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Cleaning Up the Nation's Waste Sites:
Markets and Technology Trends
2004
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Office of Solid Waste EPA 542-R-04-015
And Emergency Response September 2004
(5102G) www.epa.gov/tio
clu-in.org/marketstudy
Cleaning Up the Nation's
Waste Sites: Markets and
Technology Trends
2004 Edition
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Notice
Preparation of this report has been funded wholly or in part by the United States Environmental
Protection Agency (EPA) under contract number 68-W-03-038. Mention of trade names or
commercial products does not constitute endorsement or recommendations for use. This document is
intended for information purposes and does not create new nor alter existing Agency policy or
guidance. The document does not impose any requirements or obligations on EPA, states, other
federal agencies, or the regulated community.
A limited number of printed copies of Cleaning Up the Nation's Waste Sites: Markets and
Technology Trends, 2004 Edition is available free of charge by mail or by facsimile from:
U.S. EPA/National Service Center for Environmental Publications (NSCEP)
P.O. Box 42419
Cincinnati, OH 45242-2419
Telephone: 513-489-8190 or 800-490-9198
Fax: 513-489-8695
A portable document format (PDF) version of this report is available for viewing or downloading
from the Hazardous Waste Cleanup Information (CLU-IN) web site at http://clu-in.org/marketstudy.
Printed copies can also be ordered through that web address, subject to availability.
For More Information
For more information about remediation markets, including tools to help advance technologies
through all stages of product development from bench scale to full commercialization, visit the EPA
web site http://www.epa.gov/tio/vendor.
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Acknowledgments
This document was prepared for the U.S. Environmental Protection Agency's Technology Innovation
and Field Services Division (TIFSD). The report would not have been possible without the assistance
of staff throughout EPA, the Department of Defense (DOD), and the Department of Energy (DOE).
Special thanks go to staff in EPA's Office of Superfund Remediation and Technology Innovation;
Office of Solid Waste; Office of Underground Storage Tanks; Federal Facilities Restoration and
Reuse Office; and Office of Federal Facilities Enforcement; and Office of Brownfields Cleanup and
Redevelopment. DOD's Office of the Assistant Under Secretary of Defense for Environmental
Security, and DOE's Office of Environmental Restoration were exceptionally generous with their
time and expertise. Important contributions were also received from a number of other parties
identified in various sections of the report.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Executive Summary
Over the next several decades, federal, state, and
local governments and private industry will commit
billions of dollars annually to clean up sites
contaminated with hazardous waste and petroleum
products from a variety of industrial sources. This
commitment will result in a continuing demand for
hazardous waste site remediation services and
technologies.
Hundreds of small, medium, and large companies
across the nation will respond to this demand,
supplying skilled professionals and advanced
technologies to address contaminated sites.
Researchers and technology developers will
continue working to provide smarter and cheaper
solutions to the complex environmental
contamination problems still to be addressed.
Investors will seek to identify technologies that
provide the most promising technical and financial
future. Universities continually seek to adjust their
environmental sciences and engineering curricula to
ensure that their future graduates are prepared for
the challenges they will face in this field.
To make cost-effective and sound investment
decisions, all these groups will need information on
the nature and extent of the future cleanup market.
With this need in mind, EPA has produced this
overview of the site characterization and
remediation market. EPA believes that information
on the Nation's cleanup needs will help industry
and government officials develop better and more
targeted research, development, and business
strategies.
Background
EPA's mission includes the important goal of
restoring contaminated land to productive use, and
the Agency has established ambitious targets.1 The
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA, or
Superfund) and the Resource Conservation and
2003-2008 EPA Strategic Plan, Objective 3, Land
Preservation and Restoration.
http://vwwv.epa.gov/ocfo/plan/2003sp.pdf
Recovery Act (RCRA) provide the legal authority
for most of EPA's work toward this goal.
Cleanups are also generally required to comply
with a number of other state and federal statutes. To
achieve this goal, EPA works with many partners at
all levels of government to ensure that appropriate
cleanup tools are used; that resources, activities,
and outcomes are coordinated with partners and
stakeholders and effectively communicated to the
public; and that cleanups are protective and
contribute to community revitalization.
EPA is a leader in influencing how hazardous waste
site cleanups are conducted in all cleanup programs.
The agency directly conducts many cleanups and
removals under the Superfund program. In addition,
it conducts oversight of state, tribal, and federal
facility cleanup programs; develops regulations,
policies, guidances, and technical publications; and
promotes technology innovation. In its efforts to
coordinate across the various programs, EPA seeks
to recognize the need for cleanup tools that will
have wide applicability.
In developing this report, EPA has identified seven
major cleanup programs or market segments that
make up the national cleanup market:
• National Priorities List (NPL, or Superfund)
• Resource Conservation and Recovery Act
(RCRA) Corrective Action
• Underground Storage Tanks (UST)
• Department of Defense (DOD)
• Department of Energy (DOE)
• Other (Civilian) Federal Agencies
• States and Private Parties (including
brownfields)
While segmentation is necessary to better
understand each market, the parties involved in site
characterization and remediation require a unified
picture of the market in order to make better
informed investment, marketing, and other strategic
decisions. This study provides both perspectives—it
sums up the entire market based on a thorough
analysis of each segment. Smarter investments by
all involved parties will result in more cost-
Executive Summary
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
effective remediation technologies, thereby
reducing the cost burden for the nation as a whole
as it works to recover contaminated land and
groundwater and protect the public's health.
Study Approach
This report updates and expands a 1996 analysis
that brought together valuable information on site
characteristics, market size, and other factors that
affect the demand for remediation services.2 As
with the previous report, the focus of this study is
on the potential future applications of remediation
technologies.
To provide a useful estimate of future needs, the
demand estimates focus on remaining cleanup work
at sites where the remedies have not yet been
chosen, and do not include projects that are
underway or completed. While the report considers
a broad range of remediation services required in
the future, its purpose is to provide insight into the
potential for the application of new treatment and
site characterization technologies.
This report is not a budgeting analysis. Most of the
cleanups are typically funded by the public and
private owners of the properties and those who are
potentially responsible for the contamination. A
small percentage of cleanups are likely to be
conducted by EPA. The report's time horizon,
approximately 30 years, is beyond the budgeting
period of most private and public institutions.
Moreover, the uncertainties in many of the market
estimates, including who will conduct, oversee, and
pay for the needed cleanups, make it impossible to
convert these estimates to resource needs for
specific government or private organizations.
In addition to providing a unified perspective of the
nature and scope of the Nation's contaminated
property cleanup needs, this report includes a more
in-depth analysis of the seven major programs or
market segments identified earlier, covering areas
such as their structure, operation, and regulatory
U.S. Environmental Protection Agency, Office of
Solid Waste and Emergency Response, Technology
Innovation Office, Cleaning Up the Nation's Waste
Sites: Markets and Technology Trends, EPA 542-R-96-
005, April 1997.
requirements. Information and analyses of the
following are provided for each segment:
• Factors Affecting Demand—the economic,
political, and technical factors and trends that
may influence the size, timing, or
characteristics of the market segment (market
drivers);
• Numbers and Characteristics of Sites—
measures of the market in terms of the number
of sites to be remediated, occurrence of
contaminants, and extent of remediation work
needed;
• Estimated Cleanup Costs—remediation cost
estimates, or the value of the market;
• Market Entry Conditions—considerations that
may benefit vendors and researchers, such as
contracting practices, competition, and
information sources;
• Technology Issues and R&D—technologies
used in a specific market segment and relevant
research and development.
The study also includes analyses of remediation
needs in three market "niches," each of which
presents a specific set of remediation
challenges—the cleanup of former manufactured
gas plant (MGP) and other coal tar sites, mining
sites, and drycleaner sites. It also addresses two
specific issues that affect hazardous waste sites in
most remediation programs—site characterization
technology, and the remediation of dense non-
aqueous phase liquids (DNAPLs). These niches cut
across all seven market segments.
The data used for this report are from federal
databases, such as the Comprehensive
Environmental Response, Compensation, and
Liability Information System (CERCLIS), RCRA
Info, and DOD's Restoration Management
Information System (RMIS), published studies,
guidance documents, and web sites; commercial
information; and other sources. Some are current
through fiscal years (FY) 2001 and 2002, while
others are current through 2003 and the first part of
2004. Because many hazardous waste sites are still
undergoing evaluation, data availability differs from
one market segment to another. Each chapter of the
Executive Summary
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
report includes an explanation of the analytical
methodology, information sources, and
assumptions, and a detailed list of references.
Supporting information is included in the
appendices, as well as in explanations in the
narrative, footnotes, and figures.
Study Limitations
The reliability and detail of the estimates in this
report are a function of the availability and quality
of data, and, obviously, the innate uncertainties in
forecasting future events. In addition, each of the
seven programs have somewhat different
operational practices and use varying definitions of
terms such as "sites," "facilities," "installations,"
and "operable units." Although most of the
activities underlying this cost estimate are for
remedial action and site evaluation, they also
include some administrative work where costs are
not reported separately.
It cannot be overemphasized that the estimates in
this report are just estimates. It is likely that
assumptions about the future, which are based on
historical experience, will be more reliable for the
earlier years than the later years. Likewise,
estimates for sites already in a state or federal
cleanup program would be more reliable than those
for sites that have yet to be discovered.
Nevertheless, the resulting estimates provide a
plausible range of the likely extent of the nation's
site cleanup needs.
The estimate of the total cost of each cleanup
market segment is based on estimates of historical
averages for each market segment and these may
change in the future. Future cleanups may turn out
to be more or less complex, or applications of
advanced site characterization and cleanup
technologies may improve the cleanup cost-
effectiveness.
Predictions of potential future site discoveries and
additions to the NPL are also based on recent
history. The cleanup market includes sites that are
not yet enrolled in a cleanup program, or have not
yet been discovered. The ultimate number of
additions to the NPL or discoveries of non-NPL
sites depend upon several factors which are difficult
to predict. Nevertheless, these sites are expected to
be an important component of the market.
The limitations and uncertainties of the market
estimates vary from one market segment to another.
For example, the forecast of future releases from
USTs is hampered by a paucity of data with which
to estimate leakage rates; the estimate of the
number and potential cost of mining site cleanups is
presented as a wide range of values and reflects an
attempt to develop a consensus of a number of
industry and government sources; and the estimate
of the number of potential manufactured gas plant
sites needing cleanup is based on studies that have
estimated the number of original facilities that cause
the contamination and assumptions regarding their
disposition since their operations ceased many
years ago. Although DOD and DOE have clearly
identified most of the contamination problems at
their installations and facilities, there are
technological uncertainties at some DOE sites
which may cause the estimates to be overstated or
understated.
Although this report estimates the potential scope of
the market, it does not explicitly estimate the timing
of the cleanup work. As in most economic
activities, one cannot simply assume that the
cleanup work will be conducted at a constant pace
from year to year. The schedule of any project can
be expedited or retarded by the availability of funds
in any given year; technical uncertainties;
difficulties in achieving agreements among
stakeholders on a number of issues, such as cleanup
approach and target end states, who will pay, who
is responsible for damages, and how the site will be
reused. In addition, long-term stewardship will be
needed at many sites.
Executive Summary
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Major Findings
Although substantial progress has been made over
the past quarter century, a considerable amount of
cleanup work remains. At current levels of site
cleanup activity in the U.S. (About $6-8 billion
annually), it would take 30 to 35 years to complete
most of the work needed.
Quantifying the amount and nature of future work
is subject to the limitations and uncertainties
described above and requires making a number of
assumptions. Users of the report will reap the
greatest benefit if they carefully review the
discussions of how the estimates were developed,
which are included throughout the report. Given
these limitations, the following are some of the
major findings:
Under current regulations and practices a total
of 235,000-355,000 sites (average 294,000)
will need to be cleaned up in all seven
programs (Exhibit). More than 90 percent of
these sites are in programs that tend to have
smaller, less-complex cleanup projects, such as
UST sites and sites managed under state
cleanup programs. The sites in the remaining
programs, such as Superfund, DOD, and DOE,
tend to be larger and more complex, on
average.
These cleanups are estimated to cost $170-250
billion (average $209 billion). Most of this cost
will be borne by the owners of the properties
(private and public entities) and those
potentially responsible for the contamination.
Estimated Number of Hazardous Waste Sites
and Cleanup Costs: 2004-2033
= =
RCRA-CA
3,800
NPL
UST
&
Prwata
S3QB.
Civilian
Agencies
These estimates are derived from judgements regarding the most likely scenarios within a range of estimates. The estimates described
in the report, include a number of assumptions such as the average cleanup cost per site, number of new site discoveries, and future
to the NPL.
NPL: National Priorities List, or Superfund: RCRA-CA: Resource Conservation and Recovery Act Corrective Action program: UST:
Underground Storage Tanks: DOD: Department of Defense; DOE: Department of Energy; Civilian Agencies: non-DOO and non-DOE
federal agencies, and State & Private" mandatory, voluntary, and brownfields and private
not add due to rounding.
The estimated number of sites (294,000)
includes sites that have already been discovered
(77,000) plus an estimate of the number of sites
to be discovered in the future (217,000). The
estimated number of future sites (mostly NPL,
UST and sites managed under state programs)
is based on the rate of new sites discovered in
the late 1990s and early 2000s:
Executive Summary
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
• • Between 1993 and 2003 an average of 28
sites per year were listed on the NPL. This
report assumes that this rate will continue
for 10 years. Although listings may
continue beyond 10 years, they are not
included because of uncertainties in
predicting NPL listings.
• • The estimated number of future UST site
discoveries is based on the annual rate of
new releases in recent years (6,000-12,000)
and the assumption that this rate will
continue for 10 years. Although tank
releases may continue beyond 10 years and
leakage rates may decline, these scenarios
are not included because of uncertainties in
predicting these trends.
• • The estimated number of sites to be
discovered under state mandatory and
voluntary cleanup programs is based on an
average of 5,000 cleanups completed
annually in recent years. Because studies
indicate that there are many sites yet to be
discovered, it is assumed that this activity
level will continue for at least 30 years.
Most cleanup programs have similar
contaminants: solvents and other organics,
metals, and petroleum products.
Over the next 30 years, there will be a need to
address many smaller sites, primarily 125,000
UST and 150,000 state and private party sites
(including brownfields). There is also a need to
screen many more sites to determine whether or
not they have contamination problems.
The demand for cleanup of many sites will be
influenced by real estate development activity
as well as regulatory requirements. Some sites
do not come to the attention of state or federal
cleanup programs until they are investigated in
the course of development activity or real estate
transactions. For some properties, developers or
prospective site users may assume all or part of
the cleanup costs.
Non-DOD and non-DOE federal agencies that
have contaminated sites, including the
Departments of Interior, Agriculture, and
Transportation, combined, have been spending
less than $200 million annually for site
cleanups. They have an estimated $15-21
billion of cleanup work yet to be completed.
• Improved approaches to site characterization
have been demonstrated to lead to faster,
cheaper, and better cleanups. For example,
newer site characterization approaches have
made the removal and treatment of DNAPLs at
some sites more cost effective than containing
the material in the subsurface.
• The trend toward risk-based cleanups, which is
found throughout the remediation market, may
influence the remedy selection process, foster
more flexibility in site reuse, and provide
incentives for property owners to bring more
sites into remediation programs. It is difficult to
predict the impact of these developments on the
use of specific remedy types.
• The need for monitoring and long-term
operation and maintenance of remedy
components is expected to increase in most
market segments.
At current public and private spending levels for
site cleanups, it will take several decades to
complete all the cleanup work estimated in this
report. As with most cleanups requiring technically
complex solutions and coordination of multiple
stakeholders, the work load will probably fluctuate
from year to year. Most of these costs will be borne
by private companies, and owners of state and
federal facilities, such as DOD and DOE. This
market represents a significant opportunity for
continued development and implementation of
cleanup approaches and technologies that will result
in better, cheaper, and faster site cleanups, as well
as technologies that enable us to better address
challenging contamination problems such
characterizing NAPLs in the subsurface.
Technical solutions to a particular contaminated site
problem are generally similar, regardless of the
regulatory program under which they are
implemented. While individual markets may not
support certain investment decisions, the aggregate
demand across all markets might justify the up-
front investment in a technology that ultimately
drives down the cost of moving contaminated sites
into productive use. By recognizing this potential
for economies of scale in cleanup technology
markets, the information in this report contributes to
better investment decisions across all markets.
Executive Summary
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Table of Contents
Page
Notice iii
Acknowledgments iv
Executive Summary v
Chapter 1. Introduction and Summary 1-1
.1 Introduction 1-1
.2 Using This Document 1-2
.3 Study Approach and Limitations 1-2
.4 Market Size 1-4
.5 Hazardous Waste Site Characteristics 1-13
1.5.1 Contaminated Media 1-14
1.5.2 Contaminants of Concern 1-14
1.6 Cleanup Program Status and Factors Affecting Demand 1-16
1.6.1 Superfund Sites 1-17
1.6.2 RCRA Corrective Action Sites 1-18
1.6.3 Underground Storage Tank Sites 1-19
1.6.4 Department of Defense Sites 1-20
1.6.5 Department of Energy Sites 1-20
1.6.6 Civilian Federal Agency Sites 1-21
1.6.7 State and Private Party Sites 1-22
1.6.8 Manufactured Gas Plant Sites 1-23
1.6.9 Mining Sites 1-24
1.6.10 Drycleaner Sites 1-24
1.6.11 Site Characterization 1-25
1.6.12 DNAPLs 1-25
1.7 Implications for Site Characterization and Cleanup 1-26
Chapter 2. Remediation Technologies Used At National Priorities List Sites 2-1
2.1 Definitions of Remediation Technologies 2-1
2.2 Historical Use of Remediation Technologies at Superfund Sites 2-2
2.2.1 Containment and Disposal Technologies for Source Control 2-4
2.2.2 Treatment Technologies for Source Control 2-5
2.2.3 Groundwater Remedies 2-6
2.3 Advancing Remediation and Characterization Technologies 2-7
2.4 References 2-10
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Chapter 3. Demand For Remediation of National Priorities List Sites 3-1
3.1 The Superfund Program 3-1
3.1.1 The National Contingency Plan 3-1
3.1.2 The Superfund Process 3-2
3.1.3 Program Status 3-3
3.2 Factors Affecting Demand for Cleanup 3-3
3.3 Number of Sites 3-5
3.4 Site Characteristics 3-7
3.4.1 Types of Contaminated Matrices 3-8
3.4.2 Types of Contaminants 3-8
3.4.3 Estimated Quantities of Contaminated Material 3-11
3.5 Estimated Cleanup Costs 3-13
3.6 Market Entry Considerations 3-15
3.6.1 Market Considerations During Remedy Selection 3-16
3.6.2 Market Considerations During Design and Procurement 3-17
3.6.3 Research, Development, and Demonstration 3-18
3.7 References 3-19
Chapter 4. Demand for Remediation of RCRA Corrective Action Sites 4-1
4.1 Program Description 4-2
4.1.1 Regulatory History 4-2
4.1.2 Corrective Action Process 4-7
4.1.3 Corrective Action Implementation 4-8
4.2 Factors Affecting Demand for Cleanup 4-10
4.3 Number and Characteristics of RCRA Sites 4-11
4.3.1 Number of RCRA Sites 4-11
4.3.2 Types of RCRA Sites 4-13
4.4 Estimated Cleanup Costs 4-16
4.5 Market Entry Considerations 4-17
4.6 Remediation Technologies 4-17
4.7 References 4-19
Chapter 5. Demand for Remediation of Underground Storage Tank Sites 5-1
5.1 Federal Program Description 5-2
5.2 Factors Affecting Demand for Cleanup 5-4
5.2.1 General Trends 5-4
5.2.2 State Regulations and Funding Sources 5-6
5.2.3 2002 Brownfields Legislation and EPA's USTfields Initiative 5-7
5.2.4 MTBE Contamination and the Remediation Market 5-7
5.2.5 State Performance-Based Environmental Cleanup Programs 5-8
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5.3 Number and Location of USTs 5-9
5.3.1 Population of UST Sites in the U.S 5-9
5.3.2 Location of Regulated Tanks 5-10
5.3.3 Potential Number of Sites to be Cleaned Up 5-10
5.4 Estimated Cleanup Costs 5-12
5.5 Market Entry Considerations 5-12
5.6 Remediation Technologies 5-13
5.7 References 5-15
Chapter 6. Demand For Remediation of Department of Defense Sites 6-1
6.1 Program Description 6-2
6.1.1 Installation Restoration Program 6-2
6.1.2 Base Realignment and Closure (BRAC) 6-4
6.1.3 The Military Munitions Response Program 6-5
6.2 Factors Affecting the Demand for Cleanup 6-5
6.3 Number and Characteristics of Sites 6-6
6.3.1 Number and Types of Sites 6-6
6.3.2 Contaminated Matrices 6-9
6.3.3 Types of Contaminants 6-11
6.4 Estimated Cleanup Costs 6-13
6.5 Market Entry Considerations 6-14
6.6 Remediation Technologies 6-16
6.6.1 Technologies Used at DOD Sites 6-16
6.6.2 Research, Development, and Demonstration 6-16
6.7 References 6-18
Chapter 7. Demand For Remediation of Department of Energy Sites 7-1
7.1 Program Description 7-2
7.1.1 Deactivation and Decommissioning of Surplus Facilities 7-3
7.1.2 Remedial Actions 7-4
7.1.3 Long-Term Surveillance and Maintenance 7-5
7.1.4 Stabilization of High-Risk Materials 7-6
7.1.5 Regulatory Requirements and Other Program Drivers 7-6
7.1.6 Policy Initiatives: The Top-to-Bottom Review 7-7
7.2 Factors Affecting Demand for Cleanup 7-7
7.3 Number and Characteristics of Sites 7-9
7.4 Estimated Cleanup Costs 7-12
7.4.1 Life Cycle Costs 7-12
7.4.2 Timing of Expenditures 7-14
7.5 Market Entry Considerations 7-14
7.6 Remediation Technologies 7-17
7.6.1 Private Sector Involvement: Mechanisms 7-20
7.6.2 Private Sector Involvement: Programs 7-21
7.7 References 7-24
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Page
Chapter 8. Demand for Remediation of Sites Managed By Civilian Federal Agencies 8-1
8.1 Civilian Federal Agency Cleanup Programs 8-2
8.2 Factors Affecting Demand for Cleanup 8-3
8.3 Number of Facilities and Sites 8-4
8.4 Site Characteristics 8-7
8.5 Estimated Cleanup Costs 8-8
8.6 Remediation Technologies 8-11
8.7 References 8-11
Chapter 9. Demand for Remediation of States and Private Party Sites 9-1
9.1 Programs Addressing State Sites 9-2
9.1.1 State Hazardous Waste Cleanup Programs 9-2
9.1.2 Voluntary Cleanup and Brownfield Programs 9-4
9.1.3 Federal Initiatives Affecting State Cleanups 9-6
9.2 Factors Affecting Demand for Cleanups 9-7
9.3 Number and Characteristics of Sites 9-9
9.3.1 State Mandatory Hazardous Waste Programs 9-9
9.3.2 Voluntary Cleanup and Brownfield Programs 9-12
9.3.3 Contaminants and Media 9-13
9.4 Estimated Cleanup Costs 9-15
9.4.1 Status and Capacity of State Cleanup Funds 9-15
9.4.2 Annual and Projected Cleanup Costs 9-18
9.5 Market Entry Conditions 9-19
9.6 Remediation Technologies 9-21
9.7 References 9-22
Chapter 10. Demand for Remediation of Manufactured Gas Plants and
Related Coal Tar Sites 10-1
10.1 History 10-1
10.2 Gas Manufacturing Processes 10-2
10.3 Number and Characteristics of Sites 10-2
10.4 Waste Types and Quantities 10-7
10.5 Remediation Technologies 10-9
10.6 Estimated Cleanup Costs 10-13
10.7 References 10-15
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Chapter 11. Demand for Remediation of Mining Sites 11-1
11.1 Industry Description 11-1
11.1.1 Types of Mining 11-2
11.1.2 Mining Processes 11-2
11.1.3 Types of Wastes 11-4
11.1.4 Regulatory Programs 11-5
11.1.5 Mines on Federal Lands 11-7
11.2 Factors Affecting Demand 11-8
11.3 Number of Sites 11-9
11.4 Market Entry Conditions 11-12
11.5 Estimated Cleanup Costs 11-12
11.6 Remediation Technologies 11-13
11.7 Research and Development 11-14
11.8 References 11-15
Chapter 12. Demand for Remediation of Drycleaner Sites 12-1
12.1 Industry Description 12-1
12.1.1 Drycleaning Processes 12-2
12.1.2 Types of Wastes and Waste Management Practices 12-5
12.1.3 State and Industry Drycleaner Site Cleanup Programs 12-6
12.2 Factors Affecting Demand for Remediation 12-7
12.3 Number and Characteristics of Sites 12-8
12.3.1 Active Drycleaning Facilities 12-8
12.3.2 Inactive Drycleaning Facilities 12-10
12.4 Market Entry Considerations 12-11
12.5 Estimated Cleanup Costs 12-11
12.6 Remediation Technologies 12-11
12.6.1 Site Assessment Technologies 12-13
12.6.2 Remediation Technologies 12-14
12.7 References 12-15
Chapter 13. Demand for Site Characterization Services 13-1
13.1 Market Description 13-1
13.2 Site Characterization Tools 13-5
13.2.1 Sample Access and Collection Technologies 13-6
13.2.2 Sample Analysis Technologies 13-6
13.2.3 Field Technologies 13-7
13.2.4 Adaptive Site Management Approaches 13-7
13.3 Factors Affecting Demand 13-11
13.4 Number of Sites That Will Need Characterization 13-13
13.5 Estimated Value of Site Characterization Market 13-16
13.6 Market Entry Conditions 13-18
13.7 References 13-19
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Chapter 14. DNAPLs at Hazardous Waste Sites 14-1
14.1 Market Description 14-1
14.1.1 DNAPLs in the Environment 14-2
14.1.2 Chemical Compounds that are DNAPLs 14-2
14.1.3 Industrial Activities 14-3
14.1.4 Hydrogeological Characteristics 14-4
14.2 Factors Affecting Demand for Remediation Services 14-4
14.3 Number and Types of Sites 14-6
14.4 Estimated Cleanup Costs 14-9
14.4.1 Pump-and-Treat System Costs 14-9
14.5 Remediation Technologies 14-13
14.5.1 Site Characterization 14-13
14.5.2 Treatment Technologies 14-14
14.5.3 Balancing Source Removal/Treatment vs. Containment 14-15
14.6 References 14-16
Appendix A. Supporting Data for Analysis of National Priorities List Sites A-l
Appendix B. Supporting Data for Analysis of Underground Storage Tank Sites B-l
Appendix C. Supporting Data for Analysis of Department of Defense Sites C-l
Appendix D. Supporting Data for Analysis of Manufactured Gas Plant Sites D-l
Appendix E. Federal and State Programs E-l
Appendix F. Acronyms F-l
Table of Contents Page xvi
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
List of Exhibits
Exhibit Page
1-1 Estimated Number of Sites to be Remediated 1-5
1-2 Estimated Remaining Remediation Cost (SBillions) 1-6
1-3 Media to be Remediated 1-14
1-4 Contaminant Groups to be Remediated 1-15
2-1 Treatment Technologies 2-3
2-2 Remedy Types Selected or Used for Source Control at NPL Sites, FY 1982-2002 2-4
2-3 Superfund Remedial Actions at Source Control Treatment Projects FY 1982-2002 2-6
2-4 Groundwater and Other Remedy Types Selected or Used at NPL Sites, FY 1982-2002 2-7
2-5 Superfund Sites With P&T, In-situ Treatment, or MNA
as Part of a Groundwater Remedy FY 1982-2002 2-8
3-1 Location of NPL Sites With Planned Remedial Actions by State and EPA Region 3-5
3-2 Phase of Remediation of Operable Units at Non-Federal NPL Sites
with Planned Remedial Actions 3-6
3-3 Frequencies of Contaminated Matrices at NPL Sites With RODs 3-8
3-4 Frequencies of Major Contaminant Groups at NPL Sites With RODs 3-9
3-5 Frequencies of Major Contaminant Subgroups at NPL Sites With RODs 3-10
3-6 Frequencies of the Most Common Contaminants at NPL Sites With RODs 3-11
3-7 Distribution of Quantities of Contaminated Soil, Sediment, and Sludge
at NPL Sites With RODs 3-12
3-8 Estimated Quantity of Contaminated Soil, Sediment, and Sludge for Major
Contaminant Groups at NPL Sites With Planned Remedial Actions 3-13
3-9 Estimated Cleanup Costs for NPL Sites 3-14
4-1 Location of RCRA Sites Subject to Corrective Action by State and EPA Region 4-12
4-2 Priority Ranking of RCRA Sites Subject to Corrective Action 4-13
4-3 Location of RCRA Sites Likely to Require Corrective Action by State and EPA Region ... 4-14
4-4 Major Waste Management Processes at RCRA Facilities 4-14
4-5 Estimated RCRA Corrective Action Costs (SMillions) 4-17
4-6 Remedies Selected for Soil at 86 RCRA Corrective Action Facilities 4-18
5-1 Backlog of UST Site Cleanups to be Completed 5-4
5-2 Confirmed Releases at UST Sites 5-4
5-3 Compliance Status of USTs by Region 5-5
5-4 UST Site Cleanup Progress 1991-2002 5-10
5-5 Estimated Number of UST Sites Needing Remediation 5-11
5-6 Types and Frequencies of Soil Remediation Technologies at LUST Sites 5-13
5-7 Type and Frequency of Groundwater Remediation Technologies at LUST Sites 5-14
Table of Contents Page xvii
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit Page
6-1 Number of DOD Sites by Status 6-7
6-2 Number of DOD Sites and Installations Needing Cleanup 6-8
6-3 Location of DOD Sites Needing Cleanup 6-8
6-4 Most Common Types of DOD Sites Needing Cleanup 6-9
6-5 Frequency of Contaminated Matrices at DOD Sites Needing Cleanup 6-10
6-6 Frequency of Contaminated Matrices by Site Type at DOD Sites Needing Cleanup 6-10
6-7 Major Contaminant Groups by Matrix at DOD Sites Needing Cleanup 6-11
6-8 Major Contaminant Groups by DOD Component at Sites Needing Cleanup 6-12
6-9 Frequency of Major Contaminant Groups
for the Most Common DOD Site Types Needing Cleanup 6-13
6-10 DOD Cleanup Expenditures: FY 2001-2005 6-13
6-11 Treatment Technologies Used at DOD Sites 6-17
7-1 Remaining Release Sites and D&D Facilities by Location 7-11
7-2 Estimated Remaining Life Cycle Cost for DOE Site Restoration by Installation 7-13
7-3 Actual and Planned EM and Site Restoration Budget: FY 2000-2004 7-14
7-4 DOE Environmental Management Expenditures 2002-2004 ($000) 7-15
7-5 Examples of Innovative Technologies Useful to DOE 7-18
8-1 Number of Civilian Federal Facilities Potentially Requiring Cleanup 8-5
8-2 DOI Allocation of the Central Hazardous Materials Fund 8-6
8-3 Examples of Types of Contaminated Facilities at Civilian Federal Agencies 8-8
8-4 Estimate Cleanup Cost for Civilian Federal Agencies 8-9
9-1 State Cleanup Program Summary 9-3
9-2 Sites in State Hazardous Waste Programs 9-10
9-3 Number of Non-NPL State Hazardous Waste Sites 9-11
9-4 Voluntary and Mandatory Cleanup Program Status 9-13
9-5 Contaminants Found at a Sample of Brownfield Sites 9-14
9-6 State Fund Activity 1995, 1997, and 2000 ($ millions) 9-16
9-7 State Hazardous Waste Funds Expenditures and Balances 2000 and 1997 9-17
9-8 Estimated Total Cost of State Site Cleanups (SMillions) 9-19
9-9 Remediation Techniques Used at a Sample of Brownfield Sites 9-22
10-1 Types and Numbers of Former Manufactured Gas Plants
& Related Coal Tar Facilities in the U.S 10-4
10-2 Estimated Magnitude & Disposition of Former Manufactured Gas Plants
& Other Coal Tar Sites in the U.S 10-6
10-3 Estimated Quantities of Residuals and Wastes Released
at Former MGP & Other Coal Tar Sites in the U.S 10-8
10-4 Remediation Alternatives by Category of Waste
at Former Manufactured Gas Plants 10-11
10-5 Estimated Average Remediation Cost by Site Type 10-14
11-1 Number of Active Mining Sites - 2001 11-10
11-2 Comparison of Estimates of Number of Abandoned Hard Rock Mining Sites 11-11
11-3 Estimated Remediation Costs for U.S. Hardrock Mines 11-13
Table of Contents Page xviii
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Page
12-1 Number and Types of Active Drycleaners in the United States 12-9
12-2 Estimated Drycleaner Site Remediation Costs 12-12
12-3 Site Assessment Technologies Used at Drycleaner Sites 12-13
12-4 Site Remediation Technologies Used at Drycleaner Sites 12-14
13-1 Major Characterization Technology Subcategories 13-6
13-2 Examples of Common Field Analytical Technologies 13-8
13-3 Examples of Projects with Savings and Efficiency Improvements
Associated With Advanced Site Characterization Technologies 13-12
13-4 Estimated Number of Sites to Require Sampling and Analysis 13-15
13-5 Estimated Major Components of Superfund Costs 13-16
13-6 Remediation Cost and Site Size (Smillions) 13-17
13-7 Estimated Site Characterization Costs 13-17
14-1 Common DNAPL-Related Chemicals 14-3
14-2 Occurrence of VOCs and SVOCs at Contaminated Sites 14-6
14-3 Estimated Number of Sites With DNAPLs 14-8
14-4 Cleanup Costs for Selected Pump-and-Treat Projects 14-10
14-5 Comparison of Pump-and-Treat Costs for Selected Projects 14-11
A-2 Contaminant Groups and Subgroups for the Analysis of Contaminants
at NPL and DOD Sites A-3
A-2 Superfund Remedial Action Contractors (RACs) A-13
B-l UST Corrective Action Measures Mid-Year FY 2004 (As of March 31, 2004) B-2
C-l Location of DOD Sites Needing Cleanup C-2
C-2 Definitions of DOD Site Types C-4
C-3 DOD Site Types Needing Cleanup C-10
C-4 Frequency of Matrices by DOD Site Type C-12
C-5 Frequency of Major Contaminant Groups by Matrix and DOD Component C-l4
C-6 Frequency of Major Contaminant Groups by DOD Site Type C-l6
C-7 Frequency of Contaminant Subgroup by Matrix C-18
D-l Estimated Disposition of Former Manufactured Gas Plants
& Other Coal Tar Sites in the U.S D-2
D-2 Estimated Typical Remediation Cost by Site Type D-4
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Chapter 1
Introduction and Summary
1.1 Introduction
Over the next several decades, federal, state, and local governments and private industry will
commit billions of dollars annually to clean up sites contaminated with hazardous waste and
petroleum products. This commitment will result in a continuing demand for site remediation
services and technologies. This report provides an overview of the site characterization and
remediation market to help industry and government officials develop research, development,
and business strategies. It was prepared to aid those who are developing, commercializing, and
marketing new technologies to meet the future cleanup demand.
This report updates and expands a 1996 analysis that brought together valuable information on
site characteristics, market size, and other factors that affect the demand for remediation
services.1 As with the previous report, the focus of this study is on the potential future
applications of remediation technologies. To provide a realistic estimate of future needs, the
estimates of demand focus on remaining cleanup work at sites where cleanup technologies have
not yet been chosen, and exclude projects that are underway or completed. While the report
considers a broad range of remediation services required in the future, its purpose is to provide
insight into the potential application of new treatment and site characterization technologies.
In addition to providing a unified perspective of the characteristics and scope of the nation's
contaminated property cleanup needs, this report provides a more in-depth analysis of the seven
major cleanup programs or market segments:
• National Priorities List (NPL, or Superfund)
• Resource Conservation and Recovery Act (RCRA) Corrective Action
• Underground Storage Tanks (UST)
• Department of Defense (DOD)
• Department of Energy (DOE)
• Other (Civilian) Federal Agencies
• States and Private Parties (including brownfields)
In addition to providing updates and new information relating to these seven market segments,
this report also includes analyses of remediation needs in three market "niches," each of which
presents a specific set of remediation challenges—the cleanup of former manufactured gas plant
(MGP) and other coal tar sites, mining sites, and drycleaner sites; and two specific issues that
affect hazardous waste sites in most remediation programs—site characterization technology and
the remediation of dense non-aqueous phase liquids (DNAPLs).
U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Technology Innovation
Office, Cleaning Up the Nation's Waste Sites: Markets and Technology Trends, EPA 542-R-96-005, April 1997
Chapter 1: Introduction and Summary Page 1-1
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
1.2 Using This Document
This chapter contains a summary of the findings of this report. Chapter 2 describes the recent
trends in the use of remedial technologies at Superfund sites. Because many contamination
problems are similar across the seven market segments, the Superfund technology information is
useful to help understand potential technology trends in the other markets. Chapters 3 through 9
address each of the seven market segments listed above. These seven segments can be added to
arrive at the total remediation market.
Chapters 10 through 14 address five specialized portions of the remediation market. The
analyses in these chapters are from a different perspective than the first seven market segments,
and the estimates of market size and value are not additive to those in chapters 3 through 9. The
five topics include manufactured gas plant sites (MGPs), mining sites, drycleaner sites, site
characterization, and dense non-aqueous phase liquids (DNAPLs).
For most market segments, seven areas are addressed within each chapter:
• Program or Market Segment Description—the structure, operation, and regulatory
requirements of the program;
• Factors Affecting Demand—the economic, political, and technical factors and trends that
influence the size, timing, or characteristics of the market segment (market drivers);
• Numbers and Characteristics of Sites—measures of the market in terms of the number of
sites to be remediated, occurrence of contaminants, and extent of remediation work needed;
• Estimated Cleanup Costs—remediation cost estimates, or the value of the market;
• Market Entry Conditions—considerations that may benefit vendors and researchers, such as
contracting practices, competition, and information sources;
• Technology Issues and Research and Development (R&D)—technologies used in a specific
market segment and relevant research and development; and
• References—citations are referenced at the end of each chapter.
Appendices A through F contain supporting data, sources for additional information on the
remediation market and technologies, and definitions of terms used in this report. The acronyms
are on the last four pages of the document (Appendix F).
1.3 Study Approach and Limitations
The data used for this report are from federal databases, such as the Comprehensive
Environmental Response, Compensation, and Liability Information System (CERCLIS), RCRA
Info, and DOD's Restoration Management Information System (RMIS), published studies,
guidance documents, and web sites; commercial information; and other sources. Some are
Chapter 1: Introduction and Summary Page 1-2
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
current through fiscal years (FY) 2001 and 2002, while others are current through 2003 and the
first part of 2004. Because many sites are still undergoing evaluation, data availability differs
from one market segment to another. Each chapter includes an explanation of the analytical
methodology, information sources, and assumptions, and a list of references. Supporting
information is included in the appendices.
This report is not a budgeting analysis. Most of the cleanups are typically funded by the public
and private owners of the properties and those who are potentially responsible for the
contamination. A small percentage of cleanups are likely to be conducted by EPA. The report's
time horizon, approximately 30 years, is beyond the budgeting period of most private and public
institutions. Moreover, the uncertainties in many of the market estimates, including who will
conduct, oversee, and pay for the needed cleanups, make it impossible to convert these estimates
to resource needs for specific government or private organizations.
It cannot be overemphasized that the estimates in this report are just estimates. It is likely that
assumptions about the future, which are influenced by historical experience, will be more
reliable for the earlier years than the later years. Likewise, estimates for sites already in a state or
federal cleanup program would be more reliable than those for sites that have yet to be
discovered. Nevertheless, the resulting estimates provide a plausible picture of the likely extent
of the nation's hazardous waste site cleanup needs.
The limitations and uncertainties of the market estimates vary from one market segment to
another. For example, the forecast of future releases from USTs is hampered by a paucity of data
with which to estimate leakage rates; the estimate of the number and potential cost of mining site
cleanups is presented as a wide range of values and reflects an attempt to develop a consensus of
a number of industry sources; and the estimate of the number of potential manufactured gas plant
sites needing cleanup is based on studies that have estimated the number of original facilities that
caused the contamination and assumptions regarding their disposition since their operations
ceased many years ago. Although DOD and DOE have clearly identified much of the
contamination problems at their installations and facilities, there are a significant number of
DOE sites that have not yet been fully characterized. The analysis is further complicated by the
fact that the definitions of sites and facilities differ somewhat from one market segment to
another. In this report, the term "site" is used to indicate an individual area of contamination,
which can be small or large. The terms "facility" and "installation" identify an entire tract,
including contiguous land within the borders of a property, and may contain more than one site.
Although this report estimates the potential scope of the market, it does not explicitly estimate
the timing of the cleanup work. As in most economic activities, one cannot simply assume that
the cleanup work will be conducted at a constant pace from year to year. The schedule of any
project can be expedited or retarded by the availability of funds in any given year; technical
uncertainties; difficulties in achieving agreements among stakeholders on a number of issues,
such as cleanup approach and target end states, who will pay, who is responsible for damages,
and how the site will be reused. In addition, long-term stewardship will be needed at many sites.
Chapter 1: Introduction and Summary Page 1-3
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
1.4 Market Size
Under current regulatory requirements and practices, an estimated 294,000 sites (range 235,000 -
355,000) in the seven market segments will need to be cleaned up (Exhibit 1-1). This estimate
does not include sites where cleanup is completed or ongoing.
More than 90 percent of these sites are in programs that tend to have relatively smaller, less-
complex cleanup projects, such as the UST program (125,000 sites) and state voluntary and
mandatory cleanup programs (150,000). The sites in the remaining programs, such as Superfund,
DOD, and DOE, tend to be larger and more complex, on average.
The 294,000 sites estimate includes 77,000 sites that have already been discovered plus an
estimated 217,000 sites estimated to be discovered in the future. The estimate of the number of
future sites is based on the rate of new site discoveries in recent years and is expected to be
highly variable from year to year. Future discoveries could very well turn out to be higher or
lower than in the past. Most of these "future" sites would be managed under the UST and state
mandatory and voluntary cleanup programs, including brownfields.
This analysis assumes that EPA will add new sites to the NPL for another 10 years, UST site
discoveries will continue for 10 years, and new state and private party site discoveries will
continue for 30 years. Although new site discoveries may very well continue much longer, these
longer-term scenarios are not included in the above estimates because of uncertainties regarding
such long-term predictions. In addition to the initial site cleanup work, many sites will require
long-term stewardship and groundwater treatment or monitoring for many years.
DOD and DOE, have identified most of the contaminated sites on their properties. Nevertheless,
new ones continue to be reported each year, but at a declining rate. In addition, there is evidence
that there may be thousands of sites from
previous industrial activities, such as mining,
gas manufacturing, and drycleaning, that may
need to be cleaned up. Estimates for these
sectors are not included in the above figures.
For four of the seven cleanup programs,
regulatory authorities have identified most
hazardous waste sites. There may be several
hundred thousand contaminated state, private
party, and UST sites yet to be identified, and
additions to the NPL are continuing.
The estimated cost to clean up the 294,000
sites is about $209 billion (Exhibit 1-2). Most
of this cost will be borne by the owners of the
properties (private and public entities) and
those potentially responsible for the contamination. This estimate represents the midpoint of a
range that results from uncertainty regarding the extent and type of contamination at many sites,
the number of sites that will be identified in the future, and the average per-site cost of
remediation in some markets.
Although most of the activities underlying this cost estimate are for remedial action and site
evaluation, they also include some administrative work where costs are not reported separately.
Because this estimate does not include inflation for future years, the amounts actually to be
expended probably will be higher in future-year dollars.
Chapter 1: Introduction and Summary Page 1-4
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Exhibit 1-1. Estimated Number of Sites to be Remediated
Sites
Remaining
Market Segment to be Explanation
Remediated
Superfund
• Current Sites
• Projected Sites
• Subtotal, NPL
RCRA Corrective
Action
Underground
Storage Tanks
(USTs)
DOD
DOE
Civilian
Federal Agencies
States
Total
456
280
736
3,800
125,000
6,400
5,000
> 3,000
150,000
294,000
The number of sites includes non-federal proposed and final National Priorities List (NPL) sites that still
require at least one further remedial action (RA). The NPL also includes 177 federally-owned sites, which
are addressed in the DOD, DOE, and civilian federal agencies market segments below. In addition to
currently listed sites, it is assumed that EPA will add an average of 23-49 sites to the NPL each year for
the next 10 years (Expected value 28).
Although it is likely that construction of remedies at most of these cleanups can be completed in 30 years,
many more decades may be needed for monitoring and groundwater treatment. RCRA Corrective Action
sites related to large federal facilities are included in the DOD, DOE, and civilian federal agencies market
segments below.
Includes 35,000 sites already identified as of March 2004, and 60,000-120,000 sites (average 90,000) that
are projected to leak over the next 10 years The already identified sites may be underestimated because
sites where "cleanups are initiated" are not included, even though some of these site do not yet have
designated cleanup contractors. Although UST cleanups are expected to continue beyond 10 years as
new leaks occur, and leakage rates may decrease in the future, these scenarios are not included in the
estimate.
DOD originally identified over 30,000 sites on over 1,700 installations. Of these, responses have been
completed or cleanups are planned or underway at about 24,000 sites.
DOE has completed active cleanup of contaminated soil, debris, and structures at half of its approximately
10,000 release sites. Groundwater remediation is expected to continue at many sites, and long-term
stewardship will be needed at 129 DOE installations. The estimates also are based on the assumption
that there will be a greater emphasis on containment than on treatment and other remediation strategies.
This figure does not include an estimated 8,000-31 ,000 abandoned mine sites.
Represents 23,000 sites already identified and 127,000 new sites projected to be identified over the next
30 years in state mandated programs, voluntary cleanup programs, and brownfield programs. Additional
sites may be discovered beyond the 30 years.
The total is the most likely value within a range of 235,000 to 355,000 sites. It represents sites requiring
cleanup, and excludes sites where cleanup work is ongoing or complete.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 1-2. Estimated Remaining Remediation Cost ($Billions)
Cost to Clean Up
Remaining Sites
Market Segment Middle Comments
Value Range
Superfund
• Current Sites
• Projected Sites
• Subtotal, NPL
RCRA, Corrective
Action
RCRA, UST
DOD
DOE
Civilian
Federal Agencies
States
Total
19.4
12.7
32.1
44.5
15.6
33.2
35.0
18.5
30.0
208.9
16-23
8-27
24-50
31 -58
12-19
NA
NA
15-22
24-36
174-253
The current sites estimate is for currently listed sites not owned
by the federal government that still need remedial action. The
projected sites figure is based on an assumed 28 new additions
to the NPL annually (range 23-49) over the next 1 0 years.
Does not include long-term monitoring and groundwater
treatment. RCRA Corrective Action costs related to large federal
facilities are included in the DOD, DOE, and civilian federal
agencies market segments.
Includes 35,000 sites already identified as of March 2004, and
60,000-120,000 sites (average 90,000) that are projected to leak
over the next 10 years. Additional tank leaks will probably
continue beyond 10 years.
This figure includes some costs for sites where cleanup work has
begun.
Does not include the cost long-term stewardship, which is
needed at 129 DOE installations; and the cost of cleaning up
wastes for which no proven practical cleanup approach is
currently available, such as contamination at nuclear test sites
and certain groundwater and surface water.
Does not include the potential $18-51 billion cost for cleaning up
8,000-31,000 abandoned mine sites, most of which are on lands
for which a federal agency is responsible for cleanup.
There is a potential of several hundred thousand additional sites
beyond the 30 years.
The total represents estimated cost for the cleanup of sites
required under current regulations and practices, and excludes
sites where cleanup work has begun or is complete.
Although this study estimates the long-term need for site cleanups, it does not estimate the pace
of cleanup, which is likely to fluctuate from year to year, depending on private and public
funding, who is paying for the cleanups, and other factors. However, Chapters 3 through 14
include discussions of the factors that affect the extent and timing of the cleanup work. Most of
the cleanup program work considered in the above estimates will take 30-35 years to complete.
The estimates for each market segment are described below.
Superfund Sites
The 456 NPL sites not owned by the federal government (non-federal) that require one or more
future remedial actions (RAs) make up a relatively well-defined market for remediation
technologies. The NPL also includes 177 federally-owned sites with future RAs planned. These
sites are included in the market estimates for federal agencies. The number of future listings,
which are expected to be primarily non-federal sites, was assumed to average 28 sites annually,
Chapter 1: Introduction and Summary
Page 1-6
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
which is the average for 1993-2003. This average listing rate is within a range estimated in a
2001 study by Resources for the Future (RFF), a non-profit environmental research group. The
RFF study predicted that listings would average between 23 and 49 sites per year over a 10-year
period, with a most likely value of 35. In the three years since that study, the listing rate has
averaged 23. Most new listings are not federal sites. Although listings may continue beyond 10
years, they are not included in this analysis because of uncertainties in predicting them.
The estimated cost for the 456 non-federal already listed Superfund sites that have not begun RA
is $16-23 billion, with a middle value of $19 billion (2003 dollars). This estimate is based on an
average cost per operable unit (OU) of $1.4 million for remedial investigations/feasibility studies
(RI/FS), $1.4 million for remedial design (RD), $11.9 million for remedial action (RA), and
$10.3 million for long-term remedial action (LTRA) for sites that require long-term treatment to
restore groundwater or surface water. The range in values result from varying the RA costs by
plus and minus 20 percent. The details of these calculations and data sources are provided in
Section 3.5.
This estimate is more than twice that of a similar estimate in the 1997 edition of this report. The
difference is explained by an 18 percent increase in the general price level, the fact that the
remaining sites on the NPL that have not begun RA are expected to be more complex and have
more OUs than the average for previous NPL sites, and the fact that LTRA costs were not
included in the previous report. Although construction has been completed at many sites since
the 1996 edition, about 200 sites have since been added to the NPL.
Using the same unit cost estimates per OU, and assuming 23-49 sites will be listed annually, the
230-490 sites assumed to be listed over the next 10 years will cost $8-27 billion. At the most
likely listing rate of 28 sites annually, the cleanups would cost $13 billion. If more or fewer sites
are listed, this total would be adjusted accordingly. This estimate is based upon the above
assumptions plus the expectation that future sites will be more complex, larger, and have more
OUs per site than the average NPL site in the past.
RCRA Corrective Action Sites
EPA estimates that 3,800 regulated hazardous waste treatment, storage, and disposal facilities
(TSDFs) eventually will require remediation under the RCRA Corrective Action program. This
number is more than half of the approximately 6,670 TSDFs that currently operate or have
operated and are subject to the corrective action regulations. The emphasis in the short term is on
stabilization remedies for risk reduction at about 1,700 of the 3,800 sites. Over the longer term,
additional remedies may be required at most of the 3,800 RCRA Corrective Action sites.
Under current regulations, cleanup of the 3,800 sites that are likely to require corrective action
will cost between $31 billion and $58 billion, with a middle value of $44.5 billion, or $11.4
million per facility. Approximately 41 percent of the total cost will be incurred by nine percent
of the facilities with cleanup costs of greater than $50 million. The average cost-per-site estimate
is based on cost data in an economic analysis in support of the development of the Corrective
Action Management Unit (CAMU) Rule in 2000. Approximately 80-90 percent of this amount
will be incurred by privately-owned facilities and the remainder by federal facilities. This
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
estimate does not include costs for the large DOD and DOE facilities. However, since it includes
costs for some smaller ones, there is some overlap with the estimates for DOD and DOE below.
This estimated average cost per site is about 20 percent lower than that estimated in the 1993
Regulatory Impact Analysis (RIA) for Subpart S. This difference reflects a variety of changes
since that RIA, including more efficient site characterization and cleanup approaches, the use of
risk-based cleanup approaches, and savings due to the CAMU policies described in Section 4.1.
Over the past few years, implementation of the Corrective Action program has shifted toward
more flexible, risk-based cleanups and away from the regulatory approach modeled in the 1993
RIA. In addition, the near-term costs of the program are likely to reflect the program's emphasis
in the short term on stabilization remedies rather than permanent remedies.
Underground Storage Tank Sites
EPA estimates that 95,000 to 155,000 UST sites (middle value, 125,000) will require cleanup
under the RCRA underground storage tank regulations over the next 30 years. This estimate
includes 35,000 already identified sites that have not yet been cleaned up plus 60,000-120,000
projected releases over a 10-year period
(6,000-12,000 per year). The 35,000-site
Although USTs account for 43% of all cleanup
sites, they account for only 7% of estimated
national cleanup costs. These sites are typically
among the smallest and least costly to remediate.
figure may understate the actual market
because it does not include all sites without
designated cleanup contractors. Some sites
reported as "cleanups initiated" actually have
not yet selected remediation technologies or
contractors. UST sites average an estimated 2.7 tanks per site, although the number varies widely
from one site to another. Although USTs account for 43 percent of sites to be cleaned up, they
account for only 7 percent of the above-estimated national cleanup costs. Tank sites are typically
the smallest and least costly to remediate, There may be some overlap with the estimated
number of state and private sites, which includes brownfield sites and UST sites.
The UST cleanup market could reach $12-19 billion, with a middle-value of $16 billion, or an
average of $125,000 per UST site. This estimate does not include costs related to replacing,
testing, or upgrading tanks, pipes, and related equipment. The availability of funds for UST
cleanups is somewhat less dependent on public appropriations. Most of the UST costs are paid
by property owners, state and local governments, and special trust funds, often based on
dedicated taxes, such as fuel taxes.
Department of Defense Sites
The DOD estimated that, as of September 2003, remedies had not been selected for 6,400 sites
on hundreds of installations and other locations that require remediation of contaminated
materials. Cleanups are being planned or are underway at another almost 2,700 sites, bringing
the total number of active DOD sites to about 9,000. These sites are distributed almost evenly
among the Air Force, Army, Navy, and formerly used defense sites (FUDS). DOD estimates that
all of these sites will be cleaned up by 2015. Of all DOD installations, including those where
remedial action has begun, 146 are on the NPL.
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facilities or economic development.
DOD estimates that the cost of completing all
the remaining remediation work at all DOD Federal and state Ancles have increased
. „ ° _„„, , .,, , , .
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Civilian Federal Agency Sites
As of April 1995, over 3,000 contaminated sites on 700 facilities, distributed among 17 non-
DOD and non-DOE federal agencies, were potentially in need of remediation. A facility may
contain one or more contaminated areas or "sites." Because investigations of many of these
facilities are not complete, the exact number of facilities and sites to be remediated has yet to be
determined. The Department of Interior (DOT), Department of Agriculture (USD A), and
National Aeronautics and Space Administration (NASA) together account for about 70 percent
of the civilian federal facilities reported to EPA as potentially needing remediation. Although
3,000 sites have been identified by these agencies, there are probably more that have not yet
been reported, including an estimated 8,000-31,000 abandoned mine sites, most of which are on
federal lands.
The $15-22 billion estimated cost for the cleanup of at least 3,000 civilian federal sites is based
on estimates from various officials and reports from DOT, USD A, and NASA, which combined
account for most civilian federal contaminated sites, and extrapolated to all federal agencies. The
level and timing of these expenditures will depend upon the availability of resources and
technologies. At current funding levels, about $100-200 million annually, it could take 100-200
years to clean up all these sites. The transfer of public properties to private use may require
agencies to reallocate resources to clean up properties designated for transfer.
State, Private Party, and Brownfield Sites
It is estimated that total annual expenditures for state and private cleanups has averaged about $1
billion and that about 5,000 cleanups are typically completed annually under all mandatory and
voluntary state programs. At this rate, 150,000 sites can be completed in 30 years, at a cost of
$30 billion. Estimates beyond 30 years are not provided in this report, although there are
probably several hundred thousand additional potentially contaminated sites that have not been
identified. Sites tend to become identified and studied when a health or safety hazard becomes
known, when a real estate transaction occurs, or when development proposals are being
evaluated. These activities trigger development studies and due diligence investigations. Thus,
increases in economic activity and redevelopment projects could lead to an increase in the
number of cleanups needed at any given time.
About half of state site cleanups in recent years have been under mandated state programs and
half have been under voluntary cleanup and brownfields programs. In addition, there may be
several hundred thousand additional brownfield sites yet to be identified. EPA defines
Brownfields as "real property, the expansion, redevelopment, or reuse of which may be
complicated by the presence or potential presence of a hazardous substance, pollutant or
contaminant." Although the definition can vary from state to state, they are usually abandoned,
idled, or under-used industrial and commercial facilities. EPA's investment in brownfields, more
than $700 million since 1995, has leveraged more than $5.1 billion in cleanup and
redevelopment funding and financed the assessment of more than 4,300 properties. The cleanup
of most of these sites will be the responsibility of the property owners and will probably be
conducted in conjunction with state voluntary cleanup programs. Over the past decade, interest
in the redevelopment of potentially contaminated sites has grown. In this situation, the
availability of funds will be on a site-specific basis. If states want to accelerate the pace of work,
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they will have to rely on non-budget sources of funds, such as private party actions, voluntary
cleanups, and cost recovery/cost sharing.
Manufactured Gas Plant (MGP) Sites
There is no separate remediation program for the characterization and remediation of MGP and
other coal tar sites, and no line item for this category of sites in the above exhibits. MGP sites
may be addressed under any of the remediation programs, such as Superfund, RCRA, or a state
environmental program, depending on the nature and extent of the contamination and other site-
specific factors. Because these sites may be managed under different remediation programs, the
estimates of the MGP market should not be added to those in the seven major market segments
above. Adding these estimates would be double-counting sites and costs, thereby overestimating
the scope of the market.
Before the United States had a network of natural gas pipelines and electricity, fuel for lighting,
heating, and cooking was manufactured from coal and petroleum at thousands of manufacturing
facilities across the country. As a result of these activities, hazardous materials are likely to be
present in the subsurface and groundwater at thousands of locations. While some of these sites,
especially those currently owned and operated by large gas and electric utility companies, are
being addressed, most of the former manufactured gas sites have not been identified.
It is estimated that from 1800 to the mid-1900s between 36,000 and 55,000 manufactured gas
plants and related coal tar sites were built in the United States. These sites varied in size from
less than one acre to approximately 200 acres. Because of the nature of the gas manufacturing
process and the practices at the time, almost all these plants released contaminated materials to
the environment. It is estimated that 30,000-45,000 of these sites that probably had releases of
hazardous substances have not been investigated and many may need to be cleaned up.
MGP cleanup costs have been documented to range from a few hundred thousand dollars to $86
million for a single site. Most tend to be in the $3-10 million dollar range. Should all 30,000-
45,000 sites be need cleanup, the estimated cost would be $26-128 billion.
Mining Sites
There are about 14,500 active coal, metal, and nonmetal mineral mines in the United States,
between 100,000 and 500,000 abandoned hard rock (metals and nonmetal minerals) mines on
private, state, and federal lands in the west, and approximately 13,000 abandoned coal mines,
mostly small and mid-sized, in the east. Many of these properties continue to threaten human
health and the environment because of the materials left behind and because mined-out areas are
exposed to the elements. Most of the mine sites are on land for which the federal government is
responsible, primarily DOI and USDA. Most of the mining budgets of these agencies are
directed to safety and water quality issues, and a smaller portion is available for site remediation.
Mining sites may be addressed under any of the remediation programs, such as Superfund,
RCRA, or a state environmental program, depending on the nature and extent of the
contamination and other site-specific factors. Therefore, the estimates of the mining-site market
should not be added to those of the seven major market segments. Adding these estimates would
be double-counting sites and, therefore, overestimating the scope of the market.
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There is a wide range of estimates and opinions on how many mining properties pose a serious
risk to the environment and are likely candidates for remediation. The most promising estimates
indicate that about 8,000-31,000 abandoned mine sites pose a significant risk to the environment
and human health. The estimated cost for hardrock mining sites alone is $20-54 billion.
Drycleaner Sites
Almost 16,000 active dry cleaner sites will probably need site investigation and remediation at an
estimated cost of $6 billion. Cleanup costs are estimated to average $403,000 per site and range
from $19,000 to over $3 million. About 28 percent of the costs are for site characterization.
There may be 9,000 to 90,000 sites that were
formerly occupied by drycleaners and that are
likely to have released drycleaning chemicals to
the environment.
These estimates do not include cleanup work
that may be needed at a potential 9,000-90,000
"inactive" sites. Inactive sites are properties
that do not currently have a drycleaning
operation, but did have one in the past. Older
drycleaners used more cleaning compounds per
garment and tended to have more releases of chemicals to the environment than newer ones.
Over the past several decades, the amount of perchloroethylene used by the industry has
decreased more than 80 percent. Less than 10 percent of drycleaners still use petroleum solvents.
Site Characterization
Although the type and amount of site characterization work needed varies widely from site to
site, all potential hazardous waste sites require some sort of site investigation. Despite the
variability, it is useful to estimate an approximation of the number of sites that will need
sampling and analysis work (see box). The phases of site assessment shown in the box are
similar to, but not precisely those, used in American Society for Testing Materials (ASTM)
standards. Approximations were made to align phases of RCRA, Superfund and other programs.
Estimated Sampling and Analysis
Needs Over 30 Years (Number of Sites)
The cost of this work is estimated based on the
ratio of RI/FS cost in the Superfund program to
total cleanup cost. Remedial Investigation/
Feasibility Studies (RI/FS) have accounted for
about 10 percent of total Superfund site
expenditures and 16 percent for smaller sites.
Applying these averages to the total site
remediation market, and assuming historical
site characterization practices continue, about
$21 billion will be needed for site
characterization work over the next 30 years.
However, given the growing use of advanced
site characterization approaches-including
field analytical technologies, systematic planning, and dynamic work plans-site managers may
allocate greater proportions of their budgets for site characterization in the future. Better site
characterization can reduce the overall cost and improve the effectiveness of cleanups.
Phase I
Phase II
Phase III
Remedial Action
O&M and Long-Term
Remedial Action
1.2 million
285,000
392,000
508,000
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Sampling and analysis technologies are used during all phases of site work, except Phase I site
assessments (estimated market of almost 12 million assessments over the next 30 years). The
sampling and analysis required during remedial actions varies widely from one site to another.
Remedial actions often require confirmation sampling and sometimes major additional site
characterization. A significant amount of sampling and analysis is also needed during O&M and
long-term remediation of groundwater and surface water. Thus the 508,000 site estimate is an
upper-bound estimate for sites that will need continued sampling and analysis during O&M and,
at a number of sites, long-term remediation.
DNAPLs
This report provides a general indication of the number of sites likely to have a DNAPL
problem. It is estimated that 29-44 percent of NPL sites are likely to have free-phase liquid or
residual DNAPLs present in the subsurface, or an average of 37 percent. The estimates are 28
percent for RCRA Corrective Action and state sites, and 30 percent for DOD and DOE sites.
Applying these percentages, it is estimated that these four program areas have a combined
48,000 sites with a medium to high potential to have a DNAPL problem. For the other market
segments, the data on the types of compounds used or constituents of releases were too sparse to
develop an estimate.
Any estimate of the value of the DNAPL cleanup work needed is hampered by the extremely
wide range of potential site conditions and the paucity of program-wide data on costs that pertain
to specific DNAPL remediations. However, an indication of the level of costs is provided by
studies of pump-and-treat (P&T) costs, a major expense in DNAPL cleanups. A 2001 EPA
study found that the average annual O&M costs of pump-and-treat systems at 79 fund-financed
sites is approximately $570,000, and the median is $350,000. This difference is due to a small
number of systems with relatively high costs that raise the average. The periods of operation of
these systems as well as the costs vary widely from site to site. The average pump-and-treat
system in the EPA study operated for 18 years, for an average cost of $10 million. Pump-and-
treat systems at some sites with DNAPLs may need to operate for considerably longer periods.
1.5 Hazardous Waste Site Characteristics
The selection of remedies at contaminated sites depends largely on the types of media and
contaminants present. This section describes the types of contaminants and media that are to be
remediated in the various market segments.
The data used to develop these estimates vary widely among the market segments. The
Superfund (NPL) data are available from the Records of Decision (RODs) for over 1,100 sites.
The characteristics of these sites are assumed to be representative of all NPL sites, including
those needing further remediation. The DOD media and contaminant data are based on
information from over 6,000 sites to be remediated as of September 2001. The RCRA estimates
are based on data from fewer than 300 of the estimated 3,800 sites to be remediated. Although
the DOE estimates are based on data from over 100 installations, the data do not include
information from all 10,500 sites at these installations and other properties. The DOE and RCRA
data are from data collected in the early and mid-1990s.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
More than three-fourths of sites have
contaminated soil or groundwater, or both.
Contaminated sediment, sludge, and surface
water also are present, but at fewer sites.
1.5.1 Contaminated Media
Groundwater and soil are the most prevalent
contaminated media. In addition, large
quantities of other contaminated material,
such as sediments, landfill waste, and sludge,
are present at many sites. Exhibit 1-3 shows
the most common contaminated media for
each of four market segments. More than
three-quarters of NPL, RCRA, DOD, and DOE sites have contaminated soil or groundwater, or
both. Contaminated sediment, sludge, and surface water also are present, but at fewer sites. Soil
and groundwater also are a primary concern for UST sites, although comprehensive program-
wide data are not available.
Exhibit 1-3. Media to be Remediated
Percent of Sites
Remediation Program Groundwater Soil Sediment
NPL Sites
RCRA Corrective Action Sites
DOD Sites
DOE Sites
83%
82%
63%
72%
78%
61%
77%
72%
32%
6%
18%
72%
Notes:
• 11% of NPL sites contain contaminated sludge; 11% of the surveyed RCRA sites contain contaminated sludge
and 10% contain contaminated surface water; 9% of DOE sites contain contaminated surface water, and about
half of the DOE installations contain contaminated rubble and debris.
• The DOE soil percentages also contain sediment and sludge.
1.5.2 Contaminants of Concern
Many contamination problems and technology needs are similar across the major remediation
programs. For example, solvents, petroleum products, and metals are common to most programs.
Some markets also have more specialized needs arising from wastes that are unique to a
particular industrial practice. For example,
DOE has a need for technologies to
characterize, treat, and dispose of mixed waste;
remediate radioactive tank waste; stabilize
landfills; and deactivate facilities. DOD is
concerned with remediating soil contaminated
with explosives, unexploded ordnance, and
perchlorate.
VOCs, the most frequently occurring
contaminant type, are present at more than
two-thirds of Superfund, RCRA, and DOD sites,
and almost half of the DOE installations. VOCs
(BTEX) also are the primary contaminants at
UST sites.
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Almost all of the market sectors have
substantial numbers of sites with metals and
VOCs.
Exhibit 1-4 shows the frequency of
occurrence of the most prevalent
contaminant groups. VOCs, the most
frequently occurring contaminant type, are
present at more than two-thirds of
Superfund, RCRA, and DOD sites, and
almost half of the DOE sites.
VOCs, primarily in the form of BTEX (benzene, toluene, ethylbenzene, and xylenes) also are
primary contaminants at UST sites. Many sites to be remediated by civilian federal agencies and
states also are believed to contain VOCs, but only sparse data for these programs are available.
Metals are prevalent in almost all of the major market sectors. Metals, not including radioactive
metals, are present at about three-quarters of the Superfund and DOD sites, and about half of the
RCRA and DOE sites. They also are likely to be found in the other market segments. Of the 12
contaminants most frequently found at Superfund and DOD sites, more than half are metals,
primarily arsenic, chromium, lead, zinc, nickel, and cadmium.
Exhibit 1-4. Contaminant Groups to be Remediated
Percent of Sites
Remediation Program
VOCs Metals SVOCs
NPL Sites
RCRA Corrective Action Sites
DOD Sites
DOE Sites
78%
67%
64%
38%
77%
46%
72%
55%
71%
32%
57%
38%
Notes:
• DOE figures for VOCs and SVOCs are combined. 90% of DOE sites contain radioactive elements.
• About 1 9% of DOD sites yet to be investigated and/or cleaned up may contain unexploded ordnance or waste
military munitions.
The contamination characteristics of each market segment are discussed below.
For NPL sites, VOCs is the most common contaminant group remediated, followed by metals,
and SVOCs. Most sites are complex, requiring remediation for more than one of these
contaminant groups: 24 percent of the sites contain two contaminant groups and 52 percent
contain all three. These contaminants are not necessarily in the same contaminated medium.
Halogenated VOCs are by far the most common subgroup of organic contaminants, followed by
BTEX, non-halogenated VOCs, polynuclear aromatic hydrocarbons (PAHs), non-halogenated
SVOCs, phenols, pesticides, and polychlorinated biphenyls (PCBs). The most common metal
cleaned up at NPL sites is arsenic, followed by chromium and lead. NPL data are based on
contaminants for which remedies have been selected in the past.
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The most common contaminant groups at RCRA sites are halogenated VOCs, found at 60
percent of sites; metals, found at 46 percent of sites; and non-halogenated VOCs, found at 32
percent of sites. These estimates are based on two studies in the early 1990s that used data from
fewer than nine percent of all the likely corrective action projects.
Approximately 96 percent of USTs contain petroleum products including used oil and less than
four percent contain hazardous substances. For USTs containing petroleum products, gasoline
accounts for 66 percent and diesel fuel for 21 percent. The most likely constituents of concern in
these products are BTEX and SVOCs, such as PAHs, creosols, and phenols.
Based on information on over 6,000 DOD
• . ., . ,, ,. .• r-c^u Hundreds of DOD sites contain explosives and
sites that needed remediation as or September
one percent contain radioactive contaminants.
In addition, information from some installations
indicates that the presence of unexploded
ordnance may be significantly greater than
these percentages indicate.
2001, metals are found at 72 percent of the
sites, followed by VOCs at 64 percent, and
SVOCs at 57 percent. Although many similar
contaminants also are frequently found at
non-defense related sites, some DOD sites
contain contaminants that present unique
problems for selecting remediation
approaches. For example, hundreds of DOD sites with available data contain explosives, and
about one percent contain radioactive contaminants.
Radioactive contaminants are found at 90 percent of DOE installations and include uranium,
tritium, thorium, and plutonium. The most frequently present non-radioactive metals, which are
found at 55 percent of the installations, include lead, beryllium, mercury, arsenic, and chromium.
Organic chemicals are found at 38 percent of DOE installations and include PCBs, hydrocarbons
from fuel and other petroleum products, and TCE. Mixed waste, containing radioactive and
hazardous contaminants, also is a problem at
_,,.,. , . , , __ , many installations. The available data do not
Radioactive contaminants are found at 90 I • j- -r- -c • 11
indicate if a specific contaminant has been
percent of the DOE installations and non-
radioactive metals are found at 55 percent.
identified at only one site or at more than one
site on an installation.
Waste at civilian federal agency and state sites is typical of industrial facilities and include
organic chemicals, metals, and solvents. However, no national compilation of the specific
contaminants at these sites is available.
Based on a limited data from samples of state sites, the most prevalent pollutant categories are
organic chemicals, especially VOCs, SVOCs (PAHs and PCBs), solvents, and petroleum
products.
1.6 Cleanup Program Status and Factors Affecting Demand
The demand for remediation services is driven largely by federal and state requirements, public
and private expenditures, and activity in the real estate and property development industries.
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Changes in these factors will affect each of the market segments in a different way, since each
market has its own priorities and operating procedures. Thus, successful planning for technology
development and marketing of remediation services should include consideration of the program
structure, requirements, and site characteristics of the specific market sectors as well as the
shifting requirements and budgets. The most prevalent factors that could alter the scope of the
cleanup effort, as well as the technologies to be used in each market, are described below.
1.6.1 Superfund Sites
The Superfund program is the federal program to clean up releases of hazardous substances at
abandoned or uncontrolled hazardous waste sites. As of September 30, 2003, EPA had listed
1,518 sites on the NPL, and proposed another 54. Of these, 274 sites were deleted from the list or
referred for response to another authority, leaving a total of 1,244 final NPL sites. As additional
sites are studied and ranked, they may be added to the NPL. The scope of the cleanup effort, as
well as the technologies to be used in the future, will be influenced by the following factors:
• Between 1993 and 2003, EPA listed 305 sites, or an average of 28 sites per year. This report
assumes that future listings will average 28 sites per year from 2004 to 2013. At this rate,
280 additional sites would be listed by 2013. If more "NPL-eligible" sites are found and
evaluated, they may be addressed by other programs, such as RCRA Corrective Action or a
state program, or may continue to await evaluation and/or cleanup. Because the decision on
whether to list a site is complex, depending on many variables and input from many
stakeholders, there is some uncertainty inherent in any such prediction.
• Based on information from two GAO reports (1998 and 1999) there appears to be a
sufficient supply of Superfund-eligible sites and potentially-eligible sites in EPA's
CERCLIS database to supply the aforementioned 280 sites. GAO identified 1,800 sites that
have a Hazardous Ranking System (HRS) score of at least 28.5, which make them eligible
for consideration for listing on the NPL and estimated that another 3,800 sites in CERCLIS
are in earlier stages of the Superfund pipeline. Evaluations of the later sites have not
progressed to the point where their NPL eligibility could be determined. Estimates of state
and federal program managers have varied widely regarding the percentage of these sites
that will ultimately be listed. Thus, we can only conclude that some portion of the 5,600
(1,800 + 3,800) sites awaiting a listing decision will eventually be listed on the NPL. In
addition, from time to time, new site discoveries lead to new proposed listings. Thus the
potential supply is not inconsistent with the 280-site assumption.
• Current resources appropriated to the program may be insufficient to fully implement the
program, as defined above—to continue work on currently listed sites, address other
CERCLA programs, such as removals, and begin the process of listing, evaluating, and
cleaning up additional sites. The FY 2004 budget request to manage the Superfund program
is about $1.4 billion. According to the 2001 RFF study, Superfund faces an average annual
budget shortfall of approximately $100-200 million over a 10-year period. Depending on
how the budget is allocated, this shortfall may or may not affect the sites where remedies
have not yet been selected (the focus of this report). To address a number of long-term
Superfund issues, EPA is working with the National Advisory Council for Environmental
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Policy and Technology (NACEPT) to develop consensus on the issues and identify the
future direction of the Superfund Program. In April 2004, The Superfund Subcommittee
submitted its final report to the full NACEPT committee.
• State and PRP funding for Superfund site cleanups may fluctuate in the future. Many states
are facing serious budget shortfalls in 2003 and 2004 and many PRPs face difficult business
conditions. The PRPs have historically paid for 70 percent of Superfund site remediations.
For Superfund remedial actions, the states contribute 50 percent of the construction and
operation costs where they own the site and significant amounts of operation and
maintenance (O&M) costs for certain Superfund actions in their state. In addition, as more
Fund-lead NPL sites complete 10 years of long-term remedial actions, states will become
responsible for continuing the LTRA work.
• In planning and implementing cleanups, EPA coordinates extensively with various EPA
offices, PRPs, state and local governments, planning authorities, and local communities and
developers. These requirements may influence the sequence of work, types of cleanup
technologies selected for a site, and the number of sites to be listed on the NPL in the future.
1.6.2 RCRA Corrective Action Sites
The cleanup of RCRA Corrective Action sites is influenced by the regulatory and site-
management refinements that EPA and the states have been building into the cleanup process,
federal funding of state oversight, and improved field technologies which can lead to better site
characterization, improved remedy design, lower cleanup costs, and better and faster cleanups.
• The RCRA Cleanup Baseline sites that are striving to meet 2005 interim Government
Performance and Results Act (GPRA) goals represent the most immediate actions to be
taken at RCRA sites. While these sites represent the readily identified, near-term cleanup
market, many other RCRA sites with less immediate human health concerns will also need
cleanup.
• Revisions to the Subtitle C requirement for cleaning up some hazardous waste implemented
over the past decade are likely to encourage treatment and removal as compared to leaving
waste in place.
• Refinements in site characterization technologies during the last decade have begun to
decrease site-assessment costs, improve data quality and remedy design, and expand the
applicability of less traditional remedies.
• The pace of the cleanups is affected by the availability of funds to pay for state and federal
oversight. Many states are facing budget deficits in FY 2003 and 2004, and staffing levels
and budgets for hazardous waste remediation in most states have not increased in about a
decade.
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• Land development trends are also likely to affect the pace and nature of RCRA cleanups.
Redevelopment or transfer of commercial and industrial properties usually require site
assessments and, if necessary, remediation. The 2002 brownfields law, (The Small Business
Liability Relief and Brownfields Revitalization Act—P.L. 107-118), the Superfund
Redevelopment Program, and the RCRA Brownfields Initiative are encouraging the reuse of
former industrial and other properties. These programs have implemented policy changes
and demonstrated many approaches that foster the cleanup and redevelopment of
contaminated properties, including a number where waste has been left on site.
1.6.3 Underground Storage Tank Sites
The demand for remediation services at contaminated UST sites primarily will be influenced by
federal and state requirements, and the number of releases occurring at old and new tanks. The
timing of these cleanups will be influenced by the availability of state and federal funds
for site assessment and cleanup and the pace of economic development.
• Since 1998, there has been a more than 50 percent drop in the number of new releases
reported. As more tanks come into compliance with the new requirements, the number of
new releases is expected to continue to drop.
• Even if the current backlog of all known sites is eliminated, there will always be additional
releases at some sites in the future. Many older tanks still exist, many tanks are not in full
compliance, some new or upgraded tanks leak due to failure of components or spills, many
tanks are not operated and maintained properly, and over half of the states are not inspecting
all of their tanks at the minimum recommended rate. The GAO has estimated that 76,000
active regulated tanks may not be upgraded, which implies that there is a backlog of
potentially contaminated sites that may
be discovered over a period of time as
Although the number of releases has declined
significantly, tanks continue to leak, because
older tanks still exist, many tanks are not in full
compliance with upgrade requirements, and
many are not operated properly.
they are replaced or removed.
• The pace of the cleanups is affected by
the availability of funds.
Appropriations from one source of
funds, the federal Leaking
Underground Storage Tank Fund
(LUST Trust Fund) have been about $70-80 million annually. At the end of 2003, the fund
had a balance of $2.1 billion. The gasoline tax that supports the fund is scheduled to expire
in 2005. The other two major funding sources-state tank trust funds and direct
appropriations, and property owners or responsible parties-are stable.
• The 2002 brownfields law and EPA's USTfields initiative may lead to an increase in the
number of UST sites identified as needing cleanup as well as the pace of cleanups.
• Concerns about methyl tertiary-butyl ether (MTBE) contamination may influence the
amount and timing of UST cleanups in some states. Some states have passed legislation
addressing MTBE. These activities will lead to more site evaluations and/or cleanups.
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1.6.4 Department of Defense Sites
DOD installations typically have multiple contaminated sites regulated by either CERCLA,
RCRA, state laws, federal statutes that mandate base realignments and closings, or a
combination of these. The following factors strongly influence the nature of the cleanup needed.
• The pace of remediation is subject to change in response to budgetary and political
developments. The FY 2004 planned DOD budget for restoration is almost $1.7 billion. Of
these funds, approximately $328 million, or 20 percent, is allocated to closing (BRAC) sites.
An additional BRAC round is scheduled
for 2005.
The proportion of the environmental
restoration budget allocated to cleanup
The DOD cleanup budget has remained
steady, and is expected to continue at its
current level. The proportion of the cleanup
budget going to the cleanup of facilities
. .. • . ,, ,. JT7TTT-VC scheduled to close has fluctuated from 20 to
at active installations and FUDS 37% befween 2QQQ and
continues to increase (69% in FY 2003)
relative to study and investigation
funding.
• Although DOD believes that most sites have been located, new sites continue to be
identified. The recently established munitions program has led to an increased the number of
new sites. Between FY 2001 and FY 2003, DOD identified approximately 1,700 additional
sites. Of these, about 1,000 are munitions program sites.
• In determining the priorities for funding at all sites, DOD generally addresses the worst sites
first. As of the end of FY 2002, DOD has reduced the number of high relative risk sites at
active installations and FUDS properties by 58 percent. DOD anticipates achieving remedy
in place or remedy completes at all high relative-risk sites by 2007. In implementing its
priorities, DOD may assign varying levels of priority to different sites on a given
installation. This policy may lead to acceleration of some projects at a given installation
while other projects at the same installation are postponed.
• The rate of base closures and realignments will affect the sequencing of cleanup for all
sites. New schedules will need to be generated for the FY 2005 round of closures.
1.6.5 Department of Energy Sites
DOE is responsible for cleaning up installations and other locations that have been used for
nuclear weapons research, development, and production for over five decades. The following
policy, regulatory, economic, and technical factors will significantly affect the scope, schedule,
and cost of DOE's remediation effort.
• Based upon a 2002 critical assessment of its program—the Top-to-Bottom Review-DOE
began a major initiative to accelerate cleanup of its installations and other locations by at
least 30 years, prioritize risks, improve its contracting practices, and reduce program costs.
DOE expects this initiative to profoundly affect the scope and scheduling of its cleanups.
Chapter 1: Introduction and Summary Page 1-20
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Under the initiative, DOE is promoting a
npw "rkk hflQpH" Hpaniin stratpov that ln 2°°2' DOE began 3 "^Jor initiative to
new risk-based cleanup strategy that acceierate deanup Ofits sites by at teast 30
years, prioritize risks, improve contracting
practices, and reduce program costs.
would assist in prioritizing risk—and
thereby prioritize cleanups—among the
various sites on a DOE-wide basis. The
initiative also has the potential to
increase the use of remediation
approaches that leave more waste on site, compared to treatment and other active
remediation approaches than previously planned, thereby reducing remediation costs for
some projects.
Cleanup schedules are heavily dependent upon the availability of funds. DOE's estimate that
it can complete legacy waste cleanup at all DOE properties by 2035 could be lengthened or
shortened, depending on the funds appropriated by Congress.
At many sites it is difficult to forecast the extent of cleanup work needed, because remedy
decisions usually require balancing potential land uses with the alternative cleanup options
and long-term stewardship approaches, and collaboration with many stakeholders.
DOE estimates that long-term stewardship will
be needed at up to 129 installations and has
established the Office of Legacy Management
to address this need.
• Groundwater remediation is expected to
continue at many sites, and long-term
stewardship will be needed at 129 DOE
installations. The Department has
established the Office of Legacy
Management to address this need.
• There is a potential market for cleanup at sites for which there is no current feasible
remediation approach. The costs for these activities are excluded from the above cost
estimates, though applicable stewardship and monitoring costs for these sites are included.
For example, costs are excluded for the nuclear explosion test grounds at the Nevada Test
Site; large surface water bodies, including the Clinch and Columbia rivers; and most
contaminated groundwater for which, even with treatment, future use will remain restricted.
These factors indicate that, despite significant progress in establishing the scope of work for
DOE's cleanup program, there are uncertainties inherent in the remediation of DOE properties.
The DOE cleanup market estimates rely on several critical assumptions, which makes them
particularly sensitive to budget fluctuations, cleanup standards, and further site investigations
1.6.6 Civilian Federal Agency Sites
The responsibility to clean up non-DOD and non-DOE contaminated sites falls to 17 federal
agencies. Because these programs are more fragmented throughout the government, detailed site
characteristics data are limited and more site investigation is needed to fully identify cleanup
needs. Three primary factors influence the market for remediation of civilian federal agency
sites.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
• Lack of funds constrains federal agency site remediation programs. Based on current and
recent budgets, it would take 100 to 200 years to clean up all of the identified sites, under
current environmental regulations. The limited resources available for site cleanups provide
these agencies with incentives to prioritize efforts; encourage and eliminate barriers to the
use of less costly innovative technologies; use more cost-effective contracting procedures;
streamline management structures and processes; and seek cost recovery from other parties.
• Changes in federal and state environmental regulations and standards often impact the scope
and pace of cleanup required at civilian federal facilities.
• The transfer of public properties to private use may require agencies to reallocate resources
for cleaning up properties designated for transfer.
• Civilian federal agencies may be responsible for cleaning up between 8,000 and 31,000
abandoned mine sites, most of which have not been evaluated. The potential cost for this
effort is not included in the discussion of the civilian agency budgets above.
1.6.7 State and Private Party Sites
Sites not owned by federal agencies that require cleanup, but cannot be addressed under the
federal cleanup programs, are addressed by state cleanup programs. The cleanup of these sites
are generally financed by the states or private parties. To manage the cleanup of contaminated
sites, most states have created two types of programs—mandated cleanup programs and
voluntary cleanup and brownfield programs. The mandated programs, which are roughly
patterned after the federal Superfund
program, generally include enforcement
authority and state funds to finance the
remediation of abandoned waste sites. The
extent and pace of these programs are
, • ,, , r- -1111 cleanups and develop brownfield properties.
determined by states financial and legal
commitment to environmental restoration.
The financial and legal commitments to site
restoration vary from state to state. Almost all
states have programs to encourage voluntary
Voluntary cleanup programs (VCPs) and brownfield programs encourage private parties to
voluntarily clean up sites rather than expend state resources on enforcement actions or
remediations. Fifty states and territories have VCPs and 31 have established brownfield
programs that are separate from their VCPs. It is often difficult to distinguish between a
brownfield program and a VCP. Many brownfield sites are addressed by volunteers.
• The state market for remediation services is largely dependent upon the commitment and
ability of states and private companies to establish and manage hazardous waste programs,
to finance cleanups, and to encourage or compel responsible parties to clean up sites.
Funding and staff levels of state cleanup programs have remained steady for about a decade.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
• The Brownfields Revitalization Act is expected to expand the number of sites to be assessed
and/or cleaned up. The law greatly mitigates the potential liability of innocent (not
responsible for pollution) property owners, reduces financial uncertainties for investors and
property owners, and directly funds various projects and programs, which serve as
examples, case histories, and lessons learned for other sites.
• Over approximately the past decade, the U.S. capacity to address brownfields has grown
enormously. Today, there is a growing cadre of developers, planners, consultants,
engineering and construction firms, attorneys, and public officials with the expertise to
evaluate, clean up, and revitalize brownfield properties. The growing acceptance of the
practicability of cleaning up and revitalizing brownfield sites has the potential for enlarging
the market for site characterization and cleanup services.
• The pace of development in a region will influence the number of brownfield and voluntary
sites that need to be evaluated. It is estimated that only 10-15 percent, of the estimated one-
half to one million brownfield sites, have been identified. Most of the remaining sites have
not been identified, primarily because they are vacant or underused and the owners do not
wish to become involved in the complicated and costly world of remediation.
• The growing popularity of smart growth policies are likely to advance the demand for the
state and brownfield cleanups, since infill development and the preservation of greenfields
are primary components of smart growth programs.
• Forty-one states have long-term stewardship programs for one or more of their cleanup
programs. These programs are important because of the widespread use of remedies that
allow hazardous substances to remain on site.
1.6.8 Manufactured Gas Plant Sites
Most of the cleanups at MGP sites have involved those owned or operated by utilities. Because
the original commercial MGPs were in good locations, close to population or commercial
centers, the utilities that owned them simply reused the property for modern facilities, such as
natural gas or electricity distribution. Thus, there is a known history and chain of ownership.
Many utilities are aware of the potential environmental problems associated with their properties
and are conducting monitoring or cleanups under RCRA or a state program. However, the
location and disposition of many of the other types of MGP sites is less defined.
Former manufactured gas plants, or their waste products, may be discovered over many years, in
conjunction with other cleanup programs, such as RCRA, Superfund, or Brownfields. There is
no dedicated effort to search for them.
Site investigators and remediation planners could benefit from knowledge of the history and
operations of this defunct industry. When combined with the growing body of literature on site
characterization and remediation techniques, they would be able to develop the most effective
and practicable cleanups.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
1.6.9 Mining Sites
The following primary factors influence the market for remediation of mine lands.
• The reclamation budgets of the federal and state agencies that manage mine lands are small
in comparison to the magnitude of the abandoned mine waste problem.
• Growing markets for first or second homes and recreational activities in previously sparsely-
populated mining areas may foster increased demand for cleanup of some sites or
restrictions on park use.
• The transfer of properties in mining areas where complete control of the source of the
pollution has not been achieved may require institutional controls. Thus, there is a growing
need for methods to ensure compliance with institutional controls.
• A number of the over 14,000 active and inactive mine sites that are not abandoned also may
require remediation. Releases of contaminants into the environment can result from
inadequately designed facilities such as tailings dams, accidents, leaks and spills, or failure
to properly operate a facility. Thus some portion of these sites are likely to require
remediation of soil, groundwater, and/or surface water, among other things.
• The passage of Good Samaritan legislation would probably encourage more state and local
governments to undertake some remediation.
1.6.10 Drycleaner Sites
The use of dry cleaning solvents has been decreasing, primarily because the industry has been
switching to new more efficient machines and, to a lesser extent, the use of alternative solvents.
Nevertheless, there remain thousands of sites from previous operations.
• The declining use of perchloroethylene by dry cleaners will mean fewer discharges to the
environment in the future.
• For the 12 states with dedicated dry cleaner remediation funds, the money available to the
funds appears to be stable.
• For other states, general availability of state cleanup funds, will be a critical factor for many
cleanups. Drycleaners have average revenues of about $250,000; remediation costs can run
hundreds of thousands of dollars, and several have cost over a million. Even a moderate-cost
cleanup can amount to several years of profit for the average dry cleaner.
• In addition to active drycleaner facilities, many inactive facilities (properties that currently
do not have a drycleaner, but did in the past) have not yet been discovered. Many of these
facilities may have released hazardous substances to the environment that resulted in
contaminated soil and groundwater. Although data on these facilities are sparse, it is
estimated that there are between 9,000 and 90,000 sites.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
• The level of assessment and cleanup is directly related to the cleanup standards adopted by
the states. Many states have adopted risk-based cleanup standards for soil and groundwater.
1.6.11 Site Characterization
Although it averages only about 10 percent of cleanup costs, site characterization is a major
determinant of the ultimate effectiveness, schedule, and cost of remedial actions. The following
factors are driving the demand for sampling and analysis technologies:
• The use of field analytical technologies is expected to increase relative to traditional
approaches. There is a growing body of evidence that indicates that substantial cost and time
savings and better site characterizations are usually achieved with the use of field
technologies, especially when combined with dynamic work plans and systematic planning.
Field technologies can also foster significant savings in dollars and time during remedial
action, because they provide accurate site characterization data and allow site crews to adapt
to new information on a daily basis.
• The demand for revitalization of brownfields and UST sites implies a requirement to
conduct many Phase I and Phase II type site assessments. A smaller percentage will require
further site investigation and cleanup.
• The demand for due diligence by property purchasers, developers, and lenders also implies a
significant demand for Phase I and, possibly, Phase II assessments.
• The demand to redevelop sites provides a powerful economic incentive for faster site
assessments and cleanups. Developers and investors usually operate under serious time
constraints to implement projects. The combination of field analytics, dynamic work plans,
and systematic planning may allow development to proceed more expeditiously.
Based on these factors, it is expected that the use of newer characterization approaches will grow
relative to older ones. To the extent that improved site characterizations reduce overall
remediation costs, they would allow more sites to be cleaned up. Improved cost-effectiveness of
cleanups is especially important, given the finite resources available for most cleanup programs.
1.6.12 DNAPLs
The CERCLA remedy selection process and NCP include a preference for remedies that provide
"permanence and treatment." to the extent practicable. However, the ability to economically
delineate the DNAPL source zones varies from site to site. Similarly, the ability to show that
source reduction will dramatically reduce long-term costs of containment also varies from one
site to another. Thus, the proportion of DNAPL sites that will be subject to containment and the
number that will undergo source zone treatment is uncertain. A number of factors may affect
decisions that attempt to strike a balance between remediating a source zone and long-term pump
and treat at DNAPL sites, and hence the potential demand for remediation services. These
factors, which are not mutually exclusive, include:
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
• Potential contamination at uncharacterized or undiscovered sites, such as MGP sites, former
drycleaners sites, or other types of sites, may lead to continued additions to the number of
sites that need to be assessed and/or cleaned up.
• A number of states have recognized the need to consider newer site characterization and
remediation technologies prior to granting ARAR waivers for technical impracticability.
• Reuse considerations at a site may drive the need for faster cleanups. Developers may need
the properties that might otherwise be encumbered by pump-and-treat equipment or
institutional controls related to the contamination and remedy..
• Continued advances in site characterization techniques that allow a better definition of the
source zone, which is especially needed for deep sources, offer the potential to reduce
remediation costs. Such advances may be enhanced when coupled with more effective use
of innovative in-situ technologies for the removal or destruction of DNAPL sources, and
may contribute to increased use of treatment versus long-term containment remedies.
1.7 Implications for Site Characterization and Cleanup
Although substantial progress has been made over the past quarter century, a considerable
amount of cleanup work, which will take 30 to 35 years to complete, remains. As with most
cleanups requiring technically complex solutions and coordination of multiple stakeholders, the
work load will fluctuate from year to year. Most of the costs will be borne by private and public
owners of contaminated properties and responsible parties. This work includes the cleanup of a
number of very large, complex sites as well as the assessment and, when necessary, cleanup of
many small sites. The needed work represents a significant opportunity for the continued
development and implementation of site characterization and cleanup approaches and
technologies that can result in better, cheaper, and faster cleanups, as well as technologies that
enable us to better address challenging contamination problems such characterizing NAPLs in
the subsurface.
Technical solutions to a particular contaminated site problem are generally similar, regardless of
the regulatory program under which they are implemented. While individual markets may not
support certain important investment decisions, the aggregate demand across all markets might
justify the up-front investment in a technology that ultimately drives down the cost of moving
contaminated sites into productive use. By recognizing this potential for economies of scale in
cleanup technology markets, the information in this report contributes to better investment
decisions across all market segments.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Chapter 2
Remediation Technologies Used
At National Priorities List Sites
The U.S. faces significant technological challenges as it seeks the most efficient and effective
approaches to clean up its contaminated waste sites. This chapter examines trends in the use of
remediation technologies at hazardous waste cleanup sites covered under the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), commonly
known as Superfund.
Although Superfund sites are a small percentage of all contaminated sites, the program has been
in the forefront in selecting and applying new site characterization and remediation technologies
that are less costly and more effective. Developments in the Superfund sector tend to influence
technology selection in other market segments. Many of the remediation projects in recent years
involve technologies that were not even
available when the law was
reauthorized. The development of new
technologies has been driven, in part,
by a preference for "permanence and
treatment" in the 1986 reauthorized law
and the resulting quest for more cost-
effective processes.
2.1 Definitions of
Remediation Technologies
The text box summarizes the major
types of remedies used at hazardous
waste sites. Most Superfund records of
decision (RODs) for remedial action
address the source of contamination,
such a soil, sediment, sludge, and solid-
matrix wastes. Such "source control"
RODs select "source control
technologies." Groundwater remedial
actions, also known as "non-source
control actions," may be a component
of a "source control" ROD and the
treatment technologies chosen for
groundwater remediation are referred
to as "groundwater technologies."
Superfund Remedy Types
Source Control Remedy Types
• Source Control Treatment: Treatment of any source in situ
or ex situ, including technologies such as chemical
treatment and thermal desorption.
• Sou rce Control Contai n ment: Co nta i n ment of a
contaminant source using caps, liners, covers, on-site and
off-site landfilling, or other means.
• Other Source Control; Other forms of remediation of a
contaminant source, such as institutional controls,
monitoring, and population relocation.
Groundwater Remedy Types
• Pump and treat: Extraction of groundwater from an aquifer
and treatment above ground. Treatment can include
technologies such as air stripping and ion exchange.
• In-Situ Treatment: Treatment of groundwater in place
without extracting it from an aquifer, using technologies such
as air sparging and permeable reactive barriers.
• Monitored Natural Attenuation: The reliance on natural
attenuation processes, within the context of a carefully
controlled and monitored approach to site cleanup to
achieve site-specific remediation objectives within a time
frame that is reasonable compared to other alternatives.
• Groundwater Containment: Containment of groundwater
through the use of a vertical engineered impermeable
subsurface barrier, or a hydraulic barrier created by
pumping.
• Other Groundwater Remedies: Groundwater remedies
that do not fall into the above categories, such as water-use
restrictions and the provision of alternative water supplies.
Chapter 2: Remediation Technologies
Page 2-1
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
The term "treatment technology" means any unit operation or series of unit operations that alters
the composition of a hazardous substance, pollutant or contaminant through chemical, biological,
or physical means to reduce the toxicity, mobility, or volume of the contaminated materials
being treated. Treatment technologies are an alternative to land disposal of hazardous wastes
without treatment (see "definitions" at 40 CFR 300.5, 55 Federal Register 8819, March 8, 1990).
Established technologies are those for which cost and performance information is readily
available. The most frequently used established technologies are on- and off-site incineration,
solidification/stabilization (S/S), soil vapor extraction (SVE), thermal desorption, and pump-and-
treat (P&T) technologies for groundwater. Technologies used to treat groundwater after it has
been pumped to the surface usually involve traditional water treatment approaches, which are
considered established technologies.
Innovative treatment technologies are alternative treatment technologies with a limited number
of field applications and limited data on cost and performance. Often, these technologies are
established in other fields, such as chemical manufacturing or hazardous waste treatment. In
such cases, it is the application of a technology or process at a waste site (to soil, sediments,
sludge, and solid-matrix waste, or groundwater) that is innovative, not the technology itself.
Both innovative and established technologies are grouped as source control treatment or in-situ
groundwater treatment technologies on the basis of the type of application most commonly
associated with the technology. Some technologies can be used for both source control and in-
situ groundwater treatment.
Exhibit 2-1 lists 17 types of source control (primarily soil) technologies, 10 types of in-situ
groundwater treatment technologies, eight types of groundwater P&T technologies, as well as
other approaches, such as monitored natural attenuation (MNA) for groundwater, and
groundwater containment. The definitions of these technologies may be found in the EPA report
Treatment Technologies For Site Cleanup: Annual Status Report (Eleventh Edition) (EPA,
2004a). They are based on the Remediation Technologies Screening Matrix Reference Guide,
Version 3 (FRTR 2003a). Technologies that are applicable to both source control and
groundwater treatment are also indicated. For P&T technologies, this report focuses on the
treatment portion of the technology.
2.2 Historical Use of Remediation Technologies at Superfund Sites
This section reviews the types of hazardous waste remediation technologies that tend to be used
at NPL sites. Most of the discussion on the selection and use of innovative and established
technologies is derived from a more detailed analysis in the Annual Status Report which contains
information on each planned, ongoing, and completed treatment technology project selected for
use in the Superfund program through fiscal year (FY) 2002 (U.S. EPA 2004a). The analysis is
based on data from RODs signed between FYs 1982 and 2002, which ended on September 30,
2002. During this period, EPA made cleanup decisions in 2,610 RODs for over 1,200 NPL sites.
It also contains data on a limited number of non-Superfund federal facility sites.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 2-1. Treatment Technologies
Source Control Treatment
Technologies
• Bioremediation
• Chemical Treatment
• Electrokinetics
• Flushing
• Incineration (on-site and off-site)
• Mechanical Soil Aeration
• Multi-Phase Extraction
• Neutralization
• Open Burn (OB) and Open Detonation (OD)
• Physical Separation
• Phytoremediation
• Soil Vapor Extraction
• Soil Washing
• Solidification/Stabilization
• Solvent Extraction
• Thermal Desorption
• Thermally Enhanced Recovery
• Vitrification
In-situ Groundwater Treatment
Technologies
• Air Sparging
• Bioremediation (also a source control technology)
• Chemical Treatment (also a source control
Technology)
• Electrokinetics (also a source control technology)
• Flushing (also a source control Technology)
• In-well Air Stripping
• Multi-phase Extraction
• Permeable Reactive Barriers
• Phytoremediation (also a source control
technology)
• Thermally Enhanced Recovery (also a source
control technology)
Pump-and-treat Technologies (Ex-Situ
Treatment)
• Adsorption
• Air Stripping (also a source control technology)
• Bioremediation
• Chemical Treatment (also a source control
technology)
• Filtration
• Ion Exchange
• Metals Precipitation
• Membrane Filtration
Monitored Natural Attenuation for
Groundwater
• Includes a variety of physical, chemical, or biological
processes, such as biodegradation; dispersion;
dilution; sorption; volatilization; radioactive decay; and
chemical or biological stabilization, transformation, or
destruction of contaminants.
In-situ Groundwater Containment
• Vertical engineered subsurface impermeable barrier
• Hydraulic Barrier created by pumping
Other Groundwater
• Groundwater Use Restrictions
• Alternative Water Supply
• Groundwater remedies that do not fall into above
categories
Source: U.S. EPA, Office of Solid Waste and Emergency Response, Treatment Technologies For Site Cleanup:
Annual Status Report (Eleventh Edition), EPA-542-R-03-009, February 2004. http://www.clu-in.org/asr; and The
Remedial Technologies Development Matrix and Reference Guide web site maintained by the Federal
Remediation Technology Roundtable. http://clu-in.org/remed1.cfm#tech_sele
Chapter 2: Remediation Technologies
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
2.2.1 Containment and Disposal Technologies for Source Control
Exhibit 2-2 shows the remedy types for source control implemented or planned over the life of
the Superfund program. These data are based on an analysis of the RODs signed between 1982
and 2002. A source control remedy has been implemented or planned at 70 percent of NPL sites.
Fifty-two percent of all source control sites have selected treatment of a source, such as
contaminated soil or sediment. Fifty-five percent of sites have implemented or plan to implement
containment or off-site disposal of a source.
Exhibit 2-2. Source Control Remedy Types
Selected or Used for at NPL Sites, FY 1982-2002
Percent of Sites with
Remedy Type Number of Sites Source Control
Treatment of a Source 541 52%
Containment or Off-site Disposal of a Source 576 55%
Institutional Controls of a Source 525 49%
Other Source Control 457 44%
Total Source Control Sites 1,046 100%
Notes:
• ROD = Record of Decision.
• Data for FY 2002 includes an estimated 70 percent of FY 2002 RODs.
• 1,046 sites with source control. More than one remediation application may be used at a site.
Source: U.S. EPA, Office of Solid Waste and Emergency Response, Treatment Technologies For Site Cleanup:
Annual Status Report (Eleventh Edition), EPA-542-R-03-009, February 2004. http://vwvw.clu-in.org/asr.
Prior to 1987, the most common methods for remediating hazardous waste were to excavate the
contaminated material and dispose of it in an off-site landfill, or to contain the waste on site by
means of containment systems (e.g., caps or slurry walls). In the late 1980s and early 1990s, the
number of remedies that included treatment began to increase. Later, in the second half of the
1990s, the percentage decreased. According to the Annual Status Report, the percentage of
source control treatment RODs was generally higher from FY 1988 through FY 1996 (59 to 75
percent of the RODs) than for the period FY 1997 through FY 2002 (39 to 51 percent of the
RODs) (U.S. EPA 2004a).
Many factors contribute to the selection of remedies at hazardous waste sites. Although the
Superfund Amendments and Reauthorization Act of 1986 (SARA) requires a preference for the
use of permanent remedies, existing regulations provide site managers with flexibility in remedy
selection, so long as they meet the principle requirements for the selection of remedies. Remedy
decisions may also be influenced by EPA's policies for considering cost (U.S. EPA 1996b) and
land use (U.S. EPA 1995, 2001c) in remedy selection, new developments in remediation
technologies, and changing knowledge and experience with technologies used for site
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
characterization, containment, and treatment. By considering land use and cost-effectiveness,
decision-makers may have the flexibility to base remedy selection on restricted, rather than
unrestricted land uses. Thus, nontreatment remedies, such as containment and institutional
controls, may be protective of human health and the environment at some sites, while other sites
will require other remedies.
2.2.2 Treatment Technologies for Source Control
Between 1982 and 2002, 863 applications of treatment technologies were implemented or
planned for source control at 638 Superfund sites. More than one type of technology may have
been selected at a site. Exhibit 2-3 provides an overview of the in-situ and ex-situ technologies
selected for source control. As the figure shows, 42 percent of all treatments selected for source
control at Superfund remedial action sites were in-situ technologies. Soil vapor extraction (SVE)
(213 projects, 25 percent), bioremediation (48 projects, 6 percent), and
solidification/stabilization (48 projects, 6 percent) are the most common in-situ technologies,
together accounting for 85 percent of all in-situ source control treatment projects.
The most common ex-situ technologies are solidification/stabilization (157 projects, 18 percent);
incineration (147 projects, 17 percent); thermal desorption (69 projects, 8 percent); and
bioremediation (54 projects, 6 percent). These technologies together account for 86 percent of
ex-situ source control treatment projects.
The Annual Status Report., which is available on line, provides a detailed description of the
trends in the use of these technologies from 1982 through 2002 (U.S. EPA 2004a). An appendix
to the report lists treatment technology projects for source control at remedial sites by EPA
region. While in-situ technologies as a percent of all treatment technologies tend to fluctuate
from year-to-year, the general trend since 1985 has been an increase in their use. In-situ
treatments as a percent of source control treatments increased from 3 Ipercent for the FY 1985 to
FY 1989 period to 49 percent for the FY 1998 to FY 2002 period. Some of the key factors that
have influenced this upward trend include:
• In-situ technologies are often more cost-effective than ex-situ approaches which require
excavation and materials handling, especially for large sites.
• Because in-situ technologies require no excavation, the levels of exposure to contaminated
substances is reduced, compared to that associated with ex-situ methods.
• As in-situ treatment technologies are used more frequently, site managers and other
remediation professionals are more willing to accept them as a viable and reliable approach.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 2-3. Superfund Remedial Actions
at Source Control Treatment Projects
FY 1982-2002 (Total Projects = 863)D
i» in Situ 42*4
Notes: Data for 2002 include an estimated 70% of FY 2002 RODs. More than one remediation application may be
used at a site.
Source: U.S. EPA, Office of Solid Waste and Emergency Response, Treatoe/rf Technologies for Sle Cleanup
(Eleventh Edlion), EPA-542-R-03-009, February, 2004.
2.2.3 Groundwater Remedies
Groundwater treatment technologies are designed to remove or immobilize contamination in an
aquifer. Groundwater remedies can be grouped into five general types: remedies specifying
extraction of groundwater, usually by pumping, followed by aboveground treatment (pump and
treat); remedies specifying in-situ treatment; remedies specifying MNA; remedies specifying
containment using subsurface vertical engineered impermeable barriers or hydraulic barriers
created by pumping; and other actions, such as groundwater use restrictions, drilling
prohibitions, and other land use (institutional) controls (Exhibit 2-1).
Exhibits 2-4 and 2-5 display the application of groundwater remedies on a site basis. These data
are based on an analysis of the 2,610 RODs and supplementary documents signed between 1982
and 2002. More than one type of remedy may have been selected at a site or in a specific ROD.
At some sites, several applications of the same type of groundwater remedy may have been
specified. At sites for which several types of groundwater remedies were selected, the
remediation may not have occurred in the same aquifer or groundwater plume.
A groundwater remedy has been implemented or is planned at 71 percent of the NPL sites. Pump
and treat has been implemented or planned at 67 percent, in-situ treatment at 13 percent, and
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MNA at 19 percent of NPL groundwater sites. At many sites, more than one type of groundwater
remedy is planned or implemented.
Exhibit 2-4. Groundwater Remedy Types
Selected or Used at NPL Sites, FY 1982-2002
Remedy Type
Number of Sites Percent of Sites
Groundwater Pump and treat
In-situ Treatment of Groundwater
MNA of Groundwater
Institutional Controls for Groundwater
Other Groundwater (includes other and VEB)
Total Groundwater Sites
713
135
201
515
735
1,062
67%
13%
19%
48%
69%
100%
Notes:
• ROD = Record of Decision; VEB = vertical engineered barrier
• Data for FY 2002 includes an estimated 70 percent of FY 2002 RODs.
• 1,062 groundwater sites. Pump and treat, in-situ treatment, or MNA has been used or selected as part of the
remedy for 851 sites. More than one remediation application may be used at a site.
Source: U.S. EPA, Office of Solid Waste and Emergency Response, Treatment Technologies For Site Cleanup:
Annual Status Report (Eleventh Edition), EPA-542-R-03-009, February 2004. http://vwvw.clu-in.org/asr
Exhibit 2-5 shows the results of an analysis of the use of pump and treat, in-situ treatment, and
MNA for groundwater, both alone and in combination with other remedies. This analysis focuses
on these three remedies because they are intended to result in the reduction or immobilization of
contaminants. Of the 851 sites, pump and treat alone was used in 556 (65 percent) of the sites,
and in combination with other technologies at 713 (84 percent) sites; MNA alone at 96 sites (11
percent); and in-situ groundwater treatment alone at 31 sites (4 percent). In-situ treatment alone,
or in combination with other technologies, was selected at 135 sites (16 percent) and MNA
alone, or in combination with other technologies, was selected at 201 (24 percent) of the sites.
2.3 Advancing Remediation and Characterization Technologies
Opportunities exist for technology vendors who want to work cooperatively with EPA, and other
federal agencies, such as the Departments of Defense (DOD) and Energy (DOE). In many cases
the programs involve other industry partners as well. A number of programs are available to
support the development and use of advanced technologies through research, development,
testing, and evaluation, and through information sharing and networking about experiences with
remediation technologies. Many of these programs also include resources to help vendors
publicize the capabilities of their technologies to all interested parties. Some of the more
important efforts are listed below:
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Exhibit 2-5. Superfund Sites With P&T, In-situ Treatment,
or MNA as Part of a Groundwater Remedy FY 1982-2002
Total Nymb«r of = 8S1
P&T a rid MNA (64)
8%
P&T Only (5561
65%
P&T ana In Situ (63)
7%
InSityOnly C31J
4%
P&T, In Situ, and MNA
(30)
4%
In Srtu and MNA (11)
1 %
MNA Only (961
11%
with P&T-713
Sites with In Situ Treatment • 135
with MNA -201
Notes: Data for 2002 include an estimated 70% of FY 2002 RODs, More than one remediation application may be
used at a site.
Source; U.S. EPA, Office of Solid Waste and Emergency Response, Freateenf Tsshnobgies for Site Cleanup
(Eleventh Edition), EPA-542- R-03-009, February, 2004.
Clean-Up Information System (CLU-IN). This web site, maintained by EPA's
Technology Innovation and Field Services Division (TIFSD), provides information about
innovative treatment and site characterization technologies and acts as a forum for all waste
remediation stakeholders. It also provides tools to assist technology developers and vendors
demonstrate and bring their technologies to market. Most of the resources referred to in this
report and cited below are available for downloading from this web site, http://www.clu-
in.org
Superfund Innovative Technology Evaluation (SITE) Program. The EPA established the
SITE Program to help promote the use of innovative remediation and monitoring and
measurement technologies at hazardous waste sites. The program, which is administered by
ORD's National Risk Management Research Laboratory, headquartered in Cincinnati, Ohio,
offers a mechanism where the performance and costs of innovative technologies can be
demonstrated and evaluated by an independent third party at a particular hazardous waste
site. The demonstration projects allow participation by private entities, state environmental
agencies and federal agencies. Under this program, EPA enables the field testing of
technologies and provides reports on completed technology evaluations. The web site
describes the current technologies of interest, how to participate in the program, and
provides the publication SITE Technology Profiles for downloading. This publication
describes each project and lists available reports. http://www.epa.gov/ORD/SITE
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• EPA REACH IT. This EPA web site allows vendors to search, view, download and print
information about innovative remediation and characterization technologies. It provides
users access to comprehensive information about treatment and characterization
technologies and their applications. It combines information submitted by technology
service providers about remediation and characterization technologies with information
from EPA, the U.S. Department of Defense (DOD), the U.S. Department of Energy (DOE),
and state project managers about sites at which innovative technologies are being deployed.
Those sources together provide up-to-date information, not only about technologies one can
use to characterize or remediate a site, but also about sites at which those technologies are
being used and the service providers that offer them. As of October 2002, REACH IT
contained information on 607 remediation technology vendors; 1,380 technologies; and
1,564 sites at which remediation technologies have been applied. It also contained
information on 128 characterization technology vendors; 209 technologies; and 232 sites at
which characterization technologies have been applied, http://www.epareachit.org.
• Groundwater Remediation Technologies Analysis Center (GWRTAC). In 1995, EPA
established GWRTAC at the National Environmental Technologies Applications Center
(NET AC) in association with the University of Pittsburgh. This center develops and
disseminates information on current research, development, and demonstration efforts
related to in-situ groundwater technologies. The Center also analyzes trends in technology
development, http://www.gwrtac.org.
• Remediation Technologies Development Forum (RTDF). The RTDF was established in
1992 after industry approached the EPA to identify what they could do together to develop
and improve the environmental technologies needed to address their mutual cleanup
problems in the safest, most cost-effective manner. The RTDF is a public-private
partnership created to undertake research, development, demonstration, and evaluation
efforts focused on finding innovative solutions to high priority problems. The RTDF
includes partners from industry, several federal and state government agencies, and
academia who voluntarily share knowledge, experience, equipment, facilities, and even
proprietary technology to achieve common cleanup goals, http://www.rtdf.org.
• Federal Remediation Technologies Roundtable (FRTR). The FRTR works to build a
collaborative atmosphere among federal agencies involved in hazardous waste site cleanup.
FRTR was established in 1990 to bring together top federal cleanup program managers and
other remediation community representatives to share information and learn about
technology-related efforts of mutual interest; discuss future directions of the national site
remediation programs and their impact on the technology market; interact with similar state
and private industry technology development programs; and form partnerships to pursue
subjects of mutual interest, http://www.frtr.gov.
Since these sources are often used in the preparation of lists of cleanup alternatives or bid
documents, it is important that technology vendors and developers ensure that information on
their products and services are represented. In addition, joining and participating in activities of
various professional societies and trade groups may help a vendor promote specific capabilities.
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2.4 References
FRTR, 2003 a. Remedial Technologies Development Matrix and Reference Guide web site
including a user-friendly tool to screen for technologies for a remediation project. Federal
Remediation Technology Roundtable. http://clu-in.org/remedl.cfm#tech_sele
FRTR, 2003b. Technology Cost and Performance, web site covering case studies and cost and
performance information on site characterization, remediation, and monitoring technologies,
Federal Remediation Technology Roundtable. http://www.frtr.gov/
U.S. EPA (Environmental Protection Agency), 1995. Land Use in the CERCLA Remedy
Selection Process, OSWER Directive 9355.7-04, Office of Solid Waste and Emergency
Response, May 1995.
U.S. EPA, 1996a. Initiatives to Promote Innovative Technology in Waste Management, OSWER
Directive 9380.0-25, Office of Solid Waste and Emergency Response, April 29, 1996.
U.S. EPA, 1996b. The Role of Cost in the Superfund Remedy Selection Process, EPA 540-F-96-
018, Solid Waste and Emergency Response, September 1996.
http://www.epa.gov/superfund/resources/cost_dir
U.S. EPA, 1999. Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action,
and Underground Storage Tank Sites, OSWER Directive 9200.4-17P, Office of Solid Waste and
Emergency Response, April 21, 1999.
U.S. EPA, 200 la. Abstracts of Remediation Case Studies Volume 5, EPA-542-R-01-008, Federal
Remediation Technologies Roundtable, May 2001.
U.S. EPA, 2001b. Groundwater Pump-and-Treat Systems: Summary of Selected Cost and
Performance Information., EPA 542-R-01-0219, Office of Solid Waste and Emergency
Response, Technology Innovation Office, December 2001.
U.S. EPA. 200 Ic. Reuse Assessments: A Tool to Implement the Superfund Land Use Directive,
(OSWER Directive No. 9355.7-06P), June 2001.
http://www.epa.gov/superfund/resources/reusefinal.pdf
U.S. EPA, 2002a. Groundwater Remedies Selected at Superfund Sites, EPA 542-R-01-022, Office of
Solid Waste and Emergency Response, Technology Innovation Office, January 2002.
U.S. EPA, 2002b. Abstracts of Remediation Case Studies Volume 6, EPA-542-R-02-006, Federal
Remediation Technologies Roundtable, June 2002.
U.S. EPA, 2003a. Publications on Remediation., web site managed by EPA's Office of Solid
Waste and Emergency Response, Technology Innovation Office.
http://www.epa.gov/swertiol/pubitech.htm
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U.S. EPA, 2003b. Vendor Support, web site maintained by Office of Superfund Remediation and
Technology Innovation to provide tools to help remediation technology vendors and developers
advance and implement their technologies, http://clu-in.org/vendor.
U.S. EPA, 2004a. Treatment Technologies For Site Cleanup: Annual Status Report (Eleventh
Edition), EPA-542-R-03-009, Office of Solid Waste and Emergency Response, February 2004.
http ://www. clu-in.org/asr
U.S. EPA, 2004b. Annual Status Report Remediation Database, Office of Solid Waste and
Emergency Response, Technology Innovation Office, http://epa.gov/tio/technologies
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Chapter 3
Demand for Remediation of
National Priorities List Sites
This chapter presents estimates of the number, location, size, characteristics, and cleanup costs
of hazardous waste sites that have been or will be placed on the Superfund National Priorities
List (NPL), but for which a remedy has yet to be selected. It also describes the implications of a
number of technical, regulatory, and economic factors for the demand for cleanup technologies.
Because many Superfund sites have undergone detailed site assessments, much information is
available on their characteristics. In addition, the remediation technologies used for the
Superfund program are likely to reflect needs in other programs with similar cleanup challenges.
3.1 The Superfund Program
Superfund is the federal program,
administered by EPA, to clean up releases
of hazardous substances at abandoned or
uncontrolled hazardous waste sites. In
addition to establishing enforcement
authorities, the Comprehensive
Environmental Response, Compensation,
and Liability Act (CERCLA) created a trust
fund to be used for site identification and
cleanup. CERCLA was substantially altered
by the Superfund Amendments and
Reauthorization Act of 1986 (SARA),
which made three changes to the Superfund
program that are of particular significance
to technology vendors: (1) it stressed the
importance of permanent remedies; (2) it
supported the use of new treatment
technologies to achieve permanent
remedies; and (3) it expanded research and
demonstrations to promote the development
of innovative treatment technologies.
3.1.1 The National Contingency Plan
The procedures for implementing CERCLA are spelled out in the National Oil and Hazardous
Substances Pollution Contingency Plan, commonly referred to as the National Contingency Plan
(NCP). The NCP outlines the steps that EPA and other federal agencies must follow in
responding to releases of hazardous substances or oil into the environment. Among other things,
Highlights
• As of September 2003, remedial construction was
complete at 886 of the 1,518 NPL sites. EPA had
conducted more than 7,000 removal actions at over
5,000 sites.
• As of May 2003, 456 proposed and final NPL sites
not owned by the federal government still require
remedial action. Estimated cleanup cost for these
sites are $16-23 billion (most likely $19 billion).
• Between 1993 and 2003, EPA added an average of
28 sites annually to the NPL.
• If 28 sites per year are added to the NPL for the next
10 years, the additional cost would be $13 billion.
(The range of estimates is 23-49 sites annually for 10
years at an estimated cost of $8-27 billion).
• EPA is working with an advisory council to address
the future direction of the program. These
deliberations may impact how Superfund's budget is
allocated among the various projects.
• The need to balance the interests of diverse
stakeholders and consider redevelopment issues
may influence the sequence of work, technologies
selected, and NPL listings.
• About 83% percent of NPL sites require remediation
of groundwater, 78% of soil, 32% of sediments, and
11% of sludge.
• VOCs are to be remediated at 78% of NPL sites,
followed by metals (77%) and SVOCs (71%). More
than half the sites have all three.
Chapter 3: National Priority List (NPL) Sites
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the NCP addresses selecting remedies that protect human health and the environment,
maintaining protection over time, and minimizing untreated waste. With regard to treatment
technologies, the NCP specifies several treatment expectations, including the following:
• Principal threats are to be treated wherever practical;
• Combination of treatment with containment, as necessary; and
• Consideration of innovative treatment technologies to the maximum extent practicable.
3.1.2 The Superfund Process
The site characterization and cleanup process established by the NCP begins with the discovery
of a potential hazardous waste site, and includes the following general steps:
1) A "preliminary assessment" (PA) is conducted to determine the existence of potential
threats to human health or the environment that require a "removal action" or further study.
If the PA indicates an emergency requiring immediate or short-term action to reduce the risk
to the public, a removal action is conducted to stabilize or clean up the site.
2) If a hazard is identified or remains after a removal action is performed, a "site inspection"
(SI) is conducted to determine whether a site warrants scoring under the Hazard Ranking
System (HRS). EPA uses the HRS to score sites on the basis of their potential effects on
human health and the environment and to determine a site's eligibility for the National
Priorities List (NPL), EPA's list of sites with the worst contamination problems. Sites that
score above a threshold may be considered for proposal for the NPL. Inclusion on the NPL
authorizes EPA to respond to the site by either pursuing enforcement against responsible
parties or paying for a response using the Superfund funds.
3) When a site is added to the NPL, an in-depth planning and investigation phase begins,
during which the nature and extent of contamination and site risks are determined, and
treatment alternatives are evaluated. This phase is known as the "remedial investi-
gation/feasibility study" (RI/FS). EPA requires the results of the RI/FS, including the
rationale for selecting a remedy, to be presented to the public, and documented in a "Record
of Decision" (ROD). Some sites require a series of RI/FSs and RODs to address different
"operable units (OUs)," which are portions of a site reflecting pathways of exposure (e.g.,
soil, water) that require separate cleanup actions.
RODs provide useful information for technology vendors interested in gaining access to the
hazardous waste cleanup market. First, RODs specify the technology type determined to be
the appropriate remedy for a site. Second, technology vendors can use RODs to determine
why EPA selected or rejected a specific remedy. EPA must consider nine criteria for remedy
selection: overall protectiveness; compliance with other environmental laws and regulations;
long-term effectiveness and permanence; short-term effectiveness; implementability; cost;
reduction of toxicity, mobility, or volume of wastes; state acceptance; and community
acceptance.
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4) Following the ROD, detailed engineering specifications for the selected cleanup approach
are developed. This phase is called "remedial design" (RD). The designs are used to solicit
competitive bids to perform the "remedial action" (RA). In the RA phase, waste is actually
treated, disposed, or contained. If necessary, "operation and maintenance" (O&M) begins at
the conclusion of the RA. This phase can include such actions as groundwater monitoring
and periodic site inspections to ensure continued effectiveness of remedies. The final step in
the process is to delete the site from the NPL. This step is initiated when all necessary
cleanup responses under CERCLA are completed.
At any point in this process, an emergency requiring a removal action can occur at a site. In
addition, community involvement activities take place throughout the process to ensure that all
interested parties participate in the decision-making process. Enforcement actions that compel
those responsible for the contamination to clean up the site also occur throughout the cleanup
process to ensure optimal use of Superfund resources.
As part of its responsibility for implementing the Superfund program, EPA is responsible for
determining the best way to clean up each site. Other federal agencies such as the Department of
Defense (DOD) and Department of Energy (DOE) are responsible for cleaning up NPL sites at
their facilities in accordance with the requirements of the NCP and with EPA concurrence.
Under the Superfund program, states also may take the lead to determine remedial alternatives
and contract for the design and remediation of a site.
3.1.3 Program Status
Since its beginning in 1980, efforts under Superfund have included the identification and ranking
of sites, detailed site investigation, mitigation of immediate threats, and selection and
implementation of remedies to clean up the worst sites (those listed on the NPL). Over the life of
the program, the number of sites that have progressed from study and evaluation to actual
cleanup has grown. As of September 2003, EPA had listed 1,518 sites on the NPL and proposed
another 54. Of these, 274 sites were deleted from the NPL, or referred for response to another
authority, leaving a total of 1,244 final NPL sites. In addition, EPA had conducted over 7,000
removal actions at over 5,000 sites, over 80 percent of which are not NPL sites.
By September 30, 2003, remedial construction activity was complete at 886 sites and 375
remedial construction projects were underway at NPL sites (U.S. EPA 2004c). Another 230 sites
were in the RD phase and the remainder were in various stages of site investigation or remedy
selection. As additional sites are studied and ranked, they may be added to the NPL.
3.2 Factors Affecting Demand for Cleanup
Many technical, economic, public policy, and legal factors have combined to determine the
number of sites currently included in the Superfund program, the cleanup standards and
technologies to be used, and cleanup work schedule. Some factors that could influence the scope
of the cleanup effort, as well as the technologies to be used in the future, are described below.
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The number of sites added to the NPL, which is difficult to forecast. Listing a site is
ultimately a decision made by the Assistant Administrator of OSWER, typically, after
consulting with state and EPA regional officials, potentially responsible parties (PRPs),
local government, and the governor. Earlier in the program, new additions to the NPL
fluctuated substantially from zero to over 400 in a single year. However between 1993 and
2003, the range has been much narrower (13 to 43) and averaged 28 per year. A 2001 study
by an environmental research group predicted that it would range between 23 and 49 per
year over the next decade, with a middle value of 35 (Probst & Konisky 2001). The average
for the three years since that study has been 23. Listing rates of this magnitude are not
inconsistent with the potential supply of "NPL-caliber" sites. Section 3.3 (Number of Sites)
describes listing rate scenarios. If more "NPL-eligible" sites are found, they may be
addressed through other programs, such as RCRA Corrective Action or a state program, or
may continue to await evaluation and/or cleanup. Because the decision on whether to list a
site is complex, depending on many variables and input from many stakeholders, there is
some uncertainty inherent in any such prediction.
Although the Superfund Trust Fund now accounts for a small portion of revenues, the
Superfund operating budget has been relatively stable. Budget authority is $1.31 billion,
$1.27 billion, and $1.39 billion (requested) for FY 2002, 2003, and 2004 (requested),
respectively.
State and PRP funding for Superfund site cleanups may fluctuate in the future. Many states
are facing serious budget shortfalls in 2003 and 2004. For Superfund remedial actions, the
states contribute 50 percent of the construction costs where they own the site and all
operations and maintenance (O&M) costs for fund-financed sites in their state. For fund-
financed remedies that involve long-term treatment or other measures to restore
groundwater or surface water quality, CERCLA requires that states assume the costs after
10-years. The management of many of these sites are now being transferred to states. To
improve O&M performance and ease the potential cost burden of these projects, EPA has
been conducting studies on pump-and-treat systems to develop recommended optimization
practices prior to takeover (U.S. EPA 2001).
PRP contributions to site remediation may be affected by business conditions and EPA's
enforcement program activities. State staffing and budgets for both Superfund and non-
Superfund hazardous waste sites programs have been at about the same level in nominal
dollars for at least seven years (See Chapter 9, State and Private Party Sites).
Current resources appropriated to the program may be insufficient to fully implement the
program. According to a 2001 Resources for the Future study, Superfund faces an average
annual budget shortfall of approximately $100-200 million over a 10-year period (Probst &
Konisky 2001). To address this and other long-term Superfund issues, EPA is working with
the National Advisory Council for Environmental Policy and Technology (NACEPT) to
help guide the future direction of the Superfund Program. While the work of this group
cannot yet be quantified in terms of a market projection, it would be helpful for remediation
service providers to keep abreast of developments in this area (U.S. EPA 2004c).
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
• In planning and implementing its cleanups, EPA coordinates extensively with its regions,
potentially responsible parties (PRPs), state and local governments, planning authorities,
local communities, and developers to ensure that the remedies protect public health and the
environment and are consistent with the anticipated future use of the site. Balancing the
considerations of these stakeholders may influence the sequence of work, types of
technologies selected for a site, and the number of sites to be listed on the NPL in the future.
3.3 Number of Sites
The market for cleanup at NPL sites includes sites where remedial action (RA) is planned but
has not yet begun. Remedial action is the phase of cleanup that typically involves construction,
and in some cases operation, of the remediation technology. As of May 30, 2003, 456 proposed
and final NPL sites not owned by the federal government and 177 NPL sites located at federal
facilities still required at least one further remedial action (U.S. EPA 2003a). Federal facilities on
the NPL are addressed in Chapters 6, 7, and 8. Exhibit 3-1 presents the geographical distribution
of the 456 NPL sites for which future RAs are planned among states and EPA regions. The data
reflect the industrialized nature of these regions which have many abandoned industrial facilities.
New Jersey, Pennsylvania, New York, California, Texas and Florida alone account for
approximately 45 percent of these NPL sites.
For some of the 456 sites EPA has identified more than one operable unit (OU) or part of the site
for which an RA is planned. The total number of OUs with planned RAs is 1,073. There may be
more than one remediation or site investigation technology employed at a given OU. Forty-eight
percent of these OUs are undergoing remedial investigations and feasibility studies (RI/FSs), and
Exhibit 3-1. Location of NPL Sites With Planned Remedial Actions
by State and EPA Region
WAIZ'(
™, f-^-i \
-
~7 / T~~~-^—i/~~Ne ~~"*\ |A "*>
NV / /UT co T u!_?r "
•^ mrrf-^-x /*'
, ,. -p—F^sc -J
I \ (MS M.\e*V
i
Includes 456 final National Priority List (NPL) by the gcwernment.
Source: U.S. ERA, of CERCLIS,
Chapter 3: National Priority List (NPL) Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
still awaiting the selection of remedial technologies (Exhibit 3-2). For 52 percent, remedies have
been selected, but not implemented (i.e., RA has not begun). Although the specific technologies
selected are not included in this report, Chapter 2 enumerates the treatment technologies
previously selected at NPL sites and provides references for additional site-specific information.
Exhibit 3-2. Phase of Remediation of Operable Units at
Non-Federal NPL Sites with Planned Remedial Actions
Remedial Total
Assessment Study Remedy Design Operable
Not Begun Under Way Selected Under Way Units
174(16%) 346(32%) 70(7%) 483(45%) 1,073(100%)
Note:Total sites equals 456; each site may contain more than one operable unit. There may be more than one
remediation or site investigation technology employed at a given OU.
Source: Office of Emergency and Remedial Response, CERCLA Information System, June 2003.
Cleanup contractors for EPA-lead sites typically are selected after the remedial design (RD) has
been completed. For PRP-lead sites, some PRPs may select a vendor to conduct both the RD and
RA. Historically, PRPs have conducted RDs and RAs at about 70 percent of Superfund sites.
This report does not estimate the smaller market for remediation technologies in the Superfund
removal program. As of the end of FY 2003, EPA had conducted over 7,000 removal actions at
over 5,000 sites, over 80 percent of which are not currently NPL sites. It is difficult, to predict
the number, type, and timing of the cleanup of these sites. Removals are usually limited to one
year and $2 million, and historically have relied little on innovative technologies.
Future NPL Sites
The above estimate of the number of NPL sites to be remediated does not include future listings
on the NPL, which also represents a market for remediation technologies. The number of sites
that eventually will be listed is uncertain and may depend upon several factors which are
difficult to predict. Most regions and states do not have a proactive site discovery process aimed
at developing a complete inventory, which would provide information for such predictions. From
time to time, there are "pop-up" sites that are a surprise. The estimate of future listings is based
on recent listing trends. In addition, an examination of the potential supply of hazardous waste
sites was conducted to ensure that the projected listing rate is feasible.
Between 1993 and 2003, EPA listed 305 sites, or an average of 28 per year. This report assumes
that listings will average 28 sites per year from 2004 to 2013, totaling 280 additional sites by
2013. If more "NPL-eligible" sites are found and evaluated, they may be addressed by other
programs, such as RCRA Corrective Action or a state program, or may continue to await
evaluation and/or cleanup. Because the decision on whether to list a site is complex, depending
on many variables and input from many stakeholders, there is some uncertainty inherent in any
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
such prediction. Although EPA may continue to add sites to the NPL beyond 2013, longer-term
scenarios are not included in this analysis because of uncertainties in making these predictions.
The 28-site per year estimate is within a range of estimates developed by a private environmental
research group in 2001 (Probst & Konisky 2001). Based on interviews with EPA regions and
nine states and an analysis of listing trends, this study predicted that new listings would range
from 23 to 49 annually over a decade, with a most probable value of 35. In the three years since
that study listings have averaged 23.
Based on information from two GAO reports (U.S. GAO 1998 and 1999) there appears to be a
sufficient supply of Superfund-eligible and potentially-eligible sites in EPA's CERCLIS
database to supply the assumed number of sites for listing. GAO identified 1,800 sites that have
a Hazardous Ranking System (HRS) score of at least 28.5, which makes them eligible for
consideration for listing. GAO also estimated that another 3,800 sites in CERCLIS are in earlier
stages of the Superfund pipeline. Evaluations of the later sites have not progressed to the point
where their NPL eligibility could be determined. Estimates of state and federal program
managers have varied widely regarding the percentage of these sites that will ultimately be
listed. Thus, we can only conclude that some portion of the 5,600 (1,800 + 3,800) sites awaiting
a listing decision will eventually be listed on the NPL. In addition, from time to time, new site
discoveries lead to new proposed listings. Thus the potential supply is not inconsistent with the
280-site assumption.
The characteristics of NPL sites vary with the basis for listing and when the listing occurs. The
three basic mechanisms for adding sites to the NPL are the following:
• Each state may nominate a total of one site without regard to its Hazard Ranking System
(HRS) score;
• The Agency may propose listing sites recommended by the Agency for Toxic Substances
and Disease Registry; and
• A site may be evaluated with the HRS, and if the score is above 28.5, that score could be
used to support adding that site to the NPL.
This third mechanism is the primary one used to add sites. In the earlier years of the program,
sites listed on the NPL were ranked under the original HRS, which emphasized exposure to
contaminated groundwater. The revised HRS also considers soil and sediment exposure and
additional pathways (U.S. EPA 1990).
3.4 Site Characteristics
This section describes how frequently certain waste matrices and contaminants are being
remediated at NPL sites. This information can be used to provide insight on the potential for the
applications of certain remedial technologies at NPL sites where RAs are planned. Technologies
that tend to be used at NPL sites are discussed in Chapter 2.
The analysis is based on a study of sites with signed RODs. As of May 2003, data on
contaminants and contaminated matrices were available for 1,105 sites (U.S. EPA 2003a). Data
Chapter 3: National Priority List (NPL) Sites Page 3-7
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
are not available for another approximately 50 sites with RODs, many of which had "No Action"
RODs which do not call for remediation. Because these 1,105 sites represent 79 percent of the
1,395 non-federally owned sites ever listed or proposed for listing on the NPL as of May 2003,
EPA believes that their characteristics are likely to be representative of those of other NPL sites.
3.4.1 Types of Contaminated Matrices
Exhibit 3-3 shows the percentage of NPL sites remediated for various contaminated matrices: 83
percent of sites require remediation of groundwater, 78 percent of soil, 32 percent of sediments,
and 11 percent of sludge. Because too few RODs contain data on other types of wastes, such as
waste piles and mine tailings, a meaningful analysis for those types of wastes could not be done.
Exhibit 3-3. Frequencies of Contaminated
Matrices at NPL Sites With RODs
1000
Groimdwaier
Soil
Sediment
Matrix
Notes: Based on data available for 1,105 National Priorities List sites with fiscal year 1982-2003
Records of Decision (RODs). A site may contain more than one contaminated matrix.
Source: U.S.EPA, Office of Emergency and Remedial Response, CERCLIS, June 2003.
3.4.2 Types of Contaminants
Sites with RODs were analyzed for the presence of three major contaminant groups: volatile
organic compounds (VOCs), semivolatile organic compounds (SVOCs), and metals. These broad
groups of contaminants were further divided into more specific treatability subgroups that better
coincide with the application of certain technologies, such as bioremediation. The 12 most
frequently occurring contaminants also are identified. Appendix A, Exhibit A-l lists common
chemicals in each group. Chemicals and elements are grouped in accordance with EPA test
methods for evaluating solid waste and standard chemical references, which are also identified in
the exhibit.
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Major Contaminant Groups
Exhibit 3-4 presents the frequency of cleanup of the major contaminant groups. VOCs, alone or
in combination with other contaminant groups, are to be remediated at 78 percent of sites,
followed by metals (77 percent) and SVOCs (71 percent). For this analysis the occurrence of a
contaminant group at a site is counted only once, whether or not it was found in more than one
matrix. These data also indicate that the NPL sites tend to be complex: all three groups (VOCs,
SVOCs, and metals) are to be remediated at 52 percent of the sites and two groups are to be
remediated at 24 percent of the sites, but not necessarily in the same matrix. The sites listed as
"others" only contain contaminants described as radioactive elements, non-metallic inorganics
such as nitric oxides, explosives and asbestos, or unspecified organics or inorganics.
Exhibit 3-4. Frequencies of Major Contaminant
Groups at NPL Sites With RODs
600-
500-
V
1 400-
I 30°
I 200-
100
o-
Total VOCs =759(78%)
Total = 755 (77%)
Total = 891 (71%)
21
4?
Notes: Based on data available tor 976 National Priorities List sites with fiscal year 1982-2003 Records of Decision (RODs).
Percentages do no! total to 100 due to rounding
The 24 sites listed as "others" contain oniy radioactive elements, non-metallic inorganics, or unspecified organics or inorganics
Source: U.S. EPA. OHice of Emergency and Remadial Response, CERCLIS, June 2003.
Subgroups of Volatile and Semivolatile Organics
Two of the major contaminant groups, VOCs and SVOCs, were subdivided into more specific
treatability subgroups that better coincide with the application of certain technologies, such as
bioremediation. Exhibit 3-5 shows the frequency of cleanup of these subgroups as well as the
metals group. The subgroups are described below, grouped according to the three major
contaminant groups:
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Exhibit 3-5. Frequencies of Major Contaminant
Subgroups at NPL Sites With RODs
on data tor 976 Priorities List Sites with fiscal year 1982-2003 Records of Decision (RODS).
Contaminant information for 24 of the with data does not fall into these subgroups. A site may contain one
or more of the 10 contaminant groups,
U.S. EPA, Office of Emergency and CERCLIS, June 2003,
• VOCs include: halogenated, BTEX (benzene, toluene, ethylbenzene, xylene), and other non-
halogenated VOCs (ketones and alcohols). The most prevalent class of organics,
halogenated VOCs, which are widely used as solvents, are being remediated at 675 (69
percent) of the sites. With regard to BTEX, although many of these compounds result from
petroleum products, CERCLA prohibits listing sites on the NPL that are contaminated with
petroleum products alone.
• SVOCs include: polychlorinated biphenyls (PCBs), polynuclear aromatic hydrocarbons
(PAHs), pesticides, phenols (including pentachlorophenol), and other SVOCs, which
include chlorobenzene and phthalates. The most common SVOCs are PAHs and phenols, to
be addressed at 49 percent and 32 percent of sites, respectively.
• Metals include: lead, arsenic, chromium, cadmium, zinc, nickel, and other less frequently
found metals.
For this analysis, each subgroup was counted only once per site, regardless of whether it
occurred alone, with other types of contaminants, or in more than one matrix. Because more than
one contaminant subgroup can be present at a site, the total number of occurrences is greater
than the total number of sites.
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Most Common Individual Contaminants
Exhibit 3-6 shows the 12 contaminants most commonly found to need remediation atNPL sites.
The list contains six VOCs and six metals. Again, a contaminant is only counted once for each
site, even if it occurs in more than one matrix; and more than one contaminant can occur per site.
Exhibit 3-6. Frequencies of the Most Common
Contaminants at NPL Sites With RODs
600
500
en
.-i 400
01
* 300
z
200
100
0
fx"
502
(51%)
*•**
r
451
(46°o!
344
(35%)
^j...
340
(35%
ft
339
(35%
,
324
{33%
^
364
<®
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
RODs indicate that quantities of waste to be capped often are not documented in the ROD, the
proportion of sites that contain large quantities of wastes may be greater than the data indicate.
The quantity distributions for soil, sediment, and sludge shown in Exhibit 3-7 involve primarily
contaminated soil to be remediated.
Exhibit 3-7. Distribution of Quantities of Contaminated
Soil, Sediment, and Sludge at NPL Sites With RODs
Number of NPL Sites With Data By Matrix
Estimated Soil Sediment Sludge Total
Quantities
(Cubic Yards) Federal Non-fed. Federal Non-fed. Federal Non-fed. Federal Non-fed.
Facilities Facilities Facilities Facilities Facilities Facilities Fac. Fac.
< 1 ,000
1 ,000 - 5,000
5,001 -10,000
10,001 -30,000
30,001 - 50,000
50,001 -100,000
> 100,000
Total
10
10
7
9
10
6
14
66
44
82
57
95
52
39
75
444
2
2
0
3
2
2
2
13
29
28
16
14
10
9
16
122
1
0
0
1
1
0
2
5
9
11
5
14
11
12
10
72
13
12
7
13
13
8
18
84
82
121
78
123
73
60
101
638
Note: Data are from 714 NPL sites.
Source: U.S. EPA, Office of Emergency and Remedial Response, CERCLA Information System, June, 2003.
Quantities by Major Contaminant Group
The quantities of contaminated material (soil, sediment, and sludge) at the 456 non-federal NPL
sites with planned RAs were estimated for the three major contaminant groups (i.e., VOCs,
SVOCs, and metals) from estimates contained in the RODs for sites with similar contaminants.
The average quantity for each contaminant group at the sites with ROD data was multiplied by
the estimated number of sites that contain the same contaminant groups based on the percentages
in Exhibit 3-4.
Exhibit 3-8 indicates the estimated quantities of contaminated materials at NPL sites by
contaminant group. An estimated 74 million cubic yards of soil, sludge, and sediment are to be
remediated at the sites. Much of this material, 66 million cubic yards, is accounted for by
materials contaminated by metals alone, and in combination with other contaminants. VOCs,
alone and combined with other contaminants, total 38 million cubic yards; and SVOCs total 60
million cubic yards.
In developing these estimates, it was assumed that all of the contaminated material at a site
contained the contaminant groups present. The average site quantities by contaminant group
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varied from a low of 45,000 cubic yards for a single group (other) to a high of 682,000 cubic
yards for SVOCs and metals.
Exhibit 3-8. Estimated Quantity of Contaminated Soil, Sediment, and Sludge for
Major Contaminant Groups at NPL Sites With Planned Remedial Actions
Contaminant
Group
No. of Sites
With Data
Average Based on
Available Data
(Cu. Yds.)
Number of Sites
With Planned
Remedial Action a
Projected Total
Quantity
(Cu. Yds.) b
Single Contaminant Group
Metals
VOCs
SVOCs
Others
46
9
24
5
230,920
53,267
247,116
45,556
46
36
14
9
10,622,320
1,917,612
3,459,624
410,004
Multiple Contaminant Groups
VOCs & Metals
SVOCs & Metals
VOCs & SVOCs
VOCs, SVOCs &
Metals
Totals
27
40
46
255
452
46,450
681,618
53,527
135,683
1,494,137
41
32
41
237
456
1,904,450
21,811,776
2,194,607
32,156,871
74,477,264
Notes:
a Based on the distribution of contaminant groups among the 976 sites with contaminant data shown in Exhibit 3-
4. Each site is placed in one subgroup only.
b The total for each subgroup is calculated by multiplying columns (3) and (4).
Source: U.S. RODs, fiscal years 1 982-2003. Site-specific data are not available for all quantities of material to be
remediated at all sites with planned remedial actions.
3.5 Estimated Cleanup Costs
EPA has estimated the value of the market for the 456 non-federal facility NPL sites with
planned RAs. The estimated cost for non-federal already listed Superfund sites that have not
begun RA is $15.5-23.3 billion in 2003 dollars. This estimate is based on an average cost per
OU of $14.7 million ($1.4 million for RI/FS + $1.4 million for RD + $11.9 million for RA), and
$10.3 million for long-term remedial action (LTRA) for sites that require long-term treatment to
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restore groundwater and surface water (2003 dollars).1 The range in values result from varying
the RA costs by plus and minus 20 percent. The calculations are shown in Exhibit 3-9.
The unit cost estimates are applied to the 1,073 OUs that have not yet begun RA, as well as to
the assumed 230-490 future NPL sites. It was assumed that 50 percent of sites with RD
underway have already incurred the RD costs, 50 percent of sites with study underway already
have incurred RI/FS costs, and 45 percent of all sites will require LTRA.
Exhibit 3-9. Estimated Cleanup Costs for NPL Sites
Low Medium High
Existing Pre-RA Sites (In the Relevant Market)b
No. of Sites 456 456 456
No. of OUs 1,073 1,073 1,073
Total Cost $15,516 mil $19,395 mil $23,274 mil
Assumed New NPL Listings 2004 - 2013 '
No. of Sites Per Year 23 c 28 d 49 e
Total over 10 years 230 280 490
Number of OUs 541 658 1,152
Total Cost $8,363 mil $12,726 mil $26,725 mil
Total NPL a' b
Current & Future NPL Sites $23,879 mil $32,121 mil $50,000 mil
Notes:
Low Cost of RI/FS+RD+RA = $11.6 million per OU (from text above) and 230 additional sites to the NPL.
Medium Cost of RI/FS+RD+RA= $14.7 million per OU (from text above) and 280 additional sites to the NPL.
High Cost of RI/FS+RD+RA= $17.6 million per OU (from text above) and 490 additional sites to the NPL.
NA Not applicable
LCC Life Cycle Cost, or cost to complete
a For purposes of this analysis, it is assumed that listings cease after 10 years, although cleanup work is likely to
continue many years beyond. Although new sites may be added to the NPL beyond 10 years, they are not
included because of uncertainties in predicting NPL listings.
b Does not include costs for sites that have begun RA.
c Low case in the Resources for the Future study, derived from the average for 1996-1999 (Probst & Konisky,
2001)
d Average of 1993-2003 actual additions to the NPL
e High case in the Resources for the Future study (Probst & Konisky 2001)
These 2003 figures are adjusted from 1999 dollars reported in the 2001 Resources for the Future study ($1.3
million each for RI/FS and RD, 11.0 million for RD) ± 20% (Probst & Konisky, 2001). The average LTRA cost per OU
was reported in a 2001 EPA study using data from 79 LTRA projects as $10.0 million and adjusted to 2003 dollars
(U.S. EPA 2001). Price adjustments are based on the gross domestic product (GDP) price deflator.
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This estimate does not include (a) costs for federal facility NPL sites, which are described in
Chapters 6 through 8, (b) the cost of continuing work at NPL sites that have already begun
remedial action, and (c) costs for site assessments, removals, administrative costs such as
payrolls, other federal agency support, oversight of potentially responsible party (PRP)-lead
cleanups, and enforcement activities. This estimate is more than twice that of a similar estimate
in the 1997 edition of this report. The difference is explained by an 18 percent increase in the
general price level, the fact that the remaining sites on the NPL that have not begun RA are
expected to be more complex and have more OUs than the average for previous NPL sites, and
the fact that LTRA costs were not included in the previous report.
Using the same unit cost estimates per OU, and assuming 23-49 sites will be listed annually, the
230-490 sites assumed to be listed over the next 10 years will cost $8.7-26.7 billion (at the
assumed most-likely value of 28 sites annually for 10 years, the cost would be $12.7 billion). If
more or fewer sites are listed, this total would be adjusted accordingly. This estimate is based
upon the above assumptions plus the expectation that future sites will be more complex, larger,
and have more OUs per site than the average NPL site in the past.
Another indication of the amount of cleanup effort likely to be undertaken is the size of the EPA
Superfund budget. During the mid-1990s, Congress allocated $1.4 billion annually. By 2002,
budget authority had dropped to $1.27 billion (excluding a post-911 appropriation), and by 2003,
it was $1.24 billion. For 2004, EPA has requested $1.39 billion. The EPA budget does not
include costs incurred by PRPs, states, or other federal agencies. Although the Superfund budget
has been relatively stable in nominal dollars, it has declined about 15 percent between 2000 and
2003 in real (adjusted for inflation) dollars.
Although it is useful to examine the trends in the Superfund budget, these figures do not coincide
with total national expenditures for site work. Since the EPA budget does not include costs
incurred by PRPs, states, or other parties, the budget data do not compare with the above market
value estimates. The market estimates include both cleanup costs incurred by PRPs and other
parties and direct costs paid by EPA for sites for which there is no available responsible party.
The amount paid by responsible parties compared to EPA varies from project to project and is
difficult to forecast.
In addition to site work at Fund-paid sites, EPA's Superfund budget also pays for activities that
are not for direct site work, such as administration and management, cost recoveries,
enforcement, removals and other short-term actions, oversight of PRP activities, and research
and development. About 25-35 percent of the EPA Superfund budget typically goes to long-term
site remediation activities. Thus, the above market value estimates were not developed to be used
for budget analysis or planning.
3.6 Market Entry Considerations
Technology decisions for Superfund sites are based on the specific information available for
each site and the state-of-the-art of the available technologies. Information on new technologies
is particularly critical at two points in the decision-making process: during remedy selection, and
during remedy design and procurement. This section describes how technology vendors can
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
benefit from understanding how site managers consider their options during these two cleanup
phases.2
3.6.1 Market Considerations During Remedy Selection
The Superfund RI/FS process is an integrated, phased approach to characterizing the site risks
and evaluating remedial alternatives. Early in the RI/FS stage, technologies are identified and
screened with respect to technical implementability, effectiveness, and relative cost. To ensure
that Superfund site managers and consulting engineers consider a given technology, it is
important to make them aware of the technology at this early stage. During the final technology
evaluation, later in the RI/FS, technologies are compared and evaluated using the nine evaluation
criteria specified in the National Contingency Plan (NCP). Information on technology
performance and cost is particularly important during this final evaluation. EPA and engineering
consulting firms (who usually conduct the RI/FSs for EPA, states, and PRPs) use a variety of
information sources, many of which are described in Section 2.3, to identify potential
technologies and to make their capabilities more widely known. Since information for innovative
technologies may be limited, treatability studies or on-site demonstrations may be used to assess
cost and performance.
While Superfund policies encourage the selection and implementation of new technologies, the
Superfund remedy selection process can present some hurdles for innovative technology vendors
because:
• Information on innovative technologies is often limited. Superfund site managers and
consulting engineers may not have as much information on the performance and cost of an
innovative technology as for an established technology. Reports and databases about
established remedial technologies have already been developed. Superfund site managers
may have difficulty comparing the merits of an innovative to a conventional technology if
they do not have information on a technology's cost, implementability, short- and long-term
effectiveness, and ability to reduce the toxicity, volume, or mobility of the contaminants.
• Treatability studies and on-site demonstrations may be impractical. The NCP and EPA
policy encourage the use of bench- or pilot-scale treatability studies, when appropriate and
practical (EPA, 1990). EPA policy stipulates that: promising new technologies should not be
eliminated from consideration solely because of uncertainties in their performance and cost,
particularly when timely treatability study could resolve those uncertainties (U.S. EPA
1996a). In reality, the funding and schedule for site cleanup, as well as contracting and
regulatory impediments, may preclude the use of studies and demonstrations.
• The RI/FS contractor may be prohibited from bidding on the RA. For example, at EPA-lead
and state-lead sites, the remedial design contractor at a site usually does not conduct the
remedial action. A technology vendor that has the capability to provide both RI/FS and
A useful source for tools to help technology vendors advance and implement their technologies is the Vendor
Support web site maintained by OSRTI, http://clu-in.org/vendor/.
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RD/RA services should determine the relative value of the two opportunities before
deciding which service to provide.
To make their capabilities more widely known, technology vendors may consider participating
in the programs cited in Section 2.3, and contacting remedial project managers (RPMs) and
consulting engineers. A vendor who is interested in a particular NPL site, may contact the
assigned EPA RPM for more information. The appropriate EPA regional office or web site,
listed in Appendix A, can provide the identity of the RPM for a specific site. Also, information
on specific technologies may be provided to consulting engineers for their consideration in the
analysis of cleanup options. Appendix A also includes a list of current regional service contracts
(RACs).
3.6.2 Market Considerations During Design and Procurement
Once a remedy has been selected and documented in a ROD, the project enters the design
process, where the details of the cleanup, such as waste quantities and performance standards,
are more clearly defined. At this stage, federal and state agencies can make use of technology
information for preparing requests for proposals and evaluating bids.
All Superfund sites requiring cleanup for which EPA has the lead currently are funded by one of
the following mechanisms:
• Remedial Action Contracts (RACs): The RACs provide professional architect/engineering
services to EPA to support response planning and oversight of CERCLA. These services
include: program support (management); remedial investigation and feasibility studies;
engineering services to design remedial actions; engineering evaluations and cost analyses
for non-time-critical removal actions, including issuing and managing subcontracts for
construction of the selected remedy, and engineering services for construction oversight.
RAC services also include enforcement support, such as negotiation support, and oversight
of RI/FS studies, remedial designs, and remedial actions; and other technical assistance,
including community relations, sampling and analysis, and pre-design investigations.
Services may also include technical and management services supporting EPA's
coordination and/or oversight of remedial activities performed by a State, the U.S. Army
Corps of Engineers, or responsible parties.
• Emergency and Rapid Response Services (ERRS) Contracts: The ERRS contracts provide
emergency, time-critical removal, and quick remedial response cleanup services for the
CERCLA, Oil Pollution Act (OPA), and Underground Storage Tank (UST) programs. They
provide cleanup personnel, equipment, and materials to contain, recover, or dispose of
hazardous substances, analyze samples, and restore sites. Because of the broad range of
cleanup services needed and the rapid time frame within which the contractors must
respond, it is likely that the contractors will do substantial subcontracting.
• Interagency Agreements (lAGs): EPA enters into agreements with the U.S. Army Corps of
Engineers, Bureau of Reclamation, or other federal agencies.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
• Cooperative Agreements (CAs): EPA enters into agreements with states, political
subdivisions, or Native American Tribes. The state performs work with its own resources, or
by contracting for needed goods and services with private firms.
As previously stated, a list of regional service contracts is included in Appendix A, Exhibit A-2.
The most definitive sources of information on selected remedies for sites entering RD and RA
are the RODs, Treatment Technologies For Site Cleanup: Annual Status Report (Eleventh
Edition) (U.S. EPA2004a), and the Annual Status Report Remediation Database (U.S. EPA
2004b). The RODs provide detailed information on the site contaminants and risks posed, the
selected remedy, estimated costs, and associated cleanup levels. ROD information is also
available on the EPA web site (http://www.epa.gov/superfund/sites/rods/index.htm). A copy of
the ROD and other site background documents can also be obtained by contacting the Regional
Community Involvement Coordinator (CIC) for the site and by visiting the site information
repository. The location of the site information repository may be obtained from the EPA web
site or the CIC. The Superfund Public Information System (SPIS), available on CD ROM, also
contains ROD documents and abstracts as well as CERCLIS and Archive data. The SPIS is
available on CD-ROM from the National Technical Information Services (NTIS), (telephone 1-
800-553-6847) or from their web site at order@NTIS.gov. Their product number is SUB-5462.
For information on innovative treatment and selected established technologies, the Annual
Status Report Remediation Database (U.S. EPA 2004b) provides the most current summary
information on the contaminants and media to be remediated, anticipated or actual cleanup
schedules, and expected site lead (EPA, state, PRP).
A vendor may use these publications to identify opportunities or assess remediation service or
technology needs. Vendors also may provide cost, performance, and availability information to
the EPA RPM or state site manager and the site remedial design firm or agency. Vendors can
enhance their responsiveness to requests for proposals (RFPs) for site remedial actions by
keeping abreast of site activities. Once an RFP has been issued, the award of a contract may take
weeks or months.
3.6.3 Research, Development, and Demonstration
Technology vendors, property owners, A/E firms, site managers, and other stakeholders may
benefit from new applications that are currently in various stages of research, development,
testing an evaluation. Likewise, some vendors or technology developers may need help to
disseminate information about their technologies and services. Section 2.3 describes the major
programs that conduct or support RD&D, as well as sources to help vendors publicize to all
stakeholders the capabilities of their technologies.
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3.7 References
Probst, Katherine N. & David M. Konisky, et. al., 2001. Super fund's Future, What Will It Cost,
Resources For the Future, Washington, D.C. 2001.
Russell, Milton, et. al., 2001. SuperfundRemediation Decisions: Quantitative Analysis of
Experience., 1987-2000 and Policy Implications-Phase I Report, Joint Institute for Energy and
Environment, Knoxville, TN, October 2001.
U.S. EPA (Environmental Protection Agency), 1990. "Hazard Ranking System; Final Rule," 55
Federal Register 51532, Vol. 55, No. 241, Part II, December 14, 1990.
U.S. EPA, 1992. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, Third
Edition, Proposal Update II, PB94-170321, Office of Solid Waste and Emergency Response,
November 1992.
U.S. EPA, 1996a. Initiatives to Promote Innovative Technology in Waste Management, OSWER
Directive 9380.0-25, Office of Solid Waste and Emergency Response, April 29, 1996.
U. S. EPA, 1996b. The Facts Speak For Themselves: A Fundamentally Different Superfund
Program, Office of Emergency and Remedial Response, November 1996.
U. S. EPA, 2001. Groundwater Pump and Treat Systems: Summary of Selected Cost and
Performance Information at Superfund-fmanced Sites, EPA-542-R-01-021b, Office of Solid
Waste and Emergency Response, December 2001. http://www.clu-in.org
U. S. EPA, 2002. Records of Decision (RODs), 1982-2002, on CD-ROM, PB96-593551, Office
of Emergency and Remedial Response, 2002.
U.S. EPA, 2003a. CERCLA Information System (CERCLIS), Office of Emergency and
Remedial Response, June 2003.
U.S. EPA, 2004a. Treatment Technologies For Site Cleanup: Annual Status Report (Eleventh
Edition), EPA-542-R-03-009, Office of Solid Waste and Emergency Response, February 2004.
http ://www. clu-in.org/asr
U.S. EPA, 2004b. Annual Status Report Remediation Database, Office of Solid Waste and
Emergency Response, http://epa.gov/tio/technologies
U.S. EPA, 2004c. National Advisory Council for Environmental Policy and Technology
(NACEPT), web site. http://www.epa.gov/oswer/SFsub.htm
U.S. EPA, 2004d. Superfund: Building on the Past, Looking to the Future, ("120-day study"),
April 22, 2004.
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U.S. EPA, 2004e. Vendor Support, web site maintained by Office of Superfund Remediation and
Technology Innovation to provide tools to help remediation technology vendors advance and
implements their technologies, http://cluin.org/vendor
U.S. GAO, 1998. Hazardous Waste, Information on Potential Superfund Sites, GAO/RECD-99-
22, U.S. General Accounting Office, November 1998.
U.S. GAO, 1999a. Superfund: Progress Problems, and Future Outlook, GAO/T-RCED-99-128,
U.S. General Accounting Office, March 23, 1999.
U.S. GAO, 1999b. Superfund Progress and Challenges, Statement for the Record by David G.
Wood, Associate Director, Environmental Protection Issues, Resources, Community, and
Economic Development Division, GAO/RCED-99-202, U.S. General Accounting Office, May
25, 1999.
U.S. GAO, 1999c. Hazardous Waste, Observations on EPA 's Cleanup Program and Budget
Management Practices, GAO/T-RCED-99-168, U.S. General Accounting Office, April 29,
1999.
U.S. GAO, 1999d. Superfund: Half the Sites Have All Cleanup Remedies in Place or Completed,
GAO/T-RCED-99-245, U.S. General Accounting Office, July 1999.
U.S. GAO, 2001. EPA 's Expenditures to Clean Up the Bunker Hill Superfund Site, GAO-01-
431R, U.S. General Accounting Office, March 28, 2001.
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Chapter 4
Demand for Remediation of
RCRA Corrective Action Sites
Prior to the passage of the Resource Conservation and Recovery Act (RCRA) (42 U.S.C.
§§6901-6922k), facilities that treated, stored, or disposed of hazardous waste, and occasionally
waste generators and transporters (collectively known as waste handlers) often experienced
releases of waste into the environment. Much of that waste, which is similar to the hazardous
waste found at Superfund sites, was disposed of intentionally or unintentionally on the land. A
number of RCRA sites have remediation needs that equal or exceed those of many Superfund
sites. Although not all RCRA sites will require cleanup, this program represents a substantial
market for environmental site characterization and cleanup services.
RCRA assigns the responsibility of
corrective action to facility owners and
operators and authorizes EPA to oversee
corrective action. Unlike Superfund,
oversight responsibility is delegated to
authorized states. EPA estimates that the
universe of RCRA hazardous waste handlers
subject to corrective action exceeds 6,600
sites. EPA has discretionary or statutory
authority to impose corrective action on
these sites, when necessary. Of the 6,600
sites, about 3,800 are likely to require
corrective action. These sites have had a
preliminary evaluation by a regulatory
authority and, based on these evaluations,
are required to undergo further investigation
and/or cleanup. EPA and the states are
examining the extent of that contamination
and the scope of corrective action needed at
these sites.
Although RCRA requires that all sites in
need of corrective action be cleaned up, EPA
has set ambitious interim cleanup targets for
1,714 sites identified by EPA and the states
as warranting early action. EPA and the
authorized states selected these sites, known
collectively as the RCRA Cleanup Baseline, because they pose potential unacceptable exposures
of contaminants to humans and/or are likely to spread groundwater contamination. By 2005, 95
percent of these baseline sites will have controlled the potential for human exposure, and 70
Highlights
• EPA and the states have identified 3,829 sites
that are likely to require corrective action.
* EPA and the states have identified 1,714 sites,
known collectively as the RCRA Cleanup
Baseline, that warrant early action to control
current human exposures and migration of
contaminated groundwater.
• During the past five to ten years, refinements in
site characterization methods have been
resulting in reduced site-assessment costs,
improved data quality, expanded applicability of
less traditional remedies, and improved remedy
design.
• The pace of the cleanups is likely to be affected
by fluctuations in state budgets. State staffing
levels and budgets (in nominal dollars) for
hazardous waste remediation and oversight has
not increased in about a decade.
• Land development trends are also likely to
affect the pace and nature of RCRA cleanups,
since property transfers or redevelopment
generally require site assessments and, if
necessary, remediation.
• Based on limited samples of sites, over 80% of
RCRA sites require remediation of
groundwater, 60% of soil, 10% each of sludge
and surface water, and 6% of sediments.
• Based on limited samples of sites, VOCs are to
be remediated at 60% of sites, followed by
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percent of them will have controlled the migration of contaminated groundwater thereby
decreasing the immediate health risks from these sites. Achieving these goals will enable the
Agency to meet its interim goals for corrective action set under the Government Performance
and Results Act (GPRA) of 1993. Nevertheless, in most cases, the interim goals are not the final
remedy. While achieving final cleanups is not likely to occur as quickly as meeting the interim
goals, the steps taken to attain interim goals are directing attention to cleanup at most baseline
sites.
4.1 Program Description
RCRA has a long and complex regulatory history that has led to a performance-based approach
to evaluating and cleaning up contaminated sites. To develop a practical understanding of this
market, it is useful to understand this history, the general process that has evolved for managing
RCRA sites, and how these steps are implemented by EPA and authorized states.
4.1.1 Regulatory History
RCRA mandates several regulatory programs, but the largest is the waste management program,
known as Subtitle C. Subtitle C sets forth comprehensive national requirements for managing the
treatment, storage, disposal, and recycling of solid and hazardous waste. Among other provi-
sions, Subtitle C establishes a management system to control new hazardous waste from the time
it is generated to its ultimate disposal ("cradle-to-grave"). In addition to its primary purpose of
preventing releases of process waste into the environment by minimizing waste generation and
by creating reuse and recycling incentives, Subtitle C contains important requirements that
address releases of contaminants into the environment from RCRA sites. It is these requirements
that influence the nature and amount of nationwide cleanup activities.
Releases of contamination at RCRA sites are addressed under the RCRA Corrective Action
program, which is administered by EPA's Office of Solid Waste (OSW), EPA regional offices,
and states that EPA has authorized to implement the program. Congress initially authorized EPA
to promulgate requirements for monitoring and remediating only on-site releases to groundwater
from hazardous waste management units, such as landfills. Later, with enactment of the 1984
Hazardous and Solid Waste Amendments (HSWA) of RCRA, Congress greatly expanded EPA's
corrective action authority to include releases to all environmental media from regulated solid
waste management units (SWMUs) at treatment, storage, and disposal facilities (TSDFs) seeking
permits under Subtitle C. A solid waste management unit is a discernible unit in which solid
waste has been placed at any time, irrespective of whether the unit was intended for the
management of solid or hazardous waste. This definition includes any area of a facility at which
solid waste has been routinely and systematically released. A release may include intentional or
accidental spillage, leakage, pumping, pouring, emitting, emptying, discarding, injecting,
escaping, leaching, dumping, or disposal of hazardous waste into the environment. It also may
include the abandonment or discarding of barrels, containers, and other closed receptacles
containing hazardous waste or hazardous constituents. RCRA Corrective Action can be
conducted at any RCRA facility that handles hazardous waste.
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In 1990, EPA proposed detailed regulations intended to govern the technical and procedural
aspects of corrective action (40 CFR Part 264 Subpart S) (EPA 1990a) and in 1996, published an
Advance Notice of Proposed Rulemaking (ANPR) that established guidance on areas of the
program not addressed by the 1990 proposed regulations (U.S. EPA 1996a). Many provisions in
these proposed rules were withdrawn, and only the ANPR continues to serve as EPA's primary
corrective action implementation guidance.
In implementing the program, EPA and the authorized states have revised the basic approach to
corrective action by (a) establishing interim goals that rely on near-term actions to reduce
imminent threats and prevent further spread of contamination that had been released into the
environment; (b) establishing long-term remediation goals; (c) streamlining the procedures for
addressing newly generated waste that previously posed unintended barriers to cleaning up
RCRA sites (remediation waste); (d) increasing emphasis on using risk-based approaches and
parity with Superfund program requirements in determining appropriate cleanup levels; and (e)
implementing a number of reforms to streamline program administration. EPA's intent has been
to limit the regulatory barriers impeding timely and cost-effective cleanups, control present risks
posed by RCRA sites, and allow EPA and authorized states to exercise considerable flexibility
throughout the site management process.
Interim Goals
In conjunction with the proposed Subpart S regulations of 1990, EPA issued the RCRA
Implementation Study. This report addressed the long-term goal of cleaning up RCRA sites but
emphasized the importance of interim environmental actions to reduce imminent threats and
prevent further spread of contamination that had been released into the environment (U.S. EPA
1990b). Soon after, EPA established procedures in the 1992 RCRA Stabilization Strategy for
implementing near-term actions to prevent the migration of contamination within and outside
facility boundaries (U.S. EPA 1991).
In 1993, EPA merged the Agency's near-term strategic interests in preventing human exposures
and the spread of contamination with the GPRA goals. EPA also considered stakeholder
concerns that the Corrective Action program was focused more on the process of cleanup than on
outcomes. Therefore, in 1994, EPA established environmental indicators to measure near-term
results at RCRA sites, effectively moving the focus of the Corrective Action program from
process to outcomes. The two environmental indicators against which progress towards the 2005
GPRA goals are being measured are (1) the control of current human exposures, and (2) the
control of migration of contaminated groundwater. These indicators provide a means of evalu-
ating and reporting on current site conditions rather than on the conditions of sites following
final cleanup. Considerable progress has been made toward this end. EPA and the states have
identified 1,714 sites that warrant early action. See EPA's Corrective Action web site for the
latest information on specific sites and progress at http://www.epa.gov/epaoswer/hazwaste/ca/
facility.htm.
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Long-Term Goals
Meeting the interim environmental indicator goals generally represents only a small component
of a typical site's final corrective action. The ultimate goal of RCRA Corrective Action is to
achieve final remedies that are appropriate for reasonably anticipated future land uses. EPA, the
states, and other stakeholders are developing specific long-term goals for corrective action and
are continuing to streamline the administrative process in anticipation of cleaning up all high,
medium, and low-priority RCRA sites in the decade ahead. EPA and the states have identified
3,829 sites that are likely to require corrective action.
Remediation Waste
Early in the 1990s, EPA recognized that several Subtitle C regulations, which control newly
generated waste, also pose unintended barriers to managing "remediation waste," which is waste
generated during RCRA Corrective Action. To minimize or eliminate these and other barriers,
the Agency and authorized states, with advice from stakeholders, took several actions.
In 1993, EPA proposed the Corrective Action Management Unit (CAMU) rule allowing sites to
place waste generated during a cleanup into a CAMU or a temporary unit without first having to
treat it. CAMUs are physical, geographic areas within a facility designated during cleanups for
the treatment, storage, or disposal of remediation waste. Temporary units are tanks or container
storage areas designated during cleanups for use solely to treat or store remediation waste. The
CAMU rule eased the land disposal restrictions for remediation waste generated during a
cleanup, thus exempting these units from the Subtitle C land disposal unit minimum technology
requirements (§264.552 (a)(2)) (U.S. EPA 1993a). The CAMU rule established general
performance-based standards to accommodate the variety of site situations that exist in the
RCRA program and granted EPA and authorized states considerable regulatory relief and
flexibility in the use of CAMUs and temporary units.
The rule was intended to result in more expeditious on-site treatment of greater volumes of
remediation waste at less cost. However, in spite of broad support, the rule was challenged in
court due in large part to concern that it lacked explicit waste treatment and unit design require-
ments for CAMUs. Following this challenge, EPA agreed to re-examine the CAMU rule in the
context of developing the 1996 proposed Hazardous Remediation Waste Management
Requirements (HWIR-Media) rule, and the litigation was stayed pending the outcome of this
rulemaking process.
When EPA published the final HWIR-Media rule (63 FR 65874) in 1998, the specific provisions
of the rule did not address the basic concerns of the litigants (U.S. EPA 1998a). To remove the
litigation cloud that had been deterring the use of CAMUs in the field since 1993, EPA agreed in
2000 to amend the 1993 rule by imposing several minimal waste treatment and design standards
and limits on the types of waste that may be managed in a CAMU. The CAMU definition was
also modified to specify that CAMUs be located within contiguous property under the control of
the owner/operator where the waste originated. The final amendments to the CAMU Rule
became effective in January 2002 (U.S. EPA 2002a).
In 1998, EPA finalized selected portions of the 1996 proposed Hazardous Remediation Waste
Management Requirements (HWIR-Media) rule (U.S. EPA 1998a). Although the final rule does
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not provide the broad reforms proposed in the 1996 HWIR-media rule (U.S. EPA 1996b), it does
offer relief from some of the Subtitle C requirements on TSDFs during cleanup operations. It
also makes available a special form of RCRA permit, called a remedial action plan (RAP), for
the treatment, storage, or disposal of waste generated during cleanup activities. RAPs provide an
alternative to traditional permits and help expedite cleanup.
Until that time, the treatment, storage, or re-disposal of hazardous remediation waste required the
same type of traditional, facility-wide RCRA permit (Part B permit) as a TSDF engaged in
managing process waste. Obtaining such a permit can take several years. The final HWTR-Media
rule removed the facility-wide corrective action requirements and made available flexible
performance-based standards that may be imposed via a traditional Part B permit or a RAP for
remediation waste management sites. The new performance-based standards may be applied in
lieu of 40 CFR 264 Subparts B, C, D, and 264.101.
The final HWTR-Media rule also contained a number of important provisions, including the
creation of a new kind of waste management unit called a staging pile for storing (not treating)
waste, which then is not subject to land disposal restrictions (LDRs) or minimum technology
requirements (MTRs). The rule excludes dredged materials from RCRA Subtitle C regulations if
the materials are managed by an appropriate permit under the Clean Water Act or the Marine
Protection Research and Protection Act. The rule also simplifies the procedures states must
follow when seeking authorization to manage their RCRA programs.
In 1998, EPA established alternative treatment standards under Phase IV of the LDR for
contaminated soil produced during cleanup operations. If remediation waste is not amenable to
waste-specific standards specified in the LDR (§268.40), a facility may apply the alternative
treatment standards (§268.49; 63 FR 28556; May 26, 1998) promulgated pursuant to the 1984
HSWA (U.S. EPA 1998b). These standards are less stringent than those in §268.40.
Also in 1998, EPA amended the rule that specified the requirements for closing land disposal
units containing hazardous waste. The amendment allowed EPA and authorized states to use a
variety of authorities to impose requirements on non-permitted land disposal units requiring
post-closure care and allowed for the closure of certain land-based units with released hazardous
constituents to be addressed through the Corrective Action program (U.S. EPA 1998c). These
changes give regulators increased flexibility to use alternate mechanisms under a variety of
authorities to address closure requirements based on the particular needs of the facility.
As part of ongoing efforts to improve program coordination, the Agency issued a final memoran-
dum entitled Risk-Based Clean Closure in 1998. The Risk-Based Clean Closure memorandum
provides additional guidance on EPA's interpretation of clean closure, specifically with respect
to the amount of residual contamination that may remain in an environmental medium while still
meeting the clean closure standards (U.S. EPA 1998d). Further guidance on "restricted-use clean
closure" is available in Final Guidance on Completion of Corrective Action Activities at RCRA
Facilities, which guides EPA and authorized states through the process of determining when a
cleanup is complete (U.S. EPA 2003a).
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Risk-Based Corrective Action
EPA issued a parity policy in 1996 between the CERCLA (Superfund) and RCRA Corrective
Action programs, entitled Coordination Between RCRA Corrective Action and Closure and
CERCLA Site Activities (U.S. EPA 1996c). This guidance describes the conditions under which
acceptance of decisions made by other remedial programs may be used. It recommends risk-
based approaches when developing cleanup levels for RCRA regulated units and establishes the
general principle that RCRA and CERCLA cleanups will achieve similar environmental results,
thereby establishing a policy that cleanups under one program will be acceptable to the other
program. It also identifies situations when deferral of activities to other programs is appropriate,
and encourages coordination among the various cleanup programs at the federal and state levels.
Risk-based corrective action provides an alternative to the use of strict numeric standards for
specific contaminants as endpoints for cleanup activity, which is generally less cost effective.
RCRA Cleanup Reforms
Through a series of administrative reforms, known as the RCRA Cleanup Reforms, EPA
continues to work with the states and stakeholders to develop new results-oriented cleanup
guidelines, foster outreach and training to encourage flexible approaches to corrective action,
and enhance community involvement. The RCRA Cleanup Reforms are expected to nurture
creative, practical approaches which, in the field, means eliminating unnecessary administrative
or technical steps, evaluating sites for overall risk, and applying appropriate risk-based facility-
wide corrective action measures.
Several guidance documents have been issued since 1999 to promote effective cleanup results
and enhance public involvement. For instance, EPA's final Handbook of Groundwater
Protection and Cleanup Policies for RCRA Corrective Action, issued in 2002, is intended to help
regulators, owners and operators of RCRA sites, and the public locate and understand EPA
policies on groundwater use, protection, and cleanup within the framework of applicable state
requirements (U.S. EPA 2002b). The Results-Based Approaches and Tailored Oversight
Guidance for Facilities Subject to Corrective Action Under Subtitile C of the Resources
Conservation and Recovery Act encourages technical and administrative innovation to achieve
environmentally protective cleanups on a facility-specific basis (U.S. EPA 2003c). The
approaches discussed in the document offer regulators flexibility in setting cleanup goals,
planning data collection efforts, and letting owners/operators undertake cleanup actions with
reduced Agency oversight when appropriate. A January 2001 memorandum discusses a variety
of new enforcement approaches, such as reduced agency oversight and flexible compliance
schedules, that are available to EPA and authorized states to help accomplish timely, protective,
and efficient corrective action (U.S. EPA 2001).
EPA has also expanded outreach and developed comprehensive training as part of the 1999
reforms. Some of the training gives EPA and state regulators the opportunity to learn from their
peers about successful cleanup approaches. EPA has also begun piloting the most innovative of
these approaches at the site level. Twenty-five pilots were launched in the first year. Creating
partnerships, training, connecting communities with cleanups, and capitalizing on the redevelop-
ment potential of RCRA sites are likely to increase the number of cleanups started during this
decade.
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4.1.2 Corrective Action Process
A rigid process-oriented framework, such as that proposed in Subpart S (U.S. EPA 1990a) and
the 1994 Corrective Action Plan (U.S. EPA 1994a), is not always applicable to the wide range of
contamination problems at the diverse types of RCRA sites. The 1996 Advanced Notice of
Proposed Rulemaking (ANPR), EPA's primary corrective action implementation guidance,
emphasizes a performance-based approach and asserts that the elements of the process should
not become ends in themselves (U.S. EPA 1996a). EPA recommends that cleanups be guided by
several operating principles:
• Corrective action decisions should be based on risk;
• Corrective action should focus on results rather than process;
• Interim actions and stabilization should be used to reduce risks and prevent exposure;
• Corrective action activities should be phased to focus resources on the areas or exposure
pathways of highest concern;
• Corrective action requirements should be addressed using the most appropriate authority,
including state authorities, for any given facility (In certain cases, the states may rely on
non-RCRA state authorities to satisfy correction action requirements); and
• Corrective action implementation should provide for meaningful inclusion of all
stakeholders through full, fair, and equitable public participation.
Although the implementation of corrective action varies from site to site, it generally begins with
an evaluation of existing site conditions, including information from the initial site assessment,
called a RCRA facility assessment (RFA). EPA or an authorized state conducts the RFA, which
involves examining a facility's SWMUs to determine if a release has occurred or if the potential
for a release exists.
While site characterization is underway for the final cleanup, the owner or operator of a facility
may be required to conduct an interim action, such as stabilizing contaminated waste to prevent
the spread of contamination or providing an alternative source of drinking water if actual or
potential contamination of drinking water supplies exists. Although an interim action typically
occurs early during the investigation of the site, it may take place at any time prior to completion
of the final remedy.
When additional site information is necessary to support an interim action, cleanup decision, or
achievement of environmental indicators, the facility owner or operator may conduct a RCRA
facility investigation (RFI). The RFI involves sampling, modeling, and other testing to determine
the nature and extent of contamination and to characterize the site's geological and hydrological
conditions.
If a corrective action is needed, a site owner will conduct a corrective measures study (CMS) to
evaluate alternative remediation approaches and select a preferred alternative as the remedy.
Sometimes, the CMS, which is the responsibility of the facility owner or operator with oversight
from EPA or the state, can be conducted concurrently with the RFI. In cases where EPA or a
state is using performance standards or a similar approach, or where the preferred remedy is
apparent early in the process, the CMS may be highly focused. Upon approval of a remedy by
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the regulatory agency, the owner or operator may begin corrective measures implementation
(CMI), which involves designing, constructing, maintaining, and monitoring the remedial
measure. EPA recommends that current and reasonably expected future land uses be considered
when selecting corrective action remedies.
4.1.3 Corrective Action Implementation
Sfafe Authorization
States are the primary implementors of the RCRA program, including RCRA Corrective Action.
EPA provides several million dollars annually in grants to states for state oversight of cleanup at
RCRA sites. As of April 17, 2003, EPA has authorized 48 states, some territories, and the
District of Columbia to manage their own base programs for waste management and prevention.
Thirty-nine states and one territory are authorized to oversee RCRA Corrective Action. EPA
regional offices have the lead responsibility for implementing the program in Indian Territories
and in states that have yet to be authorized for corrective action. Many other states have for some
time been operating similar corrective action programs under their own authorities. The states
have no RCRA universe of their own that is not reported to EPA. EPA's State Authorization
Tracking System (StATS) tracks the status of each state and territory in establishing and
maintaining RCRA authorized hazardous waste programs, including corrective action (see
http://www.epa.gov/epaoswer/hazwaste/state/stats/stats.htm).
Prior to granting a state or territory full authorization for corrective action, EPA regional offices
may develop grants and cooperative agreements under RCRA §3011 giving the state the lead for
corrective action oversight at specific sites. Although authorized state programs must meet the
minimum federal requirements, a state may adopt regulations that are more stringent than the
federal requirement.
Permitting and Enforcement
Corrective action may be implemented through the RCRA permit process, state or federal
enforcement orders, or voluntarily. All sites that are required to have RCRA permits, such as
TSDFs, and those sites where EPA or a state has discretionary authority under RCRA to impose
corrective action, are subject to corrective action requirements. About 86 percent of RCRA sites
subject to corrective action are TSDFs. Corrective action may be imposed to clean up on-site
contamination, offsite contamination, and one-time spills.
EPA or an authorized state permits all TSDFs to treat, store, or dispose of hazardous waste.
Section 3004(u) of HSWA, which is directed specifically toward controlling releases from
SWMUs, is the primary authority requiring corrective action at permitted TSDFs. It compels a
facility owner or operator to address SWMU releases due to past disposal or recent contamina-
tion whenever seeking a RCRA permit. Additional authority is available under §3004(v) of
HSWA to require a permitted TSDF to clean up contamination beyond the facility boundary.
Thus, HSWA requires all hazardous waste facilities that obtain a RCRA permit after November
8, 1984, to take corrective action for any releases from past disposal or recent contamination
from the facility, including all SWMU and off-site releases. For a TSDF operating under interim
status rather than a RCRA permit, EPA can invoke HSWA §3008(h), which provides for
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enforcement orders, or state orders in an authorized state, to address any release of hazardous
waste. The corrective action process for both permitting and enforcement orders is similar.
For actual or potential releases not originating from a SWMU, such as a one-time spill from a
vehicle traveling across a facility, or for releases at RCRA sites with permits that pre-date
HSWA, EPA may impose its omnibus permitting authority pursuant to HSWA §3005(c)(3). This
provision allows EPA to modify the facility's permit as necessary, requiring corrective action for
any potential threat to human health or the environment. Also, HSWA §7003 gives EPA broad
authority to seek injunctive relief in the appropriate U.S. District Court or to issue administrative
corrective action orders for any waste from any source, including SWMUs, where the handling,
storage, treatment, transportation, or disposal of solid or hazardous waste may pose an imminent
and substantial danger to public health or the environment.
To minimize the regulatory burden of RCRA Corrective Action without endangering public
health or the environment, EPA created exemptions and special permits. For example, EPA
conditionally exempts from the Subtitle C hazardous waste regulations any waste samples
collected solely for the purpose of monitoring or testing the characteristics or composition of
RCRA facility contamination. Referred to as the Treatability Studies Sample Exemption Rule
(CFR 261.4(e) and (f)), the exemption places limits on the quantity of contaminated media than
can be shipped, stored at a laboratory or testing facility, and treated there (U.S. EPA 1994b). The
exemption rule also limits the amount of time the contaminated media may be retained for
analysis or treatment. Although EPA encourages authorized states to adopt exemptions and
special permits, the states are not required to adopt them because they are less stringent than
existing federal requirements.
Special permits and modifications are available to facilitate the development and application of
innovative technologies. For example, facility owners or operators may obtain RCRA research,
development, and demonstration (RD&D) permits for pilot-scale evaluations of treatment tech-
nologies. EPA, in collaboration with the state, has the authority to modify a permit or enforce-
ment order to allow on-site technology demonstrations at corrective action sites. In this case,
EPA may grant a site-specific treatability variance for contaminated soils and debris when the
facility cannot achieve the stringent technology-based treatment standards in the land disposal
restrictions. Other permitting options are available through the Subpart X rule of RCRA, titled
"Miscellaneous Units," which addresses hazardous waste management units that do not fit the
current RCRA definition of container, tank, surface impoundment, pile, land treatment unit,
landfill, incinerator, boiler, industrial furnace, or underground injection well (U.S. EPA 1987).
For instance, EPA and the Department of Defense have worked together to dispose of munitions
using the permitting options available for pilot-scale RD&D and the Subpart X rule.
The remedial action plan (RAP), a special type of RCRA permit, made available in the final
HWIR-media rule (1998) as an alternative to traditional permits, can be used for the treatment,
storage, or disposal of waste generated during remediation activities. RAPs can be used for
cleaning up contaminated areas or areas in close proximity to the contamination, and they may
be used for cleaning up offsite locations when treating, storing, or disposing of the waste off site
is more protective than on site.
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4.2 Factors Affecting Demand for Cleanup
The extent and timing of the cleanup of RCRA Corrective Action sites is significantly influenced
by the regulatory and site-management refinements that EPA and the states have been building
into the cleanup process; federal funding of state oversight; and improvements in field tech-
nologies that better characterize contamination, improve remedy design, lower overall cleanup
costs, and improve the quality and pace of site cleanups. These factors create incentives for
owners and operators in the broader market to consider actual cleanup over containment.
• The RCRA Cleanup Baseline sites that are striving to meet their 2005 interim GPRA goals
represent the most immediate actions to be taken at RCRA sites. While these sites represent
the readily identified, near-term market for cleanup, many other RCRA sites with less
immediate human health concerns will also need to be cleaned up.
• Revisions to the Subtitle C requirement for cleaning up some hazardous waste implemented
over the past decade are likely to encourage treatment and removal as compared to leaving
waste in place. As described in section 4.1.1, the revisions most likely to impact the market
include introducing alternative standards for CAMUs, temporary units, and staging piles
specifically to handle remediation waste that is no longer considered newly-generated
hazardous waste; defining LDR alternative treatment standards for cleanups; harmonizing
the sometimes duplicative closure and corrective action requirements; streamlining permit
requirements for cleanup activities; and removing the obligation for facility-wide corrective
action.
Before these changes occurred, the stringent Subtitle C requirement was frequently counter-
productive when applied to the cleanup of individual sites because it imposed unnecessary
costs and delays and limited cleanup options. Even if treating or permanently removing the
waste was the preferred option, parties sometimes decided not to clean up certain sites or
sought to leave the waste in place at others. Such actions may lead to increased long-term
risk of human exposure to contamination and the potential that the contamination will
spread offsite or to groundwater.
• The 1999 and 2001 cleanup reforms are intended to increase the number and efficiency of
cleanups and establish aggressive national cleanup goals. The reforms established more
flexible, facility-specific approaches to account for the variety of conditions at RCRA sites.
• Refinements in field technologies and methods used to characterize site contamination and
its likely movement in the environment and to improve remedy design are changing the
cleanup market. Refinements in these technologies during the last five to ten years have
begun to decrease site-assessment costs, improve data quality, and expand the applicability
of less traditional remedies. For instance, in the past, a semi-permanent well had to be instal-
led to sample groundwater quality and a drill rig was needed to obtain soil borings at depth.
While these technologies still have their place, newer technologies, such as the hydropunch
and cone penetrometer, are available at a dramatically lower cost. Also available are geo-
physical technologies, such as remote sensing, to determine subsurface conditions. Almost
30 percent of all sites EPA sampled in a study of RCRA Corrective Action implementation
Chapter 4. RCRA Corrective Action Sites Page 4-10
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
used some type of innovative characterization approach (U.S. EPA 2002c). Low-priority
sites were more likely than medium and high priority sites to employ these approaches. Site
characterization, conducted at less cost, often results in better designed remedies for particu-
lar site conditions, rather than in over-designed remedies intended to account for the many
unknowns associated with a site.
• The pace of the cleanups is affected by the availability of funds to pay for state and federal
oversight. Many states have been facing budget deficits in 2003 and 2004 and, on average,
state staffing levels and budgets for hazardous waste remediation has not increased in about
a decade. Section 9.4 (State and Private Party Sites) includes a description of trends in state
capabilities.
• Land development trends are also likely to affect the pace and nature of RCRA cleanups. If
there is demand for the redevelopment or transfer of commercial and industrial properties,
they will require site assessments and, if necessary, remediation. The 2002 brownfields law,
titled "The Small Business Liability Relief and Brownfields Revitalization Act (P.L.
107-118)," the Superfund Redevelopment Program, and the RCRA Brownfields Initiative
are encouraging the reuse of former industrial and other properties. These programs have
implemented policy changes and demonstrated many approaches and ideas that foster the
cleanup and redevelopment of contaminated properties, including a number where waste has
been left on site. By publicizing the potential for reusing tainted properties, these activities
may have the impact of increasing the pace of cleanup of corrective action sites. (See
Section 9.1.2, Voluntary Cleanup and Brownfield Programs).
4.3 Number and Characteristics of RCRA Sites
All RCRA sites requiring permits and those where EPA or a state has discretionary authority to
impose corrective action are subject to corrective action requirements. However, not all of these
sites will actually require corrective action, and until further study is conducted, the number of
RCRA sites that will require cleanup can only be estimated. Nevertheless, EPA's RCRAInfo
electronic database and two previous EPA studies, can be used to estimate the potential extent of
future cleanups.
4.3.1 Number of RCRA Sites
As of March 31, 2003, EPA's RCRAInfo database, a national program management and inven-
tory system on hazardous waste handlers, contained information on 6,677 RCRA sites where
EPA has discretionary or statutory authority to impose corrective action when necessary (U.S.
EPA 2003b). Exhibit 4-1 shows the distribution among the states of the RCRA sites subject to
corrective action. Exhibit 4-2 contains the current numbers of sites in this universe in EPA's ten
regions. EPA and the states have identified approximately 29 percent high-priority sites, 24
percent medium-ranked sites, 29 percent low-ranked sites, and have not ranked 19 percent of the
sites. A RCRA facility investigation (RFI) has been imposed at 38 percent of the sites subject to
Chapter 4. RCRA Corrective Action Sites Page 4-11
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corrective action. The RFI involves sampling, modeling, and other testing to determine the
nature and extent of environmental contamination and to characterize the site's geological and
hydrological conditions. A RFI has been imposed at 79 percent of the high-priority sites, 38
percent of the medium-priority sites, and 20 percent of the low-priority sites. While about 20
percent of the sites in this universe are implementing stabilization measures, only 10 percent of
them have selected a remedy.
Exhibit 4-1. Location of RCRA Sites Subject to Corrective Action
by State and EPA Region
KS MO
Motes: Includes 6.874 sites inlhe Subject to Corrective Action Universe (sites reported to EPA or
authorized states as having a release of a hazardous substance)
Source: U.S. EPA, Office of Solid Wasle, RCRA Info database. March 31, 2003.
Chapter 4. RCRA Corrective Action Sites
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Exhibit 4-2. Priority Ranking of RCRA Sites
Subject to Corrective Action
EPA
Region
1
2
o
6
4
5
6
7
8
9
10
Total
Ranking
High Medium Low Unranked
176
188
308
272
355
236
99
58
140
78
1,910
85
208
46
196
445
204
146
68
123
46
1,567
43
267
62
151
691
228
126
126
236
29
1,959
83
23
87
268
486
114
19
108
45
8
1,241
Total
Facilities
387
686
503
887
1,977
782
390
360
544
161
6,677
Source: U.S. EPA, Office of Solid Waste, RCRAInfo database, March 28, 2003
A subset of this universe represents 3,829 sites that are required to undergo further site investiga-
tion and or cleanup. These sites are most likely to require some sort of remedial action in the
near term and already may be involved in some phase of corrective action. Approximately eight
percent of these sites are federal facilities. Exhibit 4-3 shows the distribution among the states of
the RCRA sites in this universe, which is called the "corrective action workload universe." Most
states have fewer than 100 of these sites.
4.3.2 Types of RCRA Sites
The type of activities that have occurred at a site may lend insight into the nature of the cleanup
needed. A TSDF may operate one or more types of hazardous waste management processes.
Typical management processes include land disposal, such as landfills, land treatment units,
surface impoundments, waste piles, and underground injection wells; incineration; treatment,
storage in tanks; and boilers and industrial furnaces. A waste pile is any non-containerized
accumulation of solid, nonflowing hazardous waste that is used for treatment or storage. The
definitions of the other processes may be found in 40 CFR §260.10 (U.S. EPA 1980).
Chapter 4. RCRA Corrective Action Sites
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Exhibit 4-3. Location of RCRA Sites Likely to Require
Corrective Action by State and EPA Region
OR
MT
CO
NM
SO
NE
KS : MO
OK
AR
--- m
I'M
^4
ef -
-, tfl
OH
KY
TK r.
me
6*
3,829 in the Corrective Action
for corrective action to
has imposed).
U.S. of RCRA Info 31,
Exhibit 4-4 presents the major processes
operated now or in the past by RCRA
facilities in EPA's RCRAInfo database.
Because each facility may be performing
more than one process, the total number
of processes exceeds the number of
facilities. Storage and treatment account
for 72 percent of the processes reported,
followed by land disposal at 23 percent,
and incineration at four percent.
Exhibit 4-4. Major Waste Management
Processes at RCRA Facilities
Source: U.S. EPA, Office of Waste, RCHA Info 31,2003-
Chapter 4. RCRA Corrective Action Sites
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In one study, EPA's Technology Innovation Office obtained information on a total of 275
TSDFs in 1992 and 1993 for the purpose of identifying relationships between site characteristics
and the use of innovative technologies at RCRA Corrective Action sites (U.S. EPA 1994c). At
the 214 TSDFs where contamination data were available, halogenated volatile organic
compounds (VOCs), the most prevalent of all contaminant groups reported, were present at a
majority of the TSDFs, followed by heavy metals, and nonhalogenated VOCs. Groundwater
contamination was reported at 82 percent and soil contamination at 61 percent of the 256 TSDFs
for which media data were available.
A second study is EPA's 1993 regulatory impact analysis (RIA), developed to support the
corrective action rule, Subpart S (U.S. EPA 1993b). EPA analyzed information on a sample of
79 TSDFs to estimate contamination likely to be present in soil or groundwater at concentration
levels that would require action. Of the 2,600 facilities, estimated at the time of the 1993 RIA to
require corrective action, about 80 percent appeared to have significant releases to on-site
groundwater and 30 percent were likely to have significant off-site groundwater contamination.
This estimate is close to the 82 percent observed in EPA's study of 275 TSDFs (U.S. EPA
1994c).
Contaminants in groundwater and soil at RCRA facilities were estimated in the RIA. The top ten
contaminants expected in groundwater at concentrations that were high enough in 1990 to trigger
concern are, in order of frequency, chromium, benzene, methylene chloride, arsenic, lead,
tetrachloroethylene, trichloroethylene, naphthalene, 1,1,2-trichloroethane, 1,1-dichloroethylene.
Based on this data on-site soil contaminant concentrations above EPA action levels are expected
to occur at about 68 percent of the 2,600 facilities estimated at the time of the study to require
corrective action. In soil, tetrachloroethylene, trichloroethylene, chromium, and arsenic were
expected to be at concentration levels above EPA's 1990 action levels.
In 1997, EPA developed a snapshot on corrective action implementation nationwide based on a
statistically representative sample of 84 facilities among 889 corrective action sites that had final
remedies selected or stabilization measures in place. The site data reflected the universe of
RCRA facilities subject to corrective action in 1990. EPA surveyed Agency regional and state
regulators responsible for the selected facilities and received 62 responses. The survey results
were compiled into the RCRA Corrective Action Implementation Database (RCAID) (U.S. EPA
2002c).
The majority of facilities in the extrapolated RCAID universe were manufacturing industries.
Although spills were estimated to be a major concern at over half of the facilities, landfills,
surface impoundments, and underground storage tanks also contributed significantly to facility
contamination. Nearly all of the facilities had both soil and groundwater contamination, and the
contamination had migrated beyond the facility boundary at about half of the sites. Using the
extrapolated data, OSW estimated that 84 percent of the facilities with a final remedy and/or
stabilization measure in place had VOCs, 41 percent had SVOCs, 23 percent had metals, 10
percent had polychlorinated biphenyls, 5 percent had pesticides, and 20 percent had other types
of contaminants, such as radionuclides and phenol.
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Another study of treatment experiences at RCRA corrective actions involved 30 sites identified
from readily available information sources in 2000 (U.S. EPA 2000a). EPA's Technology
Innovation Office, which conducted the study, selected sites that were illustrative of the types of
cleanups conducted at RCRA corrective actions. They were not necessarily representative of the
entire universe of RCRA cleanups. The sites, which varied in size and complexity, had
chlorinated solvents, polycyclic aromatic hydrocarbons (PAHs), benzene, toluene, ethylbenzene,
and xylenes (BTEX), other VOCs and SVOCs, and petroleum hydrocarbons.
Information on contaminants and contaminated media at 99 RCRA sites was found in the
statements of basis completed before 2000 (most were signed before 1995). A statement of basis
is similar to a Superfund ROD. The number of sites reporting groundwater contamination
exceeded 70 percent and was similar to the number reporting soil contamination. Nearly 70
percent of the sites in the database reported VOCs, about 40 percent reported SVOCs (including
halogenated, nonhalogenated, PAHs, PCBs, phenols, and pesticides), and nearly 50 percent
reported metals. Dense non-aqueous phase liquids (DNAPLs) were found at 53 sites; the most
common were 1,1,1-trichloroethane (1,1,1-TCA), 1,1-dichloroethene, tetrachloroethylene and
(PCE), and 1,1-dichloroethane.
4.4 Estimated Cleanup Costs
All known estimates of the ultimate cost of the RCRA Corrective Action program are subject to
uncertainties inherent in predicting the course of a large multi-year program. The types and sizes
of sites are quite diverse, and detailed data are available on only a sample of sites. The most
appropriate estimate was prepared in the background work for the proposed amendments to the
CAMU Rule in 2000 (U.S. EPA 2000b). This estimate is based on the RCAID survey data
described in Section 4.3.3. EPA surveyed EPA regional and state regulators responsible for the
selected facilities and received 62 responses. The cleanup cost varied widely from site to site,
from under $1 million to over $50 million. Over half the facilities had cleanup costs under $5
million, and 9 percent had costs over $50 million. The data were reported in terms of ranges and
precise average cost per site was not provided. However, by taking the upper and lower cost
value of each range, a reasonable approximation of an upper and lower limit of the estimated
costs were developed. These calculations appear in Exhibit 4-5.
Based on these estimates, cleanup of the 3,829 sites that are likely to require corrective action
will cost between $31 billion and $58 billion, with a middle-value of $44 billion, or $11.4
million per facility. Approximately 41 percent of the total cost will be incurred by nine percent
of the facilities. These estimated corrective action costs do not include those of the very large
DOD and DOE facilities, although it may include some smaller ones.
This estimated average cost per site is about 20 percent lower (in 2003 dollars) than that
estimated in the 1993 Regulatory Impact Analysis for Subpart S. This difference reflects a
variety of changes since that RIA, including more efficient site characterization and cleanup
approaches, the use of risk-based cleanup approaches, and savings due to the CAMU policies
described in Section 4.1. Over the past few years, implementation of the Corrective Action
program has shifted toward more flexible, risk-based cleanups and away from the regulatory
approach modeled
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in the 1993 RIA. In addition, the near-term costs of the program are likely to be reduced due to
the program's emphasis in the short-term on stabilization remedies rather than permanent
remedies.
Exhibit 4-5. Estimated RCRA Corrective Action Costs ($Millions)
Cost Per Site * Total Cost c
Cost % of Sites Low High No. of Sites b Low High Average
< 1.0
1 -5
5- 10
10-25
25-50
>50
Total
32
24
13
20
2
9
100
0
1
5
10
25
51
1.0
5.0
10.0
25.0
50 .0
70.0
1,225
919
498
766
77
345
3,829
245
919
2,489
7,658
1,915
17,575
30,800
1,225
4,595
4,978
19,145
3,829
24,123
57,895
735
2,757
3,734
13,402
2,872
20,849
44,347
a The lowest ($200,000) and highest ($70 million) values are conservative assumptions
b Sites likely to require corrective action, from Section 3.4.3.
c Number of sites multiplied by cost per site
Source: U.S. EPA, 2000c, Economic Analysis of the Proposed Amendments to the Corrective Action Management
Unit Rule (Background Document), Office of Solid Waste, August 7, 2000.
4.5 Market Entry Considerations
The responsibility for RCRA corrective action at individual sites lies with the owners and
operators who contract directly with commercial vendors for services. RCRA requires that
owners and operators be aware of technologies that may be used and those that are subject to
restrictions or are banned. Although vendors interested in the corrective action market can obtain
some information about specific sites by querying RCRAInfo on line, they will have to contact
specific owners or operators to obtain information on an individual facility's corrective action
requirements, waste characteristics, and cleanup needs. The RCRAInfo query form is at
http://www.epa.gov/enviro/html/rcris/rcris_queryjava.html. Many state hazardous waste
agencies, and to a lesser degree EPA regional offices, have additional information about the
corrective action needs of sites in their areas.
4.6 Remediation Technologies
Remedies selected for a given site may attain media cleanup standards through various combina-
tions of removal, treatment, engineering, and institutional controls. While EPA maintains current
information on the general characteristics of RCRA sites in the RCRAInfo database, it has not
compiled information on remedial action decisions at sites undergoing cleanup.
Chapter 4. RCRA Corrective Action Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 4-6. Remedies Selected for Soil
at 86 RCRA Corrective Action Facilities
Established Technologies
(1)
Oiher (3)
(14)
(37)
Innovative Technologies
Soil Vapor (12)
In Situ (9)
Ex Situ (8)
(1)
(1)
Data on technology applications for 186 RCRA facilities are available from an EPA study
completed in 1994 (U.S. EPA 1994c). Of 133 facilities treating groundwater, pump and treat was
selected for 116 sites (87 percent) and innovative technologies were selected for nine sites
(seven percent). The innovative technologies were in-situ bioremediation at four sites, ex-situ
bioremediation for two sites, and unspecified bioremediation, thermal desorption, and chemical
treatment for one site
each. Of 86 sites
requiring soil treatment,
established technologies
were selected for 55 sites
(64 percent), including
capping and off-site
disposal at 51 sites,
incineration for one site,
and other technologies
for three sites.
Innovative technologies,
such as soil vapor
extraction (SVE),
bioremediation, and
chemical treatment, were
selected for 31 (39
percent) of the sites
requiring soil treatment.
Of the innovative
technologies selected for
contaminated soil, most were likely to be used to remediate halogenated and non-halogenated
VOCs. Exhibit 4-6 summarizes specific innovative and established technologies applied or likely
to be applied to soil contamination at the 86 sites requiring soil treatment.
Another EPA study is available on remedies selected for 30 RCRA Corrective Action sites, 18 of
which had ongoing cleanups while 12 had completed cleanups (U.S. EPA 2000c). EPA selected
these sites from information readily available in 2000 on cleanups that had occurred or were
underway between 1986 and 2000. The selected sites include a wide range of industries, such as
wood treaters, chemical plants, refineries, paper mills, manufacturing facilities, and waste
treatment plants, that vary in size, complexity, and contaminants. Seven of these sites selected
soil vapor extraction—the most frequently used soil cleanup technology. Far less frequently
selected in-situ technologies were bioremediation of soil and groundwater, bioventing, chemical
oxidation, permeable reactive barriers, and air sparging. The ex-situ technologies selected
included pump and treat, bioremediation, and thermal desorption.
Projected remedies selected for facilities in the RCAID database were based on site characteri-
zation data collected in 1992 and 1993 (U.S. EPA 2002c). The final remedy information on 78
solid waste management units in RCAID showed that pump and treat (15 percent) and cap/cover
(31 percent) were selected most often. Barrier walls were selected for 13 percent of the units, and
* one be at a single site.
of Facility Corrective Action
Chapter 4. RCRA Corrective Action Sites
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soil vapor extraction was selected for nine percent. Pump and treat and cap/cover were also the
most common stabilization measures taken at many facilities prior to selecting the final remedy.
Information on final remedies selected for RCRA sites was found in 99 statements of basis. Most
of the remedy or stabilization decisions reported in these documents were made in the mid-
1990s. The most frequently selected remedies or stabilization measures for soil were excavation
with off-site disposal, capping or cover, and in-situ soil vapor extraction. The remedies selected
most frequently for groundwater were pump and treat and containment wall.
4.7 References
U.S. EPA (Environmental Protection Agency), 1980. 40 CFRPart 260.10, U.S. Environmental
Protection Agency, 45 Federal Register, p. 33066, May 19.
U.S. EPA, 1987. Hazardous Waste Miscellaneous Units, Applicable to Owners and Operators;
Final Rule, U.S. Environmental Protection Agency, Office of Solid Waste, 52 Federal Register,
p. 46946, December 10, 1987.
U.S. EPA, 1990a. Corrective Action for Solid Waste Management Units (SWMUs) at Hazardous
Waste Management Facilities; ProposedRule (40 CFR Parts 265, 265, 270, and 217), U.S.
Environmental Protection Agency, Office of Solid Waste, 55 Federal Register 145, pp. 30798-
30884, July 27, 1990.
U.S. EPA, 1990b. The Nation's Hazardous Waste Management Program at a Crossroads: The
RCRA Implementation Study, U.S. Environmental Protection Agency, Office of Solid Waste and
Emergency Response, EPA/530-SW-90-069.
U.S. EPA, \99l.RCRA Stabilization Strategy, U.S. Environmental Protection Agency, Office of
Solid Waste, October 25, 1991.
U.S. EPA, 1993a. Corrective Action Management Units and Temporary Units; Corrective Action
Provisions Under Subtitle C; Final Rule, U.S. Environmental Protection Agency, Office of Solid
Waste, 58 Federal Register, p. 8658, February 16, 1993.
U.S. EPA, 1993b. Draft Regulatory Impact Analysis for the Final Rulemaking on Corrective
Action for Solid Waste Management Units Proposed Methodology for Analysis, U.S.
Environmental Protection Agency, Office of Solid Waste, March 1993.
U.S. EPA, 1994a. RCRA Corrective Action Plan (Final), U.S. Environmental Protection Agency,
Office of Solid Waste, Directive 9902.3-2A, May, 1994.
U.S. EPA, 1994b. Hazardous Waste Management System: Identification and Listing of
Hazardous Waste; Treatability Studies Sample Exclusion, Final Rule (40 CFR Part 261), U.S.
Environmental Protection Agency, Office of Solid Waste, 59 Federal Register 34, p. 8362,
February 18, 1994.
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U.S. EPA, 1994c. Draft Analysis of Facility Corrective Action Data, U.S. Environmental
Protection Agency, Office of Solid Waste and Emergency Response, Technology Innovation
Office, January 1994.
U.S. EPA, 1996a. Corrective Action for Releases from Solid Waste Management Units at
Hazardous Waste Management Facilities; Advanced Notice of Proposed Rulemaking, ANPR, 40
CFR, U.S. Environmental Protection Agency, Office of Solid Waste, 61 Federal Register 85, pp.
19431-19464, May 1, 1996.
U.S. EPA, 1996b. Hazardous Waste Identification Rule; Proposed Rule, U.S. Environmental
Protection Agency, 61 Federal Register, p. 18780, April 29, 1996.
U.S. EPA, 1996c. Coordination Between RCRA Corrective Action and Closure and CERCLA
Site Activities, U.S. Environmental Protection Agency, Office of Solid Waste and Emergency
Response, September 24, 1996. http://ww.epa.gov/swerffrr/doc/924memo.htm
U.S. EPA, 1998a. Hazardous Remediation Waste Identification Rule (HWIR-Media) Final Rule,
40 CFR Parts 260, 261, 264, 265, 268, 270 and 271, U.S. Environmental Protection Agency,
Office of Solid Waste and Emergency Response, 63 Federal Register 229, p. 65874, November
30, 1998.
U.S. EPA, 1998b. Land Disposal Restrictions Phase IV: Final Rule Promulgating Treatment
Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary
Materials and Bevill Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion
of Recycled Wood Preserving Wastewaters, U.S. Environmental Protection Agency, 63 Federal
Register 100, p.28555-28604, May 26, 1998.
U.S. EPA, 1998c. Standards Applicable to Owners and Operators of Closed and Closing
Hazardous Waste Management Facilities: Post-Closure Permit Requirement and Closure
Process; Final Rule (40 CFR Parts 264, 265, 270, and 271), U.S. Environmental Protection
Agency, Office of Solid Waste, 63 Federal Register 204, pp. 56710-56714, October 22, 1998.
U.S. EPA, 1998d. Risk-Based Clean Closure, memorandum, U.S. Environmental Protection
Agency, Office of Solid Waste, March 16, 1998.
U.S. EPA, 2000a. Treatment Experiences at RCRA Corrective Actions, U.S. Environmental
Protection Agency, EPA 542-F-00-020, Office of Solid Waste and Emergency Response,
December 2000.
U.S. EPA, 2000b. Economic Analysis of the Proposed Amendments to the Corrective Action
Management Unit Rule (Background document), Office of Solid Waste, August 7, 2000.
U.S. EPA, 2001. Transmittal of Guidance on Enforcement Approaches for Expediting RCRA
Corrective Action, U.S. Environmental Protection Agency, Office of Enforcement and
Compliance Assurance, January 2, 2001.
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U.S. EPA, 2002a. Amendments to the Corrective Action Management Unit Rule, U.S.
Environmental Protection Agency, Office of Solid Waste, 61 Federal Register 14, p. 2961-3029,
January 22, 2002.
U. S. EPA, 2002b. Handbook ofGroundwater Protection and Cleanup Policies for RCRA
Corrective Action for Facilities Subject to Corrective Action Under Subtitle C of the Resource
Conservation and Recovery Act, U.S. Environmental Protection Agency, Office of Solid Waste
and Emergency Response, EPA/530/R-01/015, October 17, 2001, 66 Federal Register, pp.
52762-52763, September 2002.
U.S. EPA, 2002c. A Study of the Implementation of the RCRA Corrective Action Program, and
Highlights from A Study of the Implementation of the RCRA Corrective Action Program,
Environmental Protection Agency, Office of Solid Waste, April 9, 2002.
U.S. EPA, 2003a. Final Completion of Corrective Action Activities at RCRA Facilities, U.S.
Environmental Protection Agency, Office of Solid Waste, 68 Federal Register 37, p. 8757,
February 25, 2003.
U.S. EPA, 2003b. RCRAInfo electronic database, U.S. Environmental Protection Agency, Office
of Solid Waste, March 2003.
U. S. EPA, 2003c. Results-Based Approaches and Tailored Oversight Guidance for Facilities
Subject to Corrective Action Under Subtitle C of the Resource Conservation and Recovery Act,
U.S. Environmental Protection Agency, Office of Solid Waste, September 2003.
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Chapter 5
Underground Storage Tank Sites
Underground storage tanks (USTs) are used by a wide variety of industries, such as petroleum
and chemical manufacturing and distribution, transportation, agriculture, and government. About
680,000 active tanks are currently subject to federal regulations. Ninety-six percent of these
contain petroleum products, including used oil. Less than four percent contain hazardous
substances. In addition, more than 1.5 million federally regulated USTs have been closed.
Subtitle I of the Hazardous and Solid Waste
Amendments to the Resource Conservation
and Recovery Act (RCRA) was enacted in
1984 to control and prevent leaks and spills
from USTs. Subtitle I governs USTs storing
regulated substances, including gasoline,
aviation fuel, diesel fuel, other petroleum
products, and hazardous substances defined
under the Superfund program. Pursuant to
Subtitle I, EPA has promulgated regulations
requiring, among other things, that leaks and
spills be remediated and future releases be
prevented. These regulations have compelled
cleanup activities at many UST sites,
providing opportunities for the application of
a variety of remediation technologies.
Releases of petroleum or hazardous
substances can result from a spill during tank
filling operations, leaks in the tank or pipes
attached to the tank due to corrosion,
structural failure, or faulty installation. As of
March 31, 2004, more than 443,000 releases
from federally regulated USTs had been
confirmed (U.S. EPA 2004). These releases
can contaminate soil and groundwater and
cause fire or explosions. While considerable
progress has been made in cleaning up
contamination from underground storage
tanks during the last decade—more than
311,000 contaminated sites have been
cleaned up—many more remain to be
remediated.
Highlights
• Although considerable progress has been made
in cleaning up UST sites over the past decade,
it is estimated that 95,000 to 155,000 UST sites
will require cleanup under the RCRA
underground storage tank regulations.
• This esti mate includes35,000alreadyidentifled
sites that have not yet been cleaned up plus an
estimated 60,000-120,000 sites that may have
future releases over a 10-year period.
• Although new reported releases of
contaminants from tanks may continue beyond
10 years and tank leakage rates may decline,
these scenarios are not included in this report
because of uncertainties in predicting these
trends.
• The cost of these cleanups could reach $12-19
billion. This estimate does not include costs
related to replacing, testing, or upgrading tanks,
pipes, and related equipment.
• The year-to-year fluctuations in the number of
cleanups will depend on the availability of funds
from public and private sources; the failure rate
of tank systems; cleanup cost savings through
the growing use of newer site management
approaches; and additional site characterization
and remediation costs that may result from sites
that are difficult to remediate (e.g., MTBE).
• Since 1998, the number of confirmed releases
reported to EPA has been declining.
Nevertheless, it is expected that there will
always be some additional releases in the
future.
• UST tank sites account for over 43% of all
waste sites estimated in this report to be
cleaned up.
• The average UST site is typically smaller and
less costly to remediate than those of most
Chapter 5: Underground Storage Tank Sites
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5.1 Federal Program Description
The federal regulatory program is implemented by EPA's Office of Underground Storage Tanks
(OUST). The federal UST technical requirements and state program approval regulations were
promulgated in September 1988 and became effective on December 22, 1988 (U. S. EPA 1988).
These regulations, to a large extent, determine the size of the market for cleanup services.
The regulations apply to any UST, except those specifically exempted, excluded, or deferred,
used to store petroleum products or substances defined as hazardous under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA). The regulations do not
apply to tanks storing hazardous wastes regulated under Subtitle C of RCRA. An UST is defined
as any tank that has at least 10 percent of its volume buried below ground, including piping
connected to the tank. Generally, the requirements for tanks containing chemicals are somewhat
more stringent than those containing petroleum products.
The basic federal requirements include:
• A tank owner must register his or her tank(s) with the state authority by completing a
notification form about the characteristics and contents of the UST.
• A tank owner must institute a periodic leak detection program to actively seek out releases.
For tanks installed after December 1988, leak detection requirements become effective at
the time of installation. For older tanks, the requirements were phased in over time with a
final completion date of December 1993.
• A tank owner must maintain records of leak detection activities, corrosion protection system
inspections, repair and maintenance activities, and closure site assessments.
• A tank owner must notify the appropriate regulatory authority of all suspected or confirmed
releases as well as follow-up actions taken or planned. Suspected leaks must be investigated
immediately to determine if they are real. If evidence of environmental damage is the cause
for suspicion, it must be reported immediately to the regulatory authority.
• If a leak or spill is confirmed, tank owners must: (a) take immediate action to stop and
contain the leak or spill; (b) notify the regulatory authority within 24 hours or other
reasonable time period specified by the implementing agency; and (c) take action to mitigate
further damage to people and the environment.
• All USTs must be protected from corrosion and have devices that prevent spills and
overfills, in accordance with EPA's upgrade and new tank standards.
• A tank owner closing an UST must notify the regulatory authority 30 days before permanent
closure.
Chapter 5: Underground Storage Tank Sites Page 5-2
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
The following kinds of tanks are currently exempt or excluded from the regulations:
• Farm and residential tanks holding 1,100 gallons or less of motor fuel used for non-
commercial purposes.
• Tanks storing heating oil for use on the premises.
• Storage tanks on or above the floor of areas such as basements or tunnels.
• Septic tanks.
• Storm-water and waste-water collection systems.
• Flow-through process tanks.
• Tanks holding 110 gallons or less.
• Emergency spill and overflow containment UST system.
• Certain pipeline facilities, including gathering lines regulated under other federal or state
statutes.
• Surface impoundments, pits, ponds, or lagoons.
• Liquid traps or associated gathering lines directly related to oil or gas production and
gathering operations.
• UST systems holding hazardous substances listed or identified under Subtitle C of RCRA.
• Any wastewater treatment tank system that is part of a wastewater treatment facility
regulated under Section 401 or 307(b) of the Clean Water Act (CWA).
• Equipment or machinery that contains regulated substances for operational purposes, such
as hydraulic lift tanks and electrical equipment tanks.
• Any UST system that contains a de minimis concentration of regulated substances.
In addition, certain categories of tanks, known as deferred USTs, are not yet subject to the full
federal UST regulations. Until EPA decides how to regulate these USTs fully, the only
regulations that apply are Subpart A (Interim Prohibition) and Subpart F (release, response, and
corrective action). Examples of deferred tanks include underground, field-constructed, bulk
storage tanks, and UST systems that contain radioactive wastes.
Changes in the types of tanks covered by the regulations could significantly impact the potential
size of the market. However, EPA is not contemplating any such changes at this time. Although
these categories of tanks are currently excluded from federal regulations, some of them may be
subject to state regulations.
EPA designed the UST program to be implemented by the states. Authority to implement the
program is delegated to states through either the formal process of obtaining state program
approval (SPA) or a cooperative agreement. Thirty-three states, the District of Columbia, and
Puerto Rico have all been approved to act in lieu of the federal program. Most of the other states
operate their own program under their own laws with limited federal oversight. The Act also
allows for states to have more stringent requirements than that of the federal regulations. For
example, some states may include home heating oil tanks in their program. EPA supports state
programs by providing resources from the federal Leaking Underground Storage Tank Fund
(LUST Trust Fund), grants to states and tribal programs, technical assistance, training, and
information exchange.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
5.2 Factors Affecting Demand for Cleanup
The demand for remediation services at contaminated UST sites primarily will be influenced by
federal regulations, state requirements, and the number of releases occurring at old and new
tanks. The timing of these cleanups will be influenced by the availability of state and federal
funds for site assessment and cleanup of UST sites and the pace of economic development.
5.2.1 General Trends
In October 2002, EPA
established a national goal of
completing between 18,000
and 23,000 cleanups each year
for the fiscal years 2003-2007.
If EPA is able to meet this
goal, the backlog of sites
needing remediation, which
has remained steady over the
past decade, will be halved by
2007. Exhibit 5-1 shows the
number of sites in the backlog
since 1991 (U.S. EPA 2003c).
Exhibit 5-1. Backlog of UST Site
Cleanups to be Completed
200,000
m
a.
1 «
g m
•si
o>»,
JO «
o 1 100,000
m --
50,000
1991 1992 1993 ,g94 1995 W6 1997 Igg8 1999 20QO 2001 200
Ąear
US. EPA, of «\t fl En«i-flf-Ą«ar
Exhibit 5-2. Confirmed Releases at UST Sites
S*1Jn^«*37l,M7
A number of factors led to an increase in the number of confirmed releases in 1997 and 1998,
including the implementation of leak detection requirements (which became effective in 1993);
tank upgrading requirements to prevent spills, overfills, and corrosion (which became effective
in 1998); and reporting
requirements. Since 1998, the
number of confirmed releases
has almost steadily declined
from 29,600 to 12,000 (Exhibit
5-2). During the last three
years, they have ranged from
6,000 to 12,000 and averaged
9,000. As more tanks come
into compliance, the number of
new releases is expected to
continue to drop. However, it
is expected that there will
always be releases in the
future. Many older tanks still
exist and many older, as well
15
cc
•Q
I
JQ
I
Confirmed Releases Cumulative ;
Confirmed Releases !n A Given Yea^;
1992 1994 1996 1998 1999200020{)1 2002
Year
Source- U.S. EPA, Office of Solid Waste and Emergency Response, f Y
Semi-Arwual Enc!-of-Year Activity Report. November 25.2003.
as upgraded tanks, are not in
full compliance.
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The failure rate of tank systems is determined by such factors as tank age, material of
construction, corrosion protection systems in place, and other design and site-specific factors
such as soil type, weather, and operations and maintenance practices. Because information on
these factors is limited, estimates of market size are subject to some uncertainty. The following
observations have been made about some of the factors that influence tank failure rates.
Exhibit 5-3. Compliance Status of USTs by Region
100
01
O
.
E
o
m
0
60
40
a.
O
Ł
I 20
~
TH-
rn
w
Tank Upgrading Requirements
i Leak Detection Requirements
-.
\;
While none of the states
are in full compliance
with EPA' s leak
detection and upgrading
requirements, most of the
tanks that states monitor
had the required leak
prevention and detection
equipment installed as of
September 2003. The
compliance rates were 79
percent for release
prevention and 72 percent
for leak detection. Region
9 had the highest
percentage of operational
compliance with release
prevention requirements
(93%), while Region 3
had the lowest (69%). For
leak detection
requirements, the range
was from 89 percent (Region 9) to 55 percent (Regions 1 and 10). However, there is
variation in the reporting by the states, since some states' reports are based on more
stringent requirements. (Exhibit 5-3)
According to a 2003 GAO report (based on data collected in 2001 and 2002), 29 percent of
tanks are not operated and maintained properly, thus increasing the chance of leaks and
posing health risks. In addition, over half of the states are not inspecting all of their tanks at
the minimum rate of at least once every three years recommended by EPA (U.S. GAO 2001,
and 2003). This implies that even if the backlog of all known sites is eliminated, there are
likely to be additional releases at some sites in the future.
GAO also estimates that 1 1 percent (76,000) of the active regulated tanks that states monitor
and 30 percent of tanks on tribal lands, may not be upgraded (U.S. GAO 2003). Most of
these tanks are believed to be empty or inactive. States reported to GAO that they generally
do not discover tank leaks or contamination around tanks until the empty tanks are removed
from the ground during replacement or closure. Thus, there is a backlog of potentially
contaminated sites that may be discovered over a period of time as they are replaced or
removed.
Chapter 5: Underground Storage Tank Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
• Despite the upgraded equipment, a number of states reported to GAO that upgraded tanks
leaked. GAO cites that researchers have concluded that tanks with upgraded equipment and
monitoring systems do not provide complete protection against leaks. However, the extent
of this problem is unknown.
5.2.2 State Regulations and Funding Sources
Some states have promulgated requirements that are more stringent than the federal standards,
such as a requirement for double-lined tanks, more stringent monitoring procedures, or earlier
upgrading compliance dates.
The pace of the cleanups is affected by the availability of funds to pay for cleanups and
oversight. UST cleanups are primarily financed from three sources:
• The federal Leaking Underground Storage Tank Fund (LUST Trust Fund). Revenues from
the fund are derived from a gasoline tax of 0.1 cent per gallon. Appropriations from the fund
have been about $70-80 million annually.1
• State tank trust funds or direct appropriations are generally used to assist owners and PRPs
in paying for cleanups. A number of these are also financed by gasoline taxes. Between
1999 and 2003, the annual revenues of these funds averaged $1.3 billion and they paid out
an average of about $1.1 billion annually.
• PRPs and site owners.
State Tank Funds 1999-2003 (Billions of Dollars)
1999
Revenues
Approximate amount paid
Source:
Association of State and
Survey Results 2003.
1
0
38
70
Territorial Solid and
2000
1.19
1.49
Hazardous
2001
1
0
21
68
Waste
2002
1
1
.34
.49
Management
2003
1.37
1.16
Officials,
Average
1
1
30
10
Sfafe Fund
EPA regulations that limit the liability of lenders for corrective action in many situations help to
encourage the extension of credit to credit-worthy UST owners. The availability of credit to UST
owners, especially the many small businesses that operate USTs, is necessary to assist them in
meeting their obligations to upgrade, maintain, and otherwise comply with RCRA Subtitle I and
1 The gasoline tax is scheduled to expire in 2005. The federal LUST Trust Fund helps states oversee corrective
action and pay for cleanups at UST sites where the owner or operator is unknown, unwilling, or unable to respond, or
which require emergency action. Most of the money appropriated from the fund goes to states, which use the funds to
oversee corrective action by responsible parties, to clean up sites where no responsible party can be found, and for
enforcement and administration. As of the end of 2003, the balance was $2.1 billion.
Chapter 5: Underground Storage Tank Sites Page 5-6
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
related environmental requirements. Under these regulations, which were promulgated in 1995,
any person or lending institution that guarantees loans secured by real estate containing an UST
or UST system may not be liable for the required corrective action, so long as the lender is not
otherwise engaged in petroleum production, refining, or marketing (U.S. EPA 1995b).
5.2.3 2002 Brownfields Legislation and EPA's USTfields Initiative
The 2002 brownfields law, titled "The Small Business Liability Relief and Brownfields
Revitalization Act (P.L. 107-118)," and EPA's USTfields initiative may lead to an increase in
the total number of UST sites identified as needing cleanup as well as the pace of cleanups. This
potential increase would result from the increased number of site assessments completed. The
increased pace of cleanups could result from additional funds made available under the new law.
As many as 200,000 of the estimated 500,000 brownfield sites across the country are impacted
by petroleum leaking from USTs, and many of these sites are gas stations that have shut down
because they could not comply with the 1998 federal UST upgrade requirements (NEMW 2001).
These properties pose threats to public health and the environment, and pose challenges for the
redevelopment plans of the communities in which they are located.
Many UST cleanups are funded using state assurance funds, which usually do not have sufficient
money to clean up all of the eligible sites in a given year. This scarcity of money has contributed
to the backlog of over 136,000 sites nationwide that have not completed cleanup. The new
brownfields law may help address this backlog. This law expands the current EPA Brownfields
program and for the first time, allows "low-risk" petroleum sites to be eligible for assessment
and cleanup grant funding under the Brownfields program. Prior to the new law, petroleum
contamination was not eligible for Brownfields funding. The law authorizes up to 25 percent in
grant awards annually through 2006 for the assessment and cleanup of brownfields contaminated
with petroleum. In FY 2003, EPA awarded 103 new Brownfield Petroleum grants totaling $22.3
million. This new authority builds upon and complements EPA's USTfields Initiative, which
addressed "high-priority" petroleum-contaminated properties and awards funds to states, tribes,
and intertribal consortia. Under the USTfields Initiative, $4.8 million in grants were awarded to
36 states and three tribes to cleanup properties contaminated from leaking USTs. Although no
further USTfields grants are planned, the petroleum grants under the Brownfields program
continues to encourage further site assessments, cleanup, and redevelopment.
5.2.4 MTBE Contamination and the Remediation Market
Concerns about methyl tertiary-butyl ether (MTBE) contamination may influence the amount
and timing of UST cleanups in some states. According to a 2003 survey of 50 states conducted
by The New England Interstate Water Pollution Control Commission (NEIWPCC 2003), MTBE
is detected in gasoline releases to groundwater 60 percent of the time, averaged among the states.
Most states do not intend to open closed sites to look for MTBE or tertiary-butyl alcohol (TEA),
unless they have reason to suspect a problem. Most states say there are very few cases where
MTBE is the only concern. Thirty-three states say that MTBE drives cleanup and investigative
efforts less than 20 percent of the time, or never. BTEX and free-product is the primary
Chapter 5: Underground Storage Tank Sites Page 5-7
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
remediation driver in these states. In most states, less than 10 percent of the sites have situations
where BTEX has been successfully remediated but MTBE remains.
Nevertheless, some states, such as California and New York, indicated that MTBE
contamination drives remediation at LUST sites more than 80 percent of the time. Connecticut,
Maryland, Nevada, and New Jersey indicated that MTBE drives remediation more than 60
percent of the time; Maine and New Hampshire indicated that MTBE drives remediation more
than 40 percent of the time; and Delaware and Vermont indicated that MTBE drives remediation
more than 20 percent of the time.
In this survey, Delaware indicated that the threat of lawsuits is a potential driver for remediation
at sites where MTBE contamination is present. Illinois indicated that once it adopts new
legislation to address MTBE contamination, it expects to see an increase in the number of LUST
remediation cases at sites where MTBE is the only concern. New York indicated that its high
percentage of sites where MTBE is the only concern is a reflection of the fact that more than 193
spills have impacted more than 860 private water supply wells, requiring alternate water
supplies.
5.2.5 State Performance-Based Environmental Cleanup Programs
Traditionally, environmental cleanups have been completed using time and materials (T&M)
reimbursable contracts. Under these T&M cleanups, contractors bill their clients for hours
worked and the cost of materials. Historically, these types of contracts provide very few
incentives for contractors to meet any performance standards and conduct the cleanup in a timely
and cost effective manner. In addition, there is little incentive for contractors to use the best
technologies or to develop innovative practices.
Many states are moving toward performance-based cleanup programs to reduce cleanup costs
and improve accountability for cleanup performance at UST sites. These "Pay For Performance"
(PFP) contracts include the following basic elements: 1) a firm fixed price; 2) a fixed time limit
for achieving the environmental goals of the cleanup; 3) cleanup goals specified in terms of
specific contamination levels detected at specific locations; 4) criteria for system start-up and
contamination reduction milestone payments, including closure; 5) provisions for the state to
take additional contamination measurements at its own expense and discretion; and, 6) escape
clauses specifying conditions under which the contractor can be released from the contract.
Useful information on the background of pay-for-performance and implementation tools are
available on the U.S. EPA web site, http://www.epa.gov/swerustl/pfp/
States with experience using both T&M and PFP contracting report that LUST site cleanups are
being done faster and cheaper at PFP sites. In addition, state officials report a greater use of
innovative cleanup technologies and more aggressive approaches to cleaning up "hot spots" at
PFP sites. States also have reported that their paperwork burden is reduced substantially under
PFP because they no longer monitor the details of a contractor's expenditures. Oklahoma
estimates that $6,629,000 of unnecessary expenses were incurred prior to obtaining cleanup
guarantees using its Pay-For-Performance program (Oklahoma, 2001).
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Contractors who conduct PFP cleanups have the opportunity to realize greater profit under a PFP
contract than under a T&M contract because the contractor assumes some of the risk of the
cleanup. PFP frees them to manage their sites more efficiently, lowers paperwork costs, allows
the contractor to purchase equipment that can be reused on other jobs, and allows the
government to pay the contractor in a more timely manner. In fact, PFP contractors in pioneering
states, such as California, Florida, South Carolina, and Oklahoma, are generally doing quite well
and most are looking for more PFP business.
The cost savings associated with PFP programs can be leveraged to conduct more cleanups in
states with PFP programs. In addition, PFP programs encourage the use of innovative
technologies, which may help drive the market for some newer remediation technologies
applicable to LUST sites.
5.3 Number and Location of USTs
The data on the number and status of currently registered USTs are derived from data that EPA
compiles semi-annually from reports it receives from 56 states and territories. The states compile
their data from information received from tank owners. Reporting quality varies from state-to-
state and has resulted in some under-reporting of the number of tanks subject to the regulations.
EPA estimates that there is an average of 2.65 tanks per UST site, although this number actually
varies widely from one site to another.
5.3.1 Population of UST Sites in the U.S.
The number of potential corrective actions are related to the population of active and closed
tanks subject to the federal regulations. EPA reports that as of March 31, 2004, 679,249 active
tanks and 1,582,638 closed tanks have been registered in the U.S. (U.S. EPA 2003d). Nearly all
contain petroleum. These sites include marketers who sell gasoline to the public (such as service
stations and convenience stores) and non-marketers who use tanks solely for their own needs
(such as fleet service operators and local governments). EPA estimates about 25,000 tanks hold
hazardous substances covered by the UST regulations. Using EPA's estimated average of the
2.65 tanks per site, over 256,000 active sites with USTs are subject to the UST corrective action
regulations.
In 1988, EPA estimated that there were between 5 and 7 million USTs (U.S. EPA 1988). Taking
the midpoint of this range implies a total UST population of 6 million, of which 2.2 million
active and closed USTs are currently subject to the regulations. The remaining 3.8 million tanks
are exempt from the federal regulations and are not included as part of the market for
remediation services in this report. Section 5.1 identifies the seven exempt categories of tanks.
Although the exempt tanks are not quantified in this report, they nevertheless represent a
potential for cleanup work in selected states where state regulations include some federally
exempt tanks.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
5.3.2 Location of Regulated Tanks
Appendix B lists the number of regulated tank sites by state, as reported to EPA in September
2003. Texas, California, Florida, New York, North Carolina, Michigan, Illinois, and
Pennsylvania contain almost 40 percent of all active and closed tanks. The location data should
be used with caution because a state's tank population may not be correlated with the number of
releases, and cleanup program requirements, reporting practices, and data quality vary by state.
5.3.3 Potential Number of Sites to be Cleaned Up
Exhibit 5-4. LIST Site Cleanup Progress 1991-2002
I
E
Z
°3
II
800000
4OOOOO
200000
Confirmed Releases ;
Cleanups Initiated j
Cleanups Completed
:439.385
403,558
303,120
1993 1995 1997 1999 2001
1884
Year
Soyme ti S. ŁR^, Office of Emergency Respotiis, FY 2003
Semi-Annuaf End-of-Year Aefcily Ftef«rt. November 25, 20CS.
By September 2003, 439,385
confirmed releases were reported
to EPA. Remedial design or
remedial action had been initiated
at 403,558 sites and completed at
303,120 (Exhibit 5-4). Thus,
cleanup has not been completed
at 136,265 sites. Of these,
cleanup has been initiated at
100,438 sites and no cleanup
action has been taken at the
remaining 35,827 sites. A cleanup
is considered "initiated" if a state
or responsible party has evaluated
the site and initiated one or more
of the following five types of
activities: management of
contaminated soil, removal of
free-product, management or
treatment of dissolved petroleum contamination, monitoring of the groundwater or soil being
remediated by natural attenuation, or the state has determined that no further actions are
necessary to protect human health or the environment. At this stage, some physical activity (such
as pumping, soil removal, recovery well installation) has usually begun at a site. Thus, the term
"cleanup initiated" covers a range of situations. EPA's data does not indicate the extent of work
done. Although many of these sites have substantial amounts of work yet to be done, including
these sites in the market for future cleanup work may overstate somewhat the true market
potential. Remediation contractors for some of these sites may already have been selected.
The total number of UST sites to be cleaned up in the future includes the already identified sites
plus sites that will be reported in the future due to new releases or existing releases that have not
yet been reported. Exhibit 5-5 displays the estimate of the number of UST sites likely to be
cleaned up in the future. This exhibit, which uses data as of March 31, 2004, shows that there are
34,734 already confirmed releases for which cleanup has not begun (EPA 2004). In addition, as
stated previously, there are likely to be new releases reported due to leaks in the future. The
number of projected future releases can come from the active tank universe, the inactive
universe, and unregulated tanks. There are numerous abandoned and empty tanks, many of
Chapter 5: Underground Storage Tank Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
which are not identified, that may need to be cleaned up. The estimated number of future UST
site discoveries is based on the annual rate of new releases in recent years and the assumption
that this rate will continue for 10 years. Although tank releases may continue beyond 10 years,
and leakage rates may decline, these scenarios are not included because of uncertainties in
predicting these trends.
Exhibit 5-5. Estimated Number of UST Sites Needing Remediation
Reported to EPA Estimated Future Total b
Through 3/31/04 Releases (2004-2033) a (2004-2013)
Confirmed Releases
Cleanups Completed Through
March 31 , 2004
Cleanups Initiated but Not
Completed as of 3/31 /04C
Releases Reported as of
3/31/04, but cleanups not
initiated
Future Cleanups Required, but
not initiated (2004 -2033)
443,568
311,125
97,709
34,734 d
34,734 d
60,000-120,000
NA
NA
NA
60,000-120,000
503,568-563,568
311,125
97,709
34,734
94,734-154,734°
(Average 124,734)
Notes:
NA Not applicable
a Assumes 6,000-1 2,000 confirmed releases annually for 10 years, which is the range for 2001, 2002, and 2003.
b Although tank releases may continue beyond 10 years, and leakage rates may decline, these scenarios are not
included because of uncertainties in predicting these trends.
c Some of these sites may have designated cleanup contractors and some do not, but the number that already
have contractors is unknown. To allow for a conservative market estimate, it is assumed that they all have
selected contractors.
d This figure is derived by subtracting "cleanups initiated" and "cleanups completed" from "confirmed releases."
Between 2001 and 2003, the number of confirmed releases ranged from over 6,000 to over
12,000, with no specific increasing or decreasing trend (although these figures are about half
what they were in 1998). Based on these figures, it is estimated that an average of 6,000-12,000
new releases will be reported per year over the next 10 years. Thus, an estimated 94,734-154,734
sites will need to be remediated over at least 10 years, with a middle value of 124,734.2
Although the size of the entire market has been estimated, the year-to-year fluctuations in
cleanup efforts are difficult to predict. The difference between confirmed releases and cleanups
initiated has averaged over 47,000 for the past four years. Exhibit 5-4 shows the comparison
between the number of confirmed releases and cleanups initiated each year. During the first half
of FY 2004, about 8,000 cleanups were completed. However, the year-to-year fluctuations in
activity would depend upon the factors discussed in Section 5.2, such as the availability of
private and public funds and real estate development activity.
6,000-12,000 X 10 years + 34,734 backlog as of March 31, 2004.
Chapter 5: Underground Storage Tank Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
5.4 Estimated Cleanup Costs
Site characterization and cleanup costs vary widely from one site to another and EPA does not
have a precise average cost per site.3 Nevertheless, EPA estimates that the average remediation
cost per site is $125,000. This cost estimate typically includes activities such as site
investigations, feasibility studies, and treatment or disposal of soil and groundwater. Multiplying
this average by the number of sites that will need remediation (94,734-154,734), the projected
total remediation cost is $11.8-19.2 billion (average $15.6 billion). The presence of MTBE or
other factors that may make remediation more difficult at these sites can boost the remediation
cost (See section 5.2.3).
5.5 Market Entry Considerations
The following factors will be important to the success of vendors operating in the UST
remediation market.
• Site work is primarily the responsibility of owners and operators of establishments such as
retail gasoline stations, petroleum and chemical marketing operations, fleet maintenance and
auto repair shops, and manufacturing or transportation facilities.
• Most work is contracted locally. However, some large firms and government agencies will
use national contractors. Many of the national contractors tend to subcontract to local firms.
• States also issue contracts to cover large areas over a period of time for work done directly
by the states.
• EPA is responsible for administering the program on tribal lands.
• The level of enforcement activity varies from one state to another. In addition, some states
regulate tanks that are not regulated under RCRA. Information on these activities generally
are available through state authorities. An indication of a state's commitment to its tank
program can be obtained from its compliance rate with federal tank standards. EPA
publishes a semi-annual report on its web site which provides the percent of tanks in each
state that are in significant operational compliance with federal release prevention
requirements and with leak detection requirements (U.S. EPA 2003c, 2004b).
• As tank testing and other requirements are implemented, the extent of cleanup activities and
costs per site probably will decrease. Thus, economical ways to remediate smaller releases
may be needed.
Based on a review of literature and data, the University of Tennessee reported that the cost of remediating UST
sites had varied widely, generally between $2,000 to over $400,000. Costs at individual sites can exceed a million
dollars (Bueckman & Russell, 1991). If only a small amount of soil needs to be removed or treated, cleanup costs can
run as low as $10,000. Corrective action for leaks that affect groundwater can cost from $100,000 to over $1 million,
depending on the extent of contamination.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
5.6 Remediation Technologies
Data on the kinds of innovative technologies used to remediate contaminated UST sites have not
been centralized. However, a survey conducted in 2001 by the University of Massachusetts
provided information on the use of remediation technologies for contaminated groundwater and
soils at LUST sites (Kostecki and Nascarella 2001). Thirty five states responded to this 12-
question survey. The questions dealt with the types of technologies used, use of technologies by
site, changes in technology use over time, barriers to implementation, and the impact of
monitored natural attenuation. The survey results were compared with similar data collected
from 45 states in a 1995 University of Massachusetts survey. Comparisons were made based on
a percentage of total sites for each survey (Exhibit 5-6).
Exhibit 5-6. Types and Frequencies of Soil
Remediation Technologies at LUST Sites
35 -A /=a
V)
co
Z3
30-
20
15-
28
Ł12
1995 Survey
2001 Survey
F
16
c*
$&
As the exhibit shows,
landfilling continued to be the
most frequently selected option
for soil remediation at LUST
sites (about one-third of the
sites), although most
environmentalists agree that it
is not an ideal option because it
transfers waste from one site to
another. The percentage of UST
sites using landfilling is
considerably higher than occurs
at NPL sites. Over the 2000
through 2002 period, only 23
percent of NPL sites used
containment or off-site disposal
(the data do not provide a
separate figure for landfilling).
The next two most commonly
used treatment technologies,
soil vapor extraction (SVE) and low-temperature thermal desorption (LTTD), have grown in
popularity between the 1995 and 2001 surveys. SVE use grew from 9 percent of LUST sites in
1995 to 18 percent in 2001. This is considerably greater than the SVE usage at NPL sites, where
SVE was selected for only 8 percent of the sites between 2000 and 2002 (U.S. EPA 2004a).
The use of low-temperature thermal desorption (LTTD) at LUST sites has been growing steadily
since the early 1990s. In a 1995 study, industry representatives reported that thermal desorption
was only used on a limited basis in the early 1990s. By 1995 it was used at numerous sites in
almost every state (Tremblay 1995). The 2001 data indicate that use of LTTD at LUST sites has
continued to grow from 3 percent of sites in 1995 to 16 percent in 2001. This is considerably
higher than the usage rates at NPL sites (11 percent of NPL sites between 2000 and 2002 used
either low- or high-temperature thermal desorption).
Soil Remediation Technologies
Source: Kostecki, Paul and Marc Nascarella, "Lust Cleanup Landscape Changing:
Landtilling Still In, Pump and Treat on the Way Out," Contaminated Soil Sediment
and Water, January/February 2003.
Chapter 5: Underground Storage Tank Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Although monitored natural attenuation (MNA) and biopiles showed great promise for
remediating soil at LUST sites in the early 1990s, their use declined from 28 to 19 percent and
from 16 to 3 percent, respectively between 1995 and 2001. The decline in biopile use could be
attributed to a lack of confidence in the technology while the decline in MNA is attributed to the
fact that this method of cleanup takes too long and partly to an EPA Office of Solid Waste and
Emergency Response (OSWER) directive, The Use of Monitored Natural Attenuation at
Superfund, RCRA Corrective Action, and Underground Storage Tanks Sites. During the same
period, the use of landfarming increased by 2 percent. It remains as popular in 2001 as it was in
1985 (Kostecki & Nascarella 2003).
The 2001 survey results indicate that MNA continues to be the most common option for
remediating groundwater at LUST sites (Exhibit 5-7). Between 1995 and 2001, MNA use grew
from 49 to 67 percent of sites while the use of pump and treat declined from 30 to 12 percent.
The MNA usage rate is substantially higher than that of NPL sites. MNA-only RODs have
hovered around 20 percent of groundwater RODs between 1999 and 2001, and dropped to only 7
percent in 2002. Pump and treat, which has been selected at 67 percent of NPL sites between
1982 and 2002 (U.S. EPA 2004a), has been declining at LUST sites (from 30 percent in 1995 to
12 percent in 2001). The decline of pump and treat may be attributed to the fact that it takes a
long time to achieve cleanup
goals, it has been demonstrated
to spread contamination in Exhibit 5-7. Type and Frequency of Groundwater
some cases, and it is expensive Remediation Technologies at LUST Sites
to operate and maintain.
W
(0
80
70
80
40
30
20
10
0
30
In-situ bioremediation and air
sparging are the other two
most common technologies
used at LUST sites (Kostecki
& Nascarella 2003).
Bioremediation use at LUST
sites is significantly lower than
at NPL sites (9 percent in 2001
compared to a range of 8 to 36
percent of NPL sites between
1997 and 2002).
The results of the 2001 survey
indicate that, except for low-
temperature thermal
desorption, the older soil
remediation technologies such as SVE and landfarming, are growing in popularity for soil
remediation, while MNA continues to grow as the technology of choice for groundwater
remediation. An interesting result of this study is that no new soil- or groundwater-remediation
technologies has been developed in the past decade, according to respondents in 35 states.
SSll
In, on fit Out." Soil
Chapter 5: Underground Storage Tank Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
5.7 References
Bueckman & Russell, 1991. Underground Storage Tanks: Resource Requirements for Corrective
Action, Bueckman, D. S., S. Kumar, and M. Russell, University of Tennessee, Waste
Management Research and Education Institute, Knoxville, TN, December 1991.
Kostecki & Nascarella, 2003. "Lust Cleanup Landscape Changing: Landfilling Still In, Pump
and Treat on the Way Out," Kostecki, Paul, and Marc Nascarella, Contaminated Soil Sediment
and Water, January/February 2003.
NEMW, 2002. Recycling America's Gas Stations: The Value and Promise of Revitalizing
Petroleum Contaminated Properties Northeast-Midwest Institute and National Association of
Local Government Environment Professionals, 2002.
NEIWPCC, 2003. A Survey of State Experiences With MTBE and Other Oxygenate
Contamination at LUST Sites, New England Interstate Water Pollution Control Commission,
August 2003.
Oklahoma, 2001. Oklahoma'sPay-For-PerformanceProgram, Petroleum Storage Tank
Division, Oklahoma Corporation Commission, April 2001.
http://www.nga.org/cda/files/OKPAYFORPERF.pdf
Tremblay et al, 1995. "Innovation Skyrockets at 50,000 LUST Sites," Deborah, L., D. S. Tulis,
P. Kostecki, and K. Ewald, Soil and Groundwater Cleanup, December 1995.
U. S. EPA (Environmental Protection Agency), 1988. Technical Requirements and State
Program Approval; Final Rule, 53 FR No. 185, Office of Underground Storage Tanks,
September 23, 1988.
U. S. EPA, 1991. Survey of Underground Storage Tanks, Office of Underground Storage Tanks,
Spring 1991.
U. S. EPA. 1992a. TC [Toxicity Characteristic] Study of Contaminated Media and Debris, Draft,
Office of Underground Storage Tanks, July 1992.
U.S. EPA, 1992b. Technologies and Options for UST Corrective Actions: Overview and Current
Practice, EPA/ 542/R-92/010, Office of Underground Storage Tanks and Technology
Innovation Office, August 1992.
U. S. EPA, 1993. An Overview of Underground Storage Tank Remediation Options, EPA 510-F-
93-029, Office of Underground Storage Tanks, October 1993.
U. S. EPA, 1995a. How to Evaluate Alternative Cleanup Technologies for UST Sites: A Guide
for Corrective Action Plan Reviewers, EPA-510-B-95-007, Office of Underground Storage
Tanks, May 1995.
Chapter 5: Underground Storage Tank Sites Page 5-15
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
U. S. EPA, 1995b. Underground Storage Tanks: Lender Liability; Final Rule, 40 CFR Parts 280
and 281, Federal Register, Vol. 60, p. 46692, September 7, 1995.
U.S. EPA, 1996. Pay for Performance Cleanups, Effectively Managing Underground Storage
Tank Cleanups, EPA 510-B-96-002, Office of Solid Waste and Emergency Response, June 1996.
U. S. EPA, 1997. Expedited Site Assessment Tools for USTs: A Guide for Regulators,
EPA-510-B97-001, Office of Underground Storage Tanks, March 1997.
U. S. EPA, 1999. The Use of Monitored Natural Attenuation at Superfund, RCRA Corrective
Action, and Underground Storage Tanks Sites, OSWER Directive 9200.4-17P, Office of Solid
Waste and Emergency Response, April 21, 1999.
U.S. EPA, 2000. Underground Storage Tank Program: Regional and State Contacts, EPA 510-
F-00-00, Office of Solid Waste and Emergency Response, January 2000.
U. S. EPA, 2003a. Cleanup Information Web site (CLU-IN), Office of Solid Waste and
Emergency Response, (http:// www.cluin.org).
U. S. EPA, 2003b. Office of Underground Storage Tanks web site, Office of Solid Waste and
Emergency Response, http://www.epa.gov/swerustl
U.S. EPA, 2003c. Semi-Annual Activity Report, Second Half (September 30 2003), Office of
Underground Storage Tanks, http://www.epa.gov/swerustl/cat/camarchv.htm
U.S. EPA, 2004a. Treatment Technologies For Site Cleanup: Annual Status Report (Eleventh
Edition), Office of Solid Waste and Emergency Response, Technology Innovation Office, EPA-
542-R-03-009, February 2004. http://www.clu-in.org/asr
U.S. EPA, 2004b. Semi-Annual Activity Report, First Half (March 31, 2004), Office of
Underground Storage Tanks, http://www.epa.gov/swerustl/cat/camarchv.htm
U.S. GAO, 2001. Environmental Protection: Improved Inspections in Enforcement Would Better
Ensure the Safety of Underground Storage Tanks, GAO-01-464, U.S. General Accounting
Office, Report to Congress, May 2001.
U.S. GAO, 2002. Environmental Protection: Improved Inspections and Enforcement Would
Ensure Safer Underground Storage Tanks, GAO-02-712T, U.S. General Accounting Office,
May 8, 2002.
U.S. GAO, 2003. Environmental Protection: Recommendations for Improving the Underground
Storage Tank Program, GAO-03-529T, U.S. General Accounting Office, March 5, 2003.
Chapter 5: Underground Storage Tank Sites Page 5-16
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Chapter 6
Demand for Remediation of
Department of Defense Sites
The Department of Defense (DOD) has undertaken the task of cleaning up wastes that have
resulted from numerous industrial, commercial, training, and weapons activities, as well as
cleaning up closing military bases so that the properties can be transferred to local communities
for economic revitalization. DOD has estimated that of the approximately 9,000 sites it has
remaining in the cleanup process or with future preliminary assessment starts planned, almost
6,400 of these sites have yet to start and/or complete evaluation and more than 2,600 sites have
remedial design or other remedial action underway or planned for future completion. These sites
contain hazardous waste contamination involving soil, groundwater, and other media. Typical
contaminants include petroleum products, solvents, heavy metals, explosives and munitions
residue, polychlorinated biphenyls (PCBs), and pesticides.
Over more than two decades, DOD has made
considerable progress in locating,
investigating, and cleaning up thousands of
contaminated sites. DOD has identified more
than 30,000 sites on over 1,700 installations.
Of these, over 21,000 sites were cleaned up
or found to require no further remedial
action. To address sites in its cleanup
program, DOD uses a prioritization scheme
for sequencing work based on the relative
. , „.,..,,. , ,. Achieving the above goals is contingent upon
risk of individual sites. Under this receiving adequate funding.
Highlights
• Approximately 9,000 DOD sites remain in the
remediation process.
• DO D esti mates th at it wil I cost $16.4 bi II ion to
complete cleanup of its active installations,
BRAC and FUDS sites.
• An additional $16.8 billion is projected for
Military Munitions Response sites. The full
scope of MMRP cleanup is still uncertain.
• DOD estimates that it will complete remediation
of all of its sites up by 2015.
An additional round of base closures and
realignments scheduled to begin in FY 2005
could alter the sequence of the cleanup effort.
The nature and magnitude of contamination at
some sites have yet to be determined.
management approach, decisions regarding
such issues as cleanup standards, remedy
selection, and no further action
determinations are made site-by-site rather
than for an entire installation. Decisions on
these issues are made on a risk management
approach that considers the relative threat to
human health and the environment, reasonable anticipated land use, cost-effectiveness, and
speed of cleanup, and depend on early and meaningful public participation. DOD works with the
regulatory agencies and other interested parties to streamline and find economies in the
environmental restoration process.
To accomplish site characterization and cleanups, DOD needs the services of firms that can
clean up wastes similar to those found at private sector industrial facilities as well as firms that
can remediate wastes that are unique to DOD, such as unexploded ordnance (UXO). These
environmental service firms will have to understand DOD operating procedures and keep abreast
of the overall direction of its environmental programs.
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6.1 Program Description
The DOD created the Installation Restoration program (IRP) in 1975 to investigate and
remediate contaminated sites resulting from past DOD activities. The Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), and the
Resources Conservation and Recovery Act (RCRA) are the primary federal laws that govern the
identification, investigation, and cleanup of DOD contaminated sites. Congress formally
established the Defense Environmental Restoration Program (DERP) and its funding mechanism,
the Defense Environmental Restoration Account (DERA) in 1986. DERP uses the CERCLA
framework for DOD cleanup. Also during the 1980s, Congress recognized the need to close or
reduce the size of many installations, and authorized four rounds of base realignment and
closures (BRAC) in 1988, 1991, 1993, and 1995 (U.S. Congress, 1998). The FY 2002 Defense
Authorization Act authorized another round of closures for FY 2005.
DOD installations typically have multiple contaminated sites regulated by CERCLA, RCRA
corrective action provisions, RCRA underground storage tank (UST) provisions, or all three.
Through Executive Order 12580, signed in January 1987, the President delegated to the
Secretary of Defense Presidential CERCLA authorities for investigation and cleanup measures
for releases of hazardous substances from facilities under the jurisdiction of the Secretary. The
interface between CERCLA and RCRA authorities is determined by the circumstances at
specific sites, including factors such as the source and cause of the contamination, the status of
the installation as either a National Priorities List (NPL) or non-NPL site, and whether the
installation has or is seeking a RCRA permit to manage hazardous wastes. DOD cleanups must
also consider the requirements of state laws and the BRAC acts. Partnering efforts allow DOD,
EPA, and the states to reconcile overlaps and inconsistencies in regulatory requirements to
ensure the most effective and timely cleanups. A detailed description of their remediation
programs is included in the Defense Environmental Restoration Program Annual Report to
Congress (U.S. DOD, 2002a).
The implementation process for the DOD cleanup program generally follows those of the
environmental statutes. Although the regulatory framework of CERCLA and RCRA differ in
many ways, their implementation processes generally parallel one another. Each requires
assessments and investigations to determine the need for cleanup, and the selection and design of
appropriate remedies to ensure protection of human health and the environment. However, each
program has its own nomenclature for the various phases of study, design, and cleanup.
6.1.1 Installation Restoration Program
DERP is the DOD program for the evaluation and cleanup of past contamination at DOD sites.
The Deputy Undersecretary of Defense for Installations and Environment or ODUSD (I&E)
oversees environmental restoration activities, including work conducted at BRAC installations.
DOD refers to the program for meeting its responsibilities under CERCLA as the IRP. Under
IRP, DOD cleans up all contaminated sites for which cleanup is required by environmental
statutes, whether or not the sites are on the NPL. Although policy direction and oversight of IRP
are the responsibility of the ODUSD (I&E), each individual DOD Component (Army, Navy, Air
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Force, and Defense Logistics Agency) is responsible for program implementation. The Army
Corps of Engineers (Corps) is the execution agent for all Formerly Used Defense Sites (FUDS)
as well as for the Defense and State Memorandum of Agreement (DSMOA) program which
funds states and territories for technical services they provide to support the cleanup of DOD
facilities. In 2001 DOD established the Military Munitions Response Program (MMRP) to
manage cleanup of unexploded ordnance (UXO) and waste military munitions (WMM) at areas
other than operational ranges. The DERP Management Guidance (U.S. DOD, 200la) defined
and established the MMRP, laying out specific requirements for the DOD components.
Each installation works toward completing its environmental restoration requirements by
developing and maintaining a management action plan (MAP) or a base realignment and closure
(BRAC) cleanup plan (BCP). A MAP contains information about an active installation's past
activities and current status, presents a vision for future site-level requirements, establishes
schedules, and identifies future funding requirements through completion. A BCP is the
equivalent document for an installation undergoing base closure and transfer of property to the
community. Each installation updates its MAP or BCP at least once a year.
DERP has specified procedures for evaluating sites and procuring cleanup services under the
IRP that conform to the regulatory requirements of the National Oil and Hazardous Substances
Contingency Plan (NCP). These procedures cover all the phases of site operations, including
preliminary assessment (PA), site inspection (SI), remedial investigation/feasibility study
(RI/FS), remedial design (RD), and remedial action (RA). In most cases, activities related to
preliminary assessment through remedial design are conducted by different contractors than are
those related to remedial action. Activities conducted under IRP are classified as follows:
• Investigation: Analysis to characterize the nature, extent, and risk of releases of hazardous
substances to the environment and to develop and select cleanup remedy.
• Interim Action: Early measure to reduce the risk of releases of hazardous substances before
the initiation of more complicated, comprehensive, and long-term cleanup remedies. For
example, placing fences around contaminated areas or removing and treating or disposing of
contaminated soil.
• Design: Performance specifications or detailed engineering plans and specifications to
construct and implement a final cleanup remedy.
• Cleanup: Action to construct and implement a final cleanup remedy.
In selecting and designing remedies at NPL sites, DOD officials coordinate with EPA regional
officials to ensure that cleanup goals meet regulatory requirements. Most contracting is done by
installations, either through centralized contracting service centers or directly with the
installation. Although the DOD Components follow the general procedures specified by DERP,
each DOD Component procures its own cleanup services. Section 6.5 describes typical
procurement practices.
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6.1.2 Base Realignment and Closure (BRAC)
Additional procedures and expedited timetables have been established for the cleanup of bases
being closed or realigned. These procedures, known as DOD's Fast Track Cleanup Program,
have influenced the sequence of work to be conducted. This BRAC cleanup approach balances
reuse needs and priorities with environmental requirements in prioritizing and sequencing
cleanup of sites. In the past, most restoration projects included the same overall cleanup time line
for an entire installation, regardless of the relative threat to human health and the environment
that individual sites caused. In implementing the relative risk approach, DOD is working with
EPA, the states, and the public to review the prioritization process.
A major influence on the selection of projects for remediation is DOD's effort to speed the
economic recovery of communities with closed installations. In prioritizing sites and developing
cleanup plans DOD considers the potential for local job creation and economic development, and
the accelerated pace of site investigation, evaluation, and cleanup efforts. The key features of the
program are:
• A BRAC Cleanup Team (BCT) is established at each installation slated for closure, to
enhance environmental decision-making at the installation. Each BCT includes
representatives from the installation, state environmental regulatory agency, and EPA
Regional Office. These teams have the authority, responsibility, and accountability for
environmental restoration programs at those installations.
• A BRAC Cleanup Plan (BCP) is prepared for each installation slated for closure and
updated annually to reflect new information and changing conditions. The BCP serves as a
comprehensive and consolidated statement of the status of the installation and strategy to
expedite its cleanup. The BCT is responsible for the preparation of this plan.
• A Restoration Advisory Board (RAB) is established in communities where interest is
sufficient to warrant it. RABs are intended to bring together people who reflect diverse
interests within the community, in order to foster the early and continual flow of information
between the affected community, the installation, and the state and federal regulatory
agencies (U.S. DOD, 1994).
• An Environmental Baseline Survey (EBS) is conducted for each closing installation, as
mandated the Community Environmental Response Facilitation Act (CERFA), which is an
amendment to CERCLA. The CERFA requires DOD to identify and document all
uncontaminated parcels of land and installations undergoing closure. These properties
quickly can be turned over to communities for economic reuse.
The BRAC environmental program encompasses more than environmental restoration efforts.
BRAC environmental funding also addresses closure-related environmental compliance, which
includes such actions as the removal of USTs, closure of hazardous waste treatment, storage, and
disposal facilities (TSDFs), radon surveys, and asbestos abatement.
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6.1.3 The Military Munitions Response Program
Decades of military training, weapons system testing, and munitions production has resulted in
the presence of UXO, discarded munitions, and munitions residue on ranges where training and
testing occurred. In addition, excess, obsolete, and damaged munitions have been disposed of at
numerous military installations. In 2001 DOD established the Military Munitions Response
program (MMRP) to manage the cleanup of UXO, waste military munitions (WMM), and
chemical residues of munitions at areas other than operational ranges. DOD has been addressing
these issues since the inception of the IRP and will continue to conduct some incidental
munitions response activities under the IRP. Sites within the MMRP are those where the firing or
disposal of munitions has occurred during training exercises and were not addressed under the
IRP. The 2001 Management Guidance for the Defense Environmental Restoration Program
defines the requirements for the MMRP. The guidance specifies the eligibility, identification,
characterization, tracking and reporting on munitions response sites that is similar to the IRP,
including adding the MMRP data in the Restoration Management Information System (RMIS)
database.
6.2 Factors Affecting the Demand for Cleanup
The following factors could alter the scope of the cleanup as well as the technologies used:
• The pace of remediation is subject to change in response to budgetary and political
developments. The entire FY 2003 DOD budget for environmental restoration is
approximately $2.07 billion. Of these funds, $760.6 million, or approximately 37 percent,
represent BRAC funds (U.S. DOD, 2004).
• The proportion of the environmental restoration budget allocated for cleanup at active
installations and FUDS continues to increase while study and investigation funding
decreases. The FY 2003 budget obligated approximately 59 percent of the funds to cleanup
and 26 percent to studies and investigations. The FY 2005 planned budget estimates that
approximately 70 percent of the funds will go toward cleanup.
• Although DOD believes that most sites have been located, new sites continue to be
identified. The recently established MMRP may impact on the number of new sites.
• DOD classifies all IRP sites in terms of a relative-risk framework, evaluating each site based
on three factors: the nature and extent of the contaminant, the potential for it to migrate, and
receptors that could be impacted by the contamination. The resulting evaluation is not an
estimate of absolute risk or a substitute for a baseline risk or health assessment. It serves as a
basis for discussing the relative risk of sites with involved stakeholders.
• In determining the priorities for funding at all sites, DOD generally addresses the worst sites
first. The projected time line for the remediation of high relative-risk sites is significantly
shorter than the time lines for medium or low risk sites. As of the end of FY 2002, DOD has
achieved its goal of reaching remedy in place (RIP) or response complete (RC) status at 50
percent of its high-relative risk sites. In implementing its priorities, DOD may assign
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
varying levels of priority to different sites on a given installation. This policy may lead to
acceleration of some projects at a given installation while other projects at the same
installation are postponed.
• At closing installations, DOD has been working to complete remediation at all of the current
BRAC sites by the end of FY 2005. However, the department does not anticipate reaching
this goal. It does expect to achieve RIP or RC at 83 percent of BRAC IRP sites. In addition,
for the FY 2005 round of closures the schedule and sequencing of sites may change at the
affected installations.
• DOD policy calls for extensive consultation with EPA, state environmental authorities, local
communities, local planning authorities, and other interested parties in planning and
implementing its cleanup programs. These requirements may influence the sequence of
work and types of technologies selected for a site.
• Changes in regulatory requirements also may affect cleanup goals, technologies used, and
cost.
• Cleanup requirements at many identified sites are uncertain because the nature and
magnitude of contamination is only partially known. As DOD continues to characterize the
contamination problem and accumulate data from site investigations, cleanup needs will
become more clearly defined.
6.3 Number and Characteristics of Sites
Site characteristics data presented in this chapter are based on information in the Defense
Environmental Restoration Program: Annual Report to Congress for Fiscal Year 2003 (U.S.
DOD, 2004) and an analysis of DOD's Restoration Management Information System (RMIS),
which is an important tool DOD uses for program management and oversight. RMIS contains
data provided by the Components on the status of DOD sites for which they are responsible
(U.S. DOD, 2001b). This report uses data from two separate tabulations of RMIS data - one
based on the program status as of September 30, 2003 and one based on the program status as of
September 30, 2001 (U.S. DOD 2004 and 2002a). The 2003 data are presented only at the total
program and component levels. The 2001 data provide more detail regarding the types of sites,
media, and contaminants being addressed by DOD.
6.3.1 Number and Types of Sites
As of September 30, 2003, DOD has identified 30,273 sites (including 3,091 sites on FUDS
properties) located on over 1,700 installations and facilities, that have or had potential hazardous
waste contamination involving soil, groundwater or other media. This total includes 2,817
MMRP sites, mostly on FUDS properties (U.S. DOD, 2004). Response actions were completed
at 21,213 sites (18,584 sites on DOD installations and facilities and 2,629 FUDS). Of the
remaining 9,060 sites (6,827 DOD sites and 2,233 FUDS sites, including MMRP) 6,396 were
planning for or in various phases of investigation, and 2,664 are planning for or are in various
stages of cleanup. The remaining sites also include 1,729 MMRP sites. Exhibit 6-1 shows the
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
status of these sites by component. Exhibit 6-2 shows the breakdown of the 9,060 sites needing
cleanup by component. The most significant change in number of sites between 2001 and 2003
is an almost 85 percent increase in the number of identified MMRP sites.
Exhibit 6-1. Number of POD Sites by Status
DOD
Component
Army
Navy
Air Force
DLA
DTRA
FUDS
TOTAL
Sites Identified
IRP MMRP Total
Sites Sites Sites
12,266 560 12,826
4,715 225 4,940
6,830 261 7,091
553 0 553
1 0 1
3,091 1,771 4,862
27,456 2,817 30,273
Responses
Completed a
10,927
3,220
3,984
453
0
2,629
21,213
Sites Needing Cleanup a
Cleanup Investi-
Planned gat ion
or Under Planned or
way Under way Total
398 1,501 1,899
536 1,184 1,720
1,089 2,018 3,107
64 36 100
1 0 1
576 1,657 2,233
2,664 6,396 9,060
Notes:
a Includes MMRP sites
IRP = Installation Restoration Program; MMRP = Military Munitions Response Program
DTRA = Defense Threat Reduction Agency
Source: U.S. DOD, 2004, Defense Environmental Restoration Program, Annual Report to Congress, Fiscal Year
2003, Spring 2004
DOD derived the estimates on the types and characteristics of sites in the remainder of this
chapter from a combination of data in RMIS, and information provided by the DOD Components
as of September 30, 2001. Although the total number of sites in these tabulations is slightly
lower than the FY 2003 sites indicated above, they depict typical DOD site characteristics.
However, because Sis and RI/FSs have not been completed at a number of these sites, these
estimates, as well as program cost estimates, may be revised either up or down over the next
several years as more information becomes available. Exhibit 6-3 shows the geographic
distribution of these sites, and Appendix Exhibit C-l shows the breakdown by DOD component
and state. California, with 2,011 sites has the most DOD sites needing cleanup.
Chapter 6: Department of Defense Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 6-2. Number of DOD Sites
and Installations Needing Cleanup
3000
W
.2 2500
a» 2000
13
es 1500
w
flj
Cfl
1000
«J
•9 500
3
z
0
1,979
150
=1,
Army
2.737
174
226
131
---
P-
Navy
Air Force
Service
DLA
FUDS
8,974 2,218 to be as of 30, , The of
is In C-1 by
DOD, of the of
.
Exhibit 6-3. Location of DOD Sites Needing Cleanup
Chapter 6: Department of Defense Sites
Page 6-8
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 6-4. Most Common Types of DOD
Sites Needing Cleanup
1200 r-
1,107
Z
Types Of
Notes: These 10 sit© types account for 6,364 (71%) of the 8.974 DOD sites to be remediated as of Sepfefflbef
30, 2001 Appendix Exhibit C-2 gi«es definitions of the 44 site types. Appendix Exhibit C-3 lists the
frequencies o* all 44 site types.
Source: DOD, Office of !he Deputy Under Secretary of Defence (Installations ana Environment),
Management Information System 2001
DOD categorizes its sites
into 44 types, which are
different than the site types
used to categorize the NPL
sites in Chapter 3 of this
report. The DOD system of
site nomenclature uses
categories that include both
activities and physical
descriptions. Exhibit 6-4
shows the number of sites
for each of the 10 most
common site types that
need cleanup. These sites
account for 71 percent of
all DOD sites needing
remediation. Although
some sites may have
resulted from more than
one type of activity, each
site is counted in only one
category. The definitions
of all the site types are
provided in Appendix
Exhibit C-2. Appendix Exhibit C-3 details, by DOD Component, the number of each site type
requiring remediation.
6.3.2 Contaminated Matrices
Of the 8,974 sites estimated to need cleanup in FY 2001, data that identified the type of matrix
(contaminated soil, groundwater, surface water, and sediment) were available for 6,119 sites, or
77 percent. Exhibit 6-5 shows, by DOD Component, the number of sites that contain each type
of matrix. Sixty three percent of the sites have contaminated groundwater and 77 percent have
contaminated soil. Contaminated surface water and sediment are associated with only 15 percent
and 18 percent of the sites, respectively. The totals add to up to more than the number of sites,
since a site may contain more than one type of contaminated media.
The relevant media vary from one site type to another (Exhibit 6-6). For example, contaminated
groundwater was found at 85 percent of fire/crash area sites, but only 42 percent of the storage
area sites. Likewise, 61 percent of underground storage tank sites had soil contamination,
compared to 100 percent of pesticide shop sites and 91 percent of storage area sites. However,
the amount of available data varies from one site type to another. Of the top 10 site types, data
were available for a low of 9 percent of unexploded ordnance sites to a high of 91 percent of
surface disposal areas. Appendix Exhibit C-4 provides the matrices associated with all 44 site
types.
Chapter 6: Department of Defense Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 6-5. Frequency of Contaminated
Matrices at DOD Sites Needing Cleanup
5000
4000
55
"5
43
3
Z
1000
^H Formerly Used Defense Sites
Defense
[IIj Air Foroa
i I Navy
: Army
1,126 (18%)
Surface Water
Matrix
Sediment
on 8,118 for as of 30, , C-4 the
of by C-S the by
DOD, of the of
2001,
Exhibit 6-6. Frequency of Contaminated Matrices
by Site Type at DOD Sites Needing Cleanup
No, of No. of Sites Ground- Surface
Site Type Sites w/Data water Soil Water Sediment
Spill Area
Landfill
Und. Storage Tanks
Other
Unexploded Munitions/Ord.
Surface Disposal Area
Storage Area
Contaminated Groundwater
Disposal Pit/ Dry Well
Fire/Crash
Training Area
1,107
974
840
734
588
563
477
418
414
249
874 (79%)
850 (87%)
459 (55%)
121 (16%)
54 (9%)
512(91%)
417(87%)
321 (77%)
352 (85%)
208 (84%)
58%
74%
80%
8%
5%
53%
42%
90%
54%
85%
78%
74%
61%
14%
7%
82%
91%
54%
64%
85%
12%
27%
5%
2%
2%
16%
10%
17%
13%
19%
13%
26%
7%
3%
2%
22%
14%
14%
18%
19%
Notes: The 1 0 most common site types account for 6,364 or 71 % of the 8,974 DOD sites to be remediated as of
September 30, 2001 . Appendix Exhibit C-4 lists the frequency of contaminated matrices for all 44 site types to
be remediated.
Source: DOD Office of the Deputy Under Secretary of Defense (Installations & Environment), Restoration Management
Information System (RMIS), data as of September 2001 .
Chapter 6: Department of Defense Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
6.3.3 Types of Contaminants
For this study, using available data, the contaminants were grouped into five categories: volatile
organic compounds (VOCs), semivolatile organic compounds (SVOCs), metals, explosives and
propellants, and "other." "Other" primarily includes inorganic elements and compounds such as
asbestos, arsenic, inorganic cyanides, corrosives, pesticides, and herbicides. Exhibits 6-1 and 6-
8 show the major contaminant groups by matrix and DOD Component. The data used to create
these exhibits are in Appendix Exhibit C-5.
The most prevalent contaminant groups in groundwater are VOCs and metals, which appear in
74 percent and 63 percent of DOD groundwater sites, respectively (Appendix Exhibit C-5).
However, while metals appear in the majority of sites in all matrices, VOCs are present in only
45 percent and 49 percent of the soil and surface water sites, respectively. SVOCs and metals
were more consistent across different media than VOCs. SVOCs were found at between 49 and
64 percent of the sites, and metals were found at between 63 and 79 percent of the sites.
Exhibit 6-7. Major Contaminant Groups
by Matrix at DOD Sites Needing Cleanup
100
O
3
i*-
O
**
*
O
I
Sati I "rent
Matrix
Notes Based or fi. 1' 8 sta*s needing dearuo ?c." w^ich data wpw available as q* SeotcTs»r 3C 2CC* A ec-Ttarnhant grauo
may apdea* i" vo'c r-an on« Tat1^ at a ste Append* ExMb-t C-? provioes t<~e S'-paortng oata
S-o:^'ce" DOD.
-
, New g n he • 1 C0 1
e? Sftc'etary of DetG"s*
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
industrial facilities. In addition, some sites contain contaminants that are found less frequently in
industry and that present unique problems for selecting remediation approaches. For example,
over 6 percent of DOD sites contain explosives and some contain low-level radiation. Explosives
are found at 13 percent of Army sites, but at 1 percent of Navy and Air Force sites. Appendix
Exhibit C-5 shows a breakdown of these data into the frequencies of the most common
contaminant groups for each medium and DOD Component.
Exhibit 6-8. Major Contaminant Groups
By DOD Component at Sites Needing Cleanup
100 i—
V)
4D
**
"m
1*R»
o
**4
e
w
o
fce,
«
O.
6C
4C
Artsy Navy AF QIA
DOD Component
Baser; er. 6.1" 8 sites rfiefJ-n-g clean~;OiOr'A-rk:h data were available 9scf September 3C 200' Mere t'-3n
rranrarr Taf-r group cat- appear at a site Append>; "x^ibt C-S p'ovidos ","c s..;-pport-ng data.
' DOD, Cffce o* *e JJep-Jy U^-def SffC'ctary qf Defense (Irs
^o^s a.rd Environnesst). Res:Drat--on Marggenent I "?c •
The frequency of occurrence of contaminants also varies by site type. Exhibit 6-9 shows the
relative frequency of occurrence of the major contaminant groups for five of the seven most
common site types. The "other" site type is not shown nor is the fifth most common site type
unexploded munitions/ordnance since data for this site type is sparse. Metals and VOCs are
common to all five site types, although the frequencies vary. For example the occurrence of
metals ranges from 48 percent of underground storage tanks to 88 percent of landfills. Appendix
Exhibit C-6 shows contaminant group occurrences for all 44 site types.
Chapter 6: Department of Defense Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 6-9. Frequency of Major Contaminant Groups
for the Most Common DOD Site Types Needing Cleanup
IDC
E 4C
CJ
a.
Sp'IIArca Iancf.ll Su.'fece Disposas J"tle.rgro-,."ti Swage Area
At»3 3 V; rage ~"a"Ns
Site
Notes Eta sec oi" 6,1*3 sites need ,"g steanwO^or widish data were available as o* S-sorerr-ayr 3C 20C' More t«an o-1**
conaT----"!}"" 3rc :,p cai- aopear at a sife Append* sx"-ib4 C,-6 st--cv«s t--e b-'eakdcwn of rhe csta fcr alt siJc types
Soj'CC' DOD. Off-ce o? we 3-cp-uty U".-dC'f Secretary of Defense -l^.-stal af.ois af.d Envi-'cnmc-.t). Rosroraf on N'a.rage
Svstesp-, N-cvemfce.'2001
6.4 Estimated Cleanup Costs
DOD annual funding for DERP
and BRAC combined peaked at
$2.5 billion in FY 1994. The FY
2003 funding was $2.1 billion
and planned expenditures for FY
2004 are $1.7 billion. BRAC
accounts for $344 million, or 20
percent of the planned budget
(Exhibit 6-10). Between 2000
and 2005 (estimated), the BRAC
percentage has ranged from 20 to
37 percent. However, BRAC
expenditures may need to
increase again with the addition
of installations from the next
round of BRAC scheduled for
FY 2005. Also, because the
environmental issues at a BRAC
installation require more
Exhibit 6-10. DOD Cleanup
Expenditures: FY 2001-2005
2500
2000
r"
= 1,652.4
;i 355.8
i
2,106.2
/ —
795.9
1.(
Active
BRAC
)92.9
823.9
Installat ons & FUDS j
2,068.4
760.6
1.882.8
r
344.0
1,833.7
328.2"
1000
500
2000 2001 2002 2003 2004 2005
planned estimated
Fiscal Year
a includes DIA prior year unobligated balance available for execution FY 05.
Source: U.S. Department of Defense, Environmental Restoration Program,
Annual Report to Congress, Fiscal Year 2003, 2004.
Chapter 6: Department of Defense Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
extensive consideration than active installations, BRAC cost-to-complete estimates are not
declining at the same rate as the estimates for active installations.
It should be noted that not all BRAC environmental funds are used for site investigation and
remediation. They may also be used for other closure-related environmental expenses such as
environmental compliance and planning. Compliance efforts may include actions such as the
removal of underground storage tanks, closure of hazardous waste TSDFs, and radon surveys.
Planning may involve environmental analyses required under NEPA, or decision-making with
regard to property reuse and redevelopment. On the other hand, BRAC funding is not limited to
the designated amounts.
In the past 19 years, DOD has spent approximately $25 billion on environmental restoration
(U.S. DOD 2004). DOD estimates that, as of September 2003, cost to complete of the 9,060
active installation, FUDS, and BRAC IRP sites still in progress or with anticipated future
assessments planned will be approximately $16.4 billion. The cost to complete for the 987
MMRP sites with investigation or cleanup in progress or where future activity is anticipated is
estimated to be approximately $16.8 billion. Most of these funds are for sites that have not yet
begun remedial action, although some are for sites that have already selected remedies. These
cost-to-completion estimates do not include program management, DTRA, or other
miscellaneous overhead and support costs. Approximately $1.26 billion of the $16.4 billion IRP
estimate is designated for investigation and approximately $2.55 billion of the $16.8 billion
MMRP estimate is designated for investigation. As the MMRP develops, DOD's MMRP cost-to-
complete estimates may change.
DOD's goal is to have remedial action complete at active installations by the end of FY 2014
and at the end of FY 2005 for most of the BRAC sites from pre-2005 BRAC rounds. Because
completion dates have not been determined for some FUDS properties, it is more difficult to
approximate a final cleanup date. With the MMRP still in development, it would be premature to
deal with cleanup time tables.
6.5 Market Entry Considerations
Although policy is determined centrally by the Deputy Under Secretary of Defense (Installations
and Environment), each service is responsible for investigating and restoring its own sites and
manages its own efforts to perform this work. Almost all DOD site assessments and remedial
actions are done by contractors. Generally, there are two groups of contractors: those that work
on site investigations and assessments and those that do remedial actions. Contractors in the first
group seldom do the construction work. Vendors seeking markets for innovative technologies
should take action to ensure that their technologies are considered at the earlier stages of site
investigation and assessment. For example, even if a vendor is precluded from working on the
RI/FS of a particular site, he or she may provide information on their technology to the DOD
officials and contractors working on the RI/FS. References and links to the various DOD offices
involved in technology development and contracting appear at the end of this report. The
following is a summary of the practices of each DOD Component.
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Army
The Army's environmental restoration program is managed under the Assistant Secretary of the
Army (Installations and Environment) (ASA(I&E)) and the Assistant Chief of Staff for
Installation Management (ACSIM). In addition to managing active installations and BRAC
environmental restoration programs, the ASA(I&E) and ACSIM oversee the management of the
FUDS program. Execution of the cleanup is decentralized, with centralized oversight. In both the
active installations and the BRAC programs, the Army installations are the focal point for
restoration activity. The installation environmental coordinator manages the day-to-day
activities, which are executed primarily through the U.S. Army Corps of Engineers (USAGE).
The Corps also implements remediation programs for DLA and the Air Force, and supports EPA,
other federal agencies, and states in environmental restoration activities. The Army
Environmental Center (USAEC), a field-operating agency under AC SIM, provides program
management support and oversight for ACSIM, while the Center for Health Promotion and
Preventive Medicine plays a key role in providing risk assessment expertise and review of
decision documents. For additional information on these Army programs as well as details on the
contracting process, opportunities, and contacts see the links in section 6.7.
Navy
The Navy's environmental restoration program, begins with the Assistant Secretary of the Navy
(Installations and Environment). Under the Assistant Secretary, the Chief of Naval Operations
and the Commandant of the Marine Corps rely on a host of internal and external organizations to
accomplish their DERP goals. The Naval Facilities Engineering Command (NAVFAC) and its
eight Engineering Field Divisions and Activities (EFD/As) nationwide execute the Navy's
restoration program. Remedial project managers (RPMs) are assigned for each installation in
each of the geographic regions. The RPMs reside at the EFD/As but work closely with the
installations and the regulators in planning, setting priorities, establishing budgets, and
coordinating project execution. RPMs and the support staff at the EFD/As manage contracting,
technical coordination, direction, and execution of the work on a regional basis. Installations
maintain ultimate responsibility for their respective restoration programs. Detailed information
and opportunities are available on the NAVFAC web site by command (link in section 6.7).
The Naval Facilities Engineering Service Center (NFESC) provides the Navy with specialized
engineering, scientific, and technical products and services. It is the hub for the Navy's
innovative environmental remedial technology demonstrations, evaluations, and technology
information transfer efforts. NFESC encourages vendors and innovators to submit abstracts on
their environmental technologies for potential application throughout the Navy and DOD. FY
2001 awards for field application projects totaled approximately $3.7 million. The Navy
disseminates this information through regular technical seminars and collaborative efforts with
other agencies and organizations involved in remediation technologies. For additional
information on NFESC, see the link in section 6.7.
Air Force
The Air Force's environmental restoration program begins with the Assistant Secretary for
Installations, Environment and Logistics, with a Deputy Assistant for Installations and another
Deputy Assistant for Environment, Safety, and Occupational Health. The IRP is decentralized
and executed by the nine Force Major Commands. The Air Force Center for Environmental
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Excellence (AFCEE), headquartered at Brooks Air Force Base, Texas, is a field operating
agency of the Civil Engineers of the Air Force. It has seven business lines, each with its own
technical and support staff. AFCEE provides environmental, planning and construction
management services and products. Small businesses can list themselves with the Air Force
Small Business Environmental Database (AFSBED) managed by AFCEE. Information from
AFSBED is available to small and minority businesses, government buyers, and large prime
contractors who use the database regularly. The AFCEE also lists requests for proposal (RFPs)
on its web site as well as on the federal government's general business opportunities site. Air
Force HQ also has a web site dedicated to contracting procedures and opportunities. For more
detailed information, see the links in section 6.7.
6.6 Remediation Technologies
DOD uses a variety of remediation technologies at its hazardous waste sites and actively
conducts and supports research and demonstrations to meet its environmental restoration needs
more efficiently and effectively.
6.6.1 Technologies Used at DOD Sites
EPA's treatment technologies database details the types of treatment technologies used at DOD
NPL sites (EPA 2004). Comprehensive data on technology use at other DOD sites are not
available. The available data from NPL sites may also be indicative of the types of approaches
that might be needed for non-NPL DOD sites. Exhibit 6-11 lists the types of treatment
technologies used in 153 source control applications at DOD sites and 164 groundwater projects.
The most prevalent source control treatment technologies are SVE (31% of applications), in-situ
bioremediation (15%), ex-situ bioremediation (10%), and ex-situ solidification/stabilization
(10%).
DOD groundwater applications fall into three general approaches: monitored natural attenuation
(40% of applications), pump and treat (33%), and in-situ treatment technologies (27%). The
most frequently used groundwater treatments were air sparging (44% of in-situ treatment
applications), in-situ bioremediation (20%), dual-phase extraction (13%), and chemical treatment
6.6.2 Research, Development and Demonstration
The Department's efforts predominantly focus on three major areas:
• Technology transfer,
• Demonstration and certification of emerging technologies, and
• Development of new technologies.
Technology Transfer
DOD uses the latest communications technologies to disseminate information, including the
World Wide Web. In addition to DOD's own web sites, each of the services has at least one site
dedicated to providing information on cleanup programs and technologies. The Army sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
include the U.S. Army Corps of Engineers (USAGE) and the U.S. Army Environmental Center
(USAEC). The Navy sites include the Navy Environmental Leadership Program (NELP) and the
Naval Facilities Engineering Service Center (NFESC). The Air Force Center for Environmental
Excellence (AFCEE) is the key site for information on Air Force programs and technologies.
These sites also provide information and links for innovators and vendors to contact the services
and potentially become part of the military's cleanup process.
Exhibit 6-11. Treatment Technologies Used at POD Sites
Number Number
Remediation Approach Type of Remediation Approach Type of
Projects Projects
Source Control Treatment Technologies
Bioremediation
Bioremediation
Chemical Treatment
Chemical Treatment
Dual-Phase Extraction
Flushing
Incineration
Open Burn/Open
Detonation
Physical Separation
Phytoremediation
Phytoremediation
Soil Vapor Extraction
Soil Washing
Solidification/Stabilization
Solidification/Stabilization
Thermal Desorption
Thermally Enhanced
Recovery
Total Source Control
Treatment Technologies
Ex Situ
In Situ
Ex Situ
In Situ
In Situ
In Situ
Ex Situ
Ex Situ
Ex Situ
Ex Situ
In Situ
In Situ
Ex Situ
Ex Situ
In Situ
Ex Situ
In Situ
16
23
1
1
1
1
19
2
5
1
1
48
2
15
3
11
3
153
In-Situ Groundwater Treatment Technologies
Air Sparging
Bioremediation
Chemical Treatment
Dual-Phase Extraction
In-Well Air Stripping
Permeable Reactive Barrier
Phytoremediation
Thermally Enhanced Recovery
Total In-Situ Treatment
Groundwater Technologies
In Situ
In Situ
In Situ
In Situ
In Situ
In Situ
In Situ
In Situ
20
9
3
6
1
3
2
1
45
Groundwater Approaches Summary
Pump and Treat
In-Situ Groundwater
Monitored Natural Attenuation
Total Groundwater
54
45
65
164
Source: U.S. EPA, 2003. Annual Status Report Remediation Database, Office of Solid Waste and Emergency
Response, Technology Innovation Office, http://epa.gov/tio/technologies
Chapter 6: Department of Defense Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
DOD has been active in facilitating technology transfer among development and demonstration
programs and technology users. For example, DOD is working with the Federal Remediation
Technologies Roundtable (FRTR), an interagency organization created to facilitate collaboration
among federal agencies, such as the Department of Energy (DOE) and EPA, which also have a
stake in technology development. The FRTR publishes a variety of documents on remediation
technologies, including tool guides, case studies, and reports which are available on their web
site.
Demonstrations and Certification of Emerging Technologies
The Department has two programs that research and assess technologies, the Strategic
Environmental Research and Development Program (SERDP) and the Environmental Security
Technology Certification Program (ESTCP). SERDP is a program in partnership with EPA and
DOE which focuses on identifying, developing, and implementing environmental restoration
technologies that minimize or eliminate the environmental impacts of DOD's activities. ESTCP
is a program that demonstrates, tests, and validates new technologies. Each program introduces
several cutting-edge restoration technologies. For example, in FY 2001 DOD supported a system
that combines soil washing with phytoremediation to clean lead-contaminated soil from small
arms ranges, and extended a successful pilot biowall treatment trench to clean up
trichloroethene-contaminated hot spots.
With the increased attention to munitions cleanup, the Department plans to continue its
significant investment in advancing the state of munitions response technology. To date, the
focus has been on technologies related to site characterization. The Department is now planning
to expand its technology development to address the hardware, methods, and scientific
understanding to address other aspects of munitions response. In addition to the OSD programs,
SERDP and ESTCP, that determine areas for technology investment, the Army, as the lead
service for UXO technology development, is investing in research on improvements to detection
hardware systems.
Each of the services also maintains technology development and demonstration programs. The
Army Environmental Center, the Naval Facilities Engineering Service Center, and the Air Force
Center for Environmental Excellence are leaders in cleanup technology demonstrations.
6.7 References
U.S. Congress, 1988, 1990. Base Realignment and Closure Acts of 1988, P.L. 100-526 (BRAC
88) and 1990, P.L. 101-510 (BRAC 91, 93, and 95).
http://www.dtic.mil/envirodod/brac/index.html
U.S. DOD, 1994. Restoration Advisory Board (RAB) Implementation Guidelines, Memorandum
Deputy Under Secretary of Defense (Environmental Security), U.S. Department of Defense,
October 13, 1994.
U.S. DOD, 1999. Relative Risk Site Evaluation, U.S. Department of Defense, Deputy Under
Secretary of Defense (Installations and Environment), July 1999.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
U.S. DOD, 200 la. Management Guidance for the Defense Environmental Restoration Program,
U.S. Department of Defense, Deputy Under Secretary of Defense (Installations and
Environment), September 2001. http://www.dtic.mil/envirodod/
U.S. DOD, 2001b. Restoration Management Information System (RMIS), U.S. Department of
Defense, Deputy Under Secretary of Defense (Installations and Environment).
U.S. DOD, 2002a. Defense Environmental Restoration Program: Annual Report to Congress for
Fiscal Year 2001, U.S. Department of Defense, Deputy Under Secretary of Defense
(Installations and Environment), Spring 2002. http://www.dtic.mil/envirodod
U.S. DOD, 2002b. DOD Environmental Technology Program: A Report to Congress for Fiscal
Year 2001, U.S. Department of Defense, Deputy Under Secretary of Defense (Installations and
Environment), March 2002. http://63.88.245.60/Derparc_FY01/DERP/indexEight.htm
U.S. DOD, 2002c. Restoration Management Information System (RMIS) Data Dictionary, U.S.
Department of Defense, Deputy Under Secretary of Defense (Installations and Environment),
April 2002. http://www.dtic.mil/envirodod
U.S. DOD, 2004. Defense Environmental Restoration Program: Annual Report to Congress for
Fiscal Year 2003, U.S. Department of Defense, Deputy Under Secretary of Defense
(Installations and Environment), Spring 2004. http://www.dtic.mil/envirodod/
U.S. EPA (Environmental Protection Agency), et al, June 2000. Site Remediation Technology
InfoBase: A Guide to Federal Programs, Information Resources, and Publication on
Contaminated Site Technologies, 2nd Edition, prepared by the member agencies of the Federal
Remediation Technologies Roundtable. http://www.frtr.gov
U.S. EPA, et al, December 2001. Federal Remediation Technologies Roundtable: Creating
Tools for the Hazardous Waste Cleanup Community, prepared by the member agencies of the
Federal Remediation Technologies Roundtable, December 2001. http://www.frtr.gov
U.S. EPA, et al, April 2002. Remediation Technologies Screening Matrix, 4th Edition, prepared
by the member agencies of the Federal Remediation Technologies Roundtable.
http://www.frtr.gov
U.S. EPA, et al, 2002. Abstracts of Remediation Case Studies, 1995-2002, Volumes 1 - 6,
prepared by the member agencies of the Federal Remediation Technologies Roundtable.
http://www.frtr.gov
U.S. EPA, 2003. Annual Status Report Remediation Database, tabulation done in June 2003,
Office of Solid Waste and Emergency Response, http://epa.gov/tio/technologies
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Related Links:
DOD documents on environmental cleanup:
Office of the Secretary of Defense - Cleanup: http://www.dtic.mil/envirodod/
Defense Environmental Network & Information System: http://www.denix.osd.mil
DOD business opportunities:
Federal registry of business opportunities: http://www.fedbizopps.gov
DOD central contractor registration: http://www.dodbusopps.com/egov/dod.ccr.html
National Environmental Technology Test Sites (NETTS) Program:
http ://www. serdp. org/NETT S/
Environmental Security Technology Certification Program: http://www.estcp.org
Army
US Army Environmental Center: http://www.aec.army.mil
US Army Corps of Engineers: - http://www.usaOO.army.mil
USAGE Environmental Programs Contracting Opportunities:
http://www.hq.environmental.usace.army.mil/tools
Navy
Naval Facilities Engineering Service Center: http://www.nfesc.navy.mil
Naval Facilities Engineering Command: http://www.navfac.navy.mil
Naval Environmental Leadership Program (NELP): http://nelp.navy.mil/
Air Force
Air Force Center for Environmental Excellence: http://www.afcee.brooks.af.mil/
Air Force Small Business Environmental Database: http://www.brooks-
smallbusiness.com/afsbed.htm
Air Force HQ Contracting: http://www.safaq.hq.af.mil/contracting
Air Force HQ Environmental Restoration Branch: http://www.il.hq.af.mil/ilevr.html
Chapter 6: Department of Defense Sites Page 6-20
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Chapter 7
Demand for Remediation of
Department of Energy Sites
One of the most serious and costly environmental remediation tasks facing the federal
government is the cleanup and restoration of more than 100 installations and other locations that
are the responsibility of the U.S. Department of Energy (DOE). DOE's "legacy" of
environmental contamination at these sites has resulted from activities related to the
development and production of nuclear weapons and other technologies that began in the 1940s
with the Manhattan Project and continued through the Cold War. Nuclear weapons production
halted in the United States in 1989, initially to correct widespread environmental and safety
problems; later it was stopped indefinitely because of the end of the Cold War (U.S. DOE
1996a).
DOE properties contain unique radiation
hazards, huge volumes of contaminated
soil and water, and a large number of
contaminated structures ranging from
evaporation ponds to nuclear reactors to
chemical plants used for the extraction of
nuclear materials (U.S. DOE 1996b).
DOE estimates that as of the end of
fiscal year (FY) 2004, the remaining cost
for restoration of its legacy sites would
be $111 billion (U.S. DOE 2004).
Hazardous waste remediation, including
the cleanup of buried waste, soil,
groundwater, surface water, and facility
decontamination and decommissioning
(D&D) account for about one-third of
the total, or about $35 billion. DOE's
most recent estimate for cleaning up its
contaminated sites, under its accelerated
cleanup initiative, aims for the
completion of cleanup at all release sites
by 2035. These costs are significantly
lower than estimates in the FY 2002 and
2003 budgets because of a cost reduction
made possible by management and
organizational reforms within DOE. The
remainder of DOE's environmental management costs are for activities such as waste
management; facility stabilization; nuclear material stabilization, packaging, and transportation;
program planning and management; landlord activities; and technology development.
Highlights
* DOE has estimated that the cost to complete active
remediation of wastes at most of its legacy sites will be
$35 billion, although this figure is probably an
underestimate because it does not include the cost of
addressing contamination problems that currently lack
viable cleanup technologies.
• DOE aims to complete active cleanup at most of its
sites by 2035.
• Five installations account for 73% of expected costs.
• An estimated 40 million cubic meters of soil and 1.7
trillion gallons of groundwater will require remediation.
• Approximately 3,000 surplus DOE facilities await D&D.
• Long-term stewardship will be needed at up to 129
installations and DOE has established the Office of
Legacy Management to address this need.
• In 2002, DOE began a major initiative to accelerate
cleanup of its sites, prioritize risks, improve contracting
practices, and reduce program costs. This initiative will
profoundly affect the scope and scheduling of cleanup
work, and the types of remediation technologies used.
• Achievement of DOE's cleanup goals is largely
contingent upon receipt of additional funding yet to be
approved by Congress in future years.
• The full extent of the cleanup needed is still uncertain
because the nature and extent of contamination at
some sites have not been characterized and final
remedial action or regulatory decisions have not been
made for many sites still awaiting cleanup.
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These figures are likely an underestimate of the total DOE cleanup cost because they do not
include all cleanup activities needed, such as the cost of cleaning up new releases of
contaminants, remediating facilities that are still in operation, or contamination problems that
currently lack viable cleanup technologies, such as certain groundwater contamination and
nuclear test sites. Nor does the current estimate include the costs of monitoring and maintaining
site remedies over the thousands of years that radioactive hazards will remain. DOE's
environmental cleanup program offers an enormous opportunity for firms that provide
remediation services.
7.1 Program Description
Between the inception of its environmental management program in 1989 and FY 2003, DOE
has spent over $70 billion on establishing the cleanup program, developing the management and
remediation approaches to be employed, and cleaning up the less complex sites (U.S. DOE
2002d, 2003a, and 2004). The program constitutes nearly a third of the Department's budget, and
remediation and restoration account for about a third of the cleanup program budget.
Programs to clean up environmental damage resulting from Cold War nuclear weapons
development are managed by DOE's Office of Environmental Management (EM), established in
1989. In 2003, DOE established an Office of Legacy Management to focus on the long-term care
of legacy liabilities of former nuclear weapons production areas following cleanup completion of
the surface areas at each site. In the 2005 Budget Request to Congress, the Department proposes
to create the Office of Future Liabilities, which will focus on the cleanup of facilities and
contaminated media at active sites that fall outside the EM scope.
Information on the program's activities are available in the justifications in DOE's budget
requests to Congress for the fiscal years from 2000 to 2005. Additional background is available
from DOE's Baseline Environmental Management Report (BEMR), a multi-volume study
published in 1995 and 1996.J
EM must ensure that environmental legacies of the Cold War are addressed and resolved in a
manner that does not impede future national security missions, and that the nation's radioactive
wastes are disposed of permanently and safely (U.S. DOE Web 2003b). The EM program
historically has been managed as a loose association of individual field sites (U.S. DOE 2002d).
EM provides budget and program support to nine Operations/Field Offices, each of which has
the responsibility for directing cleanup work at one or more sites (U.S. DOE 1998). The offices
are located in Albuquerque (NM), Chicago (IL), Idaho Falls (ID), Las Vegas (NV), Oakland
(CA), Oak Ridge (TN), Miamisburg (OH), Rocky Flats (CO), Richland (WA), and Aiken (SC).
The Field and Operations Offices oversee all activities to assess and clean up inactive hazardous
and radioactive facilities—such as reactors, laboratories, equipment, buildings, pipelines, waste
The BEMR report was a key source of information for the 1996 edition of this study. The BEMR combined an
analysis of current environmental management data with estimates of the future costs of the EM program. This
analysis was replaced by the Accelerating Cleanup: Paths to Closure report, which established a baseline schedule
and cost for each project. The information in Paths to Closure was updated in 1999 and 2000, but no comparably
detailed information has been published since the introduction of DOE's Central Internet Database in 2000.
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treatment systems, and storage tanks—and sites at all DOE installations, as well as at some
non-DOE locations that have been specified by Congress.
The Albuquerque, Chicago, Nevada, Oakland, Ohio, Oak Ridge, Rocky Flats, and Small Sites
Closure Offices are responsible for cleanup, facility decommissioning, and/or waste packaging at
110 (Fiori & Jones 2000) of DOE's 114 geographic sites. Many of these sites will have no
continuing DOE presence after closure, except for stewardship activities. DOE presence will
continue long term at the Idaho and Savannah River Sites and Hanford's Office of River
Protection and Richland Operations Office, where the mission encompasses remediation of
contaminated land, disposition of facilities for alternate uses, final decontamination and
decommissioning, and operational oversight (as landlord) for the facilities and programs.
Environmental restoration of the DOE complex involves the following activities:
• Deactivation and decommissioning—decontamination and safe disposition of deactivated
and surplus equipment, buildings, and other facilities;
• Remedial actions—site characterization to identify the contaminants and physical properties
at a site, and remediation activities to stabilize, reduce, or remove site contaminants;
• Long-term surveillance and maintenance (S&M)—monitoring the site to ensure that
contamination has been successfully addressed and providing maintenance services to
ensure the long-term integrity of containment remedies or continued effective operation of
pump-and-treat remedies; and
• Stabilization of high-risk materials—treatment and/or packaging of highly radioactive
materials.
These restoration activities are described in greater detail in the following subsections.
7.1.1 Deactivation and Decommissioning of Surplus Facilities
DOE constructed over 20,000 facilities to support nuclear weapons production and other
activities. More than 3,800 of them have been declared surplus to date, and approximately 3,000
await D&D. These facilities have exceeded their design life and no longer serve a mission for
DOE. Many of them are contaminated with radioactive materials, hazardous chemicals, asbestos,
and lead, including lead-based paint. Because of the potential for release of radioactive and
hazardous materials to the environment, these surplus facilities must be monitored, maintained,
and guarded. Four major types of structures require deactivation and decommissioning-reactor
facilities, radionuclide separation facilities, fuel and weapons component fabrication facilities,
and laboratories.
Deactivation involves actions that render a facility safe and stable until it can be
decommissioned. It includes processes used to place nuclear materials and chemicals,
equipment, and operating systems into a low-risk, low-cost and mostly passive condition.
Decommissioning, which takes place after deactivation, includes surveillance and maintenance,
decontamination, and/or dismantlement. It involves stabilizing, reducing, or removing
radioactive and/or other types of contamination, and can consist of dismantling a facility,
entombing or covering part or all of the facility, or converting a facility for other uses.
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Based on the FY 2005 DOE Congressional Budget Request (U.S. DOE 2004) the remaining cost
(remaining life cycle cost) for decontamination and decommissioning at legacy waste sites is
about $20 billion, as of the end of FY 2004.
EM typically performs decommissioning under CERCLA as a "non-time-critical removal
action." In fact, there are few regulatory compliance agreements for D&D at DOE sites. Most
sites' Federal Facility Agreements deal with waste from weapons production, such as high-level
waste, transuranics, mixed low-level waste, and contaminated soil and groundwater problems,
not with contaminated buildings or other structures (U.S. DOE Web 2002).
7.1.2 Remedial Actions
Remedial actions involve the containment, treatment, or removal of radioactive and/or hazardous
materials and pollutants in free product form or in soil, sediment, fractured bedrock, and
groundwater. An estimated 3 million cubic meters of solid radioactive and hazardous wastes
have been buried or otherwise released to the subsurface throughout the DOE complex. As a
result of the release of these materials, an estimated 40 million cubic meters of soil and 1.7
trillion gallons of groundwater contain contaminants above an action level and will require
remediation (U.S. DOE 2000). The largest
contamination challenges are found at the
Idaho, Oak Ridge, Hanford, Rocky Flats,
and Savannah River sites (U.S. DOE
2002e).
The typical wastes found at DOE sites are
shown in the text box. Contaminants include
hazardous metals such as chromium,
mercury, and lead; radioactive laboratory
and processing waste; explosive and
pyrophoric materials; solvents; and
numerous radionuclides.
Sources of contaminants include plumes
emanating from seepage basins, cribs,
leaking tanks, and landfills; airborne
releases deposited on the soil surface by
wind or precipitation; wells used for
underground injection of wastes; and
waste-disposal areas with contaminants
mobilized by precipitation, groundwater, or
surface water flowing through the site.
Burial of low-level radioactive waste,
mercury, lead, spent solvents, explosives,
and contaminated equipment has resulted in
large inventories of poorly characterized
land-stored waste.
DOE Waste Types:
hazardous—containing hazardous constituents
but no radionuclides;
mixed—containing both hazardous and
radioactive materials
low-level—radioactive waste not classified as
high-level waste, TRU, or spent nuclear fuel.
"Low" does not refer to its level of radioactivity
11 e(2) byproducts—mill tailings containing
very low concentrations of naturally occurring
alpha-emitting radionuclides in large volumes of
generally soil-like materials
"orphan waste"—those waste streams for
which disposal pathways have not been
identified;
transuranic (TRU)—containing plutonium,
americium, and other elements with atomic
numbers higher than uranium; and
high-level—defined based on its source rather
than its constituents and their concentrations.
Includes fission products, traces of uranium and
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DOE considers cleanup at a site "complete" when it meets the following conditions:
• Deactivation or decommissioning of all facilities listed in the EM program has been
completed, excluding any long-term surveillance and monitoring;
• All releases to the environment have been cleaned up in accordance with agreed-upon
cleanup standards;
• Groundwater contamination has been contained, and long-term treatment or monitoring is in
place;
• Nuclear material and spent fuel have been stabilized and/or placed in safe long-term storage;
and
• Legacy waste (i.e., waste produced by past nuclear weapons production activities, with the
exception of high-level waste) has been disposed of in an approved manner.
After closure, many DOE sites will require long-term surveillance and maintenance.
7.1.3 Long-Term Surveillance and Maintenance
Even after site closure, DOE will maintain a presence at most sites to ensure that the remedy
remains effective, an important responsibility at sites where contaminants have been reduced or
contained, but not eliminated. DOE has estimated that up to 129 geographic locations (e.g.,
installations) will require long-term stewardship (U.S. DOE 200Ic). Such long-term stewardship
will be active at the majority of sites with groundwater monitoring and/or treatment, containment
systems such as covers and subsurface barriers, and passive or active institutional controls. At
sites released for unrestricted use, stewardship will be passive, involving only maintenance of
records. The extent of long-term stewardship to be conducted is determined by DOE and other
stakeholders based on the end state reached at each site. In some cases, the cleanup plan
addresses an entire geographic site; in other cases, long-term stewardship may occur at a portion
of a large site long before cleanup of the entire area is completed.2
The Office of Legacy Management (LM) has responsibility for sites that have been closed and
no longer support DOE's ongoing national security, energy, and science missions, such as the
EM closure sites (Pinellas Plant, Weldon Spring), Uranium Mill Tailings Remedial Action
(UMTRA) sites, and Formerly Utilized Sites Remedial Action Program (FUSRAP) locations
where remediation is complete. As more sites are successfully remediated and closed, LM will
manage the land and associated resources as a federal trustee, preserve records and information,
perform surveillance and maintenance associated with environmental remedies, such as
long-term pump and treat, and manage post-closure liabilities.
DOE also conducts surveillance and maintenance activities during the environmental restoration process. For
example, S&M activities may be conducted to prevent worker, public, and environmental exposure to potential
hazards at a site awaiting D&D. For some facilities - particularly reactors and large processing canyons - an initial
"interim" phase of long-term stewardship is needed after a facility has been stabilized, but where further remedial
action or D&D is not expected to occur for a significant period of time (U.S. DOE 2001 b).
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7.1.4 Stabilization of High-Risk Materials
One of the most costly and dangerous components of DOE's cleanup effort—the stabilization of
high-risk materials—presents a challenge unique in environmental restoration. High-risk
materials include all highly radioactive wastes stored in tanks, spent nuclear fuel, all special
nuclear materials, and some transuranic waste. A major cost driver in the EM complex is the
plan to retrieve, treat, and vitrify waste in the tank farms, which alone is projected to cost $20
billion (U.S. DOE 2004). Special nuclear materials, primarily plutonium metals and oxides and
highly enriched uranium, must be stabilized and then packaged for long-term storage. All spent
nuclear fuel must be treated and/or packaged and placed in dry storage. Some transuranic waste
must be treated to remove organics before it is packaged for shipment and stored in the Waste
Isolation Pilot Plant. Additionally, all the structures from which high-risk materials have been
removed must undergo decontamination and decommissioning (U.S. DOE 2002d).
7.1.5 Regulatory Requirements and Compliance Agreements
DOE installations typically have multiple areas of contamination regulated by either CERCLA,
RCRA Corrective Action provisions, RCRA underground storage tank provisions, or all three.
DOE also is required to consult with EPA and consider state environmental requirements and the
needs of all stakeholders in designing and conducting remediations at facilities for which it is
responsible. The interface between the regulatory authorities is determined by circumstances at
specific sites, such as the sources and causes of the contamination, whether the installation is an
NPL site (DOE has 19 currently on the NPL and 2 deleted), whether it is operating under a
RCRA permit to manage hazardous waste, the anticipated future land use, the interest of nearby
communities, and state actions and laws. DOE works with all stakeholders at its facilities to
integrate and reconcile all the requirements and agree on an approach to address the
environmental problems. The agreements are typically summarized in a compliance agreement,
which is used for the majority of DOE cleanup work.
Compliance agreements provide for establishing legally enforceable schedule milestones that
govern the work to be done and include, but are not limited to, Federal Facility Agreements,
Interagency Agreements, settlement agreements, consent orders, and compliance orders. The 70
compliance agreements at DOE sites vary greatly but can be divided into three main types: (1)
agreements specifically required by CERCLA to address cleanup of federal NPL sites or by
RCRA to address the management of mixed radioactive and hazardous waste at DOE facilities,
(2) court-ordered agreements resulting from lawsuits initiated primarily by states, and (3) other
agreements, including state administrative orders enforcing state hazardous waste management
laws (U.S. GAO 2002a).
Compliance agreements are site-specific and are not intended to provide a mechanism for DOE
to use in prioritizing risks among the various sites. The agreements reflect local DOE and
community priorities for addressing environmental contamination at individual sites and are not
designed or developed to consider environmental risk from a DOE-wide perspective.
The first class of compliance agreements, those specifically required by CERCLA or by RCRA,
are in effect at all of DOE's major sites. They tend to cover a relatively large number of cleanup
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activities and include most of the schedule milestones that DOE must meet. By contrast,
agreements that implement court-ordered settlements exist at only a few DOE sites, tend to focus
on a specific issue or concern, and have fewer schedule milestones. These agreements are
typically between DOE and one or more states. The remaining agreements are based on state or
federal environmental laws and address a variety of needs, such as cleaning up hazardous
materials spills or remediating groundwater contamination. Some of these agreements may
specify only a few milestones, while others incorporate detailed schedules and approaches.
7.1.6 Policy Initiatives: The Top-to-Bottom Review
Early in 2002, EM completed a critical assessment of its program—the "Top-to-Bottom
Review." The Review's major observation was that EM had been oriented toward managing risks
rather than actually reducing them. Based upon the Review's recommendations, DOE began a
major initiative to accelerate cleanup of its legacy wastes by at least 30 years, prioritize risks,
improve its contracting practices, and reduce program costs. Under this initiative, DOE would
complete cleanup projects at some sites more quickly; revise other cleanup plans, such as
reclassifying certain wastes to different risk categories to speed cleanup and reduce cost; and
concentrate funding more on cleanup and less on maintenance and non-cleanup activities (U.S.
GAO 2002b).
DOE expects this initiative to profoundly affect the scope and scheduling of its cleanups. As of
mid-2004, DOE has signed letters of intent with state and federal regulators that outline an
agreement in principle to accelerate cleanup at Amchitka Island (AK), Hanford (WA), Idaho
National Engineering Laboratories (ID), Oak Ridge Reservation (TN), Nevada Test Site (NV),
Paducah (KY), Pantex (TX), Pinellas (FL), and Savannah River (SC). Increased funding has
been approved for this purpose. Of the remaining sites, some will not be able to accelerate the
cleanup schedule, either for technical reasons or because closure is already near term.
Under the initiative, DOE is promoting a new "risk-based" cleanup strategy that would assist in
prioritizing risk—and thereby prioritize cleanups—among the various sites on a DOE-wide
basis. If implemented, this approach could alter the funding balance among DOE sites.
The initiative also has the potential to increase the use of remediation approaches that leave more
wastes on site than previously planned, thereby reducing remediation costs at some projects. For
example, one proposal is to change the current practice of classifying waste as high level, based
on the treatment process that created it, to classifying the waste based on its actual composition.
This change would result in the reclassification of much of DOE's high-level waste into
low-level mixed or transuranic waste, which would significantly affect the cost of treatment and
packaging and disposition.
7.2 Factors Affecting Demand for Cleanup
The nature, extent, and timing of the DOE cleanups is determined by the annual budget provided
by Congress, DOE policy and resource allocation, the types of waste and contaminated media at
DOE properties, compliance agreements with states and other stakeholders, and the provisions of
CERCLA, RCRA, and other federal and state environmental statutes.
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DOE expects its accelerated site cleanup initiative (Section 7.1.6) to profoundly affect the
scope and scheduling of its cleanups. DOE has signed letters of intent with a number of state
and federal regulators, and is prioritizing risks, improving its contracting practices, and
implementing other measures to reduce program costs and accelerate cleanups. These
measures may lead to the reclassification of some waste to a different risk category and
concentrate funding more on cleanup and less on maintenance and non-cleanup activities.
Under the initiative, DOE is promoting a "risk-based" cleanup strategy that would assist in
prioritizing risk among the various sites on a DOE-wide basis. In addition, it is likely to
affect the types of remedies selected, such as increasing the use of remediation approaches
that leave more wastes on site than previously planned.
DOE may need to renegotiate and modify compliance agreements to implement many
aspects of the new initiatives. Federal facility compliance agreements as well as
environmental laws and regulations drive DOE's cleanup decisions. The effect of
compliance agreements on certain aspects of DOE's initiative, especially its proposal to
reclassify waste into different risk categories to increase disposal options, is unclear.
Reclassifying the waste may involve the concurrence of the Nuclear Regulatory
Commission, EPA, and other regulatory agencies. Securing the concurrence of all parties,
plus potential legal challenges by stakeholders, can delay or alter cleanup decisions.
Cleanup schedules are heavily dependent upon the availability of funds. DOE's estimate that
it can complete remediation of legacy wastes at all DOE properties by 2035 could be
lengthened or shortened, depending on the funds appropriated by Congress. A lack of funds
could limit DOE's ability to meet milestones of some existing compliance agreements
between DOE and other stakeholders, as well as limit DOE's ability to commit to new
agreements. In 2002, Congress increased the EM appropriation by $800 million (in a special
Cleanup Reform Account) to help DOE meet its 2035 cleanup completion goal.
Achievement of the accelerated cleanup goals is largely contingent upon receipt of
additional funding, yet to be approved by Congress, in future years (U.S. DOE 2003b). If
milestones cannot be achieved because of budget shortfalls, stakeholders may renegotiate
compliance plans.
The type and extent of remediation to be undertaken will be affected by the cleanup
standards/end states that are to be applied. At many sites, it is difficult to define the extent of
cleanup work needed. The decision usually requires balancing potential land uses with the
feasibility of alternative cleanup and long-term stewardship approaches. DOE determines
end-state goals for a site only after consulting with the regulatory agencies, state and local
authorities, and other affected parties. Communities must address how the land is to be used,
and regulators must determine an acceptable level of residual contamination.
Current site assumptions about planned end states do not rule out future decisions to change
the target end state from that envisioned under those assumptions. The ultimate end state of
a site may be revised due to the development of new technologies, more economical cleanup
approaches, the availability of additional resources, and changes in the cleanup agreements.
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• Uncertainty about the nature and extent of contamination at some sites contributes to the
difficulty in defining the extent of cleanup work needed. Though nearly all of the release
sites have been at least partially characterized, final remedial action and/or regulatory
decisions have not been made for most sites still awaiting cleanup. In estimating the
environmental liability related to each site, DOE used site-specific assumptions regarding
the amount and type of contamination and remediation technologies that will be employed
(U.S. DOE2003b).
• DOE assumes only existing (baseline) technologies, such as groundwater pump and treat, to
be available for estimating cleanup costs where they are applicable. Estimates are based on
remedies considered technically and environmentally reasonable and achievable. Estimated
cleanup costs at sites for which there is no current feasible remediation approach are
excluded from the baseline estimates, though applicable stewardship and monitoring costs
for these sites are included. The cost estimate would be higher if some remediation were
assumed for these areas; however, absent effective remedial technologies for the sites, no
basis for estimating costs is available. Significant areas for which cleanup costs are excluded
include the nuclear explosion test grounds at the Nevada Test Site; large surface water
bodies, including the Clinch and Columbia rivers; and contaminated groundwater for which,
even with treatment, future use will remain restricted (U.S. DOE 2003b).
• The program scope may increase in the future due to the transfer of additional facilities
and/or sites, further affecting the uncertainty of out-year work scope and schedules. For
example, DOE sought and received funding and authority from Congress in 2001 to
remediate a uranium mill tailings site at the former Atlas mill near Moab, Utah. The cleanup
will be conducted under the Uranium Mill Tailings Radiation Control Act of 1978, which is
the same authority used for the 22 sites that were remediated in the DOE UMTRA Project.
These factors indicate that there are many uncertainties inherent in the remediation of the
facilities for which DOE is responsible, despite significant efforts in recent years to establish the
scope of work for DOE's environmental management program. The work scope projections
address long periods of time, which compounds the uncertainty.
7.3 Number and Characteristics of Sites
EM historically has been responsible for environmental restoration at 134 "geographic sites,"
which are distinct locations that generated waste or were contaminated by DOE or predecessor
agency activities. Geographic sites range in size from as small as a football field to larger than
the state of Rhode Island, and usually correspond to a DOE installation or campus, such as the
Hanford Reservation in Washington or Oak Ridge Reservation in Tennessee. Altogether, they
encompass an area of over two million acres—equal to the size of Rhode Island and Delaware
combined. At the beginning of 1998, cleanup responsibility for 21 sites managed by EM under
FUSRAP was transferred to the U.S. Army Corps of Engineers, leaving 113 geographic sites in
the EM program (Applegate & Dycus 1998). The addition in 2001 of the former Atlas uranium
mill site brought the number to 114 geographic sites located in 31 states and one territory (U.S.
DOE 2000).
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DOE uses the term "release site" to mean a specific area where contaminants may have been
spilled, disposed of, or abandoned at an installation. A geographic site can contain many release
sites, or it may contain none at all; for example, the contaminated areas at the General Electric
site (CA) consist of a hot cell and a glove box enclosure. According to DOE's 2003 budget
request to Congress, of the 10,5273 release sites identified so far, 5,227 of them were cleaned up
by the end of 2002. Completion of active cleanup signifies that mobilization to remove or treat
contaminated soil, debris, and structures has ended. It does not necessarily signify that the site
has been completely cleaned up. Groundwater cleanup, which could take decades, might yet
remain to be accomplished.
Despite the complexity and size of the challenge, substantial progress has been made in cleaning
up many sites over the past decade. For example, DOE's UMTRA project successfully concluded
surface cleanup with the remediation of the 22nd and final uranium mill tailings site at Maybell,
Colorado, in 1998; a second phase of the project aims to achieve groundwater compliance at the
sites. At the beginning of FY 2003, DOE had completed active cleanup at 76 of the 114
geographic sites. Extensive work remains to be completed at some of the 38 remaining locations,
particularly at the Hanford facility and the Savannah River Site.
DOE plans to complete cleanup at an additional 13 geographic sites by the end of FY 2006. At
the sites remaining after 2006, which includes the largest ones, DOE will continue treatment of
the remaining legacy waste streams and management of legacy nuclear materials, including
nuclear material stabilization and disposition. To protect human health and the environment, the
Department will implement long-term stewardship activities after active cleanup is completed at
the sites. DOE expects to complete most high-risk work by 2012 and all currently defined work
by 2035 (U.S. DOE 2003b).
Exhibit 7-1 shows the major DOE installations where cleanup of release sites and/or facilities
has not been completed.4 The locations that have only wastes to package, with no release sites or
facilities to remediate, do not appear in the exhibit. About half of the release sites have been
cleaned up, and roughly 905 of the remaining sites are expected to have cleanup completed by
2015, 250 more by 2025, and the remaining 3,135 by 2035. Estimates for several hundred release
sites are not available. The Nevada Test Sites and the Hanford facility (including the Office of
River Protection) account for 59 percent of the release sites remaining to be remediated. Other
installations with large numbers of release sites include Los Alamos National Laboratory (795
sites), the Oak Ridge Reservation (374 sites), and the Savannah River Site (198 sites).
DOE estimates of the number of release sites discovered to date vary: the number is reported as 9,995, 10,527,
10,082, and 10,374 in the 2002, 2003, 2004, and 2005 budget requests, respectively.
4 The numbers of release sites shown in Exhibit 7-1 are slightly lower than reported above because specific data
for the "Other" category were not available.
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Exhibit 7-1. Remaining Release Sites and D&D Facilities by Location
Installation
No. of Sites Release Facili-
Re- No. of Comple- Facilities Sites ties Estimated
lease Facili ted by Completed Remain- Remain- Comple-
Sites ties 2004 by 2004 ing ing tion Date
Lab for Energy-Rel. Health Res.
Ashtabula Env. Mgmt. Proj., OH
Columbus Env. Mgmt. Proj., OH
Fernald Env. Mgmt. Proj., OH
Kansas City Plant
Lawrence Berkeley Natl. Lab
Lawrence Livermore Natl. Lab
Mound/Miamisburg Mgmt. Proj., OH
Rocky Flats Env. Tech. Center, CO
Sandia National Labs
Stanford Linear Accelerator Ctr.
Energy Technology Eng. Center
Brookhaven National Lab, NY
Lawrence Livermore Site 300
Pantex Plant
Argonne National Lab, East
Atlas Site (Moab)
West Valley Demo. Proj., OH
General Electric Vallecitos
Separations Process Research Unit
Los Alamos National Lab
Oak Ridge Reservation, TN
Portsmouth GDP, OH
Savannah River Site
Nevada Test Site & Off-Sites
Paducah GDP, KY
Hanford Site
Idaho Nat. Eng. & Env. Lab
Office of River Protection (Hanford)
Total
17
3
2
6
43
181
120
178
240
263
20
10
76
73
237
443
1
1
0
6
2,124
654
163
515
2,082
237
1,618
270
322
1
32
15
30
0
0
0
135
377
1
0
26
10
0
5
78
0
0
1
4
1
248
0
837
0
2
1,382
365
148
17
0
1
2
42
166
112
121
205
192
19
7
68
65
76
443
0
0
0
0
1,329
280
149
317
762
87
302
145
5
1
21
14
24
0
0
0
96
269
1
0
23
4
0
1
63
0
0
0
0
0
114
0
56
0
0
173
77
0
0
3
1
4
1
15
8
57
35
71
1
3
8
8
161
0
1
1
0
6
795
374
14
198
1,320
150
1,316
125
317
0
11
1
6
0
0
0
39
108
0
0
3
6
0
4
15
0
0
1
4
1
134
0
781
0
2
1,209
288
148
9,905 3,698 4,912
937 4,993 2,761
2005
2006
2006
2006
2006
2006
2006
2006
2006
2006
2006
2007
2008
2008
2008
2009
2011
2012
2014
2014
2015
2015
2025
2025
2027
2030
2035
2035
2035
Notes:
• Completed sites are not listed, nor sites where closure is near term or the work involves only waste packaging
and/or disposal: e.g., Argonne National Lab - West; General Atomics, CA; Salmon Site, MS; South Valley
Superfund Site, NM; Princeton Plasma Physics Lab, NJ; Amchitka Island, AK; and the Inhalation Toxicology
Lab, NM.
The number of release sites in this table will be slightly different from that reported in other sources because
specific data for the "Other" category were not available, and because of rounding.
Source: Department of Energy, FY 2005 Budget Request to Congress, Environmental Management.
Despite the size of the DOE complex, most of this land is uncontaminated. Less than 15 percent
of the land at the five major sites (Hanford, Savannah River, the Idaho National Engineering and
Environmental Laboratory, Rocky Flats, and the Oak Ridge Reservation) is contaminated.
However, the contamination that does exist presents extraordinary technical challenges because
of the presence of radionuclides (Probst 2000).
Chapter 7: Department of Energy Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Contaminants of concern across the complex generally include radionuclides, metals, and dense
non-aqueous phase liquids (DNAPLs). More specifically, key contaminants fall into the
following groupings (U.S. DOE 2002c).
• Radionuclides: plutonium, strontium-90, cesium-137, isotopes of uranium, tritium, thorium,
technetium-99, radium, and iodine-129.
• Metals: lead, chromium VI, mercury, zinc, beryllium, arsenic, cadmium, and copper.
• DNAPLs: carbon tetrachloride, trichloroethene, dichloroethene, tetrachloroethene,
chloroform, dichloromethane, and polychlorinated biphenyls.
7.4 Estimated Cleanup Costs
DOE has estimated the cost to complete cleanup at all sites that are currently in its program.
However, because of uncertainties that DOE has recognized, these estimates are based on a
number of critical assumptions, and revisions to these assumptions could raise or lower the
probable cost. This section presents the cost estimate and describes the critical assumptions.
7.4.1 Life Cycle Costs
DOE estimates that, as of the end of FY 2004, it will cost about $111 billion to complete the
cleanup of the remaining legacy release sites currently in EM's program, and that it will complete
active cleanup at most of its release sites by 2035 (U.S. DOE 2004).5 About $35 billion of this
total is anticipated to be for remediation. Environmental management funds not spent for site
remediation are used for national program planning and management, landlord activities, waste
management, facility stabilization, technology development, and nuclear material stabilization,
packaging, and transportation.
The estimate relies on several critical assumptions. It does not include all cleanup activities
needed, and hence is likely to underestimate the ultimate total cost of cleanup. DOE has yet to
determine the cost of remediating facilities that are still in operation (for which cleanup and
closure could become the responsibility of either the Office of Future Liabilities or the office
operating the facility), or the cost of addressing one-of-a-kind or first-of-a-kind contamination
problems that currently lack viable cleanup technologies, such as groundwater contaminated
with metals, chlorinated organics, and/or radioactive isotopes. Nor does the current estimate
include the costs of monitoring and maintaining site remedies over the thousands of years that
radioactive hazards will remain. Thus the ultimate cost of cleaning up properties for which DOE
is responsible may be greater than the estimates indicate.
The estimated life-cycle costs and remaining costs as of the end of FY 2004 for each of the
major installations are shown in Exhibit 7-2. Two sites account for 55 percent of the program's
life-cycle cost, and five sites account for 73 percent. DOE anticipates that by completing site
cleanup more quickly, it will reduce the length of time it must bear the fixed costs associated
This estimate is considerably lower than the $220 billion estimate in the 2002 top-to-bottom review because
DOE has undertaken a major effort to accelerate cleanup, improve business practices, and reduce restoration costs
(U.S. DOE 2003a and 2004).
Chapter 7: Department of Energy Sites Page 7-12
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
with maintaining the infrastructure of a site (a major component of DOE's overall costs). Hence,
the Department intends to complete as much cleanup as possible in the near term.
Exhibit 7-2. Estimated Remaining Life Cycle Cost for
DOE Site Restoration by Installation
Release Est. Est. Total Life-
Installation Sites Facilities Completion Cycle Cost
Remaining Remaining Date ($000)
Lab. for Energy-Related Health Res.
Ashtabula Env. Mgmt. Project, OH
Columbus Env. Mgmt. Proj., OH
Fernald Env. Mgmt. Proj., OH
Kansas City Plant
Lawrence Berkeley Nat. Lab.
Lawrence Livermore Nat. Lab/
LLNL Site 300
Mound/Miamisburg Proj., OH
Rocky Flats Env. Tech. Center
Sandia National Laboratories
Stanford Linear Accelerator Center
Energy Technology Eng. Center
Brookhaven National Lab
Pantex Plant
Argonne National Lab, East
Atlas Site (Moab)
West Valley Demo. Proj, OH
General Electric Vallecitos b
Separations Process Unit
Los Alamos National Laboratory
Oak Ridge Reservation
Portsmouth GDP
Savannah River Site
Nevada Test Site & Off-Sites 1
Paducah GDP
Hanford / River Protection 1
Idaho Nat. Eng. & Env. Lab
Waste Isolation Plant
Completed
Subtotal, installations 4
Other (unspecified)
Total 4
Notes:
• "Completed" includes life-cycle costs for
0
3
1
4
1
15
8
8
57
35
71
1
3
8
161
0
1
1
0
6
795
374
14
198
,320
150
,633
125
NA
,993
,993
0
11
1
6
0
0
0
0
39
108
0
0
3
6
4
15
0
0
1
4
1
134
0
781
2005
2006
2006
2006
2006
2006
2006
2008
2006
2006
2006
2006
2007
2008
2008
2009
2011
2012
2014
2014
2015
2015
2025
2025
0 2010-2027
2
1,357
288
NA
2,761
2,761
sites completed prior to
field activities that cannot be credibly allocated
"Other" includes life-cycle costs for technology
decommissioning contributions & offsets
2030
2035
2035
NA
NA
FY 2005, as
3,
1,
9
1
1,
7
6,
28
2
4
56,
14
6
1
146
11,
158,
40
156
163
553
28
33
514
503
297
230
20
204
373
192
63
186
577
923
259
013
660
758
673
0
413
868
721
599
976
359
291
221
034
Est. Remaining
Life-Cycle Cost
($000)
1
4
,366,841
245
529
351
258
643
317
694
184
415
278
077
927
520
447,
0
815
522
982
959
636
170
101
732
224
763
277
367
380
747
well as life-cycle
3
5
17
1
3
43
9
4
99
33,
33,
,324,
7,
7,
44,
771,
,555,
30,
3,
67,
154,
81,
8,
172,
933,
234,
858,
,290,
,306,
,859,
,655,
,996,
,765,
,907,
,486,
,592,
11,520
111
costs
,112,
967
605
851
958
373
028
530
800
884
018
316
746
055
559
233
388
942
0
439
700
155
287
407
160
310
834
649
913
0
107
,380
487
for various
to their respective sites.
development and
, program direction, and
This table includes non-remediation work, such
about one-third of this figure.
Source: DOE FY 2005 Budget Request
deployment,
decontamination
and
headquarters activities.
as waste packaging and waste management. Remediation is
Chapter 7: Department of Energy Sites
Page 7-13
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
7.4.2 Timing of Expenditures
The ultimate cost of DOE's cleanup will depend on annual funding levels and achievement of the
work as scheduled. Higher annual funding tends to accelerate cleanup work and reduce total life-
cycle costs in the long run; lower annual funding tends to delay work and increase total costs.
Actual or anticipated EM
Exhibit 7-3. Actual and Planned EM and
Site Restoration Budget: FY 2000-2004
Total EM 1 j |
8000 -f"
7000 ~~
6000-
M
g 5000-
H 4000 -
** 3000 -
2000-
1000-
0 ~
$6.9
' *
Remediation [ ) j
28
i
I $2.0"t
?
2000
S7.031
{• — ^
«
L
1
j
S2
2001
S7.2T
109
p
"1
4
1 $':.
2002
Year
1
p
S78
F=t
1
1
u
50
S7.8<
S2.12C
2003
H
17
i
$2241
1
wy
2004
Soyrce: U.S. DOE, Congressional for Environmental
FY
and and
expenditures for FY 2001 through
FY 2005 are shown in Exhibit 7-3.
Expenditures are expected to
increase about 14 percent between
FY 2001 and FY 2005. DOE
anticipates that these current
increases ultimately will lead to
earlier completion of many sites
and lower life-cycle costs. After
2005, EM's annual site restoration
expenditures are expected to
decline (U.S. DOE 2004).
Exhibit 7-4 shows actual or
anticipated EM expenditures for
FY 2002 through FY 2005 by
major DOE activity type.
Stabilization of high-risk materials
alone consumed almost half of the
EM budget in recent years. Remediation of soil and water took about one-tenth, and D&D of
contaminated facilities took a little over one-sixth. The estimates do not include estimates of
cleanup costs for facilities currently in use, since they are not part of the EM program.
The completion of cleanup work at release sites is the key measure of success for environmental
management, but site cleanup is a very complex task, generally involving numerous activities
over many years. The annual budget request, usually available on the DOE web site, contains
information on EM program performance, such as the volume of waste treated and disposed of,
number of release site cleanups completed and facilities decommissioned, quantity of nuclear
material stabilized, quantity of spent nuclear fuel moved to dry storage and prepared and shipped
for consolidation, and number and type of innovative technologies deployed.
7.5 Market Entry Considerations
DOE is the largest single U.S. purchaser of remediation services (over $2 billion annually),
accounting for over one-third of the U.S. remediation market in recent years. DOE also is the
largest civilian contracting agency in the federal government; about 90 percent of its annual
Chapter 7: Department of Energy Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 7-4. DOE Environmental Management
Expenditures 2002-2004 ($000)
FY 2002 FY 2003 FY 2004
Activity Comparable Comparable Comparable
Appropriation Appropriation Appropriation
Nuclear Material Stabilization and
Disposition
Spent Nuclear Fuel Stabilization
and Disposition
Solid Waste Stabilization and
Disposition
Radioactive Liquid Waste
Stabilization and Disposition
Radioactive Liquid Waste
Stabilization and Disposition: Major
Construction
Safeguards and Security
Soil and Water Remediation
Nuclear Facility Decontamination & 1
Decommissioning
Non-Nuclear Facility
Decontamination &
Decommissioning
Operate Waste Disposal Facility
Waste and Material Transportation
Technology Development
Community and Regulatory
Support
Program Direction
Federal Contribution to the
Uranium Enrichment D&D Fund
Pre-2004 Completions
Other
Total, EM 7
Note: The EM budget request also includes
shown above.
592,338
403,617
949,848
863,087
665,000
244,361
680,542
,095,039
31 ,264
154,916
43,522
200,189
43,763
301 ,422
420,000
105,392
236,977
,031,277
579,663
402,307
968,350
1,002,371
690,000
254,747
782,475
1,167,695
21,085
176,663
13,631
113,679
38,589
279,723
432,731
1 1 ,786
338,741
7,274,236
offsets, such as the Uranium
Source: DOE FY 2004 and 2005 Congressional Budget
713,337
358,176
1,078,195
1,049,629
686,036
291,124
807,501
1,257,843
55,025
153,577
43,994
66,116
41,217
276,510
449,333
0
322,856
7,650,469
Enrichment D&D fund,
FY 2QQS
Budget
Request
725,004
244,681
1,065,887
1,261,084
690,000
265,059
987,154
1,206,800
47,183
174,637
40,751
60,142
39,854
271,059
463,000
0
354,501
7,896,796
which are not
Requests (U.S. DOE 2003b and 2004).
Chapter 7: Department of Energy Sites
Page 7-15
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
budget is spent on contracts. DOE relies primarily on contractors (100,940 in 2002, according to
the 2002 performance report) to operate its facilities and carry out its diverse missions (U.S.
GAO 2003), including a small army of nearly 36,000 contractors to rectify the environmental
hazards resulting from five decades of nuclear weapons production (Probst 2000).
Characteristics of DOE Contractors
Most of EM's work is accomplished through large prime contractor companies. In 2002, more
than 60 percent of over $5 billion in EM contracting was managed by just three firms: Bechtel
Group International, Washington Group International/Westinghouse, and Fluor Corporation. Of
course, some of that money went to subcontractors. Another 30 percent of the total EM contract
revenues flowed through four prime contractors: CH2M Hill, British Nuclear Fuel (BNFL),
BWX Technologies, and Jacobs Engineering (Paterson 2002). Few new entrants have found a
way to be competitive. A DOE study (Analysis of the DOE Contractor Base, 2001) reported that
the number of potential bidders for major DOE contracts diminished from 20 to 30 companies a
decade ago to about 10 companies in 2001. Recent procurements for multi-billion dollar site
management contracts have received only one or two proposals (e.g., the Office of River
Protection Tank Waste Remediation System, Fernald Environmental Management Project, and
Savannah River Site)(YAHSGS 2002).
The consolidation of DOE remediation contractors reflects a general market trend in the
remediation services industry, as noted by Farkas Berkowitz in a 2000 comparison of market
shares. In 1994 the top ten companies claimed 38 percent of the remediation market; by 2000 the
top five companies claimed 50 percent of the market (YAHSGS 2002). The reluctance of
contractors to bid on major DOE procurements is based upon a combination of low profit
margins and the difficulty of competing with incumbent contractors. The consolidation of firms
and a diversification of firms into other, more profitable commercial markets means that EM
now faces a smaller contractor base with less "risk-bearing capacity" as it seeks to accelerate
cleanup (Tomlinson & Paterson 2002).
Increasing Emphasis on Performance-Based Contracting
DOE has committed to increasing its use of performance-based contracting as a means of
achieving risk mitigation and to strengthen its business practices. In 1994, two-thirds of
remediation contracts were based on time and materials (YAHSGS 2002). If DOE is successful
in its effort to integrate performance-based approaches into all levels of its contracting system,
companies providing risk-related services such as risk-based corrective action (RBCA) will
continue to be a major factor in determining remediation technology applications as well as
market share over the coming decade (U.S. DOE 2003a & 2002d).
EM's push to increase the use of pay-for-performance contracting is an important element in
advancing its environmental restoration program. To implement this initiative, DOE must
compete with commercial markets for the best contractors and contractor personnel. The
Department also must alter internal business practices that are not yet consistent with a
comprehensive pay-for-performance approach (YAHSGS 2002).
Chapter 7: Department of Energy Sites Page 7-16
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
DOE's Accelerated Cleanup Schedules
In response to the top-to-bottom review, DOE EM has opted to move forward more rapidly with
its cleanup activities. EM is reviewing remediation plans at many installations and negotiating
with regulators and other parties. It is expected that end state goals, remediation approaches, and
schedules will be revised, perhaps more than once, at many sites. This expected change in the
business approach may offer opportunities to a cleanup contractor who is flexible, resourceful,
and efficient in meeting these challenges.
Growing Need for Long-Term Stewardship
In the long run, DOE's program strategy anticipates that activities will shift from cleanup to
long-term stewardship, including monitoring, maintenance, and repair of properties where waste
has been left on site. For example, many nuclear sites (e.g., FUSRAP sites, low-level waste and
mixed-waste burial grounds, closed mine and mine tailings sites) may require long-term
attention. The required monitoring and maintenance work may be more suitable to smaller
contractors than to those involved in the management and cleanup of DOE's large installations.
Monitoring and stewardship programs also should open the door to new instruments and
measurement technologies coupled with remote information management systems to maintain
perpetual vigilance over past cleanups (YAHSGS 2002).
Encouraging the Use of Advanced Technologies
The contract reform mechanisms sought within EM may affect contractor incentives to use
advanced remediation techniques. A cleanup contractor's willingness to deploy an innovative or
emerging cleanup technology requires that the benefits achieved through deployment (e.g.,
reduced cost and schedule) substantially outweigh the down-side risk of failure and recovery due
to the greater uncertainties associated with new technologies. In the interest of finding better
cleanup approaches, demonstration projects can be structured so that the prime contractor's fees
are not affected by success or failure of the demonstrations (YAHSGS 2002). DOE has shown its
interest in emerging technologies by funding their development and deploying remedies such as
phytoremediation and permeable reactive barriers at its sites, as has been documented in EPA's
Treatment Technologies for Site Cleanup, Annual Status Report, llth Edition.
7.6 Remediation Technologies and Research, Development, and
Demonstration
Even for many experts in the environmental field, the terms and issues at DOE sites can differ
significantly from what most environmental engineers encounter at privately owned sites that are
subject to CERCLA or RCRA requirements. The presence of radioactive products resulting from
nuclear fuel cycles and nuclear weapons production complicates the cleanup of the more familiar
contaminants and hazardous wastes (Probst 2000) and present special hazards with regard to
worker health and safety. Exhibit 7-5 describes technologies DOE has found useful to the
cleanup effort.
Chapter 7: Department of Energy Sites Page 7-17
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 7-5. Examples of Innovative Technologies Useful to DOE
Technology
Analysis
Soil Remediation
Barometrically Enhanced Remediation Technology (BERT™) — Passively capitalizes
on wind effects and the vertical soil-gas movement resulting from natural barometric
pressure oscillations and harnesses this mechanism to ensure a net-upward, vertical
soil-gas flux in contaminated soil. Applicable to sites where contaminants are volatile
under standard conditions, close to the soil surface, and at concentrations low enough to
eliminate the need for off-gas treatment. BERT™ has been deployed at DOE's Idaho
Engineering and Environmental National Laboratory. (DOE/EM-0516)
Well Injection Depth Extraction (WIDE) — A hybrid soil flushing/soil gas extraction
system developed by researchers from North Carolina State University. WIDE uses
prefabricated vertical wells for the in-situ remediation of contaminated fine-grained soils. A
WIDE demonstration of trichloroethene removal took place in Ohio at DOE's Ashtabula
Environmental Management Project in 1999. (DOE/EM-0577)
in-situ Gaseous Reduction (ISGR) — Reduction and immobilization of hexavalent
chromium or other redox-sensitive metals in soils by injection of a low-concentration
hydrogen sulfide gas mixture. The oxidized metals are reduced and immobilized as either
an insoluble oxyhydroxide or sulfide. ISGR was demonstrated in1998 at White Sands
Missile Range, New Mexico, in a cooperative DOE/DoD effort. (DOE/EM-0521)
Groundwater
Remediation
Hydrous Pyrolysis Oxidation/Dynamic Underground Stripping (HPO/DUS) — A
combination of steam and oxygen injection, electrical heating (if required), soil vapor
extraction, in-situ bioremediation, electrical resistance tomography, and conventional
pump-and-treat technologies that removes organics (e.g., DNAPLS) from soil and
groundwater. DUS volatilizes contaminants, which are carried by the steam to a central
extraction well. HPO is a chemical process for destroying contaminants in place in the
subsurface. HPO/DUS was applied to full-scale cleanup at the Visalia Superfund Site in
Visalia, CA, from 1997 to 1999. The technology is available for licensing. (DOE/EM-0504)
Enhanced in-situ Bioremediation — Involves electron-donor injection to stimulate
indigenous microbes, groundwater pumping, air stripping, and monitoring. The patented
use of sodium lactate (or similar electron donors) at high concentrations to enhance
bioavailability is marketed as Bioavailability Enhancement Technology™, or BET™. A
1999-2000 demonstration to treat the source area of a TCE plume in the groundwater at
Idaho National Engineering and Environmental Laboratory worked so well that the Record
of Decision was amended in 2001 to incorporate the technology. (DOE/EM-624)
In-Well Vapor Stripping Technology — Represented in the United States by four types
of commercial in-well vapor stripping systems: NoVOCs™, Density Driven Convection
(DDC), Unterdruck-Verdampfer-Brunnen (UVB) Vacuum Vaporizer Well and Coaxial
Groundwater Circulation (KGB), and C-Sparger®. Specially designed wells pump water or
vapor through a screened interval and recirculate it back into the aquifer through a
separate interval. Treatment occurs below ground within the well casing, which reduces
costs. A UVB system successfully removed chlorinated solvents from groundwater at
Brookhaven National Laboratory from 1999 through 2001. (DOE/EM-0626)
Permeable Reactive Barrier (PRB) — A zone of reactive material placed in the path of a
groundwater plume to reduce concentrations of dissolved organics or inorganics as the
water flows through. The reactive medium selected varies with the contaminant(s) requiring
treatment, though elemental iron filings are used most frequently. DOE has installed PRBs
at many sites, including the Monticello Mill Tailings Site in Utah, the Kansas City Plant in
Missouri, the Rocky Flats Mound Site in Colorado, and the Oak Ridge Reservation Y-12
Site in Tennessee. (DOE/EM-0557, DOE/EM-0623)
Chapter 7: Department of Energy Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 7-5: Examples of Innovative Technologies Useful to DOE (continued)
Technology Analysis
Facilities
Deactivation
Modified Brokk Demolition Machine With Remote Operator Console — A commercially
available robotic machine purchased for deactivation and decommissioning (D&D) of
nuclear facilities. At Idaho Engineering and Environmental Laboratory (INEEL), a Brokk 250
demolition system was demonstrated in 1999 in various D&D activities and was modified
and demonstrated again in 2000. It is now part of the general INEEL D&D equipment pool.
(DOE/EM-0597)
Tank Waste
Stabilization
Thermal Denitration — Uses high temperatures and a carbon-based reductant (e.g.,
sugar) to decompose the nitrate and nitrite salts in aqueous sodium-bearing acidic waste to
nitrogen gas and oxides of nitrogen. The three-step process calls for evaporation of the
acidic liquid, decomposition of the highly volatile components, and chemical interaction of
the waste components and the added mixture to form a solid. DOE has over 1,000,000
gallons of sodium-bearing acidic waste to denitrify, solidify, and dispose of. Demonstrated at
Pacific Northwest National Laboratory. (DOE/EM-0616)
Mixed Waste
Stabilization
Solidification of Radioactive Waste Oils — Products for free-liquid control in storage,
transport, and disposal of radioactive and RCRA-defined waste oils. A polymer solidifying
agent, Nochar Petrobond®, was demonstrated in 1999 at the Mound Large-Scale
Demonstration and Deployment Project, in Miamisburg, Ohio, to absorb and solidify
high-activity tritium-contaminated vacuum-pump oils. (DOE/EM-0598)
Nuclear Materials
Processing
Real-Time Monitor for Transuranics in Glass — An optical sensor for remotely assaying
transuranic elements in molten glass as it flows into containers during the vitrification
process. The technology was demonstrated at the Savannah River Site three times between
1997 and 1999. (DOE/EM-0561)
Characterization
Tomographic Site Characterization Using CPT, ERT, and GPR — A geophysical system
delivered via cone penetrometer technology (CPT) that incorporates results from electrical
resistivity tomography (ERT) and ground penetrating radar (GPR). ERT can be used to
monitor or detect subsurface processes such as water infiltration, underground tank leaks,
and steam or electrical heating during soil cleanup operations. Data from GPR are used to
produce a cross-sectional profile or record of subsurface features. Demonstrated at a test
site in Vermont and at the Savannah River Site. (DOE/EM-0517)
Containment
Alternative Landfill Cover — A regulatory-acceptable alternative to the prescriptive RCRA
Subtitle C and D cover design. To identify covers with cost and performance advantages
over the prescriptive baseline covers at an arid or semi-arid site, DOE is monitoring an
alternative landfill cover demonstration at Sandia National Laboratories in New Mexico to
document the performance of four different alternative landfill covers. (DOE/EM-0558)
SEAtrace™ Monitoring System — A low-cost, early detection system to verify the initial
and long-term integrity of subsurface containment barriers by gaseous tracer injection,
automated multipoint sampling, and real-time global optimization modeling. The system
characterizes the integrity of impermeable barriers constructed above the water table and
determines the size and location of leaks. Demonstrated at Dover Air Force Base, Naval Air
Station Brunswick, and Brookhaven National Laboratories. (DOE/EM-0549)
Source: U.S. Department of Energy, the Innovative Technology Summary Report series. Available through DOE's
Information Bridge at http://www.osti.gov/bridge/ or at apps.em.doe.gov/OST/itsrall.asp.
Chapter 7: Department of Energy Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
7.6.1 Private Sector Involvement: Mechanisms
DOE uses different mechanisms to invite the private sector to participate in its technology
research and development programs. These include specific request for proposals (RFPs) issued
in Federal Business Opportunities or the Federal Register and broad announcements designed to
collect "best-in-class" technology providers (U.S. DOE Web 2003a).
Technology transfer can mean many things: technical assistance to solve a specific problem, use
of unique facilities, access to patents and software, exchange of personnel, and cooperative
research. The most appropriate mechanism will depend on the objective of each partner. A brief
description of several technology transfer mechanisms appears below.
Cooperative agreements: instruments entered into by the government with industry,
universities, and others to support or stimulate research. Agreements are generally cost-shared
with the nonfederal participant.
Cooperative Research and Development Agreements (CRADAs): an incentive for
collaborative research and development. CRADAs are agreements between a specific DOE
laboratory and a non-federal source to conduct mutually beneficial research and development
that is consistent with the laboratory's mission. CRADAs can be funded either entirely by the
partner or by DOE/partner cost sharing. CRADA partnerships can be developed by identifying
the specific area for research and development, the intellectual property owned, and the
laboratories/facilities technology areas that best match the needs, and then contacting that
laboratory/facility technology transfer office.
Cost-shared contracts/sub-contracts: collaboration through a procurement of mutual benefit to
industry and to government. Often the government can agree not to disseminate, for a limited
period of time, commercially valuable data that are generated under a cost-shared contract.
Licensing: the transfer of less than ownership rights in intellectual property, such as a patent or
software copyright, to permit its use by the licensee. Licenses can be exclusive or for a specific
field of use or for a specific geographical area. The potential licensee must present plans for
commercialization. The DOE Invention Licensing Home Page and its associated databases
provide information on Department-owned patents available for license for commercial use.
(http://www.osti.gov/dublincore/gencncl/)
Personnel exchange programs: arrangements allowing government or laboratory staff to work
in industry facilities and industry personnel to work in government laboratories and facilities to
enhance technical capacities and support research in specific areas. Costs are borne by the
organization sending the personnel. Intellectual property arrangements can be addressed in
exchange agreements.
R&D consortia: arrangements involving multiple federal and non-federal parties working
together for a common R&D objective. Funding for R&D consortia can be shared, but usually no
funds are exchanged between participants.
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Technical assistance to small business: undertaken by DOE/laboratory/facility personnel in
response to an inquiry from an individual or organization seeking to further knowledge, solve a
specific problem, or improve a process or product.
User facility agreements: arrangements permitting private parties to conduct research and
development at a laboratory. For proprietary R&D, the laboratory is paid for the full cost of the
activity. If the work will be published, cost can be adjusted. Intellectual property rights generally
belong to the user.
Work for Others (WFO): arrangements permitting private parties to conduct research and
development at a laboratory for either a federal agency or a non-federal entity. In this
arrangement, the private entity pays the laboratory's full costs for performing a research project.
A WFO arrangement permits a developer to gain access to highly specialized or unique DOE
facilities, services, or technical expertise. A technology developer can acquire a WFO by
identifying the unique expertise required, identifying the laboratories/facilities technology areas
that best match the technology development need, and contacting the laboratory/facility
technology transfer office. For proprietary R&D, the laboratory is paid for the full cost of the
activity. If the work will be published, cost can be adjusted. Intellectual property rights generally
belong to the user.
7.6.2 Private Sector Involvement: Programs
Among DOE's many technology development programs, the following are particularly useful to
developers of environmental technologies.
The Environmental Management Science Program (EMSP), sponsored by the Office of
Science (SC), is designed to inspire breakthroughs in areas critical to the EM mission through
basic research, and to fulfill DOE's continuing commitment to the cleanup of environmental
liabilities. The program was initiated in FY 1996 to address long-term technical issues and
provide EM with near-term fundamental data critical to the advancement of technologies that are
under development, but not yet at full scale nor implemented. Proposed basic research should
contribute to environmental management activities that would decrease risk for the public and
workers, provide opportunities for major cost reductions, reduce time required to achieve EM's
mission goals, and, in general, address problems that are considered intractable without new
knowledge (NRC 2000). The EM Science Program's solicitations are published in the Federal
Register, (http://emsp.em.doe.gov/)
Since 1996, the Program has held six competitions and has awarded over $290 million in
funding for 361 research projects. A breakdown of the EMSP awards by year is as follows:
• 1996 and 1997: 202 awards totaling $160 million targeted at a broad spectrum of basic
science cleanup and waste management issues.
• 1998: 33 awards totaling $30 million focused on high-level radioactive waste and
decontamination and decommissioning issues.
• 1999: 39 awards totaling $30 million fostered basic research in the areas of vadose zone
contamination and low dose radiation.
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• 2000: 42 awards totaling $30 million in research renewals for 1996 and 1997 funded
projects.
• 2001: 45 awards totaling $39 million focused on additional high-level radioactive waste and
decontamination and decommissioning issues (DOE 2002c).
• 2002: 38 awards totaling $33 million for research on subsurface contamination in the vadose
and saturated zones.
The Natural and Accelerated Bioremediation Research Program (NABIR) is sponsored by
DOE's Office of Biological & Environmental Research within SC to increase understanding and
utilization of contaminant bioremediation processes. (http://www.lbl.gov/NABIR/)
The Small Business Innovation Research (SBIR) and Small Business Technology Transfer
(STTR) programs are designed to stimulate and foster scientific and technological innovation in
the private sector, strengthen the role of small businesses in meeting federal research and
development needs, and increase the commercial application of innovations derived from
federally funded research. SBIR defines a small business as a for-profit enterprise operating in
the United States with majority domestic ownership and with no more than 500 employees.
Phase I SBIR awards up to $100,000 are awarded to explore the feasibility of innovative
concepts for nine months. Phase II is the principal research or R&D effort, with awards up to
$750,000 over a two-year period. DOE funds approximately 200 Phase I projects and about 90
Phase II projects per year. In Phase III, non-federal capital should be used by the small business
concern to pursue commercial applications of the R&D. To aid awardees seeking follow-on
funding for Phase III, DOE sponsors a Commercialization Assistance Project that provides
individual assistance in developing business plans and preparing presentations to potential
investment sponsors. The STTR pilot program is closely modeled on SBIR, with an additional
requirement of co-participation by a research institution such as a university, non-profit institute,
or contractor-operated, federally funded research and development center. Not less than 40
percent of the work conducted under an STTR award must be performed by the small business
concern, and not less than 30 percent of the work must be performed by the non-profit research
institution. The STTR awards are fixed-price grants of approximately $100K under Phase I,
rising to about $500K in Phase II, given continued successful program performance. University
or other non-profit involvement in a project does not limit the applicant to STTR only;
application can be made under SBIR alternatively, (http://sbir.er.doe.gov/sbir/)
Within EM, the Office of Science and Technology program provides direct technical solutions
to closure sites, which are DOE facilities whose primary mission has been completed or
terminated and where current activities are focused solely on site remediation. At the start of
each fiscal year, "alternative projects" will be identified that target immediate and specific
cleanup needs at the sites. Department-wide competitive grant and contract regulations apply.
(http ://www.em. doe.gov/ost)
The National Energy Technologies Laboratory (NETL) supports cleanup by implementing
several extramural technology development and deployment programs, with emphasis on
technologies for deactivation and decommissioning, and minimization and/or abatement of
environmental problems associated with the development and use of the nation's energy supply
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(e.g., fly ash from coal-burning facilities). NETL contracts with private-sector industrial and
academic organizations for technology development, (http://www.netl.doe.gov/business/solicit/)
The Strategic Environmental Research and Development Program (SERDP) is the
Department of Defense's corporate environmental R&D program, planned and executed in full
partnership with DOE and EPA, with participation by numerous other federal and non-federal
organizations, (http://www.serdp.org)
DOE encourages organizations and individuals to submit proposals that are relevant to the DOE
research and development mission either in response to formal DOE solicitations or through
self-generated unsolicited proposals. An Unsolicited Proposal is an application for support of an
idea, method, or approach submitted by individuals, businesses, or organizations solely on the
proposer's initiative, rather than in response to a formal government solicitation. Funding of
Unsolicited Proposals is considered a noncompetitive action. A 50-page detailed booklet titled
Guide for the Submission of Unsolicited Proposals outlines the Unsolicited Proposals process
and is available at
http://professionals.pr.doe.gov/ma5/MA-5Web.nsf/WebPages/Proposal+System?OpenDocument
In 1994, EM's Office of Science and Technology implemented the Technology Focus Area
approach as a strategy to leverage resources and facilitate sound technology development
decisions in the following technology problem areas: deactivation and decommissioning,
subsurface contaminants, transuranic and mixed waste, and tanks. The Focus Area approach
sought to optimize resources by streamlining technology management activities into a single
focus team for each major problem area. A National Research Council report, Decision Making
in the U.S. Department of Energy's Environmental Management Office of Science and
Technology (NRC 1999), provides an extensive overview of the aims and organization of the
Technology Focus and Cross-Cutting Technology Areas. As a result of the reorganization
brought about by the 2002 top-to-bottom review, EM is working to accelerate cleanup at specific
sites and has refocused the science and technology program to address a limited number of
critical site-specific cleanup needs, deliver expert services, and provide potentially high payback
solutions. DOE terminated the Focus Area and most of the Cross-Cutting Technology Area
programs at the end of FY 2002.
Numerous reports exploring DOE's environmental technology research and development needs
have been produced by the National Research Council (see the extended bibliography in the
appendix). Also, a collaborative effort to draft DOE's Long-Term Stewardship Science and
Technology Roadmap will define the strategic path forward for the critical science and
technology required to support the long-term stewardship program with regard to near-term
(5-10 year), intermediate-term (10-20 year), and long-term (20-50 year) general environmental
research and development needs (U.S. DOE 2002b).
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7.7 References
Applegate, John and Stephen Dycus, 1998. "Institutional Controls or Emperor's Clothes?
Long-Term Stewardship of the Nuclear Weapons Complex," Environmental Law Reporter:
News & Analysis, 28(11): 10631-10652.
EBI, 2002. "Industry Overview 2002," Environmental Business Journal, 14:7-8, Environmental
Business International, Inc.
Fiore, James J. and Marcus E. Jones, 2000. "The New Office of Environmental Management's
Site Closure Program," Waste Management 2000 Symposium, February 29, 2000, Tucson, AZ.
HR, 2000. Incinerating Cash: The Department of Energy's Failure to Develop & Use Innovative
Technologies to Clean Up the Nuclear Waste Legacy, U.S. House of Representatives, a staff
report prepared for the use of the Committee on Commerce.
NRC, 1999. Decision Making in the U.S. Department of Energy's Environmental Management
Office of Science and Technology, National Research Council, National Academy Press,
Washington, DC, ISBN: 0309063477.
NRC, 2000. Research Needs in Subsurface Science: U.S. Department of Energy's Environmental
Management Science Program, National Research Council, National Academy Press,
Washington, DC.
Paterson, Andrew, 2002. "New Approach in the Works for DOE," Environmental Business
Journal, 14(11-12): 18-19.
Probst, Katherine and Adam Lowes, 2000. Cleaning up the Nuclear Weapons Complex: Does
Anybody Care? Resources for the Future, Washington, DC.
Tomlinson, R. and A. Paterson, 2002. "Overview: Reengineering EM for 2003, What's Going
On?" Briefing for ITRC Board of Directors, February 19, 2002.
U.S. DOE, 1996a. The 1996 Baseline Environmental Management Report, U.S. Department of
Energy, Office of Environmental Management, DOE/EM-0290.
U.S. DOE, 1996b. Closing the Circle on the Splitting of the Atom, U.S. Department of Energy,
Office of Environmental Management, DOE/EM-0266.
U.S. DOE, 1998. Accelerating Cleanup: Paths to Closure, U.S. Department of Energy, Office of
Environmental Management, DOE/EM-0362.
U.S. DOE, 2000. Strategic Plan: Strength through Science—Powering the 21st Century, U.S.
Department of Energy.
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U.S. DOE, 200 la. Analysis of the DOE Contractor Base: Readiness, Willingness, Profitability
and Trends, U.S. Department of Energy, Contract Reform and Privatization Project Office.
U.S. DOE, 2001b. Long-Term Stewardship Study, U.S. Department of Energy, Office of
Environmental Management.
U.S. DOE, 200Ic. Report to Congress on Long-Term Stewardship. Volume 1: Summary Report;
Volume 2: Site Summaries., U.S. Department of Energy, Office of Long-Term Stewardship,
DOE/EM-0563, January 2001.
U.S. DOE, 2002a. "Environmental Management: Executive Summary," FY 2003 Budget Request
to Congress, U.S. Department of Energy.
U.S. DOE, 2002b. Long-Term Stewardship Science and Technology Roadmap (Draft), U.S.
Department of Energy, Long-Term Stewardship Science and Technology Roadmap Executive
Committee and Workgroups, Idaho Operations Office, DOE/ID-10926, October 2002.
U.S. DOE, 2002c. "Office of Science Financial Assistance Program Notice 02-03;
Environmental Management Science Program (EMSP): Research Related to Subsurface
Contamination in the Vadose and Saturated Zones," U.S. Department of Energy, Federal
Register, 67(4):719-725, January 7, 2002.
U.S. DOE, 2002d. A Review of the Environmental Management Program, United States
Department of Energy, Presented to the Assistant Secretary for Environmental Management by
the Top-to-Bottom Review Team, U.S. Department of Energy, February 4, 2002.
U.S. DOE, 2002e. "About OST," U.S. Department of Energy, Office of Environmental
Management, Office of Science and Technology web site, June 11, 2002.
http: //app s. em. doe. gov/O S T/ab outmain. asp
U.S. DOE, 2003a. "Environmental Management: Executive Summary," FY 2004 Budget Request
to Congress, U.S. Department of Energy.
U.S. DOE, 2003b. Performance and Accountability Report for FY 2002, U.S. Department of
Energy, DOE/ME-0014.
U.S. DOE, 2004. Department of Energy FY 2005 Budget Request, DOE/ME-0036, Vol. 5, U.S.
Department of Energy, February, 2004.
U.S. DOE Web, 2003a, "Technology Partnership Gateway," U.S. Department of Energy web
site, March 1, 2003. http://www.energy.gov/business/partners/ttwg.mechanisms.html
U.S. DOE Web, 2003b. "Inside the DOE—About Us: Our Mission," U.S. Department of Energy
web site, March 1,2003.
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U.S. GAO, 2002a. Waste Cleanup: Implications of Compliance Agreements on DOE's Cleanup
Program, U.S. General Accounting Office, GAO-02-852T, July 19, 2002.
U.S. GAO, 2002b. Waste Cleanup: Status and Implications of DOE's Compliance Agreements,
U.S. General Accounting Office, GAO-02-567, May 2002.
U.S. GAO, 2003. Major Management Challenges and Program Risks: Department of Energy,
U.S. General Accounting Office, GAO-03-100, January 2003.
YAHSGS, 2002. Assessment of the 2000 and 2001 Environmental Management Industry: The
Times They Are A-Changin', Prepared by YAHSGS LLC, Richland, WA, for the U.S.
Department of Energy, Washington, DC.
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Chapter 8
Demand for Remediation of Sites
Managed By Civilian Federal Agencies
This chapter describes the market for cleanup of sites owned or operated by "civilian" federal
agencies, which includes all federal agencies except the Departments of Energy and Defense.
Civilian agencies are collectively responsible for the management of millions of acres of land
and may ultimately be responsible for site characterization and remedial actions at thousands of
sites.1
The most comprehensive source of
information on contaminated facilities for
which civilian agencies are responsible is the
"Federal Agency Hazardous Waste
Compliance Docket" ("the docket") (U.S. EPA
2003a). Section 120(c) of the Comprehensive
Environmental Response, Compensation, and
Liability Act (CERCLA), as amended by the
Superfund Amendments and Reauthorization
Act (SARA), requires EPA to maintain the
docket as a repository for information about
federal facilities that manage hazardous waste
or from which hazardous substances have
been, or may be, released. As of January 2003,
1,099 facilities, distributed among 18 civilian
federal agencies, were listed on the docket. It
is estimated that approximately 70 percent of
these facilities may require environmental
cleanup.
Although an overall estimate of the potential
cost of cleaning up these facilities is
unavailable, estimates are available for
agencies managing a significant portion of the
facilities listed on the docket and for which
selected information is available: the U.S.
Department of Interior (DOI), U.S. Department of Agriculture (USDA), U.S. Department of
Transportation (DOT), and National Aeronautics and Space Administration (NASA). These
Highlights
' About 70% of civilian federal agency
contaminated sites are on lands managed by the
DOI and USDA. These agencies combined
manage over 700 million acres of land, about a
third of U.S. land.
• DOI and USDA have identified at least 3,000
contaminated sites that will require cleanup. In
addition, between 5,000 and 25,000 abandoned
mine sites are on lands for which these agencies
are responsible.
• The cost to complete cleanup at civilian federal
agency sites is estimated to be $15-22 billion.
This estimate does not include all of the mining
sites. Mining sites are addressed in Chapter 11.
• The 17 federal agencies on EPA's docket
typically spend an estimated $100-200 million
annually for contaminated site cleanup at their
properties. This figure may underestimate the
total remediation expenditures, because it
includes only some of the potential cost recovery
and cost sharing.
• Based on the above annual funding level, it will
take between 100 and 200 years to clean up the
contaminated sites at civilian federal agencies.
• Given the types of environmental problems
present, remediation approaches at civilian
federal sites are likely to be similar to those used
in other programs, such at RCRA and NPL sites.
Throughout this chapter, the term "site" is used to indicate an individual area of contamination. The term "facility"
identifies an entire tract, including contiguous land, that is the responsibility of the subject agency. A "facility" may
contain one or more contaminated areas or "sites."
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agencies together account for 75 percent of the civilian federal agency facilities listed on the
docket. These agencies are also entrusted with managing vast amounts of public land. The
largest federal land holder, DOT, is responsible for 507 million acres of surface land, or about
one-fifth of the land in the United States; and the U.S. Forest Service (part of USD A) manages
192 million acres of national forest and grasslands.
8.1 Civilian Federal Agency Cleanup Programs
Cleanup at hazardous waste sites is regulated in large part by CERCLA/SARA and the Resource
Conservation and Recovery Act (RCRA). Federal agencies must comply with CERCLA and
RCRA provisions in the same manner as private parties, and are liable for cleaning up
contaminated waste at currently- or formerly-owned facilities. Under SARA, the federal agencies
also may be liable for cleaning up contaminated waste at facilities acquired through foreclosure
or other means and at facilities purchased with federal loans. To meet these requirements,
civilian federal agencies implement various programs for assessing potentially contaminated
sites and conducting any needed cleanup actions. Some agencies have established central offices
to manage these programs, while others have adopted a decentralized approach involving the
organization of programs by function or geographic location.
For example, DOI's Office of Environmental Policy and Compliance coordinates and develops
the agency's environmental policy and programs through three teams and eight regional offices
to address: (1) requirements of the National Environmental Policy Act and Council on
Environmental Quality; (2) remedial and corrective actions involving hazardous materials; and
(3) requirements of the National Oil and
Hazardous Substances Pollution _
Contingency Plan (NCP). In 1995, DOT
established the Central Hazardous Materials
Fund (CHF) to fund medium- to long-term
DOI Agencies Manage 507 Million Acres,
One Fifth of U.S. Land: D
Bureau of Land Management: 262 million acres
Fish and Wildlife Service: 96 million acres
Bureau of Indian Affairs: 56 million acres
CERCLA cleanup actions. Each year,
bureaus and offices within DOI nominate
projects for funding that impact sites on
DOI land or that impact DOI resources. National Park Service: 84 million acres
Between 1995 and 2002, the CHF, which is
administered by the Bureau of Land
Management (BLM), received $87.4 million Bureau of Reclamation: 9 million acres
in appropriated funds. An additional $84
million was added through cost sharing and
cost recovery. Appropriations for FY 2003
are expected to be about $10 million. This fund may be used for site investigations, feasibility
studies, and cleanups at sites for which DOI is responsible. Additional cleanup activities may be
funded through the appropriations of the various DOI offices and bureaus. The major land-
management components of DOI are shown in the box.
USDA's Hazardous Materials Policy Council (HMPC) provides overall departmental leadership,
in addressing issues relating to hazardous waste management and site cleanup. The council,
which consists of senior policy representatives from the major affected offices and agencies
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within USD A, was established in 1999 to improve consistency across USDA service areas, and
consists of senior policy representatives from those areas. The implementation of the hazardous
waste-related activities is the responsibility of the Department's Hazardous Materials
Management Program (HMMP). In addition to direct funding, HMMP receives funds from the
Hazardous Materials Management Appropriation, which was established in 1988 to provide
targeted funding for priority hazardous material cleanup projects on facilities and lands under
USDA's jurisdiction, custody, or control and for USDA's share of the costs for cleanup projects
on non-USDA property where USDA activities may have contributed to the pollution. The
appropriation has been about $15.7 million over the past two years. An additional $26.7 million
annually is available for the department's environmental mission from direct USDA funds.
NASA's Environmental Compliance and Restoration Program (ECR) is managed from NASA
Headquarters under the Office of Management Systems. ECR serves as a centralized lead for
ensuring environmental stewardship and sustainability of the agency's facilities. NASA's
environmental cleanup and compliance activities are implemented through 10 research or space
flight centers located across the country.
DOT consists of 13 operating administrations responsible for different transportation sectors (as
of 2002). Each administration holds responsibility for restoration activities at its operational
facilities, including identification, investigation, and cleanup. In addition to its national mission
to protect the navigable water of the U.S., the U.S. Coast Guard provides DOT's short- and long-
term emergency response to hazardous substance or oil spills covered under CERCLA/SARA
and the NCP. Coast Guard operations were transferred from DOT to the U.S. Department of
Homeland Security in 2002.
8.2 Factors Affecting Demand for Cleanup
Four primary factors influence the market for remediation of civilian federal agency
contaminated waste sites.
• Budget considerations constrain all federal agencies planning site remediation. Although
agencies may request funds for contaminated site management and remediation, Congress
may not provide the necessary funding. Agencies have intensified their efforts to prioritize
cleanup activities within and across facilities by more effectively evaluating alternative
future land uses, estimating and prioritizing risks to human health and the environment,
evaluating a broad range of remediation technologies, and analyzing the relative costs and
benefits of various approaches to cleanup.
In addition, the federal budget process has created incentives for agencies to implement
management reforms that will reduce the costs of operations. Some of these include
encouraging and eliminating barriers to the use of less costly, innovative remediation
technologies; using more cost-effective contracting procedures; streamlining management
structures and processes; and using the "lessons learned" from other agencies and the private
sector (U.S.CEQ 1995).
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• Federal agencies are subject to the CERCLA "Lender Liability Rule," which assigns
responsibility for cleaning up contamination at acquired properties. Although federal
agencies that involuntarily acquire contaminated property (through foreclosure or other
mechanisms) generally are exempt from CERCLA liability, an agency may be liable for
remediating a hazardous waste site if it loans money to, and actively participates in
management of, an organization using or generating the hazardous waste. Federal liability is
determined on a case-by-case basis for each site that is acquired involuntarily.
•• Changes in federal and state environmental regulations and standards often impact the level
and pace of cleanup required at civilian federal facilities. If cleanup standards become more
rigorous in the future, the market may require more advanced technologies or longer-term
and more intensive use of existing technologies than anticipated currently. Conversely, if
standards become less stringent, the market for new remedial technologies could decrease.
In January 2002, for example, EPA amended regulations covering corrective action
management units (CAMUs) created under RCRA to facilitate treatment, storage, and
disposal of hazardous wastes managed for implementing cleanup. The revised regulations
established more detailed minimum design and operating standards for CAMUs and
outlined treatment requirements for wastes that are placed in CAMUs without violation of
RCRA land disposal restrictions. In addition, the amendment established specific
information requirements for CAMU applications, including opportunity for public
comment. The U.S. General Accounting Office reviewed the proposed regulations and
determined that the process for requesting and obtaining CAMU approval would increase
the time and cost of site cleanups (U.S. GAO 2000).
• The transfer of public properties to private use may require agencies to reallocate resources
for cleaning up properties designated for transfer. Recent years have witnessed an increase
in public-to-private transfers of large properties, many of which are managed for a period of
time by the General Services Administration.
8.3 Number of Facilities and Sites
Estimates of the number of civilian federal facilities that will require some type of remedial
action can be derived from the docket. CERCLA requires that the docket be updated every six
months to reflect newly characterized sites. In January 2003, the docket reflected a total of 1,099
facilities (Exhibit 8-1). The docket contains information submitted by civilian agencies under
CERCLA Section 103(a), which requires that the National Response Center be notified of a
hazardous substance release or potential release. The docket also contains information submitted
to EPA by the agencies under RCRA Sections 3005, 3010, and 3016, which addresses facility
permitting, notification of hazardous waste activity, and each agency's biennial inventory of
hazardous waste activities.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 8-1. Number of Civilian Federal Facilities Potentially Requiring Cleanup
Agency Facilities Listed
Department of Agriculture
Architect of the Capitol
Central Intelligence Agency
Department of Commerce
Army Corps of Engineers
Environmental Protection Agency
General Services Administration
Department of Health and Human Services
Department of Housing and Urban Development
Department of the Interior
Department of Justice
Department of Labor
National Aeronautics and Space Administration
U.S. Postal Service
Tennessee Valley Authority
Department of Transportation
Department of the Treasury
Veterans Administration
Total
on Docket
201
1
1
10
50
23
38
10
3
468
27
3
17
26
45
134
9
33
1099
Notes:
a The number of "sites" (individual areas of contamination) at each facility is not included in the docket.
b The U.S. Army Corps of Engineers manages environmental cleanup projects for a variety of civilian federal
agencies as well as the Department of Defense and Department of Energy.
Source:
U.S. Environmental Protection Agency. "Federal Agency Hazardous Waste Compliance Docket," 68 Federal
Register 107, January 2, 2003.
Although it is the most comprehensive source available, the docket provides only broad
indications of the remediation market. Some of the factors that limit its utility for market analysis
are: many sites listed on the docket do not require remediation; sites that have undergone
remediation are not removed from the docket; the docket does not indicate the number of
contaminated sites at each facility (a facility can have one or more sites or areas of
contamination); and many sites at federal facilities remain to be inventoried and characterized.
In addition, the docket excludes federal facilities that have been sold, private facilities where the
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federal government may have contributed to site contamination, and facilities that generate small
quantities of hazardous waste. Thus, the docket may not account for all potentially contaminated
sites on land for which civilian federal agencies are responsible.
In accordance with CERCLA Section 120(d), a preliminary assessment (PA) is conducted for
each facility listed on the docket to evaluate the threat they pose to public health and the
environment. If warranted, a site inspection is conducted to determine if CERCLA response
actions are necessary. If further actions are warranted, an evaluation is conducted to determine
whether the site should be placed on the National Priorities List (NPL) for long-term evaluation
and remedial response. As of October 2001, 15 civilian federal agency sites had been added,
proposed, or deleted from the NPL (U.S. EPA 2003b).
Approximately 30 percent of the docket facilities listed pursuant to CERCLA Section 103
require no further EPA actions, and accordingly are designated "no further remedial action
planned" (NFRAP). Although the NFRAP designation means that the contamination at a site is
not severe enough to warrant listing the site on the NPL and remediation under the Superfund
program, the site still may require cleanup under other environmental programs, such as a state
regulation.
DOI estimates that about 1,000 sites under DOI stewardship require restoration. (U.S .DOI
2003b). By 2005, DOI aims to increase its cumulative number of restoration projects to 135 and
the cumulative amount of damage settlement funds within the DOI Restoration Fund to $200
Exhibit 8-2. DOI Allocation of the Central
Hazardous Materials Fund
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Chapter 8: Civilian Federal Agency Sites
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million. For example, DOT allocated approximately $10 million of Central Hazardous Materials
Fund (CHF) money during 2001 to 35 projects spread among five bureaus: 14 projects in the
Bureau of Land Management (BLM); 13 projects in the National Park Service; 4 projects in the
Fish and Wildlife Service; 3 projects in the Bureau of Indian Affairs; and 1 project in the U.S.
Geological Survey (U.S. DOT 2003a). The geographic distribution of these projects are shown in
Exhibit 8-2. By 2005, DOT also plans to have completed cleanup of its 1,000th BLM hazardous
material site (U.S. DOT 2003b).
In addition to hazardous waste sites it has already identified, other sites may be discovered on its
properties in the future. An estimated 3.5 million acres under the Department's stewardship are
in need of restoration. DOT plans to restore about 1.1 million of these acres by 2005. This land
includes mined lands, wildlife refuges, park lands, and forests. In the course of implementing
this task, additional remediation needs are likely to arise. For example, BLM estimates that
between 5,000 and 25,000 abandoned mines on public lands the Bureau administers have caused
or could cause environmental damage, mostly from water pollution. In a typical year, DOI works
on between 50 and 150 remediation sites.
In 2001, USD A estimated that over 2,000 sites with releases or threatened releases of hazardous
substances remained to be addressed over the next 50 years, at an estimated cost of $4 billion
(USDA 2001). From 2003 to the end of 2007, USDA anticipates completing 150 CERCLA
cleanups. During 2003 alone, USDA planned to complete 68 CERCLA site assessments, 59
CERCLA cleanup plans, and 6 RCRA cleanups. (In contrast, the agency targeted 17 CERCLA
cleanups during fiscal year 2002.) More than half of the agency's CERCLA cleanups planned for
2003 involve mining sites (USDA 2003). USDA recognizes that preparation of cleanup plans is
emerging as a potential "bottleneck." While 137 CERCLA cleanups were completed in fiscal
years 1998-2001, only 84 cleanup plans were completed during that time.
DOT has made significant progress in remediating its contaminated sites. In fiscal year 2002,
DOT reported that 91 of its facilities required no further remedial actions under SARA, and that
all SARA cleanup efforts were completed (U.S. DOT 2002). This leaves 43 DOT facilities that
require remediation. The Coast Guard received DOT funding to conduct response and cleanup
activities required of the DOT under CERCLA/SARA. Continued restoration activity is
anticipated at three Coast Guard facilities for several years. In addition, the Federal Aviation
Administration plans continued cleanup activities at several facilities, and replacement of
outdated underground storage tanks and cleaning or removal of unused tanks at decommissioned
facilities. DOT uses a "worst first" prioritization system to address problems posed by DOT
facilities where significant pollution problems are identified.
8.4 Site Characteristics
The types of contamination problems at civilian federal agency facilities vary from agency to
agency. Exhibit 8-3 provides examples of the types of contaminated facilities managed by
agencies listed most often on the docket. Contaminated facilities owned or operated by other
civilian federal agencies encompass research laboratories, properties acquired through
foreclosure, and operational facilities such as the Department of Justice federal penitentiaries,
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Tennessee Valley Authority power generating plants, and Department of Veterans Affairs
medical centers.
Exhibit 8-3. Examples of Types of Contaminated
Facilities at Civilian Federal Agencies
Department of Interior
Bureau of Land Management
Bureau of Reclamation
National Park Service
Fish and Wildlife Service
Landfills (approximately 3,400 closed sites)
Abandoned mining operations
Unauthorized hazardous waste sites
Reservoirs and drinking water supplies contaminated with
agricultural runoff
Landfills and dumps (inherited with acquired land)
Abandoned mining operations
Contaminated sites resulting from agricultural runoff or upstream
industrial operations
Inherited land previously used for industrial or defense purposes
Department of Agriculture
Forest Service
Agricultural Research Service
Commodity Credit Corporation
Farmers Home Administration
Abandoned mining sites
Sanitary landfills and aboveground dumps
Wood preservation sites and laboratories
Research laboratories
Grain storage facilities
Farms (acquired through foreclosure) where pesticides and other
hazardous materials may have been disposed
Department of
Transportation
Federal Aviation Administration
(FAA)
U.S. Coast Guard
FAA Technical Center, with soil and groundwater contamination
of 22 areas
Airfields with hazardous solvent or oil spills
Fuel storage and operation/maintenance facilities
National Aeronautics and
Space Administration
Research laboratories, industrial plants
8.5 Estimated Cleanup Costs
Detailed site information for developing accurate cleanup cost estimates for civilian federal
agency sites is not readily available from the agencies. EPA's FEDPLAN-PC information system
has been discontinued and information sources on environmental activities of the agencies are
scattered among their bureaus and offices. To provide insight into the probable cost of
completing cleanup at federal civilian sites, it is useful to examine (a) the probable cost of all
sites that have been or are likely to be discovered, given current regulatory requirements, and (b)
the probable funding likely to be committed to remediation.
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Estimated Cost To Complete Cleanup
Because information on contaminated sites at most agencies is fragmented, it is difficult to
develop a clear picture of the cost to complete cleanups at civilian federal agencies. The U.S.
General Accounting Office's (GAO) recent study of the issue of environmental liabilities of
federal agencies indicates the nature of this difficulty. In an effort to improve the Congressional
budgetary process for federal agencies' environmental liabilities, the GAO recently studied the
problems posed by the waste-producing assets of these agencies. GAO recommended that the
Office of Management and Budget require federal agencies to include in their budget requests
supplemental information on estimated environmental cleanup/disposal costs for new
acquisitions (U.S. GAO 2003). This requirement implies that agencies will be required to
conduct Phase I and Phase II type site assessments when contemplating real estate transactions.
It will also ensure that agencies explicitly recognize the financial cost of their potential
environmental liabilities.
GAO also assessed the efforts that federal agencies with major cleanup responsibilities have
made in setting priorities for spending limited cleanup funds at the sites posing the highest risks
(U.S. GAO 1999). GAO found that EPA and USDA had made progress in setting priorities on
the basis of site risks, but that additional efforts were required by DOI to complete a site
inventory and establish a risk-based prioritization of its sites.
Despite these difficulties, DOI, USDA, and NASA planning and budgetary information indicate
that cleanup of sites covered under CERCLA, RCRA, and other environmental regulations will
continue to require extensive resources over many years. The following points summarize an
estimate of the cost to complete remediation at contaminated federal civilian agency sites.
Exhibit 8-4. Estimate Cleanup Cost for Civilian Federal Agencies
Cost to Complete
Agency ($ Billions) Explanation/Limitations
DOI
USDA
NASA
Subtotal
Total, all
agencies
$4.7-9.8
$4.2
$1.3
$10.2-15.3
$14.6-21.9
Over 1 ,000 sites identified on 468 facilities. It could require over
100 years to address these sites. DOI reports it could have as
many 25,000 sites. (U.S. DOI 2003a and U.S. CEQ 1995).
Over 2,000 sites with releases or threatened releases of hazardous
substances (USDA 2001). USDA expects this work to take about
50 years.
Environmental remediation of NASA's research and space flight
centers could require an additional 80 years to complete.
These agencies account for 70% of the facilities on the docket.
Divide previous figure by 0.7.
Sources: See explanation in text and references above
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Available Funding
Given the magnitude of the cost to complete cleanups at civilian federal sites, it is useful to
examine the level of recent funding.
•• Between 1995 and 2002, DOT received $87.4 million in direct funding and an additional $84
million in cost sharing or cost recovery to address sites with hazardous materials. The direct
funding comes from the Central Hazardous Materials Fund described in Section 8.1. In
recent years, annual CHF funding has been $10 million. These funds may be supplemented
through cost sharing and cost recovery from responsible parties or business operators.
Historically, about one dollar of PRP funds becomes available for each dollar of direct
appropriations.
DOI's BLM was appropriated $1 million in FY 1997, $3 million in FY 1998, and $10
million in fiscal years 1999, 2000, and 2001 for water quality-related cleanup actions at
abandoned mine land sites. In addition, states obligated $10.2 million and the Office of
Surface Mining obligated $5.9 million for emergency reclamation projects at abandoned
mine lands during 2001. The Office of Surface Mining also distributed $6.9 million to 12
states for elimination of environmental problems caused by acid mine drainage from
abandoned coal mines. Although most of these appropriations, which total $33 million, are
for land reclamation, safety hazards and other non-remediation activities, a portion of these
funds, perhaps 20 percent ($6 million) is likely to be used for site remediation. Thus, the
funds available to DOI for remediation of contaminated sites are likely to amount to $26
million annually ($10 million from CHF + $10 million from cost recovery and cost sharing
+ $6 million directly funded by bureau programs).
• USDA funding for priority CERCLA and RCRA activities are supplemented by Hazardous
Materials Management Appropriations (HMMA). For fiscal year 2003, the department
requested $15.7 million in HMMA funding, 47 percent ($7.3 million) of which covered
actual cleanup work. This request is about equal to HMMA appropriations for fiscal years
2000 and 2001, each of which totaled $15.7 million. Approximately $5.1 million of the
HMMA request targeted cleanup of abandoned and inactive mine sites on national forest
lands. Of the total HMMA budget request, approximately 88 percent covered CERCLA
activities. The remaining 12 percent was allocated to RCRA regulatory compliance,
including the removal of underground storage tanks.
A total of $26.7 million in USDA funds also were committed to meet the agency's
environmental mission. USDA anticipates that, between 2003 to the end of 2007, it will
complete 150 CERCLA cleanups. Thus, the upper-bound of funds likely to be available to
USDA for remediation of contaminated sites is estimated to be about $34 million annually
($7.3 + $26.7 million).
• NASA anticipates that 80 percent of its $41 million annual environmental restoration budget
anticipated for fiscal years 2004-2008, or $32.8 million, will be used for remediation of
contaminated sites (NASA 2003).
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• The total anticipated annual budget for the three agencies is $92.8 million, and extrapolating
this figure to all 17 agencies on the docket results in an estimated annual budget of $133
million for contaminated site remediation at federal agencies. This figure may underestimate
the total remediation expenditures, because it includes only some of the potential cost
recovery and cost sharing that will be available.
Based on the above analysis, and the assumption that funding remains at $133 million annually,
it will take 130 to 160 years to remediate the contaminated sites at civilian federal agencies.
8.6 Remediation Technologies
Little information is available on the technologies used to clean up facilities owned or operated
by civilian federal agencies. Given the types of environmental problems present, the remediation
approaches are likely to be similar to those used in other programs, such at RCRA and NPL
sites. A useful EPA publication Innovative Treatment Technologies: Annual Status Report
(Eleventh Edition) describes trends in technologies used at NPL, Department of Defense, and
Department of Energy sites (U.S. EPA 2004). Many of those technologies, in particular those
implemented at NPL industrial and mining sites, may be implemented at civilian federal agency
sites.
To stimulate the use of innovative technologies at federal, including civilian, contaminated sites,
EPA is fostering the use of federal facilities as testing and demonstration centers. For example,
several new cleanup technologies are under demonstration at the Kennedy Space Center in
Florida as part of EPA's Superfund Innovative Technology Evaluation Program. These
demonstrations will help to identify cost-effective and easily-implemented technologies for
treating groundwater contaminated with dense non-aqueous phase liquids. Also, in an effort to
reduce regulatory and institutional barriers to innovative technology development, EPA is
working with DOT and the Western Governor's Association to develop innovative technologies
for use at mining sites.
8.7 References
NASA, 2003. Fiscal Year 2004 - Congressional Budget., U.S. National Aeronautics and Space
Administration, 2004. http://www.ifmp.nasa.gov/codeb/budget
U.S. CEQ, 1995. Improving Federal Facilities Cleanup, Council on Environmental Quality,
Office of Management and Budget, October 1995.
USD A, 2001. USDA Hazardous Materials Management Program: Strategic Plan. U.S.
Department of Agriculture, December 2001. http://www.usda.gov/da/hmmg
USDA, 2003. Hazardous Materials Management: Annual Performance Plans, FY 2003, 2001,
2000. U.S. Department of Agriculture, http://www.usda.gov/da/hmmg
U.S. DOT, 2001. U.S. Strategic Plan: FY2000-2005, U.S. Department of the Interior.
http ://www. doi.gov/gpra/doioverviewstratplanv6
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U.S. DOT, 2003a. U.S. Department of Interior, Office of Environmental Policy and Compliance
web site, http://www.doi.gov/oepc
U.S. DOT, 2003b. FY 2003 Annual Performance Plan; FY 2001 Annual Performance Report,
U.S. Department of Interior, http://www.doi.gov/gpra/2003/01apr03app
U.S. DOT, 2003c. U.S. Department of Interior. Office of Surface Mining web site.
http://www.blm.gov/aml
U.S. DOT, 2002. Performance and Accountability Report: Fiscal Year 2002, U.S. Department of
Transportation, http://www.dot.gov/perfacc
U.S. EPA (Environmental Protection Agency), 2003a. "Federal Agency Hazardous Waste
Compliance Docket." U.S. Environmental Protection Agency, 68 Federal Register 107, January
2,2003.
U.S. EPA, 2003b. CERCLA Information System, U.S. Environmental Protection Agency, Office
of Solid Waste and Emergency Response 2003.
U.S. EPA, 2004. Treatment Technologies For Site Cleanup: Annual Status Report (Eleventh
Edition), Office of Solid Waste and Emergency Response, Technology Innovation Office, EPA-
542-R--03-009, February 2004. http://www.clu-in.org/asr
U.S. GAO, 1999. Progress Made by EPA and Other Federal Agencies to Resolve Program
Management Issues, U.S. General Accounting Office, GAO/RCED-99-111, April 1999.
U.S. GAO, 2000. U. S. Hazardous Waste: Effect of Proposed Rule 's Extra Cleanup
Requirements is Uncertain, U.S. General Accounting Office, GAO-01-67, October 2000.
U.S. GAO, 2003. Long-Term Commitments: Improving the Budgetary Focus on Environmental
Liabilities, U.S. General Accounting Office, GAO-03-219, January 2003.
U.S. OMB, 1995. Improving Federal Facilities Cleanup. Office of Management and Budget,
October 1995. clinton2.nara.gov/OMB/inforeg/iffc-2.html
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Chapter 9
Demand for Remediation of
States and Private Party Sites
The cleanup market includes thousands of sites managed by states and private parties. Non-
federal agency sites that are not being cleaned up under the Comprehensive Environmental
Response, Compensation, Liability Act (CERCLA), Resource Conservation and Recovery Act
(RCRA) Corrective Action, and Underground Storage Tank (UST) Programs, but still need
attention, become the responsibility of state cleanup programs, private parties, or local
jurisdictions. Most private party sites are remediated under state voluntary cleanup programs
(VCPs). State sites can vary from sites that are similar to NPL sites to small sites with low levels
of contamination.
The majority of states have enforcement
authority to compel cleanups and state
cleanup funding mechanisms dedicated to
financing the cleanup of abandoned sites. It
has been estimated that as of December
2000, about 23,000 non-National Priority
List (NPL) sites were known or suspected
to be contaminated and need further
attention requiring additional evaluation
and/or some level of cleanup (ELI 2002).
The extent of contamination at these sites is
largely unknown. However, information in
this chapter about state sites that have been
remediated indicates the likely
characteristics of these sites.
In addition to direct state cleanups, many
state sites are cleaned up by private parties
in accordance with state cleanup standards.
To encourage private party cleanups, almost
all states have created voluntary cleanup
programs that often provide incentives for
private parties to assess and cleanup their
sites, with state oversight. Most states have
also created brownfield programs that target
the cleanup and redevelopment of
properties that have been abandoned or are
underused because of the potential for
contamination.
Highlights
• There may be as many as 1/4 to1 million brownfield
sites, 85-90% of which have not been evaluated
or cleaned up.
• Based on data from EPA's brownfields grant
projects, 350,000 to 700,000 of these may require
cleanup. The exact percentage is unknown.
• About 5,000 cleanups are typically completed
annually under state mandatory and voluntary
control programs. At this rate, 150,000 sites can
be completed in 30 years.
* Annual expenditures for these cleanups are
estimated to average about $1 billion. If states
with limited funds want to accelerate the pace of
work, they will likely have to rely on private party
actions, voluntary cleanups, and cost recovery.
• The Brownfields Revitalization Act will likely lead
to an expansion in the number of sites assessed
and cleaned up.
• The federal brownfields program has served as a
catalyst for other development that use private,
state, and local funds. EPA's investment in
brownfields, more than $700 million since 1995,
has leveraged more than $5 billion in cleanup and
redevelopment funding.
• State site cleanup and redevelopment involves
coordination of many disciplines and stakeholders,
which has led remediation firms to form alliances
with firms and consultants with other specialties.
• The use of advanced remediation techniques
appears to have grown in recent years, although
data are scant.
• There is a need to screen many sites to determine
whether or not they have contamination problems.
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In recent years, an average of about 5,000 cleanups have been completed annually under direct
state cleanups, voluntary cleanup programs, and brownfield programs. During 2000, states spent
more than $505.6 million (38 states reporting) for remediation of NPL and non-NPL sites. Most
of these funds were for direct state cleanups at non-NPL sites. Despite this progress in
completing cleanups, the backlog of sites to be cleaned up has been stable, primarily because
new sites are still being identified.
9.1 Programs Addressing State Sites
The cleanup of state and private party sites is strongly influenced by a myriad of state and
federal programs that seek to encourage site investigations, cleanup, and redevelopment. The
structure and operations of these programs vary widely from state-to-state and many of them
preexist the federal brownfield program. These programs typically can require cleanups of
certain types of contamination and provide incentives for cleanup, redevelopment, and long-term
stewardship. There are two types of state hazardous waste programs: programs that primarily
address enforcement issues and oversee cleanups of abandoned sites, and state voluntary cleanup
and brownfield programs. In addition, federal programs actively encourage and assist states in
their efforts to evaluate and clean up contaminated sites.
9.1.1 State Hazardous Waste Cleanup Programs
Almost all states have established hazardous waste programs to ensure that potentially
contaminated sites are assessed and, if necessary, cleaned up. Information on these state
programs, numbers of contaminated sites, and the status of those sites has been derived from
existing published information and state web sites. Contacting individual states to obtain data
was outside the scope of this study.
Three key sources provide extensive information about the state programs, An Analysis of State
Superfund Programs: 50-State Study, 2001 Update, and An Analysis of State Superfund
Programs: 50-State Study, 1998 Update, and An Analysis of State Superfund Programs: 50-State
Study, 1995 Update. These studies, prepared by EPA and the Environmental Law Institute are
based on information collected from the 50 states, Puerto Rico, and the District of Columbia. For
convenience, these are referred to as 52 "states." These studies describe each of the states'
programs, including enabling legislation, enforcement provisions, staffing levels, funding, and
other aspects of the programs. Exhibit 9-1, which is based on data in the 50-State Study
summarizes the prevalence of the major state programs.
Unlike some environmental statutes which mandate minimum national standards that could be
administered by the states after their programs are approved by a federal agency, each state
cleanup program is developed according to the state's criteria. Nevertheless, most state
hazardous waste programs include authorities similar to the federal Superfund program. They
typically include provisions for emergency response and long-term remedial actions; cleanup
funds or other mechanisms to finance site investigation and remedial activities; enforcement
authorities to compel responsible parties to conduct or pay for studies and site remediations; staff
to administer state-lead cleanup activities and to oversee remediations conducted by other
parties; and efforts to ensure public participation in decision-making regarding site cleanup and
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reuse. About half the states also authorize long-term stewardship under their statutes (ELI 2002).
Many states have been cleaning up land contaminated by hazardous substances, or overseeing
such cleanups, for about two decades.
Exhibit 9-1. State Cleanup Program Summary
State Program Number of States Explanation
Cleanup Funds 49 Idaho, Nebraska, and the District of Columbia do not
have cleanup funds.
Voluntary Cleanup 50 North Dakota and Vermont do not have formal
Program (VCP) programs; however, they allow private parties to
initiate voluntary cleanups.
Brownfields Program 31 In addition to the 31 states with formal brownfield
programs, 14 target brownfields through their VCPs.
Long-term Stewardship 41 Most of these states have committed scant
Program resources to date.
a Based on 50 states plus Puerto Rico and the District of Columbia, referred to as "52 states."
Sources: U.S. EPA, 2002, An Analysis of State Superfund Programs: 50-State Study, 2001 Update, November
2002.
Sfafe Cleanup Funds
As of December 2000, 49 states, including Puerto Rico, have established cleanup funds or
provide another mechanism to pay for the cleanup of non-NPL sites where no responsible party
is available, able, or willing to do so. Only Idaho, Nebraska, and the District of Columbia do not
have an authorized state cleanup fund. Thirty-six states have more than one fund for cleaning up
contaminated waste sites, resulting in a total of 117 state cleanup funds. There are a variety of
reasons that states have more than one fund. A state may have multiple funds to differentiate
sources or uses of funds. For example, funds may receive money through appropriations,
penalties, cost recoveries, or proceeds from a hazardous waste fee. Some funds may apply only
to specific uses, such as for emergency response, brownfields, a voluntary cleanup program, or a
specific type of site or waste. For example, a number of states have established funds dedicated
to dry cleaning sites.
Sfafe Site Databases
State site lists are a potential source with which to evaluate the extent of the state remediation
market. Many state statutes authorize the development of a priority list, inventory, or registry of
state sites. Some states use these compilations to determine the order in which sites will be
cleaned up. By the end of 2000, about 40 states had some kind of list, registry, or inventory, with
a total of 15,000 sites. However, because the approaches and definitions used by the states vary
widely, the aggregation of these data is neither useful for this market assessment nor to make
comparison among states. Some states list all known and suspected sites, others include only
those that have completed a long evaluation process, and others include only sites where cleanup
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is funded directly by the state. Some states' lists may be useful for contractors seeking
opportunities for site investigation or remediation work in selected states.
Long-Term Stewardship
Forty-one state cleanup programs explicitly address long-term stewardship for sites where
hazardous substances are to remain in place at levels that do not allow for unrestricted use. The
statutes of these states are designed to protect the public health, safety, and the environment at
such sites. Institutional controls are the most common mechanism used for long-term
stewardship. These include property-law-based restrictions such as restrictive covenants and
easements; information systems such as signs, educational materials, published notices, warnings
about consumption offish or wildlife, and site databases; and governmental controls such as
zoning, local ordinances, building permits, and groundwater and well-drilling restrictions.
Although forty-one states have long-term stewardship programs for one or more of their cleanup
programs, most states have committed scant resources to monitoring institutional controls.
Liability
Most state statutes provide a means for charging parties, such as owners, operators, generators,
and transporters, with liability for cleanups. These are the same parties usually charged under
CERCLA. Liability may be charged under state hazardous waste laws or under another statute,
such as a solid waste, water pollution control, or imminent danger statutes.
Many state statutes include provisions for retroactive, strict, and/or joint and several liability
(CERCLA has all three). Forty-three states impose retroactive liability. That is, the state can
impose liability for cleanup of hazardous substances disposed of prior to the enactment of the
statute. Forty-one states have strict liability standards and 36 states use joint and several liability
to allocate liability among multiple responsible parties. Under a strict liability standard, liability
is based solely on the occurrence of a release and does not require proof of fault, such as through
negligence. Under joint and several liability, the state may pursue one or more responsible party
for the full amount of the cleanup. These provisions are potentially powerful incentives for
companies to undertake site remediations.
Given the prevalence of strict, joint and several, and retroactive liability, the potential for
cleanup cost liability is a significant obstacle to redevelopment and, in some cases, to cleanup.
Many state voluntary cleanup and brownfield programs include mechanisms for mitigating the
potential liability of responsible parties, prospective purchasers, owners, and developers. These
programs are described in the next section.
9.1.2 Voluntary Cleanup and Brownfield Programs
Voluntary cleanup programs, a major component of state cleanup efforts, encourage private
parties to voluntarily clean up sites rather than expend state resources or cleanup fund money on
enforcement actions or remediations. VCPs are designed to reduce factors that tend to discourage
voluntary cleanups, such as liability for cleanups, lack of control over the remediation, and cost.
These programs began as innovative programs created by states to respond to requests by
landowners and others for state assistance in facilitating private cleanups of their sites. By the
end of 2000, 50 states (including the District of Columbia and Puerto Rico) had established
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formal VCPs through statute, regulation, or policy. Although the structure, formality, and
operating practices of VCPs differ from state-to-state, there are a number of common elements.
States will generally establish eligibility requirements for participation, clear cleanup standards,
and closure procedures; provide timely oversight; and offer incentives to encourage
participation.
The most common forms of incentives are liability release mechanisms, an expedited cleanup
oversight process, and financial incentives, such as low-interest loans, grants, and tax credits.
Liability protection is the most common of these incentives. Liability protection is provided by
covenants not to sue, no further action letters, certificates of completion, and other mechanisms.
States typically limit the protection only to contamination addressed by the cleanup activities,
excluding unknown or pre-existing contamination, or new releases of hazardous substances. The
Small Business Liability Relief and Brownfields Revitalization Act, signed into law in January
2002, clarifies state and federal roles for overseeing cleanups by providing federal CERCLA
liability protection for parties who conduct a cleanup of certain properties under a state response
program designed specifically for protection of human health and the environment. Prior to this
provision, a state could provide state liability protection for brownfields cleaned up under its
own laws, but a state could not provide federal liability protection.
Most states require a participant to reimburse the state for the cost of overseeing a voluntary
cleanup. Most states also supplement the fees with state and federal funds. The 2002 brownfields
law also provides states with new resources for VCPs. As much as $50 million may be
appropriated annually over the next four years to states and tribes to help them establish and
enhance VCPs and similar response programs.
Of the 50 states that have VCPs, 14 target brownfields through their VCPs, and 31 states have
established brownfield programs that are separate from their VCPs. States define brownfields in
a variety of ways, but the term typically refers to industrial or commercial facilities that are
abandoned or underutilized due, in part, to environmental contamination or fear of
contamination. This differs somewhat from the definition under the 2002 brownfields law (See
Section 9.1.3 below). The scope of the various state programs also vary. States use a wide range
of approaches and tools to facilitate the investigation and cleanup of brownfields. For example,
some states emphasize site investigations or financial incentives, but do not authorize cleanups,
while others may take a more active role in remediations.
It is often difficult to distinguish between a brownfield program and a VCP. Many brownfield
sites are addressed by volunteers. Also, some states are reluctant to identify brownfields that are
not already being remediated because property owners are concerned about the stigma associated
with this designation, which may affect property values. This reluctance has led some states to
carefully control lists or to not publish a list of sites. State brownfield programs are
supplemented by a substantial federal brownfields initiative, which is described in the next
section.
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9.1.3 Federal Initiatives Affecting State Cleanups
The federal government has actively encouraged and assisted states in their efforts to clean up
their contaminated properties. EPA's program dedicated to help states address brownfields has
already affected a large number of sites and will probably affect many more in the future. EPA
defines "brownfield" as "real property, the expansion, redevelopment, or reuse of which may be
complicated by the presence or potential presence of a hazardous substance, pollutant, or
contaminant." These sites are usually abandoned, idled, or under-used industrial and commercial
facilities. Many brownfields are located in urban areas and are generally associated with -
declining property values, increased unemployment, and movement of industries to the suburbs.
EPA estimates that there are between 500,000 and one million brownfield sites.
Where past use of a site raises the possibility that the site may be contaminated, fear of being
caught in the Superfund liability net often stymies further development at the site. Lenders,
developers, and prospective purchasers are discouraged from getting involved with a site
because of the risk of a delay in site development or having to pay cleanup costs. Current
brownfield owners often are not willing to conduct an assessment of their sites for fear of finding
contamination that may have been a result of their activities or those of past owners. Many
brownfields end up as the property of local governments through foreclosure.
The central focus of the federal effort is the Brownfields Program and Small Business Liability
Relief and Brownfield Revitalization Act, which was signed into law in January 2002.
Brownfields Program
The EPA Brownfields Program provides technical and financial support for brownfields
revitalization. EPA's brownfields efforts are based on four themes: protecting the environment;
promoting partnerships; strengthening the marketplace; and sustaining reuse. EPA's investment
in brownfields, more than $700 million since 1993, has leveraged more than $5.1 billion in
cleanup and redevelopment funding, generated more an 25,000 jobs and assessed more than
4,300 properties. The Small Business Liability Relief and Brownfields Revitalization Act (2002)
provides the Brownfields Program with Congressional authorization, increased funding,
strengthened liability protections for certain property owners, and expanded assistance for State
and Tribal response programs.
First, the Brownfields Program protects the environment by providing grants for assessment and
cleanup to states, tribes, local governments, redevelopment authorities, and in some cases, non-
profit organizations. Assessment grants of up to $200,000 per entity can fund efforts to
inventory, characterize, assess, and conduct planning and community involvement related to
brownfields. Cleanup Revolving Loan Fund grants of up to $1 million per eligible entity help
capitalize local funds that can provide both loans and subgrants for property cleanup. Direct
cleanup grants were added by the brownfields law and provide up to $200,000 per site to public
and nonprofit entities, who must own the site to be eligible. The brownfields law added
petroleum contamination to the list of sites eligible for brownfields funding and directed that 25
percent of brownfields funds be used for petroleum sites. The Brownfields Program also gives
technical assistance and targeted assessments to help communities.
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Partnership efforts are a second key aspect of the Brownfields Program. At the federal level, the
Brownfields National Partnership brings together more than 20 federal agencies to help
communities with issues related to brownfields revitalization. For example, the Department of
Housing and Urban Development and the Economic Development Administration provides
funds to help with the redevelopment activities beyond EPA's programs, such as acquiring
property and helping rebuild infrastructure. The National Oceanic and Atmospheric
Administration leads an interagency "Portfields" project that focuses on interagency
collaboration to revitalize port and waterfront areas. The Brownfields Program provides $50
million a year to support state and tribal response programs and has signed Memoranda of
Agreement with many states to clarify regulatory responsibilities. The Brownfields Program
works with a wide range of organizations to conduct research, training, and technical assistance
for communities, including grants of up to $200,000 to communities for Brownfields Job
Training. The annual Brownfields Conference, co-sponsored by EPA, brings together the entire
range of stakeholders—more than 4,200 people attended Brownfields 2003 in Portland, Oregon.
Third, the Brownfields Program works to strengthen the private sector marketplace for
brownfields. The brownfields law provides liability protections for innocent landowners,
prospective purchasers and contiguous property owners. Enforcement policies and tools have
helped change perceptions that discouraged brownfields revitalization. As required under the
brownfields law, EPA is developing regulatory standards for "all appropriate inquiries" that will
specify actions property developers and owners must take prior to a property transfer to qualify
for liability protections. The private sector is further supported by financial tools such as
brownfields tax incentives and new insurance and risk management vehicles.
Lastly, the Brownfields Program is a strong force for sustainable development. A study
conducted by George Washington University shows that every acre of brownfields redeveloped
saves 4.5 acres of greenspace. The Brownfields Program has worked closely with Smart Growth
advocates and Green Building experts to conduct pilot projects and encourage redevelopment
that provides long-term economic and environmental benefits.
9.2 Factors Affecting Demand for Cleanups
The state market for remediation services is largely dependent upon the pace of development, the
commitment and ability of states and private companies to establish and manage hazardous
waste programs and to finance cleanups, and the extent of state and federal efforts to encourage
or compel responsible parties to clean up sites.
• Increases and decreases in state cleanup funds will affect the number and complexity of
remedial actions undertaken by the states. Total funding to state cleanup funds has remained
steady in recent years, which indicates that many states will have to rely on their ability to
either compel private parties or encourage voluntary cleanup actions. State assurance funds
may be impacted by economic and political conditions that influence state revenues.1
1 In a survey of 231 cities of all sizes published in 2000, 90 percent of the cities identified lack of funding for
cleanup as the most important impediment to cleanup and redevelopment. (U.S. Conference of Mayors 2000).
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Although total funding to state cleanup funds has remained steady, there have been shifts in
funding levels among different types of funds. For example, dry cleaner funds have grown
in recent years.
The Brownfields Revitalization Act is expected to expand the number of sites to be assessed
and/or cleaned up. The law greatly mitigates the potential liability of innocent (not
responsible for pollution) property owners; reduces financial uncertainties for investors and
property owners; and directly funds various projects and programs, which serve as
examples, case histories, and lessons learned for other sites.
By removing obstacles that cause investment capital to flee from brownfields, the
Brownfields Revitalization Act is expected to foster new opportunities for site
characterization, cleanup, and redevelopment, especially in the following situations:
• • Communities that use smart growth and infill strategies, and that are seeking to improve
community-wide quality of life;
• • Sites with "relatively low risk" petroleum contamination, which previously were
generally not eligible for federal assistance;
• • Sites where cleanup and development have been hampered by an inability to obtain
financing or insurance because of uncertainties in remediation costs;
• • States without effective voluntary and other cleanup programs or those whose programs
have been hampered by a lack of funding; and
• • Sites where cleanup and redevelopment had previously been hampered by a potential
for Superfund liability.
The new law strengthens liability protections for innocent purchasers, contiguous property
owners, and prospective purchasers, thereby encouraging more brownfield site assessments,
cleanups, and redevelopment. The 1986 amendments to CERCLA (SARA) attempted to
provide protection to "innocent landowners" through the addition of Section 101(35). This
provision applies if a party that acquired real property after the disposal of hazardous
substances did not know about the hazardous substances on, in, or at the property when it
was acquired. However, this authority was used only infrequently because it was difficult to
establish a legal defense. The new brownfields amendments provide significant statutory
changes affecting the potential liability of owners, developers, and prospective purchasers of
real estate. It is expected that the law will reduce the potential liability and transaction costs
of owners, developers, and prospective purchasers of brownfield sites.
The pace of development in a community or region will influence the number of brownfield
and voluntary sites that need to be evaluated and/or cleaned up. Because there are an
estimated hundreds of thousands of potentially contaminated brownfield sites that have not
been located, most development in populated areas are likely to encounter contaminated
sites from time-to-time.
As neighborhoods become revitalized and as communities grow, the demand for, and price
of, land will increase. Higher property values can support more investments in site cleanups.
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Given the potentially large number of brownfields compared to the number of voluntary
cleanup program and brownfield sites addressed in recent years (7,100 cleanups underway
and 2,200 completed in FY 2000), brownfield cleanups are likely to continue for many
years.
The growing popularity of smart growth policies is likely to advance the demand for the
state and brownfield cleanups, since infill development and the preservation of greenfields
are primary components of smart growth programs.
Forty-one states have long-term stewardship programs for one or more of their cleanup
programs. These programs are important because of the widespread use of remedies that
allow hazardous substances to remain on site, so long as land-use restrictions are
implemented. States have been establishing and enhancing their long-term stewardship
programs. One of the greatest needs are systems to keep track of sites requiring stewardship.
Considering the growing use of risk-based corrective action and the practice of leaving
waste on site, there is a perceived need for enhancement of long-term stewardship programs.
Over approximately the past decade, the U.S. capacity to address brownfields has grown
enormously. A decade ago, few developers and investors were willing to consider potentially
contaminated properties. Today, there is an expanding cadre of developers, planners, consultants,
engineering and construction firms, attorneys, and public officials with the expertise to evaluate,
cleanup, and revitalize brownfield properties. The increasing acceptance of the practicability of
cleaning up and revitalizing brownfield sites has the potential for enlarging the market for site
characterization and cleanup services.
9.3 Number and Characteristics of Sites
This subsection presents estimates of the number of state and private party sites expected to
require remediation under state mandatory hazardous waste remediation programs and voluntary
cleanup and brownfield programs.
9.3.1 State Mandatory Hazardous Waste Programs
The 50-State Studies present the results of surveys in which each state was asked to identify the
total number of "known and suspected sites" and "sites needing attention." The number of
known and suspected sites generally is the largest number of potentially contaminated sites
known to the state and includes, in some states, sites that have not yet undergone any type of
assessment. This category is useful in determining the outer limit of the universe of state sites.
The sites needing attention are known and suspected sites that have been evaluated by the state
and determined to require some level of further evaluation or cleanup. This category is the best
indicator of the workload facing each state's cleanup program. The studies do not present
estimates of the number of sites that definitely require remedial action. Exhibit 9-2 presents
trends in these variables and Exhibit 9-3 shows each state's estimate for both categories of sites.
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The total number of known and suspected sites reported in 2000 was 63,000 (up from 59,0002
in 1997 and down from 79,000 in 1995). Because a number of states have reclassified their sites
over the years, it is difficult to establish a firm trend. However, it appears that the universe of
sites is stable and that the states are continuing to identify new sites. The number of known and
suspected sites ranges from zero to 5,416 (Connecticut). Twenty-six states reported increases in
known and suspected sites while eight reported decreases. The states with the largest increases
between 1997 and 2000 were Connecticut, Florida, Louisiana, Missouri, New Mexico, Oregon,
Rhode Island and South Carolina; and the states with the largest decreases were Alaska, Arizona,
New Jersey, Washington, and Wisconsin.
Exhibit 9-2. Sites in State
Hazardous Waste Programs
120,000
100,000 -
.« -
m
*§«*
° -
o
J3
Z
40,000
20,000
Known & Suspected
Attention
Although states are
progressing to clean up
their sites, they continue
to identify new ones. The
total number of sites
needing further attention
in 2000 was 23,000, an
increase from 19,000 in
1997.3 During this time,
states completed cleanup
of over 19,000 sites.
While some of the data
reflects progress in
completing cleanups, it
also reflects
reclassification of sites by
some states and a decline
in the number of states
reporting. The number of
sites needing attention
ranges from zero to 3,900 (New Jersey).Only five states report having more than 1,000 sites
needing attention- Connecticut, Florida, Kentucky, Massachusetts, and New Jersey.
Of the sites reporting in both 1997 and 2000, 23 had increases and 12 states had decreases in
sites needing attention. The states with the largest increases between 1997 and 2000 were
Connecticut, Florida, Georgia, Kentucky, and South Carolina. The states with the largest
decreases were Alaska, Arizona, New Jersey, Washington, and Wisconsin. After considering
reporting discrepancies, such as those in the footnotes, it appears the total universe of sites
needing attention is stable, or growing slightly. (50-State Study 2000).
1991
1993
1995
Year
1997
2000
Source: Environmental Law Institute, An Analysis of State Superfund
Programs: 50-State Study, 2001 Update, November 2002.
The 1998 50-State Study reported 69,000. However since then, the State of New Jersey subtracted 10,000
home-owner tanks sites from the list.
3 The 1998 50-State Study reported 23,000; however, the 2000 study revised the data, primarily because of
reclassification of sites and because two states that reported in 1997 did not report in 2000. Counting only the states
that provided data in both years, the total for 1997 is 20,100 and the total for 2000 is 22,700.
Chapter 9: State and Private Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 9-3. Number of Non-NPL State Hazardous Waste Sites
Known & Suspected Sites* Sites Needing Attention b
State 1997 2000 1997 2000
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey c
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
700
1,625
900
363
3,247
624
3,029
600
NA
1,900
1,012
524
NA
5,000
NA
400
720
1,900
410
465
440
2,679
NA
3,000
960
1,475
NA
400
129
474
5,177
344
1,567
1,040
NA
1,460
793
1,933
50
NA
400
603
1,424
1,360
388
325
730
968
71
415
3,603
495
5,416
532
NA
2,646
1,280
558
NA
5,000
200
475
NA
2,200
730
475
440
2,305
NA
3,000
1,100
2,321
NA
475
112
388
5,000
1,210
1,628
1,122
NA
1,884
850
2,469
50
NA
1,200
1,037
1,342
1,501
611
390
125
1,206
75
98
420
178
668
185
NA
1,094
126
103
NA
140
NA
200
484
850
120
128
33
2,679
2,789
219
500
225
187
200
129
474
4,915
133
769
793
NA
403
124
306
20
NA
100
150
NA
234
52
40
125
783
38
67
522
200
2,107
331
NA
2,460
422
105
NA
159
61
210
NA
1,500
130
83
33
2,305
NA
100
500
250
288
225
12
388
3,900
153
851
730
NA
403
170
499
20
NA
150
516
229
210
48
50
Chapter 9: State and Private Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 9-3. Number of Non-NPL State Hazardous Waste Sites (Continued)
Known & Suspected Sites9
State 1997
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Total
362
2,015
1,493
600
5,000
140
59,450
Notes:
a Known and suspected sites are those that states
2000
390
2,015
946
NA
3,000
NA
62,580
Sites Needing Attention11
1997
255
411
1,006
150
600
NA
24,096
2000
250
411
623
NA
NA
NA
22,617
nave identified as being potentially contaminated. Many of these sites
will not require action beyond a preliminary assessment. Site numbers are derived from Table IV-3 of the 2001 50-
State Study and Table V-3 of the 1997 50-State Study, unless otherwise noted. The totals include an unknown, but
small, percentage of LIST and RCRA sites.
b Sites needing attention are those known and suspected sites that have been assessed and determined to require
further assessment or cleanup. Many of these sites will require removal or remedial actions. Site numbers are derived
from Table IV-3 of the 2001 50-State Study and Table IV-3 of the 1997 50-State Study, unless otherwise noted. The
totals include an unknown, but small, percentage
c The 1 998 50-state Study reported 69,000 sites in
homeowner tank sites from the list.
NA Indicates that data were not provided.
Sources:
Environmental Law Institute, An Analysis of State
2002.
Environmental Law Institute, An Analysis of State
of LIST and RCRA sites.
New Jersey. However, since then, the state subtracted 10,000
Superfund Programs: 50-State Study, 2001 Update
November
Superfund Programs: 50-State Study, 1998 Update.
The total number of sites determined to need further attention includes an unknown but small
percentage of RCRA and UST sites, which are addressed in Chapters 4 and 5 of this report.
During collection of data from the states, authors of the 50-State Study requested that the states
exclude RCRA and UST sites from their reports, if they could. However, some states were
unable to separate the RCRA and UST site data from other hazardous waste sites.
9.3.2 Voluntary Cleanup and Brownfield Programs
The 50-State Studies also asked states to report the number of voluntary cleanup and brownfield
sites. Exhibit 9-4 presents the national totals from the survey data. Since the inception of their
programs, states have completed cleanup at 11,600 sites under their voluntary programs and
17,300 sites under their mandatory programs. In FY 2000, states completed 2,200 voluntary
cleanups and 2,400 mandatory-program cleanups, and had a total of 15,600 cleanups underway.
By the end of 2000, the reporting states had identified 18,700 brownfields, had cleanups
underway at over 1,000 brownfield sites, and had redeveloped over 700 sites. To avoid double
counting some sites, this study does not add the data on brownfield sites to the above figures,
since many are cleaned up under voluntary and mandatory programs. Nevertheless, many sites
identified by a brownfields program may not have been reported on a voluntary or mandatory
program list. Thus, the estimates of total state and private party site market may be understated
somewhat. Another factor that may contribute to the underestimation of brownfields sites is the
fact that some states are reluctant to identify brownfields that are not already being remediated
Chapter 9: State and Private Sites
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because property owners are concerned about the stigma associated with this designation, which
may affect property values.
Based on these data, total state cleanups under all state programs has averaged approximately
5,000 per year in recent years. Despite the progress in completing many cleanups in recent years,
the known number of sites listed as needing attention or entered into a voluntary program has
remained approximately stable. As of the end of FY 2000, this inventory of sites was about
30,000 (22,600 from Exhibit 9-3 +7,100 from Exhibit 9-4). This apparent discrepancy is
attributed to the fact that state
Exhibit 9-4. Voluntary and Mandatory
Cleanup Program Status
30,000 -,
25,000 -
Ł 20,000
iio
*S 15,000
i
z
10,000 -
5,000
28,900
Mandatory
VCP
15,600
7,100
4,600
2,200
11,600
Cleanups
Underway
Cleanups
Completed
2000
Cleanups
Completed
through 2000
regulatory agencies are
continuing to identify new sites
and new sites are continuing to
enter voluntary and brownfields
programs. In addition, some of
the 18,700 brownfield sites
identified by states are not
included in this figure, in order to
avoid potential double-counting
of some sites. Thus, the currently
identified inventory of sites likely
to need remediation (30,000) is
probably underestimated.
Based on the above data, about
44,500 state sites have been
identified, including those that
have completed or are undergoing
remediation. Although it is
anticipated that many brownfields
will not require remediation, the actual number is unknown. An indication of the percentage of
sites needing cleanup is provided from data EPA has collected from recipients of EPA
brownfields pilot grants. Of 5,000 sites targeted by previous grants, about two-thirds required
further investigation and/or remediation beyond a Phase I and Phase II site assessment (EPA
2003). This figure implies that, even if the percentage of future sites needing cleanup is lower, it
is still likely to represent a substantial number of sites; and at the current rate of 5,000 cleanup
completion annually in all state programs, it will take many years to remediate all the brownfield
sites.
9.3.3 Contaminants and Media
A central source of information on the types and quantities of contaminants and media found at
state sites is not available. Three sources provide information on technologies used at state sites
across the country. Although none of these sources is based on a comprehensive survey, they
provide a picture of the types of contaminants and technologies likely to be found at state sites.
In addition, some information on contaminants found are available from a number of states.
State Cleanup Program
Source: Environmental Law Institute, An Analysis of State Superfuno
Programs: 50-State Study, 2QQ1 Update, November 2002.
Chapter 9: State and Private Sites
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The first source, The XL Environmental Land Reuse Report 2002, and The XL Environmental
Land Reuse Report 2001, are reports on a unique data collection conducted by XL
Environmental, Inc. and the International Economic Development Council. These studies are
based on a literature search of media coverage of brownfield-related stories. The researchers
used online newspaper and journal archives, such as Lexis-Nexis, to search for articles that
mention brownfields issues. The search identified 331 brownfield-related articles between July
2001 and June 2002 discussing 428 brownfield sites; and 317 articles between July 2000 and
May 2001 discussing 346 sites. Chemicals, metals, and petroleum are the most frequently
mentioned contaminants. Solvents and pesticides were also an issue at some sites. (Exhibit 9-5)
The second source is the Brownfields Management System, a database containing information
about brownfield properties that are in EPA's grant programs. As of December 2002,
contaminant data are available for only approximately 90 sites. Metals are the most frequently
identified category of pollutant. VOCs, SVOCs (including PAHs and PCBs) and petroleum
products were also frequently identified.
Exhibit 9-5. Contaminants Found at a Sample of Brownfield Sites
Contaminant
2001
2002
Total
Number Percent Number Percent
Chemicals
Metals
Other
Petroleum
Solvents
Pesticides
No. of Sites in
sample a
86 25%
61
55
35
13
4
346
a Not all articles provided information
and perhaps their relative frequency
reported per site.
18%
16%
10%
4%
1%
56
25
43
50
10
3
428
13%
6%
10%
12%
2%
1%
on contaminants. Thus, this data is an indication
, rather than a precise accounting. There may be
Number
142
86
98
85
23
7
774
Percent
18%
11%
13%
11%
3%
1%
of the types of contaminants
more than one contaminant
Source: XL Insurance, Inc. and the International Economic Development Council, The XL Environmental Land
Reuse Report 2002, and The XL Environmental Land Reuse Report 2001. XL Environmental, Inc.
The types of contaminants present at some state sites can also be inferred from sites listed in
EPA's CERCLA Information System (CERCLIS), EPA's database of potentially contaminated
sites. EPA has performed preliminary assessments at these sites to screen them for potential
listing on the federal NPL. The majority of these sites (those not listed on the NPL) are deferred
to the states for action. CERCLIS data show that the most prevalent wastes at these sites are
organic chemicals, metals, solvents, and oily waste (U.S. EPA 1991).
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In addition to national data sources, some states with established, well-funded programs are able
to produce this type of information. For example, the California Department of Toxic Substances
Control, within the state's Environmental Protection Agency, publishes extensive information
about its site mitigation programs as well as access to its Site Mitigation and Brownfields Reuse
Program Database on its web site. The database contains information on almost 10,000 potential
and known sites (CALEPA 2003).
9.4 Estimated Cleanup Costs
The cost of cleaning up state mandatory and voluntary cleanup program sites is determined by
the number of state sites and the amount of remediation work at each site. As described in
Section 9.3, the number of potential state sites is so large relative to state and private resources
that it is likely to take a number of decades to complete all the cleanups. Thus, a key determinant
of cleanup activity in a given year will be resources available, primarily in state cleanup funds,
which account for most state-funded cleanups. This section describes the trends in state
expenditures, the status of state cleanup funds, and an estimate of the total cost to complete the
cleanup of all known and likely to be discovered state sites over a period of 30 years.
9.4.1 Status and Capacity of State Cleanup Funds
A fund is an essential element of a state's program to clean up sites. It is a readily available
source of money separated from other state operations that allows activities to continue without
the need for annual appropriations or other legislation. It allows a state to avoid disruptions to
cleanups and to investigate, plan, design, and conduct emergency response and remedial actions
at sites where immediate action is required or where responsible parties are unavailable, unable,
or unwilling to conduct or pay for remedial actions. Forty-nine states have established cleanup
funds or provided a mechanism for the state agency to pay for one or more types of cleanup
activities at non-NPL sites. Idaho, Nebraska and the District of Columbia are the only states
without cleanup funds that are authorized to pay for cleanups. Although most state-financed
cleanups are paid from a state cleanup fund, some are funded by direct appropriations. Thus, the
estimate of state expenditures may understate the actual expenditures.
The combination of fund balances, additions to funds, and expenditures can indicate the
capability and stability of a state cleanup program. Exhibit 9-6 compares the fund balances,
additions to funds, and expenditures of the states in 1995, 1997, and 2000. Total fund balances
for all states in 2000 was $1.2 billion. The trends in fund balances are confounded by the fact
that in each survey there are some states that do not provide data and they differ from one survey
to another. Comparing only the states that provided data in both 1997 and 2000, the decrease
would be about 10 percent. Fund balances have been declining since 1990.
Most of the state fund balances (including bonding authority) are concentrated in a relatively few
states. In 2000, eight states (Alaska, California, Massachusetts, Michigan, New Jersey, New
York, Pennsylvania, and Texas) accounted for $909 million (73.5 percent) of the total fund
balances for all states. This concentration has been observed since this survey was first
conducted in 1991. The annual contributions to state funds fluctuated from year to year, but have
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averaged between $400 and $500 million. As with fund balances, the amounts added to funds are
concentrated in a relatively few states.
Exhibit 9-6. State Fund Activity
1995, 1997, and 2000 ($ millions)
1995
1997
2000
Total Fund Balances a
Additions to Funds
Expenditures
Obligations
Number of Known and Suspected Sites
Number of Sites Needing Attention
$1,464.9
$444.6
$386.1
$363.4
79,387
29,000
$1,413.0
$538.3
$565.1
$448.0
59,000
24,000
$1,240.0
$436.2
$505.6
$564.4
63,000
23,000
a Fund balances include both money in the fund and authority to sell bonds to raise additional monies. The
expenditures and obligations totals are likely to be understated for two reasons: Between 35 and 38 states out
of 49 provided 2000 data for most of these items. The response rate for 1997 was higher. In addition, some
states did not report expenditures for all their funds.
Exhibit 9-7 presents the Superfund balances for each state as of December 2000 and 1997 and
provides the total expenditures and obligations of funds by each state for hazardous waste
activities in 2000 and 1997. The state fund balances totaled $1.2 billion in 2000, including bond
authorizations (authority by state law to issue bonds and spend the proceeds on cleanups). While
the average state site cleanup costs less than a quarter million dollars, many sites can cost more
than $1 million. While almost all states have some cleanup funds, fund balances in some states
are quite small. These funds could pay for little more than emergency responses and removal
actions. At the end of 2000, 6 states had fund balances of less than $1 million (Alabama, Iowa,
Mississippi, North Dakota, Oklahoma, and Utah). Another 8 states had balances between $1
million and $5 million; 3 between $5 million and $10 million; 15 between $10 million and $50
million; and 8 had balances over $50 million.
Although a state's fund balance indicates its ability to pay for a cleanup at any given time, this
indication is only an approximation of cleanup activity in a state in a given year. The level of
cleanup activity also depends on the rate that funds flow into and out of the fund, which differs
from one state to another. Thus a state that rapidly replenishes its funds, for example by
recovering cleanup costs from responsible parties, would have a high level of cleanup activity
relative to the balance of the fund at any given time. Also, states may supplement funds with
appropriations for specific projects.
Another indication of state's ability to manage mandatory cleanups and oversee voluntary
cleanup programs is the level of state cleanup program staffing. In 2000, total state cleanup
program staffing (3,344) was about the same level as in 1991 (3,394). Over those years, they
have fluctuated only within a range of about 3 percent.
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Exhibit 9-7. State Hazardous Waste Funds
Expenditures and Balances 2000 and 1997
Expenditures a Fund Balances b
State 1997 2000 1997 2000
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
199,290
20,830,212
4,488,566
201,174
228,000
1,200,000
c
2,670,000
c
22,199,865
17,589,411
711,096
c
8,800,000
4,284,377
650,391
1,516,000
1,800,000
200,790
2,267,436
c
7,100,000
40,088,000
5,144,005
2,280,000
2,700,000
7,312,614
c
300,000
1,700,000
81,300,000
230,412
158,794,899
938,311
c
16,841,377
877,718
11,080,828
37,397,633
c
300,000
630,613
c
7,209,656
41,242,559
500,000
5,200,000
123,422
42,682,982
332,700
7,720,413
15,275,703
c
c
2,452,380
c
3,500,000
c
4,337,746
10,484,945
1,200,288
c
17,452,500
12,514,959
328,080
c
700,000
6,497,001
1,991,420
7,000
35,900,000
46,330,000
7,897,000
2,681,383
3,500,000
7,312,614
c
c
2,100,000
25,130,961
440,836
122,081,213
582,972
c
c
1,339,036
13,625,860
39,000,000
c
c
3,100,000
1,183,092
11,316,640
24,002,551
0
7,219,000
6,500
28,731,105
615,590
76,154,222
813,192
8,798,191
2,411,121
19,000,000
13,500,000
8,400,000
c
24,529,984
1,073,451
225,000
c
21,900,000
24,511,554
1,060,868
c
4,000,000
1,693,995
7,400,000
500,000
86,300,000
7,644,000
5,300,398
750,000
(1,300,000)
14,506,467
c
1,000,000
1,500,000
114,700,000
1,659,814
612,041,042
4,823,533
160,000
31,081,540
17,168
12,142,352
120,026,484
c
50,000
25,077,100
1,750,000
9,559,569
69,898,478
1,500,000
4,800,000
3,569,781
44,867,955
450,000
64,955,963
17,895,429
c
84,548,000
16,119,065
24,170,610
13,000,000
c
15,006,808
12,762,010
1,981,063
c
24,033,600
41,350,404
89,484
c
1,500,000
3,851,299
9,270,375
1,816,898
53,900,000
133,172,000
12,800,000
112,800
2,900,000
14,506,467
c
c
7,800,000
189,093,523
1,623,000
215,009,586
10,430,858
163,000
c
313,451
21,242,558
110,000,000
c
c
5,000,000
2,835,732
12,082,752
55,721,609
400,000
1,696,000
0
14,374,009
Chapter 9: State and Private Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 9-7. State Hazardous Waste Funds
Expenditures and Balances 2000 and 1997 (Continued)
State
West Virginia
Wisconsin
Wyoming
Total
Expenditures a
1i97 2000
758,585
2,567,000
c
565,137,222
c
9,076,600
c
477,352,498
Fund
19i7
Balances b
2000
1,800,000
21,381,000
c
1,413,193,849
c
26,542,200
c
1,224,520,553
Notes:
a Includes funds spent by the states in 1 997 and 2000 for NPL and non-NPL site cleanups. Totals differ slightly from
those in the 2001 50-State Study because of rounding.
b Includes bonding authority. Totals differ slightly from those in the 2001 50-State Study because of rounding.
C Indicates that data were not provided
Sources: Environmental Law Institute, An Analysis of State Superfund Programs: 50-State Study, 2001 Update,
November 2002.
Environmental Law Institute, An Analysis of State Superfund Programs: 50-State Study, 1998 Update.
9.4.2 Annual and Projected Cleanup Costs
The estimate of the cost of cleanup is based on trends in state and private party cleanups over the
past six years.
• It has been estimated that there are between l/2 and 1 million brownfield sites in the U.S.
(Section 9.1.3). However, the percentage of sites that will need cleanup is unknown. About
70 percent of the 5,400 properties that have been part of a federal brownfield assistance
program and that have completed site assessments require cleanup activities. However, this
percentage is likely to be lower for sites not yet in a federal brownfields program. Thus, the
70 percent (or 350,000 to 700,000 sites) is the estimated upper limit of the potential market.
• Non-NPL cleanup expenditures by states have typically been about $500 million annually.
This figure is the total of mostly non-NPL expenditures for 37 states that reported this item
separately in the 2001 50 State Study (ELI 2002a). This figure does not include 13 states for
which data are not available, nor does it include direct appropriations for specific cleanup
projects. On the other hand the total includes some costs for administration and Superfund
site cleanups.
• Responsible party expenditures are estimated to be equal to state expenditures, based on a
1994 EPA/ASTSWMO study (U.S. EPA 1994). Cost data submitted for 3,395 sites listed in
CERCLIS during the period 1980-1992 indicated that responsible parties paid $555 million
and the states paid $650 million to clean up these sites. Responsible parties' expenditures
appear to be roughly equal to state expenditures at state sites. No centralized source of data
are available that includes private party expenditures for cleanups through the states'
voluntary cleanup or brownfield programs.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
• Adding the above figures indicates that total cleanup expenditures at state sites has been
averaging about $1 billion annually in recent years. During this same period, cleanup has
been completed at about 5,000 state and private party sites annually. At this rate, about
150,000 sites can be completed over the next 30 years, at a cost of $30 billion (Exhibit 9-8).
• This level of effort may or may not be sufficient to address cleanup at all state sites within
30 years. If a small percentage of the 1A to 1 million brownfield sites require cleanup, this
level of effort may be sufficient to clean up all state sites. However, if the percentage of sites
that require remediation approaches those in the EPA brownfield assistance programs (70
percent), this level of funding will only pay for 1A to l/2 of the required cleanups.
Thus, total expenditures for both state and privately-funded remediation is estimated to be $30
billion (Exhibit 9-8). If more than 150,000 sites need cleanup it will likely take more than 30
years, unless additional funding becomes available. There may also be sites addressed by private
parties which are not under the auspices of a state or federal program. Nationwide data on these
sites are not available.
Exhibit 9-8. Estimated Total Cost of State Site Cleanups ($Millions)
Annual Average 30-Year Total
State Expenditures $500 $15,000
Private Expenditures $500 $15,000
Total Expenditures $1,000 $30,000
Source: See explanation in text.
9.5 Market Entry Conditions
The following factors will be important to the success of vendors seeking to operate in the state
and brownfield site characterization and cleanup market:
• By the end of 2000, about 40 states had some kind of list, registry, or inventory of state
sites, with a combined total of 15,000 sites (ELI 2002). Some states use these compilations
to determine the order in which sites will be cleaned up. Some states list all known and
suspected sites, others include only those that have completed a long evaluation process, and
others include only sites where cleanup is funded directly by the state. Some states' lists
may be useful for contractors seeking opportunities for site investigation or remediation
work in selected states.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
The Brownfields Revitalization Act mandates that, as a prerequisite for certain CERCLA
liability protections provided to certain sites cleaned up under state response programs, and
to receive certain federal assistance funds, states must maintain a public record of sites
addressed through their brownfield programs. These records, once established, may serve as
a source for vendors to review for prospective remediation needs. Some existing state site
lists do not include all sites that are likely to require investigation and cleanup. Nevertheless
they provide a method to quickly identify potential projects and issues.
The operating practices of state cleanup, brownfields, and voluntary programs vary from
state-to-state. Remediation technology vendors could benefit by knowledge of the practices
and trends in each state, and perhaps forming alliances and partnerships with developers in
specific areas. Much development is done by local or regional firms with knowledge of local
markets. Information on state programs is available in several publications by the Northeast-
Midwest Institute, EPA, the General Accounting Office, and the state web sites (Bartch
2000, Bartch 2002, GAO 2000, EPA 2002a).
Some states have cleanup funds, such as an emergency response fund or a drycleaning site
fund. These funds are potential sources of information about potential cleanup projects and
technology needs.
Companies interested in R&D, site assessment, cleanup, or revitalization at a brownfield site
may encourage their communities or state to apply for funds from one or more of the federal
or state programs.
Often, the site investigation and cleanup is only a small portion of the total cost of a
development project. A site may not even enter into a cleanup program until development
occurs in the area. For example, a public works project such as a pipeline or sewer line may
call for environmental assessments which result in the discovery of contaminated materials.
Remediation vendors would benefit from comprehensive knowledge of development
projects in their areas.
Development of brownfields often involves the integration of diverse disciplines (urban and
transportation planners, developers, real estate professionals, environmental engineers,
remediation experts, community involvement experts) and cooperation of many stakeholder
groups (developers, residents, local businesses, state and federal environmental regulators,
local zoning and planning officials). Thus, firms that specialize in remediation may form
alliances with firms that specialize in other aspects of brownfield projects. A number of
firms with both remediation and development capabilities have emerged over the past
decade.
Chapter 9: State and Private Sites Page 9-20
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
9.6 Remediation Technologies
Three sources provide information on technologies used at state sites. Although none of these
sources is based on a comprehensive survey, they provide a picture of the types of contaminants
and technologies likely to be found at state sites.
The first source, The XL Environmental Land Reuse Report 2002 and The XL Environmental
Land Reuse Report 2001, are reports on a unique data collection conducted by XL
Environmental, Inc. and International Economic Development Council. These studies are based
on a literature search of media coverage of brownfield-related stories. The researchers used
online newspaper and journal archives, such as Lexis-Nexis, to search for articles that mention
brownfield issues. The search identified 331 brownfield-related articles between July 2001 and
June 2002 discussing 428 brownfield sites; and 317 articles between July 2000 and May 2001
discussing 346 sites. The most frequently used remediation approaches are shown in Exhibit 9-9.
Demolition, excavation, and capping were the most frequently used techniques. Lead paint and
asbestos are the most common contaminants in buildings. Excavation is the removal and offsite
disposal of contaminated soil from the property. Capping was used on many sites intended for
public recreation or ecological use, such as ballparks, golf courses, and nature reserves. About
one-third of the capping applications were on former landfills. More advanced methods, such as
SVE, thermal desorption, and bioremediation were mentioned infrequently. These approaches
are fairly new, and are more difficult for most developers and communities to understand.
However, the incidence of the use of innovative technologies at brownfield sites may be
understated in the source articles because reporters have chosen not to address the remediation
aspects of the projects. Because most of the articles are written for the general public,
remediation techniques and technical details are not the main focus of many articles.
Since there are numerous potential site characterization and cleanup situations that may arise at a
given state site, and since many of the sites to eventually be cleaned up are still unidentified, it is
impossible to detail the specific technologies that will be needed. Technologies that will
accelerate the pace of development or reduce remediation costs or the total cost of a project will
be needed. Real estate developers put a premium on saving time and completing projects
quickly. Delays tend to be very expensive, since they can drive up the cost of projects. EPA's
Technology Innovation Program has published a useful reference to help developers,
communities, and remediation professionals engage the process of cleanup and redevelopment.
This document, Road Map to Understanding Innovative Technology Options for Brownfields
Investigation and Cleanup, is available from the EPA web site (U.S. EPA 2001). The document
also provides links to state brownfield programs.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 9-9. Remediation Techniques Used at a Sample of Brownfield Sites
Remediation 2001 2002
Technique Number
Demolition 46
Excavation/ Removal 44
Caps 17
SVE 5
Natural Attenuation 3
Soil Flushing 2
Thermal Desorption 2
Solvent Extraction 1
Slurry Walls 1
Bioremediation NA
No. of Sites Reporting a 121
Not all articles provided information on
available for 187 sites. Thus, this data
accounting.
Percent Number Percent
38 31 46
36 16 23
14 14 21
4 1 2
2 1 2
2 1 2
2 1 2
1 NA NA
1 NA NA
NA 1 2
100% 66 100%
remediation technologies. Out of 772 sites
is an indication of the types of approaches
Total
Number Percent
77 41
60 32
31 17
6 3
4 2
3 2
3 2
1 1
1 1
NA NA
187 100%
technology information was
rather than a precise
Source: XL Environmental, Inc. and the International Economic Development Council. The XL Environmental Land
Reuse Report 2002, and The XL Environmental Land Reuse Report 2001 .
9.7 References
Bartch, Charles and Bridget Dorfman, 2000. Guide to Federal Brownfields Programs,
Northeast-Midwest Institute, Washington, D.C. October 2000.
Bartch, Charles and Rachel Deane, 2002. Brownfields State of the States, An End of Session
Review of Initiatives and Program Impacts in the 50 States, Northeast-Midwest Institute,
Washington, D.C. December 2002.
California Environmental Protection Agency (CALEPA 2003) Department of Toxic Substances
Control, Site Mitigation and Brownfields Reuse Program Database, http://www.dtsc.ca.gov/
SiteCleanup/Brownfields/index.html#Voluntary%20Cleanup%20Program
ELI (Environmental Law Institute and U.S. EPA), 1996. An Analysis of State Superfund
Programs: 50-State Study, 1995 Update, EPA-540-R-96-036, PB96-963249, July 1996.
ELI (Environmental Law Institute and U.S. EPA), 1998. An Analysis of State Superfund
Programs: 50-State Study, 1998 Update.
ELI (Environmental Law Institute and U.S. EPA), 2002a. An Analysis of State Superfund
Programs: 50-State Study, 2001 Update, November 2002.
Chapter 9: State and Private Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
National Association of Environmental Professionals (NAEP), 2003. Environmental Practice,
Special Issue on Brownfields, March 2003, ISSN 1466-0466. http://www.envpra.oupjournals.org
U.S. Conference of Mayors, 2000. Recycling America's Lands: A National Report on
Brownfields Redevelopment, Volume III, February 2000.
U.S. Congress, 2002. Small Business Liability Relief and Brownfields Revitalization Act of 2001
(PL 107-118, 11 January 2002). http://www.epa.gov/brownfields/sblrbra.htm
U.S. EPA, 1991. Superfun d CERCLIS Characterization Project: National Results, EPA/540/8-
91/080, U.S. Environmental Protection Agency, Office of Emergency and Remedial Response,
November 1991.
U.S. EPA, 1994. A Report on State/Territory Non-NPL Hazardous Waste Site Cleanup Efforts
for the Period 1980-1992, OSWERPub. 9242.2-09, EPA/540/R-94/001, U.S. Environmental
Protection Agency, Office of Solid Waste and Emergency Response and Association of State
and Territorial Solid Waste Management Officials, July 1994.
U.S. EPA, 2001. Road Map to Understanding Innovative Technology Options for Brownfields
Investigation and Cleanup, Third Edition, EPA-B-01-001, U.S. Environmental Protection
Agency, Office of Emergency and Remedial Response.
U.S. EPA, 2002. President Signs Legislation to Clean Environment and Create Jobs, U.S.
Environmental Protection Agency press release January 11, 2002.
U.S. EPA, 2003. Brownfields Management System, U.S. Environmental Protection Agency,
tabulation, June, 2003.
U.S. GAO, 1995. Community Development: Reuse of Urban Industrial Sites, RCED-95-172,
U.S. General Accounting Office, June 1995.
U.S. GAO, 2000. Brownfields, Information on the Programs of EPA and Selected States, GAO-
01-52, U.S. General Accounting Office, December 2000.
XL Environmental, Inc. and the International Economic Development Council, 2001. The XL
Environmental Land Reuse Report 2001.
XL Environmental, Inc. and the International Economic Development Council, 2002. The XL
Environmental Land Reuse Report 2002.
Yount, Kristen R, 2003. "What Are Brownfields? Finding a Conceptual Definition,"
Environmental Practice, March 2003. ISSN 1466-0466. http://www.envpra.oupjournals.org.
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Chapter 9: State and Private Sites Page 9-24
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Chapter 10
Demand for Remediation of Manufactured
Gas Plants and Related Coal Tar Sites
Before the United States had a network of natural gas pipelines and electricity, fuel for lighting,
heating, and cooking was manufactured from coal and petroleum at thousands of manufacturing
facilities across the country. As a result of these activities, hazardous materials are likely to be
present in the subsurface and groundwater at thousands of locations. While some of these sites,
especially those currently owned and operated by large gas and electric utility companies, are
being addressed, most of the former manufactured gas sites have not been identified.
There is no separate remediation program for the characterization and remediation of MGP and
other coal tar sites. MGP sites may be addressed under any of the remediation programs, such as
Superfund, RCRA, or a state environmental program, depending on the nature and extent of the
contamination and other site-specific factors. Because these sites may be managed under
different remediation programs, the estimates of the MGP market should not be added to those in
the previous chapters of this report. Adding these estimates would be double-counting sites and,
therefore, overestimating the scope of the market.
This chapter provides information to help vendors, regulators, and other stakeholders understand
the potential sources of risk to people and the environment that may have resulted from past
MGP operations. It provides background for site investigators to understand potential sources of
NAPLs, coal tars and other pollutants. The effectiveness and efficiency of site investigations and
remdiations could benefit from a good understanding of this defunct industry.
10.1 History
From the early 1800s through the mid-1900s manufactured gas plants (MGP) were operated
nationwide to provide gas from coal or petroleum for lighting, heating, and cooking. The first
manufactured gas plant built in the United States was in Baltimore in 1816. By the turn of the
20th century almost every good-sized city had its own manufactured gas plant (Gonzalo, 1995).
Larger cities had more than one plant.
A 2003 EPA report estimated that as many as 50,000 plants were built during the over 140 years
of MGP operations (U.S. EPA 2003). The first plants were located in downtown areas adjacent
to waterways and rail spurs for easy access to coal (El Digest, 1995). As the technology
developed, it became a common source of light, heat and fuel for a variety of industrial and
commercial facilities and residences. After electricity and piped in natural gas became common,
many of the larger MGP properties were converted for new uses by the utilities and other
companies that owned them. In addition to the commercial MGPs, many railroad companies,
military installations, large institutions (e.g. hotels, hospitals, prisons, schools), industrial
facilities, and large private homes were equipped with gas plants (Heritage Research, 2002).
Chapter 10: Manufactured Gas Plant Sites Page 10-1
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
The manufacturing practices at the time left an environmental legacy of hazardous waste
contamination in groundwater, soil, sediment, sludge, and surface water. Because almost all
MGPs were decommissioned over 50 years ago, prior to most federal environmental regulations,
it is difficult to assess the nature and scope of the environmental legacy left behind. MGP sites
represent a potentially significant market for site characterization and remediation technologies.
10.2 Gas Manufacturing Processes
Manufactured gas was produced primarily by three processes; coal carbonization, carburetted
water gas, and oil gas (NYDEC, 2003). Coal carbonization, was used exclusively until 1875. In
this process, the coal was heated in a closed oven with limited air contact. The volatile products
of this oxygen-deficient heating was driven off as a gas which was collected, cooled, and
purified for use. The gas was then measured, stored, and delivered to customers via underground
pipes. The solid remains would become coke, a fuel which burned hotter and more cleanly than
coal.
The carburetted water gas process was introduced in the 1875. The process involved heating
coal or coke in a closed vessel into which steam was injected. This resulted in a flammable gas
mixture of methane and carbon monoxide. Then gas works napthalene or light oil petroleum
products were sprayed into this gas mixture, resulting in petroleum constituents that were
cracked to form methane, a gas that burned hotter and brighter.
The most common oil gas process was patented in 1889. It is similar to the carburetted water gas
process with a vaporizer replacing the carburetor. Oil is added to the reactor thereby generating
more heat. The oil vapors are thermally cracked and fixed into gases.
After 1928 the Northeast was subjected to shortages of both coke and light carbureting oils and a
wide variety of newly developed oil-based gas manufacturing processes came into being. These
processes were prominent until the 1950s when reliable supplies of natural gas were in place.
10.3 Number and Characteristics of Sites
As with other types of sites, former MGP sites are subject to current environmental regulations,
and, when discovered, may be managed under either the federal Superfund, RCRA Corrective
Action, Underground Storage Tank, or other federal or state programs. However, no single
source provides definitive information on the number and characteristics of former MGP sites,
nor on the number that may require remediation. Until further investigation is conducted, the
number of MGP facilities that are likely to require remediation can only be estimated.
According to the U.S. Bureau of the Census' 1910 Manufactures Report for Principal Industries,
there were 1,296 MGP plants, mostly owned by corporations and municipalities, selling
manufactured gas in the country. Most of the sites were in the Northeast quadrant of the United
States (Heritage Research, 2002). In 1985 EPA estimated that there were a total of 1,500 MGP
plants in North America (Brown's Directory of North American Gas Plants - from 1887). This
tally however did not include plants that were not members of gas associations, those that did not
report information to the directory's publisher, or multiple plants owned by the same entity. A
Chapter 10: Manufactured Gas Plant Sites Page 10-2
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
more recent estimate by the Electric Power Research Institute (1995) indicates that there may be
as many as 2,500 MGP sites that are now associated with modern electric and gas utility
properties. Con Edison estimates that in New York State alone there are approximately 250
former gas manufacturing sites related to utility operations. An extensive proprietary database
with data on approximately 7,000 MGP and other coal tar sites provides additional information
on the potential universe of sites that may still require some sort of site characterizations and/or
remediation (Hatheway 1997).
Based on these sources, it is estimated that from 1800 to the mid-1900s between 36,000 and
55,000 manufactured gas plants and related coal tar sites operated in the United States. These
sites varied in size from less than one acre to approximately 200 acres. Exhibit 10-1 identifies
the types of sites, their typical sizes, and an estimate of the number of sites for each site type.
These site types vary greatly in size, volume of releases, and location. For example, commercial
MGPs tended to be medium-to-large plants located in urban areas where they piped gas to
consumers, businesses, and municipalities. This gas was primarily used for lighting, heating,
and cooking. In contrast, there were many more institutional and residential gas machines
owned by hotels, hospitals, universities, private estates, and other entities, that manufactured gas
for their own use. These sites ranged from several hundred square feet to a few acres.
Although most of the former MGP properties are now vacant or being used for other purposes,
many of them have not been investigated for potential soil or groundwater contamination
resulting from previous MGP activities. Nevertheless, based on the manufacturing practices at
the time, it is believed that most of these facilities had releases of contaminants to the
environment. The aforementioned sources were reviewed to estimate how many of the 36,000 to
55,000 sites were likely to have had releases and the number of those that had not been
investigated or remediated.
Estimated Land Use
Around MPG Sites
Industrial/commercial 50%
Residential 30%
Recreational & vacant 20%
By subtracting the estimated number of sites that have been
found to require no further action planned (NFRAP), those
that are enrolled in a state voluntary cleanup program (VCP),
and those that have completed remediation under a federal or
state program, the balance of the sites represent those that
have not been investigated, and are likely to require
characterization and remediation work.1 These estimates are
shown in Exhibit 10-2 and the calculations in Appendix
Exhibit D-l. As the exhibit indicates, approximately 88 percent of the sites are suspected to have
had releases of contaminated materials to the environment. It is estimated that only a small
percentage of these sites have been identified and entered into a federal or state remediation
program. Thus it is likely that the remaining 30,000 to 45,000 sites have not been investigated
and represent a significant potential for site characterization and remediation work.
Approximately 50 percent of these sites are in industrial/commercial areas, 30 percent are in
residential areas, and the balance are in recreational and vacant areas (Appendix Exhibit D-l).
1 A keyword search of EPA's CERCLIS database indicated that about 800 NFRAP sites were former MGP and
coal tar sites. Although these sites did not become candidates for listing on the NPL, they may still require
remediation under other environmental authorities such as RCRA or state laws.
Chapter 10: Manufactured Gas Plant Sites Page 10-3
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 10-1. Types and Numbers of Former Manufactured
Gas Plants & Related Coal Tar Facilities in the U.S.
Site Size
Site Type Description/Use Range & Time Number of
(Average) frame Sites
Commercial MGPs
District Gas
Holders
Rail Yard Pintsch
Oil-Gas Plants
Military Gas Plants
Ice & Refrigeration
Plants with Gas
Producers
Institutional Gas
Machines
Domestic/Resident
ial Gas Machines
Captive Gas
Producers (both
Pressure
&Suction)
Bottled
Manufactured Gas
Plants
Kerosene Refiners
Compressed Fuel
Briquette Plants
Produced and sold gas for
lighting, heating & cooking
Small: <5 million cu ft peryr.
Med. : 5-100 mil. cu ft peryr.
Large: >1 00 mil. cu ft per yr.
Held & distributed gas beyond
commercial MGPs original
distribution radius
Produced illuminating gas for
rail passenger cars
Produced illuminating and fuel
gas for use at military posts,
naval stations, arsenals, and
munitions plants
Commercial block ice and
commodity refrigeration; used
coal-gas ammonia as a
refrigerant
Hotels, resorts, hospitals,
universities, asylums,
monasteries, private schools
Mansions and country estates
Fuel gas for wide variety of
industrial plants with
furnaces/kilns and smelters
Manufactured oil-enriched
water gas or solvent vapor
gas
Distilled lamp oil from soft
coal
Bound by-product with tars
and compressed solid fuel
1 -3 acres (2)
3-1 0 (5)
10-100(40)
1-4 acres (1.5)
0.5- 1.5 acres
(1)
0.5-1.5 acres
(1)
1 -2 acres
(1.5)
500-1 500 sq ft
(700 sq ft);
Mostly indoors
400-1 000 sq ft
(600 sq ft);
Basements &
exterior bldg
600 to 30,000
sq ft; highly
Variable; Most
enclosed
1-3 acres (1.5);
Variable; most
enclosed
1-2 acres (1.5)
1-2 acres (1.5)
Variable;
enclosed
1816-
1950s
1860-1910
1873-1960
1849-1993
1870-1940
1850-1950
1890-1950
1880-1950
1912-1940
1850-1870
1910-1950
3,500
500-1,500
100-150
150-250
200-400
5,000-10,000
10,000-15,000
11,000-15,000
100
100-150
100
Chapter 10: Manufactured Gas Plant Sites
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 10-1. Types and Numbers of Former Manufactured
Gas Plants & Related Coal Tar Facilities in the U.S. (Continued)
Site Size
Site Type Description/Use Range & Time Number of
(Average) frame Sites
Beehive Coke
Works
Merchant and
Utility Coke Works
Charcoal Plants
Tar Distilleries
WWI Federal
Wood-Tar
Distillation Plants
WWI Federal
Toluene Plants
Wood Preservation
Plants
U.S. Bureau of
Mines coal
Gasification Plants
U.S. Department of
Energy Coal
Gasification Plants
Total
Produced coke without
recovery of by-products
Produced coke with recovery
of coal tar by-products
Produced charcoal as fuel
Converted tar residues to
industrial chemicals
Produced cellulose acetate
aircraft fabric dope
Produced munitions and fuel-
grade toluene from gas-works
benzol
Pressure and non-pressure
impregnation of timber with
coal tar products
coal gasification plants to
exploit WWII German
technologies; operated mainly
by universities and industrial
grantees
Coal & oil shale gasification
pilot projects
40-100 acres;
Highly variable
40-100 acres;
variable
10-100 acres
(25); Highly
variable
10-100 acres
(15);
Variable
40-200 acres
(80); Variable
80-200 acres
(100); Variable
1 0-200 acres
(40); Highly
variable
1 0-40 acres
(20);
Variable
1 0-40 acres
(20); Variable
1800-1930
1890-1996
1820-1960
1900-1960
1918-1921
1918-1920
1880-1960
1947-1990
1970-1985
2,000-4,000
250-300
2,000-3,000
200-400
11
10
800-1,000
37-55
63-75
36,121 -55,001
Notes:
Acetylene gas plants were common from 1890 to 1940, for use in rural small-town, business and residential
markets. These plants are not included in these tabulations since they are not regarded as having produced or
left environmentally-hazardous wastes.
Source: Hatheway, Allen W. "Estimated Number of Manufactured Gas and Other Coal-Tar Sites in the United
States," Environmental Engineering Geoscience, Vol. Ill, No. 1, Spring 1997, pp. 141-142 and personal
communication with the author, February-March 2003. The data are based on Dr. Hatheway's database on MGPs
which includes information on approximately 7,000 sites, assembled from Brawn's Directory of North American
Gas Plants, historic gas industry literature, Sandborn Fire Insurance maps, state agencies, and direct on-site
observations.
Chapter 10: Manufactured Gas Plant Sites
Page 10-5
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 10-2. Estimated Magnitude & Disposition of Former Manufactured
Gas Plants & Other Coal Tar Sites in the U.S.
Original Number Number of No. of Sites Not
Site Type " of Sites Sites w/Re leases Yet Investigated
Commercial MGPs
District Gas Holders
Rail Yard Pintsch Oil-Gas Plants
Military Gas Plants
Ice & Refrigeration Plants w/Gas
Producer
Institutional Gas Machines
Domestic/Residential Gas Machines
Captive Gas Producers - Pressure &
Suction
Bottled Manufactured Gas Plants
Kerosene Refiners
Compressed Fuel Briquette Plants
Beehive Coke Works
Merchant & Utility Coke Works
Charcoal Plants
Tar Distilleries
WWI Federal Wood Tar Distillation
Plants
WWI Federal Toluene Plants
Wood Preservation Plants
U.S. Bureau of Mines - Coal
Gasification Plants
U.S. Dept. of Energy - Coal
Gasification Plants
Total
3,500
500-1,500
100-150
150-250
200-400
5,000-10,000
10,000-15,000
11,000-15,000
100
100-150
100
2,000-4,000
250-300
2,000-3,000
200-400
11
10
800-1,000
37-55
63-75
36,121-55,001
3,500
500-1,500
100-150
150-250
150-300
2,500-5,000
10,000-15,000
11,000-15,000
50
100-150
50
2,000-4,000
250-300
2,000-3,000
200-400
11
10
800-1,000
37-55
63-75
33,471-49,801
2,275+
450-1,350+
>85-129
150-250-
143-285
2,375-4,750
9,800-14,700+
10,450-14,250
50
93-140+
50
1,800-3,600+
125-150
1,800-2,700
160-320
6
5
440-550
33-49
57-67
29,975-44,926
a See Table 1 for descriptions of the site types.
Source: Hatheway, Allen W, "Estimated Number of Manufactured Gas and Other Coal-Tar Sites in the United States,"
Environmental Engineering Geoscience, Vol. Ill, No. 1, Spring 1997, pp. 141-142 and personal communication with the
author, February-March 2003. The data are based on Dr. Hatheway's database on MGPs which includes information on
approximately 7,000 sites, assembled from Brown 's Directory of North American Gas Plants, historic gas industry literature,
Sandbom Fire Insurance maps, state agencies, and direct on-site observations.
Chapter 10: Manufactured Gas Plant Sites
Page 10-6
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
10.4 Waste Types and Quantities
The gas manufacturing processes resulted in a variety of residuals, some of which were
converted to by-products, while others, many of which are hazardous, were managed as wastes.
Some of the by-products were sold to other industries. For example, coke was sold to the steel
industry. Others materials were transported offsite for disposal. It was common practice to dump
coal tar and other wastes into on-site pits or ponds, bury it, or use it as fill to adjust the grade of
the gas yard. The gas manufacturing process also involved the use of wood chips and iron filings
to remove sulfur and cyanide from the gas. These chips and filings were also disposed of in pits
or buried. As a result of these practices, wastes from manufactured gas processing can be found
in soil, sediment, groundwater and surface water.
These wastes pose potential risks to humans and the environment. A critical concern with regard
to coal tar is the fact that less than 40 percent of the mass of coal tar constituents can be
quantified using common organic chemistry extraction and chromatographic techniques. The
remaining 60 percent known as "pitch" are comprised of aromatic compounds with high
molecular weight and relatively low aqueous solubility. The compounds that make up this pitch
are of concern since many are suspected to cause mutagenic and/or carcinogenic effects. In
addition, the presence of pitch can influence the rates of release of the more soluble coal tar
constituents. Some researchers who are now looking at tar as a "supercompound" with a potent
combination of carcinogens, much like cigarette smoke, instead of studying its individual
constituents (WDNR, 1999).
The types of wastes produced depended upon the production processes and the period in which
the plants operated. Coal tar, a by-product of all MGP sites, is a dense, non-aqueous phase
liquid (DNAPL). When released into an aquifer, it migrates downward until it encounters a low-
permeability layer. This dense substance does not dissolve in the aquifer and releases
constituents into the water. The lighter oil by-products (LNAPLs) of the manufactured gas
process migrate through the groundwater. They tend to float on top of the water, contaminating
it from above.
Exhibit 10-3 shows the types and estimated quantities of residuals and wastes remaining in the
soil and groundwater at MGP and coal tar sites. The most common releases are liquids, solids,
sludges, and tar. The quantity estimates are based on information from public and private
databases cited in the footnote to the exhibit.
From 1880 to 1950, MGPs produced approximately 15 trillion cubic feet of gas and
approximately 11 billion gallons of tar as a by-product resulting in thousands of contaminated
acres of land and millions of gallons of impacted water (Fischer et al, 1999).
Chapter 10: Manufactured Gas Plant Sites Page 10-7
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 10-3. Estimated Quantities of Residuals and Wastes
Released at Former MGP & Other Coal Tar Sites in the U.S.
Original Number of Volume of
Site Type3 Number Sites With Type of Releases Residuals/Waste
of Sites Releases Per Site (000)
Commercial MGPs
District Gas Holders
Rail Yard Pintsch Oil-
Gas Plants
Military Gas Plants
Ice & Refrigeration
Plants w/Gas
Producer
Institutional Gas
Machines
Domestic/Residential
Gas Machines
Captive Gas
Producers - Pressure
& Suction
Bottled Manufactured
Gas Plants
Kerosene Refiners
Compressed Fuel
Briquette Plants
Beehive Coke Works
Merchant & Utility
Coke Works
Charcoal Plants
Tar Distilleries
WWI Federal Wood
Tar Distillation Plants
WWI Federal
Toluene Plants
Wood Preservation
Plants
3,500
500-1,500
100-150
1 50-250
200-400
5,000-10,000
10,000-15,000
11,000-15,000
100
100-150
100
2,000-4,000
250-300
2,000-3,000
200-400
11
10
800-1,000
3,500
500-1,500
100-150
150-250
150-300
2,500-5,000
10,000-15,000
11,000-15,000
50
100-150
50
2,000-4,000
250-300
2,000-3,000
200-400
11
10
800-1,000
Liquids & Solids
Liquid Leaks,
Solids inside
Liquids & Solids
Liquids & Solids
Liquids & Limited
Solids
Liquids
Limited Liquids'3
&Solids
Tars & Solids
Limited Sludges
Liquids & Sludges
Limited Liquids &
Sludges
Tars
Tars & Solids
Tars
Liquids &Tar
Sludges
Liquids &Tar
Sludges
Liquids & Sludges
Liquids & Sludges
2,000-50,000 m3
100 -500m3
500-1 0,000m3
500-1 ,000m3
500-1 ,000m3
<100m3
<50m3
100-1 0,000m3
1 00-500 m3
100-1 ,000m3
100-1 ,000m3
1,000-1 0,000m3
5,000-
100,000m3
1, 000-5,000 m3
1,000-
100,000m3
1,000-1 0,000m3
1,000-1 0,000m3
1,000-1 0,000m3
Chapter 10: Manufactured Gas Plant Sites
Page 10-8
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 10-3. Estimated Quantities of Residuals and Wastes
Released at Former MGP & Other Coal Tar Sites in the U.S. (Continued)
Site Type'
Original Number of Volume of
Number Sites With Type of Releases Residuals/Waste
of Sites Releases Per Site (000)
U.S. Bureau of
Mines-Coal
Gasification Plants
U.S. Department of
Energy-Coal
Gasification Plants
Total
37-55
63-75
36,121-55,001
37-55
63-75
33,471-49,801
Liquids & Sludges
Limited Liquids &
Sludges
500-1 ,000m3
500-1 ,000m3
Notes:
a See Exhibit 10-1 for definitions of site types.
b Limited connotes a few hundred to one thousand gallons over the period of weeks to a few months.
Source: Hatheway, Allen W, "Estimated Number of Manufactured Gas and Other Coal-Tar Sites in the United
States," Environmental Engineering Geoscience, Vol. Ill, No. 1, Spring 1997, pp. 141-142 and personal
communication with the author, February-March 2003. The data are based on Dr. Hatheway's database on MGPs
which includes information on approximately 7,000 sites, assembled from Brawn's Directory of North American
Gas Plants, historic gas industry literature, Sandborn Fire Insurance maps, state agencies, and direct on-site
observations.
Six major constituent classes are potentially present in MGP residuals (Middleton, 1995):
• polynuclear aromatic hydrocarbons (PAHs);
• volatile aromatics (BTEX);
• phenolics;
• inorganic nitrogen (including cyanide compounds);
• inorganic sulfur; and
• trace metals.
10.5 Remediation Technologies
Investigation and remediation at many MGP sites are complicated by the:
• Nature and variety of waste materials and media, including the fact that the constituents of
concern tend to interact differently in different media;
• Location of the sites (i.e near waterways or in the heart of residential neighborhoods); and
• Condition of the sites (i.e. infrastructure at the sites, lack of surface features and mixed
debris is subsurface).
A variety of site investigation techniques are available to address some of these complications.
They include ground penetrating radar (GPR), Electromagnetic (EM) Induction, Infrared
Monitoring (IM), and Seismic Reflection and Refraction to detect and measure buried debris or
other subsurface anomalies. Direct Push Sampling and Seismic Reflection and Refraction may
Chapter 10: Manufactured Gas Plant Sites
Page 10-9
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
be used to produce a geophysical profile of the subsurface. Flame lonization Detectors (FID)
and Photoionization Detectors (PID) are used to screen soil for contamination. Once the location
and profile of the waste is determined, many of the same sampling techniques are employed to
test both soil and water. These include Direct Push sampling which can be used for any
constituent, drilling both for the collection of samples and the installation of groundwater wells;
Immunoassay test fits to detect and quantify contaminants by measuring compound reactions;
Laser-Induced Fluorescence/Cone Penetrometry using a fiber optics-based chemical system to
screen primarily for petroleum contamination in the field; and, X-ray Fluorescence (XRF) to
detect and quantify individual metals in the field. In addition, soil gas surveys are used to
identify and quantify individual organic compounds (VOCs and SVOCs) that occur between
particles of the earth and soil with the help of a portable gas chromatograph (Fischer 1999).
Both established and innovative technologies are being used to remediate former MGPs. Most
of the technologies involve thermal desorption, biological processes, and/or chemical oxidation
processes (Brown et al, 1995). A number of the technologies can be applied either in situ or ex
situ. In some cases, these technologies serve to recover fuels for recycling.
A variety of remediation alternatives are available for use at former MGP sites. Exhibit 10-4
enumerates many of these alternatives and their application by waste stream category and
contaminant/media. According to the Institute for Gas Technology, wastes from former MGP
sites fall into six major categories; pumpable liquid free product (free tars & oils); organic waste
or tar/oil-contaminated waters; organic waste or tar-contaminated soil and sediments; non-
pumpable tars and sludges; purifier box (or spent oxide) waste; and, demolition debris (Fischer
1999).
Chapter 10: Manufactured Gas Plant Sites Page 10-10
-------
Exhibit 10-4. Remediation Alternatives by Category
of Waste at Former Manufactured Gas Plants
Waste Category
Organic waste or Tar-
Contaminated Soils and
Sediments
Non-pumpable tars and
sludges
Purifier box (or spent oxide)
waste
Demolition Debris
Remediation Alternatives
Soil vapor extraction - use of vacuum to separate
contaminants from soil
Bioremediation (in-situ or ex-situ)
Bioventing (combines SVE and Bioremediation)
Excavation & Aeration
Low Temperature Thermal Desorption
High Temperature Thermal Desorption
Incineration
Soil washing
Solvent extraction
Soil flushing
Clean Soil Process (CSP)
Excavation & soil mixing - to dilute the concentration of
TPAHs - removal to RCRA class D landfill - daily cover
Spent wood chips - burnt and ash dumped
Spent oxides - some sold for Vitriol - most removed to
RCRA class D landfill
Scanned and steam cleaned - removal to RCRA Class D
landfill
Contaminants and Media
VOCs and some SVOCs
PAHs
Petroleum products
VOCs, some SVOCs
VOC, SVOC, & petroleum contaminated soil
SVOCs in impacted soil, some VOCs
VOCs & SVOCs in impacted soil
Metals, gasoline, & fuel oils
PCBs, VOCs, halogenated organics, & petroleum from
soil, sediments, & sludges
Heavy metals, halogenated organics, aromatics, & PCBs
Coal Tar
Petroleum hydrocarbons
Other spent purification media
Sulphur-related PH conditions that can release cyanide
NA
o
CD
CD
c
T3
CD
'A-
CD
CO
CD
CD-
CD
3
Q.
CD
O
O
CO
CD
3
Q.
-------
Exhibit 10-4. Remediation Alternatives by Category
of Waste at Former Manufactured Gas Plants (Continued)
Waste Category
Remediation Alternatives
Contaminants and Media
Pumpable liquids (free tars &
oils)source material
Solvent extraction (separates or removes
hazardous organic contaminants)
Surfactant flushing - increases solubility and
mobility of contaminants in water
Sediments, sludges, soil with primary organic
contaminants (PCBs, VOCs, halogenated organic
compounds)
Groundwaterwith NAPLs
o
CD
CD
c
T3
Organic waste or tar/oil-
contaminated waters
Bioremediation (in-situ or ex-situ) (use of
microorganisms to break down hazardous
substances)
Air sparging - captures contaminants by vapor
extraction
Treatment wall
Groundwater extraction using a system of wells
and pumps w/ UV oxidation, activated carbon
treatment, or air stripping
Surfactant flushing
PAHs
Volatile contaminants
Chlorinated solvents, metals or radioactive
contaminants
VOCs and SVOCs
NAPLs
CD
'A-
CD
CO
CD
CD-
CD
3
Q.
CD
O
O
CO
CD
3
Q.
Sources:
• Fischer, Corey L.J., Schmitter, Robert D., and Lane, Eliesh O'Neil, 1999, Manufactured Gas Plants: The Environmental Legacy, South & Southwest
Hazardous Substance Research Center, Georgia Institute of Technology, Atlanta, GA, November.
• Personal communication with Allen W. Hatheway.
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
10.6 Estimated Cleanup Costs
MGP cleanup costs have been documented to range from a few hundred thousand dollars to $86
million for a single site. No single source provides a total nation-wide estimate of MGP cleanup
costs. To estimate the potential value of the market for cleaning up MGP and other coal tar sites,
estimates of ranges of costs for each site type were developed and multiplied by the estimated
number of sites of each type. The estimates of average costs were developed from published
information on MGP remediation costs and from analysis of data in a proprietary database
containing data on thousands of MGP and other coal tar sites (Hatheway, 1997).
The published sources provide cleanup costs for specific projects or averages for specific utility
companies that have a number of MGP sites. In 1995 the Electric Power Research Institute
estimated that cleanup and containment costs for approximately 2,500 former MGP properties to
be between $25 and 75 billion and that it would take over 30 years to clean them up (Murarka,
1995). The MGP sites in this study are those that are now part of modern utilities. This report
implies an average cost of $10-30 million per site. Other reports estimate that most per site
cleanups fall in the $3-10 million range. For example, a 2001 article reports that per site cleanup
for MGPs are in the $3-5 million range, although many sites have run much higher (Ginsburg,
2001). In 1995, the Niagara Mohawk Power Corporation of New York estimated its
environmental liability from the legacy of 55 sites in 24 cities and towns to be more than $200
million, or an average of $3.6 million per site (Neuhauser, 1995). The estimated cost varied
widely from site to site, with the cost of one site estimated as high as $86 million (Ginsburg,
2001). The Atlanta Gas Light Company is expected to spend $186 million to clean up 12 MGP
sites in Florida and Georgia, or $15.5 million per site.
The Hatheway database provided ranges of costs for a number of sites for the various site types
(Hatheway, 1997). Some engineering judgement was used to apply these to the various site
types, and to eliminate outliers (i.e., the few cases that have extremely high costs and tend to bias
the average). These estimates do not include the cost of contamination resulting from activities at
the sites after the MGP operations were closed down, nor do they consider legal costs or awards
for potential damages. The published data generally confirmed the data from this database.
It is estimated that should the 30,000-
The results of this analysis is presented in
Exhibit 10-5, which shows the range of ^«««».^« , „ , x -,
,. , , ,. ... fr i 45,000 MGP and other coal tar sites
estimated average remediation cost for each c ft cQu|d cogt $2g_$128
site type, along with the typical contaminants billion
and contaminated media. The estimated I
number of sites that have yet to be
investigated is taken from Exhibit 10-2.
Based on these estimates, the cleanup of between 30,000 and 45,000 MGP and other coal tar
sites would cost between $26 billion and $128 billion. Captive gas producer plants account for
44 percent of the total and commercial plants account for 23 percent. Although the average
cleanup cost for captive producer plants is about a third of that of commercial plants, there are 5
to 7 times as many captive plants sites.
Chapter 10: Manufactured Gas Plant Sites Page 10-13
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 10-5. Estimated Average Remediation Cost by Site Type
Average Per Site
Site Type Range of Site Size Number of Sites Remediation Cost
Not Investigated $ Millions
Commercial MGPs
District Gas Holders
Rail Yard Pintsch Oil-Gas
Plants
Military Gas Plants
Ice & Refrigeration Plants
with Gas Producers
Institutional Gas Machines
Domestic Residential Gas
Machines
Captive Gas Producers
(Pressure & Suction)
Bottled Manufactured Gas
Plants
Kerosene Refiners
Compressed Fuel Briquette
Plants
Beehive Coke Works
Merchant & Utility Coke
Works
Charcoal Plants
Tar Distilleries
WWI Federal Wood Tar
Distillation Plantscd
WWI Federal Toluene
Plantsc'd
Wood Preservation Plants
U.S. Bureau of Mines -
Coal Gasification Plants0
U.S. Department of Energy
- Coal Gasification Plants0
small (1-100 acres)
1 -4 acres
0.5-1.5 acre
0.5-1.5 acre
1 -2 acres
500-1 500 ft2
400-1 000 ft2
20/30 ft to 50x600 ft
1 -3 acres
1 -2 acres
1 -2 acres
40-100 acres
40-100 acres
10-100 acres
10-100 acres
40-200 acres
80-200 acres
10-200 acres
1 0-40 acres
1 0-40 acres
2,275+
450-1350+
95-142
150-250
147-294
2,450-4,900
9,800-14,700
10,450-14,250
50
95-142
50
1,900-3,800
100-120
1,900-2,850
150-300
11
10
480-600
33-49
57-67
3.0-100.0
0.25-1.5
0.5-5.0
1.0-4.0
0.5-1.5
0.2-0.75
0.05
1.0-10.0
0.2-0.5
1.0 -5.0
0.5-1.0
0.5-2.0
10.0-100.0
0.5-2.0
10.0-100.0
1.0-2.0
1.0-5.0
5.0-20.0
1.0-2.0
1.0-2.0
Source: Appendix Table D-2.
Chapter 10: Manufactured Gas Plant Sites
Page 10-14
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
These data provide a reasonable estimate of a range of probable cleanup costs for all MGPs,
should they require cleanup. However, because these costs vary widely, and because the above
values of the number of MGP sites remaining to be cleaned up are estimates, the cost estimates
provided here are considered a general indication of the market size.
10.7 References
American City & County, 2001. "The Problem of Manufactured Gas Plants," roundtable
discussion, American City & County, March 1, 2001.
http://www.americancityandcounty.com/ar/government_problem_manufactured_gas
Brown, Richard A., M. Jackson, and M. Loucy, 1995. "A Rational Approach to the Remediation
of Soil and Groundwater at Manufactured Gas Plants," Land Contamination & Reclamation,
Vol. Ill, No. 4.
El Digest, 1995. "Manufactured Gas Plants," El Digest, p.l, May 1995.
Fischer, et. al., 1999. Manufactured Gas Plants: The Environmental Legacy, Fisher, Corey L.J.,
Schmitter, Robert D., and Lane, Eliesh O'Neil, South & Southwest Hazardous Substance
Research Center, Georgia Institute of Technology, Atlanta, GA, November, 1999.
http://www.hsrc.org/hsrc/html/tosc/sswtosc/mgp.html
Ginsburg, Janet, 2001. "A Deadly Legacy of Poisons from the Past," Business Online, July 2,
2001. http://www.businessweek.eom/magazine/content/0l_27/b3739186.htm
Hatheway, Allen W., 1997. "Estimated Number of Manufactured Gas and Other Coal-Tar Sites
in the United States," Environmental & Engineering Geoscience, Vol. Ill, No. 1, Spring, pp.
141-142 (and 2003 updated and expanded version), http://www.allen@hatheway.net
Hatheway, Allen W., 2002. "Geoenvironmental protocol for site and waste characterization of
former manufactured gas plants; worldwide remediation challenge in semi-volatile organic
wastes," Engineering Geology 64, pp. 317-338.
Heritage Research Center, Ltd., 2002. A Brief History of the Manufactured Gas Industry in the
United States. http://www.heritageresearch.com/manufactured_gas_F.htm
Middleton, Andrew C., 1995. "Historical Overview of Manufactured Gas Processes Used in the
United States," Land Contamination & Reclamation, Vol. Ill, No. 4.
Mon, Gonzalo J., 1995. "History of the Manufactured Gas Business in the United States," in
"International Symposium and Trade Fair on the Clean-up of Manufactured Gas Plants," Land
Contamination & Reclamation, Vol. Ill, No. 4.
Murarka, Ishwar P., 1995. "Site Management Trends and Research Directions in the United
States of America," Land Contamination & Reclamation, Vol. Ill, No. 4.
Chapter 10: Manufactured Gas Plant Sites Page 10-15
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Neuhauser, Edward, 1995. "Manufactured Gas Plant Site Ownership in the 1990s," Land
Contamination & Reclamation., Vol. Ill, No. 4.
NYDEC, 2003. New York State Department of Environmental Conservation, web site on
General Information About MGPs. http://www.dec.state.ny.us/website/der/mgp/mgp_faq.html
U. S. EPA, 2003. Report on the Innovative Approaches to Manufactured Gas Plant Site
Characterization, EPA-542-R-01/003, U.S. Environmental Protection Agency, Office of Solid
Waste and Emergency Response, Technology Innovation Office.
WDNR, 1999. Wisconsin Department of Natural Resources, Contaminants of Concern from
MGP Waste and By-products.
http ://www. dnr. state, wi .us/org/water/wm/wqs/sediment/assessment/mgp
Chapter 10: Manufactured Gas Plant Sites Page 10-16
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Chapter 11
Demand for Remediation of Mining Sites
The thousands of abandoned, inactive, and operating mines in the United States present serious
potential risks to human health and the environment. The extraction and processing of metals,
nonmetal minerals, and coal result in the generation of large quantities of contaminated solid
wastes, wastewater, and air emissions which cause significant environmental impacts, including
groundwater and surface water contamination, soil erosion, and soil contamination. Mining
wastes have been detected many miles downstream from their source. This Chapter presents
estimates of the extent of mining waste environmental problems in the U.S. and its implications
for the demand for remediation technologies.
There is no separate remediation program for the characterization and remediation of mining
sites. Mining sites may be addressed under one or more of the major remediation programs, such
as Superfund, RCRA, or a state environmental program, depending on the nature and extent of
the contamination and other site-specific factors. Because these sites may be managed under
different remediation programs, the estimates of the market should not be added to those in the
previous chapters of this report. Adding these estimates would be double-counting sites and,
therefore, overestimating the scope of the market. Addressing mining sites across all remediation
programs provides vendors and regulators information from the unique perspective addressing
the hazardous waste challenges facing a specific industrial sector.
The Mine Safety and Health Administration reports that, as of 2001, there were approximately
14,500 operating coal, metal, and nonmetal mineral mines in the U.S. The Bureau of Land
Management (BLM), a component of the Department of Interior, estimates that there are
between 100,000 and over 500,000 small and mid-sized abandoned hard rock (metals and
nonmetal minerals) mines on private, state and federal lands in the west and approximately
13,000 abandoned coal mines, mostly small and mid-sized, in the east. Many of these properties
continue to threaten human health and the environment because of the materials left behind and
because mined-out areas and materials are exposed to the elements. There is a wide range of
estimates and opinions on how many of these properties pose a serious environmental risk and
are likely candidates for remediation. The most promising estimates indicate that approximately
5 to 10 percent of abandoned mines pose a significant risk to the environment and people.
11.1 Industry Description
Identifying, prioritizing, and implementing the necessary cleanup actions at thousands of sites
across the country is expected to take many years. To understand the nature of and potential
extent of the cleanup effort, it is necessary to understand the nature of mining operations in the
U.S. This section summarizes the basic characteristics of mining operation in the U.S. and their
environmental impacts, including the types of mines, common production processes and their
likely waste streams, and the regulatory programs that address them.
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11.1.1 Types of Mining
The Department of Commerce identifies three major segments of the mining industry: metal ore
mining, nonmetallic mineral mining, and coal mining. The term "mining" is used in the broad
sense to include ore extraction, quarrying, and beneficiation (e.g., crushing, screening, washing,
sizing, concentrating, and floatation), customarily done at the mine site. The term "hardrock
mining" refers primarily to the extraction and processing of metals (e.g., copper, gold, iron, lead,
magnesium, silver, uranium, zinc) and nonmetallic, non-fuel minerals (e.g., asbestos, gypsum,
phosphate rock, sulfur). Hardrock minerals are key raw materials used in many industrial
products. Non-hardrock mineral mines, such as sand, gravel, and limestone are not addressed in
this study.
Most of the minerals and coal extraction in this country is done with surface mining techniques,
primarily open pit mining. Underground techniques may be used when the deposits are hundreds
or thousands of feet below surface level. Non-metallic mineral deposits generally have far less
waste rock and foreign materials associated with them than metallic deposits. Wastes associated
with non-metallic minerals and waste rock are generally of lower toxicity and more manageable
than those associated with hardrock or coal mining wastes.
11.1.2 Mining Processes
Mining generally involves three basic processes-extraction, beneficiation, and processing-each
of which can seriously impact the environment and human health (U.S. EPA 2000).
Extraction is the removal of rock and other materials that contain the target ore/mineral. There
are three basic types of extraction used today: surface, underground, and in-situ solution mining.
A fourth type, placer mining, is no longer used in the U.S.
• Surface mining accounts for the greatest volume of mined materials in the U.S. It involves
rock removal, blasting, mucking (removal and transport of ore), crushing, and hauling. The
open pit method is the most common form of surface mining. This technique allows access
to the ore bodies by removing the surface covering (overburden) of soil and rock. Ore-
bearing rock is then removed for further processing to extract the target mineral. After the
ore body is exhausted, open pits and huge mounds of finely-ground tailings and coarser
waste rock are usually left behind. The extraction process generates large volumes of waste
rock because of the high waste-to-product ratios associated with most ores.
Strip mining is likely to be used to extract horizontal, close to the surface deposits. It has
been used for phosphate mining and coal mining. The strip mining technique is usually more
efficient but also more environmentally destructive than underground mining. In this
process, the soil and rock above the seam of coal or other target mineral are removed. The
seam is then blasted, the target material is scooped up by huge front end loaders or power
shovels and transported to a processing plant where it is subjected to physical and/or
chemical processes to separate the target material from waste rock and other materials. The
coarser waste rock is piled up adjacent to the mined out area, and the finer tailings from the
plant are discharged as a thick slurry into an impoundment. After the mining operations
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have ceased, the mine is reclaimed by regrading waste rock and other wastes to approximate
the original contours of the land and replanting the area with native vegetation. Mountaintop
mining, a relatively new variant of strip mining, is common in locations where valleys
adjacent to the areas being mined can serve as repositories for the soil and waste rock.
• Underground mining involves digging tunnels and shafts to reach mineral-rich ore. The
most common scenario is to sink vertical shafts or dig adits (horizontal entrances into
hillsides) to reach into the mineral deposit and then bore a series of horizontal tunnels to
access the entire deposit. Underground techniques may be used when the deposits are
hundreds or thousands of feet below surface level. After the ore body is exhausted,
underground tunnel complexes are left behind. In order to support the roof rock of coal
tunnels, about 50 percent of the coal is often left behind in the form of pillars. A variant of
this technique, in which hydraulic jacks are used to support the roof, allows for an 80 to 90
percent recovery rate; although this technique can result in subsidence once the equipment
is removed. Tunneling generates considerable amounts of waste rock which are either
disposed of underground or are placed in waste rock piles.
• Underground mining is more expensive than surface mining, requiring more skilled workers
and specialized equipment. Coal, salt, and potash are often mined underground. As with
hardrock mining, the minerals must be separated from the waste rock.
• in-situ solution mining involves drilling wells and circulating a solvent into an ore body left
in place to extract minerals. Although this causes little surface physical disturbance, the
solvents and pumping may adversely affect groundwater quality.
• Placer mining, a gold mining technique that was once common in the United States, is still
being used to extract surface deposits of gold in Alaska. In this technique, miners dam small
streams and dig up and process stream sediments to extract gold.
Beneficiation involves separating the target ore from waste rock. Beneficiation activities
generally do not change the mineral values themselves other than by reducing (e.g. crushing or
grinding) or enlarging (pelletizing or briquetting) particle size to facilitate processing. Some
common types of beneficiation include:
• Gravity separation relies on large differences in density between the target metal and the
surrounding materials. This techniques utilizes devices such as trommels, sluices, cyclones,
jigs, and shaker tables.
• Magnetic separation is applied in the ore milling industry for iron, columbium and tantalum,
and tungsten. Among other things, it is used for the separation of multiple valuable minerals
recovered from complex ores.
• Electrostatic separation involves taking ore that is charged and dropping the charged
particles onto a conductive rotating drum. The particles lose the charge quickly and are
thrown off and collected.
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• Flotation, the most common beneficiation method, involves adding a reagent chemical to ore
slurry causing minerals to become less dense than the waste rock or other worthless material
and rise to the top of the tank.
• Leaching involves extracting a soluble metallic compound by dissolving the ore with a
solvent, such as sulfuric acid (copper) or sodium cyanide solution (gold).
Processing is the refining of ore after beneficiation to extract the target material. Mineral
processing operations can be based on high temperatures (i.e. smelting, roasting),
hydrometallurgical (the use of liquid reagents in the treatment or reduction of ores), or
electrometallurgical techniques (the use of electric and electrolytic processes to purify metals or
reduce metallic compounds to metals). The most common of these processes is smelting which
involves applying heat to a batch of ore to separate and refine the metal.
11.1.3 Types of Wastes
The extraction, beneficiation, and processing steps can result in four types of wastes: mine water,
waste rock, overburden, and tailings.
Mine water consists of all water that collects in mine works, both surface and underground, as a
result of inflow from precipitation and surface water and groundwater seepage. In active mining
operations this water can be pumped out and used for other mining activities or discharged to
surface water under a water discharge permit. At inactive or abandoned mines the water
accumulates in the mine pit and saturates the fill material. Depending on the source of the water
and the regional and hydrological conditions, this mine water can have high concentrations of
heavy metals and total dissolved solids as well as elevated temperatures and altered pH, which
may contaminate down-gradient groundwater and surface water.
Waste rock consists of non-mineralized and low-grade mineralized rock removed from an ore
body during extraction. It includes granular, broken rock that range in size from fine sand to
large boulders and is typically piled or disposed in piles or dumps near the point of extraction.
The geochemistry of waste rock varies widely from mine to mine and may even vary
significantly at individual mines over time. Generally, waste rock contains some concentration of
the target mineral, along with other metals and minerals. Waste rock can be a source of acid rock
drainage and heavy metals such as arsenic. Acid rock drainage occurs when precipitation or
runoff leaches sulfuric and other materials from waste rock. The resulting contaminated water
can flow offsite, where it may contaminate soil, surface waters, and groundwater.
Overburden is the surface rock and soil removed to expose the ore at surface mines. As long as
this material is salvaged and returned to the mine site during closure or decommissioning it is
exempt from Resource Conservation and Recovery Act (RCRA) regulations.
Tailings are the coarsely and finely ground waste portions of mined material remaining after
beneficiation. The physical and chemical characteristics of tailings vary according to the ore
being mined and the beneficiation process used. Tailings have traditionally been disposed of in a
variety of configurations including impoundments, piles, in backfill for underground mines, and
under water. Subaqueous disposal is currently prohibited by the Clean Water Act (CWA).
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Like mineral mining, coal mining generates large quantities of solid waste materials which are
piled on the surface and subject to saturation and runoff resulting in an increase of total
suspended solids in water bodies, acid drainage into surface and groundwater, and increased
build-up of sediments in local waters. At the processing stage, the impurities removed during the
screening and washing of the coal are also placed in waste piles, thereby adding to the hazardous
waste problems of the coal mining process. Coal piles are flammable, susceptible to spontaneous
combustion, and prone to erosion which leads to highly acidic runoff and seepage.
11.1.4 Regulatory Programs
Mining activities, including the investigation and cleanup of abandoned mine sites, are managed
in accordance with a complex web of jurisdictions, laws, and regulations covering several
environmental media. Generally, the Comprehensive Environmental Response Compensation
and Liability Act (CERCLA) and CWA are the most prevalent statutes that are applicable to
mine cleanup programs. For coal mining, the Surface Mining Control and Reclamation Act of
1977 is the primary authority on mining operations and reclamation. Depending on the
circumstances of any specific mine site, its operations and/or cleanup may also be governed by
the provisions of RCRA, National Environmental Policy Act (NEPA), the Clean Air Act, the
Emergency Planning and Community Right to know Act, the Safe Drinking Water Act, the
Atomic Energy Act, the Toxic Substances Control Act, and state or local statutes. Cleanup
requirements may further be complicated by land ownership and tenancy issues, such as whether
it is on federal, state, or tribal land.
This document concentrates on the environmental aspects of mining sites. Many mine sites also
contain physical hazards, such as open shafts and unstable slopes and buildings. Although these
safety hazards are not the focus of this report, they also deserve consideration in developing site
management strategies since they are part of the overall responsibility of site owners.
CERCLA. CERCLA's main applicability to mining activities is that it provides EPA with the
authority to conduct or require a private party to conduct a removal or remedial activity. Federal
agencies that are responsible for land must comply in the same manner as private parties with the
provisions of CERCLA (and RCRA). This responsibility is especially important for the
Department of Interior (BLM, Fish and Wildlife Service, National Park Service, Bureau of
Indian Affairs, and Bureau of Reclamation) and USD A (U.S. Forest Service), DOD, and DOE,
each of which is responsible for management of mining sites. Their responsibilities also extend
to many non-NPL mining sites. Where a site crosses property boundaries between private and
federal ownership, all parties generally coordinate to develop agreements that specify the
responsibilities of all parties. Inactive sites classified as having the most severe environmental
problems are placed on the NPL. As of December 2002, close to 90 mining and processing sites
were listed on the NPL.
Under CERCLA, EPA can require compliance with appropriate regulations adopted under other
relevant and appropriate regulations (ARARs), which may include state standards as well as
other federal regulations such as RCRA. EPA has published a manual outlining all potential
federal ARARs that may be requirements at Superfund sites (CERCLA Compliance With Other
Laws Manual, Part I, August, 1988, and Part II, August 1989).
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Clean Water Act (CWA). The CWA provides a mandate for controlling discharges from point
sources and non-point sources of pollution. The Act prohibits any pollution discharges from
"point sources" into navigable waters of the United States (33 U.S.C. § 1251-1387). A point
source includes any "discernible, confined, and discrete conveyance, including such structures as
pipes, ditches, and channels." All point source discharges to surface waters must be permitted by
EPA or authorized states, in accordance with the National Pollutant Discharge Elimination
System (NPDES). This requirement is especially important to the mining industry, since waters
coming into contact with mining materials often become acidic or contaminated with other
materials. The CWA also regulates the construction of impoundments that serve as repositories
for tailings and treatment of waste from mining and mineral processing operations. Although
mining permits are issued by the states, EPA's Office of Water may review these permits to
ensure compliance and proper application of guidelines. A landowner is liable for pollution
stemming from activities that took place prior to his/her ownership of the land.
RCRA. Section 3001(b)(3)(A)(ii) of RCRA excluded certain solid wastes from mining and
processing from regulation as a hazardous waste under Subtitle C, pending certain studies by
EPA. Congress included this provision, also known as the "Bevill Amendment," to apply to
"high-volume, low-hazard waste."1 In 1989 EPA promulgated regulations defining the criteria
for "high volume, low hazard" and published a list of waste types that are no longer excluded.
EPA also stated that it may conduct evaluations of additional waste streams in the future to
determine whether they should remain excluded (40 CFR Part 26, Mining Waste Exclusion, 54
FR 36592, September 1, 1989). The rule does not impose Subtitle C requirements on mineral
processing wastes that were disposed prior to the effective date of the rule.
As a result of these regulatory proceedings, wastes from the extraction and beneficiation
processes continue to be excluded from Subtitle C requirements. Only 20 wastes from mineral
processing are exempt from RCRA (40 CFR 261.4(b)(7)). Today, relatively little mining waste is
subject to RCRA regulation as hazardous waste. Overburden is exempt from RCRA regulations,
so long as it is returned to the mine site.
Surface Mining Control and Reclamation Act (SMCRA). The SMCRA was passed in 1977
to ensure that coal mines are operated in a manner that protects citizens and the environment
during mining, ensure that the land is restored to beneficial use following mining, and mitigate
the effects of past mining by aggressively pursuing reclamation of abandoned mine lands. The
Surface Mining Law gives primary responsibility for regulating surface coal mine reclamation to
the states, a responsibility that 31 states have chosen to exercise.
The Office of Surface Mining (OSM) was established within the Department of the Interior to
help carry out the SMCRA. The OSM handles enforcement on federal lands and Indian
Reservations and in coal states that have not set up regulatory programs. Funds for reclamation
of abandoned mines come from tonnage-based fees paid by active coal mines - 350/ton of
surface mined coal, 150/ton of coal mined underground, and 100/ton of lignite. The fund consists
of fees, contributions, late payment interest, penalties, administrative charges, and interest earned
1 The Bevill Amendment was Section 7 of Public Law 96-482, which was enacted on October 21,1980, to include
several amendments to RCRA.
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on investment of principal. From January 1978 when the first fees were paid through March
2003 over $6.7 billion has been collected. As of March 2003 the balance of unappropriated
funds is in excess of $1.4 billion (DOT, 2003). States that have completed the reclamation of coal
mines can apply unused funds for the remediation of safety and environmental hazards at
hardrock and other non-coal sites.
11.1.5 Mines on Federal Lands
Hardrock and non-coal mining exist in all 50 states. A significant number of both active and
abandoned mines are located on public lands. Three of the four major land managing agencies -
the Bureau of Land Management, the National Park Service, and the Fish and Wildlife Service -
are part of the Department of the Interior. The fourth agency, the Forest Service (USFS), is part
of the Department of Agriculture (USD A). Most federal lands are managed by the BLM and the
USFS.
Most of the BLM-managed 264 million acres are in 12 western states, and 90 percent of this land
is open to mining. The Bureau administers 700 million acres of sub-surface mineral assets
throughout the nation. The Bureau has a budget of $1.8 billion and a workforce of about 9,000
employees. The USFS manages 163 million acres in the west of which about 80 percent is open
to mining. Together, the two land management agencies are responsible for 38 percent of the
total area of the western states. These lands are important for their minerals, timber, and grazing
resources; as a source of clean water; as a location for recreational activities; and as wildlife
habitats and scenic areas, among other purposes. Regulations promulgated by the BLM (1980)
and the Forest Service (1974), require that once mining activities are completed, mine operators
must reclaim all areas disturbed by their operations (U.S. GAO, 1996). Prior to these
regulations, state laws required reclamation of mined sites.
With regard to coal mines, OSM is responsible for enforcement of SMCRA on federal lands and
Indian reservations and in coal states that have not set up regulatory programs. As noted above,
the Surface Mining Law gives primary responsibility for regulating surface coal mine
reclamation to the states, a responsibility that 31 states have chosen to exercise.
Funding Cleanups
Unlike coal mining, there is no single source of federal funding for the reclamation of abandoned
hardrock mining lands. However, as noted above, states with both coal and non-coal mines may
use funds left over from the coal mining reclamation funds for non-coal mining remediation.
There have been a number of efforts over the years to pass Good Samaritan and/or a hardrock
mines reclamation fund legislation.2 A bill proposed in 2002 (HR 4078) would have created a
sliding scale fee on existing mining operations and a permit program detailing cleanup
A "Good Samaritan" provision would protect a remediating agency or "Good Samaritan" who does not otherwise have
liability for abandoned or inactive mine sites, and that attempts to improve the conditions at these sites even though all impacts
from the site will not be eliminated, from becoming legally responsible, under section 301 (a) and section 402 of the Clean Water
Act, for any continuing discharges from the mined land after completion of a cleanup project. This potential liability is an
overwhelming disincentive to voluntary remedial activities financed or conducted by public entities to address the serious
problems associated with abandoned or inactive mined lands.
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requirements and liability limits of parties undertaking voluntary cleanup of the sites. Proponents
of this legislation estimate that the program outlined in this bill would generate approximately
$45 million annually to clean up abandoned mines. At least one other proposal in committee
excludes the funds and focuses solely on the Good Samaritan issue.
The Role of Watershed Management
In the 1990s, the DOT and USD A, in conjunction with the EPA, began to focus environmental
remediation on the nation's watersheds and the problems caused by abandoned mines on
federally administered lands. Investigations into watersheds involve surface and groundwater
sampling, adit discharges, surface runoff, mine wastes, and surrounding rock to locate and
characterize the contamination. Biological assessments are conducted on local species,
engineering cost estimates for reclamation are developed, and searches are performed to identify
potentially responsible parties. This interagency effort eventually led to a cooperative agreement
between the National Mining Association, Western Governors Association and Department of
Energy resulting in the establishment of the Abandoned Mine Land Initiative. The goal of this
Initiative is to increase public and private investment in remediation and consolidate financial
resources and technological expertise to promote cleanup. By 1999 DOE's Federal Energy
Technology Center, now known as the National Energy Technology Laboratory, signed an
agreement with the Office of Surface Mining to share technical services, expertise, and
information on mining and environmental issues (Greeley, 1999).
11.2 Factors Affecting Demand
The following primary factors influence the market for remediation of mine lands.
• Federal and state agencies that manage mine lands are constrained by budget considerations.
The reclamation budgets for the federal agencies are small in comparison to the magnitude
of the abandoned mine waste problem. The OSM fund is designated primarily for coal
mines, and there is very little left for non-coal mining. In addition, the law mandates that
priority be given to addressing safety, health and general welfare rather than environmental
problems.
• A growing market for first or second homes in previously sparsely-populated mining areas
may foster increased demand for cleanup of some sites. Because mine wastes can travel long
distances, contamination from abandoned mines can affect areas many miles downstream
from the source.
• Increase of recreational activities on public lands, in the vicinity of many abandoned mine
sites, may spark increased demand for cleanup or restrictions on park use.
• The transfer of properties in mining areas where complete control of the source of the
pollution has not been achieved may require institutional controls to ensure that prospective
purchasers or developers are aware of any potential risks resulting from a mining operation.
Thus, there is a growing need for methods to ensure compliance with institutional controls.
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• A number of the over 14,000 active and inactive mine sites that are not abandoned also may
require remediation. Releases of contaminants into the environment can result from
inadequately designed facilities such as tailings dams, accidents, leaks and spills, or failure
to properly operate a facility. Thus some portion of these sites are likely to require
remediation of soil, groundwater, and/or surface water, among other things.
• The passage of Good Samaritan legislation would probably encourage more state and local
governments to undertake some remediation. This point is explained in Section 11.1.5.
11.3 Number of Sites
All mining operations have the potential for releasing hazardous materials to the environment.
However because data collection practices vary widely among various sources, it is difficult to
establish the number of mines in the U.S. Moreover, not all of these facilities will actually
require remediation. Until further investigation, the number of mining sites and the number of
these sites that are likely to require remediation can only be estimated.
Active Mines
Information on the numbers and production levels of active mines are available in Department of
Interior, Department of Energy, Department of Labor and the National Mining Association data.
Exhibit 11-1 summarizes these numbers by type of mining operation for the year 2001. The
1,714 active coal mines operating in 26 states produced a total of 1,121.3 million short tons, 66.2
percent at surface mines and 33.8 percent at underground mines. The fees that these mines pay
into the Office of Surface Mining reclamation fund for abandoned mines is based on this
tonnage. Almost 92 percent of active non-coal mines are stone and sand/gravel operations. Metal
and non-metal mineral mines account for 1,039 sites, or almost 8 percent the mines and
processing facilities. Nevertheless, these non-coal mining activities, which operate in all fifty
states, are responsible for the production of between 1 and 2 billion tons of mine waste annually.
In the nine western states, where most of the hardrock mines are concentrated, the industry is
responsible for polluting 3,400 miles of streams and over 440,000 acres of land (U.S. EPA
2000b). Although remediation will probably be needed at active mines, no quantitative estimate
is available.
Abandoned Mines
There are an estimated 13,000 abandoned coal mines, mostly small and mid-sized in the east
(Stone, 2001). Reclamation work at these sites may be funded in part by the Abandoned Mine
Land Fund. However, by law, the bulk of the funding (86 percent in FY 2002) is given to
priority 1 and 2 sites, sites with problems that pose a threat to the health, safety and general
welfare of people. Only 16 percent in FY 2002 went to funding priority 3, environmental
hazards. If a state has completed its 1 and 2 priority sites, funding can be applied to priority 3
sites. According to the 2002 annual report, $13.9 million went to funding watershed projects and
another $1.6 million in the form of watershed cooperative agreements for acid mine drainage
treatment programs.
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Exhibit 11-1. Number of Active Mining Sites - 2001
Coal
Metal
Non-metal
mineral
Stone
Sand/Gravel
Total
Underground
Mines
111
78
44
113
NA
1,012
Surface
Mines
937
124
542
3,914
7,069
12,586
Source: National Mining Association, (updated 2003)
Health Administration, Number of Coal and Non-Fuel
Total Processing
Active Mines Facilities
1,714
202
586
4,027
7,069
13,416
reprinted from the
Mineral Operations
418
72
179
228
NA
897
U.S. Department of Labor,
in the United States
Total
2,122
274
765
4,255
7,069
14,485
Mine Safety &
Since the definition of abandoned hardrock and non-metal mineral mines is slightly different
from state to state and from agency to agency, it is difficult to accurately establish the number of
these mines around the U.S. In some states, multiple shafts and openings in one location are
considered a single mine. In other cases, each opening, shaft, or disturbance is considered a
separate mine. Several organizations have attempted to estimate the number of mines, mostly
based on data from individual states, federal agencies, and USGS maps. However, these numbers
cannot be added for an estimate of the total number of sites. Because of the built-in uncertainties,
most analyses of the scope of the abandoned mine problem are presented in terms of ranges
(Exhibit 11-2).
The BLM estimates that 5 percent (5,000-25,000) of the 100,000 - 500,000 abandoned hard rock
mines on the public lands which the Bureau administers, has caused or could cause
environmental damage, mostly in the form of water pollution (Stone, 2001). The Forest Service
estimated that 5 percent of the approximately 25,000 - 35,000 abandoned mine sites on its lands
would require cleanup under CERCLA and about 12 percent would require remediation of non-
CERCLA water quality problems (Greeley, 1999 and U.S.GAO, 1996). The Mineral Policy
Center estimates that approximately 15,000 of the 557,000 sites have surface or groundwater
contamination, and an undetermined number have other environmental hazards (Lyon et al, 1993
and 2003). Based on discussions with officials at land management agencies, states, and EPA
regional staff, EPA estimates that approximately 5 to 10 percent of abandoned mine lands
require site investigation and cleanup.
Given these data, between, 7,700 and 31,000 abandoned mining sites are likely to require
cleanup. This wide range in the estimate is due primarily to the fact that most sites have not been
evaluated and, therefore, there is a wide range of estimates regarding how many will require
remediation.
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Exhibit 11-2. Comparison of Estimates of
Number of Abandoned Hard Rock Mining Sites
Source
Estimated Number
of Sites
Explanations/Comments
Federal Agencies
Bureau of Land Management
(Department of Interior)
1996,2003
Forest Service
(Department of Agriculture)
1996,1999
National Park Service
(Department of Interior) 1996
Fish and Wildlife
(Department of Interior) 1996
Bureau of Mines
(defunct agency) 1996
US Geological Survey
(Department of Interior) 1996
100,000-500,000
25,000-34,500
2,500
240
15,300 on Dept. of Interior
lands; 12,500 on Dept. of
Agriculture lands
88,000 on Dept. of Interior
lands
On lands managed by BLM; based on
targeted surveys conducted by BLM
and states, and the Abandoned Mine
Land Inventory which is not yet
completed.
On lands within FS boundaries; based
on aerial photos, fieldwork, and Dept. of
Agriculture data.
Actual count in some states, not
including Alaska and part of California
Based on department files and field
office confirmation
Based on database of past mineral
deposit activities
Based on data assembled from
agencies and Western Governors'
Association estimates
Other Organizations
Mineral Policy Center
1993,2003
Western Governors'
Association
1998,2003
557,700
No total estimates given
Based on 32 western states; compiled
from state databases and records
Estimates for 13 of the 15 states
involved, if added would total 263,000;
some state numbers based on
inventory; range from 150 in North
Dakota to 100,000 in Arizona; wide
variations in definition of mines.
Sources:
• U.S. GAO, 1996. Federal Land Management, Information on Efforts to Inventory Abandoned Hard Rock Mines,
GAO-RCED-96-30, February 1996.
Stone, George, 2001. Bureau of Land Management, Overview of Mining in the USA , Abandoned Mines.
Problems, Issues and Policy Challenges for Decision Makers, Santiago, Chile (Updated in conversation in May
2003).
Greeley, Michael N., 1999. US Department of Agriculture - Forest Service, National Reclamation of Abandoned
Lands.
Western Governors Association (1998 ), Cleaning Up Abandoned Mines: A Western Partnership (Updated in
conversation in May 2003).
• Lyon, James S., Milliard, Thomas J., and Bethell, Thomas N., 1993, Burden of Gilt. Mineral Policy Center,
(Updated in 2003 draft report on Cleaning Up Western Watersheds).
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11.4 Market Entry Conditions
The great majority of the sites will be cleaned up under state and local programs, or by private
parties. Federal agencies, since they are often the land managers, will also be involved. Although
their remediation budgets are small, they may participate in negotiations with stakeholders, seek
cost recovery, or may participate in cost sharing.
Superfund site contracting may differ depending on whether the cleanup is fund-lead or PRP-
lead. For fund-lead sites, the EPA or state site manager will have information on the status of the
site, the characterization already done on the site, any treatability studies that might be needed,
and contracting plans and options. For PRP-lead sites, the RPM will be able to refer a vendor to
the PRPs and their contractors. Large PRP-lead sites are usually handled by national
architectural and engineering firms who tend to contract out elements of the cleanup to local
operators. Technology vendors might contact these firms directly for targeted opportunities
within larger cleanup efforts.
11.5 Estimated Cleanup Costs
No single source provides information on remediation costs for mining sites. Some sources deal
with a specific category of sites, while others fold mining remediation costs into an overall
estimate for total reclamation. Because most of the latter category of estimates include costs for
activities beyond remediation, such as correcting safety hazards and landscaping, the amount of
the costs attributable to remediation is unknown.3
The Mineral Policy Center does break down cleanup costs by category and provides estimates
for surface and groundwater cleanup and for cleanup of Superfund sites. According to the MFC,
cleanup of 14,400 surface water contaminated sites would run $1-3 million per site, cleanup of
500 groundwater contaminated sites would run $7.5-12.5 million per site, and Superfund sites
would run $250-350 million per site. However, the MFC analysis does not consider other media,
its estimates are based on only 32 states, and the per site range of cost estimated for Superfund
sites is considerably higher than estimates from other sources both inside and outside of the
EPA. A reasonable estimate can be developed by combining the MFC's non-Superfund estimates
with per site Superfund cleanup estimates derived from Resources for the Future and EPA
records. These estimates are derived from data from EPA's regional offices. Based on these data,
the cost of remediating all hardrock mines is estimated to be between $20 and $54 billion. NPL
sites account for about $3.5 billion of this amount. These estimates are shown in Exhibit 11-3.
These estimates represents costs necessary to clean up sites according to current regulatory
standards and practices. However, if current levels of funding at the federal, state, and local
levels continue, these sites are not likely to be cleaned up in 30 years. Total federal, state, and
PRP outlays for mining site remediation has been averaging no more than $100-150 million
Nevertheless, these data provide some useful insight. These estimates range from $165 million for the National
Park Service, $4.7 billion for the Forest Service, and $4 to $35.3 billion for the Bureau of Mines (GAO, 1996). The
Mine Waste Technology Program Annual Report for 2000 contains estimated remediation costs for all abandoned
non-coal mine sites in the 15 western states (EPA 2000b). The report estimates that the cost of cleaning up these
sites will be between $4 and $45 billion.
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annually in recent years. At this rate of expenditures, no more than 8-20 percent of all the
cleanup work could be complete in 30 years.
Exhibit 11-3. Estimated Remediation Costs for U.S. Hardrock Mines
Number of Average Cost Per Cost
Type of Site Sites site ($M ill ions) ($Billions)
Surface water contamination3
Groundwater contamination3
Superfund Mega sites'3
Superfund Non-mega sites'3
Total
14,400
500
20
70
1 -3
7.5-12.5
100
22c
14.4-43.2
2.5-7.5
2.0
1.5
20.4 - 54.2
3 Source: Lyon, James S., Milliard, Thomas J., and Bethell, Thomas N.,, Burden of Gilt. Mineral Policy Center,
Washington, D.C., 1993. This estimate may not include costs for soil and debris remediation.
b Source: Approximation based on EPA report, supplemented with updated data (EPA 2000a)
c Source: Probst, Katherine N., Konisky, David M., Hersh, Robert, Batz, Michael B., and Walker, Katherine D.,
(2001). Superfund's Future What Will It Cost?, Resources for the Future, Washington, D.C.
11.6 Remediation Technologies
There are a number of conventional technologies, both treatment and containment/diversion, that
have become standard practice in the mining and mineral processing industries. Treatment
technologies which involve changing the composition of the contaminant or limiting its mobility
include chemical treatment (i.e. lime to neutralize acid drainage), stabilization (i.e pH
adjustment), solidification (i.e. solidifying contaminant using cement), solvent extraction (i.e.
leaching), soil washing, and soil flushing. When treatment technologies cannot control the
contaminants to an acceptable level, collection, diversion, and containment technologies are
used. These include landfill disposal, a variety of cutoff walls (i.e. slurry, cement, sheet piling),
pumping groundwater for treatment, capping, diversion and erosion controls.
The prevalent technology today for the single most addressed issue in the remediation of mining
waste is physical/chemical treatment of wastewater using settling agents in clarifying tanks to
precipitate the heavy metals. This treatment costs between $0.5 to $1.00 per thousand gallons
treated. A similar but somewhat less expensive and less successful method involves adding the
chemicals to wastewater in a settling pond. A more innovative technology, mostly still in pilot or
field scale operation, is the anaerobic bioreactor. This process involves adding biological
nutrients to stimulate natural bioorganisms to stabilize heavy metals. Thus far, this technology
has not caught on, probably because early models of the technology failed. The estimated costs
for this treatment is $0.05 per 1,000 gallons.
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11.7 Research and Development
There are two distinct EPA sponsored programs that focus on mining and mine waste. They
work jointly on some projects and with other government, academic and private entities on a
variety of research programs.
The Mine Waste Technology Program (MWTP) in Butte Montana is funded by EPA and jointly
administered by EPA and DOE. MSE Technology Applications, Inc. is the principal contractor
for the MWTP, with Montana Tech serving as a subcontractor for many of the projects. The
Bureau of Land Management and Forest Service provide sites for demonstrations of
technologies. The objective of the program is to develop and prove technologies that provide
satisfactory short- and long-term solutions to the remedial problems facing abandoned mines and
the ongoing compliance problems associated with active mines. Its activities include testing and
evaluation at bench- and pilot-scale and education in training and technology transfer. Priority
areas for research include source control technologies such as sulfate-reducing bacteria and
transport control/pathway interruption techniques; short-term end-of-pipe treatment options for
immediate alleviation of severe environmental problems; and, resource recovery options.
http://www.mtech.edu; and http://www.epa.gov/ord/nrmrl/std/mtb/mwtpannualOO.pdf
The Rocky Mountain Regional Hazardous Substance Research Center in Denver, with oversight
from U.S. EPA Region 8, consists of a consortium made up of Colorado State University,
Colorado School of Mines, Montana Tech, and a variety of participants from academe and the
private sector from all over the U.S. and Canada. The center focuses on geochemical, biological,
hydrological/mineralogical and engineering aspects of environmental problems associated with
mining and mine waste. Research is divided into five areas including site characterization and
contaminant transport/transformation; surface water and sediment transport; treatment processes;
technologies; and, ecological and human health toxicity. http://www.engr.colostate.edu/hsrc/
In addition to the targeted mining programs, EPA sponsors the Superfund Innovative
Technology Evaluation (SITE), administered by EPA's ORD National Risk Management
Research Laboratory. SITE encourages the development and implementation of innovative
treatment technologies for hazardous waste site remediation and monitoring and measuring.
Technology is field tested on hazardous waste materials and engineering and cost data are
gathered so that potential users can assess the technology's applicability to a particular site. EPA
prepares reports evaluating all available information on the technology. SITE works closely with
Montana Tech, helping to leverage funding for projects, http://www.epa.gov/ord/site/
U.S. DOE's, National Energy Technology Laboratory conducts in-house and contracted
research and development including on technologies that identify and treat sources of water and
air contamination at coal sites and watershed mapping. It works jointly with EPA on the Mine
Waste Technology Program, http://www.netl.doe.gov
The National Mine Land Reclamation Center (NMLRC), headquartered at West Virginia
University, addresses reclamation issues for both abandoned and active coal mine sites. Program
participants perform research on acid mine drainage, prime farmland restoration, subsidence
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control, and groundwater purification. The NMLRC provides technical support to local
watershed initiatives, www.nrcce.wvu.edu/nmlrc
11.8 References
Barringer, S. 1999. Mining Regulatory Programs in the Western United States: A Survey of State
Laws and Regulations. Unpublished, 87 pp.
Buck, Stuart and David Gerard, 2001. Cleaning Up Mining Waste, Political Economy Research
Center, http://www.perc.org/pdf/rs01_l.pdf
BLM, 1999. Surface Management Regulations for Locatable Mineral Operations: Draft
Environmental Impact Statement, U.S. Department of Interior, Bureau of Land Management.
Clean Air Task Force, 2001. Cradle to Grave: The Environmental Impacts from Coal.
http://www.catf us/publications/reports/cradle_to_grave.php
Custer, Kelly, 2003. Cleaning up Western Watersheds, Mineral Policy Center, May 2003.
Greeley, Michael N., 1999. National Reclamation of Abandoned Lands., U.S. Department of
Agriculture, U.S. Forest Service, http://www.fs.fed.us/geology/amlpaper.htm
Heritage Research Center, 2003. Mining and the Environment, http://www.heritageresearch.com
Interstate Mining Compact Commission, 1997. Noncoal Mineral Resource Report.
Kodish, Jeffrey A., 2002. Restoring Inactive and Abandoned Mine Sites: A Guide to Managing
Environmental Liabilities, http://www.restorationtrust.org/!egal_guide.pdf
Lyon, James S., et. al., 1993. Burden of Gilt. (Updated in 2003 draft report on Cleaning Up
Western Watersheds), James S. Lyon, Hilliard, Thomas J., and Bethell, Thomas N., Mineral
Policy Center.
McElfish, J. M., T. Bernstein, S. P. Bass, and E. Sheldon, 1996. Hard Rock Mining: State
Approaches to Environmental Protection, Environmental Law Institute, Washington, D.C.
National Research Council, 1999. Hardrock Mining on Federal Lands, National Academy Press,
Washington, D.C.
Northwest Mining Association, 1997. Permitting Directory for Hard Rock Mineral Exploration.
Spokane, Washington.
Probst, Katherine N., D.M. Konisky, R. Hersh, M.B. Batz, and K.D. Walker, 2001. Superfund's
Future What Will It Cost?, Resources for the Future, Washington, D.C.
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Stone, George, Bureau of Land Management, 2001. overview of mining in the USA at the
Abandoned Mines Problems, Issues and Policy Challenges for Decision Makers Conference,
Santiago, Chile. www.mineralresourcesforum.org/news_events/release/abandminesl001 .htm
U.S. DOT, 2003. Personal communication, U.S. Department of Interior, Office of Surface Mining
Reclamation and Enforcement (OSMRE), June 2003.
U.S. EPA (Environmental Protection Agency), 1989. Mining Waste Exclusion., 40 CFR Part 26,
54 FR 36592, September 1, 1989.
U.S. EPA, 1997. National Hardrock Mining Framework, Mine Waste Task Force.
U.S. EPA, 2000a. Abandoned Mine Site Characterization and Cleanup Handbook, EPA 910-B-
00-001, http://www.epa.gov/oerrpage/superfund/resources/remedy/pdf/amscch.pdf
U.S. EPA, 2000b. The Mine Waste Technology Program Annual Report,
http://www.epa.gov/ord/nrmrl/std/mtb/mwtpannualOO.pdf
U.S. EPA, 2003. EPA and Hardrock Mining: A Source book for Industry in the Northwest and
Alaska, Region 10, January 2003.
U.S. EPA, Office of Wastewater Management publications on mining, mining wastes,
environmental impact, and regulations, http://www.epa.gov/npdes/pubs
U.S. GAO, 1996. Federal Land Management, Information on Efforts to Inventory Abandoned
Hard Rock Mines, GAO-RCED-96-30, U.S. General Accounting Office, February 1996.
Western Governors' Association, 1998. Cleaning Up Abandoned Mines: A We stern Partner ship.
http ://www. westgov. org/wga/initiatives/aml/aml .htm
General Web Sites on Mining
Mineral Policy Center at http://www.mineralpolicy.org
National Mining Association at http://www.nma.org
U.S. Department of Energy, Energy Information Administration.http://www.eia.doe.gov
U.S. DOI, Office of Surface Mining Reclamation and Enforcement: information on coal mining
and the Abandoned Mine Lands Program including the inventory system, AML grants, the AML
fund, and annual reports, http://www.osmre.gov
U.S. DOI, Bureau of Land Management: information on the Abandoned Mine Lands Program in
the western states, including project descriptions and the inventory system,
http://www.blm.gov/aml
U.S. Department of Labor, Mine Safety and Health Administration at http://www.msha.gov
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Chapter 12
Demand for Remediation
of Drycleaner Sites
There are approximately 30,000 active commercial dry cleaning facilities in the United States
(IFI, 2003). It has been estimated that soil and groundwater contaminated with drycleaning
solvent are associated with about 75 percent of these facilities (Schmidt, 1999). This does not
imply that all of these facilities will require active remediation, but that further investigation is
warranted. In addition, there is an undetermined number of inactive, or former drycleaning
locations, many of which have not been identified. Because most drycleaning facilities are in
urban and suburban areas, drycleaning solvent contamination has impacted many water supply
wells and threatens many others. Addressing this problem will require the deployment of site
characterization and remediation technologies at many diverse locations.
Drycleaning sites may be addressed under any
of the remediation programs, such as
Superfund, RCRA, or a state environmental
program, depending on the nature and extent
of the contamination and other site-specific
factors. Because these sites may be managed
under different remediation programs, the
estimates of the drycleaning site remediation
market should not be added to those in the
previous chapters of this report. Adding these
estimates would be double-counting sites and,
therefore, overestimating the scope of the
market.
12.1 Industry Description
Drycleaning is the washing of fabrics in non-
aqueous solvents. The drycleaning industry
provides garment cleaning, pressing,
finishing, and related services, primarily to
households. Although the sizes of drycleaning
facilities vary, most are single-facility,
family-owned businesses. This section
summarizes the types of drycleaning
processes, wastes produced, regulatory
programs that affect demand, and
industry efforts to address the contamination issues.
Highlights
* An estimated 15,750 active dry cleaners require
cleanup at an estimated cost of $6.3 billion.
• In addition to active drycleaners, there may be
between 9,000 and 90,000 inactive dry cleaner
sites (the facilities closed, moved, or otherwise
disappeared) that have not been discovered.
• About 90% of active drycleaners use PCE as
their primary solvent. Older facilities used
petroleum solvents, which are LNAPLs.
• Cleanup costs at drycleaner sites range from
$19,000 to $3 million per site and average
$402,000, based on expenditure data from 50
sites with completed remediations.
• On average, about 28% of cleanup costs are for
site assessment.
• Twelve states have dedicated programs and
cleanup funds for drycleaners and several other
states participate in industry activities through
other environmental programs in their states.
• The cooperative efforts between EPA and
states with dedicated drycleanling programs
have fostered the sharing of substantial
amounts of information about site
characterization and cleanup technologies and
costs, state cleanup program operating
practices, and drycleaning industry trends.
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12.1.1 Drycleaning Processes
Drycleaning operations generally consist of three processes: precleaning, drycleaning, and
finishing. In addition, many drycleaning establishments also do conventional laundering.
Precleaning
Prior to being dry cleaned, heavily stained garments are usually pre-cleaned, or "spotted." Spot
cleaning may also be performed after fabrics are drycleaned and stains still remain on the fabric.
A wide variety of chemicals may be used in spotting, depending on the type of stain and fabric.
Spotting is generally done on a "spotting board," where spotting agents, steam, and compressed
air are used to clean stained fabrics. The board is supplied with steam and compressed air to
allow steam or warm air to be applied to fabrics. Wastes are disposed of through a vacuum line
and a drain receptacle mounted on the base of the spotting board. The spotting agents are
contained in bowls or containers placed on or mounted on the board. The chemicals used depend
on the type of stain and fabric being cleaned. There are three general types:
Agents to clean water-soluble stains,
including synthetic detergents; alkaline
agents such as lye, ammonia, potassium
hydroxide, and sodium hydroxide; and
protein formula detergents containing
digester enzymes and acid agents, such
as acetic acid, hydrofluoric acid, glycolic
acid, and sulfuric acid;
Non-aqueous solvents and alcohols, such
as tetrachloroethylene (PCE),
trichloroethylene (TCE), trichloroethane
(TCA), carbon tetrachloride, methylene
chloride, amyl acetate, and petroleum
solvents. These solvents tend to be of
great concern from an environmental and
regulatory standpoint.
Bleaches, such as sodium perborate,
hydrogen peroxide, sodium percarbonate,
sodium hypochlorite, sodium bisulfite,
sodium hydrosulfite, titanium sulfate,
and oxalic acid.
Facts About PCE
• Manufacturers: Dow Chemical (trade name
DowPer) Vulcan Chemicals (PerSec), PPG
Industries, Ineos Chlor Americas (Perklone).
* Although not normally corrosive, PCE can cause
corrosive problems when in the presence of heat
and moisture, or other chlorinated compounds, such
as trichloroethane (TCA), which has been used in
spotting agents.
* To mitigate corrosion, small quantities (0.05-0.2%
by volume) of stabilizers, such as
nemethylmorpholine, diallylamine, tripropylene,
cyclohexene oxide, benzotiriazeole, and
betaethoxypropylnitrile are used.
* PCE used in dry cleaning may also be accompanied
by other potential pollutants, since some dry
cleaners may use reclaimed PCE, which can
contain 1-5% impurities (SCRD2001).Typical
impurities include methyl ethyl ketone, mineral
spirits, toluene, TCA, other chlorinated solvents,
and butylated hydroxytoluene (BHT). Non-reclaimed
PCE is generally 99.9% pure. The impurities are
other chlorinated hydrocarbons.
Drycleaning Machine Processing
The drycleaning process is physically similar to the home laundry process, except that clothes
are washed in a non-aqueous solvent instead of water. Drycleaning is usually done in a
drycleaning machine that agitates the fabric in solvent, extracts the solvent by spinning it, and
dries it through a combination of aeration, heat, and tumbling. Over the past century and a half, a
number of different solvents and machines have been used (See text box on the history of dry
cleaning). Today, about 80 percent of the drycleaning machines use PCE as the solvent. Solvent
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usage has become significantly more efficient over the years, declining from 82 pounds of PCE
to 10 pounds to clean 1,000 pounds of clothing (National Clothesline, 2002). Coin operated
dry cleaning machines, introduced in the 1960s by Whirlpool Corporation, are no longer being
manufactured. However, they are still being used, primarily in laundromats.
History of Dryeleaning
Nineteenth Century: The dryeleaning industry first emerged in Europe in the first half of the nineteenth century.
Over the years, a number of different compounds have been used as dryeleaning solvents, most of them
petroleum-based. The most widely used solvents were petroleum naphtha, benzene, kerosene, and white
gasoline. White gasoline was the predominant dryeleaning solvent in the United States from the late 1800s until
the early 1920s. Because of the high volatility of gasoline, many fires and explosions were associated with
dryeleaning operations. Dryeleaning facilities were unable to obtain insurance and many cities banned
dryeleaning operations within their city limits.
1920s: During the 1920s, drycleaners began using Stoddard solvent, a less volatile petroleum solvent (flash
point of 100 degrees Fahrenheit). From the late 1920s until the 1950s, Stoddard solvent was the predominant
dryeleaning solvent in the United States. This solvent is a mixture of petroleum distillate fractions (petroleum
naphtha) which Is composed of over 200 different compounds. These solvents are composed primarily of
alkanes and eycloalkanes, with some aromatic compounds. Over the years, the trend has been toward the
introduction of higher flash point solvents which have very low aromatics content.
To mitigate biodegradation of petroleum dryeleaning solvents, baeteriacides or biocides are added to the
system, usually In detergents. The biocides used today are similar to those used In shampoos, laundry products
and cosmetics (SCRD, 2001). In the past, perehloroethylene (PCE) was added to dryeleaning soaps as a
bacterial inhibitor.
1920s-1960s: From the 1920s until the early 1960s, a number of chlorinated solvents were introduced into
dryeleaning operations.
• Carbon tetraehloride was used in the United States from the 1920s until early 1950s. Because of its high
tenacity and tendency to corrode equipment, carbon tetraehloride Is no longer used as a dryeleaning solvent
(SCRD, 2001).
« Trichloroethylene (TCE) was introduced as a dryeleaning solvent in 1930. Because it causes bleeding of
some acetate dyes, it is no longer used as a primary dryeleaning solvent (SCRD, 2001).
« Perchloroetylene was Introduced as a dryeleaning solvent in 1934. In 1948, PCE surpassed carbon
tetraehloride use in dryeleaning operations. By the early 1960s, PCE had become the predominant
dryeleaning solvent In the U.S. (Linn, 2002b).
Today: It is estimated that over 90 percent of the eommereial dryeleaners in the United States use PCE (IFI,
2003).
Over the years, several other dryeleaning solvents have been marketed, but never attained a large market
share. For example, in the late 1960s, Dupont began marketing a chlorofluoroearbon as a dryeleaning agent
(trade name: valelene, also known as fluorocarbon 113). These are no longer being manufactured, largely
because of the restrictions on chlorofluorocarbons in the Montreal Protocols. In the early 1980s, Dow Chemical
introduced TCA as a solvent. It was used by only a small number of drycleaners, particularly for leather
cleaning. This solvent proved to be unstable and to cause equipment corrosion. It is no longer being used as a
dryeleaning solvent.
Beginning in the 1990s, several new solvents were developed, including TYNEX (dipropylene glycol tertiary-
butyl ether), liquid carbon dioxide, Green Earth™ (a silicone-based solvent called
deeameethyleyelopentasiloxane), and Pure Dry (a mixture of petroleum hydrocarbons, hydrofluoroethanes, and
perf I u o rocarbons).
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An important influence on the design of dry cleaning machines, dry cleaning practices, and
solvent usage are regulations promulgated under the Clean Air Act (CAA) Amendments of 1990.
The primary CAA regulatory standards for controlling airborne emissions of PCE are the
National Emission Standards for Hazardous Air Pollutants (NESHAP), which was promulgated
in September 1993. These regulations require mandates for retrofitting or replacing certain types
of dry cleaning equipment that are based on PCE, record keeping, inspections, and reporting.
They have encouraged the upgrading or replacement of much equipment in the industry. The
newer dry cleaning machines use considerably less solvent per pound of clothing than older
machines. Detergents are also used in the dry cleaning process to aid in the removal of water-
soluble soil, to suspend the soil after it has been removed from the fabric, and as a spotting agent
to penetrate the fabric, thereby allowing the solvent and water to remove stains. Detergents are
added to comprise typically 1-2 percent of the dry cleaning solvent. The earliest dry cleaning
detergents were soaps, usually composed of surfactant, Stoddard Solvent (see box), free fatty
acids, and some water to create an emulsion. By the early 1950s, liquid soaps were rapidly being
replaced by synthetic detergents.
Finishing
After drycleaning, fabrics are generally pressed with a steam press. The press is supplied with
steam lines and serviced by vacuum lines which create a partial vacuum at the bottom of the
press to hold fabrics in place. Steam from the pressing operation is vented to the atmosphere and
steam condensate is collected in a tank.
In addition to pressing, a dry cleaner's service may include the application of one or more
garment-treating chemicals, including sizing, waterproofing, flame retardants, stain repellants,
and fabric conditioners. Sizing is a finish used to impart body to a fabric. It is usually applied by
textile and garment manufacturers, but becomes depleted after several cleanings. Sizing used in
drycleaning operations consists of polymers or polymer blends and often uses a petroleum
naphtha carrier. Often, anti-static agents and optical brighteners are added to sizing. The sizing
can be applied in the drycleaning machine, by dipping fabrics in a tank of sizing, or by spraying
in an aerosol form.
Waterproofing agents are usually wax-based products and the predominant carrying agents
utilized have been PCE and petroleum solvent. Some of the chemicals used in flame retardants
include decabromodiphenyl oxide (DBDPO), organo-phosphates, phosphate salts, and
phosphated esters. Stain retardants are generally silicon based and the carrying agents are
trichloroethane (TCA) or petroleum naphtha (IFI, 1994). These agents may be applied by several
methods, such as immersion in a dip tank, spraying in the form of an aerosol spray, and in an
auxiliary tank in the drycleaning machine. Drycleaning solvent may also be used as the carrying
agent.
Conventional Laundry Operations
Many drycleaning establishments also have conventional laundries. If clothing is pre-cleaned
with solvents prior to laundering, the washwater may contain solvents.
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12.1.2 Types of Wastes and Waste Management Practices
The wide variety of chemicals and processes at drycleaning facilities results in a variety of
wastes. Most of the wastes, especially those from chlorinated solvent drycleaning operations, are
hazardous (Linn, 2002a). Releases of these wastes to the environment have caused soil and
groundwater contamination at drycleaning sites. Prior to the enactment of the RCRA in 1980,
almost none of the waste generated at drycleaning facilities was regulated. The primary wastes
that contain hazardous materials include the following:
Contact Water. Contact water is any water that has come into contact with drycleaning
solvents, solvent vapors or other hazardous materials. The primary sources of contact water are:
• Separator water. Separator water is generated during solvent recovery processes such as
distillation. Distillation is used to capture solvent vapors and purify spent solvent. The
distillation unit is usually incorporated into the modern drycleaning machines, although it is
a separate piece of equipment in some older machines.
• Vacuum Water. Vacuum water results from the steam and condensate from steam pressing.
This water generally contains drycleaning solvent. Vacuum water samples collected from
PCE drycleaning operations generally contain PCE in concentrations in the tens of parts per
billion range, although some samples have exceeded 100 parts per billion (Linn p. 2002b).
• Mop water. It is common to have spills and leaks within a drycleaning facility. When the
floors are mopped, the solvent and other residues will saturate the mop water.
• Boiler Blowdown Water. This is water from water and steam used to clean the boilers daily.
Because some drycleaners have disposed of separator water to the boiler, solvent residues
can remain in the boiler.
• Conventional Laundry Water. As previously mentioned, the washwater may contain
residues from pre-cleaning chemicals.
Historically, sanitary sewers and septic tanks have been the most common discharge points for
contact water. Over 70.7 percent of 909 respondents to a 1988 survey conducted by the
International Fabricare Institute indicated that separator water was being discharged either to a
sanitary sewer or septic tank (Linn, 2002a). A study of drycleaning contamination in California
in the early 1990s concluded that "the main discharge point for drycleaners is the sewer line"
(Izzo, 1992). Studies in California have found evidence of free-phase PCE in sewer lines serving
drycleaner facilities. Since sewers, especially older ones, have been known to leak, this could be
a conduit for discharge of PCE and other chemicals to the environment.
Other disposal practices for contact water have included discharge to the ground, storm sewers,
soakage pits, blind drains, cooling towers, and boilers at the drycleaning plant. Separator water
has also been known to be used to mop floors (Linn 2002a). Contact water can also be filtered,
followed by evaporation or misting to the atmosphere; or removed by a hazardous waste
management firm. Filtering materials are usually granular activated carbon or polymers, which,
after use, are considered hazardous waste.
Still Bottoms. Still bottoms and cooked powder residues are generated from the distillation
process. They contain grease, oil, detergent, dyes, sizing, waxes, filter materials, and non-volatile
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residues. Distillation residues can contain up to 75 percent solvent by weight and are hazardous
waste managed under RCRA. Prior to the mid-1980s, most of these wastes were either disposed
of in landfills or discharged to the ground (Linn 2002b).
Muck. Muck is the filter waste generated by the purification and recovery of spent solvents by
filtration using a powder filtering material. Muck, which can contain considerable solvent, is
usually produced at petroleum-solvent dry cleaning operations. Prior to the mid-1980s, most of
these wastes were either disposed of in landfills or discharged to the ground.
Spent Filters. Spent cartridge filters can contain up to a gallon of solvent. Spent filters can be
allowed to drain in a drycleaning machine overnight prior to being changed. Because this
practice is not always followed, spent solvent is often spilled during filter changes. In the past,
spent cartridge filters were stored in cardboard boxes or on the ground outside the facility prior
to being discarded in the trash. Solvent tends to drain from these discarded filters if they have not
been drained prior to disposal.
Spent Solvent. Spent solvents are those used as carriers for finishing agents (e.g., PCE) and
petroleum solvents that have biodegraded. At drycleaning operations that use PCE as a carrier
for waterproofing or other agents, oils, fats, and other non-volatile residues from the fabrics
would accumulate in the dip tank and periodically the spent waterproofing agent, which contains
solvent, would have to be discarded.
Spent Vapors. A considerable amount of solvent is lost to the atmosphere in the form of vapors
from the drycleaning machine.
Spotting Residues. These wastes are generated from the leaks, splashes, and spills during
spotting operations, and can contain a wide variety of solvents, bleaches, detergents, and other
agents. These wastes have been discharged to floor drains, which usually go to a sanitary sewer,
septic tanks, or into the ground.
Lint. Lint is generated at various points in drycleaning operations, such as from the button trap
or pump strainer. Historically, the lint, which contains drycleaning solvent, has been disposed of
with trash or discharged to the ground on the property.
12.1.3 State and Industry Drycleaner Site Cleanup Programs
Like other generally small sites, dry cleaner sites may be remediated under one or more state or
federal cleanup programs, such as RCRA Corrective Action, Superfund, and state mandatory or
voluntary cleanup programs. A number of states have established programs dedicated to
dry cleaner sites and some of these programs include funds earmarked for the investigation and
cleanup of these sites. Twelve states have legislation specific to the investigation and
remediation of drycleaner sites (Alabama, Florida, Illinois, Kansas, Minnesota, Missouri, North
Carolina, Oregon, South Carolina, Tennessee, Texas, and Wisconsin).
The 12 states with dedicated drycleaner programs comprise the State Coalition for Remediation
of Dry cleaners (SCRD), formed in 1998 to provide a forum, share information, and encourage
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the use of innovative technologies in dry cleaner site remediation. Also active in the Coalition are
California and New York, which do not have formal drycleaner programs, but are active in
dry cleaner remediation under other authorities. One-third of the nation's dry cleaners are located
in states that are participating in SCRD. SCRD, which operates with support from the U.S.
EPA's Office of Superfund Remediation and Technology Innovation and the National Ground
Water Association, provides a valuable forum for states to share programmatic, technical and
environmental information to improve the characterization and remediation of drycleaner sites
(http://www.drycleancoalition.org/). Much of the information in this chapter is derived from
their research, analysis and forums.
Although the practices and procedures of each state program differ, they all share the same basic
premise: drycleaners and, in some states, solvent suppliers pay fees in exchange for financial
relief and/or liability protection, to clean up contaminated sites. The level of financial relief, type
and amount of fees, and who conducts the site investigations and cleanups differ from one state
to another. Some states, such as Florida and Kansas, hire and direct the activities of an
environmental contractor that investigates and remediates drycleaner sites. Most states develop
some sort of scoring system to prioritize sites. In other states, such as Wisconsin, the program is
a reimbursement or insurance program in which the drycleaner is responsible for investigating
and remediating the site. Usually, there is some cap on the amount of reimbursement per site
and, sometimes, a deductible.
Some states require drycleaner facilities to register with the state, while others require licenses.
Each state program also includes requirements for pollution prevention measures. Most states
also charge drycleaner facilities annual fees, usually based on gross receipts from drycleaner
services, and solvents fees per gallon of solvent used. The solvent fee has also provided an
incentive for drycleaners to use solvents as efficiently as possible.
Drycleaner sites in other states or sites that are not eligible for these state drycleaner programs
are investigated and remediated under other state authorities, such as state superfund, RCRA,
brownfield, or voluntary cleanup programs. These programs are described in other chapters of
this report.
12.2 Factors Affecting Demand for Remediation
• The declining use of PCE by drycleaners will mean fewer discharges to the environment in
the future. The decline is the result of several developments: First, newer drycleaning
machines require substantially less PCE per pound of fabric cleaned than older machines.
Second, a number of new drycleaning solvents have become available in the last decade
(Section 12.1.1). Third, there are movements in a number of communities around the
country to ban the use of PCE in drycleaning. For example, California's South Coast Air
Quality Management District has voted to phase out PCE by 2020. A bill has been
introduced in the California Legislature to increase fees on PCE and provide grants for
drycleaners to switch to non-PCE cleaning processes. In February, 2003, Environment
Canada published new regulations for PCE drycleaners that, among other things, requires
that new cleaning machines have a "manufacturer's design rating" of PCE consumption
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equal to less than 10 kilograms, or 6.2 liters, per 1,000 kilograms of clothing cleaned. This is
equivalent to 1,350 pounds of clothing per gallon of solvent.
The use of solvents has been decreasing primarily by the industry's switching to new more
efficient machines that use significantly less solvent. Perchloroethylene use by drycleaners
dropped from 268 million pounds in 1985 to 47 million pounds in 2002 (National
Clothesline, 2003). These data are based on a survey conducted by the Textile Care Allied
Trades Association. Most of this decrease is due to conversion to newer dry cleaning
machines, although a smaller portion of the change may be due to the use of alternative
solvents.
• For the 12 states with dry cleaner remediation funds, the money available to the fund will
influence the pace of site investigation and remediation work.
• For other states, general availability of state cleanup funds, as discussed in Chapter 9 (State
Sites), will be the deciding factor for many cleanups. Drycleaners have average revenues of
about $250,000; remediation costs can run hundreds of thousands of dollars; and several
have cost over a million dollars. Even a moderate-cost cleanup can amount to several years
of profit for the average dry cleaner.
• In addition to active drycleaner facilities, many inactive facilities may have had releases of
hazardous substances to the environment that have resulted in contaminated soil and
groundwater that have not been discovered. Although data on these facilities are sparse,
estimates range from 9,000 to 90,000 sites (See Section 12.3.2).
• The level of assessment and cleanup is directly related to the cleanup standards adopted by
the individual states. Many states have adopted risk-based cleanup standards for soil and
groundwater.
12.3 Number and Characteristics of Sites
12.3.1 Active Drycleaning Facilities
The drycleaning industry includes three types of operations: commercial, industrial, and coin-
operated. The commercial facilities are by far the most prevalent and include full-service, retail
operations located in shopping centers, urban neighborhoods, and other densely populated areas.
Commercial facilities typically clean small quantities of garments from individuals and only a
small minority clean furs or leathers. Exhibit 12-1 indicates the scale of the various types of
operations. Commercial laundries tend to be located in urban areas because of the greater
demand for drycleaning in these areas.
According to the International Fabricare Institute, there are about 30,000 active drycleaning
facilities in the U.S. Almost all of these are commercial facilities, which are primarily small,
neighborhood businesses whose primary customers are individuals. Based on data for a "model"
drycleaning plant in a 1998 EPA study, it is assumed that the average commercial drycleaner
facility cleans 26 tons of fabric, and produces 660 gallons of hazardous waste annually, mostly
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PCE and PCE-containing materials from distillation residues and from filters (EPA 1998). Based
on information from a hazardous waste treater, EPA estimated that this waste is, on average, 40
percent PCE.1
Exhibit 12-1. Number and Types of Active Drycleaners in the United States
No. of Average Tons Per Hazardous Waste Hazardous Waste
Facilities Facility/year Average Gal./Year Total Gal./Year
Commercial 30,000a 26b 660b 19,800,000°
Industrial 325d 578d 14,672e 4,768,000c
Coin-Operated 100d 1.6d 40d 4,000c
Total 24,572,000
Notes:
3 International Fabricare Institute, web site, 2003, http://vwwv.IFI.org
b EPA, 1998
c Product of Column 2 and column 4
d EPA, 1995
e Based on gallons per output for commercial facilities
Industrial drycleaners, which tend to be larger than commercial facilities, clean uniforms,
restaurant linens, wiping towels, floor mats, work gloves and other items for institutional,
professional, and industrial customers. In many cases, industrial drycleaning firms also rent
uniforms and other industrial clothing. Based on a 1995 EPA report, these facilities are assumed
to average 578 tons of clothing annually (U.S. EPA1995). Assuming the same ratios of waste to
output as for commercial cleaners, industrial cleaners average 14,672 gallons of hazardous waste
annually. Industrial drycleaning is included within the Census category Industrial Laundry
Services. About one-quarter of these establishments include drycleaning. The remainder are
exclusively wet laundries.
Coin-operated drycleaners use machines that are self-service or are run by an attendant in self-
service laundromats. Coin operated machines, which were introduced in the 1960s by Whirlpool
Corporation, are no longer being manufactured. In 1993, EPA estimated that there were 3,000
coin-operated drycleaners (U.S. EPA 1993), although a 1995 EPA report speculated that there
are fewer than 100 in operation (U.S. EPA 1995). For this report, it is assumed that there are
100. Based on the same ratios used for commercial cleaners above, the average coin-operated
facility would average 40 gallons of hazardous waste annually.
There are a number of uncertainties associated with these averages. Discharges vary widely from one
drycleaning facility to another, because of differing processing technology, equipment, and operating practices. Thus,
releases from a specific facility in the real world may not compare with these averages. Moreover, equipment and
practices at many facilities have changed since the data upon which these estimates are based were collected (early
1990s). Nevertheless, these averages reflect the approximate discharges to be expected.
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Another potential source of groundwater, surface water, and soil contamination is contact
wastewater discharges. Most drycleaning contact water is discharged to sewer systems or
directly to the ground. Because many sewer systems are known to leak, PCE can contaminate
groundwater downstream from drycleaning facilities.
A 1999 study by SCRD estimates that about 75 percent of active commercial dry cleaners have
some level of contamination. Although not all of these sites will require remediation, they will
probably require site investigation. Assuming that 70 percent of these will ultimately require
remediation, there are about 15,750 active sites that will need remediation.2 This estimate does
not include inactive sites.
12.3.2 Inactive Drycleaning Facilities
In addition to releases of hazardous materials by active drycleaning facilities, there are a
substantial number of sites that were formerly occupied by drycleaners that have moved or gone
out of business. Some drycleaners have moved within the same shopping center or city block,
thereby confounding site investigations.
Another factor that may complicate site
investigations and remediations is the fact
,,, , , , , , ,, there may be between 9,000 and 90,000
that many drycleaners have changed the jnactjve ^clemer sites that have not been
In addition to about 30,000 active drycleaners,
discovered.
cleaning processes over the years, including
changes in the solvents, other chemicals, and
equipment, especially drycleaning machines.
One indication of the number of inactive sites can be discerned by observing trends in the
number of drycleaner facilities. According to the Economic Census, the number of drycleaner
facilities has fluctuated over time, from a peak of 30,525 in 1967 to a low of 21,257 in 1987,
before growing to 27,939 in 1997.3 This implies that at least 9,268 sites have closed over time
(30,525 - 21,257). Since it is unlikely that newer establishments opened in the same location as
the old ones, these figures imply that there are at least 9,000 inactive facilities. There are
probably more than 9,000 facilities because the Census data do not indicate how many have
moved or been replaced by another nearby dry cleaner. There are no data regarding how many of
these may have been remediated over the years. Compounding these uncertainties is the fact that
Census does not account for the fact that a drycleaning facility may move within the same
shopping center or block, a fact that can easily elude site investigation efforts. Moreover, Census
did not collect information on drycleaners prior to the 1960s and many drycleaners probably
moved or closed before that time. Thus, there are at least, and probably many more than, 9,000
inactive sites that have not been explicitly identified. Some estimates, which are based on field
experience with drycleaner sites, indicate that there could be 3 to 5 times as many inactive sites
The 70% estimate is based on conversations with four states with active drycleaner programs (Florida, Kansas,
Oregon, and Wisconsin).
3 This figure differs from the other estimate used in this report for currently active facilities (30,000) because of
differences in survey methodology and industry definitions.
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as active sites.4 Older dry cleaners consumed, and released to the environment, substantially
more solvent per pound of clothing processed than newer ones. The older dry cleaners tended to
use more petroleum solvent and less PCE.
12.4 Market Entry Considerations
• The operating practices of dry cleaner site cleanup programs vary from state to state. Some
states have a fund dedicated to drycleaner site investigations and cleanups. These programs
often have considerable information about potential drycleaner site projects and technology
needs.
• Some states engage one or more contractors to address all sites under their drycleaner sites
program. In other states, the property owner or operator is responsible for conducting the
cleanup.
• Most states, including states that do not have formal drycleaner remediation programs, have
drycleaner trade associations, which are a potential source of contacts and information on
potential cleanups needed. Most of these are available through links available on the SCRD
web site, http://www.drycleancoalition.org/links.cfmffindustry
12.5 Estimated Cleanup Costs
To estimate the value of the drycleaner remediation market, EPA estimated the average
remediation cost actually incurred from a sample of sites and multiplied this average by the
estimated number of drycleaner sites likely to require remediation (15,750 sites estimated in
Section 12.3). Only active sites were considered, since data on inactive sites are sparse.
EPA analyzed data on 50 drycleaner sites that reported total site cost data, as well as other site
information to the SCRD. Total cost data includes site assessment, remediation, and O&M.
While this sample was not scientifically designed, it is drawn from a number of different states
and represents a wide variety of site conditions, and site assessment and remediation
technologies. The costs vary from $19,000 to over $3 million, and average $402,400 per site
(Exhibit 12-2).
Based on this average, the total value of the U.S. drycleaner remediation market would be $6.3
billion. This estimate does not include the potentially thousands of inactive drycleaner
sites-properties that are either vacant or are being used for other purposes.
12.6 Remediation Technologies
Drycleaner sites have unique characteristics that need to be considered in site characterization
and remediation work. A drycleaning facility may have used a chlorinated solvent, such as PCE,
petroleum hydrocarbons, or a combination of chemicals. Sometimes the current owner may not
4 Based on personal communications with four members of SCRD (Florida, Kansas, Oregon, and Wisconsin).
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know what solvents were used in the past at the site, especially if it is an old facility. PCE, TCE,
carbon tetrachloride, TCA, and Freonl 13 are DNAPLs and petroleum hydrocarbons are
LNAPLs. A knowledge of the history of dry cleaning processes may help identify what to look
for. For example, earlier petroleum hydrocarbon solvents contained aromatic compounds. Over
the years, the proportion of these compounds have been reduced, and the later petroleum
drycleaning solvents contain little or no aromatic compounds (SCRD, 2001).
Exhibit 12-2. Estimated Drycleaner Site Remediation Costs
Average of 50 sites
Range
Percent Site Assessment Cost
Percent O&M Cost
Estimated National Total (active
drycleaners requiring cleanup)a
$402,400
$19,000- 3.3 million
28.2%
16.8%
$6.3 billion
50 sites reporting
50 sites reporting
38 sites reporting
38 sites reporting
15,750 sites estimated a
Total Cleanup Cost
Range Detail
Number of Sites
Percent
$5,000-100,000
11 sites
22%
$100,000-250,000
17 sites
34%
$250,000 - 500,000
16 sites
32%
$500,000 -1 million
3 sites
6%
Over$1 million
3 sites
6%
Estimate from Section 12.3. No estimate is provided for inactive sites, as described in the text, though there
may be thousands of them.
Source: Analysis of site profile data from State Coalition for Remediation of Drycleaners (SCRD, 2003)
Site investigators often use information on the location of the discharge point of contaminants to
facilitate identification of the contaminant source areas. However, for inactive sites where the
building has been razed or is being used for a different purpose, it may be impossible to locate
these discharge points. Sampling and analysis for the above types of contaminants often must be
conducted in and around active businesses, usually retail. To accommodate these businesses, the
work may be scheduled after business hours or on weekends. Work space is often limited and
samples must be collected from beneath building floor slabs.
In addition, a site investigation or remediation may need to address contaminated groundwater
that has migrated off site. A study of site assessments conducted at 150 contaminated drycleaner
sites in Florida found that contaminated groundwater had migrated off the property at about 57
percent of the sites (Linn 2002b). In an urban or suburban area, this could require obtaining site
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access to public areas, such as roads and parks, as well as other commercial or residential
properties.
12.6.1 Site Assessment Technologies
In 1999, the SCRD conducted a survey of all states to determine what site investigation and
remediation technologies were used at dry cleaner sites (Jurgens, 1999). The 28 states that
responded reported that they have employed 18 site assessment technologies (Exhibit 12-3).
These include five media sampling techniques, such as gas surveys and direct push; five
geophysical techniques, such as ground penetrating radar, soil conductivity analysis, and induced
laser fluoroscopy, to assist in interpreting subsurface conditions; five sample analysis
approaches, such as fixed laboratories, mobile laboratories, and portable gas chromatography, to
determine the relative or actual concentrations of contaminants in the sampled media; and three
techniques for the analysis of DNAPLs.
Exhibit 12-3. Site Assessment Technologies Used at Drycleaner Sites
Technology Percent of States
Sampling Tools
Monitoring Well/boring 91
Direct Push 87
Active Soil Gas 78
Passive Soil Gas 39
Microwells 26
Geophysical Techniques
Soil Conductivity Surveys 39
Ground Penetrating Radar 30
Magnetometer 30
Induced Laser Fluoroscopy 17
Electrical Resistivity Survey 13
Analytical Techniques
Fixed Laboratory 91
Mobile Laboratory 61
Portable Gas Chromatography 48
Immunoassay 30
Colorimetric Tube 17
DNAPL Detection
Ultraviolet Fluorescence 17
Hydrophobic Dye 17
Partition Interwell Tracer Set 4
Source: Jurgens, Bob, et. al. Study of Assessment and Remediation Technologies for Drycleaner Sites, State
Coalition for Remediation of Drycleaners, with support from the Technology Innovation Office, U.S. Environmental
Protection Agency, 1999.
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In addition, the respondents identified several other techniques that could be used. These
techniques include fracture trace analysis, an inexpensive method of identifying fracture zones
with aerial photographs and knowledge of area geology; sonic drilling, an expensive method of
drilling that can penetrate consolidated and unconsolidated formations; and video cameras to
inspect the inside of sewer lines to help identify joints, cracks, or holes in the lines that may
allow the release of solvent-contaminated waste water. Cameras are also used in boreholes to
identify fractures and dissolution zones (Jurgens, 1999).
12.6.2 Remediation Technologies
The SCRD survey also identified 18 remediation technologies that had been employed in the
states (Exhibit 12-4). These include three soil remediation techniques, five general groundwater
remediation techniques, six groundwater techniques that use bioremediation or chemical
oxidation, and four groundwater techniques that use in-situ flushing or thermal treatment.
Exhibit 12-4. Site Remediation Technologies Used at Drycleaner Sites
Technology Percent of States
Soil Remediation
Excavation 86
Soil Vapor Extraction 86
Bioventing 29
Groundwater Remediation: General
Natural Attenuation 71
Air Sparging 67
Multi-Phase Extraction 33
Permeable Wall 14
Recirculating Well 14
Groundwater Remediation: Bioremediation & Chemical Oxidation
Hydrogen Release Compound (HRC) 29
Hydrogen Peroxide 24
Potassium Permanganate 19
Organic Release Compounds (ORC) 10
Recirculating Well 10
Potassium Permanganate 5
Groundwater Remediation: In-Situ Flushing & Treatment
Surfactant Flush 14
Co-Solvent Flush 5
Steam Injection 5
Electrical Heating 5
Source: Jurgens, Bob, et. al. Study of Assessment and Remediation Technologies for Drycleaner Sites, State
Coalition for Remediation of Drycleaners, with support from the Technology Innovation Office, U.S. Environmental
Protection Agency, 1999.
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12.7 References
Cardimone, 2001. Drycleaner Remediation Programs: An Overview and Case Studies, U.S.
Environmental Protection Agency, Technology Innovation Office, August 2001.
HSIA, 2003. Amended Rule 1421 - Control ofPerchloroethylene Emissions from Dry Cleaning
Operations, Halogenated Solvents Industry Alliance, http://www.hsia.org/scaqmd.htm
IFI, 2003. Profile of the Fabricare Industry, International Fabricare Industry, web site.
http://www.ifi.org/industry/industry-profile.html
Jurgens, Bob, et.al., 1999. Study of Assessment and Remediation Technologies for Drycleaner
Sites, State Coalition for Remediation of Dry cleaners, with support from the Technology
Innovation Office, U.S. Environmental Protection Agency.
http://www.drycleancoalition.org/tech
Linn, William J. and K. Mixell, 2002a. Leaks, Spills, and Discharges At Florida Drycleaning
Sites, State Coalition for Remediation of Dry cleaners.
http://www.drycleancoalition.org/download/leaks
Linn, William, et. al., 2002b. Conducting Contaminant Assessment Work at Drycleaning Sites,
State Coalition for Remediation of Dry cleaners, http://www.drycleancoalition.org/chemicals
National Clothesline, 2002. "Cleaners' Perc use Continues to Decline," National Clothesline,
August 2002. http://www.natclo.com/0208/aalO.htm
National Clothesline, 2003. "PERC Demand Continues 17-Year Decline" National Clothesline,
August 2003. http://www.natclo.com/0308/aa90.htm
Schmidt, Robin, R. DeZeeuw, L. Henning, and D. Trippler, 1999. State Programs to Clean Up
Drycleaner, State Coalition for Remediation of Dry cleaners.
http://www.drycleancoalition.org/survey
SCRD, 2002. Chemicals Used in Drycleaning Operations, State Coalition for Remediation of
Drycleaners, January, 2002.
SCRD, 2003. Site Profiles, State Coalition for Remediation of Drycleaners.
http://www.drycleancoalition.org/profiles
U.S. Census Bureau, 1998. Economic Census: Comparative Statistics of the United States for
Service Industries, U.S. Department of Commerce.
U.S. EPA, 1991. Dry Cleaning Facilities - Background Information for Proposed Standards,
Draft EIA, U.S. Environmental Protection Agency, Office of Air Quality Planning and
Standards, November 1991.
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U.S. EPA, 1993. Economic Analysis of Regulatory Controls in the Dry Cleaning Industry, Final,
EPA 450/3-91-021b, U.S. Environmental Protection Agency, September, 1993.
U.S. EPA, 1995. EPA Office of Compliance Sector Notebook Project Profile of the Dry Cleaning
Industry, EPA/310-R-95-001, U.S. Environmental Protection Agency, Office of Enforcement
and Compliance Assistance, September, 1995.
U.S. EPA, 1998. Cleaner Technologies Substitutes Assessment: ProfessionalFabricare
Processes, U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxic
Substances, Washington, D.C., June 1998.
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Chapter 13
Demand for Site
Characterization Services
Site characterization is usually the first step in the remediation of soil and groundwater pollution
and continues throughout all aspects of the cleanup process. Site characteristics data are crucial
to locating the sources of contamination, predicting where chemicals may migrate, developing
risk assessments and remediation strategies, influencing community reactions, evaluating reuse
options, monitoring progress of remediation efforts, and conducting long-term monitoring.
Although site characterization is usually a small part of total remediation costs, it lays the
foundation for the entire project and can substantially affect the total project effectiveness, cost,
and schedule.
This chapter examines the market for sampling and analysis technologies used to investigate the
nature and extent of contamination at hazardous waste sites in the U.S. and its implications for
the continued demand for newer, streamlined technologies. Sampling and analysis is an integral
component of all site investigations and remediations, whether the work is conducted under
Superfund, RCRA, or another cleanup program. Thus, the market estimates in this chapter
should not be added to those in the previous chapters of this report. Adding these estimates
would be double-counting sites and, therefore, overestimating the scope of the market.
In recent years, the use of more timely and more accurate site characterization approaches has
been growing. Many analyses that previously were conducted in laboratories can now be done in
the field. Better methods can reduce the time and cost needed to evaluate sites and result in more
efficient remediation designs. These new technologies can be applied in conjunction with
systematic planning and dynamic work plans that are used to manage the site from initial site
assessment through remediation and closeout. The integration of these three strategies is referred
to as the Triad approach to hazardous waste site cleanups. The use of the Triad approach has
significantly reduced the overall cleanup costs and time at many sites.
13.1 Market Description
Site characterization is the process of identifying, quantifying and describing the nature, extent,
and fate and transport of hazardous substances released into the environment to detect their
impacts on human health and the environment. The information developed in site
characterization studies have a profound influence on all future activities at a site. For example,
underestimation of the nature and extent of the contamination, or inaccurate description of
geological conditions, may lead to response actions that are inadequate to protect human health
and the environment. If additional contamination is discovered during remedial action, costly
construction delays and redesign of the remedy may be necessary. Conversely, if the nature and
extent of contamination is overestimated, the remedy may be over-designed, causing greater
remediation expenditures than necessary to protect human health and the environment. A more
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effective site characterization, even if greater sampling and analysis costs are incurred, can lead
to lower total cleanup costs.
Site characterization information affects all stages of site management, from site discovery to
close out. Specifically, site characterization is an important component in the following five
steps of the site management process.
Phase One Site Assessment. The purpose of a Phase One site assessment is to determine the
likelihood of environmental contamination at a property. This type of assessment is often done
when a site is reported to a regulatory authority or in conjunction with the development,
purchase, lease, sale, or other means of transfer of a property. Property purchasers and lenders
hire environmental firms to conduct these assessments as part of their due diligence
responsibility. A Phase One assessment is not expected to provide a detailed description of the
contamination; its function is to indicate whether further study is warranted. Environmental
samples are rarely collected at this point. This phase is approximately, but not precisely,
equivalent to the 1994 American Society of Testing Materials (ASTM) industry standard E-1527
for Phase I environmental site assessments.
The structure and role of the ASTM standard may change as a result of new requirements under
the Small Business Liability Relief and Revitalization Act (the "Brownfields Law") of 2002.
Among other things, the law revises some of the provisions of CERCLA Section 101(35)
clarifying requirements necessary to establish the innocent landowner defense under CERCLA
and provides Superfund liability limitations for bona fide prospective purchasers and contiguous
property owners. Among the requirements added to CERCLA is the requirement that such
parties undertake "all appropriate inquiry" into prior ownership and use of a property at the time
at which a party acquires the property. EPA plans to promulgate federal standards for "all
appropriate inquiry." These standards may replace the ASTM standards in many, if not most,
real estate industry practices.
The Phase One site assessment is similar to, but not precisely equivalent to, the Preliminary
Assessment (PA) which is performed on every site listed in the CERCLA Information System
(CERCLIS), and the RCRA Facility Assessment (RFA). The RFA is conducted for hazardous
waste treatment, storage, and disposal facilities and other locations that may be subject to
corrective action under the RCRA Corrective Action program. PAs are generally conducted by a
state, or federal agency to distinguish, based on limited data, between sites that clearly pose little
or no threat to human health or the environment and sites that may pose a threat and require
further investigation. The PA also identifies sites requiring assessment for possible emergency
response actions. If the PA results in a recommendation for further investigation, a Site
Inspection is performed.
RFA's are conducted or directed by a state or federal regulatory agency to identify solid waste
management units (SWMUs) that are, or are suspected to be, the source of a release to the
environment. This information is used to determine whether a RCRA Facility Investigation
(RFI), interim measures, or other corrective measures are needed.
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Phase One assessments generally include the following components:
• Review of fundamental information about the site, such as that available from aerial
photography, public information, and other sources;
• A review of historical documents and records search to determine whether there is any
publicly available information on actual or potential contamination on or related to the
property;
• A physical tour of the property to record visual, olfactory, and tactile observations. The tour
may include interviews with on-site personnel who may have knowledge of past and present
environmental practices; and
• A written report documenting the process and results of the Phase One assessment.
In addition to serving as a screening mechanism, the information collected during Phase One can
be used to develop a preliminary conceptual site model (CSM), which is generally refined as
work at the site continues. A CSM is a planning tool that organizes what is already known about
the site and helps the site management team identify additional information needed to make the
decisions that will achieve the project's goals.
Phase Two Site Assessment. The Phase Two site assessment includes further investigation of
possible contamination discovered during phase one to confirm the presence of contamination. It
may include on-site environmental testing and laboratory analysis. The investigation may require
extensive sampling and analysis in several stages to obtain the required information. The ASTM
standard appears in E 1903, Standard Guide for Environmental Site Assessments: Phase II
Environmental Site Assessment Process. The Phase Two site assessment is similar to, but not
precisely equivalent to, the Site Inspection (SI) which is often, but not always, performed on
sites listed in CERCLIS; the sampling portion of the RFA, which is conducted for hazardous
waste treatment, storage, and disposal facilities and other locations that may be subject to
corrective action under the RCRA Corrective Action program; and tier evaluations of a risk-
based corrective action (RBCA) at UST sites.
Sis are generally conducted by a state or federal agency to provide or augment the data needed
for Hazard Ranking System (HRS) scoring and documentation. The HRS score is an important
input to the decision of whether to list a site on the NPL. If a site receives an HRS score greater
than 28.5, it is eligible for listing on the NPL. SI investigators may collect samples of soil, water,
free product, and other media to determine if hazardous substances are present, and if there is
human exposure or contamination of sensitive environments. The EPA publication Guidance for
Performing Site Inspections Under CERCLA; Interim Final, September 1992, (NTIS PB92-
963375, EPA 9345.1-05) provides more information on conducting Sis. This publication may be
found at: http://www.epa.gov/superfund/whatissf/sfproces/pasi.htm
Phase Two assessments generally include one or more of the following components:
• Soil sampling to determine if a release has impacted site soil;
• Groundwater sampling to determine if a release has impacted groundwater;
• Drums and waste materials testing;
• Asbestos testing;
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• Indoor air quality testing;
• Underground tank testing to determine whether tanks and associated piping have leaked or
are likely to leak, and whether the tanks meet federal and state requirements; and
• A written report documenting the process, quality assurance procedures, and results of the
Phase Two assessment.
Phase Three Site Assessment. A Phase Three site assessment is generally required if the results
of Phase Two reveal the presence of contamination. The purpose of the Phase Three analysis is
to quantify and characterize the full extent of the contamination, determine the risk, and select an
appropriate remedy. The Phase Three site assessment is approximately, but not precisely,
equivalent to the Remedial Investigation/Feasibility Study (RI/FS) which is performed on
Superfund sites and the RFI/Corrective Measures Study (CMS) which is conducted for facilities
that may be subject to corrective action under the RCRA Corrective Action program.
RI/FSs are generally conducted by potentially responsible parties, states, or EPA after a site is
listed on the NPL. RFIs/CMS are generally conducted by the facility owners or operators, with
oversight by a state or federal regulatory agency. For state voluntary cleanup program or
underground storage tank sites the Phase Three assessment is generally conducted by the facility
owners, with state oversight.
The RI and FS are generally done interactively. The RI serves as the mechanism for collecting
data to characterize site conditions and further refine the conceptual site model; determine the
nature of the waste; assess risk to human health and the environment; and provide data necessary
for treatability studies. The FS is the mechanism for the development, screening, and detailed
evaluation of alternative remedial actions. Data collected in the RI influence the development of
remedial alternatives in the FS, which in turn affect the data needs and scope of treatability
studies and additional field investigations. Treatability testing is conducted under the FS to
evaluate the potential performance and cost of the treatment technologies being considered. This
interactive approach encourages the continual scoping of the site characterization effort, which
minimizes the collection of unnecessary data and maximizes data usability.
Generally, the more thorough and accurate the conceptual site model developed during the RI or
RFI, the more cost effective the cleanup will be. The greater the uncertainty in the CSM, the
greater the likelihood that problems will arise during the implementation of the remedy. For
example, if the sampling plan during the RI caused investigators to overlook contaminated
material, the contamination might be discovered during construction of the remedy. The
contractor would then have to conduct additional sampling and analysis, revise cleanup plans
and, perhaps, select different treatment technologies. These activities would cause delays and
drive up cleanup costs.
It is generally impossible to completely collect and document information about all aspects of a
site with 100 percent certainty because an RI or RFI can be expensive and time-consuming. Site
investigators must address both sampling uncertainty and analytic uncertainty. Sampling
uncertainly refers to the ability of the sample to represent the true site conditions, and generally
is directly related to the density of sampling points and number of samples taken. Analytic
uncertainty refers to the ability of the sample analysis techniques to accurately describe the
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constituents in the sample. Typically, site investigators and managers use their best judgement to
determine how much effort to put into characterization on a case-by-case basis. There is a
tradeoff between the level of effort invested in characterization and the probability of missing
contaminants that may cause unforseen problems during remediation or uncorrected health risks.
Remedial Design and Construction. Although it may not be explicitly regarded as site
characterization, sampling and analysis is necessary during remedy design and construction or
other corrective measures at most sites. Sampling is used to confirm that various aspects of the
remediation were successful and, sometimes, to revise the original site characterization plans
based on site conditions that were not anticipated prior to construction. Site characterization
during remedial design and construction would generally use sampling and analysis technologies
that are similar to those used during the Phase Three site investigations.
Operations and Maintenance (O&M). The use of site characterization technologies also may
occur during the O&M phase of the site. O&M measures related to waste containment and
control are initiated after the remedy has been constructed in accordance with the ROD or other
site agreements and is determined to be operational and functional based on state and federal
agreement. For Superfund-lead sites, remedies are considered operational and functional either
one year after construction is complete or when the remedy is functioning properly and
performing as designed, whichever is earlier.
Typical remedy components requiring long-term O&M measures include landfill covers and
liners; gas extraction, treatment, and monitoring systems; water collection, treatment, and
monitoring systems; and permeable reactive barriers. The remedy and reuse plans must allow for
access necessary for sampling, inspection, and repair of these components. O&M monitoring
may include five types of activities: inspection, sampling and analysis, routine maintenance and
small repairs, reporting, and five-year reviews. The five-year reviews are primarily a
requirement for some Superfund sites. The most likely demands for site characterization
technologies include periodic topographic surveys to measure the rate of movement or
settlement, the collection and chemical analysis of gas, air, and water samples from wells, probes
and other collection means.
13.2 Site Characterization Tools
Site characterization technologies can be grouped into those related to accessing, collecting, and
analyzing samples and environmental data and geophysical tools that can sometimes be used to
directly locate contamination such as a leachate plume or buried drums but are more often used
to refine the CSM with regards to site stratigraphy. These technologies are supported by
computer software and other decision support tools that facilitate efficient and effective data
management, interpretation, and decision making as data are collected and analyzed. In addition,
it is important to consider how the deployment of each technology is integrated into a
characterization program, and ultimately into the general site management process. A number of
newer characterization technologies have made possible more efficient and flexible site
management processes. Conversely, site managers are using scientifically designed, systematic
approaches to planning and conducting site investigations and cleanups which optimize the
effectiveness of the technologies. A systematic approach to site characterization can ensure that
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data collected are appropriate, reduce the time and cost it takes to initiate cleanup, and reduce
overall remediation costs.
The large number of characterization
techniques makes it impossible to describe
them all in this report. Exhibit 13-1 lists the
major groups of tools. The publications Field
Sampling and Analysis Technologies Matrix
(FRTR 1998, http://www.frtr.gov/site) and
Field Analytical Technologies Encyclopedia
(EPA 2003) provide more detailed
descriptions of the categories, the commonly
used and proven techniques, conditions under
which they tend to be used, and other useful
information. The following four subsections
provide an overview of these technologies.
13.2.1 Sample Access and Collection
Technologies
The access and collection techniques enable
site investigators to access soil, groundwater
and other media for the purpose of collecting
samples; physically remove samples; and
directly extract contaminants of concern from
soil for subsequent analysis. Exhibit 13-1
above lists the major types of access and
collection techniques.
13.2.2 Sample Analysis Technologies
Qualitative chemical analysis is used to
determine whether chemicals of concern are
present in a sample. Once it is known that
chemicals of concern may be present,
quantitative analysis is used to determine the
identities and concentrations of the chemicals
in the sample. To determine the extent and
type of analyte to collect and the extent of
quantitative analysis to conduct, site
investigators first develop explicit data
quality objectives (DQOs) early in the
project. Exhibit 13-1 above lists the major
types of sample analysis techniques.
Exhibit 13-1: Major Characterization
Technology Subcategories
Sample Access Tool Groups
• Drilling methods - unconsolidated materials
• Drilling methods - consolidated materials
• Drive methods utilize a hydraulic device
• Sampling installations for portable samplers
• Portable in-situ groundwater samplers
• Fixed in-situ samplers cover
• Destructive sampling methods
Sample Collection Tool Groups
• Hand-held methods (soil)
• Portable positive displacement pumps
• Other portable groundwater sampling pumps
• Portable grab samplers (water)
• Extractive collection methods
• Gas/air collection methods
Sample Analysis Tool Groups
• Ex-situ methods for analyzing VOCs and
SVOCs
• In-situ methods for analyzing VOCs and
SVOCs
• Ex-situ methods for analyzing metals
• Ex-situ and in-situ methods for analyzing
radionuclides
• Ex-situ methods for analyzing explosives
Geophysical Tools
• Electromagnetic
• Resistivity
• Conductance
• Ground Penetrating Radar
• Seismic
Decision Support Tool Groups
• Computer software to aid decision-tree
analysis for CSMs
• Software that integrates geographic information
systems, global positioning systems, imaging,
analytical technologies, and databases to
assist in modeling of site conditions and
evolution of the CSM
• Statistical methods or sampling design and
analysis
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13.2.3 Field Technologies
The technology groups listed in Exhibit 13-1 include both "traditional" technologies and newer
technologies. In the traditional phased engineering approach samples are collected, shipped
offsite for analysis, and the data are returned long after the sample collection staff have gone.
The newer technologies allow sampling and analysis of groundwater and soil to be done on site
to a greater extent, and more rapidly, than ever before. These newer approaches have been made
possible by technological advances such as computerization, microfabrication, and
biotechnology. Site investigators now have the capability to conduct analyses in the field that
previously could only be done in a laboratory. By rapidly characterizing contaminated soil and
groundwater on site, site staff are able to make immediate decisions which can guide
characterization efforts, accelerate site assessment schedules, monitor progress of remediation
efforts, and conduct confirmation sampling at closeout at reduced cost. Field analytical
technologies also provide greater flexibility in responding to changes in conditions that are
discovered during construction of the remedy.
Examples of the common field technologies are listed in Exhibit 13-2. Because of the advantages
of field analytical technologies, especially when combined with adaptive site management
strategies (described below), their use has been growing over the past decade. EPA has been
promoting their use as a means of achieving faster, better, and more efficient cleanups, and
expects them to replace the traditional phased engineering approach in many future cleanup
projects.
13.2.4 Adaptive Site Management Approaches
Field analytical technologies provide site staff with the capability to use an adaptive sampling
strategy, which feeds the previous day's results into the decision-making process to help direct
the collection of the next round of samples. This
strategy is typically implemented through a
systematic planning process that relies on
dynamic work strategies that are carefully aligned
to provide data to support on-site decisions. A
dynamic work strategy incorporates all known
information about the site into a conceptual site
model (CSM) and decision-making framework,
such as a decision tree. This approach permits
rapid location and definition of hot spots, guides
the removal or treatment of contaminated media,
and quickly identifies when enough information has been collected to address the site decision. It
also helps avoid unnecessary treatment and the collection and analysis of uninformative samples,
and to determine when enough information has been collected to meet site management goals.
The use of field technologies, combined with a dynamic work strategy often allow some projects
to be completed in only one field mobilization.
By rapidly characterizing contaminated
soil and groundwater on site, site staff are
able to make immediate decisions which
can guide characterization efforts,
accelerate site assessment schedules,
monitor progress of remediation efforts,
and conduct confirmation sampling at
closeout at reduced cost.
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Systematic planning is a process based on the scientific method for developing a framework for
the effective use of dynamic work strategies and real-time field measurement and analytical
technologies. It is a process for developing defensible site decisions by managing the
uncertainties or unknowns that could cause decision errors. A typical systematic site plan would
include collaboration of decision-makers with stakeholders, a clear statement of project goals, a
multi-disciplinary technical team to develop realistic technical objectives that will achieve the
goals, and the development of one or more conceptual site models that depict what is already
known about the site and identifies what additional information and analysis will be needed to
achieve the project's goals. The CSM can be used to direct field work, as a tool for planning and
organizing work and interpreting data, and as a communication device.
The integration of systematic planning, dynamic work strategies, and real-time measurement
technologies is often referred to as the Triad approach to planning and implementing data
collection and technical decision-making at hazardous waste sites. More information on the
theory and application of the Triad is available on an EPA web site (http://www.cluin.org/triad).
Exhibit 13-2. Examples of Common Field Analytical Technologies
Technology Description
Sample Analysis Tools
Test Kits
Ion Specific
Electrodes
Fiber Optic
Chemical Sensors
Gas
Chromatography
Infrared
Spectroscopy
Measures select organic chemicals and classes of chemicals using
immunoassay colorimetric techniques.
Measures inorganic cations and anions and some organic chemicals in water
using colorimetric techniques.
Measures the presence or absence of DNAPL chemicals using dyes.
Inorganic colorimetric techniques that use spectrophotometers are generally
quantitative techniques. Immunoassay are generally semi-quantitative.
Measures selected cations and anions in water. Can be deployed in situ or ex
situ.
In-situ measurements of the presence of chemicals or classes of chemicals
using chemical specific cladding placed in water or exposed to vapors.
Generally considered semi-quantitative.
Measures the presence of volatile and semivolatile organics and some
inorganics in soil gas (volatiles), soil, and water. Depending upon level of
sample preparation and QA/QC imposed can be quantitative or semi-
quantitative.
Is used in soil and water analysis for total extractable hydrocarbon analysis in
the field.
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Exhibit 13-2. Examples of Common Field Analytical Technologies (Continued)
Technology
Description
Open Path Air
measurements
In open-path Fourier transform infrared spectroscopy can provide a
quantitative average of various chemical concentrations in air over a
predetermined distance.
In open-path UV differential absorption can provide a quantitative average
concentration of a limited number of chemicals in air over a predetermined
distance.
In open-path differential absorption lidar can provide a quantitative
concentration of a limited number of chemicals (one at a time) in air at a
predetermined distance which allows the construction of isopleth contour
maps.
In open-path Raman spectroscopy can, at close distance, detect a variety of
chemicals in air (average concentration) or on a soil or building surface.
Laser-Induced
Fluorescence
Generally employed as a tool for locating petroleum hydrocarbons (polycyclic
aromatics) in situ, using direct push technologies to drive it into the
subsurface.
Mass Spectrometry
Can be used in conjunction with a GC to provide quantitative speciation of
organic chemicals in gases, soil, and water. As a stand alone instrument
employing ion trap mass spectrometry, it is used to measure organic
compounds brought to the surface by a membrane interface probe mounted
on a CRT rig.
X-Ray Fluorescence
Depending on the rigor of the sample preparation technique used provides
screening to semi-quantitative determinations of metals in soil and water. In
the screening application the metal concentrations can be measured in situ at
the ground surface with little sample preparation.
Ground Penetrating
Radar
Has had very uneven success in locating LNAPL plumes and is not chemical
specific.
Electromagnetics/
Resistivity for
Environmental
Applications
In specific settings can be used to delineate the extent of an electrically
conductive plume.
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Exhibit 13-2. Examples of Common Field Analytical Technologies (Continued)
Technology Description
Sample Access and Collection Tools
Direct-Push
Analytical Systems
(using rig)
Direct-Push
Geotechnical
Sensors
Direct-Push
Groundwater
Samplers
Direct Push Soil-Gas
Samplers (without
rig)
Laser induced fluorescence probe uses fluorescence intensities to determine
the relative presence of petroleum hydrocarbons (polycyclic aromatics) in
soil.
Membrane interface probe uses a heated permeable membrane to volatilize
chemicals in soil and groundwater while applying a vacuum that brings them
to the surface for analysis.
Halogen specific probe uses a heated membrane to volatilize chemicals in
soil and groundwater while applying a vacuum that draws them across a
halogen specific detector located in the probe.
Conductivity probe used to determine changes in lithology or conductivity
changes that may be related to a change in the chemical makeup of soil and
water.
Single point systems that are capable of providing access to groundwater at a
predetermined depth. The groundwater is recovered by bailer or pump and
brought to the surface for subsequent analysis. The system has to be
withdrawn and cleaned before it can be driven to another depth.
Multi-point systems that are capable of providing a vertical profile of
groundwater at a single station. The groundwater is sampled using a pump
and the system is driven further into the subsurface.
A sample probe in driven or vibrated into the ground using a hammer or hand
held driver. A vacuum is applied to the probe and soil gas is drawn to the
surface. The gas can be measured directly at the probe using a syringe and
portable GC or can be collected in a container for subsequent analysis by GC
or GC/MS instruments located on- or off- site.
Geophysical Tools
Electromagnetic
Resistivity/
Conductivity
Magnetics
An electromagnetic field is introduced into the ground which causes a current
to flow that in turn produce a secondary electromagnetic field which is
measured by a receiving unit. Most of the instruments in this class essentially
measure a change in subsurface conductivity and are used to aid in
conceptualizing the subsurface stratigraphy, identifying potential leachate
groundwater plumes, and in some modes locating buried drums and piping.
Methods include terrain conductivity, horizontal loop, very low frequency em,
and time domain.
Electrical currents are injected into the ground and the patterns of subsurface
flow indicate the resistivity or conductivity of the material the current is flowing
through. This technique is generally used to aid in conceptualizing the
subsurface stratigraphy.
This method measures the change in the subsurface magnetic field as the
instrument is moved across a site. Its primary use is in locating magnetic
objects such as buried drums.
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Exhibit 13-2. Examples of Common Field Analytical Technologies (Continued)
Technology
Description
Ground Penetrating
Radar
In this method electromagnetic energy is pulsed into the ground where some
of the energy is reflected by a change in strata while the rest passes through
the layer. The instrument relates the time of reflection to the depth of the
reflector and a cross section of subsurface reflectors is plotted. GPR can be
used to locate the groundwater table, find buried objects, and contribute to
the conceptualization of the subsurface stratigraphy.
Seismic
An acoustical wave is generated in one area. The wave propagates through
the subsurface with some of it being reflected or refracted when there are
changes in the subsurface and the rest continue on. Geophones are used to
measure the time of arrival of the reflected or refracted sound and this is used
to plot changes in the stratigraphy. These techniques are generally used to
aid in conceptualizing the subsurface stratigraphy.
13.3 Factors Affecting Demand
To understand the direction of the market for site characterization technologies, it is important to
examine the factors that are driving the demand for these technologies.
• Because site characterization is a critical component of all remediation efforts it is expected
to account for a significant amount of work, although it is only a minor portion of the over
$200 billion cleanup market. The overall demand for remediation services is expected to be
stable over the next decade.
• The strong market for redevelopment of Superfund, brownfields, and other sites will likely
foster demand for additional site assessments.
• The growing practice in the real estate industry (property purchasers, developers, and
lenders) of conducting site assessments as part of standard due diligence activities at
commercial properties may increase the demand for site assessment, primarily Phase One
and Two type assessments.
• A number of case studies have demonstrated that the use of field analytical technologies can
substantially reduce the cost and time to complete site investigations and improve the
confidence of the results (Exhibit 13-3). Because these technologies have lower costs per
sample, they permit higher sampling densities than is affordable using traditional laboratory
analysis. Higher densities generally lead to a more complete and appropriate CSMs that
facilitate effective remedy design and implementation.
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When combined with systematic planning and dynamic work strategies, real-time field
measurement and analytical technologies can significantly reduce the overall cleanup costs
at many sites and provide better site characterizations. For example, during remedial action,
field technologies can provide accurate data that allow the site crew to rapidly adapt to new
information, thereby realizing significant savings in dollars and time. Exhibit 13-3 provides
examples of successes of newer approaches at specific sites.
Exhibit 13-3
Examples of Projects with Savings and Efficiency Improvements
Associated With Advanced Site Characterization Technologies
The site characterization and cleanup approach used at the Wenatchee Tree Fruit Test Plot, resulted in savings of 50%
over traditional site characterization and remediation methods which rely on fixed-based laboratory analysis with multiple
rounds of mobilization and demobilization. The approach used a combination of field analytical technologies, a dynamic
work plan, and systematic site management (U.S. Environmental Protection Agency, Office of Solid Waste and
Emergency Response, Innovation in Site Characterization Case Study; Site Cleanup of Wenatchee Tree Fruit Test Plot
Site Using a Dynamic Work Plan, EPA 5420R-00-Q09, August 2000. http://clu-in.org/charl_edu.cfm#site_char).
At the Hanscom Air Force Base in Middlesex County, Massachusetts, the original site investigation failed to find some
contamination sources. As a result, a pump-and-treat system was operated for five years without achieving a sufficient
reduction in pollutant concentrations. To better characterize the site, site investigators used field analytical instruments in
the context of a dynamic work plan that relied on an adaptive sampling and analysis strategy. The project demonstrated
that this approach could substantially reduce the cost and time and improve the confidence of the results of site
investigations. (U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Innovation in
Site Characterization Case Study; Hanscom Air Force Base Operable Unit I (Sites 1, 2, and 3), EPA-543-R-98-006,
September 1998. http://clu-in.org/download/char/hafbcs2.pdfj.
A demonstration of several surface geophysical and direct push technologies at New York State Electric & Gas
Company's Court Street Manufactured Gas Plant Site in Binghamton, New York, concluded, in part, that CPT/DP offered
an excellent alternative to traditional investigation methods both in terms of cost per borehole and the information
provided (EPA 2002).
At Florida drycleaning sites, site characterization costs have been reduced by an estimated 30 to 50 percent when
compared to conventional assessments. The state conducts rapid site characterizations using on-site mobile laboratories
and direct push technologies to characterize soil and groundwater contamination, assess cleanup options, and install
permanent monitoring wells, all in an average of 10 days per site (Applegate 1998).
Argonne National Laboratory's Adaptive Sampling and Analysis Programs (ASAP) makes hazardous waste site
characterization and remediation more effective and efficient by relying on real-time data collection and field-based
decision-making within the framework of dynamic work plans. Argonne has documented cost savings of more than 50
percent as compared to more traditional sampling programs (U.S. DOE 2002).
ASAP data collection efforts have been used at Sandia National Laboratories and Kirtland Air Force Base in New
Mexico; Brookhaven National Laboratory in New York; Argonne National Laboratory and Joliet Army Ammunition
Plant in Illinois; and several Formerly Utilized Sites Remedial Action Program (FUSRAP) sites. In addition to providing
better characterizations than traditional approaches, these programs cost 30% to 70% less (U.S. DOE 2002).
DOE reports that recent work at the Fernald site as part of its soil excavation program has shown that the use of real-time
data collection technologies and decision support techniques will save the site more than $20 million over the life of the
project In addition to analysis cost savings, these approaches have resulted in reduced excavation schedules and soil
disposal costs, and superior overall soil characterization compared with conventional sampling and analysis.
DOE reports that a precision excavation project at the FUSRAP Ashland 2 site that used adaptive sampling and analysis
techniques resulted in an estimated $10 million savings. Data collection efforts were particularly effective when
integrated within remedial designs.
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• The ability to reduce uncertainty in decisions can reduce the perceived financial risk of site
owners, developers, and communities, thereby contributing to revitalization of many
properties. The newer characterization approaches can reduce uncertainty by enabling site
investigators to increase the sampling density at reasonable cost.
• Although real-time field measurement and analytical technologies, dynamic work strategies,
and systematic planning techniques have been known for some time, their acceptance has
been slow, primarily because of a conservative engineering and regulatory atmosphere that
appears to favor the established methods for conducting site characterizations.
• To help overcome this inertia, EPA, DOE, DOD, and other organizations have been
promoting the use of the new technologies and strategies for characterizing, cleaning up, and
monitoring hazardous waste sites.
• The use of field analytical technologies is expected to increase relative to traditional
approaches, for several reasons:
• »EPA, DOE, DOD, and other organizations have been sponsoring research on and
promoting the use of the newer approaches.
• 'Newer approaches have been shown to mitigate deficiencies in groundwater
characterization at many sites that relied on conventional approaches, which have lead to
inadequate remedial designs.
• »The demand for revitalization of brownfields and UST sites implies a requirement to
conduct many site assessments, often at small- and medium-size sites. These activities
will lead to further site investigation and cleanup for some percentage of these sites.
• • The demand for due diligence by property purchasers, developers, and lenders implies a
significant demand for Phase I and, possibly, Phase II assessments.
• • The demand to redevelop sites provides a powerful economic incentive for faster site
assessments and cleanups. Developers, property owners, and investors are under serious
time constraints to get plans approved and secure financing and insurance. The
integration of field analytics, dynamic work strategies, and systematic planning will
allow investors to more expeditiously proceed with their projects.
Based on these factors, it is expected that the newer technologies will replace older technologies
at many future and some existing sites. Although some newer technologies may not be
appropriate for all sites, they are likely to reduce overall remediation costs at many sites, thereby
allowing more sites to be cleaned up. Most of the major remediation programs are constrained by
budgets, and not by the amount of cleanup work. Thus, if average site cleanup costs are reduced,
more cleanups would be possible.
13.4 Number of Sites That Will Need Characterization
All potential hazardous waste sites will require some sort of site characterization. In addition,
there is a healthy market for site characterization resulting from due diligence investigations
conducted in support of real estate and other business transactions. However, no single source
provides definitive information on the number and characteristics of sites that may require site
characterization. The type and amount of characterization work needed varies widely from one
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site to another, depending on the nature and extent of the contaminant release, geology and
hydrogeology of the site and surrounding area, source of contamination, size of the site, and
other factors.
Exhibit 13-4 presents estimates of the potential number of sites that may require site
characterization under the Superfund, RCRA Corrective Action, and other remediation programs
described earlier in this report. As described in Chapter 1 and subsequent chapters, the definition
of the term "site" differs somewhat from one market segment to another. In this report, the term
is used to indicate an individual area of contamination, which can be small or large. This term is
not to be confused with the terms "facility" and "installation," which identify an entire tract,
including all contiguous land within the borders of a property. A "facility" may contain one or
more contaminated areas or "sites." For this exhibit, the Superfund sites are counted as operable
units (OUs) rather than sites.
As described in Section 13.1, Phase One site assessments do not generally include sampling,
chemical analysis, and similar activities. Nevertheless, sites undergoing these assessments are of
interest to this study because they comprise the universe of sites from which sites needing further
study will be drawn. This is the largest market, amounting to 11.8 million Phase One
assessments over 30 years, and costing $23 billion. Most of these assessments are in support of
due diligence responsibilities in real estate and business transactions.
The other phases are potential markets for both conventional and new sampling and analysis
technologies. Over the next 30 years, it is estimated that 1.2-2.3 million Phase Two assessments
and 285,000 Phase Three assessments will be conducted. Sampling and analysis will also be
needed during 392,000 remedial actions. The sampling and analysis required during remedial
actions can be quite variable. If unforseen conditions arise at a site, extensive supplemental
sampling and analysis may be called for. The sampling and analysis during O&M is also highly
variable, with some sites needing none or minimal amounts, while others such as the Superfund
and RCRA sites, are likely to require more comprehensive sampling and analysis. Thus the
estimate of 507,000 sites likely to need sampling and analysis during O&M represents the
middle value of a wide range of activities among the sites.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 13-4. Estimated Number of Sites
to Require Sampling and Analysis
Phase
One
Phase
Two
Phase
Three
Remedial Action
O&M
Superfund(OUs)c
RCRA-CAd
USTe
DODf
DOE9
Civ. Agencies
States h
Private '
Total J
658
0
NA
NA
NA
NA
h
11. 5 mil.
11. 8 mil.
658
1,269
NA
1,425
NA
NA
h
1.2 -2.3 mil.
1.2 -2.3 mil.
832
< 3,827
125,000
4,774
NA
NA
150,000
NA
285,433
1,700
3,800
223,000
8,800
5,000
NA
150,000
NA
392,300
2,500
3,800
320,000
18,400
8,000
NA
155,000
NA
507,700
NA Estimate not available;
a Assumes all sites will require at least some sampling and analysis during remedial action; however the amount
needed will vary widely from site-to-site.
b Total number of sites cleaned up. Some, but not all, of these sites will require sampling and analysis on a
continuing or periodic basis. Some will require only minimal amounts and some will require more.
c Superfund: Operable units (OUs) were counted rather than sites. Phases 1-2 will only be needed at future
sites to be listed (280 sites with an estimated 658 OUs). Phase 3 will be needed at the same 658 OUs plus 174
OUs (from Exhibit 3-2) that have not begun remedial assessment (658 + 174 = 832). Remedial action (RA) from
2004-2013 will be needed at 1,731 (658+1073) OUs. (The 1,073 OUs are at the 456 already listed sites that
have not begun RA (Exhibit 3-2)). The 1,731 estimate does not include sites already in RA. It is assumed that
O&M will be needed by 80% of all completed OUs, based on the facts developed in Chapters 2 and 3 that 83%
of NPL sites have contaminated groundwater and 95% of groundwater remediations use monitored natural
attenuation (MNA), P&T, or both (0.83 X 0.95 = 0.8) Thus, combining the above figures, it is estimated that 2,523
OUs will need O&M (1,731 OUs plus 1,399 OUs that have completed or are in RA = 3,130X0.8 = 2,504).
d RCRA: The 1,269 RCRA Corrective Action sites have not yet received priority ranking. The 3,827 sites represent
all those likely to require site investigation and/or cleanup. Some of these investigations have already begun,
although only a small portion of the cleanups have actually begun.
e LIST: It is assumed that tank sites to be reported in the future will not do Phase 1 and 2 assessments, but will go
straight to phase 3. Phase 3 is assumed to include all future cleanups, which equals 35,000 already confirmed
releases where cleanups have not been initiated (Exhibit 5-5) plus 90,000 (average of range in Exhibit 5-5)
projected future releases. The Remedial action estimates are based on the assumption that 60% of all sites in
RA will require some sort of confirmation sampling. This assumption is derived from the estimates in Chapter 5
that 79% of UST groundwater sites use MNA or P&T. Assuming that 80% of the sites have groundwater
contamination, about 60% will need O&M. Adding sites yet to complete remediation (125,000 that will need
Phase 3 + 98,000 initiated but not complete = 223,000) to sites with cleanups completed (311,000 from Chapter
5) and multiplying by 0.6 gives a total of 320,000 (534,000 X 0.6) sites that will ultimately require monitoring.
f DOD: Future investigation is planned at 1,425 sites, underway at 4,774 sites, and 2,775 sites are already in
remediation. The O&M estimate includes all previously remediated sites times 0.8 (from the percentage of NPL
sites that will require O&M).
9 DOE: has completed construction at 5,000 release sites; and 8,000 sites (10,000 X 0.8) may need O&M.
h States: From Chapter 9, (estimated 5,000 sites annually X 30 years plus 44,000 with cleanups completed
through 2003 = 194,000 X 0.8 = 155,000). Phase 1 and 2 figures are included with estimate for private sites.
' Private Sites: Industry sources have estimated that the number of Phase I (ASTM definition) site assessments
averaged 235,000 per year between 1999 and 2001 (EAS 2002). Summing this amount over 30 years, and
assuming a 3% annual growth rate (which is approximately the growth rate of the GDP over the past 50 years),
this would total 11.5 million Phase 1s. It is assumed that 10-20% of Phase 1s will need a Phase 2, based on
industry history. These figures incorporates brownfields and voluntary cleanup programs.
J Excludes civilian federal agency and some DOE sites, because data could not be disaggregated.
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13.5 Estimated Site Characterization Costs
Any estimate of the value of the site characterization market is hampered by the extremely wide
range of potential situations involving the use of sampling and analysis tools and the paucity of
program-wide data on costs. Many cleanup programs do not record expenditures by type of
action. For example, EPA has not kept track of its own Fund-lead expenditures on specific
actions, such as RD or RA. The Agency has no simple way of determining how much is spent on
specific types of actions, such as site investigation. Cost estimates in RODs, which are done
prior to remedy design, are estimates which serve as only general indicators of potential cost.
A 2001 Resources for the Future study (Probst, 2001) used expenditure data from EPA's
financial management system to estimate the average dollars spent for Fund-lead RI/FSs, RDs,
and RAs at the operable unit level for sites between 1992 and 1999. These costs are primarily
extramural costs and do not cover other site-specific costs such as community and state
involvement, nor other program costs, such as rent. Nevertheless, they provide an approximation
of the relationship of site investigation costs to remedial design and remedial action costs. These
cost comparisons are shown in Exhibit 13-5. The average RI/FS expenditures over all Fund-lead
Superfund sites averaged 10 percent of combined costs for RI/FS, RD, and RA, which together
account for most site expenditures. Since this estimate does not include the sampling and
analysis work that occurs during remedial action, long-term remedial actions, and O&M, it
represents a conservative estimate of the extent of site characterization work needed.
Exhibit 13-5. Estimated Major Components of Superfund Costs
Expenditure Cost per Fund-Lead Percent of Total Expenditures
Category Operable Unit ($000)
RI/FS 1,363 9.9
RD 1,331 9.7
RA 11,059 80.4
Total 13,753 100.0
Notes:
• RI/FS costs do not include site characterization work conducted during remediations, O&M and long-term
remedial actions.
Average for non-federal Superfund Fund-lead sites from 1992 to 1999. These data do not include costs for
long-term remedial actions and O&M.
Source: Probst, Katherine N. & David M. Konisky, et. al., 2001. Superfund's Future, What Will It Cost, Resources
For the Future, Washington, D.C. 2001.
The data also indicate that site characterization cost as a percent of total cleanup cost is larger for
smaller sites, than for larger sites (Exhibit 3-6). Site investigation costs are 7 percent of total site
costs for "mega" Superfund sites (those with over $50 million in cost) and 15.5 percent for non-
mega Superfund sites. Data are also available for drycleaner sites, which are almost all small and
provide a useful comparison. On average, 28.2 percent of drycleaner site cleanup costs are for
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site investigations. The drycleaner data, from a sample of 50 drycleaner sites from the State
Coalition for Remediation of Dry cleaners database, also indicate the extent of site investigation
costs (See Chapter 12, Drycleaner Sites). The site investigation costs cited in this section do not
include site characterization work that is often undertaken during remedial action and O&M.
Almost 17 percent of drycleaner site cleanup costs were for O&M.
Exhibit 13-6. Remediation Cost and Site Size
Site Type Average Total Cleanup Cost Site Investigation Cost Percent
Mega Superfund (per OU)
Non-Mega Superfund (per OU)
Drycleaner
$36,652,000
$6,750.000
$402,000
$2,582
$1 ,047
$113,000
Notes:
• Includes Total market value over 30 years.
Does not include site characterization work conducted during remediations and O&M.
Source: Probst, Katherine N. & David M. Konisky, et. al., 2001. Superfund's Future, What Will It Cost,
For the Future, Washington, D.C. 2001; and Exhibit 12-2.
7.0%
15.5%
28.2%
Resources
Applying these ratios to the estimated 30-year market values of each of the seven major
remediation programs, the site characterization market is likely to be $21 billion over the next 30
years (Exhibit 13-7). Because this estimate does not include site characterization work that is
undertaken during remedial action and O&M, it may underestimate the total amount of sampling
and analysis work needed.
Exhibit 13-7. Estimated Site Characterization Costs
Market Segment
Medium and Large Sites
(Superfund, RCRA
Corrective Action, DOD, &
DOE)
Small Sites (UST, Civilian
Agencies, and States)
Total
Total Remediation Market
Number Value
of Sites ($ Billions)
16,000 145
278,000 64
294,000 209
Percent Value of Site
for Site Characterization
Investigation Market ($Billions) a
10
16
3 Because this estimate does not include site characterization work that is undertaken during
O&M, it may underestimate the total amount of sampling and analysis work needed.
Source: Exhibits 1-1, 1-2, 12-2, 13-6.
14.5
6.5
21.0
remedial action and
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13.6 Market Entry Conditions
The characterization market can generally be divided into two vendor groups: architecture and
engineering (A&E) firms who generally provide technical investigation expertise (e.g.,
geologists, chemists, project managers) and equipment and analytical vendors who provide the
drill rigs, geophysical equipment, and analytical equipment use to carry out site characterization.
Although the two types of firms usually operate differently, there is some overlap. Some A&E
firms have their own equipment and some vendors that provide interpretation services for some
of the innovative direct push probes. The exception to this generalization are very small
specialized firms that might do site characterization only, or risk assessments only, and firms that
primarily work in the UST area.
In recent years, there has been a great deal of consolidation in the A&E area. Firms that were
once considered large players in the environmental characterization field have been merged into
even larger firms. For example, URS-Griner acquired Woodward-Clyde, Dames and Moore, and
EG&E. Consolidation is also occurring in the analytical laboratories sector. It has, however, not
been as extensive in the heavy equipment operator business. Drill rigs and direct push rigs are
generally supplied by large firms with many small offices around the country or small drilling
firms that do environmental work as a supplement to their construction and water well business.
Because of high mobilization costs, companies located closer to the site have a cost advantage.
Large corporations and government agencies (e.g., DOE and DOD) with large complex
contaminated sites tend to rely on the large A&E firms. This is also true for some government
agencies and companies that have many smaller sites around the country. Nevertheless, there are
opportunities for smaller vendors to subcontract. Since the larger A&E firms generally view field
equipment as a subcontract issue, companies that can provide services such as direct push with
various ancillary detection equipment, as well as traditional drilling rigs, are more likely to
prevail in contract award.
In the larger facility market, there is increasing regulatory pressure to perform better site
characterizations than have been done in the past as well as pressure from the facility owners to
keep costs down. This presents an excellent opportunity for new characterization technologies
and site management approaches that are geared towards better and potentially less expensive
site investigations and site management approaches (Section 3.2). The USEPA make this point in
their Dynamic Field Activities and Triad initiatives (see web pages at
http://www.epa.gov/superfund/programs/dfa/index.htm and http://www.epa.gov/tio/triad).
The cleanup market involving smaller hazardous waste handlers and generators, USTs, and
commercial property transfers is somewhat more fragmented in terms of vendor participation.
Smaller waste generators, such as drycleaners and independent UST owners (as opposed to those
owned by the major oil companies), and real estate owners and developers are more likely to
employ specialty firms (e.g., tank investigations only) or smaller A&E firms that can perform
Phase 1 and Phase 2 assessments but are unlikely to have a robust RI/FS practice. In addition,
many of the larger A&E firms are not interested in this type of work because of their higher
overhead costs and the relatively small profit margin that smaller jobs entail.
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The cleanup budgets for the smaller facilities are much smaller and their environmental problems
are generally better defined, such as a leaking tank or a PCE release at a drycleaner. Innovative
specialty tools such as LIF, MTP, or the halogen specific probe can, in most cases, perform a
complete characterization for relatively little cost. These capabilities should be a good selling
point for specialty contractors or the smaller A&E firms that undertake this type of work.
Significant portions of this market can be accessed through local and state governments and
prime contractors.
Finally, commercial property transactions, especially for those properties with a history of
handling hazardous materials/wastes, generally have very low budgets for Phase 2
characterizations. Nevertheless, the characterization results often carry with them a high degree
of financial liability. This market would be receptive to technologies that provide analytical
results that are more representative of true site conditions at a reasonable cost.
Firms practicing dynamic field activities and the Triad approach need to bring together
professionals with many disciplines, such as project management, statistical and geostatistical
sampling design, and analytical chemistry. To achieve the appropriate disciplinary mix, some
firms may partner with analytical service providers, statisticians, and other disciplines.
13.7 References
Applegate, J.L. and D.M. Fitton, 1998. "Rapid Site Assessment Applied to the Florida
Department of Environmental Protection's Dry cleaning Solvent Cleanup Program," in
Proceedings Volume for the First International Symposium on Integrated Technical Approaches
to Site Characterization., Argonne National Laboratory, pp. 77-92, http://clu-
in.org/charl_edu.cfm#mode_expe.
Business Information Services, 2001. "ISO 14015 Finalized, New Site Assessment Standard for
the International Community," Environmental Site Assessment Report, Southport, CT, December
2001.
Business Information Services, 2002. "Market Radar," in Environmental Site Assessment Report.,
Southport, CT, January 2002.
Crumbling, D.M., 200 la. Applying the Concept of Effective Data to Environmental Analyses for
Contaminated Sites, EPA-542-R-01-013, U.S. Environmental Protection Agency, Office of Solid
Waste and Emergency Response, Technology Innovation Office, October 2001.
Crumbling, D.M., 2001b. Using the Triad Approach to Improve the Cost-Effectiveness of
Hazardous Waste Site Cleanups, EPA-542-R-01-016, U.S. Environmental Protection Agency,
Office of Solid Waste and Emergency Response, Technology Innovation Office, October 2001.
FRTR, 1998. Field Sampling and Analysis Technologies Matrix. A publication of the Federal
Remediation Technologies Roundtable. http://www.frtr.gov/site/analysismatrix.html
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Probst, Katherine N. & David M. Konisky, et. al., 2001. Super fund's Future, What Will It Cost,
Resources For the Future, Washington, D.C. 2001.
U.S. DOE, 2002. Adaptive Sampling and Analysis Programs (ASAP) web page, U. S.
Department of Energy. http://www.Ead.anl.gov/project/dsp_topicdetail.cfm?topicid=23
U.S. EPA (Environmental Protection Agency), 1998. Innovation in Site Characterization Case
Study: Hanscom Air Force Base Operable Unit 1 (Sites 1, 2, and 3), EPA-543-R-98-006, U.S.
Environmental Protection Agency, September 1998. http://clu-in.org/download/char/hafbcs2.pdf.
U.S. EPA, 2000. Innovation in Site Characterization Case Study: Site Cleanup ofWenatchee
Tree Fruit Test Plot Site Using a Dynamic Work Plan, EPA 5420R-00-009. Washington, D.C.,
August 2000. Http://clu-in.org/charl_edu.cfm#site_char
U.S. EPA and USAGE, 200la. Dynamic Data Collection Strategy Using Systematic Planning
and Innovative Field-Based Measurement Technologies, Seminar sponsored by U.S. Army
Corps of Engineers and U.S. Environmental Protection Agency's Technology Innovation Office,
March 15, 2001.
U.S. EPA, 2001b. Site Characterization for Subsurface Remediation, EPA/625/4-91/026, Office
of Research and Development, November 2001.
U. S. EPA, 2002. Report on Innovative Approaches to Manufactured Gas Plant Site
Characterization, EPA-542-R-01-003, Office of Solid Waste and Emergency Response,
Washington, D.C. October, 2002
U.S. EPA, 2003. Using Dynamic Field Activities for On-Site Decision Making: A Guide for
Project Managers, EPA-540-R-03-002, Office of Solid Waste and Emergency Response,
Washington, D.C. May 2003. http://fate.clu-in.org
U.S. EPA, web site. Field Analytic Technologies Encyclopedia (FATE), http://fate.clu-in.org
U.S. EPA, web site. Field Sampling and Analysis Technologies Matrix, Version 1.0.
http://www.frtr.gov/scrntools.htm
U.S. EPA, web site. Dynamic Field Activities Internet Web Site,
http://www.epa.gov/superfund/programs/dfa
U.S. GAO, 2000. Analysis of Costs at Five Superfund Sites, GAO/RCED-00-22, U.S. General
Accounting Office, January, 2000.
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Chapter 14
DNAPLs at Hazardous Waste Sites
Dense non-aqueous phase liquids (DNAPLs) are chemicals that are denser than water and are
only slightly soluble. Because of their physical and chemical properties, characterization and
remediation of DNAPL-contaminated sites can pose significant challenges to site managers.
Contamination of soil and groundwater by DNAPLs is associated with many hazardous waste
sites and many industries, and has posed serious environmental problems for many years. This
chapter describes the nature of the DNAPL problem and estimates of the extent of the market for
its remediation.
Because of their density and low solubility, DNAPLs are often present in the subsurface in an
undissolved phase. Most DNAPLs undergo only limited degradation in the subsurface, and
persist for long periods of time while slowly releasing soluble organic constituents to
groundwater. The most frequently applied remediation approach has been to use groundwater
pump-and-treat systems primarily to contain the dissolved phase plume and not treat the source
zone.1 However, it has been shown that this approach has not been successful in achieving
cleanup goals at many sites (NRC 1994). Efforts to remove free-phase and residual DNAPLs
face the challenge of our limited capability to delineate the source zones. If some of the free-
phase or residual DNAPLs remain, the deposit may continue to dissolve into the groundwater.
Whether to treat or remove free-phase or residual DNAPLs involves tradeoffs between long-term
and short-term site management options and costs. There is a debate in the scientific and
engineering community regarding how much mass must be removed to have an effect on the
groundwater concentration profile and on the duration of post-treatment containment activities.
DNAPL compounds are encountered in most industries and under all the remediation programs,
including Superfund, RCRA Corrective Action, UST, DOD, DOE, and other cleanup programs.
Thus, the market estimates in this chapter should not be added to those in the previous chapters
of this report. Adding these estimates would be double-counting sites and, therefore,
overestimating the scope of the market.
14.1 Market Description
While no compilation of the number of sites with DNAPLs exists, the extent of the problem can
be described in terms of the occurrence of DNAPL-related chemical compounds at waste sites,
the types of industrial activities that have resulted in free-phase DNAPLs, and the frequency of
occurrence of those chemicals in the seven major remediation market segments.
A source zone is that portion of the subsurface where immiscible liquids (free-phase or residual DNAPLs) are
present either above or below the water table. The contaminated material in the source zone acts as a reservoir for
the continued migration of contamination to surrounding environmental media or as a source for direct exposure
(ITRC 2002).
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14.1.1 DNAPLs in the Environment
Because DNAPLs are marginally soluble in, and heavier than, water, they can migrate to depths
well below the water table. As they migrate, they can leave behind ganglia or microglobules in
pore spaces of the soil matrix. When the sinking DNAPLs encounter a low-permeability layer,
such as clay or bedrock, they can accumulate, or "pool" and spread laterally, until they encounter
a fracture or other path toward deeper zones. Globules can also enter pores and be held there in
capillary suspension. All these forms of undissolved chemicals (ganglia, globules, and pools)
effectively serve as long-term sources of groundwater pollution. They can slowly dissolve in the
surrounding groundwater and form contamination plumes. These plumes can have varying levels
of concentration, such as narrow bands of high-concentration and bands of low-concentration.
Because DNAPLs have very low solubility points, they can continue to release small, but
environmentally important, quantities of contaminants into the groundwater for centuries. As a
result of this complex pattern of subsurface transport, the distribution of DNAPLs can be
difficult to delineate. In addition, very few sites report direct observation of DNAPLs in the
subsurface. Many DNAPLs are colorless liquids which, when present as residuals in soil pores,
are difficult to visually observe.2
14.1.2 Chemical Compounds that are DNAPLs
DNAPLs include halogenated organic solvents such as trichloroethylene (TCE), 1,1,1-
trichloroethane (TCA), perchloroethylene (PCE), carbon tetrachloride, substituted aromatics,
phthalates, polychlorinated biphenyl (PCB) mixtures, coal and process tars, creosote, and some
pesticides. Exhibit 14-1 shows some of the common DNAPLs. A more comprehensive list of
chemical compounds that are DNAPLs are found in various sources (Cohen and Mercer 1993,
EPA 1992, 1993). DNAPLs are often complex mixtures of the listed chemicals, and many sites
are contaminated with various combinations of DNAPLs, LNAPLs, metals and/or radionuclides.
These compounds are also among the most common contaminants at Superfund, DOD, RCRA,
and DOE sites. Specific data for the other market segments are not available. State and
brownfield sites, which include many former industrial properties, are likely to have a similar
profile of chemical usage.
The presence of these chemicals does not guarantee that DNAPLs are present in free or residual
phase. The occurrence of DNAPLs is a function of whether compounds were discharged to the
environment in dissolved or free-phase liquid form, the material, waste management practices,
volume and pattern of releases, and hydrogeological characteristics. Many early site
investigations may have missed the presence of DNAPLs or presumed that the source of any
dissolved-phase DNAPLs was from points of discharge on the surface. The presence and
location of DNAPLs are usually not obvious, and EPA has produced reports and fact sheets to
help site investigators estimate the potential occurrence of DNAPLs (U.S. EPA 1992).
They can be identified through the use of reactive dyes that turn colors in the presence of DNAPLs or shaking a
soil sample in a jar of water and observing DNAPLs as a second phase at the bottom of the jar.
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Exhibit 14-1. Common DNAPL-Related Chemicals
Halogenated VOCs
Chlorobenzene
1,2,-Dichloropropane
1,1,-Dichloroethane
1,1,-Dichloroethylene
1,2,-Dichloroethane
Trans-1 ,2,-Dichloroethylene
Cis-1 ,2,-Dichloroethylene
1,1,1-Trichloroethane
Methylene Chloride
1,1,2-Trichloroethane
Trichloroethylene
Chloroform
Carbon Tetrachloride
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Ethylene Dibromide
Halogenated SVOCs
1 ,4-Dichlorobenzene
1 ,2-Dichlorobenzene
Aroclor1242, 1254, 1260
Chlordane
Diedrin
2,3,4,6-Tetrachlorophenol
Pentachlorophenol
Non-Halogenated SVOCs
2-Methyl Napthalene
o-Cresol
p-Cresol
2,4-Dimethylphenol
— Cresol
Phenol
Napthalene
Benzo(a)Anthracene
Fluorene
Acenapthene
Anthracene
Dibenzo(a,h)Anthracene
Fluoranthene
Pyrene
Chrysene
2,4-Dinitrophenol
Other polynuclear aromatic
hydrocarbons
Miscellaneous
Coal tar
Creosote
Note: Many of these chemicals are found mixed with other chemicals or carrier oils.
Source: U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Estimating
Potential Occurrence of DNAPLs at Superfund Sites, Publication 9355.4-07S, January 1992.
14.1.3 Industrial Activities
One of the most accurate indicators of
probable releases of DNAPLs at a site is the
site's history—the types of industries that
operated on the site, industrial processes,
and waste management practices. The text
box lists industries that have a high
probability of DNAPL releases, based on
the materials they use or discharge and
historical industrial and waste management
practices. Industrial or waste disposal
processes with a high probability of DNAPL
release include metal cleaning and
degreasing, tool-and die operations;
machinery, equipment, and instrument
repair and maintenance; paint removing and
stripping; storage of solvents in
underground storage tanks; storage of
drummed solvents in uncontained storage
areas; solvents loading and unloading;
disposal of mixed chemical waste in
landfills; and treatment of mixed chemical
waste in lagoons or ponds.
Industries With High Probability of Past
DNAPLs Release
•• Wood preservation
•• Manufactured gas plants
•• Electronics and electrical equipment
manufacturing
•• Transportation equipment manufacturing (e.g.
aircraft, automobiles, and engines)
•• Fabricated metal products manufacturing
•• Solvent manufacturing, distribution,
packaging, and recycling
•• Pesticide and herbicide manufacturing,
packaging, and distribution
•• Organic chemical manufacturing, distribution,
packaging, and recycling
•• Equipment maintenance
•• Drycleaning
•• Instrument manufacturing
•• Transformer oil production/reprocessing
•• Coking operations
•• Pipeline compressor stations
•• Departments of Defense and Energy
maintenance and training activities.
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14.1.4 Hydrogeological Characteristics
Because of its tendency to migrate to the lowest possible level and pool, DNAPL transport in the
subsurface is very sensitive to the geological media through which it passes. Site geology can
affect many aspects of DNAPL contamination, including the likelihood that the DNAPL will
reach the saturated zone, ultimate depth of the DNAPL travel, extent of lateral travel, likelihood
that pools will form and their shape, and the spatial distribution of the dissolved-phase plume.
These factors will also affect the nature and probable success of the site characterization and
remediation work that will be needed. Previous research indicates that the nature of DNAPL
deposits are most likely to be influenced by local and site-specific geological formations, rather
than overall hydrogeological regions (U.S. EPA 1993a).
Approaches to DNAPL characterization and remediation differ significantly depending on
whether DNAPL source zones are shallow or deep. Examples of situations encountered with
shallow source zones are:
••Sites with installed pump-and-treat systems that have inadequately contained plumes, whether
or not they have addressed the source zones. Additional characterization and decisions
regarding revisions to the remedies may be called for, either to address the plume, the source
zone, or both;
••A continuing market where pump and treat and permeable reactive barriers (PRBs) will be
used as part of remediation;
••Old and new sites with undefined source zones. The remediation approaches used at these
sites will depend on regulatory policy, available technology, and economics in affecting
tradeoffs between source reduction and containment.
In all these situations, there appears to be an expanding market for the new technologies that
provide on-site characterization.
It is likely that characterization of deep source areas and bedrock will continue to use
"traditional" technologies, such as drilling rigs, in the near future. Research and development in
this area is needed to develop more effective characterization and remediation approaches.
14.2 Factors Affecting Demand for Remediation Services
The proportion of DNAPL sites that will be subject to containment and how many will undergo
source zone treatment is uncertain. A number of factors may affect the decision to attempt to
strike a balance between remediating a source zone and long-term pump and treat at a DNAPL
site, and hence the potential demand for remediation services. These factors, which are not
mutually exclusive, include:
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•Regulatory requirements at some sites may call for achieving groundwater MCLs in the
source zone. In some cases, regulatory requirements may be so stringent that property owners
and PRPs seek alternatives, such as technical impracticability waivers, to source reduction or
removal.
•The CERCLA process of remedy selection includes a preference for remedies that provide
"permanence and treatment" to the extent practicable. This implies that, to the extent
practicable, contaminants are to be treated and/or destroyed.
•The ability to economically delineate the DNAPL source zones varies from site to site, and is
especially difficult in fractured rock.
•The ability to show that source reduction will significantly reduce the long-term costs of
containment also varies from one site to another.
•The effective combinations of technologies have the potential for performance and cost
advantages. However, sometimes the need to apply more than one cleanup technology may
increase the complexity, cost, and uncertainty of a remediation.
•Potential contamination at uncharacterized, or undiscovered sites, such as MGP sites, former
drycleaners sites, or other brownfields sites, may increase the number of sites that need
characterization and/or remediation.
•Development and acceptance of innovative remedial and characterization technologies.
Effective technologies are especially needed for deep sources. Characterization and
remediation of deep sources are more costly and usually produce less certain results than
those of shallower sources.
•A number of states have recognized the need to consider newer site characterization and
remediation technologies prior to granting waivers from ARARs for technical impracticability
(ITRC 2002).
•Reuse considerations at a site may drive the type of remediation approach selected and/or
generate a need for a faster cleanup at a site. For example, a developer may not be able to use
a property that has pump-and-treat equipment in important locations on the property, or
institutional controls that limit the property's intended use. In some situations, it may be
possible to place treatment system features in locations more compatible with the intended
reuse, or use a different treatment approach.
Some prospective property purchasers may need the property cleaned up faster than is
possible with a pump-and-treat system. An alternative, such as a protective cap may be
installed more quickly than a groundwater treatment system, thereby enabling the property to
be put into productive use more quickly. On the other hand, a cap may not be compatible with
some reasonably anticipated future site uses, and usually will be accompanied by institutional
controls.
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14.3 Number and Types of Sites
Based on the types of contaminants found at hazardous waste sites and other factors, it is likely
that a significant number of sites have a DNAPL problem. However, no single source provides
definitive information on the number and characteristics of sites that may require DNAPL
remediation. The type and amount of DNAPL remediation work needed vary widely from one
site to another, depending on the nature and extent of the contaminant release, geology and
hydrogeology of the area, source of contamination, size of the site, and other factors. Exhibit 14-
2 summarizes data on the incidence of VOCs and SVOCs, many of which are DNAPL
chemicals. About 78 percent of NPL sites contain VOCs (69 percent halogenated) and 71 percent
contain SVOCs ( 44 percent PAHs, 28 percent pesticides, 27 percent PCBs, and 26 percent
halogenated SVOCs). Many NPL sites have combinations of these compounds. About 64 percent
of DOD sites contain VOCs (49 percent halogenated, 32 percent non-halogenated). Fifty-seven
percent of DOD sites contain SVOCS, including PAHs (16 percent) organic pesticides or
herbicides (15 percent), halogenated SVOCs (8 percent), and PCBs (6 percent) (Exhibit 14-2).
Based on data from 214 RCRA Corrective Action sites collected in the early 1990s, 60 percent
contained halogenated VOCs, 18 percent PAHs, 11 percent non-halogenated SVOCs, 11 percent
halogenated SVOCs, and 9 percent unspecified VOCs and SVOCs. Halogenated compounds are
often DNAPLs. Based on a 1993 EPA evaluation of 79 treatment, storage, and disposal facilities,
9 of the 19 predominant constituents projected above action levels in groundwater are DNAPL
chemicals (U.S. EPA 1994).
The use of DNAPL compounds at a site does not guarantee that DNAPLs are present in free-
phase or residual form. The nature and extent of the DNAPL deposits also depend upon the
form, pattern, and volume of release, hydrological conditions and other factors.
Exhibit 14-2. Occurrence of VOCs and SVOCs at Contaminated Sites
Remediation Program VOCs SVOCs
NPL 78% 71%
RCRA Corrective Action 60% + 18% +
DOD 64% 57%
DOE 38%* 38%*
•• * DOE figure combines SVOCs and VOCs. This figure is based on data in early 1990s.
•• About 69% of NPL sites contain halogenated VOCs, 44% PAHs, 28% pesticides, 27% PCBs, and 26%
halogenated SVOCs.
•• About 49% of DOD sites contain halogenated VOCs, 32% non-halogenated SVOCs, 16% PAHs, 15% organic
pesticides or herbicides, 8% halogenated SVOCs, and 6% PCBs.
•• The RCRA VOCs figure is for halogenated VOCs, since the data were not aggregated into major contaminant
groups. About 32% of RCRA sites also contain other non-halogenated VOCs, and 11% contain BTEX. The
SVOCs figure for RCRA Corrective Action sites is for PAHs, since the data were not aggregated into major
contaminant groups. About 11% contained non-halogenated SVOCs, 11% halogenated SVOCs, 9% unspecified
VOCs and SVOCs, and 36% contain other unspecified contaminants.
Source: Chapters 3, 4, and 6.
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Although the occurrence of halogenated
compounds is a strong indication that the site
may have DNAPLs, it does not guarantee that
it will. The occurrence of DNAPLs is also
influenced by industrial practices, form and
volume of releases, and hydrogeological
29-45% of NPL sites, or an average of
37%, are likely to have free-phase or
residual DNAPLs present in the
subsurface. These estimates incorporate
several approximations and simplifying
,-.- ., f . A iririo assumptions as described in the text.
conditions, among other factors. A 1993 K
EPA study considered these factors to
estimate the likelihood of free-phase DNAPL
presence at NPL sites (U.S. EPA 1993a). This study concluded that approximately 57 percent of
NPL sites with organics contamination in groundwater either have, or could be expected to have
a medium to high potential of DNAPLs presence, which could provide a source of groundwater
contamination in the subsurface. The remainder of the sites could be expected to fall within the
category of "low to unlikely" to have DNAPLs present. (The percentages were: 100% potential
= 5%, high potential = 32%, medium potential = 20%, low potential = 27%, and zero potential =
16%). Based on interpolation of data in this report (U.S. EPA 1993a), it is estimated that 29-45
percent of all NPL sites, or an average of 37 percent are likely to have free-phase or residual
DNAPLs.
Many of the compounds found at these sites are also found at many non-Superfund sites, such as
RCRA sites. Based on information about previous site uses, it is likely that these chemicals are
also present at contaminated brownfields sites. Conclusions regarding UST sites are less certain.
There are an estimated 25,000 USTs containing hazardous substances and many are likely to
contain solvents. Although it is likely that a significant number of these contain solvents, there
are no recent data regarding the specific chemicals contained in USTs. Petroleum-containing
USTs are more likely to contribute to the presence of BTEX, which are LNAPLs.
DNAPL-related chemicals are also released to the environment by the drycleaning industry and
were released by the now defunct manufactured gas industry. The characteristics of drycleaner
sites are described in Chapter 12. Based on that discussion, over 15,000 active drycleaner sites
will probably need site investigation and remediation. About 90 percent of these facilities use
perchloroethylene (PCE) as their primary drycleaning solvent. In addition, there may be 9,000 to
90,000 "inactive" sites, which are former or closed drycleaning facilities. Older facilities used
more drycleaning solvent than newer ones and tended to have more releases. Most of these sites
tend to be remediated under a state mandated or voluntary control program. They are not counted
separately in the above estimates, but are probably a component of the state site figure.
The cleanup of former manufactured gas plants (MGPs) and other coal tar sites may be
addressed under any of the remediation programs, such as Superfund, RCRA, or a state
environmental program, depending on the nature and extent of the contamination and other site-
specific factors. The characteristics of MGPs and other coal tar sites are discussed in Chapter 10.
Based on the estimates presented in that chapter, there may be 30,000 to 45,000 former MGP
sites. These sites varied in size from less than one acre to approximately 200 acres. Because of
the nature of the gas manufacturing process and the practices at the time, releases of
contaminated materials to the environment were common. A small percentage of these sites have
been, or are being, cleaned up under one or more of the seven major market segments. For
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example, 12 MGP sites are on the NPL and some have been reported under state cleanup
programs. Because these sites may be managed under any of the remediation programs, the
estimates of the MGP market should not be added to those of the seven major market segments
above. Adding these estimates would be double-counting sites and cleanup costs, thereby
overestimating the market's scope.
Summarizing this information, it is estimated that, 37 percent of non-federal NPL sites, 28
percent of RCRA, 28 percent of state, 30 percent of DOD, and 30 percent of DOE sites are likely
to have a DNAPL problem. Although there are possibly thousands of UST sites with DNAPLs
(e.g., tanks containing solvents), there are insufficient data on the number of tanks that contain
them to make a meaningful estimate. These percentages result in the estimates presented in
Exhibit 14-3. The estimated percentage of sites with DNAPLs is interpolated from data in the
EPA study (U.S. EPA 1993a) and adjusted for the percentage of sites with groundwater
contamination (83 percent). The NPL percentages are applied to the other market segments
based on the occurrence of organics in those segments relative to the NPL segment.
In addition to sites that have not yet begun remediation, there may be old sites (those with
ongoing or completed remedy construction) where a DNAPL problem has not yet been
discovered, where operating pump-and-treat systems are not adequately containing the plumes,
and/or where addressing the source zones have not been attempted. As new characterization and
remediation approaches become practicable, the remedies at these sites may be revisited.
Exhibit 14-3. Estimated Number of Sites With DNAPLs
Cleanup Estimated Estimated Percent Estimated Number of Sites
Market No. of Sites to be With DNAPLs (%) With DNAPLs
Segments Cleaned upa
Range Average Range Average
NPL (non-federal)
RCRA
UST
DOD
DOE
Civilian Agencies
State & Private
Total
736
3,800
125,000
6,400
5000
> 3,000
150,000
293,936
29-44
22-34
NA
24-37
24-37
NA
22-34
37
28
NA
30
30
NA
28
213 -324
836 - 1 ,292
NA
1,536-2,368
1,200-1,850
NA
33,000-51,000
37,260-54,814
538
1,052
NA
1,819
1,469
NA
41,200
46,078
NANot available
3 From Exhibit 1-1.
Source: Analysis of data in Evaluation of the Likelihood of DNAPL Presence at NPL Sites, National Results,
OSWER Publication 9335.4-13, EPA 540-R-93-073, PB93-963343, Office of Solid Waste and Emergency
Response, September, 1993.
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These estimates are approximations that incorporate a number of simplifying assumptions as
described above. For example, evidence of discharge of a compound does not necessarily mean
it remains in free-phase or residual form. The compounds could be dissolved, in which case this
methodology would overstate the number of sites with free-phase or residual DNAPLs. On the
other hand, since not all compounds associated with DNAPLs were included in previous studies,
the estimate may be understating the extent of the DNAPL problem.
14.4 Estimated Remediation Costs
Any estimate of the value of the site characterization market is hampered by the extremely wide
range of potential site conditions and the paucity of program-wide data on costs that pertain to
specific DNAPL remediations. Most cleanup programs do not compile data on expenditures
pertaining to specific contaminants or pollutants, or specific actions such as pump-and-treat
operations, excavations, or laboratory analyses in a manner that can be aggregated or used to
compute averages. Many sites are being remediated for more than one contaminant and medium.
Even if total remediation cost for a site is known, the specific costs attributable to DNAPL
remediation would be difficult to determine. Cost estimates in RODs, which are done prior to
remedy design, are estimates which serve as only general indicators of potential cost.
Remediation costs for DNAPLs are primarily affected by costs involved in removing or reducing
source zones and costs incurred in addressing dissolved phase plumes. Because pump-and-treat
systems have often been a major part of both types of DNAPL remediations, it is useful to
examine the historical experience with their costs. In reviewing historical cost data, it is
important to bear in mind that the study of many existing sites is complicated by the fact that
many previous pump-and-treat systems were installed and began operations before the existence
of a subsurface DNAPL source zone was suspected. Thus, historical cost data from these sites
may not be reflective of ultimate costs at future sites.
14.4.1 Pump-and-Treat System Costs
Historically, pump-and-treat systems have been the principal remedy at DNAPL sites.
Information on the cost of pump-and-treat systems from three EPA studies provides useful
insight into the potential magnitude and variability of these costs. In a 1999 study of 26 pump-
and-treat remediations and two PRB systems, EPA estimated that the average capital cost for
pump-and-treat systems was $3.5 million and the average annual operating cost was $670,000
(U.S. EPA 1999). Some of these expenditures may include costs for source control remedies,
such as slurry walls, when the source control was an integral part of the groundwater cleanup.
Comparing these costs on a per volume of water treated basis, the estimates were $250 capital
and $31 O&M per 1,000 gallons per year, respectively (Exhibit 14-4). A 2001 EPA study
indicated similar results (U.S. EPA 2001c).
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit 14-4. Cleanup Costs for Selected Pump-and-Treat Projects
Annual O&M Costs
Per Per
Mem 1,000 Median 1,000
(000) Gallons (000) Gallons
Annually Annually
26 Project Sample (U.S. EPA 1999) b
All 26 Sites 670 31 190 18
32 Project Sample (U.S. EPA 2001 c)
All 32 sites 770 32 260 16
79 Project Sample (U.S. EPA 2001 a)
All 79 Sites 570 NA 350 NA
Sites with Observed 736 NA 402 NA
NAPLs
Sites With 568 NA 285 NA
Suspected NAPLs
Mean
(000)
3,500
4,900
NA
NA
NA
Capital Costs
Per
1,000 Median
Gallons (000)
Annually
250 1 ,900
280 2,000
NA NA
NA NA
NA NA
Per
1,000
Gall.
Ann
96
78
NA
NA
NA
Millions of
Gallons/Year
Mean Med
63 21
120 30
NA NA
NA NA
NA NA
b Does not include two sites where PRBs were used as the only remediation technology.
NA Not available
source: U .S. EPA. 1 999. Groundwater Cleanup: Overview of Operating Experience at 28 Sites, EPA 542-R-99-006, Office of Solid
Waste and Emergency Response, September 1999; U.S. EPA. 2001 . Groundwater Pump and Treat Systems: Summary of Selected
Cost and Performance Information at Superfund-financed Sites, EPA 542-R-01 -021 b, Office of Solid Waste and Emergency Response,
December 2001; U.S. EPA. 2001. Cost Analysis for Selected Groundwater Cleanup Projects: Pump and Treat Systems and Permeable
Reactive Barriers, EPA 542-R-01-013, Office of Solid Waste and Emergency Response, February 2001 .
The 2001 study, which used data from the above 26 sites plus 6 additional pump-and-treat sites,
indicated significant economies of scale, (decreasing cost per gallon of water treated) for systems
that pump and treat up to 20 million gallons per year. As system sizes exceed 20 million gallons
per year, there is little change in cost per gallon. However, because the systems studied represent
several different technologies, contaminants, and site conditions, some of the variation in unit
costs may be due to variations between sites using different technologies or treating for different
contaminants. There were not enough data points to develop meaningful separate cost curves for
each technology and set of site conditions.
Nevertheless, these data imply a general
tendency of decreasing unit costs up to a
point. To the extent that economies of scale
exist, it is likely that per gallon pump-and-
treat costs at most state and private sites will
probably be higher than at most Superfund,
RCRA, DOD and DOE sites, which tend to
be larger (Exhibit 14-5).
The exhibit also shows that the type of contaminant group and type of aboveground treatment
affects the operating cost of a pump-and-treat system. Sites at which chlorinated solvents, alone
or with other VOCs, were present had lower operating costs and capital costs than sites with
Because of potential economies of scale in P&T
systems, most smaller sites, such as most state
sites, are likely to have higher unit P&T costs,
on average, than most Superfund, RCRA,
DOD, and DOE sites.
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other combinations of contaminants (average of $26 per 1,000 gallons per year compared to $53,
and median of $12 compared to $39). Similarly, treating for chlorinated solvents, alone or with
other VOCs, using air stripping or granulated activated carbon only, the average O&M cost was
substantially lower than the average for sites treating for these contaminants plus other
combinations of contaminants, such as solvents, BTEX, metals, PCBs, or PAHs (median of $3
per 1,000 gallons per year compared to $40).
Exhibit 14-5. Comparison of Pump-and-Treat Costs for Selected Projects
Ave. O&M
Site Characteristic Cost per
Thous. Gal.
Annually
• -20 million gallons per year (14 sites) 62
• -20 million gallons per year (18 sites) 10
Sites with chlorinated solvents alone or with 26
other VOCs (18 sites)
Sites with other combinations of 53
contaminants (solvents, BTEX, metals,
PCBs, or PHBs) (9 sites)
Sites with chlorinated solvents alone or with NA
other VOCs that use air stripping and/or GAC
(11 sites)
Sites with other combinations of treatment NA
technologies (7 sites)
Median O&M Ave. Capital Median
Cost per Cost per Capital Cost
Thous. Gal, Thous, Gal. per Thous.
Annually Annually Gal. Annually
42 580 440
5 49 24
12 3,600,000 1,900,000
39 8,900,000 7,400,000
3 NA NA
40 NA NA
Notes: GAC: Granulated activated carbon
NA: Data not available
These results should be interpreted with caution. First, the sites were not selected for this study
to be a statistically representative sample of groundwater remediation projects, although they
include a range of system types and situations at Superfund and RCRA Corrective Action sites.
Second, the unit cost (per 1,000 gallons treated) is highly dependent on site-specific factors, such
as the specific treatment technology used, complexity of the aquifer, types and mix of
contaminants targeted for treatment, water and air discharge limits, and restoration goals. Third,
the data are presented primarily as annual O&M costs and initial capital costs. These data are
necessary, but insufficient to make decisions on selecting technologies for a given site. Decisions
about which technology is less expensive are typically based on life-cycle costs. Estimating life-
cycle costs requires information on the duration of the system and repair and replacement
requirements in the out years, which were not available in these studies.
The third study, a 2001 EPA study of 79 Superfund-fmanced sites, estimated that the average
annual O&M costs of a pump-and-treat system is approximately $570,000, and the median is
$350,000 (U.S. EPA 2001a). This difference is due to a small number of systems with relatively
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high costs that raise the average. Factoring in
estimated durations of the pump-and-treat
systems obtained from an RPM survey, the
study estimated average life-cycle cost to reach
remediation completion for the average Fund-
lead pump-and-treat system is approximately
$10 million without discounting and $6 million
with discounting (i.e., present value).3 The study
also indicated that average annual pump-and-
treat cost for sites where NAPLs (the report did
not differentiate between LNAPLs and
DNAPLs) were observed is 29 percent higher
than for all sites. Exhibit 14-4 displays the
estimated average costs from these studies.
The average life-cycle cost for pump-and-
treat systems at Fund-lead sites has been
estimated to be $10 million and have a net
present value of $6 million. This average
may be higher if systems continue to operate
beyond 30 years, which is likely to be the
case for sites with appreciable unaddressed
NAPL contamination.
The O&M costs per 1,000 gallons of water
treated per year with pump-and-treat
systems appears to decline with increasing
volume of water treated until about 20 million
gallons per year. Above 20 million gallons,
there is little change in unit cost as volume
increases.
In applying this information to understand the
potential cost of DNAPL cleanups it is
important to understand that these estimates may understate future costs of the systems studied.
Regional staff surveyed may have assigned a default value of 30 years to systems for which the
expected system duration was unknown. While the practice of using 30 years as a default value
has been used in many engineering cost applications, some pump-and-treat systems may need to
operate many decades, or centuries beyond. EPA guidance on cost analysis for feasibility studies
states that the period of analysis "should not necessarily be limited to the commonly-used
assumption of 30 years"(U.S. EPA 200b). There is an increased likelihood that, over long
periods, additional maintenance and replacement of system components and reactive materials
will be needed. In addition, the cost of replacing system components during the initial 30 years
may have not been included. These uncounted costs may be significant.
Also not included in the above cost estimates is the potential cost of revising remedies at older
sites where the original remedy design did not adequately consider the existence of free-phase or
residual DNAPLs in the subsurface. The case studies indicate that there may be such situations,
because the groundwater pump-and-treat systems at some sites began before the existence of
subsurface DNAPL source zones were suspected.
Knowledge about the present value of the future O&M costs is an important factor in
determining the balance between containment and treatment at a site. Present value estimates can
be compared to the cost of additional source removal in the short term (which is usually not
discounted since it is an early, short-term cost). Similar calculations might be used by state or
federal regulators in ensuring that adequate funds are available to continue O&M at a site. In
Because funds not spent at present can be invested at a rate that exceeds inflation, current funds can yield
additional money for future expenditures, thereby making present-day dollars worth more than future dollars. As a
result, future costs are often discounted and reported as present value. The discount rate, which is similar to an
interest rate and differs from project to project, is primarily a function of the cost of capital to the responsible entity, or,
in the case of some federal rulemakings and expenditures, a "social discount rate." The discount rate used in the
2001 study is 5 percent and all figures are reported in 2001 dollars.
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addition to examining discounted costs and performance, decision makers are also advised to
examine undiscounted costs in comparing alternative remedies.
The data in these studies demonstrate the highly variable nature of the costs among sites.
Because of this variability and because of the small sample sizes, the estimates are presented as a
general overview of pump-and-treat costs, and are not meant to be used to guide cost estimates
for any specific project.
14.5 Remediation Technologies and R&D
Effectively remediating DNAPLs requires adequate means of finding and delineating them
(characterization) and treating them (remediation). In the past, both characterization and
remediation have tended to be expensive. As a result, many potentially responsible parties have
not characterized source zones but rather have chosen dissolved plume containment while
seeking a "technical impracticability waiver" for the actual cleanup of the source zone. The
dissolved plume containment has generally consisted of a groundwater pump-and-treat system
and more recently of some form of permeable reactive barrier (PRB) such as zero valent iron for
TCE. A pump-and-treat system is relatively inexpensive to install but incurs relatively high
operation and maintenance costs over the life of the system. PRBs are relatively expensive to
install and their effective lifetime before requiring replacement is uncertain.
Despite the many groundwater pump-and-treat projects, many sites have not achieved cleanup
goals, largely due to the infeasibility of recovering more mass by continued pump and treat. A
1994 study by the National Academy of Sciences concluded that 42 of 77 sites examined, were
unlikely to achieve cleanup to drinking water standards. At 29 sites, cleanup to drinking water
standards is possible but subject to significant uncertainties. For these later sites, partial cleanup
was offered as a possibly more realistic scenario (NRC 1994). Without treatment of the source
zone, these systems will be required to function for many years, perhaps decades or centuries at
some DNAPL sites, as the sources slowly dissolve into the groundwater.
14.5.1 Site Characterization Technologies
Characterization of a DNAPL source zone has traditionally been problematic. For the most part,
characterization in unconsolidated formations calls for a relatively refined description of the site
stratigraphy and vertical and horizontal profiling of dissolved DNAPL concentrations in the
groundwater. This characterization information, in conjunction with a knowledge of the site
history, is then used to determine where to drill for the DNAPLs. Since DNAPL subsurface
architecture can be very complex, with many thin lenses of pure phase with randomly occurring
residual areas, continuous coring and screening/testing of the cores is a prevalent practice. When
the coring is done using a hollow stem auger it is slow and costly. This cost of characterization
has in some cases led to an inadequate delineation of the source area and dissolved plume and,
subsequently, to the installation of containment systems that inadvertently do not address the
source area nor the entire plume.
In the past ten years a number of characterization technologies have become available that
greatly reduce the difficulty, and sometimes cost, of finding DNAPLs in the shallow (less than
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
60 feet) subsurface. Most of these advances have come as a result of direct push technology
(DPT) and provide either direct in-situ sampling (near continuous groundwater sampling for
vertical profiling, membrane interface probe for near continuous contaminant sampling ) or in-
situ measurement of contaminants (e.g., induced fluorescence, halogen probe). Also, dual tube
DPT rigs can provide a relatively inexpensive way to collect continuous cores for surface
contaminant screening by portable instruments and hydrophobic dye tests. The degree of
characterization needed also depends on the remediation technology under consideration.
However, the corollary is also true: Because they make possible more accurate delineation of
contamination plumes and DNAPL source areas, the newer characterization technologies can
improve the effectiveness of some of the older remediation technologies and enable the
application of the newer approaches.
14.5.2 Treatment Technologies
A number of in-situ remediation technologies have recently been developed to address DNAPL
contamination. These technologies generally fall into one of three categories: thermal, oxidation,
or surfactant and cosolvent flushing. Thermal technologies (steam and electrical) rely on
elevating the temperature of the subsurface to make the contaminants more mobile so they can
be captured by collection devices. The elevated heat can also cause direct chemical destruction
or destruction by hydrous pyrolysis. Since thermal technologies treat general areas, the precise
location of DNAPL masses is not as important as it is for the other technologies.
Oxidation techniques rely on the injection of oxidizing chemicals, such as permanganates or
hydrogen peroxide, into the subsurface where they react with the DNAPLs and destroy them.
Since the main expense with oxidizing technologies is the cost of the oxidant, information on
quantities of contamination and the extent of naturally-occurring oxidant demand (NOD) are
important. There is a growing body of full-scale remedial experience where this very approach
has been approved by regulators and resulted in the issuance of no-further action letters.
Nevertheless, contact between oxidizing agents and contaminants is required for effective
treatment and achieving adequate contact is problematic in low-permeability and /or
heterogenous media.
Finally, flushing can be accomplished using cosolvents (alcohols), surfactants, or hot/cold water.
Otherwise stationary contaminant masses are mobilized by the flushing agent and both are
captured by a collection well(s). With the exception of hot/cold flushing, the above technologies
have been shown to be able to capture or destroy between 60 and 90 percent of the
contamination.
There is a great deal of discussion in the remediation community as to whether removal of 60 to
90 percent of a DNAPL mass is worth the cost. Because the remaining mass will continue to be a
source of groundwater contamination, containment may still be needed to prevent risk of
exposure. Some argue that by creatively structuring a treatment train across a site using
aggressive source removal followed by downstream passive polishing techniques, such as
bioremediation, natural attenuation could then be used instead of pump and treat to address the
dissolved phase plume. This is an area where more research is required to determine which
sources might be amenable to this approach. The research is needed to better define mass flux
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rates from reduced source zones and the potential for early shut down of pump-and-treat
systems. There is also a need to develop better tools for both characterizing and remediating
deep DNAPL sources, particularly those found in fractured bedrock.
14.5.3 Balancing Source Removal/Treatment vs. Containment
The extent to which site managers will continue to rely on containment approaches compared to
source zone reduction will depend on decisions made at individual sites. These decisions will be
based on technical, financial, and reuse considerations for the site, as well as regulatory
requirements and policy.
Through most of the 1990s, EPA policy recognized the difficulties of remediating sites
containing DNAPL source zones and associated groundwater plumes, although the Agency
continued to encourage aggressive cleanup of DNAPL source areas to the extent feasible. As a
result, EPA policy has incorporated an implicit presumption that removal of DNAPLs from the
subsurface is not practicable in many situations. In its 1993 guidance on "technical
impracticability" EPA recognized that current technology was not capable of removing DNAPL
mass (U.S. EPA 1993b). EPA policy has also suggested that waivers due to technical
impracticability would be a presumptive remedy at DNAPL sites (U.S. EPA 1995 and 1996).
Since then, progress has been made in both site characterization and remediation technologies
that can affect DNAPL site management. Improved site characterization approaches may be used
to improve the effectiveness and cost of plume management and treatment and treatment of the
source zone. Thus, there is a growing awareness that accelerated groundwater restoration may be
cost effective at many sites.
A number of states have recognized the potential of the newer characterization and treatment
tools in their regulatory policies regarding DNAPLs (ITRC 2002). They encourage the use of
these tools to reduce the DNAPL source zone through removal and/or treatment of free-phase or
residual DNAPLs. Their policy is to not grant ARAR waivers due to technical impracticability
without serious consideration of innovative and emerging source reduction technologies.
In conjunction with the state and federal regulatory policies, remediation professionals generally
compare the costs and relative effectiveness of alternative approaches to reducing risks. For most
DNAPL sites, the choice will be between a high initial cost and low future annual cost, on the
one hand, and lower initial costs and moderate annual O&M costs for many years, perhaps
decades or centuries, on the other. This tradeoff will be influenced by the discount rate used to
compare future expenses to current expenses. Although EPA guidance provides "rules of thumb"
for the selection of the discount rate, decision makers may use a lower or higher discount rate if
there is justification for it (U.S. EPA 2000b). Some additional critical factors to be considered
include life-cycle cost of all alternatives in both discounted and undiscounted dollars, including
all probable costs, such as replacement of equipment and reactive materials, projected repairs,
and O&M; and probable performance of each technology considered, given the site's history,
type and form of contaminants, manner and form of contaminant releases, and hydrogeologic
characteristics. Regulators, responsible parties, and site owners will need to carefully structure
these evaluations to ensure that funds will be available to continue O&M as long as necessary to
protect human health and the environment.
Chapter 14: DNAPLs Page 14-15
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
14.6 References
FRTR, 2004. Technology Cost and Performance, a database maintained by the Federal
Remediation Technologies Roundtable (FRTR). http://costperformance.org/search.cfm
ITRC, 2002. DNAPL Source Reduction: Facing the Challenge., Interstate Technology and
Regulatory Council, April, 2002.
ITRC, 2003 a. Technical and Regulatory Guidance for Surfactant/Cosolvent Flushing of DNAPL
Source Zones, Interstate Technology and Regulatory Council, April 2003.
ITRC, 2003b. An Introduction to Characterizing Sites Contaminated withDNAPLs, Interstate
Technology and Regulatory Council, September 2003.
Kram, Keller, Rossabi, & Everett, 2001. "DNAPL Characterization Methods and Approaches,
Part 1: Performance Comparisons," Mark L Kram, A.A. Keller, J. Rossabi, and L.G. Everett,
Ground Water Monitoring & Remediation, Fall 2001, pp. 109-123.
http ://www. cluin.org/download/char/GWMR_Fall_l 09-123 .pdf
Kram, Keller, Rossabi, & Everett, 2002. "DNAPL Characterization Methods and Approaches,
Part 2: Cost Comparisons," Mark L Kram, A.A. Keller, J. Rossabi, and L.G. Everett, Ground
Water Monitoring & Remediation, Winter 2002, pp. 46-61.
http://www.cluin.org/download/char/GWMR_W_02_46-61.pdf
NRC, 1994. Alternatives for Groundwater Cleanup, National Research Council, National
Academy Press, Washington, D.C., 1994.
SERDP, 2001. Final Report, SERDP/ESTCP Expert Panel Workshop on Research and
Development Needs for Cleanup of Chlorinated Solvent Sites, Strategic Environmental Research
and Development Program sponsored by U.S. DOD, U.S. DOE, and U.S. EPA.
http://www.serdp.org/news/other_events/2001/chlorsolv/chl orsolvcleanup.pdf
U.S. EPA (Environmental Protection Agency), 1993a. Evaluation of the Likelihood of DNAPL
Presence atNPL Sites, National Results, OSWER Publication 9335.4-13, EPA 540-R-93-073,
PB93-963343, Office of Solid Waste and Emergency Response, September, 1993.
U.S. EPA, 1993b. Guidance for Evaluating Technical Impracticability of Groundwater
Restoration, OSWER Directive 9234.2-25.
U.S. EPA, 1994. Draft Analysis of Facility Corrective Action Data, Office of Solid Waste and
Emergency Response, Technology Innovation Office, January 1994.
U.S. EPA, 1995. Superfund Ground Water RODS: Implementing Change This Fiscal Year,
OSWER Memorandum 9335.5-03P, EPA/540-F-99-005, Office of Solid Waste and Emergency
Response.
Chapter 14: DNAPLs Page 14-16
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
U.S. EPA, 1996. Presumptive Response Strategy and Ex-Situ Treatment Technologies for
Contaminated Groundwater at CERCLA sites, OSWER Directive 9283.1-12, Office of Solid
Waste and Emergency Response.
U.S. EPA 1997'a. Cleaning Up the Nation's Waste Sites: Markets and Technology Trends, EPA
542-R-96-005. Office of Solid Waste and Emergency Response, Technology Innovation Office,
April 1997.
U.S. EPA, 1997b. Field Analytical and Site Characterization Technologies: Summary of
Applications, EPA 542-R-97-011. http://www.epa.gov/swerustl/cat/fasc.pdf
U.S. EPA, 1999. Groundwater Cleanup: Overview of Operating Experience at 28 Sites, EPA
542-R-99-006, Office of Solid Waste and Emergency Response, September 1999.
U.S. EPA, 2000a. Innovative Remediation Technologies: Field-Scale Demonstration Projects in
North America, 2nd Edition Year 2000 Report, EPA/542/B-00-004, Office of Solid Waste and
Emergency Response, http://www.epa.gov/tio/download/remed/nairt_2000.pdf
U.S. EPA, 2000b. Remedy Cost Estimating Manual, A Guide to Developing and Documenting
Remedial Alternative Cost Estimates During the Feasibility Study, EPA 540 R-DO-002, OSWER
9355.0-75, Office of Solid Waste and Emergency Response.
U. S. EPA, 2001 a. Groundwater Pump and Treat Systems: Summary of Selected Cost and
Performance Information at Super fund-financed Sites, EPA 542-R-01-021b, Office of Solid
Waste and Emergency Response, December 2001.
U.S. EPA, 2001b. State of the Practice of Characterization and Remediation of Contaminated
Ground Water at Fractured Rock Sites, EPA 542-R-01-010, Office of Solid Waste and
Emergency Response, July 2001.
U.S. EPA, 200 Ic. Cost Analysis for Selected Groundwater Cleanup Projects: Pump and Treat
Systems and Permeable Reactive Barriers, EPA 542-R-00-013, Office of Solid Waste and
Emergency Response, February 2001.
U. S. EPA, 2003. Report on Innovative Approaches to Manufactured Gas Plant Site
Characterization, EPA/542/R-01/003, Office of Solid Waste and Emergency Response,
Technology Innovation Office.
Chapter 14: DNAPLs Page 14-17
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Web Sites
Chemical Oxidation Site Profiles
http ://www. cluin.org/products/chemox/search/chem_search. cfm
Fractured Bedrock Site Profiles and Other Links
http ://www. cluin.org/fracrock/
In Situ Thermal Treatment Site Profiles
http ://www. cluin.org/products/thermal/
Remediation Technology Cost and Performance Information
http://www.frtr.gov/costperf.htm
Field Analytic Technologies Information
http: //fate. clu-in. org/
Chapter 14: DNAPLs Page 14-18
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Appendix A
Supporting Data for Analysis of
National Priority List Sites
Appendix A. Supporting Data for National Priority List Sites Page A-1
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Exhibit A-1. Contaminant Groups
and Subgroups for the Analysis of
Contaminants at NPL and DOD Sites
This appendix contains the definitions of the chemical groups and subgroups used for the
analyses of chemicals of concern found at NPL and DOD sites in chapters 3 and 6 of this report.
The table on this page indicates the major chemical groups and subgroups, and the following
pages list the individual chemicals that belong to each group and subgroup. This taxonomy was
developed by grouping chemicals and elements in accordance with EPA test methods for
evaluating solid waste and other standard chemical references listed on page A-11 of this
appendix.
Breakdown of Contaminant Groups and Subgroups
Individual
Contaminant Group Contaminant Subgroup Contaminants
1 . Volatile organic
compounds (VOCs)
2. Semivolatile organic
compounds (SVOCs)
3. Metals
4. Fuels & other
petroleum distillates
5. Explosives &
propellants
6. Other
Halogenated
Non-halogenated
BTEX
Halogenated
Non-halogenated
PAHs
Pesticides
Phenols
PCBs
No subgroup
Fuels and distillates
Solvents
No subgroup
Miscellaneous inorganic elements and
compounds
Radioactive materials
Other Organic (coal tar, creosote)
Unspecified Solvents
See pages A-4 and A-5
See pages A-6 through
A-10
See page A-10
See page A-10
See page A-1 1
See page A-1 1
Sources: See page A-1 1
Appendix A. Supporting Data for National Priority List Sites
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1. VOLATILE ORGANIC COMPOUNDS (VOCs)
Halogenated VOCs
1,1-Dichloroethane 75-34-3
1,1-Dichloroethene 75-35-4
1,1,1 -Trichloroethane 71-55-6
1,1,1,2-Tetrachloroethane 630-20-6
1,1,2-Trichloro-1,2,2-Trifluoroethane 76-13 -1
1,1,2-Trichloroethane 79-00-5
1,1,2,2-Tetrachloro-1,2-difluoroethane 76-12-0
1,1,2,2-Tetrachloroethane 79-34-5
l,2-Dibromo-3-chloropropane 96-12-8
1,2-Dibromoethane 106-93-4
1,2-Dichloro-l, 1,2,2-Tetrafluoroethane 76-14-2
1,2-Dichlorobenzene 95-50-1
1,2-Dichloroethane 107-06-2
1,2-Dichloropropane 78-87-5
1,2,3-Trichloropropane 96-18-4
1,2,3-Trichlorbenzene 87-61-6
1,2,4-Trichlorobenzene 120-82-1
l,3-Dichloro-2-propanol 96-23-1
1,3-Dichlorobenzene 541-73-1
1,4-Dichlorobenzene 106-46-7
1,4-Difluorobenzene (IS) 540-36-3
2-Chloroethanol 107-07-3
2-Chloroethyl vinyl ether 110-75-8
2-Picoline 109-06-8
3-Chloropropionitrile 542-76-7 I
4-Bromofluorobenzene (surr) 460-00-4
4-Chlorophenyl phenyl ether 7005-72-3
Allyl chloride 107-05-1
Benzyl chloride 100-44-7
Bis(2-chloroethoxy)methane 111-91-1
Bis(2-chloroethyl) ether 111-44-4
Bis(2-chloroethyl)sulfide 505-60-2
Bis(2-chloroisopropyl) ether 108-60-1
Bromoacetone 598-31-2
Bromochloromethane 74-97-5
Bromodichloromethane 75-27-4
Bromoform 75-25-2
Bromomethane 74-83-9
Carbon tetrachloride 56-23-5
Chloral hydrate 302-17-0
Chlorobenzene 108-90-7
Chlorodibromomethane 124-48-1
Chloroethane 75-00-3
Chloroform 67-66-3
Chloromethane 74-87-3
Chloroprene 126-99-8
cis-1,3 -Dichloropropene 10061-01-5
cis-l,4-Dichloro-2-butene 1476-11-5
cis-l,2-Dichloroethene 156-59-2
Dibromochloromethane 124-48-1
Dibromomethane 74-95-3
Dichlorodifluoromethane 75-71-8
Difluoromethane
Epichlorohydrin 106-89-8 I
Fluorobenzene (IS) 462-06-6
Hexachlorobutadiene 87-68-3
Hexachloroethane 67-72-11
lodomethane 74-88-4
Methylene chloride 75-09-2
Pentachloroethane 76-01-7 I
Tetrachloroethene 127-18-4
trans-1,2-Dichloroethene 156-60-5
trans-1,3 -Dichloropropene 10061-02-6
trans-l,4-Dichloro-2-butene 110-57-6
Trichloroethene 79-01-6
Trichlorofluoromethane 75-69-4
Vinyl chloride 75-01-4
Non-halogenated VOCs
110-86-11 p-Propiolactone 57-57-8
l-Propano!71-23-8
1,2,3,4-Diepoxybutane 1464-53-5
1,4-Dioxane 123-91-1
2-Butanone (MEK) 78-93-3
2-Hexanone 591-78-6
2-Hydroxypropionitrile 78-97-7 I
2-Nitropropane 79-46-9
2-Pentanone 107-87-9
2-Propanol 67-63-0
2,5-Dimethylbenzaldehyde 5779-94-2
4-Methyl-2-pentanone (MIBK) 108-10-1
Acetone 67-64-1
Acetonitrile 75-05-8
Acrolein (Propenal) 107-02-8
Acrylonitrile 107-13-1
Allyl alcohol 107-18-6
Benzaldehyde 100-52-7
Butanal (Butyraldehyde) 123-72-8
Carbon disulfide 75-15-0
Croton aldehyde 4170-30-3
Croton aldehyde 123-73-9
Cyclohexene 110-82-7
Cyclohexanone 108-94-1
Decanal 112-31-2
Diethyl ether 60-29-7
Ethanol 64-17-5 I
Ethyl methacrylate 97-63-2
Ethyl acetate 141-78-61
Ethylene oxide 75-21-8
Formaldehyde 50-00-0
Heptanallll-71-7
Appendix A. Supporting Data for National Priority List Sites
Page A-4
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Hexanal (Hexaldehyde) 66-25-1
Isobutyl alcohol 78-83-1
Isopropylbenzene 98-82-8
Isovaleraldehyde 590-86-3
m-Tolualdehyde 620-23-5
Malononitrile 109-77-3
Methacrylonitrile 126-98-7
Methane 74-82-8
Methanol 67-56-11
Methyl Acetate 79-20-9
Methylcyclohexane 108-87-2
Methyl methacrylate 80-62-6
Methyl-tert-butyl ether 1634-04-4
n-Butanol 71-36-3
N-Nitroso-di-n-butylamine 924-16-3
n-Propylamine 107-10-8
Naphthalene 91-20-3
Nitrobenzene 98-95-3
Nonanal 124-19-6
o-Tolualdehyde 529-20-4
o-Toluidine 95-53-4
Octanal 124-13-0
p-Tolualdehyde 104-87-OParaldehyde 123-63-7
Pentanal (Valeraldehyde) 110-62-3
Propanal (Propionaldehyde) 123-38-6
Propargyl alcohol 107-19-7
Propionitrile (ethyl cyanide) 107-12-0
Pyridine
Styrene 100-42-5
Tetrahydrofuran 109-99-9
t-Butyl alcohol 75-65-0
Vinyl acetate 108-05-4
BTEX
Benzene 71-43-2
Toluene 108-88-3
Ethylbenzene 100-41-4
m-Xylene 108-38-3
o-Xylene 95-47-6
p-Xylene 106-42-3
Notes (VOCs):
List compiled from SW-846, CLP Target Compound List, Drinking Water Standard, Priority Pollutant
List.
Appendix A. Supporting Data for National Priority List Sites
Page A-5
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2. SEMIVOLATILE ORGANIC COMPOUNDS (SVOCs)
Halogenated SVOCs
1-Chloronaphthalene 90-13-1
l,2-Dibromo-3-chloropropane 96-12-8
1,2-Dichlorobenzene 95-50-1
1,2,3,4,5,6,7,8-Octachlorodibenzofuran (OCDF) 39001-02-0
1,2,3,4,5,6,7,8-Octachlorodibenzo-p-dioxin (OCDD) 3268-87-9
1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin (HpCDD) 35822-46-9
1,2,3,4,6,7,8-Heptachlorodibenzofuran (HpCDF) 67562-39-4
1,2,3,4,7,8-Hexachlorodibenzo-p-dioxin (HxCDD) 39227-28-6
1,2,3,4,7,8-Hexachlorodibenzofuran (HxCDF) 70648-26-9
1,2,3,4,7,8,9-Heptachlorodibenzofuran (HpCDF) 55673-89-7
1,2,3,6,7,8-Hexachlorodibenzofuran (HxCDF) 57117-44-9
1,2,3,6,7,8-Hexachlorodibenzo-p-dioxin (HxCDD) 57653-85-7
1,2,3,7,8-Pentachlorodibenzo-p-dioxin (PeCDD) 40321-76-4
1,2,3,7,8-Pentachlorodibenzofuran (PeCDF) 57117-41-6
1,2,3,7,8,9-Hexachlorodibenzofuran (HxCDF) 72918-21-9
1,2,3,7,8,9-Hexachlorodibenzo-p-dioxin (HxCDD) 19408-74-3
1,2,4-Trichlorobenzene 120-82-1
1,2,4,5-Tetrachlorobenzene 95-94-3
1,3-Dichlorobenzene 541-73-1
1,4-Dichlorobenzene 106-46-7
2-Chloroaniline 101-14-4
2-Chloronaphthalene 91-58-7
2,3,4,6-Tetrachlorophenol 58-90-2
2,3,4,6,7,8-Hexachlorodibenzofuran (HxCDF) 60851-34-5
2,3,4,7,8-Pentachlorodibenzofuran (PeCDF) 57117-31-4
2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD) 1746-01-6
2,3,7,8-Tetrachlorodibenzofuran (TCDF) 51207-31-9
3-(Chloromethyl)pyridine 6959-48-4
3-Methylcholanthrene 56-49-5
3,3'-Dichlorobenzidine 91-94-1
4-Bromophenyl phenyl ether 101-55-3
4-Chloro-l,2-phenylenediamine 95-83-0
4-Chloro-1,3 -phenylenediamine 5131 -60-2
4-Chloroaniline 106-47-8
4-Chlorophenyl phenyl ether 7005-72-3
4,4'-Methylenebis (2-chloroaniline) 101-14-4
5-Chloro-2-methylaniline 95-79-4
Bis(2-chloroethoxy)methane 111-91-1
Bis(2-chloroethyl) ether 111-44-4
Bis(2-chloroisopropyl) ether 108-60-1
Chlorobenzilate 510-15-6
p-Chloro-m-creosol
Hexachlorobenzene 118-74-1
Hexachlorobutadiene 87-68-3
Hexachlorocyclopentadiene 77-47-4
Hexachloroethane 67-72-1
Hexachlorophene 70-30-4
Hexachloropropene 1888-71-7
Hexamethylphosphoramide 680-31-9
Appendix A. Supporting Data for National Priority List Sites Page A-6
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Hydrochloride 6959-48-4
Pentachlorobenzene 608-93-5
Pentachloronitrobenzene 82-68-8
Total Heptachlorodibenzo-p-dioxin (HpCDD) 37871-00-4
Total Tetrachlorodibenzo-p-dioxin (TCDD) 41903-57-5
Total Pentachlorodibenzo-p-dioxin (PeCDD) 36088-22-9
Total Hexachlorodibenzo-p-dioxin (HxCDD) 34465-46-8
Total Tetrachlorodibenzofuran (TCDF) 55722-27-5
Total Pentachlorodibenzofuran (PeCDF) 30402-15-4
Total Hexachlorodibenzofuran (HxCDF) 55684-94-1
Total Heptachlorodibenzofuran (HpCDF) 38998-75-3
Tris(2,3-dibromopropyl) phosphate 126-72-7
Non-halogenated SVOCs
N,N-dimethylaniline 101-61-1
a,a-Dimethylphenethylamine 122-09-8
l-Acetyl-2-thiourea 591-08-2
1-Naphthylamine 134-32-7
1,2-Dinitrobenzene 528-29-0
1,2-Diphenylhydrazine 122-66-7
1,3-Dinitrobenzene 99-65-0
1,3,5-Trinitrobenzene 99-35-4
1,4-Dinitrobenzene 100-25-4
1,4-Naphthoquinone 130-15-4
1,4-Phenylenediamine 106-50-3
2-Acetylaminofluorene 53-96-3
2-Amino-4, 6-dinitrotoluene 35572-78-2
2-Aminoanthraquinone 117-79-3
4-Bromophenyl phenyl ether 101-55-3
2-Naphthylamine 91-59-8
2-Nitroaniline 88-74-4
2-Nitrotoluene 88-72-2
2-Picoline (2-Methylpyridine) 109-06-8
2,4-Diaminotoluene 95-80-7
2,4-Dinitrotoluene 121-14-2
2,4,5-Trimethylaniline 137-17-7
2,4,6-Trinitrotoluene 118-96-7
2,6-Dinitrotoluene 606-20-2
3-Amino-9-ethylcarbazole 132-32-1
3-Nitroaniline 99-09-2
3-Nitrotoluene 99-08-1
3,3'-Dimethoxybenzidine 119-90-4
3,3'-Dimethylbenzidine 119-93-7
4-Amino-2,6-dinitrotoluene 1946-51 -0
4-Aminobiphenyl 92-67-1
4-Nitroaniline 100-01-6
4-Nitrobiphenyl 92-93-3
4-Nitrotoluene 99-99-0
4,4'-Methylenebis (2-chloroaniline)
101-14-4
4,4'-Oxydianiline 101-80-4
4,6-Dinitro-2-methylphenol 534-52-1
5-Nitro-o-anisidine 99-59-2
5-Nitro-o-toluidine 99-55-8
5-Nitroacenaphthene 602-87-9
5,5-Diphenylhydantoin 57-41-0
Acetophenone 98-86-2
Aminoazobenzene 60-09-3
Anilazine 101-05-3
Aniline 62-53-3
Benzidine 92-87-5
Benzoic acid 65-85-0
Benzyl alcohol 100-51-6
Bis(2-chloroethoxy)methane 111-91-1
Bis(2-chloroethyl)ether 111-44-4
Bis(2-chloroisopropyl)ether 108-60-1
Bis(2-ethylhexyl) phthalate 117-81-7
Butyl benzyl phthalate 85-68-7
Carbazole 86-74-8
Di-n-butyl phthalate 84-74-2
Di-n-octyl phthalate 117-84-0
Dibenzofuran 132-64-9
Diethyl phthalate 84-66-2
Diethyl sulfate 64-67-5
Diethylstilbestrol 56-53-1
Dihydrosaffrole 56312-13-1
Dimethyl phthalate 131-11-3
Dimethylaminoazobenzene 60-11-7
Diphenylamine 122-39-4
Ethyl methanesulfonate 62-50-0
Hexahydro-l,3,5-trinitro-l,3,5-triazine
(RDX) 121-82-4
Hydroquinone 123-31-9
Isophorone 78-59-1
Isosafrole 120-58-1
Appendix A. Supporting Data for National Priority List Sites
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Non-halogenated SVOCs (Continued)
Maleic anhydride 108-31-6
Mestranol 72-33-3
Methapyrilene 91-80-5
Methyl methanesulfonate 66-27-3
Methyl-2,4,6-trinitrophenylnitramine
(Tetryl) 479-45-8
N-Nitrosodi-n-butylamine 924-16-3
N-Nitrosodi-n-propylamine 621-64-7
N-Nitrosodiethylamine 55-18-5
N-Nitrosodimethylamine 62-75-9
N-Nitrosodiphenylamine 86-30-6
N-Nitrosomethylethylamine 10595-95-6
N-Nitrosomorpholine 59-89-2
N-Nitrosopiperidine 100-75-4
N-Nitrosopyrrolidine 930-55-2
Nicotine 54-11-5
Nitrobenzene 98-95-3
Nitroquinoline-1-oxide 56-57-5
o-Anisidine 90-04-0
o-Toluidine 95-53-4
Octahydro-l,3,5,7-tetranitro-l,3,5,7-tetrazocine
(HMX) 2691-41-0
Octamethyl pyrophosphoramide 152-16-9
O,O,O-Triethyl phosphorothioate 126-68-1
p-Benzoquinone 106-51-4
p-Cresidine 120-71-8
Phenacetin 62-44-2Phenobarbital 50-06-6
Phthalic anhydride 85-44-9
Piperonyl sulfoxide 120-62-7
Pronamide 23950-58-5
Propylthiouracil 51-52-5
Pyridine 110-86-1
Resorcinol 108-46-3
Tetraethyl dithiopyrophosphate 3689-24-5
Tetraethyl pyrophosphate 107-49-3
Toluene diisocyanate 584-84-9
Tri-p-tolyl phosphate 78-32-0
Trimethyl phosphate 512-56-1
Polynuclear Aromatic Hydrocarbons (PAHs)
Acenaphthene 83-32-9
Acenaphthylene 208-96-8
Anthracene 120-12-7
Benzo(a)anthracene 56-55-3
Benzo(a)pyrene 50-32-8
Benzo(b)fluoranthene 205-99-2
Benzo(j)fluoranthene 205-83-3
Benzo(k)fluoranthene 207-08-9
Benzo(ghi)perylene 191-24-2
Chrysene 218-01-9
Dibenz(a,h)acridine 226-36-8
Dibenz(aj)acridine 224-42-0
Dibenzo(a,h)anthracene 53-70-3
Dibenzo(a,e)pyrene 192-65-4
Dibenzo(a,h)pyrene 189-64-0
Dibenzo(a,i)pyrene 189-55-9
Fluoranthene 206-44-0
Fluorene 86-73-7
Indeno(l,2,3-cd)pyrene 193-39-5
3-Methylcholanthrene 56-49-5
Naphthalene 91-20-3
Phenanthrene 85-01-8
Pyrene 129-00-0
7,12-Dimethylbenz(a)anthracene 57-97-6
2-Methylnaphthalene 91-57-6
Pesticides
a-BHC 319-84-6
a-Chlordane 5103-71-9
P-BHC 319-85-7
y-BHC (Lindane) 58-89-9
y-Chlordane 5103-74-2
5-BHC 319-86-8
2,4-D 94-75-7
2,4-DB 94-82-6
2,4,5-T 93-76-5
2,4,5-TP (Silvex) 93-72-1
3-Hydroxycarbofuran 16655-82-6
4-Nitrophenol 100-02-1
4,4'-DDD 72-54-8
4,4'-DDE 72-55-9
4,4'-DDT 50-29-3
Aldicarb
Aldicarb (Temik) 116-06-3
Aldicarb Sulfone 1646-88-4
Aldicarb Sulfoxide
Aldrin 309-00-2
Aramite 140-57-8
Aspon, 3244-90-4
Atrazine 1912-24-9
Azinphos-ethyl 2642-71-9
Azinphos-methyl 86-50-0
Barban 101-27-9
Bolstar (Sulprofos) 35400-43-2
Bromoxynil 1689-84-5
Captafol 2425-06-1
Captan 133-06-2
Carbaryl (Sevin) 63-25-2
Carbofuran (Furadan) 1563-66-2
Carbophenothion 786-19-6
Chlordane - not otherwise specified 57-74-9
Chlorfenvinphos 470-90-6
Appendix A. Supporting Data for National Priority List Sites
Page A-8
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Pesticides (Continued)
Chlorobenzilate 510-15-6
Chlorpyrifos 2921-88-2
Chlorpyrifos methyl 5598-13-0
Coumaphos 56-72-4
Crotoxyphos 7700-17-6
Dalapon 75-99-0
Dibromochloropropane (DBCP) 96-12-8
Demeton 8065-48-3
Diallate (cis or trans) 2303-16-4
Diazinon 333-41-5
Dicamba 1918-00-9
Dichlone 117-80-6
Dichlorofenthion 97-17-6
Dichloroprop 120-36-5
Dichlorvos (DDVP) 62-73-7
Dicrotophos 141-66-2
Dieldrin 60-57-1
Dimethoate 60-51-5
Dinocap 39300-45-3
Dinoseb 88-85-7
Dioxacarb 6988-21-2
Dioxathion 78-34-2
Diquat 2764-72-9
Diuron 330-54-1
Disulfoton 298-04-4
Endosulfan I 959-98-8
Endosulfan sulfate 1031-07-8
Endosulfan II 33213-65-9
Endrin 72-20-8
Endrin ketone 53494-70-5
Endrin aldehyde 7421-93-4
EPN 2104-64-5
Ethion 563-12-2
Ethoprop 13194-48-4
Ethyl carbamate 51-79-6
Ethyl parathion 56-38-2
Famphur 52-85-7 a
Fenitrothion 122-14-5
Fensulfothion 115-90-2
Fenthion 55-38-9
Fluchloralin 33245-39-5
Fonophos 944-22-9
Heptachlor epoxide 1024-57-3
Heptachlor 76-44-8
Hexachlorobenzene 118-74-1
Hexachlorocyclopentadiene 77-47-4
Hexamethylphosphoramide (HMPA) 680-31-9
Isodrin 465-73-6
Kepone 143-50-0
Leptophos 21609-90-5
Linuron 330-55-2
Malathion 121-75-5
MCPA 94-74-6
MCPP 93-65-2
Merphos 150-50-5
Methiocarb (Mesurol) 2032-65-7
Methomyl (Lannate) 16752-77-5
Methoxychlor 72-43-5
Methyl parathion 298-00-0
Mevinphos 7786-34-7
Mexacarbate 315-18-4
Mirex 2385-85-5
Monocrotophos 6923-22-4
Monuron 150-68-5
Naled 300-76-5
Nitrofen 1836-75-5
Parathion 56-38-2
Parathion, methyl 298-00-0
Pentachlorophenol 87-86-5
Phorate 298-02-2
Phosalone 2310-17-0
Phosmet 732-11-6
Phosphamidon 13171-21-6
Picloram 1918-02-1
Promecarb 2631-37-0
Propoxur (Baygon) 114-26-1
Ronnel 299-84-3
Rotenone 83-79-4
Safrole 94-59-7
Siduron 1982-49-6
Simazine 122-34-9
Stirophos (Tetrachlorovinphos) 22248-79-9
Strychnine 57-24-9
Sulfallate 95-06-7
Sulfotepp 3689-24-5
TEPP 21646-99-1
Terbufos 13071-79-9
Tetrachlorvinphos 961 -11 -5
Tetraethyl dithiopyrophosphate 3689-24-5
Tetraethyl pyrophosphate 107-49-3
Thionazin (Zinophos) 297-97-2
Thiophenol (Benzenethiol) 108-98-5
Tokuthion (Protothiofos) 34643-46-4
Toxaphene 8001-35-2
Tri-o-cresylphosphate (TOCP) 78-30-8
Triazine Herbicides (NPD only)
Trichlorfon 52-68-6
Trichloronate 327-98-0
Trifluralin 1582-09-8
Appendix A. Supporting Data for National Priority List Sites
Page A-9
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Phenols
2-Chlorophenol 95-57-8
2-Cyclohexyl-4,6-dinitrophenol 131-89-5
2-Methyl-4,6-dinitrophenol 534-52-1
2-Methylphenol (o-Cresol) 95-48-7
2-Nitrophenol 88-75-5
2,3,4,5-Tetrachlorophenol 4901-51-3
2,3,4,6-Tetrachlorophenol 58-90-2
2,3,5,6-Tetrachlorophenol 935-95-5
2,4-Dichlorophenol 120-83-2
2,4-Dimethylphenol 105-67-9
2,4-Dinitrophenol 51-28-5
2,4,5-Trichlorophenol 95-95-4
2,4,6-Trichlorophenol 88-06-2
2,6-Dichlorophenol 87-65-0
3-Methylphenol (m-Cresol) 108-39-4
4-Chloro-3-methylphenol 59-50-7
4-Methylphenol (p-Cresol) 106-44-5
4-Nitrophenol 100-02-7
Dinoseb (DNBP) 88-85-7
(2-(Sec-butyl)-4,6-dinitrophenol)
Pentachlorophenol 87-86-5
Phenol 108-95-2 DC(28)
Polychlorinatedbiphenyls (PCBs)
Aroclorl016 12674-11-2-
Aroclorl221 11104-28-2-
Aroclorl232 11141-16-5-
Aroclor 1242 53469-21-9 -
Aroclor 1248 12672-29-6 -
Aroclorl254 11097-69-1 -
Aroclor 1260 11096-82-5-
2-Chlorobiphenyl 2051-60-7 1
2,3-Dichlorobiphenyl 16605-91-7 5
2,2',5-Trichlorobiphenyl 37680-65-2 18
2,4',5-Trichlorobiphenyl 16606-02-3 31
2,2',3,5'-Tetrachlorobiphenyl 41464-39-5 44
2,2',5,5'-Tetrachlorobiphenyl 35693-99-3 52
2,3',4,4'-Tetrachlorobiphenyl 32598-10-0 66
2,2',3,4,5'-Pentachlorobiphenyl 38380-02-8 87
2,2',4,5,5'-Pentachlorobiphenyl 37680-73-2 101
2,3,3',4',6-Pentachlorobiphenyl 38380-03-9 110
2,2',3,4,4',5'-Hexachlorobiphenyl 35065-28-2 138
2,2',3,4,5,5'-Hexachlorobiphenyl 52712-04-6 141
2,2',3,5,5',6-Hexachlorobiphenyl 52663-63-5 151
2,2',4,4',5,5'-Hexachlorobiphenyl 35065-27-1 153
2,2',3,3',4,4',5-Heptachlorobiphenyl 35065-30-6 170
2,2',3,4,4',5,5'-Heptachlorobiphenyl 35065-29-3 180
2,2',3,4,4',5',6-Heptachlorobiphenyl 52663-69-1 183
2,2',3,4',5,5',6-Heptachlorobiphenyl 52663-68-0 187
2,2',3,3',4,4',5,5',6-Nonachlorobiphenyl 40186-72-9
3. METALS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Lithium
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Potassium
Selenium
Silver
Sodium
Strontium
Thallium
Tin
Vanadium
Zinc
Note (metals):
The above are either TAL metals, drinking water
primary or secondary metals, or have toxicity values
associated with the Region 9 preliminary cleanup goals
list
4. FUELS AND OTHER
PETROLEUM DISTILLATES
Diesel Fuel
Gasoline
JP-4
JP-5
Kerosene
No. 2 Fuel oil
Unspecified fuel
Solvents
Mineral Spirits
Stoddard solvent
Appendix A. Supporting Data for National Priority List Sites
Page A-10
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
5. EXPLOSIVES AND
PROPELLANTS
Explosives
Propellants
Other Organic Substances
Coal Tar
Creosote
Unspecified organic materials
Unspecified solvents
6. OTHER WASTES
Miscellaneous Inorganic Elements and
Compounds (Misc. Organics)
Ammonia
Asbestos
Copper Chromated Arsenic
Chloride
Hydrazine
Hydrofluoric acid
Inorganic cyanides
Nitrate
Nitrite
Perchlorate
Phosphine
Phosphorus
Silicon tetrafluoride
Sulfides
Radioactive Materials
Americium
Cesium 137 Cobalt 60
Curium
Iodine 131
Lead 210
Neptunium
Plutonium
Polonium 210
Radium
Radon
Strontium 90
Technetium
Thorium
Tritium
Uranium
7. REFERENCES
Greenberg, A. etal., editors. 1985. Standard Methods for
the Examination of Water and Wastewater, American
Public Health Association.
U.S. Congress. Code of Federal Regulations: 40 CFR 136
Guidelines Establishing Test Procedures for the Analysis
of Pollutants.
U.S. EPA, 1997. Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods, " Third Edition,
Office of Solid Waste and Emergency Response, June 13,
1997.
U.S. EPA, 1998. Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods Draft Update IVA,
Office of Solid Waste and Emergency Response, May
1998, http://www.epa.gov/epaoswer/
hazwaste/test/sw846.htm
U.S. EPA, 1999. Multi-Media, Multi-Concentration
Organics Analysis OLM04.2, Office of Solid Waste and
Emergency Response, Fall 1999.
U.S. EPA, 2000. Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods Draft Update IVB,
Office of Solid Waste and Emergency Response,
November 2000. http://www.
epa. gov/epaoswer/hazwaste/test/sw846. htm
U.S. EPA, 2002a. Multi-Media, Multi-Concentration
Dioxins and Furans Analysis, DLM01.4 (a Non-Routine
Analytical Service) Statement of Work, Office of Solid
Waste and Emergency Response, January 2002.
U.S. EPA, 2002b. Multi-Media, Multi-Concentration
Inorganic Analysis ILM05.2, Office of Solid Waste and
Emergency Response, September 2002.
Appendix A. Supporting Data for National Priority List Sites
PageA-11
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Appendix A. Supporting Data for National Priority List Sites Page A-12
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit A-2. Superfund Remedial
Action Contractors (RACs)
Region 1
Tetra Tech NUS, Inc.
55 Jonspin Road
Wilmington, MA 01887
Contact: George Gardner
508-658-7899
email: bbrd680@b-r.com
Metcalf and Eddy, Inc.
30 Harvard Mill Square
P.O. Box
Wakefield, MA01880
Contact: Neville Chung
617-224-6385
email: neville_chung@metcalfeddy.com
Region 2
Foster Wheeler Environmental Corp.
1000 The American Road
Morris Plains, NJ 07950
Contact: William Colvin
973-630-8554
email: wcolvin@fwenc.com
CDM Federal Programs Corp.
125 Maiden Lane - 5th Floor
New York, NY 1003 8
Contact: Robert Goltz
212-785-9123
email: goltz.rd@cdm.com
Region 3
Tetra Tech NUS, Inc.
661 Andersen Drive
Pittsburgh, PA 15220
Contact: Don Senovich
412-921-7090
email: dsenovich(S)b-r.com
Tetra Tech/Black and Veatch (joint venture)
56 West Main Street
Christiana, DE 19702
Contact: Dr. Carl Hsu
302-738-7551
email: carl.hsu@tetratech.com
CDM Federal Programs Corp.
13135 Lee Jackson Memorial Highway
Suite 200
Fairfax, VA 22033
Contact: Joan Knapp
703-968-0200 ex. 358
email: knappjo@cdm.com
Region 4
Black & Veatch Special Project Corp.
1145 Sanctuary Parkway, Suite 475
Alpharetta, GA 30004
Contact: Harvey B. Coppage
770-751-7517
email: coppagehb@bv.com
Region 5
CH2MHILL
135 South 84th St., Suite 325
Milwaukee, WI 53214
Contact: Isaac Johnson
414-272-2426
email: ijohnson@ch2m.com
Weston Solutions, Inc.
750 E. Bunker Court, Suite 500
Vernon Hills, IL 60061-1450
Contact: James M. Burton
847-918-4000
email: james.burton@westonsolutions.com
Appendix A. Supporting Data for National Priority List Sites
Page A-13
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Region 6
CH2MHILL
10th Floor
123 77 Merit Drive
Dallas, TX 75251
Contact: Al Sloan
972-980-2170
email: asloan@ch2m.com
Tetra Tech Environmental Management,
Inc.
1 Dallas Center
3SON. St. Paul St., Suite2600
Dallas, TX 75201
Contact: Lou Barinka
214-740-2014
email: barinkal@ttemi.com
Region 7
Black & Veatch
6601 College Blvd.
Overland Park, KS 66211
Contact: Ray Herzog
913-458-6600
email: herzogrh@bv.com
Region 8
CDM Federal Programs
1331 17th Street, Suite 1050
Denver, CO 80202
Contact: Richard Culver
303-295-1237
email: culverrl@cdm.com
Region 9
CH2MHILL
155 Grand Avenue, Suite 1000
Oakland CA 94612
Contact: Udai Singh
510-587-7555
email: usingh@ch2m.com
Region 10
URS Greiner, Inc.
2401 4th Avenue, Suite 1000
Seattle, WA 98121-1459
Contact: Vivianne Larkin
206-674-1871
email: vivianne_larkin@urscorp.com
Appendix A. Supporting Data for National Priority List Sites
Page A-14
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Appendix B
Supporting Data for Analysis of
Underground Storage Tank Sites
Appendix B. Supporting Data for Underground Storage Tank Sites Page B-1
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit B-1. LIST Corrective Action Measures
Mid-Year FY 2004 (As of March 31, 2004)
Region/ Active Closed Confirmed Cleanups Cleanups Cleanup Emergency
State Tanks Tanks Released Initiated Completed Backlog Responses
Region One
CT
MA
ME
NH
Rl
VT
Subtotal
12,358
11,489
3,443
3,027
1,720
2,967
35,004
191 49
21,689
11,963
10,639
7,041
5,104
75,585
2,388
5,958
2,080
2,141
1,199
1,897
15,663
2,344
5,745
2,029
2,141
1,199
1,885
15,343
1,538
4,525
1,948
1,292
942
1,086
11,331
850
1,433
132
849
257
811
4,332
110
4,868
370
606
26
261
6,241
Region Two
NJ
NY
PR
VI
Subtotal
18,836
29,683
4,684
124
53,327
52,720
78,126
5,202
278
136,326
9,257
19,719
999
14
29,989
8,400
19,130
843
14
28,387
5,466
17,264
380
0
23,110
3,791
2,455
619
14
6,879
51
410
168
14
643
Region Three
DC
DE
MD
PA
VA
WV
Subtotal
723
1,560
9,369
26,739
28,024
6,267
72,682
2,998
6,378
27,639
57,841
48,907
18,198
161,961
781
2,204
11,999
13,445
9,988
2,801
41,218
781
2,142
10,420
13,331
9,714
2,632
39,020
528
1,889
8,661
9,090
9,083
1,584
30,835
253
315
3,338
4,355
905
1,217
10,383
228
390
330
28
63
9
1,048
Region Four
AL
FL
GA
KY
MS
NC
SC
TN
Subtotal
18,194
32,786
38,725
13,452
8,994
30,932
12,325
16,550
171,958
28,236
91,252
43,707
34,284
21,351
61,902
30,999
31,726
343,457
10,688
25,220
10,443
12,744
6,357
23,090
8,490
12,359
109,391
10,587
14,012
9,904
12,739
6,207
22,290
8,101
11,697
95,537
8,987
7,606
7,321
10,176
6,061
16,053
4,912
11,092
72,208
1,701
17,614
3,122
2,568
296
7,037
3,578
1,267
37,183
276
204
10
148
114
503
94
68
1,417
Appendix B. Supporting Data for Underground Storage Tank Sites
Page B-2
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit B-1. LIST Corrective Action Measures (Continued)
Mid-Year FY 2004 (As of March 31, 2004)
Region/ Active Closed Confirmed Cleanups Cleanups Cleanup Emergency
State Tanks Tanks Released Initiated Completed Backlog Responses
Region Five
IL
IN
Ml
MN
OH
Wl
Subtotal
23,373
14,299
21,493
14,077
24,758
14,149
112,149
60,961
34,673
63,453
28,025
41,311
63,672
292,095
21,895
7,943
20,242
9,311
23,288
18,038
100,717
20,499
6,994
19,867
8,816
22,891
17,123
96,190
13,158
4,347
11,296
8,054
19,698
14,464
71,017
8,737
3,596
8,946
1,257
3,590
3,574
29,700
1,755
226
87
432
417
388
3,305
Region Six
AR
LA
NM
OK
TX
Subtotal
9,952
14,913
4,189
11,890
58,218
99,162
19,554
30,709
12,086
23,908
106,926
193,183
1,205
2,595
2,419
3,902
23,585
33,706
927
1,894
1,660
3,902
21,499
29,882
877
1,584
1,502
3,395
18,186
25,544
328
1,011
917
507
5,399
8,162
12
691
79
89
500
1,371
Region Seven
LA
KS
MO
NE
Subtotal
7,846
7,556
10,328
6,962
32,692
21,699
19,055
27,847
13,926
82,527
5,708
4,526
5,995
5,890
22,119
5,492
4,255
5,621
3,837
19,205
3,603
2,438
4,562
3,524
14,127
2,105
2,088
1,433
2,366
7,992
0
115
329
10
454
Region Eight
CO
MT
ND
SD
UT
WY
Subtotal
8,225
3,584
2,194
3,084
4,042
2,073
23,202
20,453
12,894
6,892
6,522
12,355
7,695
66,811
6,291
3,045
811
2,307
4,038
1,978
18,470
6,066
2,289
800
2,258
3,852
1,212
16,477
5,241
1,880
756
2,039
3,518
955
14,389
1,050
1,165
55
268
520
1,023
4,081
41
48
3
21
3
62
178
Appendix B. Supporting Data for Underground Storage Tank Sites
Page B-3
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit B-1. LIST Corrective Action Measures (Continued)
Mid-Year FY 2004 (As of March 31, 2004)
Region/ Tanks Closed Confirmed Cleanups Cleanups Cleanup Emergency
State Tanks Released Initiated Completed Backlog Responses
Region Nine
AZ
CA
HI
NV
CNMI
GU
AS
Subtotal
8,303
41,005
1,835
3,695
79
280
12
55,209
19,584
117,655
4,921
6,613
19
398
52
149,242
8,085
42,487
1,776
2,420
9
132
7
54,916
5,550
42,487
1,680
2,410
8
132
7
52,274
5,512
27,245
1,414
2,133
2
108
6
36,420
2,573
15,242
362
287
7
24
1
18,496
2
0
0
52
0
0
1
55
Region Ten
AK
ID
OR
WA
Subtotal
1,086
3,527
6,629
9,939
21,181
6,151
9,169
25,861
35,014
76,195
2,300
1,315
6,760
5,977
16,352
2,163
1,284
6,407
5,742
15,596
1,292
1,135
5,167
3,956
11,550
1,008
180
1,593
2,021
4,802
95
12
56
37
200
Regional Corrective Actions for Indian Country
Region 1
Region 2
Region 3
Region 4
Region 5
Region 6
1 Region 7
Region 8
Region 9
Region 10
Subtotal
4
179
NA
58
374
301
88
571
708
400
2,683
2
21
NA
55
996
195
91
1,885
1,165
846
5,256
0
7
NA
10
191
34
20
436
181
148
1,027
0
1
NA
10
188
34
15
397
136
142
923
0
0
NA
4
124
30
8
215
101
112
594
0
7
NA
6
67
4
12
221
80
36
433
0
2
NA
0
0
1
0
5
0
0
8
National Totals
Active Closed Confirmed Cleanups Cleanups Cleanup Emergency
Tanks Tanks Released Initiated Completed Backlog Responses
National
Total
679,249
1,582,638
443,568
408,834
311,125
132,443
14,920
Source: U.S. Environmental Protection Agency, Office of Underground Storage Tanks, Semi-Annual Activity
Report, First Half ( March 31, 2004). http://vwvw.epa.gov/swerust1/cat/camarchv.htm
Appendix B. Supporting Data for Underground Storage Tank Sites
Page B-4
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Appendix C
Supporting Data for Analysis of
Department of Defense Sites
Appendix C: Department of Defense Sites Page C-1
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit C-1: Location of POD Sites Needing Cleanup
DOD DOD Army Navy Air Force DLA FUDS
EPA Region State Installations Sites Sites Sites Sites Sites Sites
One
Two
Three
Four
Five
Six
CT
MA
ME
NH
Rl
VT
Subtotal
NJ
NY
PR
VI
Subtotal
DC
DE
MD
PA
VA
WV
Subtotal
AL
FL
GA
KY
MS
NC
SC
TN
Subtotal
IL
IN
Ml
MN
OH
Wl
Subtotal
AR
LA
NM
OK
TX
Subtotal
16
56
39
9
27
5
152
44
89
12
1
146
29
7
30
34
43
6
149
24
96
26
8
24
31
29
21
259
55
18
31
10
33
19
166
11
13
124
41
125
314
51
153
67
36
60
10
377
268
260
60
1
589
63
44
357
135
318
39
956
217
462
163
74
61
168
163
140
1,448
247
124
120
37
148
36
712
49
31
184
123
359
746
7
34
1
6
9
0
57
173
60
0
0
233
3
0
174
73
62
0
312
180
0
75
63
0
15
19
46
398
89
62
0
20
35
9
215
12
5
20
25
67
129
27
10
9
10
15
0
71
32
6
48
0
86
26
0
140
19
202
13
400
0
161
10
3
16
82
68
16
356
23
33
0
3
0
0
59
0
1
0
0
48
49
8
56
15
17
1
5
102
19
80
2
0
101
7
39
26
10
20
0
102
18
217
64
0
25
45
53
24
446
69
10
80
5
50
11
225
19
11
32
47
122
231
0
0
0
0
0
0
0
1
8
0
0
9
0
0
4
10
9
1
24
0
0
0
0
0
0
0
39
39
0
0
0
0
1
0
1
0
7
0
0
1
8
9
53
42
3
35
5
147
4
106
10
1
160
27
5
13
23
25
25
118
19
84
14
8
20
26
23
15
209
66
19
40
9
62
16
212
18
7
132
51
121
329
Appendix C: Department of Defense Sites
Page C-2
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit C-1: Location of DOD Sites Needing Cleanup (Continued)
DOD DOD Army Navy Air Force DLA FUDS
EPA Region State Installations Sites Sites Sites Sites Sites Sites
Seven
Eight
Nine
Ten
Total
IA
KS
MO
NE
Subtotal
CO
MT
ND
SD
UT
WY
Subtotal
AS
AZ
CA
CN
GM
GU
HI
JQ
MQ
NV
WQ
Subtotal
AK
ID
OR
WA
Subtotal
8
55
24
41
128
28
6
3
19
24
21
101
6
87
402
15
13
8
73
2
1
29
1
637
120
9
17
36
182
2,234
33
164
85
69
351
226
18
6
30
227
37
544
6
140
2,011
18
14
49
251
8
1
78
37
2,613
454
32
33
119
638
8,974
23
83
22
3
131
154
0
1
0
159
0
314
0
39
68
0
0
0
12
0
0
18
0
137
24
0
4
25
53
1,979
0
0
0
0
0
1
0
0
0
0
0
1
0
2
653
0
0
28
109
0
1
20
0
813
0
17
0
41
58
1,893
2
8
37
17
64
47
12
5
11
35
17
127
0
20
830
0
0
21
67
7
0
11
37
993
293
8
14
31
346
2,737
0
0
0
0
0
0
0
0
0
6
0
6
0
0
44
0
0
0
0
0
0
0
0
44
0
0
0
0
0
131
8
73
26
49
156
24
6
0
19
27
20
96
6
79
416
18
14
0
63
0
0
29
0
625
137
7
15
22
181
2,233
Notes:
• Needing Cleanup means sites that have not achieved Response Complete (RC) status.
• The column for DOD Installations and Sites includes one Defense Threat Reduction Agency (DTRA) site at Johnston Atoll
(JQ).
• JQ = Johnston Atoll; AS = American Samoa; GM/GU = Guam; WQ = Wake Island; MQ = Midway; CN = Marianas; VI = Virgin
Islands.
Source: DOD, Office of the Under Secretary of Defense (Installations & Environment), Restoration Management Information
System (RMIS), data as of September 2001 .
Appendix C: Department of Defense Sites
Page C-3
-------
Exhibit C-2: Definitions of POD Site Types
Site Type Site Description Primary Contaminants
Underground
Storage Tank
Spill Area
Landfill
Unexploded
Munitions/Ordnance
Area
Surface Disposal
Area
Disposal Pit/Dry Well
Storage Area
Contaminated
Groundwater
Underground storage tank sites result from the release of substances from
underground storage tanks and any associated piping.
Spill areas are small areas where spills from drums, tanks, and other waste
units have taken place.
Landfill sites are typically areas formerly used to dispose of both domestic
and industrial hazardous waste.
Unexploded munitions and ordnance areas are areas that have been used
for munitions and ordnance training.
Surface disposal area sites consist of small areas formerly used for disposal
of solid wastes with little or no free liquids. Typical materials include rags,
filters, paint cans, small capacitors, and batteries.
Disposal pit/dry well sites consist of small unlined excavations and structures
that were used over a period of time to dispose of small quantities of liquid
wastes.
Storage areas are areas where spills and leaks occurred from stored
containers or equipment.
Contaminated groundwater results from various types of releases of known
or unknown origin, such as migration of leachate from disposal areas and
migration of substances from contaminated surface and subsurface soils.
• POLs -Solvents
• POL sludges • Metals
•POLs • Sludge
•PCBs • Metals
• Solvents
• POLs -Pesticides
•Solvents • Metals
Paint • Ord. compounds
• UXO • Explosive chemicals
• Metals • Ord. compounds
• POLs -Metals
•Solvents • Acids
•Paints • PCBs
• Pesticides
• POLs «Acids
•Metals • Solvents
•Ordnance compounds
• Explosive chemicals
• POLs -Metals
•Solvents • Acid
•POL sludge • PCBs
•Metals • POLs
•Chlorinated solvents
• Explosive chemicals
• Non-chlorinated solvents
o
CD
CD
c
T3
CD
'A-
CD
CO
CD
CD-
CD
3
Q.
CD
O
O
CO
CD
3
Q.
-------
Exhibit C-2: Definitions of POD Site Types (Continued)
Site T?ne Site Description Primary Contaminants
Fire/Crash Training
Area
Building Demolition/
Debris Removal
Surface
Impoundment/
Lagoon
Aboveground
Storage Tanks
Contaminated Fill
Contaminated
Building
Burn Area
Contaminated
Sediments
Fire and crash rescue training areas consist of trenches and/or pits where
flammable materials were ignited periodically for demonstrations and training
exercises.
Building demolition and debris removal sites consist of buildings and/or debris that
are unsafe or must be removed.
Surface impoundments and lagoons consist of unlined depressions,
excavations, or diked areas which were used to accumulate liquid waste,
waste containing free liquid, or industrial wastewaters.
Aboveground storage tank sites result from release of substances to
surrounding areas from aboveground tanks, containers, and any
associated piping.
Contaminated fill areas consist of contaminated material resulting from
excavations for construction, tanks, and other purposes.
Contaminated building sites result from releases within or on the outside of
a structure of a substance that has been contained within the building.
Burn area sites consist of pits or surface areas that were used for open-air
incineration of waste.
Contaminated sediments include sediments of bodies of water that have
been contaminated by surface runoff, subsurface migration, or direct
discharge of contaminants.
• POLs • POL sludges
• Solvents • Metals
• Asbestos • Lead paint
• Construction debris
• POLs • Metals
• Solvents • Ord. compounds
• Explosive chemicals
• Industrial wastewater
• POLs
• POLs • Explosive chem.
• Metals • Paint waste
• Ordnance compounds
POL • Asbestos
Plating waste • Propellants
Metals • Pesticides
POL sludge • Solvents
PCBs • Acids
POLs • Explosives
Propellants • Ordnance
Solvents
• POLs • Metals
PCBs • Solvents
Pesticides • Explosive chem.
o
CD
CD
c
T3
CD
'A-
CD
CO
CD
CD-
CD
3
Q.
CD
O
O
CO
CD
3
Q.
-------
Exhibit C-2: Definitions of POD Site Types (Continued)
Site Type Site Description Primary Contaminants
Explosive/Ordnance
Disposal Area
Waste Line
Waste Treatment
Plant
Sewage Treatment
Plant
Petroleum, Oil,
Lubricant (POL)
Distribution Line
Underground
Storage Tank Farm
Firing Range
Soil Contaminated
After Tank Removal
Explosive ordnance disposal areas consist of open-air areas that were
used to detonate, demilitarize, bury, or dispose of explosives.
Waste lines are underground piping used to carry industrial wastes from
shop facilities to a wastewater treatment plant.
Wastewater treatment plant sites result from releases of substances at
plants that were used to treat and dispose of domestic and/or industrial
wastewater.
Sewage treatment plants typically consist of a complex of tanks, piping,
and sludge management areas used to treat sanitary sewage generated
at an installation. The unit may use chemical or biological treatment
methods. Lagoons associated with the biological treatment of sewage
currently may be considered to be separate units.
Petroleum, oil, lubricant distribution lines are used to transport POL
products from storage to dispensing facilities.
Underground storage tank farm sites result from the release of
substances from multiple, typically large, underground storage tanks and
associated piping which make up a tank farm complex.
Firing ranges consist of large areas of land used for practice firing of
large artillery or mortars, or as a practice bombing range for aircraft.
These areas are typically contaminated with unexploded ordnance,
which may be found on and below the ground surface.
This unit consists of soil that has been removed during a tank removal
operation and staged prior to treatment.
• Unexploded • Metals
• Ordnance (UXO)
• Ordnance compounds
• Explosive chemicals
• Solvents • Metals
• Plating sludges • Pesticides
• Explosive chemicals
• POLs • Industrial
• Solvents wastewater
• Plating sludges
• Explosive chemicals
• Metals
• Industrial wastewater
• Solvents
• POLs
• POLs
• POL sludge
• POLs • Solvents
• POL sludges • Metals
• Metals • UXO
• Ord. compounds
• Explosives
• Radionuclides
• POLs
• POL sludge
o
CD
CD
c
T3
CD
'A-
CD
CO
CD
CD-
CD
3
Q.
CD
O
O
CO
CD
3
Q.
-------
Exhibit C-2: Definitions of POD Site Types (Continued)
Site Type Site Description Primary Contaminants
Storm Drain
Oil/Water Separator
Maintenance Yard
Low-level
Radioactive Waste
Area
Washrack
Drainage Ditch
Small Arms Range
Incinerator
Storm drains typically consist of a natural or man-made drain used as a
runoff control structure for rainfall. The unit also may be used from runoff
from other sources such as process operations. Man-made units may be
concrete lined.
Oil/water separators are typically small units that skim oil from storm-water
runoff. The oil/water separator consists of the unit, and any associated
piping.
Maintenance yards consist of paved or unpaved areas where vehicles and
other maintenance equipment is stored and often serviced. Typically,
maintenance supplies are stored at these units.
Low-level radioactive waste areas consist of areas used to store or dispose
of low-level radioactive materials of various types (for example, radium
paint, and radioactive instruments and propellants).
Washrack sites typically consist of a building designed for washing
vehicles such as tanks, aircraft, and other military vehicles. This unit also
may consist of a paved area where washing of vehicles occurs.
Drainage units typically consist of a natural or a man-made ditch used as a
runoff control structure for rainfall. The unit also may be used for runoff
from other sources such as process operations. Man-made units may be
concrete lined.
Small arms ranges are typically located outdoors and used for target
practice of small arms, usually 50 caliber or less. The unit may include a
soil or sandbag berm, or hill located behind the targets to prevent bullets
from traveling outside the range area.
Incinerators typically consist of a furnace and stack unit used for a variety
of disposal activities including the incineration of medical waste, or an
installation's dunnage. These units vary in size and may either be
freestanding or part of other operations such as hospitals.
• POLs • Pesticides
• Metals • Industrial wastewater
• POL sludge • Solvents
• POLs • PCBs
• Solvents
• Industrial wastewater
• POLs
• Metals
• Low-level
• Solvents
radioactive waste
• POLs
• POLs
• Solvents
• Explosive
• Metals
• Ordnance
• Ash
• Metals
• Ordnance
• Metals
• PCBs
chemicals
compounds
compounds
o
CD
CD
c
T3
CD
'A-
CD
CO
CD
CD-
CD
3
Q.
CD
O
O
CO
CD
3
Q.
-------
Exhibit C-2: Definitions of POD Site Types (Continued)
Site Type Site Description Primary
Contaminated
Soil Piles
Mixed Waste
Area
Pistol Range
Chemical
Disposal
Pesticide Shop
Industrial
Discharge
Surface Runoff
Leach Field
This unit consists of soil that has been staged after an excavation activity.
Mixed waste areas consist of areas used to store or dispose of hazardous
wastes that have been mixed with or contaminated by radioisotopes.
Pistol ranges may be located indoors or outdoors and are used for target
practice. Outdoor units include a soil or sandbag berm located behind the
targets to prevent bullets from traveling outside the range area.
Chemical disposal units are areas that have been used for the disposal of
chemicals, typically of an unknown type. The unit may be a burial area where
bottles or packages of chemicals were placed or an area where liquids were
disposed of on the soil.
Pesticide shops typically are used to store and prepare large volumes of
pesticides and solvents for maintenance. The units may be located in a
freestanding building or attached to another building. Areas near the unit may
have been used for the disposal of off-specification pesticides.
Industrial discharge units consist of a pipe system used to discharge industrial
effluent to the environment. The unit may discharge to a natural or man-made
water body, dry creek bed or some other natural feature.
Surface runoff is an area with runoff from rain which may occur anywhere
within a facility, particularly adjacent to industrial areas and airfield aprons.
Leach fields typically consist of a subsurface area generally associated with
septic tanks. The unit serves the purpose of biologically treating sanitary
sewage, however, in cases where these units were used at industrial facilities,
there also is contamination from non-biodegradable industrial contaminants.
• POLs
• Sludge
• Metals
Contaminants
Solvents
PCBs
Ord. compounds
• Solvents
• Mixed waste
• Metals
• POLs
• Metals
• Solvents
• Explosive chemicals
• Pesticides
• Metals
• POLs
• Metals
• Industrial wastewater
• POLs
• Metals
Solvents
Explosive chemicals
• Metals
• Solvents
o
CD
CD
c
T3
CD
'A-
CD
CO
CD
CD-
CD
3
Q.
CD
O
O
CO
CD
3
Q.
-------
Exhibit C-2: Definitions of POD Site Types (Continued)
Site Type Site Description Primary Contaminants
Plating Shop
Sewage Effluent
Settling Pond
Dip Tank
Plating shops typically consist of a building or room within a building used
for coating metal parts. The unit contains several tanks of solvents which
are used in the plating process.
Sewage effluent settling ponds consist of a lagoon used for the settling of
solids and/or biological treatment of sewage. The units also may be used
as infiltration galleries.
Dip tanks are typically metal or concrete units located in coating shops that
range in size from 50 to more than 500 gallons. The tanks are used to
clean parts prior to treatment, or to coat parts with various materials
includinq metals and plastics.
• Metals
• Solvents
• Acids
• Industrial wastewater
• Metals
• Ordnance compounds
• Solvents
•POLs
•Chlorinated solvents
• Metals
• Acids
Notes: POLs = Petroleum, oil, lubricants and POL sludge; PCB = Polychlorinated Biphenyls; Ord. = Ordnance
Source: DOD, Office of the Deputy Undersecretary of Defense (Environmental Security), Defense Environmental Restoration Program Annual
Report to Congress, for Fiscal Year 2001 , Appendix G.
o
CD
CD
c
T3
CD
'A-
CD
CO
CD
CD-
CD
3
Q.
CD
O
O
CO
CD
3
Q.
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit C-3: POD Site Types Needing Cleanup
Site Type Army Navy Air Force DLA FUDS Total
Spill Site Area
Landfill
Underground Storage Tanks
Other
Unexploded Munitions and Ordnance Area
Surface Disposal Area
Storage Area
Contaminated Groundwater
Disposal Pit and Dry Well
Fire/Crash Training Area
Surface Impoundment/Lagoon
Aboveground Storage Tank
Explosive Ordnance Disposal Area
Burn Area
Contaminated Buildings
Building Demolition/Debris Removal
Contaminated Sediments
POL (Petroleum/Oil/Lubricants) Lines
Firing Range
Contaminated Fill
Industrial Discharge
Storm Drain
Waste Lines
Chemical Disposal
Soil Contamination After Tank Removal
Maintenance Yard
Underground Tank Farm
Waste Treatment Plant
Oil/Water Separator
Sewage Treatment Plant
Drainage Ditch
Small Arms Range
Mixed Waste Area
Washrack
Radioactive Waste Area
Contaminated Soil Piles
145
300
75
25
48
110
171
143
97
29
97
26
51
93
105
7
38
12
17
18
66
2
22
48
10
26
14
29
10
11
13
10
5
23
5
14
151
231
237
38
24
246
190
65
65
59
37
52
32
31
32
11
63
38
3
12
11
13
38
6
7
31
43
18
13
5
11
4
20
4
2
7
789
373
311
1
17
179
77
44
216
153
25
40
12
10
5
22
16
77
8
5
11
70
25
20
6
18
14
26
30
26
18
12
8
13
26
4
9
8
14
4
0
8
21
16
24
1
2
1
0
0
2
5
0
2
0
3
0
1
0
0
5
1
0
0
0
0
1
0
0
0
0
0
12
62
203
666
499
20
18
150
12
7
13
48
68
20
12
111
33
8
76
61
3
2
2
6
52
2
7
3
0
2
1
17
8
1
6
12
1,107
974
840
734
588
563
477
418
414
249
174
167
163
159
156
151
150
137
104
99
91
88
87
80
80
78
78
76
53
44
44
43
41
41
39
37
Appendix C: Department of Defense Sites
Page C-10
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit C-3: POD Site Types Needing Cleanup (Continued)
Site Type Army Navy Air Force DLA FUDS Total
Leach Field
Incinerator
Pesticide Shop
Surface Runoff
Plating Shop
Dip Tank
Pistol Range
Sewage Effluent Settling Ponds
Total
19
18
10
5
2
3
6
1
1,979
8
6
9
1
13
4
1
1
1,893
7
2
5
8
2
4
1
1
2,737
1
0
0
1
0
0
1
0
131
0
3
1
2
0
0
2
2
861
35
29
25
17
17
11
1
5
8,974
Note 1 : The column for Total DOD includes one Defense Threat Reduction Agency (DTRA) site at Johnston Atoll (JQ).
Note 2: Needing cleanup is interpreted as sites that have not achieved Response Complete (RC) status.
Source: DOD, Office of the Deputy Under Secretary of Defense (Installations & Environment), Restoration Management
Information System (RMIS), data as of September 2001
Appendix C: Department of Defense Sites
PageC-11
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit C-4: Frequency of Matrices by POD Site Type
No. of Sites Ground- Surface
Site Type with Data water Soil Water Sediment
Spill Site Area
Landfill
Surface Disposal Area
Underground Storage Tanks
Storage Area
Disposal Pit and Dry Well
Contaminated Groundwater
Fire/Crash Training Area
Surface Impoundment/Lagoon
Burn Area
Contaminated Buildings
Contaminated Sediments
Other
Aboveground Storage Tank
POL (Petroleum/Oil/Lubricants) Lines
Explosive Ordnance Disposal Area
Contaminated Fill
Industrial Discharge
Waste Lines
Waste Treatment Plant
Maintenance Yard
Chemical Disposal
Underground Tank Farm
Storm Drain
Soil Contamination After Tank Removal
Unexploded Munitions and Ordnance Area
Oil/Water Separator
Drainage Ditch
Washrack
Contaminated Soil Piles
Sewage Treatment Plant
Mixed Waste Area
Leach Field
Incinerator
Radioactive Waste Area
Pesticide Shop
Firing Range
874
850
512
459
417
352
321
208
156
146
145
132
121
106
103
91
85
79
76
68
68
67
66
63
57
54
45
38
36
35
34
32
28
27
23
23
23
507
629
271
366
176
223
288
176
105
89
68
49
56
51
75
49
44
60
51
41
33
38
61
44
43
30
25
16
26
16
19
15
20
9
12
12
5
681
630
420
280
379
266
172
176
110
133
131
70
102
94
69
81
80
60
56
52
60
57
37
28
48
44
39
23
30
34
31
26
20
26
22
23
22
105
229
82
23
41
54
53
40
44
30
11
39
16
7
3
19
13
19
6
4
4
6
7
14
5
12
3
10
6
3
6
5
2
2
3
1
2
114
217
112
32
57
74
45
40
62
35
23
73
20
8
9
14
16
30
12
13
10
11
9
17
3
10
7
10
5
2
6
7
2
3
2
4
0
Appendix C: Department of Defense Sites
Page C-12
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit C-4: Frequency of Matrices by DOD Site Type (Continued)
No. of Sites Ground- Surface
Site Type with Data water Soil Water Sediment
Small Arms Range
Building Demolition/Debris Removal
Plating Shop
Surface Runoff
Dip Tank
Pistol Range
Sewage Effluent Settling Ponds
Total
22
22
16
14
11
9
5
6,119
7
6
16
8
3
3
5
3,846
20
20
15
9
11
8
4
4,699
1
1
2
4
0
0
1
938
2
2
2
4
0
2
1
1,127
Notes: The numbers in this table represent only those sites for which media data is available. The total count for a site type may
exceed the number of sites with data for the site type because a site may have more than one contaminated matrix. The
total includes 1 DTRA site.
Source: OD, Office of the Deputy Under Secretary of Defense (Installations & Environment), Restoration Management Information
System (RMIS), Data as of September 2001 .
Appendix C: Department of Defense Sites
Page C-13
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit C-5: Frequency of Major Contaminant Groups
by Matrix and POD Component
Component
Army
Navy
Air Force
Contaminant
Group
VOCs
SVOCs
Metals
Other
Explosives and
Propellants
No Group Determined
VOCs & SVOCs
VOCs & Metals
SVOCs & Metals
VOCs, SVOCs, &
Metals
No. Sites with Data
VOCs
SVOCs
Metals
Other
Explosives and
Propellants
No Group Determined
VOCs & SVOCs
VOCs & Metals
SVOCs & Metals
VOCs, SVOCs &
Metals
No. Sites with Data
VOCs
SVOCs
Metals
Other
Explosives and
Propellants
No Group Determined
VOCs & SVOCs
VOCs & Metals
SVOCs & Metals
VOCs, SVOCs, &
Metals
No. Sites with Data
Ground-
water
696
410
724
345
124
0
74
197
90
180
1114
877
610
785
587
44
0
95
172
70
419
1096
1059
447
699
441
15
2
132
227
44
242
1321
Sediment
80
217
315
118
17
0
11
17
123
43
389
147
249
295
218
15
1
9
16
116
118
331
117
192
222
91
2
0
21
12
105
58
305
Soil
389
792
1135
340
142
0
63
61
362
188
1458
734
862
1043
638
49
7
81
84
268
397
1417
784
680
859
329
11
0
113
124
178
268
1385
Surface
Water
114
110
225
86
28
0
10
32
49
44
279
108
115
192
123
13
0
8
34
35
58
229
204
108
213
87
3
0
17
70
43
42
321
Total
All Media
900
1065
1447
672
234
0
140
279
519
331
1854
1240
1165
1341
930
90
8
169
269
418
649
1812
1458
947
1231
690
27
2
249
374
308
470
1945
% Sites
w/Data
49%
57%
78%
36%
13%
0%
8%
15%
28%
18%
68%
64%
74%
51%
1%
0%
9%
15%
23%
36%
75%
49%
63%
35%
1%
0%
13%
19%
16%
24%
Appendix C: Department of Defense Sites
Page C-14
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit C-5. Frequency of Major Contaminant Groups
by Matrix and POD Component (Continued)
Component Contaminant G round -
Group
DLA VOCs
SVOCs
Metals
Other
Explosives and
Propellants
No Group Determined
VOCs & SVOCs
VOCs & Metals
SVOCs & Metals
VOCs, SVOCs, &
Metals
No. Sites with Data
FUDS VOCs
SVOCs
Metals
Other
Explosives and
Propellants
No Group Determined
VOCs & SVOCs
VOCs & Metals
SVOCs & Metals
VOCs, SVOCs &
Metals
No. Sites with Data
Total DOD VOCs
SVOCs
Metals
Other
Explosives and
Propellants
No Group Determined
VOCs & SVOCs
VOCs * Metals
VOCs, SVOCs &
Metals
No. Sites with Data
water
21
5
8
6
0
0
4
5
0
1
23
211
119
207
87
25
0
33
68
18
63
292
2864
1591
2423
1466
208
2
338
669
905
3846
Sediment Soil
2
9
2
1
0
0
2
0
1
0
10
29
51
79
23
4
0
2
4
36
21
91
375
718
913
451
38
1
45
49
240
1126
16
33
52
8
1
0
1
3
20
6
65
181
208
295
99
31
0
31
41
76
81
373
2104
2575
3384
1414
234
7
289
313
940
4698
Surface
Water
1
1
4
1
0
0
0
1
1
0
4
33
34
93
26
7
0
2
11
22
13
104
460
368
727
323
51
0
37
148
157
937
Total % Sites
All Media w/Data
33
41
59
15
1
0
7
8
22
7
80
290
263
337
155
45
0
57
110
117
123
427
3921
3481
4415
2462
397
10
622
1040
1580
6118
41%
51%
74%
19%
1%
0%
9%
10%
28%
9%
68%
62%
79%
36%
11%
0%
13%
26%
27%
29%
64%
57%
72%
40%
6%
0%
10%
17%
26%
Notes:
• FUDS = Formerly Used Defense Sites; DLA - Defense Logistics
Agency; VOCs - Volatile
Organic Compounds;
SVOCs = Semivolatile Organic Compounds.
• The total amount for a matrix or contaminant groups
may exceed the number
of sites with
data, because
a site
may have more than one contaminant group or contaminated matrix.
•
Source: DOD, Office of the Deputy Under
Management Information System (RMIS),
Secretary
of Defense
(Installations
& Environment), Restoration
data as of September 2001 .
Appendix C: Department of Defense Sites
Page C-15
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit C-6: Frequency of Major Contaminant
Groups by POD Site Type
No. of Explosives
Site Type Total No. Sites VOCs Metals SVOCs Other & No Group
of Sites w/Data Propel lants Determined
Spill Site Area
Landfill
Underground Storage
Tanks
Other
Unexploded Munitions
and Ordnance Area
Surface Disposal Area
Storage Area
Contaminated
Groundwater
Disposal Pit and Dry Well
Fire/Crash Training Area
Surface
Impoundment/Lagoon
Aboveground Storage
Tank
Explosive Ordnance
Disposal Area
Burn Area
Contaminated Buildings
Building
Demolition/Debris
Removal
Contaminated Sediments
POL
(Petroleum/Oil/Lubricants)
Lines
Firing Range
Contaminated Fill
Industrial Discharge
Storm Drain
Waste Lines
Chemical Disposal
Soil Contamination After
Tank Removal
Maintenance Yard
Underground Tank Farm
Waste Treatment Plant
Oil/Water Separator
Drainage Ditch
Sewage Treatment Plant
Small Arms Range
Mixed Waste Area
Washrack
1,107
974
840
734
588
563
477
418
414
249
174
167
163
159
156
151
150
137
104
99
91
88
87
80
80
78
78
76
53
44
44
43
41
41
874
850
459
121
54
512
417
321
352
208
156
106
91
146
145
22
132
103
23
85
79
63
76
67
57
68
66
68
45
38
34
22
32
36
619
535
408
75
26
289
215
271
231
178
83
77
26
82
53
4
52
89
5
46
44
47
42
32
48
50
64
40
35
19
20
4
17
23
478
748
219
90
47
402
300
203
273
168
142
60
79
120
111
20
110
56
21
67
55
46
65
54
33
44
40
56
35
26
24
22
27
30
462
516
213
74
34
282
266
143
208
153
95
53
53
99
101
16
87
63
8
54
56
28
43
18
31
34
43
48
26
22
18
4
21
19
274
444
130
45
28
225
161
127
154
118
90
27
35
68
43
11
57
30
7
25
31
32
31
16
22
31
18
31
22
9
8
8
16
13
35
45
4
12
18
25
10
15
14
7
34
3
33
41
25
2
12
2
2
2
18
0
10
5
2
0
0
6
0
3
0
0
0
1
0
1
1
0
0
0
2
0
0
1
0
0
0
0
0
0
0
0
0
0
2
1
1
0
0
0
0
0
0
0
0
0
0
0
Appendix C: Department of Defense Sites
Page C-16
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit C-6: Frequency of Major Contaminant Groups
by POD Site Type (Continued)
No. of Explosives
Site Type Total No. Sites VOCs Metals SVOCs Other & No Group
of Sites w/Data Propel lants Determined
Radioactive Waste Area
Contaminated Soil Piles
Leach Field
Incinerator
Pesticide Shop
Plating Shop
Surface Runoff
Dip Tank
Pistol Range
Sewage Effluent Settling
Ponds
TOTAL
39
37
35
29
25
17
17
11
11
5
8,974
23
35
28
27
23
16
14
11
9
5
6,119
4
11
12
7
8
12
8
5
1
4
3,921
8
31
22
21
16
16
9
10
9
2
4,415
7
15
12
8
21
9
9
4
2
3
3,481
20
12
8
7
8
12
3
3
2
1
2,463
1
2
1
3
1
1
1
0
0
1
397
0
0
1
0
0
0
0
0
0
0
10
Notes a Number of sites needing remediation; data were available for 6, 119 of the sites needing remediation, including
1 DTRAsite.
POL = petroleum, oil, lubricant
The total count for a site type may exceed the number of sites with data for the site type, because a site may have
more than one contaminant group.
Source: DOD, Office of the Deputy Under Secretary of Defense (Installations & Environment), Restoration Management
Information System (RMIS), data as of September 2001 .
Appendix C: Department of Defense Sites
PageC-17
-------
Exhibit C-7. Frequency of Contaminant Subgroup by Matrix
Percent of Sites With Data
Ground- GW Sediment Sediment Soil Soil Surface SW
Contaminant Sub Group water % % % Water %
Metals
Halogenated VOCs
BTEX
Miscellaneous Inorganic Elements and Compounds
(Misc. Organics)
Non-halogenated VOCs
Non-halogenated SVOCs
Polynuclear Aromatic Hydrocarbons (PAHs)
Pesticides
Phenols
Halogenated SVOCs
Explosives and Propellants
Polychlorinated biphenyls (PCBs)
Radioactive Materials
Other
Other Organic (Coal Tar, Creosote)
No Group Determined
2423
2151
1465
1418
1307
847
638
458
315
288
208
84
46
18
10
2
63.00
55.93
38.09
36.87
33.98
22.02
16.59
11.91
8.19
7.49
5.41
2.18
1.20
0.47
0.26
0.05
913
211
151
449
263
242
445
369
84
58
38
165
3
2
4
1
81.01
18.72
13.40
39.84
23.34
21.47
39.49
32.74
7.45
5.15
3.37
14.64
0.27
0.18
0.35
0.09
3384
1052
1218
1361
1282
973
1450
988
218
214
234
602
42
25
6
7
72.02
22.39
25.92
28.96
27.28
20.71
30.86
21.03
4.64
4.55
4.98
12.81
0.89
0.53
0.13
0.15
727
333
144
316
184
189
80
147
62
27
51
29
6
1
4
0
77.51
35.50
15.35
33.69
19.62
20.15
8.53
15.67
6.61
2.88
5.44
3.09
0.64
0.11
0.43
0.00
Notes: VOC = Volatile Organic Compound; SVOC - Semivolatile Organic Compound; BTEX = Benzene, Toluene, Ethylbenzene, Xylenes;
Data were available for 6,1 19 sites
Source: DOD, Office of the Under Secretary of Defense (Installations & Environment), Restoration Management Information System (RMIS), data
as of September 2001.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Appendix D
Supporting Data for Analysis of
Manufactured Gas Plant Sites
Appendix D. Supporting Data for Manufactured Gas Plant Sites Page D-1
-------
Exhibit D-1. Estimated Disposition of Former Manufactured
Gas Plants & Other Coal Tar Sites in the U.S.
Site Type a
Commercial MGPs
District Gas
Holders
Rail Yard Pintsch
Oil-Gas Plants
Military Gas Plants
Ice & Refrigeration
Plants w/Gas
Producer
Institutional Gas
Machines
Domestic/Residen-
tial Gas Machines
Captive Gas
Producers -
Pressure & Suction
Bottled Gas Plants
Kerosene Refiners
Compressed Fuel
Briquette Plants
Beehive Coke
Works
Number of Sites
Sites Sites Instate Studied Not Yet
Original With Previously Cleanup and Rem- Inves-
Sites Releases NFRAPD" Program ediated tigated
3,500
500-
1,500
100-150
150-250
200-400
5,000-
10,000
10,000-
15,000
11,000-
15,000
100
100-150
100
2,000-
4,000
3,500
500-1,500
100-150
150-250
150-300
2,500-
5,000
10,000-
15,000
11,000-
15,000
50
100-150
50
2,000-
4,000
<700
25-75+
<5-7
0
7-15
125-250
0
<550-750
0
<5-7
0
<1 00-200
>175
0
<5-7
0
0
0
0
0
0
0
0
0
<350
<25-75
<5-7
0
0
0+
<200-300
<550-750
<2
<2-3
0
<1 00-200
2,275+
450-
1,350+
>85-129
150-250-
143-285
2,375-
4,750
9,800-
14,700+
9,900-
13,500
50
93-140+
50
>1,800-
3,600
Estimated Current Land Use of Site
Industrial/ Resi- Recrea-
Commercial dential tional Vacant
2,450
300-900+
85-127+
120-200+
90+
>75
0
>8,800-
12,000
>80
>90-135
>95
200-400
350
75-225
<5-7
<7-12
<5
<10
9,000-
13,500
<550-
750
<5
<5-7
0
100-
200
350
75-225
<5-7
<15-25
0+
<5
<500-
750
<550-
750
<5
0+
0
100-200
350
<50-150
<5-7
<7-12
<5
5
500-750
1,100-
1,500
10
10-15
<5
1,400-
2,800
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Exhibit D-1. Estimated Disposition of Former Manufactured
Gas Plants & Other Coal Tar Sites in the U.S. (Continued)
Site Type a
Merchant & Utility
Coke Works
Charcoal Plants
Tar Distilleries
WWI Federal
Wood Tar
Distillation Plants
WWI Federal
Toluene Plants
Wood Preservation
Plants
U.S. BOM Coal
Gasification Plants
U.S. DOE Coal
Gasification Plants
Total
Number of Sites
Sites Sites in State Studied Sites Not
Original With Previously Cleanup and Rem- Yet Inves-
Sites Releases NFRAPD" Program ediated tigated
250-300
2,000-
3,000
200-400
11
10
800-
1,000
37-55
63-75
36,121-
55,001
250-300
2,000-
3,000
200-400
11
10
800-1,000
37-55
63-75
33,471-
49,801
25-30
<1 00-1 50
20-40
0
0
240-300
2-3
3-4
1,907-
2,531
25-30
0
10-20
0
0
<80-100
2-3
3-4
300-339
75-90
<1 00-1 50
10-20
<5
<5
<40-50
0
0
1,469-
2,007
125-150
1,800-
2,700
160-320
6
5
440-550
33-49
57-67
29,975-
44,926
Estimated Current Land Use of Site
Industrial/ Resi- Recrea-
Commercial dential tional Vacant
225-285
900-1,350
160-320
95
95
640-800
17-25
28-34
14,545-
19,556
0
100-
150
10-20
<5
<5
40-50
0
0
10,272-
15,300
0
100-150
10-20
<5
<5
40-50
0
0
1,765-
2,547
<12-15
900-
1,350
20-40
<5
<5
80-100
17-25
28-34
4,509-
7,291
Notes: Volume of releases includes present-day bodies of contaminated soil in the subsurface, not otherwise visible at ground surface
a See Exhibit 10-1 for definitions
b No Further Remedial Action Planned
Source: Allen W. Hatheway, "Estimated Number of Manufactured Gas and Other Coal-Tar Sites in the United States," Environmental Engineering
Geoscience, Vol. Ill, No. 1, Spring 1997, pp. 141-142 and personal communication with the author, February-March 2003. The data are based
on Dr. Hatheway's database on MGPs which includes information on approximately 7,000 sites, assembled from Brown's Directory of North
American Gas Plants, historic gas industry literature, Sandborn Fire Insurance maps, state agencies, and direct on-site observations.
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit D-2
Estimated Typical Remediation Cost by Site Type
Typical Ave.
Number of Sites Contaminants Remediation
Range of Site Not Investigated &Contaminated Release Cost Per Site
Site Type Size Media a Volume Per ($ Millions)
Site (000) b
Commercial
MGPs
District Gas
Holders
Rail Yard Pintsch
Oil-Gas Plants
Military Gas
Plants
lce&
Refrigeration
Plants with Gas
Producers
Institutional Gas
Machines
Domestic
Residential Gas
Machines
small - 1-3 acres
medium - 3-10
acres
large- 10-100
acres
1 -4 acres
0.5-1.5 acre
0.5-1.5 acre
1 -2 acres
500-1 500 ft2
400-1 000 ft2
2,275+
450-1350+
95-142
1 50-250
147-294
2,450-4,900
9,800-14,700
Soil: Tars stored in
subsurface vessels
or discharged to
surface/subsurf.
Spent Box Waste.
PAH- cont. solid
waste.
Soil: Leaks in
below-ground
holders. Tars in
abandoned
subsurface.
Holder tanks -
basins pits.
Soil: Dumped
sludge & lampblack
Soil: Tars stored in
subsurface vessels
and discharged to
surface/subsurf. .
Spent Box Waste.
PAH - cont. solid
waste.
Soil: Tars stored in
subsurface vessels
and discharged to
surface/subsurf.
Soil
Soil
2,000-50,000
m3
1 00-500 m3
500-1 0,000m3
500-1,000 m3
500-1,000 m3
<100m3
<50m3
small -3. 0-5.0
medium - 4.0 -
10.0
large- 10.0-
100.0
0.25-1.5
0.5-5.0
1.0-4.0
0.5- 1.5
0.2-0.75
0.05
Appendix D. Supporting Data for Manufactured Gas Plant Sites
Page D-4
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit D-2
Estimated Typical Remediation Cost by Site Type (Continued)
Typical Release Ave.
Number of Sites Contaminants Volume Remediation
Range of Site Not Investigated &Contaminated Per Site (000) b Cost Per Site
Site Type Size Media a ($ Millions)
Captive Gas
Producers
(Pressure &
Suction)
Bottled
Manufactured
Gas Plants
Kerosene
Refiners
Compressed
Fuel Briquette
Plants
Beehive Coke
Works
Merchant &
Utility Coke
Works
20/30 to 50x600
ft
1 -3 acres
1 -2 acres
1 -2 acres
40-1 00 acres
40-1 00 acres
10,450-14,250
50
95-142
50
1,900-3,800
100-120
Soil: Tars stored in
subsurface vessels
and discharged to
surface/subsurf.
Spent Box Waste.
PAH cont. solid
waste.
Soil: Tars stored in
subsurface vessels
& discharged to
surface/subsurf.
Spent Box Waste.
Soil: Tars stored in
subsurface vessels
& discharge to
surface/subsurf..
Filtration sludges
from recovery
Soil: Tars stored in
subsurface vessels
& discharged to
surface/subsurf..
Coal, coke,
lampblack, fines
secondarily cont.
w/PAH.
Tar &/or light oil in
soil. PAH-cont.
solid waste.
Soil: Tars stored in
subsurface vessels
& discharged to
surface/subsurface
Spent Box Waste.
PAH-contaminated
solid waste.
100-1 0,000m3
1 00-500 m3
100-1 ,000m3
100-1 ,000m3
1,000-10,000
m3
5,000-100,000
m3
1.0-10.0
0.2-0.5
1.0-5.0
0.5- 1.0
0.5-2.0
10.0-100.0
Appendix D. Supporting Data for Manufactured Gas Plant Sites
Page D-5
-------
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit D-2
Estimated Typical Remediation Cost by Site Type (Continued)
Typical Ave.
Number of Sites Contaminants Remediation
Range of Site Not Investigated &Contaminated Release Cost Per Site
Site Type Size Media a Volume ($ Millions)
Per Site (000) b
Charcoal Plants
Tar Distilleries
WWI Federal
Wood Tar
Distillation
Plantsc-d
WWI Federal
Toluene Plantscd
Wood
Preservation
Plants
10-100 acres
10-1 00 acres
40-200 acres
80-200 acres
10-200 acres
1,900-2,850
150-300
11
10
480-600
Tars and/or light oil
in soil.
PAH-contaminated
solid waste.
Soil: Tars stored in
subsurface vessels
& discharged to
surface/subsurf.
Filtration sludges
from recovery
process.
Soil: Tars stored in
subsurface vessels
& discharged to
surface/subsurf.
Filtration sludges
from recovery
process.
Soil: Tars stored in
subsurface vessels
& discharged to
surface/subsurf.
Filtration sludges
from recovery
process.
PAH-contaminated
solid waste.
Soil: Tars stored in
subsurface
vessels,
discharged to
surface/subsurf, or
in abandoned
lagoons;
PAH-contaminated
solid waste.
1,000-5, 000m3
1,000-100,000
m3
1,000-10,000
m3
1,000-10,000
m3
1,000-10,000
m3
0.5-2.0
10.0-100.0
1.01 -2.0
1.0-5.0
5.0-20.0
Appendix D. Supporting Data for Manufactured Gas Plant Sites
Page D-6
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Exhibit D-2
Estimated Typical Remediation Cost by Site Type (Continued)
Site Type
Range of Site
Size
Number of Sites
Not Investigated
Typical
Contaminants
&Contam mated
Media a
Release
Volume
Per Site (000)!
Ave.
Remediation
Cost Per Site
($ Millions)
U.S. Bureau of
Mines -
Coal Gasification
Plants'
U.S. Department
of Energy - Coal
Gasification
Plants0
1 0-40 acres
1 0-40 acres
33-49
57-67
Soil: Tars stored in
subsurface
vessels. Tars
discharged to
surface/subsurface
PAH-contaminated
solid waste.
Soil: Tars stored in
subsurface
vessels. Tars
discharged to
surface/subsurface
PAH-contaminated
solid waste.
500-1,000 m3
500-1,000 m3
1.0-2.0
1.0-2.0
Assumptions:
• Cleanup cost estimates are inferred from sites that have been fully characterized, based on knowledge of actual site operation
history and reasonable exploration of depth and breadth of subsurface conditions reflecting the presence of MGP residuals.
• Estimates do not consider the presence of post-operational contaminants not typically associated with MGP operations.
Estimates do not reflect the costs of litigation judgements involving human health and gas works hazardous or toxic residuals at
sites.
It is assumed that 35% of the commercial plants are small, 35% are medium, and 30% are large, and that the average high-
estimate costs for these size groups are $4 million, $7 million, and $13 million, respectively.
Footnotes:
a This table includes nominal groundwater contamination primarily associated with LNAPLs. It does not include solids lodged in
the matrix of an aquifer (DNAPLs). Sites with solids lodged in the aquifer are difficult to predict, highly site specific, and
potentially very costly to remediate.
b Volume of releases consider only highly-contaminated soil requiring direct or indirect treatment on site or placement in a RCRA
Class C facility. Other more lightly contaminated soils are expected to be present and possibly subject to placement in a RCRA
Class D facility.
c Estimates are based on analogous sites.
d These plants were constructed as a WWI emergency measure. Some were barely operational at war's end. Others were
operated after the war for commercial purposes and will bear higher remediation costs.
Appendix D. Supporting Data for Manufactured Gas Plant Sites
Page D-7
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Appendix D. Supporting Data for Manufactured Gas Plant Sites Page D-8
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Appendix E
Federal and State Agency Programs
Appendix E. Federal and State Agency Programs Page E-1
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
State and Federal Agency Contacts
EPA Regional Offices
EPA Region 1 (ME, NH, VT, MA, RI, CT)
http://www.epa.gov/regionO I/
EPA Region 2 (NY, NJ, PR, VI).
http ://www. epa.gov/Region2/
Region 3 (PA, DE, DC, MD, VA, WV).
http ://www. epa.gov/region03/
EPA Region 4 (KY, TN, NC, SC, MS, AL,
GA, FL). http://www.epa.gov/region4/
EPA Region 5 (MN, WI, IL, MI, IN, OH).
http ://www. epa.gov/Region5/
EPA Region 6 (MM, TX, OK, AR, LA).
http ://www. epa.gov/earth 1 r6/
EPA Region 7 (ME, KS, IA, MO).
http ://www. epa.gov/region07/
EPA Region 8 (MT, ND, WY, SD, UT,
CO), http://www.epa.gov/region08/
EPA Region 9 (CA, NV, AZ, HI).
http ://www. epa.gov/region09/
EPA Region 10 (WA, OR, ID, AK).
http ://www. epa.gov/r 1 Dearth/
State Agencies
Links to U.S. states and territories
http ://www. epa.gov/epaoswer/osw/stateweb.
htm
RCRA State Authorizaton Status
http://www.epa.gov/epaoswer/hazwaste/stat
e/stats/stats_by state. htm
UST State and Territory Program Directory
http ://www. epa.gov/swerust 1 /state s/statcon 1
.htm
Appendix E. Federal and State Agency Programs
Page E-2
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Civilian Federal Agencies
Department of Agriculture
http://www.nrcs.usda.gov/
Agricultural Research Service
http://www.ars.usda.gov/
U.S. Forest Services
http://www.fs.fed.us/
National Resources Conservation Service
http://www.nrcs.usda.gov
United States Geological Survey
http: //toxics. usgs. gov/topics/remediation. html
Department of Interior
National Park Service
http://www.nps.gov/
Fish and Wildlife Service
http: //www. fws. gov/
Bureau of Land Management
http: //www. blm. gov/nhp/index. htm
Office of Surface Mining
http://www. osmre.gov/
Bureau of Reclamation
http: //www. usbr. gov/main/index. html
Bureau of Indian Affairs
http://www.doi.gov/bureau-indian-affairs.html
Office of Environmental Policy and
Compliance
Solid and Hazardous Materials
Management Team
http: //www. doi.gov/oepc/shazmat. html
Natural Resource Damage Assessment and
Restoration Program
http: //restoration, doi. gov/
United States postal Service
http: //www. usps. com/
National Aeronautics and Space
Administration (NASA)
http: //www. hq. nasa.gov/office/codej/codej e/j e
_site/about_us/about_us.html
Tennessee Valley Authority
http: //www. rva. gov/environment/envservices/i
ndex.htm
Department of Transportation
http: //www. dot. gov/
Department of the Treasury
http: //www. treas. gov/
Department of Veterans Affairs
http://www.va.gov/
Appendix E. Federal and State Agency Programs
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Appendix E. Federal and State Agency Programs Page E-4
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
Appendix F
Acronyms
ACSIM
A&E
AFCEE
AFSBED
ANPR
ARARs
ASTM
ASTSWMO
ATSDR
BCP BRAC
BCT BRAC
BEMR
BLM
BRAC
BTEX
CA
CA RCRA
CAMU
CBO
CERCLA
CERCLIS
CERFA
CFAs
CFR
CHF
CHP
CIC
CID
CLU-IN
CMI
CMS
CSM
CRADA
CWA
D&D
DERA
DERP
DLA
DNAPL
DOD
DOE
DOI
DOT
DQO
ORE
Assistant Chief of Staff for Installation Management (DOD)
Architectural and Engineering
Air Force Center for Environmental Excellence
Air Force Small Business Environmental Database
Advanced Notice of Public Rulemaking
Applicable or relevant and appropriate requirements
American Society of Testing Materials
Association of State and Territorial Solid Waste Management Officials
Agency for Toxic Substances and Disease Registry
Cleanup Plan
Cleanup Team
Baseline Environmental Management Report
Bureau of Land Management
Base Realignment and Closures
Benzene, Toluene, Ethylbenzene, and Xylene
Cooperative Agreement
Corrective Action Program under the Resource Conservation and Recovery Act
Corrective Action Management Unit
Congressional Budget Office
Comprehensive Environmental Response, Compensation, and Liability Act
CERCLA Information System
Community Environmental Response Facilitation Act
Civilian Federal Agencies
Code of Federal Regulations
Central Hazardous Materials Fund (DOI)
Central Hazardous Materials Fund
Community Involvement Coordinator
Central Internet Database (DOE)
Clean-Up Information System
Corrective Measures Implementation (RCRA)
Corrective Measures Study (RCRA)
Conceptual Site Model
Cooperative Research and Development Agreement (DOE)
Clean Water Act
Deactivation and Decommissioning
Defense Environmental Restoration Account
Defense Environmental Restoration Program
Defense Logistics Agency
Dense Non-Aqueous Phase Liquid
Department of Defense
Department of Energy
Department of Interior
Department of Transportation
Data Quality Objectives
Destruction and Removal Efficiency
Appendix F: Acronyms
Page F-1
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
DSMOA
DTRA
BBS
ECR
EM
EMSP
EOU
EPA
ERRS
ESTCP
FAA
FR
FRTR
FUDS
FUSRAP
FY
GAC
GAO
GPRA
GWRTAC
HMMA
HMMP
HMPC
HRS
HSWA
HWIR-Media
Defense and State Memorandum of Agreement
Defense Threat Reduction Agency
Environmental Baseline Survey
Environmental Compliance and Restoration Program (NASA)
Environmental Management
Environmental Management Science Program
Excess, Obsolete or Unserviceable
Environmental Protection Agency
Emergency and Rapid Response Services
Environmental Security Technology Certification Program
Federal Aviation Administration
Federal Register
Federal Remediation Technologies Roundtable
Formerly Used Defense Sites
Formerly Utilized Sites Remedial Action Program
Fiscal Year
Granulated Activated Carbon
General Accounting Office
Government Performance and Results Act
Groundwater Remediation Technologies Analysis Center
Hazardous Materials Management Appropriations
Hazardous Materials Management Program (USDA)
Hazardous Materials Policy Council (USD A)
Hazard Ranking System (Superfund)
Hazardous and Solid Waste Amendments of RCRA
Hazardous Waste Identification Rule - Media
IAG
IRP
LDRs
LM
LNAPLs
LTTD
LUSTs
MAP
MCL
MGP
MMRP
MNA
MTBE
MTRs
MWTP
NABIR
NACEPT
NAPLs
NASA
NAVFAC
NCP
Interagency Agreement
Installation Restoration Program (DOD)
Land Disposal Restrictions
Office of Legacy Management (DOE)
Light Non-Aqueous Phase Liquids
Low Temperature Thermal Desorption
Leaking Underground Storage Tanks
Management Action Plan
Maximum Contaminant Level
Manufactured Gas Plant
Military Munitions Response Program
Monitored Natural Attenruation
Methyl Tertiary-butyl Ether
Minimum Technology Requirements
Mine Waste Technology Program
Natural and Accelerated Bioremediation Research Program
National Advisory Council for Environmental Policy and Technology
Non-Aqueous Phase Liquids
National Aeronautics and Space Administration
Naval Facilities Engineering Command
National Oil and Hazardous Substances Contingency Plan
Appendix F: Acronyms
Page F-2
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
NELP
NEPA
NETAC
NETL
NETTS
NFESC
NFRAP
NMLRC
NPDES
NPL
NTIS
O&M
OB
OD
ODUSD (I&E)
OERR
OPA
ORD
OSM
OSMRE
OSW
OSWER
OU
OUST
PA
PAHs
PCBs
PCE
PFP
POL
PRP
P&T
RA
RAB
RACS
RAP
RBCA
RC
RCAID
RCRA
RCRACA
RD
RD&D
RFA
RFI
RFP
RIA
RI/FS
RIP
RIS
RMIS
ROD
Naval Environmental Leadership Program
National Environmental Policy Act
National Environmental Technologies Applications Center
National Energy Technologies Laboratory
National Environmental Technology Test Sites Program
Naval Facilities Engineering Service Center
No Further Action Planned
National Mine Land Reclamation Center
National Pollutant Discharge Elimination System
National Priorities List
National Technical Information Services
Operations and Maintenance
Open Burn
Open Detonation
Office of Deputy Undersecretary of Defense (Installations & Environment)
Office of Emergency and Remedial Response
Oil Pollution Act
Office of Research and Development
Office of Surface Mining
Office of Surface Mining Reclamation and Enforcement
Office of Solid Waste
Office of Solid Waste and Emergency Response
Operable Unit
Office of Underground Storage Tanks
Preliminary Assessment
Polynuclear Aromatic Hydrocarbons
Polychlorinated Biphenyls
Perchloroethylene
Pay for Performance
Petroleum, Oil, and Lubricants
Potentially Responsible Party
Pump and Treat
Remedial Action
Restoration Advisory Board
Remedial Action Contracting Strategy
Remedial Action Plan
Risk-Based Corrective Action
Response Complete (DOD)
RCRA Action Implementation Database
Resource Conservation and Recovery Act of 1976
RCRA Corrective Action Program
Remedial Design
Research, Development and Demonstrations
RCRA Facility Assessment
RCRA Facility Investigation
Request for Proposals
Regulatory Impact Analysis
Remedial Investigation and Feasibility Study
Remedy In Place (DoD)
RCRA Implementation Study
Restoration Management Information System (DOD)
Record of Decision
Appendix F: Acronyms
Page F-3
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Cleaning Up the Nation's Waste Sites: Markets and Technology Trends
RP
RPM
RTDF
SARA
SBIR
SCRD
SERDP
SI
SITE
S&M
SMCRA
s/s
StATS
STTR
SVE
SVOC
SWMU
TCE
TIO
T&M
TRU
TSDF
TJMTRA
USAGE
USAEC
USDA
USFS
USGS
UST
UV
UXO
VCP
VEB
voc
WFO
WMM
Responsible Party
Remedial Project Manager
Remediation Technologies Development Forum
Superfund Amendment and Reauthorization Act of 1986
Small Business Innovation Research
State Coalition for Remediation of Drycleaners
Strategic Environmental Research and Development Program
Site Inspection
Superfund Innovative Technology Evaluation
Surveillance and Maintenance
Surface Mining Control and Reclamation Act
Solidification/Stabilization
State Authorization Tracking System
Small Business Technology Transfer
Soil Vapor Extraction
Semi-Volatile Organic Compound
Solid Waste Management Unit
Trichloroethylene
Technology Innovation Office
Time and Materials
Transuranic
Treatment, Storage, and Disposal Facility
Uranium Mill Tailings Remedial Action
United States Army Corps of Engineers
United States Army Environmental Center
United Department of Agriculture
United States Forest Service
United States Geological Survey
Underground Storage Tanks
Ultraviolet
Unexploded Ordnance
Voluntary Cleanup Program
Vertical Engineered Barrier
Volatile Organic Compound
Work for Others
Waste Military Munitions
Appendix F: Acronyms
Page F-4
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