Making Cleanup Decisions at Hazardous Waste Sites: The Clean Sites Approach

This paper provides a summary of the results of an 18-month study conducted by Clean Sites, Inc. of Alexandria, Virginia. The study was designed to take a critical look at the way remedies are selected for abandoned hazardous waste sites that are cleaned up under the authority of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) and to develop recommendations for improving that process. The recommendations were released in an October 1990 report entitled “Improving Remedy Selection: An Explicit and Interactive Process for the Superfund Program.” Through a cooperative agreement with the U.S. Environmental Protection Agency, Clean Sites is working to test these recommendations. At two actual Superfund sites, Clean Sites will assist EPA in performing the remedy selection in accordance with the process Clean Sites has developed.     

Making cleanup decisions at hazardous waste sites: the clean sites approach.

This paper provides a summary of the results of an 18-month study conducted by Clean Sites, Inc. of Alexandria, Virginia. The study was designed to take a critical look at the way remedies are selected for abandoned hazardous waste sites that are cleaned up under the authority of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) and to develop recommendations for improving that process. The recommendations were released in an October 1990 report entitled "Improving Remedy Selection: An Explicit and Interactive Process for the Superfund Program." Through a cooperative agreement with the U.S. Environmental Protection Agency, Clean Sites is working to test these recommendations. At two actual Superfund sites, Clean Sites will assist EPA in performing the remedy selection in accordance with the process Clean Sites has developed.     

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.     

Results of Treatment Evaluations of a Contaminated Synthetic Soil

Under Phase I of EPA’s Superfund soil treatability research program, which was conducted from April to November 1987, a surrogate soil containing a wide range of chemical contaminants typically occurring at Superfund sites was prepared and subjected to bench- or pilot-scale performance evaluations using the following treatment technologies: 1) physical separation/volume reduction (soil washing); 2) chemical treatment (KPEG); 3) thermal desorption; 4 ) incineration; and 5) stabilization/fixation. This report covers the formulation and development of the surrogate soil; it also highlights the results of the five treatment evaluations. Virtually all of the analytical data underlying this research were developed using EPA-SW846 methods. Detailed project reports covering the findings of each study are available through EPA’s Risk Reduction Engineering Laboratory in Cincinnati, Ohio.     

Thermal Encapsulation of Metals in Superfund Soils

Abstract

Superfund sites frequently contain both heavy metals and organic hazardous waste. If not properly controlled, the metals may be changed to a more leachable form and may also be emitted to the atmosphere via the exhaust stack. This paper documents a batch kiln R&D test program to solve these metal-related problems. It was performed under the U.S. EPA’s SITE (Superfund Innovative Technology Evaluation) Emerging Technology Program. Allis Mineral Systems has developed the Thermal Encapsulation Process. Metals with limits set by EPA’s TCLP (Toxicity Characteristic Leaching Procedure) test and BIF (boiler and industrial furnace) stack emission regulations, such as cadmium, chromium, and lead, are the initial target of this process. This process, while unproven in these areas, may also apply to mixed waste (EPA hazardous waste/low-level radioactive wastes) and may also benefit commercial hazardous waste or Superfund thermal treatment systems. The results of the SITE tests were positive: strong, durable nodules were produced with excellent crush strength and improved resistance to leaching. Feed preparation, particularly control of moisture content, was found to be a key element in initiation of agglomeration. A good correlation was found between decreasing TCLP metals leachate levels and increasing crush strength.     

Control of incidental asbestos exposure at hazardous waste sites

This paper discusses asbestos regulations that are not part of Superfund and examines how these regulations can help to identify, evaluate and manage the risk associated with Asbestos Containing Material (ACM) at hazardous waste cleanup sites. Unless one knows where to look for ACM at hazardous waste sites, it may go undetected even after all the traditional sampling is done. Although EPA is currently developing a policy for evaluating risk from asbestos exposure at certain Superfund sites, information from existing regulations can be used to manage hazards associated with asbestos exposure at hazardous waste sites. This paper also identifies where to find governmental agency personnel and consultants who may be retained for site-specific help.     

Overview and update of the Superfund Innovative Technology Evaluation (SITE) Demonstration Program

The Superfund Innovative Technology Evaluation (SITE) Program is now in its sixth year of demonstrating technologies applicable to Superfund sites. The SITE Program, conducted by the U.S. Environmental Protection Agency's Risk Reduction Engineering Laboratory, is intended to accelerate the use of new and innovative treatment processes as well as evaluate innovative measurement and monitoring techniques. Within the SITE Program, the Demonstration Program and the Emerging Technologies Program are responsible for innovative/alternative waste treatment technology development. Separate and parallel activities are progressing for development and evaluation of measuring and monitoring technologies as well as technology transfer operations.     

Refinery Sludge Treatment/Hazardous Waste Minimization Via Dehydration and Solvent Extraction

Abstract

The patented Carver-Greenfield (C-G) Process®, a combination of dehydration and solvent extraction treatment technologies, has a wide range of uses in separating hydrocarbon solvent-soluble hazardous organic contaminants (indigenous oil) from sludges, soils, and industrial wastes. As a result of this treatment, the products from a C-G Process facility are: ? Clean, dry solids which are typically suitable for disposal in nonhazardous landfills;

? Water which is treatable in an industrial or Publicly Owned Treatment Works (POTW) wastewater treatment facility;

? Extracted indigenous oil containing hydrocarbon soluble contaminants which may be recycled or reused or disposed of at less cost because its volume is smaller than the original waste feed.

The C-G Process was demonstrated on spent oily drilling fluids as part of the U.S. Environmental Protection Agency Superfund Innovative Technology Evaluation (SITE) Program. This paper summarizes the use of the C-G Process for economical treatment and minimization of hazardous refinery wastes, reviews the SITE program results, and describes extending the C-G Process technology to treatment of other wastes. Estimated treatment costs are presented.     

Overview and Update of the Superfund Innovative Technology Evaluation (site) Demonstration Program

The Superfund Innovative Technology Evaluation (SITE) Program is now in its sixth year of demonstrating technologies applicable to Superfund sites. The SITE Program, conducted by the U.S. Environmental Protection Agency’s Risk Reduction Engineering Laboratory, is intended to accelerate the use of new and innovative treatment processes as well as evaluate innovative measurement and monitoring techniques. Within the SITE Program, the Demonstration Program and the Emerging Technologies Program are responsible for innovative/ alternative waste treatment technology development. Separate and parallel activities are progressing for development and evaluation of measuring and monitoring technologies as well as technology transfer operations.     

Liability Theories in Contaminated Groundwater Litigation

Disputes regarding contaminated sites have given rise to an explosion of federal and state court litigation. Congress enacted the Resource Conservation and Recovery Act of 1976 ("RCRA"), 42 U.S.C. §§6901 et seq. , as a contemplated "cradle to grave" regulatory scheme for solid waste, and passed the Comprehensive Environmental Response, Compensation, and Liability Act ("CERCLA"), 42 U.S.C. §§9601 et seq. , to address the investigation and remediation of contaminated sites. RCRA and CERCLA each contemplate a strict, joint and several regulatory liability scheme to address sites that have required billions of dollars to investigate and remediate, and which will require additional billions in order to complete the job. Federal and state law cases involving groundwater contamination cases have presented special challenges to litigants and the Courts. Determining the source of groundwater contamination is often a matter of technical dispute, particularly in the case of commingled plumes or older plumes where original point source locations can no longer be located or where there has been a significant amount of contaminant degradation over time. Contaminated plumes derived in whole or in part from potential continuing sources can present difficult remedy selection issues and uncertainty regarding future cost obligations. While a variety of federal and state law theories of liability are available to address groundwater contamination, each presents certain benefits and limitations. For example, CERCLA claims can cover a wide spectrum of potentially responsible parties and are based on strict liability; however, CERCLA excludes petroleum from the scope of its liability scheme and limits recovery to necessary response costs consistent with the National Contingency Plan. RCRA claims can include petroleum contamination, but cannot seek recovery of past costs. Common law theories such as nuisance, trespass and negligence can permit recovery of a broader scope of potential damages and provide for joint and several liability, but they are not based on notions of strict liability and sometimes present difficult statute of limitations problems. This article identifies federal and California state law liability theories addressing responsibility for groundwater contamination, and reviews the elements of liability, potential limitations on available relief, and recent case law developments under these theories.     

The Use of Electrokinetics for Hazardous Waste Site Remediation

The Superfund Innovative Technology Evaluation (SITE) program was authorized as part of the 1986 amendments to the Superfund legislation. It represents a joint effort between U.S. EPA’s Office of Research and Development and Office of Solid Waste and Emergency Response. The program is designed to assist and encourage the development of waste treatment technologies that would contribute to more solutions to our hazardous waste problems.

Recently, EPA, through the SITE program, issued a work assignment to assess the “stateof- the-art” of electroklnetically enhanced contaminant removal from soils. Prior research efforts, both laboratory and field, have demonstrated that electroosmosis has the potential to be effective In facilitating the removal of certain types of hazardous wastes from soils. Particularly encouraging results have been achieved with inorganics in fine-grained soils where more traditional removal alternatives are less effective.

Although the results of various studies suggest that electrokinetics is a promising technology, further testing Is needed at both the laboratory and field levels to fully develop this technology for site remediation. A conceptual test program Is presented based on best available data which incorporates system design and operating parameters used in previous applications of this technology In the use of electrokinetics treatment as a remediation technique at hazardous waste sites.     

An evaluation of the role of risk-based decision-making in a former manufactured gas plant site remediation

Environmental remediation decisions are driven by the need to minimize human health and ecological risks posed by environmental releases. The Risk Assessment Guidance for Superfund Sites enunciates the principles of exposure and risk assessment that are to be used for reaching remediation decisions for sites under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Experience with remediation management under CERCLA has led to recognition of some crucial infirmities in the processes for managing remediation: cleanup management policies are ad hoc in character, mandates and practices are strongly conservative, and contaminant risk management occurs in an artificially narrow context. The purpose of this case study is to show how a policy of risk-based decision-making was used to avoid customary pitfalls in site remediation. This case study describes the risk-based decision-making process in a remedial action program at a former manufactured gas plant site that successfully achieved timely and effective cleanup. The remediation process operated outside the confines of the CERCLA process under an administrative consent order between the utility and the New Jersey Department of Environmental Protection. A residential use end state was negotiated as part of this agreement. The attendant uncertainties, complications, and unexpected contingencies were overcome by using the likely exposures associated with the desired end state to structure all of the remediation management decisions and by collecting site-specific information from the very outset to obtain a detailed and realistic characterization of human health risks that needed to be mitigated. The lessons from this case study are generalizable to more complicated remediation cases, when supported by correspondingly sophisticated technical approaches.     

Control Technologies for Remediation of Contaminated Soil and Waste Deposits at Superf und Lead Battery Recycling Sites

This paper primarily addresses remediation of contaminated soils and waste deposits at defunct lead-acid battery recycling sites (LBRS) via immobilization and separation processes. A defunct LBRS is a facility at which battery breaking, secondary lead smelting, or both operations were performed for the primary purpose of reclaiming lead from spent lead-acid batteries. Metallic lead and lead compounds are generally the principal contaminants of concern in soils and waste deposits (i.e., buried, piled, landfilled waste) at these sites. Other metals (e.g., cadmium, copper, arsenic, antimony, and selenium) are often present at LBRS, but usually at much lower concentrations than lead and often present below hazardous concentrations. This article is primarily based on experience gained from: (1) Superfund site investigation, removal, and remedial actions, and (2) development and demonstration of control technologies under the Superfund Innovative Technology Evaluation (SITE) Program. The primary remedial options for lead contaminated soils and waste deposits include: (1) no action, (2) off-site disposal, (3) containment, (4) immobilization, (5) separation with resource recovery, and (6) separation without resource recovery. In spite of the toxicity of lead at low concentrations, the relative immobility of lead and site-specific risk assessments can still result in the selection of no action or containment remedies. Solidification/stabilization of lead-contaminated soils has been implemented at three Superfund sites and is the selected remedy at several others. Separation technologies (e.g., screening, extraction) are attractive because, if successful, they actually remove the contaminant from the environmental media. Separation technologies also offer the possibility that a valuable product (e.g., lead, plastic, energy) can be recovered, but careful consideration of economic and technical factors are required. Compared to the implementation of containment and solidification I stabilization remedies, separation technologies tend to be relatively novel, complex, and costly.     

1990 Update of the U.S. Environmental Protection Agency’s SITE Emerging Technology Program

The Superfund Amendments and Reauthorization Act of 1986 (SARA) directed the U.S. Environmental Protection Agency (EPA) to establish an Alternative/Innovative Treatment Technology Research and Demonstration Program. The EPA’s Office of Solid Waste and Emergency Response and the Office of Research and Development established a program called the Superfund Innovative Technology Evaluation (SITE) Program to accelerate the development and use of innovative cleanup technologies at hazardous waste sites. The SITE Program comprises of five areas: the Demonstration Program, the Emerging Technology Program, the Measurement and Monitoring Technologies Development Program, the Innovative Technologies Program, and the Technology Transfer Program.

This paper discusses the Emerging Technology Program (ETP) that supports the development of technologies that have been successfully tested at bench-scale level. Before a technology can be accepted into the Emerging Technology Program, sufficient data must be available to validate its basic concepts. The ETP enters into a co-funding effort with developers for a one- or two-year effort. Developers are responsible for contributing financial support and conducting the developmental research. After development and data collection, the technology’s performance is documented and a report is prepared, which may include recommendations for further developing the technology. If test results are encouraging, a technology may proceed with approval to a field demonstration.

The purpose of this article is to provide the reader with (1) an introduction to the Emerging Technology Program (2) an understanding of how the program operates (3) a summary of those technologies currently being tested and evaluated under the program and (4) information on how to apply to the program.     

A Comparison of Organic Emissions from Hazardous Waste Incinerators Versus the 1990 Toxics Release Inventory Air Releases

Incineration is often the preferred technology for disposing of hazardous waste and remediating Superfund sites. The effective implementation of this technology is frequently impeded by strong public opposition to hazardous waste incineration (HWI). One of the reasons cited for this opposition is the perception that the emission of organics pose an unreasonable threat to human health. While numerous risk assessments for these facilities have demonstrated that the risks from the inhalation of HWI emissions are very low, this has not totally allayed some of the concerns. In order to put organic emissions in perspective, the mass of these emissions from the incineration of hazardous waste on a national scale has been estimated using “reasonable worst-case” assumptions and compared to the 1990 Toxics Release Inventory (TRI) air releases. Comparisons were made for 15 carcinogenic organic compounds and 17 non-carcinogenic organic compounds. Ratios for all but one of these compound-specific HWI emissions to their corresponding TRI air releases ranged from 0.0003 to 0.678 percent. The total mass emissions (110.5 tons) of all 32 specific organics from HWIs was less than 0.03 percent of the corresponding 1990 TRI air releases (431,586 tons).     

Alternating Current Electrocoagulation for Superfund Site Remediation

Abstract

The Superfund Innovative Technology Evaluation (SITE) Emerging Technology (ET) Program, authorized under the Superfund Amendments and Reauthorization Act (SARA) of 1986, implements the goal of the SITE Program to promote, accelerate the development of, and make commercially available alternative innovative treatment technologies for use at Superfund sites.

Under this program, the technical and economical feasibility of alternating current electrocoagulation (ACE) developed by Electro-Pure Systems, Inc., was evaluated for a two-year period. ACE is an electrochemical technology where highly-charged aluminum polyhydroxide species are introduced into aqueous media for the removal of suspended solids, oil droplets and soluble ionic pollutants. ACE can break stable aqueous colloidal suspensions of up to 10 percent total solids and stable emulsions containing up to 5 percent oil.

Major operating parameters have been defined for different classes of effluents based on experimental results using complex synthetic soil slurries and metals. Test results indicate that ACE produces aqueous and solid separations comparable to those produced by chemical flocculent additions, but with reduced filtration times and sludge volumes. The technology has application where removal of soluble and suspended pollutants from effluents is required, and in the recovery of fine-grained products from process streams. The technology, however, has not yet been demonstrated at full-scale for Superfund site remediation. The principal results of the SITE research program, and results of ACE treatment on some different classes of industrial effluents not part of the SITE Program, are summarized.     

A review of the Texas,USA San Jacinto Superfund site and the deposition of polychlorinated dibenzo-p-dioxins and dibenzofurans in the San Jacinto River and Houston Ship Channel

The San Jacinto River (SJR) waste pits that lie just under the 1–10 overpass in eastern Harris County east of Houston, Texas, USA, were created in the 1960s as dumping grounds for paper mill waste. The deposition of this waste led to accumulation of highly toxic polychlorinated dibenzo-p-dioxins and dibenzofurans (PCCDDs/PCDFs) over the course of several decades. After abandonment, the waste material eventually became submerged under the waters of the SJR, resulting in widespread environmental contamination that currently constitutes a significant health concern for eastern Harris County communities. The original waste pits were rediscovered in 2005, and the San Jacinto waste site is now a designated EPA superfund site. The objective of this review then is to discuss the history and current state of containment around the San Jacinto waste pits and analyze spatial and temporal trends in the PCDD/PCDF deposition through the SJR system from the data available. We will discuss the current exposure and health risks represented by the Superfund site and the SJR system itself, as well as the discovery of liver, kidney, brain (glioma), and retinoblastoma cancer clusters in eastern Harris County across multiple census tracts that border the Superfund site. We will also cover the two primary management options, containment versus removal of the waste from the Superfund and provide recommendations for increased monitoring of existing concentrations of polychlorinated waste in the SJR and its nearby associated communities.     

Allocation by Contribution to Cost and Risk at Superfund Sites

Because there is no specific legislative or regulatory guidance, there is no “right” way to allocate liability at Superfund sites. Allocation based on the cost of a remedy, and allocation based on the need for a remedy, i.e. risk-based allocation, represent two possibilities. Other allocation schemes can be located between these two philosophical poles. When waste streams and environmental impacts are qualitatively similar, allocation based solely on costs may make the most sense. When one or more potentially responsible parties (PRPs) have qualitatively different wastes or impacts, an allocation scheme based on both contribution to cost and to risk may be able to incorporate all PRPs. In any case, dissident PRPs, whose contribution to remedy costs is large but whose contribution to risk is small, may find satisfaction in the courts where there is precedent for risk-based allocation.     

Allocation by Contribution to Cost and Risk at Superfund Sites

Because there is no specific legislative or regulatory guidance, there is no "right" way to allocate liability at Superfund sites. Allocation based on the cost of a remedy, and allocation based on the need for a remedy, i.e. risk-based allocation, represent two possibilities. Other allocation schemes can be located between these two philosophical poles. When waste streams and environmental impacts are qualitatively similar, allocation based solely on costs may make the most sense. When one or more potentially responsible parties (PRPs) have qualitatively different wastes or impacts, an allocation scheme based on both contribution to cost and to risk may be able to incorporate all PRPs. In any case, dissident PRPs, whose contribution to remedy costs is large but whose contribution to risk is small, may find satisfaction in the courts where there is precedent for risk-based allocation.     

1992 Update of U.S. EPA’s Superfund Innovative Technology Evaluation (SITE) Emerging Technology Program

The Superfund Innovative Technology Evaluation (SITE) Emerging Technology Program (ETP) has encouraged and financially supported further development of bench- and pilot-scale testing and evaluation of innovative technologies suitable for use at hazardous waste sites for five years. The ETP was established under the Superfund Amendments and Reauthorization Act (SARA) of 1986. The ETP complies with the goal of the SITE Program to promote, accelerate and make commercially available the development ofalternative /innovative treatment technologies for use at Superfund sites.

Technologies are submitted to the ETP through yearly solicitations for Preproposals. Following a technical review, chosen applicants are asked to submit a detailed project proposal and a cooperative agreement application that requires Developer I EPA cost sharing. EPA co-funds selected Developers for one to two years. Second-year funding requires documentation of significant progress during the first year. Facilities, equipment, data collection, performance and development are monitored throughout the project. The U. S. Department of Energy (DOE) and the U. S. Air Force (USAF) are participants in the ETP. DOE has co-funded ETP projects since 1990 and the USAF since 1991.

A primary goal of the ETP is to move developed technologies to the field-demonstration stage. Therefore, a developer may be considered for participation in the SITE Demonstration Program provided performance in the ETP indicates the technology is field-ready for demonstration and evaluation.

Six technology categories: biological, chemical, materials handling, physical, solidification/ stabilization and thermal, are presently in the ETP.

Technologies of primary interest to EPA are those that can treat complex mixtures of hazardous organic and inorganic contaminants and provide improved solids handling and/orpretreatment.

An account of the background and progress of the ETP’s first five years is presented in this paper. Technologies currently in the ETP, including those selected from the fifth (EOS) solicitation, are noted, and developers, along with EPA Project Managers, are listed.