferences or technology performance. The model is designed to reflect the site decision maker's preferences and the site-specific characteristics within the framework of the nine CERCLA criteria. This model will give Superfund site decision makers an objective and transparent framework to evaluate remedial technologies.     

Treatment technologies for 1,4‐Dioxane: Fundamentals and field applications

1,4‐Dioxane is a synthetic industrial chemical frequently found at contaminated sites where 1,1,1‐trichloroethane was used for degreasing. It is a probable human carcinogen and has been found in groundwater at sites throughout the United States. The physical and chemical properties and behavior of 1,4‐dioxane create challenges for its characterization and treatment. It is highly mobile and has not been shown to readily biodegrade in the environment. In December 2006, the U.S. Environmental Protection Agency's Office of Superfund Remediation and Technology Innovation (OSRTI) prepared a report titled “Treatment Technologies for 1,4‐Dioxane: Fundamentals and Field Applications.” The report provides information about the chemistry of dioxane, cleanup goals, analytical methods, available treatment technologies, and site‐specific treatment performance data. The information may be useful to project managers, technology providers, consulting engineers, and members of academia faced with addressing dioxane at cleanup sites or in drinking water supplies. This article provides a synopsis of the US EPA report, which is available at http://cluin.org/542R06009 . © 2007 Wiley Periodicals, Inc.     

Improving decision quality: Making the case for adopting next‐generation site characterization practices

Better site characterization is critical for cheaper, faster, and more effective cleanup. This fact is especially true as cleanup decisions increasingly include site redevelopment and reuse considerations. However, established attitudes about what constitutes “data quality” create many barriers to exciting new tools capable of achieving better characterization, slowing their dissemination into the mainstream. Traditional approaches to environmental “data quality” rest on simplifying assumptions that are rarely acknowledged by the environmental community. Data quality assessments focus on the quality of the analysis, while seldom asking what impact matrix heterogeneity has had on analytical results. Assessments of data quality typically assume that chemical contaminants are distributed nearly homogeneously throughout environmental matrices and that contaminant‐matrix interactions are well behaved during analysis. Yet, these assumptions seldom hold true for real‐world matrices and contaminants at scales relevant to accurate risk assessment and efficient remedial design. For the site cleanup industry to continue technical advancement, over‐simplified paradigms must give way to next‐generation models that are built on current scientific understanding. If reuse programs such as Brownfields are to thrive, the scientific defensibility of individual projects must be maintained at the same time as characterization and cleanup costs are lowered. The U.S. Environmental Protection Agency (EPA) offers the Triad Approach as an alternative paradigm to foster highly defensible, yet extremely cost‐effective reuse decisions. © 2003 Wiley Periodicals, Inc.     

Application of In-Situ Vitrification at the Parsons Chemical Site

This article presents the results of demonstration of Geosafe Corporation's in-situ vitrification (ISV) technology at the Parsons Chemical/ETM Enterprises Superfund site in Grand Ledge, Michigan. The primary focus of this article is on the EPA's Superfund Innovative Technology Evaluation (SITE) Program assessment of the sixth melt. A total of eight melts were performed during this project. This demonstration was part of the SITE Program Demonstration (USEPA, 1994), which helped develop innovative hazardous waste treatment technologies, especially those offering permanent remedies for contaminated Superfund and other hazardous waste sites. The demonstration results are not only applicable to this particular project, but are also indicative of other Geosafe project experiences and demonstrate the current state of the ISV technology. The demonstration included two phases. In the first phase, the ISV technology was used to treat the Parsons contaminated soil. In the second phase, post-testing and analysis were conducted about one year after the ISV technology was applied to confirm that the vitrification was completed and that no contamination migration had occurred.     

A New Perspective on Sustainable Soil Remediation—Case Study Suggests Novel Fungal Genera Could Facilitate in situ Biodegradation of Hazardous Contaminants

Deciding upon a cost effective and sustainable method to address soil pollution is a challenge for many remedial project managers. High pressure to quickly achieve cleanup goals pushes for energy‐intensive remedies that rapidly address the contaminants of concern with established technologies, often leaving little room for research and development especially for slower treatment technologies, such as bioremediation, for the more heavily polluted sites. In this case study, new genomic approaches have been leveraged to assess fungal biostimulation potential in soils polluted with particularly persistent hydrophobic contaminants. This new approach provides insights into the genetic functions available at a given site in a way never before possible. In particular, this article presents a case study where next‐generation sequencing has been used to categorize fungi in soils from the Atlantic Wood Industries Superfund site in Portsmouth, Virginia. Data suggest that original attempts to harness fungi for bioremediation may have focused on fungal genera poorly suited to survive under heavily polluted site conditions, and that more targeted approaches relying on native indigenous fungi which are better equipped to survive under site‐specific conditions may be more appropriate. ©2016 Wiley Periodicals, Inc.     

Proven methods for managing public perception of cleanups

Negative public perceptions can dramatically increase site remediation costs or even bring projects to a grinding halt. Public opposition and ensuing political pressure are two damaging, but often ignored, obstacles that confront remediation managers. This article discusses these and other public management issues, recommending tactics proven for maintaining positive working relationships with a site's human neighbors, the media (electronic and print), government officials, regulatory agencies, and other concerned groups to allow site cleanup to proceed without intervention, opposition, or unnecessary delay. It illustrates its warnings about public and political hostility with case histories from Superfund, RCRA, and other cleanup sites, recounting how corporate management won the public's confidence and kept their projects on time and within budget.     

In‐Canal Stabilization/Solidification of NAPL‐Impacted Sediments

In situ solidification (ISS) has been used with increasing frequency as a remedial technology for source area treatment at upland sites impacted with a variety of organic contaminants, including coal tar, creosote, and other nonaqueous phase liquids (NAPLs). With several large, complex, urban water ways and rivers impacted with NAPLs, ISS is more recently being considered as a technology of choice to help reduce remedial costs, minimize short‐ and long‐term impacts of mobile NAPL, and lower the carbon footprint. This article presents the results of a successful pilot study of ISS at the Gowanus Canal Superfund site in Brooklyn, New York. This represents the first major sediment ISS field demonstration project in a saline environment and the first project to evaluate large‐scale implementation of ISS from a barge and through overlaying sediment. ©2016 Wiley Periodicals, Inc.     

Examining the economics of remediation by fluid injection with vacuum extraction

Enhanced methods of in-situ remediation based on patented technology involving fluid injection with vacuum extraction have been used successfully at the Sand Creek Superfund Site in Commerce City, Colorado. Approximately 177,000 pounds of volatile organic compounds (VOCs) were removed from the subsurface in six months, two months ahead of schedule. Remediation goals were achieved on this thermally enhanced soil vapor extraction project by using vertical and horizontal wells interchangeably in vacuum or pressure service for vapor extraction, dual vacuum extraction, heated vapor reinjection, and air sparging. Although VOCs consisted of mixed chlorinated and petroleum hydrocarbons, the petroleum hydrocarbons, some in the form of nonaqueous phase liquids, had not been fully characterized. This article examines the evolution of the remedial design from that conceptualized in the Record of Decision (ROD) of the U.S. EPA, presents the rationale for the selection of alternative system components, and provides a cost analysis of the selected remedial technology, with comparisons to that of alternatives considered for use at Sand Creek.     

Look at groundwater quality to set VOC cleanup levels

In 1981, the Arizona Department of Health Services (ADHS) discovered groundwater contamination by solvents and chromium at the Phoenix Goodyear Airport (PGA), just outside the city of Phoenix. ADHS and the U.S. EPA sampled the site for the next two years, finding that eighteen of their wells were contaminated with trichloroethene (TCE), six exceeding ADHS's action level of five micrograms per liter (μg/l). In 1983, the PGA site was added to the National Priorities List, and, in 1984, EPA began a $3 million remedial investigation, focusing on soils and groundwater. This article discusses how that investigation inspired the authors to develop a stream-lined evaluation method for PGA's volatile organic compounds (VOCs), the process for establishing VOC cleanup levels, and the $26 million of remediation work needed to be done at the site. The heart of this effort is a computer program called VLEACH, loosely standing for VOC-LEACHing, which anticipates the influence of VOCs on PGA's groundwater, even as remediation proceeds.     

Superfund cleanup: Designing containment remedies for recreational reuse

In July, 1999, EPA announced its Superfund Redevelopment Initiative, the Agency's effort to help communities bring Superfund sites back into productive use in a manner that is protective of human health and the environment. As part of the Superfund Redevelopment Initiative, the Agency is developing reuse design guides that provide technical information related to the design of remedies that safely support reuse. The design guides focus on the reuse of containment sites, and address such topics as settlement, gas control, irrigation, drainage, and operation and maintenance. Case studies of redeveloped sites are also presented in the guides. EPA is currently developing design guides that address the reuse of Superfund sites for commercial purposes, wildlife areas, parking lots, recreational sports fields, and golf courses. This article provides information on the first guide in the series‐the reuse of Superfund sites for recreational purposes.     

A Slice of Guidance Provides Some Insight to Addressing Contaminated Sediments

The U.S. Environmental Protection Agency (EPA) has issued guidance to improve cleanup risk management decisions at sites involving contaminated sediments. The guidance is titled Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites and is important because sediment cleanup decisions are often very technical and complex. While the guidance is not a step‐by‐step “how to” document, it does provide the framework for risk‐based decision making and national consistency. Although it does not answer the more technical questions associated with remediation, it will likely provide site managers with greater certainty related to their decisions and help determine what questions need to be asked for many complex issues. Additional and forthcoming EPA reports, seminars, and products will be useful in building upon this framework. This article provides an overview of the risk management principles presented in the guidance. © 2002 Wiley Periodicals, Inc.     

Development of a site‐specific cleanup goal for PAHs in soil based on anthropogenic background levels

During removal of an industrial landfill in Folsom, California, fill material was excavated and processed through a mechanical screening plant to segregate soil from construction and demolition debris. The segregated soil was stockpiled and analyzed for a wide range of chemical groups to determine if the soil could be backfilled on‐site. The analytical results indicated many of the stockpiles had concentrations of polycyclic aromatic hydrocarbons (PAHs) that exceeded US EPA Regional Screening Levels, and a large quantity of soil was initially classified as requiring off‐site disposal at considerable cost. Because PAHs are ubiquitous in urban settings and the landfill did not contain a significant source of PAHs, development of a site‐specific PAH cleanup goal was proposed to regulators. Cal/EPA guidance for using on‐site data to develop a background threshold for metals was applied to the development of the PAH cleanup goal. The Cal/EPA approach involves demonstrating whether the data belong to a single population or multiple populations based on data distribution tests and probability plots. This article explains the statistical and graphical methods that were used to demonstrate that the Cal/EPA approach was valid for PAHs and that the calculated cleanup level was consistent with published anthropogenic background levels of PAHs in California and across the United States. The site‐specific PAH cleanup goal enabled most of the soil to be backfilled on‐site, saving about $227,000 in transportation and disposal costs, and regulators subsequently approved unrestricted future use of the property. © 2010 Wiley Periodicals, Inc.     

How chemically stable is stabilized hazardous waste?

Bioassays can provide meaningful information about the relative toxicity of remediated soil samples, revealing the unwelcome toxic side effects produced by some cleanup projects. Section 121 of CERCLA's 1986 amendments calls for hazardous waste site remediations to permanently and significantly reduce the volume, toxicity, and mobility of hazardous substances, pollutants, and contaminants. Traditional engineering technology has focused on reducing volume and mobility, assuming that such reduction would lead to reductions in toxicity. Environmental scientists have argued, however, that such reductions are not always the result, but lack of consensus on how hazardous waste mixtures should be measured toxicologically has slowed development of integrated assessments. The aquatic and terrestrial bioassays discussed in this article are evaluated for various chemicals, mixtures of chemicals, and actual waste site chemical mixtures at a Superfund mobility reduction project in Kent, Washington. Results suggest that although remediation accomplished the primary objective of reducing mobility, it also introduced toxic effects. These tradeoffs must be viewed holistically when the ultimate performance of cleanup measures is judged.