vvEPA
United States
Environmental Protection
Agency
Office of Emergency and
Remedial Response
Washington DC 20460
Office of Research and
Development
Municipal Environmental Research
Laboratory
Cincinnati OH 45268
Superfund
EPA-540/2-84-002a Mar. 1984
Summary Report:
Remedial Response at
Hazardous Waste
Sites
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EPA-5i(0/2-8'4-002a
March
SUMMARY REPORT:
REMEDIAL RESPONSE AT
HAZARDOUS WASTE SITES
MUNICIPAL ENVIRONMENTAL RESEARCH LABORATORY
OFFICE OF ENVIRONMENTAL ENGINEERING AND TECHNOLOGY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
and
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
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$•-.£.w. '••'; Libra-y
££§ J\o.iit!i De:--iborn Street
Chicago, iiiinois 60504
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NOTICE
The information in this document has been funded wholly or in part by
the United States Environmental Protection Agency under Contract Number
68-03-3113, Task 39-3 and Cooperative Agreement Number CR 809392 to JRB
Associates and the Environmental Law Institute. It has been subject to the
Agency's peer and administrative review, and it has been approved for publi-
cation as an EPA document.
U,S. Envhormentef Prefactton Agency
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ABSTRACT
In response to the threat to human health and the environment posed by
numerous uncontrolled hazardous waste sites across the country, new remedial
action technologies are evolving and known technologies are being retrofitted
and adapted for use in cleaning up these sites. This report identifies and
assesses the various types of site response activities which have been
implemented, are in progress, or have been proposed to date at uncontrolled
hazardous waste sites across the United States. This was accomplished through
the combined efforts of JRB Associates (JRB) and the Environmental Law
Institute (ELI). A nationwide survey was conducted in which 395 uncontrolled
hazardous waste sites across the U.S. were identified where some form of
remedial action was planned, was presently ongoing, or has been completed.
Each of these sites was assessed and the results are presented herein. Based
on these survey findings, JRB and ELI selected a total of 23 sites for which
detailed case study investigations have been conducted. Case study reports
for each of the 23 sites are presented. These reports include extensive
discussions of the remedial responses at each of the 23 sites with respect to
technology, cost, and institutional framework. JRB and ELI maintained a
specific focus for each of these parameters. JRB's primary focus in these
investigations was to assess site response activities from a geotechnical and
engineering perspective, while ELI's main objective was to assess these
remedial actions from a cost and institutional perspective. Additionally,
technological, cost, and institutional data for the 23 case study sites are
summarized in several user guidance indices.
This report was submitted in fulfillment of EPA-ELI Cooperative Agreement
No. CR 809392 by the Environmental Law Institute and fulfillment of Contract
No. 68-03-3113, Task 39-3 by JRB Associates under the sponsorship of the U. S.
Environmental Protection Agency.
111
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CONTENTS
Abstract iii
Figures v
Tables vi
Abbreviations and SyuiLols viii
Acknowledgments ix
1. Introduction 1
2. Survey and Case Study Methodology 3
3. Nationwide Survey Results and Technologies
of Site Response 9
4. Cost of Response 23
5. Planning and Management of Responses 64
6. Findings and Recommendations 84
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SECTION 1. INTRODUCTION
The Solid and Hazardous Waste Research Division USEPA (Cincinnati, OH)
is involved in the research and development of existing and emerging
technologies for use in the remediation of uncontrolled hazardous wastes
released to the environment. As part of this effort, a two-phased study was
conducted involving a nationwide survey of uncontrolled hazardous waste sites
and detailed case studies on selected sites. The objective of the nationwide
survey was to identify and examine and quantify various types of remedial
response actions wich have been implemented, proposed, or are in progress at
sites throughout the country.
From the results of the survey, sites were selected for which detailed
case studies are prepared. These case studies analyze response actions from
the perspectives of technology, cost, planning and management. The case
studies documents the specific reasons for the success or failure of applied
response action, and determines the limitations and applicability of these
technologies, cost control methods, and response planning efforts to other
sites.
The survey and case study reports are intended for use by USEPA Regional
Officials, State Agencies, industry and commerce, and local authorities
involved in selection, evaluation and design of remedial response actions.
The data will be useful in the following ways:
provide an understanding of the remedial process so that future
response actions can be developed and implemented in the most
efficient way possible
provide a standard of comparison when evaluating or deciding on
response actions for sites with similar problems
identify cleanup technologies wich may warrant further research
quantify and document the extent and type of remedial response
actions on a nationwide basis
developing data to aid in cost recovery action promulgated by EPA.
Section 2 describes the methodology used for the nationwide survey, and
discusses how the sites were chosen for detailed case studies. The results
of the nationwide survey are presented and analyzed in Section 3. Section 4
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and 5 focus more specifically on the case studies and analyze the costs of
responses and the institutional frameworks for decision making, respectively,
Section 6 contains the findings and recommendations concerning the issues
discussed in Sections 3, 4, and 5.
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SECTION 2
SURVEY AND CASE STUDY METHODOLOGY
2.1 SURVEY METHODOLOGY
The purpose of the survey was to compile a list of completed and
on-going remedial response actions at uncontrolled hazardous waste sites
across the United States, including landfills, surface impoundments, drum
storage facilities, incinerators, and deep well injection sites. This
information was compiled systematically through:
• Reviewing in-house literature
• Reviewing data from EPA Municipal Environmental Research Laboratory
(MERL) and Office of Emergency and Remedial Response (OERR)
• Contacting appropriate EPA Headquarters and Regional personnel
• Contacting state and local environment and health agency officials
• Contacting Department of Defense officials knowledgeable about
restoration work at military bases
• Contacting representatives of trade associations involved in manage-
ment of hazardous materials and/or spill responses
• Contacting members of private industry specializing in remedial
action design and implementation.
A total of 395 uncontrolled hazardous waste facilities across the
country were identified at which site responses were either completed, in
progress, or in the planning stages. Each of these sites was evaluated
according to various criteria, including: the type of hazardous waste
management, affected media, type of remedial action, status of remedial
action, ease of access for case studies; etc. Sample evaluation summary
sheets are shown in Figure 1.
Several data sources were reviewed to develop the list of sites for
potential case study analysis. During the data collection activity an effort
was made to focus on sites where remedial actions had begun or were in the
design stage. Existing data sources included:
• The 1981 survey of remedial action site (EPA Publication No.
430/9-81-05)
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• The Hazardous Waste Site and National Priorities List published by
EPA on December 20, 1982
• Publications such as the Groundwater Newsletter, Hazardous Waste
Report, Hazardous Materials Intelligence Report, Environmental
Science and Technology, and Waste Age
• EPA Field Investigation Team Reports.
Once the data review was completed, a telephone review was conducted in
order to verify and add to the data already obtained, as well as to identify
new sites. Knowledgeable parties contacted included USEPA Regional Emergency
Response coordinators, Regional Land Disposal Branch Personnel, Regional and
State On-scene Coordinators, consulting contractors and State and local
officials.
Department of Defense (DoD) officials with knowledge of restoration work
at military bases were also contacted. The results of the DoD survey effort
indicated that remediation activities within the armed forces are in the
initial stages. The DoD has established a phased approach for conducting
site restoration activities within all branches of the Armed Forces.
Presently, each branch of DoD is proceeding at different rates relative to
the phase program, and in most cases have conducted initial site assessments
but have not initiated site restoration activities.
At this point, the survey methodology had accounted for those
uncontrolled hazardous waste sites at which there was some form of public
involvement for addressing site response, hence public officials had been
able to provide the information. An attempt was made to pursue information
regarding private industry site clean-up which had not been provided through
the previous literature review and telephone survey. This involved con-
tacting trade associations, industrial officials, cleanup firms and
consultants involved in remedial design. Client confidentiality agreements
and the sensitivity of many of these cases prevented full cooperation in
identifying private industry sites and documenting remedial response action
at sites which were identified.
2.2 CASE STUDY SITE SELECTION
On the basis of the survey results, 23 sites were selected for detailed
case study investigations. These sites are listed in Table 1. The criteria
used to select candidate sites for detailed case study analysis included:
• Availability, accessibility, and completeness of remedial action cost
and engineering data
• Availability for field survey activities
• Type of remedial action technology implemented, so that a range of
remedial action techniques was investigated
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TABLE 1. SITF? CHOSEN INITIALLY FOR CASE STUDY INVESTIGATION
Site Name
Anonymous Site A
Anonymous Site B
Anonymous Site C
Biocraft
*Chemical Metals Industry
Chemical Recovery
*College Point Site
*Fairchild Republic Co.
General Electric
*Gallup Site
Goose Farm
H & M Drum
Houston Chemical Co.
Howe Chemical
*Marty's CMC
Mauthe
Occidental Chemical Co.
PP&L/Brodhead Creek
*Quanta Resources
Richmond Sanitary Service
Trammell Crow Co.
*University of Idaho
Vertac Chemical Corp.
Location
Northern San Francisco Bay Area, CA
Northern California
DePere, WI
Waldwick, NJ
Baltimore, MD
Romulus, MI
Queens, NY
Hagerstown, MD
Oakland, CA
Plainfield, CT
Plumsted, NJ
N. Dartmouth, MA
Houston, MO
Minneapolis, MN
Kingston, MA
Appleton, WI
Lathrop, CA
Stroudsburg, PA
Queens, NY
Richmond, CA
Dallas, TX
Moscow, ID
Jacksonville, AR
*Case studies prepared by ELI only
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• Type of waste management practice, so that a wide range of
technologies common to hazardous waste management was studied
• Whether response was conducted by public or private party
• Types of waste and contaminants present at the facility to ensure
that a variety of waste streams and pollutants was included
• Hydrogeologic setting, so that a variety of settings was represented
• Geographic locations to provide a nationwide distribution of sites.
Once sites were collected for detailed case study, field visits were
made to gather additional information and to meet with the appropriate
Federal, State and private parties and cleanup contractors in order to ensure
the development of accurate and complete case history information.
Engineering reports, contracts, feasibility studies, and invoices relating to
the clean-ups were examined during preparation of each case study. A final
case study report for each site is included in Chapter II and follows the
format shown below:
SITE NAME, LOCATION
INTRODUCTION
Background
Synopsis of Site Response
SITE DESCRIPTION
Surface Characteristics
Hydrogeology
WASTE DISPOSAL HISTORY
DESCRIPTION OF CONTAMINATION
PLANNING THE SITE RESPONSE
Initiation of Response
Selection of Response Technologies
Extent of Response
DESIGN AND EXECUTION OF SITE RESPONSE
COST AND FUNDING
Source of Funding
Selection of Contractors
Project Costs
PERFORMANCE EVALUATION
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SECTION 3
NATIONWIDE SURVEY RESULTS AND TECHNOLOGIES OF SITE RESPONSE
The survey identified 395 hazardous waste sites across the United States
where as of December, 1982 some form of remedial activity is planned, is
presently ongoing, or has been completed. The survey results are summarized
for the 395 sites in Tables 2 through 7. Individual assessments for each of
the 395 identified sites are contained in Appendix A.
Tables 2A and 2B show the geographic distribution of the remedial action
sites, by state and by EPA Region. Five states: Florida, Michigan, New
Jersey, New York, and Pennsylvania account for approximately one-third of all
sites identified during the survey. These five states also have the largest
number of sites eligible for Superfund monies based on the National
Priorities List (NPL). According to that list, however, sites in these five
states account for 42 percent of the eligible sites nationwide. This
difference in percentage of total sites is due to the fact that our survey
only considered Superfund sites at which remedial actions were ongoing or
completed while the NPL lists all sites eligible for cleanup under Superfund.
The large number of hazardous waste sites located in these five states
is attributed to the fact that these states are highly industrialized. In
the past, it was both economical and convenient to dispose of hazardous
wastes near the generating source. These states have also been very active
in identifying sites and initiating remedial response actions.
Our survey did not identify any sites in Alaska, Hawaii, Nebraska,
Nevada or Vermont at which remedial actions were ongoing or completed.
However, it should be pointed out that Vermont and Nebraska do have sites
which appear on the NPL but remedial response actions have not progressed to
the point where they could be included in the survey.
Based on the survey results, Region V had the largest number of sites,
followed by Region IV and Region II. According to the NPL the number of
sites in these three regions are as follows:
Region Number of Sites % of Total
V 144 26
II 123 23
IV 67 12
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TABLE 2A. STATE LOCATION OF REMEDIAL ACTION SITES IN 1980 AND 1982
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
D.C.
Delaware
Florida
Georgia
Hawai i
Idaho
111 inois
Ind iana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Miss iss ippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Number of Sites
(1982)
4
0
6
4
11
5
13
1
7
27
5
0
2
18
10
3
3
10
11
4
5
16
24
10
2
11
5
0
0
7
25
3
26
10
8
9
2
2
27
8
7
1
10
Percent of Total
Identified Nationwide
1.0
0
1.5
1.0
2.7
1.3
3.3
0.3
1.8
6.8
1.3
0
0.5
4.6
2.5
0.8
0.8
2.5
2.7
1.0
1.3
4.1
6.1
2.5
0.5
2.7
1.3
0
0
1.8
6.3
0.8
6.6
2.5
2.0
2.3
0.5
0.5
6.8
2.0
1.8
0.3
2.5
10
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TABLE 2A. STATE LOCATION OF REMEDIAL ACTION SITES
IN 1980 AND 1982 (Continued)
State
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Number of Sites
(1982)
9
2
0
5
6
3
7
1
395
Percent of Total
Identified Nationwide
2.3
0.5
0
1.3
1.6
0.8
1.8
0.3
100%
TABLE 2B. GEOGRAPHIC DISTRIBUTION OF REMEDIAL
ACTION SITES BY EPA REGION
EPA Region
(States in Region)
I (CT, MA, ME,
II (NJ, NY)
III (D.C. , DE, MD
IV (AL, FL, GA,
V (IL, IN, MI,
VI (AR, LA, NM,
VII (IA, KS, MO,
VIII (CO, MT, ND,
IX (AZ, CA, HI,
X (AK, ID, OR,
NH, RI, VT)
, PA, VA, WV)
KY, MS, NC, SC, TN)
MN, OH, WI)
OK, TX)
NE)
SD, UT, WY)
NV)
WA)
Number of Sites
48
51
48
75
78
29
17
22
17
10
395
Percent
of Total
12.2
12.9
12.2
18.9
19.7
7.3
4.3
5.6
4.3
2.5
100%
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*NOTE:
TABLE 3. WASTE MANAGEMENT PRACTICES EMPLOYED
AT IDENTIFIED REMEDIAL ACTION SITES
Percentages do not total 100 because a facility may use more
than one method.
Waste Management
Practices
Landfill
Illegal Dump
Tank/Drum Storage
Surface Impoundments
Injection Wells
Inc inerator
Spi 1 Is/Leaks
Combined Practices
Unknown or Other
Number of Sites
128
54
85
148
9
13
42
84
48
Percent of
Total 395 Sites
32.4
13.6
21.5
37.5
2.3
3.3
10.6
21.2
12.2
TABLE 4. ACTIVITY STATUS OF IDENTIFIED REMEDIAL ACTION SITES
Site Status
Act ive
Abandoned or Inactive
(includes spill incidents)
Unknown Status
*Superfund Priority Sites
Number of Sites
64
226
105
395
208
Percent of Total
395 Sites
16.2
57.2
26.5
100%
53%
12
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*Note:
TABLE 5. CONTAMINATED MEDIA (TYPE OF POLLUTION)
REPORTED AT REMEDIAL ACTION SITES
Percentages do not total 100 since many sites reported more than
one form of pollution.
Contaminated Medium/
Type of Pollution
Ground Water
Surface Water
Soils
Air
Food Chain/Biota
Sediments
Unknown
Number of Sites
268
188
130
70
39
20
55
Percent of
Total 395 Sites
67.8
47.6
32.9
17.7
9.8
5.1
14
13
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TABLE 6. WASTE TYPES/CONTAMINANTS REPORTED AT REMEDIAL ACTION SITES
*Note: Percentages do not total 100 since many sites contain more than
one waste type.
Waste Types/Contaminants
Inorganics
Me t a 1 s
Other Inorganics (e.g.,
cyanide, ammonia, nitrates)
Organics
Pe stic ides/ Herbicides
(e.g., DDT, dioxin)
Hydrocarbons (oil,
fuel, creosote, etc.)
Solvents
Methane Gas
PCBs
Other Organics (e.g., phenols)
or Unspecified Organics
Waste Types
Acids/Caust ics
Waste Sludges
Mining and Milling Wastes
Radioactive Wastes
Explosives
Paints, Pigments, Dyes, Inks
Pharmaceutical
Mixed Waste Types
Unknown/Unreported Waste Types
Number of Sites
116
51
43
59
109
7
51
89
44
59
6
13
8
18
5
146
29
Percent of
Total 395 Sites
29.4
12.9
10.8
14.9
27.6
1.7
12.9
22.5
11.1
14.9
1.5
3.3
2.0
4.6
1.3
36.9
7.3
14
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TABLE 7. RESPONSE TECHNOLOGIES EMPLOYED AT SURVEY SITES
*Note: Percentages do not total 100 since more than one remedial action
technique has been used at many sites.
Remedial Action
Capping/Grading/Revegetation
Surface Water Diversion/Runoff Controls
(including spill containment controls,
e.g., dikes)
Leachate Collection (e.g., underdrains)
Lining (clay or synthetic)
Drum Removal/Recontainerization
Waste/Contaminated Materials Removal
Waste Recovery/Recycling (solvents, metals)
Contaminant Treatment/On-site Treatment
Encapsulation/ Solidification
Ground Water Pumping
Ground Water Containment (e.g., slurry walls)
Ground Water Monitoring
Gas Control
Dredging
Incineration
Other Methods (e.g., new water supply)
Combined Techniques
Unknown (remedial actions planned,
but unspecified)
Number
of Sites
69
34
19
13
55
107
8
66
10
29
17
73
5
5
5
28
126
60
Percent of
Total 395 Sites
17.5
8.6
4.8
3.3
13.9
27.1
2.0
16.7
2.5
7.3
4.3
18.5
1.3
1.3
1.3
7.1
31.8
15.2
15
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Again, the difference in site distribution between the survey and the
NPL is due to the fact that the survey considers sites where remedial actions
are ongoing or completed whereas NPL considers all sites eligible for
Superfund. It has been estimated that for a typical NPL site, the time span
from start of investigation to completion of remedial response will be about
3 to 5 years. Therefore it could be a few years before many of the NPL sites
would be included in a survey of ongoing or completed remedial actions.
Table 3 is a compilation of the various types of documented waste
management practices employed at the sites identified by the survey. These
practices represent the sources of uncontrolled releases of hazardous waste
materials to local environments, and they include spill incidents reported at
the remedial action sites. Waste management practices documented at the 395
remedial action sites include landfilling, drum and tank storage, surface
impoundment treatment and storage, subsurface waste injection, incineration,
illegal dumping, and spills. Most of the remedial response actions are
associated with three waste management technologies: landfilling, surface
impounding and drum storage. This association is to be expected based on the
fact that they have been the most common methods for hazardous waste
disposal. Nearly 40 percent of all sites identified contained some form of
surface impoundments (pits, ponds, lagoons), and one-third of all sites were
characterized as landfill sites. Tank or drum storage activities were
reported for approximately 22 percent of all sites identified. Approximately
14 percent of remedial action sites were characterized as illegal dumps in
the survey literature, however many of those sites reported as landfills or
drum storage areas might legitimately be considered as illegal dump sites.
Over one-fifth of the sites identified during the survey (21 percent)
reportedly used a combination of two or more of the waste management prac-
tices considered in Table 3. A number of these sites, for instance, used
both land disposal methods (landfills, dumps) and drum storage or liquid
waste impoundments to handle hazardous wastes. Spill incidents or leaks
(from storage operations, facility process lines, and transportation
accidents) accounted for approximately 10 percent of all remedial action
sites identified. The use of injection wells or incinerators to dispose of
hazardous wastes was reported at less than five percent of the sites. The
relatively low percentage of these two disposal methods can be attributed to
their limited applicability in treating a broad spectrum of wastes and to
limitations on their use in certain geographic areas.
Table 4 gives a breakdown of the sites in terms of their most recently
reported activity status. Of the 395 remedial action sites identified,
57 percent are reported as inactive or abandoned sites (including spill
sites), while approximately 16 percent are known to be "active" facilities;
facilities with identified owner/operators still engaged in their primary
activities, whether they be chemical manufacturing firms, military bases,
municipal landfills, mining companies, commercial waste management facili-
ties, etc. The actual number of "active" facilities may be far larger than
the number identified in this survey. Many of these sites are owned by
private industries and information on remedial response actions was
considered confidential. Others are located at military bases where remedial
response actions have not progressed to the point that they could be included
in the survey. Over one-fourth (approximately 27 percent) of all remedial
16
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action sites identified lacked sufficient information to determine their
current status. It is likely that most of these 103 sites are inactive or
abandoned waste disposal facilities.
Table 4 also shows that of the 395 remedial action sites, 208 sites
(53 percent) are Superfund priority sites. These sites were drawn from the
proposed National Priority List (NPL) of 418 sites eligible for remedial
actions under Superfund. These 208 sites represent uncontrolled hazardous
waste sites with sufficient data to identify the planned or ongoing remedial
actions at the sites. The main sources of this data for the survey were
Superfund site descriptions published by EPA/OSWER in December, 1982. Of the
400+ NPL sites, 210 lacked sufficient information on planned or ongoing
remedial actions to be included in this survey.
The types of pollution (contaminated media) documented at remedial
action sites are summarized in Table 5. Ground water contamination is the
most common form of pollution reported at the sites, occurring at nearly 70
percent (268) of the remedial action sites. Approximately half of the sites
(nearly 48 percent) have surface water contamination. The prevalence of
surface water and ground water contamination problems can be attributed to
past widespread practices of disposing of wastes in landfills and
impoundments without taking any measures to prevent surface seepage or
leaching into ground water. Soil contamination is the third most prevalent
form of pollution documented at remedial action sites (33 percent of all
sites). Air contamination by methane gas, volatile hazardous compounds, or
other toxic gases is reported at about 18 percent of the survey sites.
Contamination of sediments and food chain media (livestock, fish, crops) is
the least prevalent form of pollution documented at the waste sites. Thus,
the survey reveals that contamination of local water resources which may
serve as public drinking water supplies (on both municipal and residential
scales) continues to be the most critical problem posed by uncontrolled
hazardous waste sites. And it is the protection or clean-up of these ground
water and surface water supplies that is the focus of most site remediation
technologies and strategies.
Table 6 documents the waste types and chemical contaminants which are of
concern at the 395 remedial action sites. Metals (Pb, Zn, Cd, Cu, As, etc.)
represent the single most prevalent class of contaminants, reported as
pollutants at approximately 30 percent (116) of the remedial action sites.
Other inorganic contaminants (e.g., cyanide, nitrates) are reported at
approximately 13 percent of the sites.
Organic chemical contaminants include pesticides and herbicides, hydro-
carbon fuels and oils, solvents, PCBs, and methane gas. Solvents are the
most common organic source of contamination reported at nearly 28 percent of
the identified sites. Organic solvents generally sorb poorly to soils and
leach readily into ground water and are therefore a major cause of the
extensive groundwater contamination problem. Hydrocarbon waste compounds
(especially waste oil and creosote) occur at approximately 15 percent of the
sites. Polychlorinated biphenyls are a problem at nearly 13 percent of the
sites. Pesticide and herbicide compounds (including DDT and dioxin) are
documented contaminants at 11 percent of all sites surveyed. Methane gas
problems are reported at only 2 percent of the remedial action sites.
17
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In terms of general waste types present at remedial action sites, waste
sludges are the most prevalent source of contamination, occurring at almost
15 percent of the sites. Acids and caustic waste types are reported at
11 percent of the sites. Mining wastes, radioactive wastes, explosives,
paint and dye-related wastes, and pharmaceutical wastes are all reported at
less than 5 percent of the sites. Nearly 40 percent of the remedial action
sites contain a combination of two or more waste types or chemical
contaminants, presenting the potential for dangerously incompatible or
undesirable chemical reactions. For instance, co-disposal of acid wastes and
metal-laden wastes is documented at a number of the sites, causing rapid
environmental migration of metals to be a major concern. The presence of
incompatible wastes also greatly complicates the cleanup of waste sites and
often reduces the possible options for remedial actions, particularly those
options involving aqueous or in-situ treatment or incineration.
A wide variety of response technologies have been employed (or are
planned) at the waste sites identified by the survey (see Table 7). The most
commonly implemented remedial action strategy is removal of wastes from the
site. This remediation technique was documented at over one-quarter of all
the sites (41 percent) identified during the survey. It includes such
activities as excavation and off-site transport of contaminated soils and
drums and the removal of dewatered or solidified waste sludges from disposal
sites.
Another widely used site remediation technique is site capping, grading,
and revegetat ion. This includes the construction of clay caps over
landfills, drum burial pits, and dewatered lagoons. It was reported as a
preliminary remedial action or site closure activity at 17 percent of the
sites. Eight percent of the sites used surface water diversion structures
and run-off controls (dikes, berms, trenches, sandbags, etc.) as remedial
actions to contain contaminated site runoff and spills.
On-site treatment (16 percent of all sites surveyed) of wastes has also
been widely used. In most instances, these techniques correlate well with
the high percentage of facilities identified as practicing landfilling, drum
storage, or surface impounding as a waste management method. This
correlation is based on the following factors:
• Most remedial actions to date have been directed at controlling the
immediate threat, i.e. removal of the waste material by landfill and
contaminated soil removal, surface impoundment pumping and removal,
or drum removal.
• Technologies such as grading/capping, surface water diversions,
contaminant removal, and drum removal are in most cases relatively
unsophisticated and economic remedial activities when compared with
other remedial options.
• In the natural order of implementing remedial actions, removal of the
contaminant source is the most likely initial step in performing a
staged facility cleanup.
18
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• Complete removal of the source of contamination is the most effective
and direct method of reducing or eliminating continued releases of
contaminants to the environment.
This category of response actions includes the use of leachate treatment
systems, the collection and treatment (via carbon filtration, aeration, etc.)
of contaminated well water and surface waters, and in-situ neutralization of
impounded acidic or caustic wastes or contaminated soils. These technologies
have been widely used in treating industrial wastes in the past. Consider-
able bench and pilot scale testing has been conducted over the past 10 years
to adapt these treatment methods for treating highly variable leachates and
to develop mobile units for use in the field.
Groundwater contamination controls including pumping and use of ground-
water containment structures such as slurry cut-off walls, and clay-filled
trenches have been used at nearly 12 percent of the sites. Pumping accounts
for the overwhelming majority of groundwater contamination controls.
Other techniques such as gas control measures, leachate collection
drains, encapsulation/solidification and dredging have been used at
relatively few of the sites.
Reasons for the more restricted use of these methods include:
• Constraints based on site specific conditions such as waste type,
area of contamination, and media contaminated
• Present level of technological development relative to proven field
use and successful application in real world situation.
For 15 percent of the sites identified in the survey, specific
information on planned remedial actions were unavailable.
A combination of two or more of the individual remedial action tech-
nologies shown in Table 7, such as drum removal followed by site capping and
ground water monitoring, has been documented as the remedial action strategy
at nearly one-third of all the sites surveyed. The 23 sites for which case
studies have been prepared parallel these results; at each site a combination
of response technologies has been used. These are, of course, dependent upon
the site characterization as well as the type of contaminants present. The
chosen technologies are in some instances an historical function in that they
might have been the most highly developed technology known to exist at the
time the remedial response was implemented. The details regarding the site
response technologies are discussed in the individual case studies in Chapter
II. A summary of the response actions taken at the 23 case study sites is
1 is ted in Table 8 .
19
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TABLE 8. SUMMARY OF RESPONSE TECHNOLOGIES
EMPLOYED AT CASE STUDY SITES
Site Name and Location
Response Technologies
Anonymous Site A
San Francisco Bay Area, CA
dike reinforcement, ASPEMIX
cut-off walls, interceptor
trench , dams
Anonymous Site B
Northern California
interceptor trench and sump, carbon
treatment, basin dewatering and
capping, upgraded drainage system
Anonymous Site C
DePere, WI
runoff control via surface drain
to surface impoundment, ground water
interceptor trench
Biocraft
Waldwick, NJ
ground water extraction., biological
treatment, reinjection, in-situ
aerat ion
*Chemical Metals Industries
Baltimore, MD
drum and tank removal, bulk liquid
pumping, soil removal, treatment and
disposal, asphalt and clay capping
Chemical Recovery
Romulus, MI
asphalt cut-off wall, underdrain
system, drain removal, dredging,
lagoon waste removal
*College Point Site
Queens, NY
pumping waste oil into tanks,
solidification with fly ash, filtering
of lagoon water, transport and
disposal of contaminated materials
*Fairchild Republic Co.
Hagerstown, MD
excavation and disposal of contaminated
soil, surface water diversions, clay
cap, grading, revegetation
General Electric
Oakland, CA
Trench drain system, on-site PCB
oil/water separation, contaminated
soil removal, clay capping
*Gallup Site
Plainfield, CT
excavation and removal of drums and
contaminated materials, in-situ
lime treatment
(continued)
*Case studies performed by ELI only.
20
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TABLE 8. (continued)
Site Name and Location
Goose Farm
Plumstead, NJ
H & M Drum
N. Dartmouth, MA
Houston Chemical Co.
Houston, MO
Howe Chemical
Minneapolis, MN
*Marty's CMC
Kingston, MA
Mauthe
Apple ton, WI
Occidental Chemical Co.
Lathrop, CA
PP&L/Brodhead Creek
Stroudsburg, PA
*Quanta Resources
Queens, NY
Richmond Sanitary Service
Richmond, CA
Response Technologies
wellpoint collection/spray irrigation/
recharge system, ground water carbon
adsorption and aeration, drum
excavation, segregation, off-site
disposal
excavation of drums and contaminated
soil, soil landspreading, interceptor
trench, sorbent pillows, drum
segregation, off-site disposal
pond skimming, PCP/oil recovery,
carbon treatment, dredging
pesticide-contaminated debris removal,
frozen materials thawed in lined
lagoon, landspreading liquid wastes,
landf arming soils, ground water
extraction wells to POTW
excavation, aeration, capping
contaminated soils removal, leachate
collection trench and treatment system
ground water extraction, carbon
treatment, aquifer reinjection,
excavation and recapping of disposal
ditches and lagoon
filter fences in stream, cement-
bentonite slurry wall, contaminated
soils excavation, recovery wells for
coal tar, ground water monitoring
soil removal, solidification, in-situ
wastewater treatment
bay mud subsurface barrier wall
dike construction to prevent flooding
*Case studies prepared by ELI only.
(continued)
21
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TABLE 8. (continued)
Site Name and Location
Response Technologies
Trammell Crow Co.
Dallas, TX
*University of Idaho
Moscow, ID
Vertac Chemical Corp.
Jacksonvilie, AR
waste oil sludge
cement kiln dust
of solidified sludge
solidification by
on-site landfilling
excavation and disposal of contaminated
materials, backfilling, covering with
topsoil and seed
_ i
landfill capping with on-site clay '
and revegetation of soil cover, clay '
barrier walls, drum repacking, j
contaminated soil excavation and
containerization, asphalt/clay covering
of spill area, basin dewatering and
sludge solidification, interceptor
trench, herbicide waste recycling
*Cnse studios prepared by ELI only.
22
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SECTION 4.
COST OF RESPONSES
INTRODUCTION
Documenting expenditures related to the responses at the 23 case study
sites was a major focus of the research. This section presents the data in
various summarized forms and draws generalizations, to the extent possible, on
the actual costs of specific tasks and the factors that affected them. The
intent here is to report an illustrative range of costs based on actual
expenditures so that they can be compared to future cost models. To this end,
remedial response cost estimates from an EPA engineering costing model
(Rishel, H.L. et al., 1982) are included in some of the tables for comparison
purposes. This engineering cost model uses standard Construction Cost Manuals
(Means and Dodge manuals) to estimate component and unit operations of several
hypothetical landfill and impoundment scenarios in mid-1980 dollars.
The cost of remedial actions varied greatly depending on the site
characteristics. The nature of the contamination, hydrogeological factors,
and the perceived level of risk to humans and the environment, were found to
influence the costs of responses, even among similar remedial technologies.
Estimating the unit costs of remedial actions probably will never acquire the
precision of other pollution control measures, such as emission reduction and
wastewater treatment, since the uniqueness of each site and the uncertainties
associated with most remedial actions hinder generalizations about unit
costs. However, the importance of effectively managing remedial work at the
nation's uncontrolled sites and the probable scale of future remedial opera-
tions calls for the development of some efficient method of estimating these
costs. The results here can serve that purpose.
The results of these case studies can be best used with an understanding
of the site characteristics and of the limitations of the results. To address
the former concern, site characteristics are included in many of the summary
tables and charts along with the costs. Of course, for a more complete
understanding of the circumstances in which expenditures occurred, it is
essential to read the individual case studies. Meanwhile, a careful reading
23
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of the "Methodology" sub-section below will provide a general understanding of
the factors underlying the data limitations, such as levels of aggregation,
sources of information, and quality of documentation.
This remaining section covers the following topics:
Methodology
Results
total cost by site
comparative cost by technology
operation and maintenance costs
comparison of costs of publicly-funded responses
with privately-funded responses
METHODOLOGY
Site Selection
The site selection process is described in Section 3 of this chapter.
Collection of Data
Cost data were generally collected in three stages:
1. Interview preparation
2. Interview and file search
3. Follow-up inquiry and data refinement.
Before the site visits, readily available cost data were obtained through
the mail in preparation for interviews with response managers. Researchers
also used available information about work performed at the sites to prepare
questions and organize the work into discrete unit operations and component
tasks.
Interviews and file searches during the site visits were the primary
sources of cost data. Invoices, memoranda, letters, proposals and contracts
were photocopied. This information was supplemented by interviews with
participating personnel who recalled numbers that confirmed invoices, helped
aggregate related activities, or related dates and contractors with response
activities.
The last phase of data collection was the site visit follow-ups. Phone
calls and correspondence were used to refine and verify the data. Again, site
contacts were helpful in describing the organization and sequence of events
and tasks, and specifying what was or was not included in contractors'
invoices.
24
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Categorization of Data
The data base resulting from researching State and Federal agencies,
contractors and corporations consists of three forms:
1. Invoices
2. Reports, memoranda and correspondence
3. Interviews.
Cost data were constructed into functional categories by two primary
means and supplemented with a variety of sources. The categorization method
depended on the type of data available from the source. The first method was
the aggregation and summing of specific costs on invoices to determine the
total cost of particular operations, such as slurry wall construction.
Component costs of the total are detailed in the case study text. Unit costs
for items such as ton of waste disposal or square foot of slurry walls were
multiplied with the volumes given in as-built engineering reports to verify
the total task costs. Where unit costs were unstated, they were derived by
dividing the total cost of a particular task by the quantity of material dealt
with.
The second categorization method was the correlation of weekly invoice
summaries of general cost categories with the activity occurring during that
period to estimate the cost of an operation. Weekly invoice summaries were
often categorized by items such as labor, equipment, transportation and
disposal. These categories were broken down according to each operation
contributing to the invoice and the proportion of the weekly total used^for
that operation. For example, excavation might have been performed for 100% of
a given week, and 50% of the labor and 30% of the equipment were devoted to
this operation, with the remainder devoted to analytical work. The cost would
be further broken down if the daily reports showed that transportation and
disposal occurred during two of the seven days included on the invoice for
which XX labor and equipment were used for loading and analysis.
These invoice based methods were supplemented with other sources such as
interviews, reports, correspondence and contracts. When aggregating specific
invoice items, particular item costs were sometimes determined by referring to
other file material or the site contacts. The breakdowns of general invoice
summaries according to daily reports were often refined by interviewing or
corresponding with site contacts about the execution and timetable for
particular operations. Private response in-house costs were estimated, when
available, by totalling company time sheets or other work records for the
appropriate project. Private in-house costs were the most difficult cost data
to obtain, usually because of the lack of available records. Data on in-house
costs of government responses were sometimes available because such records
were kept for cost-recovery purposes.
25
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RESULTS
Total Cost By Site
The total cost of each of the 23 case study site responses is shown in
Table 9, and the frequency distribution of the totals is shown in Figure 2.
The average cost per site was about $1.5 million, but the standard deviation
of $2.3 million and a standard error of $0.48 million shows a wide variation
in the costs. The total site response costs ranged from $23,000 to $10.3
million. This range represents a difference of a factor of 448. Seventeen of
the 23 responses (74%) cost between $200,000 and $2.0 million. The problem
and the primary response at each site are listed in Table 9, with the total
cost and the data to describe the most significant site responses
characteristics. The relationship between the costs and the site
characteristics is detailed in the individual case studies and is summarized
in the "Cost by Technology" sub-section below.
The variation in the total costs for the case study responses shows the
range of actual site costs, but must be evaluated in light of four
characteristics of the data base. These characteristics limit the
comparability of costs among the case study sites and with future remedial
actions.
The four significant characteristics of the data that had an effect on
the total costs of sites are:
o Remedial work was not necessarily completed
o Some hidden or in-house costs were excluded
o Remedial contracting market conditions were dynamic
o Sites were not necessarily statistically representative.
The most important characteristic of these total cost data is that the
remedial work performed at the sites was not necessarily complete or final.
Significantly, at many of the sites the source of contamination has been
partly or completely removed, but the contaminated subsurface has not been
dealt with. Additional costs for such sites may involve any or all of the
following: hydrogeological studies; ground water withdrawal wells to retard
plume migration; treatment systems for extracted contaminated ground water;
and future operation and maintenance costs of ground water collection/
treatment systems. In many cases, caps, cut-off walls and subsurface drains
will require future expenditures for monitoring and maintenance. Many of the
uncertainties regarding total cost stem from uncertainty about the efficacy of
the response technologies implemented. Regarding most of the case study
sites, however, there is a significant amount of confidence on the part of the
companies or agencies involved that the reported costs substantially represent
the actual totals for the sites.
The second characteristic of the total site cost data is the exclusion of
private or governmental in-house costs from the totals reported for several
sites. Estimates of in-house costs were included in each case study whenever
possible. However, in the cases where this was not possible, the cost of
unaccounted for in-house labor, equipment, and services such as monitoring and
management performed by government agencies, were not included in the total
site cost.
26
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15-
14-
Figure 2. Distribution Of Total Site Costs
12-
11
10J
34567
TOTAL COST OF SITE RESPONSE (IN MILLIONS $)
10
11
-------
TABLE 9. TOTAL COST BY SITE
N)
00
Site Name
Anonymous
Site A
Anonymous
Site B
Anonymous
Site C
Biocraf t
Laboratories
Chemical
Metals Industries
Chemical
Recovery
Systems, Inc.
College
Point
Fairchild
Republic
Date
1982
1980
1981
1981
1981
1980
1980
1980
1982
Problem/Risk (a)
pesticide/fertilizer s w
discharge adjacent bay
solvents /herbicide
gw contamination
hexavalent chromium
soil, gw contamination
solvents
gw, sw contamination
solvents, metals; gw,sw
explosion/fire threat
solvents, metals
gw contamination
PCB oil;
gw, sw, fire threat
hexavalent chromium
gw threat
Primary
Response Technologies
waste water disposal
cut-off wall
subsurface drain
leachate treatment
subsurface drain
leachate treatment
eo llect ion/ rein jec-
tion trenches
biodegradation
soil scraping, disposal
capping
subsurface drain
cut-off wall
oil/soil, solidifica-
tion/disposal! waste
water treatment
excavation, disposal
capping
Quantity
2.8 X 1010 l
9,637 m2
80 m long
3. 6-5. 2 m deep
82,080-112,320
Ipd (b)
73 m long
4 m deep
1,040 lpd(b)
51,779 Ipd (b)
2,000 drums
91 Mt
300 m long
2-3 m deep
1,341 m2
2,514 Mt
4,129 Mt
15 cm thick
Total
Site Cost
$10.3 million
$268,217
$23,000
$926,158(c)
$341,349
$1.4 million
$1.75 million
$450,000
(a) gw = ground water; sw = surface water
(b) Ipd = liters per day
(c) Includes significant research
and development costs
-------
TABLE 9. (continued)
Site Name
Gallup
General Electric
Goose Farm
H 4 M Drum
Houston Chemical
Howe , Inc.
Marty's CMC
Mauthe
Date
1978
1981
1980 -
1981
1979 -
1981
1979
1979 -
1981
1980 -
1981
1982
Problem/Risk (a)
solvents, metals
gw, sw contamination
PCB, trichlorobenzene
gw, sw threat
solvents, metals, PCB
gw, sw contamination
solvents
sw, gw contamination
pentachlorophenol
sw contamination
pesticides
gw, sw contamination
solvents, PCB's
gw, fire threat
hexavalent chromium
sw, gw contamination
Primary
Response Technologies
excavation, disposal
in-situ lime treatment
subsurface drain oil/
water separator
excavation, disposal
gw extraction/ treatment
excavation, disposal
soil scraping, disposal
water treatment
soil scraping, disposal
excavation, disposal
aeration, capping
excavation, disposal
subsurface drain
Ouant i ty
3,647 Mt
126-189 lpd(b)
3,900 Mt
151,400 Ipd
368 Mt
2,015 Mt
266,670 Ipd
1,988 Mt
426 Mt
76.5 Mt
Total
Site Cost
$610,445
51.58
mill ion
S5.1
mi 1 1 ion
Si. 25
mi] 1 ion
$709,428
$470,000
$557,735
$72,229
(a) gw = ground water; sw = surface water
(b) Ipd = liters per day
(continued)
-------
TABLE 9. (continued)
U)
o
Site Name
Occidental Chemical
Quanta Resources
Richmond Sanitary
Stroudsburg
Trammell Crow
University of
Idaho
Vertac
Date
1980-
1981
1982
1976-
1977
1981-
1982
19R1
1981
1979 -
1980
Problem/Risk (a)
pesticides (DBCP, lindane)
gw contamination
solvents, PCB
sw, fire, explosion
threat
miscellaneous organics
sw, air threat
sw contamination
non-hazardous oil
pesticides, solvents
gw threat
solvents, pesticides,
dioxin, gw, sw con-
tamination
Primary
Response Technologies
excavation, disposal
gw treatment
solidification,
disposal waste water
re, tment
cut-off wall
cut-off wall
recovery wells
solidification
capping
excavation, disposal
excavation, disposal,
cap, subsurface drain,
cut-off wall
Quantity
3,559 Mt
1.8-2.7 x
10& Ipd (b)
2,387 Mt
10,000 lpd(c)
3,709 m2
(1.5 m thick)
1,023 m2
(0.3 m thick)
18,925 Mt
625 Mt
—
Total
Site Cost
$3.91
million
$2.26
million
$111,036
$594,500
$427,527
$174,897
$2.016
million
(a) gw = ground water; sw = surface water
(b) Ipd = liters per day
(c) bulk treatment for 1^/2 month operation - 630,000 1
-------
Third, the costs for the case study responses were incurred during a
period of dynamic conditions in the remedial action contracting market.
Increased competition and improved economies of scale from greater utilization
of specialized equipment may have tended to decrease costs of the more recent
site responses. Further, some responses included costs for research and
development of remedial technologies; these costs may not be present in future
clean-ups. Also, there were unquantifiable costs of contractors and
government officials learning how to carry out remedial actions, which may not
be as evident in future clean-ups. However, these factors may have been
offset by other pressures that tended to increase costs. For example,
changing regulations during the period resulted in more stringent and costly
hazardous waste management requirements.
Finally, the site selection procedure did not attempt to assemble a group
of 23 sites that were statistically representative of the range of site costs,
which is itself still unknown. The site selection criteria affecting the
lower end of the cost spectrum were probably less significant than those
affecting the upper end. The average total response cost may be an
underestimate because the site selection procedure excluded most CERCLA-funded
sites, which are generally the largest uncontrolled hazardous waste sites in
the country. Also, more costly sites tended to involve litigation that
rendered them unavailable for study. Although some sites were studied because
of useful unit operations, this was not possible for partially cleaned-up
sites involved in enforcement actions because of the confidentiality of the
information.
Comparative Cost by Technology
The case studies encountered several primary technologies which are
commonly used in remedial actions. Their costs are discussed separately in
the following sequence:
o Capping
o Cut-off Walls
o Excavation, Transportation and Disposal
o Site Investigation
o Solidification
o Subsurface Drains
o Water Treatment.
For each technology, its cost is described in terms of its range and component
costs. Then the cost is analyzed in three ways: (1) comparison across the
sites (when the technology is used at more than one site); (2) identification
of site characteristics underlying the costs; and (3) comparison with the
engineering cost model by Rishel et al in the 1982 "Costs of Remedial Actions
at Uncontrolled Hazardous Waste Sites". The costs for various remedial
technologies are compared to those estimated by this engineering costing model
to test the accuracy of these estimates in a real world situation. Such
comparisons of actual expenditures and estimated costs may generally prove
useful for refining future costing models, which can provide an efficient
method of planning remedial responses, because data on remedial cost is very
limited, and most available cost data is derived from similar cost models.
31
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Generally, the case study cost estimates are of limited comparability
because of site characteristics such as waste type and scale of response.
However, these factors that limit cost comparisons are discussed briefly in
each section to the extent that they were found to affect costs in the case
study sites. Also, the usefulness of the expenditures found for generalizing
to similar unit operations may be limited.
Capping Cost—
Capping cost data were available for 3 of the 8 case study sites at which
capping was used. These costs are given along with significant cost factors
and the engineering cost model estimate for comparison in Table 10. The costs
include capital costs but not operation and maintenance costs. The costs
appeared to be similar, ranging from $0.95 - 1.63/fC ($10.23 - 17.55/m ).
The engineering cost model estimate of $0.61 - 0.84/ft ($6.58 - 9.06/m ) was
slightly lower, but had a different design than the case study caps. This
difference, as well as design differences that affected costs among case study
sites, will be considered below to the extent that they provide examples of
factors that affect costs.
Although the case study research found insufficient data to determine an
average cost for a particular cap or the quantifiable effect of particular
cost factors, several cap characteristics that appeared to affect costs are
listed in the outline below.
A. Material variations
(1) Cap material
(a) bentonite/clay
(b) asphalt
(2) Related material costs
(1) top gravel
(2) gravel bed
(3) curbs
(4) topsoil and seeding
B. Dimensional variations
(1) Thickness
(2) Area covered
The characteristics of the hypothetical cap (see components below) used
for the engineering cost model estimate should be considered in the context of
the above outline along with case study cap costs. The following costs were
included in the engineering cost model estimate:
32
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TABLE 10. CAPPING COSTS
Site Name
Fairchild
Republic
General
Electric
Vertac
Engineering cost
Model
Date
1981
1981
1981
1980
1980
Cap Material
clay
gravel/
bent on it e- soil
asphalt
clay
bituminous
concrete
Thickness
6 inches
(0.15 m)
6 inches
(0.15 m)/
4-6 inches
(0.1-0.2 m)
(b)
1 foot
(0.3 m) (a)
3 inches
(0.08 m)
Coverage
(b)
156,000 ft2
(14,493 m2)
135,000 ft2
(12,542 m2)
100,000 ft2
(292,681 m2)
595,953 ft2
(55,364 m )
Unit Cost
$1.63/ft2
($17.55/m3)
$1.137 ft2
($12.36/m2)
1.15/ ft2
($12.26/m2)
$0.95/ ft2
($10.23/m2)
$0.61 - 0.84/ft2
($6.58-9.06/m2)
oo
Co
(a) Reported thickness in proposed design
(b) Data not available
-------
Dollars
Capital Costs Lower U.S. Upper U.S.
Excavation, Grading and Recontouring
of Site -36,208 cu yd (27,685 m3 ) $43,820 $50,790
Excavation and Grading, Soil
(for contouring - 22,116 cu yd
(16,910 m )) $15,190 $17,720
Surface Seal - 595,953 ft2
(55,364 m ) Bituminous Concrete
Cap - 3 inches (0.08 m) $168,590 $244,990
Capital Cost (subtotal) $227,600 $313,500
Overhead Allowance
(25 percent) $56,900 $78,380
Contingency Allowance
(35 percent) $79,660 $109,730
Unit costs $0.61/ft $0.84
($6.58/mZ) ($9.06/ra2)
Total Capital Costs $364,160 $501,610
Source: Rishel et al. 1981. "Costs of Remedial Actions at
Uncontrolled Hazardous Waste Sites", EPA-600/2-82-035.
Details of case study capping costs are given in the individual case
studies. The hypothetical cap used for the engineering cost model estimate
varied from the case study caps in two characteristics that may be reflected
in the relatively lower engineering cost model cost estimate. First, unlike
any of the case study caps, the engineering cost model cap was made of
bituminous concrete. Second, the hypothetical engineering cost model cap was
several times larger than any of the case study caps. Although no realistic
material costs could be gleaned from the case study data, the larger
engineering cost model cap size may have allowed for greater economies of
scale. When necessary equipment such as graders and rollers are mobilized, a
relatively small marginal cost would be incurred for any given amount of
additional work.
The difference in the material, between bentonite and asphalt, was not
shown to significantly affect cap costs. The costs of the two cap types were
found to be very similar at the General Electric site. However, this cost
similarity may be a result of the second category of material variations:
related material costs.
Variations among the costs of cap related materials may have affected the
total costs of the various caps. The cost of the bentoriite-soil cap at
General Electric included the cost of the 6 inch (0.15 m) cover of 3/4 inch
(1.9 cm) gravel to prevent erosion of the cap. The cost of the asphalt cap at
General Electric included a requisite gravel bed. The cost of curbs for run-
34
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off control at General Electric was not included in the total reported cap
cost, but their installation may have caused a cap cost increase not incurred
in the other sites lacking this feature. Several of the sites for which cap
costs were not available used common clean fill for capping. The seeding of
soil caps to prevent erosion and restore the site should be included in
calculating cap costs.
Finally, the cap dimensions — thickness and area covered — tended to
affect cap unit costs. Increased cap thickness could generally be expected to
add to cap costs by increasing the volume of cap material required. The exact
function for this relationship cannot be determined with the available case
study data. The total area covered affects the unit cap costs by determining
potential economies of scale. Although the engineering cost model included
separate calculations for different scales of operation of surface sealing,
the cost per unit operation (e.g., dollars per cubic meter) was found to be
very similar for vastly different scales of operation. The only remedial
technology for which separate scale calculations showed significant economies
of scale was well point systems.
Cut-Off Wall Costs —
Although the data may not be adequate to support generalizations about
absolute or relative costs of cut-off walls, for the 5 sites surveyed the clay
and bentonite slurry walls listed in Table 11 were less costly per unit area
blocked off than the ASPEMIX cut-off walls. However, these wall types have
significant technical differences that are reflected in the costs. All costs
in the table are for capital expenditures and exclude operation and
maintenance costs, which would include site monitoring, wall inspection, and
possibly, repair or replacement. The unit costs are given in $/area blocked
off for comparison because this unit best represents the cost of performing
the intended function of cut-off walls. This function is either to divert the
flow of ground water to lower the water table below the waste, in the case of
an upgradient wall, or to contain a contaminant plume, in the case of a
downgradient wall.
Total cut-off wall costs ranged from $56,118 to $976,276. Unit costs
ranged from $0.21/ft ($2.26 m ) to $29.59/ft ($319Ym ). If the two extremes
are eliminated, unit costs ranged from $1.42/ft ($15.13/m ) to $14/ft
($150/m ).
The hypothetical model cut-off wall engineering cost model estimate is
fundamentally different from those studied at the case study sites because of
variations in what each includes and how the costs are derived. The
35
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TABLE 11. SUMMARY CUT-OFF WALL COSTS (a)
Site Name
Anonymous Site A
Anonymous Site A
Chemical Recovery
Systems, Inc.
Stroudsburg (d)
Richmond Sanitary
Service (c),
Vertac
Engineering cost
MortpJ
Date
1980
1982
1980
1981
1983
1980
1980
Cut-off Wall Type
ASPEMIX (f)
ASPEMIX (f)
ASPEMIX (f)
bentonite
cement
slurry
local clay
local clay com-
pacted in lifts
bentonite
slurry
Size (depth underlined)
2,000 X 1T_ X 0.83 ft-34, 000ft2
(510 X 5 X 0.025 m - 3,159 m2)
2,929 X 17 X 0.83 ft-69,734 ft2
(893 X j> X 0.025 m - 6,478 m2)
1,465 X 10 X 1 ft - 14,650 ft2
(447 X 1 X 0.3 m - 1,341 m2)
— =.=_.
648 X 17 X 1ft - 11,016 ft
(198.6 X 5.2 X 0.3 m - 1023 m2)
2,765 X 14.3 X 5ft-39,490 sq ft
(843 X 4.4 X 1.5 m - 3,709 m2 )
NA (b)
2,306 X 48 X 3.2 feet -
110,688 ft2
(720 X 15 X 1 m - 10,800 m2)
Expenditure
$238,000
$976,276
$83,000
$326,000(d)
$56,118
NA
$588, 13Q
Unit Cost
$77 ft2
($75/m2)
$14/ft2
($150/m2)
$5.60/ft2
($61/m2)
$29.59/ft2
(319/m2)(d)
$1.42/ft2
(15.13/m2)
$0.21/ft2
($2.26/m2
$5,31*8, S3/ft2
(55-96/ra2)
(a) Costs are of limited comparability; (d) Includes excavating the trench
gpp tGXt *
/, N D , * transporting and disposing of
(b) Reported to be 2 feet (0.6 m) thick contaminated soil
by design drawings (e) Total capital costs
(c) Based on Means "Building Construction" (f) asphalt, sand, concrete, water
Cost Data: 1983. emulsion.
-------
engineering cost model estimate includes costs for specific related tasks that
are not included in the costs for most of the case study cut-off walls. The
following cost categories are included in the engineering cost model estimate:
Capital Costs Lower U.S. Upper U.S.
Geotechnical Investigation $3,850 $6,520
Slurry Trench Excavation
2,306 X 48 - 110,688 ft2
(720 X 15 X 1 m - 10,800 m2)
(3 feet (1 m) thick)
(includes installation of
bentonite slurry) $347,760 $588,710
Bentonite, Delivered -
462 tons (419 Mt) $27,830 $74.200
Capital Cost (subtotal) $379,440 $669,430
Overhead Allowance (25 percent) $94,860 $167,360
Contingency Allowance (30 percent)$113,830 $200,830
Total Capital Costs $588,130 $1,037,620
Unit Cost $5.31/ft2 $8.93/ft2
($54.46/m2) (96/m2)
Source: Rishel, et al. 1982 "Costs of Remedial Actions at Uncontrolled
Hazardous Waste Sites," EPA-600/2-82-035.
Details of case study cut-off wall costs can be found in the individual
case study reports. None of the case study site costs include the cost of
contingency or geotechnical investigation. If these costs are excluded from
the engineering cost model estimate, the engineering cost model estimated unit
cost is 4.28 - $7.56/ft2 ($46-$81/m2).
The engineering cost model estimates were derived from the Means and the
Dodge costing guides along with cost information from Bentonite suppliers. Of
the case study sites only the costs for Richmond Sanitary Service relied
partly on the Means guide. The costing procedures used for the Richmond
Sanitary case study differed from the cost model, however, in that the
Richmond Sanitary costs were derived using daily construction progress reports
to determine the actual hours of work performed, rather than an assumed number
of hours for a similar operation in a non-hazardous setting.
The engineering cost model estimate lies in the middle of the case study
cost range. It is over double the costs found for the case study clay and
bentonite walls, except for Stroudsburg, for which the total cost figure
included excavation, transportation and disposal costs for contaminated trench
soil. The engineering cost model estimate is closer to the costs found for
37
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for the ASPEMIX walls.
There were two categories of factors found to affect costs: technical and
non-technical. Site characteristics such as waste/wall compatibility,
impermeability requirements, and terrain dictate different technical
specifications that affect costs. Also, economic factors such as marketing
and inflation were found to affect costs. The following outline summarizes
the factors found to affect slurry wall costs.
Factors found to Affect Cut-off Wall Costs In Case Studies:
A. Technical Factors
1. Inclusion of Related Necessary Costs
(a) Geotechnical Investigation (included in SCS estimate)
(b) Excavation, transportation and disposal of trench
spoils (included in Stroudsburg)
(c) Subsurface drain
(d) Staging area set-up (not included in Anonymous A, see
case study)
2. Cut-off wall characteristics
(a) Permeability
(i) Waste/wall compatibility, corrosion resistance
(Anonymous A and Chemical Recovery Systems, Inc.
(CRSI) waste incompatible with clay)
(ii) Wall thickness variability (compare Anonymous A, CRSI
with Richmond, Stroudsburg)
B. Non-technical Factors
1. Contractor market entry loss investment
2. Inflation effects
There are four types of related costs that may reasonably be included in
the operation costs—(1) excavation, transportation and disposal costs for
contaminated trench soil; (2) subsurface drain costs; (3) staging area set up;
and (4) geotechnical investigation of these only the first was included in the
total cut-off wall costs reported for one case study site Stroudsburg. It was
included because it was considered a necessary part of the operation, and
separate costs were not available. The subsurface drain costs were excluded
from the cut-off wall costs in Chemical Recovery Systems, Inc. (CRSI) because
it was useful to consider them separately, despite the fact that it is often a
necessary part of the total cost in order to relieve hydraulic pressure on the
wall, and prevent ponding. The cost of grading a staging area was included
separately in Anonymous A because it was believed to be relatively unique to
38
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the terrain because the work was done on a dike.
Another factor limiting the comparison of slurry wall costs with ASPEMIX
"grout curtain" costs, is the distinct permeability and installation
characteristics of the two walls. The technical specifications of the
different walls is such that the slurry wall could not have been used instead
of the ASPEMIX wall in some cases for two reasons. First, in bench scale
tests with lucite columns, the ASPEMIX walls were found to be less permeable
per unit thickness than the clay cut-off walls (10 vs. 10 cm/sec). This
was primarily due to greater corrosion resistance to waste of the ASPEMIX
mixture. In independent bench scale tests, the wastes at Anonymous A and CRSI
were found to cause coagulation, corrosion and eventually breakdown of the
structured integrity of compacted clay. The lower permeability cut-off walls
were required by court or administrative orders at both sites. Hence, the
slurry wall was not adequate to meet State requirements.
Second, a standard slurry wall excavation technique would have threatened
the integrity of the dike at the Anon A site, and hence could not have been
used without substantially reinforcing the dike with new fill. Hence,
comparison of the different costs shown for these different types of cut-off
wall should be tempered with this consideration about the distinction in
installation flexibility. Since this ASPEMIX wall was installed in a raised
dike, the company's engineers were concerned that the excavation of the trench
necessary for a clay or slurry trench cut-off wall would have threatened the
interim integrity of the dike before the wall was completed.
In addition material costs varied between the wall types since the clay
and slurry trench cut-off walls were installed with backhoes or excavators to
varying thicknesses between 1-5 feet (0.3 - 1.5 m) depending on the character-
istics of the wall materials and the site. These variations in thickness were
found to cause more cost variations than the relatively fixed thickness of the
ASPEMIX walls (4-9 inches (10 - 23 cm)). This difference in cost comparison
is related to the secondary issue of how these different walls were found to
be priced. The ASPEMIX wall was priced by the unit area (e.g., $/ sq ft),
whereas local clay or slurry trench cut-off walls were found to be priced by
the unit volume (e.g., $/cu yd). Again, the reason for these pricing unit
differences is that ASPEMIX wall thickness is largely fixed between 4-9
inches (10 - 23 cm) by the size of the vibrating I-beam used to install the
wall, whereas other cut-off wall thicknesses can vary more widely.
As with most excavation work, the cost of compacted clay or slurry trench
walls was largely a function of volume of earth moved. The price per unit
area costs are derived only for rough comparison purposes for Richmond
Sanitary Service, Stroudsburg and Vertac in Table 12. The price per area
derived from the volume is multiplied by the thickness (in equivalent units)
because this thickness is necessary for each square area of the wall, (e.g.,
$0.28/cubic foot X 5 feet thick = $ 1.40/ square foot frontage). Again,
however, it should be emphasized that the qualitative, technical differences
between these walls limit the comparability of these costs.
The excavation volume and the total size of the cut-off wall may have had
some effect on unit costs. However, for the case studies any effect of
economies of scale on unit cost was apparently overshadowed by other
39
-------
factors. Although the engineering cost model included separate calculations
for different scales of operation of cut-off wall construction, the cost per
unit operation (e.g., dollars per cubic meter) was found to be very similar
for vastly different scales of operation. The only remedial technology for
which separate scale calculations showed significant economies of scale was
well point systems.
Finally, nontechnical market forces were found to affect the cost of the
ASPEMIX, which is a relatively new technology. The second wall at Anonymous A
was significantly more expensive than the first wall there or at CRSI.
However, the effect of increasing experience and streamlining may help absorb
any future price increases. Also, inflation has a common effect on all costs
but has an additional effect on the ASPEMIX cost. Since the asphalt component
is petroleum based its cost varies as widely as petroleum prices. The
engineers at Anonymous A noted that their cut-off wall would have cost
significantly less if it was installed before the 1979 oil price increases.
Excavation, Transportation and Disposal—
The costs of excavation, transportation and disposal for the case study
sites are given in Tables 12 and 13. Generally, the tables are organized in
order of descending costs, and are grouped by RCRA-hazardous waste in Table 12
and PCB wastes in Table 13. Several significant site characteristics are
given. Specific site characteristics are detailed in the individual case
studies, and are outlined briefly below. The engineering cost model estimates
are also given for comparison in each table.
The costs reported cannot be interpreted strictly as being statistically
representative, but they illustrate the ranges of costs encountered and the
factors that affect the costs, and provide data to compare with the existing
engineering cost model estimates. The average unit cost for excavation,
transportation and legal disposal of non-PCB, RCRA-hazardous waste for the
eight case study sites (11 waste streams) shown in Table 12 for which all
three costs were available was $187.64/Mt (SD=$97.22) - $198.64/Mt
(SD-$91.47). The lowest total cost shown of $48.48/Mt for one contractor at
Fairchild Republic Company was for illegal disposal. The average cost of PCB
waste excavation, transportation and disposal for the three sites (5 waste
streams) in Table 13 was $415/Mt (SD=$132/Mt). These costs generally included
the cost of personnel protective gear, loading, permitting and other related
costs discussed briefly below. They do not include operation and maintenance
costs for future site monitoring because all wastes are assumed to be removed,
for the purposes of data comparison.
40
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TABLE 12. EXCAVATION, TRANSPORTATION, DISPOSAL COSTS
Site N.ime
Oc cldental
Chem i c a 1
M.irtv ' s
CMC
Oi cident.il
Cliem i ca 1
L'ni vers 1 ty
of Idaho
Dec ident.il
(.h( ml( .1]
f.oose
Kirm
H & M
Drum
Houston
Chemical
C.il lup
Eng ineerlng
cost model
Estimate (c)
D.ite
1981
1981
1981
1981
1981
1981
1981
1979
1978
1980
Material
bottles (f)
pnl lets
soil
sludge
SOU ((•)
soil
si lldRC
s..ll (h)
drums
soil
drums
soil
soil
drums
soi 1
"landfill"
Quantity (c)
562 m3
804 m3 (d)
151 drums
562 m3
625 m3
2,435 m3
3,900 m3
368 Mr.
2,015 m3
3,647 Mt
596,388 m3 or
324,620 Mt
Contaminant
pestic ides
(DHCP, ett . )
c h 1 or i na ted
solvents
pes t ic i des
pest i( i des
so 1 ven t s
pest ic Ides
so 1 vents
metals
solvents
PCP
solvents
metals
"hazardous
waste"
Excavation
Depth
4.6 m
1-5 m
4.6 m
4m
4.6 m
5-8 m
—
0.01-
0.015 m
1-4 m
4 m
Excavation
S191/m3
S 61/m3
$191/m3
Transportation
Distance (.1)
Disposal (h)
S144/mJ
(225 km)
S149/Mt
(825 km)
$9J/Mt
s9H/n3
(225 km)
S231/ m3 (409 km)
$191/m3
$44-90/m3
—
$40-90/m3
$14/m3
$2.38-
2.75/m3
S46/m3
(225 km)
$63/Mr
(708 km)
$79/Mt
(772 km)
S26/Mt
(273 km)
$74/Mt
(800 km
S3.18-6.17/
Mt(32 km)
S44/Mt
S93/Mt
S48/Mt
$44/Mt
S121.26/Mt
lot.ll
S i35/m^
S )02/Mt
S289/m3
?2'>l/m3
S237/m3
S15l-207/Mt
—
S114-164/Mt
S132/Mt
$128.57-
$133/Mt
(a) One way distance
(b) Land filling unless otherwise noted
(c) standard m3: Mt landfill ratio=l:l
unless otherwise noted
(d) 470 Mt disposed, m3:
Mt ratio used by
contractor=l:,3;211 Mt
aerated on-site
(e) Cost raodel=1.5m3:! Mt
(f) CA Class I "extremely
hazardous"
(g) CA Class I "hazardous"
(h) CA Class II - I
-------
TABLE 12. (continued)
Site N. ime
Quanta
Resource's
M.uithe
Knirchild
Republic
Howe
K.iirchlld
Republic
Chemical
Metals
Anonymous
Site A
Anonymous
Site A
Anon. A
Engineering
cgat model
Estimate
Date
1982
1982
1981
1979
1980
1981
1980
1980
1980
1980
Material
oil
soil
soil
sludge
ice
soil
soil
sludge
soil
debris
waste
water
waste
water
waste
water
"landfill"
Quantity (c)
299 m3
76.5 m3
4,129 m3
1,988 Mt
1,856 m3
91 Mt
35,200 Mt
146,000 Mt
205,000 Mt
596,388 m3
324,620 Mt(f)
Contaminant
solvents
hexavalent
chromium
solvents
chromium
pesticides
solvents
chromium
metals
carbon
fungicide
ammonia
fertilizer
"hazardous
waste"
Excavation
Depth
-- (d)
1.2m
0.6-1.7 m
0.3-
0.6 m
0.6-1.7 m
— (d)
— (e)
~ (e)
— (e)
Excavation
—
$19/m3
Transportation
Distance (a)
$99/Mt
(1,316 km)
Disposal (b)
$22/m3
incineration
$ 80/m3
(365 km)
SP7/m3 (100 km)
$10/m3
$37/Mt
(225 km)
$10-25/Mt
landfarming
$48. 48/ m4
illegal
—
—
—
—
$2.38-
2.75/mS
—
$41/Mt
$39.637 Mt
( 24 kra )
$31.707 Mt
( 80 km )
$5.28-7.93/Mt
land farming
$3.18-
6.17/Mt
(32 km)
$121. 26/Ml
Total
—
$99/Mt
$97/Mt
$57-72/Mt
$48.48/Mt
—
—
—
$128. 57 -
$133/Mt
(a) One-way distance
(b) Land filling unless otherwise noted
(c) Standard m^: Mt landfill conversion
of 1:1 used unless otherwise noted
(d) surface scraping, no excavation
(e) lagoon emptying
(f) m3: Mt conversion used by the engineering
cost model
-------
TABLE 13. EXCAVATION, TRANSPORTATION, DISPOSAL PCB WASTES
Site Sane
OuanCa
Resouri i-s
Martv ' »
CMC
Co lie HI/
Point
Quanta
Resouri es
hn^lni er ing
cost model
Est imatu
Date
1982
1982
1981
1980
1982
1980
Material
oil
pumb.ih 1 e
sludge
soil
s 1 udge
flyash/
oil , soi 1
sol id i fed
s 1 udge
"landfill"
Quantity(c)
147 Ml
216 Mt
63 Mt
2, 51 A Mt
6. 5 Mt
59b, 388 m-1 or
394, 510 Mt
Contaminan t
1'CB
PCB
PCB
PCB
PCB
"haza rdous
was t e"
Excavat ion
Depth
— d-)
— (O
1-5 m
— (d)
— (c)
4 ni
Excavat ion
—
—
$61/m3
—
—
$2. 38-
2.75/m3
1 ransport.it ion
Distance (a)
S27h/Mt
(2,800 km)
S267/ Mt
(2,285 kin)
$149/Mt
(825 km)
$81/Mt
(644 km)
Disposal (b)
i277/Mt
i in i in-ra t ion
S259/ Mt
i m i in r,i t ion
S228/Mt
$212/Mt
S264/ Mt (644 km)
$3.18-6. 17
/Mt(32 km)
$121 .26/Mt
Total
S55 i/Mt
S52h/Mt
S4iH/Mt
S2(i4/Mt
$2h4/Mt
$128.57-
1 31 .59/Ht
(a) One-way distance
(b) Landfilling unless otherwise noted
(c) surface tanks, no excavation
(d) surface scraping
(e) m^: Mt conversion used by the
engineering cost model = 1.5:1
-------
The engineering cost model estimates for excavation, transportation and
disposal costs are based on the following capital costs:
Capital Costs
Total Cost includes:
Lower U.S.
Upper U.S.
780,000 cu yd (596,388 mj)
357,832 tons (324,620 Mt).
Excavation/grading (includes
truck loading)
Transportation, 30-ton (27 Mt)
dump truck (64 km RT)
Hazardous Waste Surcharge
for Excavation and
Transportation (50 percent)
Tipping Fee
Capital Cost
Unit Cost
$944,140
$687,040
$815,590
$39,361,520
$41,808,290
$53.60/cuyd
($70/m3)
$117/ton
($128/Mt)
$1,094,190
$1,465,680
$1,279,940
$39,361.520
$43,201,330
$55/cuyd
($72/m3)
$121/ton
($133/Mt)
Source: Rishel et al. 1982. "Cost of Remedial Actions at Uncontrolled
Hazardous Waste Sites" EPA-600/2-82-035.
The 50% hazardous waste surcharge in the engineering cost model estimate was
proportionally allocated to the excavation and transportation costs for the
purpose of calculating unit costs. The hazardous waste surcharge of 50
percent for excavation and transportation includes increased costs due to:
o Personnel safety equipment
o Increased labor rest time
o Equipment modification and decontamination
o Increased insurance costs
o Transportation permits.
o
The m : Mt ton conversion of 1.5:1 is based on the given quantities of 596,388
m = 357,832 tons, used for the engineering cost model.
Direct comparison of case study costs with each other and with the cost
model estimates is limited by individual site specific characteristics.
However, these characteristics represent some of the factors that may affect
costs. The outline below lists significant factors found to affect costs at
case study sites.
44
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Factors Found to Affect Excavation, Transportation and Disposal
Costs in Case Study Sites.
I. Technical
A. Excavation or On-site Transfer
1. Excavation depth
2. Site surface characteristics
3. Waste explosivity
4. Material - liquid/solid/drums
5. Waste quantity
B. Transportation
1. Distance to disposal facility
2. Accessibility to road
3. Material - liquid vs. solid
4. Waste quantity
C. Disposal
1. PCB
a) concentration - over/under 500 ppm
b) material - solid vs. liquid
2. Non-PCB RCRA Hazardous
(a) solid vs. liquid
(b) aqueous vs. organic
II. Non-Technical
A. Community relations
B. Interstate relations
C. Inflation and regulatory factors.
The costs for excavation or on-site transferring of waste were found to
be affected by the five factors shown in the above outline. The effect of
excavation depth on costs is probably non-linear, since the most significant
cost changes resulted from equipment differences. For example, the depth of
excavation at University of Idaho, Goose Farm and Marty's CMC necessitated the
use of a Caterpillar 235, which is a large, treaded backhoe (excavator), with
a 30 foot (10 m) arm, which rents for about $65/hour without crew.
At other sites where the excavation depth was shallower, a smaller, less
expensive backhoe such as a Case 580C was used. At sites where only surface
45
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scraping was performed, a front loader, which is generally even less
expensive, was used. Excavation was performed at a relatively quicker pace,
which reduced labor and rental costs, at sites with sandy soil and
unconsolidated soil. At Quanta and Anonymous A, no excavation costs were
incurred because removal involved pumping liquid waste into trucks from tanks
and ponds, respectively. Although no cost information was available for this
type of bulkpumping operation, it was believed to be much less expensive than
digging or scrapping.
Site surface characteristics probably had a relatively small effect on
the excavation costs at most of the case study sites. At Marty's CMC the
waste was excavated from a steep embankment. Clean fill was removed from the
top of the embankment to prevent its cross-contamination with the wastes
buried at the toe during the excavation. This process added slightly to the
labor and rental charges. Muddy conditions at Houston Chemical caused some
delays in excavation work.
Explosivity of waste affected removal costs at Chemical Metals
Industries, where highly explosive zirconium powder was found. This cost is
not shown in Tables 12 or 13 because it was internalized by the City of
Baltimore, whose bomb squad disposed of the waste. Much more time and care
was required for this removal than for other wastes.
The loading costs for liquids were lower than for solids and were
generally too low to be significant. But solidification costs for
transportation or incineration costs for disposal may have negated this lower
cost. Liquid wastes at Quanta and Anonymous A were quickly and continuously
pumped into trucks or trains instead of by the bucket load as with
contaminated soil. Drum handling was most efficiently performed with a
hydraulic drum grappler at Marty's CMC and Goose Farm. This backhoe
attachment rented for over $200/day, but reduced labor costs and other
equipment charges by speeding up the loading process. The net cost effect is
unclear from the available case study data, but the use of this apparatus by
experienced removal contractors suggests its economizing value.
Finally, waste quantity may have affected excavation costs through
unquantifiable economies of scale. Larger sites such as Fairchild Republic
Company and Occidental Chemical could maximize the use of daily rental charges
of backhoes because of the greater amount of waste present, However, this
effect does not appear to be significant since waste quantity and unit
excavation cost do among the case study sites does not appear to be related.
Although the engineering cost model included separate calculations for
different scales of operation of excavation and removal, the cost per unit
operation (e.g., dollars per cubic meter) was found to be very similar for
vastly different scales of operation. The only remedial technology for which
separate scale calculations showed significant economies of scale was well
point systems.
Hazardous waste transportation costs at the case study sites were found
to be affected primarily by the four factors given in the above outline. The
distance between the removal and disposal sites appeared to be the most
significant factor affecting transportation costs. Since PCB waste
transportation costs did not appear to vary significantly from non-PCB RCRA
46
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waste, transportation costs for both waste types are listed together in Table
14. The average cost for the ten sites for which separate transportation
costs were available was $0.16/ton/mile (SD = $0.053/ton/mile) ($0.11/Mt/km SD
= $0.03/Mt/km)). The engineering cost model estimate falls within the range
of costs found for the case study sites.
The accessibility of the site to major roads was found to affect
transportation costs at Occidental Chemical. The contractor stated that a
relatively lower price was charged because the site was near a major
interstate highway which led to the disposal site. This proximity to the
highway minimized the distance travelled on secondary roads and was said to
cause less wear and tear on the trucks. This factor may have affected
transportation costs at other sites where it was not stated explicitly.
TABLE 14. TRANSPORTATION UNIT COSTS
Site
Marty's CMC
Goose Farm
H & M Drum
Houston Chemical
Gallup
Quanta
Howe
Quanta
Quanta
College Point
Average
Standard deviation
Standard error
Engineering Cost
Model Estimate
Unit Weight Cost
$149/Mt
$63/Mt
$79/Mt
al $26/Mt
$74/Mt
$99/Mt
$37/Mt
$276/Mt
$267/Mt
$ 81/Mt
(divided by) Distance
825 km
708 km
772 km
273 km
800 km
1,316 km
225 km
2,800 km
2,285 km
644 km
$3.18 - 6.17/Mt
32 km
Unit
Distance Cost
$0.18/Mt/km
$0.09/Mt/km
$0.10/Mt/km
$0.09/Mt/km
$0.09/Mt/km
$0.06/Mt/km
$0.16/Mt/km
$0.10/Mt/km
$0.11/Mt/km
$0.13/Mt/km
$0.16/ton/mile
($0.11/Mt/Km)
$0.053/ton/mile
($0.036/Mt/Km)
$0.017/ton/raile
($0.012/Mt/Km)
$0.09-0.19/Mt/km
The type of waste material affected transportation costs by dictating the
transportation method. Liquid wastes were most economically transported in
bulk using truck or train tankers. Solid waste was generally transported via
truck, which required extra costs for plastic lining and tailgate sealing.
Sealing of bulk liquid tanks was quicker because it only required closing and
checking valves, instead of the silicon foam or asphalt sealing necessary on
dump truck tailgates.
The cost of transportation was also affected by the waste quantity
because of its influence on the type of transportation used. Economies of
scale were achieved by using bulk tank trucks and rail cars for large
quantitites of liquid waste at Quanta and Anonymous A. Rail tankers, which
carried several times as much as trucks, provided the lowest unit transporta-
tion cost, as shown in the Quanta case study. Economies of scale with solids
transportation costs were generally limited by state laws regarding weight per
47
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axle. Hence, the five axle, 20 cubic yard (15 nr) dump truck was generally
used.
The most significant factor affecting disposal costs was whether the
wastes were PCB contaminated. The cost of disposal for PCS waste was much
higher than non-PCB hazardous waste. Among the PCB wastes, waste oil with
over 500 mg/1 PCB at Quanta was disposed of separately from PCB oil with
between 50 - 500 mg/1. The disposal cost alone was the same for waste oil
above and below 500 mg/1, but the required separate handling affected other
costs because of economies of scale. Liquids from Quanta were disposed of by
incineration, at a slightly higher unit cost than solids, which were
landfilled.
A wide variation in disposal costs for non-PCB RCRA hazardous waste is
shown in Tables 12 and 13. Liquid wastes that were solidified prior to
landfilling, such as at Houston Chemical, cost more per excavated weight
because the weight and bulk increased due to the added solidification material
such as sawdust or lime. Aqueous wastes such as those at Anonymous A had
lower tipping rates than the organic wastes at other sites.
The non-technical factors affecting costs are difficult to quantify
fully. An increase in disposal cost was encountered at: Howe when the
community near a proposed incinerator blocked disposal of the waste there,
which required a more expensive disposal option to be used. At Quanta, delays
and more expensive disposal options were encountered when an out-of-state
landfill refused to accept wastes. The city's consultant stated that this
problem "had less to do with waste characterization data discrepancies as with
inter-state regulatory political factors." Pre-1981 costs were significantly
lower than the post - 1981 costs. This may be due to the anticipated RCRA
landfill regulations, as well as inflation.
Site Investigation—
All 23 responses studied included some site investigation work, ranging
in scale from rapid sampling of surface media during emergencies to detailed
hydrogeological surveys. The costs for the variety of investigational work at
the 15 sites for which this data was available are listed in Table 15. The
percentage of the total site response cost that this investigation cost
represents is given for comparison of the scale of work. No engineering cost
model estimate of investigation costs estimate is available for comparison.
The cost of investigations ranged from $7,643 (N.W. Mauthe) to $1,425,000
(Occidental Chemical Co.). Twelve, or 80%, of the investigations cost less
than $131,000. If the investigation cost is expressed as a percentage of the
total response cost, the figures range from 4% (Marty's CMC) to 35% (Anonymous
C). Nine investigations cost between 8% and 13% of the total response cost.
It is important to note that the ratio between investigation costs and total
costs is as much a function of the cost of the remedial measures as it is of
the cost of investigations.
Because of data limitations such as unquantified costs or limited cost
breakdowns, some of the actual investigation costs probably varied from the
figures reported in Table 15. As noted in the table,, six of the investigation
cost figures also include the cost of engineering design for subsequent
48
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TABLE 15. SITE INVESTIGATION COSTS
Site Name
Anonymous B
Anonymous C
Biocraf t
Fairchild Republic
Gallup
Howe , Inc .
Marty's CMC
N.W. Mauthe
Occidental Chemical
Quanta Resources
Richmond Sanitary
Stroudsburg
Trammel 1 Crow
Univ. of Idaho
Vertac Chemical
Average investigation
Standard deviation
Standard error
Cost of
$
$
$
$
$
$
$
$
$1
$
$
$
$
$
$
cost
Investigation
23,794
8,000 (b)
73,948
107,000 (a)
61,333
62,536 (a)
25,000 (b)
7,643
,425,000 (a)
217,395 (b)
15,000 (a)
130,999 (b)
50,000 (a)
18,237
531,000 (a)(b)
Percentage of
Total Response Cost
9%
35%
8%
24%
10%
13%
4%
10%
32%
10%
14%
22%
12%
10%
26%
16%
9%
2%
(a) Includes engineering design costs
(b) There were additional unquantified investigation costs.
remedial measures. Engineering costs may account for 15% to 80% of the
reported figures. Also, at five sites noted in the table, there were
unreported costs associated with other investigative work that occurred. This
work most often was initial sampling performed by in-house employees of
government agencies before contractors were hired to perform in-depth
investigations.
While the 15 site studies varied widely in scope and complexity, there
were a few similarities among them. All studies involved some subsurface
investigation, such as soil borings, monitoring wells, or test trenches. All
but one (Richmond Sanitary Service) involved sampling and analysis for
contaminants. All but one (Anonymous B) were performed by outside
contractors.
There were a number of factors that contributed to the wide variation in
site investigation costs evident in Table 15. These can be categorized
according to sampling factors and analysis factors, which are detailed in the
outline below and explained in the text that follows.
Factors Found to Affect Site Investigation Costs in Case Studies
A. Sampling
1. Number of samples
2. Number of sampling points
49
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3. Sampling medium (e.g., air, surface, or subsurface)
4. Wells and borings
a. depth
b. diameter
c. site geology
d. single or cluster wells
e. conjunctive use of wells
5. Worker safety requirements
B. Analysis
1. Number of samples analyzed
2. Number of contaminants analyzed for
3. Type of contaminants analyzed for
4. Quality control (e.g., independent
split-sample analysis)
5. Laboratory on-site or off-site.
The most significant factors affecting sampling costs were the quantity
of samples taken, the number of sampling points, and the medium being
sampled. Sampling subsurface media tended to be more costly because it
usually required excavation, soil borings, or monitoring wells. Resistivity
testing and metal detectors were exceptions to this.
Soil boring and sampling well costs were significantly affected by site
geology and the required depth and diameter of the borings. The cost of a
well in an investigation was affected further by whether it had a conjunctive
use in the site response. For example, if a well was installed for sampling
purposes, but later became part of a ground water recovery system, the cost
was appropriately distributed between investigational and remedial costs.
This was the case at Biocraft and Howe, where wells that were initially
installed for monitoring were subsequently retrofitted for extraction pumping
or aeration.
Finally, the need at some sites for worker safety measures seemed to
increase investigation costs substantially. For example, in the site
investigation at Quanta Resources, workers often wore self-contained breathing
apparatus or respirators and protective clothing, and air quality was
monitored continuously.
The major factors that affected the cost of sample analysis were the
number of samples analyzed, the number and type of contaminants analyzed for,
and quality control measures such as split-sample analysis by separate
50
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laboratories. Additionally, use of on-site laboratories could reduce analysis
costs, but in the case of mobile labs, had to be balanced against rental
costs. On-site labs generally offer the benefit of rapid turnaround time,
which can hasten an investigation and allow the clean-up phase to begin sooner
than would be possible if a distant off-site lab were used. Use of a mobile
on-site lab at Quanta Resources is an example of this project acceleration.
An additional factor, that seemed to be related to the proportion of site
costs spent on investigations, was the role of enforcement actions. The five
sites that involved significantly greater shares (20% v. 10%) of investigation
resources, were aLl conducted under intensive enforcement action (Anonymous C
- 35%, Fairchild Republic - 24%, Occidental Chemical - 32%, Stroudsburg - 22%,
and Vertac Chemical - 28%). Of these, all but Stroudsburg were conducted by
private parties. Stroudsburg involved parallel private and government clean-
up operations. Of the remaining ten sites, four were cleaned-up privately
using a relatively small proportion of investigation costs (8-14%).
Subsurface Drains—
The costs of the subsurface drains used in the case study sites are
presented in Table 16. Capital but not operation and maintenance costs are
included. The costs are given with significant drain characteristics, along
with the engineering cost model estimate for comparison. The subsurface drain
costs ranged from $2.78-$71/foot ($30-$768/m ) for the case study sites. Jhe
engineering cost model estimate ranged from $4.88-$9.42/foot ($53-$102/m ).
This wide range of costs results from a variety of individual drain purposes,
characteristics, and the inclusion of related costs. These factors are
discussed briefly below to the extent that they illustrate cost considera-
tions, following a description of the engineering cost model estimate and an
explanation of the unit cost calculation.
The unit costs are given in $/unit area of one side of the trench instead
of $/unit length, $/total perimeter area, or $/unit volume of trench, because
$/unit area most clearly and accurately conveys the functional cost of the
subsurface drains, using the available data. A unit cost per length, as used
in the engineering cost model estimate, would exclude from consideration the
trench depth which is an important element of the cost and function of the
drain. Width of the trench is not included in calculating cost per unit area,
since width represents a relatively insignificant proportion of the total area
intercepted by a drain. The following costs are included in the engineering
cost estimate model given in:
51
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TABLE 16. SUB SURFACE DRAIN COSTS
Site Name
Ccneral
Electric
Anonymous
Site B
Biocraft
Laboratories
Chemical
Recovery
N.W. Mauthe
Anonymous C
Engineering
cost model
Date
1981
1980
1981
1976,
1980
1982
1981
1980
Dimensions - lenj',1 li X
depth: on area (a)
210 x 22.5£t:4,725 ft2
(64 x 7m: 439 m2)
261 x 12-16 ft:
3,122 - 4,176 ft2
(80 x 4-5 m: 290-387 m2)
280 x 10 ft:2,800 ft2 (c)
(85 x 3 m: 260 m2)
990 x 7-10 ft:
6,930-9,900 ft2
(302 x 2-3 m: 644-920 m2)
750 x 3 ft: 2,250 ft2
(229 x 1 m: 209 m2)
240 x 12 ft; 2,880 ft2
(73 x 3.7 m: 268 m2)
197 x 16 ft: 3,232 ft2
(60 x 5m : 300 m2)
Width
3 ft
(I m)
4 - 6ft.
(1.3 -2m)
4 ft
(1.3 m)
—
2 ft
(0.6 m)
4ft
(1.3 m)
3.3 ft
(1 m)
Sump depth (s) ,
other characteristics
29.5 feet (9 m)
triple level drain (b)
20 feet (6 m)
+ bucket well (e)
no sump
rebuilt drain (d)
2 sumps-
4 feet (1.2 m)
6 feet (2m)
15 ft
(5 m)
—
Total Cost
$337,000
$207,046
$110,000
$71,000(d)
$18,000
$8,000
$ 15,780-
30,450
Unit Cost
$71/foot2
($768/m2)
$50-66/ft2
$538-710/m2)
$39/ft2
($420/m2)
$7 - 10/ft2
($77-110/m2)
$8/ft2
($86/m2)
$2.278/ft2
(30/m2)
$4.88-9.42/ft2
$52. 60-101. 50/m2
N>
(a) surface area of one side .
(b) slotted pvc piping stack 1 foot
(0.3 m) apart, three arms to sump
summed.
(c) three trenches summed, 2 injection,
1 withrawal
(d) includes original and renovation costs
(e) cost includes additional bucket well
-------
Capital Costs*
Lower U.S.
Upper U.S.
Trench Excavation (300 m )
5 m (d) x 1 m (w) x 60 m (L)
(3,232 ft2, 300 m3)
Cement Pipe (70 m)
Gravel (70 m3)
Sump (1)
Pump, Submersible (1)
Capital Costs (subtotal)
Overhead Allowance (25 percent)
Total Capital Costs
Unit Costs
$ 400
$ 450
$ 570
$ 500
$1,100
$ 550
$12,620
$ 3,160
$15,780
$ 4.88/ft2
$ 880
$ 760
$1,870
$ 900
$24,360
$ 6,090
$30,450
$ 9.42/ft2
($53/mZ)
($102/iO
*As with case study costs, the model estimates do not include operation and
maintenance costs.
Source: Rishel et al. 1982. "Cost of Remedial Actions at Uncontrolled
Hazardous Waste Sites." EPA-600/2-82-035.
The cost of the subsurface drains in Table 16 are of limited comparability
because of the varied characteristics of the different drains. However, by
considering the characteristics of the two basic elements of the drains,
trench and sump, the cost variation can be explained. The following factors
were found to significantly affect the cost of subsurface drains at the case
study sites:
A. Collection Trench
1. trench length and depth
2. plumbing complexity
3. gravel installation
B. Leachate Storage
1. sump size
2. tank size.
An additional significant factor regarding both construction cost
elements is the potential need for disposing of contaminated soil encountered
while constructing the trench or the sump. Excavation of contaminated soil,
which sometimes resulted in additional costs for disposal, occurred when
trenches were constructed within a contaminated area, rather than at the site
53
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perimeter. This additional cost was incurred at Mauthe where hexavalent
chromium contaminated soil was disposed of from the hole excavated for a
sump. However, at General Electric, PCB contaminated soil was returned to the
drain cap because the system was considered an "Immediate Correction Plan",
not a long term remedy. This action saved the cost of off-site disposal of
the PCB soil.
The importance of the trench size is discussed above in connection with
unit cost dimensions. The trench size depended on factors such as waste type,
soil permeability, climate and purpose of the system. At General Electric a
relatively large three-armed drain system was used because of the relatively
tight soil and the strong adhesion of the PCBs to the soil, and because
California's Mediterranean climate has seasonally heavy rains,. The length of
the drain at Chemical Recovery Systems reflected its purpose of relieving
hydraulic pressure on the ASPEMIX cut-off wall. At Biocraft: the purpose of
the relatively small drain at trench A was to collect contaminated water by
creating a cone of depression. The size of the drains affected construction
costs by dictating different installation methods between the deepest and the
most shallow drains. At General Electric steel sheet piling was driven into
place to support the 30 foot (10 m) deep trenches during construction, whereas
at Mauthe no reinforcement was necessary for the 3 foot; (0.3 m) deep
trenches. The cost for trench reinforcement necessary for the deeper drains
at General Electric and Anonymous B, which used steel sheet piling, and
Biocraft, which used plywood shoring, was perhaps the most important factor in
the different case study drain costs. The available cost data breakdowns are
inadequate to confirm this relationship, but the cost difference among these
shown in Table 16 suggests its significance.
The plumbing complexity of the collection pipe running the length of the
trench ranged from a single pipe to multi-level pipes. At most of the case
study sites a single pipe ran the length of the trench and drained into a
collection sump or as in the case of Biocraft, was drained by an extraction
pump. A General Electric, three levels of slotted PVC piping were installed
in each of three trench arms, with valves into the sump at each level to
control the flow from the different oil-lense depths. The cost for design,
materials and installation of the trench plumbing part of the system at
General Electric was significantly higher than the other case study sites.
The gravel fill installation procedure affected the costs of the drain at
one site, where a different design was used. At Biocraft, an outer layer of
1/4 inch (0.6 cm) washed stone was placed around an inner layer of 1 1/2- inch
(3.2 cm) stone, which surrounded the collection pipe. This relatively complex
design was intended to provide filtration by the outer layer and high collec-
tion rates from the coarser inner layer. This added expense was intended to
obviate the need for future operation and maintenance costs for clearing the
clogged pipe. Reconstruction of a drain installed in 1976 that had become
clogged was necessary at Chemical Recovery Systems. Drains at the other case
study sites used a single size of stone or gravel.
The second cost item included in the costs of the subsurface drains is
for storage of collected water in sumps or tanks. Biocraft was the only site
for which leachate storage costs are not included because the collected water
was pumped directly into the treatment system. The inclusion of sumps in the
54
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other case study site costs assumes that the size and cost of sumps and
storage tanks were generally proportional to the size of the collection
trench. The storage systems differed in type as well as size. Large
prefabricated concrete sumps were used at the end of some drains, whereas
steel tanks or pipes were used at others.
Solidification—
Some form of waste solidification was performed in 5 of the case study
responses. Of these, only one, Trammell Crow, involved on-site solidification
plus on-site landfilling. At the other 4 sites, Marty's CMC, Houston
Chemical, College Point and Quanta, various materials were used to solidify
wastes for off-site landfill disposal.
The cost and method of solidification in all 5 of these responses were
affected by the nature of the waste, particularly its viscosity, and the
price, proximity and availability of solidification materials. Of the 5
sites, only the data for Trammell Crow permit the solidification cost to be
distinguished from other tasks performed. The total cost of the Trammell Crow
project was $427,527, which included $50,000 for a feasibility study. The
project involved mixing, at a ratio of about ljl.5, 25,000 yd (1.9 x 104 m )
of oil sludge with 41,000 tons (3.7 x 10 m ) of kiln dust in a landfill
constructed on-site. About a quarter of the kiln dust was fresh; the
remainder was stale, which had a lower absorption capacity than fresh kiln
dust.
The other 4 sites involved a variety of solidification materials. At
College Point, New York City officials purchased fly ash from municipal
incinerators to solidify PCB-contaminated oil for off-site disposal. The
ratio of fly ash to oil ranged from 5:1 to 99:1. At Quanta Resources, the
clean-up contractor used lime to solidify non-pumpable RCRA-hazardous sludge
at a ratio of 1:1. At Marty's CMC, Massachusetts officials mixed 18 drums of
liquid waste with solid waste and soil for off-site landfilling. At Houston
Chemical, in the course of scraping and removing soil contaminated with
pentachlorophenol (PCP), it was necessary to use sawdust from a nearby sawmill
to solidify watery mud before trucking it off-site.
Waste Water Treatment Costs—
The costs for water treatment at eight case study sites and the
comparable engineering cost model estimate are listed in order of decreasing
unit cost in Table 17. These costs include either: operation and maintenance
costs for permanent systems constructed on-site; labor, material and rental
costs for temporary on-site systems; prices charged by contractors for water
sent to commercial industrial waste treatment plants; or the prices charged by
publicly owned treatment works (POTWs) for accepting waste water. Capital
costs generally are not included because they are not always applicable and
because calculation of amortization is not possible because of uncertainty
about operational lifetimes. The cost of withdrawing ground water is not
included in these costs but is discussed briefly with other factors below to
the extent that it influenced treatment costs. Unit cost information may be
more appropriately expressed in terms of price per unit of contaminant
removed, but adequate data was inconsistently available for this level of data
55
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TABLE 17. CONTAMINATED WATER TREATMENT COST (a)
Site Name
General
Electric
Quanta
Resources
Goose Farm
Houston
Chemical
Biocraf t
Laboratories
Mauthe
Howe , Inc.
Occidental
Chemical
Engineering
cost model
Date
1981
1982
1980
1979
1983
1982
1979
1982
1980
Treatment
Technology
On-site advanced oil/
water separator
Off-site Commercial
Treatment
On-site carbon ,
clarification, air
stripping
On-site carbon, pea
gravel/lime
filtration
On-site
Biodegradation
Off-site
POTW (c)
Off-site
POTW (c)
On-site
Granular Activated
Carbon (reverse
pulse)
On-site
"Chemical,
biological and/or
physical"
Primary
Contaminant
PCB/oll
Cyanide
mixed solvents,
PCB
Pentachlorophenol
(PCP)
methylene
chloride,
butanol,
acetone
hexavalent
chromium
Pesticides
(atrazine,
alachlor)
Pesticides
(DBCP)
"contaminant"
Quantity Treated
1,000-1,500 gallons
(3,785-5678 I)/ month
9,425 gallons
(35,674 1)
7.8 x 106 gallons
(2.9 x 109 1)
over 6 month period
2 x 106 gallons
(8 x 106 1)
over 1 month period
13,680 gallons
(51,779 l)/day
273,000 gallons
(1.03 x 106 1)
9 x 107 gallons
(3.4 x 108 1)
over 5 month period
1.5-2.6 x 108 gallons
(6.8-9.8 x 108 l)/year
4.3 x 10' gallons
(1.6 x 108 1 )/year
Expenditure
S4,167/month
$12,724
$2-3
mill ion
$200,000-
350,000
$226.53/day
$2,275
$50,169
$133,320-
370,800/year
$51,900-
94,340/year
Unit Cost
$2.70-4.6/g.il
($0.73-1.10/1)
$1.35/gallon
($0.036/1)
$0.26-0.40/gal(b
($0.068-0.10/1)
$0.10-0.18/gal
($0. 026-0. 048/
1)
$0.0165/gal
($0.0044/1)
$0.008/gallon
($0.002/1)
$0.00056/gallon
($0.00015/1)
$0. 0005-0. 0011/
gal Ion
($0.00013-
0.00029/1)
$0.0012-
0.0022/gal.
($0.00032-
0.00058/1)
Ul
(a) Operation and maintenance,
or rental cost
(b) Includes ground water
recovery cost
(c) Publicly Owned Treatment Works
-------
analysis. The engineering cost model estimate reflects the operation and
maintenance cost for a generalized "chemical, biological, and/or physical
treatment" system constructed permanently on-site at a total capital cost of
$669,900 - $1,134,050.
The following operation and maintenance costs are included in the
engineering cost model estimate:
Operation and Maintenance Cost*
Operating Cost (3 operators)
(2,080 hr/yr ea.) (6,240 hr/yr total)
Power Cost (electricity) (32,000 kwh/yr)
Chemical cost (16.922/ day) X
260 days/year
Total 0 & M Costs
Unit operation & maintenance cost
Lower U.S.
$39,300
$$1,600
$11,000
$51,900
Upper U.S.
$81,740
$ 1,600
$11,000
$94,340
$0.0012/gallon $0.00032/gallon
($0.00032/1) ($0.00058/1)
*For treating (116,443 gallons (440,740 1) of contaminated ground
water/day at a medium size site of 13 acres (5.41 ha).
Source: Rishel et al. 1982 "Costs of Remedial Actions at
Uncontrolled Hazardous Waste Sites," EPA 600/2-82-035.
Details of case study water treatment costs can be found in the
individual case study reports. The component tasks in the engineering cost
model estimate do not appear to differ significantly from those included in
the cost for case study sites. The cost estimated by engineering cost model
is between the two case study costs incurred for water discharged to POTW's.
The technical characteristics of the hypothetical system used for the
engineering cost model estimate were not described.
Direct comparison of the case study costs with each other and with the
engineering cost model estimates is limited by individual site
characteristics. However, these characteristics can indicate some factors
that may affect costs. The significant factors that influenced treatment
costs in the case studies are listed in Table 17 and are outlined below.
Factors Found to Affect Water Treatment Costs in Case Studies.
A. Technical Factors
1. Nature and degree of contamination
a. Treatability
b. Solubility
c. Concentration
d. Diversity of contaminants
57
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2. Variations in type of treatment processes selected
a. Carbon
b. Biological
c. Physicochemical secondary treatment (POTW)
d. Other individual treatments (e.g., air stripping,
fabric filtering)
3. Variations among particular processes
a. Level of treatment
b. On-site/off-site
c. Efficiency
d. Treatment system capacity
e. Collection limitations
f. Climate
Non-technical Factors
1. POTW rate system
2. Use of existing system
3. Rental vs. purchase of treatment system
4. Market competition by treatment contractors
5. Inflation.
The cost factors are organized into three categories of technical factors
and several non-technical factors. The choice of treatment process was
usually dictated by the nature and extent of contamination. For example, high
concentrations of a refractory contaminant like cyanide at Quanta precluded
the exclusive use of a standard POTW or on-site filtering and clarification.
The three technical categories in the outline are separated to
distinguish between the contaminant characteristics and the actual choice of
the treatment alternative. The variation in cost of a particular process was
often related to general site and contaminant characteristics such as the
required extent of treatment in terms of volume and concentration reduction.
These categories help identify the specific cost factors found in the case
studies.
Before considering the costs found for different treatment processes, the
data in Table 17 should be clarified by highlighting the highest and lowest
treatment costs found in the case studies because of the apparent anomalies
they represent. These cost variations were affected by characteristics of the
particular system at the site, not the type of process.
The unit treatment cost at General Electric was relatively high because
of a combination of high operation and maintenance costs and low volume of
treated wastes. The unit operation and maintenance cost was unusually high at
General Electric because the capacity of the treatment system was several
times the volume actually treated. The volume of water treated was low
because the tight soil minimizes the recharge into the sump from the
subsurface drain, which served the purpose of containment by creating a cone
of depression.
58
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The unit treatment cost at Occidental Chemical was relatively low largely
because of the very large volume of water being treated. The operation and
maintenance cost figures that were used for calculating the additional unit
cost at Occidental in Table 17 are incomplete because the system currently is
being modified to achieve the contaminant level reduction ordered by the
state. In addition, no written documentation of these relatively low costs
were not obtained. Data on the actual cost of the adequately effective
system, with its double carbon contactors, were not available. In addition,
the unit cost of operation and maintenance of the treatment system at
Occidental was relatively low because of the high efficiency of the state-of-
the-art reverse pulse bed. This system was apparently designed to take
advantage of the economies of scale of the system. The large volume of water
treated reflects the purpose of the system, which was to reclaim a
contaminated aquifer as well as contain a contaminant plume.
Excluding General Electric and Occidental Chemical, the treatment costs
in Table 17 were primarily a function of the type of treatment sytem used. In
order of decreasing cost the following treatment system types were found: (1)
off-site commercial treatment; (2) on-site carbon filtration with additional
treatment; (3) on-site biodegradation; (4) off-site publicly-owned treatment
works (POTW). The process types were generally dictated by the nature and
extent of contamination. Only wastewater with low concentrations of treatable
contaminants could go to POTWs. Biodegradation was not considered effective
with PCB or cyanide contaminated wastewater. The type of treatment processes
used at Goose Farm and Houston were also used at Quanta, but cyanide waste was
considered incompatible with the other wastes in the system. Finally,
marginal cost increases were incurred at Goose Farm for additional treatment
tasks for additional contaminants.
The very large gap in costs between various on-site treatment systems
(carbon filtration, neutralization/precipitation and flocculation, biological
treatment, etc.) and off-site POTWs may suggest a general pattern that is
applicable to other uncontrolled hazardous waste site remedial actions. POTWs
may be capable universally of providing relatively inexpensive water treatment
of contaminated, pumped leachate if the water has an adequately low
concentration of nonrefractory contaminants. This cost differential may be
due to the advantages of very long term amortization, in-place capital and
labor, and general economies of scale. Certainly, subsidies from the federal
and local governments has some impact on this cost differential, but
internalization of these costs will probably still allow for significant cost
savings from the use of POTWs where it is possible to attain adequate
treatment levels.
Within each of these process types, several factors were found to
significantly affect treatment costs. The level of contaminant reduction
affected the cost of the treatment system at Occidental. The number of carbon
contactors is being doubled to achieve the reduction agreed upon with the
state. Off-site treatment for cyanide wastewater at Quanta necessitated
additional costs of loading and unloading, as well as outside contractor
costs. The relatively low carbon usage rate at Occidental shows how process
efficiency can affect costs. Typically, carbon costs are a major component of
this process type. However, the reverse pulse bed used at Occidental
minimized this rate for a given level of treatment. The effect of treatment
59
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system capacity on costs was encountered at both General Electric and
Occidental. Although large for the treatment needs encountered, the system at
General Electric was significantly smaller than Occidental and could not
capitalize on potential economies of scale. Also, POTW costs are typically
low because of the small marginal load increase in their total load caused by
the addition of wastewater from a site.
Collection limitations generally affected the numerator of the unit cost
formula - i.e., the quantity of water treated. At Quanta, wastewater
collection was facilitated by the water's accessibility above ground in diked
areas, pits and tanks. At General Electric, the volume of water was limited
because the tight soil minimized the recharge of the sump from the subsurface
drain.
At Goose Farm, climate affected the treatment cost by increasing the
down-time cost of the mobile on-site system and by necessitating cold-weather
system modification. The system operated on-site during the winter when
freezing weather conditions impaired its functions.
The five non-technical factors are interrelated, but are distinguished on
the outline to highlight factors of particular sites, some of which are not
listed on Table 17 because of insufficient treatment cost data. Most non-
technical factors affected the internalization of costs among different
parties.
At Anonymous C (not on Table 17), the POTW cost was based on the volume
of water used by a customer, not on discharge. Hence, the contaminated ground
water added no marginal cost to the discharge fee. At another site, Anonymous
B, additional costs for the water treatment were not encountered because of
available capacity at an existing on-site system. At two of the sites listed
in Table 17, Goose Farm and Houston Chemical, mobile rented treatment systems
were used. The costs of purchased systems often excluded in-house costs for
operation and maintenance overhead, which were explicitly included in the cost
of rented systems. At Occidental, the project manager and treatment system
company engineer believed that market competition was significant in reducing
the cost of the treatment system. Because of a desire to increase its market
share of the new ground water treatment market, the contractor minimized its
profit to obtain the contract.
Operation and Maintenance Costs—
All but four of the 23 case study sites will require some ongoing
operation and maintenance (O&M) expenditures. At one site where no future O&M
is expected by the state or the developer, Trammell Crow, non-hazardous sludge
was solidified and landfilled over thick clay and shale. No monitoring wells
have been installed or are planned. At the other three sites, College Point,
Houston Chemical and Howe, emergency surface or subsurface removal and
disposal operations were performed, and no follow-up monitoring is being
performed.
The lack of ground water and soil monitoring, and the incurred costs, may
be somewhat characteristic of immediate, complete removal actions.
Institutionally, funds for monitoring sites where all wastes were to have been
60
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removed may not be justifiable since all of the wastes were to have been
removed. In addition, a party contending that all of the wastes have been
removed, may not find it in its own best interests to authorize monitoring
that may provide data indicating an ineffective removal. This potential
dilemma suggests the need for some distinction between remedial and monitoring
authorities.
The other 19 sites are expected to require future O&M in two forms.
First, varying amounts of monitoring well sampling and analysis will be
performed at all 19 sites. Second, four of these sites will also require
ongoing water treatment expenditures, for withdrawn ground water. These costs
include only expected O&M and exclude potential future costs for maintenance
such as repairing failed cut-off walls or clearing clogged subsurface drains.
The four sites at which future ground water treatment costs are expected
are Biocraft, General Electric, Mauthe and Occidental. At Mauthe, the
contaminated ground water is being treated at a POTW for a relatively low
cost. For example, the O&M cost at Mauthe for treating the contaminated water
from the subsurface drain amounts to $235 per 3,000 gallon (11,355 1)
truckload for pumping and transportation ($210), and treatment ($25) or about
$36,660 for 156 truckloads per year. The O&M costs for treatment at the three
sites where permanent water treatment systems were built ranged from 6-21% of
the capital costs for the systems (see Table 18).
TABLE 18. COMPARISON OF O&M VS. CAPITAL COSTS FOR PERMANENT ON-SITE
WATER TREATMENT SYSTEMS (1982 COSTS)
Site
Operation & Maintenance CAPITAL
Percent O&M Capital
Biocraft
Laboratories
$82,683/year
$926,158(a)
9%/year
General
Electric
Occidental
Chemical
$50,000/year
$133,320 -
370,800/year
$846,200
$1.735
million
6%/year
8-21%/year
(a) includes significant research and development costs
61
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The operation and maintenance cost data for sampling and analysis of
ground water from monitoring wells were not available for most of the sites.
These costs appeared to vary among the sites depending on the monitoring work
performed. Different amounts of monitoring were often required for ensuring
that the site response is performing as expected. Many of the variables
affecting these costs are discussed in the "Comparative Cost by Technology:
Site Investigation Costs" subsection above. For follow-up monitoring O&M, the
most important factors found to affect costs at all of the sites were the
frequency of sampling and the number of samples taken on each round
(replicates times number of wells). These costs were routinely internalized
into the operating budgets at operating facilities. For example, at Biocraft,
in-house laboratory technicians have been trained to sample and analyze wells
on a weekly basis. At the University of Idaho, site wells are sampled and
analyzed by students as part of a lab class in hydrogeology. These procedures
eliminate the higher cost of an outside consultant to perform the sampling and
analysis. The amount of sampling costs depended on the remedial technology
implemented. At sites using a cut-off wall or subsurface drain, more
monitoring O&M was performed than at sites where removal was performed,
especially where the removal was performed quickly before ground water
contamination could occur.
Public vs. Private Clean-ups
Of the 23 responses studied, 11 were funded and executed by state, local,
or federal agencies, 11 were funded and executed by private firms, and one,
Gallup, was privately funded but executed by a state agency. Analysis of the
costs of, and the variables affecting, the 23 responses gives no indication
that government executed clean-ups tended to be more or less cost-effective
than privately executed clean-ups. In particular no pattern of unit costs for
similar operations could be discerned. While it is possible that such a
difference exists, the highly individual nature of each site prevents a valid
comparison of relative costs.
Numerous factors influencing costs limit the comparability of the
responses. No two sites or responses were alike. While the sites and
response technologies can be grouped in general classes, variables such as
site geology, accessibility, weather, nature and extent of contamination, and
site-specific design of responses, make each case unique.
There were hidden or unquantifiable costs in many of the case study
responses. Many of the private sites made use of existing capital resources
and personnel, the cost of which were not included in the reported total
response costs. For example, at Anonymous B, a private site, there was a
wastewater treatment plant already on-site to treat contaminated effluent from
a subsurface drain. In contrast, at Houston Chemical, a government-funded
site, it was necessary for EPA to pay for rental and operation of a mobile
water treatment system. Even when in-house personnel cost data were
available, these figures usually did not include the additional costs of
overhead and profit that would have been incurred if similar labor were hired
from outside the firms. This finding suggests that, generally, when
scrutinizing costs of private responses, the role of in-house resources should
be determined.
62
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All but one of the government executed clean-ups involved emergency
responses, while only one of the private clean-ups did. Consequently,
government agencies necessarily incurred additional expenses associated with
rapid mobilization, limited planning time, and limited site data.
It is clear that in some government executed responses, institutional
factors increased costs. Such factors included delayed or interrupted
funding, citizen opposition to selected responses, and pressure to begin
clean-ups before adequate data were available or before weather conditions
were favorable. However, private clean-ups suffered delays and added costs as
well. Many of the private clean-ups involved a protracted period of
negotiation or litigation with government agencies before there was agreement
on the nature and extent of response. In addition, some private parties had
internal funding or decision making disagreements among different levels or
divisions of their corporate structures, which may have delayed and added
costs to the responses.
63
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SECTION 5
PLANNING AND MANAGEMENT OF RESPONSES
INTRODUCTION
This section summarizes institutional and decision making aspects of the
23 clean-ups studied and examines the degree to which the responses were
affected by factors generally thought to be significant in hazardous waste
site clean-ups. These factors are:
• The basis for initiation of responses;
• Public interaction with clean-ups;
• The basis for the extent of the responses;
• The role of federal and state statutes in the
execution of clean-ups; and
• Methods of hiring contractors to perform the clean-ups.
The following sections state the findings regarding the significance of
the above factors, and then summarize the results that led to the findings.
It is important to note that these 23 cases were not intended to be a
statistically representative sample; rather, they were selected fur their
illustrative value.
BASIS FOR INITIATION OF RESPONSES
The reasons for initiating clean-ups were significant in that they often
determined whether responses were considered emergencies, and influenced the
choice of response technologies. Among the 23 sices studied, the responses
were initiated to protect humans, agricultural biota, or natural biota from
exposure to contaminants via surface water, ground water, air, or airecc
-------
contact. Table 19 summarizes the primary exposure routes, contaminants, and
threatened populations that were the basis of response initiation at each site
and notes the clean-ups that began as emergency responses.
Emergency Response Designation
Twelve of the 23 responses began as designated emergency actions,
although most of these continued into a remedial phase addressing threats that
were more long-term. In general, the emergency sites were initially
considered imminent hazards either because they threatened to release
contaminants catastrophically, e.g., by fire, explosion, or flood, or because
they had already caused environmental damage or drinking water contamina-
tion. The remainder of the sites were believed to pose less immediate
threats.
Contaminants
The sites studied contained a broad range of contaminants. At 20 sites,
the predominant contaminants were organic compounds such as pesticides,
solvents, PCBs, phenols, and mixtures such as coal tar and petroleum refining
sludge. At 3 sites, the predominant contaminant was hexavalent chromium.
Most of the sites contained combinations of substances, often numbering dozens
of different contaminants at a single site. At only 3 sites was contamination
limited to a single substance. PCBs were present at 6 sites, usually mixed
with oil.
Potential Exposure Routes
Surface and ground water were the primary routes of contaminant migration
and potential exposure. All of the sites contained multiple routes. Surface
water was a route at 17 sites, and ground water at 16 sites. Other exposure
routes included air, at 6 sites, and direct contact, at 10 sites.
Population at Risk
At all but four sites, the primary reason for response initiation was an
imminent or potential threat to human health. Eight sites were situated in
rural areas, where the potentially affected human population was relatively
low. Seven sites were situated in commercial/industrial areas, where
residences were relatively far from the sites. Finally, 8 sites were situated
in areas that were either predominantly residential, or were mixed
residential/commercial/industrial. At the 4 sites where human health was not
directly at risk, contamination most often threatened aquatic environments
used by humans for recreation.
Four of the sites threatened agricultural biota such as cropland,
pasture, or gardens. Fifteen sites threatened or actually damaged natural
biota, most often aquatic life. Threats to natural biota at seven of these
sites also represented threats to recreational resources, most often fishing,
boating, and swimming.
65
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TABLE 19. BASIS FOR INITIATION OF RESPONSE
Site Name
I. Anonymous A
2. Anonymous 8
3 Anonymous C
4. Biocraft
5. Chemical Metals
Industries
-5. Chemical Recovery
Systems
7. College Point
8. Faircnild Republic
9. Galluo
10. General Electric
1 1. Goose Farm
12. ri i \I Drum
13. Houston Chemical
! 4. Howe, Inc.
15. Marty's G VIC
16. N.W. .Meuthp
17. Occidental Chem.
13. Quanta Resources
19. Ricnrnond Samtirv
20. Stroudsburs;
21. Trarnmell Crow
22. Univ. of Idaho
23. Vertac Chemical
Contaminants
pesticide, ammonia waste water
pesticides, solvents
hexavalent chromium
butanol, methylene chloride
various orgiinics, metais
various organics, PCB,
vinyl cloride
PCS oil
total and hexavalent chromium,
various or^amcs
various metals, organu:s
PCB, tricnlorobenzene
various orgames, metals, PCB's
various orgamcs
pentachloropnenol
pesticides
solvents, paint sludge, PCB
hexavalent chromium
pesticides (DBCP)
PCB oil, chlorinated solvents
cyanide
various or
-------
PUBLIC INTERACTION WITH CLEAN-UPS
Almost half of the sites were first reported to authorities by private
citizens, but local citizens were not significantly involved in decision
making in most of the responses studied. Ten of the clean-ups received
attention from the news media, ranging from occasional progress reports to
highly sensational editorials. Four sites involved town meetings or public
hearings regarding the clean-ups. These sites were: Chemical Recovery
Systems, Inc., Howe, Inc., Marty's CMC, and Occidental Chemical. Public
attention usually focused on ensuring that a response was initiated, rather
than on specific aspects of the clean-ups.
At one site, however, public opinion did have a significant effect on the
nature and cost of the remedial actions. During the Howe, Inc. clean-up,
state officials proposed six different options for disposal of contaminated
materials before finding a method that was acceptable to the public. The
disposal method ultimately chosen was substantially more costly than others
proposed.
Of the 23 sites studied, few clean-up operations were reported to have
had a significant direct impact on the health or activities of local
populations. Five of the responses included closing residential, municipal,
or commercial drinking water wells and providing alternative water supplies.
At only one site, Goose Farm, were there reports of ill health effects among
nearby residents as a result of the clean-up, apparently caused by air
emissions from excavated wastes stored on-site.
BASIS FOR THE EXTENT OF RESPONSES
The goal of all 23 responses was to clean up the sites to eliminate or
mitigate the threat to public health or the environment. In some responses
specific physical standards (e.g., parts per million of hexavalent chromium),
based on pre-existing design or performance standards from statutes, regula-
tions or scientific studies, were used to achieve this goal. Other responses
used no specific physical standards, relying instead on the clean-up managers'
evaluation of the effectiveness of the work based upon their "best
professional judgement." The research on the 23 responses indicates that
specific physical standards were valuable management tools for selecting
response technologies and determining when clean-up work was completed.
In addition to clean-up standards, another factor affected decisions
about the extent of response: the manner in which the standards were
selected. The researchers identified three major ways in which these
standards were chosen: through judicial or administrative process; by
voluntary agreement; and selection by the government agency conducting the
response.
Every case study attempted to identify the factors, such as clean-up
standards used and the way they were selected, that actually influenced
decisions, as reported by the decision makers and those closely connected to
the response actions, in order to provide a realistic picture of how response
actions were defined and terminated. The following discussion groups the case
studies according to these factors. Table 20 presents these factors in
summary form.
67
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TABLE 20. EXTENT OF RESPONSE
SITE NAME
1. Anonymous A
2. Anonymous B
3- Anonymous C
4. Biocraft
5. Chemical Metals
Industries
6. Chemical Recovery
System, Inc.
7. College Point
8. Fairchlld Republic
9. Gallup
10. General Electric (b)
11. Goose Farm
12. H 4 M Drum
13. Houston Chemical
14. Howe, Inc.
15. Marty's CMC
16. N.H. Mauthe
17. Occidental Chemical
18. Quanta Resources (b)
19. Richmond Sanitary
20. Stroudsburg (b)
21. Trammell Crow
22. Univ. of Idaho
23. Vertac Chemical (b)
EMERGENCY
RESPONSE (a)
X
X
X
X
X
X
X
X
X
X
X
X
REMEDIAL ACTION
Source of Standards
Judgement
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Standards
Design
X
X
X
X
Perfor-
mance
X
X
X
X
X
X
X
X
X
Manner of Selecting Standards
Judical or
Process
X
X
X
X
X
X
X
X
Voluntary
X
X
X
X
X
X
Government
Remedial Action
,
X
X
X
X
X
X
(a) source of standards for emergency
phase was always best professional
judgement, and manner of selecting
standards was either judicial or
administrative process, voluntary
agreement, or procedures followed
by governments in conductin responses.
(b) denotes cases having more
than 1 response action.
68
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Emergency Responses
Twelve of the 23 case studies involved emergency response actions in some
form or another. Responses were classified as emergency operations based on
how the people involved with the clean-up described the situation, not with
reference to any criteria or guidelines such as those contained in CERCLA or
the National Contingency Plan. Three cases were rather straight forward
emergency removal operations that were terminated when the threat of fire,
explosion or release was mitigated: Chemical Metals Industries, Gallup, and
H&M Drum. In eight other cases, the emergency response work overlapped some
planned removal or remedial actions: Goose Farm, Howe, Mauthe, Stroudsburg,
Vertac, Quanta, College Point, and Houston Chemical. For example, although
Goose Farm was labelled as an emergency response, the emergency work was
followed by ground water treatment, which is usually associated with a longer
term response. In Stroudsburg, the emergency containment measures were
followed by construction of a slurry wall and ultimately by a plume recovery
action, which generally are used in remedial actions. Despite the fact that
some emergency responses were followed by planned removal or remedial actions,
each emergency response itself appeared to be defined and terminated based on
the best professional judgment of the responsible on-scene personnel, given
the available data about contaminants and health and environmental risks.
In three emergency response cases, Houston Chemical, Howe, Inc., and
Marty's CMC, the government authorities performing the response actions
established explicit standards for themselves regarding the extent of
response. In Houston Chemical, for example, EPA and the U.S. Coast Guard
accepted the level of 10 ug/1 for pentachlorophenol (PCP), supplied by the
Missouri Department of Conservation, as the criterion for abatement of the
long term threat. This level was based on the department's research, which
included bioassays on bluegill for PCP and a review of U.S. Fish and Wildlife
Service data on the effects of PCP on fish, and constituted the department's
best professional judgment as to the appropriate clean-up level.
Remedial Actions
The extent of remedial actions in the case studies can be viewed from two
perspectives: the source of standards used for response and the manner by
which those standards were selected. Standards often were closely related to
the extent of remedial actions because they defined when a clean-up was
considered effective or complete. Sources of standards were important because
they often determined how clearly and precisely the standards were expressed,
and how justifiable or defensible the standards would be if called into
question. The manner by which the standards were chosen was important because
it determined who had authority to set and modify the standards, and it
affected the time required to decide upon a course of action.
Source of Standards
Two important categories of standards emerged in this research: best
professional judgment and pre-existing standards. These are discussed below.
Best professional judgment
Best professional judgment represents a professional's decision about the
69
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extent of clean-up needed at a particular site in light of the circumstances
surrounding the response. This type of judgment might be based on visual
observations about the extent of contamination, generally accepted scientific
studies about the effects of specific levels of toxic substances on organisms,
or the past experience of response personnel. Best professional judgments
could be exercised by a single person or represent the consensus of experts
involved in the responses, as where the On-Scene Coordinator (OSC) consults
with government officials and private parties. An example of this sort of
clean-up standard is Fairchild Republic Company, where the parties used their
best professional judgment, based on visual observations and composit soil
sample analysis, to determine that the practical extent of excavation of
contaminated materials had been reached.
Pre-existing standards
Pre-existing standards can be tailored to the features of a given site
and serve as benchmarks for clean-ups. They also can make response actions
consistent with federal and state environmental laws, such as the National
Pollution Discharge Elimination System (NPDES) of the Federal Water Pollution
Control Act (FWPCA). Pre-existing standards can be subdivided into two
classes, design standards and performance standards. An example of the use of
a design standard is the Richmond Sanitary Services landfill, where an
Administrative Order directed the company to construct a cut-off wall and
dikes in accordance with California design requirements for hazardous waste
land disposal facilities. Another case, Anonymous C, is an example of the use
of a performance standard. In that case, the company was required to continue
collecting contaminated ground water in an interceptor trench and disposing of
it in a sanitary sewer system until discharge monitoring showed a trend
indicating that total and hexavalent chromium were below the discharge limits
set by the Wisconsin Pollutant Discharge Elimination System.
Manner of Selecting Standards
Standards were chosen in three basic ways: through judicial or
administrative processes, by voluntary agreement, and by governmental
procedures followed in the course of response actions conducted by government
agencies.
Judicial or Administrative Process
In eight cases, decisions about the extent of response were made through
a formal legal process, involving either litigation that resulted in the entry
of a judicial order or a consent decree, or litigation or negotiation that
resulted in an administrative order. These formal legal orders tended to
include general goals of protecting public health and the environment as well
as specific directives for remedial action, such as installing a slurry wall
or a French drain. These orders might require the parties to exercise best
professional judgment or comply with pre-existing standards or both. They
also might establish a framework whereby the parties could propose and decide
upon future remedial action plans, as in the case of Vertac Chemical
Corporation. The research on these clean-ups indicated that judicial and
administrative orders significantly affected decisions about the extent of
response, not only by setting the standards utilized but also by formalizing
70
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the decision making process, which had the advantages of greater clarity and
assurances of compliance but the disadvantage of greater delay.
Voluntary Agreement
Another way one can analyze the extent of response is by distinguishing
between those cases where the decisions were made within the formal legal
process and those cases where the decisions are made outside of such a
process. An example of decision making without litigation is Anonymous B,
where the state informally approved a company's remedial plan, allowed the
company to proceed with its remedial action, and then evaluated the results
and agreed that the response was adequate. Trammell Crow is similar in that
the state examined and agreed with the company's proposal to solidify the oil
sludge, although this case differs somewhat from Anonymous B because the state
did have to grant formal approval of the company's closure plan for its on-
site landfill.
Government Remedial Action
Where the responsible private party was unable or unwilling to conduct a
remedial action, the local, state or federal government, or some combination
of these, had to decide what was the appropriate extent of response. In 11 of
the 12 emergency responses, as discussed above, government authorities
conducted the work, and in these cases they determined the necessary extent of
response. Further, in all of these 11 emergency responses, the government
authorities had to determine whether a remedial action, if any was necessary,
should follow certain emergency or interim measures and what type of remedial
action would be appropriate. At 6 sites, government authorities carried out
what appeared to be remedial actions after the emergency work was completed.
It should be noted that in some emergency response ands remedial actions, the
government authorities selected only the technology to be employed and not the
extent to which that technology would be used to clean up a site, while in
others they made both decisions.
INTERFACE OF KEY FEDERAL AND STATE LAWS WITH RESPONSES
The response actions studied in this research dealt with a number of
federal and state environmental laws. These laws, which included statutes as
well as regulations, were quite varied in nature, which makes it difficult to
generalize about the response actions. Generally speaking, most of the
responses were affected by laws governing hazardous substances or laws
protecting water resources, but not by laws protecting air quality per se,
although air pollution was often an important concern. Table 21 presents the
laws that affected the 23 responses.
71
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ZL
123. Vertac Chemical
X
X
X
X
X
X
X
X
X
X
122. University of Idaho
X
NJ
H
rammell Crow
X
X
NJ
troudsburg
X
X
M
^0
90
Lchmond Sanitary
X
00
JO
janta Resources
X
^•J
o
cidental Chemical
X
i
X
X
x
X
CT>
2
W. Mauthe
X
X
X
X
X
Wl
»
1-1
rt
"<
K
o
2
n
X
X
X
4>
re
s:
re
3
n
X
EC
uston Chemical
X
s
o
1-1
c
3
X
X
X
o
o
o
01
ft)
^
to
§
X
X
X
110. General Electric
X
X
X
X
0
p
1— •
4-J
c
•u
X
I 8. Fairchild Republic
X
!X
1 7. College Point
X
X
1 6. Chemical Recovery Systems
X
1 5. Chemical Metals Industries
X
X
1 4. Biocraft
X
X
j 3. Anonymous C
X
X
1 2. Anonymous B
X
X
>
•;
Cfl
>
X
w
M
H
PI
z
lesponse
Authority-
§104
Induction
Hazardous Waste
Characteristics
S6(d) Ruling-
Imminent Hazard:
Transfer Ban
ECB .
Requirements
Inj action
Ambient Water
Quality Standards
NPDES Permit
Spill Fund §311
Spill Fund
Emergency
Appropriation
Inj unction
Waste Discharge
Requirements-
Land Disposal
Facility
disposal
Requirements
Closure Plan
Elan
Injunction
Ambient Quality
Standards
Effluent
Discharge Levels.
Threat of Con-
tamination of
Well
a
CERCLAJi RCRA
H
W
P
1
FWPCA
RESPONSE
FUNDING
_J
HAZARDOUS WASTE (a) j
WATER QUALITY
'DRINKING
WATER
FEDERAL STATUTES AND REGULATIONS
STATE STATUTES AND REGL
LATIONS - BY FU
9
1-1
i
aivis am ivHaoai
HIM
-iz aiavi
-------
Laws significantly affected clean-ups in three important ways. First,
federal or state laws gave government agencies the authority to initiate
responses and provided funding for the work. The best example of this sort of
law, of course, is CERCLA. Second, laws affected response actions because
they provided the basis for governments to prompt private emergency response
or remedial efforts through enforcement. When a company was charged with
violating RCRA, the FWPCA, and several state statutes, as in the Vertac case,
the litigation led to the initiation of certain emergency response and
remedial actions at the site as well as the beginning of studies to determine
the need for further action. Third, laws affected response actions because
they contained design or performance requirements that were used as standards
to determine the extent of response.
Many laws that applied to response actions are not discussed here because
they did not affect the responses significantly or directly. For example, the
federal Hazardous Materials Transportation Act governed the transport of some
materials from sites to licensed disposal facilities, as did the more general
federal and state laws regulating trucks, but in no response examined in this
research did these laws significantly shape the planning or execution of a
clean-up.
Funding and Initiation of Government Responses
Two federal statutes, the CERCLA (Superfund) and the FWPCA, provided
money and response authority for several sites. Clean-up under the response
authority (section 104) of CERCLA occurred in three cases, Chemical Metals
Industries (CMI), Stroudsburg and Goose Farm, where emergency response actions
were triggered by the release or threat of release of hazardous substances.
For example, the situation at CMI posed an imminent threat of fire or
explosion, and the federal government, with the cooperation of the state and
local governments, conducted an emergency removal operation. All three sites
involving CERCLA also were funded in part by the section 311 spill fund of the
FWPCA. Emergency action under the FWPCA was triggered by the discharge or
threat of discharge of hazardous substances into navigable water. One site,
Houston Chemical, was funded and cleaned up solely under the authority of the
FWPCA.
State statutes provided funds and response authority for cleaning up
several sites. Two states, New Jersey (Goose Farm) and Wisconsin (Mauthe) had
spill funds that paid for all or part of the government emergency response
actions. Two other states, Massachusetts and Minnesota, were faced with
several sites requiring emergency responses and enacted a series of emergency
appropriations to pay for the clean-ups at H&M Drum and Howe, respectively.
After passing its emergency appropriation, Massachusetts enacted a special
hazardous waste clean-up fund, which provided money for work at Marty's CMC
and for part of the response at H&M.
A pattern emerged in the research concerning the funding of responses by
federal and state governments. While the cases involving federally funded
response actions had a high degree of overlap between CERCLA and FWPCA monies,
the cases where state funds were used had much less overlap between state and
federal funds. Only 1 out of 5 state funded cases, Goose Farm, also used
federal money. This pattern suggests that the federal and state governments
73
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tended to fund emergency responses exclusively. Often either a state provided
the clean-up funds, in which case the federal government provided none, or the
state provided little or no money, in which case the federal government
provided it under CERCLA or the FWPCA.
Initiation of Private Response
The enforcement of federal and state environmental laws prompted the
initiation of all of the private responses studied except one, Trammell
Crow. Enforcement took several forms: litigation in court that resulted in a
consent decree, injunction or other judicial ruling; negotiations with or
proceedings before an administrative agency that led to an administrative
order or administrative consent order; or an administrative ruling by an
agency directed at a particular company. These legal measures were important
because they prompted the initiation of response actions, specified clean-up
standards and goals, and once the required activities were completed, often
served as the basis for terminating responses. Further, the legal orders and
rulings provided a means of ensuring that follow-up monitoring of the sites
would be done and that any needed future remedial work could be compelled
readily.
Federal enforcement efforts fell under three statutes: the Resource
Conservation and Recovery Act (RCRA), the Federal Water Pollution Control Act
(FWPCA), and the Toxic Substances Control Act (TSCA). All three statutes were
relied upon in various proceedings against Vertac Chemical Corporation, for
example, along with several state laws. The EPA sued Vertac for violating
RCRA as well as the FWPCA1s ambient water quality standards and NPDES effluent
discharge levels. The agency also sought and obtained injunctive relief based
on RCRA and the FWPCA. While several remedial actions had already been
completed at the Vertac site, some of which were required by an earlier state
administrative order, the EPA1s lawsuit led to the company's initiation of
several specific remedial actions, as well as engineering studies about the
effectiveness of past remedial actions and the need for future on-site and
off-site actions.
One enforcement measure taken under TSCA that prompted the initiation of
a private response was found in the case study research, and also involved
Vertac. The EPA Administrator issued a section 6(d) ruling, the first of its
kind, that directed the company not to transport drums containing 2,4-D still
bottoms, which were contaminated with dioxin, from the plant site for
disposal. This ruling occurred during the period in which Vertac was taking
various response actions required by the prior injunction arid state adminis-
trative order, and forced Vertac to change its disposal plans from off-site
disposal to incineration or chemical destruction and recycling.
State enforcement efforts under hazardous waste, water pollution and
public health laws were found more frequently than federal efforts in the 23
case studies. In 7 cases, a state administrative order was entered that
specified what clean-up work had to be done: Anonymous A, Anonymous C,
Biocraft, General Electric, Occidental Chemical, Richmond Sanitary, and
Vertac. The circumstances in which administrative orders were made varied
considerably in terms of how the situation was brought to an agency s
attention, whether the agency formally charged a company with violating the
74
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law or simply told the company that it had to comply with certain
requirements, and whether response work began before or after entry of the
order.
Two cases, Chemical Recovery Systems, Inc. (CRSI) and Gallup, involved
lawsuits brought by state agencies in state courts. These two lawsuits
prompted the initiation of private response actions in different ways. In
CRSI, the suit was settled by a consent decree that stated what sort of
remedial actions the company would take (e.g., construct a slurry wall
according to explicit specifications). The Gallup suit was brought by the
state against Mr. Gallup, the site owner, who pleaded nolo contendre and
agreed to reimburse the state for its clean-up costs. In Vertac, the state
followed its administrative order by joining the U.S. EPA in a suit against
the company that was brought in federal district court, not state court. The
state and EPA first obtained an injunction that required Vertac to take
certain actions, then eventually settled the case by a consent decree that
specified further remedial wtfrk.
State hazardous waste laws provided the basis for many of the state
lawsuits and administrative proceedings. In Vertac, for example, both the
administrative order and the state's complaint in the lawsuit were brought
under the enforcement authority established in the Arkansas hazardous and
solid waste management laws. California's hazardous waste management law
governing operating land disposal facilities was enforced by orders issued by
the Regional Water Quality Control Board in two responses: Richmond Sanitary
Service and Anonymous A. State hazardous waste laws governing disposal were
also enforced in 4 cases, Occidental Chemical, General Electric, Fairchild
Republic and Anonymous C. In Fairchild Republic, for example, a contractor
hired to do the excavation and removal work was prosecuted and convicted in
state court of illegally disposing of contaminated materials from the
Fairchild Republic site. In Anonymous C, the company itself was charged with
illegal disposal of chromium at its plant.
State water laws were the basis for several enforcement actions.
Biocraft and Vertac involved administrative orders prompted by charges that
the companies had violated ambient quality standards or effluent discharge
limits. As discussed above, in CRSI and Gallup, state agencies brought suit
in state courts, alleging violations of water laws. In Vertac, the state sued
in federal district court along with EPA, alleging that the company had
violated Arkansas ambient water quality standards and effluent discharge
limits, in addition to the alleged violations of the hazardous waste laws.
This case was settled by a consent order.
State laws concerning public drinking water supply wells led to the
initiation of remedial measures in 5 cases, H&M Drum, University of Idaho,
Marty's CMC Occidental Chemical, and Biocraft. In H&M Drum and University of
Idaho, state agencies were concerned with the distance between a hazardous
waste site and a drinking water supply well. In H&M, the state Department of
Environmental Quality Engineering ordered the town of Dartmouth to close a
well near the dump site as a precaution, but several months later advised the
town that it could reopen the well. When it closed the well, the town had to
take the response measure of obtaining alternative drinking water supplies.
In the University of Idaho case, the City of Moscow proposed to install a
75
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drinking supply well near the university's dump site, and the state Department
of Health and Welfare required the university to conduct a study of potential
health hazards posed by the site. This requirement was one of the factors
that led to the initiation of remedial action at the site. Marty's CMC and
Occidental Chemical were cases where state authorities closed drinking water
wells due to contamination, while at Biocraft the state closed a well because
of the threat of contamination. The closing of wells in these latter 3 cases
was part of the initial response measures, which were carried out by the state
at Marty's CMC and by private companies at Biocraft and Occidental Chemical.
Laws Affecting Implementation of Responses
One of the most important ways in which laws affected clean-ups was by
serving as sources of standards that were imposed upon remedial actions, as
dicsussed above in the "Basis for Extent of Response" section. Often a
judicial or consent order would take design or performance standards found in
federal or state laws, whether or not they were being enforced in that
particular case, and require that the responsible party comply with them.
This had the result of making the sites consistent with the state or federal
regulatory frameworks.
Two cases in California involving land disposal facilities showed how
pre-existing standards can affect remedial actions. The California
Administrative Code contains provisions governing discharge requirements of
solid waste disposal facilities as they relate to surface and ground water
quality. These Administrative Code regulations were promulgated by the State
Water Resources Control Board under the authority of the California Water
Code, and provide that Regional Water Quality Control Boards (RWQCB's) can
establish the particular manner by which a land disposal site shall meeet
waste discharge requirements. The RWQCB's can prescribe for particular
facilities various design and performance standards relating to land
discharge, surface water controls, subsurface drainage facilities, waste well
construction, and site closure plans. A RWQCB imposed both design standards
and waste discharge requirements upon companies in two cases, Anonymous A and
Richmond Sanitary Service. In Anonymous A, the RWQCB required J;hat the
company install barrier walls that had a permeability of less than 10 cm/sec
and permitted no discharge, pursuant to the requirements for a Class II-l
hazardous waste disposal facility. Similarly, in Richmond Sanitary Service,
the RWQCB set design standards based on state Class I hazardous waste disposal
facility regulations (5 foot cut-off wall with permeability of less than 10
cm/sec, specifications for height of dike, etc.) as well as performance
standards for run-off discharge. These detailed design and performance
standards were applied in remedial actions in order to upgrade the two
facilities so that they would comply with California's regulations for land
disposal facilities.
Design standards in less explicit form were used in two other remedial
actions, Trammell Crow and Fairchild Republic, where particular closure plans
were submitted to state authorities for approval. In Trammell Crow, the on-
site landfill for solidified oil sludge was treated as a Class II industrial
waste landfill. The company submitted the closure plan to the Texas Water
Resources Board, which had authority over it pursuant to the Texas hazardous
waste law, and the Board approved it. However, no detailed design or
76
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performance specifications such as those found in the California cases were
imposed. In Fairchild Republic, the situation was similar in that the closure
plan was submitted for state approval, with the difference that what was
approved was the closure of an excavated area rather than a landfill
containing hazardous substances. Hence, there were few ways in which the
state could impose specific design and performance standards at Fairchild
Republic, other than for backfilling and capping.
In addition to hazardous waste laws, water pollution control laws
provided standards for several response actions. Effluent discharge limits
contained in National Pollutant Discharge Elimination System (NPDES) permits
were used directly or indirectly as performance standards in 5 responses.
State effluent discharge limits were also used in two of these cases, Vertac
and Occidental Chemical. In two other cases, Anonymous C and Quanta
Resources, only state effluent discharge limits were used.
Vertac is an example of the direct use of a NPDES permit. In this case,
the company already had a NPDES permit for its plant for process wastewater,
but had exceeded the levels for some pollutants. State and federal
authorities required the company to undertake remedial actions at the plant
site to reduce the discharges to within permit levels. Cases where NPDES
permits served indirectly as clean-up standards are Anonymous B, General
Electric, College Point, and Quanta Resources. In General Electric, for
example, the state indirectly based the pretreatment standard for the plant on
the federal ambient water quality criterion for PCB. This standard was
influenced by the capacity of the local publicly owned treatment works (POTW)
that received the discharge, which had a NPDES permit.
Government authorities used effluent discharge limits as performance
standards even when companies did not have a NPDES permit and the permit held
by a POTW was not the primary concern. At Anonymous C, ground water had to be
pumped out and properly disposed of until a trend emerged in the contaminant
levels (less than 0.5 mg/1 for total chromium and less than 0.05 mg/1 for
hexavalent chromium) that fell within the Wisconsin Pollutant Discharge
Elimination System. At Occidental Chemical, the state used the "action level"
that had been set specifically for dibromochloropropane (DBCP) contamination
in ground water as the effluent discharge limit for treated water to be
discharged into a deep saline aquifer below the plant. In this way, DBCP was
used as a surrogate criterion for other contaminants.
In one case, Biocraft, the administrative consent order set specific
performance standards for cleaning up the site using ambient water quality
standards. The order required the company to operate its decontamination
system until the ground water met the explicit contaminant standards or until
the state determined that the system was incapable of achieving those clean-up
standards.
One final way in which laws provided standards in these response actions
concerned TSCA. At College Point, General Electric, Marty's CMC, and Quanta
Resources, the managers of the clean-ups were specifically aware that TSCA
governed PCB in waste oil in excess of 50 ppm, and conducted the response
actions accordingly in terms of removing, transporting and disposing of
contaminated materials. The effect of TSCA was to provide an alternative set
77
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of performance standards for these responses, since PCS wastes had to be
handled differently than non-PCB wastes.
Another way in which TSCA provided a performance standard occurred in the
Vertac case, where the EPA Administrator issued a section 6(d) ruling. This
ruling was directed specifically at Vertac and prohibited the company from
transporting dioxin-contaminated 2,4-D still bottoms off-site for disposal.
In forcing the company to change its remedial plan regarding disposal, the
ruling drew a line between permissible and non-permissible performance.
SELECTION OF CONTRACTORS
The researchers found that the ways in which private parties and
governments selected contractors for clean-up work differed in three main
respects: (1) the procedures by which contractors were chosen; (2) the
criteria used to select contractors; and (3) the types of contracts used.
Table 3 groups the data into these three categories, and then divides the data
further into numerous subcategories.
The data seem to suggest that government authorities tended to use sole
source selection procedures, to rely heavily on the technical qualification of
contractors as a criterion for selecting firms, to use time and materials
contracts, and to allow subcontracting. It also appears that private
companies also used sole source selection procedures frequently, but tended to
use bidding procedures more often, to make selections based on a more balanced
set of criteria, and to favor lump sum and unit price contracts as a way of
controlling costs. However, these generalizations should be tempered by the
fact that 10 out of 11 government responses were considered to be emergency
removal actions. When time is of the essence, it appears more plausible to
select qualified contractors quickly. Since in most emergency situations
little is known about the actual nature and extent of contamination, a time
and materials contract may seem not only expedient but necessary.
Subcontracting also seems more appropriate when a response might encounter
hazardous situations that require rapid mobilization of special services.
The private cases, in contrast, were primarily remedial actions where the
companies had enough time to determine the scope of the needed responses.
More preliminary investigations were conducted and remedial action plans
developed. Usually, government authorities participated in the investigative
and planning phases of the work. As a result, the private firms were in a
better position to know what had to be done, and could use bidding procedures,
balanced criteria for selection, and lump sum or unit price contracts to
control costs. In light of the differences between the types of response
actions then, it does not appear that the data will support many broad
generalizations about the respective abilities of the private and public
sectors to select appropriate contractors and control response costs. The
comparison of private and public approaches should take into consideration the
types of response actions involved.
The data on selection of contractors were taken from interviews from on-
scene coordinators, contracting personnel and, where available, from copies of
contracts, proposals and contractor selection guidelines. Table 22 is
intended to show which response actions fall into the listed categories. Many
78
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TABLE 22. SELECTION OF CONTRACTORS
VO
PRIVATE RESPONSE ACTION
GOVERNMENT RESPONSE ACTION
Sl'Ifc NAME
1. Anonymous A
2. Anonymous B
3. Anonymous C
4. Biocraft
5. Chemical Recovery
Systems
6. Falrchlld
Republic
7. General Electric(b)
8. Occidental
Chemical
9. Richmond Sanitary
10. Trammell Crow
11. Vertac Chemical
1. Chemical Metals
Industries
2. College Point
3. Gallup
4 . Goose Farm
5. HiM Drum
6. Houston Chemical
7. Howe, Inc.
8. Marty's CMC
9. N.W. Mauthe
10. Quanta Resources
11. Stroudsburg
12. Univ. of Idaho
SILECTINC, CONTRACTORS
Open Compete-
tlve Bid
X
X
X
X
X
X
X
X
Request for
Bids from
Pre-selected
Group
X
X
X
X
X
X
X
0)
u
3
O
VI
01
1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Informal
X
X
X
X
X
Pre-existing
Contract
X
X
X
X
Emergency
.SlSSHKfifBL -
CRITERIA FOR SELECTION j
Lowest Bid
X
X
X
XI
X
X
X
X
X
X
x
X
X
52.
•3 *J C
•r* « «
X
X
X
X
X
X
X
Experience
and Technical
Qualifications
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
w >
» u C
(0 C -H
DM 01 1*.
X
X
X
X
X
X
X
Reputation
X
X
X
X
X
X
X
Proximity to
Site
X
X
X
X
X
X
X
X
Familiarity
with Site
X
X
X
X
X
Guarantee of
Technology
X
X
1
X
X
X
Technical
Approach of
.EliESSSl.
ii
i
«
i
N
TYPE OF CONTRACT
Subcontract
Let by
Contractor
X
i
i *
:
i
i
H
1
j
X
! x
H
: x
j X
x : x
! *
! x
X
X
x !
1
* i
x !
i
vt
I
X
X
X
X
X
X
X
X
X
Time and
Materials
X
X
X
X
X
X
X
X
X
X
X
X
X
si
x
X
u
a.
a
X
X
X
X
X
X
X
Price List
on File-By
Contractor
X
X
X
Celling
X
X
X
X
X
X
X
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TABLE 22, (continued)
oo
o
DESCRIPTION OK CAIKdUKLKS
Procedure for Sricrt Infi Contrac t ors
Open Competitive Hid - where public
announcement of Job or RFP Is made
and any interested party rnn respond.
Ri-fMic-st for Hlds from I're-seli t li il
(Jruup - where the responsible party
seeks bids from firms that were
pre-selected based on criteria
buch as prior experience, tt't (inleal
qualification*, general reputation,
etc.
Sole Source - whore the responsible
party hires a particular firm
without .my bidding by other firms.
Informal - win-re the responsible p.irty
selects and hires a firm without
following express procedures or
guidelines ; contract could be
oral or written.
Prc— existing Contract - where the
responsible p.irty had an ongoing
contract with a firm to provide
various services at a site or
particular services at similar sites.
Emergenty Procurement - where the
responsible party, usually a
government ngt-ncy, has special
procurement powers for emergency
response actions.
C r11 er i 3 fur Selection
Lowest Bid - the lowest price quoted
for the work to be performed. Used
primarily in procedures Involving
competitive bidding or bidding by
pre-sclected group, and where lump
Hum or fixed price contracts are
uied.
Bid In Competitive Range - bid was not lowest
but among the lowest; other criteria may have
a role in the decision.
Experience and Tt-ihnli.il (Ju.il II Ic.illnnt - :i firm's
experience with, the proposed kinds of response
work; Its technical expertise to do the job.
Past Experience with Firm - the responslbe party's
prior dealings witti a firm in similar work
situations.
Reputation - what is generally and informally known
about a f inn1 s competence, prof cantonal standards
and management capability.
Proximity to Site - how far a firm has to travel
to work cm-site or how far materials have to be
transported from the site to a facility for
treatment or disposal.
Familiarity with Site - usually based on previous
experience working on-site for the responsible
party or working with local geology; may Include
knowledge of plant operat ions, hydrogeology,
previous remedial actions, etc.
Guarantee of Technology - contractual guarantee
that technology, e.g.,3 slurry wall, will
meet stated specifications.
Responsiveness to RFP - how well a proposal
responded to the responsible party's Request
for Proposals, which usually describes the
known or expected contamination or threat.
Management Responsibility - how well a firm ran
organize and manage a task; whether It can be
depended on to complete Its work In A profrsslon.il
manner. This may include financial responsibility
and solvency as well.
Technical Approach of Proposal - tiow well a
firm analyzed a situation and proposed
a course of action, from an engineering,
rhemf r.tl or sr irnt I Mr standpoint.
Tyj>c of Contract
Subcontract Let by Contractor - contract
made between a primary or general con-
tractor having broad authority for a
response and a subcontractor for
spcclfie tasks.
Lump Sum - a contract tn.it states a total
price for given activities, e.g.,
$60,000 for a ground w.-iter study.
Time and Materials - where the contractor
1)11 Is the responsibl e party for the
labor of its personnel as well as for
the rontr.K tor's rosts of procuring con-
sumable cqulpmi nt and materials; this
may or may not have a celling.
Cost Plus f Ixed Fee - a cont ract whereby the
contractor is palJ alJ of Its direct
costs of the work, sui h a-, purchase of
consumable equipment, as well .m a fee
that could be a lump sum, percentage of
total construction cost, etc.
Unit Price List on File - by Contractor -
some responsible part ies, usually
government agencies, keep a price list of
tlie costs for labor ,ind mater la 1 s sub-
mitted by various contractors, s-o thit
the responsible parties can more readily
price list may be incorporated Into the
contract.
Cel I Ing - the upper 1 Imit ol ,i respons ible
party's liability on a contract* rei-.ardles-
of wherthcr It Is fixed price, time and
materials, etc.; disbursement limits or
temporary HmlLH on upending authority
arc n«t included In this category.
-------
response actions involved more than one contractor. When this occurred, each
process by which a contractor was selected is marked on the table. For
example, in Fairchild Republic Company, three contractors were hired by the
company, and one contractor hired several subcontractors. The engineering
contractor was hired on a sole source, lump sum contract and the two
excavating and hauling contractors were hired based on separate competitive
bidding procedures, one as lowest bid and one as a bid in the competitive
range that was from a contractor known to be reputable. The table lists all
of the contractor selection issues: competitive bid, sole source, bid in
competitive range, reputation, and subcontract. This way of presenting the
data enables one to identify how many times a particular issue, such as
competitive bidding, appears in the 23 case studies. To find the selection
process used for a certain contractor in a given response action one can turn
to the "Selection of Contractors" secton of that case study.
The case studies are also divided into private and government response
actions in this table. This allows one to compare the selection procedures,
criteria for selection, and types of contracts used by the private sector with
those used by the public sector. For example, one can compare the number of
cases where competitive bidding was used in private versus public response
actions, which are 5 and 3 occasions, respectively, or the number of cases
where a time and materials contract was used, 3 and 10, respectively. Such a
format provides a general idea of how public and private entities select
contractors for response actions.
Procedures for Selecting Contractors
The most common procedure used was the sole source method, which was
found in 18 of the 23 case studies. Competitive bidding was the next most
common with 8 appearances, followed closely by requests for bids from pre-
selected contractors at 7 appearances. When combined the two bidding
categories account for 15 of the 23 case studies. Pre-existing contracts,
informal selections and emergency procurements were found at about one-half
the frequency of the two bidding or the sole source categories.
Criteria for Selection
The criteria of experience and technical qualifications were the most
commonly used basis for selecting contractors, appearing in 17 of 23 case
studies. Lowest bid and proximity to site were next, with 8 occurrences each,
followed by past experience with a firm and reputation (7 each), familiarity
with site (5), and technical approach of the contractor's proposal (4). The
remaining criteria, guarantee of technology and management responsibility,
appeared twice each.
Type of Contracts
Three principal types of contracts were encountered in this research:
time and materials (13 cases), lump sum (9 cases), and unit price (7 cases).
Two cases involved cost plus fixed fee contracts and three cases had contracts
using a contractor's price list that was on file with a government agency
before the response began. Two characteristics of contracting were frequently
found: the use of ceilings and the letting of subcontracts by primary or
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general contractors. In 8 cases, contracts that contained ceilings were used,
and these often were time and materials contracts. Subcontracts appeared in
10 cases.
Private and Government Response Actions Compared
The data in Table 3 show some differences in the way private and public
parties selected contractors for response actions. Some of the more
noteworthy points of comparison are discussed below.
Procedures for Selecting Contractors
Private and public responses appeared to use selection procedures with
roughly the same frequency. For example, of 11 private actions, 5 used
competitive bidding, 4 used bidding from pre-selected groups and 9 used sole
source methods, compared to 12 government responses, which used 3 open bids, 3
bids from pre-selected groups and 9 sole source contracts. Some differences
in selection procedures can be explained in terms of the different
responsibilities of government versus private response authorities.
Government actions included 5 cases involving pre-existing contracts and 3
cases using emergency procurement procedures, two features that are fairly
common with agencies charged with the responsibility for responding to
emergency situations. Only one private response involved a pre-existing
contract, and in that case the contract was for a broad rang;e of engineering
services relating to construction at the site. Informal selection of
contractors occurred in several private actions but in no public actions,
probably due to government procurement requirements.
In three cases, Quanta Resources, Marty's GMC and H&M Drum, the state
hired a management consulting firm to establish criteria for selecting
contractors by competitive bidding and to evaluate proposals. The state then
hired the contractor recommended by the consulting firm. A similar procedure
occurred in Trammell Crow, where a private company that owned the site had an
engineering consulting firm, which had developed the remedial action plan,
evaluate contractors' competitive bids. The company hired the contractor
recommended by the engineering firm.
Criteria for Selection
All government response authorities stated that they selected contractors
based at least in part on the firms' experience and technical qualifications,
while only half of the private response authorities did so. The next most
common criterion used by governments was proximity to the site (4 cases),
followed by lowest bid, past experience with a firm, and the technical
approach of proposals (3 cases each). Bids in the competitive range and
reputation each appeared in three cases. These data suggest that government
agencies always looked at a contractor's technical expertise, but that in less
than half of the cases they also looked at other factors such as lowest bid,
bid in competitive range, etc.
Private companies directing response actions used these criteria with a
more even frequency. Cost considerations seemed to be more important in these
actions: lowest bids appeared in 5 of 11 cases and bids in. the competitive
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range in 4 cases. Four cases involved selections based on past experience
with the contractor or the contractor's reputation. The contractor's
familiarity with the site appeared in 5 cases. Proximity to the site appeared
4 times and technical approach of the proposal only once. An interesting
criterion, contractual guarantee of technology, was found in two private
responses. One criterion, management responsibility, apparently related to a
more formalized screening of contractors because it never appeared in the
private response cases. On the whole, it seems that private firms used
several criteria with about the same frequency, but that no single criterion
was used in every case.
Type of Contract
Government agencies used time and materials contracts in 10 of 12
response actions, compared to only 3 of 11 occurrences in the private cases.
Contracts included ceilings in 6 government cases and 2 private cases; each
time a ceiling was used, the contract was for time and materials, whether
public or private. Government authorities allowed primary or general
contractors to let subcontracts in 8 cases, whereas only 2 private cases
involved subcontracts. Private companies seemed to use lump sum and unit
price contracts more often than governments. Private responses had 6 lump sum
and 4 unit price contracts, as compared to government responses, which had 3
lump sum and 3 unit price contracts. Two private cases involved cost plus
fixed fee contracts and two government contracts incorporated contractors'
price lists that were already on file. Thus, i|t appears that private
companies used types of contracts that could provide more certainty about and
control over response costs, while government authorities used less
controllable forms, such as time and material contracts, but often sought to
control costs by imposing ceilings. Also, private firms tended to do their
contracting directly with all contractors, regardless of how minor or
specialized the services were, while government officials were more willing
for primary contractors to subcontract for specialized work.
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SECTION 6
FINDINGS AND RECOMMENDATIONS
The findings and recommendations in this section are based on general
observations from the broad-based research for the nationwide survey and
detailed case studies. They are useful for defining and understanding the
nature of hazardous waste problems and site response activities in the United
States today. These conclusions are also useful for planning future site
response activities or improving those response activities which have already
taken place, in the most cost-effective and technically sound manner possible.
The following subsections present the findings and recommendations based
on the nationwide survey, followed by the findings and recommendations based
on the 23 case studies.
NATIONWIDE SURVEY FINDINGS AND RECOMMENDATIONS
A number of conclusions can be drawn from the nationwide survey results
regarding the nature of uncontrolled hazardous waste sites in the United
States and the remediation technologies implemented at the sites. The most
significant conclusions include the following:
• More than one-half of the 395 sites identified are abandoned or
inactive facilities.
• More than one-half of the 395 sites identified are Superfund priority
sites.
• Surface impoundments and landfills are the most common waste manage-
ment practices employed at the identified sites.
• Metals and solvents are the two most prevalent types of contaminants
found at the sites identified through this survey.
• Ground water and surface water are the media types most frequently
contaminated at the identified sites.
• Almost one-third of the remediation programs implemented at the sites
involved a combination of remedial action techniques.
• The most common remediation technique implemented to date has been the
removal of waste and contaminated materials from the identified sites.
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• EPA Regions IV and V contain the greatest concentration of
uncontrolled hazardous waste sites where remedial actions are either
planned, ongoing, or completed.
This survey has been valuable in assessing the number of uncontrolled
hazardous waste sites across the country where remedial response actions have
been completed, are ongoing, or are in* the planning stages, as well as what
types of technologies are being implemented. It is anticipated that the
information provided by this survey and the accompanying case study reports
will serve as a guide for future clean-up efforts from both a technical and a
managerial perspective. Additionally, this information is a measure of the
development and implementation of remedial response actions through 1982. It
is recommended that this information be used as a comparative measure with
future studies of this kind in order that members of both government and
industry can identify the options which are available to them and the general
direction in which hazardous waste site response is taking in the United
States.
FINDINGS AND RECOMMENDATIONS BASED ON 23 CASE STUDIES
The findings and recommendations in this subsection are based on general
observations from the research for the 23 case studies. To some extent, the
National Contingency Plan addresses the issues raised here; the recommenda-
tions simply focus on more specific considerations that merit attention in the
management of remedial actions. The three issues discussed here are:
• Technology selection
• Planning the extent of responses
• Documentation of responses.
Technology Selection
Findings
Upon careful examination of the remedial response technologies chosen at
the 23 case study sites, it is evident that decisions were based on various
factors such as:
• Objective of response
• Site specifications/characterization
• Available technologies
• Engineering standards
• Long term effectiveness
• Cost
• Regulatory compliance
• Public interest
• Economic return on investment.
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Because no decision could be based solely on one factor, at each site,
all or a combination of these factors were considered to some extent. Of
primary importance was the objective of the site response—what was the
purpose for choosing the response technology? Keeping this in mind, tech-
nology selection had to be quite site specific, hence the best technology
chosen for a site was contingent upon site specifications and characteriza-
tions. This not only included the nature and type of contamination present,
facility type, and status of operation (active, inactive, or abandoned), but
it also included the physical characteristics of the site such as hydro-
geologic setting, surface characteristics, climate, and proximity to drinking
water supplies, residential areas, unique environments, etc.
Once these factors had been outlined, decision makers determined what
technologies were available to them. Generally this involved evaluating
several technologies because there were frequently a number of technologies
which could have remedied a specific problem and/or because the nature of the
problems at the case study sites were multi-fold. For instance, a ground
water contamination problem not only involved responding to the actual ground
water contamination itself but also involved responding to the cause of the
contamination to prevent further problems.
By determining the technology options available, decision makers could
then examine the engineering and design standards relevant to a particular
site, thus judge which responses were technologically feasible. Another
consideration from the engineering perspective was that of long term
effectiveness—how useful would this response activity be in years to come?
In some instances, it was evident that this was a major concern and that
technologies have been implemented where long term monitoring is in effect.
In other instances it was evident that this was not a major concern and
therefore long term monitoring has not been implemented.
Also of major concern in selecting response technologies was cost. The
technology options in most instances were evaluated not only for their ability
to remedy hazardous waste problems, but also for their cost feasibility. In
the long term, high cost technologies can prove ineffective because mainte-
nance and upkeep on a complex system can be too costly. If a facility
operator does not have the ability to keep such a system in optimum working
condition, then the response cannot be successful. These case studies have
shown that technology selection has been in many cases based on compromises
between technical and economic feasibility.
In addition, selection of site response technologies, as these case
studies have shown, is based on compliance with the intent of Federal and
State regulations to the extent possible. This includes compliance with the
intent of RCRA, CERCLA, OSHA, etc. during selection and implementation of
remedial response actions. For instance, at sites where wastewater treatment
systems were installed, systems were designed to ensure that the treated
wastewater was within compliance with the National Pollutant Discharge
Elimination System (NPDES) prior to discharge into a tributary.
Another factor considered at some of the sites was that of public
interest. Because of the overall sensitive nature of hazardous waste issues,
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technology selection in some instances took public interest into consider-
ation. For example, at one site plans for implementation were designed so
that construction could be halted if a threat to human health was evident
because of high winds. In other cases, design plans submitted by private
companies to State officials were explained to citizens' groups who had the
opportunity to comment on the plans.
The most successful of the response actions at the case study sites were
those that took into consideration all of these selection considerations.
This could be ensured through a systematic approach to technology selection.
Benefits
It is essential that the remedial actions selections process evolve
around a systematic approach tailored to achieve the objectives of the
remediation effort. The ultimate benefit of such an approach is the creation
of an effective management scheme for remedial action selection. By imple-
menting an organized management approach several inherent problems observed in
the case studies evaluation may have been avoided. For example, at several
sites, had a clear definition of the objectives of the remedial actions been
established, then the extent of the response and degree of clean-up could have
been developed (i.e., in the action of an emergency removal or the initial
stage of a long term remedial activity). By setting remedial actions
objectives (scope of work to be performed) several communication, costs, and
technology selection problems are avoided or reduced.
It is more likely that implemented action will succeed if a system exists
for selecting remedial alternatives which factors in elements such as site
characteristics, cost, response objectives, and other key decision elements.
For example, in the case of an emergency action little time is available for
evaluating and selecting the type of remedial action. However, if a series of
reference charts were available which outlined the positive and negative
aspects for implementing various alternatives, then the decision maker could
quickly compare the site specific conditions with the limiting factor for each
remedial option. Using this gross comparison he could then select the most
feasible option and as a result reduce the risk of making a poor selection.
The benefit of remedial actions design guidance is realized most during
the implementation and long term performance of the action. Once a remedial
alternative has been selected there exists a need to design the action so as
to meet or exceed the performance standard specified in the response objec-
tives. It is necessary that guidance be provided which des.cribes the baseline
design requirements for the various remedial actions (i.e., where to key
slurry walls, how large drain pipes should be, and what chemicals are effec-
tively treated by carbon absorption). With these baseline design requirements
available the planner is able to develop construction specifications which
will assure effective implementation of remedial actions.
Recommendations
The National Contingency Plan has established a process for planning site
responses. Within section 300.67 guidelines are provided on criteria and
screening methodologies for selecting remedial alternatives. However, no
specific guidance is provided on the steps or tools for conducting a remedial
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action selection analysis. It is recommended that a methodology be developed
for selecting remedial actions at uncontrolled hazardous waste sites on the
basis of site characteristics and anticipated level of response. This should
provide the user with mechanisms for evaluating candidate remedial actions by
considering the following:
• Media to be controlled
• Characteristics of the contaminants
• Objective of the remedial action
• Design and application limitations and advantages of the remedial
actions
• General cost feasibility
• Compliance with regulatory requirements
• Development of a post-remedial action monitoring plan.
A systematic procedure illustrating the steps for collecting and
evaluating the supporting data needs to be created in order to perform an
evaluation of the factors listed above. Briefly, these steps should include
identification of the problem; evaluation of the extent and nature of contam-
ination; collection of site specific data and determination of remedial
options; comparison of remedial options with site-specific characteristics,
costs, and regulatory requirements; development of preliminary recommendations
for remedial actions; and recommendations of a post-remedial action monitoring
plan.
Planning the Extent of Responses
Findings
In many of the responses studied, decision makers did not establish
specific physical standards regarding the extent of response before beginning
clean-up work, or in some cases, before completing clean-up work. Reasons for
this include: time constraints in emergency responses; uncertain funding; and
lack of data on the extent of contamination or feasibility of achieving a
predetermined standard. This lack of standards sometimes was an obstacle to
effective planning and management of responses, making it difficult to project
the amount of funding that would be required and to choose the most appro-
priate response technologies.
Many of the responses examined, however, demonstrated that it is possible
to establish specific physical standards regarding the extent of remedy prior
to initiation of responses. Decision makers often used or adapted existing
standards for pollutants, referring to drinking water standards, effluent
discharge standards, crop tolerance limits, suggested no-adverse-response
levels, and others. These standards, however, were not always stated clearly
at the outset of the responses.
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Benefits of Setting Response Standards
Goals expressed in terms of specific standards are basic tools of
effective management. Standards regarding the extent of response, established
before clean-up work starts, allow response managers to select the most appro-
priate technologies and predict demands on funding. As responses are
performed and completed, response managers can use the standards to evaluate
the performance of technologies and decide whether further work is needed.
The primary benefit of specific standards as discussed here is as management
tools in individual responses. The policy questions of the most appropriate
sources of standards, or their applicability across sites, are beyond the
scope of this study.
Recommendat ions
It is essential that response managers establish, after site investi-
gation and prior to beginning clean-up work, explicit clean-up standards
defined by specific physical parameters. The standards should be incorporated
into the Remedial Action Master Plan (RAMP) and should serve as the basis for
planning and managing the clean-up. However, it should be recognized that
standards may have to be modified later, as technical limitations become
apparent or new data become available. The Remedial Action Master Plan should
specify, to the extent possible:
• Acceptable levels of contaminants allowed to remain in the soil,
ground water, surface water, or air after a clean-up is complete
• Acceptable uses of the site or site environs after completion of
clean-up
• If remedial structures or devices are installed on-site, the amount of
time they will be maintained or operated
• The methodology that will be used to evaluate the performance of the
remedial measures and determine if the standards have been met.
Documentation of Responses
Findings
The case study research found that the documentation of both government
and private responses was often not conducive to retrospective analysis of the
response. Consequently, a substantial amount of the researchers' time was
invested in reviewing files and conducting interviews in order to determine
the task-specific costs, bases for decisions, and technical details of
responses. It became apparent during the research that, if lessons are to be
learned from future hazardous waste site responses, clean-ups will have to be
documented in a manner that provides ready access to the relevant data without
such a great expenditure of resources. The most useful documentation would be
a summary report similar to the On-Scene Coordinator's (OSC's) reports
required for responses under section 311 of the FWPCA, but would provide more
specific details on costs, decision making, and performance of technology.
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Benefits of Improved Documentation
Cleaning up hazardous waste sites is a new field in science, engineering,
and public policy. Consequently, little data are readily available on the
performance and costs of remedial technologies and on management of clean-ups.
Such data will be required for effective planning of the large number of
clean-ups that State and Federal agencies will manage in coming years. While
the case studies in this report provide useful reference points for costs,
technologies, and decision making, data and experience from a much larger
sample of sites will be required to improve the cost-effectiveness of the
diverse range of future clean-ups.
A central file of summary reports on site investigations and clean-ups
detailing task-specific costs, performance of technologies, and decision-
making would assist:
• Planning and management of future clean-up
• Cost-recovery litigation
• Clean-up negotiations with responsible parties
• States' management of their own clean-ups.
The data file would aid in planning and management of individual clean-
ups. By reviewing the costs and performance of past site investigations and
responses, decision makers would be better able to evaluate bids and
proposals, select contractors, and predict the cost and duration of the
various tasks that comprise a clean-up. The data file could continue to
assist decision makers during clean-ups by providing examples of solutions to
unanticipated problems in past responses.
The summary reports would assist cost recovery litigation by providing
coherent explanations and justifications for expenditures and decisions
associated with individual cases being litigated, and by facilitating compar-
ison of costs of litigated clean-ups with similar sites in order to justify
expenditures.
The data file would assist in clean-up negotiations with responsible
parties. By reviewing the range of costs of similar previous clean-ups,
government negotiators would be better able to estimate the costs of clean-
ups, thereby strengthening their negotiating positions.
Finally, the data file would improve the States' ability to perform or
contribute to remedial actions by giving them access to a nationwide pool of
experience with remedial action management, costs, and technologies.
Recommendations
The National Contingency Plan (NCP) discusses the need to provide
documentation of responses under CERCLA and the FWPCA, and is a useful
starting point for guidance on what such documentation should include. Under
Subpart F, which addresses hazardous substance responses, section 300.69
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requires that adequate documentation be maintained, but does not specify the
content and format, and does not require an OSC report for each response.
Under Subpart E, which addresses oil removal, sections 300.54 and 300.56 are
somewhat more specific, but even if they were applied to hazardous substance
responses, they would not provide sufficiently detailed and accessible data on
costs and institutional aspects of clean-ups. Section 300.54 refers to
documentation requirements under 33 CFR section 153. In section 153.415(c),
the OSC is required to provide in a summary report an estimate of the cost of
each function performed by each agency and contractor. This is an important
requirement and should be applied to hazardous waste responses as well.
Section 300.56 of the NCP provides a specific outline for OSC reports on
oil spill responses, but does not require all of the institutional and cost
data that would be useful in hazardous waste clean-ups under CERCLA. While
oil spill clean-ups involve relatively well-known technologies and costs which
do not require detailed summary documentation for research purposes, data from
hazardous waste clean-ups should be made more readily available.
The following two recommendations are intended to make the most efficient
use of government resources for management of uncontrolled hazardous waste
site remedial actions.
1. Hazardous substance responses should be summarized in a report
similar to the OSC report outlined in section 300.56 of the NCP, but
with the additions suggested in the Sample Protocol (see Example 1).
In order to maximize accessibility of the data, the reports should be
available in a central file and should be cross-referenced according
to relevant factors such as: type of contamination; type of remedial
technology; and type of site, including geological and surface
characteristics.
2. Contractors hired for responses should be required to include
specific information in invoices, aggregated by task, regarding the
amount and type of equipment and materials used, and amount and type
of labor. Quantities of materials should be expressed in standard
units; for example, quantities of waste transported should be
expressed in tons or cubic yards, in addition to truck loads. Actual
unit costs should be expressed where applicable. If a contractor
produces a summary report, the report should include a task-specific
accounting of that contractor's costs, in addition to the technical
information normally provided. If the cost of a contractor's work
deviated from an initial estimate, the contractor should explain and
document the reason for the deviation.
The OSC summary report outlined below would simply provide for informa-
tion that is already documented, in most cases, to be assembled in the most
useful format:
Example 1. SAMPLE PROTOCOL FOR HAZARDOUS SUBSTANCE RESPONSE SUMMARY
REPORTS
I. Summary of Events, including chronology
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II. Description of site investigation, including explanation of
basis for type and extent of investigation performed
III. Basis for initiation of response
(a) threatened populations, including distance from site
(b) type of contaminants
(c) contaminant pathways
IV. Basis for selection of contractors and description of
contracting method
V. Basis for selection of response technology
VI. Basis for planned extent of response
VII. Description of technical details of response, organized by task
and sub-task, including the amount of time it took to complete
each task.
(a) description of site
(b) quantities of waste
(c) dimensions, quantities, or design specifications of
materials or equipment used in the response
(d) schematic diagrams of remedial measures
VIII. Cost of response
(a) initial cost estimate prior to response, and basis for
estimate
(b) actual cost breakdown by task
(i) site investigation cost
(ii) cost of each remedial task
(A) unit costs
(B) expected future costs, particularly operation,
maintenance and monitoring
(iii) administrative costs
(c) factors affecting costs
(d) reasons for variance of actual cost from initial estimate
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IX. Evaluation of effectiveness of response, in light of planned extent
X. Problems encountered
XI. Recommendations
XII. Bibliography of significant documents related to response
*USGPO: 1984-759-102-889 93
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