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
              lib. L:-v-/>-o-!,".:;-f!v.:<; rrctcctlon
              $•-.£.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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Figure  I.   Sample Evaluation Summary Sheet

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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%
                         11

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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

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                                    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

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   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)

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                             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

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     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

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                                                  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

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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

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              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

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 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

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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

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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
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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

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 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
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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.

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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

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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
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90
Lchmond Sanitary












X






00
JO
janta Resources







X


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o
cidental Chemical







X


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X



X



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X




X



X



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X







X
X









110. General Electric




X

X
X





X





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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





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X






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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
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CERCLAJi RCRA
H
W
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FWPCA
RESPONSE
FUNDING
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HAZARDOUS WASTE (a) j
WATER QUALITY
'DRINKING
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FEDERAL STATUTES AND REGULATIONS
STATE STATUTES AND REGL
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-------
     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



-------
                                   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

                                      81

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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

                                       82

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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.
                                       83

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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.
                                      84

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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.

                                      85

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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,

                                      86

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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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