s'1-7:0
PRELIMINARY ASSESSMENT OF CLEANUP COSTS
FOR NATIONAL HAZARDOUS WASTE PROBLEMS
This report describes work performed for
the Office of Solid Waste under contract no. 68-01-5063
and is reproduced as received from the contractor.
The findings should be attributed to the contractor
and not to the Office of Solid Waste.
U.S. ENVIRONMENTAL PROTECTION AGENCY
1979
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Page 37 of the report submitted by the contractor on February 23, 1979,
has been replaced by new pages (37, 37-A, and 37-B). These pag^es clarify
and expand the assumptions concerning financial viability considerations
and make clear the distinctions between Level I and Level II costs.
This report has been reviewed by the U.S. Environmental Protection
Agency and approved for publication. Its publication does not specify
that the contents necessarily reflect the views and policies of the U.S.
Environmental Protection Agency, nor does mention of commercial products
constitute endorsement or recommendation for use by the U.S. Government.
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TABLE OF CONTENTS
PAGE
I. Introduction . 1
A. Purpose 1
' B. Scope 2
C. Extrapolation Approach 4
II. National Survey Results 10
A. Inventory of Hazardous Waste Sites by Regions 10
B. Problem Characterization 24
III. Case Studies and Cost Extrapolations 32
A. Characterization of 24 Selected Cases 32
B. Cost Extrapolation 36
Appendix A: National Survey Letter from EPA to Regions 38
Appendix B: Sample Calculation: Accumulation of Important
Active and Inactive HW Sites 44
Appendix C: Summary: Number of Incidents by Problem Type/
Waste Type/ Facility Type 45
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LIST OF TABLES
TABLE PAG
1 Quantitative Summary of EPA Regional Estimates
of Nationwide Hazardous Waste Sites . 11
2 Hazardous Waste Site Prevalence Methodologies
of EPA Regions 12
3 Summary of the Estimated Number of Active Hazardous
Waste Sites by EPA Region 18
4 Estimated Number of Permittees by Facility
Category and EPA Region 19
5 Inventory of Estimated Active and Inactive
Hazardous Waste Sites 23
6 Comparison of Prevalence Data on Hazardous
Waste Sites 25
7 Summaries: Problem Type - Facility Type -
Waste Type -. . 26
8 Statistical Information on 232 Hazardous
Waste Cases 29
9 Characterization of 24 Selected Cases 33
10 Costs for Private Viable, Private Non-Viable, and Public Sites 37-
LIST OF FIGURES
1 Methodology for Estimating the Number of
Hazardous Waste Treatment/Storage Sites 17
2 Accumulation of Active and Inactive Hazardous
Waste Sites Over Time 21
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Assessment of Cleanup Costs for Nationwide
Hazardous Waste Problems
I. Introduction
A. Purpose
The purpose of this study is to develop a projection of potential
costs for cleanup of mismanaged hazardous and radioactive waste disposal
sites throughout the country. This report provides preliminary results
based upon an initial assessment phase which was completed in 60 days,
pursuant to contract requirements. This cost assessment will be used by
EPA and, in turn, by OMB to assist in the development of a National policy
for the mitigation of hazardous waste mismanagement problems existing
throughout the country. Due to (1) the many uncertainties that exist as to
the number of sites that may now (or in the future) pose significant threat
to public health and/or the environment, (2) the great variability of
problem circumstances from site to site, and (3) unresolved questions as to
whether cleanup cost liabilities will fall to the public or private sector,
it was not possible to attach an exact cost figure to governmental funding
requirements for mitigating these hazardous waste problems. Nonetheless,
this study represents a first attempt to extrapolate the order of magnitude
of the expenditures needed to clean up the Nation's significant hazardous
waste problems and thus should provide guidance to OMB for reaching near-
term budgetary decisions.
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B. Scope
In order to-provide needed background data for this study, EPA Head-
quarters requested each of its Regions to develop an inventory of hazardous
waste problems. A copy of the letter from EPA to the Regions is included
in the Appendix. Information requested from the Regions included:
1. A rough estimate of the total number of landfill, storage and
other sites that may contain hazardous wastes in any quantity
which now or potentially could cause adverse impact on public
health or the environment.
2. A rough estimate of the number of these sites that may^ contain
significant quantities of hazardous wastes that could cause
significant imminent hazard to public health (this is a subset
of above estimate).
3. An inventory and description of those sites for which EPA has
information in its files (this is a further subset of the above
estimates).
4. An estimate of the costs of (a) assessing the public health and
environmental hazard, (b) engineering studies to determine
remedial measures, and (c) remedial measures for a dozen or more
sites which typify various types of incidents.
In addition to inventory information in these four areas, the Regions
provided information on 103 sites. This material, in conjunction with
information from Headquarters' files and from the files of the Contractor
regarding 129 additional sites, constitute the data base for this study.
All immediately available files, reports and data concerning the 232 cases
were reviewed, abstracted and categorized. Twenty-four representative
cases were then selected for more in-depth study. In selecting the 24
cases, the prevalence of the types of facilities—as represented by the
larger population of 232 sites—was taken into consideration. Efforts were
made to match the proportion of site types in the 24 selected cases to the
proportion in the 232 cases.
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Data availability was also a determining factor in the selection
process. Where sufficient information existed in the assembled files as to
the scope of the problem, appropriate remedies (either executed or planned)
and cleanup costs, it was not considered fruitful to conduct additional
assessment. Since adequate evaluation of sites for which information and
problem documentation were scanty could not be performed within the time
frame or budget allocated to this study, such sites were not considered as
candidates for the 24 case evaluations. The sites selected, therefore,
included representative cases where it was anticipated that remedial
approaches and costs could be developed through review of files maintained
at Regional, State or local governmental offices, discussion with knowledge-
able personnel within those offices, and/or site visits. Neither problem
severity nor cleanup costs associated with specific sites was a factor in
the selection process. The 24 representative cases range significantly
in terms of problem severity and in estimated costs of cleanup.
Investigation of these sites was conducted during a four-week period
and involved arranging and carrying out information-gathering and/or site
visits to the States of Washington, Georgia, California, Colorado, Illinois,
Tennessee, Utah, Indiana, Texas and Virginia. Information obtained from
examination of the hazardous waste problems and the 24 case studies was
used in combination with the hazardous waste problem prevalence data
provided by the Regions in order to develop cleanup cost extrapolations.
Methods employed in conducting this extrapolation, along with a discussion
of the variables that affect the validity of such an extrapolation, are
presented in the next section.
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C. Extrapolation Approach
1. Methodology
The methodology for extrapolating the cleanup costs for all potential
hazardous waste problems which exist throughout the country is based on the
data available at the time of writing, and is consequently as reliable as
the data base is complete.
In order to develop an understanding of the general types of hazardous
waste problems that exist and the national prevalence of such general types
of problems, the 232 cases examined during this study were categorized by
facility type, waste type and problem type. These categories are listed
below:
I. Facility Type
1. above ground storage/disposal of wastes
2. uncovered pits, ponds and lagoons—below grade (or bermed)
3. below grade covered pits and landfills
4. underground injection facilities
5. direct dumping to surface water
6. natural impoundments
II. Problem Type
1. explosion
2. fi re
3. air pollution
4. ground water contamination (drinking water supply)
5. surface water contamination (drinking water supply)
6. ecological impact (surface water, including wetlands)
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Data availability was also a determining factor in the selection
process. Where sufficient information existed in the assembled files as to
the scope of the problem, appropriate remedies (either executed or planned)
and cleanup costs, it was not considered fruitful to conduct additional
assessment. Since adequate evaluation of sites for which information and
problem documentation were scanty could not be performed within the time
frame or budget allocated to this study, such sites were not considered as
candidates for the 24 case evaluations. The sites selected, therefore,
included representative cases where it was anticipated that remedial
approaches and costs could be developed through review of files maintained
at Regional, State or local governmental offices, discussion with knowledge-
able personnel within those offices, and/or site visits. Neither problem
severity nor cleanup costs associated with specific sites was a factor in
the selection process. The 24 representative cases range significantly
in terms of problem severity and in estimated costs of cleanup.
Investigation of these sites was conducted during a four-week period
and involved arranging and carrying out information-gathering and/or site
visits to the States of Washington, Georgia, California, Colorado, Illinois,
Tennessee, Utah, Indiana, Texas and Virginia. Information obtained from
examination of the hazardous waste problems and the 24 case studies was
used in combination with the hazardous waste problem prevalence data
provided by the Regions in order to develop cleanup cost extrapolations.
Methods employed in conducting this extrapolation, along with a discussion
of the variables that affect the validity of such an extrapolation, are
presented in the next section.
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C. Extrapolation Approach
1. Methodology
The methodology for extrapolating the cleanup costs for all potential
hazardous waste problems which exist throughout the country is based on the
data available at the time of writing, and is consequently as reliable as
the data base is complete.
In order to develop an understanding of the general types of hazardous
waste problems that exist and the national prevalence of such general types
of problems, the 232 cases examined during this study were categorized by
facility type, waste type and problem type. These categories are listed
below:
I. Facility Type
1. above ground storage/disposal of wastes
2. uncovered pits, ponds and lagoons—below grade (or bermed)
3. below grade covered pits and landfills
4. underground injection facilities
5. direct dumping to surface water
6. natural impoundments
II. Problem Type
1. explosion
2. fire
3. air pollution
4. ground water contamination (drinking water supply)
5. surface water contamination (drinking water supply)
6. ecological impact (surface water, including wetlands)
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For this study, the term Level I mitigative measures refers to the
minimum acceptable cleanup activities deemed appropriate for a site. This
term addresses those efforts which could be accomplished on an emergency
basis (usually in less time than one year) and which would significantly
reduce the present rate of hazardous waste migration into the environment.
For purposes of this report, the efforts to accomplish this degree of
cleanup for the 24 sites studied included such items as site investigation,
study and design, waste removal or clay cover, perimeter protection using
dikes or ditches, cut-off barriers, security fencing, monitoring, and admin-
istration. The term Level II mitigative measures, as used in this report,
implies a thorough site cleanup which would afford permanent protection to
human health and the environment. In addition to certain short-term cleanup
requirements used for Level I, complete waste removal and redisposal at
secured facilities were applied to most of the sites. Hazardous waste
remedial activities, in general, included the same items used for Level I
mitigation plus, in many instances, allowances for testing on-site contami-
nated soils in addition to the treatment for concentrated wastes. Judgment
was used for each of the investigated sites in evaluating the appropriate
measures and methods for cleanup required to meet Level I and Level II
criteria.
2. Uncertainties
There are usually a number of uncertainties and unknowns associated
with sample data which can affect the accuracy of extrapolation to the
population as a whole. Making a sound projection requires an effort to
identify these unknowns and taken them into consideration in the extrapo-
lation process. In such cases, "best professional estimates" were made.
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There are at least five uncertainties and unknowns which must be considered
in projecting potential costs for cleaning up mismanaged hazardous and
radioactive waste disposal sites.
First, the number of sites used as the basis of estimation was rela-
tively small. The cost projections were based on limited information for
232 cases of hazardous waste mismanagement and more in-depth information on
24 representative cases.
Second, generalization was difficult because of the broad range of
potential problems represented by the 232 cases. Because of the number of
factors that affect the costs of cleanup (e.g. site size, volume of waste,
extent of contamination, distance to a more secure landfill, etc.), each
site in reality is distinct from the others. Because of this lack of a
definitive common denominator between sites or groups of sites, the
extrapolation had to be based on average costs for cleaning up facility
type/problem type/waste type categories. These average costs mask substan-
tial site-specific variation. For example, costs of adequate disposal of
liquid wastes ranged from about $0.11/gallon to $ll/gallon.
Thirdly, there is a lack of sufficient data on the very factors that
most affect the costs of cleanup, namely site size, volume of waste, extent
of contamination, and status of cleanup measures taken to date. In addi-
tion, in many cases the data that were available were outdated, or proved
wrong upon investigation. For example, some of the sites in the data base
proved not to be significant hazardous waste problems. All available
data were evaluated to the extent possible within the short time frame of
this contract; but, because of such constraints, the accuracy of the data
base cannot be vouchsafed.
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A fourth uncertainty in the known data base concerns the question of
liability for funding the site cleanup. Many of the sites have been aban-
doned by the owner; in other instances, the owner does not possess the
financial capability to fund the cleanup. In such cases, the government
(federal, state, local) must provide the funds. In many instances,
however, it could not be ascertained from the data available if a site had
been abandoned or if an owner could be identified as financially capable
of funding the cleanup. Such unresolved questions leave uncertain whether
the public or private sector will be liable for cleanup costs related to
these sites. Consequently, an estimate was made based on best available
evidence of the probable percentage of sites which are abandoned or
abandonable. This estimate was one of the major factors which affects
government funding requirements, and was therefore an important aspect of
the extrapolation process.
A fifth area in which current data were found to be lacking is the
status of cleanup efforts already accomplished. Many of the sites are in
various stages of cleanup, some simply involving partial removal of the
waste, others involving a level of cleanup corresponding to our Level I
and Level II measures. The Level I and Level II costs are presented with-
out offering a judgement as to which level of remedial measures may be more
warranted in each particular instance. Such a judgement would have to be
made on a case-by-case basis and is outside the scope of this project.
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II. National Survey Results
A. Inventory of Hazardous Waste Sites by Region
In the initial letter from EPA Headquarters, the Regions were asked to
provide information for those sites for which data on size, waste volume,
site conditions, and related areas were available. The combined responses
from the Regions estimated (a) 32,254 sites with some hazardous wastes,
(b) 838 sites with at least potentially significant problems, and provided
(c) varying amounts of information on 103 sites. The estimates by Region
are presented in Table 1. However, a review of the Regions' submittals,
and specifically their site prevalence "methodologies," indicates that
(a) several made highly qualitative estimates, and (b) many types of sites
viewed as potential problem areas were left out due to lack of information.
The assumptions made by each of the Regions are outlined in Table 2.
It should be noted that most of the Regions stated that they could not
provide verifiable, quantitative estimates for any of these sites, due to a
lack of information on the nature, location and condition of sites and the
frequent problems of what wastes in various quantities constitute a health
hazard. A nationwide survey of open dumps (which is likely to assist in the
the efforts to estimate the number of hazardous waste sites) was mandated
by RCRA for completion in two years, but recent statements by Thomas Jorling,
the Assistant Administrator of EPA's Office of Water and Waste Management,
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TABLE 1
QUANTITATIVE SUMMARY OF EPA REGIONAL ESTIMATES
OF NATIONWIDE HAZARDOUS WASTE SITES
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
No. of Sites Which
May Contain
Hazardous Wastes
1,200
509
5,000
14,000
1,800
320
8,000
25
400
1,000
32,254*
No. of Sites Which
May Contain
Significant Quantities
of Hazardous Waste
275
25
12
210
Unknown
19
Unknown
10
37
250
838
No. of .Sites on
Which Information
Was Supplied
5
4
5
16
22
3
7
9
1
31
103
* Due to the estimation procedures employed, the last three digits of this
number lack significance.
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TABLE 2
HAZARDOUS WASTE SITE PREVALENCE METHODOLOGIES OF EPA REGIONS
Region Assumptions
I .All Landfills May Contain Hazardous Waste
Surface Impoundments Not Included
All Metropolitan-Area Landfills May Contain
Significant Quantities of Hazardous Waste
II . No Methodology Given
III .No Methodology Given
IV . Different Methodology for Each State in the
Region
V . No Methodology Given
VI .All Active Municipal Sites May Contain Hazardous
Waste
All Closed Municipal Sites May Contain Hazardous
Wastes
Pits, Ponds and Lagoons (very many in this region)
are not Included due to Lack of Data
Pesticide Disposal (important in this region) Also
Left Out
VII . No Methodology Given
VIII . No On-Site Industrial Disposal Sites are
Included
Refer to Extensive Uranium Mining and Asso-
ciated Mill Tailings Sites of Which Only a
Few are Included Here
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TABLE 2 (continued)
Region Assumptions
IX .All Based on States' "Best Professional Esti-
mates" Without Any Real Data Base
X . Best Rough Estimate of 1,000 Municipal and
Industrial Sites Was Used but this Estimate
Cannot Be Substantiated by Region's File Data
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have made it clear that this data collection effort will not be avail-
able until 1982. Due to the delays in this Federal effort and the
general lack of equivalent data on the regional or state level, the ten
Regions were left with mostly qualitative estimate options. In fact,
two Regions (V and VII) did not choose to offer any estimates of the
number of serious sites within their areas.
Alternative Prevalence Methodology
Initial review of the Regions' submittals, coupled with their
admissions of the extremely tentative nature of the data provided,
suggested that a revised inventory of all sites containing hazardous
wastes (as well as those within this group that represent the most
serious environmental threat) may be required before any meaningful assess-
ment of nationwide costs to correct these problems could be developed.
The four procedural steps identified for such an inventory are the
following:
STEP 1: Identify Active Sites. Those treat-
ment, storage and disposal facilities presently
handling various types and volumes of hazardous
wastes must be estimated, including such factors
as (a) waste type(s); (b) technology used (e.g.,
landfill, lagooning, incineration, etc.); and
(c) condition of the site, including whether it
is in an environmentally sensitive area (e.g.,
wetlands, floodplain, etc.).
1. "EPA Without Policy to Discover Imminently Dangerous Waste Sites",
Environmental Reporter, November 3, 1978.
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STEP 2: Identify Inactive Sites. The number
of sites formerly used as hazardous waste faci-
lities must be estimated, along with the range
of information identified in Step 1 above.
STEP 3: Assess Environmental Adequacy of Site.
Based on site data and treatment, storage and
disposal facility guidelines as mandated under
RCRA, the adequacy of both active and inactive
sites must be determined.
STEP 4: Assign Required Level of Clean-up.
The necessity of Level I measures (e.g., emer-
gency mitigative measures), Level II steps
(e.g., extensive clean-up procedures, removal
of wastes, etc.) or some phased combination
of the two must be assessed.
The following sections describe mechanisms that can be used to
perform the first three of these steps.
STEP 1: Identify Active Sites. Section 3005 of RCRA requires
that all facilities involved in the treatment, storage or disposal of
hazardous wastes obtain permits. To assist EPA in defining and charac-
terizing the businesses and government entities which may require such
permits, Fred C. Hart Associates developed a methodology that estimated
the following information on these facilities: (a) number and geographic
distribution of establishments; (b) number of employees and annual
revenues; (c) volume and types of hazardous wastes; and (d) method of
waste treatment or disposal. The key element of the methodology was
the combining of two data sources:
1. Reference: Fred C. Hart Associates, Inc., Demonstrational/
Instructional Materials in Hazardous Haste Management, EPA Contract
#68-01-4456, August, 1977.
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1. studies of hazardous waste management practices performed
for EPA for the 16 industries identified as the major
sources of hazardous waste (along with contacting state and
Federal agency officials); and
2. data from the Census of Manufacturing, Census of Retail,
and the U.S. Department of Commerce sources that profile
the Nation's economy.
Figure 1 shows how these -factors work together to generate the number
of active hazardous treatment sites. The analysis in the original study
required numerous assumptions to fill in often substantial data gaps in
all aspects of the methodology (e.g. data were unavailable on the two
largest industrial generators). Readers interested in more detail are
directed to the original report. Table 3 summarizes the estimated number
of facilities that presently handle hazardous wastes, broken out by EPA
Region. Table 4 presents this information by Region and industry category,
totals the three subcategories of permittees, and assigns the governmental
facilities to the Regions by population. The estimate of 19,365 sites in
Table 3 is therefore the number of sites needed to handle the existing
hazardous waste stream. In the next section, the question of inactive
sites is addressed.
STEP 2: Identification of Inactive Sites. The serious environmental
problems that have surfaced in areas such as the Love Canal site in Niagara
Falls, New York, have clearly shown that the toxicity of "disposed"
hazardous wastes can last for decades. The methodology proposed here can
provide a rough, "first cut" estimate of these sites, but the serious
nature of the problem requires that it receive more extensive analyses in
the near future.
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Figure 1
Methodology for Estimating the
Number of HW Treatment/Storage Sites
Industry Studies
& Related Sources
Average Volume of
Waste Generated
Per Plant
Census Data and
Industry Trade
Assoc. Material
Number of
Establishments
in Generating
Industries
Volume of
Waste
Requiring Treat
ment/Disposal
Treatment and
Disposal Practices
of Industries
Number of
Regional Facilitie
for HW Treatment/
Disposal
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TABLE 3
SUMMARY OF THE ESTIMATED NUMBER OF
ACTIVE HAZARDOUS WASTE SITES BY EPA REGION
I
II
III
IV
V
VI
VII
VIII
IX
X
1,560
2,243
1,850
2,711
4,665
1,956
1,180
613
1,949
638
19,365
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TABLE 4
ESTIMATED NUMBER OF PERMITTEES BY FACILITY CATEGORY
AND EPA REGION
FACILIJY
INDUSTRY:
1. Organic Chemicals, Pesticides
and Explosives
2. Ferrous Metals
3. Electroplating
a. Job Shops
b. Captive Shops
4. Inorganic Chsinicals
5. flonferrous Metals
6. Textiles
7. Petroleum Refining
8. Plastics Materials and
Synthetics
9. Special Machinery
10. Leather Tanning
11. a. Paint and Allied Products
b. Contract Solvent Reclaiming
c. Factory Applied Coatings
12. Pharmaceuticals
13. Petroleum Re-refining and
Processing
14. Rubber
15. Electronic Components
16. Batteries
17. Hazardous Waste Management
Industry
SUBTOTAL:
.GOVERNMENTAL.:
18. Publicly Owned Treatment
Works
19. Solid Haste Disposal
Facilities
20. Federal
Installations
SUBTOTAL:
OTHERS:
21. a. Hospitals
b. Medical Laboratories
22. Research Facilities
?3. Dry Cleaning Plants
24. Service Stations
SUBTOTAL:
REGION
I
58
1
109
580
2
10
24
—
36
121
n
4
5
22
—
26
48
4
6
1,067
-
397
- -
397
II III IV V VI VII VIII IX X TOTAL
269
15
92
492
16
36
35
c
52
197
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13
17
113
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27
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63
59
312
15
40
19
10
59
89
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46
19
30
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1,021
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651
321
37
53
276
27
34
94
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28
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1,528
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12
33
176
34
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55
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B L E
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10
16
88
6
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1
7
2
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2
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264
320
- -
120
1,781
214
751
4,000
138
341
190
143
452
f,115
30
70
90
440
35
226
371
51
110
10,558
969
413
251
1,633
7,174
_ - . _
7,174
1. Geographic distribution of potential permittees is assumed to be proportionate to
the distribution of hazardous waste generating establishments providsd in Table 2.
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Figure 2 demonstrates how the total number of sites containing
hazardous wastes (active and closed) accumulate over time. As firms use a
site's full capacity (assumed to be ten years), the inactive site then
joins the total site inventory for as long as its wastes remain a
threat. The guidelines developed under RCRA for properly operated and
closed sites required 20 years, of post-closure monitoring and mainte-
nance. One would assume that inadequate sites could require monitoring and
maintenance for much longer than 20 years, especially for those substances
that are highly resistant to decomposition when buried. An arbitrary
figure of 40 years will be assigned here—twice as long as for adequate
sites. In the context of Figure 2, this means that from one ten-year
period to the next, 25 percent of the inactive sites no longer pose any
health threat (e.g., an inventory of inactive sites of potential concern
made in 1975 would only include 75 percent of those sites that were on the
1965 inactive site list). This figure, however, represents only a rough
estimation and does not take into account a number of other variables,
including the increasing quality of such facilities over time.
A review of Department of Commerce data on the number of firms in the
hazardous waste generating or treating industries, outlined in Table 4,
showed that there were approximately 77 percent as many establishments in
1963 as in the estimates used for 1978. However, the higher 1978 number is
mainly due to the increases in dry cleaning plants, research facilities
and service stations, none of which was assumed to affect the number of
treatment, storage or disposal sites as outlined in Table 4. In other
industrial categories, the number of establishments actually fell between
1963 and 1978 due to the merger of smaller firms or foreign competition
(e.g., leather and tanning fell by other 50 percent).
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- 21 -
Figure 2
Accumulation of Active and
Inactive HW Sites Over Time
1940
1950
1960
1970
1980
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- 22 -
Consequently, any exact empirical estimates will be impossible here,
especially when data from earlier periods are considered, and the numerous
assumptions needed to make existing active site estimates are remembered.
It will therefore be assumed that the number of generators and associated
sites will decrease every ten years at a rate = [.80 - N(.05)], where
N is the number of decades away from the 1970-80 period (e.g., the average
number of generators in the 1940-50 period would be [.80 - 3(.05)] = 65
percent of the 1970-80 number). The numbers for the past 50 years are
shown in Table 5. A sample calculation is shown in Appendix B of this
report.
The total of 50,644 sites is therefore a very rough estimate of the
number of active and inactive sites that contain hazardous wastes and (by
virtue of this characteristic alone) may pose an environmental or health
threat.
STEP 3: Assessment of Site's Environmental Adequacy. Eight Regions
provided estimates of the number of hazardous waste sites which may include
significant amounts of waste and the number of sites which may pose a
significant health threat. The eight Regions estimated that 838 sites of
the 32,254 sites (or approximately 4 percent) may pose significant problems,
This "4% Rule" is used later in this report for extrapolation purposes.
In contrast, EPA's Office of Solid Waste recently estimated that
up to 90 percent of the annual hazardous waste volume "is subject to
improper waste disposal." Moreover, the seriousness of a particular site
1. "Most Industrial Hazardous Wastes Subject to Improper Disposal, EPA
Says," Chemical Regulations Reporter, November, 17, 1978.
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- 24 -
is dependent on the geological nature of the area as well as on waste type
and volume, and disposal methods. In a recent Fred C. Hart Associates'
study, for example, it was estimated that roughly 75 percent of landfill
sites were located in areas where wetlands, major aquifers and floodplains
are concentrated.^ Such locations are particularly susceptible to contami-
nation problems. If 75 percent of the 90 percent of wastes improperly
disposed are found in susceptible environmental settings and therefore
create significant problems, then 34,452 of the 50,664 cases listed in
Table 5 could be considered significant problem situations. This can be
stated in the calculation: (.75 x .90)50,664 = 34,452.
Table 6 presents the overall results of this alternative prevalence
methodology effort, and compares them with the values provided by the EPA
Regions. Using the EPA Regional estimates and the estimates generated here
as the lower and upper bounds respectively, the total number of sites that
include hazardous wastes range from roughly 32,000 to 51,000, while the
number that may pose significant problems range from 1,200 to 34,000.
B. Problem Characterization
1. Overview. The review and classification of available information
concerning the 232 cases included in the data base for this study provide a
very useful picture of the Nation's hazardous waste problem. Table 7
presents a summary of problem prevalence in terms of facility type, problem
type and waste type. Matrices of problem type/ waste type/facility type
are presented in Appendix C. It was found that 85 percent of the
1. Reference: Fred C. Hart Associates, Task IV--Economic Analysis,
Draft Report, EPA Contract No. 68-014895, October 12, 1978, pp. 66-74.
-------
- 25 --
TABLE 6
COMPARISON OF PREVALENCE DATA IN HAZARDOUS WASTE SITES
Total Number of Hazar-
dous Waste Sites
Number of
Significant Problem Sites
4% Rule
Alternative
Ratio2
EPA Regional Estimates
Alternative Methodology
Estimates
32,254
50,664
12041
2027
21,933
34,452
1. .04 x total number of hazardous waste sites.
2. (.75 x .90) x total number of hazardous waste sites.
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- 26 -
TABLE 7
SUMMARIES: PROBLEM TYPE - FACILITY TYPE - WASTE TYPE
I. Facility Type
II. Problem Type
III. Waste Type
Number*
1. Above ground storage/disposal 102
2. Uncovered pits, ponds, lagoons - below grade 75
3. Covered pits, landfills 71
4. Underground injection 7
5. Direct dumping into surface water 14
6. Natural impoundments 72
291
1. Explosion 3
2. Fire 12
3= Air pollution 13
4. Ground water contamination - potable supply 131
5. Surface water contamination - potable supply 57
6, Ecological impacts 75
291
1. Pesticides and highly toxic organics 59
2. Other organics 93
3, Inorganics 118
4. Radioactive substances 19
5. Explosives and flammables 2_
291
The total number of sites described (232) is less than the total
falling into separate categories (291) because some sites were
listed under more than one category.
-------
- 27 -
232 cases involves storage facilities, ponds or landfills (facility types 1,
2 and 3). The most prevalent problems (90 percent of the cases) are surface
and ground-water contamination (problem types 4, 5 and 6), and 93 percent of
the cases involve organic and inorganic contaminants (waste types 1, 2 and
3). The most common case type is a facility where organic chemical wastes
are stored/disposed on the land surface and/or in ponds, and create a ground-
water contamination problem.
Cases involving fires, explosion or air pollution problems only, are
considerably less prevalent in the data base than those discussed above.
Although air pollution problems have rarely been measured, odor problems
are often mentioned in cases where the major problem is one of surface
and/or ground-water contamination. In fire and explosion cases, little
can be done once a facility has been destroyed by these means. Also, it
is virtually impossible to predict such events, although good housekeeping
practices and monitoring can help avert them.
Very few cases relating to underground injection (and virtually no
cleanup cost information) are included in the data base. Also, such
problems are extremely difficult to assess in terms of potential remedial
costs. This category is therefore not dealt with individually in the
projections presented in this report.
Direct dumping into surface water also represents unique situations.
Mitigation of such problems may not be possible, or may be dealt with
under Section 311 of the Clean Water Act; thus, applicability of these
cases to the objective of this report is uncertain. A "direct dumping"
problem, however, was included as one of the 24 selected cases examined
for this report.
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- 28 -
Similarly, radioactive waste problems are distinctive and show a low
prevalence in the data base, though three cases of this nature were
included in the 24 selected situations studied over the past month.
2. Site Characteristics. Table 8 presents statistics on the 232
cases reviewed. The table is .indicative of the fact that little is known
about many of the cases, and thus the population for the extrapolation of
certain factors is limited. Nonetheless, several pertinent points can be
drawn from the table:
. Some remedial action has been taken on 26 percent of the
cases for which information is available. This is indicative
of substantial efforts by EPA Headquarters, the Regions,
States and local authorities to seek resolution of documented
hazardous waste problems.
Of the 80 facilities which can be tentatively categorized in
terms of financial status, it appears that there may be
cleanup monies available through sources other than special
governmental funding for 50 percent of the facilities.
. Of the 155 problems which can be tentatively categorized in
terms of setting, 88 percent are located within floodplain,
wetland and/or major aquifer areas. This would certainly
support the Agency's position in drafting regulations under
RCRA that such areas should be avoided in siting new hazardous
waste facilities.
Other pertinent pieces of information also identified during this
study include the following:
. Reported health oroblems were associated with 16 of the sites,
including Illnesses, injuries, poisoning cases and deaths.
. A total of 25 facilities are known to be owned by governmental
entities (8 Federal, 3 State and 14 local).
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- 29 -
TABLE 8
STATISTICAL INFORMATION ON 232 HAZARDOUS WASTE CASES
FACTORS PERCENT OF- 232 SITES
Sites for which some remedial action has been
taken 0) 26%
Number of Active Sites
Active 22%
Inactive 30%
Uncertain 48%
(2)
Financial Status^ '
abandoned/abandonable 17%
viable 17%
uncertain 66%
Setting^3)
located within environmentally sensitive area 59%
not located within environmentally sensitive area 8%
uncertain 33%
(1) remedial actions range from substantive efforts to explore the
problems and develop remedies to completion of various cleanup
measures.
(2) abandoned/abandonable sites include those identified as such within
the information base (e.g., owner bankrupt); financial viability
means that the facility is owned by a governmental entity, or that
information submitted by Regions or contained in reports states
that the owner/operator has sufficient financial resources to fund
cleanup; all sites for which there is question as to financial
viability or liability were counted as "uncertain".
(3) si-tes within "environmentally sensitive areas" are those in which a
local ground or surface water resource has been damaged or is
threatened.
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- 30 -
. Of the 110 facilities which can be identified by SIC code,
69.2 percent fall into five industrial groups as follows:
38.2% SIC 28 Chemicals & Allied Products
8.2% SIC 14 Mining & Quarrying of Nonmetallic Minerals,
Except Fuels
8.2% SIC 33 Primary Metal Industries
7.3% SIC 10 Metal Mining
7.3% SIC 29 .Petroleum Refining
Four more industries account for another 13.5 percent of the sites:
SIC 34 - Fabricated Metal Products; SIC 36 - Electrical & Electronic
Machinery, SIC 37 - Transportation Equipment; and SIC 42 - Motor Freight
Transportation & Warehousing. The remaining 17.3 percent of the sites fall
into 14 SIC groups.
3. Cost Factors. Cleanup cost information (frequently cost ranges)
for 52 sites was contained in the information base on the 232 sites. The
total costs for 51 sites (excluding "billions" quoted for one of the sites
involving radioactive wastes) are a minimum of $322 million and a maximum
of $938 million, or $6.3 to $18.4 million per site. The total for the 18
classified as abandoned or abandonable was $36 to $225 million, or $2 to
$12.5 million per site. Using these figures alone, and extrapolating them
directly to the National population of sites which could cause significant
hazardous waste problems, results in total cleanup cost estimates of $7.6
to $22 billion for the site population of 1,204 derived frorr. the numbers
providej by the Regions. Considering costs for the abandoned sites,
extrapolated costs would range from $2.4 to $15 billion.
These are obviously gross estimates and the available data were
screened to determine whether cost factors could be correlated with other
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- 31 -
basic quantitative aspects related to the sites. Information on site size
and/or waste quantity was available for 31 of the sites for which cost data
were available. Examination of cleanup costs per acre, per drum, per
gallon and per cubic yard showed erratic variation. This is further
testimony to the uncertainties inherent in available data, and the lack of
a common denominator for costs, reflecting the uniqueness of each case.
Closer examination of 24 selected cases was used to improve the data base.
The 24 cases are characterized in the following section.
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- 32 -
III. Case Studies and Cost Extrapolations
A. Characterization of 24 Selected Cases
Twenty-four cases selected for more in-depth investigation were
studied over a four-week period. Information was gathered by interviewing
EPA Regional and State personnel, reviewing Regional and State files
(some of which were used verbatim), and, in some cases, making site visits.
Remedial measures were developed or were adapted directly from file
information, based on best available information at the time of writing.
These measures are intended to serve only as a conceptual approach to
problem mitigation.
Remedies cannot be interpreted as recommendations because, in most
cases, they were not based upon adequate study. Cleanup costs were
developed by applying best engineering estimates and utilizing known cost
factors from available studies. In several instances, insufficient
information was available to complete Level II estimates. In these cases.
Level II costs were assumed to be at least the amount of Level I costs.
In one instance, only a Level II approach appeared viable.
Table 9 summarizes the facility type/problem type/waste type for each
of the 24 sites, and presents available site size/waste volume data and
the estimated total costs for Level I and Level II cleanup.
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- 33 -
TABLE 9
CHARACTERIZATION OF 24 SELECTED CASES
Site
Description
Costs
Site Size/Waste Volume Level I
Level II
-Above ground storage; un-
covered pits, ponds, la-
goons - below grade
-Ground water contamination
-Pesticides and highly
toxic organics
-Uncovered pits, ponds,
lagoons
-Ecological impacts
-Organics; inorganics
-Covered pits/landfill
-Air pollution
-Organics
-Direct dumping into
surface water
-Ecological impacts
-Pesticides and other
highly toxic organics
-Above ground storage
-Surface water contamination
-Organics; inorganics
-Above ground storage
-Ground water contamination
-Pesticides and other high-
ly toxic organics; other
organics-, inorganics
-Above ground storage
-Surface water contamination
-Inorganics
-Uncovered pits, ponds,
lagoons
-Ground and surface water
contamination
-Pesticides and other high-
ly toxic organics; other
organics; inorganics
37,000 cu. yds.
1,109,000 3,170,000
12 acres
150 drums (55 gal.)
80 acres
18,000 cu. yds.
5 acres
28,667 drums
(55 gal.)
0.8 acres
140 acres
16.7 acres
300,000 gal
33,600
92,600
624,000 1,236,000
3,042,000 19,349,000
21,000 1,631,000
4,633,200 23,330,000
370,000 3,700,000
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- 34 -
TABLE 9
CHARACTERIZATION OF 24 SELECTED CASES (continued)
Site
Description
Costs
Site Size/Waste Volume Level I
Level II
10
11
12
13
14
15
**16
17
11 acres
750,000 gal.
2,680 acres
24,884 gal
80 acres
-Above ground storage
-Surface water contamination
-Organics
-Covered pit/landfill
-Ground water contamination
-Organics; inorganics
-Covered pit/landfill
-Ground water contamination
-Pesticides and other high-
ly toxic organics
-Above ground storage
-Ground water contamination
-Pesticides and other high-
ly toxic organics
-Covered pit/landfill
-Ground and surface water
contamination
-Organics
-Covered pit/landfill
-Ground water contamination
-Pesticides and other high-
ly toxic organics
-Above ground storage 8 acres
-Surface water contamination 45,000 drums
-Organics; inorganics (55 gal.)
-Above ground storage; un- 27 acres
covered pits, ponds, lagoons 63,000 cu. yd,
-Surface water contamination
-Inorganics; radioactive
substances
1,762,000 1,762,000*
11.7 acres
40 acres
-Covered pit/landfill
-Ground and surface water
contamination
-Pesticides and other high-
ly toxic organics
50 acres
300,000 drums
(55 gal.)
not
applicable 617,000
20,000,000 200,000,000
1,077,000 33,610,000
4,845,000 4,845,000*
1,800,000 3,114,000
3,498,000 10,875,000
5,965,000 165,370,000
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- 35 -
TABLE 9
CHARACTERIZATION OF 24 SELECTED CASES (completed^
Costs
Site
Description
. 18 -Covered pit/landfill
-Ground and surface water
contamination
-Inorganics
**19 -Above ground storage;
covered pit/landfill
-Ground water contamination
-Radioactive substances
20 -Above ground storage;
covered pit/landfill
-Ground and surface water
contamination
-Organics
21 -Uncovered pits, ponds,
lagoons
-Air pollution; surface
water contamination
-Pesticides and other high-
ly toxic organics
22 -Above ground storage; un-
covered pits,
ponds, lagoons
-Surface water contamination
-Pesticides and other highly
toxic organics
23 -Above ground storage
-Ground water contamination
-Organics; inorganics
**24 -Covered pit/landfill
-Ecological impacts
-Radioactive substances
Site Size/Waste Volume Level I
Level II
10 acres
300 drums
188,000
625,000
144 acres
1,400 drums (55 gal.) 340,000,000 340,000,000*
4 acres
1000 drums (55 gal.)
77,780 cu. yds.
20,460 gal.
23,863 cu. yds.
4 acres
1,850,000 gal.
27,700,000 gal.
295,000 3,730,000
17,000,000 22,600,000
2,000,000 2,000,000*
160,000
597,000
1,343,000,000 1,343,000,000*
*Level II costs were assumed to be at least as high as Level I costs when there
was insufficient information available to estimate Level II costs.
**These radioactive sites are being studied by'the Department of Energy.
Published reports on these sites are available. As indicated in the next
section, remedial costs for these sites were not considered in the
extrapolation process.
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- 36 -
B. Cost Extrapolation
It was found that two of the 24 selected cases (8%) could be
resolved without incurring cleanup costs. It is probable that a portion
of the total population of cases identified as potentially significant
hazardous waste problems will be found, upon investigation, to not, in
fact, pose problems. The assumption was made that the finding of two
"no cost" situations in the 24 case studies was representative of the
larger population, which was thus reduced by 8 percent.
In the data base of 232 cases, 19 (or 8%) involved radioactive wastes.
Three of the 24 case studies involve radioactive waste problems. These will
apparently entail cleanup expenditures substantially larger than the range
of costs associated with the other cases, (also, two of the three are govern-
ment-owned). These costs were thus excluded from the average cost per site
calculated for the remaining cases and the larger population of problem
sites was reduced by an additional 8%.
Average cost for Level I treatment (exclusive of "no cost" and
rad-waste sites) is 3.6 million per site. The average for Level II
treatment is $25.9 million per site. These figures approximate the cost
estimate range in the data base of 51 sites ($6.3 to $18.4 million per
site). Estimates of the prevalence of potential hazardous waste problems
show a significant range. While some problems may develop at a large
percentage of hazardous waste sites, it seems unlikely that all such
problems would be deemed imminent, hazards. Thus, for the purpose of this
study, the more conservative ("4% rule") estimates were applied.
-------
37
The first assessment of financial viability of sites (pages 28, 29, and
37 in an earlier version of this report) grouped the government owned sites
with the financially viable private sites resulting in a total of 50% of
financially viable sites. Consequently, a maximum cleanup figure of
$44.2 billion was derived (i.e., $22.1 billion Federally funded and $22.1
billion privately funded). Upon further deliberation, it was determined that
this conclusion could be misleading, and it was decided to refine the calculations
by considering the government owned sites separately without making a judgment
about viability. In the analysis below, sites are reallocated into three
categories: private viable; private non-viable; and government (i.e., publicly)
owned.
Of the 232 sites for which information was available, 19 are radioactive
waste disposal sites requiring enormous expenditures for cleanup. These were
deleted from calculations in order to keep the cost figures representative.
Of the remaining 213 sites, 190 or 89.2% are private sites.
Twenty-five of the original 232 sites are publicly owned, but 2 are
radioactive waste sites and are excluded, leaving 23 out of 213, or 10.8%
public non-radioactive waste disposal sites.
Of the 80 sites discussed earlier in the report, 77 are non-radioactive
waste disposal sites. We have information concerning financial viability
on the private sites, of which there are 54. We do not consider the question
of viability of the 23 public sites. In Table 10 the cost of cleanup of
these sites is listed separately.
Of the 54 private sites with financial viability data, 15 or 27.8% are
considered viable and 39, or 72.2% are non-viable. These percentages give a
best estimate of financial status among the small number of private sites about
which we have this information.
-------
37-A
From our population of 213 sites, we have derived the best estimate of
the proportion of sites which are private (89.2%) versus public (10.8%).
From the 54 sites with data on financial viability, we have derived the best
estimate of the proportion of viable and non-viable private sites. To produce
a more refined estimate of the number of private sites which are either
financially viable or non-viable, the calculations are as follows:
Of the 89.2% of sites which are private, 27.8% are viable. Therefore,
89.2% x 27.8% or 24.8% are viable private sites. This is used to calculate the
number of viable private sites in Table 10.
Similarly, of the 89.2% private sites, 72.2% are non-viable. Therefore,
89.2% x 72.2% or 64.4% of the total population of sites can be considered non-
viable private sites.
The proportion of public sites remains at 10.8% and no judgment on viability
is made.
Table 10 shows the extrapolation of the number of sites in each category
and for the two estimates of the number of sites nationally. The associated
cleanup costs for Level I and Level II remedies are also calculated. It should
be noted that Level I and Level II cost estimates are not additive, but represent
two distinct types of approaches. Each approach includes necessary elements for
either preventing the problem from worsening (Level I) or ultimate and complete
remedy (Level II). (Note that calculations have been rounded to the nearest
significant number.)
Costs for cleanup of the publicly-owned sites and the privately-owned
non-viable sites could be funded through special public funds, Federally
appropriated funds, State/local funds, or from a combination of all three.
-------
37-B
TABLE 10
Costs for Private Viable, Private
Non-Viable, and Public Sites
EPA Estimate Alternate Estimate
Assumptions 1204 Sites 2027 Sites
Facilities Excluded
8% radioactive
waste sites
8% no-cost sites - 193 - 324
Population of Interest 1011 1703
(a) number of privately
owned financially
viable sites (24.8%) 251 422
(b) number of privately
owned financially
non-viable sites (64.4%) 651 1097
(c) number of publicly
owned sites (10.8%) 109 184
Cost of Level I Remedy
(average cost $3.6 million
per site)
(a) privately-owned/
financially viable $0.9 billion $1.5 billion
(b) privately-owned/
financially non-viable 2.3 billion 3.9 billion
(c) publicly-owned CL_4 billion 0.7 billion
Total Level I Costs $3.6 billion $6.1 billion
Cost of Level II Remedy
(average cost $25.9 million
per site)
(a) privately-owned/
financially viable $ 6.5 billion $10.9 billion
(b) privately-owned/
financially non-viable 16.9 billion 28.4 billion
(c) publicly-owned 2.8 billion 4.8 billion
Total Level II Costs $26.2 billion $44.1 billion
-------
cD STATES ENVIRONMENTAL PROTECTION AGENCY
-38-
APPENDIX A
1979
Information Needed on Disposal Sites Where Hazardous Waste
Threatens Public Health
PROM, Thomasp.
Assistant Administrate/ for Water and Waste Management (WH-556
TO, Regional Administrators, EPA
Regions I-X
The Office of Management and Budget is concerned about
the increasing pressure on the Federal Government to provide
funding for cleanup of environmental incidents involving
prior disposal or storage of hazardous chemicals and sub-
stances. The most recent example is the situation at the
Love Canal dump site in Niagara Falls, New York. OMB has
established a task force to assess the potential magnitude
of such incidents and to develop and assess various options
for Federal policy respective to such incidents. OMB has
asked EPA to collect information to assist the efforts of
the task force and to participate on the task force. In
addition, it is very probable that the Congress will want
to address this issue in oversight hearings next year and
will expect and request EPA to supply substantive information
on environmental incidents, both recent and potential. This
memorandum is to ask your assistance in gathering information
for these two purposes. This request was discussed with your
Solid Waste Branch Chiefs in a recent meeting at headquarters
on September 14.
In brief, the OMB task force would like to obtain four
types of information:
1. a rough estimate of the total number of landfill,
storage and other sites that may contain nazardous
wastes, in any quantity which now or potentially
could cause adverse impact on public health or
the environment,
2. a rough estimate of the number of these sites that
may contain significant quantities of hazardous
wastes which could cause significant imminent
hazard to public health (this is a subset of
above estimate)
3. an inventory and description of those sites for
which EPA has information in its files (this is a
further subset of the above estimates) and
4. an estimate of the costs of (a) assessing the public
health and environmental hazard, (b) engineering
studies to determine remedial measures and (c) rcmedia
measures for a dozen or more sites which typify vari-
ous types of incidents.
EPA FORM 1320-6 (REV. 3-76)
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-39-
It is fully recognized that the estimates for Itsms 1
and 2 must and can only be "best professional es ti.-natss. "
It is not expected that SPA make any effort to "d.isco^r"
sites (through field visits, substantial file searches or
other means) for which we do not current! y hi«/a ir, forr.^. ti on .
Eathar, it i: excreted .that EPA make r: r. in-ite:; caijd c.i
knowledge about present and past industrial activity and
present and. past disposal practices in each Region. It is
not required that you involve the States, but, .if you can
consult with and obtain information from your States without
causing undo burden, such State participation would ba
welcomed.
The purpose of I ten 3 ;:- to obtain a better understanding-
of various sizes and types of incidents that flight be -v.pactad
in the total universe." In a sense, this inventory will be
treated as a "representative sample" of the universe. The
attachment provides the format and instructions for supplying
this inventory and descriptions. It is expected that this
information will derive only from your current regional files.
However, if you can readily an"d ccnvenien tly -sol ici t additional
informatio-n and help from the States, we encourage this.1' It is
recognized that the development of this inventory will add
national visibility to the incidents identified therein
because the inventory will be shared with che Congress and
will .probably be requested by and be made available to the
public. Because of this, incidents included in the inventory
should ba situations for which you have more than circum-
stantial information, the public (at least locally) is already
aware, and publicly accessible information is already or, file.
We intend to use an experienced contractor to carry out
Item 4. We will select 2 dozen or sera incidents frosn the
inventory you submit under Item 3 and have- the cor.-ric~o--
d e v 31 c p the three cost e s t i :n a t -2 s d e i i r. '-t s. ~ e d a s 3 v 2 . "or
rr.cst, if not all, of these salscte- : r,-i-l2n:s, :r.e _•?.;: rra: tor
will need ~.o visit yo'.;r office and, in :on:e cises, rsi-ce /isiis
to the State offices and/or the site. In all cases, the centra';
tor wilt work with,- and through, your Sol id-i-.'as :e Srincr, Chiefs
and will not make visfts without your appro.val and arr jngerner: ts
I would like you to supply the infornaticn described in
Item 1, 2 and 3 to Gary Dietrich, Assssiats^aputy Assistant
Acmi nj s tra tor for Solid "U'asse, by C-c •::-•:•;' x3.
Attachments
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Instructions and Format for
Preparing an Inventory and Description
of Disposal Sitas Where Hazardous Wasta
Threatans Public Health
Purpose: Tlid purposa is to inventory .a:vi describe kncv.-n ha;?.rd~j5 v.-as;2
storage or disposal situations which posa a currant or potential hazard
to public health. This information w-ill ba usad by EPA to (1) describe
types and variety of the imminent hazard situations currently faced by
State and local governments and (2} when combined with representative
cost information, to assess the fiscal magnitude-of these situations for
the purposes of formulating Federal policy for dealing with these situations,
This- information will ba shared with CMS ar.d Congressional oversight and
•legislative comr,itteas. Although there aro no pinna to -ubl.icly r^'sasa
tin's information, it wi-11 probably be made cub'!c c.iroug:: ra^uesis by
Congressional committees and others.
Definitions: Criteria for the types of situations to ba inventoried and
described are: •
(1) known situations for'which information is available and on
file in the Regional Office. It nead net cover situations
for which all or most information must be obtained from the
States, local agencies or others or for which field inspection's
mist be made to "discover" and describe the situation. There
definitely is no requirement to go out and "discover" hazardous
situations, nor is it expected to inventory situations for
which only unconfirmed information is available.
(2) hazardous waste storage and/or disposal situations involv-ir.g
hazardous chemicals or radioactive wastes.. Situations involving
methane gas cr leachata problems frc.^ typcial municipal "ardfii's
or disposal sites should not bs cover-rd unless the sit::a::c?:
is dominated by hazardous Charles's 7.r rsdicscuiva v:astas co-
disposed with z'r.s r.unicioal ..vistss. Zcr^- .ib;.ricr.ad i:v- «:j.ist;r,g
sites shoul-- -0 i."c"ud-j-j irrs.v?jj'; :v. £ of v.r. •*;.-. -:•;• there ii s.r.
appa-ent responsible parry t.nat ::(:s: be :as<«c v;i:h -:.:i5
responsibility of correcting "he prob-lsn. (-"ui'e often :r.a
responsible party M=vaporatas!l by ceclaraticn o^ bsnkrjpcy or
other legal means when the cost of ccrreccicr, is found to ::e
high.)"
]} situations that pose an existing cr potsrtis" ir,r:inert
hazard ;c public health through crcu.icv.'aiir c^KtarMi.oatfcr;,
surfaca water discharges including c;:an-;.;"t 531".Is, air
emission and/or radiation emissions.
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(4) situations that can be sufficiently described, pursuant'
to the following format, using available information.
IJJlLOS1 ^';1t3 co:;:plst2 inventory and 'descriptions ~-jst he subrri ttnd CD
Gery j|. 0-ietrich, Associite Deputy Ajsistir.t: A-l^ir.iiti-;::or ,-or ^oiicl
taste, by October 23, 1978.
Format: For each situation, a two-tc-fiva page description should bs
submitted. The attached format is suggestad. However, if it is too
confining to enable a good exposition of information, a free-form narrative,
covering the same points, may be used.
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Format for Inventory of
Disposal Sites Whs re Hazardous tfaste
Threatens Public Health .
Location.; (by city, town or county and state)-
Ownership; (of site)
Operator: (of site)
-^ta Es tablishoc1.: (or acoroxiiriate year.* ?f 00-2rs,tier.)
Status: (active or abandoned or in ••receivership). .
Type of Business: (treataraent, storage, disposal coaibinaticr.)
Financial: (capacity of ov/ner "or operator to rerr.a-dy the
problem)
Waste Handling; (e.g., incineration, landfill, deecvell,•
landfar^i; midnight dumping; transport; storage (warehouse/
field) drums, tanks (size, condition, fixation)
Type of Hazardous Waste Involved; (e.g., ?C3 vzste.-, or'j?.:;ic
solvents, pesticide v/asces) . •
Size of 3usin_5ss; (e.g., volume and servir-2 area; capacity
an-d si 25 of iigoons and storage area; nu.rjo^ - cf drur' '•
Cpr. .:.i - i z- - '.-• f ? a z i 1 i ty : (e.c;., rioujslccerir.::, leikir.-r drur.'.s ,
^j-••• •» —..-. —k - '-* s ^3, "*•* "* 3 i. M^ o"" oor*. •" cir? * "^ x C3 "i ~ "** •"* **•
Physical Factors: (e:g. , •hydrolog-y-goclogy of ?.rsa, clirjate,
a-cun- of precipitation, proximity to v:at;-:r bodies, soil
types, permeability, depth to bedrock, location on flood
plain or wetlands, proximity to residents, nurier of monitoring
wells)
History and Sates of Incidents; (e.g., p*rnit violacions,
persons injured, residents conpZ.di:; cs, £pi:'.-2r'.i::lo-./ic dica,
v/ill cor.tai~inr.tion, ai-r pollution environr.-.^nfil d
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Action Taken to Data: Federal, Stata, local remedial -action
takan ana with what result.
Co_s_£: •r'aosral, Stats local cos; ir.r:i.rrv^-'i o:: sstir.atos of
cost for anssssr.snt or the probloa, cngir.c'urir.r; «i
carrying out.a remedy.
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APPENDIX B
ACCUMULATION OF IMPORTANT ACTIVE AND INACTIVE HW SITES
Assumption 1: Sites remain active for (i.e. have a capacity of) 10 years.
Result: A complete turnover of active sites every 10 years
Assumption 2:
Sites upon closure (or abandonment) remain a potential
hazard for 40 years.
Result: Every 10 years, 25% of the sites on last
decades inactive list will be dropped.
Assumption 3:
Number of generators and associated active HW sites V
decades ago will = (.80-n(.05)) x the present # of sites.
Result: # sites in 1970-80
# sites in 1960-70
# sites in 1950-60
# sites in 1940-50
# sites in 1930-40
(given from existing data)= 19,365
(.80-(.05)) x 19,365 = 14,524
(.80-2(.05)) x 14,524 = 10,167
(.80-3(.05)j x 10,167 = 6,608
(.80-4(.05)) x 6,608 = 3,967
Assumption 4:
Number of sites on accumulated site list = active sites and
inactive sites £40 years old. = 19,365 + 14,524 + 10,167 +
6,608 = 50,664.
NOTE: 1930 - 40 active sites were not included as they
were > 40 years old.
Assumption 5:
Number of sites that pose environmental threat.
Lower Bound: EPA Region's Estimates -> "4% Rule" = 1204 sites,
Upper Bound: # Sites on accumulated site list x % sites in
"environmentally sensitive areas" x % sites
using inadequate disposal methods =
# potential sites x (.75 x .90) =
50,664 x .68 = 34,452
.". Full Range: 1204 - 34,452 sites.
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APPENDIX C
SUMMARY: NUMBER OF INCIDENTS
WASTE TYPES
FACILITY TYPE
Pesticides
and Highly Radio- Explosives
Toxic Other active &
Organics Organics Inorganics Substances Flammables Total
PROBLEM TYPE:
EXPLOSION
Above ground
storage/disposal
Uncovered ponds,
lagoons,
below grade
Covered pits/
landfills,
below grade
Underground
injection
Direct dumping
into surface
water
Natural
impoundments
TOTAL
PROBLEM TYPE:
FIRE
Above ground
storage/disposal
Uncovered ponds,
lagoons,
below grade
Covered pits/
landfills,
below grade
Underground
injection
Direct dumping
into surface
water
Natural
impoundments
TOTAL
7
1
12
.continued)
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WASTE TYPES
FACILITY TYPE
Pesticides
and Highly Radio- Explosives
Toxic Other active &
Organics Organics Inorganics Substances Flammables Total
PROBLEM TYPE:
AIR POLLUTION
Above ground
storage/disposal
Uncovered ponds,
lagoons,
below grade
Covered pits/
landfills,
below grade
Underground
injection
Direct dumping
into surface
water
Natural
impoundments
TOTAL
13
PROBLEM TYPE:
GROUND WATER
CONTAMINATION—
POTABLE SUPPLY
Above ground
storage/disposal
Uncovered ponds,
lagoons,
below grade
Covered pits/
landfills,
below grade
Underground
injection
Direct dumping
into surface
water
Natural
impoundments
TOTAL
9
3
7
3
22
14
17
14
3
2
"50"
20
20
11
1
1
2
52
44
43
35
7
2
T3T
(continued)
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WASTE TYPES
FACILITY TYPE
PROBLEM TYPE:
SURFACE WATER
CONTAMINATION-
POTABLE SUPPLY
Above ground
storage/disposal
Uncovered ponds,
lagoons,
below grade
Covered pits/
landfills,
below grade
Underground
injection
Direct dumping
into surface
water
Natural
impoundments
TOTAL
Pesticides
and Highly
Toxic Other
Organics Organics
7 3
1 2
1 4
2 1
11 10
Radio- Explosives
active &
Inorganics Substances Flammables Total
6 1 17
7 1 11
\
2 1 8
2 5
14 2 16
31 4 1 57
PROBLEM TYPE:
ECOLOGICAL
IMPACTS
Above ground
storage/disposal
Uncovered ponds,
lagoons,
below grade
Covered pits/
landfills,
below grade
Underground
injection
Direct dumping
into surface
water
Natural
impoundments
TOTAL
11
4
4
8
5
3
25
18
19
7
6
20
17
30
75
SW-750
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