-------
These substitutions yield the following dimensionless equation
                                                                                                                            (8)
        Y  + XY +
                                                           (4)
 -2   slnh(mrN(l-X))sln(mtY)sln(n*B)

(n7°2             sinh(nirN)
                                                                 Solving for *jj yields
Numerical Flow Model
  The next step in the research was to develop a numerical model
for calculating the dimensionless streamline distribution and incor-
porating flexibility to handle situations other than that depicted in
Figure 1. The model was calibrated with the analytical solution
developed above.
  The governing  equation for groundwater  flow  through an
anisotropic, homogeneous media is
                   S2f
                       + K
                                                                             KAY2
                                                                      2(KAyz+Ax2)
                                                                                          ,+*,
                                                                                             ' 1+1,1  Ti-l,j)
                                                                                                                        (9)
                                                                This equation can  be programmed on  a  computer  using  an
                                                              iterative alternating direction solution procedure to converge upon
                                                              the solution for *jj at the nodes of an artificial grid representing
                                                              the 2-dimensional aquifer. The program can  calculate a value of
                                                       (5)    *iC,T for nocle (i>J)bv Usin8its four surrounding nodes. A new value
                                                              of * for node (i,j) is calculated by a relaxation equation of the form
 where
   Kx =  hydraulic conductivity in the x-direction
   Ky =  hydraulic conductivity in the y-direction
 Dividing both sides of the equation by Ky and remembering that
 = */*o, X  = x/s and Y = y/d, yields
                                                                               old
 Letting K = Kx/Ky (d/s)2 be the aspect ratio, yields
                  contaminated recharge (C0,c)
                                                           (6)
                                                           (7)
        //////  s  / /  /  / / / / s /
                           Figure 1
           Hypothetical aquifer-barrier system subjected to
                steady-state contaminated recharge
                                                                       i.j
      calc   _ old
           - y     }
      >   .    T  .  . /
                                                                                                                       (10)
                                                                The relaxation factor accelerates the convergence of the method.
                                                              A convergence criterion of 0 was input to the model to increase ac-
                                                              curacy. So, the process is controlledjpy an iteration limit (ITER =
                                                              30) The end result is a dimensionless * distribution for all the nodes
                                                              in the grid.
                                                              SOLUTE TRAVEL TIME UTILIZING
                                                              PLUG FLOW ANALYSIS
                                                                Development  of pollutant  breakthrough  curves  can  be  ac-
                                                              complished by considering the kinematics of the flow field in Figure
                                                              1 as was done by McLin.2 This type of analysis ignores  the effects
                                                              of dispersion and inherently assumes that vertical flow effects can
                                                              be ignored  for the elongated (width/depth ratio  ^ 4) aquifer.  In
                                                              essence, the assumption is that the contaminated recharge travels as
                                                              "plugs"  (Figure  2).  By definition,  the   flow between  two
                                                              streamlines must remain  constant. The time  for a particle  to flow
                                                              from one point (sj) to another (82 is equal to the volume of water in
                                                              the  flow field divided by the volumetric flow rate. Using a unit
                                                              dimension in the third direction, the time becomes equal  to the area
                                                              of flow divided by the areal flow rate.  From Figure 2 this time can
                                                              be expressed by
                                                                                                                          (ID
                                                              where Q = d*
                                                                Using the  following substitutions to non-dimensionalize the
                                                              equation:

                                                                A0 =  SD, the cross section of the aquifer,
                                                                *0 =«S,
                                                                e = recharge rate,
                                                              A(*) =  A(*)/A0, a dimensionless area, and
                                                                ^ =  i'/'i'o, a dimensionless streamline
                                                              yields
   The continuous derivatives of the above equation can be replaced
 by their finite difference approximations. This yields
                                                                   nSDdA(f)

                                                                    eSd?
C/tc
(12)
 180
          BARRIERS

-------
where tc =  n D/e is defined as the solute response time for the
aquifer. If the numerical model can generate the distribution of the
dimensionless ¥, one can numerically integrate to determine the
relationship of* vs. A(^). The sjppe of this curve can then be deter-
mined to generate the dA(¥)/d* term needed.
                                                                   C/Co

                                                                   1.0 '
                           Figure 2
                    Illustration of plug flow

  If one considers the flow of the contaminant to be "plug flow"
as outlined in Figure 2, the outflow concentration can be generated.
If each of the stream tubes in Figure 2 carries one tenth of the con-
taminated recharge (e) at a concentration C0, then the average con-
centration of the outflow at any time will depend on the number of
stream  tubes that  have arrived  at the point  of  outflow.  More
specifically, if two of the stream tubes have arrived, the average
concentration C, at the point of outflow, will  be equal to 0.2C0.
The relationship in terms of an equation is

  C'/2C0 = *                                             (13)

Hence,   pollutant breakthrough curves  (C/C0 vs t/tQ) can  be
generated from the known distribution of * in  the aquifer.

Problem 1: Full Recharge, Varying Depths of
Penetration, Isotropic Soil

  The first, and probably the simplest, problem to be examined is
that of full length recharge and varying depths of penetration of the
barrier  in  a homogeneous,  isotropic aquifer.  Conceptually, this
situation is equivalent to placing a barrier  right next to a source of
contaminated recharge.
  Plotted in Figure 3 are the pollutant breakthrough curves for no
barrier and for two different depths of penetration of the barrier.
All three of the curves show a fictitious immediate response in the
form of a relative concentration (C/C0) increase. The curves also
show that as the depth of the barrier increases,  the initial response
of the system decreases. In  other words,  the two  "with barrier"
cases show a time lag before a dramatic response over that of the
"no barrier" case. The curves also show  that the "with barrier"
cases actually catch and then surpass the "no barrier" case in  terms
of relative concentration.
  The time lag for the "with barrier" cases can be explained by ex-
amining the ¥ distributions under the barrier (Figure 4). As might
be expected, the placement of a barrier significantly increases the
flow distance for the  near streamlines. The far streamlines are af-
fected less by placement of the barrier.  The increase in flow path
distances explains the time lag seen in Figure 3.
  The  reason  for the  deeper barrier actually overtaking  the
shallower barrier and the no barrier cases in terms of relative con-
centration  over  time can be  explained  by the spacing of  the
                                                                                             Figure 3
                                                                    Pollutant breakthrough curves for aquifer subjected to full recharge
                                                                                             Figure 4
                                                                       Streamline distributions for 50% and 90% penetration barrier
                                                                  streamlines around the  opening in the  barrier in  Figure 4. The
                                                                  Cauchy-Riemann conditions state that velocity (specific discharge)
                                                                  vectors are proportional to the rate  of change of *  in the or-
                                                                  thogonal direction.
t«*    and
 «y
Y  a IT  O»
 y    y 6x
                                                                                                                           (14)
                                                                    Since the streamlines  are closely spaced near the opening, the
                                                                  velocities in both directions are increasing.  Notice that, for the
                                                                  deeper barrier, the velocity gradient around the opening is steeper
                                                                  and its effects are felt further into the aquifer. Although the travel
                                                                  distances for the deep harrier are increased, the contaminant is ac-
                                                                  tually subjected to a more intense velocity gradient and,  as such,
                                                                  will overtake the cases of shallow or no barrier  with their mild
                                                                  velocity gradients. Flow in the deep barrier case overtakes the other
                                                                  cases  at  a relative concentration of about  0.4 (Figure  3). This
                                                                  phenomenon may or may not be significant depending on what
                                                                  relative concentration is considered critical. This critical concentra-
                                                                  tion will be pollutant specific.
                                                                  Problem 2: Variable Length of Recharge

                                                                    One of the variations imposed on the aquifer was changing the
                                                                  length of the recharge area.  A comparison was made for full
                                                                  recharge and recharge over the outer 3/4, 1/2  and 1/4 of the
                                                                  aquifer.  Conceptually, this is equivalent to placing the barrier
                                                                  downgradient from a source of contaminated recharge.
                                                                                                          BARRIERS
                                                                                                                            181

-------
  Note that although moving the barrier further away from the
source of recharge provides a greater initial time lag, this increased
lag can only be attributed to the increased travel distance and not to
the performance of the barrier. The effectiveness  of the barriers is
diminished by placing them downgradient. Plotted in Figure 5 are
the pollutant breakthrough curves for the deep barrier for the four
different lengths of recharge. Although the barrier placed furthest
downgradient  provides  the greatest  time lag,  it  actually has the
greatest rate of concentration increase and overtakes the  barrier
placed right next to the source at a relative concentration of about
0.7. The explanation for this phenomenon is that placement of a
barrier downgradient from the recharge allows the flow pattern to
become established before entering the area of influence of the bar-
rier.

Problem 3: Anisotropic Soil
   Another  variation  imposed  on   the  aquifer was to  place
anisotropic soils within the aquifer.  Two cases will be examined.
First, the soil  will be assumed to  be highly  conductive  in the
horizontal direction (Kj'^Ky). Conceptually, this is equivalent to
a highly stratified  soil, perhaps layers of sand and gravel between
layers of clay. The second case will be that of a  soil highly conduc-
tive  in the vertical direction  (Ky» KJ. Conceptually,  this is
equivalent to a highly fracured soil.
  C/Co

 1.0 -
                      -R«charg» Ow*r Outer 1/2


                      -R»crt»rgo Over Oul«r 1/4


                      	1	
                            Figure 5
      Pollutant breakthrough curves for 90% penetrating barrier
                    at variable recharge lengths
                           Figure 6
     Pollutant breakthrough curves for no-barrier and 90% barrier
                  in horizontally conductive soil
                                                                                    Figure 7
                                                                Pollutant breakthrough curves for no-barrier and 90%
                                                                   penetrating barrier in vertically conductive soil
                                                           The approach used was to apply an overall directional conduc-
                                                        tivity reflecting the ability of the soil to transmit water in that direc-
                                                        tion. Also, because the hydraulic conductivities for this model are
                                                        incorporated in an aspect ratio (K = (Kx/Ky)(D/S)2), only the ratio
                                                        of horizontal  conductivity  to vertical conductivity is needed.
                                                        Hence, if a conductivity ratio of 10 (Kx/Ky = 10) is used, this im-
                                                        plies that the aquifer has a greater propensity to transmit the water
                                                        laterally than vertically.
                                                           Plotted in Figure 6 are the pollutant breakthrough curves for no
                                                        barrier and a  deep (90%) barrier in  a horizontally conductive
                                                        (Kx/Ky  = 10) aquifer subjected to  full  length recharge. These
                                                        curves follow the pattern established previously, i.e., the deep bar-
                                                        rier provides an initial time lag but eventually overtakes the no bar-
                                                        rier case. The interesting  aspect of these  curves, however, is the
                                                        very gradual concentration increase at the higher values of C/C0.
                                                        What is happening is that the furthest streamtubes (the streamtubes
                                                        that must travel furthest downward) are having trouble moving ver-
                                                        tically downward  initially. Hence their  time  of arrival under the
                                                        barrier is being delayed.
                                                           Plotted in Figure 7  are the same curves except the soil is  now
                                                        dominated by vertical conductivity (Kx/Ky = 0.1). These  curves
                                                        show  a  more  gradual  rate  of  concentration increase.  This
                                                        phenomenon reflects the  fact  that the streamtubes are dropping
                                                        vertically with relative ease but are having trouble moving laterally.
                                                        Since  the difference  in  horizontal  distance  (x-direction) each
                                                        streamtube must travel is greater than the distance difference in the
                                                        vertical direction,  the streamtubes will tend to arrive in proportion
                                                        to the horizontal distance which they must travel. This accounts for
                                                        the gradual rate of concentration increase.
                                                        ANALYSIS BY NUMERICAL SOLUTE
                                                        TRANSPORT MODEL
                                                           This phase of the analysis involved applying the Konikow-Brede-
                                                        hoeft  (K-B)3 numerical solute  transport model to  the proposed
                                                        problem to examine three  phenomena.  First, the effects of disper-
                                                        sion on the pollutant breakthrough curves were examined. Second,
                                                        the effects of keying the barrier into a relatively impermeable yet
                                                        not totally impermeable  formation  were  analyzed.  Finally, the
                                                        behavior of a totally penetrating but semi-permeable barrier was
                                                        assessed.
                                                        Problem 4: Effects of Dispersion

                                                           Plotted in Figure 8 are the pollutant breakthrough curves at 90%
                                                        depth for the no-barrier case and three dispersive cases for a 90%
                                                        penetrating barrier. The aquifer is 100 ft deep and 500 ft wide.
                                                           The first thing to note about  Figure 8 is that  the placement of a
                                                        partially penetrating barrier in the aquifer is ineffective in terms of
182
BARRIERS

-------
                                                     T (y.ori)'
                            Figure 8
        Pollutant breakthrough curves for an elongated aquifer
retarding pollutant migration. The no-barrier case shows an almost
immediate response to the contaminated recharge. However, the
with-barrier cases only provide time lags on the order of one year
over that of the no-barrier case. Moreover, the rate of concentra-
tion increase under the barrier is as great as, if not greater than,
that of the no-barrier case. In essence, all the barrier does is provide
a small initial time lag. The actual numerical values of these time
lags is not important because the input data is hypothetical, but the
relative behavior of the barrier to the no-barrier case is important.
It shows that partially penetrating barriers are not completely effec-
tive in retarding pollutant migration.

Problem 5: Layered Soils
  One means of alleviating the problem of a partially penetrating
barrier  would be  to construct an adequate key  into  an  im-
permeaable formation. If an impermeable formation does not exist
at  a reasonable depth,  one would probably not use  a barrier.
However, if a relatively, yet not totally,  impermeable layer exists at
a reasonable depth, one might key into it. Plotted in Figure 9 are
the breakthrough curves for a partially penetrating barrier (90%)
and a barrier that has been keyed into a  formation  only slightly less
permeable than the overlying aquifer (Klayer = 0.1 Kaquifer). The re-
sults are quite dramatic. Not only does the impermeable layer delay
the initial appearance of contaminant under the barrier, but it also
decreases the rate at which the concentration of the escaping con-
taminant increases. This effect is even more pronounced for deeper
aquifers.
                           Figure 10
           Pollutant breakthrough curve for barrier keyed
                   to impermeable layer (50 ft)
                            Figure 9
           Pollutant breakthrough curves for barrier keyed
                   to impermeable layer (25 ft)
                           Figure 11
             Pollutant breakthrough curves adjacent to a
                semi-permeable barrier at 30% depth

  Plotted in Figure 10 are the same curves for an aquifer twice as
deep as that of Figure 9. The time lag is approximately twice that of
Figure 9 and this is explained by the fact that the contaminant must
travel twice the distance vertically before attempting to penetrate
the layer.
  The above phenomenon has practical significance because it im-
plies that barriers might be useful at future facilities where an ar-
tificial impermeable layer (such as a clay liner) has been placed. In
these situations, an adequate key can be assured by simply  sinking
the barrier down past the liner. Such is not the case with deep im-
permeable  bedrock where one must be concerned with  both the
quality and depth of penetration of the key into the bedrock.

Problem 6: Semi-Permeable Barriers

  Another problem that has plagued barriers  is  that the  im-
permeability of the wall itself cannot be assured. Steel sheet-piles
are not initially water-tight, and grout curtains and slurry walls are
both subject  to permeability  increases upon exposure to  certain
contaminants.  Plotted  in  Figure  11   are  the  concentration
breakthrough curves at  30% depths on the left side  of the barrier
for two different  barrier  permeabilities.  The  barrier  is  fully
penetrating but possesses a permeability only slightly less  than that
of the aquifer. Insuring the impermeability of the barrier appears to
be a more critical factor than  insuring an adequate key. Note that
keying the  barrier into a semi-permeable layer was extremely effec-
tive in retarding pollutant migration.
  A fully penetrating barrier  (Figure 11) does not perform effec-
tively unless the permeability of the barrier is at least two orders of
magnitude lower than the adjacent aquifer (Kbarrier  =  Kaquifer).
This is reasonable because  there exists a significant stress in the
horizontal  direction, while  stresses in  the vertical direction  are
minor, i.e., in  this situation the tendency is for the pollutant to
migrate laterally more than downward.
                                                                                                            BARRIERS
                                                                                                                              183

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  C/Co

  1.0 -
                           Figure 12
               Comparison of simple and K-B models
COMPARISON OF MODELS

  By imposing a constant head difference across the impermeable
barrier, a constant  flow  through the opening in the barrier is
developed. Since the aquifer is assumed to be at steady state condi-
tions, the  flow through the opening in the barrier must be equal to
the amount of recharge coming into the aquifer. The recharge rate
the aquifer is subjected to is the recharge flow divided by the length
of the  aquifer. With this known recharge rate, it is possible to use
the simple analysis and calculate the response time (tc  = —)  for a
given aquifer. With a known tc, the pollutant breakthrough curves
can  be converted  to include an  absolute time (t) rather than a
dimensionless  time parameter (t/tc).  This will  allow  for a  com-
parison of the results of the  simple  plug  flow  model and the
sophisticated K-B model.
  Plotted  in Figure  12 are the  pollutant  breakthrough curves for
the  100 ft deep, 400 ft wide  aquifer. Two of the  curves  were
generated  by the K-B model and they reflect the case of no disper-
sion and  mild dispersion. The third  curve represents the results
generated  by the simple plug flow model, converted to an absolute
time scale by the process outlined above.  The curves illustrate that
the simple model tends to predict an earlier first arrival and a  more
gradual concentration increase  of pollutant under the barrier. An
interesting aspect of Figure 12  is  that the results of both the K-B
model  and the simple plug flow  model are  not significantly dif-
ferent. This same trend was found when converting the simple plug
flow model results to a comparable basis with the K-B model results
for other depths of aquifers. Hence, it is concluded that the simple
model  not only gives an accurate prediction of the general behavior
of these barrier systems, but can also provide fairly comparable ac-
tual values relative to the results of the K-B model if the parameter
tc can be calculated.

CONCLUSIONS

  The  first phase of the analysis  utilized a simplified (plug  flow)
model  to  examine  the travel of pollutants from a  source of con-
taminated recharge through an aquifer and under a partially pene-
trating impermeable barrier. The model  was  applied to  a variety
of simple input conditions. From this analysis the following conclu-
sions can be drawn.
  • The most efficient use of barrier technology is to place the bar-
rier  directly adjacent to  the  source  of contaminated  recharge.
Placement of the barrier downgradient has been examined under a
variety of  conditions and, in each case, was found to be less effec-
tive than an adjacent barrier. Placing a barrier downgradient allows
the pollution front to become established and approach the gap in
the barrier as a wall. Hence, concentration increase under the bar-
rier is quite dramatic following a  small initial time lag. The initial
time lag is due solely to aquifer geometry. When  these facts are
coupled with  the added consideration that placing a  barrier
downgradient will  increase its total length (and cost), it becomes
                                                        obvious  that  this  is  less  than  optimum  application  of  the
                                                        technology.
                                                          • Unless a perfect connection can be made between the barrier
                                                        and the underlying impermeable formation,  the barrier does  not
                                                        provide complete containment. The barrier will provide an initial
                                                        time lag before the appearance and increase in concentration of a
                                                        contaminant under the barrier. However, this positive attribute is
                                                        counterbalanced by the fact that the concentration under a partially
                                                        penetrating barrier will actually increase faster than  the outflow
                                                        concentration in an aquifer with no barrier. This phenomena will
                                                        be significant depending on the pollutant and the relative concen-
                                                        tration considered to be critical.
                                                          • When an aquifer with a waste source is  highly conductive in
                                                        the vertical direction, the effectiveness  of a  barrier is practically
                                                        negligible. Conversely,  aquifers conductive in the horizontal direc-
                                                        tion are more amenable to barrier technology. This is because the
                                                        pollutants tend to run laterally initially until they reach the barrier.
                                                        They then must travel vertically downward to  get by the barrier. In
                                                        essence, the  barrier dramatically increases the flow path distance
                                                        the pollutant would normally follow.
                                                          • The numerical model and analysis employed in this phase of
                                                        the research was relatively simple, quick and economical. However,
                                                        the results  generated only provide  information  on  the  general
                                                        behavior of barriers. The results would be hard to apply to a field
                                                        problem unless specific parameters, such as aquifer response time
                                                        (tc), could be related to input data, such as hydraulic conductivity.
                                                        Additionally, the simple numerical model does not handle some of
                                                        the more complex variations  such as dispersion, layered soils or
                                                        semi-permeable barriers.
                                                          As a result of the second phase of the analysis, a number of addi-
                                                        tional conclusions can be drawn about the general behavior of bar-
                                                        riers. Because the input data was hypothetical, no specifics can be
                                                        discussed, but the trends can be outlined. The conclusions are:
                                                          • The effects  of dispersion on the overall behavior of barrier
                                                        systems is negligible. The general pattern of an initial time lag prior
                                                        to first appearance of contaminant, followed by a rapid increase in
                                                        concentration and concluded with an assymptotic approach to in-
                                                        put concentration is followed whether the pollutant is dispersive or
                                                        not. Dispersive pollutants tend to arrive earlier than non-dispersive
                                                        pollutants, but this factor is not significant when one considers that
                                                        the time lags are on the order of fractions of years.
                                                          •The ability  to key a truly  impermeable barrier  to  an  im-
                                                        permeable  formation,  be it  totally  or  only  moderately  im-
                                                        permeable, dramatically improves the performance of the barrier.
                                                        If an adequate key cannot be assured, barriers are a poor (and ex-
                                                        pensive) choice of groundwater pollution control.
                                                          • The placement  of a barrier that is  not dramatically  less
                                                        permeable than the native aquifer material is ineffective. Moreover,
                                                        the contaminant tends to first penetrate the upper parts of a semi-
                                                        permeable barrier, and this fact should be considered in the design
                                                        of monitoring networks for barriers. Monitoring these systems only
                                                        at full depth may not detect the movement of contaminant out of
                                                        the upper layers.
                                                        REFERENCES

                                                        1. Kirkham, D. and Powers, W.L., "Physical Artifices for Solving Flow
                                                          Problems", Advanced Soil Physics, 1st Ed., John Wiley and Sons,
                                                          1972, pp. 85-130.
                                                        2. McLin,  S.G.,  "Lumped Parameter Hydrosalinity  Model", Ph.D.
                                                          Dissertation, New Mexico Mining and Technology Institute, 1980,
                                                          Socorro, New Mexico.
                                                        3. Konikow,  L.F. and  Bredehoeft,  J.D., "Computer Model of Two-
                                                          Dimensional Solute Transport and Dispersion in Ground Water", Book
                                                          1, Chapter 2, 1978, Techniques of Water Resources Investigations of
                                                          the United States Geological Survey, Washington, D.C.
 184
BARRIERS

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FUNDAMENTALS    or    SYNTHETIC    MEMBRANE    LINER
   SELECTION: A  PRACTICAL PROTOCOL  FOR SPECIFIERS
                                           J. BRIAN AINSWORTH
                                       Schlegel Lining Technology, Inc.
                                             The Woodlands, Texas
 INTRODUCTION

   Subtitle C of RCRA creates a "cradle to grave" hazardous waste
 management system whose intent is to protect human health and
 the environment. With rare exception, the regulations as currently
 promulgated require the use of a synthetic liner at least 30 mils
 (0.76 mm) thick in hazardous waste surface impoundments, waste
 piles and landfills.
   Yet it is unfortunate, and of probable risk to human health and
 the environment, that  no  one profession has taken that body of
 knowledge and experience called "liner  technology" as its own.
 The science-based fundamentals of synthetic liners are to be found
 in a number of disciplines including civil, chemical and mechanical
 engineering;  polymer   formulation  or  rubber  compounding;
 geology, hydrology and hydrogeology; and, occasionally, business
 administration.
   It  is urgent  that specifiers and permit writers extend their
 understanding of containment technology and the role that a liner
 plays within a containment system. New liner technologies are in-
 creasingly available, while some older lining concepts have been
 called into question. Recent technological advances  in the produc-
 tion, supply and installation of synthetic membrane liners have, for
 example, provided liners that resist thermal  deterioration; are inert
 to chemical attack, including organics; and are capable of with-
 standing severe loading and other physical  forces.
   Designing a containment system for the future as  well as for to-
 day's legal requirements is now necessary. Specifying a liner for
 that containment system  is  a complicated task, one that goes
 beyond the token use of a 30 mil thickness or naive acceptance of a
 manufacturer's  or installer's unsubstantiated  promise of "trust
 me."
   It is imperative that liners be viewed and evaluated as part of a
 system designed to contain hazardous wastes. This  evaluation in-
 cludes the selection of the liner material and the installation of the
 liner, all within the context of the uses to which the liner will be put
 during its intended life.
   Evaluation of liner properties is a key procedure. It has been
 pointed out by others' that the  essential  factors to consider in
 selecting an appropriate liner include:
 •The compatibility of a liner with supporting and surrounding
  environmental elements at the site
 •The compatibility of the specified wastes or waste  leachates with
  liner materials
 •The period of time that the liner will be expected to contain the
  specified  wastes.
   It is the author's intention  that this  paper itemize  those in-
 fluences on a liner for a specific application  at a given site, that will
affect the performance and service life of a containment system.
  This discussion of the many factors that will have varying degrees
of impact on liner performance, and thus the containment system
in its entirety, is also intended to provoke specification writers to
issue much more detailed and far more demanding performance re-
quirements for lining systems.
STRENGTH AND THICKNESS
  The ability of a synthetic liner to resist puncture and tear, both
during installation and during  the service  life of a facility, is
especially critical. Puncture of a liner can occur through a number
of means including falling objects, equipment moving on the liner,
ice forces, wind and wave action, abrasion and movement against
sharp-edged protrusions. Tear is encountered when  a  damaged
area, such as a small hole or rip, is subjected to tensile stress that
propagates the damage.
  Reliance on the  USEPA requirements for a 30 mil minimum
thickness is totally inadequate for protecting  a liner from puncture
and tear. It is this author's considered opinion,  derived in part
from field experience in replacing punctured  and failed thin liners,
that a minimum thickness of at least 80 mils is necessary to sustain
the many predictable loadings that a liner can be  expected to en-
counter.
  The author also  believes  a lining system should be  designed to
minimize the risk  of puncture and tear.  The converse design ap-
proach is to settle for the least  permissible thickness to reduce
short-term costs, even though this approach often, and erroneous-
ly, assumes that incremental liner thicknesses  will result in in-
cremental costs.
  Two methods for increasing a synthetic liner's resistance to punc-
ture and tear are available to the design engineer: selecting a high-
strength material or increasing the thickness of a given liner. In
those cases where the design engineer must  exercise extreme cau-
tion, usually because of the nature of the facility, it is prudent prac-
tice to opt for both alternatives to afford a factor of safety as high
as possible.
Puncture Tests
  Schlegel Lining Technology  has performed puncture and  tear
resistance testing on various synthetic membrane  lining materials
currently available on the market2 (Figures 1,  2 and 3). The purpose
of this testing was to determine the relationship between puncture
resistance and tear resistance vs HDPE liner  thickness  and to com-
pare the strength of various liner materials by measuring  their
respective tear resistance values.
  The test procedure used for the puncture  resistance testing was
the Swiss Standard SIA 280/14. In this test, a steel bolt of specified
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 dimensions and weight is allowed to fall onto a liner specimen. The
 height is  varied until the critical drop height is found;  i.e., the
 greatest height from which the steel bolt is dropped and causes no
 liner puncture for five individual trials.
    The tear resistance testing was conducted in accordance with the
 German Standard DIN  53 515. In this test, a Graves angle test
 specimen is subjected to tensile stress using  a testing speed of 20
 in./min;  this  relatively high  testing speed allows for an  accurate
 simulation of rapid tearing as would be found in actual site condi-
 tions.
    There is a  linear  relationship between puncture  resistance and
 liner thickness and between tear resistance and liner thickness
 (Figures 1 and 2). Figure 3 shows a comparison of tear resistance
 and thickness for various synthetic membrane liners.  This com-
 parison shows how different materials afford  different resistance to
 tear, with HDPE essentially  a magnitude of order above  the next
 closest lining material. These curves clearly illustrate that the design
 engineer can opt for a high safety factor by specifying a thick liner
 of the appropriate material.
    There are many predictable forces with puncture and tear poten-
 tial that  the  synthetic liner  must withstand. These loads can be
 delineated in  the following areas:
 Installation Procedures and Problems
    Vehicular,  equipment and pedestrian traffic on  or  about the
 liner, particularly during installation, must be considered. Methods
  for unrolling the liner  and laying it  out should be specified, in-
 cluding the permissibility of traffic on the liner. Methods of field
 seaming  the  liner and the allowable equipment  and  pedestrian
 loading at that time must also be considered.  Large, heavy seaming
 equipment working  on thin mil liners should generally not be al-
 lowed.
I
[j
£
o
                                    TESTING ACCORDING TO SIA 280/14
                                                         O
                                                         O «o
                                                         O
                                                         z
                                                         cc
                                                                                             TESTING ACCORDING TO DIN S3 515
                                                                                 LINER THICKNESS (mm)


                                                                                    Figure 2
                                                                             Tear Resistance Testing
                                                                    Tearing Force vs. Thickness for HDPE Liner
                                                                   Ul „_
                                                                   CC *°
                                                                   n
                                                                TESTING ACCORDING TO DIN S3 515
                                                                                             40     50    50     70
                                                                                            LINER THICKNESS - MILS
                       LINER THICKNESS (mm)
                             Figure 1
                    Puncture Resistance Testing
          Critical Drop Height vs. Thickness for HDPE Liner
                                                                                    Figure 3
                                                                             Tear Resistance Testing
                                                          Tearing Force vs. Thickness for Various Synthetic Membrane Liners
    Consideration  must be made  for other trades working  on or
  about the  synthetic liner. Situations such as the construction of
  contiguous roadways or the construction of pipe trestles or racks
  above and across lined basins are factors in this category. Heavy
  tools falling from a great distance or sparks from welding and cut-
  ting equipment must be considered in the design. Liners that cannot
  tolerate any and all of the anticipated loadings should be excluded
  from the specifications.

  Subgrade Conditions and Earth Covers

    The subgrade must be properly prepared for the placement of a
  synthetic membrane liner. The ability of the liner to tolerate the
  puncture forces generated by stones, rocks, roots and other sharp-
  edged protrusions in the underlying soil, when subjected to a load
                                                        from above  or below, is a major consideration. The puncture
                                                        resistance of a liner is a direct measure of its ability to resist these
                                                        forces. With thin liners, a layer of sand or very well graded soil is
                                                        required;  using a thicker  lining, however, generally results in the
                                                        opportunity to use screened in situ materials for the liner sub-base,
                                                        resulting in a cost savings to the owner.
                                                          The placement of an earth cover on a synthetic membrane liner
                                                        following its installation serves to protect the liner from the move-
                                                        ment of heavy equipment or unplanned and unpredictable high
                                                        loads. The supply and placement of an earthen cover over a liner
                                                        requires careful and close inspection. The proper grades of material
                                                        are required and should be rigidly inspected  prior to and during
                                                        placement. The specifications for the supply and placement of the
                                                        subgrade must also  apply to the covering material. Sharp-edged ob-
  186
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jects in the cover material can puncture a liner from above, as those
in the subgrade can puncture  it from below. Any suspect areas
should be uncovered, inspected and repaired as necessary.

Underlying Soil Stability

  Localized differential settling of the basin floor and side slopes
can exert forces on a synthetic liner. It can be expected that minor
amounts of differential settling and ground shifting (seismic activ-
ity) wil occur. Specifications should anticipate this event by calling
for:  a tensile strength of the liner at yield of greater than  1500
lb/in.2, and an elongation of at least 10% before reaching the yield
point. By specifying these properties,  certain inconsistencies in the
subgrade can be tolerated.
  If there  is  even minor sloughing of the soil on the side slopes
under the  liner,  this  earth movement could  tear the liner as it
migrates down the slope behind the liner.
  A major contributing factor to the  movement of soil on a slope
behind a liner is excess moisture in the soil. This can be caused by:
an improperly graded  top of berm which then allows moisture to
permeate through the anchor trench and berm area; overfilling of a
basin with  inadequate overflow protection; or a tear in the liner on
the slope, allowing water to impinge directly on the earthen slope,
with head pressure forcing it quickly into the side slope.

Hail, Rainfall and Wind Loads

  Weather conditions  that  produce  violent  thunderstorms,
hailstorms, or severe wind loads are  serious considerations in the
selection of a liner. A severe  thunderstorm, for example,  could
puncture a thin liner and a hailstorm is even more likely to cause
damage. These types of storms must be coped with both during and
following  installation. During the time that  a liner is being in-
stalled, weather presents a more severe problem because generally a
broad area of the liner would be exposed to the storm. Following
commissioning of a basin, only the exposed liner  berm area would
be susceptible to damage from storms.
  High wind loads are an additional problem. All possible precau-
tions should be taken to protect the liner from wind damage during
installation. Planning the layout pattern of the liner and providing
for proper ballasting and protection during installation are impor-
tant  procedures.  Shut-down  operations  such as weekends  and
holidays must be accommodated.
  It should not be viewed as anachronistic that a specifier enter in-
to the scheduling and sequencing of operations. Establishment of a
well-planned course of action and strict adherence to it is prudent
during lining installation.
  Following  installation of a synthetic liner in the basin, wind can
pose further problems. If the basin is to  be left empty for an ex-
tended period of time  before plant startup,  or if it will be drained
on a  regular  basis due to  plant process  operations, necessary
ballasting  and protection against  the wind  are again required. A
strong wind blowing across an empty basin generates an uplift force
on  a synthetic liner.  Ways to design against this include  proper
ballasting or  providing vent holes at the top of the berms.

Ballast
  Ballasting of a synthetic liner in a large basin is generally required
both during  and after installation. Many means  of ballasting are
available,  including sand bagging, covering the entire floor with a
layer of water or soil, piling soil in strategic areas, placing rubber
tires filled  with grout and placing concrete ballast blocks.
  Considerable thought  should be  put  into a proposal  for  a
ballasting operation. The possibility exists for the occurrence of an
adverse  chemical reaction between a rubber tire and the consti-
tuents of a basin. In arid regions, a layer of water used as ballast in
the bottom of the basin is not possible. If  a heavy soil cover is used
over  the bottom of a basin and is not subsequently removed, it
lessens the working volume of the basin.
Thermal Exposure
  Synthetic liners tolerate varying ranges of temperatures; newer
liner technologies in  particular have generated  liners  capable  of
tolerating temperatures as  high as  190°F and as low  as  -74°F.
Fluid temperature within the basis is of prime importance but the
exposed liner on the berm of an impoundment experiences tremen-
dous sun loads and a corresponding rise in temperature. In many
areas of the country, such as the Southwest United States, this fac-
tor cannot  be ignored. On some  polymeric  membrane  liners,
sunlight  acting in conjunction with ozone can cause shrinkage  or
liner embrittlement.
  The fluid temperatures within a basin can generally be predicted
or calculated during the initial design. Many times the  term "am-
bient temperature" is used. Generally, and  probably  accurately,
this temperature can be expected to be less than 100°F, although in-
vestigations into the actual temperature of the contents of the basin
must be  conducted and considered. Two key items for  assessment
are: (1) the possibility  of an exothermic chemical reaction occurring
within the basin, and  (2) the concentration of salts in a basin that
might result in the formation of a crude solar pond.
  An exothermic chemical  reaction could cause the instantaneous
temperature to be greater than 150°F. This localized temperature
would be detrimental  to many liners. Further, a slow build-up  of
salts in a basin could  contribute to the formation of a crude solar
pond.  Temperatures  in the bottom of  a solar pond  have been
known to approach 200 °F, a level that is far beyond the ability  of
many liners to withstand.
  It is difficult to design against these two problems. Unless strict
controls  to  prevent the dumping  of unexpected and  unplanned
chemicals are maintained within the plant or unless temperatures  in
a pond are monitored on an intermittent basis,  the possibility  of
subjecting  a  synthetic  membrane   liner  to  a high localized
temperature exists. This unwanted event should be designed for by
selecting a liner material that will tolerate temperatures in ranges  to
be reasonably expected.

Startup Procedures
  Initial  filling of a basin requires vigilance.  Items such as splash
pads, diffusers and  other means of alleviating water forces on the
liner during filling should be considered.
  Proper design requires specifications for a puncture resistant lin-
ing able  to withstand the anticipated forces  of falling  water, ap-
propriate design of the piping network and  the inclusion of con-
crete or earth cover in strategic areas.
Subsequent Cleanout  Operations

  If  the  basin  will  be cleaned on  a periodic basis, the forces  to
which it  will be subjected  during these operations  must be con-
sidered. A suction hose or submersible trash  pump, small rubber-
tired equipment with  a front end  bucket or possibly a dredging
operation are all processes  that could be used to clean the basin.
The impact of these processes upon the liner should be considered.
Ice

  In northern climates, two forces can occur from the formation  of
ice in a basin. The first is the lateral pressure exerted on the side
slopes of the basin when the entire  surface freezes. The  second oc-
curs  in the springtime;  large chunks of ice,  broken off from the
main body, can be driven by wind and wave  action into the slopes
creating localized point source forces on the liner. The location  of
the basin with respect to wind direction and wind velocities must  be
considered; prevailing winds, frequencies and maximum velocities
should be studied. The possibility of strategically siting a basin  to
shelter it from wind  forces as much as possible should  be in-
vestigated.
  The specification  for the  side slope gradient should be analyzed.
By employing a relatively "mild"  slope, such as 3:1 (horizontal-
vertical) or greater, the lateral pressure of a solid ice cap on a basin
is eased due to the ability of the cap to "ride up" on the slopes and
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never impinge on the liner in a direction perpendicular to the slope.
This same phenomenon occurs with ice chunks driven or  carried
into the liner during the spring breakup of the ice cap; the more
gradual the slope, the easier it is for the water to carry the ice up the
slope instead of directly into it.
  A Final consideration in ice loading is a determination of the
tendency of the ice to adhere to the synthetic liner.  If adherence is
possible it occurs more frequently with rough textured liners; this
process increases the adverse effect of the ice on the liner. If an ice
cap forms across the entire basin, portions of the ice  cap around the
perimeter can actually "hang" on the liner and readily tear it when
spring  breakup occurs.
Abrasion
  Wind-blown sand  can abrade the liner at the  top  of the berm
area. The dumping of bottom ash or fly ash slurried with water can
cause abrasion in the inlet areas of the basin or in areas where ex-
cessive wind and  wave action occur. Few formal sources of abra-
sion resistance tabulations for liners have been generated; however,
various  pipe  manufacturers fabricate pipe  made of the same
material  as  some synthetic liners (HDPE and PVC). Some  pub-
lished  data exists from these sources.

Process Uses of the Basin
   Liquid level fluctuations, amount of agitation and mixing, heavy
equipment movement and wind and wave action must also be con-
sidered. The installation of floating aerators or submerged aeration
equipment or mixing via high velocity pumping  or influent chan-
nels, are all factors that can cause uplift forces on  the basin  floor
and varying amounts of wind and  wave action on the slopes.
   The puncture resistance of the synthetic liner plus the soil stabil-
ity of  the side slopes are the parameters of specification for  these
applications.
Recreation Uses of the Basin
   Recreational uses of a very large basin or water reservoir can pro-
duce forces on the liner that must be considered before its selection.
If the  upstream face of a dam is lined with a synthetic membrane,
such forces as extreme wind and wave action, floating logs, debris
and ice all must be considered.
Economy of Volume
   The term economy of volume describes how a change in gradient
on a side slope from a shallower one to a steeper  one  positively af-
fects the working volume of a basin in two ways: (1) if steeper
slopes are employed, the user realizes a much greater basin  volume
for the same land area, and (2) if steeper slopes are used, the  same
volume can be realized for a smaller land area as compared to
shallow slopes over a greater land area.
   Clearly, if realizing economy of volume is desired, two elements
are  necessary. The first is that  the earthen subgrade be  able to
maintain its stability at the desired slope; slopes steeper than  1.5:1
are  generally  not encountered. The second is that the synthetic
membrane liner be able to support its own weight and not elongate
when installed on a steep  slope.
Vandalism and Wildlife

  Vandalism at any facility is always possible; particularly suscepti-
ble areas would be the berm and top portions of a liner. The effects
of  wildlife  must  also be  considered;  the penetration of  animal
hooves, again primarily in the berm areas, is a definite possibility.
  The prime method of preventing these problems includes proper
security and fencing. As a contingency measure, however, a liner
having a high puncture resistance can also be specified.
Burrowing Animals and Plant Penetration

  Small rodents and burrowing animals sometimes  use a liner as a
food source and are able to gnaw through it.  Further, some types of
synthetic  liners are susceptible to the penetration of roots and
                                                       plants. Linings containing plasticizers or other possible rodent food
                                                       sources should not be specified; rodent populations are difficult to
                                                       control, and rodents can gnaw through a liner in unexpected loca-
                                                       tions making it very difficult to isolate any leakage.
                                                       LINER CHEMICAL COMPATIBILITY
                                                          In addition to assessing and  specifying physical properties re-
                                                       quired to meet the service needs  of the facility, it is also absolutely
                                                       necessary to  assess the chemical compatibility of a synthetic mem-
                                                       brane liner in order to specify an appropriate material. The com-
                                                       pilation of a complete list of chemical constituents and their con-
                                                       centrations that could come in contact with the synthetic membrane
                                                       liner is required. A design engineer must consider each of these con-
                                                       stituents on a case-by-case basis to determine the ability of a syn-
                                                       thetic liner to withstand the effects of the chemicals in contact with
                                                       it.
                                                          All  the waste fluids  that could  contact  the  liner should be
                                                       categorized and characterized. Items that should be considered in
                                                       this characterization include fluid temperature, pH and concentra-
                                                       tion of organics. Initial liner selection or rejection can be  made
                                                       from knowledge of the chemicals.
                                                          The problem of synergism of the various chemicals, however, is a
                                                       more complex one. Synergism involves many unknowns. Predict-
                                                       ing synergistic reactions requires a vast amount of knowledge; it is a
                                                       seemingly impossible task to predict any and all combinations of
                                                       chemicals that might contact the liner. A  waste that one day might
                                                       have an innocuous effect on a liner could the next day, in conjunc-
                                                       tion with an additional chemical, have a disastrous effect on the
                                                       same liner. Clearly, the most efficient means of designing around
                                                       this problem is to select a lining that tolerates and withstands any
                                                       and all combinations of chemicals envisioned.
                                                          An effective and common procedure to determine the general
                                                       compatibility of a synthetic membrane liner is to consult a matrix.
                                                       Matrices showing the types  of liner materials and a variety of in-
                                                       dustrial and hazardous wastes are easily obtained. By consulting a
                                                       matrix, one can quickly learn what families of chemicals or hazar-
                                                       dous wastes are detrimental to a given synthetic membrane  liner.
                                                       The intent, of course, is to select a lining material that is compatible
                                                       with all families of chemicals and hazardous  wastes that it can be
                                                       expected to encounter during its life.
                                                          A more specific measure for determining the chemical  com-
                                                       patibility of a synthetic membrane liner is an immersion test. In this
                                                       test, a sample of the synthetic membrane liner is immersed in the
                                                       anticipated waste (one  side immersion only  per USEPA Method
                                                       9090) in the concentrations  that can be expected. Certain physical
                                                       parameters of the liner material are then monitored and recorded as
                                                       the test proceeds. The key parameter monitored during the  test is
                                                       the weight change of the sample. Values that are generally deter-
                                                       mined following the planned time of soaking are weight gain, ten-
                                                       sile strength at yield and break and elongation at yield and break.
                                                          During the test, an indication of a gain in weight by the sample
                                                       means the synthetic liner is absorbing the chemical with which it is
                                                       in contact; generally, the elongation properties of a synthetic liner
                                                       are adversely affected when  a severe weight gain occurs. If a weight
                                                       loss occurs, it is an indication that the chemicals in contact with the
                                                       liner are dissolving it; in this case, it can be expected that there will
                                                       be a definite drop in the tensile strength both at break and at yield
                                                       and elongation both at yield and at break.
                                                          Schlegel Lining Technology has developed its own 28-day immer-
                                                       sion test, run at 158 °F and employing total immersion of the sam-
                                                       ple. The purpose of this is to accelerate the results that would be ex-
                                                       perienced during a test run at ambient temperature on only one side
                                                       of the liner. The maximum  allowable weight gain or loss, and the
                                                       maximum allowable drop or increase in tensile  properties, have
                                                       been standardized by Schlegel Lining Technology for in-house use.
                                                          If a given chemical waste affects the lining material adversely at
                                                       this elevated temperature, however, it is rejected from considera-
                                                       tion as a lining material, even though anticipated exposure might be
                                                       only to an ambient temperature waste. Selected examples of such
                                                       chemical compatibility testing are as follows:
 188
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Example 1
Test: 28 days, 158°F
Liquid Sample: Oily Waste Water Containing High Amounts of
               Sulfates and Chlorides
Liner Material
HOPE
CSPE
PVC
CPE
                   % Weight Change
      Chloride Solution             Sulfate Solution
          0.12                           +   0.90
         20.2                             +  19.3
          1.46
         17.1
                             15.8
                             22.5
Example 2
Test: 28 days, 158 °F
Liquid Sample: Aqueous Brine Solution
Liner
Material
CSPE
HOPE
Example 3
Test: 28 days,
Liquid Sample
Liner
Material
CSPE
 % Weight
 Change
 + 2.58
 (Not stabilized
 after 28 days)
 + 0.08
°7o Change in
Tensile B
+ 39.1
                    1.87
% Change in
Elongation B
- 30.8
HOPE
Example 4
Test: 28 days,
Liquid Sample
Liner
Material
PVC
194 °F
:  20%  Aqueous Phosphoric Acid Solution
 % Weight      % Change in   % Change in
 Change        Tensile B       Elongation B
 + 8.83        +  102         - 26.4
 (Not stabilized
 after 28 days)
 + 0.14        -   0.78
              0
158°F
: Sodium Cyanide Leachate Solution
HDPE
Example 5
Test: 28 days,
Liquid Sample

Liner
Material
XR-5
HDPE
 % Weight
 Change
 + 7.46
 (Not stabilized
 After 28 days)
 + 0.13
% Change in
Tensile B
- 11.3
                                 1.30
% Change in
Elongation B
- 5.65
158°F
  Mostly water, containing heavy metals, organic
  solvents, organic acids, alcohols and aldehydes
 % Weight      % Change in    % Change in
 Change        Tensile B       Elongation B
 + 2.73        +  31.9        + 8.57
 + 0.29        +  0.11       0
  These  examples clearly  illustrate  the  effects  of  different
chemicals at elevated temperatures on  various  synthetic liners
available on the market.
LINER SEAMING METHODS
  How a liner  is seamed, whether  in the factory or the field, is
critical to a system's performance. Although this author is unaware
of any published  study ranking lining system failure mechanisms,
common sense  and knowledge of the propensity for human error
suggest that seam failures are very likely a leading cause of lining
system failure.  Specifications for a seam should state not only a
joining technique,  but  also  a quantification of seam  strength,
which is  a function of the base material's strength and a quality
control program for testing seams.
  There are eight methods for joining seams:
  (1) Adhesive  seams are joined with a chemical adhesive system
that bonds together two separate membrane surfaces. The chemical
adhesive system is an additional element to the seam system and,
thus, must meet all the criteria of the application such as chemical
resistance,  temperature  extremes,  etc. Generally,  when  using
adhesives, a two-component system is employed. This requires care
in mixing. When the adhesive is applied, the residence time before
bonding is critical as well as the  pressure applied and timing of
pressure. These variables may be difficult to control in the field.
  (2) With a bodied solvent seam, lining material is dissolved in a
solvent  which softens and bonds the liner  surfaces together. This
method is essentially an adhesive system made up from the parent
material. Problems of  application timing  and pressure, as men-
tioned for adhesive seams, do exist, and the amount of solvent used
is critical. Again,  field  application requires care.
  (3) Dielectric seams are made when a high frequency dielectric
current  is used to melt the surfaces of a membrane material so that
the surfaces  can be  homogeneously  bonded  together under
pressure. This process is used most often to fabricate factory
seams, because the use  of high frequency current is more difficult
in the field. The timing and the amount of pressure is critical.
  (4) For extrusion welded seams,  a bond is obtained between two
flexible  membranes by extruding  a molten ribbon of the parent
material between  overlapped  liner pieces, followed by  applied
pressure. This is a relatively straight-forward task  in the field.
  (5) Solvent seams use solvents to soften the surfaces to be bond-
ed; generally, pressure is then applied to the seam. Under field con-
ditions, the application of the solvent and timing and pressure can
be a difficult task.
  (6) A chemically adhesive tape may be used to bond liner surfaces
together. This tape system adds an additional element to the seam
system that must be assessed for the application. Taped seams are
not commonly made in  the field and have all the hazards associated
with adhesive seams.
  (7) To make thermal seams, high temperature air or gas is applied
between the two surfaces to be bonded until the membrane surfaces
melt, at which time pressure is applied to create a homogeneous
bond  between the two surfaces.  Timing  and pressure  must be
carefully controlled.
  (7) Vulcanized seams  are formed when the areas to be bonded are
unvulcanized materials that  are  cured together  with  heat and
pressure. This method is applicable only for thermoset materials.
  A lining system owner or operator may plan to install such a
system in several stages  or may wish to have the option of enlarging
his facility at some future time. This not infrequent situation will
affect the selection of a material, because some liners do not have
the capability of joining new materials  to   old. A liner that
undergoes complete vulcanization after exposure to the sun, for ex-
ample, cannot be  amended. On the other hand, there are liners to
which new materials can be seamed at any time.

LINER SERVICE AGREEMENTS
AND COST PROJECTIONS

  When one or more lining materials  have been selected as  the
material(s) that the specifier is confident will withstand the broad
range of physical and chemical attack envisioned during the life of
the basin, the service life and concomitant long term costs must be
determined to complete the liner selection  process. Both the liner
service agreement (warranty)  and  long term costs enter  into this
cost selection phase.

Liner Service Agreements

  A synthetic liner must be able to withstand severe physical stress-
ing and chemical attack.  Even  the most intelligent specifier,
however, might overlook some design details or future intended use
and service work may be necessary.
  A well written, detailed warranty statement  is an advantage to
both the customer and the membrane liner supplier and installer.
By delineating all  parameters at the outset, the  customer knows
what he can expect in terms of repairs and the supplier knows what
agreements he must uphold. Vague warranties with bland promises
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must be scrutinized closely and rejected by the customer where ap-
propriate.
  Key items to be included in a service agreement include: length of
time it is in force, hazards covered and not covered, breadth of the
statement (liners can fail from a wide range of factors), expediency
of repair and cost. Some warranties contain a section that could be
termed a "full warranty" and a section that could be termed a "pro
rata warranty."
  Generally, the full warranty protects the customer completely for
a specified time, as long as the customer is not guilty of negligence
or misuse. However, it would be wise to define exactly what is in-
cluded in the so-called "full warranty"; the technical specifications
must closely define  all  wastes,  temperature,   concentrations,
volumes and frequencies that are to be expected.  Many warranty
statements include the terminology "customery use" or "use for
which it was intended." If the job specifications closely define these
normal or  intended uses, the customer is protected. Failure to
define and categorize could create a loophole for an unethical sup-
plier.
   Pro rata warranties are a current phenomenon in service agree-
ments. In essence, both the supplier and customer pay for repairs,
in proportion to the length of time a lined basin has been in service.
On the surface, it is a reasonable arrangement where, in effect, the
supplier/installer is rewarded  for properly installing the synthetic
membrane liner and providing first-class workmanship.
   Failure to define the intended purpose of the basin and its consti-
tuents,  however, could again allow  an unethical company to shirk
its responsibility and fail to bear its share for repair of the damage.
   In the preceding discussion the terms "manufacturer" and  "in-
staller" have been used interchangeably.  Very often, however, the
liner manufacturer simply sells his product to a liner installer  (fre-
quently an excavation company that actually dug the basin), who in
turn marks up the price and installs the  liner. A  subsequent  liner
failure results in a disagreement over  repair responsibility.
   The customer calls to report a failure of the liner, and invariably
the first party it is reported to implicates the second party involved;
the liner is not repaired (or it requires an exorbitant time period to
replace  it) and legal  battles ensue. This causes nothing but delays,
frustration and expense for the customer who is left with the battle
of fighting the regulatory  authority  in charge of protecting the en-
vironment. The customer  pays for the inabilities of others.
  A specifier should insist that  the entire lining  package be  pro-
vided and installed by a single, responsible, stable business entity.
Then, if a  failure occurs, a single party is  responsible for  liner
repairs, whether related to manufacturing problems or installation
deficiencies.  The customer benefits with more control over the
situation and a greater likelihood of repairs being made in a timely,
low or no cost manner. If the financial integrity  of the manufac-
turer/installer is questionable, it is certainly in order to require
100% Performance  and Payment Bond, for as long a period as
practicable. Any company incapable of providing the necessary
bonding and financial security should be immediately eliminated
from consideration. A customer must be assured of having repairs
made on an equitable and timely basis.

Liner Cost Projections

  Long term cost projections are difficult  to make but are  a
necessary task  in  attempting to assess  the  efficacy of a lining
system.  The initial reaction of a customer is generally to accept the
lowest cost  bid. Unfortunately,  this myopic  viewpoint totally ig-
nores long term security.  Opting for thin mil liners, installed  by
under-capitalized installers, is not a cost efficient means of  pro-
viding a secure impoundment for long term service.
                                                           Leaks occurring in a lined basin can be costly and require a great
                                                        deal of time and effort to repair. Costs that occur  in repairing a
                                                        liner can include: pumping, demucking, sludge disposal (including
                                                        permits), loss of  revenue  from  normal  basin uses,  fines  to
                                                        regulatory agencies for failure to protect the environment and costs
                                                        of cleanup operations. Clearly, these costs can be expensive for one
                                                        leak in a liner. Adding these repair costs to the  initial low cost in-
                                                        stallation can quickly drive the cumulative cost far in excess of the
                                                        initial installation cost for a  thicker liner capable of withstanding
                                                        the forces a synthetic membrane liner experiences during operation.

                                                        LINER QUALITY ASSURANCE PROGRAM

                                                           Although a complete  discussion of this  subject is beyond the
                                                        scope of this paper, certain  highlights of any Quality Assurance
                                                        (QA) program should be noted.
                                                           A raw material supplier should be required to provide and certify
                                                        all the technical aspects of his product. Upon  receipt of the raw
                                                        material by the membrane manufacturer, these  parameters should
                                                        be rechecked in the  manufacturer's facility before production
                                                        begins.
                                                           During membrane liner production,  QA  should  be monitored
                                                        closely to ensure that the liner meets all specifications  required.
                                                        Tolerance  ranges  should be established,  clearly   defined and
                                                        adhered  to.  Lining material not meeting the specifications must be
                                                        scrapped.
                                                           The lining installation itself requires exacting QA standards. No
                                                        liner, regardless of its production QA, is useful until it is seamed
                                                        and installed properly. Again, standards of proper temperature for
                                                        joining,  proper weather for joining  and the use of skilled tech-
                                                        nicians to properly join and test the panels must  be established and
                                                        maintained.
                                                           Adherence to each of these stages of QA will result in an integral
                                                        lining system capable of containing the hazardous wastes for which
                                                        it  was  designed.

                                                        CONCLUSIONS

                                                           Synthetic liners are subjected to a broad spectrum of mechanical
                                                        and chemical attack during their service lives. Some of these factors
                                                        can be predicted during the design phase of the specifier; others
                                                        are difficult  or impossible to predict or envision. Therefore, the
                                                        specifier should select a synthetic liner of at  least 80 mil  thickness
                                                        that exhibits a wide range of chemical compatibility.

                                                        REFERENCES

                                                        1.  USEPA, Office of Solid Waste and Emergency Response, "Lining of
                                                           Waste  Impoundment and Disposal Facilities", p.  2, SW-870, Revised
                                                           Edition, Washington, D.C., Mar. 1983.
                                                        2.  Etter, D., "Puncture Resistance and Tear Resistance of Plastic Liners",
                                                           Schlegel Engineering GmbH, Hamburg, West Germany, 1979.
                                                        3.  Clarke, R.T., Jr., "Uses For Synthetic Membrane  Liners In Retarding
                                                           The  Movement of Contaminated Groundwater From Hazardous Waste
                                                           Sites", Schlegel Lining Technology, Inc., The Woodlands, Texas, 1983.
                                                        4.  "USEPA,  Hazardous  Waste Management  System;  Standards Ap-
                                                           plicable To Owners and Operators of Hazardous Waste Treatment,
                                                           Storage and Disposal Facilities; and EPA Administered Permit Pro-
                                                           grams", Federal Register. 47, July 26, 1982, 32274-32388.
                                                        5.  VanderVoort,  J.,  "The  Containment of Hazardous  and  Chemical
                                                           Wastes By The Use of Polymeric Flexible Membrane Liners", Schlegel
                                                           Lining Technology, Inc., The Woodlands, Texas,  1981.
                                                        6.  VanderVoort, J.,  "Comprehensive Quality Control in the Geomem-
                                                           brane  Industry", Schlegel Lining Technology, Inc., The Woodlands,
                                                           Texas, 1983.
 190
BARRIERS

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       THE  "ENVIROWALL  CUT-OFF"  VERTICAL BARRIER

                                        SALVATORE V. ARLOTTA, JR.
                                        Wehran Engineering Corporation
                                              Middletown, New York
INTRODUCTION

  The migration of polluted groundwater or leachate from con-
taminated sites or waste disposal areas, especially abandoned sites,
is an environmental problem of national proportions. A new and
unique concept called the "Envirowall Cut-Off" has been devel-
oped to construct a vertical, impermeable barrier to prevent this
migration.
  "Envirowall Cut-Off" is a hybrid cut-off wall. It is constructed
with high density polyethylene (HDPE) and sand backfill and is
installed by using the slurry trench construction method. Once in-
stalled, a very low permeability,  composite, vertical barrier is es-
tablished with several unique engineering properties.
  The overall concept and construction methodology was demon-
strated during a full scale construction test at a sanitary landfill in
New Brunswick, New Jersey during the Fall of 1982. The test was
planned to demonstrate the feasibility of the techniques and ma-
terials used to construct the  Envirowall  Cut-Off under  generally
difficult (by design) conditions.  The test also  demonstrated the
major advantages of the Envirowall Cut-Off over other types of
cut-off wall construction.
WALL CONSTRUCTION

  The Envirowall Cut-Off essentially functions as a cut-off wall
with redundant features for  controlling  horizontal seepage. One
hundred mil  HDPE sheet is used to form an envelope which lines
the walls of an excavated trench.  The bentonite slurry used during
construction  keeps the trench stable for placement of the HDPE
sheet and sand backfill and also forms a filter cake on the walls of
the trench. This filter cake further decreases the permeability of
the composite in-place barrier. The sand backfill, besides serving as
ballast, provides an internal, porous medium for monitoring seep-
age and, if necessary, withdrawal of intruding pollutants.

MIGRATION PREVENTION
  The prevention of groundwater contamination by the seepage of
pollutants is  often  the major focus of the engineering effort for
remedial  measures at a chemically contaminated site. Many var-
iables enter into the picture. Some of these variables are:
•Quality and direction of the groundwater flow
•Characteristics of the waste
•Hydrogeological characteristics of the site and adjacent areas
•Human health risks involved
  When the site is a landfill,  the prevention of subsurface migra-
tion of leachate from the site is usually the goal in order to pre-
vent environmental degradation. A thorough study of the geology,
groundwater regime and soil conditions is required to select the best
method of preventing subsurface seepage of pollutants or migra-
tion of leachate.  If leachate  enters the groundwater, the polluted
groundwater will migrate, following the hydraulic gradient of the
water table.
  To prevent leachate from moving laterally via the groundwater,
an impermeable barrier or cut-off wall  must  be constructed per-
pendicular to the groundwater hydraulic gradient. Depending on
site stratigraphy,  cut-off walls are often keyed into an underlying
soil stratum of low  permeability to  effectively seal off the sub-
surface horizontal migration of contaminants. This is often done at
landfill sites or hazardous waste disposal sites as a remedial meas-
ure.
LEACHATE GENERATION

  Typically, a certain percentage of precipitation which falls on a
landfill eventually ends up percolating through the waste, which is
often buried, to form leachate. Any contaminants which are picked
up in the leachate through contact with waste will be transported
with the leachate.
  Some landfill sites contain hazardous toxic compounds which
can be leached out of the waste and eventually contaminate the
groundwater. Two types of leachate are involved:
•Flowable constituents of the waste
•The flowables generated from infiltration or percolation as men-
 tioned above
  These are usually  referred to as primary and secondary leach-
ate, respectively.  The majority of industrial hazardous wastes are
produced  as liquids and, therefore,  can easily become primary
leachates.  Both the solute and solvent phases of leachate can affect
the permeability  of the natural ground, of liners or of cut-offs.
Wastes can be classified either by source (i.e., municipal refuse,
industrial  and  chemical process waste,  dredge spoil, etc.)  or by
physical class (i.e.,  organic,  aqueous-inorganic, aqueous-organic,
etc.). Physical  classification  is more useful when assessing likely
effects on liners or cut-offs.  Organic fluids associated with indus-
trial wastes which are often placed in a disposal  facility cover a
spectrum of types.


WASTE CONTAINMENT STRUCTURAL FAILURES

  Recent research has indicated possible concerns for soil  struc-
tures, such as clay dikes, cut-offs and liners, which are used for
containment of wastes.  Failure mechanisms fall into four major
categories:
                                                                                                     BARRIERS
                                                                                                                     191

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                                          r~
                                             emutiD SUKFACC
                                         FILL
                                        -AND-
                                        REFUSE
                                     _ MEADOW
                                      MATERIAL'S
                           Figure 1
           Excavated Trench before Placement of the Liner
   GROUND 51/«/MC£
                  SLURRY	
                (BENTONITE)
                                     • HOPE LINED
                                    - WATER AND SAND FILL
                           Figure 2
               Cross-Section of the Trench with Liner
1. Dissolution
2. Syneresis
3. Piping
4. Desiccation
  It is important  to  evaluate the materials  for containment in
relation to the wastes. Generally strong acids, strong bases, salts
and highly ionic wastes are aggressive toward soils.

ENVIROWALL ADVANTAGES

  The Envirowall Cut-Off has several advantageous features when
used as a vertical barrier to form a cut-off wall. The Envirowall
Cut-Off, when used for environmental control, combines some of
the ideas of clay and of a soil bentonite cut-off wall and adds the
capability for monitoring performance and withdrawal of contam-
inants from within the cut-off wall.  The HDPE  envelope pro-
vides  a stable,  low permeability (10~12 cm/sec)  membrane and,
when  installed in the trench, provides improved resistance to perm-
eation and low overall permeability  for the  Envirowall Cut-Off
system.

Construction

  The slurry trench construction method allows installation of the
Envirowall Cut-Off in areas with difficult site conditions  and to
relatively deep elevations.  The  bentonite slurry used in the con-
struction maintains the stability of the trench during the installa-
tion of the Envirowall Cut-Off HDPE envelope. The slurry also
                                                       develops a filter cake on the walls of the trench, which provides an
                                                       additional low permeability bentonite and soil layer.
                                                         The Envirowall Cut-Off is constructed in a similar manner as the
                                                       soil bentonite cut-off wall. A narrow trench is excavated and filled
                                                       with bentonite slurry to stabilize the trench walls during construc-
                                                       tion.  The HDPE envelope is fabricated above ground to fit the
                                                       dimensions of the trench. Sheets are cut and seamed to form a U-
                                                       shaped envelope and  set with ballast weight to  provide an initial
                                                       submergence into the trench. The envelope is lifted and set in the
                                                       trench. Water and sand are pumped into the envelope to  develop
                                                       negative  buoyancy  and to form  the  HDPE to  the  shape of the
                                                       trench (Figures 1 and 2).
                                                       Monitoring

                                                         The sand also provides a medium for placing a system of mon-
                                                       itoring or withdrawal  wells within the cut-off wall envelope. Sand
                                                       backfill is an important component  of the Envirowall Cut-Off.
                                                       Water quality within the wall can be monitored  through the sand
                                                       on a long-term basis. If leakage is ever noted by detection of con-
                                                       tamination in a monitoring well,  the porous sand medium can  be
                                                       pumped to evacuate and control the contaminated water and pre-
                                                       vent further migration beyond the Envirowall Cut-Off.
                                                         The sand is graded to provide a high permeability medium with-
                                                       in the envelope, ideally with a higher permeability than the sur-
                                                       rounding soil in which the cut-off wall is excavated. Small diameter
                                                       piezometers or monitoring wells  are placed in the sand backfill.
                                                       Piezometric head can be routinely observed  and  water  quality
                                                       samples extracted for testing.
                                                         When  piezometers  are installed  within the homogenous sand
                                                       medium  contained  in the envelope,  continuous  monitoring  of
                                                       piezometric head would  indicate  the  condition of the  liner. This
                                                       would require that the water level within the envelope be adjusted
                                                       initially to an elevation below that  of the site. In this  way, a net
                                                       positive head into the Envirowall Cut-Off is established (Figure 3).
                                                                            100 Ull_ SCHLESEL
                                                                            HOPE SHEET
                                                                                           — MONITORING  WELL
                                                                                                   EXISTING
                                                                                                 /— WOUND sunrtct
                                                                 SOIL PERMEATED 73*
                                                                 WITH  BENTONITE^ j
                                                                                                          BENTONITE  FILTER CAKE
                                                                                                       WATER LEVEL AT SITt
                                                                                                      WATER LEVEL INSIDE OF
                                                                                                      ENVELOP HONITOREO
                                                                                                    CLAY LAYER <*->.
                                                                                                       KOMOCK     »
                                                                            PIEZOMETER  IN SAND
                                                                                    N T.S.
                                                                                  Figure 3
                                                                              Piezometer in Sand
                                                                                   N.T.S.
192
BARRIERS

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If leakage of the HDPE  membrane were detected, the gradient
would be into the envelope and a rise in piezometric head would
occur, providing a simple indicator of membrane integrity.
  Water quality monitoring could also be undertaken to determine
the type and  characteristics  of any substances entering the en-
velope. If the envelope were damaged  such that a high rate of
leakage occurred, the high permeability sand medium could also
be pumped. A series of withdrawal wells or well points, likewise
within the sand, could be  used to extract any contaminated liquid
entering and maintain a net gradient into the liner. This provides
a redundant safety feature beyond the  initial establishment of a
low permeability barrier (Figure 4).
                                 - WITHDRAWAL WELLS
                           Figure 4
                   Withdrawal Well Operation
                            N.T.S.
Effluent Removal
   In the case where the waste is very aggressive toward the ben-
tonite  filter cake and HDPE such that the integrity of the mem-
brane  is reduced considerably, the sand medium with withdrawal
wells or well points  simulates a  control structure for dewatering.
This is especially beneficial where existing soil conditions  at the
site are not conducive for establishing an efficient pumping sys-
tem for withdrawal. Collected effluent would then be discharged
for treatment. The  effectiveness will depend on  the spacing of
the wells within the sand.
   Where conditions are such that the sand and withdrawal wells
are being used to control seepage from a site, the Envirowall Cut-
Off will approximate a  fully penetrating slot drain or line sink,
and a  solution  for  drawdown  can be obtained using equations
based on this type of drainage concept.
   Assuming equilibrium conditions under unconfined flow from a
line source and with a vertical  slot penetrating a homogeneous
isotropic stratum and bounded at the base by a horizontal imper-
vious stratum, and further assuming the Dupuit-Forchheimer con-
ditions apply to the hydraulic gradient, then the flow through a
vertical element to the sink can be described by Darcy's Law:
                   Q = kiA
                ,   .    dh
             and:  i  ='—;   A = hx
                       dy

substituting given:   Q = khx  —
                            dy
(1)

(2)


(3)
which describes the basic relationship for drawdown and flow. The
flow (Q) would be equal to the withdrawal rate within the Enviro-
wall Cut-Off (Figure 5).

FULL SCALE TEST
  A full scale construction test project of the Envirowall Cut-Off
was performed at an existing sanitary landfill in New Jersey in the
fall of 1982 to demonstrate the overall construction procedure for
          ORIGINAL
          GROUND
          WATER LEVEL
                                                                                               IMPERVIOUS  BASE
                                                                                            Figure 5
                                                                       Idealized Flow from a Line Source to a Fully Penetrating Slot
fabricating the HDPE envelope and placing it into a trench filled
with slurry by backfilling with sand. The project was conducted
in three phases:
1. The excavation of a triangular-shaped trench filled with  the
   bentonite slurry mixture through the landfill waste
2. The cutting and seaming of HDPE material to form an envelope
   with the prescribed geometry
3. The placement of this HDPE envelope in the trench and sub-
   sequent backfilling with sand and water
  The high density polyethylene (HDPE) envelope was fabricated
by Schlegel Lining Technology, Inc. and later submerged by ICOS
Corporation of America into a trench excavated to  a triangular-
shaped plan. This full scale test introduced several potential  ad-
vantages  of the Envirowall Cut-Off over other types of cut-off
walls and demonstrated the techniques and materials which could
be used in the construction of Envirowall Cut-Off under realistic
conditions.
  Indeed, the test site was an inactive portion of a working land-
fill. The trench was excavated approximately 22 ft, passing through
approximately 10 ft  of previously  deposited solid waste and  ex-
tending down into  the  underlying foundation of meadow mat
(organic peat) which generally occupied the landfill site.
  The trench was excavated by a backhoe in triangular plan creat-
ing sharp corners to  check  the workability of the 100 mil HDPE
membrane to accommodate very angular corners. Each side of the
trench was excavated a distance of 51 ft. The triangular configura-
tion used in the test project presented an example of extreme hand-
ling conditions and provided a good  idea of the problems pre-
sented  in this new type of construction. The entire envelope was
prefabricated from  33  ft wide  rolls of  HDPE above ground to
conform to the triangular-shaped plan (Figure 6).
  Various shapes and sizes were cut and seamed for the one piece
envelope using the Schlegel extrusion welder.  Two corners of the
envelope were preconstructed using a corner jig. The third corner
of the triangle was a closure system which consisted  of two inter-
locking HDPE pipes. Experience indicated  that it was beneficial
to perform as much of the fabrication as close  to the trench as
possible to minimize excessive movement of the liner. This re-
duced the potential for abrasion and handling damage.
  The  trench was filled  with sodium montmorillinite bentonite
slurry having a viscosity of approximately 40 sec by Marsh Fun-
nel. The  slurry stabilized the walls  of the trench until the prefab-
ricated HDPE envelope was ready to be placed.
  A 3 ft  diameter HDPE pipe and a 0.5 ft diameter HDPE pipe
were welded on each  of the two outer edges of the envelope. These
two pipes were used to form an  interlocking joint  at the third
corner of the triangle. The 3 ft diameter pipe was slotted as the
envelope was submerged into the trench  on the last triangular leg.
This pipe joint would later be bonded by pressure grouting.
                                                                                                         BARRIERS
                                                                193

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                                             SAND AND WATER FILL
                                    SIDE A « 51 FT.
                                    SIDE 8 » 72 FT.
                                    SIDE C * 51 FT.
                           Figure 6
               Plan View of the HOPE Liner in Place
                           N.T.S.
  A crane was used to move the 100 mil HDPE into position for
seaming and fabrication. Continuous support was provided for the
envelope with lifting bars and battens to keep it from bending and
wrinkling.
                                                         The entire fabrication process required several days for this first
                                                       installation. As fabrication of the envelope neared completion and
                                                       was made ready for installation, the  trench  was checked and
                                                       cleaned of any debris which  might have  inhibited the installa-
                                                       tion. A clam shell was used to remove any objects that might be
                                                       protruding from the walls or collecting at the bottom of the trench.
                                                       Cranes were again used for the lift of the liner into the trench.
                                                         Using the spreader bars to lift each envelope side and keeping
                                                       them straight, the cranes worked together to set the membrane en-
                                                       velope in place above the trench. The side with the 3 ft pipe  at-
                                                       tached was lowered into the trench first; water was pumped into the
                                                       envelope so that this initial side was lowered sufficiently to allow a
                                                       front-end loader to begin filling with sand. An overflow trench was
                                                       prepared in one corner of the trench to  handle the slurry that was
                                                       displaced as the envelope was submerged. The pipe joint was then
                                                       made by sleeving the 0.5  ft diameter pipe  into the 3 ft diameter
                                                       pipe, making the envelope continuous.
                                                         Sand continued to be dumped into the envelope at a rapid pace
                                                       until it was completely submerged. The  membrane expanded well
                                                       to conform to the shape of the trench. The test program was term-
                                                       inated at this point. However,  at a remedial site, monitoring wells
                                                       and piezometers would be installed in addition  to  pressure grout-
                                                       ing the sleeved pipe joint. Also, the excess membrane above grade
                                                       would be welded to completely  enclose the sand medium within
                                                       the envelope, thereby protecting  it from the weather or accidental
                                                       contamination from above grade. If a site is scheduled to be capped
                                                       with an HDPE membrane, the butting outside edges of the capping
                                                       membrane and the top of the envelope can be jointed by welding to
                                                       complete the enclosure of the site.
                                                         The test project made the Envirowall  Cut-Off concept a reality
                                                       and demonstrated  the feasibility of installing a composite  cut-off
                                                       wall at a landfill site.
194
BARRIERS

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                      SPENT  ACID  AND  PLATING WASTE
                     SURFACE IMPOUNDMENT  CLOSURE

                                             FRANK D. HALE
                                      O'Brien & Gere Engineers, Inc.
                                            Syracuse, New York
                                 CORNELIUS B. MURPHY, JR., Ph.D.
                                       OBG Technical Services, Inc.
                                            Syracuse, New York
                                          ROYDEN  S.  PARRATT
                                         Renshaw Bay  Corporation
                                           E. Syracuse, New York
BACKGROUND

  Since  1958, a surface  impoundment had  been  used  as  a
depository for process wastes from a steel rod and wire manufac-
turing company. A plan view, shown in Figure 1, illustrates the
cellular arrangement of the impoundment constructed using ex-
isting alluvial clay soils. The surface impoundment was expanded
as the  manufacturing  facility grew;  as a  cell was  filled with
wastewater, a higher dike was constructed encompassing a larger
surface area.  The total volume of the impoundment in 1983 was
estimated at 33,000,000 gal, with a surface area of 13.4 acres.
  An Industrial Waste Survey conducted in 1981-82 indicated that
alkaline  cleaners,   hydrochloric  acid,  zinc  plating  solutions,
chromate conversion coating solutions and  wastewater from the
pickling line were discharged to the impoundment. The principal
contributor was the pickling operation where waste pickle liquor
and caustic rinses were generated. The liquid impoundment was
analyzed (Table 1).
 PROPERTY UNE-»(
                                     PROPERTY LINE -
  A treatment facility which would eliminate the need for the sur-
face impoundment was being designed in 1982. These facilities were
expected to be operational by the fourth quarter of 1983. Conse-
quently in Nov. 1982, consideration was given to closing the surface
impoundment. In addition, the water level was rising to a point
where continued discharges to the impoundment was not prudent.

                        Table 1
     Concentrations of Various Chemicals in the Impoundment


Chemical
Arsenic
Barium
Cadmium
Calcium
Chloride
Chromium (hex)
Chromium (total)
Cyanide (free)
Cyanide (total)
Floride
Iron
Lead
Magnesium
Concen-
tration
(mg/1)
0.024
0.5
0.058
435
1729
0.005
2.57
0.01
0.05
46.7
1933
0.4
75


Chemical
Mercury
Nitrate (as N)
Nickel
Orthophosphate
pH
Potassium
Selenium
Silicon
Silver
Sodium
Sulfate
Suspended Solids
Zinc
Concen-
tration
(mg/1)
0.0004
1.0
1.75
0.7
1.75 unit
81.6
0.002
94
0.05
596
6150
41
191
                        Figure 1
               Surface Impoundment Site Plan
  As the recipient of listed hazardous wastes, namely "spent pickle
liquor from steel finishing operations," the surface impoundment
was regulated as a Treatment, Storage or Disposal Facility under
the  Resource Conservation and Recovery Act of 1976. Data col-
lected during the Industrial Waste Survey indicated that corrosivity
was the only characteristic of either the sediments or the overlying
water which would qualify as hazardous per RCRA criteria. The
concentrations of lead and chrome in the acidic impoundment
water were less than the USEPA's EP Toxicity Limit of 5 mg/1 as
was the EP extract from impoundment sediments.
  As the impoundment did receive the "listed" hazardous waste
"KO6, spent pickle liquor from steel finishing operations," the
contents and contaminated soil was regulated as a hazardous waste
until "delisted" pursuant to 40 CFR 260.20 and 40 CFR 260.22.
Consequently the handling of the liquid contents and contaminated
soils was dictated by RCRA. Projected delays in the approval of
                                                                                           TREATMENT
                                                   195

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 the "delisting" petition resulted in the submittal of a Closure Plan
 which assumed the materials were hazardous wastes.
   The first step in the closure of the site required the removal of the
 free liquid in the impoundment. Given the specific conditions, the
 most attractive  discharge point was the available sanitary sewer
 system. The advantages  included dilution of the high total dis-
 solved solids, minimal permitting requirements and ready access to
 a suitable sewer. Discharge to the sanitary sewers required com-
 pliance with the sewer  use ordinance (Tabale 2).

                           Table 2
               Sewer Use Ordinance Discharge Limits
                                                                   100
         Chemical
         PH
         Boron
         Cadmium
         Chromium (hex)
         Chromium (tri)
         Iron
         Nickel
         Lead
         Zinc
Discharge Limit
 6-9 units
 1
 2
 2
10
15
 3
 0.1
 2
   Based on the comprehensive sampling and analysis, it was deter-
 mined that iron, sulfates, chlorides and  zinc were the principal
 ionic components. In addition, the average concentrations  of 0.4
 mg/1,  191  mg Zn/1 and 1933 mg Fe/1 were in excess of the cor-
 responding limits for discharge to the sewer. The existing pH of less
 than 2 also was not suitable for discharge to sanitary sewers.
   An evaluation of alternatives for the removal of the metals of
 concern by physical/chemical process,  disposal of  sludge and
 subsequent closure of the surface impoundment was initiated. The
 criteria used to evaluate these alternatives included compatibility
 with program objectives, technical feasibility, ease of implementa-
 tion,  potential  for  regulatory agency acceptance  and estimated
 costs.

 TREATMENT TECHNOLOGY
   Various treatment methods such as chemical precipitation, ion
 exchange,   electrochemical  oxidation  and  reverse osmosis  are
 available  for  the   removal  of chemical  constituents  from
 wastewaters.' Initial screening indicated that chemical precipitation
 was  the most  attractive approach. Neutralization of the  highly
 acidic wastewater in the impoundment could be accomplished with
 hydrated lime (CafOH)^, sodium carbonate (Na2CO3), limestone
 (CaCo3) or sodium hydroxide (NaOH).
   Zinc and lead have minimum solubilities (Figure 2) with respect
 to the hydroxides at a pH of 9 to 10.' At these hydrogen ion con-
 centrations, the iron content would also be within sewer use limita-
 tions. Combined neutralization of the 33,000,000  gal in the im-
poundment and subsequent precipitation of the metals at a pH of
approximately 9 therefore, appeared to be the most technically and
economically feasible alternative.
   Preliminary tests conducted by the manufacturer indicated that
 agricultural limestone could increase the impoundment pH only to
 5, even at limestone dosages as high as 23 g/1. As much as 5 g/1
 hydrated lime was required to further raise the pH to 9. Hydrated
 lime alone could neutralize the raw water to pH 9 at a dosage of ap-
 proximately 10 g/1.
   It was apparent that the chemical  make-up of the liquid  in the
 impoundment was such that a number of physical/chemical reac-
 tions were  involved. An extensive  laboratory investigation to arrive
 at optimum combination and dosages of chemicals would have
 been time consuming and costly and would have defeated the pur-
 pose of minimizing total costs. Hence, a more rational approach
                              i.o
 o.i
0.01
                                                                 0.001
                           0.0001
                                                      Figure 2
                                   Solubilities of Metal Hydroxides as a Function of pH
                                             from USEPA 440/1-82/091-b
                           was followed. This consisted of the simulation of chemical treat-
                           ment using a chemical equilibrium program and verification of the
                           computer simulated results with bench scale tests.
                           COMPUTER SIMULATION

                             An aqueous chemical equilibrium model, MINEQL, developed
                           by Westall, et a/.2 and modified at Syracuse University, was used to
                           evaluate treatment chemicals and operating pH.  MINEQL solves
                           for the concentration of various soluble and precipitated chemical
                           species  from mass  action and mass balance expressions  by the
                           Newton-Ralphson interactive  technique.  The  effects  of ionic
                           strength and temperature on the thermodynamic  equilibrium con-
                           stants are incorporated in the computation. A detailed description
                           of the computer algorithm is given by Westall, et al.1 The input to
                           the model includes temperature and the total concentration of ca-
                           tions and anions.
                             Four  combinations of chemicals: (1) hydrated lime, (2) calcium
                           carbonate and hydrated lime, (3) caustic and (4) calcium carbonate
                           and caustic  were  simulated.  Two  general  conditions were
                           evaluated, an open condition and a closed condition. The open
                           condition simulates a system  at equilibrium with the  atmosphere,
                           whereas a closed system does not interact with the  atmosphere. The
                           predicted pH values from the computer simulation for the open
                           and closed system are presented in Tables 3 and 4.
                             The results of CaCo3 computations confirmed preliminary find-
                           ings that CaCo3  would not  increase the pH above  5.3-5.9 in a
1%
         TREATMENT

-------
                            Table 3
           pH from Computer Simulations of Titrations for
                   System Open to Atmosphere
(1)
CaC03
Dose pH
9/1
0 1.8
2 2.1
6 2.5
8 7.5
10


(2)
Ca(OH),
Dose pH
9/1
0 1.8
2 2.1
6 7.5
8 7.5



(3)
8 g/1 CaC03;
and Ca(OH).
Dose pH
9/1
0 7.5
2 7.5
6 7.5




(4)
NaOH
Dose
9/1
0
1
3
4
5
6
7

pH
1.8
2.1
2. 1
2.2
2.4
3.0
8.0
8.9
'(5)
8 g/1 CaCO,;
and NaOHJ
Dose pH
9/1
0 7.50
1 7.6
2 7.6
3 7.7
4 7.7
5 7.8
6 8.00
7 8.9
                           Table 4
          pH from Computer Simulations of Titrations for
                  System Closed to Atmosphere
(1)
CaC03
Dose
9/1
0
2
4
6
8
10


pH

1.8
2.1
2.2
2.5
5.6
5.6


(2)
Ca(OH)?
Dose pH
9/1
0 1.8
2 2.1
4 2.3
6 11.8
8 11.8



(3)
8 g/1 CaC03;
and Ca(OH),
Dose
9/1
0
1
2
3
4
5
6
7
PH<

5.9
6.0
6.1
6.4
7.4
7.8
8.2
11.6
(4)

NaOH
Dose
9/1
0
1
2
3
4
5
6
7
PH

1.8
2.5
3.5
4.1
7.2
7.7
8.0
9.0
(5)

8 g/1 CaCO,;
and NaOHJ
Dose
9/1
0
1
2
3
4
5
6
7
pH

5.9
6.0
6.2
6.5
6.6
6.7
6.9
7.5
closed system. This is similar to a short term laboratory test. The
maximum pH was attained at a minimum CaCO3 dosage of 8 g/1.
An open system would allow the pH to rise to about 7.5 at the same
CaCO3 dosage. The reduction in the Zn and Pb concentrations was
significant  but inadequate. At pH  7.5, Zn  concentrations were
estimated at 34.7 mg  Zn/1 and 0.27 mg Pb/1. This suggested that a
higher pH would be required to achieve the limits.
  Utilizing Ca(OH)2  to neutralize the impoundment contents also
resulted in variable results depending on whether the system was
open or closed. An open system resulted in a maximum pH of 7.5;
consequently, the  metal concentrations were unacceptable. The
closed system required between 4 and 6 g/1 to raise the pH above
9.5. At  a dosage of 6 g/1 the resultant pH was 11.8, and the key
metal concentrations  were 0.56  mg Zn/1 and 0.002 mg Pb/1. Diffu-
sion of  CO2 from the atmosphere into the treated liquid would
depress  the pH. In most applications of Ca(OH)2 this diffusion is
insignificant.
  A test utilizing  pretreatment with 8 g/1 of CaCO3 followed by
Ca(OH)2 resulted  in  no pH change in the open system. This was
due to movement of CO2 into the solution. The closed system
resulted in a pH rise. However,  the amount of Ca(OH)2 required to
raise the pH to 9 was similar to the test case with no CaCO3
pretreatment.
  Sodium hydroxide at a dosage of 7 g/1 would be required to raise
the pH to  9. Interaction with atmospheric CO2 had little effect on
the required dosage.
  The fifth system tested utilized 8 g/1 CaCO3 followed by NaOH.
This system under closed conditions precipitated CaCO3 and the
pH increased with NaOH  addition.  Under both closed and  open
conditions, over 7 g/1 NaOH was required to  raise the pH to 9.
  In situations where calcium or carbonate compounds were to be
used to neutralize impoundment contents, the equilibrium with the
atmospheric significantly affected chemical requirements. A system
which was allowed to equilibrate, after 8 g/1 of CaCO3 addition,
with the atmosphere (open system) would  contain very little CO2.
Subsequent alkalinity addition under relatively closed  conditions
would optimize chemical dosages  for these materials. Such a com-
bination theoretically required 8 g/1 CaCO3 and approximately 0.2
g/1 Ca(OH2) of NaOH to neutralize the raw waste to a pH of 9. The
actual Ca(OH)2 dosage would be expected to be somewhat higher if
the CO2 supersaturation in the impoundment after CaCO3 addition
is not completely relieved.
  As a result  of the MINEQL computer evaluation, it  was deter-
mined that certain combinations  of chemicals and reaction times
were likely to be effective in neutralizing the impoundment and
reducing soluble  metal components to acceptable  concentrations.
Preliminary costs, presented as Table  5, were determined to focus
laboratory verification on the more cost effective alternatives.

                           Table 5
        Projected Chemical Costs for Surface Impoundment
             Neutralization from Computer Simulation

                                            Cost
Treatment                       Dosage (g/1)   ($/MiIlion Gal)
CaCo3                          8             not effective
Ca(OH)2                        6              2200
CaCO3, then Ca(OH)2             8/6            3170
CaCo3, equilibrate, Ca(OH)2        8/0.1          1010
NaOH                          7             15170
CaCO3, then NaOH               8/7           16140
CaCO3> equilibrate, NaOH         8/0.1          1190
LABORATORY EVALUATION
  Based on the computer model simulation, the following systems
were tested using samples obtained from various points on the sur-
face of the impoundment:
  a. Single stage Ca(OH)2
  b. Pretreat with CaCO3, polish with Ca(OH)2
  c. Pretreat with CaCO3, polish with NaOH
  The bench scale tests conducted in the laboratory utilized con-
ventional jar test  equipment with field tests conducted using 10 1
containers. A titration with NaOH was used to verify model predic-
tions. The results, presented in Figure 3, indicated that 5.5-6.0 g/1
NaOH would be required.
                          Figure 3
        Neutralization Requirements from Bench Scale Tests
                                                                                                     TREATMENT
                                                         197

-------
Single Stage

  The  computer model results suggested a theoretical Ca(OH)2
dosage of 6 g (Ca(OH)2/l under expected conditions. After 10 min.
of mixing, 6 g Ca(OH)2/l resulted in a pH of 7.3 whereas 10 g
(Ca(OH)2/l resulted in a pH greater than 12. These experimental
results indicated that with the waste stream, the actual dosage re-
quired was  greater than the predicted 6 g/1  but less than 10 g
Ca(OH)2/l.
  A 10 1 test was conducted at 8.0 g Ca(OH>2/l to  obtain larger
volumes of sample to work  with. The 8.0 g Ca(OH)2/l treatment
resulted in a pH of 9.0 after 15  hr. The difference between  the
predicted dosage of 6 g/1 and observed dosage of 8 g/1 was at-
tributed  to  mixing  efficiency and CO2 infiltration. Supernatant
metals were measured at 0.15 mg Zn/1 and less than 0.2 mg Pb/1.
  A completely mixed sample dosed at 10 g Ca(OH)2/l was used to
conduct a settling test in a 100 ml graduated cylinder. The results,
presented in Tables 6 and 7, suggest a settling velocity for this treat-
ment of 0.5 cm/min., equivalent to a surface overflow rate of 170
gal/day-ft2. Allowing the material to settle further  resulted  in a
final sludge volume of B% (v/v).

Pretreatment with CaCO3 Polish with Ca(OH)2

   Impoundment contents treated with 10 g CaCO3/l are used as a
starting material. The pH was 4.0 after 15 hr of equilibration. After
39  hours of equilibration, the pH had risen to 5.0. When aerated
for 2 hr after  39 hr of equilibration, the pH increased to  5.5.  Ex-
amination of  the titration curves presented in Figure 3 illustrates
the significant  impact  the residual CO2 had on  chemical re-
                                                      quirements. As expected, the closer the CaCO3 solution was to
                                                      equilibrium with the atmosphere, the lower the Ca(OH)2 require-
                                                      ment to reach a target pH of 9.0.
                                                         Analyses conducted on the supernatant indicate that at a 3 g
                                                      Ca(OH)2/l dosage, metal concentrations were 0.2 mg Zn/1 and less
                                                      than 0.1 mg Pb/1. The supernatant cleared rapidly with settling test
                                                      results suggesting a settling velocity of 2.7 cm/min. or 950 gal/day-
                                                      ft2.  The  residual sludge volume after polishing treatment, when
                                                      combined with that expected from the CaCO3  pretreatment, was
                                                      comparable to that observed for the Ca(OH)2 treatment.  Solids
                                                      production was estimated to be 8550 mg/1 or 37 tons/million gal
                                                      for both stages of treatment.
                                                      Pretreatment with CaCO3, Polishing with NaOH

                                                         A 15 hr settled supernatant of a 10 g CaCO3/l pretreated sample
                                                      was treated with NaOH. A  dosage of 1.5 g NaOH/1 resulted in a
                                                      pH of 8.6, whereas a pH of 9.2 was achieved with a dosage of 2.0 g
                                                      NaOH/1.  A  sample which  had been stored for a  longer period
                                                      resulted in a pH of 10.3 at a  dosage of 2.0 g NaOH/1. These results
                                                      indicated that residual CO2  in the CaCO3 pretreated sample con-
                                                      sumed considerable  alkalinity.  Analyses of supernatant samples
                                                      resulted in metal concentrations of 0.03  mg Zn/1 and less than 0.1
                                                      mg Pb/1. Supernatant TSS was  determined to be 90  mg/1.
                                                         The sample was resuspended and the interface height reported as
                                                      a  function of time. The results, presented in Table 7, suggested a
                                                      settling velocity for the  solids of approximately  0.5 cm/min.,
                                                      equivalent to a surface overflow rate of 170 gal/day-ft2. The NaOH
                                                      sludge volume was greater  than that observed for the Ca(OH)2
                                                      treatment mode. The sludge production  was 5700 mg/1.
                                                            Table 6
                                            Laboratory Evaluation of Chemical Treatment


Pretreatment

— —
-
-
10 g/1 CaC03
10 g/1 CaC03


Treatment

10 g/1 CaC03
8.0 g/1 Ca(OH)2
6.5 g/1 NaOH
20 g/1 CaCO /6 g/1 Ca(OH)
3 g/1 Ca(OH)2
2 g/1 NaOH
Final
pH
(S.U.)

3.0
9.5
11.5
7.1
10.5
10.3



Supernatant
TSS
(mg/1 )
1400
162
-
130
90
Zn
(mg/1 )
72
0.15
0.25
0.04
0.20
0.03
Pb
(mg/1 )
0.3
0.1
0.1
0.1
0.1
0.1


Sludge
TSS Vol.
(mg/1) (%)
3100
6200
-
5480
5700
(a)

10
27
-
20
25
40
  a. Sludge volume measured after 15 hours.
                                                            Table 7
                                             Sludge Volumes after Chemical Treatment
Pretreatment
None
None
None
10 g/1 CaCO
10 g/1 CaCO
Treatment
12 g/1 CaCO
6 g/1 Ca(OH)
10 g/1 Ca(OH)
3 g/1 Ca(OH)
2 g/1 NaOH
Final
pH
4.8
5.5
11.3
9.5
10.3
Sludge Volume (%)
5 min
100
70
90
25
94
10 min
52
40
76
20
73
30 min 60 min
10 9
20 12
44 32
19 16*
46 31
Comments
Fines, settle slow
Fines, settle slow
Few fines
Clear supernatant
Clear supernatant
 198
TREATMENT

-------
CHEMICAL TREATMENT OF IMPOUNDMENT
  Two process schematics were prepared.  One involved in situ
neutralization of the impoundment with the capability of polishing
prior  to  discharge to the sanitary  sewer. The second provided
neutralization of the impoundment in a temporary facility con-
structed on site.
  Bench scale tests conducted using 100 cm long and  1 cm inner
diameter tubes demonstrated  that limestone slurry up to 35%
(w/w) sprayed over the surface of the impoundment to give a mean
dosage of  10 g/1 would  result in  uniform distribution of the
limestone with minimim mixing. Similar tests with Ca(OH)2 sug-
gested incomplete mixing.
  Major equipment items were identified and costs allocated for in
situ neutralization and external neutralization. The most cost effec-
tive approach was the  in situ  neutralization  with CaCO3  and
Ca(OH)2.
  The selected approach involved bulk limestone deliveries of ap-
proximately 22  ton  capacity.  Specialized  equipment to  slurry
limestone at a concentration of 35% (w/w) CaCO3 in  to dilution
tank was provided as illustrated in Figure 4. The slurry from the
dilution tank at 18% (w/w) was then pumped to a 100  ft distribu-
tion header utilizing flexible hose with a quick disconnect fitting. A
winch was  used  to move  the  distribution header  across the im-
poundment in 100 ft swathes. The velocity was maintained at 1.5
ft/min.
 TO DISTRIBUTION
    SYSTEM
-1
OISTHBUTION WMP-^ 1

<_r
BULK SHIFMENT

1 // "--SLUfmr WSTER MMP
r~77
  IMPOUNDMENT /I   -I V

    DILUTION TUK-S  /
                           Figure 4
                  Lime Application Equipment
  One thousand four hundred and thirty tons of limestone were ad-
ded to the impoundment over a period of two weeks. Visual obser-
vation indicated that the mixing of the impoundment due to injec-
tion velocity and wind provided good distribution of the limestone
throughout the impoundment.
  Stoichiometric calculations indicated that 3.3 g CO2/1 would be
generated due to the limestone addition. Based on diffusion rates,3
the time for 90% of the CO2 generated to be  released to the at-
mosphere was  estimated to be 30 hr. Measurements at various
                                                            Figure 5
                                                    Effluent Polishing Facilities

                                 points in the impoundment indicated  that the pH rose steadily to
                                 approximately 5 after five days with a clear supernatant observed.
                                   Approximately  a  week after the final limestone additions, 220
                                 tons of hydrated lime  were added to  the impoundment over a
                                 period of five days.  Although earlier laboratory tests with the 100
                                 cm glass column  indicated that lime  did  not mix as well as the
                                 limestone, the high degree of mixing observed with limestone addi-
                                 tion justified trying the same procedure with the hydrated lime. The
                                 total amount of lime added resulted in a dosage of about 1.6 g/1.
                                 When all the lime  was added, the impoundment was uniformly at a
                                 pH of approximately 11.5. Analysis of supernatant indicated that
                                 lead and zinc concentrations were well below the sewer use limits.
                                 The excess alkalinity was provided to neutralize expected subse-
                                 quent discharges of acid waste from the processing plant.
                                   Within a week of the final bulk lime addition, supernatant from
                                 surface of the impoundment was pumped to a clarifier to remove
                                 any suspended particles prior to  discharge to  the city sewer. The
                                 system included for polishing the wastewater, if required, is shown
                                 in Figure 5. The approved discharge was at an average rate of 180
                                 gal/min. The discharge was discontinued during periods of rain
                                 when the  municipal treatment plant was close to  its handling
                                 capacity of 6 mgd. Typical effluent quality is presented in  Table 8.
                                 IMPOUNDMENT CLOSURE
                                   As  the impoundment was still actively treating the plant waste,
                                 discharge to the sanitary sewers was  in compliance with RCRA.
                                 Final  closure required that an approved Closure Plan be submitted
                                 to the regulatory authorities at least 180 days prior to closure initia-
                                 tion. As the waste treatment facilities were expected to be on line
                                 during Aug. 1983, the Closure Plan was submitted to the regulatory
                                 authorities  in early Mar. 1983.
                                   The projected timetable, presented as Figure 6,  was submitted
                                 with the Closure Plan. The actual timetable will be significantly af-
                                 fected by weather conditions and regulatory action. At the time of
                                 writing, the timetable is being met. However,  indications are that
                                                            Table 8
                                                Treated Impoundment Water Quality
   Sample  Date
Sample Site
                                                                Zn
Concentration  (mg/1)
  Pb                 Fe
                                                                                      Cr
April 4, 1983
April 4, 1983
April 
-------
                      Groundwater Monitoring
                      Closure Plan Submlllal
                      Discharges to Impoundment
                      Equipment Delivery
                      ln~situ Neutralization
                      Water Level Reduction
                      Passive Dcwaterlnp.
                      Dellsling Petition
                      Grading and Compaction
                      Surface Reclamation
                      Certification  of Closure
                                                                           777%
                                                                                                     177x1
V////A
    X//////////////////777A
         V/////////////////////1
                                      Y77*
                                                                                   -t-
                                            JFMAMJJASONDJFMAMJJ

                                                              1983                                   198<
                                                                     Figure 6
                                                     Surface Impoundment Closure Timetable
                                                                    Figure 1
                                                Approximate Contours After Closure—Plan View
200        TREATMENT
-------
               90S


               994


               992


               990
                                   a~ LIME MS40JC -
                                                     -EXISTING NATURAL ALLUVIAL O.OV3
                                                                     996


                                                                     906


                                                                     994


                                                                     992


                                                                     990


                                                                     960


                                                                     90S


                                                                     9*)
               •M


               984
EXISTING INTERNAL CLAY DUE
                              B LIME RESlBJt
                                                             Figure 8
                                            Approximate Grade After Closure—Section View
additional  residue  samples will  be required by the regulatory
authority  prior to Closure  Plan  approval.  This may  delay
regulatory approval and thus move Final Closure into 1984.
  The proposed  Closure  Plan results in  a  final  grading  plan
presented as Figure 7 and sections as illustrated in Figure 8. Use of
local  clays for the cap  will provide  an environmentally sound
closure for the material present.

SUMMARY
  A 33,000,000 gal. surface impoundment containing spent pickle
liquor and plating wastewater required treatment  and aqueous
disposal. The  combined use of a chemical equilibrium model and
bench scale tests made it  possible to  evaluate a combination of
chemicals  within  a short  period of time. The required chemical
dosages and final pH conditions, as predicted by the computer pro-
gram, were in agreement with both bench  scale tests and actual
treatment of the waste impoundment. The least cost chemical treat-
ment  system consisted of limestone addition followed by hydrated
lime.
                        A specialized chemical slurry distribution system provided an ex-
                      cellent means of adding limestone and hydrated lime uniformly to
                      the impoundment. Effluent quality met sewer use limitations and
                      the aqueous disposal is continuing on schedule.
                        Final closure of the site will depend on regulatory review and ap-
                      proval. The projected final closure involves utilizing in situ passive
                      dewatering followed by the installation of a clay cap. The clay cap
                      will be graded and protected by top soil.

                      REFERENCES
                      1. Patterson, J.W., Wastewater Treatment Technology, Ann Arbor Sci-
                        ence, Ann Arbor, MI,  1970.
                      2. Westall, J.C., Zachary, J.L.  and Morel,  F.M.M., "MINEQL-A Com-
                        puter Program for the Calculation of Chemical Equilibrium Composi-
                        tion of Aqueous Systems," Technical Note No. 18, Department of Civil
                        Engineering, MIT, July 1976.
                      3. Stumm, W. and Morgan, J.J., Aquatic Chemistry: An Introduction
                        Emphasizing  Chemical Equilibria  in  Natural  Waters,  Wiley-
                        Interscience, New York, 1970.
                                                                                                        TREATMENT
                                                                                 201
-------
      TREATABILITY OF HAZARDOUS  WASTE LEACHATE
              AT PUBLICLY  OWNED TREATMENT WORKS

                                             ROBERT D. GOLTZ
                                       SALVATORE BADALAMENTI
                                               ROBERT N. OGG
                             U.S. Environmental Protection Agency, Region II
                                             New York, New York
INTRODUCTION

  During the past three years, the control and cleanup of hazar-
dous waste landfills has become an environmental program priority
in the United States. One of the primary objectives of the program
has been to mitigate the effects of leachate from hazardous waste
landfills on ground and  surface  waters, especially those used as
drinking water supplies.  One method being explored in USEPA
Region II  is treatment of hazardous waste leachate in Publicly
Owned Treatment Works.
  Since passage of the Clean Water Act in 1972, the Congress has
appropriated approximately $45  billion to  construct  new and
rehabilitate existing municipal sewer systems and treatment works
to provide a minimum of secondary treatment capability to ensure
attainment of water quality standards within the United States.
During the last  10 years, that effort has resulted in the construction
of plants,  using federal,  state and local funds, in many com-
munities.  Frequently, however,  those  treatment  systems  are
hydraulically underutilized. Therefore, it appears prudent, where
possible, to utilize the excess capacity of Publicly Owned Treat-
ment  Works (POTWs) to treat  leachate from  hazardous waste
landfills. Such an effort will increase the return on the  public in-
vestment  in the POTWs by providing new revenues while
simultaneously  addressing the environmental priority of cleaning
up hazardous waste sites.
  Because  POTWs were  generally designed to  treat sewage, it is
critical to determine whether hazardous waste leachate can be safe-
ly treated before a full-scale addition is begun. Such a determina-
tion requires the performance of a treatability study.
  In this paper, the authors present the results of two treatability
studies performed on leachate from the Lipari Landfill' in Pitman,
New Jersey and the Kin-Buc Landfill2 in Edison, New Jersey. Addi-
tionally, a general approach for conducting these types of studies is
discussed. As a result of this effort, the authors believe that treating
hazardous  waste landfill leachate in POTWs will provide a cost-
effective solution for disposing of leachate from many hazardous
waste sites.

METHODS

  The State of New Jersey has established the following guidelines
for conducting treatability studies:
•Sample Collection and Analysis
  At least three samples of leachate must be taken, composited and
analyzed for conventional and priority pollutants. One  8 hr day-
time composite sample of the  influent and effluent of the POTW
shall be analyzed in the same way.
                                                   •Inhibition
                                                     Using various dilutions of leachate and influent, either an acute
                                                   toxicity test or an oxygen uptake test shall be run to examine in-
                                                   hibitory effects of leachate on the activated sludge.
                                                   •Treatability
                                                     An influent (8 hr day-time composite) and leachate combination
                                                   shall be added to a stabilized bench-scale replicate of the activated
                                                   sludge treatment system. The dilution should provide for a safety
                                                   margin of five; that is, the fraction of leachate for the test shall be
                                                   at least five times the expected fraction of the final discharge. The
                                                   test shall be run for at least three days after the system is stabilized.
                                                   •Evaluation
                                                     The following tests shall be performed during the  treatability
                                                   test:
                                                   (1) Sludge settling characteristics
                                                   (2) Mixed liquor suspended solids
                                                   (3) Oxygen uptake
                                                   (4) Treatment removal efficiency for conventional,  selected or-
                                                      ganic compounds and metals
                                                   •Nitrification—Denitrification
                                                     If the  POTW utilizes a nitrogenous treatment system,  the
                                                   treatability tests  and  evaluation shall be  replicated  for  the
                                                   nitrogenous and the carbonaceous systems.
                                                   •Discussion
                                                     In the report on this testing, the discussion should include: effect
                                                   of leachate on treatment system; need for pretreatment;  effect of
                                                   pretreatment  of leachate  on  treatability;  calculation  of  pass
                                                   through  and sludge contamination of pollutants of full-sized
                                                   system based on  bench scale studies.
                                                   •Conclusions and Recommendations
                                                     As a result of conducting the study, it can be determined whether
                                                   or not the POTW should  accept the leachate and any specific
                                                   pretreatment measures that  may be required.
                                                   KIN-BUC LANDFILL STUDY

                                                     The Kin-Buc Landfill is located in Edison, New Jersey. From
                                                   1971 to 1976, it accepted approximately 70,000,000 gal of various
                                                   industrial and chemical waste. In 1979, an oily sheen, presumed to
                                                   be leachate from the landfill, was observed in a natural depression
                                                   near the toe of the landfill. Further investigation determined that
                                                   both an oily phase and aqueous phase leachate were flowing from
                                                   the landfill. The oily phase of the leachate contained high concen-
                                                   trations  of polychlorinated  biphenyls  (PCBs) and the aqueous
                                                   phase contained other priority pollutants.
202
TREATMENT
-------
  Since 1980, the USEPA  has been collecting the oily phase
leachate while releasing the aqueous phase into a nearby creek
where it ultimately finds it way into the Raritan River. To alleviate
this situation, the USEPA developed a plan to collect the aqueous
phase,  pretreat it, and discharge it to the Middlesex County Utility
Authority's (MCUA) POTW for treatment.
  To  determine   specific  pretreatment  requirements  for  the
leachate, a treatability study was performed  based on the New
Jersey  Department of Environmental Protection guidelines. It was
calculated that a maximum of 10,000 gal/day of aqueous leachate
would  have to be collected,  pretreated  and discharged to the
MCUA. Flow at the MCUA is estimated to be about 70 mgd with
an average flow between 80-85 mgd; the plant capacity is 120 mgd.
The biological treatment process of the plant utilizes pure oxygen.
  A sample of the aqueous  leachate was  collected  and analyzed.
The  total  petroleum hydrocarbon  level was reduced by physical
separation to less than 100 mg/1, the pretreatment level required by
the New Jersey  Department of Environmental  Protection. This
sample was then analyzed for the 129 priority pollutants, seven con-
ventional  pollutants and 24  non-conventional pollutants.  The
pollutants that were found are shown on Table 1.
  The  aqueous phase leachate was subjected to an acute toxicity
test, an oxygen  uptake study  and a bench scale continuous ac-
tivated sludge treatability  study.
  There was no measurable effect of the Kin-Buc leachate even at
100% concentration as determined by final dissolved oxygen. The
oxygen  uptake study demonstrated  that greater  than 2% by
volume  of the Kin-Buc leachate  has the potential to initially in-
hibit the unadapted MCUA  activated sludge.  Above  12.5%  a
definite  inhibition  is apparent. Removal  efficiencies  of a bench
scale activated sludge system for the  129  priority pollutants that
were above detectable limits in the leachate and the accumulation
of these priority pollutants in the sludge generated by the system
are shown in Tables 2 and 3. As can be seen, the removal efficiency
for most compounds ranged from 95% to 99%. There also  ap-
peared to be no accumulation of priority pollutants in the sludge
except  for  methylene chloride and  bis (2-ethylhexyl)  phthalate
which was probably due to the use of Tygon tubing.

Lipari Landfill Results
  The Lipari Landfill is located in  the  Township of  Pitman,
Gloucester County, New Jersey. From 1958-1971, the landfill ac-
cepted household wastes, liquid and semi-solid chemical wastes and
other industrial wastes and  materials. Components  of the hazar-
dous wastes dumped at the landfill  have percolated  into  the
groundwater. Chemical contaminants  have leached through  the
embankments of two nearby streams.
                                                           Table 1
                                              Analysis of Aqueous Kin-Buc Leachate
A) Priority Pollutants (GC/MS)
1) Purgeable Organics

Benzene
Chlorobenzene
1 ,2-Dichloroethane
1 , 1 -Dichloroethylene
Ethylbenzene
Methylene Chloride
Trichlorethylene
Toluene

Concentration
fno/n
lug/ U
2860
1390
1120
1530
243
1180
1040
5120
Non-Priority Pollutants in Purgeable Fraction
Acetone
Ethyl Acetate
Cyclopentane
Methyl Ethyl Ketone
Aklyl Ether
Total Xylenes
2) Acid Extractables
Phenol
1210
2220
884
1530
4750
393
(mg/1)
15.4
Non-Priority Pollutants in Acid Extractable Fraction
Cresol Isomer
Bensoic Acid
Phenyl Acetic Acid
Phenyl Proponic Acid
3) Base/Neutral Compounds
Diethylphthalate
Non-Priority Pollutants in Base/Neutral
Aniline
Anisol
Dimethyl Aniline Isomer
Alkyl Benzene Isomer
Methyl Benzylamide
Dichloroaniline Isomer
Quinoline or Isoquinoline
Alkylamine Isomer
4) Pesticides and PCB
Compounds were in concentrations below
detectable limits
4.23
29.1
53.3
20.9
(mg/1)
7.37
Fraction
0.50
1.27
3.68
1.57
11.4
0.41
2.79
15.2
(mg/1)


5) Metals
Antimony
Cadmium
Chromium (Total)
Copper
Lead
Mercury
Nickel
Zinc
B) Conventional Parameters
1) Analysis Parameters
BOD
COD
TOC
TSS
TDS
NH3
pH (units)
C) Non-conventional Parameters
1) Analysis Parameter
Color (units)
Nitrate-N
Nitrite-N
Total Organic Nitrogen
Oil and Grease
Total Phosphorus
Radioactivity
Sulfate
Sulfide
Sulfite
Surfactants
Aluminum
Boron
Cobalt
Iron
Magnesium
Manganese
Tin
Titanium


(mg/1)
0.535
0.012
0.439
0.06
0.108
0.0025
1.59
28.4

(mg/1)
18,000
15,200
940
1,860
2,048
44.8
5.8

mg/1
5,000
0.05
0.004
85
1,040
2.6
Insuff. sample
1,150
84.5
30
0.897
4.18
10.8
0.18
1,540
382
24.5
1.2
2.3


                                                                                                     TREATMENT
                                                         203
-------
  As part of USEPA's feasibility study, an examination of an alter-
native that includes collection and treatment of this leachate at the
Gloucester County Utilities Authority (GCUA) was conducted.
  The  GCUA treatment plant consists of primary clarification
followed by a "modified" contact stabilization activated sludge
process. After secondary clarification, the water is chlorinated and
discharged. The sludge is presently disposed of in a landfill, but
GCUA is considering composting of the sludge for application to
non-agricultural lands. The average flow rate is 14.5 mgd.
  The treatability study examined the following:
                                                        •Pollutant removal
                                                        •Accumulation of pollutants in the sludge
                                                        •Release of volatiles into the air
                                                        •Inhibition screening study in accordance with the NJDEP guide-
                                                         lines
                                                          Two reactor vessels were used in the biotreatability study; Reac-
                                                        tor #1  represents a sewage to leachate ratio (by volume) of 100:1
                                                        which will reflect actual operations,  and Reactor 02 represents a
                                                        sewage to leachate ratio of 20:1 which provides the safety margin of
                                                        five required by NJDEP.
                                                             Table 2
                           Kin-Bat: Purgeable Organic Constituent Analysis of Effluent Samples Treatability Testing
Compound
Benzene
Bronod ichlorone thane
Chloroform
1 ,1-Dichloroe thane
1 , 2-Dichloroethane
Ethylbenzene
Methylene Chloride
Toluene
1,1, 1-Tr ichloroe thane
Trichloroethylene
Total Xylenes
MCSV
Kin-Buc
Influent
10/25(ppb)
103
36.9
36.5
32.5
1240
10.4
689
132
8.0
4.5
24.0
Effluent
10/25-
10/26
(ppb)
ND
ND
ND
ND
ND
ND
10.7
ND
ND
ND
ND
%
Removal
10/25-
10/26
>99
>97
>97
>97
>99
>90
>98
>99
>87
>78
>95
MCSV
Kin-Buc
Influent
10/26(ppb)
112
31.4
32.4
30.2
1730
8.2
621
81.3
7.6
ND
18.6
Effluent
10/26-
10/27
(ppb)
ND
ND
ND
ND
ND
ND
5.3
ND
ND
ND
ND
%
Removal
10/26-
10/27
>99
>96
>96
>96
>99
>88
>99
>98
>87
—
>94
MCSV
Kin-Buc
Influent
10/27 (ppb)
106
30.7
30.7
31.5
1980
7.3
786
29.7
4.5
ND
12.4
Effluent
10/27-
10/28
(ppb)
ND
ND
ND
ND
ND
ND
4.1
ND
ND
ND
ND
%
Removal
10/27-
10/28
>99
>96
>96
>96
>99
>86
>99
>96
>78
—
>92
    ND — Nondctcctable less than 1.0 ppb
    Dales of Testing: 10/25, 10/26. 10/27
                                                             Table 2
                  Kin-Buc: Acid Extractable Organic Compound Constituent Analysis of Effluent Samples Treatability Testing
Compound
4-Chloro-3-Methyl-
phenol
2,4-Dinitrophenol
2-Methyl-4,6-
Dinitrophenol
Phenol
2,4, 6-Tr ichloro-
phenol
MCSV
Kin-Buc
Influent
10/25(ppb)
510
100
38
7850
210
Effluent
10/25-
10/26
(ppb)
ND
ND
ND
ND
ND
%
Removal
10/25-
10/26
>99
>99
>97
>99
>99
MCSV
Kin-Buc
Influent
10/26 (ppb)
ND
ND
53
9770
300
Effluent
10/26-
10/27
(ppb)
ND
ND
ND
ND
ND
%
Removal
10/26-
10/27
—
—
>98
>99
>99
MCSV
Kin-Buc
Influent
10/27 (ppb)
540
46.5
ND
8150
ND
Effluent
10/27-
10/28
(ppb)
ND
ND
ND
ND
ND
%
Removal
10/27-
10/28
>99
>97
—
>99
—
    ND — NofKJctectable lew than 20 ppb
 204
TREATMENT
-------
                                                             Table 2
                 Kin-Due: Base-Neutral Organic Compound Constituent Analysis of Effluent Samples Treatability Testing
Compound
Benzo( a ) Anthracene
Benzo ( a ) Pyrene
Bis ( 2-Ethylhexyl )
Phthalate
Butyl Benzyl
Phthalate
Di-n-Butylphthalate
1 , 2-Dichlorobenzene
Diethylphthalate
2 ,4-Dinitrotoluene
2 ,6-Dinitrotoluene
Hexachlorobutad iene
Hexachlorocyc lopent-
adiene
MCSA/
Kin-Buc
Influent
10/25 (ppb)
ND
ND
ND
58.9
ND
38.6
45.6
33.7
72.9
42.4
255
Effluent
10/25-
10/26
(ppb)
45.9
36.4
ND
ND
ND
ND
ND
ND
ND
ND
ND
%
Removal
10/25-
10/26
(in-
crease)
(in-
crease )
—
>98
—
>97
>97
>97
>98
>97
>99
MCSA/
Kin-Buc
Influent
10/26(ppb)
ND
ND
4890
48.5
ND
405
34.8
ND
ND
36.6
124
Effluent
10/26-
10/27
(ppb)
ND
ND
3900
ND
35.6
ND
ND
ND
ND
ND
ND
%
Removal
10/26-
10/27
—
—
20
>97
(in-
crease )
>99
>97
—
—
>97
>99
MCSA/
Kin-Buc
Influent
10/27 (ppb)
22.3
ND
ND
83.4
ND
40.8
38.8
25.7
45.8
43.8
229
Effluent
10/27-
10/28
(ppb)
ND
ND
4900
ND
ND
ND
ND
ND
ND
ND
ND
%
Removal
10/27-
10/28
>95
—
(in-
crease )
>98
—
>97
>97
>96
>98
>97
>99
ND — Nondetectable less than 20.0 ppb
                                                              Table 2
                                   Kin-Buc: Selected Metal Constituent Analysis of Effluent Samples



Compound
Zinc
Chromium
Nickel
MCSA/
Kin-Buc
Influent
10/25(ppb)
4.90
0.075
0.054
Effluent
10/25-
10/26
(ppb)
1.58
0.028
0.043
%
Removal
10/25-
10/26
68
73
20
MCSA/
Kin-Buc
Influent
10/26(ppb)
3.44
0.069
0.049
Effluent
10/26-
10/27
(ppb)
2.99
0.036
0.044
%
Removal
10/26-
10/27
13
48
10
MCSA/
Kin-Buc
Influent
10/27(ppb)
6.63
0.083
0.060
Effluent
10/27-
10/28
(ppb)
2.77
0.043
0.060
%
Removal
10/27-
10/28
58
48
0
                                                                                                           TREATMENT
205
-------
                                                                     Table 3
                                        Kin-Bnc: Purgeable Organic Compound Analysis of Sludge Samples
Compound
Chloroform
1,1-Dichloroethane
1,2-Dichloroethanc
Ethylbenzene
Methylene Chloride
Toluene
1,1,1-Trichloro-
 ethane
Total Xylenes
         Before Kn-Bac
         Addition
         10/25/S2
         CoKtilration
         0*/i)
         118
          12.9
          25.6
          8.8
         ND
          9.8

          12.9
          8.0
                                      Dwtag Tmtabflity Testing
                                    10/27/82  10/27/82  10/2I/S2
                                    3:45 pm   6M pm   8:00 pm
18.9
19.2
18.3
 7.8
ND
 5.2

 9.6
 9.0
19.4
 9.5
17.2
 6.8
ND
 4.8

 9.3
 5.2
12.3
10.9
10.6
 3.8
 5.9
 2.41

11.4
ND
        Kln-Bac: Add ExtracUble Organic Compound Analysis
                          of Sludge Samples
No compounds present above detectable limits (200 pg/1)
         Kin-Buc: Base Neutral Organic Compound Constituent
                      Analysis of Sludge Samples
Bis(2-Ethylhe*yl)      6000             1710      3600      1600
 Phthalate
Di-N-Butyl-
 phthalate           ND               330      ND       ND
           Kin-Buc: Pesticide and PCBs Organic Compound
                      Analysis of Sludge Samples
Aldrin               10.4            ND       ND        1.3
    Kin-Buc: Selected  Metal Constituent Analysis of Sludge Samples
                                    During Treatability Testing
                                                                Parameter
                                                                Zinc
                                                                Chromium
                                                                Nickel
                                                                Total Suspended
                                                                 Solids
                   Before KJn-Boc
                   Addition
                   10/25/82
                   (mg/1)
                     47.8
                      0.596
                      0.176

                   4400
10/27/82   10/27/82   10/28/82
3:45 pm   6:35 pm    8:00 pm
(mg/1)     (mg/1)     (mg/1)
  28.7       29.9       16.3
   0.423      0.368     0.273
   0.135      0.125     0.125
                                                                           5000
                                                                                     4800
                                                                                               4560
                                                                     Table 4
                                                         Llpari Water Quality Analyses*

Detection
Limit
Influent
Effluent
Percent
Removal
Expected
Percent
Removal
Mixed Liquid
Total
Sludge
Liquid
Phase
Total
Sludge
(mg/kg)
                                                                    REACTOR  II
COD (mg/L)
BOD, (mg/L)
Phenol
Benzene (pg/L)
Toluene (ug/L)
Ethyl-benzene (ug/L)
pMn xylene (ug/L)
o+Xylene (ug/L)
1,2-Dichloroethane (ug/L)
bis(chloroethayl)ether
(ug/L)
bis(chloroethoxy)ethane
(ug/L)
Copper (ug/L)
Iron (ug/L)
Manganese (ug/L)
Zinc (ug/L)

-
5
1
1
1
1
1
1
25
5
1
8
1
3
248(32)
157(10)
135(8)
11(13)
59(13)
1.5(13)
3.3(8)
1.5(8)
41.6(8)
174(8)
364(12)
6.4(9)
461(9)
4.5(9)
8.2(9)
28(31)
18(10)
<10(8)
<1(12)
<1(12)
92.3(8)
>86.5(11)
>96.6(11)
>42.7(4)
>58.4(8)
>50.7(4)
86.3(6)
>85.9(6)
>98.3(11)
-10.0(6)
71.4(9)
59.1(5)
8.4(9)


>90
>80
>80
>80
—
—
>60
>80
>50
<50
>80
<20
>60
NA
NA
<76.2(8)
-------
                                                        Table 4 (continued)

Detection
Limit
Influent
Effluent
Percent
Removal
Expected
Percent
Removal
Mixed Liquid
Total
Sludge
Liquid
Phase
Total
Sludge
(rog/kg)
REACTOR 12
COD (mg/L)
BOD, (rng/L)
Phenol
Benzene (pg/L)
Toluene (ug/L)
Ethyl-benzene (ug/L)
p-nn Xylene (ug/L)
o-Xylene (ug/L)
1 , 2-Dichlor oethane ( ug/L)
bis ( chloroethayl ) ether
(ug/L)
bis( chloroethoxy) ethane
(ug/L)
Copper (ug/L)
Iron (ug/L)
Manganese (ug/L)
Zinc (ug/L)

	
5
1
1
1
1
1
1
25
5
1
8
1
3
309(31)
184(10)
430(8)
65.3(11)
485(11)
7.6(11)
22(11)
11.5(11)
273(8)
1344(8)
1980(12)
8.0(9)
2265(9)
8.9(9)
15.5(9)
31(31)
17(10)
<8.1(10)
<1(10)
96.2(8)
>98.6(9)
>99.8(9)
>88.5(9)
>94.1(10)
>91.3(9)
79.6(8)
>97.1(8)
>99.8(11)
14.3(7)
84.7(9)
63.7(9)
-6.04(6)


>90
>80
>80
>80
—
—
>60
>80
>50
<50
>80
<20
>60
NA
NA
<152(8)
<2(10)
<8.8(10)
<1.4(10)
<1.3(9)
<1.1(10)
78.8(9)
<25.6(9)
<11.9(11)
<240(8)
45012(8)
157(8)
510(9)
NA
NA
<61.3(3)
<4.7(3)
<47.7(3)
<1(3)
<1.1(3)
<1(3)
41(4)
<25(3)
<28(5)
<2(4)
3498(4)
263(4)
11.5(4)


62.0
<0.82
3.6
0.57
0.53
0.45
32.2
10.4
4.8
97.9
18,372
64
208
  A summary of the results of selected pollutants removed by the
system is shown in Table 4. In general, the organic removals were
consistent with expectations. However, the metal removals varied
widely.
  The accumulation of the pollutants in the sludge are also noted in
Table 4. The concentrations of these  substances do not  exceed
any  of  the parameters  listed  in  New Jersey's Sludge  Quality
Assurance  Regulations (Table 5). However, no regulations have
been established for the allowable concentrations of organic com-
pounds  found in the Lipari ground water.
  Results of the air quality monitoring during the reactor operation
are presented in Table 6. For the chemicals present in the Lipari
groundwater, no air concentrations exceeded the NIOSH-8 hour
Time Weighted Averages.
  Inhibition  screening  tests  were  performed  on  composited
leachate samples. The objective of the tests was to determine if the
leachate would have an inhibiting effect on the activated sludge
process. The data indicated that only slight inhibition occurred at a
sewage  to  leachate ratio of 3:1. This  inhibition, measured by a
decrease in the oxygen uptake rate, is not considered to be signifi-
cant.

CONCLUSIONS
  The results of these two studies show that both the MCUA and
the GCUA POTWs are capable of treating  the leachate from the
                           Table 5
      State of New Jersey Sludge Quality Assurance Regulations
Contamination Indicators for Heavy Metals & Toxic Organic Compounds
Heavy Metals
Arsenic (total)
Cadmium (total)
Chromium (total)
Copper (total)
Lead (total)
Mercury
Nickel (total)
Zinc (total)




mg/kg
10
16
890
850
500
5
82
1,740




Toxic Organic
Compounds
Aldrin
Chlordane
Dieldrin
Endrin
Heptachlor
Heptachlor
exposide
Lindane
Methoxychlor
p.p-DDT
p,p'-DDE
Toxaphene
Polychlorinated
biphenyls (PCBs)
mg/kg
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.25
0.25
0.25
1.0
0.50
                                                                                                      TREATMENT
                                                         207
-------
                           Table 6
  N1OSH 8-Hour Time-Weighted Averages (TWA)1 for Chemicals in the
   Leachate and Observed Emission Concentrations for Lipari Landfill
Compound
Benzene
Toluene
Ethylbenzene
m + p-Xylene
o-Xylene
Methylene chloride
1 ,2-Dichloroethane
bis(chloroethyl)-ether
1. OSHA Safely and Health
NIOSH 8-Hr
TWA (ppmv)
10
200
100
100
100
500
50
152
Manual; 29 CFR 1910,
Emission
Concentration
No Wind
(ppmv)
0.031
0.090
0.0031
0.0073
0.0035
0.405
0.537
0.0085
Revised November 7,
01. mph Wind
(ppmv)
0.00014
0.00038
0.000013
0.000031
0.000014
0.0017
0.0023
0.000036
1978. Reference (14)
Kin-Buc and Lipari landfills respectively. However, it is still the
prerogative of the POTW as to whether or not they will accept the
waste. Factors which the POTW must consider are the following:
•How much of the underutilized capacity does the POTW want to
 be used by leachate? What is the anticipated future loading from
 other sources in the POTW's service area?
                                                        •What additional cost would the POTW incur by accepting the
                                                         leachate? For example, are there any additional monitoring re-
                                                         quirements or are any process changes necessary to better accom-
                                                         modate the leachate?
                                                        •What pretreatment levels, if any, should be set for the leachate?
                                                         Are local pretreatment requirements being met?
                                                        •What is the public perception of the POTW treating the leachate?
                                                         Also, what are  the POTW workers'  perception?  Air quality
                                                         studies alone may not allay people's fears.
                                                          Discharging to a POTW has the advantage of utilizing an existing
                                                        system that can effectively treat the waste and provides  an alter-
                                                        native to creating another  on-site treatment system with direct
                                                        discharge into  a surface water and  its associated operation and
                                                        maintenance cost.
                                                       REFERENCES

                                                       1. Radian Corporation; Draft Report of the "Treatability Study of Con-
                                                          taminated Groundwater From the Lipari Landfill,  Pitman,  N.J.,
                                                          Feb. 1983.
                                                       2. Princeton Aqua  Science,  "Treatability Study of Kin-Buc  Landfill
                                                          Leachate", Dec. 1982.
208
TREATMENT
-------
 COST  EFFECTIVE TREATMENT  OF PRIORITY POLLUTANT
     COMPOUNDS WITH  GRANULAR ACTIVATED CARBON

                                                V.A. BRUNOTTS
                                                L.R.  EMERSON
                                                   E.N. REBIS
                                                    A.J. ROY
                                               Calgon Corporation
                                            Pittsburgh, Pennsylvania
INTRODUCTION
  Carbon adsorption has played a key role in many wastewater
treatment installations in helping them meet their treatment objec-
tives. Based on a decade of experience, the authors discuss the ef-
fectiveness of activated  carbon for the removal of a variety of
pollutants when utilized for treatment in a representative sample of
17 industrial projects. Data from 29 groundwater and spill control
applications will be presented to demonstrate the efficiency of car-
bon adsorption in this area of treatment. The cost effectiveness of
carbon adsorption, while accomplishing high removal efficiencies,
will also be  discussed.
  In light of new treatment challenges (groundwater contamina-
tion, for example) and  future comprehensive priority pollutant
regulations, Calgon has developed a new technology for analyzing
contaminated water quickly. The newly developed Accelerated Col-
umn Test (ACT) has several advantages over conventional test
methods in addition to the speed with which it can be run. The ad-
vantages of the ACT will be discussed along with an example of
how the ACT correlates  to current testing methods.

CARBON EFFICIENCY
  During the past 10 years, granular  activated carbon (GAC) has
been used to remove a wide variety of organic compounds from
many types  of contaminated water. The wide diversity of applica-
tions is illustrated in Tables 1 and 2 which show the type of applica-
tion, major  priority pollutants involved and project operating con-
ditions.  In  all,  project  operational  data are  presented for 17
industrial wastewater, 11 chemical spills and 18 groundwater ap-
plications.
  The majority of applications employ dual adsorption units. Each
adsorber contains 20,000 Ib of granular activated  carbon  (GAC)
and operates under pressure in a downflow series mode. Series
operation provides for total exhaustion of the GAC in the lead bed
while the polish bed produces the required effluent quality.
  Analytical monitoring data consisted of GC/MS characterization
of composite  samples of  adsorber influent and  effluent. This
monitoring reflects the period between installation of fresh carbon
in the lead adsorber and the time  of exhaustion for the organic
compound of interest. High percentage removals were observed in
all cases, regardless of the type or concentration of priority pollu-
tant present. Greater than 99% removal was achieved in a majority
of cases. Priority pollutants  in these applications were typically
reduced to non-detectable levels (approximately 1 /tg/1).
  When removal  of other  organic compounds  (non-priority
pollutants) was not a treatment objective,  the systems were not
operated to achieve low microgram per liter levels of these com-
pounds in the effluent.
  A wide variety of organic compounds are present in the listed ap-
plications (Tables 1 and 2); the most common are aromatic and
halogenated solvents. Contaminants in both groups are removed
very well by the adsorption process. Solubility is a key parameter in
determining how  well an organic  compound will adsorb; low
solubilities are  preferable for adsorption efficiency. Generally,
organic compounds which adsorb poorly are low molecular weight,
highly polar species such as methanol, formaldehyde or acetic acid.
High molecular weight highly branched aliphatics such as car-
bohydrates and proteins also adsorb poorly. A few of each group
are listed in Tables 1 and 2. Typically, the  type of organic com-
pounds which do not adsorb well from water exhibit low toxicity
and can be discharged to a  biological unit process for further
removal, if necessary.
  Methylene chloride is one halogenated solvent present in fairly
high concentrations in a number of effluents. Because of its high
polarity and solubility, methylene chloride will break through a car-
bon bed earlier than most other priority pollutants. When methy-
lene chloride removal was not a specific requirement, this con-
taminant was allowed to opass into the effluent while other con-
taminants of more importance continued to adsorb  on the lead
carbon adsorber. This is the case in Table 1, examples 2 and 12.
  Another critical parameter in adsorption system design is contact
time, which is normally reported as empty bed contact time, as
computed by the ratio of adsorber volume to flow rate. The recom-
mended minimum contact time, 7.5 min for surface water treat-
ment, is adequate to assure no  kinetic limitations to adsorption per-
formance. For wastewater applications, greater contact times are
sometimes needed. The projects listed have  contact times ranging
from 12 min to 30 hr.
  It is obvious that contact time must be critically evaluated for
each project. The new Accelerated Column Test, discussed later in
this paper, is a valuable tool for the evaluation of this parameter.

EXTRACTION/CONCENTRATION OF
ORGANIC COMPOUNDS

  A prime benefit of adsorption is the ability of activated carbon to
concentrate organic compounds several thousand-fold from dilute
solutions (Table 3 and Figure 3). For highly contaminated streams,
organic compounds are concentrated 80 to 100 times. This adsorp-
tion characteristic is important in evaluating disposal  costs of con-
taminated  waters. Cleanup  of contaminated waters through
adsorption, followed by transportation of the spend carbon to  a
                                                                                               TREATMENT
                                                      209
-------
                                              T»ble 1
Influent
Project
1







2







3


TVM Conwunds Cone.
WW TOC
Benzene
Toluene
Trimethylpyradine
Aniline
Benzonitrile
Phenol
Cresol
Dimethyl phenol
in Methylene Chloride
Dlchloroethylene
D1 ethyl Ether
Chloroform
Dlchloroe thane
Trlchloroe thane
Benzene
B1s(2-Chloroethyl) Ether
Benzole Add
TOC
WW Nltrophenol
Phenol
Chlorophenol
(•9/1)
440
.388
.290
.200
.460
.080
11
7.600
2.475
.013
.034
.207
5.080
.100
1.400
.008
2.240
.025
340
296
2.8
1.2
Dimethyl coumaranylmethylmethylcarbamate 2.4
Methyl phenol 21
Xylene ?•?






4






5

6




7












Ethylbenzene
1-Chloro 3-N1trobenzene
Nltrophenol
Acetophenone
Olchlorocyclobutane
TOC
WW Methylene Chloride
Chloroform
Trlchloroe thylene
Olmethylcoumaranylmethylcarbamate
Hydro xycuma rone
Methyl pro penyl phenol
Dlethylethanolamine
TOC
WW Methylene Chloride
Acetone
Hydroxymethyl pentanone
TOC
Mil Acetone
Methylene Chloride
Methyl ethyl Ketone
Tol uene
Methyl pentanone
Phenol
Dimethyl phenol
TOC
WW Butadiene
Chloroform
Methylchloropentane
Benzene
Toluene
Ethylbenzene
Napthalene
Flourene
Acenapthalene
Phenanthrene
Dimethyl phenol
Phenol
TOC
0.6
0.2
0.16
0.62
0.27
700
5.4
0.3
0.5
52.2
54.6
7.8
7.8
385
0.4
0.09
0.15
40
0.45
0.92
0.32
0.32
0.42
4
0.9
130
0.014
0.036
0.092
2.8
3.0
0.8
0.16
0.008
0.007
0.009
0.041
4.4
10
.„-„-, Contact
Effluent Q Annua1 , 6AC Tine
Cone, (ngyi) GPM Gal x 10° 1/1000 Gal (Min)

.002
N/D
N/D
N/D 30 6.5 40 330
N/D
.001
N/D
N/D
.013
N/D
N/D
754
'N/D 60 10.5 7.9 165
.011
N/D
N/D
.003
100
18
0.08
0.2
0.07
1.2 300 157 15 60
0.3
0.1
0.006
N/D
0.006
0.001
43
0.3
0.01
N/D
0.006 5 T.2 50 2000
0.01
N/D
0.005
7
0.2
0.01 270 140 0.6 37
0.04
20
0.14
N/D
0.002
N/D 40 20 25 250
N/D
N/D
N/D
5
0.002
0.025
0.002
0.6
0.3
N/D 1000 520 0.9 20
N/D
N/0
N/D
N/D
0.002
0.085
< 2

Pretreataent











Coagulation
Filtration







Sedimentation
Filtration








None




Coagulation
Bio-Treatment

Filtration








Coagulation







210
TREATMENT
-------
Table 1
Influent
Project Type Compounds Cone
8 WU Benzene
Toluene
Acrylonitrile
Dichloroethane
Thiophene
Benzonitrile
Styrene
Xylene
Pyrldine
Aniline
Phenol
Benzofuran
Cresol
Napthalene
Quinoline
Indole
Dimethyl phenol
TOC
9 WU TOC
Chloroform
Phenol
Dimethyl phenol
Trichlorophenol
Dichlorophenol
Isopropyl phenol
Arochlor 1242
10 WU Chlorotoluene
Xylene
Dimethylacetamide
Pyradine
Dichlorobenzene
Dimethylamiline
Isophorone
Dichlorobenzene
Chloroform
Butylalcohol
Benzene
Tetrachloroethylene
Toluene
Hethanol
Acetic Acid
TOC
11 WW TOC
Phenol
Nitrophenol
Chlorophenol
Methyl pyrolodone
Dimethyl Sulfone
Chlorocresol
Dimethyl acetami do
Acetone
Benzene
Toluene
Xylene
Hexyloxyethenol
Butoxy Ethoxy Ethanol
12 WU Phenol
Chlorocresol
Trichlorophenol
Isophorone
Napthalene
Ethylbenzene
Chlorobenzene
Toluene
Trichloroethylene
Trichlorethane
Chloroform
Methylene Chloride
TOC
13 WW Phenol
Cresol
Dimethyl phenol
Dichloroethane
Dichloropropane
Trichloroethylene
Tertbutyl Alcohol
Acetone
TOC
. (mg/1)
5.8
2.1
0.15
0.06
0.42
4.9
0.5
0.5
12.9
3.5
29
0.4
5.6
3.6
5.2
7.0
0.9
345
14
0.026
0.254
0.015
0.077
0.053
0.168
0.015
2
0.7
1.2
0.06
0.04
0.2
3.2
0.24
0.62
0.170
0.11
0.4
0.185
167
800
2000
1100
18
6.5
1.9
.62
.27
.30
.79
.42
0.22
0.065
0.2
10.9
2.9
8.9
0.7
0.08
0.3
0.036
0.1
0.04
1.6
1.4
1.3
0.6
10.3
3400
69
107
2.9
0.18
0.05
0.16
0.62
1.43
400
..,,. . n Annual /../•
Effluent Q fi 6AC
Cone, (mg/1) GPM Gal x 10° 1/1000 Gal
0.08
N/D
0.03
N/D
N/D
N/D
N/D
N/D
0.5 280 180 14
0.07
0.04
N/D
N/D
0.001
0.001
0.0004
N/D
70
4
0.006
0.002
0.002 200 126 0.6
N/D
N/D
0.016
N/D
N/D
N/D
0.4
N/D
N/D 40 10 50
N/D
N/D
N/D
0.005
0.105
N/D
N/D
N/D
150
800
1000

N/D
N/D
N/D
.32
.18
N/D 55 20 12
.56
.29
N/D
N/D
N/D
N/D
N/D
0.7
N/D
N/D
Of\A
• U*f
N/D
N/D 40 8.0 15
N/D
N/D
0.1
OT
. I
0.25
21.0
1000
N/D
N/D
N/D
N/D 175 90 16
N/D
0.01
0.32
0.31

Contact
Time
(Min) Pretreatment








71 Filtration












100 Sedimentation
Filtration







250 Precipitation
Coagulation
Filtration














180 Coagulation
Neutralization
Filtration








250 Coagulation
Ammonia Strip
Filtration






57 Equalization
Filtration


                                  TREATMENT
211
-------
                                                           Table 1

Project Type
14 WW











IS WW *





16 WW

















>7 WW
Leachate











Compounds
TOC
Phenol
Dimethyl phenol
Cresol
Tertbutyl phenol
Ethyl benzene
Xylene
Tetramethy 1 butyl phenol
Benzene
THoxane
Toluene
Formaldehyde
TOC
Dlchloroethylene
Trlchloroethylene
Tetrachloroethylene
Trlchlorobenzene
Alkyl Phthalate
P.CB
TOC
Methylbenzolcacld
Phenol
Benzole Acid
Benzene
Toluene
Chlorobenzene
Ethyl benzene
Xylene
Cresol
Chlorooctane
Butoxy Ethoxy Ethenol
Olphenylether
01ethylbenzam1de
Phenoxy Toluene
Butyl toluamlde
Dlallylphthalate
Phenoxybenzyl Alcohol

TOC
Phenol
Benzole Add
Chlorobenzolc Add
Dlchlorophenol
Dimethyl butadiene
Chlorotoluene
Benzaldehyde
Xylene
Toluene
Tetrachloroethylene
Influent
Cone. («g/1)
610
13.5
0.38
0.35
2.1
8.4
26.4
2.1
0.025
0.035
0.3
100
18
0.46
0.40
0.07
0.005
0.034
0.060
860
33
2.8
0.9
0.8
5.1
3.8
2.6
9.3
4.2
2.7
6.2
2.1
4.8
9.6
253
11.0
79.1

3100
47
79
35
2.9
7.8
26.3
3.5
7.1
7.1
17.1
Effluent Q
Cone. fug/I) GPH
320
0.12
N/D
N/D
N/D
0.016 70
0.07
0.002
N/D
0.004
N/D
100
7
0.12
0.031
N/D 100
N/D
0.014
N/D
245
0.71
0.3
N/D
0.3
2.1
1.0 7
0.3
0.7
N/D
0.035
0.5
0.035
1.1
0.1
63
0.011
12

250
1.2
1.8
1.5
N/D 40
N/D
N/D
N/D
N/D
N/D
N/D
Annual Contact
"nnu" 8 GAC Tine
Gal x 10° 1/1000 Gal (Mln) Pretreatnent





36 45 140 Sedimentation








52 1.6 100 Filtration









3.6 64 1400 011 Skin
Equalization
Filtration














20 40 250 None





* Carbon 1s land-filled and not reactivated
central reactivation facility, is almost  always more cost effective
than transporting  and handling  bulk  liquids for  diposal. Com-
pounded with environmental and safety concerns of handling bulk
liquids, it is apparent that disposal of bulk liquids is not as desirable
as the reactivation  or disposal of spent carbon.
  Despite the variability of treatment requirements, the majority of
projects utilize adsorbers containing 20,000 Ib, the equivalent of
one full  truckload  (due to over-the-road  weight  limitations) of
granular activated carbon. The size of the adsorbers allows the car-
bon to be handled  in bulk, thereby reducing freight expenses.
  Spent  carbon  is removed  from  the  treatment  system when
organic contamination is detected in the system effluent. Carbon
removal  is  accomplished by using air pressure to automatically
transfer the carbon out of an adsorber as  a  slurry. The slurry  is
directed to a waiting truck which transports the carbon to a central
reactivation center. The transfer is accomplished in a closed system
with no worker exposure to the spent carbon.
Costs

  Several factors influence the costs of adsorption:
•The type of contaminants present
•Influent concentrations
•Flow rates
                                                        •Carbon (volume and type)
                                                        •Discharge requirements
                                                        •Urgency and duration of the project
                                                        The applications shown in Tables 1 and 2 range in flow from 5 to
                                                        1000 gal/min, in TOC concentrations from less than 1 mg/1 to 3400
                                                        mg/1 and in carbon utilization from 0.1 to 64 lb/1000 gal. In addi-
                                                        tion, a wide range of organic compounds is also encountered. Us-
                                                        ing this information, treatment economics are more clearly defined.
                                                          Adsorption costs per volume treated are illustrated by the shaded
                                                        area in Figure 1. The costs are all-inclusive, encompassing the car-
                                                        bon, adsorption equipment, reactivation and transportation.  In
                                                        two applications in which the carbon is landfilled for disposal, the
                                                        cost of landfill disposal is included. At low concentrations (TOC
                                                        below  10 mg/1, as in the case of many groundwaters), adsorption
                                                        costs range from  a few cents to about $3/1000 gal  treated. At
                                                        higher concentrations, costs rise. TOC concentrations of 1000 mg/1
                                                        result in GAC treatment costs ranging from $6 to $35 per 1000 gal.
                                                        Low polarity, low  solubility organic compounds have the lowest
                                                        unit costs in each case.
                                                          System economics can be viewed in another way by calculating
                                                        the $/lb of contaminant removed, as shown by the shaded area in
                                                        Figure 2.  At TOC concentrations above 1000 mg/1,  removal costs
                                                        are below $4/lb TOC removed for all the  organic compounds
212
TREATMENT
-------
Table 2
Project
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

Type
Truck Spill
Rail Car
Spill
Rail Car
Spill
Rail Car
Spill
Chemical
Spill
Chemical
Spill
Chemical
Spill
Gasoline
Spill
Solvent
Spill
Gasoline
Tank
Leakage
Rail Car
Spill
Chemical
Solvents
Gasoline
Tank
Leakage
Chemical
Solvents
On-Site
Storage
Tanks
Chemical
Spill
Chemical
Spill
On-Site
Storage
Tanks
On-Site
Storage
Tanks
Chemical
Landfill
Landfill
Site
On-Site
Storage
Tanks
On-Site
Storage
Tanks

Compounds
Methylene Chloride
1 ,1 ,1-Trichloroethane
Phenol
Orthachl oro-Phenol
Phenol
Vinyl idine Chloride
Ethyl Aery late
Tetrachl oroethy 1 ene
Chloroform
Carbon Tetrachl oride
Trichloroethylene
Chloroform
Carbon Tetrachloride
Trichloroethylene
Tetrachl oroethy 1 ene
Benzene
Tetrachl oroethy 1 ene
Benzene
Toluene
Xylene
1 ,1 ,1-Trichloroethane
Trichloroethylene
Tetrachl oroethy 1 ene
Methyl T-Butyl Ether
Di-isopropyl Ether
Trichloroethylene
Chloroform
Trichloroethylene
Tetrachl oroethy 1 ene
Trichloroethylene
Di-isopropyl Ether
Trichloroethylene
CIS-1 ,2-Dichloroethylene
Trichloroethylene
CIS-1 ,2-Dichloroethylene
Trichloroethylene
Tetrachloroethylene
CIS-1 ,2-Dichloroethylene
Trichloroethylene
Tetrachl oroethy 1 ene
Chloroform
Trichloroethylene
Trichloroethylene
1 ,1 ,1-Trichloroethane
1 ,l-D1chloroethylene
TOC
Chloroform
Carbon Tetrachloride
Etc., Etc.
CIS,l-2-Dichloroethylene
Trichloroethylene
Tetrach 1 oroethy 1 ene
Methylene Chloride
1,1 ,1-Trichloroethane

Influent
Cone, (wj/1)
21
25
63
100
32-40
2-4
200
70
3-4
130-135
2-3
0.8
10.0
0.4
10-20
0.4
4.5
9-11
5-7
6-10
143
8.4
26
30-35
30-40
50-60
20
30-40
140-200
40-50
20-30
20-25
10-15
50
5
5
10
5
5
10
300-500
5-10
30-250
60-80
5-15
20
1.4
1.0
14.0
0.5
1.0
7.0
1.5
3.3

Effluent Q
Cone, (mg/1) GPM
< 0.001 20
< 0.001
< 0.001 80
< 0.001
< 0.01 173
< 0.01
< 0.001 100
< 0.001 40
< 0.001
< 0.001
< 0.001
< 0.001 180
< 0.001
< 0.001
< 0.001
< 0.001 95
< 0.001
< 0.1 5
Total
< 0.001 350
* 0.001
< 0.001
< 0.005 450
< 0.001
< 0.001
< 0.001 30
< 0.001 260
< 0.001
< 0.001 450
« 0.001
< 0.001 160
e 0.001
< 0.001 250
< 0.001 85
« 0.001
< 0.001
< 0.001 150
< 0.001
< 0.001
< .1 200
< 0.001
< 0.001 350
< 0.001 350
< 0.001
< 0.005 20
< 0.001
< 0.001
< 0.001
< 0.001 165
< 0.001
< 0.001
« 0.10 20
< 0.001

.„-.„! Contact
GAC Annua1 , TIM
0/1000 Gal Gal x 10b (Min)
3.9 10.4 534
5.8 41.5 201
2.1 875 TVT* 60
13.3 300 TVT* 52
11.6 20.7 262
2.8 93.3 58
1.9 49.2 112
< 1.01 2.6 214
.40 191.9 15
.62 233.3 12
7.7 15.6 160
0.21 131.4 21
0.10 233.3 12
0.32 82.9 35
0.38 129.6 42
0.25 44.1 121
0.25 77.8 70
1.19 103.7 26
0.16 181.4 30
<0.45 181.4 30
1.15 10.4 41
0.8 85.5 64
4.0 10.4 526
* TVT - TOTAL
Pretreatment
None
Filtration
None
Filtration
None
None
None
None
None
None
Air Strip
None
Air Strip
None
None
None
None
None
Filtration
Air Strip
None
Filtration
None
None
VOLUME TREATED
                                 TREATMENT
213
-------
                                                         Table 2


Project Type
24 On-slte
Storage
Tanks

25 On-Slte
Storage
Tanks
26 On-S1te
Well
Storage
Tanks
27 Chemical
By-
Products
28 Hfg.
Residues

29 Leachate




Compounds
TMchloroethylene
Xylene
Isopropyl Alcohol
Acetone
1,1,1-Trlchloroe thane
1 ,2-D1chloroethylene
Xylene
CIS-l,2-D1chloroethylene
Trlchloroethylene
Tetrachl oroethy 1 ene

Dl-lsopropyl Methyl
Phosphonate
Dlchloropentadlene
DDT
TOC
1 ,3-Dichloropropane
Hexachloroe thane
Hexachlorobenzene
Hexachlorobutadlene

Influent
Cone, (mg/1)
3-8
.2-. 5
.2
.1
12
0.5
8.0
0.2
0.5
2.0

1.25

0.45
0.004
9.0
0.01
3
4
6
Annual Contact
Effluent Q GAC fi Time
Cone, (mg/1) 6PM 1/1000 Gal Gal x 10° (M1n)
< 0.001 30 1.54 15.6 36
< 0.001
< 0.01
< 0.01
< 0.005 200 1.0 103.7 52
< 0.001
* 0.001
< 0.001 150 0.75 77.8 70
< 0.001
< 0.001

< 0.05 175 0.70 90.7 30

< 0.01
O.0005 160 1.8 82.9 31
-
< 0.001
< 0.001 200 1.0 103.7 30
< 0.001
< 0.001


Pretreatment
None



None


None



Filtration


Filtration





  1,000
    100
                                                                 1,000
                                                          100
                                                                    10  -
            10  20  30 40 50  60  70  80  90  100 110 120

               Treatment Cost ($71000 Gallons Treated)
                                                                      6       12       18     24     30

                                                                      Treatment Cost ($/lb.TOC Removed)
                         Figure 1
    Influent TOC Concentration vs. Treatment Cost (Gal treated)
                                                                               Figure 2
                                                       Influent TOC Concentration vs. Treatment Cost (Ibs TOC removed)
214
TREATMENT
-------
listed. At lower concentrations, removal costs ranged from $6 to
$30/lb of TOC. In field applications, the economy of the successful
isolation of a concentrated point source can be readily seen. At
high concentrations, proportionally high percentage loadings are
possible. This reduces  carbon usage and results in more favorable
treatment costs. The best way to determine treatment cost for a
particular stream is to  test in a pilot plant.

ACCELERATED COLUMN TESTING

  Once installed, the system must be effective in removing the con-
taminants  and operate in a  cost-effective manner. The key to
designing an operational adsorption system for a particular ap-
plication hinges on the validation testing done before installation.
Until now, necessary validation testing was often time consuming
and  expensive.  Extensive  time consumption  results from  pilot
systems that totally simulate full-scale systems, therefore requiring
the same time period to  saturate carbon as a full-scale system. In
the case of groundwaters, where systems can be on-line for months
or longer,  feasibility testing time requirements limit the  ability to
respond quickly to contamination emergencies.
  Responding to a need for much shorter and accurate tests to ob-
tain design  and  predicted  performance  data,  Calgon R&D
developed the Accelerated Column Test. The ACT is an improved
technique for testing carbon's ability to remove organic impurities;
it combines the speed  of an isotherm with the accuracy of a pilot
column. The ACT can compress a month-long pilot study into a
few days, saving money and time, which can be a critical  factor in
responding to spills or other emergencies.
                            Table 3
                     Concentration Factors
Project


1-3
1-5
1-10
1-11
1-16
1-17
2-1
2-4
2-5
2-7
2-21
2-22
2-38
TOC (mg/1)


700
40
2,000
400
18
3,100
45
200
200
4.9
20
8.5
9
lb/1000 Gal


15
0.6
50
16
1.6
40
3.9
13.3
11.6
1.9
1.15
0.8
1.1
Loading
mg/gm-
GAC
389
278
334
209
94
640
96.2
125.4
143.8
21.5
145.0
88.6
68.2
Loading
1/gm
Carbon
.555
6.95
.167
.52
5.2
.206
2.1
.627
.719
4.39
7.25
10.4
7.58
Concentra-
tion Factor

277
3,475
84
260
2,606
103
1,069
313
359
2,195
3,626
5,212
3,790
                            Table 4
                      Act Field Comparison
                          Field*
                          Conditions
              ACT
              Simulation
Influent Phenol
  Concentration (mg/1)
Effluent Phenol
  Concentration (mg/1)
Lbs/1000 Gallons
  (Initial Breakthrough)
Lbs/1000 Gallons
  (Saturation)
29

<1

16

14
mg/1
35.7

<1

12.5

10.7
mg/1
*The high variability of industrial waste influent is the primary reason for variability between ACT
simulation and field conditions.
                                       1O,000
                                        1,000
                                         100
                                          10
                                                       10
                                                                  100         1,000
                                                              Influent TOC Concentration (mg/l)
                                                                                        10,000
                                                                Figure 3
                                             Concentration Factor vs. Influent TOC Concentration
                                                                                     THREE WAY
                                                                                        VALVE
                                                                                        VENT
                                                                       LIQUID
                                                                     RESERVOIR
                                                                        t UV CONTINUOUS MOMTORNM
                                                                        2. TOC LOW LEVEL
                                                                        X TOC HIGH LEVEL
                                                                        4. CC FLAME KWIZATON
                                                                        t. OC ELECTRON CAPTURE
                                                                          DETECTION SYSTEM
                                                                           100 r
                                                                                              Figure 4
                                                                                            Basic System
                                                                                            ACETOXIME/P-NITROPHENOL
                                                                                            1 FOOT BED DEPTH/7 GPM/FT1
                                                                                        ACCELERATED TEST VS11NCH COLUMN
                                                                  % BREAKTHROUGH/
                                                                            SO
                                              25
                                                                                   ACETOXIME BREAKTHROUGH
                                                                                              ACT
                                                                                   ___-1 INCH COLUMN
                                                                       P-NITROraENOL BREAKTHROUGH
                                                                                ACT
                                                                   ___ i1NCH COLUMN
                                                              JL
                                                                                  JL
                                   20   40   60   80   100   120   140   160
                                                 VOLUME (LITERS)


                                               Figure 5
                                      Multicomponent Adsorption
                                                                                            180  200
                                                                                                         TREATMENT
                                                                                                215
-------
  The ACT generates data equivalent to a conventional laboratory
scale or field study, which can then be easily translated into a full-
scale design. Because only a few days are required to perform the
tests, problems with sample degradation  or loss of volatile com-
ponents  are  eliminated.  In  fact,  field validation  of  ACTs
demonstrates a degree of accuracy that is difficult to match with
any of the other more time-consuming methods.
  Acceleration of the carbon adsorption cycle is achieved through
a scaling down of conventional column testing hardware. Except
for reduced scale, other components of  the test system and the
overall  system  design  are essentially  identical  to larger scale
laboratory  or field evaluation systems (Figure 4). The technology
behind the ACT is based upon Calgon  discoveries relating to the
basic  kinetics  of carbon adsorption.   Using  kinetic  data,  a
mathematical  model  of  the  column  adsorption process  was
developed. With this model, breakthrough curves for full-scale ad-
sorption systems are readily predicted from data generated by the
scaled-down column.
  To confirm the validity of the ACT,  a  series of tests were con-
ducted comparing the ACT against a conventional 1 in. column for
the prediction of breakthrough for both strongly and weakly ad-
sorbed components. For the purpose of this test, a synthetic stream
containing  acetoxime and paranitrophenol was prepared. The ac-
celerated test successfully predicted the performance of the 1 in.
column (Figure 5). This degree of correlation was maintained in 30
additional tests under a  variety of operating parameters.
                                                         The ACT was also applied to several full-scale systems already in
                                                       operation. Actual operating data, compared to the ACT results,
                                                       are presented in Table 4. The influent phenol concentrations on the
                                                       full-scale system and ACT were 29 mg/I and 35.7 mg/1 respectively.
                                                       The ACT accurately predicted removal to less than 1 mg/1 phenol.
                                                         The close correlation with full-scale data shows that the ACT is a
                                                       valuable tool in predicting system performance; however,  inherent
                                                       to the test is the small quantity of influent needed. This makes the
                                                       representativeness of the sample used critical to the accuracy of the
                                                       ACT results. Likewise, in systems where actual field operation has
                                                       highly variable influent characteristics,  the  ACT  will predict the
                                                       performance corresponding to the influent  characteristics of the
                                                       sample collected.


                                                       CONCLUSIONS
                                                         In summary, wastewater treatment is,  and will continue to be, a
                                                       dominant  concern for industries  and municipalities. Granular ac-
                                                       tivated carbon is effective for removal of a broad range of  con-
                                                       taminants over a variety of treatment conditions  and concentra-
                                                       tions. Granular activated carbon treatment is cost-effective, mak-
                                                       ing this technology a viable alternative for point source,  end-of-
                                                       pipe and groundwater treatment.
                                                         Finally,  Calgon  has  introduced a  quick,  cost-effective  Ac-
                                                       celerated Column Test to improve carbon system design and  per-
                                                       formance prediction.
216
TREATMENf
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    TREATMENT  OF HAZARDOUS  LANDFILL LEACHATES
           UTILIZING IN-SITU MICROBIAL DEGRADATION

                                               DAVID S. KOSSON
                                         ROBERT C.  AHLERT,  Ph.D.
                           Department of Chemical and Biochemical Engineering
                                                Rutgers University
                                             Piscataway, New  Jersey
INTRODUCTION

  Industrial  wastes  have been frequently placed in landfills,
lagoons and  uncontrolled dump sites, subsequently producing li-
quid residuals as the result of compaction, rainfall runoff and in-
filtration, and biodegradation. These liquids can leach  from  a
disposal site  and  contaminate underlying groundwater and adja-
cent surface waters.
  Leachate management creates many dilemmas, both economic
and technical. These wastewaters are highly complex; composition
is site-specific and subject to seasonal variability. Treatment often
necessitates collection and transport of large volumes of hazardous
liquids, bulk oil and contaminated water, as  well as  waste con-
tainers, solid waste and soil. The potential for further dispersion of
hazardous substances in the environment is increased  by the
cleanup process itself.
  An in situ treatment process for treatment  of aqueous landfill
leachates has been developed. Transport  of hazardous materials  is
avoided, offering safety and economic advantages. A combination
of physical, chemical and biological processes results in effective
ultimate disposal. Landfill leachate is pretreated to remove suspen-
sions, dispersed oil  and heavy metals. Subsequently, treatment  is
effected with a land based biological process. Utilizing aerobic and
anaerobic degradation processes associated with mixed microbial
populations,  hazardous waste treatment is viewed as  proceeding
either in the landfill structure or in a neighboring soil system.

RELATED RESEARCH
  A viable in  situ  process must (1) operate  within natural en-
vironmental temperature and precipitation fluctuations, (2) allow
for monitoring of treatment in progress and (3) provide an effective
pathway for safe ultimate disposal. Three primary studies of in situ
biodegradation of landfill  leachates have been conducted. The first
study was conducted by Pohland.'  His experimental system con-
sisted of four 3-ft diameter columns  containing 10 ft  of un-
shredded, compacted refuse covered with 2.5 ft of soil. Leachate
was collected from the base of the columns and recycled by means
of a distributor located at the interface between the soil and com-
pacted refuse. The refuse was domestic  in origin and not of in-
dustrial character.
  Refuse  of  the  composition used by  Pohland is more readily
biodegradable than  the recalcitrant organics  found  in  landfill
leachate of an industrial or hazardous nature. The effects of initial
sludge seeding and pH control on the rate of biological stabilization
of the refuse and resulting leachate were studied. Through analysis
of results over approximately three years, Pohland concluded that
recycling leachate helped to stabilize the refuse and leachate. Both
pH control, at approximately 7, and initial addition of sewage
sludge enhanced the rate of decrease of organic pollutants in the
leachate.
  Tittlebaum2 conducted a second study using an experimental ap-
paratus similar to that of Pohland. Tittlebaum investigated the ef-
fects of refuse shredding on the rate of refuse and leachate organic
carbon (LOC) stabilization. The refuse had a composition com-
parable to that studied by Pohland. The effects  of pH control,
nutrient control and initial sludge seeding were also considered.
After 514  days of operation, Tittlebaum concluded that refuse
shredding had little effect on the rate of stabilization. He also con-
cluded that nutrient control did not offer any advantage. However,
the refuse  was readily biodegradable. Other conclusions were in
consonance with Pohland.
  Another relevant  study examined microbial degradation  of
hazardous  organic substances,  resulting  from  spills, in  soil
systems.' At a high octane gasoline spill in Whitemarsh Township,
Pennsylvania,  stimulation of an indigenous microflora population
was utilized successfully to degrade the organics contaminating a
dolomite aquifier. Addition of nutrients and aeration stimulated
biodegradation of the gasoline residuals. Biodegradation required
approximately two years; data indicated approximately 95% of the
residual material was degraded.

PROCESS DESCRIPTION

  The indigenous microflora of the soil or landfill is supplemented
through the addition of an inoculum of a mixed microbial popula-
tion derived from the secondary sludge of a municipal sewage treat-
ment facility.  The microbial  population is established in the soil
system through daily additions of an aqueous, nutrient-balanced,
glucose feed medium for ten days. Subsequent to the establishment
of the microbial  population, daily additions of landfill leachate
with supplemental nutrients and glucose were distributed on the
surface. Prior to application, the leachate is pretreated using a lime
flocculation/recarbonation sequence developed by Slater.4
  Natural  selection is allowed to control the process as completely
as possible.  Stratification results  in response to chemical  and
physical gradients that exist in the vertical profile of the treatment
zone. The principal gradient is in oxygen concentration. The ox-
ygen concentration is greatest at the surface, where diffusion from
ambient  air  drives  the gradient.  The  oxygen concentration
diminishes with depth as it is depleted by aerobic respiration.  This
leads to aerobic  communities near the surface;  anaerobic com-
munities dominate at greater depths. Other important gradients in-
                                                                                               TREATMENT
                                                      217
-------
elude  available  substrate  and  nutrients,  pore  water  and
temperature. Competitive adsorption by the soil also creates an im-
portant gradient. Readily adsorbed components of the leachate will
be  in greater  concentration  near  the  surface.  Others  will
predominate at greater depths.
EXPERIMENTAL DESIGN
  Pilot-scale field demonstrations have been carried out with soil
filled, self-contained lysimeters (SCLs). The effective soil column
was 2 ft in diameter and 4  ft deep. A once-through configuration
has been employed.
  The experiment  was designed  to  evaluate the  biochemical and
physical processes involved at a scale suited tcr simulation of field
conditions including  soil  type,  permeability, cation exchange
capacity,  moisture distribution,  soil water  activity, etc. Effluent
streams were collected continuously in entirety, under the vacuum
employed to balance capillary forces in the soil pore structures.
Thus, complete mass balances were possible. Two soil types, a
sandy loam and a clay loam (Table 1, have been evaluated at several
         	SO. <1  - S.AJ, Liu.	
                                         •—•  InHuMt

                                         tr--tL  Effluent

                                        (I In I Aru • ].«.)
                  48    60    68    189    128    148    160   11)8
                               TINC (MTS)
                  figure I • Influent end effluent Quantities

                           Figure 1
                 Influent and Effluent Quantities
   le
                  1	1	1	1	1	\—•—r
           28    48     68    SB    108    129   140   168   108
                             II* (MTS)

                           Figure 2
                 Influent and Effluent Quantities
                                                        feed dilutions and compositions. Leachate samples were obtained
                                                        from a USEPA designated "Superfund" site.

                                                        HYDRAULIC RESPONSE
                                                          Throughout the period of operation, influent was applied daily,
                                                        batchwise. The permeability of the soils varied considerably during
                                                        the experiment.  Initially, there was considerable adsorption of in-
                                                        fluent by the soil as field status was established. After this period,
                                                        the original hydraulic loading target of 1 m/day was unreasonable.
                                                        A more workable hydraulic loading of approximately 0.5 in./day
                                                        was adopted.
                                                          When the permeability decreased significantly, it could usually
                                                        be increased  by turning the top several inches of soil.  Decreases
                                                        were  probably the result of  increased microbial growth  in  the
                                                        aerobic regions of the soil,  near the surface.  Suspending the  ap-
                                                        plication of influent  for short periods resulted in  an increase in
                                                        permeability. On a larger scale, it would probably be advantageous
                                                        to turn the soil at regular intervals and to design excess capacity for
                                                        intermittent operation.
                                                          Small daily fluctuations of influent and effluent volumes most
                                                        likely resulted from the complex nature of the soil-water systems;'
                                                        see Figures 1 and 2. Long term decreases in permeability may be ac-
                                                        counted for by the increased mass of microflora. The three SCLs
                                                        containing clay loam  displayed increasing permeability during  ap-
                                                        proximately the  first 100 days, as indicated by increasing influent
                                                        and effluent quantities. This is probably a result of a shift of  the
                                                        sodium/calcium balance of the soil.  The  high concentration of
                                                        calcium ions in clarified leachate from lime flocculation pretreat-
                                                        ment  can lead to soil aggregate formation, resulting in  increased
                                                        permeability.6-7 Very  small differences between influent and  ef-
                                                        fluent quantities are the result of evaporation and variations in field
                                                        status. Maintaining uniform packing was difficult at times. Initial-
                                                        ly, continued  settling of soil frequently allowed influent to pass
                                                        along relatively few pathways. When channeling occurred, the top
                                                        few inches, sometimes more, of soil were loosened and  repacked.
                                                        Eventually channeling was  eliminated, although  it did reoccur
                                                        periodically. Periodic episodes probably resulted from cyclic drying
                                                        and saturation of the soil, inherent with batchwise influent addi-
                                                        tions. On a larger scale, channeling should not present difficulty.
                                                                                  Table 1
                                                                       Soil Composition In Lysimeter Tests
Parameter
Designation
Sand (%)
Silt (%)
Clay (%)
Organic Carbon (%)
Total Nitrogen (%)
C.E.C. (meq/100 gin)
PH
Total Metals (mg/kg)
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
Metals soluble in 0.1 N HC1
(mg/kg)
Cadmium
Copper
Iron
Lead
Nickel
Zinc
Glacial Till
Clay loam
35
37
28
1.34
0.12
6.9
5.54

1.0
6.2
12
10
19
70


0.10
0.49
40
1.2
0.3
3.2
Alluvlam
Sandy loam
59
24
17
0.52
0.06
3.6
5.41

1.0
4.2
6.8
10
7.9
44


0.10
2.1
105
4.5
0.30
7.4
218
TREATMENT
-------
4500-
1250-
u
3
•j 750-
500-
250-
0 —
.


_J 	 1





1 20








1 '
40





r-











a








• \ '
80
	 Toul


1 	 1




1 . ' 1 ' 1 ' 1
100 ' 120 140 161








li
                                                                    700
                                                                                           SCL I 1 - Sandy Loam
 21000-
                        TIHC (DAYS)


                      Figure 3
               Influent Organic Carbon


                       SCL I 1 - Sandy Loam
 12000-
   -,	1	•	1	•	1	P	1	1	1	P	1	I	1   I   |   *•
0     20     40     60     80     100    120    140     160    180
                          TIME (DAYS)


                      Figure 4
Influent Total Organic Carbon, Mass Basis—6 Day Average
TOTAL ORGANIC CARBON RESPONSE
  Total organic carbon was monitored throughout the experiment.
During 161 days of operation, the influent TOC consisted of eight
regimes including the dextrose-only feed solution  for the  initial
development interval (Table 2 and Figure 3). Six leachate samples,
exhibiting considerable variability, were used (Table 3). Dilutions
with sparged potable water were used to maintain the desired in-
fluent TOC concentration.
  Effluent TOC was measured on alternate days. Because of vary-
ing flow rates through the SCLs, TOC data was evaluated in  two
forms. The first approach was a concentration basis, with typical
units of mg TOC/1. The  second approach was  a mass basis;  this
meass quantity is the product of daily effluent (influent) quantity
and TOC  concentration.  On days when effluent TOC was  not
measured, the concentration was approximated by linear interpola-
tion.
  The effluent TOC was  low, if not negligible, during operation
with type A  influent for  all SCLs. Transition to type B influent
                                                                   300 -
                                                                           •   I   •   I   •   I   •   I   •   I   •   I   <   I   '   I
                                                                       '     20     40     60     80     100    120    140     160    ISO
                                                                                                TIME (DAYS)
                                                                                              Figure 5
                                                                       Effluent Total Organic Carbon, Mass Basis—6 Day Average


                                                                       „	set i s - city IOM	
                                                                            1  r  T  r 'i   '  i  '   i   •  i   '   i  '  i   r
                                                                         0     ?0    40    10     80   100     UO    140    160    180
                                                                                                TIHC (UTS)
                                                                                             Figure 6
                                                                      Influent Total Organic Carbon, Mass Balance—6 Day Average
                                                                    700-
                                                                                              SCL I 5 - Clay Loam
                                                             1

                                                             g 300 —
                                                               100-
 I
80
                                                                                                       120
                                                                                                                    I
                                                                                                                   160
                                                                                                100
                                                                                             TIME (DAYS)
                                                                                        Figure 7
                                                                  Effluent Total Organic Carbon, Mass Basis—6 Day Average
                               180
                                                                                                        TREATMENT
                                                                                                                       219
-------
                                                            Table 2
                                            Feed Solution Composition, Field Experiments

Type Dates (Days)

A 6/15/82-6/24/82(01-10)
B 6/25/82-7/16/82(11-32)
C 7/1 7/82-8/04/82 (22-5 1 )
D 8/05/82-8/10/82 (52-57)
E 8/11/82-8/19/82(58-66)
F 8/20/82-9/16/82 (67-94)
G 9/17/82-11/05/82(95-144)
H 1 1/06/82-1 1/22/82 (145-161)
(NH4hSO4/Trace Element Solution contains:
50 g/l (NVUnSO* 10 g/l MgSOt ' 7H2O
50 mg/l FeCb • 6H2O 1000 mg/l MnSO4 • H2O
750 mg/l CaCl2

TOC GOC
(mg/l) (mg/l)
1050 1050
1100 210
230 210
510 210
4500 210
710 210
1010 210
930 210




Trace Elements
LOC Leachate Solution 1M K2HPO4
(mg/l) Vol %, * (ml/1) (ml/1)
0 - 25 25
890 6.6% EPA-04 5 5
20 6.6% EPA-05 5 5
300 100% EPA-05 12 6
4290 100% EPA-05A 12 6
500 100% EPA-06 33 18
800 4.5% EPA-07A 50 27
720 4.5% EPA-07B 50 27




All dilutions made with dcchlohnated (sparged) potable water.
Table 3
Leachate Characteristics




Parameter Raw Leachate
pH 5.6 - 6.0
COD 1000-36000*
TOC 300-18000
TDS 2100-28000
Turbidity 75-150 NTU
Color Brown
Conductivity 5000-3500 pu/cm
Na lO'-lO6
Fe IQMO5
Mg lOMO3
Ca 10M06
Pretreated Sample TOC
EPA-04 13500*
EPA-05 300
EPA-05A 4500
EPA-06 710
EPA-07A 18000
EPA-07B 16100

•All values reported in mg/l unless noted otherwise
+ This pH is adjusted to the desired value





Pretreated
Leachate
12 +
1000-36000
300-18000

0
Yellow


1-10
0-1

COD
35000
1000

1100
34900
36100



dicate net reductions in TOC of over 95%. SCLs 3 and 4 showed
net TOC reductions of approximately 90%. Lower reductions in
TOC were due to prolonged periods of channeling in these col-
umns.

DESIGN CONSIDERATIONS
Process designs must be developed on a site specific basis. The
parameters that control the extent of microbial degradation and the
depthof the aerobic and anaerobic zones are hydraulic loading,
organic carbon content, carbon-to-nitrogen-to-phosphorous ratios,
buffer strength, supplemental energy (carbon) source and optimum
pH. The process can be run once-through on an intermittent or on
a continuous basis. Intermittent operation permits recovery of the
aerobic bioslime zone during the intervals between flooding. The
process can be operated with intermittent or continuous recycle,
also. Recycle allows control of feed stream organic carbon concen-
tration, i.e., dilution and overall carbon conversion. Recycle to
zero effluent carbon concentrations appears feasible for a "closed"
site. Effluent "polishing" may be required prior to discharge.
REFERENCES

1. Pohland, F.G., "Sanitary Landfill Stabilization with Leachate Recycle
and Residual Treatment," USEPA Report No. EPA/600/275/043,
Environmental Protection Technology Series, 1975.

2. Tittlebaum, M.E., "Organic Carbon Content Stabilization Through
Landfill Leachate Recirculation," JWPCF. 54, 1982, 428-433.
3. Chapin, R.W., "Microbiological Degradation of Organic Hazardous
resulted in a delayed response in SCLs 1, 2, and 3 (sandy loam)
followed by an adaptation period. The response delay varied from
approximately 13 days (SCLs 1  and 2) to  19 days  (SCL 3). The
adaptation period varied in duration from approximately 10 days
(SCL 2) to 25 days (SCL 1). Maximum effluent TOC was between
134 (SCL 2) and 278  mg TOC/1 (SCL 1)  or 994  and 1764 mg
TOC/mVday. A second peak  in  effluent  TOC  from the SCLs
packed with  the sandy loam  was in response to type E influent.
SCLs 3, 4 and 5 (clay loam) did not exhibit response or adaptation
periods until after 60 to 80 days. Typical long-term influent and ef-
fluent TOCs on a mass basis are shown in Figures 4  through 7.
  Integration under the curves of influent and effluent TOC on a
mass basis for SCL 1 and 2 (sandy loam) and 5 and 6 (clay loam) in-
                                                           Substances: A Review of the  Art and  Its Application  to Soil  and
                                                           Groundwater  Decontamination at the Goose Farm Hazardous Waste
                                                           Site, Plumsted Township, New Jersey." USEPA Region II,  Hazard
                                                           Response Branch, Technical Assistance Team, Aug. 1981, 1-3.
                                                        4. Slater, C.S., "Coagulation/Flocculation  and Oxidation Processes for
                                                           Pretreatment  of Wastewater," Progress Report under  Cooperative
                                                           Agreement CR807805 with USEPA, 1982.
                                                        5. Brady, N.C.,  The Nature and Properties of Soils, 8th Edition, Mac-
                                                           millan Publishing Co., Inc., New York, 1974.
                                                        6. Carlile, B.L. and Phillips, J.A., "Evaluation of Soil Systems for Land
                                                           Disposal  of Industrial and Municipal Effluents," Water Resources
                                                           Research Institute of the University of North Carolina, Report No.  118,
                                                           July 1976.
                                                        7. Bonn, H., McNeal, B., and O'Connor, G., Soil Chemistry, John Wiley
                                                           & Sons, New York, 1979.
220
TREATMENT
-------
                IN  SITU  TREATMENT ALTERNATIVES AND
                                         SITE  ASSESSMENT

                                          DONALD G. MILLER, JR.
                                      Law Engineering Testing Company
                                                Marietta, Georgia
INTRODUCTION

  Remedial action  alternatives  at sites contaminated  by waste
management practices should be evaluated on the basis of technical
feasibility, cost  and long  term  effectiveness.'  One set of alter-
natives,  in situ  treatment, is  attractive because it can result in
minimal exposure and eliminate off-site  transportation  of the
waste. In situ treatment, however, is questionable with regard to
physical and  chemical uniformity of  treatment and long  term
chemical stability.   Experience  with  numerous  projects  has
demonstrated  the  need  for  adequate physical and  chemical
characterization  of the system to be treated.
  In situ treatment as considered in this paper is restricted to the in-
troduction of chemicals  into the subsurface, rendering  con-
taminants less hazardous to the environment (Figure 1). The pro-
cess has also been referred to as neutralization/detoxification2 or
detoxification and stabilization.3
  In this paper, the  author addresses in situ treatment of inorganic
contaminants, primarily heavy metals,  although similar concepts
and physical characteristic concerns may be applicable to in situ
biodegradation.  In spite of demonstrations of physical  feasibility
by full scale tests, current use is limited because  of the concerns of
overall reliability and costs associated with demonstration and im-
plementation. An understanding of these concerns is necessary to
properly evaluate in situ treatment as an alternative.
BASIC APPROACH TO ASSESSMENT
  The basic steps in  assessment of in situ treatment are summarized
in Figure 2. Additional details regarding initial feasibility and cost
review, physical characterization and chemical characterization are
presented in the  following sections.
Initial Feasibility and Cost Review
  This initial evaluation is based on available data and is intended
as a "fatal flaw" screening. The projected  costs of other conven-
tional alternatives are estimated to provide a basis for comparison.
A maximum  dollar amount  for in  situ treatment is  therefore
established. A conservative estimate (probable maximum cost) of
the in situ treatment system cost is then developed. If the available
dollar amount would allow construction of such a system, then the
next  stage of assessment is appropriate. Otherwise, in situ treat-
ment need not be evaluated in further detail.
  For example,  the maximum projected  costs of conventional
alternatives are  normally associated with off-site treatment and
disposal. If a waste  comprises  a one acre area to a depth of 10 ft,
the costs might  typically be estimated  based on the excavation,
                   SURFACE APPLICATION
                  	V	

                  TTTT
      SHALLOW TRENCHES
                                      WELLS
                                    /    \
                         Figure 1
          Basic Concepts of Treatment Fluid Application
transportation and disposal costs, approximately $100/yd3.  For
this example, this off-site disposal would be about $1.6 million.
  For in situ treatment the site requires injection wells to a depth of
10 ft at a cost of $40/ft (including a distribution system) plus an ad-
ditional evaluation cost of $50,000 and an operation/maintenance
allowance of $100,000. Wells could be spaced on approximately 3.5
ft centers across the site without exceeding the $1.6 million cost for
off-site removal.
  Experience indicates that such spacing should be  adequate for
subsurface materials behaving hydraulically as sands and silts and
possibly adequate  for  some finer  grained, lower  permeability
materials. Assuming the site met these characteristics, it would then
be feasible to proceed with the physical and chemical characteriza-
tions required for in situ treatment.
                                                                                       IN SITU TREATMENT
                                                                                                                  221
-------
 PHYSICAL CHARACTERIZATION

   The physical characterization  attempts to determine how the
 treatment fluids will move into the mass of material to be treated.
 The mass to be  treated may be  either unsaturated, saturated or
 both. The key factors are the lateral and horizontal extent of
 various waste and subsurface materials and their corresponding
 hydraulic properties. These factors can be effectively evaluated by
 an incremental characterization as summarized in Figure 3.
   The initial model of fluid movement is an extention of the initial
 feasibility and cost review and is based on available site informa-
 tion or limited additional data gathering. Plan drawings and sub-
 surface profiles  summarizing the subsurface conditions are the
 primary components of the model. Boundary conditions and ques-
 tionable areas are thus defined.
INITIAL FEASIBILITY
AND COST REVIEW


                   PLANS  FOR  IMPLEMENTATION
                           Figure 2
            Flow Chart of In Situ Alternative Assessment
   There are several techniques including conventional soil borings,
 test pits and geophysical surveys that can be used to determine the
 uniformity of wastes and subsurface materials in both lateral and
 horizontal extent. At a settling pond site, reconnaissance revealed
 some harder, apparently cemented, layers near the surface of the
 waste. The  waste, covering several acres, was a byproduct of a
 single process. At this site, the immediate question was whether or
 not these harder layers were laterally continuous, which would cer-
 tainly impede the vertical movement of treatment fluids.
   A shallow seismic refraction survey was performed. The survey
 revealed a simple two layer system of unsaturated waste materials
 approximately 20 ft thick overlying saturated waste. The  shallow
 refraction survey  did,  however,  reveal  a  localized  subsurface
 anomaly related to an earlier stage of pond construction.
   The type of detailed testing necessary to confirm the hydraulic
 characteristics of  waste  and subsurface materials depends  on
 whether the materials  are saturated or unsaturated. The degree of
 saturation  can  be determined  on  the  basis  of  conventional
 laboratory measurements or by field measurements (geophysical
 logging in boreholes).
                                                                           INITIAL MODEL REVIEW
                                                                             FLUID  MOVEMENT
                                                                              VERIFICATION  OF
                                                                                UNIFORMITY
                                                                                DETAILED TESTING TO  CONFIRM
                                                                                     WASTE/SUBSURFACE
                                                                                       CHARACTERISTICS
                                                                                        PREDICTION OF
                                                                                       FLUID  MOVEMENT
                                                                                     FULL SCALE TESTING
                                                                                 VERIFICATION OF  TREATMENT
                                                                                     QUANTITES  AND  TIME
                                                                                  Figure 3
                                                                    Flow Chart of Physical Characterization

                                                         Porosity, important for evaluation of flow in saturated and un-
                                                       saturated materials, can also be determined in the laboratory or in
                                                       the field. Comparisons of laboratory and field measurements for
                                                       degree of saturation and porosity for waste in a partially drained
                                                       impoundment are shown in Figure 4. The laboratory degree of
                                                       saturation was  based on a weight-volume  relationship for un-
                                                       disturbed sampled. The field degree of saturation  was based  on
                                                       geophysical logging (density, gamma ray  and velocity logs). The
                                                       field measurements of porosity (based on compensated bulk densi-
                                                       ty logs) were generally higher than the laboratory measurements.
                                                       Compression of the waste material during sampling  and extruding
                                                       in the laboratory most likely accounted for  the lower laboratory
                                                       values  of porosities.  Note that  these porosities of  the waste are
                                                       much higher  than  the 10 to 60% typically expected for  natural
                                                       soils.4
                                                         A key factor  in predicting  movement of treatment fluids is
                                                       saturated  permeability  (hydraulic   conductivity).   Field
                                                       measurements in  specially constructed  observation  wells  or
                                                       piezometers are generally thought to produce measurements most
                                                       representative of the in situ  materials. However, except in the case
                                                       of specially constructed test facilities, the permeant commonly used
                                                       is water. Laboratory  tests on undisturbed samples allow use of
                                                       various fluids for permeants and thus the potential for changes in
                                                       permeability due to chemical reactions can  be more thoroughly
                                                       evaluated because of controlled conditions. Changes in permeabil-
                                                       ity (reductions being the worst case with respect to time and extent
                                                       of in situ treatment) due to in situ chemical reactions have not been
                                                       thoroughly evaluated  and are one of the primary concerns with
                                                       respect to use of in situ treatment. With some wastes, however,
                                                       misleading results can be obtained in the laboratory due to distur-
                                                       bance and incomplete saturation.
222
IN SITU TREATMENT
-------



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V - TOTAL VOLUME OF SOIL MASS

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Vw • VOLUME OP WATER tN SOIL MASS
Vv • VCLUMK OF VOIDS IN SOIL MASS



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Ok * uz
loE n =



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                                                         Figure 4
                                      Summaries of Laboratory and Field "to Saturation
                                          and Porosity for Confidential Waste Site


cr-i
01 D

a
CP-l

CP-l
CL-I
CT-I O A O "-I
CT-4 O A O«T-«
CP-l
CL-S

CP-l
a
                                                       CP-4
                                                        a
                 Q MONITORING WELLS
                      (2-C SCREENED SECTION, 5' BELOW GROUND WATER)

                 A MONITORING WELL AND  LYSIMETERS
                      (1 LYSIMETERS AT 3, «. * 10FT.)

                 O TENSIOMETER STRING
                      (4 TENSIOMETERS AT 2, I, I, 4 I IFT.)
                                                                                    NUMBER INSTALLED
POND SURFACE
              "
GROUND WATER
               -\
                        O
a
                                WELLS             «

                                LYSIMETERS        8

                                TENSIOMETERS     It
                                                         Figure 5
                                                   Full Scale Test Facility
                                                                                              IN SITU TREATMENT       223
-------
   For saturated materials, the prediction of fluid movement time
 and distance into the waste mass can be accomplished by use of the
 relatively  simple  equations'  involving  hydraulic conductivity,
 porosity and quantity injected. The use of more sophisticated com-
 puter models' is generally required for unsaturated flow conditions.
 The latter model should be calibrated by full scale tests.
   The full scale  test  apparatus  for a mass of partially saturated
 waste is shown schematically in Figure 5. The monitoring wells (2
 in.  O.D.  PVC with  bentonite seal at groundwater level  and
 manufactured screen extending into the groundwater) were used to
 monitor changes in groundwater levels and to allow sampling for
 chemical analyses. The pressure vacuum lysimeters, utilizing suc-
 tion of pore water through a porous cup, were used to obtain water
 samples for chemical analyses from above the groundwater level.
 The mercury manometer type tensiometers were used to measure
 negative pore water pressure around a porous tip.  Negative pore
 water pressure values along with water characteristic data are input
 to the unsaturated flow computer model.
   Data from the full scale tests can then be used to verify the treat-
 ment method, quantities of treatment fluids and treatment times.
 In the field test described  in the preceding paragraph, it was deter-
 mined that the water content of the waste should be slightly less
 than required for saturation to be efficient with respect to treat-
 ment fluid mixing and displacement of pore water. Thus, the op-
 timum level of pore water pressure (as monitored by tensiometers)
 to achieve miscible displacement was approximately 200 mb. This
 meant  that using natural rainfall  with  periods of wetting  and
 drainage to advance the treatment fluids would be more desirable
 than flooding or injection to treat the contaminated unsaturated
 zone. In fact, according to the theory of miscible flow,7 maintain-
 ing complete saturation would result in flow of treatment fluid and,
 thus, treatment only through the larger pores in the waste mass.

 CHEMICAL CHARACTERIZATION

   The general steps in the chemical characterization for  in  situ
 treatment are summarized in Figure 6. The initial definition simply
 consists  of a tentative  selection of a treatment process. For in-
 organic contaminants, this may consist of reduction (i.e., Cr(VI) to
 Cr(III)) or neutralization and precipitation. Thus, analyses must be
 made  of concentrations  of contaminants at the  site.  Initially,
 analyses typically available for  site characterization and  proper
 evaluation of any alternatives should suffice. Care must be taken,
 however, to distinguish between tal and dissolved metallic  consti-
 tuents.
   The vertical and horizontal distribution of contaminants must be
 defined  to determine whether  the treatment is  to  be applied
 uniformly across the site or directed toward somewhat isolated
 "hot spots." Sites with inorganic contamination typically exhibit
 increased specific conductance of the pore water. Therefore, con-
 taminant zones become excellent targets for electrical resistivity
 surveys.  The general  approach for such surveys is described by
 White and Brandwein.'
   At a site in  the southeastern United States, a combination of
 review of pre-construction topographic maps, conventional  soil
 borings and surface geophysical surveys identified  previous,  now
 buried, drainage features which corresponded to zones of increased
 permeability. These zones provided paths of preferential movement
 of various heavy metals and salts. These preferential flow zones
 then became the focus for potential in situ treatment.
   At this site, with preferential flow zones, the contaminants in-
 cluded Fe, Zn, Ni, Cd, Cr and Pb in concentrations ranging from
 21,000 to 2 mg/1, respectively. The groundwater within the con-
 taminated zones had a pH as low as 2.5. The in situ treatment alter-
 natives included introduction of calcium hydroxide for neutraliza-
 tion and precipitation of each metal as the hydroxide. Considering
 the species and concentrations, it was estimated that up to about
 0.5 Ib of lime would be required for treatment of each gallon of
 contaminated groundwater. Although this amount would not have
 been prohibitive, there were other questions such as the ability to
                                                                                 INITIAL DEFINITION
                                                                             OF TREATMENT  PROCESS
                                                                           CONTAMINANT  CONCENTRATION
                                                                                 AND DISTRIBUTION
                                                                                  EVALUATION OF
                                                                            SUBSURFACE GEOCHEMISTRY
                                                               PREDICTION  OF
                                                              FLUID MOVEMENT
                                                                                 CONFIRMATION OF
                                                                               TREAMENT PROCESS
                                                                              OUANTATIES AND TIME
                                                                                 ASSESSMENT  OF
                                                                                    LONG  TERM
                                                                               TREATMENT  STABILITY
                                                                                  Figure 6
                                                                     Flow Chart of Chemical Characterization

                                                       inject and maintain the calcium hydroxide slurry. These questions
                                                       resulted in in situ treatment not being selected as an initial alter-
                                                       native but held as a possible method of treating isolated hot spots
                                                       instead of removal and off-site disposal/treatment.
                                                         The geochemical stability at a site is a factor which may not be
                                                       evaluated  in a conventional site characterization but is quite rele-
                                                       vant with regard to in situ treatment of metals. The  chemical
                                                       stability of chromium in the shallow subsurface,  for example, is
                                                       primarily  a  function  of pH and  oxidation  reduction  potential
                                                       (ORP). For shallow groundwater systems, the normal tendency is
                                                       for Cr(HI) to be the stable species under acid conditions. The ap-
                                                       proximate relationships that  should exist to keep chromium in the
                                                       non-hazardous Cr(III) state as opposed to Cr(VI) are as follows:1
                                                       For pH of
                                                           14
                                                           12
                                                           10
                                                            8
                                                            6
Keep ORP less than: (MY)
              -00
             -100
             + 100
             + 200
             + 400
                                                         Based on  actual field pH and ORP measurements, conditions
                                                       have been found where  the geochemical system is close to the
                                                       equilibrium border and Cr(VI) occurs.
                                                         For sites with marginal geochemical stability, in situ treatment
                                                       may be a viable alternative used alone or in conjunction with other
                                                       remedial alternatives. For example, at a shallow waste fill site, one
                                                       option was to use a one-time in situ chemical stabilization in com-
                                                       bination with a low permeability cover. The purpose of the in situ
                                                       chemical stabilization was to drive the geochemical equilibrium
                                                       toward Cr(III) stability.
                                                         Conceptually, such a stabilization could be accomplished by ap-
                                                       plying a liquid reducing agent (such as sodium thiosulfate) on the
224
IN SITU TREATMENT
-------
fill surface and  forcing circulation  through a series  of shallow
pumped trenches to recirculate reductant in the fill area. This cir-
culating system would also provide a means of reducing the pH of
the system by adding acidic material with the reductant. The op-
timum pH would be about 6 where Cr(VI) formation could be
prevented and Cr(III) solubility is still quite low. The  clay cover
should be applied as soon as possible after the stabilization process
to achieve optimum results.
CONCLUSIONS
  In situ treatment is subject to questions regarding uniformity of
treatment and long term reliability. However, it may be cost com-
petitive with other remedial alternatives. It  may very well  have
future use with respect to  providing barriers to prevent off-site
migration and to selectively treat "hot spots" in conjunction with
other techniques.
  The barrier concept would be to create a zone that would provide
subsurface treatment of contaminants such that discharge beyond
the barrier would be at environmentally acceptable levels. Barrier
construction could involve a line of injection wells spaced to pro-
vide a continuous treatment zone or a trench with granular material
into which treatment fluids could be injected. Such barriers could
also be used in conjunction with other groundwater control and
recovery systems. Essential to the  design and construction of these
barriers would be adequate physical and chemical characterization
of the waste/subsurface system.
REFERENCES

1.  47 CFR§300.68 (j)
2.  Kufs, C., Rogoshewski, P., Repa, E. and Barkley, N., "Alternates to
   Ground Water Pumping for Controlling Hazardous Waste Leachates,"
   Proc. National Conference on Management of Uncontrolled Hazardous
   Waste S/to,Nov. 1982, 146-149.
3.  Sills, M.A., Struzzierv, J.J. and Silberman, P.T., "Evaluation of Re-
   medial  Treatment  Detoxification  and Stabilization Alternatives,"
   Proc. National Conference on Management of Uncontrolled Hazard-
   ous  Waste Sites, Oct., 1980, 192-201.
4.  Fetter, C.W., Applied Hydrogeology, Merrill Publishing Co., Colum-
   bus, OH, 1982, 60-67.
5.  Warner, D.L. and Lehr, J.H., "An Introduction to the Technology of
   Subsurface Wastewater Injection," EPA 600/2-77-240, 104.
6.  Nielson, D.R.,  et al.,  "Spatial  Variability  of  Field Measured Soil
   Water Properties," Hilgardia, 42, 1973, 215-260.
7.  Biggar,  J.W.  and Nielson, D.R., "Miscible Displacement and Leach-
   ing  Phenomenon,"  in  Irrigation of Agricultural Lands, edited  by
   R.M. Hagan, et al.,  American Society of Agronomy Monograph
   No.  11, Madison, WI,  1967, 254-274.
8.  White,  R.M.  and Brandwein, S.S., "Applications of Geophysics to
   Hazardous Waste Investigations," Proc. National Conference on Man-
   agement of Uncontrolled Hazardous Waste Sites, Nov. 1982,  91-93.
9.  Hem, J.D., "Reactions of Metal Ions at  Surfaces of Hydrous Iron
   Oxides," Geochem. et Cosmochim Acta 41, 1977, 527-538.
                                                                                                 IN SITU TREATMENT
                                                            225
-------
                        IN SITU  TREATMENT TECHNIQUES
                  APPLICABLE  TO  LARGE  QUANTITIES OF
              HAZARDOUS  WASTE CONTAMINATED SOILS
                                               RONALD C. SIMS
                                       Utah Water Research Laboratory
                                              Utah State University
                                                   Logan, Utah
                                            KATHLEEN WAGNER
                                                 JRB Associates
                                                McLean, Virginia
INTRODUCTION

  Uncontrolled disposal of hazardous wastes frequently results in
the production of large quantities of contaminated soils. It is often
cost prohibitive or impractical to excavate, haul and dispose of
these soils in an approved landfill. In situ treatment of these soils
was investigated in this project as an alternative. The approach to
treating soils is based on:  (1) fundamental soil chemical, physical
and biological processes, (2) methods developed for land treatment
of industrial wastes  and (3) hazardous  waste  land treatment
(HWLT)  regulations  recently promulgated in 40CFR, part 264,
1983.  The goals  of  in situ  management include  treating con-
taminated soils until an acceptable level is achieved and protecting
groundwater and surface water resources without physically remov-
ing or isolating the contaminated soil from the contiguous environ-
ment.

TECHNICAL GUIDANCE MANUAL

  The results of this paper study will be presented in  a two-volume
manual titled, "In Situ Treatment Techniques Applicable to Large
Quantities of Hazardous Waste Contaminated  Soils." The manual
is being developed by the authors, and in this paper they present its
projected contents. Volume one will contain flow charts, decision
trees, procedures and quantitative and qualitative criteria for deter-
mining treatment feasibility and selecting treatment  processes and
combinations of processes. Characterization of site specific condi-
tions  requires  information  concerning  soil,  site  and  waste
parameters in order to assess the behavior and fate of chemical-soil
interactions using qualitative and quantitative models. Based on
the results  obtained, treatment  needs  can  be identified  and
prioritized with respect to: (1) potential migration to groundwater
and surface water and to the atmosphere, and (2) recalcitrance, tox-
icity and persistence in soil systems.
  Specific in situ treatment options  will be selected based on the
following factors:
•Waste characterization
•Matching of waste  constituent  properties and  treatment tech-
 niques
•Safety considerations
•Analysis of the suitability of soil for treatment
•Economic analysis
  Waste  characterization  includes chemical class,  concentration
and behavior in soil systems. Matrices will be developed to match
specific treatment techniques with waste  constituents. Complex
wastes will be constructed from individual constituents present in
the wastes,  and  treatment techniques will be evaluated for in-
                                                  dividual constituents as well as complex wastes. Finally, verifica-
                                                  tion procedures to determine in situ treatment effectiveness will be
                                                  suggested. The verification procedures include: (1) groundwater
                                                  sampling, (2) soil core/soil pore sampling, and (3) monitoring of
                                                  soil macrostructure characteristics.
                                                    Volume two will contain specific information concerning in situ
                                                  treatment technologies and soil-waste interactions.  A discussion
                                                  and  summary  of specific physical,  biological,   chemical and
                                                  photochemical treatment  techniques applicable for  in situ treat-
                                                  ment will be presented. For each treatment process, factors ad-
                                                  dressed will include the achievable level of treatment, secondary im-
                                                  pacts of using the treatment technique, monitoring treatment per-
                                                  formance, equipment needs and application  methods and  costs.
                                                  Combinations of processes into treatment trains will also be con-
                                                  sidered. The final section of volume two will contain specific infor-
                                                  mation concerning the characterization and evaluation of fun-
                                                  damental processes in soil-waste systems that  affect the feasibility
                                                  and effectiveness of in situ treatment.
                                                    The  two-volume  manual will be prepared for engineers and
                                                  managers to select and apply in situ treatment technologies. Since
                                                  the majority of  in situ treatment technologies presently available
                                                  for hazardous wastes have not been thoroughly field tested, this
                                                  manual will contain information on promising techniques based on
                                                  laboratory and  field  results with hazardous and  nonhazardous
                                                  wastes. Also, the manual will provide a framework for  incor-
                                                  porating new developments in technology. The document can be
                                                  used by on-scene coordinators, toxic waste managers, regulatory
                                                  agencies and researchers as it will provide a format for bridging the
                                                  gap between research and  development and field applications of in
                                                  situ treatment techniques which are applicable to large quantities of
                                                  hazardous waste contaminated soils.

                                                  APPROACH FOR IN SITU TREATMENT

                                                    Elements that are believed to be essential in  a comprehensive ap-
                                                  proach to an in situ treatment program are shown in Figures 1 and
                                                  2. Those elements related to  the goals of in situ treatment are
                                                  shown  in Figure 1: (1) reducing concentration of contaminants to
                                                  an acceptable level and (2) protection of public health through con-
                                                  trol of transport pathways (leaching, runoff and volatilization)
                                                  from terrestrial systems to the environment (groundwater, surface
                                                  water and atmosphere).
                                                    The  steps required for efficiently and cost-effectively accom-
                                                  plishing the goals of in situ treatment are shown  in Figure 2: (I)
                                                  characterization of the site-waste system, (2) problem definition
                                                  with respect to potential waste impact, (3) management of the site-
 226
IN SITU TREATMENT
-------
                    GOALS OF IN SITU MANAGEMENT7""!
            PROTECTION OF PUBLIC HEALTH AND ENVIRONMENT

      TREATMENT OF WASTE CONSTITUENTS TO AN ACCEPTABLE LEVEL
    GROUNOWATER
                          SURFACE WATER
                                                  ATMOSPHERE
                        [SOIL SYSTEM j
                           DEGRADATION
                         TRANSFORMATION
                         IMMOBILIZATION
                            Figure 1
  Elements related to the goals of in situ treatment of hazardous wastes
                           SOIL SYSTEM
                          DEGRADATION
                         TRANSFORMATION
                          IMMOBILIZATION
    NO  EXOGENOUS AGENT
    ADDITION
ADDITION OF EXOGENOUS
AGENT
          MANAGEMENT OF SITE-WASTE SYSTEM


          PROBLEM DEFINITION

                          t
          ASSESSMENT OF SITE-WASTE SYSTEM



          CHARACTERIZATION OF SITE-WASTE  SYSTEM
                            Figure 2
           Steps required for accomplishing in situ treatment
waste system and (4) soil treatment technique(s) selection and ap-
plication including addition of a treatment agent(s), or augmenta-
tion of natural processes, for example, through amendment addi-
tion, or a combination of both approaches.

Characterization of the Site-Waste System
  Characterization and evaluation  of the  site-waste  system  is
necessary in order to select treatment techniques that are appropri-
ate and cost-effective. Each of these factors  shown below will in-
fluence the selection and application of treatment techniques for  in
situ treatment. This phase of the methodology includes the follow-
ing specific components:
•Assessment of  site-waste-soil conditions
•Role of sorption in determining the fate of  waste  constituents
•Fate of constituents with respect to microbial processes in soil
•Potential chemical reactions in the soil-waste matrix
•Assessment of  potential volatilization of waste constituents from
 the soil-waste matrix
  Specific  site and soil characteristics which  need to be identified
during site assessment for in situ treatment management are sum-
marized in Table 1. The first aspect of site assessment with respect
                            Table 1
Site and Soil Characteristics Identified as Important in In Situ Treatment


Site location/topography
Slope of site — degree and aspect
Soil, type and extent
Soil profile properties
  depth
  boundary characteristics
  texture*
  amount and type of coarse fragments
  structure*
  color
  degree of mottling
  presence of carbonates
  bulk density*
  cation exchange capacity*
  clay content
  type of clay
  PH*
  Eh*
  surface area*
  organic matter content*
  nutrient status*
  microbial activity*
Hydraulic properties and conditions
  depth to impermeable layer or bedrock
  depth to ground water,* including seasonal variations
  infiltration rates*
  permeability* (under saturated and a range of unsaturated conditions)
  water holding capacity*
  soil water characteristic curve
  field capacity/permanent wilting point
  flooding frequency
  runoff potential*
  aeration status*
Climatological factors
  temperature*
  wind velocity and direction
*Factors that may be managed to enhance soil treatment
                           to in situ treatment is to evaluate potential public health hazards
                           due to off-site migration of hazardous compounds to ground and
                           surface waters and transmission  through air.  The  potential for
                           migration, along with characteristics of the waste and the surround-
                           ing environment,  indicate the  degree of hazard  the site poses.
                           Secondly, the site must  be evaluated in terms of its potential for
                           decreasing the degree of hazard through degradation, transforma-
                           tion and immobilization. Those site-soil conditions that may be
                           managed to enhance these soil processes are indicated in Table 1. A
                           third aspect of site characterization involves assessment of the site
                           with regard to actual execution of in situ treatment, for example,
                           trafficability of the soil.
                             Soil sorption is perhaps the most important soil-waste process af-
                           fecting the  toxic and recalcitrant fractions of  hazardous wastes.
                           The influence of soil sorption on the extent and rate of leaching and
                           also on biological decomposition of  these  fractions  must  be
                           understood and described in order to effectively use the sorption
                           reaction as  part of treatment processes. The relationship between
                           immobilization of chemical constituents in soil systems, based on
                           soil chemical properties, and chemical class,  based  on chemical
                           structure, is summarized in  Table 2.  Generally,  nonionic consti-
                           tuents of low water solubility and cationic constituents have low
                           mobilities with respect to leaching potential. Acidic constituents at
                           neutral and high pH values are  most easily  leached  from soil
                           systems.
                             Understanding the relationship between  soil water content and
                           extent of sorption of hazardous chemicals provides the hazardous
                           waste manager with a process for controlling potential release and
                           migration of constituents through leaching. One commonly used
                           isotherm that is used to describe the immobilization of organic con-
                           stituents in  soils is the Freundlich isotherm:
                                                                                                  IN SITU TREATMENT
                                                                                                                                227
-------
 Leaching
 Potential
                   Table!
  Leaching Potential of Chemicals in Soil Systems


                  Chemical Class
            Nonionic
                                    Ionic
             Water
            Solubility
                bask
                            cationk
                                          acidic
        high med  low   low pH neutral pH
                                                low pH neutral pH
 Low

 Medium       X

 High      X
  S = K C1/n                                               (1)
  where K and n are constants,
  S  =  amount of chemical associated with the solid phase, or the
        solid phase concentration (weight of chemical per weight
        of solid),
  C  =  amount of chemical associated with the solution phase, or
        the solution phase concentration (weight of chemical per
        weight or volume solution).
The Freundlich isotherm relates the solid phase concentration to
the solution phase concentration at equilibrium conditions.
  The linear isotherm is an important isotherm which can be ob-
tained from the Freundlich isotherm when N = 1. The linear iso-
therm may be expressed as:

  S = kd C                                                 (2)
where kd  is called  the  distribution coefficient. This form of the
isotherm  has  been  used  for  relatively  low concentration  of
pesticides in soil systems.
  The relationship between kd, soil water 9, and percent adsorption
of an organic chemical can be used to manage a soil system:
  percent adsorbed =  kd/(kd + 0)                          (3)
where 6 = soil moisture content (volume of water per weight of dry
soil, assuming density of water = 1.0 g per ml).
      90
      so
      70
      60
      50
                         •   9-20%
                         »   9- 40X
                            e- eo%
                         •   e- eon
                         »               20

                     DISTRIBUTION COEFFICIENT, Kd
                                                         30
                           Figure 3
        Extent of sorption as a function of soil moisture and kd
  The extent of sorption (percent adsorbed) as a function of soil
moisture content for different values of the distribution coefficient
is illustrated in Figure 3. Thus, careful control of soil water content
will determine, to a large extent, the relative immobilization of a
given set of chemical constituents identified at a remedial site. Op-
timization of cost effective and efficient treatment may require a
compromise   between   optimum  soil  moisture  content  for
biodegradation versus sorption. Implications for specific treatment
schemes will be discussed in the manual.
  The organic carbon content of a soil appears to play a dominant
role in influencing the distribution coefficient (kd). Results from in-
vestigations of soil-hazardous and soil-nonhazardous organic in-
teractions suggest that soil organic matter plays the most important
role in adsorption of organic chemicals by soils.
  The fate of metals (inorganic constituents) added to soil is con-
trolled by a complex and dynamic system of physical, chemical and
biological reactions. Metals, unlike many hazardous organic consti-
tuents,  cannot be  degraded or readily detoxified.  Toxic metals
represent a long term threat in the soil environment. This threat can
be reduced considerably if the heavy metals can be permanently im-
mobilized by either chemical or physical methods.
  The concentration ranges of inorganic constituents in soils found
at 436 field investigation team (FIT) sites are shown  in Table 3.
Also listed are the natural background levels of these constituents
in uncontaminated soils. Barium, cobalt and vanadium concentra-
tions were within background levels.
                                                                                    Table 3
                                                                 Content of Various Elements in Uncontaminated1
                                                                          Contaminated (FIT Sites) Soils
                                                   and
Element
Sb
As
Ba
Be
B
Cd
Cr
Cu
Co
Pb
Hg
Mo
Ni
Se
Ag
V
Zn
F
Common Range for
Soils (ppm)
2-10
1-50
100-3,000
0.1-40
2-100
0.01-0.70
1-1,000
2-100
1-40
2-200
0.01-0.3
0.2-5
5-500
0.1-2
0.01-5
20-500
10-300
104,000
Range at FIT Sites
for Soils (ppm)
15*
0.02-11,700
0.02-0.2
2-38
0.3*
0.3-118,300
0.04-136,000
2.2-186,300
2.6*
0.16-466,000
0.04-83,200
322*
0.4-8.800
0.9-1.3
1.2-18
0.04-2
0.03-38,000
110,000*
                                                         •one site reporting concentration
                                                         Source: Ecology and Environment, Inc. Field Investigations of uncontrolled hazardous waste sites.
                                                         FIT Project, USEPA Contract #68-01-«056.
  The chemistry of heavy metals in soils can be divided into two in-
terdependent but separate categories: (1) solution chemistry and (2)
interfacial  chemistry.  Factors  affecting  and  controlling  the
behavior of inorganic constituents in soil systems will be considered
in detail in the field guidance manual.
  Microorganisms are highly effective in removing certain hazar-
dous  organic constituents from soil systems. Organic chemical
decomposition in soil systems is a complex process which depends
upon organic substance properties, soil properties and environmen-
tal factors. The addition of exogenous toxic organic wastes to soil
systems greatly increases the complexity of soil metabolic pro-
cesses. This is partly because organisms are exposed to at least three
different types of chemicals:  (1) readily  consumable substrates, (2)
228
IN SITU TREATMENT
-------
      02
 c

 "f   101
 o>
 X
 01
 o
     10° =
10'
        *— ACENAPHTHENE
        e— ACENAPHTHYLENE
        ••— ACRIDINE
        *— ANTHRACENE
        O— BENZU) ANTHRACENE
        «— BENZO(b)FLUORANTHENE
        t— BENZO(k)FLUORANTHENE
        *— BENZOUJPYRENE
        a— CHRYSENE
                                  «— DIBENZd. j) ACRIDINE
                                  •»— DI BENZU. K) ANTHRACENE
                                  *— 01BENZOFURAN
                                  a— 01BENZOTHIOPHENE
                                  «— FLUORENE
                                  *— FLUORANTHENE
                                  e~ NAPHTHALENE

                                  *— PHENANTHRENE
                                  •I	 PYRENE
        10'1     10°    10'     102    103    \04    105
          INITIAL  CONCENTRATION  (ug/g-dry  wt.)
                            Figure 4
         Rates of transformation of PNA compounds in soil
              as a function of initial soil concentration
toxic constituents  which may inhibit metabolic processes and (3)
non-readily consumable organics which may not  be toxic, but
which do not serve as sources of carbon and energy for cellular
metabolism (cosubstrates).
  Although results for degradation  of  hazardous waste consti-
tuents cannot be presented here in full, data are summarized for the
polynuclear aromatic (PNA) class of organic priority pollutants in
Figure 4. The data compiled  by Sims and  Overcash2 represent
results from the literature and from laboratory  results. General
trends can be summarized as follows: (1) the initial rate of transfor-
mation increases with increasing initial  soil concentration  for a
given PNA compound, (2) the initial rate of transformation de-
creases with increasing number of fused benzene rings within the
class of PNA compounds.
  Several classes of chemical contaminants are considered concern-
ing chemical-soil reactions and reactions resulting from addition of
treatment agents to soil-waste  systems. Only the solvent class  of
chemical contaminants is discussed here.
  Available studies indicate  that little  information  has  been
generated concerning the leaching behavior or effects of nonaque-
ous  or  aqueous-non-aqueous mixtures  in terrestrial  systems.
However,  assessment  of hazardous  waste sites has  identified
numerous organic solvents present that are not present as trace con-
taminants in an aqueous solvent.
  Several recent studies have indicated that organic materials will
react with clay minerals in soil systems to generally increase clay
permeability.3'4-5'6'7 Studies  onthe effects  of solvents  on  clay
permeability have been concerned with clay liner integrity in land-
fill sites. However,  results from these studies have important im-
plications for  large quantities of hazardous waste  contaminated
soils, specifically with respect to soil structure and the effects of soil
structure on leaching potential.
  The effects of organic solvents on clay permeability of one soil
having smecitite as the dominant clay mineral are presented  in
Table 4.  Smecitite clays were the most susceptible to permeability
changes by organic solvents. General classes of organics, including
acidic, basic, neutral polar and neutral nonpolar are included. It is
evident  that most solvent organics  increase permeability  of clay
minerals in soil systems. It  is not known, at present, how dilute
aqueous mixtures of organic solvents will affect the permeability of
soils.

                            Table 4
           Effect of Organic Solvent in Clay Permeability4
Chemical
Class
Acid
Base
Neutral
Polar
Neutral
Nonpolar
*smectite clay
Solvent
Acetic acid
Aniline
Acetone
Ethylene
Glycol
Xylene
Heptane

Effect on
Permeability
decrease
increase
increase
increase
increase
increase

Comment
dissolution of clay
100 fold for Lufkin"1
10 fold for H.B.*
1000 fold for Lufkin
50 fold for H.B.
100 fold for Lufkin
4 fold for H.B.
1000 fold for Lufkin
100 fold for H.B.
similar to Xylene

                                                                 Volume I of the manual will include the methodology for choos-
                                                              ing treatment techniques. Specific information needs and analysis
                                                              and endpoints obtained will be indicated with respect to: (1) char-
                                                              acterization of the site-waste-soil system, (2) assessment of the site-
                                                              waste system, (3) problem  definition and (4) management of the
                                                              soil-waste-site system. Examples for using the methodology for
                                                              specific site-soil-waste combinations will be reported in the  field
                                                              guidance manual.

                                                              Soil Treatment Technique(s) Selection and  Application
                                                                 Soil treatment is defined as a set  of physical, chemical and/or
                                                              biological  reactions,  natural  or   induced,  that  accomplishes
                                                              degradation, transformation or immobilization of hazardous con-
                                                              stituents in the soil system. The endpoint is to achieve acceptable
                                                              levels of constituents in the soil solution.
                                                                 Treatment involves two  major approaches. A  treatment  agent
                                                              (physical, chemical or biological) may be added to the soil-waste
                                                              system to accomplish the objectives of treatment, or treatment may
                                                              be accomplished through the augmentation of natural processes in
                                                              the soil-waste system. Addition  of an amendment to a soil-waste
                                                              system may cause an increase in the rate, effectiveness or extent of
                                                              natural processes.
                                                                 Physical, chemical and biological treatment processes considered
                                                              for in situ treatment of hazardous waste contaminated  soil are
                                                              characterized and   organized for   presentation  and  evaluation
                                                              according to the outline presented in Table 5.
                                                                 A summary of variables that can  be controlled  in physical,
                                                              chemical and biological treatment processes for in situ treatment in-
                                                              cluding treatment agent addition and treatment augmentation, are
                                                              presented in  Table 6.
                                                                 Based upon the information presented concerning the behavior,
                                                              fate and reactions of chemical constituents in soil systems and treat-
                                                              ment options available  for in situ  treatment, a methodology  is
                                                              presented for choosing specific techniques to match site-waste-soil
                                                              requirements. In order to determine cost effective, rational and ap-
                                                                                               IN SITU TREATMENT
                                                                                                                         229
-------
                            TtbleS
          la Situ Treatment Processes for Hazardous Wastes
 1. IDENTIFICATION
   Process fundamentals
   Information requirements
 2. EVALUATION
   Status of the technique
   Feasibility and effectiveness
 3. DESIGN
   Management variables
   Equipment needs
   Application methods
 4. COST ANALYSIS
   Unit costs
   Other costs
 5. EXAMPLES AND SOURCES OF INFORMATION


propriate treatment techniques it is necessary to define the problem
within the context of the treatment endpoints.

ACKNOWLEDGMENT

  This work was funded by the USEPA Municipal Environmental
Research   Laboratory,   Cincinnati,   Ohio,  under  Contract
68-03-3113, task 41. The authors  wish  to  acknowledge  the
assistance and support of the project officer, Naomi Barkley. They
also  wish to  thank the project staff,  Dr. Darwin Sorensen,  co-
principal investigator, Dr. Jerry Jurinak,  Dr. Dean Adams, Joan
McLean, Judith Sims, Ramzi  Mahmood and the support staff at
the Utah Water Research Laboratory. The contributions of Dr.
Ryan Dupont, Utah Water Research Laboratory, are appreciated.

REFERENCES

1. Lindsay,  W.L.,  Chemical Equilibria in Soils. John Wiley and Sons,
   New York.
2.  Sims, R.C. and Overcash, M.R., "Fate of Polynuclear Aromatic Com-
   pounds (PNAs)  in  Soil-Plant  Systems". Residue Reviews,  88, 1983,
   1-68.
3.  Buchanan, P.N., "Effect  of  Temperature and Adsorbed Water on
   Permeability and Consolidation Characteristics of Sodium and Cal-
   cium Montmorillonite." Ph.D. Dissertation, Texas A & M University,
   College Station, Texas, 1964.
                                                                                    Table 6
                                                                Physical, Chemical and Biological Treatment Processes
                                                                         Considered for In Situ Treatment

No
Exogenous
Agent









Exogenous
Agent
Addition








Btotogkal
moisture
modification
nutrient
addition
analog enrichment
pH adjustment
aeration
organic matter
addition
temperature
adjustment
microorganism
seeding
genetic strains
acclimated
strains







Chemical
moisture
modification
(oxidation/
reduction)
pH adjustment
(hydrolysis)
temperature
adjustment



oxidation
ozone
peroxides
reduction
sodium sutfide
calcium sulfide
sodium boro-
hydride
organic matter
precipitation
calcium oxide
chelation
Physical
moisture
modification
pH adjustment








sorption
activated
carbon
organic
matter
mineral
addition





Photochemical
moisture
modification
volatilization








photosensitized
sensitizers
dyes









                                                        4.  Anderson, D.C. and Brown, K.W., "Organic Leachate Effects on the
                                                           Permeability of Clay Liners". Proc. of the Seventh Annual Research
                                                           Symposium, D.W. Schultz, ed., EPA-600/9-81-002b, 1981.
                                                        5.  Anderson, D.C., Brown, K.W. and Green, J.,  "Organic Solvent Ef-
                                                           fects on the Permeability of Clay Soils". Land Disposal of Hazardous
                                                           Wastes. EPA-600/9-82-002,  1982.
                                                        6.  Brown, K.W. and Anderson, D.C., "Effects of Organic Solvents on
                                                           the Permeability of Clay Soils." EPA-600/2-83-016, 1983.
                                                        7.  Brown, K.W.,  Green, J. and Thomas, J., "The Influence of Selected
                                                           Organics Liquid on the Permeability of Clay Liners." In: D.W. Schultz
                                                           (ed.) Land Disposal, Incineration, and Treatment of Hazardous Waste.
                                                           In Press. 1983.
230
IN SITU TREATMENT
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       IN SITU DETOXIFICATION OF HAZARDOUS WASTE

                                       VINOD K. SRIVASTAVA, Ph.D.
                                        SIROUS  HAJI-DJAFARI, Ph.D.
                               D'Appolonia Waste Management Services, Inc.
                                             Pittsburgh, Pennsylvania
INTRODUCTION

  Uncontrolled disposal of hazardous wastes usually results in con-
tamination of soil and rock followed by groundwater contamina-
tion. The removal of contaminated ground and emplaced waste is
costly and often impractical. Open excavation requires careful
transportation  of contaminated  mixtures and disposal in a safe
landfill. An alternative to contaminated ground removal is in situ
treatment or detoxification.
  In situ detoxification in this paper means "in-place" treatment
of waste, soil and fluid to reduce the contamination level to an ac-
ceptable one. In this process, contaminated materials  remain in
place, while external additives are used to alter their physical
and/or chemical characteristics.
  Although many of the fundamental concepts of in situ detox-
ification are  known,  and others are  being studied  at several
laboratories, the feasibility assessment  has not been collectively
considered  for  different  applications,  mainly  because  these
technologies are  either  in the conceptual or early infancy stage.
Recently, the USEPA began a research  program at the  Municipal
Environmental Research Laboratory,  Cincinnati, Ohio, to  in-
vestigate in situ treatment of hazardous wastes. A literature search
has been conducted to identify the technologies that either exist or
have the potential  for  further investigation. The  most common
technologies considered for in situ treatment include:
•Immobilization
•Biodegradation
•Neutralization
•Solvent Mining
•Oxidation-Reduction
  One significant limitation of in situ treatment is  that  it is waste
specific. Heavy metals, pesticides, residues,  organic solvents, in-
organic salts, explosives, etc., have their own chemical  properties
and require  different treatment.  Proper identification  of wastes
and their physical, chemical and toxicological properties is vitally
important to determine the best strategy planning for in situ treat-
ment to avoid undesirable reactions or production of additional un-
wanted toxic species. In the following paragraphs, the present and
promising  in situ detoxification technologies are  evaluated; this
evaluation is summarized in Tables 1 and 2.
  In  these tables,  the applications of  in situ  detoxification
technologies for organic and inorganic contaminants are identified
and their applications are assessed with particular regard to their:
•Availability—Commercially developed,  pilot plant or laboratory
 scale
•Feasibility—Design, construct and operation feasibility
•Cost-Effectiveness—Design, construction and operational cost
•Advantages and Disadvantages—Unwanted chemical reactions or
 end products
•Environmental Impact—Assess environmental hazards, spread of
 contamination
•Safety of the Method—Personnel safety
  The application of each technology for treatment of solid and li-
quid wastes is as follows.
IMMOBILIZATION
  Immobilization or gelation is the fixation of toxic waste to render
it insoluble. The waste materials are immobilized in a normal earth
  Mutated organisms have been shown to break down the complex
persistent pollutant 2-4T13'14 pesticides and organic solvents.15 Use
Contaminated Soils/Solids
  A field conceptual design1 of placing polymerized ion exchange
resins around the waste was studied in the laboratory.  Reduced
concentrations of phenols, cyanide and nickel were recorded as the
leachate passed through ion exchange  barriers. Complexing of
trinitrotoluene (TNT) using surfactants2 failed due to poor results
and potent mutagenic end products.
  In laboratory experiments, a 70% decrease  in the mobility of
radioactive  strontium3  was achieved using  CaCO3  as  a fixative
agent. Feasibility studies for  in situ stabilization of  low-level
radioactive waste were  accomplished4 by encapsulating the waste,
using cement kiln dust, fly ash, synthetic ion exchange resins and
impervious liners.

Contaminated Water/Liquids

  Conceptual design1 as described earlier is not feasible; however,
external fixation technologies are commercially available.'
Technology Assessment

  The technology of encapsulating and treating of waste to make it
non-hazardous is commercially available.5 Some technologies are
applicable in the field. The cost  is dependent on the technology,
processing methods and the chemicals used. The process of encap-
sulating is generally cheaper than placement of an  ion exchange
barrier. The major costs may be the determination of the extent of
the contamination and  installation of monitoring wells.
  The environmental impact is dependent on the length of time the
waste remains immobilized and is usually minimal. The technology
is waste specific and often cannot be used  in mixed waste systems.
The health hazards associated with the technology may be minimal.
                                                                                         IN SITU TREATMENT
                                                                                                                     231
-------
                                                            Table 1
                                   Assessment of In Situ Detoxification Technologies Organic Wastes
TECHNOLOGY
CONTAMINANT

Hydrocarbon!
Oi 1 and Greaae

Organic Acid!
S. Conpounds
Alcohol!
Peroxide!
Halocarbons
PCB's and
Peat icides

Phenols

Ethers
Anni 1 ine
Amines
Pyr id ine!
Nitro Compound!
Aldehyde
Herbicide!
Solvent!
COMMENTS :
Available Technology
X - None
L - Lab Scale
P - Pilot Plant Scale
F - Field Scale




OXIDATION ""ERENCES
IMMOBILIZATON BIOOECRADATION NEUTRALIZATION SOLVENT MINING REDUCTION
F,6,D,c,Y
F,8,D,d,Y
F,6,D,c,Y
N,8,E,d,Z
N,8,E,d,Z

F,6,D,c,Y

L,4,E,b,Z
L,4.E,d,Z
L,4,E,d,Z
F,6,I),c,Y
F,5,N,d,Y N,8,E,d,Z
L,4,E,d,Z
F,4,2,c,Z
F,5.D.>.,Z
F,5,D,C,Z

L,3,B,a,X
F,4,0,c,Y
L^.E.d.Z
P,8,E,d,Z
F,6,D,c,Y
1 - None A Severe
2 Very Poor B Moderate
3 - Poor C Poor
4 Fair D None
5 Good E Unknown
6 Very Good
7 Excellent
8 Not Known
6
7
21
23
11
N.B.E.d.Z N,8,E,d,Z 2,54
22

12
13
14
1
N,8,E,d,Z N,8,E,d,Z 22,55,16,54
34
56
N,8,E,d,Z 31,57
57

N,8,E,d,Z 2,34
N.S.E.d.Z 10,34
13,14
15
21
Cost Effect iveneai Safety of Method
a - High X Unsafe
b - Medium Y - Safe
c - Low Z Unknown
d - Not Known




BIODEGRADATION
  Biodegradation or microbial degradation is the process of plac-
ing waste in contact with specific microorganisms and providing the
necessary environment for  growth to metabolize the toxic com-
ponents to nontoxic or less toxic species. Biodegradation processes
may be aerobic or anaerobic, depending on the microorganisms
and chemical species.
Contaminated Soil/Solids
  The  use  of microbes for treatment of oil  residues  has been
reported in  the early  1970s.6'7 Extensive research  and  mutation
techniques have  resulted  in specific microbes  now commercially
available.8 The success of these microbes has been demonstrated
during the  cleanup of oil  contaminated  beaches of Great Yar-
mouth, United Kingdom,9 and a California formaldehyde spill.10
Laboratory scale degradation of phenols and benzoic acids11'12 is
promising.
  Mutated organisms have been shown to break down the complex
persistent pollutant 2-4T13-14 pesticides and organic solvents.15 Use
of thermophilic  organisms in  composting  process has  shown
degradation  of complex compounds such as chlorophenols and
chlorobenzenes;16 insecticides diszonium, parathion and dieldrin;17
chlordane;18 grease and oils;19 crude oil;20 TNT and pulp and paper
mill wastes; and pharmaceutical wastes.21
                                                       Contaminated Water/Liquids
                                                         Microbial  detoxification is comparatively  easy in external
                                                       aqueous systems. Field applications of aerobic microorganisms at
                                                       Mobay and Exxon Chemical have  shown  degradation of con-
                                                       taminants in wastewater contaminated with oil, grease, petroleum
                                                       waste  and various  other organics.22'23 including ethers56 and
                                                       amines.57 Degradation of substituted phenols," halocarbons12 and
                                                       trace organics and polynucleated hydrocarbons has been shown in
                                                       laboratory studies. Biological  treatment systems for groundwater
                                                       contaminated with  benzene  and  phenol24  and  other  organic
                                                       pollutants58 are under development.
                                                         Inorganic metals cannot be  metabolized by microbes; however,
                                                       biological reduction of ammonia25 and denitrification of nitrites**
                                                       have been achieved. Phosphorous has been found to concentrate in
                                                       microbial cells under aerobic conditions.
                                                       Technology Assessment

                                                         Aerobic treatment technology is available on a commercial scale
                                                       for certain contaminated liquids and soils. The need for oxygen and
                                                       water restricts the use of the technology to surface contamination,
                                                       especially for solid systems; however, the aqueous streams can also
                                                       be effectively treated with greater efficiency. The technology can be
                                                       applied in the field. Portable biological treatment systems are com-
                                                       mercially available.27
232
IN SITU TREATMENT
-------
                                                            Table 2
                                   Assessment of In Situ Detoxification Technologies Inorganic Waste
                       CONTAMINANT
                                        IMMOBILIZATON   BIODEGRADATION  NEUTRALIZATION   SOLVENT MINING
METALS
Arsenic
Barium

Cadmium
Chromium
Lead
Mercury
Selenium
Silvr
Nickel
Copper
Aluminum
NONMETALS
Acids
Alkalies
Ammonia
Salts
Cyanide
Fluoride
Nitrates
Peroxides
COMMENTS :
Available Technology
N - None
L Lab Scale
P - Pilot Plant Scale
F Field Scale





Complexing
Agent for As,
Cd, Cr, Cu, Zn
P,5,E,d,Y





L,4,E,d,Z







L,4,E,d,Z


L 5 E d Y

Feas ibi 1 it y
1 None
2 Very Poor
3 Poor
4 Fair
5 Good
6 - Very Good
7 Excellent
8 Not Known

Metals
L,4,E,d,Z 52

53
P,5,E,d,Z 46




L,S,E,d,Z 50
L,R,E,d,Z 50
L,8,E,d,Z 50



P,5,D,Y 25

N,l,E,d,Z F,4,E,b,Z 1,35,52
N,8,E,d,Z 35
L,4,E,«,Z 26
3

Environmental Impact Cost Effective Safety of Method
A - Severe a High X Unsafe
B - Moderate b - Medium Y Safe
C - Poor c Low Z Unknown
D - None d - Not Known
E - Unknown



  The cost of biological treatment is low compared to excavation
and disposal in secure landfills. The processing cost is low and
dependent on the type, scale of process and concentration of the
contaminants.
  The environmental impact is very limited because the end pro-
ducts are usually gases, spent microbes and low concentrations of
undegraded products. Commercially available technology is limited
to aerobic  microbes. Further research  is needed to  develop
anaerobic systems and "oligotroph" groups of microbes capable of
growing on low concentrations of substrates.  There are no ap-
parent health hazards associated with this technology.


NEUTRALIZATION

Contaminated Soil/Solids
  Chemical neutralizing agents can be injected into a waste with an
acidic or basic functional group to destroy or change the chemical
properties. Organic compounds with acidic functional groups, such
as carboxylic, sulphonic acids and phenols and alkaline groups such
as amines and aniline, can be neutralized either by  alkali or acids.
Neutralizing solid  wastes with poor reactivity may be a long and
continuous process.
Contaminated Water/Liquids
  The chemical industry produces wastewaters with diverse ranges
of pHs. These waters can be neutralized to make them nonhazar-
dous. Petrochemical wastes27 containing alkylation, sulphonation
products and steel mill  pickling liquors  can be  neutralized  on
site.28-29 Metal finishing wastewaters containing  sulphuric,
phosphoric and chromic acids and metal ions30 and plating wastes
containing cyanides can be treated with the appropriate neutraliz-
ing agents on site before disposal.

Technology Assessment
  It appears that solid wastes cannot be effectively treated with this
technique; however,  it is a commercially feasible technology for
wastewater and may be applied to liquid wastes in the field. The
treatment cost should be less than for excavation, incineration or
disposal in a secure landfill, dependent on the treatment process,
volume of the waste  and nature of the contaminants.
  The environmental impact can be variable, based on the process.
The waste-specific  process restricts its use to known contaminants
and noncontainerized wastes. Health hazards associated with the
technology are uncertain.
SOLVENT MINING

  In solution mining or soil flushing, a solvent is injected or flood-
ed  over the waste  disposal area or  the area of contamination to
remove the hazardous chemical. The elutriate (flushing liquid) is
collected by impervious liners placed under the waste and brought
back to the surface,  treated to remove the contaminants and rein-
jected. The concept.is similar to leachate generation under natural
conditions. The rate of contaminant migration is  dependent on
several factors such as waste-solvent interaction, active functional
group, soil-contaminant interaction, attenuation properties of the
waste, etc.
                                                                                              IN SITU TREATMENT
                                                          233
-------
     SOLVENT
      IMPERVIOUS  LINER
      LEACHATE  COLLECTION SYSTEM-
                          Figure 1
           Schematic Design for In Situ Solution Mining

  The conceptual design  of such a system is shown in Figure 1.
Water is the most accepted cost-effective solvent without the wor-
ries of secondary contamination, although other polar solvents or
aqueous mixtures of solvents can be used in a two-step process as
shown in Figure 2. The first step involved in the process of solution
mining is the use of an organic polar solvent to produce elutriate.
The contaminant is separated from the  elutriate and the solvent
recycled. The second step is similar to the first except that the con-
taminant is the polar organic solvent and the elutriate is water. The
process of solution mining is continued until all the polar solvent is
removed.

Contaminated Soil/Solids

  Organic  compounds   with  hydrophobic  functional  groups
become strongly attached to the soil and cannot be eluted with
water.  Leaching  of  these compounds  can  be enhanced  using
suitable polar organic solvents,  mixtures of solvents or complexing
agents. Wastes with hydrophilic groups can be more easily eluted
with water. Dilute acids may serve as a solvent to flush certain basic
organics such as amines and aniline.31 Surfactants may be useful in
dissolving oil and grease.
  Inorganic acids may  be used to dissolve basic metals, oxides,
hydroxides and carbonates.  Carbon dioxide with ammonia  has
been used  for leaching copper and nickel.32 Other complexing or
chelation agents  commonly employed  may be ammonia, am-
monium sulfate, citric acid, EDTA, thiourea, etc. Sodium has been
used to dissolve metallic aluminum and can be used for zinc,  tin,
lead and other metals. The Goose Farm site, Plumsted Township,
New Jersey, is an example of the solution mining technology being
developed.33

Contaminated Water/Liquids

  Solvent flushing for a liquid system is  not applicable.

Technology Assessment

  The technology is not available commercially, although research
and field trials are in progress, its feasibility, however, is good. The
cost of the system  could be less than for excavation and physical
removal or incineration;  chemical properties, quantity of waste,
type of solvent  and placement of an  impervious layer under the
waste will govern the cleanup cost. Additional costs will include the
installation of monitoring wells and an elutriate treatment system.
                                                        The technology is dependent on the fail-safe placement of the
                                                      liner and elutriate collection system. There is always uncertainty
                                                      with respect to adequate contact of buried waste to solvent systems.
                                                      The technology is not applicable to mixed or containerized wastes.
                                                      There should be no health hazards associated with the properly ap-
                                                      plied technology.
                                                      OXIDATION-REDUCTION

                                                        In oxidation-reduction systems, the valency-electrons of wastes
                                                      are changed to convert them into nontoxic or less toxic substances.
                                                      Laboratory studies  have shown the oxidation of highly toxic
                                                      cyanide to less toxic cyanates and the reduction of Cr+6 to Cr+3, in-
                                                      dicating the potential exists for use of this technology.
                                                                    STEP I
                                                                                    ELUTRIATE
                                                                 CONTAMINANT REMOVAL
                                                                          BY
                                                                    SOLUTION MINING
                                                                          SOLVENT
                                                           STEP 2

                                                             WATER AS SOLVENT
                                                           SOLVENT RECOVERY
                                                                 BY
                                                           SOLUTION MINING
                                                                          'ELUTRIATE
                                                                                Figure 2
                                                        Concept for Two-Step In Situ Solution Mining Using Polar Solvent

                                                      Contaminated Soils/Solids

                                                        Unsaturated organics  can generally be treated by oxidation-
                                                      reduction techniques. Hydrogen peroxide has been used to oxidize
                                                      aldehydes,  dialkyl  sulfides,  dithionate  nitrogen compounds,
                                                      phenols and sulfur compounds.34 Conceptual design and  in situ
                                                      cyanide detoxification by oxidation with sodium hypochlorite have
                                                      been described35 in a hypothetical ten-acre disposal site by injecting
                                                      hypochlorite at different depths.
                                                        Chloralkali industries are reported  to use  chemical oxidative
                                                      techniques to remove mercury from ores as well as from wastes
                                                      with a 99% recovery. In situ treatment of chlorinated pesticides
                                                      utilizing an anaerobic ferrous-ferric-redox system3*-37 was reported
                                                      in laboratory studies.

                                                      Contaminated Water/Liquids

                                                        Liquid wastes are easily treated by external chemical oxidation-
                                                      reduction. Trace quantities of phenols,38 diquat and paraquat,39
                                                      organic sulfur compounds40 and formaldehyde38-40 have been ox-
                                                      idized in  aqueous  streams using  potassium  permanganate,
                                                      hydrogen peroxide, sodium or potassium hypochlorite. Reduced
                                                      concentrations of phenols,  trichloroethylene41 and benzene were
                                                      reported in lake waters following ozone oxidation.
                                                        Chemical oxidation of soluble lead43 and the reduction of Cr*6
                                                      to Cr*3 using sulfur dioxide and sodium metabisulphite44-45 have
 234
IN SITU TREATMENT
-------
Table 3
Status of In Situ Detoxification Technologies Organic Wastes

Existing Promising
Technology Technology
Solids or Liquids Solids Liquids
Hydrocarbons
including Oil and
Grease Biodegradation E E
Organic Acids U Biodegradation Biodegradation
Oxidation-Reduction
Sulfur Compounds U Solution Mining Oxidation-Reduction
Oxidation-Reduction
Alcohols Biodegradation E E
Peroxides U U U
Halocarbons U Biodegradation Biodegradation
PCB and Pesticides Biodegradation E E
Phenols Biodegradation Immobilization Oxidation-Reduction
Oxidation-Reduction
Ether Biodegradation Solution Mining U
Anilines, Amines Biodegradation Solution Mining Neutralization
Neutralization
Pyridines U U U
Other Nitro-
compounds U Immobilization U
Oxidation-Reduction
Aldehydes Biodegradation Oxidation-Reduction Oxidation-Reduction
Herbicides U Biodegradation Biodegradation
Solvents Biodegradation E E
Pharmaceutical Waste Biodegradation E E
COMMENTS:
Technology Status: U - Unknown/Uncertain; E = Potential for Expansion
been achieved. In situ reduction of Cr+6 to Cr+3 in Arizona well
water using minute quantities of reducing agents46 is an indication
of the potential for this technology.

Technology Assessment
There are no fully developed commercially available
technologies, although several concepts look promising and feas-
ible in the field. The technology is cost-effective compared to ex-
cavation, physical removal and disposal to secure landfills. Major
costs incurred will be governed by such factors as nature, quantity
of the waste and chemical costs.
The technology is waste specific and not applicable to mixed
waste systems and containerized waste. Danger exists that the pro-
cess may add additional contaminants to the system. There are no
apparent health hazards associated with this technology.
OTHER NOVEL TECHNIQUES
Laboratory experiments have shown an effective oxidation of
phenols and amines by enzyme horseradish peroxidase and
hydrogen peroxide.46 Ninety-nine percent of the PBB and kepone
in soil was destroyed when exposed to solar radiation in the
presence of tertiary amines.47 Adsorption of metals by cellulosic
materials, such as wood product wastes, showed some promising
results.48

CONCLUSIONS
In this paper, the available and promising in situ detoxification
technologies have been reviewed; their application, feasibility and
cost-effectiveness have been assessed. The status of these
technologies has been summarized in Tables 3 and 4 for organic
and inorganic wastes. In situ treatment has been used in the field on
a limited basis for sites with well-defined wastes, especially shallow
and small contamination, chemical spills, surface contamination
and shallow industrial impoundments. In reviewing these technolo-
gies, in situ biological or chemical waste treatment may be an at-
tractive alternative compared to the waste removal. The literature
search indicates that the in situ detoxification can be applied for
aqueous and solid wastes separately.
For aqueous waste streams, the biodegradation is most promis-
ing followed by neutralization and oxidation-reduction.
GV\T cr\i1 /cnliHc nr fiiiripd u/actpc thp cnliitinn minimi fnllowpH hv
rtji awii/ aijiiu.& \ji uuiicu wdoicbf LIIC oiiiLiMuii milling, lunuwcu \jy
immobilization, neutralization and oxidation-reduction, respec-
tively, provide promising technology for in situ detoxification.
Biodegradation techniques can be applied to soils where the con-
tamination is at the surface and oxygen is readily available. The
technique of solution mining for buried wastes seems to be the
alternative to excavation and disposal to a landfill. The major
drawback of the technology is its limitation for use in mixed waste
systems and containerized wastes. More research is needed at the
laboratory and pilot plant scale level to develop these technologies
commercially.

REFERENCES
1. Porter, J.F., "Investigation of In Situ Gelatin to Control Emission
from Abandoned Hazardous Waste Site," Energy and Environmental
Engineers, Inc., Cambridge, Massachusetts, NTIS PUB. 82-103508,
1982.
2. Kaplan, D.L., et al., "2,4,6 Trinitrotoluene-Surfactant Complex:
Decomposition, Mutagenicity and Soil Leaching Studies," Environ.
Sci. Tech., 16, 1982, 566-571.
3. Spalding, B.P., "Chemical Treatments of Soil to Decrease Radio-
strontium Leachability," J. Environ. Qual., 10, 1981, 42-46.
4. Metry., A.A., Phoenix, D.R. and Lenthe, A.L., "In Situ Stabiliza-
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the American Nuclear Society Topical Meeting on the Treatment and
Handling of Radioactive Wastes, Richland, WA, Apr. 1982.
5. "Chemical Stability of Metal Silicates vs. Metal Hydroxide in Ground
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Table 4
Status of In Situ Detoxification Technologies Inorganic Waste


Existing Promising
Technology Technology
Solids or Liquids Solids Liquids
METALS
Arsenic Immobilization U U

mmo iization U
Cadmium Immobilization U U
Chromium Immobilization U Reduction
Reduction
Lead Immobilization Reduction U
Mercury Immobilization U U
Selenium Immobilization U U
Silver Immobilization U U
Nickel Immobilization Immobilization U
Solution Mining
Copper Immobilization Solution Mining U
Aluminum Immobilization Solution Mining U
Zinc Immobilization Solution Mining U

NONMETALS
Acids Neutralization U U
Alkalies Neutralization U U
Ammonia Biodegradation E E
Salts U U U
Cyanides Immobilization Immobilization Oxidation
Oxidation
Fluorides Neutralization E E

Nitrates Biodegradation E E
Peroxides U U U
RADIOACTIVE
WASTES Immobilization E E
COMMENTS:
Technology Status: U = Unknown/Uncertain; E = Potential for Expansion

IN SITU TREATMENT
                     235
-------
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14.  Kellog, S.T.. etal.. Science, 214, 1981, 1133-1135.
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16.  Sikora, L.J., et al., "Degradation of Pentachlorophenol and Penta-
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17.  Rose, W.W., et al., "Fate of Pesticides in a Composted  Agricultural
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18.  Mullins, D.E., et  al.,  "Preliminary Studies Evaluating  Composting
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19.  Deever, W.R., et  al.,  "Composting Petroleum  Refinery Sludges,"
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20.  Epstein, E., et al., "Enhanced Biodegradation of  Oil and Hazardous
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21.  Huddleston, R.L., et al., "Evaluation of Subsurface Effects of Long-
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22.  Zitrides, T.G.,  "Mutant Bacteria for Disposal of Hazardous Organic
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23.  Tracy, K.D., et al., "Mutant Bacteria Aids  Exxon Waste Systems,"
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24.  Hazardous  Waste Intelligence Report, Oct. 22, 1982, 8.
25.  "Biotreatment of  Ammonia," Environmental Reporter, Bureau of
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26.  Whinney, W.N., "Evaluation of Alternatives for  Disposal of Heavy
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27.  Cytox, CTX Bioxtreatment System, Technical Data  Sheet,  Allen-
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28.  Cheremisinoff,  P.N., el al., Pollution Engineering Practices, Hand-
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29.  "Limestone Treatment  of  Rinse Water from  Hydrochloric  Acid
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30.  Parsons,  W.A., "Chemical Treatment  of Sewage and Industrial
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31.  Weininger,  S.,  Contemporary Organic Chemistry,  Holt, Rinehart
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32.  DeRenzo, D., Unit Operation for Treatment of Hazardous  Wastes,
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                                                           33. Kufs, C., Rogoshewski, P., Repa, E. and Barkley, N.. "Alternatives
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                                                               DC,  Nov. 1982, 146-150.
                                                           34. FMC Corporation,  "Industrial Waste Treatment  with  Hydrogen
                                                               Peroxide," Industrial Chemicals Group, Philadelphia, PA, 1979.
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                                                               Disposal Sites," USEPA, Cincinnati, OH, EPA 600/2-78-142, 1978.
                                                           36. Glass, B.L.,  "Relation Between Degradation of DDT and Iron Redox
                                                               System in Soils," /. Ag. Food Chem., 20, 1972, 324-327.
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                                                           38. "Cleaner Waste," Indian Civil Engineers, 14, Oct. 1974, 21.
                                                           39. Comma, M.H., et al.,  "Kinetics of Chemical Oxidation of Dipyridy-
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                                                           40. Anderson, C.E., "Potassium Permanganate Control of Certain Or-
                                                               ganic Residues  in Air and  Wastewater," Symposium, Progress in
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                                                               Sanitation Research International, 1972.
                                                           41. Glaze, W.H., Peyton, G.R., Huang, F.Y., Burleson, J.L. and Jones,
                                                               P.C., "Oxidation of Water Supply Refractory Species by Ozone with
                                                               Ultraviolet Radiation," USEPA,  Cincinnati,  Ohio,  EPA  600/2-80-
                                                               110,  NTIS Accession No. PB-81107104, Aug. 1980.
                                                           42. Hoigne, J. and Bader, H., "Ozone Requirements and Oxidation Com-
                                                               pletion Values of Various Types of Water for the Oxidation of Trace
                                                               Impurities,"  in. Proc.,  Oxidation  Technique in Drinking Water
                                                               Treatment, USEPA, Office of Drinking Water, Washington,  DC,
                                                               EPA 570/9-74-020,  1979.
                                                           43. Augustine, R.L., Oxidation  Techniques and Application in  Organic
                                                               Synthesis, Vol. 1, Marcel Dekkar, Inc., New York, 1969.
                                                           44. Pollution Eng., 5, Nov. 1973, 45-48.
                                                           45. Metcalf and  Eddy, Inc., Wastewater Engineering Collection, Treat-
                                                               ment Disposal, McGraw-Hill Book Company, New York, 1972.
                                                           46. Arizona Republic, Phoenix, AZ, 1982, 10-16.
                                                           47. Alberti, B.N.,  et  al., "Pexoxidase  for  Removal of Hazardous
                                                               Aromatics  from Industrial Waste Water," Biological Detoxification
                                                               of Hazardous  Wastes,  J.H.  Exner,  ed., Ann Arbor Science,  Ann
                                                               Arbor, MI, 1982, 349.
                                                           48. Christinsen,  D.C.,  et  al.,  "Enhanced Photo  Degradation  of  Per-
                                                               sistent  Halogenated  Organic Materials," Proc. of the 34th Indus-
                                                               trial  Waste  Conference, Purdue  University,  Lafayette,  IN,  1980,
                                                               160-166.
                                                           49. Sabadell, J.,  "Adsorption  of Heavy  Metals  from  Wastewater and
                                                               Sludge on Forest Residuals and Forest Produce Waste," Proc. of the
                                                               2nd National Conference on Complete Water Use,  Waters Interface
                                                               with  Energy,  Air and Solids, Chicago, IL, May, AICHE, New York,
                                                               1975, 234-240.
                                                           50. Berkowitz, J.B., Funkhouser, J.T.  and Stevens, J.I., Unit Opera-
                                                               tions for Treatment of Hazardous Industrial Wastes, Noyes  Data
                                                               Corporation, Park Ridge, NJ,  1978.
                                                           51. Farb, D.G.,  "Upgrading Hazardous Waste Disposal Site: Remedial
                                                               Approach,"  USEPA, Cincinnati, OH, SW-677, 1978.
                                                           52. Munemon, M.,  et al.,  "Simultaneous Removal of Hazardous Metals
                                                               from Wastewater and  Disposal of  Resultant Sludge,"  Toxic and
                                                               Hazardous Waste Disposal, 3,  1980, 97-105.
                                                           53. Rouse, J.V.,  "Removal of Heavy Metals from Industrial Effluents,"
                                                               ASCE, J. Environ. Eng., Div.  ASCE, 1976, 929-936.
                                                           54. Considine, D., Chemical  and Process  Technology Encyclopedia,
                                                               McGraw-Hill Book Company, New York, 1974.
                                                           55. Troop, W.M., "Alternative Methods of Phenol Waste Water Con-
                                                               trol," J. Haz. Mat., I, 1977, 319-329.
                                                           56. Kimke, G.W., Hall, J.F. and Oeben,  R.W., "Conversion  to Acti-
                                                               vated Sludge at Union Carbide Institute Plant," JWPCF, 40,  1968,
                                                               1408-1422.

                                                           57. S.C.S. Engineers, Selected Biodegradation Techniques for Treatment
                                                               and/or Ultimate Disposal of Organic Material, EPA 600/2-79-006,
                                                               USEPA, Cincinnati, OH, 1979, 377.
                                                           58.  Wilson, J.T.  and McNabb, J.F., "Biological Transformation of Or-
                                                               ganic Pollutants in Ground Waters," EOS, Aug. 1983, 505.
 236
IN SITU TREATMENT
-------
ENGINEERING TECHNIQUES APPLIED IN DESIGN OF A TOE
 DRAIN  SYSTEM  THROUGH STRAITS  SCHIST FORMATIONS
                                              BRIAN D. GILLEN
                                          MICHAEL A. BARBARA
                                         Fred C. Hart Associates, Inc.
                                             New York,  New York
 INTRODUCTION

   In this paper, the authors discuss the engineering concepts and
 design parameters  developed  for a remedial leachate collection
 trench drain constructed in glacial till and straits schist formations
 surrounding a landfill located on a hill top. The site is presently
 receiving municipal wastes. However, in the past the site received
 industrial and potentially hazardous wastes. It is currently listed as
 a top priority Superfund site in the State of Connecticut,
   The landfill property consists of approximately 30 acres, of
 which about 17 are the active fill. Located above a bedrock forma-
 tion known as Straits Schist, the environmental issue is the route
 and effect of leachate migrating from the site and discharging at the
 perimeter to the west and north (Figure 1). A small portion of the
 leachate  may  flow via  a man-made  ditch to  a nearby brook.
 Leachate and contaminated runoff from the fill have migrated to
 an unnamed tributary and have caused some degree of contamina-
 tion. Geologic and hydrologic  investigations by Fred C. Hart
 Associates, Inc., (FCHA) of New York, New York1 have indicated
 that the underlying bedrock and compacted glacial till acts as an
 impermeable barrier and causes leachate to migrate radially from
 the site.
   Upon the completion of their study, FCHA recommended a
 course of action to eliminate the current problem with the leachate
 and contaminated  runoff. The  plan  called for construction of
 trenches  in both  glacial till  and  the  Straits Schist  formation,
 backfilling  with till and gravel, covering the trenches with till and
 sand, installing flexible drainage tubing and capping the completed
 trench. In this paper, the authors discuss the engineering concepts
 used in the design of the leachate collection system.
 DEVELOPMENT OF DESIGN CONCEPT

   Prior to  the design of remedial  activities to control leachate
 emanating from this site, FCHA and others conducted various sur-
 face, subsurface and groundwater investigations.1'2 The initial ac-
 tivities included installation of four 2 in. diameter wells varying in
 depth from 20 ft to  100 ft.  The following subsections briefly
 describe key elements of the FCHA site characterization study.

 Drainage Patterns
   Prior to the development of the landfill (i.e., natural conditions),
 an area known as Huntington Hill was the division between two
 major watersheds in the area:  (1) the Long Meadow Pond Brook
 Watershed and (2) the Spruce Brook Watershed, both of which are
 part of the Naugatuck Regional Basin (Figure 1).
   The development of  the landfill has significantly influenced
 drainage patterns.2 As the result of landfilling operations, it was
                        Figure 1
               Site Specific Drainage Patterns

necessary to delineate the Spruce Brook Watershed into two sub-
watersheds (Figure 1).
  The major portion of the landfill, approximately 19 acres, is still
part of the Long Meadow Pond Brook Watershed. Most surface
drainage is channeled through a drainage ditch located around the
southern and western perimeter of the landfill. This drainage ditch
channels this controlled runoff around the site into the unnamed
creek. The unnamed creek flows into Long Meadow Pond Brook
within the city limits of Naugatuck and eventually empties into the
Naugatuck River.
  The eastern portion of the site, approximately 7 acres, drains as
uncontrolled runoff. Some surface runoff enters the  heavily
wooded area to the east as intermittent streams and flows down the
steep slopes toward the Naugatuck River. Another portion of sur-
face runoff is channeled east across the access road at the base of
the landfill (Figure 1). Additionally, some direct storm runoff, not
related to the landfill, drains east down Hunters Mountain Road.
Flow Volume

  To develop estimates of flow volumes generated from the site, a
water balance was prepared  to calculate the total yearly quantities
of anticipated leachate generation.  The methodology used in this
assessment was developed by Fenn et al.1
                                                                                      IN SITU TREATMENT
                                                    237
-------
                                                               Table 1
                                               Water Balance for Laurel Park Landfill (In.)
                                                                                                             TOTAL
Pet
Preclp
Cr/o
r/o
I
I-PET
hcg 
 NOTES:
 LT  Less than
^H Organic carbon fraction of total solids
 •  Percentages extrapolated from actual Laurel Park leachate concentrations as reported in Uie 2/83
   etc. laboratory testing report.
 1 Estimates developed from leachate characterization as reported in Handbook of Environmental
  Coni/ol. Vol. II. unless noted.
 2 Assumptions and overall formulation used in developing the components of the total volatile
  solids are provided in Figure 3.
 3 Primarily iron and aluminum.

                            Figure 2
                        Landfill Leachate
          tCharactertzauon of Tolal Solids Based on FCHA Estimates')
                                                            In summary, total yearly percolation is expected to total 4 in./yr.
                                                         This is equivalent to a leachate generation rate over the 19 acre sur-
                                                         face area of the fill of approximately 2,000,000 gal/yr. This flow
                                                         would actually  vary on a month to month  basis, with  flows
                                                         reaching  20,000 gal/day during peak  months and with no ap-
                                                         preciable  leachate  generation  during  months  of   high
                                                         evapotranspiration (late  spring).

                                                         Leachate Characterization

                                                            The proposed leachate collection system was designed to convey
                                                         wastes off-site for ultimate discharge and disposal into the 10 mgd
                                                         Naugatuck  wastewater  treatment  plant  (NTP) located approx-
                                                         imately 2 miles away. Prior to entering into an agreement to accept
                                                         leachate  into the plant, NTP operating personnel requested infor-
                                                         mation on the composition of total organic carbon and metals.4
                                                            Laboratory analysis'  of  landfill leachate  revealed that  the
                                                         leachate  had a total solids (TS) concentration of 11,000 mg/1 and a
                                                         total  organic carbon concentration of 2030  mg/1  (Figure 2).
                                                         Estimates  of other  constituent concentrations  were  based on
                                                         published data extrapolated  from various other sources' in cases
                                                         where laboratory  analyses  were  not  available.  Approximately
                                                         18.5% of the total solids consisted  of total organic carbon (Figure
                                                         2). The organic component of the leachate, commonly referred to
                                                         as total  volatile  solids,  consisted  primarily of carbon, oxygen,
                                                         hydrogen and small quantities of nutrients and halogens (usually
                                                         chlorine). The carbon molecule represented between 30 and 80% by
                                                         weight of the total volatile solids, depending on the refuse compo-
                                                         nent from which the leachate originated. For example, the ultimate
                                                         analysis  listed  below indicates  a  wide  variability  of carbon,
                                                         hydrogen, oxygen  (CHO) formulas typical of differing organic
                                                         municipal refuse components.
                                                         REFUSE
                                                         COMPONENT                     ULTIMATE ANALYSIS (%)

Plastic
Maga-
zine
paper
C
78


37.90
H
9


4.95
O
13


38.
                                                                                                       N
                                                                                             0.07
0.09
                                                                                                              Inert
                                                                                                              22.47
                                                           For the analysis shown in Figure 2, FCHA assumed an average
                                                         ultimate analysis of refuse as 50% carbon, 5% hydrogen and 45%
                                                         oxygen. Using this formula and measured total organic carbon con-
                                                         centrations in the leachate, FCHA estimated that the total volatile
                                                         solids equals approximately twice the total organic carbon concen-
                                                         trations or approximately 31% of the total solids concentrations.
                                                         Assumptions used in developing estimates of the constituent com-
                                                         ponents in the total volatile solids are shown in Figure 3. More than
                                                         99% of the volatile solids were expected to be partially degraded
 238
IN SITU TREATMENT
-------
                                                TOTAL VOLATILE
                                                  SOLIDS  37%
                                                  C>o Ho O4« (2)
                                                   Table 2
                      Estimated Metal Effluent Concentrations Due to Leachate Contributions


"CHIOH-1
-(HC-OH)J
_CHO J



(3)
co-con
MCO-COH'
UCO-COR*
L*1 J

-PROTEINS
(h-co-





Zinc
Barium
Lead

Chromium
Arsenic
Iron
Copper

(A)
Laurel Park
Landfill Leachate
(Max. Concent.
Observed)
-------
  The proposed  design  objective is  to effectively  capture  the
leachate in perimeter gravity toe drains and convey the leachate by
gravity to the NTP for treatment and disposal. The leachate collec-
tion system consists of two separate systems, referred to as the East
and West Trench Drains. A 6 in. rigid polyethylene (RPE) gravity
sewer pipe will collect flow from both the drains and transport the
leachate to the NTP.
                           Figure 5
            East Toe Drain Section through Straits Schist

East Trench Drain
  The East Trench Drain will consist of approximately 1,400 ft of 4
in. diameter perforated flexible polyethylene (PFPE) placed within
a gravel envelope.  The perforated leachate collection pipe and
gravel will be installed in a trench varying in size from 10 to 60 ft2 in
cross-sectional area and will cut through rock along the south and
east  sides of Huntington Hill along the toe  of the landfill slope.
This  installation will require the removal of  900 yd3 of Straits
Schist, 1,200 yd3 of unconsolidated till and the  placement of 1,700
yd3 of gravel. The 1,000 ft long, 6 in. diameter RPE trunk line will
also  be required to transport the leachate from the East Trench
Drain to the proposed 8 in.  polyvinyl chloride  (PVC) sewer trunk
drain to be installed under a separate contract.
  A  plan view of  the site, the  approximate location of the East
Trench Drain and  a typical  cross-sectional detail of the proposed
method of construction are shown in Figure 5. A trench varying in
depth from 4 to 22 ft will be cut into the Straits Schist unit along
portions of the southern and eastern portions of  the site. The
trench will be located in or near areas of exposed rock and will cir-
cumvent the present fill areas and toe of slope. The drain pipes will
be 4 in. diameter, ABS pipe conforming with A.A.S.H.T.O. M-252
specification with nylon covering with 0.25 in. diameter holes.
  A  bedding of 1 to 1.25 in. gravel will be placed in the trenches
and  around perforated  pipes to provide uniform lateral  support
and to also serve as a high permeability channel (i.e., French drain).
The gravel media, consisting of coarse material, will not enter and
clog the 0.25 in. diameter perforations of the pipe. As an additional
protection against clogging, the pipes will be factory-covered with a
plastic filter fabric  to prevent fines from entering the pipe. The
fabric will have a weave that will match a U.S.  Standard pore size
of 200.
  The trench will be sealed with a layer of cushion sand to convey
leachate down  the slope and  into the trench. A 1 ft layer of recom-
pacted till will be placed over the sand to prevent surface runoff
from entering the gravel envelope and to contain leachate in the fill
so that it will drain  into the  toe  drain. The sand/clay blanket will
be topped with one  foot of cover material and seeded.
                                                        West Trench Drain
                                                          The West Trench Drain will consist of approximately 2,400 ft of
                                                        4 in. diameter PFPE pipe placed within a gravel envelope. The pipe
                                                        and gravel will also be installed in a trench varying in size from 10
                                                        to 40 ft2 in cross-sectional area excavated in till along the south,
                                                        west and north sides of the landfill at the  toe of the landfill slope.
                                                        This installation will require the  removal of 2,500 yd3 of uncon-
                                                        solidated till and the placement of the same amount of gravel.
                                                          A plan view of the site, the approximate location of the West
                                                        Trench Drain and a typical cross-sectional detail of  the proposed
                                                        method of construction are shown  in  Figure 6. A  trench drain
                                                        similar in design to the East Trench Drain will be constructed with
                                                        minor differences. The trench will be cut into unconsolidated till
                                                        along  the western   and  northern  portions of  the site.  The
                                                        permeability of this material varies, but FCHA soil investigations'
                                                        suggest that soil permeabilities are low, ranging from 10~5 cm/sec
                                                        to 10"' cm/sec. Excavated material from  this and  other locations
                                                        on site will be used to cover the West Trench. Gravel, filter fabric,
                                                        pipe and cushion sand will be employed in the same  manner as used
                                                        in the East Trench. After completion of the rock excavation, the
                                                        trench will be cleaned and inspected  for cracks in the schist. Two
                                                        coats (20 mils thick) of  a  high-build, flexible  epoxy protective
                                                        coating will be applied to fractures which may occur in the schist
                                                        during construction.
                                                          The contract also provides for installation of nine manholes and
                                                        17 standard single connection cleanout  assemblies, with case iron
                                                        frame and covers. These facilities will be installed at breaks in grade
                                                        or direction to allow for  periodic cleaning and/or testing  of the
                                                        pipe in the leachate collection system.
                                                                                  Figure 6
                                                               West Toe Drain Section through Unconsolidated Till
                                                        CONTRACTUAL CONSIDERATIONS, TECHNICAL
                                                        SPECIFICATIONS AND ENGINEER'S ESTIMATE
                                                          Contract drawings and specifications for this job were prepared
                                                        May 2, 1983 and submitted to the Connecticut Department of En-
                                                        vironmental Protection (CDEP)  for  review  and approval.  The
                                                        specifications contained a unit price contract format with estimated
                                                        quantities provided for bidding purposes.  Each work item  was
                                                        numbered for identification in the Contract Bid Proposal  and
                                                        Technical Specifications. These items (Item 2.01 through 7) are
                                                        summarized in Table 3. Items 2.01 through 7.12 refer to "State of
                                                        Connecticut  Department  of  Transportation   1980  Standard
                                                        Specifications for Roads and Incidental Construction (Form 812).
240
IN SITU TREATMENT
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                             Table 3
                     Contract Unit Price Items
Item 2.01
Item 2.05X
Item 2.06
Item 2.07AX
Item 2.07BX
Item2.12X
Item 3-PFPE
Item 4X
Item 5
Item 6X
Item 7
Clearing and Grubbing
Trench Excavation
Ditch Excavation
Embankment in Place
Borrow
Trimming Shoulders and Slopes/Preparing Fine Grade
Rigid Polyethylene (RPE) Sewer Pipe
Manholes
Connection to Existing Sewer Facilities
Single Connection Cleanout Assembly
Protective Coating
NOTE:
a. Item Nos. 2.01-2.12 above refer to the "State of Connecticut Department of Transportation
  1980 Standard Specifications for Roads and Incidental Construction (Form 812)" as detailed
  in Section 1(3)(1) of the Supplementary and Special Conditions.
b. "X" denotes sub-items.

   The Engineer's Estimate prepared for the contract is summarized
 in Table 4. The total  cost of the project is $150,000 with $100,000
 required for earthwork and rock excavation and $50,000 required
 for  installation of the toe drain and leachate collection system.
   Earthwork includes excavation of an estimated 3,900 yd3 of earth
 and solid  wastes  and 900 yd3  of rock-in-trench. Excavation of an
 estimated 200 yd3 of  material from runon and runoff control and
 construction of embankments from excavated sand (2,300 yd3), till
 (2,500 yd3) and  selected borrow (gravel, 3900 yd3)  are  other
 earthwork items. Preparing  fine grade for 7,900 yd3 of till and sand
 cover subgrades is a major component of the earthwork activities.
   The  leachate  collection  system  includes placement of an
 estimated 3,800 ft of 4 in. diameter PFPE under drains for leachate
 collection, an estimated  1,000  ft of 6  in.  RPE  sewer pipes for
 leachate transport, manholes for the toe drain and trunk sewer
 lines, connections to  existing  sewer lines and single cleanout con-
 nection assemblies.
                             Table 4
                        Engineer's Estimate

Item
2.01 BXA
2.05 XA
2.05 XB
2.06
2.07 AXA
AX8
AXC
2.07 BXA
BXB
BXC
2.12 XA
XB
XC
3-PFPE

3-RPE
4XA
5

6AX
7



Description Pay

• Unit
Estimated Unit
Quantity Price
Total
Cost
Clearing and Grubbing Lump Sui 	
Trench Excavation
Rock-ln-Trehcn Excavation
Ditch Excavation
Embankaent In Place - Sand
- Till
- Rock
Borrow - Sand
- Gravel
- Till
Preparing Fine Grade - Subgrade
- Top of Till
- Top of Sand
4" diameter Perforated Flexible
Polyethylene Pipe
6" Rigid Polyethylene Sewer Pipe
Manhole
Connection to Existing Sewer
Facility
Cleanout
Protective Coating


CY
CY
CY
CY
CV
CV
CV
CY
CV
SY
SY
SY

LF
LF
Each

Each
Each
Gallon


3,700 2
900 20
200 5
2,300 5
2,500 5
5

3,900 7

7,200 1
7,900 1
7,900 1

3,800 2
1,000 6
9 2

2 1,000
17 1,000
1 50 20
TOTAL:
Say:
7,400
18,000
1,000
11,500
12,500


27,300

7,200
7,900
7,900

7,600
6,000
18,000

2,000
17,000
1.000
UsT.Joo
$150,000
  This project was approved for construction by the CDEP in Aug.
1983 and was bid in Sept. 1983. At the time this paper was being
prepared, bids were being reviewed by the owner. Once a contract
is negotiated, project completion dates specified  in the contract
documents call for completion of this project  one month subse-
quent to commencement of construction.
JUSTIFICATION FOR PROPOSED DESIGN
  The proposed design should provide a highly effective system for
controlling  leachate  surface escape from the  landfill site. The
design offers a number of specific advantages including the provi-
sion of:
•A  toe drain system at the base  of the fill (above impermeable
 materials) for the  complete site perimeter
•Excess capacity  in the trench and perforated pipe collection sys-
 tem (i.e., the 4 in. perforated pipe alone can handle flows up to
 300,000 gal/day)
•Design  redundancy  in providing a perforated pipe  and gravel
 envelope collection system
•A  low-cost, essentially maintenance free system utilizing gravity
 flow for fluid transports and a filter fabric pipe  wrap for  solids
 screening
•Maintenance facilities including manholes and  single  connection
 cleanout assemblies  for the collection  system
•A  structurally sound system (i.e., by emplacement of the system
 in  rock excavation or undisturbed till)
•Easy to install flexible perforated polyethylene drainage tubing
 designed to withstand burial under 150 ft  of compacted solid
 waste
•Contract  quality  control provisions insuring  that the leachate
 collection system contains leachate within the toe drain system
  The last item was provided in the contract specifications which
called for a minimum of one permeability and one compaction test
per acre to insure  that recompacted glacial till  materials used as
liner  in the toe drain system have a permeability of at least 10"6
cm/sec and an optimum moisture content of 95% for subgrades
and 90% for till.
  For rock in trench  excavation activities, the specifications called
for placement of two coats (20 mils) of a high build flexible epoxy
protective coating to  be applied at the discretion of the engineer to
fractures which may occur in the schist during construction.

REFERENCES
1. Fred C. Hart Associates, Inc., "Laurel Park Landfill Hydrogeological
  Assessment," Feb. 1983.
2. Fuss & O'Neill, Inc., "Hydrogeologic Report, Laurel Park Landfill,"
   Jan. 1983.
3. Fenn. D., et  al.,  "Methodology Used in the Assessment of Leachate
   Generation from Landfills," 1975.
4. Personal Communication Fred C. Hart Associates to the Naugatuck
   Treatment Company, Mar.  1983.
5. Personal Communication Fred C. Hart Associates to the Naugatuck
  Treatment Company, Mar.  1983.
6. Environmental Testing Corporation Laboratory Report, Feb. 1983.
7. Richard  C.  Bond,  et al.,  Handbook  of Environmental  Control,
   Vol. II, 1971.
8. Personal Communication Fred C.  Hart Associates, Inc. to the Nauga-
  tuck Treatment Company, Mar. 1983.
9. USEPA Report, EPA-600-8-8-082.
                                                                                                 IN SITU TREATMENT
                                                                                                         241
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   BIO-RECLAMATION  OF GROUND AND  GROUNDWATER
                                           CASE  HISTORY

                                          VIDYUT JHAVERI, Ph.D.
                                           ALFRED J. MAZZACCA
                                Groundwater Decontamination Systems, Inc.
                                             Waldwick, New Jersey
HISTORY

  In Aug. 1975, contamination was observed in a small creek that
discharges into Allendale Brook in New Jersey. A storm sewer line
that discharges into the stream was a point source of pollution.
Data obtained in Nov. 1975 indicated the contamination was com-
ing from Biocraft Laboratories, Inc., a semi-synthetic penicillin
manufacturing  plant  located  nearby.  Biocraft's investigation
revealed a leak in an underground process line that carried a mix-
ture of methylene chloride, acetone, n-butyl alcohol and dimethyl
aniline. This mixture infiltrated into the storm sewer line in front of
the building which was the point source of contamination.
  On Nov. 24, 1975, all underground lines were disconnected and
above ground lines installed. The investigation failed to determine
when the leak started. Based on daily tank inventory readings from
June 1972 when the plant started  up, it was estimated that the
following amounts of substances may have leaked into the subsur-
face:
     •Methylene  chloride	181,500 Ib
     •N-butyl alcohol	66,825 Ib
     •Dimethyl aniline  	26,300 Ib
     •Acetone	10,890 Ib

SITE INVESTIGATION

  Biocraft's plant is located on a 4.3 acre site in the northern sec-
tion of Bergen County, NJ (Figure 1). The property is relatively flat
with approximately 30%  of  the area  paved or covered  with
buildings,  lO^o  grass  and the remaining 60%  lightly forested
(Figure 2). Glacial till underlying the surface at a thickness of about
8 to 15 ft is a poorly sorted mixture of boulders, cobbles, pebbles,
sand, silt and clay.
  The contaminated area covered approximately 1.75 acres (Figure
2). Permeability is highly variable throughout the till layer; ground-
water migrates at an average rate of 0.4 ft/day. The hydraulic con-
ductivity calculated from slug tests ranged from 0.02 to 36 gal/day
ft2 and hydraulic gradients ranged from 0.002 to 0.03 ft/ft. A
noticeable  groundwater mound is present, corresponding to the
south and east ends of the black-topped areas. Groundwater flow
from the mound  is omnidirectional (Figure 3).
  Approximately 40 ft of semi-consolidated silt  and  fine sand
underlies the till layer. Visual inspection of the  material  in this
deposit suggested very low permeability. Brunswick Shale of the
Treassic Newark  Group underlies the semi-consolidated layer for a
thickness of several hundred feet. The Brunswick formation is the
primary source of water supply aquifer for the area (Figure 4).
                                                                           Figure 1
                                                           Location of Biocraft Laboratories, Waldwick, N.J.
                                                   REMOVAL AND DISPOSAL

                                                     On Jan. 21,1976, the first monitoring wells were installed and by
                                                   Nov., ten were completed. Removal and disposal of contaminated
                                                   groundwater from selected wells started in Jan. 1977 at a rate of
                                                   2500 gal/month. This was later increased to 10,000 gal/month due
                                                   to the installation of 12 in. pumping  wells. The average cost of
                                                   disposal was $0.35/gal.  Contamination levels  fluctuated widely
                                                   during periods of high and low  groundwater levels.
                                                     Estimates indicated it would take decades to clean up the site. In
                                                   Dec. 1978 the New Jersey Department of Environmental Protec-
                                                   tion (NJDEP) ordered Biocraft  to accelerate the decontamination
                                                   process.

                                                   BIODEGRADATION

                                                     Aerobic  biodegradation  of acetone and  n-butyl  alcohol has
                                                   been known  for a long time.1'2-3 When Biocraft started the in-
                                                   vestigation in July 1978, the toxicity and the biodegradability of
                                                   methylene chloride was questionable. Later published reports and
242
GROUNDWATER TREATMENT
-------
         05
            \ .'   	UNDERGROUND TAMK FARM
                Figure 2
Configuration of Biocraft Site, Waldwick, N.J.
                      INDUSTRIAL PARK


                          	-i-
                                 '5
   	"  Deep Well

          \   213.5
Biocraft's  own studies showed  that  methylene chloride is
biodegradable."

Initial Study
  Contaminated groundwater  was inoculated  with various  soil
samples to  find  organisms that would biodegrade  methylene
chloride. Samples of soil were obtained from the homes of Biocraft
employees and from the contaminated site. The study indicated the
soil sample from the contaminated site was most promising.

Shake Flask Study
  A shake flask study using contaminated water as the sole carbon
source was done. Various mineral salt combinations were used to
obtain maximum cell mass.  A medium composed of NH4NO3 100
mg; Na2HPO4.7H2O 40 mg: KH2PO4 100 mg., MgSO4.7H2O 20
mg., Na2CO3 100 mg., CaCl2 1 mg., MnSO4 2 mg., FESo4.7H2O
0.5 mg. per  liter was  satisfactory. However, an increase in
methylene chloride concentration required  an increase in  dibasic
phosphate  to  buffer the acid  formed due to the oxidation of
methylene chloride.
  A similar anerobic study was not successful.

Field Feasibility Study
  In Dec.  1978, a  pilot study in  one of the monitoring wells
demonstrated the feasibility  of a biostimulation program. Aeration
                                                                      •'.o.
                                                                             0-3 Feet.* Silt and Gravel
                         3-5 Feet.* Glacial Till and Stratified Drift
                                                                             40 Feet.* Semiconsolidated Silt and Fine
                                                                                     Sand
                                                                              60 Feet.* Brunswick Shale
                                                                              •Formation Thickness
                Figure 3
     Water Table Configuration—1979
                          Figure 4
              Geologic Column for the Biocraft Site
                                                                        GROUNDWATER TREATMENT       243
-------
of the groundwater (temperature 12-14°Q in this well with a small
sparger and the subsequent addition of nutrients resulted in an in-
crease of bacteria from 1.8 x lOVml to 1.6 x Iff/ml in seven days.
The oxygen  uptake rate increased from an initial value so low it
could not be measured to 10 mg/1 hr.

Batch Process Study
  The batch study was carried in a Chemap 14 1 glass fermentor.
The fermentor  contained  10 1  of contaminated  groundwater;
mineral salts were added and air was sparged through a fritted glass
tube at 0.6 wm. The effluent air was passed through activated car-
bon. Biodegradation was determined by COD analysis  and total
bacterial count  (Figure 5).
 ssoo--
 33oo--
  lioo--
                                                     --IO
                                                     --IO
                                                     --IOJ
                                                     --10-
                                                      --IO
                                                      Pilot Plant Study
                                                        A pilot plant study was carried out in 55 gal drums set on their
                                                      sides to approximate a biological treatment plant. The drums were
                                                      set up in series with one drum as the activating unit and the other
                                                      drum as the settling unit. The activating drum was charged with 170
                                                      1 of contaminated groundwater and inoculated with 10% inoculum
                                                      obtained from the experiments in the laboratory. Air was sparged
                                                      through porous alumina air diffusers at a rate of 0.4 1/min. Con-
                                                      taminated groundwater was fed into the activating unit at the rate
                                                      of 12 1/hr.  The temperature was held at 20°C (±2°).
                                                        The effluent was pumped to the settling unit where the superna-
                                                      tant was pumped out and the settled biomass returned to the ac-
                                                      tivating unit. Pilot  plant studies ran  for approximately 17 days
                                                      (Figures 6,  6a, 6b). The pilot plant studies gave the basic informa-
                                                      tion for the design of the biological treatment plant.
                                                                                              -INFLUENT
                                                                     1000--
                                                                 -_.   6°°--
                                                                 u
                                                                 OJ
                                                                 5
                                                                      200- -
                                                                                        -EFFLUENT
                                                                                                8
                                                                                                DAYS

                                                                                           Figure 6
                                                                                       Pilot Plant Study
                                                                                                           12
                                                                                                   "T'T'1—I""1
                                                                                                            16
                           Figure 5
                      Batch Process Study
   On the eighth day, a large decrease in COD was noticed cor-
 relating with a large increase in total count on the ninth day. The
 first eight days were evidently an acclimation  period for the
 organisms. On the twelfth day the COD values leveled off in-
 dicating  the completion of the  biodegradation.  A similar experi-
 ment was done using  acclimated inoculum and the log phase was
 reduced from eight days to two days. There were no significant dif-
 ferences  between treatment at 20 °C and 30°C.
 Continuous Biodegradation Process
   Two Chemap 14 1 fermentors were set up in series. One, used as
 the biodegradation unit (activating  unit) contained  12 1 of con-
 taminated groundwater while the second  was used as the settling
 unit. A 19 1  reservoir was filled with contaminated groundwater,
 and essential minerals were added. One  line of a multi-channel
 peristaltic pump was used to pump contaminated water into the ac-
 tivating unit at the rate of 0.7 1/hr. The second line pumped treated
 water from the activating unit  into  the settling unit, and a third
 pumped  supernatant from the settling unit to an effluent reservoir.
 The continuous process had a 17 hr  retention time.
   After the first four days, the level  of methylene chloride was be-
 ing reduced  by 85-95% (Table 1).  However,  acetone  showed a
 three- to seven-fold increase in concentration. Under aerobic condi-
 tions, isopropyl alcohol (IPA) is transformed into acetone.5'6 An
 investigation of the gas chromatograph found that the methylene
 choride peak was hiding the isopropyl alcohol  (IPA) peak.  Later
 data indicated IPA was less than 100 mg/1.
   A similar  experiment was run  using water contaminated with
 dimethyl aniline (DMA) with a 90%  reduction in DMA.
                                                           500--
                                                                      300.--
                                                                                                             INFLUENT
                                                        5
                                                        Q
                                                            100--  —
                                                                                 Figure 6a
                                                                             Pilot Plant Study
                                                                              -INFLUENT
                                                                                          i—i  r  i   i—i ' i' i "i
                                                                                                          15
                                                                                 Figure 6b
                                                                              Pilot Plant Study
 244
GROUNDWATER TREATMENT
-------
                            Table 1
Level of Organic Contaminants in Continuous Laboratory Process (mg/1)
           INFLUENT
                                         EFFLUENT
 Day



 2
 3
 4
 5
 6
 7
MeClJ  Acetone BuOH  COO   MeCLj  Acetone  BuOH  COD
9975
4571
4847
4690
5040
4725
4583
4448
29
20
21
43
48
78
79
147
1091
 491
 518
 508
 584
 501
 476
 431
11939
 6320
 6360
 6460
 6460
 6115
 5933
 6437
9045
3285
1943
 719
 707
 818
 891
 227
 64
 73
143
 43
 20
 32
 34
 57
893
303
 81
ND
 3
 30
ND
 6
11497
 5287
 1908
 1113
 518
 1127
 759
 440
 ND: Not detectable. Detection limit 1 mg/1
 SITE DECONTAMINATION SYSTEM
   The biostimulation-decontamination system consists of the fol-
 lowing major components: (1) a groundwater  collection  system
 down  gradient of the contamination area, (2) a four-tank,  dual
 aerobic biological treatment system, (3) a series of in situ  aeration
 ells along teh path of groundwater flow, (4) effluent injection  tren-
 ches up gradient of the contaminated area and, (5) a control room.
   The groundwater collection system consists of a trench about 80
 ft long, 4 ft wide and 10 ft deep. Two slotted collection pipes  were
 placed on a gravel bed at the bottom of the trench, sloped toward
 the center and connected to a central collection pumping well. The
 trench was backfilled with washed stone, and then covered with 15
 mil plastic sheet and backfilled with earth to grade.
   The pumping wells were installed by digging an open hole about
 4 ft by 6 ft by 10 ft deep. A 12 in. PVC slotted casing was installed
 and the trench backfilled with washed stone. A sump pump with a
 10 gal/min. capacity was installed in the wells.
   Four stainless  steel, insulated, non-roadable tank wagons  have
 been altered so that  two 6,000 gal wagons could be used  for the
 biodegradation process and two 5,000 gal wagons for the  settling
 tanks  (Figure 7).
  The activating tank wagon contains steam line, recirculating line,
sludge return line, influent line, porous aluminum oxide air dif-
fusers with an average pore size of 60 microns, effluent line, vent
line leading to an activated carbon  filter, drain lines, gauges and
temperature recorders.
  The settling tank wagon contains steam line, sludge line, influent
line, effluent line,  vent line  leading to an activated carbon filter,
drain lines, gauges and temperature indicators.
  Air is sparged into the liquid through air diffusers in each 5000
activating tank at a rate of 20 standard ftVmin.
  There are two injection trenches 80 ft long, 4 ft wide and 10 ft
deep. They are lined on the bottom, sides, back and top with 15 mil
plastic sheet, so that the injected, treated water  leaves at the front
of the trench. The bottom section of the liner is laid on 1 ft of sand
base and then covered with 0.5 ft of sand. The trenches are hand
filled with 2 in. of washed stone to a thickness of 5 ft. A 2 in.
recharge pipe is installed in the center of the trench. The vertical in-
let pipe ends in a "Y" connection. Two 20 ft slotted sections of 2
in. pipe are connected to the  "Y." The trenches  are backfilled with
2 in. stone to the surface. A 4  ft high manhole is installed over the
recharge pipe and the top section of plastic is covered to a height of
4 ft with the soil that was removed. Each trench has two monitoring
wells, one at each end of the trench. The wells can also be used for
flushing the system if required (Figure 8).
  Nine air injection wells, 30 ft apart,  are installed in the subsur-
face along the major  pathway of the groundwater flow. Air is
injected into each well at  a pressure of 4 Ib/in. The radius of in-
fluence of each air well is greater than  15 ft. The average ground-
water flow through the aerated zones is 0.4 ft/day. Groundwater
temperatures range from 10 to  12 °C providing adequate conditions
for in situ biodegradation as the nutrient-rich water passes through
the aerated zone.
  The nutrient tanks, pumps,  flow meters, temperature recorders
and etc. are located in a small control room for monitoring and rate
adjustments as required.
                            Figure 7
          Above-Ground Biological Treatment System Design
                                                                                     Figure 8
                                                                                 Injection Trenches

                                                          Biological Treatment Plant Operation

                                                             On June 30,  1981, the above ground biological treatment system
                                                          was started. The intial treatment was a batch operation to develop
                                                          growth of the organisms. Each activating tank wagon containing
                                                          4,000 gal of contaminated water was inoculated with 50 gal of inoc-
                                                          culum from the pilot plant.  A combination of mineral salts was
                                                          added, air  was sparged at the  rate  of 50 ftVmin.  gal  and the
                                                          temperature maintained at 20 to 25 °C.
                                                             After one month, the entire system was  operated continuously.
                                                          The influent to  the activating  tank was  gradually increased to
                                                          match the recharge rate  of the pumping wells. The air was gradually
                                                          reduced and nutrient concentration was adjusted.
                                                             At present, about 13,500 gal of water are being treated per day
                                                          with a retention time of 17 hr. Air is sparged at a rate of 20 ftVmin.
                                                                                      GROUNDWATER TREATMENT
                                                                                                                     245
-------
and temperature maintained at 20 to 25 °C. The effluent air is pass-
ed through an  activated carbon filter and the  treated water is
pumped to the settling  tanks at a rate  to maintain a balanced
system.
  Solids from the settling tanks are recycled back to the activating
tank. The supernatant of the settling tank which is low in solids is
pumped into the injection trenches.
  The system could effectively treat 20,000 gal of water per day
with a 12  hr retention time. However, the pumping wells will not
yield the required  amount of water at a steady rate.
  The range and average composition of the process influent and
effluent are given in Table 2 for the first 16 months of operation
(Aug. 1981-Dec.  1982)  and for the  following  seven months of
operation. The average removal efficiency for  contaminants is
shown below.
                 August 1981-December 1982
 Substance
 Isopropyl Alcohol (IPA)
 Methylene Chloride (MeCy
 Acetone
 n-Butyl Alcohol (BuOH)
 Dimethyl Aniline (DMA)
                   December 1981-June 1983
 Substance
 Isopropyl Alcohol (IP A)
 Methylene Chloride (MeCy
 Acetone
 n-Butyl Alcohol (BuOH)
 Dimethyl Aniline
                                           Removal
                                      Efficiency (%)
                                              >98
                                              >98
                                              >88
                                              >97
                                              >64
                                           Removal
                                      Efficiency (%)
                                               >99
                                               >98
                                               >97
                                              >98
                                              >93
   Samples of the air space in the activating tanks based on 101 air
 samples show methylene chloride concentrations  in the range of
 0.030 to 0.040 mg/1 or less than 1 % of the contained methylene
 chloride.
   The microorganisms isolated from the activating tank consisted
 of the following: Pseudomonas (40%), Agrobacterium (40%) and
 Arthrobacter (20%). These are naturally occurring soil organisms
 that are known to use a wide variety of organics as a carbon source.
 A laboratory study using a Gilsen Differential Respirometer has
 shown that the above isolates can respire on one or more of the
                                                      following compounds—acetone,  methylene chloride,  n-butyl
                                                      alcohol and  di-methylaniline. Typical  data for Pseudomonas
                                                      isolate #28 respiring on methylene chloride are shown in Figure 9.
                                                        Experiments to show that methylene chloride adhering to the soil
                                                      is biodegraded were done by Umbreit at Rutgers University using
                                                      '*C labelled methylene chloride. A 0.5 in .  diameter glass column
                                                      was constructed using four 1 ft glass sections. The column was
                                                      packed with soil taken to a depth of 4 ft. Radioactive methylene
                                                          2oo--
                                                                    loo- -
                                                       
                                                       ^
                                                       -
                                                                                     cellswithCH2CI2
                                                                                                     cells without
                                                            TIME-mins.

                                                             Figure 9
                                                   Oxidation of Methylene Chloride

                                   chloride was added to the bottom 1 ft section and air was sparged
                                   through the bottom of the column at approximately 6 ml/min. The
                                   exit gases passed through a trap containing 0.1 N KOH solution
                                   and  then through a series of  activated  carbon traps. The  ex-
                                   periments were run in duplicate for  a total of six to seven days per
                                   run. One column contained uninoculated soil and the second col-
                                   umn was inoculated with organisms from the settling tanks. The
                                   results indicated a small conversion of methylene chloride to car-
                                   bon dioxide ( 2.3%)  in the uninoculated column but  appreciable
                                   conversion (56.1 %) in the inoculated column. Radioactivity could
                                   not be measured accurately in the soil because the soil granules in-
                                   terfered with the measurement of radioactivity. The larger percen-
                                   tage of CO2 was found adhering to  the soil. This was measured by
                                   removing  the CO2 with acid  treatment and then measuring  the
                                   radioactivity. A large percentage of the methylene chloride was
                                   unaccounted for (Table 3). This could represent methylene chloride
                                   tightly adsorbed to the soil, conversion to some non-volatile in-
                                   termediate or incorporation of the radioactive carbon into the cells.
                                                          Table 2
                                              Full Scale Biological Treatment Process
                                           Organic Influent and Organic Effluent (mg/1)
                                          PERIOD AUGUST 1981 - DECEMBER 1982

                                   INFLUENT
                                                                                     EFFLUENT
      Range

      Avg.
         IPA

         1 20-ND

          52
HeCl2   Acetone    BuOH     DMA         IPA     MeCl2    Acetone     BuOH     DMA

203-30  113-12     129-8    115-3       1-ND    22-ND    31-ND       7-ND     77-ND

 98        47        43       23          1        2.2       5.4        1.4      8.3
      Range

      Avg.
         IPA


         13-ND


          6.3
                                           PERIOD DECEMBER  1982  -  JUNE 1983

                            MeCl2    Acetone   jiuOH     DMA        IPA     MeCl2
                                                                            Acetone
250-11    120-20   92-3     23-1

 58.5      38.8     19.1      2.9
0.002-ND  5.7-ND    5.0-ND

  0.0     0.92       1.12
       ND • NOT DETECTED (Detection limit 5 »cg per liter)
BuOH     DMA

0.5-ND   1.0-ND

0.04     0.18
246
GROUNDWATER TREATMENT
-------
Performance Evaluation
  The groundwater quality cleanup goals for the decontamination
program were directed  by the New  Jersey Department of En-
vironmental Protection in an Administrative Consent Order dated
Sept. 25, 1980. The acceptable water quality is shown in Table 4.
  The biostimulation process implemented at  the Biocraft site is
reducing pollutant concentrations in the ground and groundwater.
Chemical analyses of  groundwater for  selected  pumping  and
monitoring wells prior to the startup of the continuous process and
after two years of operation are shown in Table 5.
  Pumping well  #13  in  the main collection trench has shown a
dramatic decrease in pollutants during the two-year  operation.
Pumping wells  #30  and  #32A show  a significant decrease in

                            Table 3
             Soil Column Experiments—Labeled MeCh
                                                               Table 6
                                               Levels of Contaminants in Monitoring Wells
Columns
Uninoculated
Methylene Chloride — in air 2.2%
Carbon Dioxide— in air 0. 1 %
Carbon Dioxide — in soil 2.3%
% = percent of added radioactivity found
Table 4
Acceptable Water Quality Parameters
BOD
COD
TOC
Chlorides
Acetone
n-Butyl Alcohol
Methylene Chloride
Inoculated
2.9%
0.1%
56.1%



6.0 mg/1
23.0 mg/1
18.0 mg/1
153. mg/1
100 /tg/1
lOOfig/1
8.0/tg/l
                            Table 5
   Levels of Organic Contaminants in Monitoring and Pumping Wells
Date
6/1-4/81
5/23/83
6/30/83
6/1-4/81
5/23/83
6/30/83
6/1-4/81
6/26/83
6/1-4/81
6/30/83
6/1-4/81
5/23/83
6/30/83
6/1-4/81
5/23/83
6/30/83
6/1-4/81
5/23/83
6/30/83
Well
4A
4A
4A
25
25
25
26
26
31
31
P-13
P-13
P-13
P-30
P-30
P-30
P-32A
P-32A
P-32A
MeCl2
67
ND
ND
260
ND
ND
360
<8«
78
<10*
989
ND
ND
880
23.5
64
305
182
281
Acetone
67
ND
ND
40
ND
ND
5
ND
81
ND
24
ND
ND
82
17.0
23.8
105
60
131
BuOH
.
ND
ND

ND
ND

<22*
to
<42
56
ND
ND
37
ND
ND
33
ND
129
DMA
23
ND
ND

ND
ND
19
ND


354
ND
ND
69
ND
ND
208
ND
ND
COD
300
48
60
286
5
3
939
180
425
75
2455
82
30
1418
200
600
1711
890
1600
Period
April- July 82





July-October 82



October 82-
March 83





March-Hay 83





6/30/83


Hell
1
2
4A
9
23
25
10
20
24
42
6
1 1
1 2
14
17
19
29
4A
5
9
24
25
42
S
17
29
HeClj
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Acetone
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
All values in mg/1
ND = Not Detected (detection limit is 5 /ig/1)
MeCli methylene chloride
BuOH
ND
ND
ND
ND
ND
ND
ND
HD
HD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
DMA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
COD
S3
32
60
150
35
153
99
31
17
20
30
10
10
12
19
127
70
48
114
17
10
15.4
3
30
2
80
TOC
12
2
14
39.2
2
40
20.2
1.4
3
2
3
2
1 .5
3
4.5
39.2
15.5
42
23
4
2.5
1.2
5.6
11
2.3
1 1
BOD5
14
8.6
24
44
5.1
4.2
36
3.6
8
3
7.5
4.2
5.0
7
1.4
43.2
70
59.9
42.0
7
4.7
5
0
6
1
11
BuOH n-butyl alcohol
DMA Dimethylaniline
COD chemical oxygen demand
All values in mg/1
ND = Not Detected (detection limit is 5 /ig/1)
* = Values given in /tg/1
MeCli methylene chloride
BuOH n-butyl alcohol
DMA Dimethylaniline
COD chemical oxygen demand
P pumping well
pollutants. It is believed that pockets of gross contamination are
being collected by these wells. The data strongly indicate a gross
reduction of contamination in ground and groundwater (Table 6).
This demonstrates that biostimulation can be successful not only in
relatively permeable but also in low permeable formations.
  Based  on COD values from a  few monitoring wells,  it is
estimated that the site should be clean by the end of 1984.

Project Cost

  The total cost for the biostimulation project is tabulated below.
1. Research and development                          $453,399.
2. Hydrogeological design and construction              184,243.
3. Process plant design and construction                 221,207.

                                               Total $858,849
  A literature search revealed little or no information on in situ
biodegradation of contaminants in the ground and groundwater by
recirculation. Therefore, the total amount of dollars spent includes
all aspects of the three individual costs. If the cost of the learning
curve is not considered, the projected cost at the Biocraft site would
be approximately $300,000.00.

Operating Cost

  Based  on treating  13,500 gal/day, the total operating cost in-
cluding utilities, nutrient cost, labor, maintenance and overhead is
$0.0165/gal. The  total  cost including amortization base on pro-
jected cost is $0.0358/gal over a three-year period.

REFERENCES

1. Levine, S. and Krampitz, L.O., "The Oxidation of Acetone by  a Soil
   Diphtheroid.", J. Bacterial., 64, 1952, 645-650.
2. Heinle, D.A. and Fuerst, R., "Acetone Utilization in Streptococcus
   Pyogenes." Dev. Ind. Microbiol. 17, 1976, 253-263.
3. Heinle, D.A. and Fuerst, R.,  "Acetone Incorporation in Streptococ-
   cus," Dev. Ind. Microbiol., 18, 1977, 557-563.
4. Brunner, Staub & Leisinger (1980), Appl. Environ. Microbiol  40(5V
   950-958.
5. Muller (1931), Biochem. z. 238: 253-267.
6. Pabst and Brown, Dev. Ind. Microbiol, 9, 1968, 394-400.
                                                                                      GROUNDWATER TREATMENT
                                                                                              247
-------
            A COMPUTER MODEL FOR OPTIMIZATION OF
                    GROUND WATER DECONTAMINATION

                                             LOUIS J. BILELLO
                                         MICHAEL H. DYBEVICK
                               Environmental Science and Engineering, Inc.
                                              Gainesville, Florida
INTRODUCTION
  Groundwater  contamination  can result  from past  industrial
waste disposal practices. Groundwater in shallow and deep aquifers
underlying a disposal area, as well as off-site water sources, may
contain traces or even significant concentrations of most of the
contaminants contained in materials disposed of in the landfill or
on the ground surrounding an industrial facility.
  Treatment of the contaminated ground water may be required (1)
for removal of contaminants from drinking water aquifers or wells,
(2) to lower the ground water table to implement a remedial action,
or (3) to prevent further off-site contaminant migration.
  Organic contaminants can either be volatile or non-volatile, with
the  volatile contaminants most  common because  of  their
widespread  use as industrial solvents and their greater mobility
through  soils. Inorganic contaminants, especially heavy  metals,
may  also be found in many contaminated ground waters.
  Although not the only applicable technologies, air stripping and
carbon adsorption are the most common ones used to  remove
organic contaminants. They are generally favored for the following
reasons:
•Most organic compounds can  be, to  some degree, removed by
 either or a combination of both processes
•Very low concentrations of most organics found in contaminated
 groundwater can be attained after treatment
•Limited, if any, pre-treatment is required for implementation of
 either process
•Costs are generally less than for other  applicable water treatment
 processes
•Equipment is readily available  either for purchase or lease from
 several manufacturers

Usefulness of a Rapid Assessment Model

  In  the  development  of  a  remedial action  plan or activity,
numerous alternatives maybe  considered.  Associated with the
evaluation of each alternative is the  development and achievement
of acceptable response objectives. In many cases, criteria may not
be established for recommended contaminant levels for a particular
site or aquifer.  This effort may require the consideration  and
evaluation  of  several  groundwater  treatment  scenarios.  To
minimize  the time required to perform each evaluation and the
overall alternatives analysis, the use of a model that performs both
a technical and economic assessment is essential.
  To more efficiently develop and cost remedial action alter-
natives, Environmental  Science  and Engineering, Inc. (ESE) has
combined its expertise in groundwater treatment and cost estima-
tion to develop a model that determines the design and cost of an
                                                   optimum treatment system using air stripping and/or granular ac-
                                                   tivated carbon (GAC). The system design and cost components are
                                                   specific to the treatment of contaminated groundwater at remedial
                                                   action sites and, therefore, may not be representative of other ap-
                                                   plications for either of the processes.
                                                     In this paper, the authors  discuss  the methodology used in
                                                   developing the computer model and present several examples of its
                                                   application. The theoretical and cost assumptions used are included
                                                   with the results and conclusions based on these assumptions.

                                                   AIR STRIPPING TECHNOLOGY

                                                   Theory

                                                     Removal of volatile organics from water by air stripping in a
                                                   packed column is based on the transfer of the compound from the
                                                   liquid to the  gaseous phase. To accomplish this, intimate contact
                                                   between the liquid and gas is essential. In a packed column, the
                                                   packing medium  provides a high  surface-area-to-volume  ratio,
                                                   allowing a thin water film to be produced and exposed to air. Effi-
                                                   ciency is dependent on the type and size of the packing medium and
                                                   several other  factors.
                                                     The amenability of an organic compound to be stripped from
                                                   water by air is determined by the equilibrium between the concen-
                                                   tration of the organic in the water phase and the concentration in
                                                   the air phase. For partially miscible organics at low concentrations,
                                                   these concentrations can be related  by Henry's Law:
Px = H,WL
                                                                                                         (1)
                                                     where Px =  partial pressure on the contaminant in the air (atm)
                                                          H! =  Henry's Law constant (atm-mVmole)
                                                          WL =  concentration of  the contaminant in the  water
                                                                 phase (moles/m3)

                                                   Determination of Henry's Law coefficients in this manner requires
                                                   costly laboratory analysis to determine the equilibrium relation-
                                                   ship.
                                                     If Henry's Law constants are not available for a contaminant
                                                   from the literature or from experimental data, an estimate can be
                                                   made using the  following approximation:

                                                     1/H, = 16.04(Vp)(MW)                               (2)
                                                        2        TOl

                                                     where 1/H2  = partition coefficient
                                                            Vp    = vapor pressure of the contaminant in water
                                                                   (mm Hg)
                                                          MW   = molecular weight of the contaminant
                                                             T    = temperature (°K)
                                                             S    = contaminant solubility in water (mg/1)
24S
GROUNDWAtER TREATMENT
-------
1/H2 is usually reported as dimensionless. Either form should be
calculated for  each contaminant  at  the  minimum anticipated
temperature of  the groundwater.  Temperature dependency of
Henry's Law constants follows the Van't Hoff relationship:
          10 t-
  log H  =  -AH°
              RT
(3)
  where  - AH ° =  enthalpy change due to the dissolution of the
                 compound in water
           R   = universal gas constant
           T   = absolute temperature

Units for the coefficients are  dependent on the units of the Henry's
Law constant. The higher the value of the Henry's Law constant,
the greater the potential for a contaminant to be stripped. McCarty
et a/.1 presented a number of Henry's Law constants for common
organic compounds.  McCarty indicated that compounds  with
Henry's Law constants greater than 1.0 x 10 ~3 atm - mVmole were
amenable to stripping.  The partition  coefficient (1/H2) is the
minimum theoretical air-to-water ratio required  to achieve  an
equilibrium between the air  and  water  phases for a  specific con-
taminant.2
 Air Stripper Design
   The design of an air stripping tower can be estimated from the
 Henry's Law coefficient, the maximum concentration of each con-
 taminant, the desired contaminant concentration in the stripper ef-
 fluent,  and knowledge  of the  mass transfer coefficient for the
 specific contaminant, packing medium and liquid loading rate on
 the column. Mass transfer coefficients can be obtained from ex-
 perimental studies or can be estimated from theoretical predictions.
   Treybal3 reports that the mass transfer coefficients of two com-
 pounds are related by the ratio of their molecular weights to the 0.3
 power.  Therefore, if the mass transfer coefficient for a specific set
 of conditions is known for one compound, it can be estimated for a
 second  compound.
   In the design of the air stripper, the liquid loading rate (lbH2O/ft2
 of column area) affects the maximum air loading rate that can be
 used. This limitation, termed flooding, is a physical constraint of
 the packing medium. At flooding, passage of water downflow
 through the column is restricted by the upcoming air.  Generalized
 flooding correlations are available for all packing media, as well as
 specific correlations for the individual packing materials.
   Once a liquid loading rate for  a selected packing medium is deter-
 mined,  the mass transfer coefficients (KL) can be determined from
 theoretical correlations* or from empirically determined coeffi-
 cients.
   Singley and Bilello5 described a linear relationship between the
 mass transfer coefficient and the liquid Reynolds number for water
 passing through a column. This relationship was determined from
 experimental data using chloroform as the contaminant. The ex-
 periments were conducted in a 15 in. diameter column containing 1
 in. Super Intalox® saddles. The equation is as follows:
     Re  = 3.32eLQ
            aAuL
(4)
   where Re  = Reynolds number
         eL  = liquid density (lb/ft3)
         Q   = liquid flow rate (gal/min)
         a   = surface area of the packing medium per cubic
               foot of packed volume (ftVft3)
         A   = column cross-sectional area (ft2)
         uL  = liquid viscosity (cp)
   The experimentally determined relationship between the mass
 transfer coefficient (KL) and the Reynolds number for 1 in. Super
 Intalox®  saddles is presented in Figure 1.
       s
       o
       £
       1
       I
          1.0
         0.10
         0.01
                                 SLOPE* • 0.7«
                               10

                                REYNOLDS NUMBER
                                                  100
                                 Figure 1
               Mass Transfer Coefficient versus Reynolds Number
                         for Super Intalox®  Saddles

         The packed depth for the medium is calculated using equations
       similar to the following:

           dm/dt = KL a LAACfL                                (5)
         where dm/dt  =  weight of compound transferred per unit
                         time Otg/min)
               K^a    =  overall mass transfer coefficient specific to the
                _    '   compound and packing material (1/ftVmin)
               A€L    =  1°8 mean concentration driving force 0*8/1)
                L     =  packing depth (ft)
                 A    =  column area (ft2)
       The log mean driving force is defined as follows:
                       -  (C
                         CE*)
               In
                  CI - CI*
                  CE - CE*
                                                                (6)
  where Cj   =  influent concentration of the organic compound
                in water Oig/1)
        Cj*  =  concentration of the organic compound in water
                in equilibrium with the outlet air (/tg/1) de-
                termined from the partition coefficient
        CE* =  concentration of the organic compound in water
                in equilibrium with the inlet air (jtg/1), which
                should be free of the organic contaminant
                (CE* = 0)
        Cg  ©  effluent concentration of the organic compound
                in water (/tg/1)

GRANULAR ACTIVATED CARBON  (GAC)
TECHNOLOGY

  GAC is an established,  effective technology for the removal of
organic contaminants from water and  wastewaters. Removal of
contaminants by GAC treatment depends on the type of carbon
used and the composition and concentration of the organics pre-
                                                                                   GROUNDWATER TREATMENT
                                                                249
-------
sent. In contaminated groundwater, several contaminants may be
present in a varying range of concentrations. The ability of GAC to
adsorb a specific contaminant depends on its relative concentration
and the  contaminant mix. The limiting contaminant  is the  first
compound to appear above its objective concentration in the car-
bon column effluent. At the breakthrough of this contaminant, the
GAC in the adsorber should be replaced.
   Determination of the limiting contaminant and the frequency of
carbon replacement is best accomplished  through pilot studies or
dynamic bench-scale studies such as the  Dynamic  Mini Column
Adsorption Technique (DMCAT).' Pilot studies  could be con-
ducted on-site, but are a major effort and cost. DMCAT studies
can be conducted quickly and  inexpensively on a sample of the
water or a synthetic matrix.
   Published isotherm data, although not in a dynamic system or
determined in a competitive matrix, can be used to obtain estimates
of carbon loading (Ib contaminant/lb of carbon), albeit for single
component systems.
   Several carbon  manufacturers and vendors provide adsorbers
and GAC. Spent GAC is replaced and hauled away for reactivation
or disposal. Generally, adsorber  sizes  are fixed with  20,000 to
40,000 Ib of GAC.
   In addition  to  frequency of GAC replacement, contact time is
another  design variable of interest. In  service systems, as would
most often be used at remedial action sites, contact time would be
determined by both flow and the amount of GAC. Since the quan-
tity of GAC is fixed per adsorber, a minimum contact time would
be selected  and  the number of adsorbers chosen  to  meet  this
minimum contact time.
DESIGN CONSIDERATIONS AND
ASSUMPTIONS USED IN THE MODEL

Air Stripper Design

  A series of air-to-water ratios (volume of air/volume of water)
was investigated for each contaminant identified in a hypothetical
groundwater matrix.  The minimum ratio considered was twice the
theoretical air requirements based on the partition coefficient. The
maximum ratio was the lesser of 250 or 8 times the theoretical air-
to-water ratio.  Above an air-to-water ratio of 250, the pressure
drop becomes  too high for efficient column operation. This limit
eliminated compounds with low partition coefficients from treat-
ment by air stripping.
  For a given compound and flow rate, the diameter for each air-
to-water ratio was calculated so that the column pressure drop was
no greater than 0.5 in water per packed foot, as recommended by
most  packing  manufacturers. Parallel streams were considered
when calculated column diameters  for single streams exceeded 14
ft. A design diameter  equal to  or larger  than the  calculated
diameter was chosen  from a set of standard diameters.
  The Reynolds number at the design diameter and flow rate was
calculated, and the mass transfer coefficient is recalculated at the
design Reynolds number according to the following (as discussed
by Singley and Bilello):'

  KU = KLI (NRea/NRe,)  0.76                             (7)
  The packed column length necessary for the required removal ef-
ficiency  was calculated by equations discussed by Kavanaugh and
Trussel.4 Maximum column height was limited  to 36  ft, which
allows for 22 ft of packing depth, 5 ft of column for a wet well and
9 ft for internal support equipment clearance. When the calculated
packed height exceeded 22 ft, a series operation was specified. In all
cases, use of 1  in. Super Intalox® packing medium was  assumed.
Air Stripper Cost

Capital

  Costs for columns and internals (distributors and support plates)
were based on vendor quotes for carbon steel. Packing costs  as-
                                                       sumed were $14/ft3 for quantities greater than 100 ft3 and $18/ft3
                                                       for lesser quantities.
                                                         Fans and pumps were chosen from a set of standard sizes provid-
                                                       ed by vendors. Where possible, a single fan was used to supply air
                                                       to all columns. One pump was assigned to each column.
                                                         Installed piping  costs  were included for 100 ft of carbon steel
                                                       pipe  to supply the system and 50 ft of pipe for each column.
                                                         The subtotal of the above costs was used as a basis to calculate
                                                       installation costs at 20%  and electrical and instrumentation costs at
                                                       13%. Duct work was assumed to add 100% of fan cost to total
                                                       direct costs.
                                                         Indirect costs were assigned as percentages of direct  costs as
                                                       shown in Table 1.

                                                                                  Table 1
                                                                         Indirect Cost Assumptions
                                                                             Engineering — 15%
                                                                            Contractor fee — 15%
                                                                                Legal — 2%
                                                                            Contingencies — 15%
                                                         It was assumed, for purposes of this paper, that control of air
                                                       emissions from the stripper is not necessary. In cases where the
                                                       emissions may cause a concern to the local residents or to workers,
                                                       control systems such as carbon cannisters would be used and their
                                                       cost included.
                                                       Operating Costs

                                                         Operating costs included electrical, maintenance, labor and ad-
                                                       ministration costs. Cost assumptions for each item are listed in
                                                       Table 2.

                                                                                  Table 2
                                                                   Operating Cost Assumptions for Air Stripper
                                                          •Electrical costs were based on total pump and fan horsepower at
                                                          $0.06/kWh.
                                                          •Maintenance material costs were estimated at 4% of direct costs.
                                                          •Labor costs were assumed to be $12/hr for 1 hr per day times the
                                                          number of columns to the one-third power.
                                                          •Administration costs were estimated at 20% of labor costs.
                                                       Granular Activated Carbon

                                                         The  basis for the GAC system designed was  a  leased,  truck-
                                                       mounted,  pre-engineered contractor containing 20,000 Ib of car-
                                                       bon. The package design does not have capability for backwashing.
                                                       When carbon usage is low, carbon replacement may be less fre-
                                                       quent than necessary to prevent unacceptable pressure drop. Under
                                                       such low usage conditions, a smaller charge may be necessary to
                                                       allow room for backwashing, possibly necessitating an additional
                                                       contactor  to maintain  the  minimum  empty-bed  contact time
                                                       (EBCT). Only  non-backwash  operation  was considered in this
                                                       analysis.
                                                         The package  contactor was assumed to be 10 ft in diameter. A
                                                       reactivated carbon with  a bulk density of 30 lb/ft3  was assumed.
                                                       Contactors were arranged in series  and parallel to  ensure  a
                                                       hydraulic loading less than 6 gal/min. ft2 and an EBCT of at least
                                                       40 min.
                                                         For the examples presented in this paper, carbon usage rates were
                                                       based on  isotherm data collected by Dobbs and Cohen.' Usage
                                                       rates determined from experimental studies can also be input. Ad-
                                                       sorption capacities were based on influent concentrations.
                                                       Granular Activated Carbon System Cost

                                                         The assumptions for GAC system capital, indirect and operating
                                                       costs are listed in Table 3.
250
GROUNDWATER TREATMENT
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                             Table 3
                   GAC System Cost Assumptions
CAPITAL COSTS:
•Contactors—A lease fee of $3,560 per contactor per month was used. A
 setup fee of $3,100 per site was assumed; setup labor to be provided on-
 site at 4 manhours per contactor at $12/hr.
•Site Preparation—$400 per contactor was allowed for a concrete pad.
•Pumps—Vendor lists of pump and driver costs were used.

INDIRECT COSTS (assigned as percentages of direct costs):
•Legal—2%
•Contractor fee—15%
•Contingencies—20%

OPERATING COSTS
•Electricity costs were based on rated driven horsepower and $0.06/kWh.
•Carbon costs were calculated from $0.70/lb carbon replaced.
•Operating labor was assigned at  1 hr per day times the square root of
 the number of contactors, plus 1 hr per carbon change.
•Administration and supervision costs were estimated at 20% of operating
 labor.
NOTE: Because the designs addressed in this paper are most appropriate for response to waste site
cleanup, no cost for land or working capital is included. Start-up costs are included in the installation
cost.
 PROGRAM REQUIREMENTS
   For  the  design  programs,  each  compound  is  completely
 characterized by a carbon adsorption capacity at influent concen-
 tration, a mass transfer coefficient and a partition coefficient. All
 parameters are specific to the temperature of interest. The waste
 stream flow rate is the only other parameter needed to specify a
 design.
   The program is used to calculate the number of GAC contactors
 necessary to maintain a minimum contact time of 40 min. and max-
 imum hydraulic loading, the column  diameter and  the  packed
 length  for air stripping.   The  ancillary equipment  and  costs
 associated with each design configuration have been previously
 discussed.
 EXAMPLES OF  PREDICTIVE  MODEL
   The example compounds (Table 4) chosen for this paper had par-
 tition coefficients  of 0.015 to 0.117 and Freundlich adsorption
 parameters ranging from 2.6 to 132  for K  (adsorbate/g carbon).
   In general, compounds that are easily removed by air stripping
 are not easily removed by carbon adsorption.  The effects of this in-
 verse relationship on  the  economics of  removal are shown in
 Figures 2 and 3. As more contaminant is removed from the water at
 a given flow  rate, the capitalcost of the stripper increases  more
                 PLOW HATE - IM •»•
                 INFLUENT COMCCNTIUTKW • 14M <**
                                            TOTAL FIMT-TEAP. COtT HAPTHALEMEJ
                                            CAPTTAL COtT P4APTHAUNQ
                                            TOTAL PHUT-TEAM COtT' (CHLOnOTOP.MI
                                            CAPITAL COST ICMLOftoFOHU)
                                        	OPEMATWM COtT (NAPTHALENQ
                                            OPCMTMO COtT tCHLOWOFOMHI
               AIR STRIPPER EFFLUENT CONCENTRATION (ugfl)

                            Figure 2
         Capital and Operating Costs for Air Stripper Systems
rapidly than the stripper operating cost. The operating cost of a
carbon system, however, increases  as  more contaminant is  re-
moved, and the least cost remains fixed. For compounds (such as
naphthalene) that are more efficiently removed by GAC, the GAC
operating costs are also relatively constant when compared to total
cost.
=>
£
            FLOW KATI - 100 «pn
            EFFLUENT CONCENTRATION • 0.1 upA
                                                  TOTAL FIRST-YEAR COST
                                                  (CHLOROFORM)
                                                  OPERATING COST
                                                  (NAPTHALEHQ
                1-i         W.t        10M        1.000.0

               CARBON CONTACTOR INFLUENT CONCENTRATION (ug/l)



                            Figure 3
           Capital and Operating Costs for Carbon Systems

                   AIR STRIPPER EFFLUENT CONCENTRATION (ugfl)
                 CARBON CONTACTOR INFLUENT CONCENTRATION (ug/l)

                            Figure 4
    Air Stripper and Carbon System Costs for Chloroform Removal

   Comparisons of air stripping and GAC technologies for the ex-
ample compounds are presented in Figures  4 through 6. For
chloroform, the compound with the highest partition coefficient
considered in this paper, it is always less expensive to use air strip-
ping than to use GAC  (Figure 4).
   For bromoform, a compound with a higher carbon adsorbability
but lower partition coefficient than chloroform, it is almost always
as economical to use  air stripping as it is to use GAC at a flow rate
of 100 gal/min. But at greater flow rates, the cost of leasing more
GAC contactors to maintain sufficient contact time increases more
rapidly than the cost of using a larger stripper column. Stripping
again  becomes the more economical choice.
                                                                                        GROUNDWATER TREATMENT
                                                             251
-------
                  AIR STRIPPER EFFLUENT CONCENTRATION (ufl/t)
               CARBON CONTACTOR INFLUENT CONCENTRATION lugfl)
                            Figure 5
    Air Stripper and Carbon System Costs for Bromoform Removal
                                                    ••»• Cf
                                                   ' KAMON
                 AIR STRIPPER EFFLUENT CONCENTRATION (l>0/T)
               CARBON CONTACTOR INFLUENT CONCENTRATION (ue/l)
                            Figure 6
    Air Stripper and Carbon System Costs for Naphthalene Removal
  For naphthalene, GAC is more economical at higher flow rates
than it is for bromoform, but stripping is still more economical at
flow rates above 300 gal/min.
  In general, for compounds with partition coefficients lower than
naphthalene,  it  becomes impractical  to use  air  stripping.  The
necessary air-to-water ratio becomes so high that very large column
diameters are necessary, and hydraulic loading becomes so low that
adequate wetting of packing material may not occur. Carbon ad-
sorption is economical only for removing compounds for which air
stripping is impractical.
                                                                     SUMMARY
                                                                       The design and cost estimating methods used in this paper allow
                                                                     two processes to be compared by specifying the waste stream flow
                                                                     rate and three parameters for each compound: partition coeffi-
                                                                     cient, mass transfer coefficient and carbon adsorption capacity.
                                                                     For single-component waste streams, the most economical choice is
                                                                     usually  clear; for  waste streams  with several contaminants for

                                                                                                  Table 4
                                                                                Physical Properties of Compounds Investigated



Compound

Chloroform
Bromoform
Naphthalene


Molecular
Weight

119.4
252.8
128.2


Partition
Coeffic.*

0.117
0.026
0.015
Miss Transfer
Coefficient
(KL)t
(l/f|2-mln)

0.55
0.44
0.54


Freundllch
Parameters**
K" I/a
2.6 0.73
19.6 0.52
132 0.42
                                                           • Ratio of concentration in air to concentration in water at 20°C. Calculated from EPA (1979)'
                                                            solubility data.
                                                           t Based on experimental data for chloroform at NRe = 100; based on ratio of molecular weights
                                                            to 0.3 power for other compounds. From ESE (1981)' and Treybal (1968).'
                                                           ••From Dobbs and Cohen (197_).'
                                                           tt Adsorptive capacity (mg/g carbon) at residual concentration of 1.0 mg/l.
                                                           which there are varying response objectives, several alternatives, in-
                                                           cluding combined technologies, may be evaluated quickly and on
                                                           an equivalent basis to determine the most effective system or the
                                                           most likely  candidates for  pilot  study.  In none  of the cases
                                                           evaluated for this paper were the economics of a combined system
                                                           more favorable than a system using only one of the technologies.


                                                           REFERENCES

                                                           1.  McCarty, P.L., Sutherland,  K.H., Graydon,  J. and Reinhard, M.,
                                                              "Volatile Organic  Contaminants Removal by Air  Stripping." Pre-
                                                              sented at: Seminar on Controlling Organics in Drinking Water. 99th
                                                              Annual National AWWA Conference, San Francisco, CA, 1979.
                                                           2.  Love, O.T. and Eilers, R.G.,  "Treatment for the Control of Trichloro-
                                                              ethylene and Related Industrial Solvents in Drinking Water." USEPA,
                                                              Drinking Water Research  Division, Cincinnati, OH, 1981.
                                                           3.  Treyval, R.A.,  Mass Transfer Operations, McGraw Hill, New York,
                                                              1968.
                                                           4.  Kavanaugh, M.C. and Trussell, R.R., "Design of Aeration Towers to
                                                              Strip Volatile Contaminants from  Drinking Water,"  JAWWA,  72,
                                                              1980, 684-69 2.
                                                           5.  Singley, J.E. and Bilello,  L.J., "Advances in the Development of De-
                                                              sign Criteria for Packed Column Aeration." Submitted to JAWWA,
                                                              1981.
                                                           6.  Beaudet, B.A.,  Bilello, L.J., Kellar, E.M. and  Allan, H.J., "Removal
                                                              of Specific Organics from Wastewaters by Activated Carbon Adsorp-
                                                              tion: Evaluation of a  Rapid Method for Determining  Carbon Usage
                                                              Rates."  35th Industrial Waste  Conference, Purdue University, La-
                                                              fayette, Ind., 1980, 381-391.
                                                           7.  Dobbs, R.A. and Cohen, J.M.,  "Carbon Adsorption Isotherms  for
                                                              Toxic  Organics," EPA 600/8-80-023. USEPA,  Office of  Research
                                                              and Development, MERL, Wastewater Research Division, Cincinnati,
                                                              OH, 1980.
252
GROUNDWATER TREATMENT
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                 REMOVAL OF  POLYNUCLEAR  AROMATIC
 HYDROCARBONS  FROM  CONTAMINATED  GROUNDWATER

                                             MICHAEL R. HARRIS
                                                 CH2M Hill, Inc.
                                          Industrial Processes Division
                                              Milwaukee, Wisconsin
                                             MICHAEL J.  HANSEL
                                      Minnesota Pollution  Control Agency
                                    Division of  Solid and Hazardous Waste
                                               Roseville, Minnesota
BACKGROUND

  Reilly Tar and Chemical Corporation operated a coal tar distilla-
tion and wood preserving plant in St. Louis Park, Minnesota, be-
tween 1918 and 1972. Reilly disposed of wastes from the operation
consisting of a mixture of many compounds, including a class of
organic compounds known as Polynuclear  Aromatic Hydrocar-
bons (PAH),  some of which  are carcinogenic, in a network of
ditches that discharged to an adjacent wetland.
  In 1932, the first St. Louis Park village well was constructed. The
well was shut down after several weeks of operation because of
complaints about odors attributed to  phenol.
  Throughout the 1960's and early 1970's, the Minnesota Depart-
ment of Health (MDH) and St. Louis Park monitored municipal,
commercial and industrial wells for phenol. In the mid 1970's, the
MDH and Minnesota Pollution Control Agency (MPCA) became
concerned about PAH  compounds which are found in coal tar.
  In 1975, MPCA conducted a study to assess the extent and
magnitude of the contamination. The  study concluded that the soil
and shallow unconsolidated sandy aquifers near the old Reilly site
were seriously contaminated and were acting as a source of con-
taminants to deeper bedrock aquifers.
  In May 1978, the MDH began  analyses using High Performance
Liquid Chromatography. An investigation in St. Louis Park iden-
tified PAHs present in several municipal wells. These wells, located
approximately 1/4 to 1/2 mile north of the site, were subsequently
closed down  in 1978.  Other well closures occurred  in 1979 and
1981. The well closures in St. Louis Park accounted for over 35%
of the city's water supply capacity.
  In the fall of 1978, the USGS conducted a study of private wells
in the area and, in particular, the  Reilly deep well (W23) which was
used as a source  of cooling water for the plant. The USGS in-
vestigation revealed a down-hole  flow  of contaminated water from
shallow aquifers to the Prairie du Chein-Jordan aquifer. This flow,
estimated to be greater than 150 gpm, was stopped in 1978. In 1982,
the MPCA cleaned out the well and removed over 150 ft of coal tar-
like wastes and debris. W23 is  now regarded as a major source of
contamination of the Prairie du Chein-Jordan aquifer.
  All of the closed municipal wells draw from a water-bearing rock
layer, known as the Prairie  du  Chein-Jordan aquifer, between 250
and 510 ft below  the land surface.  Approximately  80"%  of the
groundwater utilized in the  Twin Cities is from this aquifer.
  The Reilly site has been designated  as the  State of Minnesota's
highest priority Superfund site.
CURRENT STUDY

  In August 1982, MPCA contracted with CH2M Hill to complete
an evaluation of groundwater treatment and  potable water supply
alternatives  for the City of St. Louis Park. During this study,
CH2M Hill  conducted bench-scale tests using a number of water
treatment technologies. These tests were designed to determine the
efficiency of various technologies in removing PAHs and other coal
tar  derivatives  from groundwater.  Pilot-scale  tests  on  one
technology  were also conducted.  The ultimate purpose of this
testing program was to determine whether contaminated ground-
water  could  be cost effectively treated for discharge into St. Louis
Park's potable water distribution system.
Analytical Procedures
  During preparation for this study, CH2M Hill considered the use
of several analytical techniques for measuring compounds in the in-
fluent and effluent from the bench- and pilot-scale test units. Based
on historical analyses and project goals, it was expected that raw
water  would contain several thousand nanograms/liter (ng/1) of
PAH  and other  compounds  and that "treated effluents" could
contain total concentrations as low as 10 to 100 ng/1 for the selected
target  compounds.

  In consultation with MPCA and EPA, it was agreed that target
compounds  would include:
•20 polynuclear aromatic hydrocarbons (7 carcinogens, 13 "other"
 PAH compounds)
•5 nitrogen  heterocycles
•2 sulfur heterocycles
•1 oxygen heterocycle
•3 aromatic amines
•3 miscellaneous compounds (indene, biphenyl and 2,3-dihydro-
 indene)

  Historically, analyses of groundwater at the site had primarily
used HPLC  techniques and Selective Ion Monitoring techniques us-
ing  GC/MS. Both of these techniques achieve low  nanogram/liter
detection limits,  but results  are limited to  specific target com-
pounds.
  The GC/MS method developed by CH2M  Hill for the St. Louis
Park project is a modification of USEPA Method 625. The method
detection limits for the PAH compounds are 1000 to 3000 times
lower  than those published for Method 625. The method has been
validated and detection limits determined in  accordance with pro-
cedures published by USEPA in the December 1981 issue of En-
vironmental Science and Technology.

  The method deviates from Method 625 in the following ways:
•a 21 sample is extracted
•The final volume of the extract is 20 jtl as  compared to 1 ml  in
 Method 625
                                                                              GROUNDWATER TREATMENT
                                                                                                                  253
-------
•The electron multiplier of the mass spectrometer is adjusted to
 provide 8 to 10 times more sensitivity than normally required for
 Method 625
•The method utilizes a high resolution narrow bore fused silica
 capillary column for better resolution and sensitivity
•A mixture of five internal standards are mixed with the 1 ml ex-
 tract of the sample just prior to further concentration of the ex-
 tract to 20 ii\
  The  USEPA  Method  610 HPLC technique has been conven-
tionally applied to water samples requiring  trace PAH analyses.
The trace GC/MS method used for this studylias the following ad-
vantages over Method 610:
•The average method detection limit for all of the PAH parameters
 is approximately 400 times lower than the average detection limit
 of the parameters published for  Method 610.
•The GC/MS detection limits are more or less uniform (1 to 2 ng/1)
 whereas the detection limits published for  Method 610 vary for
 different  compounds by more than 2 orders of magnitude.
•The method is  validated for both the PAH parameters and a vari-
 ety of nitrogen, oxygen and sulfur heterocycles.
•The mass spectrometer provides more compound specificity than
 ultraviolet  or  fluorescence detection prescribed by  the PHLC
 procedure.  Chromotographic resolution  is  not- required for  de-
 tection and quantification.
•The method provides the  capability of additional characteriza-
 tion  of samples by tentative identification of non-target com-
 pounds that appear in the chromatogram.
•The method specifies spiking of surrogates  into each sample  an-
 alyzed. The surrogate data can be used to judge the validity of the
 sample processing steps for each analysis.
•All raw GC/MS data is stored on magnetic tape for future recall
 in case further data processing is required at some later date.

Selection of Technologies for Bench-Scale Test Work
  CH2M  Hill conducted a search of technical literature for infor-
mation to assess technologies which are applicable for the removal
of PAH and other coal tar derivative compounds from ground-
water. The search was conducted through both in-house technical
libraries and two computerized data bases.  The search produced
about  280 sources, but only about  40 sources  (see bibliography)
were directly relevant to the situation at St.  Louis Park.
  Information collected  in the literature search was used to assess
the potential applicability of a wide variety of technologies and to
select those to be tested in bench-scale tests.  Technologies selected
were:
•Adsorption Technologies
 -granular activated carbon
 -macroreticular resins
•Oxidation Technologies
 -ozone/ultraviolet (O3/UV)
 -hydrogen peroxide/ultraviolet (H2O2/UV)

 -"A
 -chlorine  (C12)
 -chlorine  dioxide (C1O2)
 -chlorine  in combination with aeration, flocculation and filtration
BENCH-SCALE TESTING RESULTS

  Water samples  were obtained from one  of the contaminated
municipal wells in St. Louis Park and shipped to CH2M Hill's
laboratory for bench-scale testing.
  A 2-round bench testing program was designed. The first round
of testing was conducted under very conservative test conditions
(high  dosages, long retention  times, etc.) and was  designed to
quickly  determine which technologies could achieve compliance
with treatment "goals" established by the Minnesota Department
of Health:
                                                                                      MDH Treatment
                                                       PAH Category                   Goal
                                                       Carcinogenic PAHs, total           28 ng/1
                                                       All other PAHs, total             280 ng/1
                                                         The goal for carcinogenic PAHs is based on USEPA criteria.
                                                       The goal for "other" PAHs is based on concerns about synergistic
                                                       effects, and concerns that not all compounds have been tested for
                                                       carcinogenicity.
                                                         Round two  testing was conducted only on technologies which
                                                       met the treatment goals in the first round tests and was designed to
                                                       identify required dosages, loading  rates and  retention times in
                                                       greater detail.


                                                       Granular Activated Carbon (GAC)
                                                         During round  one testing,  adsorption isotherms were  developed
                                                       for five granular activated carbons:
                                                       •Westvaco Nuchar WV-G
                                                       •ICI HD 40 W
                                                       •Calgon Filtrasorb 300
                                                       •Ceca Groundwater
                                                       •Witco Witcarb
                                                         Three dosages were investigated for each adsorbent: 1 mg/1,  10
                                                       mg/1 and 25 mg/1. A blank was also run to evaluate the effect of the
                                                       test apparatus  on water quality. The isotherm procedure consisted
                                                       of pulverizing  and selectively screening the carbon (Nos. 200 and
                                                       400 sieves), measuring the desired dose into  21 of sample (pH  =
                                                       7.0), contacting the adsorbent and water for 2 hr at SOT, filtering
                                                       and analyzing for PAH and other target compounds. Filtration was
                                                       done using millipore all glass filter apparatus and Selas silver metal
                                                       membranes (0.45 /*). The apparatus is  shown in Figure 1.
                                                         Raw water and effluent data from the isotherm tests are shown in
                                                       Table 1.
                                                         Isotherm data for the  GACs was plotted using the Freundlich
                                                       equation:
                                                         log X/M = log kf + J_log c                               (1)
                                                                            n
                                                       where:
                                                         X/M =  weight of adsorbed PAHs
                                                                     weight of  carbon
                                                         kf and n are constants
                                                         C  = residual total PAH concentration
                                                         Adsorption  isotherms  for the five tested  carbons  for  total
                                                       residual PAH  concentrations (not corrected for blank results) are
                                                       shown in Figure 2. Although the performance  of all five carbons
                                                       was similar, the  Calgon and Westvaco carbons appeared to have
                                                       slightly higher  adsorptive capacity.
                                                         Bench-scale column tests (Figure 3) were conducted during round
                                                       two testing. Based on the results of the isotherm tests, only the
                                                       Calgon and Westvaco carbons  were tested in round two.
                                                         The objective  of round two testing was to evaluate carbon per-
                                                       formance after 100 bed volumes (BV) of water were passed through
                                                       the column at a loading  rate of 4 gpm/ft2. Because of time con-
                                                       straints, cost of sample shipment, analytical cost and long com-
                                                       puted breakthrough times, no attempt was made to run the bench-
                                                       scale columns to breakthrough  or exhaustion.
                                                         Analytical data from the column tests are shown in Table 2. Due
                                                       to sample volume availability, the Calgon run was terminated after
                                                       70 BV of water were passed through the column. Both carbons
                                                       achieved high removals of PAH and other compounds. Because of
                                                       the limited run-time,  no attempt was made to  plot column
                                                       breakthrough curves.

                                                       Macroreticular Resin Adsorption

                                                          During round one testing, isotherm testing (same procedures as
                                                       GAC) was conducted with three macroreticular resins:
254
GROUNDWATER TREATMENT
-------
 JO


 §
                                                                                                            Table 1

                                                                                                   Carbon Isotherm Results

                                                                                   (Note: No value is shown for compounds found at less than detection limit)
 o
 ?o
 O
 c

 o

 $
PARAMETER
(ALL VALUES IN ng/1)
PAH ('INDICATES CARCINOGENIC PAH)
NAPHTHALENE
1 -METHYIMAPHTHALEHE
2-METHYUUPHTHALENE
ACENAPHTHYLENE
ACENAPHTHENE
FLOOREHE
ANTHRACENE
PHENANTHRENE
PYRENE
FLUORANTHENE
Raw
Hat«r

37
103
23
1200
1900
1900
170
66
440
560
Isotbera
Blank

120
120
71
1200
1900
1900
150
61
380
490
Calqcii

48
110
60
790
1400
1000
56
35
140
190
Calgon Calgon
10 Mj/1 35 Mj/1

IS 13
13 5.4
19 10
21 .3
46 .5
17 .5
0.49
1.6 .0
1.0 .0
1.6 .0
Nucnai
1 MJ/1

44
76
29
960
1700
1300
88
37
150
190
Nuchar Nuchar
10 Mj/1 25 Mj/1

9.0 .8
5.6 .3
7.1 .6
24 .8
52 .0
30 .3
0.48 0.48
1.5 .0
1.5 .0
3.6 .0
IC1

39
130
55
970
1700
1300
80
36
190
250
IC1 ICI tBL*
10 M]/l 25 M/ 1/Mi/l

11 . «*
8.4 . «
8.9 . 33
4B . 1000
110 . 1800
33 . 1600
0.93 0 9 1 110
l.S . 48
2.0 . 200
3.5 . 370
10 Ml/1

14
16
10
137
366
150
4.3
3.0
7.9
11
35 Mj/1 1 Mj/1

9. 37
4. 84
7. 27
6. 1000
1 1600
12 16OO
0.49 130
2.6 53
1.6 340
3.6 430
10 Mi/1 25 Mi/1

17 8.9
36 4.8
13 8.7
240 19
440 37
250 16
9.0 1.0
5.6 3.0
38 3.0
36 2.0
PHENYIJUPHTHALENE
1 , 2 , 6 , 7-TETRAWDROPYRENE
BENZO ( a) ANTHRACENE*
9 , 1 0- BENZPHENAHTHHENE
CHHYSENE*
BDtZO fb*JO FLUORANTHENE*
BENZO(a)PYREHE*
tEHZO(e)PYRENE
BEHZO(;))FLDORAWTHBiE«
PERYLENE
RENZOIg,h,l)PERYLDtE
I»EK)(1,2,3-«1)PYRO4E"
0-PHEMY LEMEPYRENE
DIBEKZO (a , h) ANTHRACENE*
TOTAL CARCINOGENIC PAH'S
TUTAL "OTHKK" PAH'S
NITROGEN HETOBXYCLES
ACRIDINE
CAFBAIOLE
IHTOLE
PHEKAKTHRIDINE
OUIHOLINE
SULFUR HETEROCYCLES
BENZO (b)THIOPHEHE
DIBENZOTHIOPHENE
OXYGEN HETEROCYCLES
DIBEHZOFURAN
MISCELLANEOUS
BIPHEHYL
2,3-DIHYDROINDEHE
INDENE
AROMATIC MINES
ANILINE
1-AMIHOHAPHTHALENE
3-AHIHOBIPHENVL


12 6.5 — -- ~ 5.6 ~ — — " 1.7 6.9 — — 8.4 3.5

9.2 4.8 — — -- 3.5 ____ — -- a.o 5.1 — — 6.5 2.4 —









31.3 11.3 — — — 9.1 — — — -- 3.7 13.0 — — 14.9 4.» —
6400 6392 3819 135.7 42.7 4574 123.8 45. 3 494O 326.2 41.5 5367 619.1 61.3 5300 1063.6 101.4

19 8.4 — — 11 — — 7.7 — — 18 0.65 — 12 3.3
14 9.7 7.4 ~ — 4.8 0.58 — 6.6 — 1.6 9.0 0.57 — 10 3.0




490 460 360 30 3.6 370 23 4.6 380 32 3.8 410 1OO 14 420 ISO 22


1300 12OO 740 14 2.8 900 13 3.4 880 17 3.4 1000 77 4.2 1000 ISO 13

610 370 35O 10 2.9 400 9.3 3.5 390 10 2.2 4SO 5* S.4 SO2 95 9.3
1500 1200 1300 100 51 1300 130 26 1300 260 26 1400 430 8.2 110O 480 110
100 91 79 11 3.1 81 8.3 3.3 77 11 1.6 «0 24 5.1 71 » 6.4




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                                                   TAP HirfTEP TO WdTFJ?
                                                 DOnftt* MAGNETIC
                                      A-TEFU>M STIR EkAffS
                           Figure 1
                 Apparatus for Isotherm Testing
•Rohm and Haas XAD-2
•Rohm and Haas XAD-4
•Dow XFS-4022
  Analytical data from the resin isotherm tests are shown in Table
3. Since the resins achieved little or no PAH removal, no isotherm
plots were developed and no round two testing was conducted.

Chemical Oxidation Testing
  All oxidation tests were conducted in a stainless  steel  reactor
vessel. The unit was 3 in. diameter by a 3 ft length. The vessel was
jacketed with copper tubing for temperature control and housed in
an insulated container. The  reactor was equipped with a quartz
tube into which an ultraviolet light source could be placed.  The
reactor was also equipped with a fritted glass diffuser through
which  air or ozone could be  injected. A sketch  of the reactor is
shown in Figure 4.
  All  oxidation  "effluents" were  extracted immediately upon
withdrawal from the reactor vessel. All samples requiring filtration
                                                                                                             COtUMN
                                                                                                            CM
                                                                       MOTE- ALL TUBIM3 IS VO.DL
                                                                         6TAMLESS Srffl EXCEPT
                                                                                      AIPC31.UMWS FOB
                                                                                      6UBGE SUPPRESSES
\cra\c Mixep
j STA/WLESS sreei.^
FT/1WD POOf \
/
/
/
/
/
/
/
/
/
/
<
£



?
s



                                                                                                                TO--
                                                                                                               DBAIW
                                                                   55 G^L. TEFLOW
                                                                    UWEO DBUt/l
FMI
PUMP
                                                                                    Figure 3
                                                                      Bench-Scale Carbon Column Apparatus
                      I	1   I t i I 7 » » I	1   1  i  i » T III	1   lit
                0 1000
                   100
                                       10
                                                         100

                                                     RESIDUAL TOTAL PAH
                                                                  1000              10000

                                                             CONCENTRATION, Nq/1
                                                             Figure 2
                                                  Total PAH Isotherm—All Carbons
 256
GROUND\VAT£R TREATMENT
-------
                         Table 2
         Carbon Adsorption Column Test Results
 (Note: No value Is shown for compounds found at less than detection limit)
PARAMETER Km
(ALL VALUES IN ng/1) Hater
>rui 1
PAH (• INDICATES CAKCINOGENI
NAPHTHALENE 3]
Row
Hater
Drua 2

70
Raw
Hater
Dru» 3

38
Calgon
35BV
MID

6.4
Calgon
35BV
BOTTOM

9.7
Calgon
70BV
HID

11
Nuchar
3SBV
HID

12.0
Nuchar
3SBV
BOTTOM

13
Nuchar
70BV
HID

12
Nuchar
70BV
BOTTOM

11
Nuchar
85BV
BOTTOM

11
Kucha r
85BV
BOTTOM

13
Ngchar
100BV
HID

13
100BV
BOTTOM

14
1-METHYLNAPHTHALENt
2-HETHYLNAPHTHALENE
ACENAPIrTHYLENE
ACENAnnHENE
FLUORENE
ANTHRACENE
PHENANTHRENE
PVRENE
FLUORANTHENE
110
14
1200
2000
2100
160
77
400
520
120
41
1200
2100
2100
170
85
450
580
120
19
1200
2000
2600
170
81
370
490
2.3
5. 5



1.4

1.0
1.9
S.S
1.5
.1
.2

.9
.0
.0
4.0
7.1
7.8
16
13

1.6
2.7
3.3

1.4

1.5 1.4 1.1

1.3 1.3 2.6 2.5 1.2 3.0
2.3 1.2
2.4 1.5 1.4
3.2 2.7
6.8 6.0



1.6


FHENyLNAPHTHALEHE
1 , 2 ,6 , 7-TETRAHYDROPIREHE
BENZOIalAHTKRACENE* 11
9 , lO-BENZPHENANTHRENE
CHXVSENE* 11
BENZO (btk) FLUORANTHENE*
BENZOIalPYRENE*
BENZO (c)PYRENE
BQIZO 1] ) FLUORANTHENE*
PERILENE
BENZOIg,h,l)PER¥UME
INDENO(l,2,3-cd)PyRENE*
0-PHENYLENEPYRENI
DIBENZOIa.hlANTHRACENE*
TOTAL CARCINOGENIC PAH'S 22
TOTAL "OTHER" PAH'S 6613
NITROGEN HETEROCYCLES
ACRID1NE 17
CARBAZOLE 14
INDOLE
PHENANTHRIDINE
ODINOLINE 11
SULFUR HETEROCYCLES
BEMZOIblTHIOPIIEME 480
DIBEHZOTHIOPHENE
OXYGEN IIETEROCVCLES
DIBENZOFURAN 1300
MISCELLANEOUS
BIPHENYL 590
2,3-DlHTDROINDEHE 1700
INDENE 100
AROMATIC AMINES
ANILINE
1-AMIHONAPHTHALENE
2-AKINOBIPHENYL


39 8.7

28 7.7









57 16.4
6916 7088 16.6 32.8 66.5 29.4 28.J 27.3 26.1 25.2 28.1 24.6 22.7

19 11
17 11


13 11 1.3 1.5 1.0

480 500 1.1 3.3 4.4 1.1 1.0 1.0 1.0


1400 1200 2.1 7.2


1400 1900 4.8 14 23 3.3 2.7 3.1 3.4 4.4 4.6 4.2 3.3
91 99 1.7 3.4 3.8 2.9 2.2 1.8 2.3 3.2 3.5 2.8 2.7




           VE-WT PIPE
  COOUUQ KMTEP
    CUTLET

FEED PIPE fWOTOSEO
KB Jv&TCW CPEBATIOU)
                                         MATEO JACKET
                                         fEWBE LEW<5TM)
                              PIFFUSEC'
                         Figure 4
                 Oxidation Reactor Vessel
                                                   GROUNDWATER TREATMENT
257
-------
                                                                     Table 3
                                                             Carbon Isotherm Results
                                              (Note: No raise Is shown for compounds fonnd at less than detection limit)
Rav
PARAMETER "at«r
PAH 1'IMDlCATfS CARCUCGEtn 	
HAPBTBM-PT 37

2-HETKTLHAPHTrlALEHt 25
ACENAPtfTHrLPIE 	 1200 	
ACtHAPHTHEHE 	 1900
(Tuonan: 	 190Q
ANTHmCEHE 170
mowmaam 6*

rtOORAHTHDIE 560
nirimjunmui.BlE

BEHZOIalANTHDACENE* 12
? , 10-BBIZPHDMrrHREflE
CHRYSENE* 9.2
BENZO U>lk) rUX)RANTHENE»
BENZOIalPYRENE*
BENZO ItOPlRENE

Dm
170
130
120
1400
2400
170
71
500
650


7.6

7.0




Dow Dow
10 aq/1 25 «g/l
160 170
120 120
120 110
2100 2100
150 160
59 65
470 480
600 620


5.7 8.1

7.0 7.5




XAD-2 XAD-2
1 M/l 10 -J/l
180 ISO
140 130
140 130
2000 1900
160 160
67 64
390 380
500 490


6.0 5.9

5.9 5.8




XAD-2
25 ../I
190
140
130
	 HOP
1700
160
64
380
500




7.8




XAD-4 XAD-4
1 M/l 10 M/l
190 	 180
140 130
140 130
	 UfiS 	 1MB 	
1900 1800
160 140
65 58
390 J90
510 380


7.5 11

5.5 5.4




XAD-4
25 ml
ISO
IIP
110
1900
HP
58

sop


6.»

6.3




PERTLIXE
BENZOta ,h . 1 ) PERYUME
lNDENO 30 uln 7

75 0V npocur* far full ruction tt
75 DV «xponm for full mctlon tl
75 trv •Bpomra for full ronctlan tl
75 0V nroosaim tor ful motion til
50 350 ol/Bln nlr flov
50 350 Bl/Bln Mrntlaa prior to Cl,
50 350 ol/oln oirntlon prior to Cl,
M/l FOCI,
75
50 350 ul/oln otrntlon prior to Cl(
75
50
•0
m
m
rooctlon
, ftaM 10
rooctloB


                                                               Ira* round tvu ««lld*u«i unttlut.
258
GROUNDWATER TREATMENT
-------
                              Table 5
                 Round One Oxidation Test Results
       (Note: No value Is shown for compounds found at less than detection limit)
PARAMETER Raw
(ALL VALUES IN ng/1) Hater
Druai 1
3519-A
PAH (•INDICATES CARCINOGEN:
NAPHTHAkBiE 37
l-HETHYUUPHTHALENE 102
2-NETHYLNAPHTHAUKE 25
ACENAPirniYLENE 1200
ACENAPHTHDffi 1900
FLUORQ1E 1900
ANTHRACENE 170
PHENAMTHRBIE 66
PYHQTE «4fl
FUlnMNTHDie 560
PHDIYLNAPHTHALBIE
Ran
Hater
DruB 2
M-lll

180
HO
150
1200
2000
2100
160
68
450
590

HjOj/UV H,0,/UV
N-121 N-126.

8.0 18
4.4 6.0
5.2 1.4
4.8 1.6
4.9 3.7
21 2.1

1.9 1.0
4.1 1.1
11 1.6

Aer/Cl,
Aer. Aer, Cl, /Hoc. Aeration/
0,/uv 0,/uv rut. rut. mu. ci., ci,-i cio,
M-141 N-142 M-117 M-128 M-166 M-119 M-130 M-107

6.1 4.9 140 67 49 63 71 54
1.9 1.8 110 8.7 29 7.3 14 90
3.7 4.2 110 7.7 14 2.9 5.8 53
1160 810
1000 1700
1900 1700 1700 1800 18OO 1900
150 5.4
1.0 63 23 48 16 10 61
1.1 170 180
1.1 470 160 190 150 210 560

CIO,
N-114

70
100
53
1100
1000
1100

65
380
570

1.2.6. 7-TETRAlttDROPYRENE
BEMZOIalANTHRACEKE* 12
9 . in-BENZPHENAHTHRENE
CHHYSENE* 9.1
BENZO (b£k ) FLUORAHTHDIE*
12

11





6.8

4.7 8.1

3.5

6.5

BENZO la IPYRENE*
BEMZOlelPYREKE
BFWZO t 11 FLUORANTHENE*
PERYLENE
BENZO (u ,h , 1 ) PERYLENE
INDENO (1 , 2 , 1-cd) PYRIHE*
0-PHDnLQ(EPYRENE
DIBENZO(a,MANTHRACENE«
TOTAL CARCINOGENIC PAH'S 21.2
TOTAL "OTHER" PAH'S 6400
NITROGEN HETEROCtCLES
ACRIDINE 19
rjiRMZoLe )4
INDOLE
23
7038

27
18

—
65.4 3B.S




. — ».e — — — — 8.1
15.1 10.9 6571 1966.4 1115.4 1019.2 1150.8 5509

20 20
13 5.7

10
6538

11


PHENAHTHRIDIHE
OUINOLINE
SlimiD IICTFR«!YCIJS
BEN20lblTHIOPHENE 490
DIBENZOTHIOPHENE
480

6.6 2.1

460 250 450

510

OXYGEN HETEROCYCLES
OIBEMZOFURAN 1300
1300
18 1.8
2.9 1300 1200 1100 1100 1100 1200
1400
MISCELLANEOUS
BIPHENYL 610
2.3-DIHYDROINDENE 1500
INDENE 100
AROMATIC AMINES
570
1300
100

7.4 1.8
20 9.3
1.2 7.7

1.0 560 500 430 540 510 520
1.6 1.9 950 760 690 1100 1000 1200
79 50

610
1500
81

ANILINE
1-ArlINONAPHTHAUHE
2-AHINOBIPHEHYL ,


M-156
H-159
H-160
N-157
H-158
H-168
M-147
H-152
H-153
H-148
H-149
n-154
Test Conditions
Dosage
Oxldant •0/1
0 /UV 6.0
Oj/tnr i.j
0,/UV 1.1
0, 5.6
05 5.3
03 1.2
H,0,/UV i
H,o,/irv 2
»,<>, !
H,0, 5
Table 6
for Round Two Chemical Oxidation Tests
Reactor
TlBe pH TeBp °F Comments
60 Bin 7.0 50 UV exposure for full reaction tlBe
60 Bin 7.0 40 UV exposure for full reaction tlae
20 Bin 7.0 40 UV exposure for full reaction tlBe
60 Bin 7.0 50 No UV
20 Bin 7.0 50 No UV
20 Bin 7.0 40 No UV
60 Bin 7.0 50 UV exposure for full reaction tlBe
60 Bin 7.0 40 UV exposure for full reaction tlBe
20 Bin 7.0 40 UV exposure for full reaction tlBe
60 Bin 7.0 50 No UV
20 Bin 7.0 50 No UV
20 Bin 7.0 40 No UV

This test was conducted In drum sample fro* round two validation testing.
                                                        GROUNDWATER TREATMENT
259
-------
                                                            Table 7
                                                  Round 2 Oxidation Test Results
                                        (Note: No value Is shown for compounds found it less thin detection limit)

PARAMETER
UU. VALUES 1H ng/ll
[
SAMP1.E NUMBER 	 	
PAH (•IMDICATfr ("ABTINOGEf
1-METHYLHAPHTHALENE 	 .
2-HETHYLNAPhTHALENE
ACEHAPHTHENE
FLUORENE
ANTHRACENE
PHENANTHRENE

FLUORANTHD4E

1 i2j6j7-TETRAMYDROPYRENE
BENZO (a ) ANTHRACENE*
9 . 10-BENZPHENANTHRENE
CHRYSENE*
BD4ZO (bfcX 1 FLUORANTHENE*
CENZOIolPYRENE*
BENZO lelPYRENE
BENZO 1 i ) FLUORANTHENE*
PERYL£NE
BENZOIel.h.DPERYLENE
INDENO(l,2,3-ccJ)PYRENE*
0-PHENYLENEPYRENE
DIBENZOU.h) ANTHRACENE*
TOTAL CARCINOGENIC PAH'S
TOTAL "OTHER" PAH'S
NITROGEN HETEROCYCLES
ACRIDINE
CARBAZOLE
IHrmi.F.
PHENANTHRIDINt
OUINOLINE
SULFUR HETEROCYCLES
BENZO ILITHIOPHENE
DIBENZOTIUOPHENE
OXYGEN HETEROCYCLES
DIBtNZOFURAN
MISCELLANEOUS
BIPHENYL
2.3-DIHYDROINDENE
INDENE
AROMATIC AMINES
ANILINE
1-AMINONAPHTHALENE
2-AMINOBIPHENYL

Raw
Hater
)run 1
M-144
32
no
14
1200
2000
2100
160
77
400
520


11

11









22
6613

17
14


11

480


1300

590
1700
100





FU.W
Hater
DniB 2
M-155
70
120
41
1200
2100
2100
170
85
450
580


29

28









57
6916

19
17


13

480


1400

600
1400
91




Ozone Ozone
Raw 5 Bg/1 1 Bg/1
Hater 60 Bin. 60 Bin.
Dm» 3 »/UV W/UV
M-163 H-156 M-159
38 4.3 7.4
120 2.4
1200 1.0
2000 2.2 1.7
2600 6.8 3.2
170
81 1.0
370 1.4 1.5
490 5.5 2.0


8.7

7.7









16.4
7088 20.9 24.1

11
11


11

500 26


1200 23 2.6

610 2.1 1.3
1900 9.6 4.1
99 5.9 2.6




Ozone Ozone Ozone Ozone
1 Bg/1 5 Bg/1 5 Bg/1 1 Bg/1
20 Bin. 60 Bin. 20 mln. 20 Bin.
w/UV w/o UV w/o UV w/o UV
M-160 M-157 N-158 H-168
7.8 12 4.4 7.3
2.9 3.0 1.2 1.2
1.0
2.2 1.1 1.7 2.8
34 430 740 990

1.4 1.0 1.4 0.93
2.0 1.0 1.5 1.5
5.5 1.0 4.5




1.1 1.9









1.1 1.9
60.6 454.4 753.2 1011.93


1.0


1.4

7.4 1.1


42 425 660 780

10 240 350 390
37 250 390 640
2.6 5.1 3.4 4.3




H2°2 H2°2 H2°2
5 Bg/1 2 Bg/1 2 Bg/1
60 Bin. 60 Bin. 20 Bin
w/UV w/UV w/UV
M-147 H-152 M-153
4.9 13
1.8 10
	 2-8 8.2 	
7.0 1.1 14
14 3.9 79
22 4.5 74
1.3
1.0 5.6
2.0 15
9.6 3.5 36














—
52.6 25.5 256.1





1.4

2.3 43


15 5.1 93

6.2 2.2 27
8.2 110
1.7 3.4




H2°2
5 Bg/1
60 Bin.
w/o UV
M-148
55
100
980
1800
1900
140
70
390
490


8.5

8.5









17
5945

9.1
11


8.1

470


1200

540
1400
87




H2°2
5 ag/1
20 Bin.
v/o UV
H-149
55
100
1100
1800
2300
159
78
370
4BO


9.1

7.0









16.1
6456

14
11


8.0

450


1200

550
1300
84




H2°2
Test B
2 Bg/1
20 Bin.
v/o UV
H-154
50
no
JO
940
1500
1900
140
76
330
. 450


9T0

7.3









16.3
5516

11
11


7.4

480


1100

580
1400
88




were passed through a 0.45 micron silver metal membrane prior to
extraction. When air was used for reagent preparation (i.e., C1O2)
or for aeration, compressed air was passed through activated car-
bon and a molecular sieve to ensure a "clean" air source.
Round One Oxidation Testing
  During round one testing,  special emphasis was placed on com-
binations  of  aeration, chlorination,  flocculation  and filtration.
These unit  operations  are employed in the iron removal treatment
plants at St.  Louis Park's municipal wells. Test conditions for
round one oxidation  tests are given  in Table 4  while analytical
results are shown in Table 5.
  Ozone/UV and Hydrogen  Peroxide/UV were the only two oxi-
dant systems tested which met the treatment goal of 280 ng/1 total
"other" PAHs. Significantly less oxidation was seen with chlorine,
chlorine dioxide  and the aeration/filtration/flocculation options.
This trend was expected  based on the standard oxidation potential
of the oxidants tested.

Round Two Oxidation Testing

  Based on the results of the first round tests, O3/UV and H2O2/
UV were selected for round two testing.
  Test conditions and analytical results are shown in Tables 6 and 7
respectively.
                                                       Ozone/UV

                                                         Ozone/UV achieved the treatment goals at all conditions tested.
                                                       Ozone by itself did not achieve comparable results.
                                                         Two GC/MS data files from the round two tests were chosen to
                                                       search for oxidation by-products.  The data file for bench-scale
                                                       sample M-158 was searched first to determine what by-products
                                                       resulted from ozone treatment only. A number of compounds were
                                                       detected whch had mass spectral properties expected for oxidized
                                                       PAH compounds. The mass spectra were searched through the Na-
                                                       tional Bureau of Standards Mass Spectral library for tentative iden-
                                                       tification.  All of the compounds could not be  identified, but  the
                                                       following list of compounds did give high computer calculated cor-
                                                       relations:
                                                       1. 2,3-Dihydro-lH-Indene-l-one
                                                       2. Fluorene-9-one
                                                       3. 5H-Phenanthridine-6-one
                                                       4. Dibenzothiophene-5-oxide (sulfoxide)
                                                       5. 9,10-Anthracenedione
                                                       6. 1,10-Phenanthrenedione
                                                         The data file for bench-scale sample M-159 was then searched for
                                                       these compounds plus any other that might be present from O /UV
                                                       oxidation. No oxidation by-products were detected in this file.
260
GROUNDWATER TREATMENT
-------
   FLOW TOTALIZED
                     Figure 5
       Schematic of GAC Pilot Testing Equipment
10.000. ,, _
                                ".^ j»Et,iw!r&1:fi!'£tw«*;tio>i':. "•.
                               :  : ) tpIALflM«eR"»XH*|- -']'.•:
                               I!iMJiIT]Ji|)tlJp|r
                               :-4:.:-l"  '  :.||q
                                   ..,,,. ,,r    :,,|!;i,
                                     • r-TRCMMf NT PQAf-; i T :-
                                     / (TOTAL >"OTHER*MH1I
                      12,000    11,000
                    VOL PAUED (OALLONI)
  The literature indicates that the oxidation of PAH compounds
produces a wide variety of carboxylic acid derivatives. The method
of analysis used in this study would not detect such compounds.
These compounds do not present significant public health concerns
at these levels.

H2O2/UV
  H2O2/UV met the stated treatment  goals at the higher dosages
and retention times tested, but failed to meet the treatment goal at
the lowest dosage and retention time tested. H2O2, by itself, failed
to meet the stated goal of 280 ng/1 for total "other" PAH.
PILOT-SCALE TESTING
  All of the tested technologies achieved compliance with the 28
ng/1 treatment goal for carcinogenic PAH. Based on the results of
the bench testing program, however, only three technologies were
shown to be effective in removing PAH compounds to below the
treatment goal of 280 ng/1 total "other" PAH compounds.  These
three technologies were:
•Granular Activated Carbon (GAC)
•Ozone/Ultraviolet
•Hydrogen Peroxide/Ultraviolet
  An analysis of these three technologies concluded that  GAC
would be the most cost-effective treatment  for the raw water PAH
concentrations (about 7,000 ng/1) anticipated at the municipal well
in St. Louis Park. Although no test work was completed on water
with very high PAH concentrations, it is possible that O3/UV could
prove to be more cost-effective at higher raw water PAH concen-
trations.
  To provide design criteria for a full-scale treatment system, a
GAC pilot plant was set up and operated in the pump station at one
of St. Louis Park's contaminated wells. Two GAC pilot trains were
operated parallel. Each train (Figure 5) consisted of four 4 in.
diameter by 4-ft high glass columns, operated in series. Each col-
umn contained approximately 3 ft of carbon. Calgon Filtrasorb 300
and Westvaco Nuchar WV-G were  used, respectively in  the two
pilot trains.
  Since the pilot train containing  Westvaco carbon experienced a
number of mechanical and operational problems during the pilot
study,  the data collected from this unit have been  excluded from
this paper.
  The train containing Calgon carbon  was operated for 42 days.
Average operational conditions are summarized as follows:
Paramater
Flow rate, gpm
Surface Loading Rate gpm/ft2
Contact time (empty bed basis), min
  Column 1
  Column 2
  Column 3
  Column 4
  Total
Temperature (average) °C
Conductivity, umhos/cm
Dissolved Oxygen, mg/1
PH
    Value
     0.44
     5.04

     4.69
     4.59
     4.43
     4.44
    18.15
       10
      412
       0
7.10-7.45
                     Figure 6
      Breakthrough Profile Calgon Column Train
   Influent effluent samples from each of the  four columns were
obtained at regular intervals throughout the pilot testing period and
analyzed for all target compounds. Analytical work from the pilot
testing program is given in Tables 8 to 12.
   A chronological plot of total PAH concentrations in pilot plant
influent and in the effluent from each of the four pilot columns is
shown in Figure 6. After passing through the  first column,  total
PAH concentrations were reduced to roughly 10 to 20 ng/1. Essen-
tially, no further removals occurred across the second,  third and
fourth columns.
                                                                               GROUNDWATER TREATMENT
                                                          261
-------
PAkAHETES

(ALL VALUES IS 1.9/11
ANALYSIS BY:
                                              2/28/83
                                                                  Table 8
                                                       Influent to Pilot Column Trains
                                                       2/26/83   3/12/83    3/12/83    3/20/83   3/20/83
                                                                                                    4/1/83
                                           " CH2H HILL	CH2M HILL CH2M HILL  CH2H HILL  CH2H HILL  CH2M HILL  CH2M HILL
DAY Or PILOT TEST
ANALYTICAL EQUIFHENT
                                                                                                     GCHS
PAN VINDICATES CARCINOGENIC PAH)
NAPHTHALENE
1-HETHYLNAPHTHALENE
36
ISO
35
170
31
160
29
160
30
110
30
110
32
120
32
130
34
150
   1 -HETHYLNAPHTHALENE
   ACENAPHTHYLENE
                           1300
   ACEHAPHTHENE
                                     1800
    PHENANTI IRENE
    FLUORANniENE
    FHENY LNA PIITHALENE
    1,2,6,7 -TCTRAHYDROPYREHE
    BENZO lal ANTHRACENE*
    9,10-BENZPHENANTHRENE
    CHRVSENE*
    BENZO(bik) FLUORANTHENE*
    BENZOlalPVRENE*
    BENZO(e)PYRENE
    BENZO(})FLUORANTHENE*
    PERYLENE
    BENZO(a,h,1)PERYLENE
    INDENO(l,2,3-cd)PYRENE*
    0-PHENYLENEPYRENE
    DIBENZO(a,M ANTHRACENE*
                                                                                    22.0
                                                                                            ~22T6~
    TOTAL CARCINOGENIC PAH'S
    TOTAL "OTHER" PAH'S
 NITROGEN HETEROCYCLES
                                                                                             15
    PHENANTHRIDINE
    OUINOLINE
 SULFUR HETEROCYCLES
    BENZO(b)THIOPHENE
                                                                                           "BOCT
                                                                                                    ~840~
    DIBENZOTHIOPHENE
 OXYGEN HETEROCYCLES
    DIBENZOFURAN
 MISCELLANEOUS
    BIPHENYL
                                                         720
    2,3-niHYDROINDENE
    INDENE
                                                                         "120"
                                                                                  ~TI6~
 AROMATIC AMINES
    1-AMINONAPHTHALENE
    l-AMINOBIPHENYL
Note:  No value Is shown for compounds found at less than the detection Halt.
   Although several additional compounds started appearing in ef-
 fluent from the first column toward the end of the testing period,
 there  was  no evidence  of PAH breakthrough after 42 days of
 operation.  Although increased run time would have been desirable
 to define carbon breakthrough and exhaustion characteristics, the
 pilot test was terminated after 42 days.
   Data collected in the pilot testing program were used to evaluate
 GAC  treatment of contaminated groundwater  versus  providing
 alternative  potable water supply alternatives for St. Louis  Park.
 Discussion  of the analysis of alternatives is beyond the scope of this
 paper.
SUMMARY

   As part  of a study  for  the MPCA, CH2M Hill developed a
GC/MS test protocol with an average method of detection limit of
1 to 2 ng/1  for a variety of PAH and other coal  tar derivative com-
pounds.
   Bench-scale and pilot-scale testing data are presented for a varie-
ty of water treatment technologies, illustrating the degree of treat-
ment achievable with each  technology. Influent and effluent con-
                                                            centrations are reported for 34 PAH and other coal tar derivative
                                                            compounds.
                                                              Three of the technologies tested (GAC, O/UV and H2O2/UV)
                                                            achieved compliance with project specific treatment goals and pro-
                                                            vided effluent water quality adequate  for use in a potable water
                                                            distribution system.

                                                            REFERENCES

                                                             1.  Fochtman,  E.G., "Biodegradation and Carbon Adsorption of Car-
                                                                cinogenic and Hazardous Organic Compounds," IIT Research Inst.,
                                                                Chicago,  IL. Available from  the National  Technical  Information
                                                                Service, Springfield,  VA 22161 as PB81-171852.
                                                             2.  Shuckrow,  A.J.,  Pajak,  A.P. and Osheka,  J.W.,  "Concentration
                                                                Technologies  for Hazardous Aqueous Waste Treatment," Touhill,
                                                                Shuckrow and Associates, Inc., Pittsburgh, PA.  Available  from the
                                                                National Technical  Information  Service, Springfield, VA  22161 as
                                                                PBS 1-150583.
                                                             3.  Snoeyink, V.L., McCreary, J.J. and Murin, C.H., "Activated Carbon
                                                                Adsorption of Trace Organic Compounds," Illinois Univ. at Urbana-
                                                                Champaign. Dept. of Civil and Ceramic Engineering. Available from
                                                                the National Technical Information Service, Springfield VA 22161 as
                                                                PB-279253.
 262
GROUNDWATER TREATMENT
-------
                                                                 Table 9
                                                     Effluent from Calgon Column tt\
PARAMETER
(ALL VALUES IN ng/1)
DATE:
ANALYSIS BY:
DATE OF COLLECTION
2/20/83 2/24/83 2/28/83 3/4/83 3/8/83 3/12/83 3/16/83 3/20/83 3/26/83 4/1/83
CH2M HILL CH2M HILL CH2M HILL CH2H HILL CH2M HILL CH2M HILL CH2M HILL CH2M HILL CH2M HILL CH2M HILL

DAY OF PILOT TEST:
ANALYTICAL EQUIPMENT
PAH ('INDICATES CARCINOGENIC PAH)
NAPHTHALENE
1-METHYLNAPHTHALENE
2-METHYLNAPHTHALENE
ACENAPHTllYLENE
ACENAPHTHENE
FLUORENE
2 6 10 13 18 22 26 30 36 42
GCMS GCMS GCMS GCMS GCMS GCMS GCMS GCMS GCMS GCMS

4.2 21 3.9 5.5 4.4 5.8 11 4.5 2.6 3.B
1.2 1.2 2.1 1.2 1.7 1.2 1.3 1.9
2-0 2.7 2.6 5.0 2.9 3.4 2.8 2.2 2.4 3.1
2.0
2.5 2.2 4.8
1.4 2.6
ANTHRACENE
PHENANTHRENE
PYRENE
FLUORANTHENE
PHENYLNAPHTHALENF.
1,2,6, 7-TETRAHYDROPYRENE
1.4 1.4 1.4 1.9 1.5 1.0
1.4 1.5
1.5 3.3


BEN20 (a) ANTHRACENE*
9 , 10-BENZPHENANTHRENE
CHRYSENE*
BENZO (btk ) FLUORANTHENE*
BENZO (a) PYRENE*
BENZO(e)PYRENE
BENZO (j I FLUORANTHENE*
fLKfLtm
BENHO(g,h,ill'ERYLmE
INDENO ( 1 , 2 , 3 -cd ) PYRENE*
O-PHENYLENEPYRENE
DIBENZO (a, h] ANTHRACENE*
TOTAL CARCINOGENIC PAH'S
TOTAL "OTHER" PAH'S











—
7.4 23.7 7.7 14.0 7.0 12.3 19.7 14.9 8.2 21.5
NITROGEN HETEROCYCLES
ACRIDINE
CARBAZOLE
INDOLE
PHENANTHRIDINE
QUINOLINE

3.0 1.4 1.4 2.1 1.5 1.8 1.7
SULFUR HETEROCYCLES
BENZO (b)THIOPHENE
DIBENZOTUIOPHENE
1.1 1.1 1.1 1.2 2.9

OXYGEN HETEROCYCLES
DIBENZOFORAN
MISCELLANEOUS
BIPHENYL
2,3-DIHYDROINDENE
INDENE
1.3 1.4 1.3
3.8 3.6 3.5 3.3 5.5 5.8 7.8 12 14 22
1.0 3.1 1.0 1.8 2.6 1.8 2.5 3.5 4.5 3.7
AROMATIC AMINES
ANILINE
1-AMINONAPHTHALENE
1-AMINOBIPHENYL
Note: No value is shown for compounds found at less than the detection limit.
4. Sforzolini, G.S., Savino, A. and Monarca, S., "Decontamination of
   Water Contaminated with Polycyclic Aromatic Hydrocarbons (PAH)
   II. Action of Chlorine and Ozone on PAH Dissolved in Drinking
   and River Water (Rough Draft),"  Perugia Univ. (Italy). Inst. of Hy-
   giene. Available from the National Technical  Information Service,
   Springfield, VA 22161  as ORNL-tr-2961.
5. Duvel, W.A. Jr. and Helfgott, T., "Removal of Wastewater Organics
   by Reverse Osmosis," JWPCF47,  1975, 57-65.
6. Sorrell, R.K., Barss, H.J. and Reding, R., "Review of Occurrences
   and Treatment of Polynuclear Aromatic Hydrocarbons in Water,"
   Env. Int., 4, 1980, 245-254.
7. Murin,  C.J.  and Snoeyink, V.L., "Competitive Adsorption of 2, 4-
   Dichlorophenol  and 2, 4, 6-Trichlorophenol  in  the Nanomolar  to
   Micromolar Concentration Range," Env. Sci. Tech. 13, 1979, 305-311.
8. Suffet, I.H., Brenner, L., Coyle, J.T. and Cairo, P.R., "Evaluation of
   the Capability of Granular Activated Carbon and Xad-2 Resin to Re-
   move Trace Organics from Treated  Drinking Water," Env. Sci. Tech.
   12, 1978,  1315-1322.
9. Basu, D.K. and  Saxena, J.,  "Monitoring of Polynuclear Aromatic
   Hydrocarbons in Water  Compounds  with Polyurethane  Foams,"
   Env. Sci.  Tech. 12, 1978, 791-795.
10.  Chriswell, C.D., Ericson,  R.L., Jun, G.A., Lee, K.W., Fritz,  J.S.
    and Svec, H.J., JAWWA 69, 1977, 669-674.

11.  Zogorski, J.S. and Faust, S.D., "Operational Parameters for Opti-
    mum Removal of Phenolic Compounds  from Polluted Waters by
    Columns of Activated Carbon," Water-1976, AICHE Symp. Ser 73,
    No. 166, 1977, 54-65.

12.  Baird, R., Carmona, L. and Jenkins, R.L., "Behavior of Benzidine
    and Other Aromatic  Amines  in  Aerobic Wastewater Treatment,"
    JWPCF, 49,  1977, 1609-1615.

13.  Harrison, R.M., Perry, R.  and Wellings, R.A.,  "Chemical Kinetics of
    Chlorination  of Some Polynuclear Aromatic Hydrocarbons under
    Conditions of Water  Treatment  Processes,"  Env. Sci.  Tech.,  10,
    1976, 1156-1160.

14.  Harrison, R.M.,  Perry, R. and Wellings, R.A., "Effect of Water
    Chlorination upon  Levels  of  Some Polynuclear Aromatic Hydro-
    carbons in Water," Env. Sci. Tech., 10, 1976,  1151-1156.

15.  Acheson, M.A.,  Harrison, R.M.,  Perry, R. and Wellings, R.A.,
    "Factors  affecting the  extraction  and   Analysis of  Polynuclear
    Aromatic Hydrocarbons in Water," Water Res., 10, 1976, 207-212.
                                                                                           GROUNDWATER TREATMENT
                                                               263
-------
                                                                    Table 10
                                                         Effluent from Calgon Column #2
 PARAMETER
 (ALL VALUC IN nq/1)
UATt:
ANALYSIS BY:
DATE OF COLLECTION
2/20/83 2/24/83 2/28/83 3/4/83 3/8/83 3/12/83 3/16/83 3/20/83 3/26/83 4/1/83
CH2H HILL CH2H HILL CH2M HILL CH2H HILL CH2M HILL CH2K HILL CH2M HILL OUM HILL CH2M HILL CH2M HILL
 DAY OF PILOT TEST:
 ANALYTICAL EQUIPMENT
                                                                                                                             GCMS
 PAH ('INDICATES CABC1NOGENIC PAH I
    HAPHTHALEHE
                                                     5.1
    1 -METHY LNAPHTHALENE
                                                                                                                      1.3
    2-HETHY LNAPHTHALENE
    ACENAPHTHYLENE
    ACENAPHTHENE
    PHENANTHREHE
    FLUORANTHENE
     PHENY LNAPHTHALENE
     1,2,6,7-TETRAHYDROPYRENE
     BENZO (a) ANTHRACENE*
     9,10-BENZPHEHANTHRENE
     BENZO(bSk)FLUORANTHEHE*
     BENZOIolPYRENE*
     BENZO(e)PYRENE
     BENZO I)) FLUORANTHENE*
     PERYLENE
     BENZO(9,h,l)PERYLENE
     INDENO(1,2,3-cd)PYRENE*
     0-PHENYLENEPYRENE
     D1BEHZOla,h)ANTHRACENE*
     TOTAL CARCINOGENIC PAH'S
     TOTAL "OTHER" PAH'S
                                                                                                                              12.2
 NITROGEN HETEROCYCLES
     I'HENANTHRIDINE
     QUINOLINE
 SULFUR HETEROCYCLES
     BENZOIblTHIOPHENE
     DIBENZOTHIOPHENE
 OXYGEN HETEROCYCLES
     D1BENZOFUKAN
 MISCELLANEOUS
     2,3-DIHYDROINDENE
                                                              3.5
                                                                                                             5.3
                                                                                                                               7.8
                                                                                                                      2.9
 AROMATIC AMINES
     1-AHINONAPHTHALENE
     1-AMINOBIPHENYL
 Note:  No valume is shown tor compounds found at  lu^s than the detection Unit.
16. Abrams, I.M., "Removal of organics from water by synthetic resinous
    adsorbents," Water-1969,  Chem. Eng. Prog. Symp. Ser., 65, No. 97
    1969, 106-12.

17. Hindin E., Bennett, P.J. and Narayanan, S.S., "Organic compounds
    removed by reverse osmosis,"  Water & Sewage  Works, 116, 1969
    466-70.

18. Van Vliet, B.M., Weber, W.J. Jr.  and Hozumi, H., "Modeling and
    Prediction of Specific Compound  Adsorption by Activated Carbon
    and Synthetic Adsorbents,"  Water Res., 14, 1980, 1719-1728.

19. Pringle, W., "Analysis of the Chemistry Associated with Ozonolysis
    of Organic Pollutants Molecules in Water." Available from the Na-
    tional Technical Information Service, Springfield, VA 22161 as PB81-
    115651.

20. Gracf, W. and Nothhafft, O., "Chlorination of Drinking Water and
    Benzopyrene," Arch. Hyg. Bakl., 147, 1963, 135-146.

21. Reichert, J.K.,  "Carcinogenic Substances in Water and Soil. XXI.
    Quantitative Results  on the Removal of Polycyclic Aromatic Com-
    pounds from Drinking Water by Chlorine Dioxide Treatment," Arch.
    Hvg. Bakl.. 152, 1968, 37-44.
22. Reichert, J.K., "Carcinogens in Water and Soil. XXIV. Removal of
    Polycyclic Aromatic Compounds in Drinking Water Treatment with
    Chlorine Dioxide: Identification of Previously Unknown Products of
    the Reaction of 3,4-benzopyrene and Chlorine Dioxide," Arch. Hug.
    Bakt.,  152, 1968, 277-279.
23. Reichert, J.K., "Carcinogens in Water and Soil. XXIV. Removal of
    Polycyclic Aromatic  Compounds in the Treatment of Tap Water
    with Chlorine Dioxide: Isolation and Identification of Products of the
    Reaction  with 3,4-benzopyrene,"  Arch.  Hyg. Bakt.,  152,  1968,
    265-276.
24. Smith,  J.O., McCall, R.B. and  Chan,  P.K.,  "Formation of Poly-
    chlorinated  Aromatic Compounds during  Aqueous Chlorination,"
    Env. Pollut., 14, 1977, 289-296.
25. Oyler,  A.R., et al.,  "Determination  of Aqueous Chlorination Re-
    action  Products of Polynuclear Aromatic Hydrocarbons by Reversed
    Phase  High Performance  Liquid Chromatography-Oas Chromato-
    graphy," Anal. Chem., 50, 1978, 837-842.
26. Carlson, R.M., et al., "Aqueous Chlorination  Products of Polynu-
    clear Aromatic Hydrocarbons,"  Water Chlorination:  Envir. Imp**
    and Health  Effects,  Proc.  of Conf. on  the Envir. Impact of Wate
    Chlorination, 2nd Ed., Ann Arbor Sci.,  1978, 59-65.
264       GROUNDWATER TREATMENT
-------
                                 Table 11
                     Effluent from Calgon Column #3
                                 Table 12
                     Effluent from Calgon Column #4
PARAMETER
(ALL VALUES  IN ng/l)
                                         2/20/83
                                                              3/20/83
ANALYSIS BY:
DAY OF PILOT TEST
ANALYTICAL EQUIPMENT
PAH ('INDICATES CARCINOGENIC PAH)
    NAPHTHALENE
    1-METHYLNAPHTHALENE
    2-METHYLNAPHTHALENE
    ACENAPHTHYLENE
    ACENAPHTHENE
    PHENANTHRENE
    FLUORANTHENE
    THENYLNAPHTHALENE
    1,2,6,7-TETSAHYDROPYRENE
    BEN20(a)ANTHRACENE*
    9,10-BENZPHENANTHRENE
    BENZO(bsk)FLUORANTHENE*
    BENZOIalPYRENE*
    BENZO(e)PYRENE
    BENZO(3)FLUORANTHENE*
    BENZO(g,h,i)PERYLENE
    INDENO(l,2,3-cd)PYRENE*
    0-PHENYLENEPYRENE
    DIBENZO (a,h)ANTHRACENE*
    TOTAL CARCINOGENIC PAH'S
    TOTAL "OTHER" PAH'S
NITROGEN HETEROCYCLES
    PHENANTHRIDINE
    QUINOLINE
SULFUR HETEROCYCLES
    BENZO (b)THIOPHENE
    DIBENZOTHIOPHENE
OXYGEN HETEROCYCLES
    DIBENZOFURAN
MISCELLANEOUS
    2,3-DIHYDROINDENE
AROMATIC AMINES
    1-AMINONAPHTHALENE
    1-AMIIIOBIPHENYL
                                       CH2B HILL   CH2M HILL   CH2M HILL
                                           6.0
NuLe:  Mo value is shown for compounds found at less than the detection limits.
PARAMETER
(ALL VALUES IB ng/l)
                                                                             DATE:
                                                                             ANALYSIS BY:
                                         2/20/83      3/8/83    3/20/83
                                       CH2M HILLCH2M HILLCH2M HILL
                                                                             DAY OF PILOT TEST
                                                                             ANALYTICAL EQUIPMENT
                                                                             PAI1 ("INDICATES CARCINOGENIC PAH)
                                                                                 NAPHTHALENE
                                                                                 1-METHYLNAPHTHALENE
                                                                                 2-METHYLNAPHTHALENE
                                                                                 ACENAPHTHYLENE
                                                                                 ACENAPHTHENE
                                                                                 PHENANTHRENE
                                                                                 FLUORANTHENE
                                                                                 PHENY LNAPHTHALENE
                                                                                 1,2,6,7-TETRAHYDROPYRENE
                                                                                 BENZO(a)ANTHRACENE*
                                                                                 9,10-BENZPHENANTHRENE
                                                                                 BENZO(b£k)FLUORANTHENE*
                                                                                 BENZOIalPYRENE*
                                                                                 BENZOIelPYRENE
                                                                                 BENZO(j)FLUORANTHENE*
                                                                                 PERYLENE
                                                                                 BENZO(g,h,i)PERYLENE
                                                                                 INDENO(l,2,3-cd)PYRENE*
                                                                                 0-PHENYLENEPYRENE
                                                                                 DIBENZO(a,hlANTHRACENE*
                                                                                 TOTAL CARCINOGENIC PAH'S
                                                                                 TOTAL "OTHER" PAH'S
                                                                             NITROGEN HETEROCYCLES
                                                                                 PHENANTHRIDINE
                                                                                 QUINOLINE
                                                                             SULFUR HETEROCYCLES
                                                                                 BENZO(b)THIOPHENE
                                                                                 DIBENZOTHIOPHENE
                                                                             OXYGEN HETEROCYCLES
                                                                                 DIBENZOFURAN
                                                                             MISCELLANEOUS
                                                                                 BIPHENYL
                                                                                 2,3-DIHYDROINDENE
                                                                             AROMATIC AMINES
                                                                                 1-AMINONAPHTHALENE
                                                                                 1-AMINOBIPHENYL
                                                                             Note:  No value is  shown for compounds found at loss than the detection limit.
27.  Personal communication, Dr.  Bricks Leitis  of Westgate Research,
     Sept. 1982.
28.  Lipowicz, M., "Rapid Oxidation Destroys Organics in Wastewater,"
     Chem.  Ens., 88, Nov. 1981, 40-41.
29.  Chang, I.L., "Rapid Free Radical Oxidation of Organic Wastewater
     by U.V./H2O2/Cavitation," 21st WEH Seminar, Grundlagen der
     Desinfektion and Reingung  von  Wasse mittels Ultraviolet—Strah-
     lung, March 1982.

30.  "Study of Groundwater Contamination in St.  Louis Park,  Minne-
     sota Final  Report," Memorandum No. GR8-12, Eugene A.  Hickok
     and Associates,  Nov., 1981.
31.  Leitis,  E., Zeff, J.D. and Smith, M.M., "Chemistry and Application
     of Ozone and Ozone/UV Light for Water Reuse," U.S. Department
     of Interior, Office of Water Research and Technology, OWRT14-34-
     0001-9436, May 1981.
32.  Basu, D.K. and Saxena, J., "Polynuclear Aromatic Hydrocarbons in
     Selected U.S. Drinking Waters  and Their Raw Water Sources," Env.
     Sci. Tech.,  12, 1978, 791-794.
33. Carlson, R.M., et al., "Facile Incorporation of Chlorine into Aro-
    matic Systems During Aqueous  Chlorination Processes," Env. Sci.
    Tech., 9, 1975, 674-675.
34. Gabovich,  R.D., et al., "Effect  of Ozone and Chlorine on  3,4-Ben-
    zopyrene during the Disinfection  of Water," Gig. Naselennykh Mest,
    8, 1969, 88-91 (Russ.).
35. Reichert, J., "Elimination of Carcinogenic Aromatic Polycyclic Com-
    pounds in  Drinking Water Treatment with Special Consideration of
    Ozone," Gas-Wasserbach, 110, 1969, 477-482, (German).

36. H'nsitkii,  A.P., et al., "Effect of Ozonation on Aromatic, Particu-
   larly Carcinogenic,  Hydrocarbons,"  Gig. Sanit., 33 (3),  1968,  8-11,
    (Russ.).
37. Saxena, J., Basu, D.K. and Kozuchowski, J.,  "Method Development
    and  Monitoring  of Polynuclear  Aromatic Hydrocarbons in Selected
    U.S. Waters," U.S. Dept. of Comm., PB-276635, Nov.  1977.
38. CH2M Hill, "Evaluation of Groundwater Treatment and Water Sup-
    ply Alternatives  for  St.  Louis Park, Minnesota" prepared for the
    Minnesota Pollution Central Agency, July 1983.
                                                                                                     GROUNDWATER TREATMENT
                                                                      265
-------
MINED CAVITIES  IN SALT-A LAND DISPOSAL ALTERNATIVE
                                              MARK W. HOOPER
                                             JAN N. GEISELMAN
                                                Pakhoed USA Inc.
                                                  Houston, Texas
                                               THOMAS E. NOEL
                                                   EMPAK Inc.
                                                  Houston, Texas
  EXISTING TECHNOLOGY

    By 1985, United States industry will generate approximately 48
  million metric tons of hazardous waste. The USEPA estimates that
  approximately 50% of this hazardous waste will be disposed of
  through  land storage/disposal (Figure  1).  However, current
  legislative trends are to limit land disposal, especially landfills.
    This suggests that the use of treatment/detoxification, incinera-
  tion, recovery and/or conservation must increase. This theoretical-
  ly optimum situation glosses over two realities:
  •That the generation of large volumes of inorganic sludges  and
   solids contaminated with trace amounts of hazardous materials
   such as asbestos, heavy metals and organic compounds are inher-
   ent in the manufacturing service,  mining industries  and many
   treatment processes
  •That the disposal problem associated with these sludges and solids
   is not going to be handled by treatment, incineration, recovery
   and/or conservation; instead, some form of land storage/disposal
   will continue to be necessary.
    California,  which is currently reducing its dependence on land
  disposal faster than any other industrialized state, has estimated
  that only 75"% of the hazardous waste disposal in landfills could be
  recycled,  treated or destroyed.'
    More importantly, ignored in this legislative crusade is the hazar-
  dous waste that has been deposited in landfills and lagoons in the
  past. This waste, amounting to several hundred million  tons, must
          ESTIMATED NATIONAL HAZARDOUS
              WASTE DISPOSAL METHODS
                            1985
    CD SURFACE IMPOUNDMENTS
    CD LANDFILL
    CD INCINERATION
                         B DEEPWELL INJECTION
                         mQ TREATMENT
                         E3 RECOVERY
 266
                Figure I


ULTIMATE DfSPOSAL
be multiplied by a factor to take into consideration the amount of
additional earth contaminated.
  Landfills and lagoons operated by private industry account for
the majority of this stored volume because over 85% of the hazar-
dous  waste has been  historically  handled  on-site,  within the
generating plant's boundaries. Only 15"% has been handled off-site
in commercial facilities.2
  Private industry will be closing many of these older landfills and
lagoons  in coming years because of recently enacted monitoring
regulations and the anticipation of additional restrictions. Similar-
ly, billions of dollars will be expended to handle the small fraction
of sites that have been abandoned. The cleanup of these problems
alone will take many years.
  The current and projected  state of technology  calls for the ma-
jority of these hundreds of millions of tons of sludges, solids and
contaminated  soils to  either  be covered with  clay caps and sur-
rounded by grout curtains or be removed to other landfills. These
short-term solutions will probably fail due  to leaching, erosion,
breaching, faulting,  subsidence, flooding, construction, etc., dur-
ing our lifetime.

ALTERNATIVE TECHNOLOGY

  A 1983 report3 prepared by  the National Research Council of the
National Academy of Science, the National Academy of Engineer-
ing and the Institute of Medicine, contained the following conclu-
sion:
  "To subsurface disposal areas that have considerabale potential
  for the disposal of hazardous industrial wastes (both solid and
  liquid) are salt domes and arid region's unsaturated zones."
  The USEPA,4 in a Request  For Proposal issued Mar. 12,1983 to
initiate preliminary activities relative to a salt cavity waste disposal
demonstration project,  stated:
  "The absolute containment and isolation of many hazardous in-
  dustrial wastes is an economic and environmental necessity. Use
  of underground salt mines  for the long-term, controlled storage
  of these wastes has been and is recommended  by  EPA for fur-
  ther study as a possible solution to this pressing problem. Prom-
  ising results of studies by  EPA's Solid and Hazardous Waste
  Research Division (SHWRD) and other agencies,  as well as the
  successful operation  of such a  facility in West Germany,  indi-
  cate a high likelihood of success for such a technology."
  Salt deposits have been used for the safe, secure storage of hazar-
dous  materials  since 1941. Currently,  solution-mined and dry-
mined cavities in salt deposits are used for the storage of hundreds
of millions of tons of liquid and gaseous products, hazardous waste
-------
                          STORAGE IN SALT
                     (IN TEXAS, LOUISIANA & MISSISSIPPI)

                    CURRENT STORAGE     TOTAL VALUE OF
                        VOLUME        STORED PRODUCT
                       (BARRELS)

                       635,000,000
                           Figure 2
 (DOLLARS)

13,640,000,000
and nuclear waste. Salt domes in Texas, Louisiana and Mississippi
store over 600 million barrels of hazardous product worth approx-
imately $14 billion (Figure 2). One such dome is used for over 100
million barrels of chemicals and gaseous hydrocarbons. Another,
located beneath  Houston, has  been  used for the storage of 12
million barrels of high pressure hydrocarbons for over 30 years. An
additional 93 million barrels of hazardous products are stored in
mined cavities in bedded salt deposits in the Northeast, Midwest
and Western United States.
  In the United States and Holland, solution-mined cavities are be-
ing used for the disposal of caustic-chlorine manufacturing sludges
and drilling muds.9 In West Germany, salt cavities  are used for
strategic crude oil stockpiles, natural gas storage, compressed air
energy storage (CAES), a nuclear waste repository and hazardous
waste storage. The Herfa Neurode potash/salt mine in West Ger-
many has been operated by a subsidiary of Kali und Salz AG for
almost 10 years as a repository  for containerized hazardous waste.
Waste from the United States has been deposited there, including
kepone from  the Hopewell, Virginia incident.
                 U.S. SALT DEPOSITS
  O ROCK SALT IN SUBSURFACE
  B SALT DOME BASINS
                           Figures
  The technology for hazardous waste  placement in solution-
mined and dry-mined salt cavities is well developed and proven.
This technology has been developed in dry salt mining over the past
100 years, in industrial brining operations over 100 years and in
hazardous product storage over 40 years. The same technology cur-
rently used for the safe and retrievable storage of hundreds of
millions of tons of hazardous material is readily applicable to
hazardous waste storage in the United States. The only thing miss-
ing has been economic incentive.
Research
  Research into the characteristics of salt deposits and their use for
product, hazardous waste and nuclear waste repositories has been
exhaustive. A bibliography on the subject would involve several
thousand entries. Only a very small sampling is included in  the
reference section of this paper. A major task in the USEPA RFP is
a literature review and research activity update.
SALT CHARACTERISTICS
  Two factors account for the extensive use  of salt as a storage
medium: (1) distribution and (2) characteristics. In the United
States, salt deposits exist in bedded or domal form in most of the
industrial regions  of the  country (Figure  3). More important,
however, are the characteristics of salt which makes it particulary
amendable to storage. Salt, underground and under pressure, is
plastic, strong and impermeable.
Plastic Behavior
  Underground, and at the associated pressures and temperatures,
salt behaves as a semi-plastic. This phenomena has enabled salt to
evolve from deep salt beds into salt domes along the Gulf Coast.
These domes are immense mountains of solid salt up to 13 miles in
diameter that have risen from mother salt  beds  via plastic flow
through 5 to 10 miles of sedimentary overburden over the past 100
million years or so at rates averaging 1 in. every 100 years  (Figure
4).
                                                 Figure 4

                         A more familiar example of salt's plasticity is the salt block used
                       by livestock. This block starts out in a form similar to crushed ice
                       cream salt before  it is subjected to 2000 lb/m2 of pressure. The
                       result is a solid block—without using glue—all due to salt's plas-
                       ticity.

                       Strength

                         One of the more visible examples of salt's strength is in a room
                       and pillar salt mine where the salt pillars hold up millions of tons of
                       ceiling  weight. A more impressive example was the  5 kiloton
                       nuclear detonation set off deep inside a salt dome in Mississippi.
                       The salt was strong enough to contain this blast and 3 subsequent
                       ones with no release of blast gases through the salt.

                       Impermeability

                         The in situ permeability of salt is zero due to salt's crystalline and
                       plastic structure.6 Product storage and dry mining operations pro-
                       vide examples  of  this characteristic. Gaseous hydrocarbons are
                       stored at pressures up to 4000 lb/in2 with no leakage of material
                       through the surrounding  salt.  Salt domes  are  surrounded  by
                       brackish and brine aquifers with no leakage through the salt into
                       room and pillar salt mines located within the dome. In one salt
                       dome in Louisiana, the United States Government  is  storing 70
                                                                                            ULTIMATE DISPOSAL
                                                                                267
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                                                                   was the Vinton Salt Dome in Louisiana. How this site measured up
                                                                   to the key siting criteria is shown in Table 2.
                                                                                                Table 2
                                                                                       Vinton Sail Dome Analysis
                            Figure 5

million barrels of crude oil in a converted salt mine adjacent to an
active room and pillar salt mine employing over 100 miners with no
leakage of oil into the mine.

PROJECT DESCRIPTION

Site Selection

  EMPAK developed a computer model to optimize site selection,
as  well  as site  speciic  facility  design,  capital  investment and
operating budgets, market volumes and rates and waste logistics.
The major criteria considered in site selection are listed in Table 1.

                            Table 1
                      Site Screening Criteria
Population Density/Proximity
Wetland Proximity
Floodplain Proximity
Highway Access
Barge Access
Depth to Salt
Priot Salt Dome Activity
                      Land/Dome Ownership
                      Market Proximity
                      Power Supply
                      Land Availability/Cost
                      Dome Configuration/Size
                      Brine Disposal Availability
                      Prior Area Activity
  Sites coinciding with the major industrialized states have been
fully analyzed; however, the Gulf Coast region was selected for the
First repository  because it coincided  with  the  company's major
facilities and headquarters. After thorough analysis of the 250 or so
salt domes onshore in Texas, Louisiana, Mississippi and Alabama,
plus a few offshore salt domes, the Big Hill Salt Dome in Texas was
ranked number one. Unfortunately, the United States Government
initiated condemnation proceedings in 1982 to take the dome for
inclusion in the Strategic Petroleum Reserve. The number two site
                                                                    Population Density/Prixunity

                                                                    Wetland Proximity
                                                                    Floodplain Proximity
                                                                    Highway Access
                                                                    Barge Access
                                                                    Depth to Salt
                                                                    Prior Salt  Dome Activity

                                                                    Land/Dome Ownership
                                                                    Market Proximity
                                                                    Power Supply
                                                                    Land Availability/Cost
                                                                    Dome Configuration/Size
                                                                    Brine Disposal Availability
                                                                    Prior Area Activity
                                                                                       Less than 30 people within 2 miles; Vinton
                                                                                        3V* miles (Pop: 3.600)
                                                                                       None involved in project
                                                                                       Site above 100 year floodplain
                                                                                       Immediate to interstate highway
                                                                                       Immediate to barge canal
                                                                                       Less than 1,000 ft
                                                                                       No sulfur mining, no brining, no storage,
                                                                                        no mining
                                                                                       Single owner for all project requirements
                                                                                       More than sufficient market in Louisiana
                                                                                       Immediate, adequate
                                                                                       Available, reasonable
                                                                                       Large enough for buffers and project
                                                                                       Existing
                                                                                       Ranching, farming, oil/gas production
Surface Facilities
  Surface facilities at the Vinton Salt Dome site will include an of-
fice, laboratory, vacuum truck unloading pad, dumpster unloading
pad, barge unloading dock, interim storage tanks and neutraliza-
tion tanks.  They will conform to standardized company design,
which includes:
•All waste  stored  and  processed in steel, Fiberglass or  concrete
 tanks—no earthen impoundments
•All waste storage and processing areas fully concreted and sur-
 rounded by a concrete dike
•All unloading areas fully concreted and curbed
•All toxic and odorous emission sources collected and handled by
 emission control equipment
•All waste handling areas surrounded by monitoring wells
Subsurface Facilities

  The configuration of a storage cavity varies considerably, depen-
ding on whether it is in bedded or domal salt, the depth of the salt
and the cavity and whether it is new construction for storage or
conversion of a brining cavity (or mine). A typical new construc-
tion product storage cavity might have a cylindrical configuration
with dimensions of 900 ft in height and 200 ft in diameter. A similar
design  could be used for hazardous waste storage, but computer
optimization indicated that breaking the single large cavity into a
series of smaller cavities or a  "string-of-pearls" was preferable
(Figure 5).
  This string-of-pearls design has been used in gas storage in bed-
ded salt  and has been  tested for waste storage  in domal salt in
Holland.9 Patents have been granted to others for use of the design
in storing nuclear waste, garbage and municipal sewage  sludges.
EMPAK has applied for a patent for its use in  hazardous waste
storage.

PROJECT ECONOMICS

  The capital investment  through the third year in the Vinton Salt
Dome  Waste Storage  Project,  inclusive of permitting,  surface
facilities and subsurface facilities, will be approximately $20 million
(1983 dollars). The investment after  20 years will exceed $100
million, the difference being the additional investment in storage
wells and cavities.  The capacity of the facility at this investment
level will be approximately 200,000 metric tons per year.
  Although a capital intensive activity, the concept remains highly
competitive with landfill technology (Table 3).
 268
ULTIMATE DISPOSAL
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                            Table 3
          Economic Comparison of Landfill vs. Salt Dome
                  Disposal of Hazardous Waste

Disposal
Method
Landfill
Salt Dome

Waste
Type
Sludges
Sludges
Ave.
Breakeven
Disposal Cost
Rate-$ BBL$ BBL
12.50
11.76
11.86
4.72
Incremental
Cost
$BBL
5.22
1.78
PROJECT SAFETY

  The long  history  of hazardous material  storage  in  salt  is
characterized by safety and reliability. On a volume stored basis, it
has proven to be  safer than  steel, above ground tankage and
definitely more secure than landfills and lagoons. No one would en-
trust the security of $14 billion worth of product on the Gulf Coast
to a landfill or lagoon.
  However, EMPAK has reviewed case histories of accidents in-
volving salt domes7 as well as conceptualized failure scenarios and
has developed design and operating precautions to offset each and
every one.  A few of these are identified in Table 4.

                            Table 4
              Design and Operating Safety Precautions
                  of a Salt Dome Storage Facility
Potential Problem
1.  Accidentally drilling
   into filled cavity
2. Cavern Stability
Safety Precaution(s)
a. Only EMPAK allowed to drill on salt
  dome
b. No oil and gas well allowed to be drilled
  within 100 ft of salt
c. 500 ft salt buffer zone on sides of salt
  dome

a. Cavern design dimensions and
  configuration
b. Initial cavities above 3,000 ft
c. Brine evacuation stability test period
d. Cavern pressurization, if necessary
   EMPAK is confident that a hazardous waste repository in salt
 can be designed and operated to:
 •Result in lower levels of toxic substances released to the environ-
  ment over its lifetime than those  from either incineratioan or
  treatment facilities
 •Be safe and secure in perpetuity
   EMPAK has taken out insurance binders on the proposed facility
 that will provide for $100 million worth of Sudden and Accidental
 as well as Non-Sudden and Accidental insurance coverage and has
 agreed to include  this coverage as a permit provision. Apparently,
 the insurance carrier shares the firm's confidence as evidenced by
 both the commitment itself and the quite reasonable premium.
                                              PERMITS
                                                In the highly sensitized environment of hazardous waste disposal
                                              facility permitting, public relations is paramount. EMPAK began
                                              working on this problem in 1981, long before settling on a specific
                                              site. A salt dome brochure was published in Dec., 1981, and this
                                              was incorporated into  a site specific public information/media
                                              packet produced in Jan., 1983. These are only two elements in the
                                              overall public relations strategy for this project.
                                                The opposition to the Vinton  Salt Dome Project has embraced
                                              the  "not-in-my-backyard" syndrome  and has focused on emo-
                                              tional rather than technical or substantive issues. The key opposi-
                                              tion leaders have sought to ban the use of salt domes for hazardous
                                              waste storage on the grounds that they are unsafe, while totally ig-
                                              noring the safe,  secure  examples of  salt dome utilization in their
                                              "backyard" in the form of high pressure gaseous hydrocarbon and
                                              crude oil storage as well as 100 year old salt mines still going strong.
                                                The  federal and state permit  applications for the Vinton  Salt
                                              Dome site were  filed with the appropriate agencies in Mar.  and
                                              Apr., 1983. The permitting process will probably take two to three
                                              years.
FUTURE OPERATIONS
  Mined cavities in salt enjoy obvious technological and economic
superiority over landfills. This fact, combined with the reality that
significant volumes of hazardous sludges and solids must continue
to go to land disposal, will ultimately create an increasing demand
for this method in the United States as well as other industrialized
countries. With this in mind, EMPAK continues to pursue sites in
other states as well as Latin America and Europe.
REFERENCES

 .  "Alternatives to the Land Disposal of Hazardous Wastes,"  Gover-
   nor's Office of Appropriate Technology, CA, 1981.
2.  "Hazardous Waste Market-Handling, Storage & Disposal," Frost &
   Sullivan, Inc., New York, NY,  1981.
3.  "Management of Hazardous Industrial Wastes: Research and Develop-
   ment Needs," National Materials Advisory Board, Commission on
   Engineering  and  Technical  Systems,  National  Research Council
   (NMAB-398, Washington, D.C., 1983)
4.  "Assessment of Current Status of Using Mined Space for Long-Term
   Retention of Nonradioactive  Hazardous Waste," RFP CI 83-0094,
   USEPA, Cincinnati, OH, 1983.
5.  Wassmann, Th. Hans, "Cavity Utilization in the Netherlands," Hen-
   gelo, The Netherlands, 1983.
6.  Halbouty, Michel T., Salt Domes Gulf Region, United States and Mex-
   ico, Second Edition, Houston, TX,  1979.
7.  Coates, O.K., et al., "Failure of Man-Made Cavities In Salt and Sur-
   face Subsidence Due to Sulfur Mining" (Topical Report RSI-0131),
   Prepared for Sandia Corporation by RE/SPEC, Inc. under DOE Con-
   tract AT (29-l)-789, Albuquerque, NM, 1981.
                                                                                               ULTIMATE DISPOSAL
                                                                                                         269
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 SOLIDIFICATION  AND THERMAL  DEGRADATION  OF  TNT
     WASTE SLUDGES  USING  ASPHALT ENCAPSULATION

                                              ELLY K. TRIEGEL
                                            JOSEPH R. KOLMER
                                         Woodward-Clyde Consultants
                                       Plymouth Meeting, Pennsylvania
                                         DOUGLAS W. OUNANIAN
                                         Foster-Miller Associates, Inc.
                                            Waltham, Massachusetts
INTRODUCTION
  Research is being conducted by the USEPA to investigate closure
methods for lagoons containing TNT wastes (pink water). Asphalt
encapsulation, combining heating and mixing, is  one process be-
ing considered' for the treatment of a sludge containing trinitroto-
luene  (TNT), hexahydro-l,3-5-trinitro-l,3,5-triazine  (RDX) and
other  nitroaromatics.  The lagoon  under investigation contains
approximately 365 mj of sludge with up to 56,700 mg/kg TNT,
3740 mg/kg RDX and lesser amounts of other nitroaromatics and
metals.
  Asphalt encapsulation techniques, consisting of mixing heated
asphalt with the sludge material, are being considered as a treat-
ment option. Coating (or microencapsulation) of the sludge par-
ticles would improve the leachate quality and should act to re-
duce the reactivity of the explosive  compounds by decreasing the
propagation pathway of any reactions in the explosive compounds.
Addition heating of the mixture should  act to thermally degrade
the nitroaromatic and RDX compounds in the sludge.
  Research to date has included:
•An evaluation of existing asphalt encapsulation techniques for
 hazardous wastes
•An evaluation of alternative heating/mixing systems
•Review of the properties of various asphalt products which may be
 used
•Laboratory  experiments on  the temperature and holding times
 required for thermal breakdown  of  the various  compounds
 present in the sludge
•Preliminary design of a pilot mixer/heating system.
  A synthetic sludge with physical properties similar to the actual
sludge will be used during the initial  runs and during modifications
of the pilot system. Actual  lagoon sludge will be used in the field
for the final testing.
  Factors which are being evaluated include residence times re-
quired for both mixing and thermal breakdown,  mobility  of the
system, safety considerations, batch vs.  continuous  designs and
throughput rates. Previously developed asphalt encapsulation pro-
cedures which could be mobilized would  require excessive process-
ing times and high capital  costs for lagoons of this size. Use of
ancillary processes, such as dewatering, and necessity for predry-
ing of the sludge prior to  encapsulation will also be evaluated.
This work is being funded by the  USEPA-MERL.
SITE CONDITIONS

  The pink water lagoon under study is approximately 3500 m2 in
area and has been in  existence  since the late 1960s. Field mea-
surements were made to determine the thicknesses and volumes of
the sludge and wastewater in the lagoon. At the time  of measure-
ment, the water was approximately 1 m deep and the sludge volume
was estimated to be 365 m'. It was  found that the greatest thick-
ness of sludge occurred very near the point of discharge of wastes
into the lagoon, indicating rapid settling of coarser particulates in
the water.
  Concentration distributions of several of the sludge constituents
(tetryl, RDX and 2,4-Dinitrotoluene) were similar to the thickness
contours, indicating a possible association of these compounds
with the coarser particulates. The concentration of 2,4,6-TNT did
not vary in a systematic manner with the sludge depths indicating
a more uniform, non-size dependent distribution of the compound.
  Chemical analyses of the ground water, lagoon water, sludge and
soils underlying the lagoons were performed  to identify the con-
taminants present and to characterize certain parameters which
could  affect the treatment process. These results are summarized
in  Table 1.  Three monitoring wells were  installed in addition to
an existing well for long-term monitoring of the groundwater qual-
ity near the lagoon.
PROCESS SELECTION
  Asphalt encapsulation was considered as a treatment technique
at the  pink  water  lagoon  since it  has  the  potential to both
thermally degrade as well as encapsulate the explosive and nitro-
aromatic compounds in the sludge. Asphalt encapsulation in this
situation is the combining, heating and mixing of asphalt and a
waste material. It is not the coating of a monolithic block of waste
with asphalt.
  Coating of waste particles with asphalt using twin-screw extrud-
ers  has been used in the past, primarily  for waste processing in
the nuclear industry.1'2 In this process, the asphalt and wastes are
heated and mixed in the extruder, which serves the dual purposes of
reducing waste particle size while mixing and coating the waste
thoroughly with the asphalt. Coating of the pink water sludge par-
ticles should also reduce reaction propagation pathways and en-
hance the safety of the design.
  The temperature profile along the screws (several feet in length)
can be closely controlled. The residence time in each section of the
screw can be varied by changing the  screw configuration and the
speed of rotation. Water and volatile organics are evaporated and
collected in a condenser system or removed under vacuum. The
process generally results in a substantial volume reduction due to
the removal of water, and the treated product is more resistant to
weathering and cracking.
  A vendor was contacted to evaluate the costs and feasibility of
utilizing a twin-screw extruder as a mobile unit. Several factors
which were unique to this project but had not been critical in past
waste encapsulation systems using the twin-screw extruder /asphalt
system included: (1) the need  for a mobile  system, (2)  demon-
stration of the safety aspects prior to implementation to allow pro-
tection for personnel working with potentially reactive material, (3)
heating requirements beyond those necessary to melt and  mix the
asphalt in order to enhance thermal degradation of nitroaromatic
 270
         ULTIMATE DISPOSAL
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                                                            Table 1
                                         Summary of Analytical Results, Pink Water Lagoon
Parameter
Pink Water
2,4,6-TNT
Tetryl
RDX
2,4-DNT
2,6-DNT
Nitrobenzene
1,3-Dini-
trobenzene
Moisture
PH
Reactivity
Sludge
200 to 56,700 ppm
41.8 to 2100 ppm
611 to 3740 ppm
.825 to 40.1 ppm
.106 to .901 ppm
1.090 to 9.14 ppm
.287 to 7.02 ppm
49% to 92%
7.1 to 7.5
No
Soil
Directly Beneath the Lagoon
(sample depth less than 0.5 m)
18.9 to 158 ppm
.04 to 19.6 ppm
35.7 to 91.6 ppm
.04 to .180 ppm
.04 to .173 ppm
.05 to 1.78 ppm
.04 to .29 ppm
17% to 21%
7.5 to 8.6
NA
Lagoon
Water
774 to 998 ppb
NA
19170 ppb
1.1 ppb
1.1 ppb
11 ppb
1.8 ppb
NA
7.69
NA
Groundwater
2900 to 6400 ppb
NA
NA
113 to 185 ppb
10 to 19.5 ppb
11 ppb
135 to 173 ppb
NA
5.63 to 5.64
NA
 NA:  not determined
% moisture = (g water/g sample) x 100
compounds and (4) possible extension of the system to treat larger
volumes of contaminated soils that may  be located beneath the
lagoons.
  These considerations were in addition to the normal constraints
of time required to process the wastes, costs of treatment, com-
patability  of the wastes and  asphalt, lack of undesirable  by-
products and the suitability of the product in terms of stability and
leaching characteristics.
  After a preliminary evaluation, it was concluded that: (1) a twin-
screw extruder which was small enough to be mobile would require
excessive (more than 1  year) throughput times for  the pink water
lagoon sludge,  and (2) the cost of the equipment  (rental or
purchase)  and the additional engineering  time  was too great for
closure of only one lagoon.
  At this point, a feasibility study of alternative mixer systems was
initiated by Foster-Miller Associates, Inc. This  study included an
evaluation of existing mixing equipment and asphaltic materials, an
outline of  the major process steps and a heating experiment to de-
termine the breakdown temperature and holding time for the nitro-
aromatics and RDX in the pink water sludge.

SELECTION CRITERIA FOR
MIXERS AND ASPHALT TYPES
  Since a  wide  range of both batch and continuous type mixing
candidates was available for consideration, evaluation criteria were
established to compare the relevant features:
'Degree of Mixing—Generally, how well does the equipment mix
 materials when used in its normal operating range for a nominal
 duration?
•Provisions for Loading/Discharging Materials—Does the mixer
 have loading chutes, discharge gates?
•Field Worthiness—Is it able to withstand over-the-road vibration?
 Resistance to elements as is? Ruggedness?
•Heat Capabilities'—Is  the mixer equipped with a heat jacket, is it
 a standard option or is a separate design required?
•Sludge Consistencies—Can it  be loaded and used at all ranges of
 sludge water content from slurry to dried mud?
•Portability—Can it be taken over-the-road in terms of weight
 and size? Is it compact in design? Can it fit on one truck trailer?
•Cost—What is the cost including the driving power, motors,
 pumps, etc?
•Overall Complexity—Can  it be operated with minimum worker
 training?  Number  of working parts? Does it  require  specialized
 service technicians? Are replacement parts difficult to locate?
                                       A number of different mixers was considered (Table 2). Some
                                     types of mixers are similar and were considered as a group, i.e.,
                                     vertical axis mixers. The mixers were then evaluated using the cri-
                                     teria outlined above (Table 3).
                                       In the mixer selection process, two mixers appeared to be super-
                                     ior: the pug mill and the static mixer. Since neither of these two
                                     has been used  for this particular encapsulation process, it is diffi-
                                     cult  to compare their  anticipated performance. However,  each
                                     has a few general advantages and disadvantages  described  as
                                     follows:
                                     Mixer         Advantages
                                     Pug mill      'Proven construction
                                                    worthy machinery
                                                   •High degree of mixing

                                                   •Minimal design
                                                    change for use
                                     Static         'Inexpensive
                                                   •No moving parts
                                                   •Can be used to
                                                    transfer heat to
                                                    sludge
                                                   •Extremely compact,
                                                    portable
                                                   •Easy to simulate
                                                    on a pilot scale
Disadvantages

•Large, heavy
 machinery
•Requires large power
 drive
•More expensive
 option
•Requires pump to
 drive materials
 through mixer
•Sharp increases in
 asphalt viscosity
 at cooler temperatures
 may cause problems
•Greater design cost
                                       As a part of the effort to identify mixing methods, a survey of
                                     the common asphalt grades was investigated (Table 4). The infor-
                                     mation most pertinent to mixing is the viscosity properties and flash
                                     points  of the asphalts. These  parameters  help  identify mixing
                                     energy requirements and safe operating temperatures.
                                     PRELIMINARY DESIGN OF THE SYSTEM

                                       The  major steps of the proposed  encapsulation  process are
                                     shown in Figure 1. The raw sludge would be transported from the
                                                                                            ULTIMATE DISPOSAL       271
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Table 2
Mixer Candidates
Mixer
Pug Mill
Dryer-Drum
Vertical
Axis
Horizontal
Axis
Extruder
Static
Industry Use
Base Stabilization (soil mixing),
Asphalt Paving Concretes,
Portland Cement Concretes

Portable Asphalt Concrete Plants
Chemical: Abrasive, Corrosives
Explosives, Concretes, Clays
Food, Chemical: Pastes,
Batter, Candy
Plastics, Food, Waste
Disposal.
Chemical Processing, Fibrous
Slurries, Explosives, Polymer
Mixing, Liquid-Liquid or
Liquid-Solid Mixing. Rubber,
Paint Mixing, Food Mixing
t



Type
Batch or
Continuous
Continuous
Batch
Batch
Continuous
Continuous
Options
Spray Bar (liquid
additions), Covers,
Intake/Discharge
Chutes, Heat Jacketing
Sealed drum, Bag House
Raw Material Storage
Conveyors, Asphalt
Tank
Muller & Plow Combinations,
Dust Cover, Liquid Metering
System, Renewable Pan
Liners
Mixing Elements: Ribbon,
Gate, Differential Screw.
Heat Jacketing
Heat Jacketing, Vapor
Collection, Remote
Controlling
Heat Jacketing
Table 3
Mixer Selection Matrix
MIXER
CRITERION
Degree of Mixing
Provision for Loading/
Discharging Materials
Field Worthiness
Heat Capabilities
Handles all Sludge
Consistencies
Portability
Cost
Overall Complexity
VERTICAL HORIZONTAL
PUG DRYER AXIS AXIS
MILL DRUM (PLANETARY, (RIBBON, GATE,
(STABILIZER) COUNTER-CURRENT DOUBLE-SCREW)
Mod-High Low
Exists Exists
Rugged Rugged
Heat Jacket
is Common Exists
Option
Cannot Use
Yes a Slurry
Yes Yes
Low Mod
Low Low
Mod-High ,
Requires
Design
Requires
Weather-
proofing
Requires
Addition
of Heat
Jacket
Yes
Mod-High
Requires
Design
Requires
Weather-
proofing
Heat Jacket
Available
for Some
Types
Yes
Trailer mounting Trailer mounting
req'd. Many are req'd. Many are
not practical not practical
to use in field to use in field
Mod
Mod
Mod
Mod
EXTRUDER STATIC
High Mod
Exists Requires
Design
Requires Requires
Weather- Weather-
proofing proofing
Requires
Addition
Exists of Heat
Jacket
Must Use
Yes a Slurry
Trailer Trailer
Mounting Mounting
Required Required
High Very Low
High Low
272
ULTIMATE DISPOSAL
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Table 4
Asphalt Types
Type
Blown Asphalt
(oxidized)
ASTM D312
Asphalt
Cement
ASTM D946
ASTM D3381
Penetration & Viscosity
Graded
Viscosity
Range
80-550
Centistokes
at 275°F
Uses
Steep Roofing, Pipe Coating
Under Sealing, Cavity Filling
Waterproofing
Plant-Made Asphalt Concrete
for Roads, Sidewalks, Parking
Lots, Dam Facings, Penetra-
tion Macadam.
Pure
Asphalt Use Temp
To C
100 135°
(min)
100 82°-176°
ASTM Minimum
Flash Point**
°C
225°
(min)
163°-238° (min)
Cutback Asphalt
Rapid
Medium   curing
Slow
ASTM D2028, D2027
D2026
  30-6000
Centistokes
 at 140°F
Road Mixing of Asphalt Concretes.
Asphalt Penetration Applications.
Prime & Tack Coats Before Paving.
Stockpiled Patching Mixes.
                                                                                   50-80
                                                   57°-116°**
RC-27
MC-38°-66°
SC-66°-107°
Emulsified
Asphalts
Rapid
Medium   setting
Slow
ASTM D977, D2397
  20-100
  Saybolt
  Seconds
  at 77°F
Seal Coating. Penetration Macadam.
Road Mixing of Asphalt Concretes.
Fine Aggregate or Soil Stabiliza-
tion. Cold or Hot Plant Mixing.
Patching Mixes.
                                        55-65
   Will Not
    Flash
*Flash points of specific products may exceed the minimum required by ASTM for that category.
"Application temperature may exceed flash point. Caution must be exercised.
                                                          TableS
                     Concentrations of Nitroaromatics, Tetryl and RDX in Heated Sludge Samples (ppm, dry weight basis)
Sample No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
17 Dupl
Method
Blank
Temperature Holding
(°C) Time (min)
150°C 5
10
15
20
200°C 5
10
15
20
250°C 5
10
15
20
300°C 5
10
15
20
100°C 120
120
— —

2,4,6-TNT
39,750
62,690
31,210
31,670
15,850
7180
23,660
22,680
2300
3500
3240
1740
35
3.6
5.6
1.5
42,360
43,320
0.47

RDX
604
470
495
668
779
862
974
926
362
357
485
685
10
29
0.85
0.85
300
314
0.85

Tetryl
2730
5050
16,000
11,300
2780
390
5260
3220
4140
23
19
19
(b)
1
1
1
43,760
——
1

NB*
0.7
0.7
0.7
0.7
0.7
0.7
0.7
0.7
0.7
0.7
0.7
0.7
0.7
0.7
0.7
0.7
0.7
0.7
0.7

1,3-DNB*
0.55
0.55
0.55
13
14
29
13
13
20
19
27
26
3
0.55
0.55
0.55
0.55
0.55
0.55

2,6-DNT*
126
104
69
83
76
42
94
115
57
71
89
62
6.9
0.42
0.42
0.42
0.42
0.42
0.42

2,4-DNT*
209
190
194
190
151
154
206
235
86
106
137
117
7.5
0.48
0.48
0.48
33
37
0.48

1,3,5-TNB*
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
91
95
125
122
6.4
0.6
0.6
0.6
0.6
0.6
0.6

  *NB = nitrobenzene
   DNB = dinitrobenzene
   DNT = trinitrotoluene
   TNB = trinitrobenzene
                                                                                           ULTIMATE DISPOSAL
                                                                                            273
-------
                   OPTION
                r—i
               ••J PHETH6ATUENTJ
                                              	,

                                              I  EVAPORATOR |
                                            •*)   /HEATER

                                              I	J
                           Figure 1
                  Sludge Encapsulation Process
 pond through a classifier which could take the form of a screen or
 grizzly to prevent oversize and foreign objects such as wood and
 cobbles from entering the system. The material would then proceed
 to pretreatment such as dewatering by filters, centrifuges  or heat-
 ing, or it could be deposited  directly into a surge tank to await
 feeding to the mixer. The advantages of heating or other forms of
 pretreatment depend upon the mixing process chosen.  The muck
 feeder may be a weight conveyor, screw conveyor,  batch weigh-
 ing system or positive displacement pump. This ensures  that the
 sludge is added in correct proportions to the asphalt.
   Heated asphalt would be fed into the blender/mixer separately
 using a positive displacement, oil-type pump. The grade of asphalt
 used would depend upon the mixing temperature chosen. Once the
 sludge and  heated asphalt have been combined satisfactorily, the
 encapsulated  material may  require an additional step involving
 heating  for a longer interval  to dewater and/or degrade com-
 ponents of the TNT sludge. Alternatively, if the mixing method
 itself provides sufficient time and temperature to degrade as well as
 encapsulate the sludge, the material can be discharged to  contain-
 ers or pumped to a storage pit/pond.
   The operating rate and mixer size were evaluated in order to
 assess  whether the  sludge in the lagoon could  be processed in a
 reasonable time frame using a portable mixer. Assuming  a use of
 50% asphalt to 50% wet sludge, a total of 730 m1 would be pro-
 cessed. Assuming a reasonable operating period of 24 days at 8 hr.
 each, an average throughput of 0.075 m'/min of encapsulated
 waste must be handled. This requires sludge and asphalt feed rates
 of 0.038 m'/min. The amount of time required to achieve proper
 mixing plus the additional time (if any) at the temperature that is
 required to degrade the TNT  is regarded as the system residence
 time. The residence time identifies the mixer and/or detention tank
 volume by the following computation.
  Throughput (m Vmin) x Residence Time (min) = Tank Size (m!)
Residence Time
(min)

 5
10
15
20
                  Mixer/Tank Size
                  (m')

                  0.38
                  0.75
                  1.13
                  1.51
                                                          It is readily apparent that a residence time in excess of 20 min
                                                       will require an unpractically large tank. In this case two options
                                                       are available: (1) operate at lower throughput or (2) consider the
                                                       energy retained by the encapsulated  sludge after discharge. De-
                                                       pending upon the size of casting or briquette used, the encapsulated
                                                       sludge may maintain a high temperature for hours.

                                                       HEATING REQUIREMENTS
                                                         A laboratory evaluation was conducted to assess the temperature
                                                       and holding times required for breakdown of the nitroaromatics
                                                       and RDX in the sludge. This information is necessary to design the
                                                       mixer system and to determine if thermal degradation  occurs at
                                                       temperatures below  the  flashpoint of available asphalts. Seven-
                                                       teen tests were conducted at four temperatures (150, 200, 250 and
                                                       300°C) and  four  residence times (5, 10, 15 and  20 min) plus one
                                                       sample heated for 2 hr at boiling (100°C).
                                                         For each  test,  80  g  of sludge  were placed in a 250  ml erlen-
                                                       meyer flask. The flask was then placed in the preheated high temp-
                                                       erature oven set to the end temperature desired. Temperature of the
                                                       sludge was monitored throughout the test.
                                                         The samples of the heated sludge were sent to the laboratory for
                                                       analysis. The results are found in Table 5.
                                                         Although the sludge was homogenized prior to the heating exper-
                                                       iment, variations in the concentrations were observed. These varia-
                                                       tions have occurred in most of the work with these sludges and may
                                                       be due to the presence of small particles of nearly pure TNT or for-
                                                       eign materials  (sand,  waxes,  etc.) which  cannot be completely
                                                       homogenized. The results, however, do indicate that thermal de-
                                                       gradation of approximately  90%  of the  explosive  and  nitro-
                                                       aromatic compounds occurs at 250 °C.
                                                         The results presented here are based solely on the heating of the
                                                       sludge.  Further testing  will  be  required   to determine  whether
                                                       various types of asphalt  in combination with the sludge result in
                                                       equally low levels of explosive and nitroaromatic compounds.
CONCLUSIONS

  Asphalt encapsulation of pink water sludges using either a static
or pug mill mixer appears to be a potential alternative to encapsu-
lation by twin-screw extruders or other treatment techniques based
on a preliminary evaluation of available mixers. The use of these
mixers may reduce equipment costs and processing times for mobile
systems.  Heating experiments of pink water sludge not yet encap-
sulated indicated a 90% reduction in  the levels of explosive and
nitroaromatic compounds at a temperature of 250 °C.
  Pilot scale testing of the encapsulation system will be conducted
prior to implementation in the field. The initial tests will use a syn-
thetic sludge  with  physical properties similar to  the pink water
sludge. Modifications to the system and safety reviews will be com-
pleted prior to final pilot testing of the actual TNT-sludge. Addi-
tional  laboratory tests on the asphalt-sludge  mixture,  perhaps
heated to temperatures between 250 °C and 300 °C, may also be re-
quired to assess the leaching characteristics of the final product.

REFERENCES
1.  Doyle,  R.D., "Use of an extruder/evaporator to stabilize and solidify
   hazardous wastes," Chapter 4 in Toxic and Hazardous Waste Disposal,
   Vol. I, R.B. Pojasek, ed.,  Ann Arbor  Science  Publ.,  Ann Arbor,
   MI,  1979.
2.  Malone, P. and Jones, L., Guide to the Disposal of Chemically Stabil-
   ized and Solidified Wastes, USEPA, Cincinnati, OH, 1980.
3.  Triegel, E.K. and Kolmer,  J.R., Remedial action  research:  waste-
   water lagoons,  in Proc. 9th  Annual Research Symposium: Land Dis-
   posal,  Incineration  and Treatment of Hazardous  Waste, USEPA,
   Cincinnati, OH, 1983.
4.  Wentsel, R.S.,  Sommerer, S. and Kitchens, J.F., Treatment of Ex-
   plosives Contaminated Lagoon Sediment—Phase I: Literature Review
   and Evaluation, USATHAMA, Edgewood, MD, 1981.
274
ULTIMATE DISPOSAL
-------
                      EVOLUTION OF PRACTICAL  ON SITE
                               ABOVE GROUND  CLOSURES

                                               LARRY GRAYBILL
                                      Rollins Environmental  Services,  Inc.
                                                  Houston, Texas
INTRODUCTION
  The basic disposal method through the ages has been land burial.
Prior to industrial development, the waste was minimal in quantity
and  the composition could  easily  be handled by the planetary
ecological system. The industrialization process began generating
more complex waste products and larger per capita quantities both
in the form of discarded refuse and by-products of manufacture.
The explosion in technology and the standard of living during the
past  100 years has taken place without an appreciation or awareness
of the problems associated with the land disposal of the tremen-
dous quantities of complex waste that was an integral part of the in-
dustrialization process.
  Due to this lack of awareness, industrial waste was handled by
burial methods. As the quantities of both household refuse and in-
dustrial waste continued to grow,  a crude land disposal industry
developed that generally handled  both municipal and industrial
waste in the same facility. Disposal was primarily a transportation,
dumping and sometimes covering operation. On-site disposal was a
common practice and eliminated the transportation cost for the in-
dustrial waste producers. These practices were simply an extension
of a  cultural "burial heritage" and were a normal response that
resulted from both a lack of awareness of the long term ecological
implications and the abundance of land resources in  this country.
Since most  wastes have been deposited in or on the land, most
hazardous waste generated since the industrialization process began
still exists. The waste is either present in the many thousands of
waste sites or has been discharged into the air and water.

RCRA Passed
  Once the growing awareness of the problems associated with the
"open  dumps"  reached a sufficient level, the  passage of  the
Resource  Conservation and  Recovery Act (RCRA)  of 1976 was
possible. RCRA began a new era for the hazardous waste disposal
industry. An attack was launched  on  open dumping and new ef-
forts were made to encourage waste volume reduction, recycling
and high technological approaches to the treatment or destruction
or hazardous waste.
  The  geotechnical-hydrogeological disciplines  were the initial
disciplines looked to for safe solutions to the land disposal prob-
lem.  With their help, specifications were developed  for the loca-
tion, clay liner construction and monitoring of new designs  for
secure landfills.  It was believed that these secure landfills  could
safely store hazardous wastes  for the  decades necessary  for
biological degradation of the waste.
  The new  secure landfill technology was a major improvement
over the preceding era. However, based on the anticipated security,
low cost of operation and federal support,  the land disposal
policies effectively eliminated the more costly higher technology ap-
proaches to resource recovery, volume reduction, treatment and
disposal. The economics favored  land disposal by a significant
margin.
  The complexity of the secure landfilling of the broad spectrum of
hazardous  waste,  including  the  organic  compounds,  was
underestimated. The real  world comingling of organic and in-
organic  waste did not fit  the models used by the geotechnical-
hydrogeological disciplines in their  design specifications for secure
landfill.  Many land disposal firms could not be regulated or
depended on to operate the landfills properly. Actual operating ex-
perience at many hazardous waste landfills did not support the long
life expectancy of the early RCRA  secure landfill specifications.
  The early RCRA land disposal policy is now under intense re-
examination, and the role of secure  landfills for disposal of organic
hazardous waste has been reduced or curtailed in many states. This
re-examination has now become a national issue with both USEPA
and congressional pressures moving toward major changes in our
land  disposal  policies in this country. The issue of organics and
secure landfill is a complex issue  and  beyond the scope of this
paper. The major point to note is that the present direction of both
state and national land disposal policies will result in major limita-
tions on the types and quantities of hazardous organic waste going
into secure landfills.
RCRA Chapter Two

  A second new era in the evolution of hazardous waste disposal
practices is now beginning. Continued limitation of the land
disposal or organic hazardous waste is obvious.  The proposed tax-
ing schemes for land disposal, pro-rated transportation taxes, taxes
on per unit waste generation, along with the increasing generator
liability-remediation risks associated with land disposal and many
other considerations point to basic changes in future waste disposal.
practices. Without going into detail, one can safely say that as the
relatively inexpensive landfilling of  organics is curtailed or becomes
cost intensive  on site waste volume reduction, resource recovery,
technical detoxification  and disposal methods will become  the
economical method of choice for ongoing waste streams.


CLOSURE DILEMMA

  RCRA Chapter Two presents a dilemma for  the closure of cur-
rently used hazardous waste sites according to the regulations of
Superfund and RCRA.  The nature of the wastes stored in the
thousands  of  waste lagoons, impoundments, etc., does not allow
                                                                                        ULTIMATE DISPOSAL
                                                      275
-------
the use of traditional proven technological treatment approaches.
The wastes generally have been comingled. The physical properties
range from liquids and sludges to significant quantities of con-
taminated soil and groundwater. The broader the range of chemical
composition, the more limited  the treatment  options. Therefore,
the majority of this material will not fit into the present technical
treatment scenario.
  The economics  of the closure of large impoundments are also
prohibitive. Typical closure  cost ranges are as follows:
COST ELEMENT                              COST ($/yd3)
Secure Landfill Disposal                                50-100
Transportation                                        10-50
On-Site Handling                                        5-20
Site Restoration                                         5-20
                                                     70-190
The above costs do not include assessment and engineering. Use of
higher technological  approaches  for off-site  or on-site methods
(slurry walls, sheet piling, etc.) often are significantly more expen-
sive than the above range. Based on the above cost, closure of a 30
acre impoundment with 15 ft of organic sludge waste could range
from $50,000,000  to $150,000,000.
   The following key points illustrate the present dilemma being
faced in the cleanup of waste sites:
•Tremendous  quantities of historic hazardous organic waste are
  currently stored  in  an  extremely large  number of uncontrolled
  waste sites
•The economic and technical reality of available closure options
  prohibit most disposal options with the  possible exception of se-
  cure landfill
•The current direction of the U.S. land disposal policy could soon
  eliminate secure  landfill as an economically viable closure option
  for the vast majority of historic organic  waste sites
   Therefore, it can  realistically  be  assumed that under RCRA
Chapter  Two  little progress can be  made toward addressing the
historic waste  sites in this country without the development of a
new generation of on-site closure methods  that provide a signifi-
cant increase in environmental security and can be implemented at
a fraction of the present closure costs.
ON-SITE CLOSURES
   Economics and current waste disposal technology will not en-
courage the closure of the historic waste sites under RCRA Chapter
Two. Waste migration from the present uncontrolled storage con-
ditions is continually expanding the total volume of contaminated
materials through contamination of air, surface water, subsurface
soil and groundwater. As a  result of these pressures, the state and
federal regulatory agencies are re-assessing site closure regulations.
   Most closure methods are based on surface or subsurface con-
tainment barriers. The waste, however, continues to be exposed to
the same hydrodynamic environmental  forces as in the case of
secure landfills but without the design advantages of secure land-
fills. Since they are located  on all kinds of geological formations,
the integrity and useful life of the containment method can be ex-
pected to be much less than  secure landfill.
  The above ground closure method to be discussed in the remain-
ing sections of this paper has successfully addressed the problems
associated with typical containment approaches and can be ex-
ecuted at a fraction of the traditional closure methods. The above
ground approach differs from traditional containment methods in
the following ways:
•The above ground  method utilizes  high volume waste handling
  techniques  developed by waste disposal firms during the  first
  chapter of RCRA. Use of civil construction methods and special
  pumping equipment allows the economical bulk handling, manip-
  ulation and exhumation of waste at  large hazardous waste sites.
•The above ground  method uses waste solidification processes
  that were also developed from operating  experience during RCRA
  Chapter One. The waste solidification  processes allow the his-
  toric waste to be  compacted into a load bearing material.
•The solidification and bulk handling capability allows the use of
 traditional civil engineering  methods  to  design  above ground
 closures that effectively address the environmental hydrodynamic
 forces operating against traditional landfills and on-site contain-
 ments.

EVOLUTION AND DESIGN OF
THE ABOVE GROUND CLOSURE
  The above ground concept can be used on old impoundments as
well as for the design of future secure landfills. This concept is an
example of the benefits that have resulted from the waste disposal
experience under the first chapter of RCRA. The high volume bulk
waste handling and  solidification methods  developed for new
secure landfill operation and the study of landfill failures provided
new insights into the design of safer, longer life hazardous waste
structures.  This information along  with actual field experience
from early  closure work at older waste sites led to the following
observations:
•Organic waste impoundments exposed to the environment for
 several years generally contain 20% to 30% solids. The solids and
 liquids are unique to each system and are  continually interacting
 with the environment: rainfall,  sunlight, wind,  soils, climate,
 etc. Water is present in various states (entrained,  layers, natural
 emulsions, suspensions, solutions, etc.).
•Organic waste sludge dewatering to levels much  below 50% is
 seldom possible.
•A  pozzolanic reaction with portland cement or cement kiln flue
 dust and the water present in the organic waste sludge will yield a
 "soil like" load  bearing  material in approximately 75%  of the
 impoundments examined  to date.
•The ability to convert organic waste sludges to a load bearing
 "soil like" consistency allows the use of conventional earth mov-
 ing equipment for the handling, placement and compaction of
 waste.
•Civil engineering concepts can be applied to solidified waste ma-
 terial for the design of stable above ground compacted and formed
 shapes.
  The basic advantage of an above ground compacted shape versus
below ground containment approaches is shown in Figure 1. In the
                  lift
                   ijlil
      ABOVE  GROUND  CLOSURE
                                          BELOW GROUND
                                          LANDFILL
                          Figure 1
                  Hydrodynamic Comparison
 276
          ULTIMATEDISPOSAL
-------
                                       IASS
                                        TOPSOIL
                                           IP ACTED CLAY
 GRAVITY FEED
   LEAK
 DETECTION
  SYSTEMS
GRAVITV FEED
 INFILTRATE
 DIVERSION
  SYSTEM
     UNCONTROLLED MEDIUM
                                        COMPACTED CLAY
                           Figure 2
            Schematic—Above Ground Closure Concept

below ground approach,  the hydrodynamic forces of gravity and
water are constantly working against the integrity of the structure.
Because of these forces, landfills are designed with the assumption
that leachate (water  that has leached through the waste) will be
generated; therefore, various liners and removal systems are incor-
porated to  protect or minimize damage  of the  system by the
leachate. When failure occurs, the exit is to the uncontrolled soil-
groundwater medium. Since few current on-site containment land-
fills are able to incorporate the internal lining and leachate protec-
tive systems associated with landfills and the above ground closure
concept, they are certain to succumb to the natural hydrodynamic
pressures on the system.
  The lag  between failure and  detection can be significant with
respect to both time and cost of remediation. Since detection of
failure in the below grade system is documented by contaminated
groundwater, serious environmental damage and waste volume ex-
pansion  may occur  prior  to  detection.  Even  when  technical
remedial methods are available, costs of exhuming waste, below
grade site repair and addressing expanded contamination in the un-
controlled medium are very expensive.
  The above ground illustration (Figure 1) shows how the natural
hydrodynamic pressures  can be controlled and isolated  from the
waste. Since the  structure is above ground, its shape can  be de-
signed to remove rainfall or permeate from the system. Again the
shape along with the design of internal conduits allows the use of
gravity to redirect any water that penetrates the structure.  Since the
entire system is above ground, a leak detection system can also be
incorporated to monitor both the top and bottom liners.
  Another illustration of how the leak detection system  of the
above ground approach prevents both the time lag and substantial
contamination  of the uncontrolled medium associated  with the
failure of a below grade system is given in Figure 2.
                       2ND LINER
                       STRUCTURAL
                       SUPPORT

                  WALL FUNCTIONALITY
                  AREA: RUNOFF
                  COLLECTION LINER
                  DETECTION SYSTEM
                  MOTION SENSORS
                  STRESS MONITORS
                  GAS VENTS

                  BASE PAD
                  IMPERVIOUS LOAD-
                  BEARING MATERIAL

-Y
/



  Failure of the above ground closure is the loss of integrity or a
leak in either the upper liner or the lower liner. The gravity feed in-
filtrate diversion system eliminates continual head pressure on the
upper liner and significantly lowers the probability of water break-
ing down or penetrating the upper liner. Should the upper liner  be
damaged or fail, the water will leach through the waste to the inter-
nal detection system. Since the above ground system is designed to
have no leachate generation, any effluent from either leak detection
system is an immediate notice that failure has occurred.
  Equally important to early detection and non-contamination  of
the surroundings is the ease of remedial work on an above ground
structure. The structure is easily accessible from the top and sides.
Since initial failure will be in the top lining, corrective repairs can
be done quickly and economically. Simple design methods can  be
incorporated in the leak detection system to pinpoint the sector
where  failure has  occurred. Contrast this to exhuming the waste
material of a below grade containment, locating  and repairing the
failure and handling the contaminated soil and groundwater.
  With proper maintenance, the integrity of the internal lining
system is the probable limit to the useful life of the above ground
system. The wet interface between the waste and liner typical  of
most secure landfill designs can result in accelerated deterioration
of the liner. Therefore,  a key concept in the above  ground ap-
proach is the conversion of the waste to a dry compactable form
and the provision for a protective layer of sand or other construc-
tion medium between the solidified waste material and the liner.
  By eliminating a wet interface or any contact with the waste, the
life of a synthetic or clay lining system could last indefinitely. Use
of high density polyethylene resins  for power line insulation has
demonstrated extremely long life under the full range  of exposure
to sun and climatic fluctuations. Since the above ground design
eliminates sunlight exposure, climatic fluctuation and contact with
the waste, the most severe pressure on the liner becomes the contact
with water in the  diversion systems. Therefore,  the lifetime of a
properly maintained above ground closure could be indefinite.
ECONOMICS  OF ABOVE GROUND CLOSURES
  Typical above ground closures can be installed for 25% to 50%
of the off-site alternative. The cost advantages result from:
•The elimination  of transportation and disposal  fees associated
 with off-site disposal
•Conventional  simple civil methods can be executed  by a large
 number of general construction firms as compared  to  specialty
 slurry wall contractors,  etc.
•High volume  waste handling methods shorten project time. Ex-
 humation and solidification rates  of  1,000-3,000 ydVday are
 easily attainable

                  GROUND COVER/CLIMATE  APPROPRIATE MATERIAL
                     CLAY/PROTECTIVE MATERIAL CAP
                         SAND - INNER LINER PROTECTION LAYER
                                                                                               SURFACE RUNOFF PROTECTION
                                                                                                        LAYER
                                         INNER LINER WASTE
                                           COMPATIBLE
                                         SAND INNER LINER
                                         PROTECTION LAYER
                                         SOLIDIFIED-COMPACTED
                                          LOAD-BEARING WASTE
                                        GRAVITY FED LINER INTEGRITY
                                             DETECTION SYSTEM

                                                            Figure 3
                                                    Rollins Environmental Vault
                                                                                              ULTIMATE DISPOSAL
                                                                                                                            277
-------
                                       CONTAINMENT VAULT
                             Figure 4
           Above Ground Closure—Hillside Site Adaptation

   Project cost ranges from $25.00/yd3 for a land intensive design
with  inexpensive on-site  clay  or a waste  material  requiring  no
solidification (such as contaminated earth), to S100.00/yd3 for dif-
ficult to handle waste requiring solidification and construction of
land efficient concrete  wall  structures with extensive  monitoring
and control systems. Obviously, the scale of operation also has a
significant impact on the project economics.
   A high security, long-life design approach to the above ground
concept is shown in Figure 3. This schematic is of the  Rollins En-
vironmental Vault (patent applied for) which incorporates all the
design  features outlined earlier  and  provides for  additional
monitoring and security for more difficult waste problems.
   The ease in adapting  specific site and waste considerations to an
above ground closure design  is illustrated in Figures 4 and 5, which
are based on an actual project to accommodate up to 10,000 yd3 of
organic waste from a  PCB  lagoon closure. The concept, as il-
lustrated in Figure 3, was adapted to  a hillside site with all struc-
tural components remaining  above grade, thereby maintaining the
above  ground  advantages while maximizing  the efficiency and
asthetics of site land use. Details of the separate systems for surface
                                                           water  runoff,  infiltrate diversion  systems  and  leak  detection
                                                           systems for both  top and bottom liners are shown in Figures 6
                                                           and 7.
                                                             The project detailed in Figures 4 through 7 was estimated to cost
                                                           $70-$80/yd3 for a  solidified PCB sludge. This cost included:
                                                           •Detailed site assessment and evaluation
                                                           •Detailed engineering design
                                                           •Preparation, submittal and USEPA approval of closure plan
                                                           •Groundwater monitoring system for new facility
                                                           •Project execution of all construction,  waste placement, closure
                                                            and landscaping of the site
                                                             The off-site disposal  alternative excluding site restoration was
                                                           approximately $192/yd3 of waste transported to a PCB approved
                                                           landfill.

                                                           FUTURE RECOVERY AND TREATMENT OPTIONS

                                                             Most land disposal and containment options are, at best, long
                                                           term storage as opposed to true  disposal. Present  treatment and
                                                           recovery methods do not exist for the large comingled waste masses
                                                           present in older impoundments. The above ground closure method
                                                           is the only land disposal or storage method that approaches a 100%
                                                           level of containment security over a very long period. Performance
                                                           of routine maintenance should allow the structures  to last in-
                                                           definitely.
                                                             Future access for recovery or treatment of the waste is a signifi-
                                                           cant advantage, especially if individual cells are used to isolate
                                                           specific waste materials that have not been comingled with a broad
                                                           spectrum  of other  wastes.  For   example,  specific  biological
                                                           organisms are being developed for specific wastes  such as 2,4,5-T,
                                                           dioxin wastes, etc. These organisms are very specific in their ability
                                                           to detoxify certain chemicals. The preservation of specific wastes
                                                           will be a major benefit for future biological treatment.
                                                             Comingling of  waste also compounds the resource recovery
                                                           problem. Closure of two large waste impoundments resulted in the
                                                           landfilling of 5,000,000 Ib of manganese from a 90,000 yd3 organic
                                                           waste lagoon and over  $1,000,000.00 worth of mercury from a
                                                           14,000 yd3 lagoon. The comingling of these valuable raw materials
                                                           in a large landfill compounds or eliminates future recovery options.
                                                           Who knows the value of these rare metals 50 years from now. Had
                                                           these waste materials been segregated in an above ground cell, the
                                                           opportunity for future treatment and  recovery options would be
                                                           much more attractive.
                                                                                         ABOVE GROUND VAULT SCHEME

                                                                                            "       >"      ,'(! I P-, <
Compacted Clay Base & Compacted Clay Cap
1. A minimum thickness of 3.0 (1 is required for the in-place, compacted clay base and clay cap.
2. Cla> Soils forming the cap and base will be placed in lifts not greater than 9 in. loose thickness.
  The clay will be compacted to a unit dty weight of at least 95 percent of the maximum dry density
  indicated by ASTM D-698, the Standard Proctor Compaction Test.
.1  Clay Soils used for the base and cap will have the following properties:
  -• liquid limn greater than 30
  •a plastiaiy index greater than 15
  -the percentage of material passing a No. 200 mesh sieve greater than 30
  -an in-plice permeabilit> not greater than 1.0 - ' cm/sec when compacted.
                                                           Leachate Collection System
                                                           1. The leachate collector system will consist of well-compacted, well-graded, free-draining gravel.
                                                           2. The collector system will have a minimum thickness of at least 1.0 ft.
                                                           Sand Drainage Blankets
                                                           1. The drainage blankets will consist of well-compacted, free-draining sand.
                                                           2. The drainage blankets will have a minimum thickness of 6 in.
                                                           Synthetic Liner
                                                           The synthetic membrane liner will have the following properties:
                                                             -a minimum thickness of 30 mils
                                                             -chemically compatible with Compacted fill
                                                             -a permeability of not more than IxlO-' cm/sec.
                                                               Figure 5
                                             Above Ground Closure—Hillside Section Details
278
ULTIMATE DISPOSAL
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     Sand-filled
     Cinder Uiocks
     or Sand it.uts
                                 Synthetic Liner
    Reinforrr-d
   ConcreU- «.ill
                               DRAINAGE MONITORING DETAIL

                                     (i    1     ?    1 Fec-l
                            Figure 6
          Above Ground Closure—Detection System Details
SUMMARY

  In summary, the above ground closure method offers the follow-
ing advantages over  conventional surface  and  subsurface  ap-
proaches:
•There is essentially zero risk of contaminating the uncontrolled
 medium of soil  and groundwater because  the entire system  is
 above  ground, with buffer  zones and failure  detection systems
 between the waste and groundwater
•Easier access for maintenance
•Top, walls and all effluent can be visually inspected
•Provides  opportunity  to  detect any  errant  leachate  prior to
 groundwater contamination
•Provides easy access for future manipulation of the waste for re-
 source recovery and new treatment methodology
•Versatility—the above ground cells  can be used over low  and
 high water tables and over clay and non-clay substrata
 •Their  design is in harmony with  environmental, hydrodynamic
 pressure; therefore,  no leachate collection  system is  necessary
 for pumping leachate up from the  bottom of a landfill
•Rick of groundwater contamination is reduced  in the event of
 geological action such as  fault slippage, slumping or any other
 massive earth movement.  Remedial action is easier, quicker and
 less costly
  The  above advantages,  along with  the long-term  security,
economics and  widespread application make  the above ground
closure  approach a powerful new tool for addressing many of the
pressing hazardous waste problems in this country.

REFERENCES

 1.  Miller, D.W., (Ed.), "Waste Disposal Practices and Their Effects on
    Ground Water."  USEPA, Report  No. E.P.A.-660/2-74-001,  Final
    Report to Congress, 1977.
 2.  "Notice of Proposed Changes in Regulations of the Department of
    Health  Services  Regarding  Hazardous Waste  Land  Disposal Re-
    strictions (R-32-82)." Department of Health Services, State of Cali-
    fornia.
 3.  For  detailed  review of solidification materials and processes, see
    Toxic and Hazardous  Waste Disposal,  Volume 2, "Options for Sta-
    bilization/Solidification".  R.B. Pojasek,  Ed.,  Ann Arbor  Science
    Publishers, Ann Arbor, MI,  1981.
 4.  Morrison, Allen,  "Can Clay Liners  Prevent  Migration of Toxic
    Leachate?" Civil Engineering, ASCE, July 1981, 60-63.
 5.  Landreth,  R.E., Project Officer. "Design and Construction of Covers
    for Solid Waste Landfills". EPA-600/2-79-165, August 1979.
 6.  Haxo, H.E., Jr., "Effects  of Liner Materials of Long-Term Exposure
    in Waste Environments".  Paper read at 8th Annual Research Sum-
    posium, Land Disposal, Incineration and Treatment of Hazardous
    Waste, USEPA, Ft. Mitchell, KY, Mar. 1982.
 7.  Julien, P.A., "Land Burial of Hazardous Wastes in Clay-Lined Land-
    fills  in Illinois: A Permanent Economic Solution?" Paper presented
    at 1981 Annual Meeting of  American  Geographers, San Francisco,
    CA.
 8.  Water budget models, or, water balance models, are generally cov-
    ered in climate, engineering, and hydrology texts.  For detailed ex-
    planation, see: Thornthwaite,  C.W. and Mather, J.R., The Water
    Balance, 1955. Volume 3, Number 1,  Publications in Climatology,
    Centerton, NJ,   and J.R. Mather,  The Climatic Water Budget in
    Environmental Analysis. Lexington Books,  D.C. Heath and Com-
    pany, Lexington, MA, 1978.
 9.  Carter,  D.B., et al.. Applications of the  Water Budget in Physical
    Geography. Publications in  Climatology,  Centerton, NJ,  24, 1973,
    and  J.R.  Mather, Climatology: Fundamentals and Applications,
    McGraw-Hill, New York,  1974.
10.  Brown,  K.W.  Landfills of the Future. Paper available from Soil and
    Crop Science Department, Texas A  & M University, College Station,
    TX.
                                                                                            TOP-OF-SLOPE DRAINAGE DETAIL
                                                              Figure 7
                                         Above Ground Closure—Surface Water Diversion Details
                                                                                                 ULTIMATE DISPOSAL
                                                            279
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SAFETY PLAN FOR CONSTRUCTION OF REMEDIAL ACTIONS
                                         DONNA LYNN BAREIS, Ph.D.
                                             Science Applications, Inc.
                                                  McLean, Virginia
                                                  LARY R.  COOK
                                                  GENE A. PARKS
                                          U.S. Army Corps of Engineers
                                                  Washington,  D.C.
 INTRODUCTION
   The USEPA and the Army Corps of Engineers have an inter-
 agency agreement for the Corps of Engineers to manage Super-
 fund design and construction contracts and provide other technical
 assistance as requested in support of remedial action at hazardous
 waste sites. The Corps of Engineers primary responsibilities under
 this agreement take place when the USEPA has determined  that
 Federal cleanup is appropriate (as opposed  to remedial measures
 managed by states or private entities), and the USEPA has selected
 the remedial alternative to be implemented.  The Corps then con-
 tracts for actual design and construction work and serves as the
 contract manager, reviewing designs and monitoring construction.
 A detailed  description  of the Corps of Engineers management
 plan and contracting processes for these activities was presented
 last year at the  Third  National Conference on Management of
 Uncontrolled Hazardous Waste Sites.1
   A crucial part of successful remedial actions is  insuring ade-
 quate safety and health precautions to protect both on-site em-
 ployees and off-site populations. Construction of remedial meas-
 ures often involves extensive physical disturbance of hazardous
 material; this creates hazards in addition to those normally encoun-
 tered  in site investigations. Another factor increasing the likeli-
 hood  of a serious accident during construction activities involving
 hazardous waste is that construction workers  often lack the special-
 ized training given to site investigation teams. For these and other
 reasons, it became evident that existing safety manuals written to
 cover hazardous waste  site investigations2 would not be  directly
 applicable to construction activities. Therefore, the Corps of En-
 gineers has  developed guidelines for design contractors to  prepare
 site-specific construction safety plans.

 CORPS USE OF THE SAFETY PLAN
 FOR SUPERFUND SITES

   Safety planning is considered an  integral part  of the remedial
 action design process. Corps guidance to design contractors in-
 cludes the safety plan presented here and a sample construction
 contract specification containing minimum  safety and health re-
 quirements  at hazardous waste sites. The design contractor pre-
 pares  a site-specific safety  plan by using the information he has on
 the site and the nature of the remedial action in order to address
 all the topics in  the outline. The design contractor also expands
 the construction contract specifications to include additional occu-
 pational  health  and  safety requirements (identified in the safety
 plan)  that will be the responsibility of the  construction contrac-
 tor. Both the site-specific safety plan and the contract specifica-
                                                    tions are reviewed by Corps' industrial hygienists and occupational
                                                    health specialists.
                                                      From a health and safety viewpoint, the site-specific safety plan
                                                    is  slightly more comprehensive than the construction contract
                                                    specifications. The safety plan  outlines Federal, State, local and
                                                    contractor organizational responsibilities for implementation of the
                                                    safety requirements, whereas the contract specifications contain
                                                    only those elements which are the responsibility of the construc-
                                                    tion contractor.  The construction contractor prepares  an Acci-
                                                    dent Prevention Plan which describes his methods for meeting the
                                                    contract safety requirements. The net effect of all these documents
                                                    is that all on-site personnel during construction must comply with
                                                    the provisions of both the site specific safety plan and the Corps of
                                                    Engineers. "Safety and Health Requirements Manual", a manual
                                                    which covers standard safety practices on all construction pro-
                                                    jects.1
                                                      Each of the next 11 sections  is devoted to a major element in
                                                    the Corps of Engineers Safety Plan. The plan is in outline form,
                                                    so each section will begin with an element of the outline followed
                                                    by a brief narrative discussion of the components of that element.
                                                    THE SAFETY PLAN
                                                    Background

                                                      A listing of chemicals  identified at the site and a discussion of
                                                    the safety  and  health implications  of  each,  to  include acute,
                                                    chronic and delayed effects (mutagenicity, carcinogenicity, terato-
                                                    genicity, sensitization  reactions), radioactivity, flammability and
                                                    explosibility. A  fact sheet shall  be prepared in layman's language
                                                    outlining possible adverse consequences of working on the site if
                                                    proper safety procedures are not observed or if protective equip-
                                                    ment fails or is worn improperly.
                                                       The first section amounts to a summary of what is known about
                                                    the chemicals at a particular site. The Corps of Engineers recog-
                                                    nizes that in at  least some, and probably most, instances  this list
                                                    will be incomplete. The  prepared safety plan should not just ex-
                                                    plain the extent of the knowledge available; it should also indicate
                                                    the amount of ignorance  or uncertainty which exists concerning the
                                                    possible hazards.
                                                       Site investigations and a review of the site history will normally
                                                    identify major components of the hazardous waste present. Iden-
                                                    tification of safety problems (explosivity, flammability) associated
                                                    with these compounds is  critically important. Such hazards are too
                                                    often neglected  because  of a  preoccupation with toxic  effects.
                                                    Whenever possible, the health effects discussed should be limited
                                                    to those supported by data which have been critically reviewed.
  280
SITE SAFETY
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  The "fact sheet" prepared under this section is later used as part
of the training given to all on-site personnel. It should supplement
the NIOSH Worker Bulletin on "Hazardous Waste Sites and Haz-
ardous Substance Emergencies" which was  prepared to  provide
preliminary  guidance  to protect the health  of hazardous waste
workers.4
Site Location

•Vicinity Map
•Perimeter identification
•Existing geographic features, public utilities and/or private  im-
 provements
•Security measures
  This general information on the site geography is obviously not
just related to health and safety, but it is necessary in order to pre-
pare the site layout and determine where it is most critical to mon-
itor possible migration of contaminants off  site.  Some examples
of the pertinent information  to be obtained are:  (1) the location
of the nearest residence of development; (2) whether or not a school
or playground is nearby; (3) potential for contaminant runoff into
a body of water; and (4) possible contamination of food crops. The
usual necessary security measures  consist of  restricting public
access to the site through guards  and fencing. The purpose of
security precautions is primarily to protect public health and safety
in addition to preventing interference with the construction opera-
tions.
Site Layout

  Every work site will have three basic areas—Exclusion, Contam-
ination Reduction and Support. The Exclusion Area will be divided
into up to three zones as determined by the degree of hazard pres-
ent. A maximum of three zones exists because Zone D may not be
included if there is a requirement for Zone A.  When established
standards or adequate site  information are not  available, a mini-
mum of Zone B will be established. All items listed in Paragraph
A & B below will be displayed on a site map.
A. Determination of areas
    1. Exclusion Area. Criteria for determining zones are listed be-
       low. Protective equipment may be specified for workers in
       the Exclusion Area on the basis of location or operation or
       both.
       a. Zone A. Maximum respiratory, skin and eye protection
         is required.
         (1) Where atmospheres have the potential to be immed-
             iately dangerous to life and health (IDLH)
         (2) Atmospheric  sampling indicates concentrations cap-
             able of being absorbed through the skin or eyes in
             toxic quantities or atmospheric concentrations  of
             corrosives exist which could destroy skin.
         (3) Skin contact with extremely hazardous substances
             (known or suspected to be on site) is possible.
       b. Zone B. Maximum respiratory  protection required and
         low probability of skin contact.
         (1) Where atmospheric concentration  of contaminant is
             known and the concentration  of contaminants is
             greater than the protection factor for air purifying
             respirators or atmosphere is oxygen deficient  (less
             than 19.5% oxygen).
         (2) Contaminants absorbed through or toxic to skin are
             not present.
         (3) Safeguards preclude splashing of contaminant on the
             skin or in eyes of individuals.
       c. ZoneC.
         (1) Air contaminant levels are being monitored and do
             not exceed the protection  factors of air purifying
             respirators.
         (2) The contaminants have good warning properties.
         (3) The contaminants are not known  to be absorbed
             through or to be toxic to the skin.
         (4)  A reliable history of prior entry exists without acute
             or chronic effects on personnel.
      d. Zone D. Can only be included inside the Exclusion Area
         if there is no Zone A or requirement for Level A pro-
         tective equipment,  and if there is no requirement for
         Zone B or Level B protection other than a restricted
         area with an oxygen deficient atmosphere.
         (1)  No known airborne hazards present and there is lit-
             tle or no potential for release of an airborne  con-
             taminant.
         (2)  Work function precludes splashing.
   2. Contamination Reduction Area. Provides area to prevent
      the transfer of contaminants from the Exclusion Area to the
      Support area, including personnel showers, change rooms,
      equipment decontamination.
   3. Support Area. The outer area, considered to be clear  of
      contamination, including vehicle parking, administrative
      areas, etc.
B. Access to existing roadways and any associated problems with
   access and egress to the site.
  The Corps of Engineers has adopted the plan and  terminology
for a site layout which has been standardized and promulgated by
the USPEA  Environmental Response Team in Edison, NJ; these
USEPA recommendations have been distributed as the "Interim
Standard Operating Safety Guides".5 A "Zone" inside the Exclu-
sion Area does not have to be a geographic area; it is also possible
to classify a particular job or work operation as "Zone B". When-
ever possible  (and it usually is not), zone classifications should be
based on the amounts and types of atmospheric contaminants
present  using good industrial hygiene practices and  established
standards such as  the current threshold limit values (TLVs) for
occupational exposure.6 In the absence of sufficient information to
use such standards, zone classifications can be made on the basis
of total  gas/vapor readings as initially suggested by Turpin of the
USEPA Environmental Response Team7 and subsequently pub-
lished in the "Interim Standard Operating Safety Guides". These
criteria are:
Zone/Level A: 500-1000 ppm above background
Zone/Level B: 5-500 ppm above background
Zone/Level C: 0-5 ppm above background
  The zone designation determines the level of personal protective
equipment to be worn; a description of each level follows in the
next section.

Personnel Protection—Personal Protective Equipment

  Personal protective equipment for each zone and area will be
determined. Protective gloves, boots and suits shall be of material
resistant to the chemicals present on the specific site. All respira-
tory protective equipment must be approved by NIOSH or MSHA.
   1. Level A Protection.  Required in Zone A.
      a. Positive-pressure  demand type,  air-supplied breathing
         apparatus
      b. Fully encapsulating suit
      c. Outer and inner gloves (both chemical-resistant)
      d. Steel toe and shank boots
      e. Hard hat (under suit)
      f. Options as required:
         (1)  Coveralls
         (2)  Long cotton underwear
         (3)  Disposable protective suit, gloves and boots, worn
             fully encapsulating suit
   2. Level B. Protection. Required in Zone B.
      a. Positive pressure demand, air-supplied breathing appa-
         ratus
      b. Chemical-resistant clothing, long  sleeves,  one or two
         pieces, requirement for hood to be determined
      c. Outer and inner gloves (both chemical-resistant)
      d. Steel toe and shank boots
      e. Hard hat
                                                                                                       SITE SAFETY
                                                                                                                           281
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      f.  Options as required:
         (1) Coveralls
         (2) Disposable outer boots
   3. Level C Protection. Required in Zone C.
      a.  Full-face piece, air-purifying, canister-equipped respir-
         ator
      b. Chemical-resistant  clothing,  long sleeves, one or  two
         pieces, requirement for hood to be determined
      c.  Gloves
      d. Steel toe and shank boots
      e.  Hard hat
      f.  Options as required:
         (1) Coveralls
         (2) Inner chemical-resistant gloves
         (3) Disposable outer boots
         (4) Escape mask
   4. Level D Protection. Required in Zone D and in the Con-
      tamination Reduction Area
      a. Coveralls
      b. Leather or chemical-resistant boots or shoes, steel toe
         and shank
      c. Hard hat
      d. Options as required:
         (1) Gloves
         (2)  Disposable outer boots
         (3) Safety glasses or chemical splash goggles
         (4)  Escape mask or respirator
  Three levels  of personal protective equipment are based on those
in the USEPA "Interim Standard Operating Safety Guides", but
there are a few  differences, two of which are notable. First, a
hard hat is always required on  a construction project; it is not an
option. The second difference  is that a requirement for supplied
air does not necessarily dictate use  of a self-contained breathing
apparatus (SCBA). Positive pressure manifold-type air line systems
may also be acceptable under some circumstances if the use of such
a system will facilitate the construction operations and not create
additional safety hazards.
  Fortunately, a requirement for Level A equipment is extremely
rare  (the only  example on a Corps project to date was for entry
into  a buried tank),  and Level B has not had to be used extensive-
ly. Hard labor is  difficult in Level B and nearly impossible in Level
A. When feasible, the first priority during any remedial action at
a hazardous waste site should  be to control  or eliminate major
hazards in  order to reduce subsequent requirements for personal
protective equipment.
Personnel Protection—Medical Surveillance

  Establishment  of medical requirements and special tests for
chemical exposure, if available.  Frequency of exams and tests will
be specified.
   1. Preemployment medical examinations
   2. Periodic medical examinations
   3. Pretermination medical examinations
C. Work-rest  scheduled for each level of protective  equipment
   considering the expected climate.
D. Heat or cold stress monitoring requirements and procedures.

  The purpose of this section  is to identify  any additional  med-
ical tests and examinations which may be required over and above
the minimal requirements in  the Corps of Engineers guide specif-
ication and "Medical  Surveillance Handbook."1 The minimal re-
quirements include a medical examination and certification  as to
fitness for employment on the job prior to participation in on-site
operations, at  the conclusion of the work, and/or at 12-month
intervals during the  progress of the operations. The examinations
must include: medical history,  work history, vital signs, physical
examination of all major organ systems, audiogram, vision screen-
ing,  chest X-ray  (normally only once every four years), EKG for
individuals over 35, CBC with differential, blood chemistry screen-
                                                       SMAC 23 test survey,  urinalysis and  a pulmonary function test
                                                       that includes Force Expiratory Capacity at  1  sec  (FEV10) and
                                                       Forced Vital Capacity  (FVC). Depending on the site and work
                                                       operations to be performed, some additional tests commonly rec-
                                                       ommended are: full SMAC series (SMA 32), blood and/or urine
                                                       heavy metals, an exercise stress test and EKG and blood cholines-
                                                       terase activity. During the course of the project, any employee who
                                                       has a  time-loss illness or injury must be certified fit to return to
                                                       work by a physician before resuming his duties.
                                                         The requirements for personal protective equipment may create
                                                       heat stress. Heat stress symptoms may occur at any level of protec-
                                                       tion, but they are especially common in Levels A and B. The safe-
                                                       ty plan should consider the expected climate and suggest monitor-
                                                       ing ambient  temperature and employee heat stress (pulse, body
                                                       temperature and water loss) above a certain ambient temperature.
                                                       Corps construction contractors are usually provided with the Army
                                                       guidelines for personnel wearing a military M3 lexicological suit (a
                                                       two-piece, hooded, butyl rubber suit).
                                                       Ambient Temperature

                                                       Above 90 degrees F
                                                       85-90 degrees F
                                                       80-85 degrees F
                                                       70-80 degrees F
                                                       60-70 degrees F
                                                       50-60 degrees F
                                                       30-50 degrees F
                                                       Below 30 degrees F
Maximum Wearing Time, (hr)
1/4
Vi
1
                                                       Contractors  should develop their  own work-rest  schedules for
                                                       Levels A, B and C, using this information for guidance.
                                                       Contaminant Monitoring
                                                         Identification of  specific  methods, frequency  and locations.
                                                       When available, NIOSH approved methods must be used.
                                                       A. Personnel Monitoring (breathing zone samples)
                                                          1. High hazard operations
                                                          2. Hazardous site areas or zones
                                                       B. Area Monitoring
                                                          1. Atmospheric concentrations of contaminants
                                                          2. Oxygen' content
                                                          3. Explosive atmospheres
                                                          4. Radioactivity (primarily beta and gamma emissions)
                                                         Construction work operations which involve handling of haz-
                                                       ardous waste require continuous contaminant monitoring using
                                                       direct-reading field instruments. Site conditions may change rapid-
                                                       ly as a result of construction activity; excavation  may bring haz-
                                                       ardous wastes to the surface, drums may be accidentally ruptured
                                                       and tanks may accumulate explosive concentrations of vapors
                                                       when emptied. Continuous monitoring indicates when the level of
                                                       personnel protection needs to be adjusted, or when an area of the
                                                       site must be evacuated.  Contaminant monitoring is usually accom-
                                                       plished using organic vapor analyzers or photoionization detectors,
                                                       but these devices are not sufficient at sites where hydrogen  cya-
                                                       nide or hydrogen sulfide could be generated. Drawer tubes should
                                                       be used to detect these compounds.
                                                         Air monitoring stations for collection of air samples for subse-
                                                       quent analysis  should  also  be  provided in addition to  portable
                                                       direct-reading  equipment. This  serves two purposes. First, ab-
                                                       normally high  readings on the  field instruments can  be confirmed
                                                       and the nature of the principal contaminants identified. Although
                                                       the results are obtained later, it is still a useful check to determine
                                                       if appropriate  action was taken, the likely nature of future  inci-
                                                       dents and whether or not personnel need to be examined for symp-
                                                       toms of chemical exposure.  The second purpose  is monitoring of
                                                       the site perimeter to insure  that off-site populations are not ad-
                                                       versely affected by construction activities.
 282
SITE SAFETY
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Decontamination

A. Personnel decontamination procedures
B. Equipment decontamination procedures
C. "Scrap" decontamination procedures
  The extent of the decontamination necessary for personnel and
equipment is highly site-specific. For personnel, the extent of de-
contamination increases as the level of protection increases.  Per-
sonnel assisting  in decontamination should be in the  next lower
level of protection from the person being decontaminated. Basic
elements of a personnel decontamination station include an equip-
ment drop area, solutions for outer garment washdown and rinse, a
place to remove outer clothing for additional decontamination or
disposal,  a place to remove  respiratory protection devices and,
finally, an area to remove remaining clothing for laundering or dis-
posal before entering the shower.' Initial equipment drop and outer
garment  washdown occurs just inside the Exclusion Area; the re-
maining  operations are in the Contamination Reduction Area,
located in a place which is normally upwind of the Exclusion Areas.
  Decontamination of trucks and  other construction  equipment
can involve  simply  washing down the tires  and undercarriage or
can require steam cleaning  or sand blasting. In truly extreme cases,
equipment may  be buried  on site. The minimum Corps of Engi-
neers requirements for an equipment decontamination  facility are
a high pressure  wash area for equipment and vehicles and a steam
180°F hot water for use after the mud and/or dirt has been cleaned
from the equipment. Equipment maintenance requiring contact
with ground soil must be done in a special "clean area" set aside
for that purpose. Before removing equipment from the site at the
conclusion of the project, fluids and filters should be changed and
the old materials should be disposed of as hazardous waste.
  All wash water used for personnel or equipment  decontamina-
tion must be contained and collected in a segregated  system for
subsequent treatment and disposal as hazardous waste.
Prevention of Contamination Spread
  Identification of specific methods, frequency and location for
monitoring. USEPA approved methods should be used where ap-
plicable.
A.  Waste water
B.  Soil
C.  Groundwater/Surface water
D.  Meteorological Monitoring
  Spills  or releases of hazardous materials are not merely poss-
ible, but probable during construction activities, requiring special
attention to specific spill control procedures. As mentioned in the
previous section, waste water is segregated for  disposal as  haz-
ardous waste. Liquid spills can be controlled by adsorbent ma-
terials kept  close to active work areas. Both  the  adsorbent and
surrounding soil are contained for  subsequent disposal. Erosion
and storm water run-off control measures are a part of the remed-
ial action design in order  to  prevent contaminant migration  dur-
ing construction.
  Continuous meteorological monitoring  is required  during  all
Corps remedial  actions at hazardous waste  sites. This determines
the downwind locations for air monitoring stations and also the
likely dispersion of airborne contaminants in case of a hazardous
substance release. Other kinds of environmental monitoring involv-
ing off-site migration of contaminants (particularly groundwater
monitoring) are not normally part  of Corps Superfund construc-
tion activities; at most sites the USEPA provides for this under a
separate contract.

Communications
A. Communications on site compatible with protection  equip-
   ment used
B. Communications with on call emergency equipment
  Two-way  radio communications  are needed to  link  all active
work areas  with the office and support areas.  Two-way radios
should also be provided to all personnel wearing Level A or Level
B protective equipment. Although radio communication with local
emergency response  organizations (fire  and police  departments,
ambulance service, hospital) can be arranged if desired, it is usual-
ly sufficient to post the necessary phone numbers next to all pro-
ject phones and be certain that someone near a  phone has radio
contact with the rest of the site at all times.

Emergency Procedures

  Establishment of protocols and equipment  necessary for emer-
gency response procedures for occurrence of A through E below in
each of the site areas and zones.
A. Chemical Exposure
B. Personal Injury
C. Potential or actual fire or explosion  (including criteria  for
   determining a hazard exists)
D. Environmental accident
   1.  Spill control procedures
   2.  Information resources for emergency response
   3.  Reporting requirements
E. Radiation
   1.  Criteria for determining hazard
   2.  Regulatory agency requirements
F.  Identification of local and state emergency response personnel
   required on standby to support activities on site (fire depart-
   ment, police, hospital and emergency room, others).
   1.  Level of expertise available
   2.  Emergency and personal protective equipment available
   3.  Training required for emergency personnel supporting site
       operations
G. Definition of interfaces between the  contractor,  Corps repre-
   sentative, and USEPA On-Scene Coordinator for implemen-
   tation  of the USEPA Community Protection Plan. The Com-
   munity Protection Plan shall be a part of the  Site Specific
   Safety Plan in order to insure adequate contingency planning
   has been done by all Federal, State and local  agencies  in-
   volved.

  Contingency planning to cover possible emergencies on site must
consider all kinds of accidents whether or not they are related to
hazardous materials.  Basic factors to consider are: (1) criteria for
determining an emergency exists; (2) specific  procedures to con-
trol or abate the hazard,  or prevent injury; and (3) who to call
for help or information. This information should  be written down
and conspicuously posted in convenient locations.
  One of the major problems which must be addressed is the hand-
ling of ill or injured persons inside the Exclusion Area. An on-site
employee with a current first aid certification (and wearing appro-
priate protective gear) should administer  immediate treatment and
determine if the employee can be moved and go through decon-
tamination. A handbook  of first aid protocols  for  chemical ex-
posures has recently  been  published as an Army Field Manual;10
a copy of  this book is on-site at all Corps of Engineers Super-
fund remedial actions. Emergency medical  care support must be
prearranged with a convenient medical facility. The staff at that
facility should be aware of the potential  medical  emergencies and
be advised that the patient's clothing and skin might be contam-
inated with specific chemicals.
  An extremely important part of emergency  planning is making
the necessary arrangements with  off-site emergency response per-
sonnel to  provide  support upon request when on-site employees
can not handle the crisis alone. It  is not sufficient just to make sure
the phone numbers  are correct  for  the police  department,  fire
department, ambulance company and poison control  center. Other
issues must be addressed such as whether or  not the fire depart-
ment has the training, equipment and materials  to fight chemical
fires and determining who can and will supply personal protective
equipment for emergency  personnel.  It may be necessary to train
and  equip some local departments that will be supporting  site
operations.
                                                                                                      SITE SAFETY
                                                          283
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  Each site should be carefully evaluated to determine if a cata-
strophic accident  requiring evacuation of  local residents could
occur. Actual evacuation planning is usually done by a state or
local  agency, and it  should  be coordinated  with  the USEPA
Regional Office as well as the construction contractor and other
government representatives, as appropriate. All  parties  involved
in evacuation planning for community protection should  realize
that an evacuation, or even the act of planning one, presents an
enormous public relations problem which could interfere with con-
struction of remedial measures.
Training
  Personnel will have either formal training or prior on-the-job
training  for those  tasks they are assigned to perform. All un-
familiar  operations will be rehearsed prior to performing the ac-
tual procedure.  Additionally,  an on-site orientation session must
be developed covering the following subjects as a minimum.
A.  Health effects and hazards of the chemicals  identified or sus-
    pected to be on site. The  basis for this discussion will  be the
    background information and fact sheet prepared  under Sec-
    tion I.
B.  Personnel Protection
    1.  Use, care and fitting of personnel protective equipment
    2.  Necessity for personnel protection, effectiveness and lim-
       itations of equipment
C.  Decontamination Procedures
D.  Prohibitions in areas and zones
    1.  Site layout
    2.  Procedures for entry and exit of areas and zones
    3.  Use of lunch, break and shower facilities
E.  Emergency procedures as identified in Section IX
F.  Medical requirements, necessity for medical examinations and
    specific tests
  Before proceeding with any construction operations at  a haz-
ardous waste site, all on-site personnel (contractor, subcontractor
and government) should receive site orientation training to famil-
iarize them with the  hazards present,  specific equipment  to be
used, special work procedures and prohibitions required, and what
to do in an emergency. This orientation should supplement, not
replace, prior training in handling hazardous materials and use of
protective gear. It is important that site  workers have both a heal-
thy degree  of respect for the hazards and confidence in their abil-
ity  to work safely.  Experience has  demonstrated that this confi-
dence is usually not developed during a single training session.
  During the construction project, regular periodic safety sessions
should be held  to review problem areas and also call attention to
special hazards associated with each phase of work or change in
operations.
                                                         CONCLUSION

                                                           The outline of a site safety plan which has been presented here
                                                         should not be regarded  as final or totally comprehensive. The
                                                         Corps of Engineers expects revisions as Corps personnel gain ex-
                                                         perience with hazardous waste remedial actions. Most importantly,
                                                         the Corps welcomes comments and suggestions from other haz-
                                                         ardous waste experts in order to improve Corps guidance  for in-
                                                         suring safe implementation of remedial measures.

                                                         ACKNOWLEDGEMENTS

                                                           The authors wish to thank Dr. Stephen Dorrler, Dr.  Joseph La-
                                                         Fornara and  Rodney Turpin of the USEPA Environmental Re-
                                                         sponse Team, and Noel Urban, James Ballif, Dr. George Schloss-
                                                         nagle, John Geiglein, John Dezan and  Frank Bizzoco of the U.S.
                                                         Army Corps  of  Engineers for their helpful comments and dis-
                                                         cussions during the development of this plan.
                                                           The views expressed here are those of the authors and do not
                                                         necessarily represent those of the Army Corps of Engineers or the
                                                         Department of the Army.

                                                         REFERENCES

                                                         1. Gay, F.T., Urban, N.W. and Ballif, J.D., "U.S. Army Corps of En-
                                                            gineers Role in Remedial Response", Proc. National Conference on
                                                            Management of Uncontrolled Hazardous Waste Sites, 1982,414-417.
                                                         2. USEPA, "Safety Manual for Hazardous Waste Site Investigations",
                                                            Office of Occupational Health and Safety, and the National Enforce-
                                                            ment Investigation Center. Denver, CO, Draft 1979.
                                                         3. U.S.  Army Corps of Engineers,  "Safety and Health Requirements
                                                            Manual", EM 385-1-1 with Change 1 (1 Dec 81), Office of the Chief
                                                            of Engineers, Washington, DC, Apr. 1981.
                                                         4. NIOSH Worker  Bulletin,  "Hazardous Waste Sites and Hazardous
                                                            Substance Emergencies", DHHS (NIOSH)  Publication No. 82-115,
                                                            Cincinnati, OH, 1982.
                                                         5. USEPA, "Interim Standard Operating Safety Guides", Office of
                                                            Emergency and Remedial Response, Hazardous  Response Support
                                                            Division, Washington, DC. Revised Sept. 1982.
                                                         6. ACGIH, "TLVs-Threshold Limit Values for Chemical Substances in
                                                            Work Air", ISBN: 0-936712-39-2, Cincinnati, OH, Adopted  by
                                                            ACGIH for 1982. Revised annually.
                                                         7. Turpin, R.D., "Initial Site Personnel Protection Levels Based on Total
                                                            Vapor Readings", Proc. National  Conference on Management of
                                                            Uncontrolled Hazardous Waste Sites, 1981,277-279.
                                                         8. U.S.  Army Corps of Engineers. "Medical Surveillance Handbook",
                                                            EP 385-1-58, Office of the Chief of Engineers, Washington, DC, 1981.
                                                         9. Gallagher,  G.A.,  "TAT/FIT  Health and Safety Program for Haz-
                                                            ardous Waste  Site Investigation", Proc.  National Conference on
                                                            Management of Uncontrolled Hazardous Waste Sites, 1980,85-90.
                                                         10. Stutz, D.R., Ricks,  R.C., and Olsen, M.F., "Hazardous  Materials
                                                            Injuries—A Handbook for Pre-Hospital Care", FM 8-500, Office of
                                                            the Surgeon General, Department of the Army, Washington, DC.
                                                            Copyright  by  Bradford Communications  Corporation,  Greenbelt,
                                                            MD 1982.
284
SITE SAFETY
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                HEALTH  AND SAFETY CONSIDERATIONS:
                  SUPERFUND HAZARDOUS WASTE SITES

                                             KATHLEEN S. ROOS
                                          PATRICIA  A. SCOFIELD
                                             Rockwell  International
                                Environmental Monitoring & Services Center
                                           Newbury Park, California
INTRODUCTION
  The  Superfund program has added a new dimension to the
science as well as potential legal ramifications resulting from pro-
viding health and safety protection for the worker and general pub-
lic.  The Occupational Safety and Health Administration (OSHA)
has primarily concentrated on employee health and safety in the in-
dustrial setting.  However, the Superfund program has illustrated
the need and growing concern for field health and safety. The haz-
ardous materials cleanup employee can  be exposed to  toxic  and
hazardous substances that may or may not be identified, and the
potential health effects of exposure to these substances may not be
known. Hence, Health and Safety considerations must be oriented
toward the "prevention" of exposures and impacts, rather than
toward "after-the-fact" emergency actions.  Having a Health and
Safety  Program oriented toward "prevention" of exposures will
hopefully reduce the potential,  if not the magnitude, of employee
and general public legal actions.
  The OSHA General Industry Standards (29 CFR 1910) are gen-
erally applicable to a wide range of "normal"  industrial opera-
tions but are limited in their applicability to  field operations as
well as to the number and type of chemical substances regulated.
However, the Occupational Safety and Health Act of 1970 broadly
defines employer duties and responsibilities. These duties require
the  employer to provide a place of employment free from "recog-
nized hazards." Section 5(1 )(A) of the Act gives the OSHA the
authority to require safe working conditions in any place of em-
ployment. Failure of an employer to comply with the "recognized
hazard" duty could result in a citation or notice  of violation and,
if established, the imposition of a penalty. Therefore, one must be
concerned not only with potential legal actions from employees and
the  general public, but also from regulatory agencies.
  To protect a party, both government and contractor, from lit-
igation incurred by the loss of health or safety, the party must
demonstrate best professional judgment in preventing any harm to
workers or public.  Prevention is the key to protection from legal
action. To prevent  harm to the worker and the public,  a thor-
oughly reviewed Health and Safety Program and  effective man-
agement and enforcement of the program are essential.
  A health and safety program consists of many elements including
a Health  and Safety (H&S) Plan for worker safety and contin-
gency planning for public safety. Other elements include the devel-
opment of a medical  surveillance and training program for per-
sonnel. The objective of any health and safety program is to estab-
lish and assure safe procedures and practices throughout the organ-
ization for investigation and cleanup of a site. Safety responsibil-
ities must be incorporated into the site management roles to ensure
the protection of all those involved. The plan is not complete until
it has undergone review and is finally executed by  the office in
charge. In any health and safety program, tradeoffs  must be con-
sidered and operational efficiency and expediency of work bal-
anced with ultimate protection of workers and the public. An H&S
program can only minimize, but never  eliminate, all risks inherent
in cleanup.
  The effective management of a hazardous waste  site remedial
and cleanup action requires a realistic  health and safety program
for both on-site personnel and for the general public. The 'Love
Canal"  situation has affected public perception of  what  is con-
sidered dangerous. Prevention and containment should be the is-
sues addressed in the Community Relations Plan and considered by
first line managers to assure the public that their health and safe-
ty  are continuously addressed. The public must believe that the
problem is contained and that the responsible parties will prevent
any harm from coming to them.
  In this paper, the authors discuss methods that  are available to
responsible parties to demonstrate best professional judgment to
protect public and worker safety and health.
HEALTH AND SAFETY PLAN

  The prime contractor to the USEPA and/or the Corps of En-
gineers is responsible for development and implementation of the
H&S plan for the hazardous waste site. However, the USEPA or
Corps of Engineers must approve the plan. To provide assistance
to the contractor for H&S plan development, both federal agen-
cies have issued draft guidelines for health and safety at spill, re-
moval and remedial action-sites.7'8
  The primary objective of a H&S plan is to establish, prior to
work start, work safety guidelines, requirements and procedures.
The plan must address the two types of potential exposures—acute
and chronic. Acute exposures are often of short duration and  may
result from splashes or sudden high concentrations of toxic con-
taminants. Chronic exposures generally occur over longer periods
of time and often from low concentrations of toxic contaminants.
Chronic exposures at  hazardous waste sites represent significant
problems. Acute exposure may also increase due to activities such
as sampling and  handling of containers  due  to  splashes, mists,
gases or particulate releases.
  The health and safety plan must account for site specific  con-
ditions but be flexible to cover unanticipated hazards. Unlike in-
dustrial exposures, workers at hazardous waste sites may be ex-
                                                                                               SITE SAFETY
                                                      285
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posed to unknown  quantities and types of chemical substances.
Chemical substances existing at Superfund sites may be combus-
tible, explosive, corrosive, reactive, toxic, biologically active or any
combination of these characteristics. Due to the unknown nature of
the sites, all possible realistic scenarios in plan development must
be evaluated.
  Additional factors that must be addressed in H&S plan develop-
ment include:
•Site and work descriptions
•Role definition for responsible parties
•Hazard analysis-definition of  contamination type,  levels and
 zones
•Operational safety procedures
•Appropriate protection and decontamination levels
•Training and education requirements
•Emergency procedures
•Medical surveillance program
•Recordkeeping procedures
  The plan must be site specific. Site description may include dia-
grams of locations  of waste containing drums, sampling stations
and exploratory boreholes or trenches. It may also describe  the
proximity of the hazardous waste site to groundwater or surface
water  supplies, demographic population distribution and other
characteristics that  impact the investigative, removal or remedial
actions. The plan should also outline the proposed work activities
and procedures. For example, the plan should specify that work ac-
tivities include field investigations and collection of environmental
samples of soil, groundwater and surface water.
  The role of responsible parties is of paramount importance in
health and safety planning. Specifying responsibilities of the gov-
ernmental agencies, contractors and employees helps to highlight
potential gaps in the plan and safety procedures as well as dictates
who does what, when and where. Delineation of responsibilities
may have a significant impact on future legal actions.  For example,
it is the responsibility of the USEPA to approve all aspects of the
contractor  health and safety program and any procedures per-
formed by the contractors or state agency  and work zones. The
contractor  is  responsible  for  implementation of all health and
safety procedures, providing safe hazardous waste site conditions,
designation of a safety officer and establishing on-site work zones.
The employee responsibilities  include understanding  all  safety
operations  and decontamination procedures and utilizing protec-
tive equipment required for various work zones. The plan must
state  these responsibilities and  describe how  they will  be  imple-
mented.
   A hazard analysis or assessment must be conducted for the haz-
ardous waste site to determine where hazards are likely to exist,
what  type and amount of chemical contaminant substance  are in-
volved, what area would most likely be adversely affected and the
probability of  hazardous material incidents.  Hazard analysis is
essential for both H&S planning and contingency planning. The
hazard analysis helps to decide  the types of  safe operating pro-
cedures, emergency actions, equipment needs  and medical screen-
ing and training requirements.
  The plan must define safe operating procedures and work prac-
tices.  These procedures are intended to provide uniform instruc-
tions  for accomplishing a specific task in a manner that protects
the worker. These procedures  may cover various activities at the
hazardous waste site, such as site control and entry. As an example,
for site entry the following safe operating procedures may apply1:
•Entrance and  exit  must be planned and emergency escape routes
 delineated. Warning signals for site evacuation must be estab-
 lished.
•Personnel on-site  must use the  "buddy"  system when wearing
 respiratory protective equipment.
•Communications using radios or other means must be maintained
 among initial entry members at all times. Emergency communica-
 tions should be prearranged in case of radio failure, necessity for
 e%acuation of site or other reasons.
                                                      •Personnel and equipment in the contaminated area should be min-
                                                       imized, consistent with effective site operations.
                                                      •Work areas for various operational activities must be established.
                                                        The plan for the hazardous waste site must also define appro-
                                                      priate protection level and site control, otherwise known as decon-
                                                      tamination levels. The USEPA and the Corps of Engineers  have
                                                      established four levels (A, B, C, and D) that correspond with per-
                                                      sonal protective equipment  needed for specific types and  concen-
                                                      trations of contaminants. The protection levels A, B, C and D are
                                                      briefly described as follows:
                                                        LEVEL A requires the highest level of respiratory, skin  and eye
                                                        protection and often corresponds to the exclusion zone (area of
                                                        potential contamination).
                                                        LEVEL B is selected when the highest level of respiratory  pro-
                                                        tection is needed, but  a lesser level of skin protection is suffic-
                                                        ient.  Level B protection is the minimum level recommended on
                                                        initial site entries until the  hazards are further defined.
                                                        LEVEL C is selected when the type of airborne substances are
                                                        known and the criteria for air purifying respirators are met.
                                                        LEVEL D is selected when there are no respiratory or skin  haz-
                                                        ards. A work uniform may be worn which provides minimal  pro-
                                                        tection.
                                                        Site control or decontamination procedures must be delineated
                                                      and followed. Even when protective clothing, respirators and good
                                                      work practices are utilized,  contamination may  occur. Harmful
                                                      materials can be transferred  into clean areas, exposing unprotected
                                                      personnel. To prevent such  occurrences, methods to reduce  con-
                                                      tamination and decontamination procedures  must be developed
                                                      and be  contaminant specific. Defined procedures  and their execu-
                                                      tion must be enforceable.
                                                        Decontamination procedures  are often based on  worst-case
                                                      situations. Specific conditions at  the  hazardous  waste site  that
                                                      should  be evaluated include: type of contaminant(s), amount of
                                                      contamination, levels of protection required and type of  protec-
                                                      tive clothing worn. Decontamination procedures must also identify
                                                      use and possible reuse of protective gear, on-site and off-site clean-
                                                      ing methods, disposal methods for gear and contaminated wash
                                                      water and specific wet/dry decontamination procedures.
                                                        Areas of contamination reduction must also be determined. An
                                                      example  of a contamination reduction zone  layout is shown in
                                                      Figure 1. An area within  the  contamination reduction zone is desig-
                                                      nated the Contamination Reduction Corridor  (CRC). The size of
                                                      the corridor depends on the number of stations  required in the
                                                      decontamination procedures, overall  dimensions of  work  con-
                                                      trol zones and the amount of space available at the site.
                                                        Training and education requirements for personnel should be
                                                      outlined  in the plan.  The primary topics that should be addressed
                                                      include:  (1)  H&S program  organization and  structure,  (2)  safe
                                                      operating procedures, (3) emergency procedures, (4) protection
                                                      levels and personal protective equipment use,  (5) safe field equip-
                                                      ment use, e.g., construction, and (6) decontamination procedures.
                                                      For a detailed discussion on training program requirements  refer
                                                      to the subsection on the H&S Training program.
                                                        The  emphasis of  the  H&S program as well  as  investigative,
                                                      removal  and remedial actions must be oriented toward "preven-
                                                      tion",  especially as these relate to liability considerations. How-
                                                      ever, procedures must be established to handle emergency situa-
                                                      tions. In this case, if one is liable but can prove everything pos-
                                                      sible was done to remedy the situation, one may  suffer less in the
                                                      legal action. Emergency planning procedures should include notif-
                                                      ication requirements, telephone roster of key individuals and emer-
                                                      gency response groups, emergency decontamination procedures,
                                                      rescue  techniques, first  aid procedures  and the  itemization and
                                                      location of emergency equipment and supplies, e.g., eye wash and
                                                      shower areas.  It should also include emergency evacuation and
                                                      transport routes.
                                                        The establishment  of a medical surveillance program is another
                                                      element of the plan. The medical surveillance  program consists of
                                                      two components: medical screening and emergency medical care
 286
SITE SAFETY
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    HEAVY EQUIPMENT
    DECONTAMINATION
        AKEA
EXCLUSION
  ZONE
                                      BIT
                                     »ATH
                   CONTAMINATION
                     REDUCTION
                        ZONE
                                      ill
                                      3 U S
                                      hi
                                      !? iu W
         SUPPORT
          ZONE
                           Figure 1.
               Contamination Reduction Zone Layout

and treatment.  The plan must dictate specific responsibilities of
the physician, contractor and employee, and type of examinations
and treatment procedures.
  Recordkeeping procedures, though listed last, are by no means
of least importance. Delineation of recordkeeping procedures is
essential, especially as it related to liabilities. Recordkeeping pro-
cedures should  be required for all aspects of the H&S  program.
OSHA has established both general and specific requirements  for
maintaining medical training surveillance records. The OSHA Gen-
eral Industry Standards, Title 29, Section 1910.20 states that "each
employer who makes, maintains,  or has  access to employee  ex-
posure records  or employee  medical records shall  preserve these
records." Recordkeeping requirements for 29 CFR 1910, Subpart
Z, Toxic and Hazardous  Substances are more specific. For  ex-
ample, the medical records  for workers  who work  with benzi-
dine must be maintained for the duration of the employee's  em-
ployment. Upon termination,  records  or notarized  true copies
must be forwarded to the OSHA Director. Recordkeeping is also
important to validate that training requirements were  satisfied.
Maintenance  of records, whether  legally  required or not, may
greatly reduce the impact of any possible legal actions.
  Preparation of a  hazardous waste site  H&S plan requires  the
input from groups with varied responsibilities. These groups may
include contractors, hospitals and local agencies such as the police,
fire and health departments. It should never be assumed that these
groups are  prepared for emergency situations emanating from a
hazardous waste site. In the case  of E&E's cleanup of General
Disposal, the H&S plan required input from USEPA, Region IX,
the USEPA Environmental Response Team, USCG Strike Team,
LA County Sheriff's Department,  City of Santa Fe Springs Fire
Department, Department of Health Services, prime & subcontrac-
tors and E&E.'
  The groups that  may be  involved in H&S  actions should be
contacted prior to work start, and the possible hazards outlined
and  protocols arranged. A  copy  of the  reviewed  and  approved
health & safety plan should be made available to all personnel and
agencies which may be involved in a hazardous waste site cleanup
or resultant emergency situation. A plan distribution list should be
developed so that any revisions or updates to the plan will be sent to
these groups.
MEDICAL SURVEILLANCE PROGRAM

  Hazardous materials cleanup personnel can be exposed to condi-
tions that are atypical of normal  occupational exposures. There-
fore, special attention should be given when developing medical
surveillance programs for this type of worker. The team member
can be exposed to thousands of toxic chemicals that may or may
not be identified and the potential health effects  of exposure to
these chemicals or mixtures of the chemical may  not be known.
Some  other differences  between  the  normal worker  and  the
response team member are as follows:
•Usually the response team member's exposure to  hazardous sub-
 stances is relatively short in duration and primarily dependent on
 the length of the cleanup operation.
•Industrial exposures are controlled by engineering and industrial
 hygiene practices. However,  the response team member's source
 of protection from exposure to hazardous substances  is usually
 proper work practices and proper utilization of personal protec-
 tive  equipment,  e.g.,  gloves, respirators,  coveralls,  chemical
 suits, boots, etc.
•Generally, industrial exposures evolve  from  known substances
 and sources, whereas the response team member may be exposed
 to substances that are unknown in type, quantity  and concentra-
 tion, as well as combinations of substances.
  With these differences between the normal industrial worker and
the hazardous waste cleanup team member, a medical surveillance
program should be established to meet the following objectives:"
•Preassignment health screening of all employees who will be di-
 rectly engaged in hazardous waste investigations, removal and/or
 remedial actions.
•Support of the health of employees assigned to hazardous waste
 investigations
•Evaluation and care of individuals with work-related exposures,
 injuries or illness
•Monitoring of workers' health for evidence of work-related health
 effects and their suitability for further assignments  in this field
  To  safeguard the health of response personnel,  a medical sur-
veillance program must be developed, established and maintained.
A physician experienced in occupational  medicine  and the effects
of toxic industrial substances  should  develop and  be involved in
maintenance of the medical surveillance program. An experienced
physician not only helps to ensure the protection of  on-site workers
health, but also helps to protect the employer from legal action.
  Two components of a medical surveillance program are medical
screening and  emergency treatment.  Medical screening generally
consists of preplacement, periodic and termination examinations.
These examinations establish an individual's state of health,  base-
line physiological data and ability to use personal protective equip-
ment. Medical screening also  provides for special  medical exam-
inations, usually as periodic  examinations, in evaluating known
or suspected exposure to toxic substances. Emergency  treatment,
on  the other hand, is medical care given when possible overex-
posure to toxic substances or injuries occur due  to accidents or
physical problems. In the event of emergency treatment, specific
emergency care provisions should have already been delineated.
For the purposes of this report, the authors will focus on medical
screening provisions.


MEDICAL SCREENING—EXAMINATIONS

  As  mentioned previously, medical screening usually  consists of
three  main  examinations—preplacement or baseline, periodic  and
termination. Preplacement or baseline examinations serve an essen-
tial function in medical surveillance by providing a historical record
of previous exposures, information on the state of health prior to
joining the team and a baseline for comparison with later health
                                                                                                      SITE SAFETY
                                                                                                287
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examinations. Preplacement examinations are used to ensure that
workers are physically able to use personal protective equipment
as specified by Occupational Safety and Health Administration
Standards,  29CFR1910, Part 134. Preplacement examinations also
serve to document preexisting conditions and exposures prior to
new job assignment, thus establishing a point of reference in case
of future legal actions.
  Periodic  examinations can be used as a tool to detect incipient
disease, physiological changes and evidence of absorption of toxic
agents. It is important to consider periodic examinations in terms
of what is legally required, what is recommended by official agen-
cies such as the USEPA and the National  Institute for Occupation-
al Safety and Health (NIOSH)  and what has persuasive medical
justification. The periodic examination is similar to the preplace-
ment  examination,  i.e.,  occupational/medical history, physical
exam and  biological monitoring; however, emphasis is oriented
toward followup studies on possible exposures that had occurred
since the previous examination. Periodic examinations can contrib-
ute to early diagnosis and treatment  of the  individual and  may
identify common factors in a group, thereby enhancing the value of
preventive  programs. Periodic examination can also be used as a
tool to determine whether the individual  should be removed from
the work environment if it is indicated that his/her health may be
adversely affected.
   Examinations at the termination  of  employment or job assign-
ment are desirable since they can be used to document the health
status  at the end of employment  and provide evidence of  any
changes that occurred during the job assignment or employment
period. This does not rule out the possibility that effects may show
up at a later date. For example,  asbestosis can progress years after
the last exposure to asbestos dust, and cancer from a chemical car-
cinogen may not  appear  for decades.  The termination examina-
tion would be very  similar to the preplacement examination, al-
though special tests may be required if occupational exposures had
occurred during the work period that the employee had been work-
ing at a hazardous waste cleanup site.
MEDICAL SCREENING—SURVEILLANCE ELEMENTS
   Each of  these examinations—preplacement, periodic and term-
ination, consists of occupational and medical history, physical
examination and  biological monitoring elements.  Each of these
elements is  described below.
Occupational/Medical History
  The occupational  and  medical history information  obtained
from  the employee  assists the  examining physician in perform-
ing an examination of appropriate scope. Examples of occupa-
tional and medical history parameters of interest may include:
•Job-related illnesses or injuries
•Types of substances handled at work
•Personal habits, e.g., smoking,  alcohol and drug consumption
•Medication history
•Allergies
•Immunizations, vaccines and antitoxins
  The USEPA strongly recommends that a medical and occupa-
tional history form similar to the one that USEPA developed be
used. The USEPA feels that "standard" medical history forms are
too sketchy, especially in terms of occupational history exposure.

Physical Examinations
  A physician or medical advisory board responsible for medical
screening should determine the content and methods required for
the physical examination.  Examples of physical parameters  that
are typically evaluated include: basic physiological parameters
such as vision, tonometry, hearing, height and weight; respira-
tory parameters such as pulmonary function analysis and chest
and  back   X-rays;  cardiac  parameters—electrocardiogram  and
blood pressure; and  a physical examination. The physical exami-
nation may include skin inspection, reflex evaluation and a chest
                                                      examination. The USEPA recommends that the physical exam-
                                                      ination be recorded on a standard form such as government stand-
                                                      ard Form 88. Although the physician may have similar forms, all
                                                      work places are urged to adopt this standard form to achieve uni-
                                                      formity.
                                                      Biological Monitoring
                                                        Industrial chemicals  that might cause systemic effects are often
                                                      transported by the blood systems, metabolized  by  enzymes and
                                                      excreted by the body.  In an effort to measure exposure(s) to in-
                                                      dustrial  chemicals, biological  monitoring is  often  a logical  ap-
                                                      proach. The USEPA recommends that each individual should re-
                                                      ceive a basic panel of blood counts and chemistries  to evaluate
                                                      blood-forming, kidney, liver and endocrine/metabolic functions.
                                                      The following blood tests are  considered to be the  minimum de-
                                                      sired:'
                                                      •White blood and differential cell count
                                                      •Hemoglobin and/or hematocrit
                                                      •Albumin, globulin, and total protein
                                                      •Total bilirubin
                                                      •Serum glutamic oxalacetic transaminase (SCOT)
                                                      •Lactic dehydrogenase (LDH)
                                                      •Alkaline phosphatase
                                                      •Calcium
                                                      •Creatinine
                                                      •Urea nitrogen
                                                      •Phosphorus
                                                      •Cholesterol
                                                      •Glucose
                                                      •Uric acid
                                                        The USEPA also recommends that each  employee have a rou-
                                                      tine urinalysis that consists of the following tests:'
                                                      •Specific gravity
                                                      •pH
                                                      •Microscopic examination
                                                      •Protein
                                                        Workers who are significantly exposed to certain designated ma-
                                                      terials may require special procedures in addition to the basic panel
                                                      of tests. Examples of special tests that may be  requested due to ex-
                                                      posure to specific hazardous substances are as follows:4-6
                                                      •Lead—Lead analysis in blood or urine, neurologic exam
                                                      •Acrylonitrile—Proctosigmoidoscopy and fecal blood
                                                      •Vinyl  chloride—SGOT,  Serum  Glutamic  Phosphoric Transam-
                                                       inase (SGPT) and Alkaline Phosphate
                                                      •Asbestos—Sputum cytology
                                                      •Mercury—Mercury in blood or urine, neurologic exam
                                                      •Organophosphate pesticides—Blood cholinesterase
                                                        The physician should determine who is in need of special tests
                                                      after reviewing the occupational and medical forms and after con-
                                                      sulting  with supervisors and/or medical monitoring coordinators
                                                      and health and safety designers. Provisions should be made for re-
                                                      peating tests when necessary.
                                                        Participants  in this medical  surveillance program  should be ad-
                                                      vised that these examinations are not a direct  substitute for "gen-
                                                      eral checkups" or other periodic examinations designed to monitor
                                                      or promote general health. The occupational  medical surveillance
                                                      program is designed to screen for evidence of adverse effects of
                                                      occupational exposure, particularly exposure  to  toxic substances.
                                                      The examinations do not provide a comprehensive health evalua-
                                                      tion; neither do they provide significant screening for many of the
                                                      common nonoccupational chronic disorders.

                                                      HEALTH AND SAFETY TRAINING PROGRAM
                                                        The prime contractor is responsible for developing, implement-
                                                      ing and maintaining a training program for cleanup personnel.
                                                      The prime contractor must also insure that the subcontractors have
                                                      a comparable training program for their employees. Due to these
                                                      specified requirements, the contractor must  develop a training pro-
                                                      gram that is comprehensive and effective. A training program can
 288
SITE SAFETY
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be considered a "preventive" measure since it allows, if conducted
properly, the employee : (1) to understand the hazardous aspects
of the work; (2) to be aware of the regulations and rules of con-
duct specific to on-site activities;  (3) to understand and be com-
fortable with safe operating procedures, work practices and emer-
gency actions; and (4) to increase confidence because he/she knows
what to do and how to act in emergencies in a safe, effective man-
ner. Therefore, the training program as a "preventive" measure, if
implemented and enforced,  will help to reduce employee injury,
illnesses and accidents, thus decreasing the likelihood of worker
compensation claims  and suits and other legal actions.
  Currently, the USEPA and the  Corps of Engineers recommend
at least 16 hours of  practical and theoretical instruction for haz-
ardous waste cleanup personnel.  They also  recommend that re-
fresher training courses be conducted for at least  two hours an-
nually. Training requirements, as defined in the OSHA General In-
dustry Standards, are oriented toward specific chemical substance
requirements (Subpart Z), respirator usage (29 CFR 1910.134) and
for  activities,  such as truck operations  (29 CFR  1910.178). As
stated, the  OSHA standards specify training and  indoctrination
program requirements for employees working with  toxic and haz-
ardous substances (29 CFR 1910.1000-1046). According to these
regulations, the  employee should  receive a training program that
includes the following elements:
•The nature of the toxic or carcinogenic hazards of the chemical
  substances in question; this includes local and systemic toxicity.
•The specific nature of the  operation involving the toxic or haz-
  ardous substance which could result in exposure.
•The purpose  for and application of the medical surveillance pro-
  gram including, as appropriate, methods of self-examination.
•The purpose for and application of decontamination procedures
  and purposes.
•The purpose for and significance of emergency practices and pro-
  cedures.
•The employer's specific role in emergency procedures.
•Specific information to aid the employee in  recognition and  eval-
  uation of conditions and situations which may result in the release
  of the toxic and hazardous substances.
•The purpose for and application of specific first  aid procedures
  and practices.
•Specific emergency  procedures should be prescribed and posted.
  The employees must be familiar with the  terms  and rehearsed
  (drilled) in this application.
•Review of these elements at the employee's first training program
  and annually thereafter.
   These training elements, though specific for OSHA designated
toxic and hazardous  substances, are also key elements of the train-
ing program for hazardous  waste sites. However,  additional ele-
ments  are also recommended for hazardous waste sites. These in-
clude:
•The proper use of field sampling and laboratory equipment; this
  includes work tools, sampling equipment and decontamination of
  tools.
•The purpose and proper use  of personal protective gear such as
  the fitting  and use of respirators and personal protective apparel
  and the use of Self-Contained Breathing Apparatus (SCBA).
•The general structure of the Health and Safety program, includ-
  ing responsibilities,  and general rules of conduct at the hazardous
  waste site.
•The identification of contamination areas and level of protection
  and protective gear required.
•The implementation of safe operating procedures and work prac-
  tices;  this includes rules for site  entry and exit, site control pro-
  cedures and work limitations.
  Effective  personnel training  programs, as developed and imple-
mented by the prime contractor, should address not  only safety and
welfare of the cleanup personnel, but must also inform all person-
nel about the waste  site hazards,  and train all personnel via spill
drills prior to site investigation and cleanup. Initial and refresher
training courses are essential and should be documented to help re-
duce not only employee illness, injuries and accidents, but also re-
sultant worker compensation claims, suits and other legal actions.

CONCLUSIONS
  The nature of liability cannot be adequately addressed in a pres-
entation of this nature, nor at this time, since legalities and prec-
edence have not been set. However, it may be useful to point out
some steps which can be taken to  protect responsible parties from
possible litigation.
•Document that the health and safety program was enforced.
•All procedures should be  documented and approved by  appro-
priate officials.
•Multiple experienced  groups should be  involved  in  preparing
 health and safety and contingency plans, especially the Fire  De-
 partment and USEPA.
•Use only experienced and trained personnel for any projects.
•Do not always take the "cheapest"  route; it may be expensive
 in the end.
•Investigate limitations of protective equipment and assure that
 it is protective against chemical substances and any  combinations
 found on-site.
•Use only certified and guaranteed equipment meeting all approved
 OSHA, MSHA and/or NIOSH safety  approval for  personnel
 standards.
•Construction activities require trained equipment operators and
 support personnel. This requires a different, yet defined, safety
 procedures guideline,  e.g., the operation of heavy  equipment is
 dangerous in and of itself. Assure that all subcontractor personnel
 meet safety training requirements.
•All procedures should be  referenced and/or support specialists
 kept on call.
•Alternative operating  procedures should  be  available to  on-site
 personnel, if possible.
•Contingency plans should address realistic scenarios.  All agen-
 cies and/or groups  involved in a release  scenario should  be de-
 briefed prior to work start.
•All data must be documented with  strict QA/QC procedures;
 strict chain-of-custody protocol must be followed in every aspect.
•Health and safety responsibilities should be integrated into man-
 agement roles. Chain-of-command with  inherent responsibilities
 must be well defined.
•Safe operating procedures must be posted and enforced.  Penal-
 ties for failure to follow these procedures should be enforced.
•One party (OSC) must have ultimate authority to make decisions.
•Reference material, including codes and publications such as
 NFPA, OSHA, NIOSH,  EPA,  NIOSH/CHRIS  and  CMA's
 CHEMTREC, should be available for emergencies  as well as for
 use in development of the Health and Safety Program.
•The training  program should be approved  by the appropriate
 agency and all on-site personnel should be required to attend. A
 method of judging understanding of the course should be met.
•The medical surveillance program  must  be approved by  appro-
 priate  officials. The physican and industrial hygienist must also
 be approved by appropriate  officials, and their responsibilities
 completely understood.
•Laboratories selected  for medical screening analysis and  sample
 analysis should be reputable, certified and experienced.
•All contractors must secure adequate insurance to protect employ-
 ees and themselves.
•Employees want to know that the employer is  concerned with their
 future health  as well as on the job health. Increased morale,
 productivity and  favorable workmen's compensation insurance
 ratings may result with a health and safety program  designed with
 the employee and public of prime concern.
•Have all phases of operation available to all  personnel in  written
 form and posted.
•Assure that all personnel  are  familiar with  safe operating pro-
 cedures.
                                                                                                       SITE SAFETY
                                                          289
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•Assure that all personnel are trained in anticipation of hazards,
 equipment operation,  safety practices, hygiene,  emergency  pro-
 cedures, communications and decontamination procedures.
•Assure that all required protection—respirators, SCBA, etc., is
 available on-site and be worn by all supervisors and workers in
 specific zones.
•Written instructions must be prepared in advance.
•Operation  and safety procedures are based on best available
 knowledge, operational principles and technical guidance. Docu-
 ment this information.
•Operation  and safety procedures should be field tested, reviewed
 and revised continuously.
•These procedures must  be understandable,  feasible and appro-
 priate without sacrificing safety
•All personnel must have copies  and be briefed on the use of the
 Health and Safety plan.
•Response  personnel  must  be  trained and  undergo  refresher
 courses.
•The prime contractor must  also ensure that his subcontractors
 meet the demands of the established H&S program.  The contrac-
 tor should also determine that the appropriate health and safety
 requirements have been estimated in the subcontractor cost.

REFERENCES
 1.  Buecker, D.A. and  Bradford,  1982. "Safety  and Air  Monitoring
    Considerations at  the Cleanup of a Hazardous Waste Site" Proc.
                                                            of the  Third National Conference on  the Management  of Uncon-
                                                            trolled Hazardous Waste Sites, 1982.
                                                          2. Federal Emergency Management Agency. Planning Guide and Check-
                                                            list for Hazardous Materials Contingency Plans, FEMA, July, 1982.
                                                          3. Camp,  Dresser, and McKee. Remedial Response Activities Zone I
                                                            Uncontrolled Hazardous Waste Sites, Health and Safety Guidelines
                                                            for Cutoff Wall Construction LIPARI Landfill, NJ, Work Assign-
                                                            ment No. 2-1-21 (Draft), 1982.
                                                          4. Galley, L.J.  and Cralley,  L.V. "Theory and  Rationale of Indus-
                                                            trial  Hygiene  Practices",  Patty's Industrial Hygiene and  Toxicol-
                                                            ogy, Volume III, John Wiley and Son,  New York, 1979.
                                                          5. OSHA  (29 CFR 1910). General Industry—Occupational Safety and
                                                            Health Standards, GPO, Washington,  D.C., 1979.
                                                          6. Proctor, N.H.  and  Hughes,  J.P. Chemical Hazards of the Work-
                                                            place, J.B. Lippincott Co, Philadelphia, 1978.
                                                          7. U.S.  Army  Corps of Engineers.  Safety and Health Requirements
                                                            Manual, EM-385-1-1, 1982.
                                                          8.  USEPA OERR. Interim  Standard  Operating Safety and Health
                                                            Guides, Sept.  Hazardous  Response Support Division,  Edison, NJ,
                                                            1982.
                                                          9. USEPA. Medical Monitoring Program,  EPA  Monitoring Guide-
                                                            lines,  Poison Control Centers. 1980.
                                                        10. USEPA. Office of Water and Hazardous Materials,  Quality Criteria
                                                           for Water, Washington, 1976.
                                                        11. Woodward and  Clyde Consultants, Inc. Hazardous Waste Health
                                                            and Safety Manual, Unpublished document, 1982.
290
SITE SAFETY
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       DUAL-PURPOSE FTIR: QUALITATIVE  ANALYTICAL
   SCREENING TOOL AND QUANTITATIVE SITE  MONITOR
                                    AN EXTENDED ABSTRACT
                                           KURT W. EASTMAN
                                             Analect Instruments
                                              Utica, New York
  As the analysis of toxic materials has become increasingly im-
portant due to imposition of governmental constraints, technolo-
gies and methodology for evaluating dangerous substances have
concomitantly developed. Since the advent of computerized FTIR
technology, rapid and sensitive measurements of chemical species
have been achieved in laboratory investigations. However, the true
benefits of FTIR methodology are realizable in field situations
requiring speed, accuracy and continuous surveillance of noxious
fumes. Monitoring  exposures of workers engaged in cleanup of
Analytical
Scraaning
Parsonnel
 Safety
hazardous waste storage locations presents a prime example of such
a field application.
  Consider the flow chart in Figure 1 which involves preliminary
sampling of several quadrants of a storage facility prior to com-
mencement of cleanup activities. A given sample may exist in gel,
liquid or gaseous state. Various sampling accessories are required
for cells, while low concentrations of gases need long pathlengths
for high sensitivity. Any of these accessories is mountable in the
EVM-60 FTIR spectrometer, which displays capabilities for both
qualitative screening and personnel safety monitoring.
  A large sample compartment containing dual analytical beams
provides this  flexibility. Transmission cells, thin  films,  crystal
smears, attenuated total reflectance  (ATR) and cylindrical flow
through ATR measurements are  performed using  easily inter-
changeable accessories in one beam. The other beam is dedicated
to serving the long path gas cell for analytical work and auto-
mated monitoring. In this fashion,  gel and liquid samples are
evaluated using the utility beam, while vapor samples are analyzed
with the dedicated beam.
  For semi-quantitative or gross leak detection, site administra-
tors may prefer a general identification technique. The procedure
involves monitoring absorbing frequencies for functional groups of
interest (e.g.,  alcohol, ketone,  cyanide). In cases requiring more
accurate data, a specific identification method can be employed.
Spectral subtraction and computer search programs aid in isolating
major toxic species. Several computer data bases exist  for both
liquid and  gas phases. Additionally, users with no special skills
may be  able to identify chemicals from resultant spectra after per-
forming accurate subtractions of interferences.
  Upon ascertaining the identities of the hazardous compounds
and interfering components, analytical frequencies for  all com-
ponents are selected based on band intensities and positions (Fig-
ure 2). A calibration matrix (Figure 3) is devised by measuring the
                                                                              Measurement Point
                                                            Left

                                                                   Right End
                                                               LOCAL BASELINE
                           Reference
                                                                                               FIXED REFERENCE
                        Figure 1
EVM-60 flow scheme for hazardous substance classification and monitoring
                       Figure 2
              Mapping region for measurement
                                                                                           SITE SAFETY
                                                   291
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absorption of all chemicals at each chosen frequency. Stations for
monitoring are then entered into the analyzer program. Automated
data  collection  for  TWA  exposure  levels  are then  initiated,
followed by report generation and printout (Figure 4).
   In  the  event of additional unknowns entering the  monitored
quadrant, the  user diverges  from the cycling routine to perform
supplemental investigatory work using the appropriate  analytical
beam. Additional  compounds can be incorporated into the analy-
tical matrix  to achieve  a  maximum of ten components.  Matrices
and station sequences are alterable to  meet each imminent situa-
tion. Remote locations are accessible  with  the analyzer since  its
ruggedized optical bench allows transportability.
            RAW-DATA UATHIK
             Region 1      Region 2     R«01on 3      Region 4    fleoton 5
    Component I   075075 E-02  0.15421 £-04 0.4 r062 E-04 -0.4SOg5 E-04 -0.26300 E-04
    Component 2   0.10S70E-04  0.50323 E-02 O.S3072E-03  0.26950 E-03 0.32054 E-03
    Component 3  0.05497 E-04  017051 E-03 0.532 IS E-02  0023g3E-03 0.01273 E-04
    Component 4   -0.T7750 E-04  0.17705 E-03 0.50350 E-03  O.S8400 E-02 0.12004 E-03
    Components  0.73240 E-04  0.37007 E-04 0.43024 E-03 -0 00 14 1 E-04
                                                            Calculated time-weighted average (TWA) exposure assuming each person
                                                            was in the sampled areas a predesisnaled amount of time, was exposed
                                                            to average concentration, and used no respirator.
                                                            LOCATION:
                                                                  TWA Exposure for Tetrahydro Furan 04/21/83 08:02:1 1
                                                          r E-OI
            INVERSE MATRIX
             Region I     Region 2      eglon 3     Region 4      Region 5
    Component 1   0.13322
    Components  -0.10002 E 01  -0
    Component 4  0 10040 £01  -0
    Component ft  -0.47220 E 00  -0
                                             .401 13 E 00
                                             .10530 E 01
                                                                   JOB CLASS
                                                                   Worker «* 1
                                                                   Worker *2
                                                                   Driver •> 1
                                                                   Driver *2
   DAY
 16.3 PPB
 16.4 PPB
 32.3 PPB
 26.6 PPB
                                                                   Sample Collector  3.33 PPB
   AFT
 2.04 PPM
 2.06 PPM
 2.54 PPM
 2.70  PPM
 2.83 PPM
   EVE
9.21 PPM
9.30 PPM
 1 1.6 PPM
 12.1 PPM
 1 1.9 PPM
                                                                  TWA Exposure for Methylene Chloride 04/21/83 08:02:22
                                                                   JOB CLASS
                                                                   Worker * 1
                                                                   Worker *2
                                                                   Driver «*1
                                                                   Driver *2
   DAY
3.97 PPB
4.01 PPB
7.87 PPB
6.48 PPB
                                                                   Sample Collector  0.81 PPB
   AFT
1.15 PPM
1.16 PPM
1.44 PPM
1.53 PPM
1.60 PPM
   EVE
2.32 PPM
2.34 PPM
2.72 PPM
2.79 PPM
2.85 PPM
                             Figure 3
            Calibration matrix for a five component mixture
                                                                                        Figure 4
                                                                   Twenty-four hour TWA values for job classes of interest
292
SITE SAFETY
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         OFF-SITE ASSESSMENT OF AIR  EMISSIONS  FROM
              HAZARDOUS WASTE  DISPOSAL  FACILITIES

                                      CHARLES E. SCHMIDT, Ph.D.
                                         M.W. ELTGROTH, Ph.D.
                                              Radian Corporation
                                                 Austin, Texas
INTRODUCTION

  The assessment  of  the air emissions from hazardous waste
facilities can involve the use of several monitoring and measure-
ment approaches and modeling methodologies. Often both on-site
and off-site measurements are needed to fully characterize gaseous
emissions from these facilities. These data, when modeled, provide
assessment of the atmospheric contaminant gas releases as well as a
predictive tool for exposure assessment studies and remedial action
design.
  In this paper, the authors describe a method of characterizing at-
mospheric gas emissions from hazardous waste facilities. In order
to satisfy the assessment objective, ambient monitoring and emis-
sion measurement techniques are employed. As shown in Figure 1,
both techniques generate data (i.e., downwind concentration data
and source emissions data) that can be used to satisfy program ob-
jectives. These data are used as collected and processed or used as
input to modeling studies for waste site assessment. Note that in-
direct  emission  measurement  techniques  involve modeling to
generate useful data where ambient monitoring and direct emis-
sions measurements do not.
  The following components of the approach are discussed:
•Design of ambient monitoring  system, on site and off site
•Source-receptor modeling
•Design of emission source measurement techniques
•Receptor-source modeling
  Data are presented from field investigations at a hazardous waste
landfill where both ambient monitoring and source measurements
were performed. Results from source-receptor and receptor-source
modeling demonstrate  the utility of the assessment approach. Ap-
plications and  limitations of the approach are discussed.

METHODS AND MATERIALS
Ambient Monitoring
  The ambient monitoring portion of an assessment program (on
site  and/or off site) should provide: upwind or background air
quality data, micrometeorological data base, an  air quality data
base characterizing the  site emissions and monitoring for uncertain-
ty estimates. The design of the ambient monitoring program must
provide the information identified as satisfying the program objec-
tives. The design of site specific  monitoring strategies includes the
selection of: tracer species/parameters for monitoring, analytical
methods and instrumentation, monitoring  site locations, quality
control/quality assurance procedures and data reduction/evalua-
tion procedures. The tracer species selected depend on the type of
materials disposed of at the facility. Often this selection is influenc-
ed by state-of-the-art monitoring capabilities. The meteorological
parameters selected to characterize the micrometeorology of the
site are determined by  the modeling input requirements. Standard
analytical  methods and  EPA  approved instrumentation for
monitoring should be used for detection methods, where possible.
Unfortunately, these applications usually involve noncriteria con-
taminants and standard methods and approved instrumentation are
not available. Thus, investigation for the best available scientific
approach is required.
  Assistance, however, is available for the selection of monitoring
site locations. Guidelines published by the USEPA Office of Air
Quality Planning and  Standards describe the  proper site location
procedure and requirements for air quality and meteorological sta-
tions. USEPA also recommends the use of modeling for site selec-
tion  (USEPA industrial source complex dispersion model 1979,
    DOWNWIND
  CONCENTRATION
      DATA
                            INDIRECT
                          MEASUREMENT
                         METEOROLOGICAL
                            MODELING
   DIRECT
MEASUREMENT
                           SOURCE EMISSIONS INFORMATION
                          I
              Satlslfy Program Objectives
                         Figure 1
 Data generated from ambient monitoring and emission measurements

USEPA single source model  1977).  Quality control procedures
described in the USEPA Interim Guidelines and Specifications for
Preparing Quality Assurance  Project Plans provide the design
work  for  the program quality assurance.  Data reduction and
evaluation are dependent upon the type of data collected, computer
storage and  transducer capabilities  and  model hardware com-
patibilities.
  The monitors  and  sensors used for these studies and  their
specifications are listed in Table 1. Air quality upwind and down-
wind of the site during these experiments was monitored for SO2,
THC  and odor.  Odor was assessed using  trained  odor experts
and/or GC analysis. Meteorological monitoring consisted of wind
                                                                                               SITE SAFETY
                                                      293
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speed and wind direction. All monitors were operated continuously
during the studies  according to recommended operating pro-
cedures. All data were recorded on stripchart recorders.
Source-Receptor Modeling
  As used in this paper, source-receptor modeling means using a
model to determine source  characteristics  from measurements
made at receptor sites. Source-receptor modeling requires that the
model go back in time from when the measurements were taken to
when the effluent was emitted from the source.
  This type of modeling usually utilizes a Lagrangian technique
which assumes there are one or  more homogeneous separate air
parcels  whose  identity can  always be  known. The  receptor
measurements are assumed to take place in a single air parcel at dif-
ferent times post emission. Thus, the major effects (such  as diffu-
sion) are modeled in reverse.
                           Table 1
                 Description of Monitors/Sensors
              SO2
                            THC
                                Wind      Wind
                                Speed      Direction
Manufacturer
Model
Technique
Precision
Sensitivity
Response Time
Range
Power Supply
Service Life
Weight
InterScan
Portable
Analyzer
Electro-
chemical Cell
10%
0.05 ppm
1 sec
0-1 ppm
1 Mercury Cell
4 Aklaline
Cells
2 NiCad Cells
8hr
14 Ib
Century
Systems
OVA-1
GC/FID
10% for STD
Analyses
1 ppmv
(methane)
1 sec
1-10,000 ppm
1-100,000 ppm
Logarithmic
DC
8hr
8 Ib
Metone
010
Chopper/
Counter
1%
0.6 mph

0-50 mph
AC/DC
DC-5
days
DNA
Metone
020
Potentio-
metric
\%
0.6 mph

0-540°
AC/DC
DC-5 days
DNA
  A major problem with this type of model is that each measure-
ment will predict different source characteristics because of the in-
accuracies of the model. No model considers each process affecting
the concentrations of some  effluent to a sufficient degree to make
these discrepancies insignificant. Because of this, interpretation of
the results can be  difficult when there are multiple receptor points
at which measurements are  made.
  A variation  of  the source-receptor modeling is to alternate the
source term until the overall error between predicted and measured
concentrations  is minimized.  This  technique  usually requires
several user iterations rather than having a model decide for itself
how many and what source assumptions  should be made.
  In general, source-receptor modeling requires at least multiple
measurement values separated in space and  time. Also required are
wind speed/direction and stability. From these basic requirements
other parameters may be required depending on the sophistication
and completeness  of the model.
  A Gaussian puff model was used as the  source-receptor model. A
Gaussian puff model assumes that the emissions from a source can
be divided  into a  series of puffs that, when superimposed, depict
the actual plume.  A  Gaussian puff model is usually less demanding
than other  models on computer resources and could be used on a
small computer. However, this type of model also has some severe
limitations.
  The  most severe  limitation  of a  Gaussian puff model is that
material in  the puff is assumed to be distributed in a Gaussian man-
ner. Deformation of a puff due to terrain or non-uniform wind
field is not allowed. Due to the assumption of a Gaussian distribu-
tion,  horizontal dispersion parameters (
-------
used as a source-receptor model. It is usually a time-consuming ef-
fort, however, to change the source term often enough to deter-
mine  which  source term  gives  a minimum  error to  receptor
measurements.
  The minimum input requirements for a receptor-source model
are a source term,  wind direction/speed and stability. These re-
quirements can increase dramatically for the more sophisticated
models. Some receptor-source models also can use terrain defini-
tion, chemical mechanisms and multiple wind measurement sites.
   An Eulerian grid model was used as the receptor-source model.
An Eulerian grid model is the most realistic type of atmospheric
computer model available. However, this type of model can require
large computer resources. An Eulerian grid model assumes the at-
mosphere is subdivided horizontally  and vertically  into boxes.
These boxes, in principle, can be any size. Advection and diffusion
is then allowed to occur between the boxes. In addition, chemistry
and other processes besides  advection/diffusion can easily be
allowed in an Eulerian model.
   Radian has a  state-of-the-art  Eulerian  model called  MAGIC
(Multi-Scale Aerosol and Gas Impact Calculation). MAGIC was
developed by merging three existing,  validated models previously
developed by Radian scientists.  The model allows for advection,
diffusion, multiple sources in complex terrain, any user-supplied
chemistry and particle dynamics. It is fully optionalized so that
calculations not required are bypassed, thus saving both computer
storage and calculation time.
   One of the advantages of MAGIC is the model's flexibility. The
physical characteristics of the area being modeled are input to the
model, grid-by-grid, and not assumed. At present, secondary pro-
ducts of the emissions are not of concern. If, at a later date this is
not the case, MAGIC has the capability of handling almost any
user-supplied chemical mechanism. Particle dynamics are also in-
cluded in MAGIC  to allow for considering deposition pattern of
fugitive dust during any site disturbance.1
Model Inputs
   Both of these assessment approaches were employed to assess the
air emissions from a hazardous waste site under different condi-
tions. Source emission measurements were conducted on site under
disturbed waste conditions. Simultaneous upwind and downwind
air quality  and meteorological  monitoring  was conducted. The
tracer species observed included SO2, benzene and odor.
   Portions of air monitoring and source measurement data cor-
relating to site conditions were selected and validated and used to
satisfy specific program objectives via modeling. From these data,
representative test cases were selected and used to demonstrate the
effectiveness of this assessment approach. The input data used for
the assessment  modeling  (source-receptor,  receptor-source)  are
given in Table 2.

RESULTS
   The results from the receptor-source modeling of the disturbed
waste test case is given in Table 4. Shown here is a comparison of
the predicted downwind SO2, THC and odor levels at the down-
wind distance where actual monitoring of these species  was  ob-
served and reported. The odor estimate was based on use of the
quantitation of an ambient air sample and calculation of the odor
level using  odor/species concentration correlations provided by
TRC consultants. It appears that the receptor-source modeling
simulates the situation very well.
   The result from  the source-receptor modeling (conducted by
TRC) provided  an odor source term used for further predictive
assessment (via receptor-source modeling). In this application, an
odor term was difficult to measure but convenient to estimate from
downwind odor observations.  The odor term estimated was an
ED50 rating of 400,000. The odor source term modeled  here was
comparable to other measured odor emissions at this  site at other
locations. This odor source was in turn used for downwind odor
level prediction via receptor-source modeling and then compared to
                           Table 3
                        Modeling Inputs
Source-Receptor (MAGIC Model)
Stability - Class "D"
Wind Speed - 4 mph
Wind Direction - 270 °
Complex Site Terrain
Disturbed Waste Area - 100m2
SO2 Emission Rate - 3.2 x 106 (/ig/m2min)
THC Emission Rate - 1.1  x 105 (/«g/m2min)

Receptor-Source (ODORAR Model)
Stability - Class "B"
Wind Speed - 3  mph
Wind Direction - 230°
Disturbed Waste Area - 14m2
Odor Monitoring Observations
  Receptor 1, 137  meters  downwind - 500 D/T*
  Receptor 2, 213  meters  downwind - 240 T/D
  Receptor 3, 411  meters  downwind - <190>50 D/T

•D/T = Dilution to Threshold Value
                            Table 4
          Comparisons of Measured Downwind Parameters
                  with MAGIC Predicted Values
Parameter                    Measured
Maximum So2                O.lOppm
Ratio of downwind to back-
 ground hydrocarbons          3.4
ED50 (assumed THT)           74
•Steady-state emission estimate
MAGIC
Predicted*
0.11 ppm
3.4
67
observed  odor levels  during  site testing. These observed  and
predicted odor levels agreed well.
  Other applications of this approach for assessment of air emis-
sions from the landfill included:
•Undisturbed  site emission measurements and prediction of down-
 wind gas species concentration (validated with air quality moni-
 toring data)
•Disturbed site emission measurements under different conditions
 and prediction of downwind gas species concentration at different
 downwind distances (validated with air quality monitoring data)
•Estimate of emission control effectiveness using measured source
 data (validated with air quality monitoring data)
•Verification of source emission measurement data modeling emis-
 sions using off-site air quality data and meteorological data.

CONCLUSIONS

  The assessment approach described  for assessing the air emis-
sions from waste sites/facilities has been shown to be very valuable
in site characterization. The approach provides for a validation of
predicted levels of gas or emissions source terms by employing com-
plementing sampling and modeling techniques. The approach is ap-
plicable to a variety of assessment programs and can be used to  pro-
vide data useful in hazardous waste management design work.

REFERENCES

1. Schmidt, C.E. and Balfour, W.D., "Direct Gas Emission Techniques
  and the Utilization of Emissions Data from Hazardous Waste Sites,"
  presented at the Environmental  Engineering Division Conference
  July 1983.
2. Schmidt, C.E., Balfour, W.D., and Cox, R.D., "Sampling Techniques
  for Emissions Measurement at Hazardous Waste Sites,"  Proc. Na-
  tional  Conference  on Management  of Uncontrolled  Waste  Sites
  Nov. 1982.
                                                                                                       SITE SAFETY
                                                          295
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          CLEAN-UP OF  SHOPE'S LANDFILL,  GIRARD,  PA.
                                          ROBERT D. MUTCH, JR.
                                               JAMES DAIGLER
                                       Wehran Engineering Corporation
                                             Middletown, New York
                                         JAMES H. CLARKE, Ph.D.
                                             AWARE Corporation
                                              Nashville, Tennessee
INTRODUCTION

  Mel Shope began dumping refuse and industrial  waste at the
rear of his property in the late 1950s. Most of the material came
from the Lord Corporation of Erie, Pennsylvania, where Mel
Shope was employed in the  Maintenance Department. The waste
dumped at the site consisted of scrap  rubber, paper,  wooden
pallets, cement, oils, solvents, acids and caustics. Following a fire
in 1971, all solvent disposal at the site ceased.
  The landfill was closed in 1979 after having blanketed an area of
about 4.5 acres (Figure 1). Very evident leachate problems at the
landfill prompted the Pennsylvania Department of Environmental
Resources  to initiate discussions with Mel Shope and the Lord
Corporation. Lord Corporation, recognizing its role as generator
of virtually all of the wastes  in the landfill, accepted responsibility
for investigation and remediation of the landfill.

HYDROGEOLOGIC INVESTIGATION

  A  hydrogeologic investigation was begun in  1979 with the in-
stallation of six monitoring  wells in  the immediate vicinity of the
landfill. After  contamination was  found in the wells,  another
series of wells was constructed further downgradient of the landfill.
All the wells were constructed as well clusters, with two  or three
wells at each site screened at different intervals in the subsurface.
The  early  hydrogeologic work was undertaken by Dr. Samuel
Harrison of Allegheny College. Eleven well clusters were con-
structed, making a total of 37 individual wells at the site. The loca-
tions of the wells are depicted in Figure 2. Analyses of the ground-
water samples from the monitoring network revealed significant
levels of vinyl chloride monomer, MIBK, MEK, acetone, 4-methyl-
2 pentanol, methylene chloride,  1,2-dichloroethylene,  benzene,
toluene and xylene.
  Wehran  Engineering Corporation  was retained by Lord Corpor-
ation in Jan. 1981,  to complete the hydrogeologic investigations
begun by Dr. Harrison  and to develop  a remedial program for
the landfill. Understanding the role  of a landfill within its hydro-
geologic surroundings is vital to conceptualization and design of
remedial measures. A final investigative plan was designed to fill
in several critical data gaps requisite to design of a remedial pro-
gram. A key area where information was lacking was the hydro-
geologic condition of the landfill.
  A specific question of concern was to what extent (if  any) the
basal portions of the landfill intersected the groundwater table.
The investigative program called for four borings within the land-
fill which  were to be completed as small diameter piezometers.
                                                   In addition to providing hydrogeologic information, the piezo-
                                                   meters would also permit direct sampling of leachate within or
                                                   beneath the landfill.
                                                     A second focal point of the investigation was a low permeability
                                                   clay strata at a depth beneath the landfill. The landfill sits atop 20
                                                   to 30 ft of glacial outwash deposits of highly variable and lenticu-
                                                   lar lithology. The glacial outwash grades into lower permeability
                                                   glaciolacustrine and glacial till deposits  at depth. The water table
                                                   is very close to the surface in the area.  Several borings were pro-
                                                   posed to investigate the depth, nature and continuity of that strata.
                                                   It was anticipated that this strata could play a pivotal role in the
                                                   remedial program.  A series of exploratory test pits was also exca-
                                                   vated around the landfill perimeter. The purpose was to further de-
                                                   fine the surficial hydrogeologic conditions and to assess the stabil-
                                                   ity of the soils under excavation, thus providing insight in the selec-
                                                   tion of subsequent  remedial techniques. An additional well cluster
                                                   was also proposed. Well Cluster 12 was constructed approximately
                                                   300 ft downgradient of Well 3 (Figure 1), which appeared to coin-
                                                   cide with the main axis of the plume.
                                                                            Figure 1
                                                         Aerial photograph of Shope's Landfill and its surrounding!
296
REMEDIAL RESPONSE
-------
          MALE l» FEET
                           Figure 2
                           Site plan
  A particularly important objective of the investigation was the
development  of a water balance for the landfill. A quantitative
assessment and tabulation of all mechanisms of leachate genera-
tion in a landfill forms the cornerstone of the remedial action selec-
tion process.  In the case of Shope's Landfill, the water balance
was quite simple. Two mechanisms  of moisture infiltration and
resulting leachate generation from the landfill were identified.
These were the infiltration of precipitation through the landfill
surface and the flow of groundwater through the basal portions
of the landfill.
  The amount of precipitation percolating into the landfill was
calculated employing  the  USEPA water balance method.'  This
technique takes into account climatic, soil, slope and vegetative
considerations  in the estimation of percolation. The extent  of
groundwater  inflow to the landfill  was estimated  by means  of
Darcy's Law and was based upon the observed extent of the land-
fill/groundwater table intersection.  Discharge  mechanisms were
not specifically  quantified, although two mechanisms were  ob-
vious: (1) surface seepage of leachate, and (2) discharge to ground-
water. The results of the  landfill water balance are presented in
Table 1.
                            Table 1
                Mechanisms of Leachate Generation
                                  Est. Rate of Leachate
                                  Generation in a Typical
                                  Climatic Year
Mechanism                        (Gal/day)
Infiltration of Precipitation
Inflow of Groundwater

Total
3,500
  500
4,000
  The evaluation of previous analyses of groundwater led to sev-
eral conclusions. First, the well sampling procedures were insuffic-
iently stringent to prevent cross-contamination and to assure collec-
tion  of truly representative samples. Second,  previous analyses
had focused solely upon organic contamination instead of under-
taking a more balanced program of priority organic pollutants,
heavy metals and  other indicators of groundwater quality. This
deficiency, coupled with the sampling inconsistencies, made con-
fident interpretation of groundwater conditions impossible.
  In order to overcome  this problem, a program for future samp-
ling, designed to assure representative sampling, was  established.
                               A revised analytical program was also proposed which consisted of
                               analysis  for 11 halogenated organics,  eight non-halogenated or-
                               ganics, eight heavy metals and six indicators of groundwater qual-
                               ity (i.e., chlorides, conductance, etc.). Also called for were a Total
                               Volatile  Organic  scan (TVO)  and a Total Volatile Halogenated
                               Organic  scan (TVHO). These less expensive surrogate parameters
                               were added in hopes of performing them in leiu  of GC identifica-
                               tion and quantification of each organic species of concern.
                                 The results of the analyses permitted, for the first time, delin-
                               eation of the extent of the landfill-derived plume of contamina-
                               tion.  The plume  was found to cover an area of eight  acres, in-
                               cluding that portion beneath the landfill. Those parameters most
                               useful in identifying the  extent of the plume were chlorides, spe-
                               cific conductance and total volatile priority pollutants.  Chlorides
                               and volatile organics are  particularly mobile in most groundwater
                               systems,  and their presence is often indicative of the leading edge
                               of the plume.
                                 Mass  loadings  of  the contaminants of concern entering  the
                               groundwater  and surface water regions of the  area were calcu-
                               lated  using the average  concentrations detected in the leachate
                               and the  estimated hydraulic flux through  the landfill. The mass
                               loadings  for pre-remedial action conditions during an average cli-
                               matic year are given in Table 2.

                                                           Table 2
                                              Existing Conditions at Shope's Landfill


Parameter
Total Dissolved Solids
Chloride
Chemical Oxygen Demand
Chromium, Total
Lead
TVO
THVO
1 ,2-Dichloroethylene
1 , 1 -Dichloroethylene
Acetone
MEK
MIBK
Toluene
Xylene
Average Concentration
in Leachate
(mg/1)
2,533
590
3,360
0.25
0.10
129,000
89,900
893
18,852
1,131
386
13,980
1,313
2,340

Mass Loading
(Ibs/day)
84
19.5
111
0.0083
0.0034
4.3
3.0
0.030
0.63
0.038
0.013
0.46
0.044
0.078
REMEDIAL PROGRAM OBJECTIVES
  A particularly critical hurdle in the remediation process, due to
the emotion and controversy created, is the determination of the
acceptable  degree of  pollution  abatement. Professionals  con-
fronted with this decision find it necessary to balance concerns
for the environment and public health with the realities and lim-
itations of available funding and the effectiveness of available en-
gineering options. This difficult decision is made much more troub-
lesome by the uncertainties and paucity of information or stand-
ards on the toxicities of organic chemicals and resultant risks to
public health.
  Notwithstanding the  lexicological uncertainties,  the goals for
the remedial program must be set in as tangible a form as possible.
For example,  the goal  of maintenance of potable groundwater
quality at some key point, such as the property line, is often  used.
This standard is  often  established  as  a combination  of the In-
terim Primary Drinking Water Standards and a more arbitrary
standard for volatile organics. New Jersey sets an active level of 100
ug/1 for total volatile priority pollutants,  with a  level of 50 jig/1
for any single volatile priority pollutant. Although this type of
standard clearly does not differentiate between the variable toxici-
ties of the priority volatile organics, it is an attempt to deal with
the problem in a practical way. In a case where all or a portion of
                                                                                             REMEDIAL RESPONSE
                                                                                          297
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                                                               Table 3
                                                Evaluation of Remedial Action Alternatives
                                                           Shope's Landfill
     Alternative
                                               (1)
                                            Anticipated
                                            Degree of
                                            Abatement
      Alternative I - No Action

      Alternative 2 - Regrading; Surface Water Diversion;
      Cover; Revegetatlon

      Alternative 3 - Impermeable Cap

      Alternative 4 - Impermeable Cap; Southern Cut-Off
      Wall

      Alternative 5 - Circumferential Collection
      System; Leachate Treatment

      Alternative 6 - Circumferential Collection
      System; Southern Cut-Off Wall; Leachate
      Treatment

      Alternative 7 - Circumferential Cut-Off
      Wall and Collection System; Leachate
                                     -0-


                                      44%

                                    87.5%


                                     99+%


                                     99+%



                                     99+%
                                                                  (1)
                                                      Estimated
                                                   Construction Cost
                                                      In Dollars
                    (3)
                 Estimated
              Operational Costs;
               30-yr Duration;
               (Present Worth)
                 In Dollars
   -0-


100,000

200,000


250,000


150,000



200,000
  188,600


  207,460

  207,460


  207,460


2,751,674



2,434,826
                     (4)

                   Estimated
                   Total Cost
                   In Dollars
                    (2) + (3)
  188,600


  307,460

  407,460


  457,460


2,901,674



2,634,826
             Cost Per 1,000 Gal.
             of Leachate Managed
              In $/1000 Gallons
                  1000(4)
               (1) x 43,890,000
 N/A


 IS.92

 10.61


 10.42


 66.11



60.03
Treatment
Alternative 8 - Alternative 6; Impermeable Cap
Alternative 9 - Alternative 7; Impermeable Cap
Alternative 10 - Exhumation
99+% 225,000
99+% 350,000
99+% 375,000
99+% 12,500,000
1,484,282
850,586
229,564
-0-
1,709,282
1,200,586
604,564
12,500,000
38.94
27.35
13.77
284.80
the leachate discharge from a waste site enters an adjacent surface
water body, a similar standard can be established with respect to
surface water quality.
  Once the environmental or public health goals are set, it is then
possible to work  toward a  definition of the level of abatement
required at the waste disposal site. This environmental modeling
can be  performed using simple linear solute transport models or
more sophisticated two or three dimensional solute transport mod-
els, if  warranted.  Input data to the  model can be derived from
literature or laboratory studies in the case of relatively simple or
"first-cut" modeling efforts. If better estimates are needed, field
measurements of key input parameters can be provided.
  The objective of  the modeling is  to define the maximum  dis-
charge of contaminants from the landfill into the groundwater or
surface water beyond which the prescribed performance goals can-
not be  attained.  The discharge  can  be expressed  as  a quantita-
tive discharge of the contaminants of concern (i.e., 0.1 Ib/day of
TCE). The discharge can also be expressed in terms of a percent
abatement by comparison to existing rates of discharge (i.e., if
there was initially a discharge of 2 Ib/day of total volatile prior-
ity pollutants, a reduction to 0.1 Ib/day would be a 95% decrease).
The goals  for the  actual waste site remediation having been thus
established, the land disposal engineer's task is relatively simple—
to evaluate and design a remedial  program which meets the dis-
charge  goals.  Since there  will  typically be  numerous  ways  to
achieve the prescribed discharge goal, a series of alternatives is
evaluated in terms of the costs of  implementation and long-term
monitoring and maintenance costs. The most cost-effective alterna-
tive is then selected and ultimately designed and implemented.
  At Shope's  Landfill, the groundwater quality had already been
degraded beyond potable water standards several hundred feet past
the  property  line.  The objective established  for the remedial  ac-
tion plan at Shope's Landfill was that the existing plume of ground-
water contamination not expand to the point of adversely  im-
pacting  groundwater supplies. This objective was translated into
performance goals for the remedial  action plan in consideration of
the proximity of water supply sources and the relative mobility of
the contaminants of concern within  the aquifer.
                                                           It was decided that the remedial action program  for Shope's
                                                         Landfill should result in more than a 99% abatement of leachate
                                                         contaminants discharged. The attainment of this goal would per-
                                                         mit the ultimate  dissipation of the plume within the aquifer as
                                                         the aquifer's natural attenuating mechanisms became dominant.
                                                         The plan also embodied a comprehensive monitoring program to
                                                         verify this hypothesis over time.

                                                         EVALUATION OF REMEDIAL ALTERNATIVES
                                                           Ten alternatives for remediation of Shope's Landfill were con-
                                                         sidered, although three were dismissed since they failed to achieve
                                                         the requisite 99+% abatement  goal.  The alternatives  listed in
                                                         Table 3 ranged from "No Action" to excavation of the landfill
                                                         and subsequent off-site disposal of the exhumed material. The re-
                                                         maining alternatives considered to be capable of meeting the pre-
                                                         scribed performance goals, consisted of combinations of upgrad-
                                                         ient (southern) or circumferential cutoffs, leachate collection sys-
                                                         tems and low permeability final cover (capping).
                                                           In each case,  except Alternative  1, the remedial plan also in-
                                                         volved removal of drums lying on the  surface  or encountered in
                                                         construction  activities and removal of standing pools  of leachate.
                                                         These costs are not reflected in Table 3. Construction costs for the
                                                         alternatives under consideration (Alternatives 4 through 10) varied
                                                         from $250,000 for Alternative 4 to $12,500,000 for Alternative 10.
                                                         Alternative 10 was omitted from further consideration due to the
                                                         unreasonable costs,  thereby setting the upper limit  of the con-
                                                         struction costs at $375,000.
                                                           The annual operating  and maintenance costs for each alterna-
                                                         tive were also evaluated. A uniform period of 30 years  was em-
                                                         ployed to calculate the present worth value of  the annual costs.
                                                         The interest rate over the 30 years was assumed to be 10°7o. Annual
                                                         operating costs were assumed to remain  constant. Although it is
                                                         likely that the operation  and maintenance period would be longer
                                                         than 30 years for each alternative, the effect of longer time periods
                                                         of total present worth costs is nominal. Total costs are then cal-
                                                         culated as the sum of the construction costs and the present worth
                                                         value of the 30 years of operational and  maintenance expenditures.
                                                         The last column of Table 3 presents the costs in terms of the cost
298
REMEDIAL RESPONSE
-------
per 1,000 gallons of leachate managed over the 30 year period.
Leachate management is considered to  include leachate preven-
tion as well as leachate collection and treatment.
  The impermeable cap  and upgradient (southern) cut-off wall
alternative was selected since it achieved the prescribed degree of
abatement at the least cost.
REMEDIAL ACTION PLAN
  The selected remedial  program, Alternative 4,  encompasses a
number of individual  remedial components. The principle objec-
tive of the plan is the virtual elimination of recharge to the land-
fill, which is accomplished by the combination of the imperme-
able cap and the upgradient cut-off wall. The plan's major com-
ponents are:
1. Removal and off-site disposal of drums from the landfill sur-
   face  and  those encountered  in regrading  of  the  fill's side-
   slopes
2. Removal of standing pools of leachate and site drainage facil-
   ities
3. Surface water diversion and site drainage facilities
4. An impermeable final cover (cap)
5. An upgradient (southern) cut-off wall
6. A short- and long-term monitoring program
   Several of these components  warrant further discussion  with
respect to their engineering design.
Final Cover (Capping)
   The final  cover or "cap" of the landfill  was designed with the
intent to cut off virtually all recharge to the landfill. Consequent-
ly, the cap was designed, where feasible, as a composite cap in-
corporating  both compacted clay and a geomembrane. Extensive
regrading was required in  preparation for the placement of the
cap. Regrading involved both trimming back  the nearly vertical
sideslopes along some sides of the landfill and placement of up to
6 ft of clean fill on top of the landfill to bring the subgrade slope
to at least 4"%. The top of the fill was essentially flat prior to re-
grading.
   Two  final cover designs  were uSed. The majprity of the land-
fill was capped with a composite cap consisting of (in ascending
order):  12 in. of compacted clay with a maximum permeability of
1 x 10~6 cm/sec, a 20 mil PVC membrane and 18 in. of soil capable
of supporting begetation. Where the slope of the prepared surface
exceeded 25%, a modified final cover was  specified consisting of
(in ascending  order) 18 in. of compacted clay with a maximum
permeability of 1 x 10~7 cm/sec followed by 18 in. of soil capable
of supporting vegetation. This latter cover design constituted only
15% of the cap, being localized to the particularly steep northern
and western sideslopes.
Subsurface Cut-Off Wall
   The design of an effective cut-off wall in a relatively complex
hydrogeologic setting, such as that of Shope's Landfill, must be
founded upon a predictive model capable of quantitatively assess-
ing the  effectiveness of various designs. In this case,  the assess-
ment was performed by flow net analyses. A flow net is a graphical
representation of a groundwater flow system consisting of an inter-
secting  and  interrelated network of  equipotential lines and  flow
lines.2 The objective of the flow net analysis was to depict and
quantify flow beneath the wall and also to predict the position of
the post-construction phreatic  surface  (groundwater table) be-
neath the landfill, downgradient of the cut-off wall.
   The flow  net analysis revealed that the combination of the sub-
surface cut-off wall and the impervious cap  should  result in  a
marked decline in the phreatic surface (groundwater table) beneath
the landfill. This decline  should be approximately 6 ft immediate-
ly downgradient of the cut-off wall, about 4.5 ft, 100 ft downgrad-
ient of the cut-off wall and approximately 2 ft, 200 ft downggrad-
ient. At either end of the cut-off wall,  boundary effects will re-
duce this decline to some extent. The combined effect of the cut-
off wall and the impervious cap should be, therefore, to decrease
the phreatic surface within the fill to such an extent that the inter-
section of the phreatic surface and the base of the landfill is min-
imized or eliminated. Accordingly, leachate generation attributable
to groundwater flow through the waste should  be virtually elim-
inated in keeping with the overall objective of the remedial action
plan.

REMEDIAL PLAN IMPLEMENTATION
  Initial remedial efforts involved characterization  and removal of
exposed drums  and regrading of the site, particularly the landfill
itself. Waste deposition at the landfill resulted in a  majority of the
edges of the landfill being very steep and, in some areas, essen-
tially  vertical. The deteriorated and loosely packed nature of the
drums and waste materials resulted in dense growths of vines,
bushes and small trees through the slopes. The engineering design
called for reduction of the slopes by the removal of  drums and veg-
etative growth and regrading  to allow the placement of  the final
compacted clay, geomembrane and topsoil cover.
  Since the simple task of clearing and grubbing was to  occur in
close  proximity to  drums known to contain toxic  and flammable
substances, constant monitoring of the  air, continual observation
and supervision of the laborers and  the presence of the fully
equipped safety equipment trailer near  the work were considered
essential to the  safe performance of the work. Special training of
the newly hired workers was required to familiarize them with the
use and  care of respirators,  self-contained  breathing apparatus
and fire extinguishing equipment and methods. Additionally, a pul-
monary and respiratory  physical check-up was required for all
personnel to be involved with the drum removal.
  A  soil erosion and sedimentation plan was implemented, in-
volving construction of channels around the perimeter of the land-
fill and a large sedimentation basin. All runoff was  to be routed to
the sediment basin prior to sampling to ascertain its acceptability
for discharge. Every effort was made to  prevent the entry  of leach-
ate to the stormwater retention basin.  Intermediate collection
ponds, solely for leachate containment, were constructed at areas
of visible seepage. All collected leachate was pumped from  the
collection basins to specially lined tank trucks for transport to ap-
proved treatment facilities. When the seepage problem was min-
imized by placement of the cap, the intermediate ponds were filled
with compacted soils.
  Prior to construction,  a comprehensive soils investigation had
been  conducted to  locate a borrow pit which could supply  the
quantity and quality of clay necessary for the cap. More than 20
sites,  mostly active borrow pits, were investigated; only two  sites
were found acceptable.
  Compaction of the clay was initially accomplished with a static,
two-behind, sheepsfoot roller. However, after compaction control
testing with a nuclear densometer (used  to correlate achieved field
moisture and density to laboratory permeabilities) indicated  that
this equipment  did not obtain the required densities, a smooth
drum vibratory  two-behind roller was  brought to the job.  The
sheepsfoot and  smooth drum roller were then used in conjunction
with each other. The sheepsfoot roller provided the kneading ac-
tion important  in achieving low soil permeability and knitting of
subsequent lifts  (used before  and after the smooth drum roller),
and the smooth drum vibratory roller providing  the high densities
and smooth surfaces for subsequent PCV membrane placement.
  Approximately 4 acres of 20 mil PVC membrane were placed
over the compacted clay.  Panels up to 400 ft x 50  ft were used to
minimize  the required field  seaming.  During  the warm, early
autumn, seaming and placement of the  PVC  membrane were rou-
tine and relatively simple tasks. However, as colder weather accom-
panied by persistent rain and snow set in, special techniques had to
be developed to correctly place and seam the membrane.
  Rainwater collecting on top of the geomembrane severely ham-
pered the seaming operation.  This  often had to be controlled by
actually constructing small soil dams on top of the membrane to
                                                                                            REMEDIAL RESPONSE
                                                          299
-------
keep water away from the seams and by supporting the seam from
below with cardboard to provide a firm, dry base on which to seam
the sheets.
  Cold weather also created a problem for  the solvents used to
bond adjacent sheets of PVC. Methods of warming the membrane
and the solvents included the use  of kerosene "torpedo" heaters
and electric hair dryers. These instruments not only  heat but also
dry the membrane and allow seaming to proceed  effectively in
moderately cold and wet conditions. The  liner was  then covered
with soil. This operation was accomplished by pushing the soil out
over the geomembrane, being careful to always maintain a min-
imum of 18 in. of soil beneath the bulldozer.
  Prior to construction of  the slurry trench  cut-off wall, a work
platform was built to  provide a  relatively flat working surface.
Existing grades along the slurry trench outline were  approximate-
ly 8 to 10%. The top of the  work platform was constructed to pro-
vide a slope of 2%—steep  for slurry trench construction, but ac-
ceptable. Two smaller slurry mixing and holding ponds were con-
structed adjacent to the water supply and storage ponds.  Soil of a
specified gradation was trucked to the site for mixing with ben-
tonite  slurry to produce a trench  backfill capable of meeting the
1 x 10~7 cm/sec permeability specification.
  The bentonite-soil backfill mix was also subjected to  a search
and laboratory investigation. Samples of the soil, bentonite and
mixing water were shipped  to a soils lab for  testing  of the design
mix and preparation of field quality control data. Following com-
pletion of the slurry trench cut-off wall, the cap was  "keyed" into
the top of the wall.
 GROUNDWATER MONITORING
   The groundwater  monitoring program, aimed at assessing the
 effectiveness of the remedial measures, was designed to maximize
 cost-effectiveness while still ensuring a thorough understanding of
 the fate and distribution of contaminants within the plume.  This
 was achieved through a judicious selection of both sampling points
 and chemical parameters. The overall program incorporated the
 following approach:
 •Use of indicators such as specific conductivity, chloride ion  con-
 centration  and total volatile organics to delineate the areal and
 vertical extent of the plume
 •Analysis for specific organic constituents and heavy metals to
 evaluate character and  distribution of contaminants  within the
 plume
  Those chemicals which were present in high concentrations and
 had the highest mobilities, together with the indicators used to de-
 lineate the plume were selected for long-term monitoring. Moni-
 toring results will be  interpreted annually as part of an assessment
 of the effectiveness of the remedial program. A summary report of
 the post-construction monitoring will be prepared at the end of five
 years.

 REFERENCES
 1.  Fenn, D. and Hanley, K.J., "Use of the Water Balance Method for
   Predicting Leachate from Sanitary Landfills," Washington, USEPA/
   OSWP, 1973.
2.  Cedergren, H.R., Seepage, Drainage, and Flow Nets, John Wiley &
   Sons, New York, 1967.
300    REMEDIAL RESPONSE
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          APPROACH TOWARDS ESTABLISHING INTERIM
                HAZARDOUS WASTE  CLEANUP CRITERIA

                                         RICHARD A.  DIME, Ph.D.
                                        MARWAN  M. SADAT, Ph.D.
                                        JORGE BERKOWITZ, Ph.D.
                           New Jersey Department of  Environmental Protection
                                  Hazardous Site Migration Administration
                                              Trenton, New Jersey
INTRODUCTION

  There is great concern among scientists, academicians and the
general public about chemicals in the environment and their human
health implications. In the past decade, numerous legislation has
been passed and implemented to control the indiscriminate release
of chemicals into the ground, the water, the atmosphere and work
place environments. Legislation has been adopted to regulate the
disposal of chemical wastes and to rectify the situations created by
poor waste disposal techniques used in the past.  With the estab-
lishment of Superfund, the enormous task of remediating uncon-
trolled hazardous  waste sites is beginning, however, guidelines to
direct cleanup activities are not available.
  The Federal government, through the USEPA, is mandated to
develop methods and criteria for determining the appropriate ex-
tent of removal,  remedy and  other measures to remediate haz-
ardous  waste sites as described in the "Comprehensive Environ-
mental  Response  Compensation and  Liability Act of 1980". To
date, these guidelines have not been forthcoming  and the absence
of such criteria make remediation efforts quite difficult. Regula-
tory  agencies  are forced to rely on intuition and judgement,
rather than good science. Further, regulatory agencies are placed in
a position of entering into consent agreements with private parties
(a) causing industry to embark on remediation  without precise
knowledge of the objectives  or their extent and (b) causing regu-
latory agencies and industry to enter into cleanup agreements with-
out defined goals causing criticism at later dates.
  New  Jersey has a critical hazardous waste problem. The State
has generated  funds  and is  acquiring staff  power to tackle the
tremendous problem of uncontrolled hazardous waste sites within
its borders. As the State can not wait for the federal government to
establish hazardous waste cleanup criteria, the N.J. Department of
Environmental  Protection (NJDEP) is in the process of develop-
ing interim guidelines. It is the mission of the NJDEP to "formu-
late comprehensive policies  for the conservation of natural  re-
sources of the State,  the promotion of environmental protection
and the prevention of  pollution throughout the State" (NJSA
13:l-D-9). The State of New Jersey has several legislative mandates
which adopt an anti-degradation policy in environmental protec-
tion and this coupled with the protection of human health are the
premises upon which these guidelines are being developed.

GENERAL CONSIDERATIONS
  This  Report summarizes NJDEP's approach to setting interim
guidelines, the classification  system employed, criteria for place-
ment of chemicals into  the classification system,  chemicals to be
classified and methodology to be used to establish acceptable
contaminant levels at remediated sites. Guidelines could be es-
tablished (1) on a site specific basis according to existing or poten-
tial land uses, proximity to populated areas or  proximity to en-
vironmentally sensitive areas (i.e., wildlife  refuses), or (2) based
on site hydrogeological characteristics (i.e., depth to aquifer, soil
type, potential for erosion), or (3) which would be applied to all
sites regardless of site characteristics or locations.
  The development of site-specific guidelines seems to be a never
ending task as the number of guidelines to be developed would
depend on the number of sites to be remediated. The formula-
tion of one  set of guidelines to be applied to all sites is somewhat
more straightforward, yet, may be questionable in value. A work-
able approach is a combination  of the two. The guidelines  cur-
rently being developed by NJDEP are general in scope and are to
be modified based on specific site characteristics. This appears to
be the only realistic approach toward developing guidelines to
protect man and the environment while not needlessly spending
tremendous sums of money and time during remediation efforts.

CLASSIFICATION SCHEME

  A variety of chemical classification schemes can be found in the
scientific literature. The  European Economic Community uses a
numerical hazard ranking scheme to classify new chemicals con-
sidered for  production. The chemicals are  placed into categories
(black, white, gray) depending on the number generated by the
ranking  scheme. An alternative  is to establish  broad categories
based on selected parameters (i.e., carcinogen, noncarcinogen),
followed by placement of the chemicals of interest into the appro-
priate categories. Either approach would yield a workable system
for classifying chemical hazards  and  each  is likely to yield  sim-
ilar results.  NJDEP has  established broad  categories  into which
chemicals of interest will be placed.

Chemicals to be Included in Remedial
Action Guidelines

  The number of chemicals known is tremendous and to include all
these chemicals into the Hazardous Waste Cleanup Criteria is an
impossible task. Accordingly, NJDEP decided to incorporate into
the following interim guidelines: (1) known human carcinogens,
(2)  suspected  human carcinogens (known animal carcinogens),
(3) compounds (and metabolites)  recognized as being toxic to man
and/or biota, (4) compounds  resistant to  decomposition in the
environment (persistent), and (5) any priority pollutants not in-
cluded above since these are currently regulated.
                                                                                     REMEDIAL RESPONSE
                                                      301
-------
                                                           Class
                                                             I

                                                             II

                                                            III

                                                            TV

                                                             V

                                                            VI

                                                            VII

                                                           VIII


                                                            DC
Known Human Carcinogens
Suspected Human Carginogens
Extremely Toxic Chemical:
  (LD»50mg/kg)
Very Toxic Chemicals
  (LD» 50-500 mg/kg)
Moderately Toxic Chemicals— (Persistent and

  (LDjo 500 mg/kg)                Degradable)

Metals

                            Figure 1
              Proposed Chemical Classification Scheme
  Chemicals will be added or deleted from the guidelines as re-
quired and when justified.
Chemical Classification System
  Chemicals will be placed in one of ten categories (Figure 1).
Placement into the classification scheme is based  on the toxicol-
ogy, environmental chemistry and environmental fate of the chem-
ical. The system is devised to differentiate carcinogens from non-
carcinogens, and  persistent  compounds from  degradable  com-
pounds.  The utilization  of such an approach allows for the es-
tablishment of realistic contaminate levels which would be accep-
table after remediation.  For example, PCBs and benzene, both
human carcinogens, would fall into different categories with the
acceptable levels for PCBs being more stringent than for benzene
since PCBs are resistent to degradation in the environment.
  A chemical must meet a majority of the criteria  listed to be
placed into a particular category described below. A few examples
of chemicals which clearly fall  into  each category are provided
in Table 1.
I. KNOWN HUMAN CARCINOGENS—PERSISTENT
  All chemicals that:
(a)  have been shown via epidemiology or isolated case  reports to
  cause cancer in humans. A chemical is considered a known car-
  cinogen  when  a solid  link between exposure  and  cancer in
  humans  is well documented. If the results of a  study are ques-
  tionable due to exposure to multiple chemicals or lifestyle, such
  as smoking, the study is  considered  inadequate  to establish
  human carcinogenicity and these chemicals would be placed in
  III or IV.
(b)  are resistant to metabolism by aquatic and terrestrial biota
    and microorganisms.
(c)  are resistant to environmental hydrolysis and photolysis.
(d)  exhibit the tendency to bioaccumulate.

II.  KNOWN HUMAN CARCINOGENS—DEGRADABLE
  All chemicals that:
(a)  have been shown via epidemiology or isolated case  reports to
    cause cancer in humans (I(a)).
(b)  are susceptible to environmental hydrolysis, photolysis and/or
    biological decomposition.

III. SUSPECTED HUMAN CARCINOGENS—PERSISTENT
  All compounds that:
(a)  have  been shown to  initiate malignant neoplasms in at least
  one  species of laboratory animals regardless of route  of admin-
  istration of test chemical.
(b) are resistant  to  metabolism by aquatic and  terrestrial biota
  and microorganism';
(c)  are resistant to environmental hydrolysis and photolysis.
(d) exhibit the tendency to bioaccumulate.

IV. SUSPECTED HUMAN CARCINOGENS—DEGRADABLE
  All compounds that:
(a)  have been shown to initiate malignant neoplasms in at least one
  species of laboratory animals, regardless of route of administra-
  tion.
(b)  are susceptible to environmental hydrolysis, photolysis and/or
  biological decomposition.
V.  EXTREMELY TOXIC CHEMICALS—PERSISTENT
  All compounds that:
(a)  exhibit LDM values less than SO mg/kg in standard laboratory
  animals or aquatic species.
(b)  are resistant to metabolism by aquatic and terrestrial biota and
  microorganisms.
(c)  are  resistant to environmental hydrolysis and photolysis.
(d)  exhibit the tendency to bioaccumulate.
VI. EXTREMELY TOXIC CHEMICALS—DEGRADABLE
  All compounds that:
(a)  exhibit LD50 values less than SOmg/kg in standard laboratory
  animals or aquatic species.
(b)  are susceptible to environmental hydrolysis, photolysis and/or
  biological decomposition.
                                                                                              Table 1
                                                                   I. Known Human Carcinogens-Persistent
                                                                   II. Known Human Carcinogens-Degradable

                                                                  III. Suspected Human Carcinogens-Persistent
                                                                  IV. Suspected Human Carcinogens-Degradable
                                                                  V. Extremely Toxic-Persistent
                                                                  VI. Extremely Toxic-Degradable
                                                                 VII. Very Toxic-Persistent
                                                                 VIII. Very Toxic-Degradable

                                                                  IX. Moderately Toxic Chemicals
                                                                      Persistent and Degradable
                                                                  X. Metals
                                      PCBs
                                      benzene
                                      dimethyl sulfate
                                      amitrole
                                      kepone
                                      lindane
                                      mirex
                                      Toxaphene
                                      TCDD
                                      dibromochloropropane
                                      dimethyl carbamoyl
                                      nitrosoamines
                                      endosulfan
                                      endrin
                                      endrin aldehyde
                                      nitrophenol
                                      Acrolein
                                      1,2 dichlorobenzene
                                      1,2,4 trichlorobenzene
                                      higher chlorinated benzenes
                                      nitrophenols
                                      phenol
                                      hexachlorocyclopentadiene
                                      1,1,1 -Trichloroethane
                                      1,2-dichloropropane
                                      1,3-dichloropropane
                                      methyl chloride
                                      methyl bromide
                                      dichloroethylene
                                      isophorone
                                      phthlates (non-carcinogenic)
                                      2-4 dimethylphenol
                                      antimony
                                      copper
                                      mercury
                                      selenium
                                      thallium
                                      zinc
 302
          REMEDIAL RESPONSE
-------
VII.  VERY TOXIC CHEMICALS—PERSISTENT
  All compounds that:
(a) exhibit  LDJO values of 50-500 mg/kg in  standard laboratory
  animals or aquatic species.
(b) are resistant to metabolism by aquatic and terrestrial biota and
  microorganisms.
(c) are resistant to environmental hydrolysis and photolysis.
(d) exhibit the tendency to bioaccumulate.

VIII. VERY TOXIC CHEMICALS—DEGRADABLE
  All compounds that:
(a) exhibit  LD50 values of 50-500 mg/kg in  standard laboratory
  animals.
(b) are susceptible to environmental hydrolysis, photolysis and/or
  biological decomposition.

IX.  MODERATELY TOXIC CHEMICALS-
     PERSISTENT OR DEGRADABLE

  All compounds that exhibit LD50 values greater than 500 mg/kg
in standard laboratory animals  and aquatic species regardless of
their behavior in the environment.

X. METALS

  Any noncarcinogenic metal (on priority pollutant list) will be
placed into this  category.
  Information on carcinogenicity  is obtained from the Second
Annual Report on Carcinogens (NTP),  I ARC monographs and
EPA-CAG Reports. Toxicology and aquatic toxicology data is ob-
tained from the Registry of Toxic Effects of Chemical Substances
(RTECS), Toxicology Data Bank (TDB), the Handbook of Toxic
and  Hazardous Chemicals and the Merck Index. Oral LD50 data for
the  most sensitive species reported will  be used.  When no oral
LD50 data are available, data from other routes of administration
will  be used. If no toxicity data are available quantitative structure
activity relationships will be used, if appropriate, or toxicity will be
predicted based on scientific judgement  inferred from closely re-
lated structural analogs.
  Sources for environmental chemistry and fate information will
be obtained from the Water-related Environmental Fate of 129
Priority Pollutants—Volumes I  and II, and from other available
scientific literature.  When data are lacking, established physical-
chemical relationships or  good scientific  judgement inferred from
structural analogs will be used to estimate  the desired parameters.
 Establishment of Acceptable Contaminant
 Levels at Remediated Sites
  Acceptable contaminant levels in soils, ground water and land
 (surface) runoff entering into rivers or estuarine environments for
 remediated sites will be established. These levels will be based on
 the protection of human health and on the NJDEP's policy of non-
 degradation of the environment:
SOILS
  The acceptable residual contaminant level on soils will be based
on the potential of the compound to migrate into groundwater and
the potential for adverse health effects from direct contact with soil
(after remediation).  An appropriate model  incorporating soil
adsorption/desorption coefficients, water solubility and soil char-
acteristics will be used  to assess the potential for groundwater
contamination.

GROUNDWATER
  Groundwater will be viewed as a potential  source of drinking
water. When setting acceptable levels,  all degradation processes
other than chemical hydrolysis will be considered unimportant.
Available Water Quality Criteria and  suggested no adverse re-
sponse levels (SNARLs) will be used when available.

LAND (SURFACE) RUNOFF
  Surface water receiving land runoff from remediated hazardous
waste sites will be viewed as a possible  source of drinking water,
commercial  fisheries  and shellfish  resource,   recreational area,
and/or ecological habitat. Acceptable contaminant levels in land
runoff will be set so none of the above uses would be disrupted.
  The establishment of acceptable  contaminant levels in soils,
groundwater and land (surface) runoff is a complicated task requir-
ing a thorough knowledge of the chemical and physical properties
of each chemical (or class of chemicals)  for which acceptable con-
taminant levels are desired. The NJDEP is actively reviewing avail-
able  data which will allow the formulation of acceptable contam-
inant levels. Although it would be premature to propose such lev-
els at this time, generalizations about acceptable levels can be
made.
  Acceptable levels  for  known  human  carcinogens will be more
stringent than noncarcinogens. Within each group, acceptable lev-
els for persistent compounds  will be more stringent than for de-
gradable compounds. Levels in groundwater will be more stringent
than those for surface  waters  since more  dissipation processes
are likely to prevail in the latter.
SUMMARY

  The State of New Jersey, through the Department of Environ-
mental Protection, is formulating interinxguidelines for use during
hazardous site remediation based on the protection of human
health and a  policy  of non-degradation of the environment. Al-
though not yet complete, the approach taken by NJDEP is being
presented for review and comment by scientists and policy makers.
NJDEP welcomes comments to help achieve the goal of establish-
ing scientifically justifiable guidelines for  use in  hazardous site
remediation.  It is hoped that the effort of NJDEP coupled with
comments by interested individuals  will produce guidelines that
will enable the State to remediate hazardous waste sites in a manner
that  will  protect man and the environment without spending large
sums of money and time needlessly.
                                                                                           REMEDIAL RESPONSE
                                                         303
-------
                   TRAINING RESOURCES FOR SUPERFUND

                                        BENJAMIN TAYLOR, Ph.D.
                                  GEORGE W. SCHLOSSNAGLE, Ph.D.
                                                NOEL URBAN
                                       Office of the Chief of Engineers
                                               Washington, D.C.
INTRODUCTION

  In 1980, Congress passed, and the President signed, enabling
legislation  establishing the Comprehensive Environmental Re-
sponse Compensation and Liability Act (CERCLA) better known
as Superfund. The intent of the Superfund program was to estab-
lish a means by which former hazardous waste sites could be more
effectively  cleaned-up or controlled.  The USEPA was assigned
overall responsibility for management of the Superfund program,
and in 1982 the USEPA and the Army Corps of Engineers signed
an interagency agreement. Under this agreement, USEPA assigns
to the Corps responsibility for providing  technical assistance and
supervision of engineering design and construction for Federal lead
remedial actions.
                                                   An important aspect which had to be considered by the USEPA
                                                  and Corps, as well as private contractors involved in Superfund
                                                  activities, was the training of personnel. A review of available re-
                                                  sources for training showed that, generally, training specifically
                                                  geared to Superfund was very limited. Most of the available train-
                                                  ing resources were devoted to emergency response measures and
                                                  spill control techniques. In most cases actual remedial action (for
                                                  example, site cleanup) was not considered.
                                                   This picture is changing somewhat as the need for training in
                                                  Superfund related activities increases. Closer review of many of the
                                                  courses devoted to emergency response training indicated that, in
                                                  many instances, some of the material was also relevant to remed-
                                                  ial  action. In fact, some organizations offering training have
                                                  started to include some discussion of remedial actions.
                                                      Table 1
                                       Superfund Training Resources—Governmental
AGENCY

MISI. Fin righting Acid.
CM Iciponie Brinch
CON mi I
Cout Guird Mir. Sftr. Sen.
USD* Old. Seh.
Amy Log lit. Mgwt. Ctr.
DoD (JMPTC)
Nit. Nln« Kith. 1 Sftr. Acid.
FEMA (Kit. Bur. Trn. Ctr.)
FEXA [N.t. Fir* Acid.)
Fll. St. Fir* Colllgt
Mil. Dipt, or Tinn.
CoD Army Corpj Engs.
Dlv. of Ifcer . Srva.
Ohio St. Fin Mirih. Off.
KIOSH (Dlv. of Trn. t Manpower Dev

OSHA (Trn. tnit.)
DoT Tnniportitlon Sfty Inst.)
Nebr iki Fir* Aginey
Mont ni Oept. of Mil, Affilrs
HI»I Sch. Trins, Ngnt.
At S . Off of Dier. Sr»J.
ADDRESS

59 Horsepond M.. Sudbury. NA. 01776
Edison Ub. Edison. N.J.. 04*37
6 Penn. Ctr. Plata. PMle. PA. 1910*
Torktown, VA, 23690
11th 4 Independence Av... Wish. D.C. 20250
DRXMC-A*, Ft. Lee. VA. 21801
Aberdeen P.O., MD. 21005
P.O. Bo i 1166. Beckley WV. 25401
1(825 S. S*ton Av«.. Dmltsburg, MD, 21727
16425 S. Seton A*i.. Bmltsburg. MO, 21727
1501 S.W. Broeduey. Ocili. FL. 32670
3011 Sldeo Dr., Nishvllle. TN. 3T20«
P.O. Bo i 1600, Huntsvllle. AL, 35807
B5 Still CipHol. St. Piul. MN. 55155
8895 E. Main St. fteynoldsburg. OH »30«8
)
«"6T6 Colwbll Pkvy.. Clnn.. OH. 15226
1555 TUes Dr.. DCS PI lines. 11. 60018
6500 S. HicArthur Blvd.. Okls City, OK 73125
3721 W. Cumin*, Lincoln. HE, 6852*
Dlsistir ind Ener. Srvs. Dlv., Helens, NT
NSPDM. Oaklind Amy Bist, Oaklind, CA 9*625
P.O. Bo i 758, Conw.y, AK, 72032
PHOME CONTACT

Stephen Coin (617) **3-"926
Thomu VU (513) 6M-7537
H. «. Rhoids (215) 977-1560
(Mr. Jin Townliy (202' *26-62A6
Dr. Ednund Fulkcr (202' <*7-207T
*tglitrir'i Offloi («0») 73»-337(
nsl* M. Clirk (301) 27H.f1n5
Jin Sohiwlti (30«) 255-0* 51
Bitty Funn (202) 2R7-'902
•ogtr Unihin (301) M7-6771
Mr. Stirk (90*) 732-0526
Dr. Krwiir (615) 7*1-5141
Jmes Willis (202) 495-5032
Hick Moluton i 612) 296-0*59
Ron Ryin (61* 86«-5510

Oonni Wiligi (513) 64*-8225
Frink Wilsh (202) 376-2001
David Coodnan («05) 686-*82*
Viyni Mclaughlin («02) 171-2403
Ed Swell Jh («06) «*9.303«
Ms. Cannon (901) 872-5706
Ut Collard (501) 37*-1201
SUBJECT
MEAS

1.10 A n
All
10
1-10 A 12-1*
1-10 A 12-1*
,5 4 10
,5 4 10
-10 * 12-1*
.4.11.13 » 1*
-10. 13 t 1*
-* 4 10
-5.4.10 A t*
-it
.6.9 A 10
-10 4 1*

-10 4 12-1*
-10
.5.7.9 4 10
-« 4 10
1-*. T 4 10
5.10
1.3.10
TAPES 4
MANUALS

T«s
V*S
No
Tei
No
Tas
Yis
Tts
Tas
Tas
Tas
No
No
Tas
Tas

Tas
Tas
No
NO
No
No
Tas
COST

No
Tai
Tas
No
»«
Tas
^l»t
Tas
"c
Ik
N(
Tas
Tas
Ik
Tas

Tai
*

Nt
No
Tai
*
1.  Hulth ind Sifity
2.  Pirionil Protection
J.  ffc*rgencr S»lf-Hilp leieui
«.  leiplntory Protection
1.  Vehicle Uie it  Kanrdoul Sltei
                                            SUBJECT AIEAS

                                 6.  Usi of Field EqulpMnt
                                 7.  Monitoring
                                 4.  Contingency Planning
                                 9.  Swpllnf Techniquel
                                10.  Handling. Storing and Transport
11.  Orientation
12.  feployia 41ghti and •eiponslbllltln
13.  DMrianer/Dmtdlal Maniganint Prof"*
1*.  Mmulng lestrlete't Ionia
304
REMEDIAL RESPONSE
-------
                                                               Table 2
                                            Superfund Training Resources—Private Associations
AGENCY
ASME (Professional Dev. Dept.)
C«nter for Prof. Adv.
H«t. H«t. Ctrl. Inst.
N.E. Haz. Waste Com.
Cntr. for En. end Env. Mgmt.
Chen. Manufacturer's Assoc.
Government Institutes
Gov. Defuse Coll. 4 Clip. Assoe.
Hit. Hit. Advisory Council
Amer. Ind. Hyg. Assoe. (I.C.E.)
ADDRESS
315 E. «7th St. M.T.. N.T. 10017
P.O. Bo i 864. E. Brunswick. M.J. 08816
P.O. Boi 1085. Alpha. N.J. 08865
Hughes Just. Corep.. Trenton, N.J., OA625
P.O. Boi 536. Fairfax. VA. 22030
2501 M St. N.V.. Wash.. O.C. 20037
P.O. Boi 1096, Rockvllle. MO. 20850
5101 Dtioh Ave.. Silver Spring. HO 20902
1100 17th St., N.W., Vash.r D.C. 20036
175 Wolf Ledges Ptrvy, Akron. OH 44311
Hit. Sfty Council (Sfty. Trn. Inst.}
' FW ». Michigan Ave.. Chicago. II. 60611
PHONE CONTACT
Robert Ferry (212) 705-7743
Edith Webb (201) 249-1400
Mr. Bollokl (215) 258-7015
Robert Roblllard (609) 984-6374
Water Pearee (703) 250-5400
Carl UallU (202) 887-1257
Martin Heavner (301) 251-9250
Lanny Hlokman (301) 583-2898
Julia Selbert (202) 223-1271
J. 1. Contl (216) 762-7294
Director (312) 527-4800
SUBJECT
AREA*
1-1*
1-3,7.10.13
1-3,8,10.13
1.9 i 13
B. 10-13
6*9
11
1-10 A 13-14
11
1-1,7 » 12
10
TAPES i
MANUALS
No
No
Yea
Yes
Yes
Yes
No
Yes
No
No
No
COST
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
  Health and Safety
  Personal Protection
  Emergency Self-Help Rescue
  Respiratory Protection
  Vehicle Use at  Hazardous Sites
              SUBJECT AREAS

 6.  Use of Field Equipment
 7.  Monitoring
 8.  Contingency Planning
 9.  Sampling Techniques
10.  Handling, Storing and Transport
11.  Orientation
12.  Fnployee  Rights and Responsibilities
13.  Emergency/Remedial Management Program
1*.  Managing  Restricted Zones
                                                               Table 3
                                                  Superfund Training Resources—Firms
AGENCY
Env. Haz. Mgmt. Inst.
J. T. Baker Chem. Co.
ITS Corporation
Lion Technology, Inc.
DuPont * Co. (Fin. i Fab. Dept.)
Haz. Hat. Ctrl. Reach. Inst.
Hailna Corporation
Phoenli Sfty. Aasoc.
Trans. Skills Prog.. Inc.
ENSAFE
Gov. Srvs. Inst.

D. W. Ryckman & Assocs.. Inc.
ADDRESS
283, 15 Pleasant St., Portsmouth^ NH^ 03801
222 Red School Ln., PMlllpsburg, NJ, 08865
823 E. Gate Dr.. Mt. Laurel. NJ, 08051
P.O. Drawer 700, LaFayette, NJ, 07818
Barley Hill Plaza, Wilmington, DE, 19JJ98
9300 Colunbla Rd.^ Silver Spring, MD, 20910
7315 Wisconsin Ave., Bethesda, MD, 20811
P.O. Box 515 Phoenlivllle, PA, 19160
320 W. Main St., Kutztowrij PA, 19530
P.O. Box 31207, Memphis, TN. 38131
P.O. Box 5212. Sprlnghlll, FL. 33526
115 W. Wisconsin Ave.j^Neena^ WI, 51916
2208 Welsch Indust. Ct., St. Louis, MO, 63111
PHONE CONTACT
Kevin Soles (603) 136-3950
Robert Outer (201) 859-2151
Charles Lay (609) 231-2600
William Taggert (201) 383-OBOO
Stewart Harrison (302) 999-2390
Beverly Vilcoff (301) 587-9390
Mark Moreln (301) 652-6366
Anthony Fuscaldo (215) 935-1770
Linda Baver (215) 683-5098
Wendell ICnlght (901) 372-7962
Gary J. Gorman (901) 683-8553
Kevin Lehner (111) 722-2818
Jeff Peters (311) 569-0991
SUBJECT
AREAS
1A6.7 * 10
8^10,11 & 12
1.11 & 13-11
1.2.1-R * 10-11
10
1.2,6.7,8,9,10
11 & 13
1-1,6-10,* 13-1*
8.10.11 * 12
1.8.10.11 * 13
10
1t2,1 * 10
1-1.6-8.10.12-1-
FAPES *
ANIIALS
No
No
Yes
Yes
Yes
Yes
No
No
Yes
No
Yes
Yes
NO
COST
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
1.  Health and Safety
2.  Personal Protection
3.  Emergency Self-Help Rescue
1.  Respiratory Protection
5.  Vehicle Use at Hazardous Sites
              SUBJECT AREAS

 6.  Use of Field Equipment
 7.  Monitoring
 8.  Contingency Planning
 9.  Sampling Techniques
 10.  Handling, Storing and Transport
 11.  Orientation
 12.  Employee Rights and Responsibilities
 13.  Emergency/Remedial Management Program
 11.  Managing Restricted Zones
   In this paper, the authors review some of the training resources
 currently available which may be useful to those involved in Super-
 fund activities. This material should only be used as a guide to re-
 sources and is intended only as a reference source. The intent here
 is only to offer  a resource which includes  those sources we are
 aware of and is  not an endorsement  of anyone's product. Many
 courses related to aspects of Superfund are continually being devel-
 oped, and others are  being revised as the training needs dictate;
 therefore, it is important for the reader to keep abreast of changes.

 SUPERFUND TRAINING COURSES
   A survey of available training courses covering various aspects
 of Superfund activities is presented in  Tables  1-4. The offerings
 have been separated into four categories indicating those services
 offered by: governmental agencies (Table 1); private associations
 (Table 2); private firms (Table 3);  and educational  institutions
 (Table 4). In each case, the name of a contact person and the major
 subject areas covered have been included.
   Information about the existence of  videotapes and other course
 materials which may be available  for purchase has also been  in-
                      cluded. For some of the resources shown (especially government
                      sponsored ones) the sessions are free or the cost is nominal. How-
                      ever, for many of the other resources  the cost varies widely de-
                      pending on the offering. Since the exact cost of such services may
                      not be accurate at the time of inquiry, only the fact that the re-
                      source is available free  or for a fee has been included.  One area
                      not covered specifically in the Tables, but which is implicit in most
                      of the course offerings, is the regulatory requirements under Super-
                      fund. In  compiling the  data for Tables 1-4,  it was usually  found
                      that the agency sponsoring the course does cover the regulatory re-
                      quirements for the specific areas covered. The reader should con-
                      tact the person listed to obtain more details regarding course  des-
                      cription and content.

                      OTHER RESOURCES

                        There are other areas of training which may be useful to those
                      involved in Superfund programs. Some of these areas include train-
                      ing in the use  of computerized information systems, and training
                      on how to interpret and use the information and data contained
                      in reference books and manuals. In the following section on LINE
                                                                                                REMEDIAL RESPONSE
                                                                                  305
-------
                                                           Table 4
                                        Superfund Training Resources—Educational Institutions
AGENCT
Rutgers U. (Dept. En*. Scl.)
Dal. St. Fire Sett.
Jnlv. of Delaware Oct. of Civ. Eng.)
Johns Hopkins (Sch. of Hyu. I P. A.)
Jnl» of Cln. (Inst. of En*, nth.)
•at. Spill Ctrl. Sch.
Tex. AtHU. Sr>. (Eng. Eit. Srv.) F.E.
Mlverslty of Teias
low* St. U. (Fir* Sr». Eit.)
Colorado Tm Inat.
Jnly. of Cal. (H. Oee. nth. Ctr.) '
Ire 3r». Tm.
ADDRESS
Cook College. New Brunswick. NJ, 08903
Rte. 2. P.O. Boi 166. Dover. OF.. 19901
Of f of Cont. Ed.. Newark. OE, 19711
615 N. Wolfe St., Baltimore. MD. 21205
3223 Eden Are.. Clnolnatl. OH. 45267
6300 Oeean Dr., Corpus Chrlstl. TX 78112
Drawer. College St».. TX 778*3
Cont. Eng. Studies. Austin. TX 78712
A«es. IA. 50011
1001 E. 62nd Ave.. Denver. CO, 60216
Berkeley. CA, 9*720
COM for Voo. Ed.. Olynpla. WA, 98504
PHONE CONTACT
Vleent Dtgregorlo (201) 932-9571
touts Anablll (302) 736-4773
Dr. C. P. Huan* (302) 738-2741
Dr. Jacqueline Corn (301) 955-33*3
Dr. Raymond Susklnd (513) 872-5701
George OBerholtzer (512) 991-8692
David White (713) 845-7A41/341H
Dr. Nell Armstrong (512) 471-1711
Keith Royer (515) 294-6817
Walter DeFreeee (303) 2R9-*891
Dr. Robert Spear (415) 642-1681
Edward Prendergast (206) 753-5679
SIIBJF.CT
AREAS
1-10 4 13-14
1-6.8-10 A, 1*
10
1.7-9. 12 * 1*
1-10 t 12-1*
1.2.7.8.10.1141;
10 4 14
10
1-4.6 4 10
1.Z.5.8.10.1141J
1-10 4 12-1*
1.2.5-10 4 13
TAPES 4
«ANUAL3
Ha
TM
No
No
No
Kb
NO
No
T«s
T«s
Tta
Tes
COST
111
111
In
111
hi
T.;
hi
hi
to
'II
111
ll
   Health and Safety
   Personal Protection
   Emergency Self-Help Rescue
   Respiratory Protection
   Vehicle Use at Hazardous Sites
                                               SUBJECT AREAS

                                   6.  Use of Field Equipment
                                   7.  Monitoring
                                   8.  Contingency Planning
                                   9.  Sarapllng Techniques
                                  10.  Handling. Storing and Transport
11.  Orientation
12.  feployea »lghts end ResponslbllUlei
13.  Emergency/Remedial HanaKtawnt Profrai
1*.  Manning Restricted Zone*
 DATA BASES, and  the  succeeding  section,  BOOKS  AND
 MANUALS, some of the current resources available in these areas
 are presented. The attempt has not been to prepare an exhaustive
 list of these resources but rather to specify some items which are
 available and which may be useful to those with Superfund respon-
 sibilities at all levels.  Many of the training courses presently avail-
 able have  sections devoted  to an introduction to computer re-
 sources as well as books and manuals applicable  for Superfund
 planning and implementation. Much of the training on computer-
 ized systems, however, is supplied by the vendors of such systems.
 It is up to the purchaser to shop for the best deal.
 ON-LINE DATA BASES

  There are several vendors supplying a variety of on-line com-
 puter searchable records which may be used by those responsible
 for all aspects of Superfund activities. A list of vendors and their
 database services is given in Table 5. Vendors such as Lockheed
 and SDC have quite comprehensive offerings which span a wide
 variety of database systems. Most vendors charge the user an initial
 fee for the necessary log on passwords and start-up fees. Once the
 user has acquired access to a system, charges are incurred with use
 of the system depending upon the specific cost of the database used
 and the telephone connect time to the system.
  Most vendors offer training courses and user manuals as a part
 of their start-up fees and it is incumbent upon the user to take ad-
 vantage of these services  to learn the proper use of the system.
 Each system has its own computer language and cost, and the data
 format may vary widely for the same database among vendors. In
order to limit the time and cost of using a system, it is important
that the user make inquiries of several vendors to  compare costs
of the systems offered.

BOOKS AND MANUALS

  Everyone involved in Superfund activities should be aware of the
many books and manuals available. These references contain a
variety of information which can be used by those involved at all
levels of Superfund planning and implementation.  An integral
part of many of the training courses listed in this paper is training in
the use and understanding of reference materials. Many of these
references contain  physical and  chemical data about hazardous
substances. Others contain information about lexicological  prop-
erties and health and safety data of a variety of commonly used
 industrial chemicals.
                                                        The reader should note that in most instances the edition and
                                                      year of publication have been omitted from the listed references;
                                                      the reason for this omission is that these resources are constantly
                                                      updated and revised. It is incumbent upon the reader to acquire
                                                      the most current references available. The list presented is incom-
                                                      plete and is intended only as a guide to the kinds of information
                                                      available. There are some references which should be considered a
                                                      minimum requirement; these include:
                                                      •Physical, Chemical and Biological data
                                                      •Health and Safety information
                                                      •Hazard assessment and emergency response information
                                                      •Sampling and Analysis methods
                                                        Several organizations such as the American Conference of Gov-
                                                      ernment Industrial Hygienists (ACGIH) and the American Indus-
                                                      trial Hygiene Association'(AIHA) publish a variety of pamphlets
                                                      and manuals. The address for  the ACGIH Publication  Office is
                                                      6500 Glenway  Avenue, Building  D-5, Cincinnati, OH 45211
                                                      (Phone 513/661-7881). References from the ACGIH include:
                                                      •"Air Sampling Instruments for Evaluation of Atmospheric Con-
                                                       taminants".
                                                      •"Documentation of the Threshold  Limit Values (TLV)".  The
                                                       address for the (AIHA) is 475 Wolf Ledges  Parkway, Akron,
                                                       OH 44311 (Phone 216/762-7294) and some of the publications
                                                       obtainable include:
                                                      •"Basic Industrial Hygiene"
                                                      •"Direct Reading Colorimetric Indicator Tubes Manual"
                                                      •"Manual of Recommended Practice for Combustible Gas Indi-
                                                       cators and Portable, Direct Reading Hydrocarbon Detectors"
                                                      •"Respiratory Protective Devices Manual"
                                                      •"Hygiene Guide"
                                                        The  National Institute for  Occupational  Safety and Health
                                                      (NIOSH) and  the Occupational Safety and Health Administra-
                                                      tion (OSHA)  also publish several useful handbooks and pamph-
                                                      lets. These documents may be purchased from  the U.S. Govern-
                                                      ment Printing Office (GPO), Washington, DC 20402 (Phone 202/
                                                      783-3238). Some of the publications available include:
                                                      •"The Industrial Environment"
                                                      •"Occupational Health Guidelines for Chemical  Hazards"
                                                      •"Registry of Toxic Effects of Chemical Substances"
                                                      •"Pocket Guide to Chemical Hazards"
                                                        The USEPA publishes a variety of methods manuals for the
                                                      sampling and analysis of hazardous materials. Some of these man-
                                                      uals can be invaluable to those considering water treatment and
                                                      analysis methods. Some of these references are:
 306
REMEDIAL RESPONSE
-------
                Tables
Environmental Chemical Computerized Data Bases
Dn-Llne Data Bases
MTIONAL LIBRARY OF
(EDICINE - MEDLARS
Avllnt
Cancerllt
Cancer proj
Chenllne
Ned line
led 66 - 70
Med 71 - 7*
led 75 - 76
Med 77 - 79
Foxllne
roxback 65 - 73
Poxback 7* - 78
toxicology Data Bank
BTECS
EH IS
HATREHS
NEDS
SAROAD
STORE!
NPDES
Chemical
Information




X








X
X






OSHA HEALTH DATA
SYSTEM
OHDS
NAWDEX
LOCKHEAD INFORMATION
SYSTEMS - DIALOG
Agrloeola
Air Pollution Tech.
Infer. Center
Aquatle Sciences and
Fisheries Abstracts



Health Effects
and
Toilcologlcal
Information

X
X
X

X
X
X
X
X
X
X
X
X
X
















X
X
Environmental
Information

X






X
X
X
X
X


X
X
X
X

X

X
X

X
X
X
X
Manufacturing
Uses and
Economic
Information













X












X


Disposal
Information















X
X
X
X
X
i

X
X


X

X
Comments

Bibliographic and review data for
non-print materials In health
sciences.
Covers all aspects of cancer
literature: Includes books In
addition to standard sources.
Ongoing research funded during the
most recent three fiscal years:
overlaps with SSIC data base.
Chemical dictionary file: does not
give structural formula: provides
locator Information to MKDLARS data
bases and TSCA Inventory.
Excellent source of blomedlcal/
health effects material: Indexes
Index Medlcus plus special list
journals .
Back files of Medllne
Back files of Medllne
Back files of Medllne
Back files of Medllne
Good for toxlcologlcal and environ-
mental data: many duplicates within
system.
Back files of Toxllne - not search-
able on line.
Rack files of Toxllne
Limited number of chemicals: very
comprehensive dictionary file; lacks
Information on new chemicals.
Registry of toxic effects of
chemical substances, provided by
MIOSH. containing over 10.000
toxlcologleal measurements.
Synonyms In RETECS differ from those
in Chemllne
estimates of II. S. pollutant
emissions for previous years.
Provides data for making pollutant
trend predictions.
Emissions data on pollutants not
regulated hy the Primary Ambient Air
Standards. Included data can he
used for modeling.
Emissions data on the oollutants for
which there are Primary Ambient Air
Standards are collected 'ran about
7S,OflO point sources and T.200 area
sources. Include data on ftTC Code.
and such modeling parameters as
stack height and diameter, emissions
rate . and temperature .
Ambient air quality data 'rom over
»,000 active air monitoring sites
across the country. Uses modeling
to permit evaluation of air quality
data.
Oata on water quality across the
country collected in connection with
•L 02-WO.
Information on the quality and
quantity of discharges which have
been permitted under the National
Discharge Permit Program for all
point source discharges Into '1. X.
waters .

Monitoring data of exposure to toxic
substances.
Water monitoring data from federal
state, and local programs.
Index of data Is available by
location and pollutant category.

Good general agricultural Informa-
tion source.
Good source for air pollution
Information. Contains some emission
data. Closed file to 1978.
Some water pollution data but mostly
Overlaps the MF.OLINE file. Good for
searching 1969-1977 data on-line.
                                             REMEDIAL RESPONSE
307
-------
                                                         TableS
                                     Environmental Chemical Computerized Data Bases (cont'd)
ta-LlM Data Bases
CA Abstracts Search
Chemical
Information
X
CAI Abstracts
Chem Industry notes
Chemname X
Chemsearch X
Chemsls X
Chemical Regulation
•nd Guidelines System
(cues)
Clalma/U. S. Patents X
Clalms/Chem X
Claim/Class X
SYSTEMS DEVELOPMENT CORP. -
)RBIT
Chemcon and
Chem 7071
FSIA
Pa per chen
P/C Newa
Rlngdoo
Safety
Titus
Waterllft
VPI
IIH/EPA - CIS
CNHR
CRYST
CTCP
FRSS
MSSS
OHM-TADS
POSH
RTECS
TSC»PP
WDROP
X



X





X
X


I
I
X
X


Health Effects
and
Tbilcologleal
Information
















X
X





X
I

I

X

T
Environmental
Information

X














X
X
X





«

K


I
(
Manufacturing
Uses and
Reonomle
Information

X
X




X
X
X


1

»
Y.

t

X



t
<




T

Msposal
Information
X

X



X
X
X
X

t


T


t
X




»
«

«


t
T.
Comments
Information.
Deals primarily with applied
agriculture.
Information.
substructure searching via
nomenclature .
Chemical dictionary file - or moat
recently cited substances in CA
Search .
Chemical dictionary file or ohemle.il
substances cited only once during
C. I. period.
Guide to II. S. federal government
regulatory material relating to
control of chemical substances.
Patent and use data.
Patent and use data.
Dictionary file enhances retrieval
In the two files listed above.

Overlaps CA search.
food science and teehnoloav data
base.
Uses Information: paoer Industry.
Business and economic Information In
the petroleum industry.
Pharmaceutical Information.
Information on industrial and
occupational safety: environmental
and ecological safety.
Covers uses and biological and
environmental Information on
petroleum Industry.
International coverage of energy.
biochemistry, environment.
pollution, analytical chemistry and
health Information concerning vater.
Patent specifications.

Carbon 11 Nuclear Magnetic "esourct
Search Systems provide Information
for compounds hearing specific
spectral characteristics.
"rolvde access to the Cambridge T.
rav Cryatallographte tta *ase of
37,0?* structures.
CTCP permits searching of common
commercial products hv identifying
the product or its constituents.
•Hie toiteltv of the products in Ct»
will also he available.
"rovlrtes access to up-to-date Infor-
mation on regulatlona, rules.
atandards and guidelines Involving
chemical aubstances.
•<*S.S permits search for maas
spectral data. Oata baae Include!
spectra of 13."" eompeunda.
OHH-TUDS data base Includes a «l*e
variety of physical, chemical.
biological, toileologlcal and
commercial data on these matarlall,
with emphasis placed on their
deleterious effects on water
qualllty. lip to 126 different
fields of Information are maintain*
for more than 1.000 ehemteala.
Permits searching or data eollaeMi
by Joint Committee on Bowler
mr«Vactlon Standarda. 11.000
substances contained in data bate.
Including organles. Inorganics,
minerals and alloVR.
*ee previous listing.
lant and production range or
chemical reported under T*C»-
ntstrlbutlon teglatry of Organic
Pollui-.ant! eontalna data on drlrttN
and other types or water, date aa4
location or water sample, onmeoiavl
Identity, analytical method use".
concentration detected, and
reference to published result"-
308
REMEDIAL RESPONSE
-------
                                                            Table 5
                                       Environmental Chemical Computerized Data Bases (cont'd)
On-Llne Data Bases
EPA ON-LINE
SYSTEMS
Aeronetrlo and
Emission System
( AEROS)
Chemical
Information


Health Effects
and
Toxlcologlcal
Information


Environmental
Information

X
Manufacturing
Uses and
Economic
Information


Disposal
Information

X
Comments

Comprehensive data system use to
collect, store, and analyze air
pollution data. Provides concise
standarlzed reports on various
aspects of air pollution. SAHOAO,
HATRFHS, mm. and PHIS are all part
of the A^ROS system.
•"Biological Field and Laboratory Methods  for Measuring the
 Quality of Surface Water and Effluents" (EPA 670/4-73-001)
•"USEPA  Solid  Waste Manual, Test Methods for Evaluating
 Solid Waste, Physical/Chemical Methods" (SW-846)
•"Handbook for Analytical Quality Control in Water and Waste-
 water Laboratories" (EPA 600/4-79-019)
•"Methods of Chemical Analysis of Water and Wastes"  (EPA
 600/4-79-020)
•"Procedures  Manual for  Groundwater Monitoring  at  Solid
 Wastes Disposal Facilities".
  The  address  for these  publications is USEPA Office of Re-
search and Development,  Publications- (CERI), Cincinnati,  OH
45268 (Phone 513/684-7562). The reader should  also make in-
quiries at CERI about the numerous technical papers and mono-
graphs prepared by the agency covering a wide variety of spe-
cific topics which may be  relevant to Superfund activities.  Many
of these monographs and technical reports cover such subjects as
site entry  and control as  well as site monitoring and construc-
tion techniques.
  References containing basic physical,  chemical  and  biological
data include the following:
•Chemistry  of Hazardous Materials,  E.  Meyer,  Prentice-Hall,
 Box 500 Engjewood Cliffs, NJ 07632 (Phone 201/592-2000)
•The Condensed Chemical  Dictionary,  G. Hawley, Van  Nos-
trand Reinhold Co., New York, NY 10020 (Phone 212/265-8700)
•CRC Handbook of Chemistry and Physics, CRC Press,  2000
 Corporate Blvd., N.W.,  Boca Raton,  FL 33431  (Phone  305/
 994-0555 Ext. 330)
•Dangerous Properties of Industrial Materials,  N. Irving Sax, Van
 Nostrand Reinhold Co., New York, NY 10020 (Phone 212/265-
 8700)
•Fire Protection  Guide  to Hazardous Materials,  National Fire
 Protection Association, Batterymarch Park, Quincy, MA  02269
 (Phone 617/328-9290)
•The Merck Index, Merck  and Co., Inc.  P.O.  Box 2000 Rahway,
 NJ 07065 (Phone 201/574-5403)
  Most  of these references are quite comprehensive in their cov-
erage of the chemicals referenced; however, the reader should be
aware that no reference contains all of the chemicals which may be
present at a site, so some preliminary scanning of the reference ma-
terials or inquiry to the publishers should be made to assure pur-
chasing the appropriate references for one's purposes.
  Several other books are  devoted specifically  to safety and  first-
aid measures. Again, the  reader should  peruse several reference
sources in this area to obtain  the one most appropriate for present
and projected Superfund needs. Three such resources are:
•Best's Safety Directory, A.M. Best Company Inc., Ambest Road,
 Oldwick, NJ 08858 (Phone 201/439-2200)
•CRC Handbook of Laboratory Safety, N.V. Steere, 2000 Corp-
 orate Blvd., N.W., CRC Press, Boca Raton, FL 33431 (Phone
 305/994-0555 Ext. 330)
•National Safety Council Safety Sheets, National Safety Council,
 444 North Michigan Ave.,  Chicago, IL 60611 (Phone  312/527-
 4800)

CONCLUSIONS

  The list  of training courses,  databases,  books  and other re-
sources contained in this paper is representative of some of the re-
sources currently available. In many instances, a specific course or
other resource only covers a portion of the training requirements
of an organization. Many of the resources listed are used primarily
by emergency response groups and, only recently, has a portion of
the courses, books and manuals been devoted to Superfund. There-
fore, it is incumbent upon those seeking training in Superfund re-
lated  areas to review  as much of the available training  informa-
tion as possible.
  There  are some organizations  which will organize training
courses to suit the specific needs and objectives of a hiring group.
These courses are usually more expensive in terms  of initial cost;
however, this may be the most  cost effective way of training a
large group of workers at one time.
  Another approach to training was developed by the U.S. Corps
of Engineers. After reviewing the available offerings for training
and discovering that most of these resources were devoted to emer-
gency response rather than remedial action, the Corps developed
its own Superfund Overview Course. This course was specifically
designed to meet the needs of Corps personnel involved in Super-
fund activities and addresses  the design and  construction activities
at Federal lead Superfund sites. This course is not available to the
general public; however, it does indicate that  other organizations
interested  in Superfund involvement may  find  it more advan-
tageous to pool together specific resources to train their personnel.
It is advisable that those interested in Superfund training shop
around and make inquiries of several suppliers to achieve the most
cost effective use of training dollars.
REFERENCES

1.  The  information for Tables 1-4 was taken  from  "Hazardous Ma-
   terials Response Training" draft report prepared for USEPA by Booz-
   Allen & Hamilton, Inc.
2.  The  list  of data bases contained in Table 5 were kindly supplied by
   the Hazardous Materials Technical Center (HMTC), P.O. Box 8168,
   Rockville, MD. 20856-8168.
                                                                                           REMEDIAL RESPONSE
                                                                                                                         309
-------
       SITE  SECURITY  AND  WASTE REMOVAL  ACTIVITIES
           AT AN ABANDONED HAZARDOUS  WASTE SITE

                                          MICHAEL A. BARBARA
                                          THOMAS J. MORAHAN
                                           Fred C. Hart Associates
                                             New York,  New York
                                             ROBERT W. TEETS
                                               Cooper Industries
                                                Houston,  Texas
SUE HISTORY

  The Osborne landfill is  located in Pine Township,  Pennsyl-
vania just east of the Borough of Grove City (Figure 1) in an area
known for its coal mining and steel related industries. The land-
fill is located in an abandoned coal strip mine about  IS acres in
size.  Upon abandonment, the mine filled with water and was sub-
sequently used as a dump for a variety of industrial and domestic
wastes including foundry sand. The foundry sand filled almost
three-quarters of the stripped area. In addition, scrap metal and
drums containing potentially hazardous materials were  also dis-
posed of there.
  The site was evaluated by USEPA using the MITRE Hazard
Ranking System. Because of its proximity to the water supply wells
of Grove City, the Osbome site was  ranked as one of the top 50
Superfund Sites in the nation.
  At that time, USEPA identified a  number of suspected gener-
ators and haulers possibly responsible for  the waste problems at
the Osborne Landfill. Cooper Bessemer,  a local foundry and
subsidiary of Cooper Industries of Houston, Texas, was named as
one Of several suspected generators. Cooper, a long time resident
and major employer in Grove City, maintained that, for the safety
and  well being of area residents, it would  undertake  the task of
investigating the problems associated with the Osborne site.
  Cooper retained Fred C. Hart Associates, Inc., (FCHA) a New
York based environmental consulting firm, to provide technical
assistance in the investigation of the Osborne Landfill.
  Cooper and FCHA, working closely with the Pennsylvania De-
partment  of Environmental Resources  (PADER) and USEPA,
developed a phased approach to the  investigation. In this paper,
the authors discuss the problems encountered at the site and trace
the steps performed in the implementation  of the initial remedial
measures and site security.

INITIAL CONDITIONS

  Initial  site conditions were not conducive to performing a de-
tailed investigation of  the site.  An unknown number of 55 gal
drums were scattered about the site. These  drums may have con-
tained potentially hazardous materials. Many were crushed, rusted
or bulged and were in no condition to be safety handled. In addi-
tion,  areas of contaminated soil were found.
  These problems were compounded by unrestricted public access.
After the landfill stopped accepting wastes  in the late 1970s, un-
restricted  access afforded an excellent motivation for the illegal
dumping of wastes. Three ponds located on-site were extremely
dangerous to children.
  The unknown characteristics of the wastes and the proximity
of large surface water and groundwater impoundments made a
comprehensive site investigation imperative.
  Since the degree of hazard posed by the  site conditions pro-
hibited appropriate investigatory work, a site security program was
recommended. This program was designed to restrict access and
reduce liability while rendering the surface of the landfill safe for
personnel implementing the site investigation.
  A 6 ft high 3,740 ft chain link fence was constructed around the
site including a newly found contaminated area. Appropriate warn-
ing signs were also erected.

DRUM INVENTORY
  In order to plan for the ultimate disposal of the wastes, FCHA
gathered information from outside sources,  performed a waste
(drum) inventory and then sampled. The waste inventory was de-
signed to identify the number, locations, types,  conditions and
possible contents of drums scattered on site. A standard form was
developed and utilized throughout the study.  The site was divided
into ten distinct areas (Figure 2) which contained drums. These
areas were referred to as  "clusters". Within  each cluster, drums
were consecutively numbered.
  Each drum was then recorded on a log form with its number,
condition,  possible contents and  label information. Each cluster
was extensively photographed. The data gathered during the in-
ventory were then fed into computers for future use. Found were
433 drums, of  which 75 were full and  sealed. Of the 75 sealed
drums, approximately 20% were selected for sampling. Each drum
was chosen for sampling  based on its location, accessibility and
condition.
  FCHA designed and fabricated a remote  drum opener to en-
sure the safety  of the sampling crew. This opener consisted of a
pneumatic impact wrench  mounted on a  support stand. A tempor-
ary explosion shield  was erected around each drum  as it was
opened. The device was operated with an SCBA air tank from a
distance of 100 ft.
  Upon opening, each drum was checked with an Organic Vapor
Analyzer (OVA) and  an explosimeter to  characterize the materials
inside the drum. An "Action Level" was set at 50 ppm of organic
vapor. Drums exceeding the 50 ppm level required level "B" (Self
Contained Breathing Apparatus). All other drums were sampled in
level "C" (Cartridge respirators).
  Each sample was collected with a glass drum thief. Samples
were analyzed for PCBs, fuel value and RCRA characteristics in-
cluding ignitability, corrosivity, reactivity, metals and pesticides/
 310
         REMEDIAL RESPONSE
-------
                                                    CONTOUR INTERVAL 10 FEET
                                                NATIONAL GEODETIC VERTICAL DATUM OF 1929

                                                             Figure 1
                                                         Site Location Map
herbicides. Parameters were chosen based on requirements for the
proper manifesting and disposal of the waste.
  The results of the  selected drum analyses  were crucial  to  de-
termine  the level of protection necessary for site security work
efforts as well as to anticipate the approximate cost of this task.
Chemical analyses of the  17 liquid drum samples and three soil/
solid samples are presented in Table I. Of particular importance
was the fact that no PCB  compounds were detected in any of the
liquid samples.
  In general,  the contents of the  drums contained low levels of
RCRA metals (barium, cadmium, chromium and lead), had some
fuel value and, with only one exception, had pHs within the RCRA
non-corrosive limits of 2-12.5. Three of the samples did have flash
points below 60 °C, however.

WASTE REMOVAL
  A detailed scope  of work for the removal of the wastes, drums
and contaminated soils was developed by FCHA and issued with a
form of contract in an RFP on  June 23, 1983. The scope of work
called for the restaging and sampling (where appropriate)  of all
drums visible on the surface of the Osborne Landfill. This  was
taken to include all drums  floating on the surfaces  of the three
ponds. The contractor was required to restage all drums on plastic
covered, bermed areas for sampling. Leaking or weak drums were
to be overpacked, as required. In  addition, areas of obvious  soil
contamination beneath leaking drums were to  be excavated  and
restaged in a separate area. All drums  and contaminated soils were
to be analyzed, and the contractor was required to submit a formal
waste disposal plan prior to removal of any materials from the  site.
Five firms were invited to bid on the project.
  A site visit was held on June 28 to familiarize the bidders with
the conditions of the site and answer any questions relating to the
implementation of the scope of work. Representatives of four of
the five firms visited the site and submitted proposals on July 7,
1983. Of these responses, two were deemed non-responsive to the
terms of the RFP. The choice between the remaining two bidders
was made on the contractors' preliminary waste  disposal plan,  per-
sonnel safety plans, compliance with  the terms and schedules de-
                                                                                           REMEDIAL RESPONSE
                                                         311
-------
                                                           Table 1
                                   Chemical Analysis of Selected Drams at the Osborne Site Parameters
Ignitability Corrosivit
Fuel
DRUM Value (Flash Point
NUMBER (BTU/lb) in °C) (pH)
B14
119
J32
05
J45
B53
B4
H22
G36
B91
G50
G42
F17
A2
G33
143
Jl
AREA B SOIL
AREA G SOIL
G31 (SOLID)
RCRA ALERT
LEVEL
13741 ** 6.5
19892 49 9.5
18232
*
19631
13890
19275
19741
17243
19295
*
19453
19449
19101
13429
A
—
3.0
5.4
3.7
7.0
3.7
2.9
5.7
5.2
13.8
3.7
5.7
2.7
8.2
9.6
5.4
— 5.5
— 6
— 5.6

<60°C pH H2 or
y PCB Aroclors
1242
mgAg
ItlO
H10
11250
H250
ItlO
mo
ItlO
ItlO
ItlO
ItlO
ItlO
ItlO
ItlO
mo
mo
mo
m
	
—
—

—
1254
•gAg
mo
mo
mo
H250
mo
mo
mo
mo
mo
mo
mo
mo
mo
mo
mo
mo
HI
	
—
—

—

D004/
1260 Arsenic
mg/kg
mo
mo
mo
H250
mo
mo
mo
mo
mo
mo
mo
mo
mo
mo
mo
mo
HI
	
—
—

—
mg/kg
HO. 2
HO. 2
HO. 2
HO. 2
HO. 2
HO. 2
HO. 2
HO. 2
HO. 2
HO. 2
HO. 2
HO. 2
HO. 2
HO. 2
HO. 2
HO. 2
HO. 5
HO. 5
HO. 5
HO. 5

5
RCRA METALS
(EPA Hazardous Waste number/parameter)
D005/ Dfl06/ DuO?/
Barium Cadniun Chromium
ng/kg mg/kg
7
HO. 2
HO. 2
HO. 2
HO. 2
5
H5
1
0.4
HO. 8
0.9
HO. 2
H5
H5
7
2
H5.0
H5.0
H5.0
H5.0

100
HO. 8
HO. 8
HO. 8
HO. 8
HO. 8
2.6
HO. 8
1.2
HO. 8
HO. 8
HO. 8
HO. 8
HO. 8
HO. 8
0.9
HO. 8
HO. 8
HO. 8
HO. 8
HO. 8

1
ng/kg
0.4
HO. 2
2
HO. 2
HO. 2
HO. 2
HI
HO. 2
HO. 2
0.6
HO. 4
HO. 2
HI
HI
0.2
0.5
Hl.O
ltl.0
Hl.O
Hl.O

5

0008/ D009/ DOW
Lead Mercury Selenium
mg/kg
30
20
It2
H2
20
15
H2
8.7
4.5
4.5
H4
H2
H2
2
H2
7.7
H2.0
H2.0
6.0
H2.0

5
mg/kg
HO. 09
HO. 07
HO. 08
HO. 09
HO. 002
HO. 002
HO. 002
HO. 08
HO. 09
HO. 08
HO.l
HO. 08
HO. 002
HO. 002
HO. 008
HO. 09
0.004
HO. 002
0.003
0.002

0.2
mg/kg
HO.l
HO.l
HO.l
HO.l
HO.l
HO.l
HO. 2
HO.l
HO.l
HO.l
HO.l
HO.l
HO. 2
HO. 2
HO.l
HO.l
HO. 5
HO. 5
HO. 5
HO. 5

1

D011/
Silver
•gAg '
0.9
HO. Z
HO. 2
0.7
HO. 2
HO. 2
HO. 5
HO. 2
0.4
HO. 2
HO. 4
HO. 2
HO. 5
HO. 5
0.9
0.5
HO. 2
HO. 2
HO. 2
HO. 2

5
It
gt
No Analysis
Not ignitable
Flash Point Over 60°C
less than
greater than
                            pH gt!2.5
   -.	—  ONIO
                          Figure 2
           Drum Cluster Boundary at the Osborne Landfill
                                                            lineated  in  the RFP  and price.  Using these criteria, Fondessy
                                                            Enterprises, Inc./Associated Chemical and Environmental Services
                                                            (ACES)  of Oregon,  Ohio was selected to  perform the work.
                                                            Following an oral presentation, a unit price contract was nego-
                                                            tiated and signed by representatives of Cooper and Fondessy.
                                                              ACES' personnel mobilized their equipment on-site on July 25,
                                                            1983. Security personnel were retained to limit access 24 hours a
                                                            day for the duration of the cleanup. A field  office trailer and de-
                                                            contamination/personnel safety trailer was  also set  up. After a
                                                            safety meeting, cleanup operations commenced on the morning of
                                                            July 26.
                                                              Level "D" protection was required for all personnel entering the
                                                            site. Personnel  involved with  the supervision and handling of the
                                                            drums were required  to utilize Level "C"  (cartridge respirator)
                                                            protection whenever wastes were handled. Periodic checks of site
                                                            condition were made by the safety officer using an OVA. Within
                                                            five days, approximately 630 drums (460 of which were empty)
                                                            restaged  and 45 yd' of soil were evacuated.  Each drum contain-
                                                            ing liquid was sampled for manifest requirements. One composite
                                                            soil sample was also collected.
                                                              ACES formally submitted  their Waste Disposal Plan  to repre-
                                                            sentatives of Cooper, FCHA, PADER and  USEPA on Aug. 5,
                                                            1983. The plan specified the packaging,  transportation  and ulti-
                                                            mate disposition  of the wastes collected. Removal of the wastes
                                                            commenced on Aug. 9. The nonaqueous waste was pumped into a
                                                            tanker truck and utilized for  fuel blending by Deleware Con-
                                                            tainer Corp., Coatsville, PA.  The drums containing aqueous solu-
                                                            tions were also transported to Delaware Container, solidified and
                                                            trucked to Fondessy's secure landfill in Ohio.  All contaminated
                                                            soils and solids were transported in lined dump trucks for disposal
                                                            at the Fondessy site. All  empty  drums  were  crushed, using a
                                                            front-end loader, and transported to the Fondessy facility in box
                                                            vans.
                                                              A final inspection of the surface cleanup  was made by Cooper
                                                            personnel on Aug. 12,1983.
312      REMEDIAL RESPONSE
-------
                    STATUS OF  REM/FIT EPA  CONTRACTS

                                              PAUL F. NADEAU
                                   U.S. Environmental  Protection Agency
                                Office of Emergency and Remedial Response
                                               Washington, D.C.
                                             WILLIAM T. DEHN
                                                   CH2M  Hill
                                                Reston, Virginia
                                             PAUL GOLDSTEIN
                                               NUS Corporation
                                              Arlington, Virginia
INTRODUCTION

  The Comprehensive Environmental Response, Compensation
and Liability Act of 1980, commonly called Superfund, established
a dual-phase program for responding to environmental problems
caused  by hazardous substances.  The  "emergency program"
focuses on situations where a prompt response is needed to prevent
harm to  public health or welfare or the environment. Emergency
actions generally focus on controlling the immediate threat. The
"remedial program," on the other hand, is aimed at investigating
problem hazardous waste sites and providing cost-effective solu-
tions to these problems. In this paper, the authors discuss only the
"remedial" portion of the program.
  On Sept. 30, 1982, the USEPA awarded two 2-year contracts,
each with two 1-year options, to  investigate  and plan for the
cleanup of hazardous waste sites in the United States. The contract
for USEPA Regions I through IV, in the amount of $75 million,
was awarded to NUS Corporation of Gaithersburg, Maryland.
NUS  is  supported  by  Dynamac  Corporation  of  Rockville,
Maryland in the area of personnel health and safety, and Brown &
Root Development Inc.  of Houston, Texas  for engineering and
conceptual designs. The contract for USEPA Regions V through
X, in the amount of $89 million, was awarded to CH2M Hill of
Reston, Virginia. Ecology and Environment of Buffalo, New York
provides field investigation support to CH2M Hill.
  The purpose of this paper is to identify the various elements of
the REM/FIT contract (the acronym, REM/FIT, is composed of
REM, which stands for Remedial Planning, and FIT, which stands
for Field Investigation Teams), to discuss their present status and
accomplishments and to describe contractor's activities on two
typical projects.
ELEMENTS OF THE REM/FIT PROGRAM
Organization
  Each REM/FIT contractor maintains a Zone Program Manage-
ment Office (ZPMO) in the Washington,  D.C. metropolitan area
for managing  the overall programs and providing liaison  with
USEPA  headquarters. The ZPMO  also provides all support ser-
vices such as health and safety, training, quality control/assurance,
community relations, cost control and scheduling,  forecasting,
maintenance of records and equipment and direction of all subcon-
tracting activities.
  The heart of the program is the FIT and REM human resources.
A FIT team resides in each of the 10 USEPA Regional offices to in-
vestigate sites and determine their hazard  potential. High ranking
sites are  then considered for placement on the National Priorities
List (NPL). A total of 228 positions are currently authorized and
staffed on a full-time basis to support these activities.
  CH2M Hill and NUS also maintain one or more Remedial Plan-
ning (REM PLNG) centers in selected permanent operating offices.
These centers are responsible for the engineering activities of REM.
Staff members from these and other firm offices serve as Site Pro-
ject Managers (SPMs). Project team members are assigned from a
variety of disciplines depending on the needs of the project.
FIT Activities

  A FIT is a fully dedicated, multi-disciplinary unit ranging in size
from 13 to 40 people. Over 70% of the team members are profes-
sionals with a variety of college degrees and experience. The teams
are responsible for performing the preliminary  investigative ac-
tivities at sites to characterize the threat to public health and en-
vironment. Specific steps in the investigative process are shown on
                           HAZARD
                          RANKING
                           SYSTEM
                        Figure 1
                      FIT Overview
                                                                                    REMEDIAL RESPONSE
                                                     313
-------
Figure 1 and described below:
•Site Discovery is an initial survey of sites to confirm their existence
 and  location, to eliminate duplication on site lists, to make an
 initial determination of the types of contaminant and industrial
 waste categories and to define potential adverse impacts.
•Preliminary Assessment is a survey to characterize in a preliminary
 fashion the hazardous substances present, potential  pollutant dis-
 persal pathways, the population and resources which might be
 affected, facility management practices and the potential respon-
 sible parties. The purpose of the assessment phase  is to examine
 the list of potential hazardous waste sites contained in the Agency
 inventory (approximately 16,000) to determine if  a  site  merits
 further action.
•Site Inspection is intended to better define the extent of the prob-
 lem at a  site and provide a data base sufficient to determine the
 next  action (i.e.,  emergency  response,  enforcement and/or  re-
 medial response). A site inspection usually provides data ade-
 quate to  apply the USEPA Hazard Ranking System. Also, initial
 enforcement measures may be supported with these data. To ac-
 complish these objectives, site  specific data  on the hazardous
 substances present, pollutant dispersal pathways,  types  of  re-
 ceptors and site management practices are gathered.
•USEPA's Hazard Ranking System (HRS) model is used to rank
 each site relative  to other sites nationwide employing the data
 collected during a site inspection. The HRS model handles five
 pathways of  exposure:  groundwater, surface water,  air, direct
 contact and fire and explosion. Pathway scores for groundwater,
 surface water and air are combined and sites receiving the highest
 total scores can be placed on the National Priorities List (NPL).
 Pathway scores for fire and explosion and direct contact are used
 as indicators  for emergency action. In June 1983, 419 sites were
 proposed for inclusion on the NPL.
  The teams  spend most of their time in  field related activities.
Projects are scheduled in accordance with FIT regional work plans.
Team personnel are fully trained in health  and  safety and in field
activities such as opening containers and sampling groundwater, air
and soil. In addition to performing the activities just described, the
teams provide support to enforcement activities.
Remedial  Activities

  Once the site in on the NPL, it is a candidate for remedial action.
The REM portion  of the contracts contains level-of-effort hours
and subcontract pool dollars to develop and implement a long-term
remedy which  is consistent with a permanent solution to a  hazar-
dous site.  A variety of trained professionals ranging from chemical,
sanitary  and  civil  engineers,  chemists,  biologists,  geologists,
hydrogeologists and public  health specialists are  employed as
needed. The sequence of activities is shown on Figure 2, and the
key steps are described below:
•Remedial Action Master Plan (RAMP) is a planning-level effort
 to compile existing data,  to map out the activities needed to
 clean up  the site (with time and cost schedules) and to specifically
 define the first remedial activity recommended for the site.
•Initial Remedial Measures (IRMs) may be taken at a site to miti-
 gate  a situation which poses  a significant threat to  the public or
 environment. Examples of IRMs  include staging or off-site  re-
 moval and disposal of drums, installing a security fence around a
 site,  on-site draining control and  providing temporary alternate
 water supplies.
•Remedial Investigation is a  field-oriented effort to collect suf-
 ficient data to permit the development and evaluation of remedial
 response  alternatives for a hazardous site. The remedial  investi-
 gation also assesses the need  for IRMs to remedy any immediate
 hazards.
•Feasibility Study develops the cost-effective solution for  a site.
 It involves selection of a number of remedial alternatives; initial
 screening of  the alterantives  based on cost,  environmental  ef-
 fects and engineering  feasibility to indicate  which alternatives
 warrant further evaluation; performance  of a detailed cost, en-
 vironmental and engineering analysis; public review and comment
 on the alternative remedies considered; and selection of the most
 cost-effective solution for a site. A conceptual design is prepared
 to define the selection solution.
•Design is the preparation of bid documents to allow cost-compe-
 titive selection of a construction contractor  to  implement the
 selected solution. This is done primarily under the  auspices of
 the States or the U.S. Army Corps of Engineers.
•Implementation is the  process by which the  actual site cleanup
 occurs,  again done  primarily  by the States or the Corps of
 Engineers.
  The Remedial Investigation (RI) and the Feasibility Study (FS)
are the primary activities of the REM/FIT contractors. A detailed
work plan is prepared for each project. Although shown as sequen-
tial steps on the flow diagram, it is essential that the investigation
and feasibility study be closely coordinated. This is done to target
the scope of the investigation to provide the data needed to assess
potentially feasible alternatives. The objective is to reduce the costs
and shorten the tune schedules for completion of the studies and
selection of the remedy.

REM/FIT PROGRAM  STATUS
AND ACCOMPLISHMENTS
  The two REM/FIT zone contractors have been operational since
Oct. 1, 1982. Despite a three month mobilization period, they have
already worked on over  650 hazardous waste sites through the end
of June 1983. They have also involved over 190 subcontractors in
the program.
               EPA LEAD PROJECT
     Corp* of Engr$.
                  IMPLEMENTATION |
                           Figure 2
                 Remedial Planning Flow Diagram
FIT Activities
  The 10 regional Teams have focused their effort in performing
preliminary assessments and site inspections. Since the inception of
the two contracts, 1,716 assessments and 452 inspections have been
completed,  increasing  program-wide  totals  to  over  6,570
assessments and 1,760 inspections. The ability of the Teams to per-
form assessments and inspections has been hampered somewhat by
other high priority projects, particularly in  support  of enforce-
ment. The following summaries are intended to illustrate the types
of projects typically assigned to the FIT.
*The Regional FIT spent over 7,000 person-hours at the Seymour
Recycling Corp. site in Indiana monitoring site safety, operating an
on-site treatment facility, supervising the installation of monitoring
wells, sampling the wells and sampling over 100 drums per month.
^•FIT personnal in Regions II and VII have been extensively in-
volved in sampling  soils suspected  of  containing dioxin. Cort-
314
          REMEDIAL RESPONSE
-------
effective and safe sampling  and personnel  protection procedure
were developed for these activities.
^ Another FIT team designed and fabricated a down-hole sampler
for studying in situ emissions  of organic vapors during drilling
operations. When hooked up to a Photo-Vac unit, the sampler pro-
vides real-time data on potential organic vapor releases from the
soil and groundwater.  Immediate or real-time data allow the field
scientist to be  more selective about where to take samples down-
hole. These samples are then sent to a laboratory for confirmation
of the field data. The technique saves time, sampling collection and
analysis costs  and provides  an early indication of the order of
magnitude of the subsurface problem.
^•Around-the-clock sampling was carried out by the Region X
team for six consecutive days during  an aquifer pump test  at the
Lakewood Water District site in Washington.  The data obtained
from a continuous three-day sampling during both drawdown and
aquifer recovery enables a hydrogeologist to determine the aquifer
characteristics  and  any change in  contaminants entering  the
aquifer. While tedious and  time consuming,  the technique has
proven itself in practice to be worthwhile.
^•Special techniques for sampling mining and wood preservative
wastes are in use in Regions VII and X.
^•The Revion IV FIT provided  an electromagnetometer and
magnetometer survey on a landfill in Alabama  on a restricted time
schedule in support of a criminal investigation.
^•Immediately following a warehouse five in Canton, Mississippi,
a Region IV FIT sampling team found and removed several boxes
of sodium cyanide among auto and plumbing parts. This swift ac-
tion removed a danger to the neighborhood.
*-In Oct. 1982, eight  of 45  wells sampled in Perdido, Alabama,
were found to be contaminated with benzene. The wells were con-
demned, forcing the residents to use  drinking  water from mobile
tanks. Through the use of resistivity  testing and geophysical well
logging, the FIT  provided information that determined the  extent
and degree of the contamination. This was done with minimum
disruption to the residents.

REM Activities
   REM activities were started on 222 of the 419 sites on the Na-
tional Priorities List  from Oct.  1, 1982 through June 30,  1983.
Specific activities include 186 RAMPs, 9 IRM projects, 26 remedial
investigations and 25 feasibility studies. Several projects were also
initiated to support enforcement related  activities. The following
summaries  illustrate typical  remedial activities. In addition, de-
tailed project summaries for two sites are provided at the end of the
paper.
^•Focused feasibility studies were developed to assess the cost ef-
fectiveness of permanent relocation for the Minker Stout site  in Im-
perial, Missouri,  which was contaminated with dioxin and for the
Mountain View Mobile Home  Estates in Globe, Arizona,  which
was contaminated with asbestos.
^•A  feasibility  study for  the  Outboard  Marine  Corp. site,
Waukegan, Illinois, involved dredging the sediments in the harbor
contaminated with PCBs.
^•For the Chem-Dyne site in Hamilton, Ohio, an initial remedial
measure was authorized to  relocate  a power  line to  enable the
cleanup contractor to drain, dismantle and remove  several bulk
storage tanks.
^•The design of a carbon system was necessary for the removal of
trichloroethylene and other organic solvents from groundwater for
the New Brighton/Arden Hills site in  Minnesota.
^•A special catamaran-style vessel  was  designed and built  to
facilitate sampling on  a waste  oil and wastewater lagoon at the
Bridgeport Rental and  Oil Services Site in Gloucester, New Jersey.
^•Advanced geophysical techniques are being employed to  deter-
mine the locations and attitudes of bedrock fractures under the
Krysowaty Farm Site in Somerset County, New Jersey, where bulk
and containerized liquid chemical wastes were dumped in a remote
ravine and threaten potable water supplies.
^•Two computer models are incorporated in the remedial investiga-
tion for the New Bedford Harbor Site in Massachusetts. One in-
volves  the food chain uptake, particularly for lobsters and other
shellfish, and the second addresses the movement of contaminated
sediments by  ocean currents.

Subcontracting Activities
  The  two contracts contain a total of $60 million in subcontract-
ing funds over the four-year period of performance for other firms
to assist in the REM/FIT work. Goals have been established to
award  30% of the  funds to Small Business Enterprises (SBE) and
10% to Socially and Economically Disadvantaged Business Enter-
prises (SDBE) such as minority and women-owned firms. In addi-
tion, preference  is  given to firms located in Labor Surplus Areas
(high unemployment areas) (LSA).
  As of June 30, 1983, the program is far ahead of its goals.  Over
60% of the subcontract funds committed have gone to SBEs and
24% to SDBEs.  In addition, 22% of the subcontracts have  been
awarded to LSA firms. A more detailed summary is provided in
Table 1.
  Principal services that are subcontracted include engineering,
field services (well drilling, sampling, land and aerial surveys, etc.),
computer services, data and records research, community relations,
construction and expert testimony. Examples include subcontracts
for expert testimony about potential environmental impacts of a
specific chemical upon groundwater in support of USEPA enforce-
ment activities, basic ordering agreements for engineering services
for the preparation of RAMPs and RI/FS projects, soil sampling
for dioxin, well  drilling for groundwater contamination and air
monitoring.
  To date,  over 750 firms have filed qualifications and experience
statements with the prime firms. Opportunities still exist for addi-
tional firms to express their interest in serving as a subcontractor.
For this purpose, any interested firm should contact the subcon-
tracts administrators of the two prime firms.

                           Table 1
             REM/FIT Subcontract Activities (6/30/83)
              Total
                         SDBE
                                    SBE
                                               LSA
No. of
Contracts
Amounts
195         41          131         35
$7,599,630    $1,844,271    $4,589,901    $1,635,381
EXAMPLE REMEDIAL PROJECTS

  Two projects have been selected to illustrate the scope of ac-
tivities performed under REM/FIT. 'One project, decontamination
of Municipal Water Well  12A in Tacoma, Washington, involves
the installation of a treatment facility and has advanced to the
operational phase. The other project involves building demolition
and on-site containment measures at the Silresim Chemical Corp.
site in Lowell, Massachusetts. Planning for an initial  remedial
measure has been completed and implementation is ready to begin.
  In Apr.  1982, USEPA,  with contract support  from Black and
Veatch, Inc., began an investigation of the extent and nature of the
contamination found in Well 12A. The results indicated that there
was a dispersed underground plume of organic solvent contamina-
tion. The highest concentrations, reaching into the /ig/1 range, were
immediately to the northeast of Well 12A. Identifying the specific
source(s) of contamination was not in the  scope of this initial
assignment but is being addressed in a subsequent assignment.

Decontamination of Municipal Water Well

  The South Tacoma Channel site, which lies within the Puget
Sound's Commencement Bay  area, includes an  area of approx-
imately 10  mi2 throughout a heavy industrial and  commercial area
(Figure 3).
                                                                                            REMEDIAL RESPONSE
                                                          315
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   • EXISTING CITY WATER WELLS

       •CALI IH 'IIT
                                             Concentration
                           Figure 3
                    Existing City Water Wells
  Although  there are several areas of concern within the South
Tacoma Channel itself, the first problem to be addressed was the
contamination of the City of Tacoma drinking  water wells with
chlorinated organic solvents. These solvents were first detected in
Well 12A in  Sept. 1981. At that time, the city, in  cooperation with
the Washington State Department of Social and Health Services,
voluntarily removed the well from service.
   Well 12A is one of 13 wells in Tacoma's largest municipal well
field and  is  located nearest to and immediately  southwest of the
general area suspected  of being  the  source of contamination
(Figure 3).  Groundwater  hydrology  studies have indicated  that
when Well 12A and the other municipal wells are in operation, the
hydraulic gradient runs from the contamination source area toward
Well  12A and the entire well field. An ever-increasing plume of
contamination was expected to spread  throughout the well field
unless some remedial action was taken.
   Historically, during July, August and  September, the 13 wells in
the field have supplied as much as 30% of Tacoma's water. Total
capacity of the well field is 45 mgd. The closing of several major in-
dustrial plants due to economic conditions during 1982, coupled
with abnormally abundant surface-water supplies, reduced summer
demand. Consequently, the majority of the 13 wells were not re-
quired during 1982. However, the reopening of industrial plants in
1983 indicated that water from the  well  field would be required.
  Because the contamination source was unknown, USEPA asked
CH2M Hill  to perform a focused, or fast-track feasibility study
during Jan.  1983, to determine the most feasible and cost-effective
remedial action that  would (1) prevent the spread  of further con-
tamination into the well field and (2) supply Tacoma with enough
water to meet anticipated peak summer  demands.
  CH2M Hill first determined that an alternative supply of water
for the city was unavailable. Further, CH2M Hill found that Well
12A,  being  nearest  to the contamination source  area, could be
pumped at or near its maximum capacity and  could effectively
serve as a blocking or barrier well.  If Well 12A were not pumped
and the other wells in the field were, concentrations  of pollutants at
the other wells could be expected to increase gradually as the con-
taminated plume was pulled farther into the well field.  However, if
the water from Well 12A were brought to the surface, it would have
to be  treated either for comsumptive use or discharge.
                                                                Design
                                                                  Well 12A was contaminated with:
                                                                  Contaminant
1,1,2,2-tetrachloroethane                              17 to 300
1,2-transdichloroethylene                              30 to 100
trichloroethylene                                      54 to 130
tetrachloroethylene                                    1.6 to 5.4
  Based on an analysis of groundwater hydrology, the maximum
contamination detected to the northeast of Well 12A and the an-
ticipated effects of aquifer dilution, CH2M Hill selected an influent
level concentration of 1,000 /tg/1 of total chlorinated hydrocarbons
for the design of the treatment system.
  The minimum acceptable blocking flow rate for Well 12A was
determined to be 2,000 gpm.  However, maximum blocking effect
could be achieved if the well were operated at its maximum possible
flow rate of 3,500 gpm. Because the city indicated that it probably
would make  maximum  use  of  Well  12A to meet peak water
demands, CH2M Hill established a design flow rate of 3,500 gpm.

Alternatives Analysis
  CH2M Hill screened several treatment alternatives and discarded
them as not  feasible. Conventional treatment processes such as
coagulation and sedimentation, softening, filtration and chlorina-
tion  cannot control  volatile  organics. Ozone has been used in
laboratory  and pilot studies  but with only limited success.  The
technologies worthy of consideration, therefore, included aeration
and adsorption on granular activated carbon.
  Two types  of aeration are generally  used: diffused aeration
systems which bubble air through the water and air stripping towers
in which water cascades down the tower through a porous medium
while air is forced upwards, countercurrent to the water.  Air strip-
ping towers are generally more efficient and cost-effective than dif-
fused aeration systems.
  Volatile organics also can be adsorbed with granular activated
carbon. However, laboratory-scale pilot  tests found that for the
contaminants  in Well 12A, removal efficiencies were significantly
less than those given for forced air stripping. CH2M Hill recom-
mended that  the cost-effective technology for the removal of the
volatile organic contaminants at Well 12A was forced air stripping
in a  packed tower system.
System Design
  A  preliminary review of the data suggested that 1,1,2,2-tetra-
chloroethane was the most difficult of the contaminants to remove.
Removal of volatile contaminants is a function of their volatility as
measured by the Henry's Law coefficient. To put this problem into
perspective, the coefficient for the most common volatile organic
hydrocarbon,  trichloroethylene,  is 290 atmospheres and that for
1,1,2,2-tetrachloroethane is 11 atmospheres. Thus, if 1,1,2,2-tetra-
chloroethane  can be removed to acceptable levels, the other volatile
contaminants should be more than adequately removed.
  A series of laboratory-scale pilot tests verified  the removal effi-
ciency of the compounds and determined if there were any interac-
tions among  the  compounds  that would  interfere with their
removal. The  results of the pilot testing compared  favorably with
those reported in the literature  and, as predicted, 1,1,2,2-tetra-
chloroethane dictated the overall removal efficiency.
  Full-scale air stripping towers were designed from the pilot plant
data. The  design was then analyzed  to  determine the optimum
number and size of towers and the overall contaminant removal ef-
ficiency,  per tower, that could be anticipated.
  The cost-effectiveness curve for a  3,500-gpm tower  system i»
shown in Figure 4. It is cost-effective to consider going from four to
five  towers in terms of the percent removal of 1,1,2,2-tetrachloro-
ethane versus cost.  Beyond five  towers,  the curve  breaks  sharply
upward.
  This treatment system will  achieve approximately 90% removal
of the major contaminant. This removal level, considering further
316
          REMEDIAL RESPONSE
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dilution of the Well 12A discharge with other well discharges prior
to mixing in the city distribution system, is sufficient to meet the
applicable health  standards  recommended  by  the  Washington
Department of Social and Health Services.
   As designed, each of the five 12-ft-diameter forced air stripping
towers contains 21 ft of 1 in.  plastic saddle packing. The height of
each tower, with stack, is approximately 50 ft. The 60 hp blowers
force 29,000 ftVmin of air  through each  tower.  The treatment
system's effect on surrounding air quality  is insignificant. Com-
puter modeling indicates that the maximum ground level concen-
trations  of volatile organics  due to the air stripping towers are
several orders of magnitude less than current recommended stan-
dards.
Contracting
   Overall responsibility for construction, testing and startup of the
facilities was assigned to CH2M Hill. This was done to maintain
continuity on the project and to meet the very short startup date of
July  1, 1983. Five subcontracts were developed for procurement
and construction. The first four, awarded during March and April
 1983,  covered  the  five  fiberglass  towers,  the tower  packing
material, fan (blower) units and prefabricated piping. A single, on-
site construction contract, also awarded in April, was developed to
           NOTE: NUMBERS SHOWN NEAR DATA POINTS INDICATE
              THE NUMBER Of 12 FT. DIAMETER TOWERS REQUIRED.
              EACH WITH 21 FT. OF PACKING.
                  I REMOVAL . I.I.:.] TETRACHIOROETHANE

                           Figure 4
           Forced Air-Stripping Towers/Cost vs. Removal

 assign all coordination and site construction responsibility to an ex-
 perienced contractor.
   Each subcontractor was  selected through a bidding process in
 which from four to eight qualified firms were asked to prepare
 fixed price bids on the subcontract package. This included defined
 scope of work, schedule and contract terms. Overall, 30 firms were
 given the opportunity to bid on this work.
   Firms which could meet  the project's time schedule with the
 lowest fixed price bid were selected. The total bidding, evaluation,
 award and approval process took one  month. USEPA received all
 proposed subcontracts before they were signed. All five subcon-
 tracts were awarded to small business  firms and three, amounting
 to about two-thirds of the  total dollar amount, went to minority
 and women-owned  firms.
   The estimated cost at completion of these subcontracts and the
 associated construction management services is  approximately
 $850,000  compared  to  the $920,000  originally  authorized  by
 USEPA.

 Construction

   The subcontractors started as soon as USEPA approved the con-
 tracts. Shop fabrication  of the fiberglass towers started on Mar. 30,
 and all five towers were delivered within 11 weeks. About 14,000 ft3
 of tower packing material was  delivered by truck starting in mid-
 April and continuing into early July. The fan units and piping also
 arrived  on-site to be assembled by the construction contractor as
 his  work progressed. The  site contractor's work involved the
 following:
•Site preparation, including moving some existing facilities
•Trenching to install piping for the system
•Forming and pouring 3000 ft3 of concrete for the tower and fan
 base pads
•Construction of an effluent diversion valving system in a buried
 vault
•Erection of the towers; installation of the packing material
•Mounting and connecting the fans, motors and noise abatement
 silencers
•Fabrication and installation of piping valves
•Installation of electrical controls and wiring
  Two photographs of the construction in progress are shown in
Figures  5 and 6. Each tower is 12 ft in diameter and 50 ft high.
When mounted in place, each fan unit stands about 9 ft high. Well
water is distributed to the towers by a 24 in. piping header. An 8 in.
pipe then carries the water to the inlet distributors of each tower.
At the base of each tower a large 10 in. water trap in the discharge
piping prevents air leakage from  the tower into the water system.
  Construction was essentially completed before major summer
demands on the system occurred and the system was tested  and
placed into operation. The  fast-track schedule,  consisting of in-
vestigation, design and construction, took less than four months.
This was less than one-third of the normal schedule for such a pro-
ject.

Operation
  At this point, responsibility  for the facility has been turned over
to the City's Water Division. Tacoma will operate the well and the
treatment towers any time its water demand requires use of the well
field. The pumping of Well  12A will block the spread of con-
tamination to other wells and will contribute to the cleanup of the
contaminated aquifer. Depending on the measured quality of the
treated water from the system, Tacoma may direct it into either a
reservoir for use in the water system or to the storm drain system.
  At this time, it is not clear how long the system will be needed on
well 12A. USEPA is aggressively proceeding with additional ac-
tivities to locate and quantify the source of contamination, so that
measures can be taken to permanently correct the situation. In the
meantime, the Tacoma well  12A towers are operating  evidence of
USEPA's commitment to the protection  of public  health  and
welfare from uncontrolled toxic materials.
Cleanup of Silresim Chemical  Waste Site
  The Silresim Chemical Corporation in Lowell, approximately 10
miles north of Boston, occupies approximately 15 acres of land in
an  area  that includes numerous  small  businesses and one-story
buildings (Figure 7). Figures 8 and  9 are photographs of existing
conditions.
  Prior to going out of business in  Dec. 1977, Silresim processed
industrial waste. It was the largest corporation of its type in New
England. Federal and state environmental agencies placed certain
conditions on continued operations at the plant which the company
could not meet. As a result,  the build-up of the number of barrels
containing  waste  material  reached  dangerous  proportions.
Ultimately, 23,000  drums of toxic chemicals and industrial  solid
waste were removed over a two-year period (1980-1981).
  An estimated  6,000 gal of toxic chemicals have seeped into the
ground as a result of ruptured drums. Principal contaminants iden-
 ified at  the site are listed in Table 2.
  Several investigations conducted at Silresim indicate that:
•Surface drainage  is generally  to the west-northwest toward River
 Meadow Brook
•Groundwater is contaminated near the site. The plume is  50  ft
 deep and covers an  area 1,000 ft  (north-south) by 800 ft (east-
 west)
•Groundwater flow is generally to the north with an estimated
 velocity of 16 ft/yr
•Approximately 6,000 gal of volatile organic compounds  have
 contaminated the site; approximately 8% is  dissolved in the
 groundwater and 92% is contained in soil
                                                                                              REMEDIAL RESPONSE
                                                                                                                            317
-------
                           Figure 5
                      Three Towers in Place
                           Figure 6
                      Five Towers in Place

•Maximum levels of volatile organics exceed 1000 ppm in the soil
 at the 5 to 10 ft depths and 100 pg/1 in the groundwater at a depth
 of 15 ft
•Surface and  subsurface soil contamination extends beyond the
 site boundaries
•Volatilization to the atmosphere and transport by groundwater
 are the major contaminant pathways
  With this information,  USEPA asked  NUS Corporation to
prepare a Remedial Action  Master Plan. The RAMP called for In-
itial  Remedial Measures  (IRM) to protect  humans from contact
with contaminated soils.  Also, the RAMP recommended that the
on-site facilities be dismantled.

Initial Remedial Measures

  The  USEPA authorized  an  IRM for the Silresim Site in June
1983. the work consisted of dismantling and disposing of selected
buildings and  tanks,  followed by installation of a temporary clay
cap, a  gas collection and treatment system and surface drainage.
The project is  aimed  at preventing air emissions and contaminated
surface runoff from leaving the site and minimizing the infiltration
of rainwater through the contaminated soils. A remedial investiga-
tions/feasibility study will be performed concurrent with the IRM
to select the final remedy for the site. This study will address both
on-site  conditions and  off-site contamination,  primarily con-
taminated groundwater.
                                                                    NUS began the planning for the IRM in May 1983, so that the
                                                                  remedy could be completed during the 1983 construction season.
                                                                  The  subcontractor  procurement process was started  and  pre-
                                                                  qualified subcontractors were provided with  requests for bids to
                                                                  conduct the first  phase of the IRM. The initial subcontract for
                                                                  dismantling the building and tanks was awarded, and a second sub-
                                                                  contract for construction of the cap is scheduled for award during
                                                                  Sept.
                                                                  Engineering Design for Dismantling
                                                                  On-Site  Facilities
                                                                    An engineering design and bid specifications were needed for
                                                                  dismantling  the  faculties.  The  objective of  the  design  was to

                                                                                             Table 2
                                                                                 Chemkab Detected at Stlrate, 1M2
                                                        VotatUe OrgMks
                                                        dichloromethane
                                                        1,1 -dichloroethylene
                                                        1,2-transdichloroethylene
                                                        1,1-dichloroethane
                                                        chloroform
                                                        1,2-dichloroethane
                                                        1,1,1 -trichloroethane
                                                        1,2-dichloropropane
                                                        trichloroethylene
                                                        benzene
                                                        1,1,2-trichloroethane
                                                        tetrachloroethylene
                                                        1,1,2,2-tetrachloroethane
                                                        toluene
                                                        chlorobenzene
                                                        ethylbenzene
                                                        trichlorofluoromethane
ityrene
dimethyl formamide
tetrahylfonnamide
tetrahydrofuran
dimethylsulfide

Pesticides
lindane
2,4-dichlorophenoxyacetic
  acid (2,4-D)
2,4,5-trichlorophenoxypropionic
  acid (2,4,5-TP)

PCBs
Arochlor 1016
Arochlor 1248
                                                              CHUMD fTONC
                                                               (iT-OMC HM-.
                                                               UK CWMf • r THC«
                                                               TO» eouwci
                                                                                  Figure 7
                                                                Site Map — Silresim Chemical Corp., Lowell, MA
318
REMEDIAL RESPONSE
-------
                           Figure 8
                       Existing Buildings
                           Figure 9
                        Existing Tanks
minimize the potential for disturbing surface soils and the possibil-
ity of direct contact with soils. This was accomplished by covering
the site with a base course of crushed stone during removal of the
numberous buildings and storage tanks  from the site. The stone
will serve as a protective barrier from contact with the  soil, will
eliminate the potential for disturbing surface soil, and will serve as
the base course for the impermeable cap  to be installed at the site.
  The engineering design also  specifies the  use of dismantling
techniques  rather than demolition. The use  of blasting is  pro-
hibited. Concrete will be broken by using drills and an expandable
grout instead of  wrecking balls and  jackhammers.  Concrete
footings and slabs will be left in place to avoid disturbing the soil.
The use of cutting torches will be minimized and closely monitored.
  All dismantled facilities, except the buildings, will be decon-
taminated,  cleaned and removed from the  site. The buildings
located on-site also will be removed, although they do not require
decontamination. The NUS site management team will monitor the
decontamination process to ensure compliance with  the specifica-
tions.

Engineering Design for Sealing

  The surface of the site and adjacent off-site areas  will be sealed
with a temporary impermeable cap. The cap will:
•Limit direct contact exposure to the contaminated surface soils
•Prevent contamination of surface runoff
•Reduce contamination of the groundwater by eliminating infil-
 tration through the contaminated soils
•Reduce odors emanating from the site
  The cap will be compatible with the base course material placed
on the site for dismantling. Also, the cap will be compatible with a
permanent  capping alternative if capping is included  as  a final
remedial action. Finally the cap will be constructed  with cost-
effective materials that will  provide  the  required protection and
have the potential for being  part of a permanent system.
  A gas-venting system is required since natural and biologically
derived gases will be generated in the contaminated soils beneath
the cap. The venting system is designed to allow surface monitoring
of the gases after installation of the cap. The design also provides
for directing the gases to a central location for treatment if air
monitoring indicates treatment is required.
  Finally, the cap design includes a storm water runoff collection
and diversion system. The system  includes grading and revegeta-
tion, draining ways and a retention basin.  The storm runoff collec-
tion and diversion system will use the existing right-of-way for a
public storm sewer that passes adjacent to the site and discharges to
Meadow Brook. The  design requires safe discharge of a  100 yr
storm.
Other IRM Activities
  A testing program will be  conducted to determine what objects
exist beneath the surface and if they should be removed.  This is be-
ing done based upon reports from local residents that  containers
may have been buried at the site. A survey was conducted with a
metal-detecting instrument, which  had a  depth of penetration of
approximately 3 ft.  This survey identified areas with unexplained
anomalous readings. Since  metal  drums  are  a  commonly used
method of containment, NUS will use a two-phase exploration pro-
gram to locate metallic and non-metallic subsurface containers.
The first phase will be a magnetometer survey, while the second
phase will involve the excavation of exploratory test pits.
  The test  pits will be used to check areas identified as possibly
containing buried objects. The specification requires that a rubber-
tired  backhoe equipped  with a nonsparking bucket be used  to
minimize disturbance of surface soil and  to prevent sparks. Con-
tinuous air monitoring will be required during excavation. If buried
drums containing chemicals are encountered, their position will be
marked for removal under separate contract. Excavations that do
not encounter buried objects will be backfilled with the excavated
soils in accordance with specifications.
Neighborhood Contingency Plans

  The need for  relocation of the  local population  is considered
unlikely. The dismantling and sealing of the site will be  conducted
in a manner to minimize disturbance to the surface soils,  and to
"dismantle"  rather  than "demolish" the  facilities. However, as a
precautionary measure, NUS and several federal, state and local
government agencies are preparing standby plans for emergencies.
Plan details include arrangement for broadcast of emergency infor-
mation on radio, television and police loud-speaker. Specific plans
have also been prepared for transportation, area security and tem-
porary shelter should relocation become necessary.
CONTRIBUTORS

  Tacoma Well 12A project writeup prepared by R. Schilling, Site
Project Manager and  R. Rosain, Assistant Project Manager of
CH2M Hill.
  Silresim Chemical Waste project writeup prepared by  Patrick
Falbey, Project Manager and George Gardner, Project Engineer of
NUS Corp.
  Initial   draft of  remaining material prepared  by  James R.
Woglom, former Zone II Program Manager for CH2M Hill.
                                                                                             REMEDIAL RESPONSE
                                                          319
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       EXPEDITIOUS COMPLETION:  A FORGOTTEN  GOAL
                                                JAMES C. SCOTT
                                              ROBERT B. PEARCE
                                                   Black & Veatch
                                                 Detroit,  Michigan
INTRODUCTION

  In Oct.  1981, a paper' was presented at this conference on the
Berlin & Farro Liquid  Incinerator, a hazardous waste site  near
Flint, MI. Black & Veatch was appointed Receiver by the Gen-
esee County Circuit  Court in  Sept.  1980. Initially,  the  firm's
assignment was to act as manager of the cleanup activities. How-
ever, the role soon  evolved into one of providing evaluation and
technical recommendations to the judge.
  In 1981, the  site was declared a hazardous emergency by the
Governor. Since 1981, Berlin & Farro has moved to first on the
priority ranking of hazardous waste sites in the State of Michigan.
The State Legislature appropriated additional monies for site clean-
up. A cooperative agreement between the State and USEPA was
executed.  Superfund  monies were granted  for immediate waste
removal and continuing investigation. The court intervened and
provided direction for specific action. In spite of these apparently
positive actions, only limited cleanup has been accomplished.
  The first Formal Administrative Complaint in this case was filed
against Berlin & Farro Liquid Incineration by the State of Mich-
igan in 1973. A suit was initiated against the firm in 1979. There
is repeated reference in the court orders to the  need  for "expe-
ditious" action or  completion. Random House dictionary indi-
cates that  expeditious is "characterized by promptness" and that
prompt means "done...without delay."

CONTRIBUTING FACTORS

  Numerous factors are responsible for the cleanup delays. While
the items to  be discussed  here are  project specific, they are rep-
resentative of the types of factors that are likely to be encountered
in  many hazardous waste cleanup projects. Awareness  of these
problems may provide a basis for initiating mitigative measures if
similar difficulties are anticipated in other projects.

Bureaucratic Encumbrances

  In 1981, the authors reported' that responsibility for directing
actions at  this site had been transferred from one State agency to
another. Responsibility was subsequently reversed again. Struggle
within the State agencies  for ultimate jurisdiction and authority
was conspicuous and appears to have caused significant delays in
the cleanup.  Not only were inter-agency disagreements evident,
but intra-agency disputes  developed as well. The role of the Re-
ceiver was to assist the judge in understanding the technical issues
and arguments in this chaotic period. Even though State agencies
should have  provided unbiased opinions to the  court, many ex-
amples of poor analysis and incomplete planning  by the  State
agencies were found.
                                                     In 1983,  there were several major public administration changes
                                                     which markedly affected this project. A new governor was elected
                                                     for the first time in 14 years, thus creating changes in major de-
                                                     partment heads. In addition, a new judge was elected to the circuit
                                                     court. With these changes came the delays resulting from the need
                                                     for familiarization. There were also changes in direction as a re-
                                                     sult of new opinions.
                                                       During a court  hearing in Aug.  1983,  another bureaucratic
                                                     difficulty became apparent. Under the cooperative agreement be-
                                                     tween the State and USEPA, the  State had been designated the
                                                     lead agency. USEPA, however, indicated that this relationship was
                                                     only effective during periods of normal remedial activities. In in-
                                                     stances  where emergency funding  and actions are provided,
                                                     USEPA advised that they claim total control over the emergency
                                                     work and any portions of the site effected by their activities. In a
                                                     situation where the State court has repeatedly announced its con-
                                                     tinuing jurisdiction, the conflict is obvious.
                                                     Technical Opinion
                                                       In Apr.  1983, a court  hearing was held,  resulting in a major
                                                     change in direction in cleanup activities. This hearing was orig-
                                                     inally scheduled to provide a basis for  reporting progress in the
                                                     cleanup but evolved into a forum for debate  of the announced in-
                                                     tention of the State agencies to defer cleanup activities until the
                                                     fall of 1983. The decision to delay had  been reached by the new
                                                     governor on the basis of advice received from his staff. However,
                                                     the State agencies were now cross-defendants in the lawsuit and
                                                     were called upon by the Court to justify their decision.
                                                       The hearing started early one Saturday morning, was interrupted
                                                     only briefly for a lunch break and continued until  10:00 p.m.
                                                     The majority of the testimony during this long hearing came from
                                                     technical representatives of State and federal agencies. The testi-
                                                     mony was particularly interesting in three respects:  (1) the extent
                                                     to which the witnesses disagreed, (2) the extent to which witnesses
                                                     were willing to rely on assumed or statistical projections and (3)
                                                     the ultra-conservative  nature of some of the underlying technical
                                                     assumptions.
                                                       Controversy on the issue of continuing or deferring cleanup had
                                                     arisen as a result of fears that the impending warm weather would
                                                     aggravate the  emission of volatile hazardous materials from the
                                                     site. Representatives from departments commonly  associated in
                                                     remedial and response activities tended  to favor continued clean-
                                                     up  and believed that appropriate controls could be exercised to
                                                     allow safe and expeditious completion of the  work  in  warm
                                                     weather. Representatives from agencies more commonly associated
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REMEDIAL RESPONSE
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with evaluative activities and standard setting tended to favor con-
tinued observation and study rather than continued cleanup.
  Blind faith  in  historical information  provided  a lighthearted
moment. One witness testified that the  current warm dry trend
would continue for at least five days. The witness  was so con-
vinced of the  accuracy of the projections that they  stated all of
their predictions were going to occur with nearly 100% certainty.
Later that evening, the authors had great  difficulty in finding their
way home due to an intense storm which blanketed the Flint area
with 6 to 8 in. of snow. The authors jokingly concluded that since
the weather  predictions had been so accurate, the remaining pre-
dictions made during the hearing were likely to all come true.
  The impractical nature of some of the technical opinions and
recommended controls were a  further impediment to the cleanup.
Based on hearsay, there was concern that both cyanide and acids
might be present in the materials on the site  in sufficient quan-
tities to provide a reaction and emission of cyanide gas. Staff from
the State had carefully modeled the area and assumed a worse case
scenario in  which violent reaction  occurred,  weather conditions
were least advantageous and emissions at the  boundary resulted.
Not only did it appear that great confidence was being placed in a
model which was generated from an assumed and empirical base,
but the allowable cyanide exposure levels at the boundary were also
unbelievably conservative. The allowable  exposure had been set at
a level many times lower than the exposure levels that are accep-
table for cyanide gas in an industrial working space.
  The variety  of testimony made it  evident that the new governor
must have found it extremely difficult to evaluate the question of
continued remedial action. The opportunity for in-depth question-
ing at the prolonged hearing and the wide variety of witnesses  re-
sulted in a different conclusion being drawn by the Court; so much
so that the Court appointed a special Administrator to direct the
cleanup activities and instructed the Administrator on the goals to
be  achieved. However,  even this direct  intervention has  not  re-
sulted in achievement of the intended goal.

Legal Constraints
  In 1981, the authors  reported1 that legal constraints were en-
cumbering progress. The bankruptcy of Berlin & Farro had  re-
sulted in a temporary restraining order being imposed by the fed-
eral bankruptcy court which  stopped cleanup activities. Owner-
ship of a portion of the site by another party interfered with the
right to access and enforcement. As these legal difficulties were
overcome, it appears  the State agencies failed to use the judicial
process to its maximum advantage.  Having obtained  the ability to
proceed, the State agencies failed to follow the agreed upon plans
for remedial action. This failure prompted intervention and caused
the State agencies to become defendants  in the lawsuit. This legal
maneuvering significantly delayed the cleanup work.

Contracting

  The State agencies divided the remedial action at the site into a
variety of individual contractual  elements, i.e., fencing, sludge re-
moval,  liquid and tank  removal, drum  removal, hydrogeologic
study, etc. Efforts were made to contract the work for each element
by solicitation of separate competitive proposals. Ideally, such an
approach should bring specialists to bear on each area of need, but
it also carries with it the need for extensive coordination. In reality,
the multiple  contract approach appears to have fostered confusion,
higher costs, lack of federal support and time delavs.
  Broad general contracts are  intended to place  the responsibility
for cost control  and subcontractor coordination with a contrac-
tor that is experienced and successful in  these types  of activities.
Broad general contracts  also allow the administrative effort to be
focused on a single company and provide a better opportunity for
responding to changes in the work as it is performed. The authors
believe such an approach would have benefitted this project.
  It appears that both the State and federal agencies favor the seg-
mented approach. While the  segmented approach provides an
opportunity for a more exact evaluation of specific items of work
and of specific funding actions, it greatly delays the cleanup. In
this case,  a specific contract was expanded in scope to expedite
completion of the work. USEPA has now indicated that the addi-
tional work will not be eligible for federal funds due to the lack of
competitive solicitation of bids. State funds have been exhausted
and effective remedial action has been brought to a standstill.

Availability of Funds
  In 1981, the authors stated1 that "Money has and will continue
to be the  key issue." Nothing that has happened in the past two
years suggests that this will change. The  State has expended over
$4 million in the cleanup process. The USEPA has made some con-
tributions, but appears  to seek every opportunity to avoid doing so.
USEPA funds are, of course, limited and USEPA has asserted
that one  of its primary  objectives is maintaining the  ability to
achieve cost recovery  from industry. Any activity which might
jeopardize this  opportunity  is  apparently  not acceptable  to
USEPA.
CONCLUSIONS
  One of the conclusions drawn in the 1981 paper1 was:
   "A realistic assessment should be made  at the onset regarding
   desired results and the time for accomplishment. Wasted effort
   and lost time will otherwise result."
  Unfortunately, this  basic  concept  has not  been followed at
Berlin & Farro. It is obvious that a realistic assessment has never
been  made, cleanup has not occurred and considerable wasted
effort has  resulted.
  As Receiver, the authors' firm continually calls attention to the
need to overcome this deficiency, but the contributing factors dis-
cussed above have prevented this from occurring.
  The Berlin & Farro site cleanup is a  task  which, if properly
planned, should have taken only a few months for  implementa-
tion.  After more than two years, the cleanup  is only  half com-
pleted. It  is now being suggested that the final  cost of cleanup at
Berlin & Farro will be more than double the  funds  expended to
date.  Along with these high costs, and in many instances contrib-
uting to them, are associated delays in completion of the work.
  Public dissatisfaction with the repeated and extended delays has
been pronounced to the point that a state representative, a town-
ship supervisor and private citizens have brought suit against agen-
cies of the State of Michigan for failure to achieve a solution. This
caused some agencies which initiated action as plaintiffs to become
cross-defendants. Further, the Court pre-empted the decision mak-
ing authority of the State agencies and directed remedial action.
  The authors believe the Receiver,  as  a non-adversarial  tech-
nical adviser to the Court, has played an effective role in assist-
ing the Court  in its efforts.  Improved cooperation between State
and federal agencies and continuity in their objectives would have
further improved the results. Administrative changes such as the
utilization of a broad general contract would also have worked to
advantage.
  The Court and the  public  have  sound reason for calling for
"expeditious completion." From a contractual standpoint,  it re-
duces cost. From an environmental standpoint, it increases bene-
fit. From a political standpoint, it provides public satisfaction.
The nation's approach to cleanup activities must be modified if it
is to fulfill this demand for timely results.

REFERENCES

1. Scott, J.C. and Pearce, R.B., "Forced Cleanup: A  Police Action or a
   Moral Judgement," Proc. Second National Conference on  Manage-
   ment of Uncontrolled Hazardous  Waste  Sites, Oct.  1981, Washing-
   ton, D.C.255-258.
                                                                                             REMEDIAL RESPONSE
                                                           321
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                  HAZARDOUS  WASTES WORKER  HEALTH
                                AND  SAFETY GUIDELINES

                                         LYNN P. WALLACE,  Ph.D.
                                            WILLIAM F. MARTIN
                                 Department of Health and Human Services
                                              Public Health Service
                                          Centers for Disease Control
                           National Institute for Occupational  Safety  and  Health
                                                Cincinnati, Ohio
INTRODUCTION
  Man has been faced with waste problems since he threw away the
first food scraps, bones and used clothing. These were not  very
hazardous to his health except for sanitation and nuisance. As  man
has left agriculture and become involved in commercial and indus-
trial pursuits, workers have increasingly encountered materials that
affected their health and safety. The mining of mercury ore (cinne-
bar) in Roman times is one recorded example of a recognized  haz-
ard for which worker protection was attempted.'  As  more  and
more man-made or synthetic materials have been developed  and
utilized, the exposure of workers to materials that  are or can be
hazardous  to health and safety has greatly increased. The science
and art of  Industrial Hygiene has emerged over the years with the
express purpose of protecting workers who handle or are  exposed
to materials or conditions that are hazardous or unsafe.
  Unfortunately, while efforts were being made to improve work
conditions  and reduce work exposures, very little was done to  con-
trol the disposal of hazardous materials. Incidents such as "Love
Canal" and "Valley of the Drums" focused the attention of Con-
gress and the public on problems of hazardous waste disposal and
precipitated action to correct these problems.  Public Law 94-580,
The Resource Conservation and Recovery Act of 1976 (RCRA),
and Public Law 95-510, The Comprehensive Environmental Re-
sponse, Compensation  and Liability  Act of  1980 (CERCLA or
Superfund) were two very important legislative actions passed to
prevent future disposal problems and to remedy past disposal prac-
tices.
  These two pieces  of legislation have had a  profound effect on
the number of workers that are  or can be exposed to  hazardous
materials. It is estimated that up to 40,000 workers2 may be in-
volved in cleaning the estimated 30,000 abandoned sites' in the
United States that contain hazardous wastes.  These numbers are
in addition to the workers involved with hazardous wastes at ap-
proved disposal sites. To this estimate must be added the workers
of other industrialized nations who will also be handling hazardous
wastes throughout the world.
  Transportation  accidents involving hazardous  materials could
expose police, firemen, transportation employees and even entire
neighborhoods during efforts to contain and cleanup these mater-
ials. The total number  of such accidents and persons who may be
exposed is  anyone's guess, but  it  could happen anywhere  that
trucks, trains, barges,  airplanes and pipelines  carry  hazardous
materials.
  Not only are many workers involved  in the actual handling or
cleanup of hazardous  wastes,  but workers are also directly in-
                                                   volved in determining the extent or severity of the problems. Other
                                                   workers at neighboring facilities may not even be aware that there is
                                                   a potential for exposure. It is important to remember that each in-
                                                   dividual in this country has  a  legislated right to  a safe work-
                                                   place.4
                                                     As a vital part of its studies of occupational environments and
                                                   worker health,  the National Institute for Occupational Safety and
                                                   Health (NIOSH) has a long history of involvement in the study of
                                                   hazardous materials and their effects  on workers.  NIOSH has
                                                   developed and  recommended standards for good workplace prac-
                                                   tices for government, industry and labor. NIOSH  has also pro-
                                                   vided recommendations for specific problems through technical re-
                                                   ports, health hazard evaluations  and health and safety guides for
                                                   both employers and employees. NIOSH has established an en-
                                                   viable record of accomplishments in worker protection and con-
                                                   tinues to be actively involved in  health and safety considerations
                                                   for workers throughout the workforce.
                                                     It is not surprising that the majority of the chemicals studied by
                                                   NIOSH in the  past have been identified by USEPA as those of
                                                   greatest concern at hazardous waste sites or during emergency ac-
                                                   tions. This experience with toxic materials and work environ-
                                                   ments was a very  important reason  that NIOSH was given  spe-
                                                   cific responsibilities under the  CERCLA-Superfund legislation5
                                                   for hazardous  waste worker health and safety. These Superfund
                                                   responsibilities  have expanded many on-going NIOSH research ac-
                                                   tivities that probe the interactions between worker and hazardous
                                                   work  environments and have initiated  other necessary investiga-
                                                   tions.
                                                   INTERAGENCY AGREEMENTS
                                                     Two Interagency Agreements between the Department of Health
                                                   and Human Services (DHHS) and USEPA have been enacted to
                                                   accomplish these  responsibilities.  These agreements outline the
                                                   scope of occupational health and safety  activities and provide the
                                                   funding for their  implementation. The  two  major activities are:
                                                   (1)  to  develop comprehensive  guidelines for worker  health and
                                                   safety  and  (2) to provide scientific support and training. In this
                                                   paper, the authors discuss the first of these two activities.
                                                   Comprehensive Guidance Manual
                                                     Comprehensive guidelines were developed under a Memorandum
                                                   of Understanding (MOU)  signed on Dec. 18,  1980, by USEPA,
                                                   the Occupational Safety and Health Administration (OSHA), the
                                                   U.S. Coast Guard (USCG) and NIOSH. The four agencies, with
322
REMEDIAL RESPONSE
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NIOSH as lead,  agreed to jointly  develop  a "Comprehensive
Guidance  Manual" to be used by field supervisors and  govern-
ment authorities.
  Because of differences in anticipated user groups, including the
state and local bureaucracies that regulate such groups, it was de-
cided to present  the  guidelines  in two separate  volumes.  Even
though  they would be similar in outline and content, each vol-
ume had significant differences and was designed for a different
audience.  Volume One deals with cleanup operations at remedial
sites where hazardous wastes are known to exist and where clean-
up  will be undertaken. Volume Two deals with  worker protec-
tion during accidental releases of hazardous substances and haz-
ardous waste emergencies.
  The purpose of the two-volume  "Comprehensive Guidance
Manual"  is to provide consistent,  sound and detailed  occupa-
tional  health and safety technical information to all those in-
volved in the management, cleanup, treatment and disposal of
hazardous waste.  The Manual is designed for use by many  agen-
cies: Federal, State and local government;  emergency response
groups at all  levels; cleanup crews; unions and employee  groups;
and other public interest groups or individuals. The primary users,
however, will be those responsible for the management and super-
vision of workers  involved in the cleanup and control of hazardous
waste.
  NIOSH has completed the first drafts of the two volumes and
has submitted them to USEPA, OSHA and the USCG for review.
The Comprehensive Guidance Manual will be distributed to each
State and  local control agency as soon as it is completed.  This
paper will discuss only the contents of Volume I which deals with
cleanup operations at remedial sites.

CLEANUP OPERATIONS MANUAL
  The Manual is divided into four sections, and a very large appen-
dix of technical information.  Section "A" introduces the Manual
and contains  its purpose and historical background. It defines the
waste disposal problem, the  intended  audience and  outlines the
scope  and Manual format. Section "B" discusses  information
gathering processes and techniques from pre-entry to post closure
monitoring. This section is concerned with how to obtain the neces-
sary data to  determine the extent of any hazards. Section  "C"
covers information evaluation and hazard assessment procedures.
This section is designed to guide in evaluating the significance of
the data that are  collected. Section "D"  contains hazard control
programs including recommended administrative  practices,  work
practices, personal protective equipment, decontamination pro-
cedures, engineering controls, training requirements and  medical
surveillance protocols. This section tells what  should  be  done to
control or eliminate hazards to workers. The appendices contain  a
variety of useful references and decision-making data that are use-
ful but encumbered the main sections of the Manual.
  The Manual is a current state-of-the-art document and should be
a valuable tool to all who are involved  in hazardous waste ac-
tivities. It contains guidelines and recommendations from which
standard operating procedures can be developed for state  agencies
or  specific sites.  It is designed  to be updated as additional in-
vestigative tools are developed or as the state-of-the-art improves.
  The entire  contents of this  Manual  would  be too  extensive to
cover in a short presentation such as this. Some of the interesting
aspects of the Manual are presented to give  a flavor of what  is
contained therein  and to "spark" reader's interest.
  It is not the intent of the guidance Manual to  repeat basic in-
dustrial hygiene or toxicological information that could be found in
standard textbooks but rather to emphasize those techniques, prob-
lems and considerations that are unique at hazardous waste sites.
The guidance Manual discusses advantages and disadvantages of
various screening, sampling and monitoring techniques and makes
recommendations as to which may be best suited to a particular
circumstance or operation. Detailed information on methods, pro-
cedures, mathematical models and sampling strategies is contained
in the appendices.  Guidance is given  for  monitoring and eval-
uating chemical hazards, physical  hazards,  safety hazards and
biological hazards that pertain to remedial actions.
  The main premise of the Manual is that accurate information is
needed from which to  assess the risks involved and make intelli-
gent decisions regarding worker protection.  While this is not news
to those involved in hazardous waste activities, many decisions may
currently be based on inaccurate or insufficient information.
Selecting Worker Protection Levels

  Many of the current methods for selecting worker protection
levels have developed as work has progressed and experience has
accumulated. When an individual approaches an unknown and
potentially hazardous environment, caution  must indeed be taken.
Every effort  must be extended to  obtain  pertinent  information
from existing sources before physically entering a site. Experience
to date, however, consistently indicates  lower levels of measured
contaminants than  was anticipated. This would suggest that,  in
most cases, lower levels of protection could  therefore  be  required.
Because of the unknown elements or the  uncertainty  of many
situations, there is an extreme reluctance to lower levels of pro-
tection even when the collected data indicate that it is safe to do so.
It is certainly proper for first entry personnel  to be over-pro-
tected until actual levels of contamination are determined. To con-
tinue to utilize extra protection when the data do not warrant it or
because insufficient data have been collected from which to make
intelligent decisions is an irresponsible  action on  the part of de-
cision makers. In addition,  practice has led to increased opera-
tional costs and in some cases has actually contributed to occupa-
tional health and safety problems.
  The conservative  approach is taken mainly to protect workers
against exposure to chemical hazards. This becomes the overriding
hazard consideration and other hazards,  such as physical or safety
hazards, may not be given proper consideration. If inn attempts to
protect against chemicals a worker suffers heat exhaustion, or is
run over by a piece  of heavy equipment because his visibility was
restricted, or suffers back strain, or is  severely cut  or  crushed,
has the worker's health and safety been adequately protected?
The conservative approach is often the correct method, but some-
times the productivity of the workers is unnecessarily  restricted  or
worker stress is excessive because the approach is too conserva-
tive for actual conditions. If a worker is injured by practices that
are supposed to protect him, these practices become a false form
of worker protection. Worker protection practices  should be com-
mensurate with the hazards. This implies that the hazards must  be
defined. Accurate information  on existing  or suspected hazards
must be obtained in order to properly define the hazard.  The cost
of obtaining needed information prior to decision-making may  be
considerably less than the cost of remedial actions based on in-
accurate or incomplete information.


IDLH LEVELS
  The most important first  task is  to identify any conditions  or
situations that may be immediately dangerous to life or health
(IDHL). This, of course, includes all such situations  and not just
those associated with toxic chemicals. Monitoring for or identify-
ing IDLH situations must continue throughout the entire remedial
action at each site.  One of the most effective  methods to identify
many IDLH situations is to screen for explosive atmospheres, am-
bient air with insufficient oxygen to sustain life, air mixtures con-
taining volatile organics that may be toxic and particulates or non-
organic substances  that may be toxic. When the screening  indi-
cates a problem, more specific sampling should then take place to
properly define the problem.
  The current procedure at  many sites  is to measure  the levels of
volatile organics with an organic vapor analyzer (OVA) or an HNU
Photoionizer and determine the needed  levels of protection based
on the obtained readings. The  authors have learned  that volatile
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                                                          323
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organics, although almost always present in low  concentrations,
are only one of several classes of materials that will be encountered.
Additionally, paniculate material, in  the form of organic, non-
volatile organic or particulate-bound compounds may also be re-
sponsible for a large fraction of the  overall chemical exposures
that  might be encountered on or near  a hazardous waste site.6
These  and  other contaminants may be missed by using only the
HNU or OVA instruments.

SDRITS

   To help  fill the gap and provide needed information for proper
decision-making,  NIOSH developed a Simultaneous Direct Read-
ing Indicator Tube System (SDRITS) which concurrently draws
air through  ten  separate colorimetric  direct reading detection
tubes.7 This device enables field personnel to complete the ten tube
scKening protocol  suggested  by  Schneider with greatly reduced
sampling time.' The  SDRITS was developed to  detect the type
and extent  of unconfined dangerous chemicals or their reaction by-
products, due to  interaction with water,  each other or fire and is
sufficiently sensitive to avoid acutely dangerous conditions. The
identification is limited to definition of various substance groups,
such as acid reacting substances, amines and alcohols. Substances
not included in the Schneider scheme (such as hydrogen cyanide
and hydrogen sulfide) can also be rapidly detected, either by de-
ployment of a second sampling device or by serial screening us-
ing a single device.'
   By screening with a combination of the OVA,  HNU, SDRITS
and other  devices such as explosion meters and oxygen level in-
dicators, vital information can be obtained which will help  inves-
tigators determine what specific additional sampling is required for
materials that are suspected or indicated to be present. The level
or levels of protection can then be set commensurate with the
actual problem or problems and not based on partial or perhaps in-
correct information. Using these screening devices and then samp-
ling or monitoring with more accurate  instruments (gas chrom-
atograph and spectrometer,  for example) that can detect actual
levels  of specific contaminants is a preferred method of determin-
ing the actual hazard and more accurately assessing the risk.
PHYSICAL HAZARDS
   Most of the lost work time at hazardous waste sites to date has
been  from injuries  due to  physical  hazards  and not from ex-
posure to chemicals or toxic substances. Slips, trips and falls along
with back  strains and cuts and abrasions are reported as the lead-
ing causes  of workers being absent from work. All of the causes
for this phenomena may never be known, but it is postulated that
the loss of vision and agility from wearing protective clothing is a
contributing factor. The presence of sharp objects, unlevel ground,
improperly stacked  barrels, deteriorated buildings  and unstable
materials are all contributors to these accidents.
   The problems of working in protective clothing and equipment
have additional ramifications. Excess water vapor inside masks and
facepieces can cause fogging and severely reduce vision. The nature
of many facepieces restricts  the  range  of vision,  especially per-
ipheral vision. The ability to  communicate is reduced while wear-
ing a mask or hood. Thick gloves can severely reduce the manual
dexterity required to do certain tasks. Special boots or boot covers
can  increase clumsiness and  contribute  to slips,  trips and falls.
Bulky clothing can easily catch on protruding objects. The bulk
and weight of air tanks, hoses and controls carried for air supply
can both get in the way and increase fatigue.  The ability to freely
or quickly exit during emergencies is often reduced.
Heat Stress

   Another and perhaps more significant cause of lost or unpro-
ductive time is caused by conditions which produce heat stress. The
very nature of  personal protective clothing and equipment causes
other  problems for workers  who must  use them.  Materials are
selected which will provide a barrier of protection for the worker by
                                                       keeping liquids, vapors, fumes and smoke from reaching the body.
                                                       These same barriers prevent  body generated liquids and vapors
                                                       from escaping. This can be particularly devastating when workers
                                                       are subjected to ambient conditions  which exacerbate  this prob-
                                                       lem.  Simply put, the body is  designed to dissipate heat by sweat-
                                                       ing and evaporation. If the sweat is not allowed to evaporate be-
                                                       cause of a combination of impermeable clothing and hot, humid,
                                                       ambient conditions, the body cannot get rid  of its excess heat.
                                                       When hard manual work such as lifting, pulling, shoveling, etc., is
                                                       required,  additional stresses are placed on the workers and addi-
                                                       tional heat must be dissipated. As heat builds up in the  body, it
                                                       causes a variety of strains leading to heat exhaustion and  possible
                                                       heat stroke which can be fatal.
                                                         Add to these heat and work stress related problems the psycho-
                                                       logical stress of being surrounded by unknown toxic materials or
                                                       the claustrophobic  impact of being enclosed  in a fully encap-
                                                       sulated suit with increased breathing requirements due to a pro-
                                                       tective  respirator, and the concerns for worker safety and health
                                                       are significantly increased.
                                                         When workers are grossly uncomfortable wearing  protective
                                                       equipment  while  doing hard manual labor in  hot  humid con-
                                                       ditions, their reaction is to remove the protective equipment when
                                                       it may  be unsafe to do so or  to refuse to wear it. Unfortunately,
                                                       these same hot conditions usually increase the volatility of many
                                                       toxic materials and their ambient  concentrations increase. To re-
                                                       move the protective equipment when  toxic concentrations may be
                                                       the highest seems folly indeed, but when the temperature becomes
                                                       unbearably hot the temptation is great.
                                                         Working in protective clothing and wearing respirators can place
                                                       additional stress on the lungs and heart. Workers who have lung or
                                                       heart conditions should not be allowed to wear this equipment if
                                                       it could cause damage to their vital organs. Medical screening of
                                                       workers and supervision to determine if these workers can handle
                                                       the stress of wearing protective equipment is vital to their safety
                                                       and health. Consequently,  some people should not be permitted
                                                       at hazardous waste operations if  they  cannot wear the special
                                                       clothing and  equipment required for their protection. The sec-
                                                       tions on heat stress and medical monitoring should be very use-
                                                       ful to all who are concerned with worker protection.
                                                         If workers are required  to wear excess  protective equipment or
                                                       higher  levels of protection simply because those in charge are not
                                                       willing to properly sample or  monitor in order to specify  the cor-
                                                       rect level of protection comensurate with the actual (not supposed)
                                                       conditions, then those in charge must accept responsibility for the
                                                       heat stress and other problems caused by wearing such equipment.
                                                       Where the protective equipment is required because of actual haz-
                                                       ards, then work schedules must be altered to provide the needed
                                                       rest and cool-down periods for worker health and safety. Physical
                                                       hazards that produce the slips,  trips  and falls must be removed.
                                                       Mechanical handling of heavy or contaminated objects must be in-
                                                       stituted. Engineered controls must be implemented and proper de-
                                                       contamination procedures must be followed. The cost for adjust-
                                                       ing to these conditions is certainly justified.
                                                       PERSONAL PROTECTIVE EQUIPMENT

                                                         One particular section on the selection, use and limitations of
                                                       personal protective equipment (PPE) should prove very useful. The
                                                       schemes suggested are perhaps different than existing USEPA lev-
                                                       els of protection  in that respiratory tract protection is separate
                                                       from skin or body protection rather than being combined into a
                                                       level of protection. This scheme is based on the potential entry to
                                                       the body of toxic materials by either skin absorption or respira-
                                                       tory tract absorption and levels of protection are separately selected
                                                       commensurate with the separate problems.
                                                         The basic criteria for selection of PPE are as'follows:
                                                       •The characteristics of the substance (toxic, explosive, corrosive,
                                                        concentration, physical state, length of exposure, permissible ex-
                                                        posure limits)
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REMEDIAL RESPONSE
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•The work task to be performed (expected work duration, type of
 work, level of physical effort, proximity to exposure)
•The protective equipment  function (respiratory skin, face and
 eye, foot, head, hearing, entry and fall)
•The environment (temperature, humidity, wind, effects on both
 the worker and the PPE selected)
•Human Factors (susceptability to stress,  weight  of equipment,
 physical fitness, acclimatization, age, medical history)
  These factors all combine to select the final criteria:
•Protective ensemble  (correct combinations of protective equip-
 ment to satisfy the previous criteria)
  The  main point is that several factors must  be  simultaneously
considered in PPE selection. Different levels of protection may be
required for different jobs or for different locations on-site. It is
not an arbitrary "well let's specify level for everyone on site B to-
day" type of an approach if one truly has the total health and
safety of each worker as his objective.
  The  Manual contains a large section on the recognition, evalua-
tion and control of physical and safety hazards. This information
is in tabular form and contains the applicable regulations pertain-
ing to  the hazards listed. The Manual also contains an extensive
site safety checklist. Both of these items should be very useful to
those concerned with remedial actions at hazardous waste sites.
  Basic administrative and program requirements  for proper site
control, work practices, emergency controls and safeguards, emer-
gency medical care, health surveillance and medical  screening are
covered in the Manual. Because it was observed at some sites that
the highest levels of airborne contamination were measured in the
mobile laboratory and not where the remedial work  was proceed-
ing, a section on health and safety controls  for  mobile labora-
tories is included.
APPENDED INFORMATION
  The appendices contain sources of occupational health and safe-
ty data and information and describe the  advantages  and disad-
vantages  of  various computerized information systems  as  they
apply  to  remedial actions and hazardous substances  incidents.
NIH/USEPA Chemical Information Systems, CHEMTREC, Na-
tional  Response Center, Hazardous Materials Emergency Re-
sponse, MEDlars, Toxline, Library of Medicine and Orbit are some
of the computerized systems discussed.  CHRIS Manual Informa-
tion, Hygienic Guide Series,  NFPA Data Sheets, OHM-TADS File
listings and sample formats,  RTECS, WDROP, FRSS,  CTCP and
TSCAPP are other systems that are discussed.
  The appendices also contain a sample Occupational Health and
Safety Program, Guidelines  for Selection of Personal Protective
Equipment, more detailed decontamination procedures, a sample
Occupational Health Checklist for Hazardous Waste Sites, a Data
Book on  Chemical  Hazards, Mathematical models used in air
sampling strategies, sampling procedures and information on use
of available equipment.

CONCLUSION
  The Manual is comprehensive and the appendices are volum-
inous but together they contain valuable information which will
benefit the intended users. The appendices are separately bound
from the main Manual in order to reduce the actual volume but
still be available as reference material. The Manuals are state-of-
the-art and  are designed  to be updated as additional informa-
tion  becomes  available. The authors invite their  use  and solicit
correctional information to make them more useful and accurate.
REFERENCES

1.  Herrick,  R.  "Dangerous Properties  of Industrial Materials".  Sax,
   N.I., Ed; Van Nostrand: New York, 1979, 1-3.
2.  Robinson, D.M. and Scott, D.M.  "NIOSH Program Plan for Haz-
   ardous Waste" NIOSH program concept memorandum, Appendix II.
   July 13, 1981, NIOSH, Cincinnati, Ohio.
3.  Public Law  96-510, "The Comprehensive Environmental Response,
   Compensation, and Liability Act of  1980", 96 Congress, HR 2020,
   Dec. 11, 1980 (Legislation History, paage 6120).
4.  Public Law 91-596, "Occupational Safety and Health Act of 1970", 91
   Congress, S. 2193, Dec. 29, 1970.
5.  Public Law  96-510, "The Comprehensive Environmental Response,
   Compensation, and Liability Act of  1980", 96 Congress, HR 2020,
   Dec. 11, 1980, Sec 104(i), 111 (c)(6), 301 (f).
6.  Geraci, C.L. Jr. and Costello, R.H. "Qualitative  Screening of Air-
   borne Containments at a Hazardous Waste Site", Proc. of The Amer-
   ican Industrial Hygiene Association and American Conference of Gov-
   ernmental Industrial Hygienists Hazardous Waste  Symposium, May
   1983. Philadelphia, Pa.
7.  King, M.V.,  Eller, P.M. and Costello, R.J. "A Qualitative Sampling
   Device for Use at Hazardous Waste  Sites". Proc.  of The American
   Industrial Hygiene  Association and  American Conference of Gov-
   ernmental Industrial Hygienists Hazardous Waste  Symposium, May
   1983. Philadelphia, Pa.
8.  Schneider, D. "The Draeger Gas Detection Kit, Draeger Review 46,
   (1980), 5-12.
9.  King, M.V.,  Eller, P.M. and Costello, R.J. "A Qualitative Sampling
   Device for Use at Hazardous Waste  Sites". Proc.  of The American
   Industrial Hygiene  Association and  American Conference of Gov-
   ernmental Industrial Hygienists Hazardous Waste  Symposium, May
   1983. Philadelphia, Pa.
                                                                                             REMEDIAL RESPONSE
                                                                                                                            325
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                   NAVY  MANAGEMENT  OF  ABANDONED
                               HAZARDOUS WASTE SITES

                               LT. (jg) LILY-ANN OPENSHAW, CEC, USN
                                          ELIZABETH B. LUECKER
                               CDR. JOHN P. COLLINS, Ph.D., CEC, USN
                                    Naval Facilities Engineering Command
                                            Port Hueneme,  California
BACKGROUND
  The Navy Assessment and Control  of  Installation Pollutants
(NACIP) program began in 1980 as part  of the Department of
Defense (DOD) Installation Restoration program. DOD initiated
hazardous waste site investigations in 1975, five years before the
Comprehensive Environmental Response, Compensation and Li-
ability Act (CERCLA) of 1980.' In this paper, the Naval Energy
and Environmental Support Activity (NEESA), NACIP program
executive manager, reviews techniques in site discovery, risk assess-
ment, site sampling and site restoration.
  The NACIP program uses three levels of assessment in screen-
ing hazardous waste sites. Phase I, the Initial Assessment Study
(IAS), identifies where hazardous wastes were disposed and which
of these sites have potential problems. Phase II, the Confirmation
Study, investigates these sites and verifies those with definite con-
tamination. Phase III, the Corrective Measures Study, determines
the most effective way to control contaminant migration and pro-
vides site restoration.
  Based on the presence of heavy industrial operations, past in-
discriminate disposal of hazardous wastes and local ground or sur-
face water  used for agricultural or potable supplies, the  Navy
scheduled 79 bases for study in the 5-year NACIP program.  For a
consistent approach in  the study of all Navy sites,  NEESA, a
specialized consulting group within the  Navy, conducts the Phase
1 effort.  After the Phase I study has been completed at a  naval
base, six regional Engineering Field Divisions of the Naval  Facil-
ities Engineering Command conduct the site specific Phase II and
III efforts.
Initial Assessment Study

  NEESA assigns a team of scientists  and engineers to each In-
itial Assessment Study. The team collects and evaluates informa-
tion on  past naval base industrial operations.  Information ob-
tained may identify hazardous waste sites on the base. The  study
includes a review of archival and base records, interviews with
base personnel and an on-site survey.
  The IAS begins with  records searches at various national and
regional government agencies for a complete history of the  naval
base. More specific information needed to assess likely contam-
ination sources is found in the naval base's files.  In most cases,
the type of detailed  information needed for the IAS  will not be
found in records. Base records on waste disposal were often lost,
destroyed or not kept. Shops were concerned with keeping track of
products—not wastes.
  For these reasons, the most important part of the IAS is the time
spent interviewing long-term employees or retirees about past oper-
ations,  especially past  waste disposal.  Although interview  tech-
nique is as important to the success of the study as technical exper-
tise, it is the most difficult skill to master for the IAS team. Scien-
tists and engineers ask exacting questions  and expect immediate
                                                    and complete answers. Inexperienced team members can become
                                                    frustrated with this approach. In interviews, the NACIP program
                                                    managers stress a patient, personal approach to win the worker's
                                                    confidence.
                                                      Interviews lead the IAS team to the majority of the sites un-
                                                    covered during a study. The team then inspects the sites for signs of
                                                    contamination,  such  as stressed vegetation or ground stains, and
                                                    reviews local hydrogeology. If the waste disposed of, or spilled, has
                                                    a high soil attenuation such as PCBs or DDT, the team may take a
                                                    mixed grab sample of the area.
                                                      With  information  compiled and assimilated from  records
                                                    searches, interviews, observations and these few samples, the team
                                                    evaluates each site. If the team determines the possibility exists for
                                                    a site  to endanger human health or  the environment, a Phase II
                                                    Confirmation Study will be recommended in the IAS. This Con-
                                                    firmation Study may call for extensive sampling such as vertical
                                                    and horizontal sampling grids and monitoring wells to determine
                                                    the existence and amount of contamination.
                                                    Ranking Models

                                                      To determine the  need  for and  priority of Phase II efforts,
                                                    NEESA developed a ranking model  to score sites. This model
                                                    makes it possible to compare  sites containing different wastes,
                                                    ranging from pesticides to plating wastes, and located in different
                                                    hydrogeologic areas,  ranging from arctic tundra to South Pacific
                                                    island jungles. This decision process standardizes the type of in-
                                                    formation documented on each site and is known as the Confirma-
                                                    tion Study Ranking System (CSRS).
                                                      The first step of the CSRS is a flowchart that eliminates innoc-
                                                    uous sites from further consideration. This flowchart ensures that
                                                    all important characteristics of a site are considered before the site
                                                    is labeled innocuous. Aspects of a site reviewed in the flowchart
                                                    include the type and amount of waste, type and condition of con-
                                                    tainment (if any), hydrogeology conducive to migration, degrada-
                                                    tion of the waste and possible receptors such as humans and en-
                                                    dangered species.
                                                      Step two of the CSRS is the Confirmation Study Ranking Model
                                                    (CSRM) which objectively ranks sites needing further study. Fund-
                                                    ing priorities for  further site investigations can be  effectively es-
                                                    tablished in this step. The CSRM incorporates three major areas of
                                                    concern at a site: receptors of possible contaminants, potential mi-
                                                    gration pathways and characteristics of the wastes.  The receptors
                                                    category subscore includes items such as nearby population, crit-
                                                    ical environments for endangered species, land use and surface and
                                                    groundwater uses.
                                                      The pathways category subscore is based on analytical evidence
                                                    of contamination or the highest of one of three potential pathways
                                                    of migration. These migration pathways consider factors such as
                                                    soil  permeability, rainfall intensity, net precipitation, distance to
 326
REMEDIAL RESPONSE
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nearest surface water body and depth to groundwater. The waste
characteristics category subscore includes waste quantity, acute and
chronic toxicity, persistency, solubility, years since site closure and
similar items. The factors considered in each of the three categor-
ies are listed in Table  3. Once computed, the three category sub-
scores are then incorporated in a multiplicative model to produce
an overall score for the site.3
  As previously mentioned, most of the important information on
the various sites is obtained through interviews with long time per-
sonnel.  In many cases,  due to the uncertainty of the  corporate
memory involved, this information is only available in orders of
magnitude.  Because of this uncertainty,  the interviewers only ask
questions about location of, dates of use of and quantities of waste
at a site. Other information the model uses is readily available from
the literature,4'5 other records and field observations.
   Scores for a CSRS model may range from 0 to  100; 0 being an
innocuous site such as  a construction rubble disposal area, 100
being the worst possible site.  The highest recorded score so far is
64, where the three categories of receptors,  pathways and waste
characteristics  combined to produce  a  significant  environmental
concern. As this range of scores shows, sites within a naval base,
across the country and throughout  the Navy  are  being success-
fully compared with the use  of this model. This range of scores
can be seen in Figure 1.
 Category
            Table 1
 Factors Considered in the CSRM

Rating Factor
 Receptors        -Population within 1000 ft of site
                 -Distance to nearest down gradient well
                 -Land use/zoning within 1 mile radius
                 -Distance to reservation boundary
                 -Critical Environments within 1 mile radius
                 -Water quality/use of nearest surface water body
                 -Groundwater use of the aquifer of concern
                 -Population served by surface water supply within 3
                 miles downstream
                 -Population served by groundwater supply within 3
                 miles
 Pathways        -Direct Evidence of Contamination or potential for
   1—Surface Water Migration, or
      -Distance to nearest down gradient surface water
      -Net precipitation
      -Surface erosion
      -Soil permeability
      -Rainfall intensity
   2—Flooding, or
      -Floodplain
   3—Groundwater Migration Potential
      -Depth to groundwater
      Net precipitation
      -Soil permeability
      Subsurface flows
      Direct access to groundwater
 Waste
 Characteristics    -Waste Quantity
                 -Acute Toxicity
                 -Chronic Toxicity
                 -Persistency
                 -Flammability
                 -Reactivity
                 -Incompatibility
                 -Corrosiveness
                 -Solubility
                 -Bioaccumulation
                 -Physical State
                 -Years site was in use
                 -Years since site closed
  An important aspect of funding and cleanup priorities not con-
sidered in the CSRM is public opinion. The cleanup of abandoned
hazardous waste sites is a high visibility program and the Navy a
high visibility organization. Public opinion may demand further
action at sites  that  do not pose as much  of a  potential hazard
as others. Funding priorities may then be adjusted to incorporate
these other considerations.

Findings

  In the past three years, the Navy has completed  Initial Assess-
ment Studies at  35 naval  bases and  has  investigated over 700
sites. When  an IAS team undertakes a  study, it  examines all
disposal, storage and spill sites, ranging from the unquestionably
innocuous—rubble dumps, to the  potentially hazardous—indus-
trial waste landfills. Over two-thirds  of the  sites identified have
proved to be innocuous. Because the Navy's  highest potential
problem bases, those with heavy industrial operations such as ship-
yards and air rework facilities, were studied first, the future per-
centage of innocuous sites should increase.  In the past three  years
this projection has proven accurate: in FY1981, 65% of the  sites;
in FY1982, 69% of  the sites; and to date in FY1983, 78% of the
sites investigated required  no further action.

CASE STUDIES
  During each study, several potentially contaminated  sites are
usually identified that require further sampling and  minor correc-
tive action. The Navy has initiated Phase II, Confirmation Study,
and Phase III,  Corrective Measures Study,  at several naval bases.
In order to  discuss the general trends of the NACIP program  in
site sampling during Confirmation Study  and in site restoration
during Corrective Measures Study, several case  studies  are pre-
sented. The  sites  described represent four  typical sites recom-
mended  for  further action in the IAS: (1)  a POL (petroleum,
oils, and lubricants) disposal area, (2) a landfill, (3) a PCB site
and (4) a blasting  grit pile. The sites also represent the three most
frequent courses of action taken after the IAS.

POL Disposal Areas
  POL disposal areas may include surface  spills and underground
spills of POL (petroleum, oils and lubricants),  POL sludge dis-
posal pits and  other similar areas. The range of risk assessment
scores given for these sites is shown in Figure 2. The site that will be
 Waste
 Management
-Waste Containment
                       25     35      45
                         CSRM SCORES

                            Figure 1
                  CSRM Score Range for all Sites
                                                                                               REMEDIAL RESPONSE
                                                                                                              327
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                             25
                         CSRM SCORE
                            Figure 2
             CSRM Score Range for POL Disposal Sites
                                  BVERflGE SCORE  . 25      ~]
                         25      35
                         CSRM SCORE
                           Figure 3
                 CSRM Score Range for Landfills

discussed was a series of oily sludge disposal pits located on top of
an old landfill.
  Between 1944 and 1976, oil sludges were disposed of in three un-
lined earthen pits. Two of the pits were filled and covered in 1956,
and the third was emptied and covered in 1976. Portions of the area
have since been used as a parking lot. Exact locations of the  pits
were found on historical aerial photos from the National Archives.
  The na\ al  base is located on a peninsula bordered by a large river
and marshes. Local soils consist of a mixture of fine sand, silts
and gray clay  extending to  a depth of about 50 ft. Due to  the
peninsula's level terrain and soil composition, the IAS team geolo-
gist predicted the movement of trapped subsurface oil on the sur-
face groundsater would closely follow  surface water  drainage pat-
terns.
   As expected, several longtime employees reported oil seepage in
the adjacent marsh areas  and nearby  river banks during  heavy
rains. Because of these reports, the IAS team dug some post holes
and observed approximately 1 ft of oil floating on the shallow
ground water in the area of the sludge pits.6
   The detrimental impact  of oil on aquatic ecosystems  has been
well documented.7'8-9'10 This impact and the evidence of a waste oil
plume migrating toward surface water bodies gave the site a CSRM
score of 26. The LAS team  recommended a Confirmation Study to
determine the concentrations and movement of the oils. First, to
define the real extent of the oil contamination, two options were
proposed.                                            _
   Option 1 involved mapping the area using shallow borings on a
grid system throughout  the area. Borings would be visually  in-
spected for oil, then checked with a portable gas chromatograph
(GC) for hydrocarbons from oily residues.
   Option 2 involved the use of geophysical methods such as ground
penetrating radar (GPR) and a non-contact terrain conductivity
meter to map the area. A few soil borings would be required for
verification and calibration purposes. GPR data could  help the
team evaluate the thickness and location of the liquid oil layer in
the ground. A hand held  auger and the portable GC would be used
to map out the extent of the oily residues in the soil.6
   Option 1  was chosen  because  geophysical methods were used
during the IAS to try to  define the oil lens, but the heterogeneity
of the soils and the presence of  buried conductors prevented in-
terpretation of the data. Eighty-seven shallow borings were drilled
to determine the extent of subsurface oil.  Six  additional borings
were drilled along the river to determine the extent of oil migra-
tion to  the river. Although the use  of a portable  GC had  been
recommended, the GC was not used because visual and odor tests
would detect the levels of oils that could potentially migrate.
   Results of the borings  identified an oil body  approximately 600
ft  by 50 ft by 2-4 in. deep  in the southwestern portion of the oil
sludge area.  East of the oil body, an area of oily residue was also
identified." The location of the oil body was adjacent to the areas
of the marsh where oil seepage had been reported.
   Results of the sampling showed that the slow contaminant migra-
tion was due to a combination of the low soil permeability, the low
hydraulic gradient and the high viscosity of the waste oils. Perme-
abilities of the surficial soils were calculated as 1 x 10"6 cm/sec,
and the  hydraulic gradient was 4.5 x 10"3.
  The Confirmation Study  report concluded that, although an oil
body existed and oil movement was occurring,  the migration was
slow. Therefore, immediate corrective measures, such as soil exca-
vation, were not needed.  Instead, the report recommended two al-
ternative collection systems to prevent further migration.
  The  first  collection system  consisted of ditches,  infiltration
galleries or a combination of these placed around the oil body. The
drains would be pumped so oil could be separated from the water
and recycled. The recycled water would be used to recharge the
shallow groundwater system to speed up the oil recovery process.
The second collection system consisted  of a drainage ditch along
the southwestern edge of the oil body. The ditch would be dammed
at  the downstream end.  A  bypass pipe would  be installed at the
base of  the dam to divert the water into a storm sewer. Periodical-
ly, naval base personnel would pump the ditch to remove the top oil
layer.
  The system installed followed the design of the second alterna-
tive because there was no need to expedite oil recovery. A drain-
age ditch dug for an  adjacent  road  conveniently intercepted the
subsurface oil body and was used in  the collection system. Samp-
ling, followed by a corrective measure such as  this collection sys-
tem, is a typical course of action at sites investigated.

Landfills

   Sanitary landfills were the central depository for all waste ma-
terials  on naval bases  as in  every region of the country. Liquid
wastes  were generally drummed, and combustible  products were
          REMEDIAL RESPONSE
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burned. Trenches were sometimes used,  but usually wastes were
dumped on the ground and covered with fill material. Because of
the varied industrial wastes present, landfills are often the high
scoring sites for a naval base (Figure 3).
  The sanitary landfill described in this case study was used from
the 1930s until 1973 to dispose of solid wastes generated by a ship-
yard. Shipyards must  provide all the services required to maintain
the U.S. Navy fleet of ships: manufacturing, alterations, overhaul
and repair. As a result, the landfill received large quantities of solid
and hazardous  wastes  including  waste  solvents,  paints, paint
sludges, asbestos, metal plating sludges, mercury, PCBs, industrial
liquid wastes (organic and inorganic chemicals) and construction
rubble. In  1973, the landfill  was closed  and capped with a clay
layer. Since that time,  solid wastes have been ahuled off-base under
contract.
   The shipyard is located on a natural peninsula developed with fill
and bounded by a brackish river and a main tributary creek. The
landfill lies in the marsh near the headwaters of the tributary creek.
Surface sediments extend downward 45  ft to an underlying clay
formation. As groundwater moves slowly  through fine grained silts
and clays,  it is mineralized due to the proximity of the brackish
river and the  use  of  river and creek bed sediments for fill. No
potential exists for using shallow groundwaters for potable sup-
plies, since dissolved solid levels naturally exceed USEPA drinking
water standards. The  deep potable aquifer is artesian and is sep-
arated from the shallow aquifer by 200 ft of relatively impermeable
calcareous clay.
   From this initial' geologic  assessment  and waste characteriza-
tion, the landfill received  a relatively high CSRM score of 31. Thus,
the IAS team recommended  a  Confirmation Study to determine
the lateral migration  potential of contaminants. Specifically, the
program would evaluate subsurface stratigraphy, permeability, pie-
zometry and local groundwater quality.
   The groundwater monitoring  program was to be conducted in
two phases:  verification  and characterization.  The  verification
would consist of collecting one sample from each monitoring well
over the saturated  zone. The sampling parameters  selected were
based on suspect contaminants in the landfill: heavy metals, cya-
nides, oil and grease or petroleum hydrocarbons, PCBs and prior-
ity pollutant volatile organic compounds.
   If contaminants were present in well samples, then  further samp-
ling in the characterization phase was recommended to develop a
vertical profile of contaminant concentration and define contami-
nant migration paths.6
   In the Confirmation Study, 13 monitoring wells were installed at
different depths around the landfill perimeter. Data  collected dur-
ing well installation  confirmed previous  hydrogeologic  assess-
ments. The surficial  sediments had  a low  permeability and a
low hydraulic gradient. In addition, an  upward hydraulic gradi-
ent existed between the  deep aquifer and the  surficial deposits.
Initial sampling of the shallow aquifer showed a mineralized con-
tent with levels of dissolved solids above USEPA drinking water
standards.
   The chemical analyses of water samples collected from monitor-
ing wells along the  edge of the landfill detected the presence of low
levels of barium from  paint pigments and coatings, flouride, iron,
pentachlorphenol from wood preservatives, bis-2-ethylhexyl phtha-
late, chloroform, dibromochloromethane, chlorobenzene and vinyl
chloride.  Water from the upper calcareous  clay formation was
analyzed for volatile organic compounds; none were detected.''
  For the contaminants present in the shallow  groundwater, the
rates of migration toward the creek and river were calculated at 1 to
2 ft/yr. At these slow  rates, many of the contaminants would like-
ly be attentuated in the  soil  and would  never  reach the surface
waters. Those contaminants that might reach the creek or river
would end up in brackish mineralized waters subject to discharges
from heavy industry upstream.  In  other words, the  low levels  of
contaminants that might  reach the waters would not significantly
affect the existing water quality.
  Alternatives for preventing leachate migration considered, but
not recommended, included the installation of an impermeable bar-
rier around the landfill and the installation of a groundwater collec-
tion system around the landfill to intercept the leachate for treat-
ment. To date in the NACIP program, corrective measures such
as these have not been warranted because the Navy has found few
instances where contaminants contributed from abandoned land-
fills  are significantly  affecting the surface  water quality.  Conse-
quently, as at many sites investigated, no further action other than
continued monitoring was recommended.''
                         25       35
                        CSRM SCORES
                          Figure 4
                CSRM Score Range for PCB Sites
PCB Sites
  Other typical sites are those with possible polychlorinated bi-
phenyls (PCBs) contamination. An extremely stable compound,
PCBs are resistant to biodegradation and thermal destruction.12 As
a result, PCBs were widely used  in dielectric fluid until the late
1960s. Unfortunately PCBs, as a chlorinated  organic, are also
bioaccumulative and pose a potential threat to human health.12
  This case study involves a location with three PCBs sites; two
transformer leaks or spills dating to the mid-1960s and one trans-
former storage yard used  until 1976. These sites were discovered
during interviews with electrical shop personnel.
  The above sites were located in a coastal plain area on the sandy
soil of a peninsula adjacent to the ocean. Grab samples were taken
at these three sites during  the IAS on site visit. The two spills did
not show significant quantities of PCBs; however, the oily sludge
on the surface of the old transformer storage area had more than
70,000 ppm Archlor 1260,  as well as other PCBs  and chlorinated
hydrocarbons. Due  to this evidence of contamination, the storage
yard was recommended for a Confirmation Study."
  The PCBs storage yard was also ranked using the  CSRM. As
mentioned  before, this site is  located on the coast on sandy soil
and has a high groundwater table.  However, the corner of the stor-
age yard that  was used for transformer and capacitor storage  is
paved with asphalt. The entire storage area, currently used for sand
and gravel  storage for  road beds  and foundations, is fenced and
locked. The yard is fairly isolated, with only public works shops
nearby and no occupied buildings adjacent to the site. Because of
these factors, the CSRM score was a 26. PCBs sites uncovered dur-
ing lASs so far can be compared to each other as shown in figure 4.
                                                                                            REMEDIAL RESPONSE
                                                          329
-------
  In the case of this storage yard, the Engineering Field Division
and the naval base decided to go immediately to cleanup,  rather
than the further testing of a Confirmation Study. The asphalt area
was scraped and  all visible stains in the area were removed and
placed in drums. The area was then retested for PCBs and was
found to be uncontaminated to the limits required by regulations."
The three drums  of collected material were then sent to a  secure
landfill.
  This immediate cleanup action, while not necessarily typical of
PCBs sites, is typical of one of the three main types of action taken
at a potentially contaminated site uncovered during an IAS. Be-
cause of the simplicity of the proposed cleanup and the known exis-
tence of the  contaminant, the expense of a Confirmation  Study
may  be simply bypassed and  corrective  measures immediately
undertaken.  In other cases,  as at the following site, corrective
measures may be immediately started due to a potential health haz-
ard.
Blasting Grit Pile
  Another typical site at industrial naval bases contains spent blast-
ing grit. When ships or aircraft are overhauled, they must be
painted. Old paint is sandblasted off,  producing large quantities
of spent blasting grit  which contains paint particles. The grit itself
can be sand, glass beads,  metallic slags or walnut hulls.
  In  this case, the spent metallic slag grit was used to fill  a low
area behind a  Navy housing complex.  Thirteen years later, large
areas of grit were  still exposed and children played in the sand
piles. The site was located adjacent to a  creek  on clayey  sandy
soil.
  This  site was discovered on  the last day of the on site visit.
Samples of the grit were taken within the next week. Analyses of
these samples showed high concentrations of lead, copper and zinc.
However, the samples did pass the EP toxicity test and, thus, were
not classified as a hazardous waste. The concern here was the possi-
bility of the paint particles containing the heavy  metals becoming
airborne. The particles could then be inhaled and pose a potential
health hazard.  The paint particles and  grit could also be ingested
by children playing in the piles. Shortly after receiving results of
the sampling, the naval  base started cleanup, which consisted of
leveling the pile, covering with clean fill and seeding."
  This  immediate cleanup  is not necessarily typical of sandblast
grit  sites. In many cases the grit has already  been covered and,
as indicated  above,  is not considered a hazardous waste. This
site, then,  is typical of sites where corrective measures are immed-
iately undertaken due to a potential health hazard.
Discussion

  The four sites  discussed represent  typical sites found, and also
characterize the three most frequent courses of action taken, after
the IAS. A Confirmation Study of sampling  and  well monitor-
ing followed by corrective measures may be done, as was the case
with the POL sludge pit.
  In  other cases,  such  as the landfill, results  of a Confirma-
tion Study conclude  that, due to the low levels of contaminants
found and their minimal impact on  present surface and ground-
water quality,  no further action is required other than continued
monitoring. In the  third  case, corrective measures may be immed-
iately implemented due to cost, as at the PCB storage yard,  or due
to possible health  hazards,  as  at the  grit pile,  when a  surficial
sample has shown the presence of a specific contaminant.
CONCLUSIONS

  The three year  old  NACIP program continues to be a challenge
for the Navy scientists and engineers involved. One of the most
important, and hard to master, skills of site discovery is an effec-
tive interview technique. When effective interviewing is combined
with inspections of a site and information from  records searches,
the IAS team can determine the need for  further action  with the
help of the Confirmation Study Ranking System. Using the Con-
                                                         firmation Study Ranking Model scores, the Navy can then com-
                                                         pare sties studied and set funding priorities for further action.
                                                           A review  of completed  Confirmation Studies and Corrective
                                                         Measures  Studies  shows  further action  at sites  has  typically
                                                         followed one of three courses: extensive sampling  with restora-
                                                         tion or cleanup, extensive sampling  with no further action other
                                                         than continued monitoring and immediate cleanup.  As proven by
                                                         the case studies, the Navy  is prepared to expediently resolve any
                                                         serious contamination problems that may arise.
                                                           With the Installation Restoration Program, DOD  has shown in-
                                                         itiative in  searching for abandoned  hazardous  waste sites. The
                                                         Navy, in support of this program, developed expertise in the fields
                                                         of hydrogeology, biology, chemistry, toxicology and engineering as
                                                         shown by the design and use of the CSRM. By anticipating rather
                                                         than reacting to problems  associated with abandoned hazardous
                                                         waste sites, the Navy can propose sound engineering and cost effec-
                                                         tive solutions for these sites. In this way, the Navy will continue
                                                         to ensure the safety of naval base populations  and surrounding
                                                         communities.

                                                         ACKNOWLEDGEMENTS

                                                           The authors  thank their  colleague Dr. Richard  J. Watts for
                                                         his technical assistance with and critical review of this manuscript.

                                                         REFERENCES

                                                         1. Comprehensive Environmental Response, Compensation, and Liabil-
                                                            ity Act of 1980, Public Law 96-510, as amended.
                                                         2. Office of  the Chief of Naval Operations, Department of the Navy,
                                                            Environmental  Protection and  Natural Resources  Manual,  OP-
                                                            NAVINST 5091.1, 26 May 1983.
                                                         3. Collins, J.P.  and Luecker,  E.B.,  "Decision Strategies for Evaluating
                                                            Abandoned  Hazardous Waste Sites," Proc. Hazardous Materials
                                                            Management Conference, July 1983, in press.
                                                         4. National Fire Prevention Association, Fire Protection  Guide on Haz-
                                                            ardous Materials, seventh edition, 1979.
                                                         5. Sax,  N. Irving, Dangerous Properties of Industrial Materials, fifth
                                                            edition, Van Nostrand Rheinhold, New York, 1979.
                                                         6. Environmental Science and Engineering, Inc., Initial Assessment Study
                                                            of Naval Base Charleston, Charleston, S.C., NEESA-007, prepared
                                                            for Naval Energy  and Environmental Support Activity, Naval Facil-
                                                            ities Engineering Command, May 1983.
                                                         7. Connell, D.W. and Miller, G.J. "Petroleum Hydrocarbons in Aquatic
                                                            Ecosystems—Behavior and Effects  of Sublethal Concentrations,"
                                                            Critical Reviews In Environmental Control, 11, 1981, 37-105.
                                                         8. Gonsoulin, F. et  al.,  "Fate and Effects of Heavy  Fuel  Spills on
                                                            Georgia Salt Marsh," Marine Environmental Resources, 5, 1981,125.
                                                         9. Griffiths,  R.P. et al., "Long Term Effects of Crude  Oil on Uptake
                                                            and Respiration of Glucose and  Glutamate in Arctic and  Subarctic
                                                            Marine Sediments," AppliedEnvir. Micro. 42, 1981, 792.
                                                         10. Knapp, A.H. and Williams, P.J.,  "Experimental Studies to Determine
                                                            the Fate of Petroleum Hydrocarbons from Refinery  Effluent on an
                                                            Estuarine System," Environ. Sci. Tech., 16, 1982, 1.
                                                         11. Geraghty and Miller, Inc., Confirmation Study, Assessment of Poten-
                                                            tial Oil and Hazardous Waste Contamination of Soil and Ground
                                                            Water at Charleston Naval Shipyard, Charleston,  S. C., prepared for
                                                            Southern Division, Naval Facilities Engineering Command, Oct. 1982.
                                                         12. Lloyd, J.W. et al., "Polychlorinated Biphenyls,"  J. of Occupational
                                                            Medicine, 18, Feb. 1976.
                                                         13. Naval Energy and Environmental Support Activity, Naval Facilities
                                                            Engineering Command, Initial Assessment Study of Naval Air Station
                                                            Pensacola, Pensacola, Florida, NEESA 13-015, June 1983.
                                                         14. United  States Environmental  Protection Agency, 40  Consolidated
                                                            Federal Register  (CFR)  761, "Polychlorinated  'fiiphenyls  (PCBs)
                                                            Manufacturing, Processing, Distribution in Commerce and Use Pro-
                                                            hibitions," as amended.
                                                         15. Water and Air Research,  Inc., Initial Assessment Study of Norfolk
                                                            Naval Shipyard, Portsmouth, Virginia, NEESA, 13-010, prepared for
                                                            Naval Energy and Environmental Support Activity,  Naval Facilities
                                                            Engineering Command, March 1983.
330
REMEDIAL RESPONSE
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                  COAL TAR CONTAINMENT &  CLEANUP
                              PLATTSBURGH,  NEW YORK

                                         STEWART N. THOMPSON
                                      ANTHONY S. BURGESS, Ph.D.
                                         Acres American Incorporated
                                               Buffalo, New York
                                                DENNIS O'DEA
                                    New York State Electric & Gas Corp.
                                            Binghamton, New York
INTRODUCTION

  A gas generating plant was operated along the banks of the
Saranac River in the City of Plattsburgh, New York, from 1896 to
1960. Coal tar, a by-product of the gasification process, was inter-
mittently  disposed of in unlined ponds adjacent to the  river.
Throughout the years, the coal  tar has migrated through the
substrata resulting in periodic coal tar release into the river.
  Acres American Incorporated (Acres), Buffalo, New York, was
retained in 1979 to:
•Identify the extent of coal tar contamination
•Define the physical and chemical properties of the contaminant
•Define the mode of contaminant transport
•Define and assess the corrective remedial alternatives
•Perform final design
•Provide construction supervision and management
  The work was undertaken in a multi-phase approach from 1979
to 1982. In this paper, the authors discuss the site investigation,
remedial alternatives and final design and construction undertaken
at the site.
ASSESSMENT OF THE PROBLEM
Site Description
  The site covers an area of approximately 11 acres and lies within
the  City of Plattsburgh on the south bank of the Saranac River
(Figure 1). Topography  falls gently in steps from approximate
Elevation 125 to 130 ft Mean Sea Level (MSL) along the south edge
of the site  to 102 to 107 ft MSL along  the Saranac River banks.
Apart from a narrow band of trees and bushes adjacent to the
river, most of the site has been cleared and filled. A 24 in diameter
concrete sanitary sewer crosses the site with invert elevations bet-
ween 107.4 ft and 110.3 ft. An active transmission line owned by
the Plattsburgh Municipal Lighting District crosses the site along
the south bank of the river (Figure 1).
  After the decommissioning of the plant in  1960, the  coal tar
ponds were filled with random material and covered with layers of
cinders and ash. Large portions of the site to the west and  north
have been filled and regraded at various times during and post plant
operation.  No maps or  drawings could be found showing the
original site contours, nor  do  any records exist regarding the
amount and times of coal tar disposal into the unlined ponds.

Site Geology and Hydrology
  A total of 53 boreholes were drilled during a three-phase site in-
vestigation to define the site geology, hydrology and area of con-
                         Figure 1
                     General Site Plan

lamination (Figure  1).  All borings  were drilled vertically using
either a hollow stem auger or 4 in ID rotary drill with casing. Stan-
dard split-spoon samples  were continuously taken  in the uncon-
solidated overburden, with several borings drilled into the underly-
ing bedrock.  In addition,  three test pits were excavated on site to
obtain additional information regarding stratigraphy and to collect
bulk samples of the coal tar and soil for laboratory testing.
  Nineteen  standpipe  piezometers were  installed  in  selected
boreholes to monitor ground water levels across the site. In situ fall-
ing and constant head permeability tests were performed in selected
borings to define subsurface permeabilities.
  As a result of this investigation, three soil units were delineated.
From ground surface to bedrock they are:
•Sand and Fill
 Fill—dark brown to black cinders and ash  with traces of gravel,
 sand, coal, wood and brick fragment; medium dense to dense.
 Sand—medium brown to yellow brown; fine-grained with traces
 of salt and gravel; loose to medium dense.
•Sand and Gravel
 Dark brown to  black; fine-to-coarse-grained sand and gravel;
 loose to medium dense.
                                                                                           CASE HISTORIES
                                                      331
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•Till
 Medium gray silt and  fine sand with some medium-to-coarse-
 grained sand and gravel; extremely dense.
  The top of the till unit was readily identifiable during subsurface
drilling because of its extremely dense and impervious nature. Con-
tours of the top of the till layer are shown in Figure 2. Bedrock is a
dark gray to black, hard, competent,  fine-grained limestone.
                           Figure 2
                    Till Surface Contour Map

  Coal tar contamination was found over most of the site. Con-
tours of the maximum elevation of coal tar are shown in Figure 3
with a plot of equal thickness (isopachs) of contaminated soils
shown in Figure 4. Maximum thickness of contaminated soils was
found to be 13 ft beneath the original coal tar ponds. The investiga-
tion indicated that the coal tar was more dense than the ground-
water and formed a separate phase.  The direction of coal tar move-
ment was controlled by the dense impermeable (
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LEOEN.,

t::X?\ FINE SANO AND FILL •£• OKOUMMATEII LEVEL

[23 5*NI> •"• OUAVEL  -4£- mvra LEVEL
                                               .. COAL TA> m«>  ^
          HORIZONTAL SCALE
                       0	«0    >0 FEET
                                                                                                                 124    NOTE . SECTION LOCATIONS
                                                                                                                           SHOWN ON FIGURE I.

                                                                 Figure 5
                                                   Geologic Sections, A-A, B-B and C-C
                            Figure 6
               Groundwater Surface Contour Map
                                                                       to dissolve the coal tar. The acetone was then boiled off leaving the
                                                                       coal tar fraction behind, from which the percentage of coal tar was
                                                                       determined. The second test  procedure employed using xylene for
                                                                       water extraction. Under this  procedure, the contaminated samples
                                                                       were mixed with xylene and heated. The water was then extracted
                                                                       and the weight of the remaining solids determined.
                                                                          These  tests showed that the  tar content (percent dry weight)
                                                                       ranged from 0% for an uncontaminated sample to a high of 9.6%,
                                                                       with an average content of approximately 1.5%. Water content for
                                                                       the same samples ranged from 4.9%  to 35.9% with an average of
                                                                       14%. These results show that the majority of contaminated soils on
                                                                       the site contain only about 1.5% coal tar by weight, which  means
                                                                       that the  soil is unsaturated with  respect to  coal tar. To further
                                                                       quantify this finding, a series of laboratory model tests were under-
                                                                       taken to simulate the sequence of events that has taken place at the
                                                                       site. These events involved:
                                                                       •Pre-coal tar disposal  with a groundwater saturated strata
                                                                       •Displacement of all, or part of, the groundwater by coal tar with
                                                                         simulated flow of coal tar through the  strata
                                                                       •Removal of the coal tar source and re-establishment of the natural
                                                                         groundwater flow
                                                                 Table 1
                                                     Chemical Analyses—Heavy Metals
Sample
                       Al
                                  Ba
                                             Ca   Cd
                                                        Cr
                                                             Cu    Fe
                                                                                  Mg   (1n    Na   HI     Pb    Sb
                                                                                                                Se
  Stage I  Total Lcachaole Salts In Tar/SotT Samples


                   0.07   0.9    3    <0.3   <0.05   27   <0.05    0.12  0.2   0.4   <0.04   6.3   3.9  0.3  6.7   0.15    0.9  <0.4   <0.5
  BH-6 SSI9
  16.0' - 18.0'
  BII-8 SSI6
  10.0' -11.0'      0.07   0.7   2    <0.3   <0.05   27   <0.05    0.3   0.3   0.4   <0.04   8.4   3.4  0.7   6.3  0.1    1.0  <0.4   <0. 5
                                                                                                                       <1.0


                                                                                                                       <1.0
Stage II Total teachable Salts In Coal Tar

  Tar of BH-6      <0.04  <0. 5   <0. 5  <0. 3   <0.05
  Tar of BII-8      <0.04  <0.5   <0.5  <0.3   <0.05

  River Tar         0.06  <0. 5   <0. 5  <0. 3   <0.05    8   <0.05   <0. 1
                                                 <0.05   <0. 1  <0.05  0.2  <0.04   1.0   3.0  1.2  4.5  0.1

                                                 <0.05   <0.1  <0.05  0.2  <0.04   3.0   3.2  1.0  4.5  0.1
Stage 111 Total Salts In Coal Tar

 Tar of BH-6       0.6    25    1.0   <0.3   0.1

 Tar of DH-8       0.8    15    1.0   <0.3   0.1

 River Tar         1.3    30    4    <0.3   0.2
44   <0.05   5.0

67   <0.05   7.0

70   <0.05  12.0
0.1   0.3  <0.04   3.0   2.4  1.1   3.6  0.15




1.2    5   <0.04   2.0   7.0  7.5   5.0  6.0

0.7    7   <0.04   3.5   8.0  6.6   5.0  3.7

5.0    2   <0.04   3.0   7.0  4.5   4.0  5.3
<0.2  <0.4

<0.2  <0.4

 0.4  <0.4




 2.0  <0.4

 2.9  <0.4

 2.0  <0.4
                                                                                                                  <0. 5

                                                                                                                  <0.5

                                                                                                                  <0. 5




                                                                                                                   2.0

                                                                                                                   2.5

                                                                                                                   3.0
                                                                                                                     <1.0

                                                                                                                     <1.0

                                                                                                                     <1.0
<2.0  <1.0   0.3


<2.0  <1.0   0.2




<2.0  <1.0   1.0

<2.0  <1.0   0.4

<2.0  <1.0   0.4




<2.0  <1.0   31

<2.0  <1.0   i;

<2.0  <1.0   14
HOTE:  ALL RESULTS ARE GIVEN AS HICROCRAHS PER CRAM IT MATERIAL TESTED
                                                                                                             CASE HISTORIES
                                                                                                                                          333
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                                                            Table 2
                                               Chemical Analyses—Salt and Organics

SAMPLE pH Cl CN KJL-N NH3-N N03-N PHENOLS SULFIDE COD TOC Si 02
Stage I Total Leachable Salts
BH-6 SS »9 7.4 17.3 <1 0
16.0'-18.0'
BH-8 SS*6 7.8 20.0 <1 0
lO.O'-ll.O'
Stage II Total Leachable Salts
TAR of 4.5 — <1 <0
BH-6
TAR of 4.5 — <1 <0
BH-8
TAR from 4.6 34.4 <1 0
river
Stage III Total Salts in Coal
TAR — -- <1 0
BH-6
TAR -- - <1 0
BH-8
TAR from -- 34.4 <1 1
river
NOTE: ALL RESULTS ARE GIVEN AS

DRY
SAMPLE DESCRIPTION DENSITY
(PCF)
Compaction Test #1 127.7
(composite sample
of sand/gravel )
Perm/Retention Test »1 130.7
(composite sample
of sand/gravel )
Perm/Retention Test 12 118.1
(sand/gravel/tar
from Test Pit 79-T1 )
Compaction Test 12 129.9
(clean sand/gravel
from Test Pit 79-T3)
Perm/Retention Test 13 130.4
in Tar/soil Samples
.5 <0.1 10 0.3 <0.1 627 206 15
.4 <0.1 13 0.15 <0.1 870 310 12
in Coal Tar
.1 <0.1 <5 0.17 <0.1 2490 900
.1 <0.1 <5 0.13 <0.4 2460 850
.3 <0.1 <5 4.0 <0.1 2650 935
Tar
.4 -- <5 15
.4 -- 
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                            Table 4
                     Coal Tar Retention Tests
Sample   Sample
No.     Description

1        Composite sample of
        sand/gravel from
        split spoon
        sample

2       Sand/gravel sample
        w/coal tar from
        Test Pit 79-T1
                            Coal Tar
                            Retained


                            1.38
Water
Retained
                                                Remarks
                                      8.35       Sample Hushed
                                                w/water under
                                                slight head &
                                                allowed to drain.

                            1.96       9.7        (Prior to testing)
                            5.9        7.6        Sample taken
                                                after completion of
                                                Permeability Test
                                                w/coal tar. Not
                                                flushed or allowed
                                                to drain.

 3       Clean sand/gravel      1.29       8.74       Sample Hushed
         from Test Pit                             w/water under
         79-T3                                   slight head &
                                                allowed to drain.
 NOTE: All retention tests were run on samples immediately following completion of Permeability
 Tests with coal tar.
perties allowed the tar to migrate as an independent phase to the
groundwater regime. With continued disposal, the coal tar moved
relatively rapidly down gradient along the top of the impervious till
layer into the river. Once dumping stopped, the rate of migration
gradually  decreased.
   It is believed that the majority of coal tar presently on site is prin-
cipally being retained within the pores and matrix structure of the
soil grains, and that the mechanism causing the tar migration today
is different from that when the ponds were in operation. Although
difficult to quantify, the mechanism causing tar migration today is
most likely influenced by one or more factors, including seasonal
groundwater fluctuations causing changes in pore water pressure,
increased  ground  and groundwater temperature during  summer
causing the tar to become more  mobile due to decreased  surface
tension and viscosity and increased river flow causing a flushing of
the contaminants from the soil.
ALTERNATIVE REMEDIAL SCHEMES

   Using the principal criteria that all further coal tar contamination
into the Saranac.River must be stopped, eight alternative remedial
concepts were evaluated. These included:
1. Excavation and replacement of contaminated  soil.
2. On-site isolation  of contaminated  soil by slurry walls,  sheet
   piping, etc.
3. Grouting of soils and consolidation of contaminated materials
   in place.
4. Interception and treatment of coal tar  plume.
5. Chemical immobilization of contaminated  soils.
6. Biodegradation of coal tar.
7. Tertiary injection wells and recovery of coal tar.
8. Rerouting of the Saranac River.
   Each alternative was evaluated  for  its technical  feasibility,
method of implementation, impacts and costs. Those alternatives
that were considered technically unsuitable, or were beyond the ex-
isting state-of-the-art, were eliminated from further consideration.
Of the eight alternatives, 1, 2 and 4 appeared the  most viable. The
excessive costs  and problems associated with alternative  1  and 4
made the concept of on-site isolation the most acceptable for fur-
ther  consideration.
ALTERNATIVE SELECTION & FINAL DESIGN
  A  number  of  alternative  on-site  isolation concepts  were
evaluated. The various design alternatives had to take into con-
sideration  multi-land-ownership, underground and surface utilities
and contaminated  riverbed sediments.  Working closely in associa-
tion  with the New  York State Department of Environmental Con-
servation (NYSDEC), a list of design criteria was developed. These
were:
•Elimination of all further coal tar contamination into the river
•Insurance of the long-term integrity of the remedial method
  In addition to the above criteria, a list of desirable attributes were
addressed in the alternative evaluation. These included:
•Minimal cost
•No discharge of contaminants from the site during construction
•Potential future use of site
•Minimize long-term maintenance
  Based on  the  above, a total of 4 on-site isolation concepts were
developed. These were:
   Construction of a single cut-off wall along the riverbank
2. Complete isolation of the main ponds with the construction of
   slurry wall and impervious cap in addition to the construction
   of a cut-off wall along the river
3. Alternative 2 with the addition of river cleanup
4. Total site isolation by the construction of a slurry wall and im-
   pervious cap
  The advantages, disadvantages and costs of each of the alter-
natives were carefully evaluated and presented to the NYSDEC and
property owners. It was agreed that Alternative 3, Isolation of the
main ponds and construction of a cut-off wall along the river with
excavation and replacement of the most contaminated riverbank
and bed material, best met the criteria.
  Due to the delays in obtaining contracts and access, the work was
done in two construction seasons. Phase I, undertaken in the fall of
1981, involved the installation of 735 ft of a soil bentonite slurry
wall  around the main pond area and capping it with a temporary
20-mil polyvinyl  chloride (PVC) liner (Figures 7 and 8).  It  was
estimated that approximately 80% of the on-site coal tar was en-
capsulated within this cell,  The wall was keyed into the underlying
dense impervious till. Slurry wall depths ranged from 13 to 20 ft. A
well was placed within the cell to monitor the effectiveness of isola-
tion.
       ®
                                      / EXIST.  ..  ; I
                                  •   i /SUB-srArioN  '
                           Figure 7
                      Phase I Construction
                                                                                                    CASE HISTORIES
                                                          335
-------
                       t „.-
                                                           ^
                  IE«*0

                  P•~~.  [j  SAKO AND CRUSHCD STOMt


                  | "i#>'-J  COMTAMINATED S


                                                              •nu.


                                                              CLAY
                                                                                     *- MOUMMUTn LIVCL

                                                                                     -^- MfVCJt LCVCL
                                                                                    MQMBMTM.  SCALE
                                                                                                0    15    3OFECT
                                                             Figure 10
                                                  Section A-A, Phase II Construction
336
CASE HISTORIES
-------
  To  prevent groundwater buildup that could result in uncon-
trolled breaching of the wall, a groundwater collection system con-
sisting of 6-in. perforated drain pipe was placed 2 ft below and 10 ft
upgradient  of the  cement-bentonite slurry wall. The drain pipe
discharges into a precast manhole. A discharge line was cut through
the cement  bentonite to the river (Figure 9).
  Finally, a soil bentonite cut-off wall was placed around the re-
mainder of the spoils material. The spoils were graded and capped
with a permanent 36 mil Hypalon liner. The liner was covered with
6 in. of sand, topsoiled and seeded. Site work was completed in
September  1982.

POST CONSTRUCTION MONITORING
& SITE RESTRICTIONS

  A groundwater and river monitoring program was implemented
to supplement river water quality studies being performed by  the
NYSDEC.  Samples were obtained monthly and analyzed by an in-
dependent certified laboratory for total phenols and naphthalene.
Both of these compounds were identified during the initial site in-
vestigation  (see  Tables 1 and 2). Under expected field conditions,
phenols would show the behavior of compounds soluble in water
and naphthalene the response of those lighter fractions of coal tar
that are immiscible in water.
  During the initial nine months of monitoring, all 28 samples ob-
tained upstream and downstream of the rehabilitated river bed and
bank  sections showed no measurable concentrations of phenols or
naphthalene (
-------
                   EMERGENCY REMOVAL ACTION AT THE
                   BANKRUPT CRYSTAL CHEMICAL PLANT
                                        HOUSTON,  TEXAS

                                           E. WALLACE COOPER
                                   U.S. Environmental Protection Agency
                                         Emergency Response Branch
                                                  Dallas, Texas
LOCATION AND PHYSICAL DESCRIPTION

  The Crystal Chemical Plant is located on a five-acre tract in ex-
treme western Houston adjacent to Westchase, a fast growing
development of multistory office buildings and shopping centers.
The plant was constructed in 1968 and started producing  mono-
sodium methylarsenate (MSMA) and  disodium  methylarsenate
(DSMA). Arsenic trioxide (ASjOj), one of the most toxic forms of
arsenic, was the chief component in these herbicides. The site is
adjacent to a major flood control drainage ditch which empties into
Brays Bayou. Brays Bayou flows in an easterly direction through
the city of Houston and has its  confluence with the Houston Ship
Channel in the Port of Houston.
  When the plant was constructed, it was in a rather remote area;
however, urban growth has  reached and surrounded the  site. A
pipe company and lumber yard are located to the north and east,
respectively. A private elementary school is located one block to the
south, a large apartment complex one block northwest and a resi-
dential area two blocks southwest. Several large office buildings
have been constructed recently about one-half mile northeast of the
site.

INITIAL SITUATION

  Operations at the plant were  conducted with little or no regard
for maintenance, safety and environmental protection. Spills inside
and outside the  build;ngs, holes in the roofs of buildings and gen-
erally i-eavy rainfall'  -ised the entire site to become contaminated
withari.ji;;.
  The Texas Ueparuntnt of  Water Resources (TDWR) had mon-
itored the plant for several years. After  determining that  any re-
lease from the site was hazardous, due to the high  arsenic concen-
tration, they issued a "No Discharge Order"  for the entire site.
Action taken  at the site as a result  of this order prevented large
quantities of arsenic laden rainfall runoff from leaving the site.
Crystal Cehmical Company constructed a dike around  the perim-
eter of the plant to contain all spills and precipitation. Three large
pits and several  sumps were constructed to hold the contaminated
liquid, and spray evaporation systems were installed in the pits to
help evaporate the liquid. Additionally, a gas-fired evaporator was
installed to increase the volume  that could be evaporated. Some of
the contaminated liquid was  periodically trucked  offsite and dis-
posed of by injection into a  State approved commercial injection
well.
  A flooded to semi-flooded  condition existed at the plant most of
the time. The floor of the process buildings was covered with 6 to
8 in. of contaminated liquid due to corrosion holes in the metal
                                                  roof. Removal and/or disposal of the contaminated liquid from
                                                  inside the buildings and the plant grounds was an ongoing prob-
                                                  lem for several years.
                                                    Efforts for site cleanup and compliance were being exerted by
                                                  USEPA, State  and county agencies. There was $112,000.00 in
                                                  USEPA penalties pending against the company.
                                                    Operations continued under adverse conditions until mid-Sept.
                                                  1981, when unusually heavy  rains  flooded the entire site  and
                                                  created a serious potential for  overflowing the dikes. At this time
                                                  the TDWR ordered  the company to remove the  contaminated
                                                  liquid to prevent an offsite discharge. The company responded by
                                                  saying it was beyond their financial capability to remove that much
                                                  liquid and subsequently filed for bankruptcy. As the State had no
                                                  emergency funds to cover the situation, the TDWR requested that
                                                  an emergency removal action be initiated by USEPA under Super-
                                                  fund.

                                                  RESPONSE ORGANIZATION
                                                    The USEPA initiated an emergency removal action on Sunday,
                                                  Sept. 20, 1981. A meeting was called at the site with the plant man-
                                                  ager, USEPA contractor, TDWR representative and USEPA On-
                                                  Scene Coordinator. The decision was made to dewater the site in
                                                  Phase I as the entire site was inundated with an estimated 1,000,000
                                                  gal of contaminated liquid  that would have to be removed before
                                                  any additional work could be undertaken.
                                                    Twenty 7,500 gal stainless steel tank trucks were obtained to
                                                  transport the liquid approximately 40 miles to a State approved in-
                                                  jection  well. On-site pumps and two rented pumps were positioned
                                                  so that  four transports could be loaded simultaneously. Liquid re-
                                                  moval operations were conducted on a  24-hour basis for seven
                                                  days. A total of 815,000 gal of  liquid was removed in that time
                                                  and it contained an average arsenic concentration of 20,000 mg/1.
                                                    After all liquid was removed from the site, it was found that most
                                                  of the area outside the buildings was covered with mud. In order to
                                                  determine what areas contained concrete,  it was necessary to probe
                                                  most of the site and  prepare a plat delineating the concrete from
                                                  the exposed soil. From the plat it was determined that approx-
                                                  imately one-half the site (2 Vi acres) was covered with concrete and
                                                  the remaining one-half consisted of pits, sumps and exposed soil.
                                                    Next, it was decided that Phase II would consist of removing one
                                                  foot of the contaminated top soil from the exposed areas to use to
                                                  backfill the pits and sumps. When this was accomplished, the sur-
                                                  face would be leveled and covered with a sheet of six-mil  plastic.
                                                  This was to be covered with 6 to  12 in. of clean clay to be brought
                                                  on site. This clay cap would be graded  for proper drainage and
338
CASE HISTORIES
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seeded for erosion control. Work commenced on Phase II, Oct. 6,
1981.
  Periodic heavy rainfall continued to be a problem. Aside from
having to haul off many additional loads of contaminated liquid,
it made working conditions almost impossible at times. There were
no periods between rains adequate to dry the site. Heavy equip-
ment would bog down in the mud, and leveling and clay capping
were impossible. It was necessary to use powdered lime to dry and
stabilize the soil so the work could be accomplished. A total of 425
tons of lime was used during Phase II operations. This stabilized
the sludge in the pits as well as the muddy soil so it could be leveled
with heavy equipment and clay capped. Continued rain required
the building of dikes to keep the clean areas separated from the
contaminated areas.  Rain falling on  the clay capped  areas was
allowed to run  offsite, but that falling on the contaminated area
had to be contained and transported offsite for disposal.
  Three-fourths of the site was clay capped and Phase II was com-
pleted on Nov.  8, 1981. The southwest one-fourth of the site con-
tained the process buildings, process equipment and storage tanks,
all of which were contaminated. No work could be accomplished
in this area until the Trustee in Bankruptcy sold the equipment and
tanks, and they were removed. The equipment was sold in Feb.
1982,  removal operations commenced in May and were completed
in Sept.
  In August 1982, the Trustee in Bankruptcy entered into a con-
tract to have the seven metal buildings  removed from the site. This
work began in Sept. and was completed in Dec. During the removal
of equipment and buildings, some of the clay capped area was dam-
aged and had to be reworked. After the last building was removed,
the southwest one-fourth of the site was stabilized and clay capped,
and necessary repairs were made to other areas. Inclement weather
delayed work, and it was not until Feb. 20, 1983, that the final cap-
ping and grading were completed. A total of 1,700,000 gal of con-
taminated liquid was removed from the site.
PROBLEMS ENCOUNTERED
  A significant problem and delay occurred in conjunction with the
sale and removal of the equipment and buildings arranged by the
Trustee in Bankruptcy. The OSC  had no control over the timing
of third party operations arranged by the Trustee. This caused
numerous delays, considerable frustration and additional expense
in planning and scheduling work for USEPA contractors.

Process Buildings
  The general condition of the three process buildings presented a
critical problem prior to their dismantling. The metal roofs were
so corroded  and deteriorated that approximately 85-90% of  all
precipitation falling on the roofs ran inside the buildings. The water
became contaminated as soon as it fell on the floor and had to be
trucked away for disposal. It was determined that any roof repairs
that could be made at a modest cost would be very cost effective.
Considerable savings would result from decreasing the amount  of
contaminated water to be removed.
  The chief problem to overcome was  not the repairs, but how to
safely put workers on the roof to make the  repairs. None of the
metal  building contractors that wer? contacted would attempt the
repairs because  the roofs were so weak. Even the beams were cor-
roded to the point that some were broken.
  A system was devised using a safety  cable attached to the build-
ing corners of the tallest building  and stretched along the roof.
Workers wearing parachute harnesses with a safety line attached to
the cable could then get onto the roof. They also used a set of criss-
crossed boards to distribute the weight over a broad area. The large
holes and gutters were repaired, and this significantly reduced the
amount of rainfall entering the  buildings. This effort reduced the
number of truckloads of contaminated liquid to be removed and
resulted in a substantial cost saving.

Binary Chemical Reactions
  Possible binary reactions resulting from the mixing or spilling of
chemicals stored on-site presented a substantial threat to the health
and safety of the workers and  residents  in the immediate area.
Safety considerations commanded  the  highest priority and dic-
tated the removal of these chemicals prior to removing the tanks.
The chemicals were ranked  according to  the priority of their re-
moval, taking into account physical state (gases ranked first), po-
tential for binary reactions, toxicity and tank location. The follow-
ing list contains the chemicals found at the site listed in the priority
of removal:

Methyl  Chloride—gas,  stored as liquid under pressure.  Methyl
chloride will react with aluminum and other active metals (mg, K,
Na).  It will react  with  oxidizing materials (hydrogen, peroxide)
giving off phosgene (a very toxic gas). It may react with a  strong
acid, such as sulfuric. The methyl chloride is in the same section
of the plant as the storage for arsenic trioxide, sodium arsenite,
sodium hydroxide, sulfuric acid and hydrogen peroxide. Methyl
chloride is a dangerous gas and therefore ranked as the highest
priority.

Sulfur Dioxide—gas, stored  as liquid under pressure. It will react
with water or steam to form sulfurous acid. Sulfur dioxide is stored
near tanks of TEA, cacodylic acid, other suspected arsenic com-
pounds and rayon caustic. It is  a gas and therefore ranked very
high.

Sulfuric Acid—liquid, assumed 98% pure. Sulfuric acid can com-
bine with any arsenic compound, releasing arsine (a very toxic gas).
Contact with methyl chloride may liberate phosgene. Sulfuric acid
will react with sodium hydroxide or water in an exothermic reac-
tion.  Contact with active metals (zinc, iron, magnesium, etc.) will
generate explosive hydrogen. The acid tank is next to the hydrogen
peroxide tank and near the arsenic  trioxide, sodium arsenite and
sodium hydroxide. The sulfuric acid can combine with many chem-
icals stored nearby, releasing dangerous gases. This is ranked as the
third priority.

Hydrogen Peroxide—liquid,  oxidizing agent,  assumed  to  be at
least 90% HjC^. Contact with organic materials (diesel fuel) will
cause explosive oxidation reaction. Concentrated  hydrogen per-
oxide can explosively decompose, especially when it is  contami-
nated with metals or metal salts. It was located next to the sulfuric
acid tank and near the  tanks of: arsenic trioxide, sodium  arsen-
ite, sodium hydroxide and methyl chloride. Its potential for explo-
sive reactions ranked its as the next priority.

Toluene—liquid, will react with strong oxidizing agents (hydrogen
peroxide). It was located near the napthylamine storage. Toluene's
flammability gives it the next priority.

Beta-napthylamine—solid, is not dangerously reactive. It may re-
act with hydrogen peroxide or sulfuric acid. It was stored near the
toluene. It  is very toxic  and should be removed after the toluene
because of its high toxicity.

Diesel Fuel—liquid,  will react with hydrogen  peroxide.  It  was
located near the office building. The danger of fire gave removal of
diesel fuel the next priority.

Sodium Arsenite—solid, will react with sulfuric acid to produce
arsine gas. It will also react with sodium hydroxide. It was located
near arsenic trioxide, sodium hydroxide, methyl chloride, hydrogen
peroxide and sulfuric acid.
Arsenic Trioxide—solid, will react with sulfuric acid to produce
arsine gas. It will also react with sodium  hydroxide. It was located
near  the sodium arsenite, sodium hydroxide, methyl  chloride,
hydrogen peroxide and sulfuric acid.

Sodium Hydroxide—solid, may be stored as water solution.  It will
react  exothermally with acid or water. The storage tank was lo-
cated near the arsenic trioxide, sodium arsenate, methyl chloride,
sulfuric acid and hydrogen peroxide.  Its corrosiveness and reac-
tivity gave it the next priority.

Mono or Di-sodium Methane Arsenate-Cacodylic Acid—liquids,
arsenic compounds may react with sulfuric acid to produce arsine.
                                                                                                   CASE HISTORIES
                                                          339
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They  were contained  in numerous tanks located throughout the
facility.

Cyclohexanone—liquid. It is moderately flammable and will burn
when in contact with strong oxidents such as hydrogen peroxide. It
was stored near the napthylamine storage.

Triethanolamine (TEA)—liquid. It is slightly flammable and may
burn  in contact  with  hydrogen peroxide or sulfuric acid. It was
stored near the sulfur dioxide tank.

Dinitrophenol—liquid. Explosion hazard when heated. Moderately
flammable. It was stored inside Process Building C.

TANK AND EQUIPMENT REMOVAL

  All tank and equipment sold by the Bankruptcy Trustee had to
be decontaminated before removal from the site. Approximately
75 railcar and  truck  loads  of equipment were  hauled to other
plants, and about 25 truck loads of contaminated junk were hauled
to a state approved chemical landfill for disposal.
  As each area was cleared, it would be stabilized and clay capped.
Diversionary dikes would be constructed to separate the clean from
the contaminated areas.

DRAINAGE

  Accumulation of rainfall and site drainage was a serious prob-
lem. At first, there was no drainage  from the site because all ac-
cumulated liquid was contaminated and had to be trucked away.
As each area was clay capped,  runoff from that particular area
could  be  released, but it required diversionary structures to sep-
arate the  clean  from the contaminated areas and containment of
the contaminated liquid.
  Eventually, the entire site was capped with a clay cover overly-
ing a  sheet  of polyethylene.  The cap was graded to a low-angle
slope for drainage of precipitation. Approximately 60% of the site
drains toward the concrete driveway in the center of the site and
there was no outlet for this run-off except allowing it to exit the
property at the north  fence on the west side of the driveway. This
caused the run-off to move across the unpaved section of the access
road west of the gate and enter a roadside ditch on the north side.
It caused the road to be muddy and soft most of the time.
  On the east side of the entrance gate there is an inlet to a buried
storm drain,  but the concrete driveway blocks drainage in that di-
rection. Consideration was given to breaking a section of the drive-
way and  laying a drain pipe from the west side  to the east side
and  then  repairing the concrete drive. Upon closer investigation,
it was determined that the concrete was approximately 18 in. thick.
Breaking  out a trench would be a very  labor intensive undertak-
ing and would have the driveway closed for an undetermined time.
This  was not a desirable  solution  as equipment was being re-
moved and dump trucks were hauling in clay. Closing the drive-
way  for any extended time would virtually shut down the entire
operation.
  The OSC  had  knowledge  of  water jet equipment designed to
clean out storm sewers. This system  uses high pressure water jets
to dislodge sand and  trash  and flush it out of the pipe. A water-
jet device is secured to a flexible high pressure hose and inserted
into the line.  The device has two jets that point forward to dig into
the material, two jets  on the side (one on either side) at 90° angles
to serve as reamers to widen the opening, and four jets at the rear,
set at 45 ° angles. These rear jets flush the material back from the
digging operation and  out of the pipe; they also  furnish the force
to drive the device forward.
  The company was contacted to see  if the device would dig a tun-
nel under the concrete driveway, a distance of about 40 ft, so an 8
in. drain pipe could be inserted. The company representative said
the device was designed to work inside pipe and therefore the direc-
tion of digging could not be controlled as the device was mounted
on a flexible hose.
  It  was proposed to  the company that an 8 in. pipe be placed in
the ditch on the east side, by  the storm drain inlet. Then place the
                                                        west end of the 8 in. pipe against the soil underneath the driveway,
                                                        aim the pipe in the desired direction and let the jetting device dig
                                                        out the end of the pipe. It was further suggested that a  10 ft sec-
                                                        tion of rigid steel pipe be inserted between the jetting device and
                                                        the flexible hose. This rigid pipe would limit the amount of devia-
                                                        tion that the jetting device could take. This proposal was accepted
                                                        by the company and the next day work was commenced. As the
                                                        device would dig and ream a few inches, the 8 in. drain pipe was
                                                        forced into the tunnel. The excavated material was washed out the
                                                        east end of the pipe.
                                                          This system worked with few problems, and the 8 in. drain pipe
                                                        was installed under the driveway without closing it to traffic. This
                                                        pipe now carries all run-off from the ditch on the west side of the
                                                        driveway directly to the underground storm drain.

                                                        EROSION CONTROL
                                                        Establishing a Vegetation Cover

                                                          After the north half of the  site (about 2 acres) was capped and
                                                        proper drainage established, Bermuda grass was planted. Bermuda
                                                        was chosen because of the thick mat it forms on the surface and
                                                        the dense root system it develops to a depth of about 12 in.  Bulk
                                                        seed was  purchased  and applied with a small broadcast spreader.
                                                        Since the clay contained  very few nutrients, the area was fertil-
                                                        ized after the seed germinated.
                                                          In order to speed growth during the favorable growing season, it
                                                        was necessary to establish a watering system. The only water source
                                                        on site was a water well  on the south side of the property. On-
                                                        site material was  collected for water  lines. Steel pipe previously
                                                        used for steam lines and PVC pipe previously used  for overhead
                                                        electrical  conduit was fabricated into water lines. Faucets were in-
                                                        stalled along these lines and  the grass was watered  with garden
                                                        hoses and sprinklers. A good stand of Bermuda developed.

                                                        Gravel Berms

                                                          A major concern associated  with the integrity of the clay cap was
                                                        the control of erosion. The cap itself is essentially clay, and a veg-
                                                        etative growth has been established for two reasons. First, the vege-
                                                        tation will tend to prevent washouts or erosion on the surface and
                                                        secondly, the root system will help to hold the soil together and
                                                        prevent any trenches from forming. The site was graded to a gentle
                                                        slope in most areas so the runoff would be as uniform as possible
                                                        and prevent a large  volume of runoff from occurring at any one
                                                        place. A concrete curb runs along the south and  west sides of the
                                                        site at the fence  line and the clay  cap is slightly higher than the
                                                        curb. However, as the ground level of the site was built up higher
                                                        than surrounding ground, it created a steeper slope at the east and
                                                        north fence line and along the driveway inside the plant. To  min-
                                                        imize the possibility  of trenches forming along these steeper slopes
                                                        where the velocity of run-off would be increased, it was decided to
                                                        install gravel berms along the ridge where the slope is increased.
                                                          The berms were constructed by placing a mound of 1 '/i in. size
                                                        gravel about 18 in.  wide  and approximately 8 in. high along the
                                                        crest of the slope change. This would cause the run-off from the
                                                        broad gradual sloped area to accumulate behind the berm and de-
                                                        crease its  velocity significantly. Then, the run-off  would trickle
                                                        through the gravel over a wide area and migrate down the steeper
                                                        slope. Along the north and east fence, the run-off then leaves the
                                                        site. Along the driveway, the run-off would enter a drainage ditch
                                                        constructed along the west side of the driveway and enter a storm
                                                        drain just east of the north gate  and be carried directly to the large
                                                        drainage ditch.
                                                          The berm and drainage ditch  along the driveway and the benns
                                                        along the north and east fence were constructed in June 1982 and
                                                        worked  well during the remainder  of the emergency  removal
                                                        action.

                                                        REMOVAL OF ARSENIC TRIOXIDE

                                                          When the plant was operating, arsenic trioxide, in a dry-powder
                                                        form similar to wheat flour, was delivered in railroad hopper cars.
 340
CASE HISTORIES
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It was unloaded into an elevated storage tank with a capacity of
130,000 Ib. During the initial evaluation, the plant manager re-
ported  that the storage tank was empty. There  were,  however,
three hopper cars containing various amounts of arsenic trioxide,
and arrangements were made for them to be removed. At that time
it was thought that the only remaining pure arsenic trioxide on
site was that portion that had been spilled during normal unload-
ing operations.
  The storage tank was the last piece of equipment to be removed.
While making preparations for its removal, it was discovered that
the tank was 3/4 full (later determined to contain 99,000 Ib.) of
arsenic trioxide. The tank was owned by one of the equipment pur-
chasers, but the product was the property of the Bankruptcy Court.
The Trustee in Bankruptcy sold  the product to a metal process-
ing company, and arrangements were made for the cleanup con-
tractor to transfer it to  55-gal drums and deliver the drums to the
purchaser.
  This operation was evaluated as probably the  most difficult and
dangerous to be conducted. Not only was the handling of the ma-
terial dangerous, but the condition of the tank  was an unknown.
Several of the other tanks cracked or broke apart when they were
moved, and there was no reason to believe that this tank would not
be a problem. A large vibrator was attached to  the bottom of the
tank, and it would be necessary to use the vibrator to get the ma-
terial to flow out the bottom. An auger was attached to the vibra-
tor, and this would also have to  be used in the operation. As all
electric lines had already been removed, it was necessary to run
temporary lines to these two pieces of equipment. Both the vibrator
and auger were found to be in working condition.
   A flexible hose  was attached to  the end of the auger and run
through a hole in the  roof of the adjacent building. Inside the
building, a 16 ft x 16 ft room was constructed and covered with
plastic for dust control. The flexible hose delivered the product
through the roof of the room and  into 55  gal drums. A vacuum
truck was used to continuously pull air from the room and pass it
through bag filters. A total of 133  plastic-lined drums were filled
with arsenic trioxide. Each drum weighed  approximately  800 Ib.
The drums were placed on a roller platform before filling. When
filled, they were sealed and pushed outside the room on the rollers.
A forklift then moved each drum to another  building where  it
was washed off and then loaded onto a transport trailer outside the
building.
   All personnel involved in this operation were equipped with fully
encapsulated, Level A,  protective equipment. Before commencing
the transfer, all phases of the operation were checked, and a  com-
plete practice run was conducted. Aside from a preliminary prob-
lem of getting the product to flow  out of the tank, the operation
was a complete success.
   In the event the tank had ruptured or arsenic  trioxide  was
spilled  in any way, a fire truck was standing by.  It was  equipped
with a water cannon that could spray any  dust cloud that might
form.
   The  Harris County Pollution Control Department conducted a
continuous air monitoring survey throughout this operation. One
upwind and two downwind stations were used.  Chemical analyses
showed only background concentrations in these samples.
   All nearby businesses had been alerted for possible evacuation
in the event a  problem developed.  The operation was conducted
on a Friday, Saturday and Sunday. Since school officials decided
that it would not be feasible to evacuate 200 small children in case
of an emergency, the school was closed Friday.
   The  all-clear signal was given at approximately 3:30 p.m.  on
Sunday.

SAFETY AND COMMUNITY RELATIONS
   A safety plan and Community Relations Plan were prepared.
However, coordinating the work  and safety of several contractors
on scene at  one time proved to be a problem.  One equipment
purchaser had nine employees, a crane, a large fork-lift loader and
several trucks. The other equipment purchaser had ten employees,
a crane and several trucks on-site at the same  time. Additional
damage was done to  the  roofs of the process  buildings by the
cranes, and several clay capped areas were damaged by operating
equipment in the removal process. The  water lines were broken
several times  as were the safety showers and  eyewash fountains.
All these damages necessitated repairs at USEPA's expense.
  The purchaser of the metal buildings utilized as many as twelve
employees, two cranes and  several  trucks. He  would remove a
building, or parts of one or two buildings, and then not come back
for several days. Extended periods of ideal weather would elapse
with no activity, and when the crew returned, it was frequently at
a time of inclement weather.  Working under  these conditions
caused additional damage to the site and the delay created a need to
remove more contaminated water  after rains. After the OSC had
made numerous unsuccessful attempts to  get the purchaser to pur-
sue the removal of buildings in a prudent manner, it became neces-
sary  for the Bankruptcy Trustee to establish a cut-off date for this
operation.
  While dismantling  one of the process buildings, an employee
was using a cutting torch in an area where no fires were permitted.
Sparks and molten metal fragments ignited an  area saturated with
dinitrophenol. The ensuing fire created a large  plume of yellow
and black smoke. Houston police closed a major street due to poor
visibility and evacuated workers from a nearby construction site for
fear of toxic fumes. The Houston Fire Department responded with
more than adequate equipment; five firetrucks  and an ambulance.
This incident caused a serious community relations problem and
probably destroyed the goodwill that USEPA had established to
this point.
  However, in accordance with the Community Relations Plan, a
meeting was held with concerned  citizens,  media and parents  of
children attending the nearby  elementary  school. The  USEPA,
State and County representatives gave  explanations, answered
questions and assured those present that third party contractors
and their employees would be closely supervised. This event and
succeeding events caused the OSC to inform  the  purchaser and
his employees that any additional violations of safety and/or site
protection instructions would result in USEPA's obtaining a court
order for their removal from the site by a U.S. Marshal.
  This group completed their removal operation on Dec.  2, 1982,
but left a significant amount of trash which had to be removed
and disposed of at USEPA's expense.

CONCLUSIONS
  Much of the work was conducted on week-ends and days run-
ning longer than  eight hours.  Even though  this time  frame re-
quired paying labor time-and-one-half, it proved to be cost-effec-
tive in getting work accomplished  when working conditions were
good. As each area was clay capped, it reduced the amount  of
water to be hauled out after a  rain.  The clay  capping method of
covering was  effective in presenting  a discharge of contaminated
run-off.
  The use of lime to stabilize the sludge created an additional bene-
fit, as it converted some of the  arsenic to calcium arsenate, which
is less soluble in water.
  All work was completed on Feb. 20, 1983. The duration of the
removal was 519 days. USEPA work consisted  of 138 days (26.6%
of the time) while the balance of the time,  381 days (73.4%), was
consumed by waiting on  decisions  of the Bankruptcy  Trustee,
waiting on and monitoring third party contractors and delays
caused by inclement weather.
  The  total  expenditure   from Superfund for  this  project was
$761,798.53.  A cost-recovery action was filed by  USEPA in the
Bankruptcy Court to establish a primary claim  against the assets of
the bankrupt  estate. This issue was settled out  of court in favor of
USEPA.
  The  State has assumed the lead role in conducting a feasibility
study to determine what remedial action should be undertaken.
                                                                                                 CASE HISTORIES
                                                         341
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           THE  CASE STORY  OF THE BT-KEMI DUMPSITE

                                              PETER SOLYOM
                             Swedish Environmental Research Institutet (IVL)
                                             Stockholm, Sweden
INTRODUCTION
  Sweden's chemical industry is, in comparison with the United
States' chemical industry, rather small. The structure of it is, how-
ever, similar to that in the U.S. A number of the Swedish chem-
ical companies also have subsidiary companies in the U.S., and
some of them are not unknown in connection with hazardous waste
sites.
  Hazardous waste management in Sweden is regulated by a 1975
decree. The law defines hazardous waste and contains regulations
on the obligation for information, transport, final disposal and
export of hazardous wastes. Detailed regulations for application of
the law are issued by the Swedish Environmental Protection Board.
  The number of known hazardous waste disposal sites in Sweden
is limited. An inventory  of municipal waste disposal sites, with
specific regard to the  inclusion of hazardous wastes, is in pro-
gress. The BT-Kemi dumpsite is at present the only major clean-
up activity in Sweden.
                                                  DESCRIPTION OF BT-KEMI

                                                    BT-Kemi was a chemical company which produced herbicides,
                                                  mainly phenoxy acids, involving chlorination and condensation re-
                                                  actions of phenol and cresol. Production took place from 1965 to
                                                  1977 in a former sugar mill in southern Sweden. The wastewater
                                                  from the production was, for a number of years, collected in hold-
                                                  ing ponds on the mill area. Some of the solid wastes from produc-
                                                  tion were buried, as  the company claimed, after "careful purifi-
                                                  cation", in the same area. As the factory did not have any dis-
                                                  charge, the company claimed that  biological degradation took
                                                  place in the holding ponds and evaporation from the ponds kept
                                                  the water in balance.
                                                    Very soon after the start of production, signs of pollution were
                                                  observed.
                                                    In the fall of 1975, about 200 drums were excavated. The chem-
                                                  ical analysis of their contents revealed high concentrations of chlor-
                                                  ophenols  and phenoxy acids. During  the summer of 1977 more
                                                      Figure 1
                                                  The BT-Kemi Area
342
CASE HISTORIES
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drums were dug up. A total of about 600 drums, many degraded
by corrosion and leaking into the ground, was found. Investiga-
tions by the Swedish Environmental Protection Board showed that
highly polluted water was being discharged into the nearby river at
the same time.
  As a consequence of disobedience of environmental legislation,
the presence of highly toxic chemicals  (for example di-nitro-sec-
butyl phenol, DNBP, in addition to the above mentioned chem-
icals) and the suspicion of the presence of 2,3,7,8-TCDD, the fac-
tory was closed down by the authorities.
  At this time, the responsibility for the cleanup of the BT-Kemi
area was taken over  by the County Administration. The Admin-
istration commissioned the Swedish Environmental Research In-
stitute (IVL) to investigate:
•Measures against contamination of groundwater and the river
•Contamination of wastewater in the holding ponds
•Contaminated soil
•Highly contaminated wastes stored in drums and tanks
•Residual chemicals in the factory
•Contamination of factory building and processing equipment
  The investigations  should result in recommendations for meas-
ures against pollution,  recommendations for destruction  tech-
niques for different wastes, information about  the quantities of
different wastes and cost assessment  for  technically feasible
destruction alternatives.

INVESTIGATIONS
Risk Assessment
  The site plan of the area is shown in Figure 1. The area is about
100,000 m2 and is divided by a railway.
  The factory building, holding tanks for chemicals, etc., are on
the southern part. The holding ponds and the dumpsite are on the
northern part.  The area is  bordered by a small river.  Numerous
sewers and pipes of  varying dimensions and quality were found
beneath the factory area. A risk  assessment of health and environ-
mental effects was performed.
  One hundred seven wells, selected by the health authorities and
located in the vicinity of the BT-area and along the river down-
stream of the area, were sampled and analyzed. The choice of the
wells was in many cases based  on geographical and topographic
conditions, but public concern and fear had to be considered.
  The  samples were analyzed for phenoxy acids,  chlorophenols
and cresols and DNBP. The determinations were carried out by
means of gas chromatography (GC). Six different phenoxy acids
(including 2,4-D and 2,4,5-T), five chlorinated  phenols (di, tri-,
tetra- and pentachlorophenols) and DNBP were determined with a
sensitivity of 0.01 to 0.2 jig/1, depending on the determined chem-
ical. Ten of the 107  wells showed contamination by some of the
chemicals occurring at BT-Kemi. Only four wells were directly in-
fluenced by the contaminated river. The level of contamination was
in the range of 0.2 to 3 jtg/1.
   According to the  evaluation  of medical and lexicological ex-
pertise, this degree  of contamination did not pose any risk to
public health. Moreover, a health investigation of the inhabitants
near BT-Kemi, conducted by the County Administration, did not
detect symptoms attributable to the activities of BT-Kemi. Never-
theless, secondary effects, such as social and psychological effects,
were notable.
  The risk assessment from the  environmental viewpoint was per-
formed by chemical  analysis of river water  both up and down-
stream of the dumpsite.  The river was sampled at four points up-
stream and four points downstream of the area.
  The chemical analysis showed an increase of the phenoxy acid
content by a factor of 5 to 25 depending on the rainfall in the area.
The increased concentration of herbicides caused serious damage to
market gardens downstream of BT-Kemi  where river water was
used for irrigation.
  It was shown that the dumpsite and the piping beneath the area
were leaking contaminants into the river.
Protection of the River
  In order to establish the conditions at the dumpsite relative to
the content,  amount, extension and migration of contaminants,
geological, hydrogeological and chemical investigations were per-
formed.
  The geological investigation included determination of soil struc-
ture by screw drill sampling at 140 bore holes down to firm clay
(2-12 m) and separation of different  types of earth layers. About
250  earth  samples were  collected  for  chemical analysis. The
position of firm clay between the bore holes was determined by a
refractometric seismological method.
  The hydrogeological study,  conducted by observation of the
movement of the groundwater table in 33 pipes, showed the exis-
tence of four aquifers in  the area depending on the presence of
different earth layers with varied high  and low permeabilities.
Chemical analysis of the groundwater revealed that the two upper
aquifers were contaminated.
  From the combined results  of the geological, hydrogeological
and chemical investigations, it could be concluded, that:
•Wastes were deposited in three main areas
•The area contained  about  150,000 m3  of earth with contam-
 ination  ranging from 0 to more than  500 ppm phenoxy  acids,
 chlorophenols and DNBP from the surface to between 2 to 6 m in
 depth
•The maximum seepage rate from the area was 7.5 mVhr
•The area had to be shielded in order to protect the river
  These conclusions led to the immediate  construction of sunken
wells, a drainage  system around the  area, collection of drainage
water in holding ponds, a bentonite shield outside of the drainage
system and a safety dike toward the river.
  The bentonite shield was constructed down to firm clay by us-
ing two different techniques. The  shield along the river and  at the
west side of the dumpsite was placed by first excavating a slit  about
0.6 m wide.  The slit  was  filled continuously during the  excava-
tion with a  10%  bentonite slurry in order  to protect it  from
collapse. Finally,  the  slit was filled with a mixture of bentonite,
sand and water.
  Toward the east, the shield was constructed by injection of a
15% bentonite slurry through a number of perforated pipes  at the
same time. The separate injections formed an interconnected, tight
shield down to firm clay.
  The contamination of the river by leakage from  the dumpsite
ceased after the completion of the described measures.

The Treatment of Drainage Water
  The drainage water, which  at  this stage was collected  in  the
holding pond, consisted of leachate from the deposited wastes and
other liquid wastes pumped to  the pond from different parts  of
the factory.  As the BT-company  installed, while still in produc-
tion, an  activated  carbon (AC) treatment plant, it  was obvious
that it should be further tested for treatment purposes.
  Although different treatment alternatives, such as chemical floc-
culation, extraction with solvents, direct  biological treatment, etc.
were tested under laboratory conditions,  the AC-treatment proved
to be the most successful.
  The efficiency of the AC-treatment was very high.  The con-
centrations of 190 mg/1 of phenoxy acids and  12  mg/1 chloro-
phenols were reduced on an average to less than 0.1 and 0.01  mg/1.
Seven tons of activated carbon eliminated  1 ton of phenoxy acids
and  chlorophenols. The costs  of  the AC-treatment  amounted to
about 2.20/m3 pounds of drainage water.
  However, the treated water still contained organic matter  which
measured as 200 mg/1 BOD. The treated  water was, therefore, dis-
charged to a municipal biological treatment plant  prior to  dis-
charge to receiving water.

The Treatment of Wastes
  The wastes in the area consisted of liquid and solid wastes from
the factory and contaminated  earth from  the dumpsite. As men-
                                                                                                  CASE HISTORIES
                                                          343
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tioned previously, certain liquid wastes with lower concentrations
of phenoxy acids and chlorophenols  (less than  500 mg/1) were
either pumped to the holding pond at  the dumpsite or directly to
the AC-plant.
  Destruction of the more concentrated liquid wastes by incinera-
tion in a cement kiln was tried. The incineration was successful and
the costs were calculated to be about $100 per ton.
  The  destruction of solid  wastes, including the contaminated
earth, was more complicated. Possibilities of composting, inciner-
ation and leaching were investigated.
  Composting was tested under laboratory conditions. In order to
obtain satisfactory results, the waste had te be mixed   with bark
and  digested municipal sludge in the proportion of 1:1:0.5  (by
volume). Eighty to  ninety <7o removal of the  chemicals, with  the
exception of 2,4,5-tri-chlorophenol, was  achieved after about 1
month.
  The most suitable composting technique was performed in aer-
ated strings with suction of the air.  The exhaust air  had to be
treated in  a humic filter  in order to  avoid odor problems.  The
costs ot the composting were  estimated to be about $10 per  ton
of waste.
  The incineration of solid wastes was not possible in Sweden at
that time (1978). The investigation showed, however, that existing
cement kilns could  be supplemented with a pre-kiln operated at
low  temperature, 400-500°C, for volatilization of the chlorinated
substances from the solid wastes. The volatilized gases would be
incinerated in the cement kiln. This alternative was never utilized.
   Incineration facilities were available abroad (France,  Germany,
U.K.)  and the destruction costs were given at that time (1978) as
about $250 per ton waste.
   The possibility of leaching the contaminants from the earth  and
solid waste was  evaluated using data from the previous geological
and hydrogeological investigations and laboratory tests  conducted
with contaminated earth with varying permeabilities. The findings
showed that phenoxy acids and chlorophenols  were leachable. The
best results were obtained by forced leaching  through an infiltra-
tion ditch. If performed,  the leachate would  be  directed through
the drainage system and treated by activated carbon adsorption.

SUGGESTED CLEANUP ALTERNATIVES

   The purpose  of the cleanup was to remove the contamination
from the area. Based on the  results of the investigations, the clean-
up would  preferably  be performed by leaching  of the contam-
inants and by AC-treatment of the leachates. The AC-treatment
would continue until the concentration  of contaminants  in  the
drainage water decreased to  less than 0.5 mg/1, the limit set by the
authorities. After that period, the drainage water would be  dis-
charged directly to biological treatment.
   The wastes on the  dumpsite could  roughly be divided in three
groups, based on the degree of contamination:
 1. Low contamination (less than 50 ppm), about 130,000 m3
2. Medium contamination (50-500 ppm), about 15,000 m3
3. High contamination (more than 500 ppm); about 2,000 m3
   Eight theoretically possible cleanup alternatives were considered.
All included natural and forced leaching and some kind of special
treatment of medium and highly contaminated wastes.  Only three
of the alternatives were realistic regarding time and cost aspects.
These alternatives are  given in table 1:
                            Table 1
                      Cleanup Alternatives
Alternative Waste group Duration, Cost, million
1 2 3 years USS
Forced leaching -•-( + ) 5-6
Forced leaching + + 3
composing + +
Forced leaching •+• + 3
composting +
incineration +
2.5
2.5

3.5


                                                        The County Administration chose forced leaching as the most
                                                      suitable alternative because of the risk of smell with composting.
                                                      Additional suggestions included the transfer of certain wastes, for
                                                      instance parts of the deposition on the factory site and the remains
                                                      of the demolished factory (about 2,800 tons), to the dumpsite. The
                                                      cleanup of the BT-dumpsite was  authorized by the Swedish Gov-
                                                      ernment in June 1978 and started immediately.

                                                      CLEANUP ACTIVITIES 1978-1983
                                                        Since 1978, the dumpsite has been treated through forced leach-
                                                      ing and the drainage water purified by AC-adsorption. The leach-
                                                      ing  was performed with AC-treated drainage water and some-
                                                      times with some additional river water. During heavy rainfall, when
                                                      the holding capacity of the pond  was not sufficient, surplus quan-
                                                      tities of purified water were discharged into the municipal sewer.
                                                      The recirculation of water was high, but an average of 50,000 m!
                                                      per year had to be discharged.
                                                        Since 1978, about 5 to 6 tons  of phenoxy acids and 0.5 to 0.6
                                                      tons of chlorinated phenols have been  removed from the dump-
                                                      site  by leaching and AC-treatment. The efficiency of the AC-treat-
                                                      ment was controlled by chemical analysis of weekly composite
                                                      samples.  The efficiency  and adsorption capacity of the activated
                                                      carbon was approximately  the same as during the test period in
                                                      1977. As  the AC-plant and the activated carbon were leased from
                                                      Chemviron Corp.,  the activated carbon was replaced every fourth
                                                      month. Each  exhausted activated carbon  batch  (about  9 tons)
                                                      was sampled and analyzed  especially for TCDD  before shipment
                                                      for regeneration.
                                                        The TCDD content was always under detection limit. The regen-
                                                      eration was performed in the U.K. About 110 tons of activated car-
                                                      bon were used until the AC-treatment was stopped in Nov. 1982.
                                                        The AC-treatment of  drainage water was run without problems
                                                      during the first two years.  Increasing pressure drops through the
                                                      AC units, which consisted of a sand  filter and two carbon filters
                                                      in series,  were observed  in spite of normal  back flushing routines.
                                                      The main part of the clogging  was located  in  the  first carbon
                                                      filter.
                                                        Microbiological  investigations  showed a  massive growth of bac-
                                                      teria. Bacteria were absent during the  first two years because of
                                                      the high toxicity of the drainage  water. The isolated bacteria from
                                                      the carbon filter were capable of metabolizing phenoxy acids and
                                                      chlorophenols.
                                                        In September 1981, the organic content of the drainage water
                                                      was about 10 mg/1. The direct discharge limit of 0.5 mg/1 had not
                                                      been achieved. The treatability of the drainage water without AC-
                                                      treatment was stopped. The direct discharge of untreated water
                                                      did not influence the  efficiency  of the biological treatment plant
                                                      since the hazardous waste  site flow only comprised 1 to 2% of the
                                                      total flow.
                                                        In Nov.  1982, when the AC-treatment was finally stopped, the
                                                      organic content of the drainage water was approximately 0.9 mg/1.
                                                      The municipality which  operates  the biological treatment plant and
                                                      is responsible for  the sewer,  charges  the  County Administration
                                                      $1.20 m! for treating the  drainage water.  This amounts to about
                                                      $60,000 per year. The County Administration commissioned IVL
                                                      to investigate the possibility of directly discharging the untreated
                                                      drainage water to the river, which is the  natural recipient of the
                                                      dumpsite area.
                                                        These  investigations  included tests of biodegradability, bio-
                                                      accumulation, acute and subacute toxicity toward aquatic organ-
                                                      isms  and growth  of  aquatic and higher  plants. The tests were
                                                      conducted with a number of drainage water samples under differ-
                                                      ent weather conditions and with river water for dilution.
                                                        The biodegradation of the organic components was slow at the
                                                      bacterial densities present in the river water. Some of the com-
                                                      ponents  were nondegradable and showed a potential for bioaccum-
                                                      ulation.  Toxic effects on  fish, daphnia and algae were eliminated
                                                      at  dilutions of 50:1.  Elimination of growth inhibition of higher
                                                      plants demanded  dilutions of drainage water by 2,000 to  5,000
 344
CASE HISTORIES
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times. Considering the volumes of drainage water discharged and
the flow variation of the river throughout the year,  these dilu-
tions could not be achieved. No direct discharge of drainage water
was therefore possible.
  The heavily concentrated  solid and liquid  wastes were stored
for a number of years awaiting final destruction. After long nego-
tiations, the wastes were transported abroad for incineration. Both
solid and liquid wastes had to be repacked in order to meet trans-
port regulations for toxic  chemicals.  The liquid wastes,  amounting
to about 300 m3, were pumped into railway tanks. The solid wastes
(about 45 m3) were packed into 60 or 200 kg drums according to
the instructions of different destruction companies in Europe.
  About 3.5 m3  of  wastes  are still at  the  BT-area.  These  are
dioxine-containing production  residures  which never were depos-
ited in the dumpsite. There  are presently no  facilities in Europe
willing to undertake the destruction of these wastes.


SUMMARY

   The historical  background,   the  initial investigations and  the
cleanup of the BT-Kemi dumpsite have been described.
   The activities demanded the  expertise  of many disciplines, both
managerial and scientific. Besides project management, IVL sup-
plied experts in chemistry, biology, geology, treatment technology,
toxicology, ecology, etc., from its own organization. Medical and
health aspects were covered by the County Administration.
  As many problems in connection with the cleanup were new, a
certain amount of research had to be undertaken, especially in the
treatment of liquid and solid wastes.
  An unexpected, but very important, part of the work was within
the information field. The inhabitants of  the municipality  near
BT-Kemi had to be informed about the activities carried out and
the results of different investigations. The cleanup activities would
not have been possible  without the confidence of environmental
groups in the area and in the country.
  The cleanup limits set by the authorities were severe, depending
partly on the actions of environmental groups.
  IVL predicted that the contamination limit would be achieved
within  five to six years. Now, six years after the cleanup started,
the concentration of drainage water in the holding pond is approx-
imately 0.5 mg/1, equal to the limit set  by the authorities.  The
effluent  of the dumpsite  can now be regarded as an ordinary
industrial effluent. The forced leaching of the dumpsite has to be
continued in order  to  prevent  breakthrough of  contaminated
groundwater to the river. It is very difficult to predict how long this
activity must go on.
  The costs of the cleanup including investigations, research, treat-
ment and disposal,  amount  to about $6  to $7 million U.S.  The
annual  costs of operating the  leaching  system  and paying the
charges for treatment of the leachate are estimated to be $100,000.
The costs are being paid by the taxpayers of Sweden through the
Swedish Government.
                                                                                                  CASE HISTORIES
                                                          345
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           INVESTIGATION  OF  SUBSURFACE  DISCHARGE
                   FROM A  METAL FINISHING INDUSTRY

                                           GEORGE W. LEE, JR.
                                            RICHARD D. JONES
                                            G. DAVID KNOWLES
                                          SCOTT J. ADAMOWSKI
                                       O'Brien & Gere Engineers, Inc.
                                              Syracuse, New  York
INTRODUCTION

  In Aug. 1981, the New York State Department of Environmental
Conservation (NYSDEC) issued an order to a metal finishing and
manufacturing facility indicating alleged violations of Article 17 of
the Environmental Conservation Law (ECL). The order stated that
the facility had a permitted point source discharge into the ground-
waters of  the State,  the discharge was located approximately
1000 ft from a Town water supply well and the Town well had been
tested and determined to contain 1,1,1-trichloroethane (which had
been handled, stored or otherwise utilized by the metal finishing
and manufacturing facility). It ordered that a hydrogeologkal in-
vestigation should be conducted.
  The order stipulated that the hydrogeological  study must pro-
vide information relative to the  metal  finishing and manufac-
turing facility and include the following:
1. A statement indicating the property affected  by the discharge
   and the extent to  which  the party controlling the discharge is
   responsible for any contamination present
2. A hydrogeologic analysis of the affected aquifer,  including re-
   sults of a drilling and sampling program
3. A determination of direction and rate of flow of  both the dis-
   charge and  natural groundwater
4. An evaluation of adverse effects  of the discharge on aquifers,
   potable  water supplies or other surface or groundwater of the
   State.
5. An evaluation of the underlying strata's  ability  to attenuate
   potential pollutants  such that  best usage of  groundwaters is
   maintained
  In Oct. 1981, O'Brien & Gere Engineers, Inc. was authorized to
perform the hydrogeological investigation and  prepare a report
which  would address the concerns  of the order. The investiga-
tion was divided into five categories:
•Background research and gathering of available data
•Field investigation
•Evaluation of data
• Development of remedial alternatives
•Additional work

AVAILABLE DATA
  Prior to the  initiation of a field investigation, pertinent data was
obtained to aid in the selection of investigative  techniques which
could  be used. All previous analytical results obtained by NYS-
DEC,  the New York State Department of Health (NYSDOH) and
other sources were located, obtained and reviewed. An understand-
ing of the manufacturing  operation, the subsurface  disposal
                                                   mechanism, the nature of the chemical in question, the quanti-
                                                   ties used and the effects of the chemical on man and the environ-
                                                   ment were also acquired in order to execute a safe, thorough and
                                                   effective field investigative program.
                                                     The metal finishing and manufacturing facility began operation
                                                   in Nov. 1977, and ceased operation in Dec. 1980; there are no plans
                                                   to resume manufacturing operations at the location.
                                                     The manufacturing operation at the facility consisted of cleaning
                                                   stainless steel and non-stainless metal products. The cleaning was
                                                   accomplished  utilizing a mechanized  conveyor  system, with  a
                                                   separate conveyor utilized for the washing and rinsing of the metal
                                                   products prior to the assembly of the component parts.  Clean-
                                                   ing consisted of the metal  products passing through a degreas-
                                                   ing tank, where a mist of 1,1,1-trichloroethane was sprayed onto
                                                   the metal surface. The parts  were then submerged in  a bath of
                                                   1,1,1-trichloroethane, where contact with the degreaser  was main-
                                                   tained for a period  of time to remove residual cutting oil and
                                                   other contaminants attached to the metal. Following degreasing,
                                                   the metal products were washed and  rinsed. Wastewater from the
                                                   washing and rinsing operation was discharged along with other
                                                   waters, primarily from restrooms and process cooling waters, to the
                                                   subsurface disposal system.
                                                     The facility was issued a NYSDEC State Pollutant  Discharge
                                                   Elimination System (SPDES) discharge permit which became effec-
                                                   tive in Aug. 1979. This discharge permit authorized a discharge
                                                   into the receiving groundwaters, tributary to a major river, at a
                                                   1,1,1-trichloroethane concentration not to exceed 0.05 mg/1.
                                                     Based upon the contamination evidenced by analytical results of
                                                   NYSDEC, NYSDOH and others, it  was alleged  that the  facility
                                                   had exceeded its permit limitations. To examine this allegation, a
                                                   materials mass balance was performed.
                                                     The  mass  balance  evaluation was  based upon  purchasing
                                                   records, interviews with available facility personnel and the docu-
                                                   mentation  of sizes and ratings of various pieces of equipment.
                                                   Chemical purchase and recycle records provided an indication of
                                                   the amount of 1,1,1-trichloroethane which was purchased and the
                                                   amount which was  returned to vendors. The difference between
                                                   the amount purchased and the amount returned was considered to
                                                   be  the amount which was utilized  during processing.  Of this
                                                   amount,  some  portion  had  been released  to  the atmosphere
                                                   through volatilization, with  the  remainder being attributed to
                                                   effluent discharge to the subsurface waste disposal system.
                                                     The subsurface waste disposal system for the facility was con-
                                                   structed in early 1979. The system was designed  as a leach field,
                                                   with a total leach field area 72 ft x 100 ft. Based upon SPDES per-
346
CASE HISTORIES
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mit issued and the plant's water use records, it was calculated that
the allowable mass of 1,1,1-trichloroethane which could have been
legally discharged to the subsurface disposal system over the course
of the facility operation was 10.4 Ib.
  Volatilization calculations were performed based upon physical
characteristics of the 1,1,1-trichloroethane, conditions of operation
including temperature, surface area of chemical exposure, sizes of
exhaust fans and  vents and operating times and on chemical pur-
chasing records.  From this information, the estimated amount of
1,1,1-trichloroethane which was discharged to the subsurface dis-
posal system, and hence,  potentially to the groundwater system,
was calculated by difference to be 2200 Ib.
   This figure was checked by a calculation of the total pounds of
1,1,1-trichloroethane  leaving the facility,  utilizing the  facility's
water use records and an estimate of the  discharge  concentra-
tion. This concentration was based on the limited data available,
but generated a reasonable result, indicating the estimate to be rep-
resentative of actual conditions.
   This  estimate  supported  previous  groundwater analyses per-
formed by NYSDEC, NYSDOH and others which showed elevated
levels of 1,1,1-trichloroethane in samples from the Town well and
nearby  residential wells. The mass balance evaluation then served
to support the premise that the 1,1,1-trichloroethane was in fact
in the groundwater and may have originated from the metal fin-
ishing and manufacturing firm.
   This presented  a bonafide concern on the part of the regulatory
agencies and municipalities  involved, since  1,1,1-trichloroethane,
although not considered a carcinogen, has been considered a poten-
tial risk to humans by the USEPA based on the limited toxicologi-
cal data that exist.1
   A computer based literature search was performed to locate the
available sources  of information;2"10 specifically to determine the
environmental fate of the 1,1,1-trichloroethane. Several documents
were obtained which outlined the potential fate mechanisms con-
sisting of  sorption, biodegradation  and bioaccumulation, hydrol-
ysis and oxidation. From these documents, it was determined that
the 1,1,1-trichloroethane in the groundwater was not readily adap-
table to any of these mechanisms, and, therefore, would likely re-
main in the environment if  not removed from a subsurface loca-
tion.
   Based upon the above, it became imperative that the field inves-
tigation begin; to further document the existence of the chemical in
the groundwaters, to define the limits of the affected area and to
address the concerns and develop responses  to the issues  raised in
the consent order.

FIELD INVESTIGATION
   The field investigation was conducted from Nov. 1981 to June
1982, and included:
 •Drilling of test borings to determine the underlying soil profile and
  aquifer lithology
 •Installation of  groundwater monitoring wells to establish hy-
  draulic heads within the  aquifer, to determine groundwater flow
  rates and direction and  to  establish the distribution and concen-
  tration of 1,1,1-trichloroethane, if detected,  migrating from the
  site
 •Collection and analysis of surface water, sediment and residential
  groundwater samples to ascertain if  1,1,1-trichloroethane had
  migrated beyond the property of the metal finishing and manu-
  facturing facility
•Performance of aquifer pump tests in order to measure the trans-
  missivity and specific yield of the aquifer in question
•Topographic survey to determine the location and elevation of the
  significant features at the facility
   The first phase of the  field investigatory work included the in-
stallation  of a total of 11 groundwater monitoring wells between
Nov. 1981 and May  1982.  These groundwater monitoring wells
served to establish a contour map of hydraulic heads, the flow rate
and direction of groundwater movement and to provide  informa-
tion regarding the geology of the site. They also provided sampling
points from which representative samples of the groundwater could
be withdrawn.
  The monitoring wells were installed using a Central Mine Equip-
ment  3-1/4 in. inside diameter hollow stem auger with a stainless
steel well screen integrated into the bottom 5 ft. section. This uni-
que approach to drilling  enabled the collection and analyses of
groundwater samples at various depths during the drilling process
so that the permanent stainless steel well screen could be placed in
the vertical zone which had the greatest apparent contamination.
The technique utilized the screened auger as the lead auger, with
groundwater samples collected at the screened elevation through
the auger's hollow stem.
  The successful implementation of this technique required rapid
(24 hr) laboratory turnaround time  so that groundwater monitor-
ing wells could be installed with screens placed at the desired eleva-
tions on the day following sample collection.
  All  groundwater monitoring wells were constructed of 2 in. out-
side diameter stainless steel well screen and riser pipe. Stainless steel
was used to ensure that there would be no analytical interference,
as could be the case were standard polyvinyl chloride (PVC) screens
and risers used.
  Well nests were constructed in several borings where two stain-
less steel well screens and  stainless steel  riser pipes were installed.
The well screen to be installed at the lower elevation was placed
first at the selected depth, and Silica sand was placed around the
well screen to  an elevation just above the top of the well screen.
Auger cuttings were  then placed in  the boring to the lower  eleva-
tion where the upper well screen was to be placed. Nesting of wells
provided for the monitoring of upper and lower aquifer zones so
that the location  having the greatest contamination could be de-
termined.
  Following installation, all wells were developed by removing at
least three well volumes of water from each well. Exact elevations
of all groundwater monitoring wells were established, and upon
sufficient recovery, groundwater surface elevations were recorded.
The ground elevation at each of the groundwater monitoring wells
was also established using USGS datum, as determined from a top-
ographical survey.
  During  installation,  it  was imperative that equipment  which
would be used between boreholes, including all augers, split spoons
samplers and miscellaneous tools used in the installation of ground-
water monitoring wells, be  thoroughly  cleaned by  washing with
soap and water, a rinse with hexane and a final rinse with distilled
water. The equipment was then dried under a heat  lamp prior to
reuse. This cleaning and rinsing process was conducted to prevent
cross-contamination of the borings by the equipment.
  During  drilling operations and the installation of groundwater
monitoring wells, a  safety protocol was implemented to protect
the workers. The safety equipment available for use as necessary
included:
•Protective goggles
•Rubber gloves
•Rubber boots
•Acid-resistant suits
•Hard hat(s)
•Dual carbon filter respirators
  Groundwater samples were obtained from the monitoring wells
periodically to evaluate the characteristics of the groundwater
and to document variations in 1,1,1-trichloroethane concentrations
with time. Residential well samples were also obtained from nearby
homes and businesses to aid in the definition of the limits of con-
tamination.
  The next phase of the work consisted of drilling four soil borings
into the previously described subsurface disposal area. The purpose
of installing these borings  was to obtain an undisturbed soil sample
beneath the leach field. Soil samples were then analyzed to deter-
mine  if a reservoir  of  1,1,1-trichloroethane resided in  the  soils
beneath the leach field. The test borings were completed using
                                                                                                   CASE HISTORIES
                                                           347
-------
             LOCATION OF SEDIMENT SAMPLE


             TEST 0OPJNG

             APPROXIMATE PHOPEHTY LtIC LOCATION
                                                            Figure 1
                                 Site plan including locations of wells, test borings and sampling locations.
conventional  hollow-stem augers,  with  split  spoon samples  ob-
tained continuously from the groundwater table. Equipment was
cleaned in the previously mentioned manner to eliminate contam-
ination between boreholes.
  Finally, sediment  samples and surface water  samples were
obtained  from a lagoon adjacent to the facility. Sediment samples
were obtained by  driving Lexan tubing into the sediment and ex-
tracting the tubing to retrieve sediment cores. These core samples
were analyzed for  1,1,1-trichloroethane to ascertain whether or not
the chemical had migrated to the soils beneath the lagoon.
  All sampling was  performed in accordance with standardized
sampling protocols. Samples were collected utilizing methods that
minimized cross contamination, placed in laboratory cleaned glass
containers and placed on ice for preservation during transport to
the laboratory.  During groundwater, soil, surface water and sedi-
ment sampling,  the previously listed safety equipment was utilized;
rubber gloves were disposed of after each sample was collected to
avoid any possible cross-contamination of samples.
  In addition to the groundwater monitoring  wells  previously
identified, a 4 in.  diameter  PVC well was also installed. PVC  was
utilized in the construction  of this well,  since the  well's primary
function  was as a pumping well from which aquifer characteris-
tics could be identified.
  Two pump tests were performed to determine aquifer character-
istics during June  of 1982. The pump test  data were useful in inter-
preting aquifer coefficients including transmissivity, hydraulic con-
ductivity, specific  yield and the radius of the cone of depression.
                                                          Information such as this is used as an aid in estimating the rate
                                                       at which the groundwater can flow, the degree of contamination
                                                       which could be intercepted by a well or well system and the length
                                                       of time which would be required for the natural restoration of the
                                                       aquifer. The information could also be used to estimate the maxi-
                                                       mum rate at which the aquifer could effectively be pumped as an
                                                       active method of aquifer restoration.
                                                          Last, a  topographic survey of the  facility was performed to
                                                       establish elevations and locations of groundwater monitoring wells
                                                       and soil borings as well  as other significant land  features (Figure
                                                       1). The results of the investigation were presented as a hydrogeo-
                                                       logical report to the client and all involved regulatory agencies in
                                                       Aug. 1982.


                                                       RESULTS OF FIELD INVESTIGATION
                                                          As a result of the field investigation, it was determined that the
                                                       metal finishing  and  manufacturing  facility  had  exceeded  the
                                                       SPDES  permit for  1,1,1-trichloroethane. This  conclusion was
                                                       based upon the results of groundwater samples obtained from the
                                                       monitoring wells installed as part of the investigation and the ma-
                                                       terial mass balance evaluations as previously discussed.
                                                          Data from each well were plotted on a base map to present all
                                                        1,1,1-trichloroethane concentrations detected.  This identified a
                                                       plume of contaminant which appeared to have originated at the
                                                       discharge point of the facility and  extended to the locations shown
                                                       on Figure 2.
 348
CASE HISTORIES
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                                                                    mvert
              LOCATION OF 3URACE SAMPLE

              TEST BORING

              CROUNOWATER FLOW LMC

              GROUNOWATER CONTOUR LINE
                                                            Figure 2
                                    Results of field investigation under static (non-pumping) conditions.
  During the course of the groundwater sampling and monitoring
program, it became evident that the concentrations of 1,1,1-trich-
lorethane detected in the groundwater were decreasing in the direc-
tion of the Town well. This trend was to be expected since there had
been no additional sources of wastewater since the facility closed
in 1980. When the Town well, which is approximately  1000 ft from
the discharge location, was operational, the well was expected to
have created a cone of depression that extended such  that the dis-
charge location would have been within the radius of influence of
the well. This created a situation in which the  well pumping in-.
creased  the  water table  gradient  and accelerated the  flow  of
groundwater to the well, drawing the 1,1,1-trichloroethane with the
water. Following shut down of the  well, this situation ceased and
concentrations approaching the well began to diminish.
  The analytical results of the soil  boring samples  from the sub-
surface disposal system contained no residual 1,1,1-trichloroethane
concentration.  This was  verified by  data obtained during  the
previously mentioned literature search which produced docu-
ments stating that the 1,1,1-trichloroethane is not  attenuable by
most soils. This finding was documented by conducting a soil iso-
therm experiment utilizing actual soil and groundwater  obtained
from the site (Table 1).
  It was concluded that the 1,1,1-trichloroethane had entered the
groundwater in the  same direction and at the  same rate as the
groundwater toward a nearby river. Samples of the river water were
analyzed and found not to  contain concentrations  of 1,1,1-trich-
loroethane. This natural boundary and the groundwater monitor-
ing wells and residential wells sampled serve to define the extent of
the contamination, with the groundwater monitoring wells also
providing sufficient  data  to calculate the direction and rate of
movement of the groundwater. In general, the hydrogeologic in-
vestigation produced results which could  be used to  address the
concerns of the order and provide a basis  for the development of
remedial alternatives.

DEVELOPMENT OF REMEDIAL ALTERNATIVES
  The field  work and  hydrogeological  investigation  provided
engineers with sufficient data to formulate  a list of remedial altern-
atives which would provide the town with a potable water supply
and, if required by NYSDEC,  restore the aquifer to  a condition
where levels  of 1,1,1-trichloroethane would  be  essentially non-
existent.
  The USEPA has developed  a Suggested No Adverse Response
Level (SNARL) for 1,1,1-trichloroethane. Since the chemical is not
considered a carcinogen,  the taste and odor  threshold range of
0.3 to 0.5 mg/1 is considered by the USEPA as the limiting concen-
tration to protect the aesthetic value of drinking water and to pro-
tect the public health. The  municipality and regulatory agencies
involved were not satisfied  with this level. To  date, New York
State has not developed groundwater standards for 1,1,1-trichloro-
ethane. The state has, however,  developed guidelines which suggest
a limit of 50 ug/1 range.  It was, therefore, anticipated that any
                                                                                                   CASE HISTORIES
                                                          349
-------
treatment alternative to yield potable water would have to produce
an effluent that would meet this latter limit.
  To attain the required removals, current technology for the elim-
ination of VHOs from drinking water"-12-13 suggests the use of:
•Granular activated carbon (GAQ
•Powdered activated carbon (PAQ
•Aeration
•Ion exchange resins
•Ozonation or chemical oxidation
  As another alternative, the location of an alternate water supply
was explored.  This measure could alleviate the burden of  treating
the aquifer to the extremely low levels of 5-10 ug/1 and possibly,
pending  regulatory approval  and future monitoring  results, elim-
inate treatment of the aquifer  completely.
  Treatment of the existing aquifer to remove the 1,1,1-trichloro-
ethane from the groundwater provides three distinct advantages:
•Restores water supply to Town
•Cleans up the aquifer
•Can be taken of f-line when monitoring data warrants

                            Table 1
                    Soil Isotherm Experiment
Soil1
Quantity
(gm)
Groundwater
Quantity
(ml)
Delonlzed
Water Quantity
(ml)
Concentration of
1,1,1-trichloroethane
Jg/l
 1.02
    0
 0.50
 1.03
 2.04
 10.00
   0
 3002
 300
 300
 300
 300
300
  0
  0
  0
  0
  0
  1
520
500
480
520
520
I. Wet wcighl basis.
2. pH of groundwater sample was 6.8.

Table 1—Results of soil isotherm performed utilizing actual groundwater and soil obtained at the
site.
  The major drawback to treatment is that the treated water would
be  pumped into the existing water  distribution system  causing
public concern. With this in mind, an alternative which combines
the location  of an alternate water supply and  the restoration  of
the aquifer (if required by regulatory agencies) was proposed.
This  alternative offers the potential  for  increasing the 5  »ig/l
1,1,1-trichloroethane limitation  since  the  treated  groundwater
would be discharged to a nearby river. It is anticipated that in this
instance only the 50 >ig/l limitation developed  in the state guide-
lines would have to be met.
  Based upon the above, it appeared that treatment of the ground-
water, whether it be to a potable level (5 ug/1) or to a level suitable
for discharge to the  nearby river (50 )ig/l), was a feasible  alterna-
tive. Further investigation was appropriate.
  Prior  to selection of a  treatment scheme,  criteria for  per-
formance in addition to effluent stipulations had to be addressed.
Characteristics considered favorable in the selection of a treatment
plan included:
•Minimal capital and installation cost
•Minimal operational and maintenance costs
•System portability
•Proven design
•Ease of implementation
•Technical feasibility
  Powdered  activated carbon, ion exchange resins and  ozona-
tion/chemical oxidation  were  eliminated since  they  did not  meet
all  the  desired  performance criteria.  The remaining alternatives,
GAC and  aeration,  appeared  to  be the most favorable. A draw-
ing depicting the treatment scheme using either technique is shown
as Figure 3.
  The use of activated carbon is a well recognized and field proven
method for removal of volatile organic chemicals from drinking
water supplies. The incorporation of the activated carbon as a
GAC unit makes the system portable and implementation relative-
ly quick and  easy. For short  term applications,  many vendors
offer "rental" services which include certain operational and main-
tenance items in their fee. If the duration of use can be determined,
these can be relatively inexpensive and  worry free systems com-
pared to the outright purchase and  operation of a  GAC unit.
Carbon regeneration, constituting high operational  and  main-
tenance costs, is considered the major disadvantage.
  Aeration, or air stripping, is a  liquid-gas mass transfer opera-
tion in  which the volatiles are stripped out  of the liquid by a
counter-current air stream, are transferred  to the air  stream and
are discharged or  recovered, leaving the purified effluent. This
technique has been widely used in the chemical industry and in
other industrial applications for many years but only recently  has
been applied to the  treatment  of contaminated  drinking water
supplies.
  Capital and installation costs of aeration systems  are slightly
lower than for the GAC, while operational and maintenance costs
are considerably lower  since there are no  material regeneration
costs.
  In lieu of treatment to a potable level or treatment to a level
suitable for river discharge, the concept of locating a new water
supply is an appropriate alternative.  This alternative  is the least
capital intense, providing the contaminated  aquifer does not have
to be restored, and eliminates the public apprehension associated
with pumping the contaminated groundwater directly to the water
distribution system following treatment.
  Should it be determined that the contaminated aquifer requires
treatment,  the cost advantage held by this alternative  disappears,
leaving only the advantage of public acceptance.
  To date, an accepted remedial alternative has not been agreed
upon. It is anticipated  that, since the  monitoring program pro-
duced evidence of contaminant reduction,  the aquifer will flush
itself clean over time.
  Based upon this premise, a new water supply could be located
and utilized by the municipality while the aquifer is regularly mon-
itored to document the anticipated decline of 1,1,1-trichloroethane.
In the event it is determined that an active treatment system must
be applied  to the aquifer, further  evaluation leading to design of
an aeration or other appropriate system will be initiated.
ADDITIONAL WORK

  With  the problem defined and remedial alternatives identified,
there remains only the further  development  of the  most viable
alternative. As previously mentioned,  the location of a new Town
water supply is currently  being  investigated. Alternatives being
considered include the purchase of water from  a  nearby munici-
pality and  the pumping of water from the river and treating to a
potable level.
                                                                                   Figure 3
                                                              Remedial scheme in the event aquifer restoration is required.
 350
CASE HISTORIES
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  Additionally, work is currently being undertaken by hydrogeol-
ogists with the aid of computer modeling to simulate groundwater
flow characteristics under various natural and pumping conditions.
The  modeling effort will assist  in predicting the effectiveness of
the aquifer's natural cleansing ability and thereby identify whether
or not treatment of the contaminated aquifer is needed.
SUMMARY
  An order was  issued to a metal finishing and  manufacturing
facility in Aug.  1981. The document required that a complete
hydrogeological investigation pertaining to  the  subsurface dis-
charge of 1,1,1-trichloroethane which allegedly migrated through
the groundwater  system  to a nearby Town water  supply well be
performed.
  O'Brien & Gere Engineers, Inc. was authorized to perform the
investigation which included the installation of groundwater mon-
itoring wells, soil  and groundwater sampling and research oriented
work to confirm  or refute the allegations and to address the con-
cerns of the consent order. It was  found that the metal finishing
and manufacturing facility was responsible for the contamination
and that remedial work was in order. Alternatives were developed
and evaluated. The work completed to date indicates that the
development of a new water supply,  with the possible  treatment
of the groundwater aquifer, is the most reasonable remedial altern-
ative. Investigations are  ongoing to determine the level of treat-
ment, if any, required for the clean up of the groundwater aquifer.
 REFERENCES

  1. USEPA Office of Drinking Water "SNARLS" Program, SNARL For
    1,1,1-Trichloroethane, Washington, D.C., May 1980.
 2. Pearson, C.R. and McConnel, G., "Chlorinated C, and €2 Hydro-
   carbons in the Marine Environment," Proc. Roy. Soc., London B.
   189,1975, 305-322.
 3. Patterson, J.W. and Kodukala, P.S., Chem. Engr. Prog.,  77, Apr.
   1981,45-48.
 5. Boughman, G.L. and Lasister, R.R., "Prediction of Environmental
   Pollutant Concentration in Estimating the Hazard of Chemical Sub-
   stances to Aquatic Life," ASTM, STP. 657, J. Cairns, Jr., K.L. Dick-
   son, A.W. Maki, Eds. ASTM, 1978, 33-54.
 6. Dilling, W.L., Teferiller, N.E. and Kallos, G.J.,  Evaporation Rates
   and Reactivities of Methylene Chloride, Chloroform, 1,1,1-Trichloro-
   ethylene, Trichloroethylene,  Tetrachloroethylene and Other  Chlor-
   inated Compounds in Dilute Aqueous Solution,  Env. Sci.  Tech. 9,
   1975,833-838.
 7. Tabak,  H.H., Quave, S.A.,  Mashni,  C.I.  and  Barth, E.F., "Biode-
   gradability  Studies with Organic  Priority Pollutant  Compounds,"
   JWPCF, 53, 1981, 1503-1518.
 8. Thorn, N.S. and Agg, A.R., "The Breakdown of Synthetic Organic
   Compounds in  Biological Processes," Proc. Royal Soc.  London B
   198,1975, 347-357.
 9. Land, R.R., et. al., "Introductory Study of Biodegradation  of the
   Chlorinated Methane, Ethane and Ethene Compounds," Presented at
   the AWWA Annual Meeting, St. Louis, MO, June 1981.
10. Colwell, R.R. and Sayler, G.S., "Microbial Degradation of Industrial
   Chemicals," Water Pollution Microbiology, R. Mitchell, Ed., John
   Wiley & Sons, New York, 1978.
11. EPA  Treatability Manual Vol. 1.  Treatability Data, USEPA  600/8-
   80-042A-July 1980.
12. Controlling Pollution from the Manufacturing and Coating of Metal
   Products, Solvent Metal Cleaning, Air Pollution Control, 11, USEPA
   625/3-77-009,  May 1977.
13. Petura,  J.A.,  "Trichloroethylene and Methyl Chloroform in  Ground-
   water: A Problem Assessment," JAWWA, 1981, 200-205.
                                                                                                      CASE HISTORIES
                                                            351
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      A DUAL  PURPOSE CLEANUP AT  A SUPERFUND  SITE

                                          WILLIAM R. ADAMS, JR.
                                              Perkins Jordan, Inc.
                                             Reading, Massachusetts
                                              JAMES S. ATWELL
                                             B.C.  Jordan  Company
                                                 Portland, Maine
OVERVIEW
  In this paper,  the authors discuss the successful results gen-
erated by cooperative efforts between two state agencies, one faced
with the need to  construct a highway over  a  Superfund site and
another responsible for the cleanup of that site. Also addressed
are the engineering consultant's assessment of remedial alterna-
tives and subsequent selection of the most  cost-effective and en-
vironmentally sound solution to the problem posed by the con-
struction. The hazardous waste site is the Pine Street Canal site in
Burlington, Vermont, which was designated as Vermont's priority
Superfund site because of its proximity to both business and resi-
dential areas and  because of its location adjacent to Lake Cham-
plain—the city's source of drinking water.

PROJECT HISTORY
  Over a decade ago, after studies had determined the need and a
route had been selected, the Vermont Agency of Transportation
(AOT)  and the city of Burlington  entered  into an agreement to
construct a connector from Interstate 89 to downtown Burlington.
The AOT began preliminary engineering and made cost estimates
for budget purposes. The only practical and readily available right
of way for this road crossed an area adjacent to a wetland of Lake
Champlain, a large beautiful lake bordered by the states of Ver-
mont and New York and the Province of Quebec.  However, the
seemingly logical choice of  this  location was complicated by a
major obstacle—a hazardous waste area was located approximate-
ly on the centerline of the selected route.
  Between the years of 1908 and 1966 a coal gasification plant
was operated  in the Burlington area, and the byproducts  of the
gasification process, which included coal tars, coal oils and sludges,
were disposed of in the low areas  on  and  adjacent to this site.
Visual observation and a history of oil seeps and discharges to
the barge canal leading to the lake prompted a review of the prob-
lem by the  USEPA under the provisions of  Superfund. Prelim-
inary investigations by the Vermont Agency of Environmental
Conservation (AEC) and the USEPA determined that substantial
quantities of coal tars, oils and sludges were buried at the site.
  The question was whether or not this area could be feasibly util-
ized for highway  construction and,  if it could, how the proposed
construction could  be  accomplished within the  relatively  short
timetable established by AOT. There was no  doubt that the am-
bitious construction schedule established by  AOT would not mesh
with the long and tedious timetable of the Superfund process.

STATE AGENCY COOPERATIVE EFFORTS

  As is the case with most highway transportation agencies, the
AOT is staffed with extremely knowledgeable, dedicated and per-
                                                    sistent professionals. They had agreed with the City to construct
                                                    this road and, after learning of the hazardous waste problem, be-
                                                    gan to search for innovative ways to fulfill their commitment. AOT
                                                    engineers recognized the ramifications of constructing a highway
                                                    over a Superfund site, but instead of abandoning the project or
                                                    attempting to find another location, the AOT decided to see if a
                                                    satisfactory solution would be found to allow highway construc-
                                                      AOT officials began to look for a solution that would meet cri-
                                                    teria for good highway construction and be environmentally sound
                                                    and acceptable. At this time a course was  set which would be
                                                    followed throughout the project—one of cooperation with other
                                                    involved agencies  rather than confrontation.  Instead of confront-
                                                    ing AEC,  the AOT decided to make them a partner in determin-
                                                    ing the proper solution. Senior officials from the AOT met senior
                                                    AEC officials and established a friendly and cooperative working
                                                    arrangement which has continued throughout the project and has
                                                    carried through to their staffs.
                                                      AOT officials made it clear at the outset that, while the construc-
                                                    tion of the road across this area and the established time schedule
                                                    were of great importance, environmental responsibilities would not
                                                    be sacrificed. They believed, and later convinced AEC, that they
                                                    could accomplish their construction program in an environmental-
                                                    ly sound manner.
                                                      The meeting with the  top officials of both departments pro-
                                                    duced an  agreement on how the project should proceed and the
                                                    responsibilities of the two departments. In essence, the AOT agreed
                                                    to do  whatever was necessary to produce an environmentally ac-
                                                    ceptable solution. They agreed to fund the necessary field investi-
                                                    gation and feasibility study to determine  an acceptable solution
                                                    and requested AEC and its environmental  staff to provide the
                                                    technical direction and approval for the required environmental
                                                    studies. The AEC agreed to accept this invitation to serve as tech-
                                                    nical  consultant  to AOT and to  review,  comment  upon and
                                                    approve work plans, methods and solutions. AEC also agreed to
                                                    be the State's sole contact with the USEPA for the project and
                                                    assisted AOT in the preparation of an RFP for  the required site
                                                    investigation and feasibility study.
                                                      Throughout the process, the technical  decisions for this haz-
                                                    ardous waste work  were made by AEC staff. The AOT accepted
                                                    these decisions at  face value. AEC staff also became the only State
                                                    contact with the  USEPA, with the exception of one meeting  at
                                                    which AOT  outlined its goals and schedule. This agreement of
                                                    one state  agency, namely AEC, working with and for the AOT,
                                                    greatly accelerated  conduct of the  study  and the  decision-mak-
                                                    ing processes.
                                                      The two agencies realized that both were working for the same
                                                    public. They were able to put  aside petty differences, which fre-
352
CASE HISTORIES
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quently drive similar agencies apart,  and provide the joint lead-
ership necessary to produce an innovative, cost-effective solution
which would not only allow construction of the road, but provide
a suitable site cleanup.
  With the agreements and understanding between AOT and AEC
in place, the State was ready to investigate the site and determine
whether or not a cost-effective solution could be found to allow the
planned construction.
  In addition to the AEC and the AOT, which were the principal
agencies, both the USEPA and  the  Federal Highway  Adminis-
tration were brought into the process and have played key roles in
the project. The USEPA has provided  services through its FIT
contractors and technical consultation and review.
  The Federal Highway Administration has reviewed the road con-
struction and the remedial action program and is allowing remedial
action costs to be  included in the  funding of the roadway con-
struction when the  activity is an integral part of the roadway con-
struction.
  FHA funding is possible because:
•The remedial action—groundwater extraction to accelerate con-
 solidation of the  peat  and provide  a more stable road base—
 is designed to be an integral part of the roadway construction.
•The estimated cost of roadway construction, including the remed-
 ial action, is less than the initial cost estimates for the road which
 were made assuming conventional construction methods without
 any special provisions for waste handling.
  With the basic agreements concerning responsibility and funding
in place, AOT made the decision to proceed and requested AEC
to prepare an RFP  to study the area. The work requested took ad-
vantage of the preliminary studies and extensive soil investiga-
tions already completed by AOT. It also provided that AOT drill
crews would perform additional  drilling. The State requested the
following  program, which Perkins Jordan, Inc.  was retained to
provide:
•A review of the regulations and  requirements that might bear on
 this project
•An analysis of the liabilities connected with the proposed exca-
 vation, treatment and disposal of this material
•A strategy to ensure close coordination among the various regu-
 lating agencies and other interested parties
•Advice and guidance in the selection of boring locations
•Assistance in establishing the extent of contamination and  degree
 of hazard of material encountered
•Determination of feasible alternative solutions and  their esti-
 mated costs
•Determination of what, if any, safety requirements  should  be
 followed in the design, construction and disposal activities
•Development of any monitoring  program necessary  during or
 after construction.
  During the course of this work it became apparent to Jordan that
additional hydrogeologic data were necessary to properly determine
the most  cost-effective remedial alternative  for  the Pine  Street
Canal site. The contract was amended to provide this work.

THE CONSULTANT'S STUDY
  Hydrogeologic data revealed that 10 to 12 ft of silty fill material
overlie 10 to 15 ft of very permeable peat on top of 50 to 60 ft of
silt. The mobile contaminants were mainly found in the peat. Con-
taminants which had entered the silt were found to be relatively
stable and immobile.
  The groundwater table was generally at a shallow depth and
dropped from east  to west.  It was also determined that there was
an upward gradient from the bedrock through the silt, as well as
horizontal movement toward the canal.  The peat was  about 100
times more permeable than  either the overlying fill or underlying
silt and, hence, acted as a drain for the area.
  After the study, Jordan listed five remedial alternatives:
•Excavation and solidification or stabilization
•Excavation and offsite land farming
•Excavation and disposal at a licensed hazardous waste disposal
 facility
•Slurry trench containment
•Groundwater collection and treatment
  The first three alternatives were quickly eliminated from further
consideration because of the potential adverse environmental im-
pact and the cost involved in the excavation and disposal or treat-
ment of up to 240,000 yd3  of contaminated soil. It was also de-
termined that excavation of this volatile material could create po-
tential health problems for  nearby residents. The  alternative of
constructing a slurry wall received  additional study but was later
dismissed because of the required 17,000 yd3 of excavation neces-
sary to build the wall and the excavation/disposal  problems just
mentioned. It was also determined  that upward  seepage gradients
in the groundwater would require  long-term pumping and treat-
ment. There  were also some  questions as to the  long-term  in-
tegrity of a slurry wall.
GROUNDWATER COLLECTION AND
TREATMENT ALTERNATIVE SELECTED
  The remaining alternative of groundwater collection and treat-
ment was thoroughly investigated. Jordan determined that a com-
bination of preloading and pumping of groundwater would accom-
plish two  significant purposes.  First,  most mobile contaminants
were included in  the  peat  and  the  groundwater surrounding it.
Pumping and treating this groundwater would remove large quan-
tities of contaminants in an environmentally acceptable  manner.
Second, dewatering of the peat, combined with the controlled pre-
loading of the roadway, would bring about compaction in a period
of two years equivalent to 30 years naturally. Through laboratory
testing of the  peat, Jordan determined  that the combination of
groundwater extraction and controlled placement of the  roadway
base would provide a stable base and reduce roadway maintenance.
  The groundwater treatment facility could be of modest size since
the flows would be carefully controlled by the amount of surcharge
placed on the area and the rate of pumping. As a result, after two
years of operation, it  will be possible to  discontinue the pumping
and treatment and to construct the road.  It is  anticipated that
further pumping and treatment will not be required.
  Because this solution is innovative and  is based upon some com-
plex calculations, the AEC has requested, and the AOT has agreed,
to keep  the groundwater extraction  equipment and the treatment
facility itself in place after highway construction to provide treat-
ment if oil seepage  continues after the two year consolidation
period.
CONCLUSIONS

  The unusual features of this project are that two state agencies,
who often have diverse goals, joined together to embrace a cost-
effective solution which meets the goals of both agencies. The two
agencies brought their equivalent federal agencies into the project,
and the cooperation of the four agencies has allowed a highway to
be constructed  and a hazardous waste site to be corrected  in a
single effort. Their cooperation has been outstanding.
  The second feature is that Jordan, following a careful study and
evaluation of the site hydrogeology and contaminant location and
mobility, was able to utilize the age-old concept of dewatering to
accomplish contaminant removal with the bonus of constructing a
stable highway. The estimated cost  for this remedy is no greater
than what had been originally estimated to excavate what was then
believed to be uncontaminated peat and to replace it with granular
material. The chosen  solution will give AOT its highway within
budget and on schedule, and give AEC an accelerated, cost-effec-
tive site cleanup.
                                                                                                 CASE HISTORIES
                                                         353
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                                REMEDIAL ACTIVITIES AT
                         THE MIAMI DRUM SITE, FLORIDA

                                          VERNON B. MYERS, Ph.D.
                              Florida Department of Environmental Regulation
                                               Tallahassee, Florida
SITE DESCRIPTION

  Miami Drum Services is an  inactive drum recycling facility
located in western Miami in Dade County, Florida. The site is 0.5
hectares in area and is located in a predominantly industrial area.
The  facility operated for approximately 15 years before litigation
forced it to cease operation in June 1981. As many as 5,000 drums
of various chemical waste materials were observed on the site while
the  company was operating.  Drums were washed with a caustic
cleaning solution which, along with drum residues containing in-
dustrial solvents, acids and heavy metals, was disposed of on-site
and eventually saturated the surface soils.
  The Biscayne Aquifer is approximately 1 m below the natural
ground surface at this site. This aquifer is the only source of fresh
water utilized for the drinking water  supply of two million in-
habitants of Dade County. It is a highly permeable unconfined
shallow  aquifer composed of limestone and  sandstone which
underlies the entire county. At the site, the base of the aquifer is ap-
proximately 28 m below the natural ground surface. The natural
groundwater flow is horizontal and eastward at a velocity of about
2 ft/day. Recharge to the aquifer is from rain entering vertically
over the entire area.
  The locations of the Miami Drum site and nearby major public
well fields are shown in Figure 1. The Medley wellfield is situated
only 230 m  west of this  site, and the Miami Springs-Preston
wellfields are located about 1,500 m southeast of the site.
  The withdrawal rate from the Miami Springs-Preston wellfields
ranges from about 75 mgd during the  rainy season to nearly  150
mgd during the dry season. Medley wellfield is used during  dry
periods when the Miami Springs-Preston wellfields are threatened
by saltwater encroachment from the sea. Medley has a pumping
capacity of 50 mgd.
  In spite of the excellent hydrologic characteristics of the Biscayne
Aquifer, the withdrawal of about 150 mgd of water from the Miami
Springs-Preston wellfields causes a cone of depression about 3 m
deep. The Miami Drum site is within this cone of depression and
within the  100-day  travel time  from the  well  fields.  During
withdrawal from the Medley wellfield, there is another cone of
depression around this well field, but smaller in extent than the one
from the Miami Springs-Preston wellfields.

PAST INVESTIGATIONS

  Analytical results given in Table 1  indicated that  the soil and
water below the Miami Drum  site were contaminated.' These
results were based on samples collected to a maximum depth of 3
m. The soils showed high concentrations of phenols, heavy metals,
                                                   oil and grease and pesticides. The water from the top few feet of the
                                                   Biscayne Aquifer at the site showed high concentrations of
                                                   phenols, oil and grease, cyanide and volatile organic compounds.
                                                   Maximum allowable concentrations for several heavy metals in
                                                   groundwater and in public drinking water supplies were exceeded in
                                                   the on-site wells at the site.2
                                                                          Miami Spring!
                                                                           Well Field
                                                                           (23 Well
                                                                            Figure 1
                                                            Location of Miami Drum Site and public wellfields

                                                      In late 1981, the Florida Department of Environmental Regula-
                                                   tion contracted with  Technos,  Inc. to determine  the extent of
                                                   groundwater pollution associated with the site. Geophysical data
                                                   from  Electromagnetics (EM)  and Ground  Penetrating Radar
354
CASE HISTORIES
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                           Table 1
Contaminants in Shallow Groundwater and Soil at the Miami Drum Site
Parameter
Concentration (/tg/1)

  In Water
      378
      839
      12.4
      959
    22,500
       3.2
      220
      170
      310
      170
      210
   945,000
     1,200
                                                      In Soil
                                                        19,200
                                                        8,170
                                                      695,000
                                                      154,600
                                                      153,000
                                                        48,000
                                                        44,200
                                                    31,300,000
1,1-dichloroethane
Cis-1, 2-dichlorethylene
Chloroform
Trichlorethylene
Phenols
Mercury
Lead
Cadmium
Chromium
Arsenic
Nickel
Oil and Grease
Cyanide
Dieldrin                                    —            18,000
Lindane                                    —               140
Wingerter Laboratories, Inc. (1981) — Maximum levels found at site prior to cleanup.
 (GPR) were  used to selectively position groundwater  wells for
 direct sampling of suspected contaminated areas around the site.
 The EM results showed a significant conductivity anomaly coinci-
 dent with the site.3 The conductivity anomaly provided evidence of
 a strong plume-like trend to the southeast  in the direction of
 groundwater flow and toward the Miami Springs-Preston wellfield.
 Several less significant conductivity lobes were  also detected west
 and north of the site toward the Medley wellfield. Groundwater
 sampling levels detected significant volatile organic contamination
 levels below the site (Table 2).

 CONTAMINATED SOILS CLEANUP

   In 1981, the Dade County Department of Transportation pur-
 chased several hectares in the area around Miami Drum, including
 the site itself, as the location for a maintenance facility for its rapid
 transit system. When the county learned that it  had purchased the
 Miami Drum site, it decided to undertake remedial  cleanup of sur-
 face material and to apply  for reimbursement under Superfund.
   In Dec. 1981, the USEPA contracted with Ecology & Environ-
 ment, Inc. to determine the most feasible method of dealing with
 surface contamination at the Miami Drum Services site. The most
 cost-effective approach was determined to be soil excavation with
 off-site disposal." Dade County took the lead for the surface soil
 cleanup. The  question  soon arose as to the  extent of surface
 cleanup necessary to protect the aquifer. Dade County sought ad-
 vice and guidance from the  USEPA and the Florida Department of
 Environmental Regulation  in determining the appropriate level of
 cleanup and prepared a protocol for the cleanup action.

                           Table 2
         Shallow Groundwater Analyses at Miami Drum Site

Contaminant
Chlorobenzene
1,1 dichloroethane
1,3 dichlorobenzene
1,4 dichlorobenzene
Tetrachloroethylene
Trichloroethylene
cis 1 ,2 dichloroethane
Concentration
0.3 m
3.3
44.4
25.7
26.6
5.7
5.8
17.9
0*8/1)
3m
14.0
39.7
5.9
4.5
4.1
5.6
13.3
 Technos, Inc. (1983). Maximum levels found in monitoring wells prior to cleanup.
  It was jointly decided to stabilize the site by excavation of highly
contaminated soils and any associated groundwater  based  upon
laboratory work and best engineering and scientific judgment. The
intent of this protocol was to excavate soils showing concentrations
in excess  of the  10 times  "minimum criteria" for groundwater
unless  it was determined during the excavation process that soils
almost meeting these criteria could be left in place without posing a
threat  to the public health  and welfare. This judgment was  made
based upon  daily field observations and analytical results.
  Soil  borings were initially collected and analyzed at  29 locations
within  the site. Soil borings at 0.3, 0.6, 2 and 3 m  depths were
analyzed for oil and  grease, PCBs, heavy  metals and pesticides.
During the  time Miami Drum  Services was in operation, certain
low-lying areas on the property received the runoff from the  drum
washing operations. Additional core samples were taken from these
areas to determine the extent and level of hazardous materials that
might be concentrated there.
  Thirty-four core samples were collected from the  site at various
depths to  a maximum of 3 m. These soil samples were  initially
analyzed for: oil and grease, selenium, PCBs, silver,  arsenic, en-
drin, cadmium, methoxychlor, chromium, toxaphene,  lead, 2,4-D,
mercury and 2,4,5-TP (Silvex). The initial excavation conducted
during the cleanup activities was based upon the following criteria:
•Excavation of soils obviously contaminated as indicated by the
 total metal analyses
•Visual observations  of soil coring showing  highly colored, oily
 deposits
•Known locations of deep pits that  had received  contaminated
 runoff during the time Miami Drum Services was in operation.
  This initial excavation occurred in the northwest portion of the
property in  an area 45 m by 45 m. This area was excavated to a
depth of 0.75 m. Core samples obtained in contaminated locations
indicated the need to remove soils to depths of 2.5 to 3 m in  some
areas; visual observation of the site confirmed this need. Additional
soils were  removed in these areas up to a depth of 3 m. Forty-one
selected core samples were submitted for analysis of the following
EP  toxicity  parameters: arsenic, mercury,  barium,  silver,  cad-
miium, selenium, chromium, PCBs, lead, oil and grease.
  After completion of the analytical program, the contractor was
directed to conduct final excavations on the site based upon soils
with parameter values significantly higher than 10 times the State's
"minimum  criteria"  for  groundwater based on  EP  toxicity
analyses.  At this point in the cleanup activities, engineering and
scientific judgment played key roles in determining the final degree
of excavation to be accomplished on the site.
  The  levels of mercury found in EP extraction  analyses were
slightly higher than the "minimum  criteria" standard of 1.4 /tg/1.
All the mercury values indicated, however, were the same order of
magnitude as the standard. Visual observation of the core samples
at these depths gave no indication that these soils contained the oily
deposits or the high color exhibited by the contaminated soils ob-
tained  from other locations within  the property. Based upon this
information, it was decided to leave in place  the soils displaying
slightly elevated mercury values. A total of 7335 m3 of hazardous
debris  and soil was excavated from the Miami Drum site. These
materials  were placed in Visqueen-lined trucks and transported  to
the authorized hazardous waste disposal site operated by Chemical
Waste  Management, Inc., in Emelle, Alabama.
  In addition to the excavation operations, 2,460,000  1 of exposed
groundwater were treated  prior  to  recharge to  the Biscayne
Aquifer. Unit processes employed in the water treatment are shown
in Table 3.

GROUNDWATER INVESTIGATION

  Groundwater contamination at the Miami Drum site was not ad-
dressed by the surface remedial actions. In 1982, USEPA funded a
remedial investigation/feasibility study designed to  examine the
vertical and horizontal extent  of the migration  of hazardous
substances from the Miami Drum site.
                                                                                                   CASE HISTORIES
                                                                                          355
-------
  The Florida Department  of Environmental  Regulation (DER)
was the lead agency in this phase of the project. In Apr., 1983, the
Department contracted with the U.S. Geological Survey (USGS) to
drill monitoring wells at the site. A dual-well reverse air circulation
drilling method was used. This method offers  several advantages
over standard mud rotary or standard air rotary methods: (1) ac-
curate and "clean sampling" of geologic formations; (2) observa-
tion of water yield as bit passes various lithologies; (3) indication of
gross water quality profile; and (4) no loss of circulation in caver-
nous  zones. The information provides a good characterization of
the permeability variation of the aquifer, the geologic composition
of the aquifer and a general water quality profile for selecting zones
in which to install finished observation wells. Furthermore, the for-
mation and water are not contaminated with drilling muds.
  A geological test well was drilled to the top of the confining layer
of the aquifer (55  m). A geological log was made of the test well,
and preliminary results were used to determine the depth of the
other monitoring wells. Seven monitoring wells were subsequently
drilled at  the site  in three clusters  (Figure 3).  Cluster MD-1 was
located directly east of the site with a well 3 m deep and a well 14 m
deep. Cluster MD-2 was south of the site with a well 3 m deep, one
14 m deep and one 27 m deep. Cluster MD-3 was located west of
the site with a well 14 m deep and one 27 m deep.

                            Table 3
                    Water Treatment System
Unit Process

Acidification of water


Caustic addition


Aeration

Sand filtration

Carbon nitration
                Purpose/Function

                Break up emulsions and skim off resultant
                floating oil/grease layer
                Convert heavy metal ionic species to non-
                soluble hydroxide forms
                Oxidation of organic compounds, purging
                of volatile organic compounds
                Removal of suspended paniculate matter

                Adsorption of residual organic compounds
   Monitor wells were 7.5 cm diameter, black, steel-cased, gravel-
 packed and sealed from the bottom of the casing to the land surface
 with cement grout. The wells were developed until samples were
 free from turbidity and the conductivity had stabilized. The wells
 were finished approximately 0.6 m above land surface and capped
 with locking caps.
   Prior to drilling,  all drill pipes, casings and bits were decon-
 taminated by sandblasting and steam cleaning.  No  grease of any
 type was used on the drilling tools and bits. The wells were sampled
 by USGS in accordance with the Department's Sampling Protocol.'
   The  129  priority  pollutants tested  for included: metals,  her-
 bicides, pesticides, PCBs, volatile organic compounds, acid extrac-
 table organic compounds  and base/neutral extractable  organic
 compounds.  Samples were  analyzed by both USGS and the State
 DER for quality assurance purposes.
   Preliminary results of analyses are listed in Table 4. No metals,
 acid or base/neutral extractable organic  compounds were found
 above  detection  limits. However, several  volatile  organic  com-
 pounds and the pesticide Kelthane were found.
   The  volatile organic compounds included: 1,1 dichloroethane,
 chlorobenzene, chloroethane, chloroethene, ethyl benzene and 1,1
 dichloroethene.  Chloroethene (vinyl chloride) is a  known human
 carcinogen; ethyl benzene,  1,1  dichloroethene, 1,1 dichloroethane
 and chlorobenzene are  suspected carcinogens.'
   The volatile organic compounds were found in greatest concen-
 tration in the deeper wells,  at 13 and 27 m depth. Verification of
 these  results will occur when  the USGS analytical  data  are
 available. The  preliminary  results of USEPA's Biscayne Aquifer
                                                                                           r
                                                                                            MD-3*
                                                                                                          • MD-1
                                                                                                      MO-2*
            Figure 2
Location of Monitoring Well Clusters
             Table 4
  Miami Drum Groundwater Data
Welb
Depths (m)
CONTAMINANTS
+ 1,1 Dichloroethane
+ Chlorobenzene
Chloroethane
•Chloroethene (vinyl chloride)
+ Ethyl benzene
+ 1,1 Dichloroethene
VOC's
Kelthane
1A
2.4
IB
13
2A
2.4
2B
13
2C
23
3A
13.7
38
23
CONCENTRATION (/ij/1)
2.6
—
—
...
--

2.6
1.5
7.7
3.4
136
3.8
—
_
150.9
1.8
—
—
4.3
—
_-
._
4.3
0.8
4.4
2.6
44
2.9
5.2
—
59.1
1.2
9.5
5.8
6.7
2.0
—
._
25.8
1.8
9.1
_
128
38
—
7.7
264.7
.„
3.5
—
84
II
_
—
98
0.2
+ Suspected carcinogens (NCI test underway)
•Known carcinogens (W.H.O.)
FDER data (May, 1983)














                                                                                    Table 5
                                                                 Biscayne Aquifer Groundwater Data in the Vicinity
                                                                             of the Miami Drum Site
Welb
Depth (m)
CONTAMINANTS
I.I Dichloroethane
Chlorobenzene
Chloroethene
1,1 Dichloroethene
1 ,2 Dichloroethene
Toluene
Metbylbutylketonc
USEPA Data (November, 1982)
CIB
15.5
CIC
30.8
CJA
5.5
CONCENTRATIONS Of /!)
5
6.8
130
—
12

—

14
5
110
2
26

._

-
-
-
-
—
_
t>

 356
CASE HISTORIES
-------
Study also found similar volatile organic compounds in this area of
Dade County (Table 5).' Again, the greatest concentrations of
volatile organics were found in the deeper wells. The preliminary
results of this study and other data from the  area confirm the
presence  of contamination of the Biscayne Aquifer.2'3 This con-
tamination appears to extend to the west and south of the Miami
Drum site. These data are in agreement with the regional directions
of groundwater movement  and  the  specific  effects  of wellfield
pumping in the area.
  Levels of volatile organic compounds in  the groundwater under
this site were significant enough to warrant a feasiability study. The
non-threshold limits for carcinogens and the proximity of two ma-
jor potable water wellfields makes the assessment of water treat-
ment alternatives imperative. The feasibility study may be part of
the USEPA's general feasibility  study for the Biscayne  Aquifer
sites. A decision will be made in the summer of 1983 on the scope of
the feasibility study.
REFERENCES
1. Wingerter Laboratories, Inc., "Miami Drum Data Report." 1981.
2. Florida Administrative Code. "Chapters 17-3 and 17-22." 1983.
3. Technos, Inc., "Geophysical and Hydrogeological Investigation of the
   Miami Drum Site." 1983.
4. Ecology and Environment, Inc. "The Feasibility of abating the Source
   of Groundwater Pollution  at Miami  Drum Services, Dade County,
   Florida."  1981.
5. Florida Department of Environmental Regulation. "Standard Operat-
   ing Procedure Manual for  Handling and Collection  of Groundwater
   and Surface Water Samples."  1982.
6. Kool,  H.J., Van Kreijl, C.F., and Zoeteman, B.C.J.,  "Toxicology
   Assessment of Organic Compounds in Drinking Water." CRC Critical
   Reviews in Environmental Control, 12, 1982, 307-359.
7. U.S.  Environmental Protection Agency  "Draft—Biscayne Aquifer/
   Dade County, Phase II Report." 1983.
                                                                                                      CASE HISTORIES
                                                            357
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                                         PRICE  LANDFILL:
          INTERIM AND  LONG-TERM REMEDIAL  ACTIONS

                                             JAMES R. WALLACE
                                          Camp Dresser & McKee,  Inc.
                                              Boston, Massachusetts
                                        SALVATORE BADALAMENTI
                                                ROBERT N. OGG
                              U.S. Environmental Protection Agency, Region II
                                              New York, New York
INTRODUCTION
  The Price Landfill site near Atlantic City, New Jersey, is an in-
active landfill that operated from the mid-1960s to the mid-1970s.
Initially, it served as a sand and gravel pit, but when  the con-
tents had been  excavated to within approximately  2  ft of the
groundwater level, gravel operations ceased. At that time the site
began receiving  private and municipal wastes. For approximate-
ly 18 months,  the  landfill reportedly received  liquid  industrial
wastes, both in  55-gal drums and bulk liquids that were poured
directly onto the ground. Landfill operations ceased in  the mid-
1970s, and at that  time the landfill  was covered with  sand and
gravel.
  The site is located on a coastal plain and the area is generally
flat. The soil is mainly sandy and has a high permeability. The area
is underlain  by  two primary aquifers: (1) the Cohansey Sands
Aquifer, and (2) the Kirkwood  Aquifer. Both are aquifers used
for  private and public drinking water supplies. The Cohansey and
Kirkwood aquifers are divided by a thick clay layer that prevents
the  transfer of water between them. The Cohansey is  divided into
two zones, an upper and lower zone, that are both used for drink-
ing  water. The two  zones are divided by a thin, possibly discon-
tinuous layer of  clay that retards, but probably does not prevent,
the  movement from one level to the other.
  Groundwater  generally  flows northeast and east  toward the
ocean. Between  the site and the ocean lie  a number  of  privately
owned drinking  wells and the Atlantic City  Municipal Utilities
Authority (ACMUA) wellfield, which supplies drinking  water to
Atlantic City.
  The USEPA,  State of New Jersey and local agencies have all
conducted sampling  programs to determine the characteristics and
movement of the contaminant plume. The plume contains pollu-
tants such  as benzene, 1,2-dichloroethane, toluene,  vinyl chlor-
ide, phenol and bis (2-ethylhexyl) phthalate as well as several heavy
metals. Several private wells in the area of the landfill have been
closed, and the residents connected to the New Jersey Water Com-
pany (NJWCo) supply  system.  There is strong evidence that the
plume is moving toward the ACMUA wellfield.
OBJECTIVES

  There are two major objectives, a short term and a long term, to
be addressed in evaluating this site. Atlantic City has a seasonal
variation in the drinking water demand, and the demand increases
significantly in  the summer. Because residents were in imminent
danger, the short-term objective was  to ensure a  safe and ade-
quate supply of drinking water to Atlantic City for the summer of
1982 and until a long-term remedial action could be in place. The
long-term objective is to eliminate or mitigate any adverse effects
that contamination from the landfill will produce on the ACMUA
wellfield, on the NJWCo wells or on private wells in the area.
                                                   SHORT-TERM REMEDIAL ACTION

                                                   Contaminant Movement
                                                     The area between the landfill site and the  ACMUA wellfield
                                                   contains approximately 60 wells where the water quality has been
                                                   periodically sampled over the past few years. In addition, private
                                                   wells  in the area were sampled. The available data were entered
                                                   into a computer and sorted by contaminant, concentration, loca-
                                                   tion and sampling data in an effort to quantify the behavior of
                                                   the contaminant movement through the groundwater in this area.
                                                     Data analysis indicated the following major aspects of the con-
                                                   taminant movement:
                                                   •Contaminants generally move east  and east-northeast from the
                                                    landfill site.
                                                   •High concentrations of benzene and toluene are noted in the top
                                                    50 ft of the upper Cohansey Aquifer immediately downstream
                                                    of the landfill site. These organics  are known to be  biodegrad-
                                                    able, particularly in sandy aquifers,  and it appears that they may
                                                    be breaking down because they are not measured  in high concen-
                                                    trations as the distance from the source increases.
                                                   •Several  other, similarly non-conservative, contaminants were
                                                    noted in the region within 0.3 miles from the landfill. Highest
                                                    concentrations were typically noted in the immediate vicinity of
                                                    the landfill,  as expected, and they  decreased significantly with
                                                    distance. In addition, concentrations decreased with depth. Little
                                                    contamination  was noted  below the 50 ft depth at monitoring
                                                   wells.
                                                   •The  contaminant  1,2-trans-dichloroethylene  has also been de-
                                                    tected, almost reaching the production well AC-13.
                                                     The approximate locations of the production wells are shown in
                                                   Figure 1. Insufficient  field data exist to precisely determine the
                                                   rate of movement of the specific contaminants.  A three dimen-
                                                   sional groundwater  model was developed to predict the  general
                                                   movement of the entire contaminant  plume. This model used total
                                                   volatile organics  as  an indicator of  groundwater  contamination.
                                                   The following points relating to the potential contamination of the
                                                   ACMUA wellfield can be noted:
                                                   •Based upon modeling efforts, well AC-13 lies just beyond the
                                                    fringe of the contaminated  plume, and it should  not be returned
                                                    to service without wellhead treatment.
                                                   •Wells AC-2 and AC-4A, located in the upper zone, are likely to
                                                    be impacted within one to three years.
                                                   •Of the  lower Cohansey wells, well AC-9 is  nearest  the plume,
                                                    which is presently lying in  the upper Cohansey. It is likely that
                                                    this  plume will overlay the  location of well AC-9 in one to three
                                                    years. Based on the reported clay permeabilities,  we estimate that
                                                    it would take approximately 10 years for a contaminant to pene-
                                                    trate the clay layer that lies between the upper and lower Cohan-
                                                    sey.  Unless a hole exists in this clay layer, no immediate threat
                                                    to well AC-9 exists, provided that the well  casing  is properly
                                                    sealed.
358
CASE HISTORIES
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                                                                   ;KS>   ,.           '• i   ' '.'.'•'!''.j;;Vv""^N
                                                                      Vs.  *     Ahsornn   I".-... •'_'.' .','•'."''-   '      . >>
                                  '•  IACMUAUATER SUPPLY WAI'MCNI, PLANT
                                        '  ••".••    "
•Well AC-9 can be expected to be reached by the plume in one to
 three years. As with well AC-9, no immediate threat to this well
 exists, providing its casing is properly installed.
•All other wells should not be impacted by the plume in the next
 few years; these other wells are not threatened, unless some other
 contamination is present that has not been detected.
Short-Term Modifications
  Before the summer of 1982, several actions were taken to en-
sure a safe supply of water until long-term remedial actions were
evaluated.
  A water conservation program was initiated by Atlantic City.
This program was very successful, and the anticipated peak de-
mand during the summer of 1982 of 20 mgd. was never reached.
The actual peak demands were approximately 15 mgd.
  Piping  and  structural  modifications were  installed  at two
ACMUA  production  wells to accommodate portable,  truck-
mounted, granular activated carbon adsorption units. These units
could be used for well-head treatment in the event that contamina-
tion reached the upper Cohansey wells located near the water treat-
ment plant. After well-head treatment, the water would be treated
in the ACMUA plant.
  An interconnecting pipe was installed to allow Atlantic City to
receive  water from the NJWCo distribution system. This  water
would be  added directly to the ACMUA clearwell and could  be
used to augment ACMUA treatment capabilities.
  Plant piping modifications were installed to allow the ACMUA
to bypass the water treatment plant with the  Kirkwood Aquifer
supplies if the plant's hydraulic capacity became a limiting factor
in supplying  sufficient  quantities of  water to Atlantic  City. The
raw water quality of the Kirkwood Aquifer is sufficient to allow
discharge directly into the clearwell for chlorination only.

LONG-TERM REMEDIAL ACTION

Alternatives
  Using the results of  the three dimensional groundwater  model-
ing of the contaminated plume, several long-term alternatives were
     Figure 1
Well Location Map
  Price Landfill
         evaluated for feasibility, performance, cost and environmental ef-
         fects. These alternatives were divided into one of two main cate-
         gories.
           One category of alternatives includes the containment and treat-
         ment of the groundwater plume. Treatment options were evaluated
         as well as  the various methods of discharging the treated  water.
         For example,  the treated effluent could  be discharged to the
         groundwater, a surface water body, or, after little  or no pretreat-
         ment, to a municipal wastewater treatment plant.
           The other category of alternatives would not include cleanup of
         the plume; rather, it would relocate or provide alternatives for
         downstream receptors. Under this category,  various combinations
         of water supply options were investigated for Atlantic City. One of
         the options is to  relocate  the entire ACMUA wellfield to an area
         north of the surface water  reservoirs.  The environmental effects
         on private  well users in the area and on  the NJWCo wells are also
         a concern.
         Treatment Criteria

           At the time of this study, the USEPA had not established min-
         imum response  criteria to be used in the evaluation  of remedial
         actions at uncontrolled hazardous waste sites, like Price Land-
         fill. Additionally, safe drinking  water  standards  have not been
         established for most of the contaminants at the site. The USEPA
         and the NJDEP developed the following criteria to be used in eval-
         uating the remedial action alternatives for Price Landfill.
           The treated plume could be recharged into a contaminated por-
         tion of the aquifer, provided the discharge was part of an overall
         treatment  system. Treatment of  the plume was considered com-
         plete when the level  of volatile organic compounds in the ground-
         water at  the extraction  pumping site reached  100 /tg/1.  Con-
         currently,  monitoring wells  must be placed downstream of the
         pump site to ensure that  the entire plurne  is captured. The num-
         ber and location of the  monitoring wells  would be determined
         during the final design prior to applying for any required permits.
           The treated plume could be recharged into an  uncontaminated
         portion of the aquifer if  the level of volatile organic compounds
         was at or below 100 /tg/1.
                                                                                                  CASE HISTORIES
                                                                  359
-------
   The significant concentration of volatile organics in the plume
(benzene,  chlorobenzene, toluene, ethylbenzene, 1,2 dichloroeth-
ane,  chloroform, methylene chloride, etc.) must be reduced for
discharge  into  a  surface water.  Based on pilot studies, conven-
tional air  stripping treatment should produce an effluent  with a
volatile organic concentration of less than 100 /tg/1, which is the
concentration specified by the NJDEP for the protection of pub-
lic health. Therefore, an effluent with a volatile organics concen-
tration limit of 100 /ig/1, in conjunction with a total organic car-
bon limit of 50 mg/1 for correlation purposes, was designated as a
substitute  for BOD5 for the oxygen demand limitation. Petroleum
hydrocarbons and pH  were limited  to the standards of 15  mg/1
maximum and 6 to 9 range, respectively.

Pilot Plant Studies

   To determine the treatability of the contaminated groundwater,
a pilot plant was set up at a monitoring well to  evaluate the unit
processes of air stripping and granular activated carbon. The air to
water ratio was 80:1, with a total carbon depth of approximately 8
ft and an empty bed carbon contact time of 20 min. The results of
the pilot study  (Table  1) were favorable, and this type of a treat-
ment system was considered viable for the plume treatment alterna-
tives.
                                                           Evaluation of Alternatives
                                                              Originally, 17 different alternatives, including the no-action al-
                                                           ternative,  were considered  for the long-term remedial  action  at
                                                           Price Landfill. A preliminary evaluation was conducted to elim-
                                                           inate those alternatives that may have been  redundant  or might
                                                           have significant technical or health related limitations.
                                                              Ten  alternatives  were  evaluated  using a  present worth cost
                                                           analyses of both capital and operating and maintenance costs. In
                                                           addition, we also conducted non-cost analyses of reliability, feasi-
                                                           bility of implementation, operation and maintenance considera-
                                                           tions, environmental considerations and safety. The results of the
                                                           costs analyses are shown  on Table 2, and the results of the non-
                                                           cost analyses are shown on Table 3.
                                                           Recommendations
                                                             When  the  cost,  non-cost  and  environmental evaluations are
                                                           all considered, Alternative 13 and Alternative 14b give the best re-
                                                           sults. Alternative  13 involves relocating 13.5 mgd of ACMUA
                                                           water supply  capacity north of the reservoir with a 2 mgd plume
                                                           abatement well. Alternative 14b involves relocating 13.5 mgd north
                                                                Table 1
                                                 Water Quality Analysis—Pilot Plant Study
           EPA
               COMPOUNO(S) DETECTED
                          EPA
                       DETECTION
                         LIMIT
                          ug/1
                                             PRELIMINARY
                                                                    -DATE OF SAMPLING
     SAMPLING
 2-5-82    4-15-82   4-Z1-B2    4-22-82    4-30-82   5-5-8?    5-12-67    5-18-82   5-Z5-BZ
INFL  EFF  INFL  EFF  INFL  EFF  INFL  EFF  INFL  EFF  INFL  EFF  I NFL  EFF  INFL  EFF  1NFL  EFF
           65 A  phenol
           18 B  bis (2-chloroethyl) etherlO
           L'5 B  1,2-dlchlorobenzene
           26 B  1,3-dlchlorobenzene
           27 B  1,4-dlchlorobenzene
           54 B  Isophorone
           66 B  bis (2-ethy(henyl)phtha- 10
                 late
           69 B  dl-n-octyl phthai ate
           4 V  benzene
           7 V  chlorobenzene
           10 V  1,2-dlchloroethane
           11 V  1,1,1-trlchloroethane
           13 V  1,1-dlchloroethane
           38 V  ethylbenzene
           86 V  toluene
           88 V  vinyl chloride
                tetrahydroFuran
                dlethylether
                dllsopropylether
           102P  alpha-BHC
           111P  PCB-1260
                Aluminum
                Chromium
                Barium
                Beryllium
                Cadmium
                Cobalt
                Copper
               'Iron (rrg/1)
                Lead
                Nickel
                Manganese
                Zinc
                Boron
                Vanadium
               •Calcium  
-------
                   Table 2
            Price Landfill*Summary
             Present Worth Analysis
Alternative
 2   RELOCATE 13.5 HGD IN ICIRKWOOO
 "•   WELLS ON THE MAINLAND
 3   RELOCATE 13.5 NGO IN LOWER
     COHANSEV WELLS NORTH OF
     RESERVOIR
 7   WELLHEAD CARBON AND AIR
     STRIPPING TREATMENT
 8a  RELOCATE 6 MGD NORTH OF
     RESERVOIR IN LOWER COHANSEV
     7 HGD PLUHE ABATEMENT AND
     TREATMENT
 Rh  RELOCATE 6 HGD NORTH OF
     RESERVOIR IN LOWER COHANSEV
     2 MGD PLUHE ABATEMENT AND
     TREATMENT
10   SAME AS 84 WITH SLURRY WALL
     AROUND LANDFILL SITE AND
     TREATMENT
12   SLURRY WALL AROUND LANDFILL
     SITE WITH EXTRACTION PUMPING
     AND TREATMENT

13   RELOCATE 13.S HGD NORTH OF
     RESERVOIR -
     2 HGO PLUME ABATEMENT AND
     TREATHENT
14a  RELOCATE 13.5 HGD NORTH
     OF RESERVOIR -
     SLURRY WALL AROUND LANDFILL
     SITE WITH EXTRACTION PUMPING
14b  SAME AS 141 WITH 2 HGD
     PLUHE ABATEMENT AND
     TREATMENT
Nott:  Actull mlntenince pumping wll
     In th< slurry xill will list
     for in extended period of time
     it rtlltlvtly  loo pimping riti.
     For rtlitlvt cost co«P!rlson purposes
     only - I 5 ytir duritlon It i higher
     rite his been used.
Capital
Costs
4, ISO. 000
S. 070. 000
6.440.000
16.850.000
7. OSS, 000
20.22S.OOO
7,985,000
9.675.000
13. OSS. 000
I3.oeo.ooo
Annual
O&M
Costs
0
0
3.250.000
3.277,000'
967.000"
947.000
3.277.000'
(0)"
947,000'
(0)"
947.000
947,1)00-
0"
947.000
Present Worth
25 Year
4.168.000
5,039, ODD
35 .997 .ODD
25.092,000
15,620.000
25,253.000
9,111,000
18. 232,000
13.279.000
21.617,000
50 Year
4, 185.000
5.154.000
36.088.000
28,717,000
16.792.000
25,427.000
9,111,000
20,022.000
13,496,000
23,407.000
                                       yeirs 1 thru 5
                                       •fter ycir 5
of the reservoir, a 2 mgd plume abatement well and a slurry wall
around the landfill site. Both alternatives provide:
•An adequate drinking water supply for Atlantic City that should
 not be affected by the plume from Price Landfill
•Positive measures to control and remove the contaminated plume
•Positive measures to control the source at Price Landfill
  Several factors were considered when the final comparison of al-
ternatives was  made.  First, about 10  private residences are  near
the plume and are  not  connected  to a public water supply. If
the plume is not controlled and treated, about  100 to 200 private
residences could be affected. Second, the New Jersey Water Com-
pany's Well 3 is within a  mile to the south of Price Landfill. If the
plume is controlled,  it may impact this well in the future.  And
third, this study and  the groundwater model only addressed the
single source of contamination  from  the  Price Landfill. It is be-
lieved there  may be other sources of  contamination in the area.
These sources may change the contamination patterns in the aqui-
fer, and  the recommended action should  account for the  possi-
bility of other contaminant sources.
  The possibility of treating the contaminated plume at the Atlan-
tic County (ACUA) wastewater treatment plant should be  inves-
tigated. If treatability tests conducted on the waste show that the
ACUA plant can accept the waste, then the disposal charge would
be between $1100 and $1300 /mg, provided that the BOD/SS of
the waste is less than 250  mg/1. The net effect would be a decrease
of $2,000,000 in capital costs for the on-site treatment plant, but
the annual operating costs would essentially not change. A treat-
ability study will be conducted  to determine if the contaminated
groundwater can be accepted at the ACUA treatment plant.
  The final decision concerning the long-term remedial action for
the Price Landfill  site will be made by  the  USEPA,  and  the
NJDEP, with public comments taken into consideration.
                                                       Table 3
                                          Non-Cost Evaluation Criteria Matrix
ALTERNATIVES
10 - NO ACTION
11 . REPLACE LOST SUPPLIES
WITH (1RKUOOO WELLS
1) • REPLACE LOST SUPPLIES
WITH COHANSEY WELLS

17 . WELL HEAD TREATMENT

181- RELOCATE WELLS NORTH
OF RESERVOIR WITH 7 HGD
ABATEMENT PUMPING
lit- RELOCATE WELLS NORTH
OF RESERVOIR WITH 2 HGD
ABATEMENT PUMPING
•10- RELOCATE WELLS NORTH
OF RESERVOIR WITH 7 HGO
ABATEMENT PUMPING AND
SlURRY WALL

112- SLURRY WALL AND CAP
LANDFILL SITE

113- REPLACE LOST SUPPLIES
WITH COKANSEV WELLS
NORTH OF RESERVOIR WITH
2 HGD ABATEMENT PUMPING
I14i- RELOCATE WELLS NORTH
OF RESERVOIR WITH
SLURRY WALL
I14H-RELOCATE WELLS NORTH
OF RESERVOIR WITH
SLURRY WALL AND 2 HGD
ABATEHENT PUMPING
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                                                                                                         •ddltlvt ind should not bt totiltd.
                                                                                                0  I  LEGEND: •! SIGNIFICANT ADVANTAGE OVER

                                                                                                            OTHER ALTERNATIVES

                                                                                                           0 NO PARTICULAR ADVANTAGE

                                                                                                          -1 DISTINCT DISADVANTAGE
                                                                                                             COMPARED TO OTHER ALTERNATIVES
                                                                                                 CASE HISTORIES
                                                                361
-------
      THE APPLICATION  OF COMPUTER MODELS  TO THE
    EVALUATION OF  HAZARDOUS  WASTE  MANAGEMENT
OPTIONS  FOR UNCONTROLLED HAZARDOUS WASTE  SITES

                                          ROSALIE T.  MATTHEWS
                                 Matthews Consulting & Construction, Inc.
                                            Silver Spring, Maryland
 INTRODUCTION

   A model should provide the user with assistance in: (1) avoiding
 the unnecessary expenditure of funds; (2) mitigating the expen-
 diture of funds; and (3) providing a foundation for requesting addi-
 tional funding if necessary. In this regard, model utilization is ap-
 propriate in considering hazardous waste management options,
 either by an individual generating facility or by a regulatory agency
 developing a multiple facility hazardous waste management plan.
 The former may be  an uncontrolled hazardous waste  site from
 which hazardous materials may be generated on a continual or
 sporadic basis. Uncontrolled hazardous waste management sites
 may also  be  encompassed  in  a hazardous waste management
 regional plan.
   Hazardous  wastes sites  can be administered according  to
 statutory distinctions as delineated by the Resource Conservation
 and Recovery Act, or as defined by a host of other federal and state
 laws addressing the production and disposal of toxic materials or
 primary pollutants. However,  the generation and disposition of
 hazardous wastes occurred in many instances prior to the establish-
 ment of these statutory distinctions. Hazardous wastes can be pro-
 duced by product development, storage and delivery; by product
 obsolescence or aging; or by the storage, treatment and disposal of
 discarded materials. A model user need not distinguish statutorily
 the facility or site to be addressed. A site, controlled or  otherwise
 described,  can be considered in a model depending upon the needs
 of the model user. A model user must be able to provide the site
 specific data required by the particular model in order to consider
 the economic evaluation of management  options encompassing
 that particular site.
   Models can be advantageous in evaluating options which concur-
 rently manage waste streams from different type facilities and sites.
 For example, a generator may be responsible for managing produc-
 tion wastes, spill cleanup residues, wastes emanating from a closed
 landfill and for the removal of wastes placed in an off-site disposal
 facility.  Depending upon the capabilities and  capacity  of  the
 model(s) employed, the generator may consider options addressing
 one  or  several of these waste streams. Model utilization by a
 generator will be explored first and will be followed by a discussion
 of generation of a regional hazardous waste management plan via
 model utilization.

 ECONOMIC EVALUATION OF
 OPTIONS FOR GENERATORS

   The  Michigan  Department  of Commerce developed  several
 methodologies in order to determine whether or not  hazardous
                                                  waste  generating industries in the region would select resource
                                                  recovery. The Department's efforts included development of tech-
                                                  niques to project the  economic  effects of hazardous waste re-
                                                  quirements and to assess the potential for resource recovery. These
                                                  techniques were applied to three industries selected on the basis of
                                                  regional  economic  importance, employment  and potential  for
                                                  waste  stream recovery. The selected industries were  steel manu-
                                                  facturing, paint manufacturing and electroplating. The first step,
                                                  establishment of criteria for generator selection, addresses the size
                                                  and concentration  of the industry in  the region, waste  stream
                                                  volume and disposal methods employed  and the impacts of the
                                                  RCRA in the region. Consequently, the application of the criteria
                                                  to other regions may result in  the selection of other industries.
                                                  Paint Industry

                                                    The next step in the analysis process entails the characterization
                                                  of the nature of the industry selected (location, size, product
                                                  development and delivery) and its particular economic condition
                                                  and constraints. Approximately 30% of the paint manufacturing
                                                  industry is located  in the Great Lakes Basin region. Of the 540
                                                  plants, approximately 19% employ fewer than 50 individuals while
                                                  9% employ over 100. Total employment is approximately 25,000.
                                                  Overall,  the  number of paint  manufacturing plants has been
                                                  decreasing since the 1960's. This decrease is based on increasingly
                                                  restrictive fire and nuisance regulations rather than environmental
                                                  requirements. In addition, aging proprietorships have contributed
                                                  to the decline. The paint manufacturing industry generally  ex-
                                                  periences difficulty in  passing on the costs of hazardous waste
                                                  management. Historically, the industry has not been  able to pass
                                                  on increases in raw material costs; consequently, profits after taxes
                                                  as a per cent of sales are less than half of those for all manufactur-
                                                  ing  industries. The high level  of  product  substitution  (e.g.,
                                                  wallpaper,  plastics, glass and  paneling) is a major reason for this
                                                  constraint.
                                                    The paint manufacturing industry currently utilizes recovery,
                                                  treatment and disposal including secure landfill. Overall, the paint
                                                  manufacturing industry generates 112 primary pollutants that are
                                                  regulated as hazardous wastes under RCRA. Total waste genera-
                                                  tion in the region is 41,060 tons annually.

                                                  Electroplating

                                                    The electroplating industry encompasses motor vehicle, elec-
                                                  tronic component manufacture, blast furnace and steel mill opera-
                                                  tion, radio and television equipment and screw machine produc-
                                                  tion. The industry is composed of predominantly small enterprise*.
 362
COST
-------
Approximately half of the electroplating industry is located in the
Great Lakes Basin region with 40% of all plants in Michigan, Ohio,
Illinois and Pennsylvania.
  This industry generates approximately 80,000 metric tonnes of
hazardous wastes per year in the region. The generated wastes vary
in nature and composition and include water treatment sludges,
process wastes, degreaser sludges, salt precipitates and metal clean-
ing wastes.
Steel Industry

  The steel industry is predominantly comprised of large firms with
high employment levels depending upon market requirements. Ap-
proximately 60% of all steel plants are located in this region and are
concentrated  in Pennsylvania, Ohio, Illinois and Indiana.  In this
region, the steel industry generates substantial volumes of hazar-
dous wastes. Projected generation volumes for 1983 in metric ton-
nes,   dry  weight  are:  sludge,  996,000;  dust,  300,000;  scale,
1,000,000; and pickle liquor, 167,000. Recovery of ferric chloride,
hydrochloric acid and ferric oxide from waste pickle liquors is cur-
rently underway.
  Trade association reports cite  the steel industry's difficulty in
capital accumulation which is aggravated by environmental control
costs. The American  Iron and Steel Institute estimates that en-
vironmental control costs account for approximately 18% of the
industry's total  capital requirements.  Of  that amount, approx-
imately 16%  of costs  are associated with solid waste management
including hazardous waste management.

Discussion

   In sum, the Michigan Department of Commerce identified three
industries (steel, paint manufacturing and electroplating) that were
(1) concentrated in the Great Lakes Basin region; (2) responsible
for substantial employment in the region; (3) experiencing cost con-
straints in either cost pass-through or capital accumulation; (4) pay-
ing for increasingly  more expensive  disposal options; and (5)
generating significant  volumes of hazardous wastes  of  varying
nature.

Waste Management Costs
  A review of the total monetary costs of hazardous waste manage-
ment regulations is the next step in the economic analysis process.
The cost of storage, treatment and disposal is  a concern for those
responsible for the disposition of wastes generated by removal of
wastes from non-process sources as well as from on-going produc-
tion activities.
  The first question addressed  was whether or not costs,  such as
closure and post-closure costs and liability insurance requirements,
were  uniform for all  types of treatment,  storage and disposal
facilities  (TSDF). The Department  estimated that such costs
associated with land disposal and deep well injection should be dif-
ferent than those for incineration and treatment facilities. The lat-
ter need  only meet closure and  liability insurance requirements.
Data  accumulated supported the  prediction that costs for closure
and post-closure for an average (200 acres) landfill would be ap-
proximately $2.5M and $75,000  for liability insurance coverage;
costs  for closure and post-closure for deep well injection facilities
would be $2M and $60,000 for liability insurance coverage. Closure
costs  for incineration facilities  ranged from $10,000 to $200,000
and $50,000 for liability insurance coverage. The accumulation of
these  data may be applicable in a generic approach to  developing
model scenarios.
  The relationship between regulatory costs and the tons per day of
hazardous wastes handled by the TSDF was not demonstrated.
However, closure and post-closure costs were determined to be af-
fected by the size of the facility. The insurance carrier's estimation
of risk determined the cost of liability coverage.
  In order to determine charges to firms utilizing TSDFs, operators
of the latter were requested to estimate costs not only of closure,
post-closure and insurance, but  also annual paperwork costs, addi-
tional annual costs of personnel (field and administrative), cost for
emergency equipment and other annual payments, if required. The
anticipated incremental cost of compliance per gallon was deter-
mined for each disposal option of average .size for that option.

                            Table 1
       Disposal Option Costs per Gallon—Pre- and Posl-RCRA
Disposal
Option
Deep well
 injection
Landfill
Incineration
Treatment
   INCREMENTAL COST OF COMPLIANCE
Pre-RCRA    Anticipated   Actual       Posl-RCRA
Charge
26*
40«
43«
1C

8«

2«
3«
                        3t
                        4
-------
wastestream; interest rate; steam cost per million BTU;  time be-
tween anion  regeneration; time between cation regeneration; tax
incentive; and water cost.
  The waste  streams included chromium, cyanide and acid-alkali.
The waste processes considered are chromium reduction, cyanide
oxidation, physical/chemical treatment, sludge dewatering  and
storage.
  The disposal options  considered  are conventional treatment
without  any flow  reduction, conventional  treatment  with flow
reduction, incorporation  of ion  exchange process  for  metal
recovery,  incorporation  of an  evaporative process  for  metal
recovery, and incorporation of electrodialysis for metal recovery.
The 12 cases considered are shown in Table 2.

                             Table 2
               List of Cases, Hazardous Waste Treatment
                     Alternative Analysis Model
Case
Disposal
Trans-
Costs/gal porta-


1
2


$ .25
.25
lion/
miles
100
100
CRFi*
Interest
Rate %



Years




metal
CFRj*
Interest
Rate %


Years




and treatment chemical costs are
doubled
3
4
5
6
7
8
9
10
11
.50
.50
3.00
.25
.25
.25
.25
.25
.25
25
500
75
100
100
100
100
100
100



15
15
15
20
10




20
20
20
20
20
total



7
12
10
10
10



20
15
10
10
20
annual costs of wastewater treat-
 12
          .25
               100
ment—10% resource recovery credit
investment tax credit based on 25% of
total capital costs for plants with resource
recovery
 *CRF| Capital Recovery Factor, conventional treatment methods
 ••CRF2 Capital Recovery Factor, resource recovery processes
   The Hazardous Waste Treatment Alternative Analysis Model
was applied to 24 facilities in the Cleveland, Ohio and Milwaukee,
Wisconsin areas.  These  facilities  had varying input  values  for
wastewater flows, metal values within waste streams, potential for
flow  reduction and waste streams generated. The  results of the
model application are shown in Table 3.
   The following conditions were shown to have a positive impact
on the utilization of resource recovery  by electroplating facilities:
(1) rapid increase in plating metal costs and treatment chemical
costs as compared  to other costs;  (2)  rapid increase in waste
disposal costs in comparison to other costs; (3) favorable difference
in financing resource  recovery equipment;  and (4)  substantial in
vestment tax  credit  deductable from total capital costs upon in-
stallation of resource recovery equipment.
   Conditions which had little or  no positive effect on  resource
recovery selection were:  (1) unfavorable difference in financing
resource recovery equipment; (2) implementing a modest resource
recovery credit; and (3) an increase in the price of disposal offset by
a decrease in distance  to the disposal site.

PRODUCTION OF AN OPTIMAL
HAZARDOUS WASTE MANAGEMENT PLAN

   The Resource Recovery Planning Model (RRPlan) developed by
the National Bureau of Standards, U.S. Department of Commerce
and Edward B. Berman Associates, Inc., can be utilized to: (1) gen-
erate an optimal  solid waste  management  plan;  (2)  evaluate  a
specified plan for its  technical and economic feasibility; and (3)
provide guidance in reaching a decision by completing a series of
what-if questions. The RRPlan provides the user with a configura-
tion of facility locations,  process to be employed at each location
                                    and outputs at each  facility; transportation  network  and costs;
                                    direction of tonnages through the network to assigned facilities
                                    with  residue to  disposal  sites or secondary  markets;  and total
                                    system costs including cost per ton throughput at each faculty and
                                    cost per ton disposed.
                                       The user can direct the model to select an option which (1) mini-
                                    mizes the lifetime costs  of  the  regional plan;  (2) minimizes the
                                    lifetime discounted costs of the regional plan; (3) maximizes the net
                                    energy balance of the  regional  plan; (4)  considers  a weighted
                                    cost/energy composite; and (5) considers a specified regional plan.
                                    Source separation options can be exercised to provide the user with
                                    the means to assess the trade-offs in the cost of material sorting at a
                                    source versus a centralized location, or between the recovery of the
                                    material versus its energy value.

                                                                Table 3
                                               Number of Plants Utilizing Resource Recovery
                                                   Under Each Case and the Average  Cost
Case No.
1
2
3
4
5
6
7
8
9
10
11
12
No. of Plants
2
12
4
5
11
9
3
2
9
5
4
9
Average Cost
$141,763
81,826
101,924
104,900
79,732
82,774
142,182
171,338
91,721
88,426
145,068
83,763
                                       The RRPlan model  user supplies basic  information on: trans-
                                    portation distance and costs; facility construction, operation and
                                    maintenance  costs;  labor  costs;  disposal  costs  and  capacity
                                    availability; and market information. While this model is data-
                                    intensive, the user will find that similar data is required for utiliza-
                                    tion of  other models  such as the Hazardous  Waste Treatment
                                    Alternative Analysis Model and, hence, the effort can be produc-
                                    tive and helpful in assuring data consistency. In order to facilitate
                                    data acquisition, worksheets have been developed. A worksheet for
                                    site data requires information on:
                                     1. a. Name of this site .
                                       b. Number of this site _
                                     2. Depth of tracing requested.

                                     3. Location of this site	

                                     4. Incoming commodity	
                                       Site preparation information:
                                       a. Cost category for site preparation

                                       b. Total site preparation costs 	
                                       c. Energy category for site preparation

                                       d. Total energy required for site preparation

                                     6. Capacity considerations:
                                       a. Is the site capacitated?  	
                                       b. Is landfill possible at the site?
                                       The magnitude of the data to be acquired as well as the overall
                                     dimensions  of the  source-transport-process-market  solution fe
                                     shown in Table 4.
                                       RRPlan employs a fixed charge linear programming algorithm
                                     with a forcing procedure in order to assure that the model passe
                                     over an area of temporarily increasing cost in the solution domain
                                     to find the true optimum or preferred regional plan.  The model
                                     sites and sizes solid waste processing facilities by firfl appro*
 364
          COST
-------
                           Table 4
                Allowable Number of Key Variables
Key Variable
Waste sources
Sites
Processes*
Segments per process
Output coefficients**
Site-process combinations
Landfillst
Markets*
Segments per market
Transportation activities
Min. Value
1
1
2
1
0
1
0
0
1
1
Max. Value
60
50
30
3
7
80
30
30
5.
300
•First process in municipal solid waste plan must be a new transfer station
"By-products of processing
fThere must be at least one landfill for each location at which a land-using process is offered
{There must be at least one market if source separation is offered
imating non-linearities in the capital and operating cost functions
with up to three linear segments. Each segment has a fixed charge
(intercept), and incremental cost associated with increased process-
ing activities (slope). The assumption is made that only site-specific
or site-process specific cost functions have fixed charges. The cost
functions associated with transportation activities (e.g., source-to-
site shipments) consist only of variable  costs.
  In summary, RRPlan provides the user with a preferred regional
plan encompassing a complete characterization of each component
(sources,  sites, processes, transport  routes and  markets),  or  an
evaluation of a specified  regional plan. The model user can com-
pare the costs of the optimum to the specified (constrained) solu-
tion in order to ascertain the premium imposed.

SUMMARY
  The Hazardous  Waste Treatment Alternative Analysis Model
determines the optimum  economic hazardous waste management
option for an individual hazardous  waste generating facility. In
contrast,   RRPlan  determines an optimal regional solid  waste
management plan encompassing multiple facilities which  generate,
process and receive both marketable and non-marketable residuals.
Models, such as those discussed herein, may be helpful in achieving
a hazardous waste management program addressing all phases of
waste generation and disposition which provide  for the minimiza-
tion of costs to the generator while maximizing the efficient use of
existing or planned environmentally acceptable management op-
tions. For example, models can be directed to  address not only the
technical feasibility of waste consolidation regardless of source, but
also the economic advantages. Models cannot  change the facts but
may be employed to arrange them in a comprehensive fashion so
that various  parties can communicate in an orderly process.
  Under  Section 3006 of RCRA, states are developing  statewide
hazardous waste management plans  which must provide for the
management of wastes generated, stored, treated and disposed of
within the state. State programs must also support the tracking of
hazardous wastes via the manifest system. Under Section 3012 of
RCRA, each state will undertake an effort to compile, publish and
provide to the USEPA an inventory of sites in which hazardous
wastes have at any time been stored or disposed.
  Models may be useful tools in achieving these administrative and
planning requirements. The data accumulated under Section 3006
of RCRA and compiled under Section 3012 of RCRA can be util-
ized to fulfill  model  data requirements. Models,  such as  the
RRPlan, may be used  to  assist the state  regulatory agencies in
developing intra- and inter-state hazardous waste management net-
works. This model may be used in tandem with other models, such
as  the  Hazardous Waste  Management  Treatment Alternative
Analysis Model, to provide a common foundation for discussion of
specific regulatory  requirements or cleanup activities  with  in-
terested parties. The interested parties and the regulatory agency
can concurrently consider  actions which not only meet statutory
goals but also are affordable least cost options.
  Model utilization may enhance the discussion of the concept of
developing a degree of  hazard program. Waste characterizations
and management options serve as the foundation to any degree of
hazard program. Waste management options include a full range of
selections from waste reduction techniques (source segregation or
separation,  process modification,  end-product substituting  and
material  recovery/recycling);  combination  of  pretreatment
methods; to final disposition (deep well injection,  landfilling and
ocean disposal).
  An integrated degree of hazard approach, according to the Of-
fice of Technology Assessment, includes:
•Consideration of degrees of hazard and risk in relation to waste
 and management practices
•Assessment of the potential to reduce either the amount  or hazard
 level of hazardous waste through the use of appropriate tech-
 nology
•Development of effective  designs for monitoring strategies at all
 types of facilities
•A means for addressing severe public opposition to siting of new
 hazardous waste facilities  by  providing a technically sound basis
 for evaluating management proposals.
  However, technical and  administrative development should be
accompanied by economic analysis.  Should  the total regulatory
costs of compliance (such as those cited in the Hazardous Waste
Treatment Alternative Analysis Model) remain level while  the
volume of hazardous wastes received by selected management op-
tions be reduced under a specific degree of hazard approach, then
unwelcomed distortions in disposal practices may occur. The latter
may include the proliferation of uncontrolled sites rather than  the
reduction or elimination of such options. Models can be utilized to
predict and, thereby, perhaps forestall such an outcome.
REFERENCES
1.  Michigan Department of Commerce, "Hazardous Waste Management
   in the Great Lakes Region: Opportunities for Economic Development
   and Resource1 Recovery," U.S. Department of Commerce, Washington,
   D.C., September 1982.
2.  Chapman, R.E. and Herman, E.B., "The  Resource Recovery Plan-
   ning Model: A New Tool  for Solid Waste Management," U.S.  De-
   partment of Commerce, Washington, D.C., July 1983.
3.  Office of Technology Assessment, "Technologies and Management
   Strategies for  Hazardous Waste Control," Washington, D.C., March
   1983.
                                                                                                               COST
                                                           365
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                   THE IMPACT OF LIMITED COMPETITION
                    ON REMOVAL PROJECT COST BUDGETS

                                        GREGORY A. VANDERLAAN
                                United States Environmental Protection Agency
                                                 Chicago, Illinois
INTRODUCTION

  As an  administrative  funding category  developed under the
authority of the Comprehensive Environmental Response Com-
pensation and Liability Act of 1980 (CERCLA), planned removals
have been used primarily to achieve a necessary level of cleanup at
sites not on  the National Priorities List.1 Planned removals are
funded and  administered through the  immediate removal pro-
visions of CERCLA and,  because they are categorized  as "re-
movals", their  scope and duration are limited  according to the
terms  of the statute itself.1 Current USEPA policy requires that
states contribute funds toward the costs associated with project im-
plementation.
  Early in the CERCLA program development, it was important
to have a funding mechanism  available that allowed the Agency
to address uncontrolled  sites that were neither on the National
Priorities List (NPL) nor emergencies requiring immediate action.
As administrative policies change and the program matures, it is
becoming increasingly clear that an additional benefit associated
with planned removals has been the limited procurement  process.
Generally, conditions at  these  sites provide USEPA with enough
time to undertake a limited procurement process which normally
requires 45 to 90 days to complete (a full scale competitive pro-
curement may take 6 to 9 months to complete).
  The  procurement process associated  with a planned  removal
allows for a limited level of competition. Theoretically, the intro-
duction of competition will result in lower costs for those aspects
of cleanup involving onsite, transportation and disposal activities.
When the concept of limited  competition was  first introduced,
there appeared to be a noticeable decrease in project costs3; how-
ever, no evaluation has  been performed to demonstrate the ac-
tual impact the process has on project costs.
  During 1982, USEPA Region V completed a number of immed-
iate and planned removal projects. The  range of activities under-
taken at selected projects allows a comparison to be made of the
costs incurred under either an  immediate or planned removal ac-
tion. Specific categories for comparison have been identified to in-
clude contaminated soil, crushed drums, aqueous waste and waste
liquids  disposal.  Unit prices for these categories have been devel-
oped by evaluating their respective disposal costs. A comparison of
these unit prices  provides the basis for evaluation of costs so that
a general assessment can  be made regarding expected cost savings
associated with planned removals.

BACKGROUND

  Early in 1983, cost summaries were prepared for selected sites
in Region  V where immediate or planned removal projects had
                                                   been completed.4 The cost data summarized in this report involved
                                                   the sites listed below.
                                                   Immediate Removals
                                                   Anaconda Road Site, Akron, Ohio.
                                                     There was the abandonment in a highly populated area of Akron
                                                   of two stationary holding tanks  containing flammable  organic
                                                   materials and one tank truck trailer containing flammable organ-
                                                   ic materials with a corrosive water layer. Analyses of samples taken
                                                   from the tanks indicated that the material was flammable and cor-
                                                   rosive. An immediate  removal action was necessary to  prevent
                                                   immediate and significant  risk to the affected population  from
                                                   potential contamination of a drinking water  supply and potential
                                                   for a fire at the site.
                                                   Chem Dyne Site, Hamilton, Ohio.
                                                     The company failed to meet a  court ordered  waste reduction
                                                   schedule, was closed and placed in the control of a court appointed
                                                   receiver to utilize corporate assets to achieve site cleanup. The com-
                                                   pany was used as a waste transfer and storage facility and  handled
                                                   a wide variety of wastes including  pesticides, chlorinated  com-
                                                   pounds,  polychlorinated biphenyls (PCBs),  acids  and solvents.
                                                   Previous spills from the site had resulted in massive fish kills in a
                                                   nearby river. An immediate removal was necessary to  prevent
                                                   future discharges to this river and stabilize several  bulk storage
                                                   vessels.
                                                   Isanti Sites, Isanti, Minnesota.

                                                     Four separate problem locations developed as a result of the
                                                   local operations of a solvent recycling business.  Drums stored in
                                                   semi-trailers on the site surface and more than 800 buried drums all
                                                   contained product grade solvents. Three of the four sites were in
                                                   close proximity to a National Wild and Scenic River.  Preliminary
                                                   sampling indicated groundwater flow was toward the river. Because
                                                   many of the surface storage areas were directly  adjacent to resi-
                                                   dences, an immediate removal was necessary to prevent the threat
                                                   of fire, explosion or contact with those who lived nearby.
                                                   Planned Removals
                                                   Midco I Site, Gary, Indiana.
                                                     Several thousand  drums containing materials such as paint
                                                   sludge, solvents, acids, caustics and cyanides were left on-site sub-
                                                   sequent to a fire that halted reclaiming and recycling operations.
                                                   The site was located in a lowland area adjacent to wetlands and
366
COST
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commercial establishments. During intense storms, a nearby resi-
dential area was often inundated with flood waters including run-
off from the site.  Preliminary studies of the area indicated con-
tamination of surface water, groundwater and soils. A planned re-
moval Nvas necessary to remove the drums and contaminated soils
based on the threat of fire and explosion, human contact and run-
off into nearby wetlands.

Laskin/Poplar Waste Oil, Jefferson, Ohio.

  The  site was an abandoned waste oil recovery operation with
ponds and bulk storage vessels containing high levels of PCBs and
lesser amounts of phenols  and other organic solvents. The storage
vessels and ponds  posed a threat of contaminated overflow  and
leachate to Cemetary Creek adjacent to the site. This creek  is a
tributary of the Grand River which is a drinking water source for
Astabula County.  A planned removal was  necessary to eliminate
the threat posed by the storage vessels and large lagoons containing
PCB-contaminated waste oil.

COST CATEGORIES

  Common tasks on which to base development of cost categories
for purposes  of comparison were more difficult to identify than
anticipated. The scope of  activities necessary to  complete the de-
fined tasks for the projects discussed above varied considerably.
Their diversity, however, is representative of any given group of
sites in the industrial regions of the country.
  Because the cost data were not consistent from one site to the
next, a comparative  analysis for total project costs incurred  was
not possible. Instead, several common activities were identified for
more than one site  and, in some cases, for immediate and planned
removals. Common tasks and the site where they were undertaken
are shown in Table 1. A review of these data indicates that each
category of activity is broad and very general, so much so that addi-
tional detail must be sought in order to make a valid comparison of
their respective costs.
  Prominent  factors that ostensibly affect a unitized disposal cost
for any of the categories of activities shown in Table 1, are con-
taminants, contaminant concentration and amount of material.
The major contaminants found within these general categories and
descriptions of the  ultimate method of disposal are shown in Table
2.
  Upon closely examining the specific waste  characteristics asso-
ciated with the categories of activities, it becomes clear that there
are few commonalities on which to base a fair comparison. Of the
six categories in Table 1,  four can be considered as having had sim-
ilar disposal approaches. These four categories represent activities
conducted at immediate and planned removal projects. The unit
price for the  specific disposal method used for each site and the
highest concentration of notable contaminants are given in Table 3.
For two of these categories, the planned removal project incurred
considerably less cost on a unit basis. The unit  prices shown in
Table 3 are for disposal costs only. They include no personnel, ma-
terials or transportation  costs incurred by contractors at the sites
under discussion.
  In the crushed drum category for Midco I, the residual materials
remaining in  many of the drums  required classification of that
waste stream as a hazardous waste. This is a provision of the  Re-
source  Conservation  and Recovery Act regulations under 40 CFR
261.7.s The crushed drums at Isanti, however, were suspected of
PCB contamination. Although PCB is not a  regulated substance
under RCRA and, therefore, not  subject to the waste residuals
provisions of  40 CFR 261.7, disposal of PCB articles is governed
under regulations promulgated pursuant to the Toxic Substances
Control Act.6 These regulations required the crushed drums from
Isanti to be disposed of as PCB articles.
  The category of contaminated soils also shows a considerable
unit price cost difference between an immediate  and planned re-
moval project. The disposal option employed for these projects
                        Table 1
Common Tasks Associated with Immediate and Planned Removals
                       CrnM
                        Dnm
      SWf«
Wnu
 Oi
Anaconda. (1)
Akron, Ohio
Cham Dyn«, (1)
Hamilton, Ohio
laantl. (1)
Isanti County.
Minn. iota
Laikln'a. (P)
JaHanon. Ohio
Mldco 1. (P)
Gary, Indiana
•



•


•

•
•

•

•

•

•
•
•
•
•



•

•

(IMmmedlete Remove!
(P)-Plenned Remove)
                        Table!
         Activity Categories and Methods of Disposal
                       MAJOR
                       CONTAMINANTS
DISPOSAL/
TREATMENT
WASTE OIL
Cham Dyne. (1)
Hamilton, Ohio
Laskin's. (P)
Jefferson, Ohio
Pesticide and
Solvents
Polychlorinatad
Biphenyls (PCB)
Lead
Incineration
Incineration
CRUSHED DRUMS
Isanti, (1)
leant) County Minn
Midco I,(P)
Gary. Indiana
PCB Residuals
Residuals
Landfill
Landfill
CONTAMINATED SOIL
Anaconda, (t)
Akron, Ohio
Midco 1, (P)
Gary, Indiana
Cyanide
Lead and PCB
Landfill
Landfill
LIQUIDS
Anaconda, (1)
Akron, Ohio
Ishanti, (1)
Isanti County, Minn
Midco 1, (PI
Gary, Indiana
Cyanide,
Low Flash
Chlorinated Solvents
Non-Chlorineted
Solvent*
Waste Solvents
Treatment
Recycle
Incineration
AQUEOUS WASTES
Cham-Dyne, (1)
Hamilton. Ohio
Laskin's, (P)
Jefferson, Ohio
Midco 1, (P)
Gary, Indiana
Pesticides, PCB
PCB. Phenols
Metals, Flourides
Carbon
Adsorption
Carbon
Adsorption
Treatment/
Landfill
SLUDGES
Anaconda, (1)
Akron, Ohio
Cham-Dyne, (1)
Hamilton, Ohio
Isanti, (1)
Isanti, County.
Cyanide,
Low Flash
Pesticides
PCB
Solvents
Paint Wastes
Treatment and
Landfill
Landfill
Treatment/
Incineration
                                                                                                               COST
                                                       367
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was landfilling. While there was no prominent contaminant anal-
agous to cyanide found in the Midco I soils, soils from both Isanti
and Midco I were classified as hazardous under the provisions of
40 CFR 261.3. That is, a material becomes hazardous if contam-
inated by a listed waste or any mixture of a listed waste.

                            Table 3
              Unit Price for Certain Activity Categories
                                  CONTAMINANT
                                  CONCENTRATION
Crushad
Druma
Contaminated
Soils
Aquaoua
Wastal
Liquid!
(Wast*
Solvants)
Isanti (1)
Midco 1. (P)
Anaconda. (1)
Midco 1. |P)
Cham
Dyna. H)
Laskin-s, |P)
Midco 1. (P)
Anaconda. ID
(•ami, |l)
Midco 1. IP)
11S yards3
•.MOyard3
3» yards3
7,220 y»rd.3
35,837
Billons
430.OOO
gallons
131,300
gallons
2,737
gallons
3.200
gallons
1.SOO
gallons
PCB
Rnidu.ll

Cy»nid«
303 ppm
La»d 1170 ppm
PCB 12 ppm
Chlordana 416 ppm
Tohrana 4300 ppm
PCB SS ppb
Phanols 1 1 ppm
Mstals ^ 5 ppm
Flourlda 23« ppm
Cyanlda and
Low Flash
Chlorlnatod
Wast* Solvants
Wasta Solvents
•47-58/yard
• 17.02/yard3
S40.OO/ysrd3
• 17.O2/yard3
M.SO/gallon
•O.IS/gallon
•0^7/gallon
•0.90/gallon
•0.145/gallon
•0-27/gallon
   The aqueous phase category shown in Table 3 compares water
 treatment activities at three sites.  The need for water treatment
 at these sites was satisfied through  immediate removal contracting
 provisions. The contaminants of concern and their concentrations
 vary considerably. The treatment system used  at Laskin is owned
 by USEPA and  operated by a contractor under a cost plus fixed
 fee type contract.
   The final category compared  in Table 3 addresses disposal of
 liquids at two immediate removal projects and  one planned re-
 moval. Although the methods of treatment are not  directly com-
 parable,  the costs associated with them provide an insight into the
 effect that recycling could have on overall project costs.

 COST COMPARISONS
   In order to determine the effectiveness of limited competition
 on removal project cost budgets,  it was necessary to review the past
 costs incurred at both immediate and  planned removal projects.
 This review was  necessary so that an accurate basis of comparison
 could be developed. General task categories were first developed
 for activities common to more than one site. A  detailed review was
 then undertaken for site specific information associated with that
 particular project to determine  if  those specifics could have af-
 fected the cost. When this activity was completed, it was concluded
 that the  most accurate basis for a  project by project comparison
 would be disposal  cost. Other cost centers, such as equipment,
 labor and material, were found to be  highly site  specific and
 such specificity would preclude an accurate comparison.
   It came as no surprise to discover the diversity of disposal op-
 tions used during cleanup operations. This diversity is directly pro-
 portional to that associated with waste materials on site. Type of
 waste or  material contaminant and its concentration appeared to be
 a major factor in determining disposal option and price. From the
 four categories in Table 3  that were subjected to the detailed re-
 view, only contaminated soils could legitimately be used as a valid
 basis of comparison.
   It is interesting to note the prices paid in the three other cate-
 gories in order to highlight the prominent cost factors associated
 with that particular disposal option. In the crushed drum category,
 unit prices were developed for Isanti, an immediate  removal, and
 Midco I, a planned  removal. Part of the waste stream from Midco
 possibly  could have been handled under the residual provisions of
                                                       RCRA. However, due to economies associated with labor, equip-
                                                       ment and transportation, all shipments were chosen to be mani-
                                                       fested as a hazardous waste. The crushed drums from the Isanti
                                                       site contained PCB contaminated  liquids prior to pumping. Be-
                                                       cause of this, they had to be handled and disposed of according to
                                                       regulatory procedures under the Toxic Substances Control Act (40
                                                       CFR 761). As a result of compliance with this requirement, the
                                                       price difference between crushed drum disposal costs for Isanti and
                                                       Midco  cannot be compared for the purposes of determining the
                                                       impact of limited competition. The three fold increase in cost can
                                                       possibly be explained on the basis  of disposal requirements asso-
                                                       ciated with PCB articles.
                                                         The  aqueous phase category compares three projects that re-
                                                       quired treatment of contaminated water found on site either before
                                                       cleanup started or after cleanup was underway. The Chem-Dyne
                                                       effort involved transport of materials to the contractor's carbon
                                                       adsorption treatment unit to remove  high levels of solvents and
                                                       pesticides from water before discharging to the local sanitary sewer
                                                       system.  This was done under an emergency contract and included
                                                       sand filtration prior to adsorption.
                                                         At Midco I, run-off water generated from storms was collected
                                                       and transported to the contractor's treatment system where it was
                                                       subjected to a series of physical treatment processes including pH
                                                       adjustment and clarification to remove metals and florides. Solids
                                                       were thickened, solidified and placed  in a hazardous waste land-
                                                       fill. Treated water  was discharged to the local sanitary sewer sys-
                                                       tem. Although Midco I was contracted  through  limited compe-
                                                       tition, this aspect of work  was performed under  a special emer-
                                                       gency contract.
                                                         The treatment activities at Laskin involved use of the USEPA's
                                                       mobile carbon adsorption system to remove PCB and phenols from
                                                       ponded  water. The water was  filtered, treated and discharged to
                                                       a nearby stream according to  state established  standards. Solids
                                                       generated during filtration  were removed with the system;  spent
                                                       carbon was left on-site.
                                                         These three projects and the  costs generated for this category of
                                                       work also cannot be compared fairly for the purpose of determin-
                                                       ing the  impact of limited competition on overall project budget.
                                                       The unit price at Laskin, a planned removal, reflects the use of a
                                                       system  that  is subsidized by government funding for operations
                                                       and maintenance costs. Personnel costs are also subsidized through
                                                       a long  term government contract.  The costs associated with the
                                                       two immediate projects, Chem-Dyne and Midco I, reflect consider-
                                                       ably different  treatment  schemes for  widely  divergent waste
                                                       streams. The cost associated with the Midco I project most likely
                                                       reflects a very advantageous government negotiating position. This
                                                       cost could have been higher if the Agency and contractor had not
                                                       already  been involved together, undertaking other cleanup activ-
                                                       ities at the site. The author believes  this allowed the USEPA to
                                                       negotiate very effectively a fair price  for the immediate  removal
                                                       work associated with storm water run-off at the Midco I site.
                                                         In the liquid waste category, direct and fair  cost comparisons
                                                       could not be  made  between immediate and planned removals.
                                                       Nevertheless, the information in Table 3 does give one an idea of
                                                       the potential cost impact associated  with the recycling alternative to
                                                       disposal. The material from Isanti was "disposed of by being sub-
                                                       jected to a recycling process. The  cost of this effort, performed
                                                       under an immediate removal time and materials contract, was al-
                                                       most half of that associated with the incineration alternative used
                                                       at Midco I. The incineration alternative used at Midco I was pro-
                                                       cured through the limited competitive  process associated with
                                                       planned removals.  The contaminated liquid waste stream at Ana-
                                                       conda involved a treatment scheme to reduce the cyanide and in-
                                                       crease the flash point. As in other unit costs categories, this process
                                                       could not be compared to Isanti or  Midco I because of the obvious
                                                       dissimilarities in waste stream and treatment process.
                                                         The contaminated soils category provides data on which to make
                                                       an accurate unit cost comparison. The contaminated soils from
                                                       both projects were loaded and iandfilled in bulk  and manifested as
 368
COST
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a hazardous waste solid, not otherwise specified. Costs associated
with the cyanide contaminated soild from Anaconda were approx-
imately two and one-half times those for the lead and PCB con-
taminated soils from Midco I. The author is reluctant, however,
to attribute this entire cost differential to limited competition.
Although there were no special handling or treatment provisions
necessary to minimize the reactivity of the cyanide contaminated
soils, the landfill operator may have perceived additional long term
risks associated with this material, requiring purchase of special in-
surance provisions.  Another explanation for at least  part of the
cost differential may be due to the quantities involved. The quan-
tity of material shipped from Midco I was considerably greater
than that shipped from Anaconda. Basing unit prices on quantity
is a common practice in the waste disposal industry.

CONCLUSIONS

  Based on the above review of the  immediate and planned re-
moval projects completed in Region  5, it  is difficult to make a
definitive statement regarding the impact of limited competition
on  removal project cost  budgets. Activity categories, types and
amounts of waste materials, characteristics of waste materials and
disposal options vary considerably from one site  to the next. Al-
though the limited data generated  during this effort do not provide
conclusive  results regarding cost  savings associated with planned
removals, they do indicate, in general, that planned removals can
be more cost effective. This cost effectiveness can be attributed in
large part  to  the additional  time provided to  contractors for
project planning. The data supplied  in this paper mdicates_that_
limited competitive procurement efforts will yield lower costs for
work categories addressing similar waste streams under time and
materials contracts  than those projects where there is no compe-
tition.
  Additional comparative work needs to be done to better assess
the impact of limited procurement in  the removal program. More
projects should be reviewed to identify waste categories, character-
istics and disposal approaches^ A greater data base would provide
for a valid comparison of costs from one project to the next. With
more valid comparisons, better assessments could be made in re-
gard to the value and importance of the planned removal and lim-
ited competitive procurement process.
REFERENCES

1. 40CFR300.
2. 94 STAT. 2767-2811.
3. Vanderlaan, G.A. "A Fast Track Approach to Impact Assessment at
  Uncontrolled Hazardous Waste Sites", Proc., Second National Con-
  ference on Management of Uncontrolled Hazardous Waste Sites, Oct.
  1981,348.
4. Rutter, A. J. "Cost Summaries For Region 5 Remedial Response Branch
  Superfund Projects For 1982" unpublished.
5. 40CFR261.
6. 40CFR761.
                                                                                                                COST
                                                           369
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REMEDIAL ACTION  MANAGEMENT AND COST  ANALYSIS
                                              JAMES D. WERNER
                                          EDWARD J. YANG, Ph.D.
                                                   ERIC NAGLE
                                          Environmental Law Institute
                                                Washington, D.C.
INTRODUCTION
  Superfund presents a classic economic and management dilemma
—how to clean up the seemingly unlimited number of problem haz-
ardous waste sites using limited resources.  Congress" recognition
of this dilemma is reflected in the Comprehensive Environmental
Response, Compensation and Liability Act of 1980, by the specific
statutory requirement for  selection of the  most "cost-effective"
remedial alternative at Superfund sites. Cost effectiveness, as out-
lined in section 300.68, subpart  F of the National Contingency
Plan,  does not mean that  public health concerns  should be sub-
ordinated but rather that the least cost alternative should be selec-
ted from among adequately effective options.
  However, carrying out this mandate for cost effective remedies
requires first, that accurate cost  information be available for es-
timating the relative costs of remedial  atlernatives and second,
that this information be used to  implement the remedial alterna-
tive as efficiently as possible through effective planning and man-
agement. To help provide this information  to the EPA's Super-
fund remedial action program, the Environmental Law Institute
(ELI)  performed detailed  case studies on remedial actions at  23
hazardous waste sites across the United States.
  This study is the most comprehensive  compilation of actual ex-
penditure data for  remedial actions that has been performed to
date. For 16 of the 23 case studies, ELI worked  in conjunction
with JRB Associates, which compiled the  technical information
at the sites. This paper summarizes the findings on the costs, the
planning and the management of the cleanups at these sites.
METHODS AND MATERIALS
Site Selection

  The following information sources were  used to find potential
uncontrolled hazardous waste sites for case study consideration:
•1981  SCS Engineers Survey
•USEPA Hazardous Material Incident Reports
•USEPA Regional Offices
•State lists of hazardous substances spills responses
•Remedial contractors
•Trade Associations
•Professional contacts
  From  these sources, 23  sites were selected using the following
criteria:
•Data availability
•Useful remedial technology
•Post-1975
•Remedial actions completed
                                                       About 385 sites were considered for study at which some remed-
                                                     ial action,  or in some cases, spill response,  had occurred or was
                                                     planned. In practice, the availability  of data was the most com-
                                                     mon limiting factor. For this reason, the sites may not be repre-
                                                     sentative of the universe of existing uncontrolled hazardous waste
                                                     sites and their remedial costs.
                                                       Approximately equal  numbers of private and government fi-
                                                     nanced remedial actions were chosen at  12  and 11  sites, respec-
                                                     tively. The variety of remedial technologies included cut-off walls,
                                                     subsurface drains, solidification,  excavation  and groundwater ex-
                                                     traction, treatment (physical, chemical and biological) and reinjec-
                                                     tion.

                                                     Data Collection

                                                       Data were generally collected in three stages:
                                                     1.  Interview preparation
                                                     2.  On-site interview and file search
                                                     3.  Follow-up and refinement
                                                       After obtaining permission to study a site, preliminary informa-
                                                     tion was obtained to prepare for the site visit. This information
                                                     helped confirm the utility of the available information, generate
                                                     useful questions and organize the component tasks and aspects of
                                                     the remedial projects.
                                                       Interviews and file searches during the site visit were the primary
                                                     sources of cost  and decision making information.  All invoices,
                                                     memoranda, letters, proposals,  contracts,  consent decrees and
                                                     pleadings were photocopied. This information was typically sup-
                                                     plemented by extensive discussions with responsible personnel and
                                                     a site  tour. These sources were invaluable in  providing perspec-
                                                     tive to the large volume of file material.
                                                       The last phase of the data collection process was the site visit
                                                     follow-up to refine and  verify the data. Again, site contacts were
                                                     helpful in  organizing  related tasks and specifying what activities
                                                     were or were not included in a contractors invoices  as well as de-
                                                     tailing decision making processes.

                                                     Categorization of Data
                                                       The data base resulting from  this  search consists primarily of
                                                     three forms:
                                                     1. Invoices
                                                     2. Reports and correspondence
                                                     3. Interview notes
                                                       Cost data were divided into functional categories by two primary
                                                     means and supplemented with a variety  of  sources. The categor-
                                                     ization method  depended on the type of the data available from
                                                     the source. The first  method was  the aggregation  and summing
370
COST
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of specific costs on invoices  to determine the cost for a general
operation such as slurry wall construction. All costs related to a
particular task were totalled  to derive the cost of the  operation.
Component costs of the total are described and dissected in the
text of the particular case study. Unit costs  for items  like dis-
posal or slurry mixture were multiplied with the volumes given in
as-built engineering reports to double check the numbers.
  The second method was the correlation of weekly invoice sum-
maries of general cost categories  with the activity occurring dur-
ing that period to estimate the cost of an operation. Weekly in-
voice summaries were often categorized  by items such as labor,
equipment, transportation and disposal. These  categories were
broken down  according to the operation to  which its  function
contributed and the proportion of the weekly  total used for that
operation. For example, excavation might have been  performed
for 100% of a given week, and 50% of the labor and 30% of the
equipment were devoted  to  this  operation, with the  remainder
devoted to analytical work. The cost would be further broken down
if the daily reports showed that transportation  and disposal oc-
curred during  two of the  seven days included  on the invoice for
which X%  labor  and  equipment were used for loading  and
analysis.
   These invoice based  methods  were supplemented with other
sources such as interviews, reports, correspondence and contracts.
When aggregating specific invoice items,  particular items were
sometimes explained by references to file material or the site con-
tacts. The breakdowns of  general invoice summaries according to
daily reports were often refined  by interviewing or correspond- (
ing by mail with site contacts about the execution and timetable
for particular operations. In-house costs were  estimated, when
available,  by totalling  company time sheets for the appropriate
project. In-house private party costs were the most difficult cost
to obtain, usually because of the lack of available records.
   Planning and management information sources varied widely.
For many sites,  agency  correspondence provided most of the in-
formation. For private site responses, the agency correspondence
often included  justifications  for decisions.  For government
responses, decision making  information was usually obtained
through interviews. Court documents, such as  consent decrees,
provided another important source of data on  planning and man-
agement. At virtually all sites, follow-up phone calls were neces-
sary for  gathering  supplemental  decision making information.
Memoranda to files were perhaps the  most useful, but least com-
mon, source of planning and management data.

RESULTS
Costs

   The results of the research on  remedial action costs of the 23
remedial actions were organized and explained in two ways. First,
the cost of remedial work at  each site was given, and categorized
according to component tasks. A complete explanation of the costs
is given in each case study in a cost section that corresponds to
the technology and planning and management sections. Second,
costs of similar remedial technologies  at different sites  were com-
pared with comparable construction-engineering manual estimates
calculated by SCS Engineers in 1980.
   The frequency distribution of the total costs of the remedial ac-
 tions at the 23  case study sites,  ranging from  $23,000 to $10.3
 million, is shown (Figure 1). In Table 1  the total costs  of the first
 four of the 23 case study sites are given  in  alphabetical order.
Also given are the problems,  the response and a quantification of
the response.  The year of the expenditure  is  given but was not
 found to significantly affect  costs since  they were all  performed
relatively recently.  The  mean total cost per  site was $1.4 million.
Seventeen of the 23  case  study responses cost between  $200,000
and $2 million.
   However, these costs for total site costs, as well as the costs for
specific technologies, are not  necessarily representative of the costs
that should be expected in the universe of hazardous waste sites for
four reasons.
  First, the remedial work is not necessarily completed.  Some
sites were studied because of useful isolated preliminary tasks. At
some  sites the need  and funding source for future site work re-
mained unclear.
  Second, some hidden or in-house costs were excluded. Despite
attempts to include these costs, all costs were not necessarily doc-
umented.  For example, private parties often did not record in-
house  labor,  equipment  and  overhead costs;  and  government
actions usually did not include administrative costs. These limita-
tions also prevented  any conclusions about the relative cost-effec-
tiveness of private vs. public responses.
  Third, costs for case study responses were incurred in a period of
dynamic conditions in the remedial actions contracting market. In-
creased economies of scale and increased government expertise
tended to decrease costs in the more recent remedial actions, while
RCRA regulations and privatization of research and development
have worked to increase costs during the same period.
  Finally, the site selection procedure did not attempt to assemble
a group of 23 sites that were statistically representative of the range
of site types and costs, which are themselves still unknown.  How-
ever, the exclusionary site selection criteria that affected the lower
end of the cost spectrum were probably less significant than those
affecting the upper end. For example, the  average total response
cost may be an underestimate  because the site selection procedure
excluded  most CERCLA-funded sites, which  are  generally the
largest uncontrolled  hazardous waste sites in the country.  Also,
more costly sites tend to involve litigation that rendered them un-
available for study.
  The costs for four  of the technologies analyzed in the case stud-
ies are summarized briefly  below. These are not suggested as de-
rived average costs for any of the technologies, but merely as the
costs  for  four of the technologies  analyzed in the case studies.
Ideally, the  number  of  data points would have been allowed to
approach infinity, but the availability of data was limited because
of the small number of remedial actions that have been undertaken
and that were  available  for study. Also, these costs inconsistently
included  related costs, such as grading for capping, because the
invoices were totalled for the entire unit of operation.
ft >'
I:
                    ;-*!.« Billion
                   S.D.- » 1.1 Billion
                    TOTAL COST OF SITE HESKMSE (In Millions I)
                           Figure 1
                 Distribution of Total Site Costs
Capping

  Capping cost data for three of the case study sites are summar-
ized in Table 2.  These response unit costs are supplemented with
significant descriptors, and compared with the SCS estimate. These
                                                                                                                COST
                                                           371
-------
                            Table 1
                  Total Cost by Site (4 of 23 sites)
Site Haj»e
ABOBTBOiia
lite A.
AaooTBoaa
lite 1.
ABOBTBOUa
Site C.
ABoayBoua
110 D.
DBU
ixa
1MO
1M1
1M1
Probleia/Rtek
pesticide/
fertilizer
pooh leaked
CB»
aolventV
hBTMdcc-fw
hex. chromium
«H.f"
eoliUmlimtloil
•olmnU, iw,
•w eomjUBlmUoB
Prieury RespanM
TochBolcflo
dbpcwl,
cut-off ma
BDwface or»l«
(w treatment
•utarfec* drab
|>w treatment
Hteurte* c»lB/
Kntln,
Modepxktkai
QwnUiy
l_liw"l
t.OTm'
II. lonf
4-6 BI deep
UO.MOlpl
Tim lore
4 • deep
l,M*lpd
SMMlpd ,
1
Total Slla
Con
lll.J
•IIUOB
$lU.nT
«U,*M
WJI.1M
gw = ground water
sw = surrace water
Ipd = liters per day
                             Table 2
                          Capping Costs
Sltl Kane
Anonrmu
Slt« A.
AoonyBoue
511. 1.
AnonyBoue
Slt« C.
"SCS CatlBate"
Date
ltd
i9«i
1961
I960
I960
Cap Katerlal
clay
gravel/
bentonlte-aoll
eephalt
da?
bltwlnoue
concrete
TMckncR*
6 Inchce
(0.1S .)
4 IncKcs
(0.15 .)/
4-n Incltee
(0.1-0.2 •)
(fc>
1 foot
(0.1 •) (a)
9 Inchei
(O.OS .)
Coverage
(b)
1M.ODO (t2
(U.«9) >Z>
13S.OOO (I2
(12. MJ •*)
100.000 ft1
(292. Ul «2)
595,95) (t2
(55.JM . )
Unit Cost
Jl.tVft2
($17. 55/.')
51. I)/ It'
($12. M/.2)
1.1J/ It2
($12. 26/.2)
io.nl ft2
(S10.23/.!)
$0.61 - O.M/ft2
(St.M-9.Ot/B2)
(a) Reported thickness in proposed design
(b) Data not available
                                                          costs include capital but not operation and maintenanrccosts. The
                                                          capping costs found at the case study sites were relatively similar,
                                                          ranging from $0.95-1.63/ft2 ($10.23-17.55/mJ). The range of costs
                                                          estimated by  SCS was lower than at any case  study sites.  These
                                                          costs are of limited comparability, however, because of the various
                                                          designs of the caps, these variations are useful in considering signif-
                                                          icant cost factors.
                                                            These factors included:
                                                            A. Material Variations
                                                                (1)  Cap Material
                                                                    (a)  Bentonite/clay
                                                                    (b) Asphalt
                                                                (2)  Related material
                                                                    (1) Top gravel
                                                                    (2) Gravel bed
                                                                    (3)  Curbs
                                                                    (4) Topsoil and seeding
                                                            B.  Dimensional Variations
                                                                (1)  Thickness
                                                                (2)  Area Covered
                                                            The cost data were inadequate to determine an average cost for a
                                                          particular cap type or  to quantify the effect of a particular cost
                                                          factor, but some patterns and absence of patterns were suggested.
                                                          Among material costs, the type of cap material (bentonite/clay vs.
                                                          asphalt)  may have been less significant than the costs for related
                                                          materials such as gravel and curbing. This is suggested by the sim-
                                                          ilar costs  for  the two caps at site 2.  The dimensional variations,
                                                          such as thickness and the area covered, may explain the lower unit
                                                          costs for the SCS estimate since the hypothetical cap used in the
                                                          estimate  was  much  larger, resulting  in  significant economies of
                                                          scale.
                                                          Cut-off Walls

                                                            Cut-off wall costs  for five case study  sites are summarized in
                                                          Table 3. The wall size and basic composition are also given, along
                                                          with the comparable SCS estimate. These costs include capital but
                                                          not operation and maintenance costs.  Unit costs for the case study
                                                          site cut-off walls ranged from $0.21-$29.59/ft2, but, excluding the
                                                          extremes,  they ranged  from $1.42-$14/ft2.  The entire range esti-
                                                          mated by SCS for a hypothetical cut-off wall was lower than the
                                                               Table 3
                                                   Summary of Cut-off Wall Costs (a)
Site Hue
AnonjTBOu* Site A
AnonJTMHi* Site A
AnOBjnMHia Site 1
AnonrBou* site C
AAOByBeue Site D
AwnrBMU site I
•scs
EetlBate"
(c) 4 (e)
Dete
1950
19S2
19SO
19S1
191}
19*0
19SO
Cut-off Well Tr»e
A5FDUI (()
ASTDUI (f)
ASrEMII (f)
ecntonite
elvrry
local clajr
local clay COB-
pacced In llfta
bentonlta
Blurry
SUe (depth underlined)
2.000 I 17 I 0.13 ft-M.OOOtt2
(510 I 5 S 0.02} B - 3.159 B2)
2,929 I 17 I 0.13 (t-»9.»J* ft2
(993 I i * 0.021 B - t.«7l B2)
l.ttl I 10 X 1 It - 14,450 ft2
(447 I j > 0.3 B - 1.341 B2)
618 I 17 I 1ft - ll.Olt ft'
(191.4 S 5.2 I 0.3 B - 1023 B')
2.745 I 14.3 I lft-39.490 •< fc

HA (b)
2.306 I 41 I 3.2 feet -
110. Ml Tc2
(720 I 15 I 1 B - 10. (00 B2)
Expendltttra
J23I.OOO
$974.274
$13.000
$316.0007}/B>)
»14/ft2
WJO/B?)
t>.tO/ft>
(S41/B2)
II9.M/IC2
(319/B2)(d)
$1.42/ft»
U5.11/B>)
*0.21/ft2
($2.2t/B2
$4. 21-7. 34 /It2
                       (a) Cosls arc of limited comparability; sec text.
                       (b) Repotted to be 2 feet thick by design drawings.
                       (c) Based on Means "Building Construction Cost Data: 1983"
                       (d) Includes excavating the trench, transporting and disposing of contaminated soil.
                       (e) Total capital costs.
                       (0 Asphalt, sand, concrete, water emulsion.
372
COST
-------
mean found at the case study sites. The range of costs largely re-
flects the wide variation in the cut-off wall types.
  The  two most significant factors affecting costs were the wall
type and the disposal  of the contaminated trench material. The
ASPE  MIX walls cost significantly more than standard clay cut-
off walls, but their low permeability, demonstrated in bench scale
tests, was  required by the government agencies  overseeing  the
clean-up. At one site, the cut-off wall was  constructed within-the
contaminated area, and, hence, the trench material required dis-
posal in an engineered landfill.
  Excavation, transportation and  disposal—Because of the large
amount of data for excavation, transportation and disposal, only
the ranges  found for these costs are summarized in Table 4. The
costs of RCRA hazardous  waste were  separated from the  TSCA
hazardous  PCB waste  because of the  widely differing costs and
regulatory  programs. The  cost of excavating the  waste (without
transportation or disposal) ranged from $8-146/yd3. Transporta-
tion costs were relatively similar at $0.13-0.28 ton/mile. The costs
 for disposal ranged from $5/tonne (metric  ton) at  a USEPA sub-
 sidized landfarming operation to $277/tonne for  incineration of
 highly contaminated PCB  oil. Most RCRA hazardous waste dis-
 posal costs were about $100/tonne. No significant differences were
 found between disposal costs for bulk and containerized wastes.
   Other factors affecting these costs were:
 I. Technical
   A.  Excavation or On-site Transfer
       1. Excavation depth
       2. Site surface characteristics
       3. Waste explosivity
       4. Material-liquid/solid/drums
       5. Waste quantity
   B.  Transportation
       1. Distance to disposal facility
       2. Accessibility to road
       3. Material-liquid vs. solid
       4. Waste quantity
   C.  Disposal
       1. PCB
         a. Concentration-over/under 500 ppm
         b. Material-solid vs. liquid
       2. Non-PCB RCRA  Hazardous
         a. Solid vs. liquid
         b. Aqueous vs. organic
 II.Non-Technical
   A.  Community relations
   B.  Interstate relations
    C.  Inflation and regulatory factors.
                            Table 4
       Range of Costs for Excavation, Transportation and Disposal
Excavation
Transportation
Disposal
non-PCB H.W.
PCB
TOTAL
SlO/m1
$0.08/tonne/km
$10/tonne
(landfarming)
$212/tonne
(engineered
landfill)
$57/mJ
$119/m!
$0.18/tonne/km
$93/tonne
(engineered landfill)
$277/tonne
(incineration)
$335/m'
  Water Treatment
   Finally, costs for water treatment at eight of the 23 case study
  sites are summarized and compared with the comparable SCS es-
  timate in Table 5. These costs include either: operation and main-
tenance costs  for permanent systems constructed on-site;  labor,
material  and rental  costs for temporary on-site systems;  prices
charged by the contractors for water sent to commercial industrial
waste treatment plants; or the prices  charged by publicly owned
treatment works for  accepting wastewater. Capital costs were ex-
cluded from this summary because they are not consistently applic-
able and because of the uncertainty about the length of the opera-
tional lifetimes for amortization  purposes. Operation  and main-
tenance costs ranged from 6-20% of capital costs.
  Probably the most  important  factor affecting the unit costs
found for treating a given volume  of waste was total volume of
waste treated. Systems with large capacities were able to take ad-
vantage  of their greater  economies  of scale. For example,  at site
1 only 1,000-1,500 gal/month of water were  treated;  whereas at
site 8, about 3.5 mg of water/month were treated.
  Other factors found to  affect these costs:
  A. Technical Factors
      1.  Nature and degree of contamination
         a. Treatability
         b. Solubility
         c. Concentration
         d. Diversity of contaminants
      2.  Variations in type of treatment processes selected
         a. Carbon
         b. Biological
         c. Physicochemical secondary treatment (POTW)
         d. Other individual treatments (e.g., air stripping, fabric
           filtering)
      3.  Variations among particular processes
         a. Level of treatment
         b. On-site/off-site
         c. Efficiency
         d. Treatment system capacity
         e. Collection limitations
         f. Climate
  B.  Non-technical Factors
      1.  POTW rate system
      2.  Use of existing system
      3.  Rental vs. purchase of treatment system
      4.  Market competition by treatment contractors
      5.  Inflation

Planning and Management
  The five most significant factors regarding the  planning and
management of the remedial actions were found to be:
•The basis for initiation of the response
•Public interaction with the response
•The basis for the extent of response
•The role of federal and state statutes in the execution of the re-
 sponse
•Methods for selecting and retaining contractors
  The reasons for initiating the responses were significant because
(1)  if they were perceived as emergencies, the choice of technolo-
gies was significantly limited, and  (2) clear identification  of the
nature and extent of the  risk was  found to provide a firm basis for
designing a response strategy.
  About half of the responses were initially reported to the author-
ities by local citizens. Public attention was usually focused on in-
itiating a response,  rather than  on particular aspects  of the re-
sponse. Public interaction with the cleanup was found to be very
limited.  At one site,  however,  citizen opposition  blocked  five
initial proposals for  disposal of contaminated material. At an-
other site, though, the local media  focused attention on the large
amount  of money and time being spent on what was perceived as
just a minor spill.
  Perhaps the most important aspect of planning and management
of the case study responses regarded the decisions about the extent
of the responses. At every case study site the general goal was to
eliminate the threat to public health and the environment, but spe-
                                                                                                                COST
                                                           373
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                                                             Tables
                                                Contaminated Water Treatment Cost (a)
Sic* K*»e
Aaoajntous
Site A
Anonyanus
Site B
Aaonysous
Sice C
Anonyanus
Site D
Anonyaous
Site E
Anonymous
Site r
Anonymous
Site C
Anonysious
Site H
"SCS estimate"
Date
19*1
19*2
1980
1979
1983
1982
1979
1982
1980
Treatnent
Technology
On-alte advanced oil/
vater separator
Off-site Cowereial
Treatment
On-site carbon t
clarification, air
•ttipping
On-slte carbon, pea
gravel/lie*
filtration
On-alte
Biodegradation
Off-lite
POTW (c)
Off-lite
POTW (c)
On-alte
Granular Activated
Carbon (reverie
pulae)
On-lite
"Chemical,
biological and/or
physical"
Primary
Contaminant
rct/oii
Cyanide
•Ixed aolvents,
PCS
Pentachloropheno]
(PCP)
•ethylene
chloride,
butanol,
acetone
hexavalent
chromium
Pesticides
(atracine,
alachlor)
Pestlcldea
(DBCP)
"contaminant"
Quantity Treated
1,000-1.500 gallons
(3.785-5678 I)/ month
9.425 gallons
(35,674 1)
7.C x 10* gallons
(2.9 x 10' 1)
over 6 Month period
t x 10* gallons
(8 x 10s 1)
ever 1 Month period
13,680 gallons
(51,779 l)/day
273,000 gallons
(1.03 x 106 1)
9 x 107 gallons
(3.4 x 10* 1)
over 5 »nth period
1.5-2.6 x 108 gallons
(6.8-9.8 x 108 l)/year
4.3 x 10 gallons
(1.6 x IflS 1 )/year
Expenditure
54.167/month
$12.724
52-3
•llllon
$200.000-
350,000
$226.53/day
$2,275
$50.169
$133.320-
370,800/year
$51,900-
94,340/year
Unit Coat
52.70-4.6/gal
($0.73-1.10/1)
$1.35/gallon
($0.036/1)
$0.26-0.40/gal(b
($0.068-0.10/1)
$0.10-0.18/gal
(50. 026-0. 048/
1)
50.0165/gal
($0.0044/1)
50.008/g.llon
($0.002/1)
$0.00056/gallon
($0.00015/1)
50.0005-0.0011/
gallon
$0.00013-
0.00029/1)
50.0012-
0.0022/gal.
($0.00032-
0.00058/1)
             (a) Operation and maintenance, or rental cost
             (b) Includes ground water recovery cost
             (c) Publicity Owned Treatment Works
 cifically defining that goal took many different forms.  First, the
 goals were chosen in three major ways: through judicial or ad-
 ministrative  processes,  by voluntary agreement between agencies
 and a private party, or within the government agency undertaking
 the response.
   The second issue studied in the planning and management of the
 case study responses was the specific cleanup goals chosen. The
 sources and types of the standards varied widely at the case study
 sites. Sources of the standards were important  because they de-
 termined how clearly and precisely the standards were  expressed
 and how justifiable or defensible the standards  would be if called
 into question. Emergency cleanups were often terminated when the
 threat of fire or explosion was eliminated.  These emergency ac-
 tions, which  were  virtually all government  responses, were made
 through a  "best professional judgement"  approach rather  than
 relying on preexisting standards. Though, in three emergency re-
 sponses, the Coast Guard and/or the USEPA established specific
 physicochemical cleanup goals for themselves.
   Remedial actions goals were generally more thoroughly  con-
 sidered. However,  for remedial actions at eight of the case study
 sites, best professional judgement was used to establish a cleanup
 standard. These judgements ranged from a visual notion of what
 constituted clean soil, to the determination of an ad hoc group of
lexicologists and public health scientists who drew  upon labora-
tory and epidemiological studies. Preexisting standards, such as
 landfill  design criteria and NPDES discharge requirements, also
served as benchmarks for cleanups. At only two  of the 23 sites was
the contaminant level required to be brought to a given level. At
most sites,  plume spread had to be halted and/or reversed, and
drawn off water had to be treated to acceptable pretreatment or
surface  water standards. The plume control periods were all in-
determinant. Specific groundwater cleanup goals were determined
at  one site from three sources: (l)Suggested  No Adverse Response
Levels developed by the National Academy of Sciences; (2) Allow-
                                                        able Daily Intake for pesticides set by the World Health Organ-
                                                        ization; and (3) extrapolation from crop  tolerances levels estab-
                                                        lished by the USEPA. At other sites, states used "Action Levels"
                                                        or "Levels of Concern", set by  the health department, to deter-
                                                        mine cleanup requirements for soil or reinjected treatment effluent.
                                                          Most of the case study responses were affected by laws govern-
                                                        ing hazardous substances or law protecting water resources,  but
                                                        not by laws governing air quality, although air pollution was often
                                                        a significant concern. The three  major ways laws affected clean-
                                                        ups were: (1) they provided government agencies with the author-
                                                        ity and/or funding to initiate responses and provided funding for
                                                        the work (section 311k of the Federal Water Pollution  Control
                                                        Act and state spill funds); (2) they provided  the basis for gov-
                                                        ernment authorities to prompt private parties to undertake clean-
                                                        ups (section 7003  of the Resource Conservation  and Recovery
                                                        Act,  the  Toxic  Substances Control Act  and  the Federal Water
                                                        Pollution Control  Act);  and  (3) they contained design or  per-
                                                        formance standards that  were used as standards for determining
                                                        the extent of response  (discharge requirements in  the California
                                                        Administrative Code for land disposal facilities, NPDES).
                                                          Two major contracting issues  were studied—contractor selec-
                                                        tion methods and contract types. Private parties usually used bid-
                                                        ding procedures slightly more often, and  allowed subcontracting
                                                        much  less often, than government agencies. Three major contract
                                                        types were used at  the case study sites: lump sum, unit price and
                                                        time and materials. Private parties used lump sum contracts, with
                                                        change orders, more often than time and materials,  while govern-
                                                        ment agencies had  the opposite pattern. However, these general-
                                                        izations should  be tempered with the fact that 10 out of 11 gov-
                                                        ernment responses  were considered to be emergency responses.
                                                        Preference for unit price contracts which  involved, for example,
                                                        charging a given unit price for a  square foot of cut-off wall, or a
                                                        cubic yard of sludge removal, was equally divided between the pri-
                                                        vate and government responses.
374
COST
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CONCLUSIONS

  The case study  method was an extremely effective method for
deriving useful lessons from previous remedial actions  at  haz-
ardous waste sites. Important findings of the research include cost
accounting procedures, contracting techniques and the importance
of determining the extent of response as a management tool.
  The accounting procedures used at the case study sites were
found to vary widely. The research suggested that the most useful
way of recording costs is to aggregate the costs according to task. In
this way, it is  possible to clearly determine exactly what a slurry
wall cost in terms of a bottom  line number useful  for decision
making. This  method contrasts  with  the site-wide multiple  task
equipment/materials/labor breakdowns found at many sites.  This
information would be most useful in a Response Summary Report
which also contains a  clear summary of events and significant de-
cisions.
  The most useful contracting method seemed to be the unit price
form. This contract offers not only the cost control advantage of
lump sum contracts, but also provides the flexibility  of time and
materials contracts that is needed for the typically uncertain situa-
tions at hazardous waste sites. Lump sum contracts,  by contrast,
prompt contractors to protect themselves against these uncertain-
ties with explicit or hidden contingency allowances. Time and ma-
terials contracts are subject to abuse in drawn-out projects.
  Finally, although the sources and use of standards  varied wide-
ly at the case study sites, some type of clear end point goal seemed
necessary  for all sites. Planning  and management of the cleanup
seemed to be more efficient and effective when some  goal was set
before committing  significant resources. These goals  may  have
been altered as the work proceeded, but setting of some justifiable
goal helped organize the cleanup operation by serving as a focus for
the various tasks.
   Many  of these findings, made elsewhere, have resulted in the
planning process in Feasibility Studies and, hence,  serve to rein-
force ongoing programs. Future revisions of the National Contin-
gency Plan may draw upon these early lessons to  improve the
guidance given to future cleanups. An objective, open appraisal of
past cleanups should continue  in order to avoid reinventing the
wheel in  efficiently managing remedial actions at hazardous waste
sites.
ACKNOWLEDGEMENTS
   This paper is based on research performed to the USEPA Office
of Research and Development  and  Cooperative Agreement  R-
8059200-10. The authors wish to express their sincere thanks to
Douglas Ammon and Richard L. Stanford of the USEPA for their
sage guidance.
REFERENCES

1. Environmental Law Institute/JRB Associates. "Survey and Case Stud-
   ies of Remedial Actions at Hazardous Waste Sites." For USEPA Office
   of Research and Development, Final Draft, Apr. 1983.
2. SCS Engineers, "Costs of Remedial Response Actions at Uncontrolled
   Hazardous Waste Sites," for USEPA Office of Research and Devel-
   opment, Apr. 1981.
                                                                                                               COST
                                                          375
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     COSTS OF  REMEDIAL ACTIONS  AT UNCONTROLLED
       HAZARDOUS WASTE  SITES—IMPACTS OF WORKER
                HEALTH  AND  SAFETY CONSIDERATIONS

                                             JAMES J. WALSH
                                             JOHN M. LIPPITT
                                                  M. SCOTT
                                                SCS Engineers
                                             Covington, Kentucky
INTRODUCTION
  In December 1980, the U.S. Congress passed legislation entitled
"The  Comprehensive  Environmental Response, Compensation
and Liability Act." This Act provides the USEPA with the legis-
lative mandate and the money to assist in the elimination of public
health hazards posed by uncontrolled hazardous waste sites. Sec-
tion 105 of the Superfund legislation requires the USEPA to in-
vestigate the costs of  remedial/cleanup actions at  uncontrolled
waste sites. Specifically, Item 2 of Section 105 requires the devel-
opment of cost ranges for various types of remedial actions.
  Responsibility for implementing Superfund actions and response
to uncontrolled hazardous waste  sites rests primarily with the
USEPA Office of Emergency and Remedial Response (OERR). At
the request of OERR, the USEPA Office of Research and Devel-
opment (ORD) has been conducting research on the costs of re-
medial actions to fulfill the requirements of Section 105. In sup-
port of these activities, several studies have been conducted  to
evaluate the types  of remedial actions and associated costs applic-
able to Superfund sites (i.e., sites for which Superfund monies have
been allocated) and other hazardous waste sites.
  In these studies, costs associated with health and safety of work-
ers were either not included or not uniformly identifiable as sep-
arate cost items. As a result, the project presented in this paper was
designed to specifically  address the additional costs  of protecting
worker health and safety on a hazardous waste site. These costs do
not include costs associated with addressing concerns of the public
health and safety in the vicinity around an uncontrolled hazardous
waste site.  However, the controls and costs associated with pro-
tection of workers on the site should reflect much, if not all, of the
additional costs of protecting the public in areas removed from the
source of contamination (i.e., the hazardous waste site itself).
  The objectives of this project were:
•Identify categories of health and safety costs
•Collect and compile health and safety cost estimates and deter-
 mine a range of costs which can be encountered on hazardous
 waste sites
•Calculate percentage incremental health and safety cost adjust-
 ment factors
•Identify factors which  impact health and safety costs and should
 be considered for future study and evaluation
STUDY DESIGN AND APPROACH

  Initial data collection was based on reviews of case studies, bid
documents for Superfund sites and a telephone survey of firms and
                                                  regulatory agencies. After reviewing available data and the sum-
                                                  maries of the telephone survey, it was determined that health and
                                                  safety costs could not be readily identified. Normal  accounting
                                                  practices did not distinguish many health and safety costs. Such
                                                  costs were routinely incorporated into general categories such as
                                                  labor rates, equipment O&M costs and overhead expenditures.
                                                  In addition, extensive analysis of cost data from existing sites was
                                                  viewed by many contractors as extremely sensitive due to compet-
                                                  itive and proprietary considerations.
                                                    On the other hand, most of the contacts felt that general dis-
                                                  cussions of costs would be of little value because of site specific
                                                  considerations which impact on  the overall costs and particularly
                                                  health and safety costs. As a result, it was concluded that realistic,
                                                  but ficticious, hazardous waste  site scenarios would provide the
                                                  best format for providing and evaluating cost estimates for remed-
                                                  ial action unit operations. In fact, several of the contacts indicated
                                                  they felt it was the only reasonable approach.
                                                    From  previous studies and case history reports, 28 discrete
                                                  remedial action activities (hereafter referred to as remedial action
                                                  unit operations) were  identified (Table 1). The basis of classifica-
                                                  tion was the media that the remedial  actions control: surface
                                                  water, groundwater, subsurface  gas and waste. Nine of these are
                                                  classified as surface water controls, eight as groundwater controls,
                                                  three as gas migration controls and eight as waste controls.
                                                    Ten health and safety cost components were identified based on
                                                  literature reviews, previous site observations, discussions with field
                                                  personnel from state  and federal regulatory officials and discus-
                                                  sions with cleanup contractors (Table 2).
                                                     In providing cost estimates, contractors were requested not to
                                                  address  costs of transportation  and disposal. This approach was
                                                  taken due to the amount of information available on transporta-
                                                  tion and disposal costs and to minimize the amount of cost esti-
                                                  mations required of the contractors responding to the scenarios. A
                                                  separate telephone survey was conducted involving 11 transporta-
                                                  tion firms to identify current ranges  of transportation costs fw
                                                  hazardous waste.
                                                     Disposal cost estimates were obtained from the 1981 update of
                                                  the USEPA report entitled, "Review of Activities of Major Firms
                                                  Involved in Commercial Hazardous Waste Management Indus-
                                                  try."1 Since transportation  and disposal costs are often included
                                                  as separate line item costs, separation of these costs in the scenartol
                                                  is consistent with normal contractor procedures.
                                                  TELEPHONE SURVEY

                                                     An extensive telephone survey was made to identify available
                                                  sources  of data on health and safety costs. The survey included:
 376
COST
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                           Table 1
               Remedial Action Unit Operations
              SURFACE WATER CONTROLS
              Surface Sealing with Synthetic Membrane
              Surface Sealing with Clay
              Surface Sealing with Asphalt
              Surface Sealing with Fly Ash
              Revegetation
              Contour Grading
              Surface Water Diversion Structures
              Basins and Ponds
              Dikes and Berms
              GROUNDWATER CONTROLS
              Well Point System
              Deep Well System
              Drain System
              Injection System
              Bentonite Slurry Trenches
              Grout Curtain
              Sheet Piling Cutoff
              Grout Bottom Sealing
              GAS MIGRATION CONTROLS
              Passive Trench Vents
              Passive Trench Barriers
              Active Gas Extraction Wells
              WASTE CONTROLS
              Chemical Injection
              Chemical Fixation
              Excavation
              Leachate Recirculation
              Treatment of Contaminated Water
              Drum Processing
              Bulk Tank Processing
              Transformer Processing
                           Table 2
           Health and Safety Cost Component Categories
Decontamination
Emergency Preparedness
Hazard Assessment
Insurance
Manpower Inefficiencies
Medical Services/Surveillance
Personal Protection
Personnel Training
Record Keeping
Site Security
•Forty-seven firms with experience in remedial action responses
 on hazardous waste sites
•Eleven state and federal  regulatory  agency representatives in-
 volved with management and/or assessment of hazardous waste
 site cleanup operations
•Eight military contacts involved in the management and/or assess-
 ment of military hazardous waste sites
•Six consulting firms that have conducted studies concerned with
 remedial actions on hazardous waste sites
•Three research oriented institutions involved in hazardous waste
 management research activities
  Each telephone interview was recorded on a written telephone
summary report, evaluated and rated based on the following four
general criteria:
1.  Amount of experience in assessment and management of remed-
   ial actions on hazardous waste sites
2.  The variety of experiences with types of sites and/or remedial
   actions
3.  Access to available data
4.  Willingness to  cooperate in providing data and discussing cost
   allocations
HAZARDOUS WASTE SITE COSTING SCENARIOS

  Six hazardous waste site scenarios were developed to be repre-
sentative of three basic types of sites:
•Subsurface Burial
•Surface Impoundments
•Above-Grade Storage
  Whenever possible, these scenarios were developed based on ac-
tual cleanup operations  either completed, in progress or planned
for the future.  This approach was adopted to  ensure that  the
scenarios would reflect realistic site conditions  while providing a
means of controlling site variables which could impact cost esti-
mates. .
  Each scenario was composed of a number of distinct unit oper-
ations. The combination of the unit operations represented a com-
plete remedial action program for each hypothetical site. Site char-
acteristics (e.g.,  size, topography, hydrology, weather, etc.) were
defined for each scenario to provide a detailed profile on the site.
Similarly, the characteristics of the wastes present on each site were
defined so that  the degree-of-hazard conditions  could be deter-
mined for each unit operation.
  The  degree-of-hazard conditions described  represented con-
ditions  which parallel four levels of personal  protection recom-
mended in the Interim Standard Operating Safety  Guides devel-
oped  by the Office of Emergency and Remedial  Response, Haz-
ardous  Response Support Division, USEPA.2 A brief description
of the conditions associated with the four levels of personal pro-
tection  (designated as Levels A, B, C and D in order of decreas-
ing degree-of-hazard conditions) is given in Table 3. Contractors
were  instructed  to utilize the recommended guides  in  determin-
ing the level of personal protection required.
  Contractors providing cost estimates were instructed to provide
cost estimates for each unit operation under the conditions set forth
in the scenario and costs representative of conducting the same ac-
tivity if the hazardous wastes were not on-site (i.e., base construc-
tion costs). In order to identify the relative impact of variations in
degree-of-hazard conditions, contractors were  also instructed to
provide cost estimates based on three other modifications of hazard
conditions which were also specified. The modifications were based
only on variations of waste characteristics while all other site con-
ditions and activities remained constant.
  One additional factor  which may significantly impact health and
safety costs is ambient temperature. To identify  the relative impact
of temperature, contractors were instructed to provide an estimate
of the cost variations of the total scenario, health and safety costs
estimated for each of the four degree-of-hazard  conditions. The
cost estimate variations  were based on the costs  under the range
of temperatures given in the scenario and two  additional temper-
ature ranges.  The result was an estimate of total scenario health
and safetyjiosts under  the four degree-of-hazard conditions for
low K 0°C), normal (0-18 °C)  and high (18-38 °C) ambient tem-
perature ranges.  The relative temperature ranges included wind
chill considerations.

                            Table 3
        Conditions Associated with Levels of Personal Protection

Level  A—requires full encapsulation and protection  from any body  con-
tact or exposure to materials (i.e., toxic by inhalation and skin absorp-
tion).
Level  B—requires self-contained breathing apparatus (SCBA), and cutan-
eous or percutaneous exposure to unprotected areas  of the body (i.e.,
neck and back of head) is within acceptable exposure standards (i.e., below
harmful concentrations).
Level C—hazardous constituents known; protection required for low level
concentrations in air; exposure of unprotected body areas (i.e., head, face,
and neck) is not harmful.
Level D—no identified hazard present, but conditions  are monitored and
minimal safety equipment is available.
                                                                                                                 COST
                                                                                                377
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  The selection of contractors to respond  to  the  scenarios was
based on the following criteria:
•Their relative rating provided from the evaluation of the tele-
 phone survey results
•A match of their previous experience with sites similar to one or
 more of the scenarios
•The availability of personnel routinely involved in cost estima-
 tion and familiar with health and safety requirements on a haz-
 ardous waste site
•Project funding limitations for payment of subcontractors (i.e.,
 site cleanup contractors) to provide cost estimates
  The final selection included seven hazardous waste cleanup con-
tractors responsible for one to three scenarios apiece. Each scenario
was assigned to two different contractors for cost estimation.
  A questionnaire was also sent to the contractors providing cost
estimates. The questionnaire was designed to identify differences
in approaches to health  and safety  considerations  which  impact
costs.  The purpose of requesting the information was to provide
additional information to assist in determining probable reasons
for  cost variations anticipated. In addition,  contractors were re-
quested  to  comment  on  other considerations or differences, if
any, that they considered significant.

TRANSPORTATION COST SURVEY

   Initial literature search and review was based on:  (1) in-house
library sources and (2) the USEPA Library  in the Environmental
Research Center in Cincinnati, OH. The available literature did
not specifically address transportation costs  for hazardous waste
cleanup sites. Very little current data (1980 to 1982) were avail-
able for hazardous  materials transportation  costs.  Additional
efforts were  made to identify  cost information  from current
studies. Unfortunately, none of the data were available.
   In order to obtain current cost data, a telephone survey of trans-
portation  companies  and  services was  conducted.  A  tele-
phone interview questionnaire was developed for data collection
                                                         from companies contacted. Eleven companies were contacted. The
                                                         six responses obtained can be divided into three major groups:
                                                         1. Companies concentrating or specializing in transportation of
                                                            hazardous wastes
                                                         2. Companies whose main interests and  efforts involve general
                                                            freight and commodities and only limited involvement in haz-
                                                            ardous waste transportation
                                                         3. Waste disposal and treatment companies who provide  trans-
                                                            portation services for their customers
                                                           Two responses were obtained from companies in each category.

                                                         RESULTS
                                                         Responses to Scenarios
                                                           Eleven completed  remedial  action costing scenarios  were re-
                                                         turned.  Two contractors could not provide the requested cost es-
                                                         timates  within the required  time period due to conflicting work
                                                         schedules. As a result, cost estimates  for Scenario 5 were provided
                                                         by only one contractor. The remaining Scenarios 1, 2, 3, 4  and 6
                                                         were estimated by two contractors apiece.
                                                           The original cost estimates were reviewed and modifications were
                                                         made (e.g., assigning travel  and  per  diem costs to base  construc-
                                                         tion costs  instead of health and safety costs, correction of cal-
                                                         culation errors, etc.). Additional information was requested, as
                                                         necessary,  to reallocate costs to uniformly  cover  the health and
                                                         safety cost component items. Modifications were reviewed with the
                                                         respective contractors. Cost  estimates were provided  for the four
                                                         degree-of-hazard conditions  which were established in the scenar-
                                                         ios.  The degree-of-hazard  conditions  were  identified as  Levels
                                                         A, B, C and D which indicate maximum level of personal protec-
                                                         tion required based on the information given in the scenario in-
                                                         formation/instruction packets sent to the contractors. The degree-
                                                         of-hazard condition designated Level A as  the worst case,  while
                                                         Level D is the least hazardous condition.
                                                           In Scenario 2, costs were only requested for Level C conditions
                                                         which were considered sufficient for worker protection for  hand-
                                                             Table 4
                                              Range of Health and Safety Costs per Unit*
Unit Operation
Surface Water Controls:
Surface Seal - Synthetic Membrane
Surface Seal - Clay

Re vegetation*

Contour Grading

Surface Water Diversion

Basins and Ponds

Dikes and Berms

Ground Water Controls:
Well Point Systeo

Drain System

Bentonite Slurry Trench

Waste Controls:
Che»1cal FUatlon (Solidification)
Eicavation of Wastes/Contaminated Soil
Treatment of Contaminated Water
OruM Processing
Bulk Tank Processing

Transformer Processing
Unit of
Measure

.2
sj yd
sq yd
ha
acre
•3
cu yd
.5
cu yd
.3
cu yd
•^
cu yd

•2
sq yd
•3
cu yd
«3
cu yd

.3
c^ yd
cu yd
I/day
gpd
208 1 (55
gal) drum
30,280 1
(8.000 gal)
tanks
Transformer
Base Construction
Costs Per Unit

S14.41-S19.eS
S17.24-S23.SO
$2.74
$2.29
$6,372-$124.000l
SZ.S49-S49.600
S2.9S-S5.76
S2.22-S4.40
S1.91-S16.05"
$1.46-$12.2B
$4.52-$8.S3
$3.46-$6.S2
$12.78-$1S.96
S9.78-S12.21

$133
$111
S38.87-S49.22
$29.72-$37.63
$50.96
$38.97

$25.06-5147.33
S19.16-$112.63
$3.10-5324.41
$2.37-5248.08
S0.09-S14.31
SO. 35-553. 49
$36.18-$630.89

51.222-54.032
S2IO-S3M

Level D

Sl.l3-$3.99
$1.35-$4.77
$0.26
$0.22
$340-565.115
$136-$26,046
$0.38- $2. 10
$0.29-$1,61
S0.23-S9.13
$0.17-$6.99
$0.41-$3.4S
$0.31 -$2.64
S0.84-S14.68
S0.65-S11.23

$11.70
$9.78
S3.31-S22.99
$2.53-$17.58
$4.46
$3.41

$2.75-S46.62
$2.10-$35.64
S14.S2-S112.10
S11.I1-S8S.72
S0.01-SS.3S
S0.03-S20.27
S51.94-S928.42

S1.047-S4.162
Health and Safety Costs Per UnU
level C

$2.06-54.63
$2.46-55.53
SO. 52
SO .43
$1,215-573,342
$486-$29.337
S0.73-S2.66
$O.Se-$2.03
$0. 38-S10.72
$0.29-$8.20
$0.93-$4.60
$0.71-53.52
$2.6S-$19.94
S2.03-S1S.26

$19.63
$16.41
$6.17-$29.75
$4.72-$22.75
$6.97
$5.33

S4.12-$60.97
$3.15-546.61
SS.90-S246.42
$4. 51 -$188. 44
$0.01-$5.44
$0.05- $20. 59
$69.63-51.165.63

$1.926-55.560
$48.57-51 .196
Level B

S2.41-S5.49
S2.88-S6.S6
$0.66
$0.55
$1,215-574,940
S486-S29.976
S0.96-S3.02
S0.73-$2.31
$0.46-512.34
S0.3S-S9.44
$1.28- $5. 22
$0.98-53.99
$3.04-520.91
S2.33-S16.00

$24.06
$20.12
$7.51-532.46
S5.74-S24.82
$16.40
$12.54

S4.29-S70.04
S3.28-SS3.S4
524.70-5169.38
$18.88-5129.53
S0.02-S6.14
S0.06-S23.22
$88.89-$! .402. 86

t5.670-t6.9S8
Level Ik

S2.48-S5.93
S2.97-S7.09
$0.74
$0.62
S1.215-S78.637
S486-S31 ,455
S0.97-S3.70
S0.75-S2.83
SO. 47-513. 34
S0.36-S10.20
S1.S9-$S.S8
$1.21 -$4.27
S3. 35-523. 31
S2.57-SI7.83

$31.34
$26.20
SI0.60-S34.06
$S.IO-S26.04
$18.24
$13.94

54 .64-580. 38
S3.55-S6I.4S
$28.99-SI98.02
S22.I7-S1S1.43
S0.02-t6.97
S0.08-S26.37
S102.68-tl.690.07

$8.354-58,434
        *Cost ranges arc not adjusted for economy of scale or regional variations.
        t Range includes cosi estimates from one contractor which were significantly higher than the others.
        fA, composite of base construction costs for revegetation from previous SCS report [3J yields a range of S3,974-$ 18,079 per ha (SI ,603-57,300 per acre).
       ••Costs from previous SCS report [3] yield cost ranges of JI.75-S3.63 perm' (S1.34-S2.78 percuyd) for surf ace water diversion base construction.
378
COST
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                                                             Table 5
                      Incremental Health and Safety Costs—Range of Percentage Adjustments Over Base Construction Costs
 Unit Operation
                                                   Level D
                                                                         Degree-of-Hazard Conditions
                                                                       Level C
                                                                                             Level B
                                                                                                                   Level  A
 Surface Water Control s:
1. Surface Sealing Synthetic
2. Surface Sealing Clay
3. Surface Sealing Asphalt
4. Surface Sealing Fly Ash
5. Revegetation
6. Contour Grading
Membrane





7. Surface Water Diversion Structures
8. Basins and Ponds
9. Dikes and Berms
Ground Water Controls:
1. Well Point System
2. Deep Well System
3. Drain System
4. Injection System
5. Bentonite Slurry Trench
6. Grout Curtain
7. Sheet Piling Cutoff
8. Grout Bottom Sealing
Gas Migration Controls:












  1.  Passive Trench Vents
  2.  Passive Trench Barriers
  3.  Active Gas Extraction Systems

  Waste Controls:
  1.  Chemical Fixation  (Solidification)
  2.  Chemical Injection
  3.  Excavation of Wastes/Contaminated Soil
  4.  Leachate Recirculation
  5.  Treatment of Contaminated Water
  6.  Drum Processing
  7.  Bulk Tank Processing
  8.  Transformer Processing
                                                    8-20%
                                                     9%
                                                     5-53%
                                                     9-45%
                                                    12-57%
                                                     9-40%
                                                     7-92%
                                                     10%

                                                     9-47%

                                                      9%
11-32%

32-545%

11-38%
32-166%
86-103%
                    14-24%
                      19%
                    12-59%
                    17-57%
                    20-67%
                    21-54%
                    21-125%
                      17%

                    16-60%

                      14%
 16-41%

 44-613%

 11-38%
 75-192%
138-158%
 23-36 %
                       17-28%
                         24%
                       13-60%
                       22-65%
                       24-77%
                       28-61%
                       24-131%
                         21%

                       19-66%

                         32%
 17-48%

 50-785%

 22-43%
 50-277%
173-464%
                       17-30%
                         27%
                       14-63%
                       24-80%
                       25-83%
                       35-65%
                       26-146%
                         28%

                       27-69%

                         36%
 19-55%

 58-1990%

 22-49%
 58-353%
209-690%
ling PCBs. The scenario was included because of the number of
sites and public concern involving electrical equipment containing
PCBs and the special requirements established for PCBs by the
Toxic Substances Control Act (TSCA).
  The contractor's cost estimates  were compiled  and evaluated,
then used to calculate a cost per unit range for each remedial action
unit operation. Cost per unit calculations  were made for health
and safety costs at the four degree-of-hazard conditions and for
base construction costs  (Table 4).  A percentage incremental cost
factor was calculated by dividing the health  and safety costs per
unit for each of the degree-of-hazard conditions by the costs per
unit calculated for the base construction costs. The resulting per-
cent range of incremental health and safety cost adjustment fac-
tors are presented in Table 5.
  Estimates for those remedial action unit operations not costed as
part of the six cost scenarios can be calculated based  on a com-
parison of potential worker exposures while  conducting remedial
action unit operations. The types of activities which determine the
potential for worker exposures were  identified for each of the 28
remedial action unit operations and are presented in Table 6.
  The estimated impacts of temperature on remedial action costs
are  summarized in Table 7.  The  original  estimates did provide
costs for each unit operation, but the  specific component costs
which contractors considered temperature sensitive and the amount
of the impact were not identified. Therefore,  revisions  of original
cost estimates, after review of data and follow-up telephone con-
tacts, prevented direct modification of individual unit operations.
However, general indications of temperature impacts can be drawn
from the data provided. The percent variations were based on in-
creases above base construction costs estimated for the moderate
0 to 18°C range. As shown  in Table 7, base construction costs
and health  and  safety  increased with  higher  or lower temper-
              atures. Use of an average variation (Table 8) would enable general
              estimate adjustments relative to the impact of anticipated seasonal
              or climatic temperature differences.
              Transportation and Disposal Costs
                The costs of transportation of hazardous wastes varies widely
              with respect to specific jobs and the type of company employed
              to transport the wastes. In addition, the lack of standardized rates
              can result in even more variation depending on the amount of com-
              petition for a given job.  The  ranges obtained  from  this survey
              should reflect cost for  most of the hazardous waste  transporta-
              tion but will not reflect unusual costs associated with some sites.
                Rates can be based on costs per mile, cost per unit measure (i.e.,
              volume and/or weight of cargo) or cost per hour.  A cost per mile
              rate assumes full use of vehicle load capacity. Economies of scale
              will apply to cost per mile and cost per unit measure rates. This is
              true for mileage rates because the cost effectiveness of operation
              is greater when the ratio of time on the road increases over the
              down time spent for mobilizing, loading and unloading.
                When rates are based on cost per unit measure, the cost per unit
              will decrease as load capacity is approached since the cost of trans-
              porting (i.e., costs previously identified) is divided among  more
              units. Hourly rates normally are applied to short hauls (due to the
              increase in percentage of down time), jobs which involve indef-
              inite loading and unloading periods and for additional  costs of de-
              tention times exceeding the time allocated (included in  the cost per
              mile or cost per unit measure rates). The ranges of rates obtained
              during the survey are shown in Table 9.  Costs provided by one
              of the general  freight transporters give an indication of the impact
              of distance on  rates and are shown in Table 10.
                The disposal costs used for this project (Table 11) were obtained
              from  a USEPA publication  "Review of Activities of Major Firms
                                                                                                                 COST
                                                                          379
-------
                                                                     Tablet
                                            Activities Which Impact Potential Worker Exposures While
                                              Conducting Remedial Actions on Hazardous Waste Sites



















Unit Operation
Surface Water Controls:
1. Surface Sealing - Synthetic Membrane
2. Surface Sealing Clay
3. Surface Sealing - Asphalt
4. Surface Sealing - Fly Ash
5. Revegetation
6. Contour Grading
7. Surface Water Diversion Structures
8. Basins and Ponds
9. Dikes and Berms

Ground Water Controls:
1. Well Point System
2. Deep Well System
3. Drain System
4. Injection System
5. Bentonite Slurry Trench
6. Grout Curtain
7. Sheet Piling Cutoff
8. Grout Bottom Sealing


t/i
5
VI
5

Ifl


(5s


o-


+>

>
tj
X
LU

•
•
•
•

•
•



•

•

ID
t» f-
y "S

en 4}
c 3 o>
l_ *fl ••—

* (/)
CT CT> in
= S £ fe
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U C71 Li_
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-•- "D 4-»
- > C
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t- O>
._ Q en i-
4-> C 3
(J -O -i- */l
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••-) n 
«
u
X
Unit Operation ">
Gas Migration Controls:
1. Passive Trench Vents •
2. Passive Trench Barriers •
3. Active Gas Extraction Systems •
Waste Controls:
1. Chemical Fixation (Solidification) •
2. Chemical Injection
3. Excavation of Wastes/Contaminated Soil •
4. Leachate Recirculation
5. Treatment of Contaminated Water
6. Drum Processing 0
7. Bulk Tank Processing o
8. Transformer Processing o


M
S
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CTIM
= »
L. VI
0 i—
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01 01
•ES .£
t— C •—


t- 0» U.
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<-> c
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en
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U
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?
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•


• Denotes applicability.
o Denotes applicability 1f done 1n contaminated area.




                                                                      Table 7
                                                 Impact of Temperature on Remedial Action Costs
ContTKtor-
Scmirlo

11-1
1-2
III-2
II-)
IV-3
III-4
IV-4
l»-5
III-6
*-6
TBWKrtture
™
0-18-
18-38-
co-
0-18-
18-38-
CO-
0-18-
18-38-
CO-
0-18-
18-38*
CO-
0-18-
18r38-
CO-
o-is-
18-38-
co-
0-18-
18-38-
CO-
0-18-
18-38-
CO-
0-18-
18-38*
CO*
0-18-
18-38-
CO-
0-18-
18-38-
CO-

32-65-
65-100*
C32-
32-65-
65-100-
C32-
32-65-
65-100-
C32-
32-65-
65-100-
C32-
32-65-
65-100-
C32-
32-65-
65-100-
C32-
32-65-
65-100-
C32-
32-65-
65-100-
C32-
32-65-
65-100-
C32'
32-65-
65-100-
C32-
32-65-
65-100-
C32-

U«1 0
»
542.921
5S4.633
553.980
181.993
272.990
242.051
~
z
239.184
263.102
318.115
83.909
85.036
84.923
1.083.950
1.104.892
1.140.992
152.055
154.267
•126.037
121.434
123.564
•118.746
374.846
188.812
384.098
17,283
17.283
1 7 .283


I
186
190
189
35
52
46
"
--
225
248
299
35
35
35
30
31
32
8
B
4
9
9
34
48
49
49
11
11
11
	 n
Le«1 C

632.693
702.569
651.717
215.083
322,625
286.060
96.212
139,694
132.142
1.847.859
1 .999,002
1.976,913
282.672
310.939
375,954
121.689
123.741
123.536
2,586,279
2.690,078
2,732.903
276.819
284.368
•232.442
191,175
194.504
•167,207
461,192
482.787
456,403
26.275
28.139
28.139
ETtTTSr


216
240
223
41
62
55
29
43
40
146
345
341
266
293
354
50
51
51
72
75
76
14
15
57
14
14
48
59
61
58
17
18
18

Uvel 8

843.502
1 .067.258
898.484
248,173
372.259
300.070
~
E
326,160
358.776
433.792
136.845
139.921
139.653
4.840.374
5.326. 286
5.315,501
322.347
351.174
•258.518
380.581
409.655
•213,120
459.778
536 .855
486.169
28.584
33.239
33,239



288
364
307
47
71
63
--
--
307
338
408
56
58
57
135
149
149
17
18
64
28
X
61
58
72
62
18
21
21

L«v«l

1.132.788
1.406.375
1.203.433
281 .262
421 ,893
374.078
— +
E
369.648
406.613
491 .632
151.865
160.677
157.851
S. 632. 91 3
6.440.973
6.185.373
341.186
374,881
•281 ,424
432,941
467,512
•258.411
490,210
598,652
S13.582
31,094
39,908
39,908

A

387
480
411
54
81
71
~
--
348
383
463
47
66
65
157
180
17)
18
19
70
32
J4
74
62
76
65
20
25
25
Base Construction

292.636
300.156
299.069
523.763
654,704
591 ,852
326.905
346,818
382,466
579,239
608.201
637.163
106,293
116.922
12O.111
243.044
253,927
251 .044
3.578.0)4
3,805,192
4,145.229
1.946.303
1.9S6.7S9
407,841
1.364,876
1.379.281
•349,836
787,426
820.592
814.315
159.005
161.915
161.915

100
102
102
100
12S
113
100
106
117
109
105
110
100
110
11)
100
104
101
100
IOC
116
100
101
101
100
101
101
100
104
10)
100
192
101
' Partial costs excluding unit opcritlo
* Mot 4v«lUbte since this Scenario Z •
                                      considered Infe«itb1» «t lower tc*>p«r«turt
                                     • only «wltc«bU to («rwJ priced *t) Level C.
    Note:  Pvrctnttgef provided «r* reUtlw to bit* construction costs for 0-18"C temperature r*no4-
380
       COST
-------
                                                             Table 8
                                          Average Percent Cost Variations due to Temperature
Tenperature Ranqes
°C 'F
0-18° 32-65°
18-38° 65-100°
<0° <32°
Base
Construction
100
106
107
Level
Health 1
Safety
65
70
78
D
Total*
165
176
185
Level
Health 1
Safety
84
111
120
C
Total*
1B4
217
227
Lev
health 1
Safety
106
125
132
el B
Total*
206
255
239
Level A
Health 1
Safety
125
149
157

Total*
225
255
264
         • Totll • Health I Safety Costi Plus Base Construction Costs.
                           Table 9
        Ranges of Transportation Costs by Type of Transporter
         Type of Transporter
  Rates
 ($/km)
Treatment, Storage, and Disposal Facilities
  Providing Service to Customers

General Freight Transportation  Companies
  Which May Haul Hazardous Wastes on Request

Hazardous Waste Transportation  Companies
  Specializing in Hazardous Wastes
$0.75-$2.57


$0.75-$3.73


$1.99-$2.60
•Range based on 320 to 1,609 km (200 to 1,000 miles) distance for one-way shipment at $3/220.5
 kg (100 IDS).
                           Table 10
    Rate Schedules for Various Distances and Geographic Locations
Distance
(km)
370
560
740
1,110
1,480
1,850
2*,630


East of the
Mississippi
$1.62
1.34
1.16
0.96
0.86
0.81 +
0.81
Destination Rates*
One-Way
West of the
Mississippi
$1.78
1.51
1.34
1.15
1.05
1.00
0.90+

Round
Trip
$1.27
1.01
0.86
0.74+
0.74
0.74
,0.24
*Rates quoted in dollars per km.
+ Minimum rate-remains constant for all distances above that shown.
in the Commercial Hazardous Waste Management Industry:  1981
Update", SW-894-1. As indicated in the table, the data were based
on interviews conducted in May 1980 and Feb. 1982. The assump-
tions made to convert estimates to $/wet metric tons (WMT), when
conversion factor estimates were not available, were reported to be:
•Volumes in gallons were converted to WMT assuming the waste
 density was that of water (i.e., 8.34 Ib/gal or 0.0037 WMT/gal)
•Cubic yards were converted to WMT on  the assumption of den-
 sity equal to water at 62.4 lb/ft3 or 0.76 WMT/yd'
•Volumes disposed of  in landfills  were assumed to  be bulk ma-
 terials unless drum and bulk distribution was stated
•Capacity reported in acres was converted to WMT by assuming
 available capacity of  430,000 ftVacre or a disposal capacity of
 12,100WMT/acre

CONCLUSIONS
  Cost-effectiveness evaluations of Superfund expenditures require
consideration of additional costs of protecting workers' health and
safety. Unfortunately, not much cost data have been available con-
cerning health and safety considerations. This study represents part
of the effort to identify and estimate costs associated with protec-
tion of worker health and safety. Although the findings and results
of this project cannot be considered the final answer, they will en-
able site management and planning personnel to generalize health
and safety cost impacts.
  Several factors which impact  cost were  identified  but  not
addressed within the scope of this project. These include:
•Scale Economies
•Regional Differences
•Management Policies and Procedures
•Type and Size of Company
  Previous studies have shown scale economies and regional var-
iations to be significant in construction costs.  It would be reason-
able to assume similar impacts on health and safety costs. How-
ever,  it was not possible to quantify the impact of these factors
based on the existing data.
  During the course of this project, differences in the management
procedures and policies were identified which impacted the cost es-
timates  provided. Currently,  there are no regulatory  standards
which are uniformly enforced on hazardous waste sites. There-
fore, the impact of safety management policies and procedures of
individual contractors can significantly impact  health and safety
costs. In addition, the emphasis placed by a given contractor on the
use of equipment versus manpower to accomplish the tasks re-
quired can also impact the health and safety costs due to the differ-
ences in the exposure potential for workers operating machinery
versus workers directly handling containers and/or contaminated
materials.
  The type  and size of companies involved will impact their abil-
ity to make most efficient use of equipment and personnel. Large
companies  with deep resources and a backlog  of work projects
can coordinate the use of equipment and personnel among projects
to be more cost-efficient. However, smaller companies or specialty
firms with  smaller resources and fewer projects may incur higher
costs in order  to maintain a qualified staff and cover overhead ex-
penses of idle  equipment. Use of the data from  this report should
include evaluation of possible impacts of these factors.
  The primary result of this report is a means to  adjust remedial
action cost estimates to reflect additional costs of health and safe-
ty considerations. This may involve adding these health  and safety
costs  to engineering study  cost estimates  based  on standard con-
struction cost estimates  or adjusting  cost estimates  from actual
sites. Adjustments made will reflect the costs associated with varia-
tions in the degree-of-hazard conditions on the site being evaluated.
Additional applications may include:
•Calculation of costs for various applications of unit operations.
 For example, the cost of constructing a drain system for leach-
 ate collection could be evaluated for  on-site versus off-site loca-
 tions. The added costs for increasing the intercept area off-site
 could be compared with  the  added costs of worker safety and
 health considerations for a smaller system installed in the contam-
 inated areas on-site.
•Planning of site assessment activities prior to initiation of remed-
 ial action  activities.  The worst degree-of-hazard condition which
                                                                                                                 COST
                                                                          381
-------
                                                              Table 11
                Comparison of Hazardous Waste Management Quoted Prices for all Firms in 1980 and for Nine Major Firms in 1981*
Price
Type of Waste
Landfill
Management Type or Form of Waste
Drum
Bulk
1980
$25-$35 $/55 gal drum
$40-$50/ton
1981
$35-$50/55 gal drum
$50-$75/ton
^/Metric Ton
1980
$120-$168
$44-$55
1961
$168-$240
$55-$83
Land Treatment
                       All
                                                    $0.02-$0.09/gal
                                                                           $0.02-$0.09/gal
                                                                                                      $5-$24
                                                                                                               $5-$24
Incineration
Chemical Treatment
Resource Recovery
Deep Well Injection
Transportation
Relatively clean liquids, high
Btu value
Liquids
Solids, heavily toxic liquids
Acids/Alkalines
Cyanides, heavy metals, highly
toxic wastes
All
Oily wastewaters
Toxic rinse waters

$0.20-$0.90/gal
$0.20-$0.90/gal
$1.25-$2.50/gal
$0.06-$0.30/gal
$0.20-$2.00/gal
$0.19-$0.80/gal
$0.06-$0.15/gal
S0.50-$1.00/gal

$(0.05) -$0.20/gal
$0.20-$0.90/gal '
$1.50-$3.00/gal
$0.08-$0.35/gal
$0.25-$3.00/gal
$0.25-$1.00/gal
$0.06-$0.15/gal
$0.50-$1.00/gal
$0.15/ton mile
$53-$237
$53-$237
$330-$660
$16-$79
$53-$528
$50-$211
$16-$40
$132-$264

$(13)*-$53
$53-$237
$395-$791
$21 -$92
$66-1791
$66-$264
$16-$40
$132-$264

•Interviews were conducted in May of 1980 and Feb. of 1982.
-I- Some cement kilns and light aggregate manufacturers are now paying for wastes.
SOURCE: U.S. Environmental Protection Agency. "Review of Activities of Major Firms in the Commercial Hazardous Waste Management Industry: 1981 Update". SW-894.1. May 1982.
 is anticipated, based on available information, would determine
 the cost of worker health and safety protection which would be
 provided. The potential savings of reduced health and safety costs
 for less  hazardous conditions  could be calculated. The  cost-
 effectiveness evaluation of conducting more detailed site  char-
 acterization and  waste stream identifications to define degree-
 of-hazard conditions could then include consideration of potential
 savings if conducted prior to initiation of remedial actions.
ACKNOWLEDGEMENTS

  The project discussed in this paper was performed under USEPA
Contract No. 68-03-3028, Directive of Work No. 14. The authors
would like to thank  the USEPA Project Monitors, D. Ammon
and D. Sanning of the USEPA Municipal Environmental Research
Laboratory, Solid  and Hazardous  Waste Research Division in
Cincinnati, Ohio.
                                                        DISCLAIMER

                                                           The information and data presented in this paper do not neces-
                                                        sarily reflect the views and policy of the USEPA. This paper was
                                                        based  on the Draft Final Report—Costs of Remedial Actions at
                                                        Uncontrolled Hazardous Waste Sites— Worker Health and Safety
                                                        Considerations which  is  currently in  the  USEPA peer review
                                                        process.

                                                        REFERENCES

                                                        1. "Review of Activities of Major Firms Involved in the Commercial
                                                           Hazardous Waste Management Industry: 1981 Update," SW-894.1,
                                                           USEPA, Washington, D.C., May 1982.
                                                        2. "Interim Standard Operating Safety Guides", USEPA Office of Emer-
                                                           gency and Remedial Response, Hazardous Response Support Division,
                                                           Edison, N.J., Sept. 1982.
                                                        3. "Remedial Actions at Hazardous Waste Sites: Survey and Case Stud-
                                                           ies," EPA 430/9-81-05  SW-910.  Oil and Special Materials Control
                                                           Division, USEPA, Washington, D.C. Jan. 1981.
 382
COST
-------
                          PUBLIC  AWARENESS  PROGRAMS
                                                GEORGE M. FELL
                                                Chem-Technics Inc.
                                             Rolling Meadows, Illinois
INTRODUCTION

  Public awareness of waste disposal grows daily as issues and con-
tinuing revelations unfold across the country adding emphasis and
credence to continue the public "hue and cry." The public's senti-
ments were  captured by Shakespeare in King John:  "Oppressed
with wrongs and therefore full of fears." For despite new and far-
reaching legislation, including  public participation, many Amer-
icans perceive that the risks to  their health and safety are still too
great.
  What those who would and do operate under the new guidelines
have found is a polarized public who will, under no circumstance,
tolerate waste disposal activities in or adjacent to their community.
Those charged with  implementing the new standards are now call-
ing for public education programs. In a confrontational  atmos-
phere in which industry, legislators and regulatory agencies have
lost the credibility and the  confidence of the public, can  one  be
so presumptuous as  to imply that it is the public who must be edu-
cated? What is needed and  sought by the public is the  opportun-
ity to discuss the issues as  equals. A surgeon  will approach his
patient with respect  for human nature, expertise notwithstanding.
To be on the receiving end of subjective logic is not conducive to
allaying one's fears.
  Consider  the average citizen's position.  The new regulations
have not eased the financial burden if one  feels that he has been
exposed to or impaired by a waste disposal activity. Certainly the
grounds  for restitution are  more clearly defined. However, legal
fees, expert  witnesses and medical expenses are costly  and time-
consuming even if the citizen  is fortunate  enough to find a law
firm that will take the case on a contingency basis and if there is a
medical policy in effect that provides maximum benefits. Is it any
wonder, then, that,  upon learning that a company intends to con-
struct a waste disposal facility,  a community bans  together  to stop
its development and  urges that it be put "somewhere else."
  As many of you know, "somewhere else" meets with the same
reception. Equally, current facilities will soon compound the crisis
by reaching  capacity. Knowing that, it is doubly important to in-
stitute frank and open discussions with the public as equals. The
name given to such programs is  immaterial. It is essential that these
programs be implemented, even if initially  unsuccessful, for they
can create a cadre of people from all walks of life and divergent
views who, through their own  scrutiny, will agree that  waste dis-
posal as an industrial activity can be conducted safely  and with-
out stigma to the host community or its citizens. Such a group,
C.A.R.E.S.—Committee for the Advancement of Responsible En-
vironmental  Solutions, has emerged in Illinois. They reflect what is
intrinsic in American society. Indeed, Thomas  Jefferson must
have had such people and problems as the nation now faces in
mind when he stated:  "I know of no safe depository of the ulti-
mate forms of society but the people themselves; and if we think
them not enlightened enough to exercise their control with a whole-
some discretion, the remedy  is not to  take it from them,  but to
inform their discretion." So, it is with these thoughts in mind, that
the following remarks are offered.
PUBLIC RELATIONS PROGRAM
  Developing a compatible relationship between a company pro-
posing to locate a waste facility, the elected officials of the host
community and its citizens requires  sensitivity, skill, timing and
respect. All parties must acknowledge that a company seeking to
locate a facility has a vast number  of basic business and logistical
evaluations to undertake: road network, utilities, rate  structure,
land costs, applicability to the market to be served and regulatory
environmental needs. Factors such as these are normally conducted
within the confines of the company, not in the public forum, since
there may be  a whole series of commercial reasons for rejecting a
potential location.
  However, once a location has been chosen, it is  critical that
everyone in the community has access to the same  information
simultaneously. Informational material must be in plain language
with an introduction that provides an explanation for choosing
that location, the background work  that has already been com-
pleted, any discussions that have taken place and who  was party
to those discussions. This is  a key factor in assuring the public
that there have been no clandestine arrangements other than pro-
prietary activities up to this point in time.
  Other information that should be provided includes the site loca-
tion, the type of facility that is proposed (including its operating
life), the types of materials to be handled and the industrial source
(geographic location: local, state or regional).
  Additional  information  might  include statutory  review pro-
cedures, the time frame and  how it will dictate construction and
operational start-up of the facility, the  company's policy in either
staying within the mandatory time  frame or staggering its applica-
tions to provide additional public discussion, the name of the per-
son within the company responsible for responding to the public in-
quiry and where that person can be reached.
  The public  also needs to have a  history of the company and its
past experience or rationale for considering that it has or will ob-
tain the necessary experience in the activity proposed.
                                                                                       PUBLIC PARTICIPATION
                                                                                                                       383
-------
  There should be a summary listing the various elected representa-
tives (Federal, State, County,  Municipal)  by name, address and
telephone number  for citizen contact.  Regulatory agencies from
which information may be secured, and names of individuals to
whom representations might be made should be listed. Local chap-
ters  of  national environmental  organizations and  other public
action groups where a  citizen might get  a  different perspective
might also be included in the information. Conclude  by listing
detailed or technical data that will become  available as part of the
statutory application. All of the above information should be con-
tained in a handy reference-size brochure.
  Perhaps the most difficult task is a simultaneous release of in-
formation without offending either side. Experience has suggested
that a mass mailing to every  household in  the host community
coinciding the delivery date with a press conference (radio, tele-
vision and print)  with  time set aside  for reporters to conduct
followup interviews, is very effective. Thought should also be given
to regional media, as well, because of interest from communities
adjacent to the host community.
  Presentations to local and county officials should be followed by
more extensive written material and technical data for  their pro-
fessional staffs.  This should include adjacent communities with
special emphasis on the facets that are of particular importance
such as transportation routes and emergency  response plans in the
event of an  accident.  It  is particularly important  to  recognize
that elected officials and their  staff will bear the brunt of citizen
complaints and requests for information, and every effort must be
made to insure that they have  access to information generated by
independent sources.  If information is derived  solely  from  the
company, it is suspect.
  It is vitally important to maintain candor  with the media, to keep
them apprised of questions that are being  raised  and the com-
pany's response and its rationale for  the response. Above  all,
presentations and  meetings with community  residents must be
conducted in a non-threatening  atmosphere  and in surroundings
that are conducive to discussion such as private homes, schools or
church halls.
  A company must recognize that the issues they will have to face
are not all centered upon environmental  regulations.  Questions
will arise on such matters as Federal and State highway and vehicle
construction. Indeed, the very fundamentals of engineering and
construction will be called into question.
Risk Assessment

  Perhaps the most difficult areas of questioning will focus on the
highly specialized fields of epidemiology,  toxicology and risk
assessment. The latter, quite frankly, places a value on human life
and welfare.  When an individual is confronted with  that knowl-
edge, insuring peace of mind becomes much more difficult. Point-
ing out that an individual is already covered by actuary tables on
just about every insurance or medical policy issued to him is not
much comfort either. It is a chilling thought to consider one's own
mortality: everyone else is mortal  except one's self. How is it
possible to weigh possibility against probability when one's chil-
dren are at stake? As companies such as  the Ford Motor  Com-
pany  with its Pinto problem or the Johns-Manville reorganiza-
tion  under Chapter Eleven on the asbestos-related  claims  have
found, risk assessment and cost benefit analysis take their toll, not
only in financial terms, but also in their public images. One must
ponder which of the  existing disposal  companies could not find
themselves in a similar situation.
  The cornerstone for developing a relationship with the host com-
munity is the intent to the company. For better or worse, the pub-
lic will judge the company on its past performance. And while no
company brandishes  a  stainless record, past  practices  must be
acknowledged. Public confidence will depend, too, on the reliabil-
ity and sincerity  of the company  spokesperson, who should be
senior or executive-level management.  Continuity of the spokes-
                                                       person and assured public access is essential to the credibility and
                                                       the intent of the company.


                                                       PUBLIC PARTICIPATION
                                                         Public participation in hazardous waste issues, more than in
                                                       any other, is one in  which a citizen must collaborate with his
                                                       neighbor.  Many in industry, regulatory agencies and the media see
                                                       the public as the protagonist, and in many community-oriented
                                                       groups this has been true. However, this role has been forced upon
                                                       the public because it  has had to deal with the aftermath of un-
                                                       scrupulous practices rather than acting as a full participant. An
                                                       informed  citizen, given all the facts, scientific or otherwise,  can
                                                       be a vitally important participant.
                                                         The importance of this lies in the urgency of the current situa-
                                                       tion: landfills are rapidly filling up,  and implementing alternative
                                                       technology takes time. How can the public be expected to partic-
                                                       ipate in an evenhanded and expeditous manner when it is con-
                                                       stantly bombarded with  revelations  resulting in lengthy investi-
                                                       gation, litigation and  resolution by the judiciary? Taxpayers and
                                                       consumers know this is costly. How, then, can the public have faith
                                                       in the system that put it at risk in the first place?
                                                         Benjamin Franklin had some excellent advice about this: "In the
                                                       affairs of this world people are saved not by faith, but the want of
                                                       it."
                                                         Waste disposal is an issue that can divide families, friends and
                                                       community leaders; it  is an issue that one cannot and should not
                                                       ignore. One cannot accept another's perfunctory position.
                                                         What should be the public's level of participation? If a waste
                                                       disposal facility is proposed for a community, its residents should
                                                       know that under recent Federal, State and local regulations a facil-
                                                       ity would not be approved if it did not technically meet or  exceed
                                                       the standards established  for its construction, operation and clos-
                                                       ing at the end of its useful life. However, these reviews are under-
                                                       taken between experts, and the public is aware that people do make
                                                       mistakes. So what if there is a fire or a truck turns over and spills
                                                       it contents? Accidents  do  happen. Will poisonous fumes or liquids
                                                       escape into the air and water? How do the experts know that they
                                                       will not? Whom would one contact with a complaint? If residents
                                                       are affected,  who pays and how quickly? What about property
                                                       values  during operation  and, particularly,  after  the  facility is
                                                       closed? These are just a sample of  questions that spring to mind
                                                       when one learns of a proposal to site a facility in the community.
                                                         Finally, one cannot  forget the stigma of "Garbage City U.S.A."
                                                       in  playing host to "state-of-the-art" technology. Is it that, or just
                                                       a variation on the shell game—now you see it, later you may have
                                                       to eat or drink it! These are questions to which one can and should
                                                       solicit answers, assurances and explanations.
                                                       Information

                                                         A request  for information from  a company usually results in
                                                       presentation of an enormous amount of written material contain-
                                                       ing expert testimony  with terms and expressions akin to a new
                                                       language.  How does  one phrase  and pose  questions  without
                                                       appearing foolish? When attending  a public meeting and being
                                                       faced with opposing factions  who are hostile, how does one raise
                                                       concerns  without becoming the target  of community  fury and
                                                       scorn?
                                                         Collect  information made  available  by the company, local,
                                                       County and  State officials; watch  for  articles in the local  and
                                                       regional newspaper, on radio and on television. Use them to ans-
                                                       wer questions—they are "only a phone call away." This is an ex-
                                                       cellent way of getting citizens' views heard, and the professional
                                                       staffs of these organizations, particularly the media, are skilled in
                                                       sifting  through comments and determining the core  of the ques-
                                                       tions.
                                                          Be particularly careful of  petitions and telephone  canvassing
                                                       unless there is an opportunity to study the questions and  ask for
                                                       clarification.  Stock or carefully-worded phrases do not always re-
 384
PUBLlt PARTICIPATION
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flect^ or address the concerns one may have, and they are often
used to reflect an opinion that is not held by the popular majority.
  Sometimes a response to a question is covered by certain regula-
tions such as the control of liquids and  fumes escaping from the
facility. Request a copy of the regulation or a plain language ex-
planation of it. If a plain language document is provided, there
will be a disclaimer such as, "This document does not include com-
plete or verbatim quotations from Federal, State or local regula-
tions  or hearings.  References  made to  them are to  summarize
pertinent aspects for general information only, etc., etc." This is
not a company or  agency trying to dodge issues at the  public's
expense but is rather a liability requirement to protect the research-
er who produced the material, which is, after all, an interpreta-
tion and not the actual document. The important factor is that one
then has  the knowledge of the applicable regulation and the in-
formation from which to form an opinion.
   Quite often a regulation calls for specific equipment  to be used.
Ask where it is currently in  use and, if  it is at a local company,
ascertain  what  their experience has  been from friends  or asso-
ciates who may work there. In this manner it is possible to gain
firsthand knowledge from a known and trusted source.  Without
doubt, collaboration with one's neighbors will open up a whole
area of practical experience, since many  of the principles that will
be employed at a waste disposal facility  have  their roots in estab-
lished manufacturing, construction and engineering tenets.

Insurance
   Ask about  insurance and what level  of  coverage is provided.
Next to government regulations and statute, an insurance company
can  be the best protector  of  health  and welfare.  They always
attempt to minimize their risks  and, in addition to the experts they
have on staff, they have access to information on a whole range of
actual documented experience in equipment, chemical compatabil-
ity and health safety. Inquire  if an insurance representative will
attend a neighborhood meeting. They like to  chat and they are a
friendly bunch! Find out how the community can be kept advised
if there is a change either in the policy or the  insurance company.
Everyone knows, for example, that a bad driving record will result
in a loss of policy or, at best, lower coverage and higher premiums.
These considerations are often  overlooked by citizens who should
be aware that an insurance company's critique and ongoing review
is every bit as rigorous as a regulatory agency's.

PAST PROBLEMS
   There have been a number of tragic chapters written about the
inadequacy of the waste disposal industry, and the remainder of
the story has yet to be written. However, many facets, including
citizen awareness and new and more stringent regulations, will pro-
hibit these issues from arising  again. To insure that they do not,
requires citizen participation in discussions with regulatory person-
nel, elected officials and the companies that will operate the facil-
ities. These discussions should be frank and non-hostile, for noth-
ing can be gained if fear and anger prevail. Father a few neighbors
together in a home, club or church hall, and invite a company
representative to talk with community residents—not at them or
above them. In this manner they will come to know a person, not
an entity that is lost behind a corporate or agency image that has
no form or substance other than in legal terms. It is the public's
trust and understanding that  is  sought, ana the public must grant
it, albeit carefully, if waste disposal is to be  accomplished as it
must. For despite the notoriety the waste disposal industry has
gained, citizens do have a contribution to make in reviewing pro-
posals: it would be unfortunate if the only contribution is through
enmity, perfidy and cynicism.

CONCLUSIONS
  To summarize, public awareness and participation is long over-
due in the area of waste disposal. It is a public health service that
has as vital an impact upon society as the medical profession and
the food and pharmaceutical industries. They  come from similar
beginnings to reach the prominence they enjoy today, because the
public accepts their high standards as a fundamental requirement.
This was not achieved by simply implementing more stringent legis-
lation,  but by the practitioners in their fields  striving for stand-
ards greater than the minimum required by law. Such internal self-
discipline has brought its own rewards of public  confidence and
trust. When there has been a breach in these standards, it has been
recognized by the public for what it was, an isolated incident that
was not necessarily a breach of credibility in an entire profession
or industry.
  Likewise,  all  those  associated  with  waste  disposal activities
must try to provide more information, better access to decision-
makers and greater time so that the public believes that it has had
an opportunity to weigh the alternatives. As workers, shareholders,
consumers or taxpayers, they will  ultimately pay the bill. A pru-
dent person, from whatever point of interest or involvement, must
admit that ideas and knowledge improve with sharing.
  It would appear that the only arbiter acceptable to all parties
at this  time is the judiciary who render  decisions on the spirit or
intent as well as on the letter of the law. A program of awareness or
participation that addresses the  issues in substance will have cred-
ibility in their decision-making.  This will then earn the respect of
the majority of the public.  However, this is not a long term solu-
tion: in fact,  it is one of last resort,  for it will still pit the clear-
eyed objectivity and logic of the expert against the ordinary person
feeling ill at ease and threatened because he does not know how
best to prepare for his own or his children's future.
  Perhaps the most fitting  closing is to quote E.F. Schumacher's
SMALL IS BEA UTIFUL: Economics As If People Mattered:
"Out of the whole Christian tradition, there is perhaps no body
of teaching which is more relevant and appropriate to the modern
predicament than the marvelously subtle and realistic doctrines of
the Four  Cardinal  Virtues—prudentia,  justitia,  fortitude, and
temperantia."
                                                                                          PUBLIC PARTICIPATION
                                                          385
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      INSTITUTIONAL CHALLENGES  OF THE SUPERFUND
                     COMMUNITY RELATIONS  PROGRAM

                                         ANTHONY M. DIECIDUE
                                            DAPHNE GEMMILL
                                   U.S. Environmental Protection Agency
                                               Washington, D.C.
                                                EDWIN BERK
                                               ICF Incorporated
                                               Washington, D.C.
INTRODUCTION
  With nearly three years experience in implementing the Super-
fund program, response to hazardous waste site problems contin-
ues to be one of America's most emotionally sensitive public issues.
Within the past year alone, several major controversies surround-
ing sites across the nation have intensified the frustration citizens
are expressing about these problems.
  The USEPA, having the primary responsibility for administer-
ing the Superfund program, has established a community rela-
tions program that, under its policy, recognizes and requires cit-
izen involvement as an integral part of every Superfund-fmanced
action. Although USEPA established the final policy and guide-
lines for  conducting community  relations programs on  May 9,
1983,  institutional challenges remain to be overcome if these pro-
grams are to be successful.
  In this paper, the authors discuss the evolution USEPA's Super-
fund Community Relations Policy has undergone while the Agency
has attempted to educate citizens about hazardous waste site prob-
lems they are facing and to  involve them during response actions
to correct these problems. The authors also discuss institutional
challenges that have arisen in the past three years, as well as ones
likely to be encountered in the future. These challenges will need to
be overcome if technical solutions to hazardous waste site problems
are to  be successful and supported by the public.

HAS THE SUPERFUND COMMUNITY
RELATIONS POLICY CHANGED?
  In  Nov. 1981,  the  newly formed Office of Emergency and
Remedial Response issued a Superfund community relations pol-
icy and guidance document whose purpose was to provide guide-
lines for implementing community relations programs for Super-
fund-financed remedial actions and removal actions lasting longer
than a few days. The document provided USEPA's regional offices
with the necessary flexibility to conduct community relations pro-
grams  tailored to each specific Superfund site. The only require-
ment was for the preparation of a community relations plan. These
plans are to enable community relations activities to be  integrated
into the technical responses  at Superfund sites to ensure that the
community has a voice in these actions.
  In Mar. 1982 and May 1983, additional refinements to the policy
were issued. The basic intent  of the 1981 policy, however, is as rele-
vant today as it was when first issued.
Program Objectives
  Each Superfund community relations program is directed toward
the following objectives:
                                                   •To gather information about the community in which a site or
                                                    incident is located. A community relations program provides a
                                                    vehicle for exchanges between USEPA, the state, the public, and
                                                    local government. It enables USEPA and state staff to identify cit-
                                                    izen leaders, public concerns and a site's social and political his-
                                                    tory. Sometimes it can also yield  technical data useful in plan-
                                                    ning a solution to the site's problem—or information useful in an
                                                    enforcement case against a responsible party.
                                                   •To inform the public of planned  or ongoing actions. The pro-
                                                    gram should inform the public of the nature of the environmental
                                                    problem, the remedies under consideration and the progress al-
                                                    ready made.
                                                   •To give the public the opportunity to comment on and provide
                                                    input to technical site decisions. The program should enable cit-
                                                    izens to understand and comment on decisions that will have long-
                                                    term effects on their  community. Any course of action stands a
                                                    greater chance of public acceptance if citizens have been involved
                                                    in its planning.
                                                   •To focus and resolve  controversy. Conflict has been unavoidable
                                                    in some circumstances, but it can be constructive if it brings into
                                                    the open alternative viewpoints based upon solid reasons for crit-
                                                    icism or dissent. An effective community relations program chan-
                                                    nels conflict into a forum where it can serve a useful purpose.
                                                    When such opposition has already arisen, a concerted attempt to
                                                    communicate with and involve all parties can help reduce tension.
                                                     The program, therefore, continues to encourage two-way com-
                                                   munication between communities and government.
                                                     In meeting  these objectives, five general  principles must be
                                                   stressed.
                                                   •The community relations effort at a particular site must be tail-
                                                    ored to the distinctive and individual characteristics of the site and
                                                    surrounding community.
                                                   •The design of a community relations program for a site should
                                                    take into account both the technical complexity of the problem
                                                    and the level of citizen concern. A more intensive program is re-
                                                    quired  for situations that are  either technically complicated or
                                                    have generated a high level of citizen concern.
                                                   •Open and honest community relations planning is essential to an
                                                    effective Superfund response.  The key to proper planning is 8
                                                    thorough knowledge  of a particular community's concerns at a
                                                    site and the schedule for technical action.
                                                   •In most cases,  small-scale, informal communication techniques
                                                    should be used rather than large scale, formal techniques (such
                                                    as public hearings).
                                                   •Finally,  adequate opportunity must be given for the public to
                                                    comment on proposed  remedial cleanup  actions prior to final
                                                    USEPA decision-making.
386
PUBLIC PARTICIPATION
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Program Implementation

   As noted above, the only firm requirement  for a site  com-
munity relations program is the preparation of a plan in advance of
initiating site activities.  A community relations  plan is really a
management tool which outlines the specific communications activ-
ities to be used during a  Superfund response and  how these activ-
ities will be integrated with the technical work to be performed.
  The plan must include  an assessment of community interests and
concerns. These assessments are  based on discussions with local
officials, civic leaders and residents living in the vicinity of the site.
The  assessments  enable those  responsible  for  conducting  the
response action to gauge concerns and determine the level of com-
munity interaction necessary during the response. Each plan must
contain the following elements:
•A background and history of community involvement at the site,
 which in most cases can  be extracted from the assessment
•The specific objectives  of the community relations  program  for
 each particular site being addressed
•The community  relations techniques to be used to meet  these
 specific objectives, including periodic progress reports  on site
 work being performed and reports on upcoming activities
•A workplan and schedule
•A budget and staffing plan
•A list of names and addresses of affected and interested groups
 and individuals,  USEPA, other federal  and state technical and
 community relations officials
   An important aspect  of these plans is that they  are evolving
documents, revised at each stage of the process—from the remedial
investigation and feasibility study through design and construction
of the solution.  At the conclusion  of each stage (e.g.,  after a
feasibility study and after a construction) a responsiveness sum-
mary is prepared. This summary  includes a list of the community
relations activities conducted, an account of the  issues that  arose
and an explanation of how citizen concerns were dealt with during
the response.
Administering the Community Relations Program

   USEPA headquarters  will continue to be responsible  for  na-
tional management of the program including policy development,
review of community relations plans  and overall monitoring and
evaluation.  Headquarters also continues to provide informational
materials on Superfund  and overall  management of contractors
providing support to site-specific response actions. A permanent
community relations staff has also been established at headquart-
ers,  enabling the  program to provide the needed supervision to
make community relations in Superfund a success.
   The USEPA  regional offices  continue to be responsible  for
development, implementation and revision of community relations
plans (in conformance with the policy) during federal lead response
actions. The regions also continue to supervise contractors  provid-
ing community relations support as well as coordinating their activ-
ities with states.
   The  states continue to be  responsible for development, imple-
mentation and revision of community relations plans (also in con-
formance with this policy) when they have the lead during response
actions. They are also responsible for hiring their own support
contractors, if necessary, and for  coordinating their activities with
the Region.

Community Relations Policy Additions

   In May 1983,  two new elements were  introduced to the com-
munity relations program. With  three years of experience imple-
menting community relations programs at Superfund  sites,  the
Office of Emergency and Remedial Response recognized the need
to stress community  relations during  emergency actions.  Until
recently, press and  community briefings, informational meetings
and on-site information offices—in  other words, one-way  com-
munication—had been the recommended techniques. A short com-
munity relations plan (or profile) must now be prepared. This re-
quirement is  intended to ensure that two-way communication is
now carried out during emergency actions lasting longer than a
few days.
  The major addition to the policy, however, is the requirement
that the public be given a three week comment period to review
feasibility studies prior to selection of a site remedy. This require-
ment, together with other community relations activities, enables
the Superfund  community relations program requirements to be
functionally equivalent  to National Environmental Policy  Act
(NEPA) public participation requirements.

Emphasis on Community Discussions

  While the initial policy suggested the use of interviews as a basis
for establishing communication with citizens and developing com-
munity relations plans, this  technique was not emphasized.  The
purpose of these interviews with citizens and local officials is to
accurately identify local  concerns and major issues.  These  dis-
cussions provide USEPA regional staff with valuable background
information necessary to fully understand the site history from the
community's  perspective, to identify citizens, officials and organ-
ized groups expressing concern and to evaluate the level and nature
of these concerns.
  It has become increasingly clear to  those individuals conduct-
ing community relations programs that this information is indis-
pensible in  preparing community relations plans. Information de-
rived from  these discussions  is also proving to be  a required  pre-
requisite to successful community relations efforts at sites. There-
fore, as of  May 1983, local discussions have become the founda-
tion for community relations planning at each site.
HOW IS USEPA ENSURING THAT
THE POLICY IS CARRIED OUT?
  USEPA's Superfund community relations policy is  a head-
quarters  office product. Programs are implemented, however, by
the regional offices or by state governments when they have the
lead in a response action.
  Requirements  for implementing  the program, as noted, have
been kept to a minimum. This enables regional offices and states
to tailor  their  efforts to the distinctive characteristics of the site
and surrounding community, while remaining free from too many
bureaucratic requirements. In consequence, however, headquarters
staff have found it difficult to keep track of whether commun-
ity   relations programs were  being  developed  for  Superfund
responses and, even if so, whether any of the activities planned
were being conducted. Furthermore, a headquarters review team's
visit of regional offices over the past year, although confirming the
soundness of a flexible approach, found that the commitment  to
the program differed from region to region.

Additional Procedures
  In response to this problem, the policy changes outlined above
have been implemented  and  new  procedures have been devel-
oped to  permit  better program oversight  and  accountability  at
headquarters. Some of the major improvements include:
•Formal  procedures  have been outlined  detailing  the  specific
 responsibilities  and timetables for meeting internal community
 relations requirements. These procedures give headquarters, reg-
 ions and states for the first time a specific understanding  of how
 the community relations process must take place.
•USEPA headquarters has also developed a tracking system for
 community relations activities at sites. This system provides com-
 munity  relations staff and management with site specific informa-
 tion about whether or not planned activities have occurred and
 when events  are  scheduled, including  changes  or  modifications
 when conditions warrant.
•An interim final version of the community relations handbook—
 Community Relations in Superfund—A Handbook—is also now
 available. This  handbook supplements the policy and incorpor-
                                                                                         PUBLIC PARTICIPATION
                                                          387
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ates the program's background material and detailed procedural
guidance into one complete document.
  These management and procedural changes should also strength-
en coordination between USEPA headquarters, regional Super-
fund offices and state offices. The desired result should be a well
defined and administered system of community relations that re-
flects the Agency's commitment to the program.

WHAT INSTITUTIONAL CHALLENGES REMAIN?
  The  Superfund program has witnessed a steady growth in iden-
tifying sites that appear to present  a  significant risk  to  public
health  and the environment. USEPA's National Priorities List
(NPL) has grown from 115 sites in Oct. 1981, to a total of 546 sites,
final and proposed, in Sept.  1983. The environmental  commun-
ity, meanwhile, has begun to  organize. Various environmental
groups are conducting regional meetings  on community organ-
izing. The Environmental Defense Fund (EDF)  has even issued a
handbook, Dumpsite Cleanup: A  Citizen  Guide to Superfund.
An aware public can only mean an increase in the amount of com-
munity interaction for the Agency  in the next few years.  Several
barriers to an effective community relations program must still be
overcome.
Better  Understanding Still Required
  USEPA's efforts at identifying uncontrolled hazardous waste
site problems do not necessarily correlate to its ability to respond
quickly to the  problem.  Furthermore, inclusion of a site on the
NPL does not  mean  that USEPA  will undertake a response ac-
tion, nor does  it establish timetables for response. Public educa-
tion on the complexities of the problem and the various avenues
of response to  be considered will help prevent the development
of unrealistic public expectations for the program. Areas where
further public  understanding  is most  pressingly  needed are as
follows:
•Why  listing of a site on the NPL does not bring immediate clean-
  up. The public needs to understand that initial listing of a site on
  the NPL is intended  only to guide USEPA in determining which
  sites  warrant further investigation and to help set priorities for
  possible funding. Information collected to qualify sites  for the
  priorities list is not sufficient to determine the appropriate rem-
  edy for a particular site.
•Why  additional studies are required to select an appropriate
  remedy. The public must understand that after a site has been in-
  cluded on the  NPL,  USEPA will conduct further, more detailed
  studies. USEPA  relies on these studies to determine what  re-
  sponse, if any, is appropriate. Public understanding is also essen-
  tial on how decisions on the type and extent of remedial action
  are made,  especially as they relate to cost-effectiveness, fund-
  balancing and  other statutory and regulatory requirements.
•Why  various response and enforcement actions are considered.
  Given the limited resources available in the Hazardous Substance
  Response Trust Fund, USEPA must carefully decide between two
                                                        avenues on a site-by-site basis: whether to take enforcement ac-
                                                        tion or to proveed directly with Fund-financed cleanup and seek
                                                        recovery of response costs afterward. The public needs to under-
                                                        stand how these determinations are made and the factors influ-
                                                        encing them.
                                                       Dedication of Resources
                                                         Most of  the funds expended so far for sites on the NPL have
                                                       been for  remedial investigations and feasibility studies. Sites with
                                                       these activities now underway will begin to enter the cleanup stages
                                                       in the near  future. In the Superfund program, citizen involvement
                                                       peaks when long-term cleanup proposals are announced. The ac-
                                                       tual cleanup actions selected are frequently the source of actual or
                                                       perceived significant  personal inconveniences  and potential im-
                                                       pacts to nearby residences.
                                                         USEPA and state  staff  responsible for carrying out  commun-
                                                       ity relations programs must be aware of and be ready for an in-
                                                       tensification of their efforts. This will continue to be a critical and
                                                       challenging task as more and more sites begin to receive  funding.
                                                       USEPA's Regional office and state resources—already overly taxed
                                                       in some cases—may  be insufficient to meet  an increase  in the
                                                       demands upon community relations programs. To counter these re-
                                                       source limitations, contractor support will be required. Additional
                                                       USEPA and state staff may also be required.

                                                       Interagency Involvement
                                                         As the Superfund program gains maturity and experience, addi-
                                                       tional government agencies—the Army Corps of Engineers, the
                                                       Federal Emergency  Management  Agency,  the Department of
                                                       Health and Human Services—will have increased roles and respon-
                                                       sibilities.  This division of responsibilities, although a partnership,
                                                       will make it difficult  to  ensure that the government "speaks with
                                                       one voice". USEPA will need to work closely with these agencies
                                                       in order  to maintain coordination and consistency  toward their
                                                       individual  technical  and community  relations efforts.  If these
                                                       agencies are perceived as being uncoordinated and conflicting, it is
                                                       only natural that citizens will question their ability to  solve site
                                                       problems.

                                                       CONCLUSIONS

                                                         It has been an unfortunate history of the Superfund program
                                                       that controversial issues  surrounding sites have  received the major
                                                       public, political and media attention. There is  no doubt that the
                                                       program will live out most of its life in a "fishbowl."
                                                         Community relations  programs taking place now and  in the
                                                       future will  need to keep communities well informed and provide
                                                       some local  role in decision-making. The results should be to pre-
                                                       vent misunderstandings,  unrealistic expectations and needless frus-
                                                       trations.  In turn,  there should be greater local  acceptance of re-
                                                       sponse actions that are intended to protect the health of citizens in
                                                       the community, their welfare and their environment.
388
PUBLIC PARTICIPATION
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         HOW  ONSITE ASSESSMENTS CAN  HELP  ACHIEVE
                              SUCCESSFUL  SITE CLEANUP
                                                NANCY R.  TUOR
                                              NANCY J. JERRICK
                                                    CH2M Hill
                                                 Portland, Oregon
INTRODUCTION

  The cleanup of hazardous work sites can be highly controversial.
The reasons for this may not be readily apparent, because no one is
really for hazardous waste. However, some points of controversy
are readily  apparent. What is an unacceptable hazard to one per-
son, may be a livelihood to another. What seems to require im-
mediate action may take years, during which time the people who
are involved with the site may become increasingly frustrated and
angry.
  Finally, there are those points of controversy and conflict that
may not be apparent at all until they are actively investigated—or
until it is too late. In this paper, the authors discuss the use of on-
site assessments or interviews in gaining a full understanding of the
participants and issues that may surround a hazardous  waste site
and show why that understanding is important in arriving at prac-
ticable, cost-effective cleanup solutions.
THE NEED TO KNOW
  The establishment of  community  relations programs for all
Superfund  hazardous waste  sites is a requirement  based on two
fundamental premises. The first is that people who are affected by
the release of hazardous substances  have a right to know the atten-
dant risks,  the actions that are being taken and the possible solu-
tions to the problem. The second premise is that technical adequacy
alone does  not ensure that a cleanup solution can be successfully
implemented. The involvement, understanding and cooperation of
the public affected is essential in arriving at acceptable solutions.
  The American public has  become increasingly knowledgeable
about both the technical and political aspects of hazardous  waste
sites. Information is readily available to them from the media, from
technical experts  and from  environmental  and public  interest
groups. At  the same time, the perception of governmental inaction
or obstruction has grown. As a result, people increasingly both
want and have the ability to know what is being done in situations
that directly affect them. They are becoming more actively in-
volved, and they are becoming less and  less tolerate of apparent
unilateral decisions by governmental agencies.
  Effective, two-way communication can help avoid the adver-
sarial positions that have sometimes arisen between the public and
responsible agencies. It  can help  establish a mutual sense of
credibility and responsibility, which is particularly  important in
highly complex situations.
  If public  distrust exists, any governmental decision or solution is
likely to be viewed with suspicion.  Technical information may be
disbelieved, and matters of judgment may be especially challenged
if the public has no confidence in the decision-makers. The ongoing
exchange of information does not guarantee that all parties will
agree at all times. However, it does offer a greater opportunity for
arriving at  a  mutually  satisfactory resolution  of the  problem.
Listening to  the  public  and  responding  appropriately  is an
achievable alternative to the conflicts, legal actions and  costly
delays that occur when people feel there is no other recourse.
THE USE OF ON-SITE ASSESSMENTS
  In order  to establish and maintain effective communication
among the  various parties connected  with  a site, several com-
ponents of a community relations program must be determined:
•With whom to communicate
•How to communicate
•What concerns and issues need to be addressed
  This information  can  be  derived  by   conducting  on-site
assessments: personal  discussions with involved  or potentially in-
volved parties  and an evaluation of their concerns, perceptions and
information needs.
  Personal  contact can be very different from the  more usual
"bureaucratic" contacts by letter or announcement. It allows two-
way communication and affords an opportunity to ask  questions
and offer opinions. If the interviews are handled openly and with
sensitivity, they can create a sense of trust and can begin a dialogue
that will continue throughout the project. Personal interviews with
people who live in the area and who are familiar with its history and
nature can often reveal information that cannot be  obtained other-
wise.
With Whom to Communicate

  The parties  likely to be concerned with a  hazardous waste site
may include the  following:*
•Neighbors
•Local and  state agencies (utilities, natural  resources, planning,
 health departments, etc.)
•Local, state and Federal elected officials or staff (mayor, coun-
 cil, county commissioners, state and Federal legislators)
•Local representatives of business, industry or  labor  (unions,
 Chamber of Commerce, real estate groups)
•Local civic groups (League  of Women Voters,  church groups,
 neighborhood associations)
•Environmental  groups  (Sierra Club, Izaak Walton  League, re-
 gional or state-wide groups)

•Based on draft Community Relations Handbook. Prepared for USEPA by ICF, 1983.
                                                                                    PUBLIC PARTICIPATION
                                                       389
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•Ad hoc groups organized because of site issues
•Health organizations (American Cancer Society, Lung Associa-
 tion)
•Media representatives
Some of these groups may already be known and can be contacted
for initial on-site interviews. However, others may not yet be iden-
tified  and may be first discovered during the course of a site visit.
  At a fairly controversial site in Michigan, the responsible agency
was aware of one community group that was well organized, vocal
and actively pursuing political and media contacts. From their con-
versations with  people in the community, the interviewers became
aware that another faction in the community did not agree with this
viewpoint but had been reluctant to express opposition to the first
group. The interviewer was able to talk with representatives of this
group and to determine their concerns and needs. The community
relations program was, therefore, designed to reflect the needs of
both parties; this in turn could help avoid problems that would oc-
cur if all sides were not understood and addressed.
  Site visits can also help identify  targets of communication that
may not yet exist.  Interviews may reveal that few people are con-
cerned or even aware of a problem. However, these  discussions
may also indicate that people will be interested in a site if they learn
more  about it or if it will affect them in the future.
  One site in Arizona could potentially affect thousands of people
if investigations reveal further contamination. Although current in-
terest is limited, it could increase dramatically. An understanding
of the potentially affected community was important in  designing a
community relations program that includes information dissemina-
tion to the general public and a means for the public to make in-
quiries  and receive  further information. This can prevent  the
misunderstanding and distrust that arise when people learn too lit-
tle about the situation, too late.
How to Communicate

  As these examples indicate, the methods by which information is
exchanged must be appropriate to the situation. Site assessments
can help identify the communications techniques that should be in-
corporated into a community relations program. This point is il-
lustrated by an assessment of a small community in Iowa where a
number of farmers live in the vicinity of leaking pesticide con-
tainers. The responsible agencies believed  that community concern
was moderate and that active involvement was not likely to occur.
Interviews revealed  otherwise.
  Both the neighboring farmers and  local officials expressed in-
tense concern. However, they felt they were viewed by governmen-
tal agencies as "ignorant farmers" and  that their opinions and
needs were, therefore, not being heeded. They also believed that
their  only recourse  was through  political  pressure  and  were
prepared to take whatever action was necessary. While community
representatives  were in contact with an agency staff member and
perceived  him  to be  responsive and credible, they believed that
agency policy was to give them only partial information.
  The discussions revealed that the amount and kind of informa-
tion  being disseminated was not sufficient to meet these people's
needs. They desired a more extensive explanation of the technical
issues,the  decisions  that were being made and the circumstances
that  were responsible for delays. Once  these needs were  deter-
mined, the agency was able to establish an information format and
schedule that was appropriate to this particular community.
  The media is one of the most influential means of disseminating
information.  Familiarity with the  local media and with  local
perceptions of the media is important. Agencies that were involved
with a site in  Arizona were concerned  that media coverage was in-
accurate and sensationalized. As a result, citizens  were confused
and  alarmed  about possible  health impacts. Because  the media
would be  the most effective means  of educating  the public,  an
evaluation of its performance was essential. The community rela-
tions program in this case included distributing fact sheets and pro-
                                                       viding full information to the media to promote accurate, com-
                                                       prehensive coverage.
                                                         In a small community in the state of Washington, a local agency
                                                       has been involved with a site for several years. It has established a
                                                       credible, thorough  community relations program  through com-
                                                       munity meetings, telephone calls and personal visits to people living
                                                       near the site. Superfund involvement may change the lead in the
                                                       cleanup process to a state agency. Because the site assessment deter-
                                                       mined the  extreme effectiveness of the local agency, however, it
                                                       was recommended that the local agency staff person remain as the
                                                       primary contact with the citizens. It was also determined that the
                                                       means of communication remain the same; even though telephone
                                                       calls and visits are time-consuming, they are most appropriate to
                                                       the community involved.

                                                       CONCERNS AND ISSUES
                                                         All of the foregoing examples indicate the kinds of concerns and
                                                       issues that  can be revealed during site assessments.  A number of
                                                       other points are also instructive. As discussed in USEPA's Com-
                                                       munity Relations Handbook for Superfund, the severity of the risk
                                                       associated with the site is not in itself indicative of public reaction.
                                                       Sites that have a significant potential for hazardous release often
                                                       generate very little public concern, while sites with a low risk factor
                                                       can often generate a vocal public response. Discussed in the hand-
                                                       book are a  number of apparent reasons for this disparity including
                                                       perceived public health risks, the  role of the waste generator in the
                                                       local  economy and perceived loss of property value. After com-
                                                       pleting over 60 site assessments in the last nine months, the authors
                                                       would like  to add two additional factors that seem to strongly im-
                                                       pact a community's response to site activities—speed of response
                                                       and "lightning rod" effect.
                                                       Speed of Response
                                                         It  is becoming increasingly apparent that  slow  governmental
                                                       response to a perceived problem is a major factor in local reaction
                                                       to site cleanup. Numerous examples exist of citizen complaints that
                                                       occurred over a ten-year period before site closure and/or cleanup
                                                       commenced.  In  these instances residents have formed hardened
                                                       animosity and distrust toward local and state officials  for their
                                                       perceived lack of action.  To residents who  believe  themselves at
                                                       risk, the fact that local  government  was constrained by  limited
                                                       authority and money is  not important. What is important is that
                                                       they believe the agencies were not responsive to their concerns  and
                                                       had little regard for the potential risk that affected the community.
                                                         Once such an aura of distrust  exists, it is  very difficult to
                                                       establish effective two-way communication.  If local residents  feel
                                                       they have been  ignored in the past, they are likely to feel that at-
                                                       tempts to communicate with them are half-hearted  and less than
                                                       totally candid. If this situation exists and is not corrected, the pro-
                                                       mise  of  achieving a  cleanup plan that can  be implemented is
                                                       substantially lessened. Personal interviews have proven to be a key
                                                       factor in determining when such a situation exists. As would be ex-
                                                       pected, the agencies affected are  often relucant to admit that rela-
                                                       tions  with local residents are strained. In fact, program staff may
                                                       not even be aware of the situation  if it relates to past activities in
                                                       which they were not involved.
                                                         Successful interviews, which allow local residents an opportunity
                                                       to share their concerns, can help  to  "clear the air" and establish a
                                                       more positive future working relationship. The information gained
                                                       from these interviews can  help determine which  governmental
                                                       agencies  are viewed as credible sources and what kind of informa-
                                                       tion the residents need  in  order  to understand the alternative
                                                       cleanup options.
                                                         On a more positive note, if local and state governmental response
                                                       has been quick and effective, residents often believe  the problem it
                                                       in good hands and are willing to wait for final governmental action.
                                                       This was the case in a northern California community where mine
                                                       waste runoff has caused  major  fish  kills.  The area draws many
                                                       tourists and sports fishermen; thus  the fish kills caused widespread
390
PUBLIC PARTICIPATION
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alarm. However, state regulatory action and lawsuits over the past
eight years have convinced the community that the government is
doing what it can to resolve the problem. All residents interviewed
indicated a high level of trust in the agency involved  and said that
media coverage was sufficient to keep them informed. This is much
different from communities characterized by distrust of the respon-
sible governmental agencies.
"Lightning Rod" Effect
  Recent media coverage  of national  events  surrounding the
USEPA has heightened local awareness of the Superfund program.
It has also guaranteed press coverage of the  most mundane ac-
tivities if they are associated with Superfund. Thus, public meetings
or other events associated with site remedial activities often become
a "lightning rod" for community dissatisfaction that has little to
do with the actual site.
  Past planning and zoning issue, local taxes,  sewer and water
questions or just plain dislike of a public official can quickly take
over the public  forum. While  some may argue this provides a
worthwhile local catharsis,  it leaves  those seriously concerned
about site cleanup without a forum.
  For example,  residents adjacent to an Arizona site  asked the
USEPA to forego further public meetings because, as the residents
put it, they had turned into a "media circus of  local demagogues
and people running for office." The solution in this instance was a
series of  small  meetings  between  USEPA  officials  and local
residents in their homes. Information exchange was far more pro-
ductive  and even the most reluctant residents felt comfortable ask-
ing the questions that were on their minds.
  A critical element in the assessment process is, then, a determina-
tion of peripheral issues that could impact community response to
remedial actions. This is not meant as an attempt to dig up the local
"dirt,"  but  rather as an assessment of overriding  local concerns
that may  have an impact on the effectiveness of various com-
munication techniques.

CONCLUSIONS

  Information needs will  continue to vary from  community to
community based on cultural patterns, local political systems and
the history and people surrounding each site. If effective two-way
communication is to be achieved,- it must be based on an understan-
ding of the  local community and its  specific information needs.
Community  relations activities that fail to recognize  these basic dif-
ferences will cause problems,  rather than resolving  them.
  As the American public becomes more technically and politically
sophisticated, it is increasingly important to provide it with the in-
formation needed to review governmental decisions. The present
visibility of the Superfund program and the intense public reaction
engendered by the hazardous  waste issue make good communica-
tion even more critical.  Site assessments provide  the information
needed to design effective communication programs.
  Whether it be  Superfund cleanup or licensing of  a new facility,
intense public reaction can potentially halt future action. An effec-
tive two-way communication/education program may be the only
thing that stands between success and failure. There is no better
way to determine what kind of information people need than to ask
them. While this technique alone cannot ensure  success, success
may be very difficult to achieve without it.
                                                                                          PUBLIC PARTICIPATION
                                                          391
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    WHY GOVERNMENT AND INDUSTRY HAVE FAILED  AT
PUBLIC PARTICIPATION PROGRAMS AT SUPERFUND SITES

                                             LOIS MARIE GIBBS
                             Citizens Clearinghouse for Hazardous Wastes, Inc.
                                               Arlington, Virginia
 DEVELOPING GOOD WORKING RELATIONSHIPS
   The first important step in any program is to develop good work-
 ing relationships between all parties involved. However, developing
 good working relationships between a community faced with a
 toxic waste problem, industry and government has been a difficult
 task. Experience has shown that the approaches used in the past
 have failed. To make matters worse, no one is actively attempt-
 ing to change the existing methods to take advantage of the lessons
 learned.
   There will never be a good public participation program imple-
 mented in this country if government and industry are not willing
 to treat  affected or  potentially  affected community  people as
 equals, rather than as obstacles to be dealt with. Clearly, changes
 need to be made if a cohesive working relationship is to be devel-
 oped. One way to define those changes is  to look at what went
 wrong in the past and then to define what needs to be done in the
 future. To accomplish this, the following comments are examples
 of problems that the author has seen in the course of her travels
 and personal experiences and suggested recommendations to elim-
 inate these problems in the future.
 ALL COMMUNITIES MUST HAVE A
 PUBLIC PARTICIPATION PROGRAM
   The first change that needs to be made is to have a Public Partic-
 ipation Program for all communities that will have any involve-
 ment with hazardous waste.  USEPA's present  policy to provide
 only a program in areas where citizens are organized is simply ask-
 ing  for trouble.  The  message this policy sends out  is  "organize
 and raise  hell and you'll have input—sit back, behave  yourselves
 and you'll be ignored." The very  nature of this  policy is designed
 to force people into an adversarial role. Once a relationship begins
 poorly, it is difficult, if not impossible, to build trust.
   If a community is not organized, it  does not  mean it is not in-
 terested. Rather, the public probably does not know what is hap-
 pening or what to do about it. If there is no public participation
 program—and,  as a consequence, little or no information  locally
 on the issue—how can anyone expect local residents to become in-
 terested or voice concern?
   In most cases, the local people do not know or fail to understand
 what is happening until the first truck comes down the street. It is
 at this point that the community begins to organize. One of the first
 responses  is outrage,  followed by mistrust,  as they generally be-
 lieve that government and industry tried to deceive them.
   The end result is an immediate  adversarial relationship between
 the community and industry and government. This problem usually
                                                  haunts government and industry representatives throughout the
                                                  project. It is also an easy, uncomplicated problem to resolve. All
                                                  that needs to be done is to implement a public participation pro-
                                                  gram at every site where an action is planned.

                                                  INVOLVEMENT FROM THE START
                                                    The local people must be involved as soon as the field investi-
                                                  gators arrive on-site. Too often, citizens are informed of a planned
                                                  action after it has already been decided upon. Thus, the residents
                                                  have no say about what needs to be done or where or how it is to be
                                                  carried out. Consequently, they become angry, scared,  confused
                                                  and once again feel a loss of control over their own destinies.
                                                    "Public Participation" as currently practiced  by USEPA at
                                                  Superfund sites  is not designed to involve the public in any real
                                                  decisions  that need to be made but rather  to give the public care-
                                                  fully selected portions of information. The USEPA seems to care
                                                  more about maintaining control of data and information than shar-
                                                  ing what is known with a community. Why does USEPA do this?
                                                  One can only imagine what thoughts lurk in the minds of a Wash-
                                                  ington bureaucrat, but here are several suggestions:
                                                  •People are generally technically ignorant and will not understand
                                                  •USEPA  makes the decisions—it is their money!
                                                  •USEPA  cannot answer the questions that arise
                                                  •Scientists and  society have no easy answers to what it means to
                                                   have 25 ug/1 benzene in the drinking water
                                                    Perhaps the last suggestion is the driving force behind all the
                                                  others. As experts, most scientists and bureaucrats cannot admit
                                                  their failings in  not having answers to the questions posed to them.
                                                  As has been expressed by many government officials, "we cannot
                                                  release these data until we have a good answer or response to the
                                                  questions they will raise." So what  happens? Data are withheld,
                                                  people find out about them and distrust ensues, further alienating
                                                  the public rather than building open lines of communication.
                                                     Past history  has shown this lack of concern for true public par-
                                                   ticipation to be very damaging and extremely expensive for the
                                                   parties involved. For example, it is not unusual for USEPA to de-
                                                   fine,  in isolation from a community, a cleanup action with a tight
                                                   timetable based on engineering or  economic consideration. The
                                                   local people hear about the plan through the media and request
                                                   (from USEPA  or the state agency involved) a copy of the planned
                                                   actions. Note that I say planned actions, not proposed,  as the de-
                                                   cisions have already been made.
                                                     In response  to this request from  the community, USEPA, not
                                                   realizing  or thinking about what they are sending or to whom, re-
                                                   leases a 500-page technical document. The local people now must
 392
PUBLIC PARTICIPATION
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attempt to read and understand this technical report (which might
as well be written in Greek), become overwhelmed, more fright-
ened than ever and unsure of what to do. Their choices  are (1)
trust USEPA—a difficult task, considering recent Congressional
findings, (2) hire an expert to review the document for them—also
an unlikely event because of the cost and the lack of knowledge
about whom to hire or (3) file a lawsuit to stop the work,  to give
them more time and the opportunity to develop a mechanism for
input on the planned actions. A lawsuit is usually what occurs.
  All  of this is expensive and embarrassing to  both government
and industry. A construction season can be lost and the adverse
publicity can create tremendous public relations problems for in-
dustry, government  and elected officials. Such a lawsuit also stim-
ulates other legal actions against one or all of the parties involved.
  The early involvement of citizens is also very  important  in
settlements with responsible parties before they are finalized.  If
the local people are not involved in the decisions made in respon-
sible party settlements, they will immediately question the settle-
ment  and possibly  accuse USEPA and the other parties of ex-
cessive cooperation  with the industry at  the expense of public in-
terest. This is  especially true now  after  the recent Congressional
investigations.
   Many, if not all, of these problems can be avoided or minimized
if people are involved from the first step. Trust,  good working
relations and cooperation can and must be established from the be-
ginning, since  it is almost impossible to establish these  after the
damage has already been done.
CITIZEN INVOLVEMENT MUST BE MORE THAN TOKEN

   The local people must  have a meaningful voice in the decisions
made regarding a site in their community. The community and its
future belong  to the local people,  their  families and their neigh-
bors.  They no more  want government/industry to define  their
futures without consulting them, than you want me to define yours.
   Consultation does not  mean being informed after the decisions
are made. The current practice of  news conferences and releases,
distributing fact sheets and  holding informational meetings  with
little or no substantive information being exchanged is not serious
public participation; and the public recognizes this. Yet these ac-
tivities comprise the main thrust of the "Public Participation"
programs  implemented  across  the  country. Not only are these
token steps not serious, but the manner  in which they are carried
out further alienates the public rather than building open lines of
communications.
News Releases. News releases of actions or changes in the planned
actions are always  given  to the media before community  leaders
obtain them. Consequently, the media calls local people who are
unprepared to comment. Therefore, local people immediately be-
come angry, feeling that they are not being kept informed, and they
naturally lash  out at whoever released the press statement. Local
leaders do not like to look or feel  that they are uninformed. So,
releasing a story without notifying key community people first is
asking for bad  press.
   The second  problem is releasing impact information on Friday
afternoon. This is  especially true  of health-related information.
Too many times, people have heard on Friday that they may be ex-
posed to lethal chemicals  or that a health problem was clearly doc-
umented  in their community. There is  nowhere  for these now-
scared and panicky  people to go or call  for information on what
this all means to their families. Instead, they must sit all weekend,
upset  and  uncertain, and  wait until Monday morning for explana-
tions. This type of action not only  closes most doors to commun-
ications but is also  unnecessarily cruel to  already suffering  fam-
ilies. If such a  release must be made, I firmly believe that waiting
until Monday will not change the release's value.

Fact Sheets. Fact sheets  are useful tools to help explain what is
planned, how it will be done and other activities at the site. How-
ever,  too much weight is given to the effectiveness of fact sheets.
They serve as a good tool in a meaningful dialogue but not as a
substitute for  meeting face-to-face and  seriously discussing the
issues or actions.
Public  Meetings. Public meetings are an essential part of a public
participation program for several  reasons. First,  they provide a
mechanism for shy, quiet people and the elderly  to hear what is
happening and the issues. These people will not meet face-to-face
with industry or government because of their own shyness or dis-
abilities.  Therefore, without a public meeting, these more fragile
citizens could end up closed off in their  homes, uninformed and
needlessly frightened and confused about the happenings around
them.
  The  second  reason is that  this type  of meeting usually brings
out all  issues from all sides. In this way, local people can have a
better understanding of who's recommending what and why. Too
often, people hear only part of the story and thus  can not make a
fair and educated decision. A  public meeting not only provides the
mechanism for bringing out the issues, but also serves as a forum
for asking questions and for benefitting from questions raised  by
others.
  The  third reason for public meetings  is to provide additional
information to the field investigators. No one knows more about
the community than the people  who live and work there. Many
times in the past, the local residents were able to supply valuable
information to the investigating teams  who  reached  out to the
community at a public meeting.
  However, in the past, public meetings  have often proved to  be
unproductive, uninformative and, at times, completely out of con-
trol. There are reasons  for these problems and possible ways  to
correct them:
(1)  Involving local  citizens from the beginning will stop people
    from walking into the meeting angry and ready to criticize.
(2)  People  who attend an informational meeting expect informa-
    tion. I  have  attended hundreds of informational meetings
    where no new information was provided. This lack of informa-
    tion  sometimes  resulted from the meeting getting out of con-
    trol,  but the majority of times it was intentional. Informa-
    tion  was too often withheld from the affected people because
    the policy decisions has not yet been made or because there
    were negotiations going on with the responsible parties and it
    could hurt the legal actions.
  There are also those individuals who enjoy playing power games
with local residents. I  overheard two separate conversations where
the officials sponsoring the meetings, in both instances, were brag-
ging in a bar  about how successful they were because  they did
not "give anything away." They were actually congratulating each
other on successful meetings. The  mindset of such individuals is
hardly the proper attitude for conducting a public meeting!
  Providing local people with all the available information is not
only fair, but  it's  also the only way to  ensure a good working
relationship. Once the residents discover something has been kept
from them, the trust and rapport will be lost.
  The  language and terms used by those presenting the informa-
tion must be at the level of education and understanding of the
community. Too often, information is presented to communities in
either technical jargon or so simplified  as to be insulting. For ex-
ample, explaining the security of a complete containment system as
having "a clay cap with a permeability of 10~7, the hydraulic pres-
sure created beneath  the site by existing soil structures  and the
leachate  collection system, with  its on-site treatment capabilities,
nothing will leak" cannot be understood by the lay person.
  An example at the other extreme, from Love Canal, was the ex-
planation of how the Love Canal  leaked. An engineer explained
that the Canal was like a bath tub full of water. "When you put a
fat  lady  in  the tub, it  overflows; that's what happened here."
Needless to say, the heavier women in the  audience were not
pleased with this analogy.
  The last language problem that I  feel needs to be addressed is  the
use of "in-house" lingo. This includes the use of initials instead of
                                                                                          PUBLIC PARTICIPATION
                                                          393
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names and terms used within a given profession. The use of in-
itials is completely confusing and  the  use  of esoteric  terms is
totally inappropriate.  For  example, a  health official  was  ap-
proached  by a woman who had recently had a miscarriage. Not
realizing what  he  was saying, the official kept referring to this
woman's  miscarriage as "fetal wastage." Halfway through  the
conversation, she became very upset and pointed out to the offic-
ial that her definition of wastage was something you flush down the
drain or put out on the street each week—not an innocent baby.
Her expression of anger and emotion was contagious and many
other people became upset over other things. A once peaceful room
was turned into the scene of an emotional confrontation.
   Careful planning and serious "thinking before speaking" could
 avoid many of these language barriers. Moreover, people who be-
 come involved in the issue at hand quickly become educated on var-
 ious aspects of the problem. Therefore, one should not underes-
 timate their ability to understand and comprehend what's happen-
 ing and why.
 COMMUNITIES NEED TO HAVE THEIR OWN EXPERTS
   There is absolutely no reason to believe that either industry or
 government will look out for the primary interests of the commun-
 ity. Everyone involved at a problem site has a vested interest. The
 residents are concerned about the health of their families, industry
 is concerned  about  potential lawsuits  and  USEPA is concerned
 about politics and protecting the interests of major corporations.
   One of the most significant gaps in the past and present public
 participation program is the lack of funds to provide a way for cit-
 izens to hire their own experts to review a proposed plan. A pro-
 gram designed to sincerely involve lay people who can have an edu-
 cated and articulate voice in the decision-making process must in-
 clude a way for citizens to consult with qualified professionals of
 their own choosing to help  critique the plans.  Without these pro-
 fessionals, a real public participation program will never exist.
   Communities faced with  a problem  usually are not financially
 able to hire  their  own  experts,  and  donated services are  min-
 imal. Without some qualified person the community can trust, who
 can say that the project is safe, few communities would accept any
 plan. However, since they lack the expertise, they are unable to ar-
 ticulate why they think it is not a good plan and end up speaking
 from emotion rather than fact.
                                                          Would you, for example, buy a house tomorrow, simply accept-
                                                       ing the seller's and the real estate agent's word that the house was
                                                       structurally sound and termite-free? The answer is no. You would
                                                       bring in  someone you trust  to check out the house, not because
                                                       you thought there was something wrong with the house or felt that
                                                       you were being lied to but to protect your interests. It is no differ-
                                                       ent for people living near a waste site.  They want to protect their
                                                       interests, too.
                                                          At Love Canal, the local organization was provided with the re-
                                                       sources to hire its own expert. This person proved to be very help-
                                                       ful in explaining to residents what was going on and why. Because
                                                       the actions were explained and  approved by the group's expert,
                                                       no one objected to the plan. This person also served as a valuable
                                                       resource  person at professional meetings where a resident's pres-
                                                       ence might have made the other experts uneasy or created com-
                                                       munications problems.
                                                          The small amount of funding  that it  would take to provide this
                                                       invaluable resource to local  communities could eliminate a large
                                                       amount of future problems.

                                                       CONCLUSIONS
                                                          The problems of the past  public participation  efforts show the
                                                       way to future solutions. Rather than force residents into the role of
                                                       uninformed children  who have  no  say—and no right to have a
                                                       say—in  what  their  "parents,"  played by  government  and in-
                                                       dustry, decide, we  suggest that  those  in charge of uncontrolled
                                                       hazardous waste site cleanups:
                                                       •Provide the means for residents to hire their own experts
                                                       •Involve  residents from the very start
                                                       •Never try to deceive communities by  presenting plans when the
                                                        decisions have  already been made as  though you really wanted
                                                        their input
                                                       •Be sensitive to the various mistakes that can set up walls to com-
                                                        munications.
                                                          Sensitivity is  something we all have  to learn, usually the hard
                                                       way through experience. Communities have to learn it all the time,
                                                       since they are usually forced to learn the bureaucrats'  and indus-
                                                       try representatives'  language and ways of thinking just to com-
                                                       municate. It is  the housewives, farmers, blue collar workers and
                                                       others  who have had to reach out by  learning new jargon and new
                                                       scientific information. We'd like you  to learn some  new things
                                                       about communicating, too. It's not hard. We've done it and so can
                                                       you.
394
PUBLIC PARTICIPATION
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 THE ROLE OF  REMOVAL ACTIONS  AT UNCONTROLLED
              HAZARDOUS WASTE SITES:  CASE  STUDIES

                                        JOANNE WYMAN, Ph.D.
                                               JANN DULLER
                                       Booz, Allen  & Hamilton, Inc.
                                              Washington, D.C.
                                            CHERYL HAWKINS
                                               STEVE HEARE
                                  U.S. Environmental  Protection Agency
                               Office of Emergency and Remedial Response
                                              Washington, D.C.
INTRODUCTION

  The Comprehensive  Environmental Response,  Compensation
and Liability Act of 1980 establishes  a program of Federally
financed response to actual or threatened releases of hazardous
substances at uncontrolled waste sites. Under this program, two
types of responses are authorized: remedial action and removal ac-
tion.
  Remedial action is defined in CERCLA as a "permanent rem-
edy." Generally,  this type of response requires lengthy, compre-
hensive cleanup activities with an estimated  average cost per site
of $6.5 million. The National Priorities List (NPL), which USEPA
published pursuant to section 105 of CERCLA, identifies the high-
est priority releases at  uncontrolled sites nationwide and,  thus,
the most likely candidates for remedial  action. Removal actions,
by contrast, are short-term responses designed to provide prompt
relief from urgent threats at both NPL and non-NPL sites.
  The USEPA1 has adopted procedures for selecting and conduct-
ing the type of Superfund response most suitable for the release.
The remedial portion of the program, because of its visibility and
the magnitude of its resources, has attracted considerable public
attention. The purpose of the authors in writing this paper, there-
fore, is to give potential response  participants a more informed
understanding of the role of removal actions in Superfund. Spe-
cific topics addressed are: selecting a removal response, processing
the removal request, requesting and approving ceiling increases,
requesting and approving  exemptions  to  the six month  and
$1,000,000 limits and negotiating state participation. Information
on operating procedures was derived from USEPA's removal pro-
gram guidance, and case study data were taken from the Agency's
Removal Tracking System.

SELECTING A REMOVAL RESPONSE
  The Oil and Hazardous Substances National Contingency Plan
(40 CFR 300, NCP)2 establishes the framework for  selecting  a
CERCLA-financed response. Under this  framework, removals fall
into two categories—immediate and planned—and procedures for
evaluating the urgency  of the threat and the alternative cleanup
techniques lead to selection of an appropriate  response. If the
risk to human life, health and the environment is immediate and
significant, an immediate removal is the appropriate response re-
gardless of whether the release is at a  listed or unlisted site. A
planned removal may be appropriate either to continue  response
actions following completion of an immediate removal or to take
action at an unlisted site when threats at that site are too urgent
to await ranking and listing. Both types of removals cannot exceed
$1,000,000 or six months without special approval.

Immediate Removals
  USEPA initiates an immediate removal when  a  preliminary
assessment3 of a release unequivocably supports the need for emer-
gency action to protect human life, health and the environment.
Indicators of immediate and significant risk are: human, animal or
food chain exposure to acutely toxic substances, contamination of
a drinking water  supply, fire or  explosion  and  similarly acute
situations.4
  In some cases, the urgency of threats  from releases are so sig-
nificant that USEPA can make a decision at once to proceed with
an immediate removal. For  example, the Agency  authorized an
immediate removal to  contain and remove toxic substances  and
contaminated materials within hours of an explosion at the Plasti-
fax  plant in Mississippi last year. That explosion killed two peo-
ple  and injured 64 others. It also left pools of liquid chemicals
and contaminated water  in concentrations potent enough to eat
through a firefighter's boots. Additionally, rain threatened to dis-
perse the contaminants off-site. The site later was added to the
NPL and is eligible for future remedial action.
  On occasion, even when a release appears to pose a significant
and imminent threat, USEPA may seek outside opinions on the ex-
tent  of contamination and  the efficacy  of proposed response
activities before making a final decision on an immediate removal
request. For  example,  in the case of six asbestos-contaminated
sites in the Northeast, USEPA asked the Center for Disease Con-
trol to prepare a health advisory and to assist the Agency in assess-
ing the  urgency of the threats and determining the appropriate type
and method of response. The CDC study confirmed the need for
an immediate removal, and  USEPA approved the action shortly
thereafter.
Planned Removals

  If the preliminary assessment has ruled out an immediate re-
moval  but indicated a need for  a  different type of CERCLA
response, USEPA continues  to investigate the release. Releases at
sites already  on the NPL may be referred for remedial action.
Other releases at unlisted sites may be candidates either for hazard
ranking and eventual listing  or for planned removals. Considera-
tion of a planned removal  action may occur  in three different
situations.
  One  such circumstance may arise after USEPA has determined
an  incident does  not  meet  the NCP criteria  for an immediate
                                                                                 RISK/DECISION ANALYSIS     395
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removal request. For example, the Agency decided that an aban-
doned landfill, which had been used for industrial waste disposal
for many years and was located in a remote area of Pennsylvania,
did not pose imminent threats to public health and welfare and
thus did not warrant  an immediate removal.  A more thorough
review  of the site, with consideration to the presence  of priority
pollutants and migration of contaminants to groundwater, resulted
in USEPA's decision that the action met the NCP criteria  for a
planned removal.
  In other instances, such as the Triangle Chemical site in Texas, a
planned removal may be an appropriate follow-on to an immediate
removal. Releases from hundreds of leaking drums at that  unse-
cured site had contaminated the surrounding soil heavily and were
linked  to several fishkills.  Further, the Agency's investigation
showed that  nearby residents were removing materials from the
site, thus exposing themselves to  significant risk of direct contact
with highly corrosive substances. Consequently,  USEPA author-
ized an immediate removal to secure  the site by constructing a
fence until  mitigative action could be undertaken. Since Triangle
Chemical still posed  significant direct contact, groundwater and
environmental threats, but was not on the NPL,  USEPA decided
to undertake a  planned removal  in order to remove and dispose
of the  drums and contaminated  soil.  The  site subsequently was
added to the NPL and now is eligible for remedial action.
  A former  solvent  reprocessing facility in  Texas provides an
example of the third  situation in which a planned removal be-
comes  the selected course of action—that is, in response  to a spe-
cific request  for a planned removal to mitigate  threats  at a site
not on the NPL. This unsecured site, containing 24 deteriorated
storage tanks and littered with leaking drums, posed  direct con-
tact, fire and explosion risks as well as surface and groundwater
contamination threats. USEPA approved a planned removal action
to treat and discharge the contaminated wastewater, remove and
dispose of the drums and tank contents and encapsulate contam-
inated soil and sludges.

APPROVING THE REMOVAL REQUEST
   In order to manage Superfund resources prudently and to pro-
mote consistent removal decisions, USEPA has adopted operating
procedures for the packaging, processing and approval of removal
requests. Removals must be approved  by either the Assistant
Administrator (AA), Office  of Solid Waste and Emergency Re-
sponse (OSWER) in Headquarters,  or the Regional Administra-
tors (RAs)  in accordance with USEPA's Delegations Manual and
operating guidelines. Since May 1983, RAs have had authority to
approve the majority of immediate removals for which the expendi-
ture or extramural (procurement)  funds are not expected to exceed
$250,000. More costly immediate  removals require the approval of
the AA, OSWER as do all planned removals.
Regional Approval of Immediate Removals
  A recent case involving an  abandoned rubber and plastics facil-
ity, located in a populous area of a Pennsylvania town, is typical
of an immediate removal approved by a Regional Administrator.
A power substation located on the site was vandalized,  resulting
in an uncontrolled release of PCBs.  Several schools and a neigh-
borhood park lie within 1500 ft of the facility, and children were
seen playing on the site. The Regional Administrator approved an
immediate  removal to dispose of the  transformers and contam-
inated soil and to incinerate PCB-contaminated  liquids.

Headquarters Approval of Immediate and Planned Removals
  An immediate removal action in the Pacific  Islands  is represen-
tative of the types of actions requiring the approval of the AA,
OSWER. This complex case involves  32 separate  sites,  some of
which are on the NPL, located on Guam as well as various  other
islands in the Pacific Trust Territories. These sites contain PCBs,
pesticides, acids, bases and organic  solvents;  more than half are
unsecured  and  easily accessible. Deteriorating  site  conditions,
documented instances of direct contact and the high potential for
                                                     food chain  and drinking water  contamination indicated  that
                                                     immediate removal action was required. Because of the expected
                                                     high cost of response,  dictated  in large part  by the  lack of an
                                                     approved disposal site in the Pacific Territories and the shortage of
                                                     adequate storage sites on  the islands, the proposed  action was
                                                     referred to Headquarters.  Following a review of the Immediate
                                                     Removal Request (known informally as the ten-point document)
                                                     prepared by the Region, the removal was approved  by the AA,
                                                     OSWER.
                                                       The AA, OSWER also may require Headquarters approval for
                                                     certain types of immediate removals regardless of their costs. Pro-
                                                     posed  immediate  removals  at  dioxin-contaminated  sites in
                                                     Missouri, for example, have been referred  to Headquarters for
                                                     approval so that actions taken are consistent  with the Agency's
                                                     dioxin strategy now under development.
                                                       In addition, the AA, OSWER acts on all requests  for planned
                                                     removals. Unlike immediate removal requests,  each request for a
                                                     planned removal must include a letter from the Governor or other
                                                     designated individual of the state in which the proposed removal is
                                                     to take place. Under Section 300.67 of the NCP, the letter must
                                                     describe the nature  and extent of the release, the actions taken or
                                                     underway  at  the site and the  proposed planned removal.  The
                                                     letter also must include assurances that the state will pay its pre-
                                                     scribed share of the costs. In accordance with Agency procedures,
                                                     the Regional staff include this letter in the formal planned removal
                                                     request package they prepare and submit to Headquarters.

                                                     REQUESTING AND APPROVING CEILING INCREASES
                                                       Throughout the removal action, response costs are tracked for
                                                     several purposes: to promote sound financial management, to en-
                                                     sure that the  $1 million statutory  limit is not exceeded unknow-
                                                     ingly and  to  support potential  cost recovery actions. Tracking
                                                     begins with the establishment of an initial project ceiling at the
                                                     time the response is approved. As the response proceeds, the On-
                                                     Scene Coordinator (OSC) may find that costs are likely to exceed
                                                     the  initial ceiling if the actual extent of the release  or  threat is
                                                     greater than anticipated (e.g., a bulldozer uncovers several hun-
                                                     dred buried drums). Consequently, USEPA has established pro-
                                                     cedures for requesting and approving ceiling increases.
                                                       All requests for ceiling increases for planned removals must be
                                                     submitted to Headquarters for approval. Ceiling increase requests
                                                     for  immediate removals also  must be referred to Headquarters if
                                                     additional funding requirements will raise the project ceiling above
                                                     the  $250,000 limit established by delegation. Requests to increase
                                                     the  project ceiling,  typically sent by the OSC to Headquarters in
                                                     the  form of a pollution report (or  POLREP), must document the
                                                     reason for and the amount of additional funds requested.
                                                       The Crystal Chemical site in Texas, now on the NPL, illustrates
                                                     the  type of circumstances  in which a removal action requires a
                                                     ceiling  increase. In this case, response personnel could not com-
                                                     plete the clay cap until a buyer was found to purchase and remove
                                                     equipment left at the site. Heavy rains damaged  the cap before it
                                                     could be completed, forming pools of arsenic-contaminated water.
                                                     Remaining  contract money then had to be used to remove the
                                                     contaminated water. The OSC  submitted a written request  for,
                                                     and Headquarters approved, a ceiling increase to repair the cap and
                                                     complete it once the equipment had been moved.

                                                     EXEMPTIONS TO THE STATUTORY COST
                                                     AND DURATION  LIMITS

                                                       Section 104(c)(l) of CERCLA limits all removal actions to six
                                                     months or $1 million except in prescribed circumstances. Pro-
                                                     cedures for calculating and  tracking duration and cost  and for
                                                     submitting  requests are designed to ensure that the limits are not
                                                     exceeded unknowingly and that response work is not disrupted.
                                                       All exemptions require the approval of the AA, OSWER and
                                                     each request must document that the statutory criteria for exemp-
                                                     tions are met. These criteria are:  continued-response actions are
                                                     immediately required to prevent, limit or mitigate an emergency;
                                                     there is an immediate  risk to public health or welfare or the en-
 3%
RISK/DECISION ANALYSIS
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vironment; and such assistance will not otherwise be provided on a
timely basis.
  Site conditions at a bankrupt recycling facility in Indiana illus-
trate the type of situation for which USEPA may approve an excep-
tion to the six-month limit. Following a fire at this site, USEPA
conducted limited immediate removal activities  to prevent severely
contaminated surface water from migrating off-site. Site conditions
continued to deteriorate, however, because flammables were stored
haphazardly and because runoff was contaminating a nearby lake
used for recreational fishing. USEPA identified a planned removal
as the best form of mitigative action, because timely private  party
cleanup appeared unlikely and the site was not on the NPL. Before
approving the planned removal, however, the Agency first had to
approve an exemption to  the  statutory  time limit  because  more
than six months had elapsed since the start of the  immediate re-
moval.
   Cleanup activities at the Western Processing facility in Wash-
ington illustrate a removal action justifying an exemption from the
$1 million limit.  USEPA initiated an immediate removal at this
NPL  site to stabilize  it until a remedial action could be under-
taken for long-term  cleanup.  Cost estimates for conducting  the
immediate removal were based upon the premise that most ma-
terials could be sent to local  recyclers or other potential users.
Unfortunately, many materials were found to be contaminated or
to contain chemicals that  were unsuitable for recycling, necessi-
tating additional funds for hazardous wastes disposal. Since this
funding would raise the project ceiling above $1 million, USEPA
had to approve an exemption from the statutory ceiling to enable
the OSC to dispose of the wastes and complete the removal action.
NEGOTIATING STATE PARTICIPATION

   The NCP and  USEPA policy require that states at a minimum
make three assurances for removals: (1) cost sharing, (2) opera-
tion and maintenance (O&M) and, (3) off-site disposal. The state's
share of costs is at least 50% for immediate removals at publicly
owned NPL sites and for planned removals at publicly owned sites
and 10% for planned removals at privately owned sites. Cost shar-
ing is not required for immediate removals at privately owned or
non-NPL sites. The O&M requirement for both types of removals
is that states  must pay 100%  of the cost, starting no later than
six months after the removal begins. If off-site disposal is neces-
sary,  states must  assure the availability of a properly  permitted
facility with the capacity to accept the type and quantity of  the
removed substance.
   Beyond these requirements, states and their localities may under-
 take  specific  removal activities. The legal  instruments USEPA
uses to document a state's role in removals are Letter Contracts,
 Cooperative Agreements  (CAs) and Superfund  State  Contracts
 (SSCs). Under current policy, Letter Contracts for procurement are
 suitable only for  immediate removals, while CAs  and SSCs  are
used only for planned removals.
 Letter Contracts

   Since Dec.  1981, OSCs have had the authority  under CERCLA
to procure emergency response services from states and localities
 on a  non-competitive basis. The  mechanism for doing so is  the
 "Letter Contract for State  or Local  Response to Emergency
 Hazardous Substance Release," a standard form designed to min-
imize negotiation and avoid delays in response initiation. A Letter
 Contract is a preliminary contractual mechanism that must  be
definitized within a  certain period. While  the  Letter Contract
itself cannot exceed $50,000, the definitized contract can be for any
amount approved by USEPA's procurement office.
  Between Dec. 1981 and Aug.  1983, OSCs had used the Letter
Contract in six incidents. These Letter Contracts  were  designed
to take advantage of state and  local familiarity with local  con-
ditions and availability for rapid response. For example, the Letter
Contract between  USEPA and  Cattaraugus  County, NY, illus-
trates the types of immediate removal response services  localities
can provide effectively because of their knowledge of and prox-
imity to local problems. In this case, Cattaraugus County had
taken the lead in investigating and seeking relief for drinking water
wells  contaminated with trichloroethylene. Because of its active
role and willingness to take long-term responsibility for operations,
the County Department of Health received a Letter  Contract to
purchase, install and operate individual carbon filtration  units for
16 wells. Consistent  with  USEPA's  O&M policy,  the  County
accepted responsibility for maintenance after the expiration of the
six month statutory limit on removal actions.

Cooperative Agreements
  A Cooperative Agreement is  an assistance award and is  the
mechanism used whenever a state leads a response action. Since
current policy is for  USEPA to lead all immediate removals, the
mechanism applies only to planned removals. As of Aug. 1983,
USEPA had awarded only one planned  removal Cooperative
Agreement, for cleanup of several residences and  a  commercial
facility contaminated by radium.  The State of Ohio elected to lead
this planned removal, which included removal of contaminated soil
and materials, transporting them to a disposal facility in Wash-
ington and backfilling and landscaping excavated areas.

Superfund State Contracts
  In the remaining planned removal cases to date, USEPA has
led the response action, therefore using SSCs  to obtain  state
assurances.  Typically, negotiation of the SSC begins while  the
Region  is preparing  the planned removal request and  procure-
ment package and continues throughout the processing  of those
documents.  The significant feature of SSCs for planned removals
is that  they allow states to meet their cost share  obligation by
providing specified response services. In the case of a solvent re-
covery facility,  located in a populous residential and  commercial
area of North Carolina, the- state provided a project coordinator,
personnel to assist the OSC with technical tasks  and community
relations and a variety of services supporting the planned removal.
CONCLUSIONS

  The 14 cases discussed here have illustrated the  principal de-
cision  procedures  in  USEPA's Superfund removal program in
effect during late FY83. These procedures have been developed in
keeping with Agency experience as the program has matured. Some
changes may be expected in the future, however, as the Agency
continues to refine procedures to expedite removal responses to
threats at uncontrolled waste sites.


REFERENCES

1. Executive Order 12216 (Aug. 14, 1981) delegates Superfund authorities
   to various Federal departments and agencies, including USEPA. This
   paper focuses solely on the USEPA-administered activities.
2. Federal Register, 47, July 16, 1982, 31180-31242.
3. See 40 CFR 300.64 for preliminary assessment requirements.
4. See 40 CFR 300.65 "Phase III—Immediate Removal."
                                                                                       RISK/DECISION ANALYSIS
                                                          397
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                      RISKS, COSTS AND  PUBLIC POLICY:
          DETERMINING  ACCEPTABLE CLEANUP LEVELS
                                         J. O'NEILL COLLINS, J.D.
                                        PHILIP C. LeCLARE, Ph.D.
                                              Chas. T. Main, Inc.
                                             Boston, Massachusetts
INTRODUCTION
  Super fund1 legislation is designed to provide a governmental
mechanism to correct or mitigate the threat of a hazardous sub-
stance that may present an imminent and substantial danger to the
public health or welfare.2 The extent of remedy or the degree of
mitigation is to be determined by the selection of the most cost-
effective remedial alternative.' Cost-effectiveness is defined in the
National Oil and Hazardous Substances Pollution Contingency
Plan (the Superfund regulations) as the lowest cost alternative that
is technologically feasible and reliable and which provides ade-
quate protection of public health, welfare and the environment.4
  Key issues for public policy decisions in the Superfund mandate
arise under  the questions of imminent and substantial danger to
public health—how dangerous is "substantial" and what level of
mitigation provides "adequate" protection of public health, wel-
fare and the environment? The  principal guidance Congress pro-
vided was that the choice of the degree of the cleanup should in-
clude some consideration of how much Superfund money is avail-
able and the need  for immediate action at other sites.5
  In this paper, the authors  review what happens when decisions
on cleanup options are based on cost-effectiveness considerations
without risk assessment, what happens when risk assessment is
undertaken  without a full review of opportunities for risk  man-
agement and how risk management requires the establishment of a
specified acceptable level of risk. Finally, the authors propose an
initial approach for identifying a level of acceptable risk.

RISK ASSESSMENT

  In the context of hazardous waste site remedial action programs,
the authors refer to risk assessment as the estimation of the
frequency of occurrence of some adverse effect on human health
as a consequence of exposure to toxic levels of chemicals.
  The approach taken to estimate risk is to determine the dose of
a chemical to an individual or population through one or more en-
vironmental pathways and then to compare the dose to a unit risk
or potency derived for the specific chemical in question. While this
may sound  straightforward,  the data needed to perform  a risk
assessment may be difficult to  obtain. For example, these data
must include:
•Identification and quantification of all the waste constituents, if
 only to determine the most potent or the most likely indicators in
 environmental media
•Stability of the wastes—are they biodegradeable, subject to chem-
 ical reactions, or photodecomposition? At what rates?
                                                   •Ability to migrate through or from the media—are the chemicals
                                                    soluble or insoluble, volatile,  strongly sorbed on soils and sed-
                                                    iments, transported in runoff or leachate, biologically available to
                                                    plants, etc.
                                                   •Identification of the rates at which the materials migrate to air,
                                                    water, land and biological materials.
                                                   •The behavior of the chemicals in ecosystems and the potential for
                                                    bioaccumulation in food chains.
                                                   •The concentrations of chemicals to which people are exposed and
                                                    the resultant dose from this exposure.
                                                   •The toxic effects of the chemicals to humans for the modes of ex-
                                                    posure  (inhalation,  ingestion,  direct contact)  at  the doses
                                                    involved.
                                                     Each of these items must not only be determined for each chem-
                                                   ical, but also will probably have to be determined at a  more pre-
                                                   cise level than allowed by currently available data. That is, one may
                                                   need information on the sorbtion of a chemical by highly  organic
                                                   soils or soil high in clay minerals and one may need information
                                                   on the bioaccumulation of the chemical in a particular food crop or
                                                   fish species.
                                                     Perhaps the most serious deficiency is a lack of human toxico-
                                                   logical data for all the chemicals encountered at a wide range of
                                                   predicted doses and dose rates. The USEPA has sponsored work
                                                   such as the Multi-Media Environmental Goals (MMEG) program
                                                   to develop acceptable ambient  concentrations of  toxic  materials.
                                                   The USEPA's Carcinogen Assessment Group (CAG) and Environ-
                                                   mental Criteria and Assessment Office (ECAO)  have both been
                                                   active in evaluating epidemiological and laboratory animal studies
                                                   to provide carcinogenic potency and potency slope estimates.
                                                     While it is understood that more health related data are  needed,
                                                   one can still benefit from the use of health  risk assessments. Two
                                                   case studies  are presented for sites where there are some lexico-
                                                   logical data for the chemicals of concern.

                                                   SITE A

                                                     Site A is an abandoned hazardous waste site, inactive for 15
                                                   years.  Sources of contamination include a number of lagoons,
                                                   drums with  various chemical wastes, SO acres of  contaminated
                                                   soil and two contaminated wetland areas.
                                                     This site is located in a rural area with 25 residences within
                                                   1/3 mile and a population of  1,000 people within a mile.  Con-
                                                   siderable future  residential development is  planned for the area
                                                   within 1 or 2 miles of the site.
                                                     Sampling of the lagoons, site soils and surface and ground water
                                                   found a relatively large number of USEPA  Priority Pollutants in-
398
RISK/QECISION ANALYSIS
-------
eluding: Methylene chloride, PCBs,  trichloroethylene, benzene,
chloroform, arsenic, phenols and other chemical contaminants.
  Wells providing domestic water at Site A were sampled at the tap
and analyzed. A number of metals and several organic compounds
were identified at  or near  the detection limit. However,  methy-
lene chloride, a suspected human carcinogen, was measured at con-
centrations as high as 1.24 mg/1.
  The USEPA's water quality criterion for halomethanes includ-
ing methylene  chloride is stated in terms of incremental increase
in lifetime cancer risk. A concentration 0.19  jig/1  has an incre-
mental cancer risk of one  in a million. If one assumes, as did
USEPA in deriving this criterion, that people (the 1,000 residents
within a mile of Site A) drink water at a rate of 2 I/day and have
a mass of 70 kg, they will experience an increased lifetime can-
cer risk of 1 in 150. Their  increased annual cancer risk from this
single chemical would be on the order of 1 in 10,000.
  In order to reduce the increased lifetime cancer risk from 1 in
150 to 1  in a  million, the present methylene chloride  concentra-
tion must be reduced by a factor of 1,240 -nO.19 or about 6,500. If
the premise that methylene chloride causes cancer is accepted, then
the value of the potency could be high or low by an order of magni-
tude (e.g., 1 in 15 or 1 in 1,500 increased lifetime cancer risk) and
not alter the conclusion that there is a substantial health risk. A re-
duction of the current methylene chloride concentration by a factor
of 650 or 65,000 would be required to reduce the cancer risk from
that one chemical to water quality criterion levels. Or, alternatively,
water source substitution would be recommended.
  A complete  risk  assessment for this site would have to evaluate
other chemicals and  exposure pathways and would require addi-
tional information of the type described previously. But even with
the limited data available, it can  be concluded that an immed-
iate change in  drinking water supply would be prudent.  Such a
recommendation was not made in the feasibility study,  apparently
because specific health risks were not quantified.
   Instead, a cost-effectiveness approach which compared remedial
action costs to indicators of effectiveness was utilized at Site A. The
overall cost-effectiveness rating of a remedial action option was the
product of the sum of cost and the sum of non-cost items. There
were two categories of cost: construction costs and operation and
maintenance costs. Eleven categories of effectiveness were defined.
The effectiveness indicators used at the abandoned  waste site are
presented in Table 1.
   Costs were given a relative ranking from 1 (least expensive) to 5
(most expensive). Effectiveness measures were  generally ranked as
to their ability to achieve the stated goal on the same scale as cost
with 1 being no action and 5 being  completely effective action.
The study  compared and rated action options for four discrete
phrases:  source removal or isolation, groundwater  aquifer man-
agement, groundwater end use management and site restoration.
The most cost-effective options identified within each phase were
combined into ten remedial action plans which were then ranked as
to their overall cost effectiveness.
   The feasibility study at Site A recommended: (1) removal of the
sources of pollution ($5.5 million); (2) provision of alternate water
supplies ($0.5  million), (3)  no groundwater cleanup and (4) addi-
tional sampling and analysis for one of the affected  wetland areas
to determine whether a no action option would be cost-effective.
(Data costs of $100,000 versus cleanup costs of $4.5 million.)

                           Table 1
                    Effectiveness Indicators
 Level of Cleanup or Isolation
 Feasibility
 Reliability
 Ease of Implementation
 Time to Achieve Cleanup
            Attendant On-site Impacts
            Attendant Off-site Impacts
            Remoteness to Nearby Residents
            Site Usability
            Groundwater Usability
Surface Water Usability
  The most cost-effective measure defined for groundwater aquifer
management at this site was "no action but monitor" at a yearly
cost of $100,000. The second ranked measure—and only half as
cost-effective as no action—was passive collection of groundwater
and discharge to a municipal sewer at a cost of $500,000. Tie-in to a
municipal water supply at a cost of $170,000 and new wells in the
deep  aquifer at a  cost of $250,000  would supplement these two
alternatives,  respectively.  Additionally,  other  source specific
measures proposed to be taken at the site would remove or isolate
the sources of methylene chloride from the groundwater so that in
time the levels of contamination would be reduced as a result of
recharge and plume migration (dilution). These additional actions
would bring total site remedial costs to about $6 million.
  The feasibility study did not include risk assessments. Instead, it
spoke in qualitative terms  such as "trace", "low" or "high"
levels of contamination.  Using a relative assessment of costs and
benefits, most reviewers would come to the same conclusion as did
the feasibility study. However, a risk assessment approach, at least
in the area of the provision of alternate water  supply, would have
modified the recommended remedial action to include immediate
provision of an  alternate water supply, regardless of the fact that
municipal water would be provided in the future.
SITEB

  Site B is  Times Beach,  Missouri,  located on  the Meramac
River 15 to 20 miles southwest of St.  Louis.  Times Beach is,  or
was, a suburban community of 800  families with a total popula-
tion of approximately 1,700 and with 700 to 800 commercial and
residential structures worth approximately $33 million. In the early
1970s the Times Beach roads were  sprayed with waste oil contain-
ing 2,3,7,8-tetrachlorodibenzo-p-dioxin ("TCDD" or "dioxin").
  The community is located in a flood hazard area. Sampling after
a Dec.  1982 flood detected dioxin levels in several yards that
ranged  between 1  and 5 parts  ppb.  Sample locations on streets,
street shoulders and ditches showed dioxin levels up to 100 ppb.
The Center for Disease Control (CDC) has determined that 1 ppb
of TCDD was detrimental to public health and that people should
be disassociated from the hazard.
  Since soils  are considered the primary  source  of dioxin,  the
principal exposure pathways  to be considered are dermal contact
and uptake, inhalation of suspended dust and direct ingestion of
contaminated soil. It has been suggested that a child playing in the
dirt of a yard could ingest a significant quantity of dioxin.
  The CAG has estimated the carcinogenic  potency of dioxin
which is equivalent to 8.5 x 105 per mg/kg day. (This, incidentally,
is the highest carcinogenic potency value determined thus far  by
CAG).  If one assumes that a child weighing 7 kg were to eat one
gram of dirt each day, it would have an intake of 10~6 to 5 x 10~6
mg/day. If one further assumes that the dose rate remains constant
over the lifetime of the person—which is highly unlikely—one com-
putes a range of increased cancer risk of 1 in 8 to 10 in 16. Even if
the risk of increased cancer were computed for  a three year time
span—the estimated number of years a child might directly ingest
dioxin contaminated soil—increased risk of cancer would be on the
range of 1  in 200 to 1 in 40. If CDC's risk assessment produced
even  remotely similar values,  there's  no question as to why it
recommended removing people from the source of exposure.
  At Times Beach, the USEPA's  remedial action decisions were
based on the Center for Disease Control's health risk determina-
tion that a soil concentration of 1  ppb of dioxin was an unaccep-
table level of exposure in residential areas. No in depth risk assess-
ment of options was undertaken; nor was a detailed cost-effec-
tiveness feasibility study made.
  In assessing remedial action options, the USEPA found that be-
cause the area was flood prone, dioxin levels of 1 ppb could be ex-
pected in residential areas after every flood.'  USEPA found that
the costs for soil excavation and its off-site disposal would be con-
sidered too high,  basically because of the transportation  costs.
The possibility of capping the highly contaminated areas was dis-
                                                                                         RISK/DECISION ANALYSIS
                                                                                                      399
-------
carded as too unreliable. The option of removing all the soil and
temporarily containing it  in Times Beach,  although identified
among "temporary alternatives that may be  available,"  was dis-
carded because of the "flood prone" nature of the area.' Whether
this last option could have been implemented at a cost below $33
million was unknown  at the time of the relocation decision. No
detailed risk assessments were made for any of the options. Perm-
anent population relocation was judged the most reliable remedial
action to assure adequate protection of public health. It was con-
sidered cost effective because it was judged a necessary component
of any remedial action program undertaken.

RISK MANAGEMENT
   Risk management is defined  as: "the evaluation  of alternative
regulatory options and selecting among them."1 On the one hand,
risk management decisions  that rely on the cost-effectiveness rank-
ing of options, as done at Site A, without health risk assessments
cannot assure protection of public health. On the other hand, the
use of a risk assessment approach to identify unacceptable risks but
not to identify potentially acceptable levels of risk, leads to the
situation as in Times Beach where the only governmental choice
can be to take the lowest risk option. The proposition is put for-
ward that without an identified and quantified level of acceptable
risk, risk  management decisions remain essentially qualitative de-
cisions regardless of the degree of cost-effectiveness or risk assess-
ment input.
   In an  effort to  alter the practice  of making risk  management
decisions  on a purely  qualitative basis, the hypothesis is  offered
that if a commonly acceptable risk  event  can be found wherein
most people feel secure, then the risk level of that event would iden-
tify an "acceptable" risk. The concept is offered to stimulate dis-
cussion and  provide direction for  future work. A  preliminary
search for such an acceptable risk is given below.
   Crouch and Wilson, in their  book Risk/Benefit Analysis,'' pre-
sent some tables of commonplace risks of death in the United
States derived from the Bureau  of  Census,  the National Safety
Council, the  Department of Agriculture and the Bureau of Mines.
A summary table of some  of the representative risks is presented
in Table 2. The  risks shown are the average risk found for the 20
to 25 years of data reviewed.
   Home accidents and the service and  government occupational
accident categories from the risk table appear to offer promise for
defining an acceptable risk level. Would people feel safe if you
could promise to make them as safe as an upper income individ-
ual at home during his or her least risk prone years or as safe as a
bureaucrat sitting at a  desk? These seem relatively secure environ-
ments. What is the risk level? The assumption is made that these
examples define a risk  event for which most people would  be will-
ing to say: "Protect me to that level and  I should feel quite se-
cure; at least, I would not want major government programs to re-
quire additional expensive safety measures."
   The best available surrogate indicator found for an upper middle
class population in their least risk prone years was that population
group in the 30-50 years age bracket with at least 16 years of educa-
tion. Data were  obtained for this population  group and home ac-
cidents in New York  State. Similar data could not be found for
government workers.
   In 1980, the New York population 30 to 50 years old with 16 or
more years of education totalled  450,000 for  those outside of the
five  boroughs of Manhattan. (Data for  the  five New York City
boroughs were not available.) Accidental home deaths among this
age and education bracket totaled 14. The annual risk of death was
1 in 31,000 or 3.2 x 10~5.  The risk  is 3  times safer  than  the na-
tional average accidental home facility risk of  1 in 10,000. The risk
reduces life expectancy by about 10 hours.
                                                                                   Table 2
                                                                       Common Risks of Accidental Death
                                                       Occupation, Activity
                                                       or Risk Event*

                                                       Manufacturing
                                                       Service and Government
                                                       Agriculture
                                                       Construction
                                                       Mining and Quarrying
                                                       Motor Vehicle Accident
                                                       Home Accidents
                                                       Tornadoes
                                                       Lightning
Annual Risk

8.2x10-'
l.OxlO-4
6.0 xlO-4
6.1x10-*
9.5xlO-4
2.4xlO-«
l.lxlO-4
6xlO-7
5x10-'
                                                       •Crouch, -E.A.C. and Wilson, R.. 1982. Risk/Benefit Analysis. Cambridge, Massachusetts:
                                                       Ballinger Publishing Company.

                                                         The question then becomes: "Is a 1 in 30,000 or even 1 in 50,000
                                                       increased risk of death an acceptable risk?"
                                                         If the external environment were as safe as living in an upper in-
                                                       come house,  most people would feel secure. Most people would
                                                       not perceive the need for expenditures of money to reduce this risk
                                                       unless the cost were relatively low.  The authors propose this this
                                                       level of risk demonstrates an acceptable level of risk. Such an iden-
                                                       tifiable acceptable level should be used in comparing risks under
                                                       remedial action options  for hazardous waste sites. Certainly, more
                                                       work  needs to be  done in identifying comparable risk  events.
                                                       Study needs to be undertaken on how to assess relative life risks
                                                       (e.g.,  risks at home versus environmental risks versus occupational
                                                       or transportation risks, etc.).

                                                       CONCLUSIONS

                                                         The authors have reviewed what happens  when  decisions on
                                                       cleanup options  are  based on  cost-effectiveness considerations
                                                       without risk assessment, what happens when risk assessment is
                                                       undertaken without a full review of opportunities for risk manage-
                                                       ment  and how risk management needs the  establishment of a spec-
                                                       ified acceptable level of risk. Finally, the authors have proposed
                                                       the beginnings of an approach for identifying a level of acceptable
                                                       risk.
                                                         The issues raised are  not new issues. But addressing them will
                                                       help bring perspective to the basic  questions of how risks, costs
                                                       and public policy should be  factored into Superfund decisions.

                                                       REFERENCES

                                                       1. The Comprehensive  Environmental  Response,  Compensation and
                                                         Liability Act of 1980, (CERCLA or Superfund) Pub. L. 96-510, 94
                                                         Stat. 2767; 42 LISC 9601, et. seq.
                                                       2. CERCLA, supra. Section 104(a)(l).
                                                       3. CERCLA, supra, Section 104(c)(4).
                                                       4. National Oil and Hazardous Substances Pollution Contingency Plan,
                                                         40 CFR 300, Section 300.680).
                                                       5. CERCLA, supra. Section 104(c)(4).
                                                       6. Hedeman, W.N.,  Jr.,  Director, USEPA  Office of Emergency and
                                                         Remedial Response to the Administrator, USEPA, "Authorization to
                                                         Proceed with Permanent Relocation at Times Beach, Missouri—Action
                                                         Memorandum," Feb. 21, 1983.
                                                       7. Ibid., p. 5.
                                                       8. National Research Council, Risk Assessment In the Federal Govern-
                                                         ment: Managing the Process. Washington, D.C.  National  Academy
                                                         Press, 1983.
                                                       9. Crouch, E.A.C. and  Wilson, R., Risk/Benefit Analysis.  Ballenger
                                                         Publishing Company, Cambridge, MA., 1982.
 400
RISK/DECISION ANALYSIS
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                       COMPARATIVE RISK ASSESSMENT:
             A TOOL FOR  REMEDIAL  ACTION PLANNING

                                       JOSEPH V. RODRICKS, Ph.D.
                                               Environ Corporation
                                                Washington,  D.C.
INTRODUCTION

  One of the principal objectives of remedial actions at hazardous
waste sites is to ensure that residual concentrations of substances
present in the environment following such actions will not pose a
significant threat to human health.  It also seems desirable that the
objective of health protection is achieved in the most cost-effective
manner. The author's purpose in writing this paper is to suggest a
health evaluation process consistent with these objectives  and to
describe the  data that must be available to  perform the required
evaluation.
  In the paper, the author also provides guidance on the methods
to be used to assess the relative merits of alternative remedial action
plans according to the degree of health protection they yield. His
premise is that the most appropriate measure of effectiveness is the
degree of health protection achieved.
The Evaluation Process
  Regardless of the context in which it is performed, evaluation of
the health consequences of chemical exposures consists of two
discrete steps. The first includes a determination of the likelihood
that a toxic injury or adverse effects will result from various condi-
tions of exposure to a hazardous substance. The second step re-
quires  a  judgment regarding  the conditions of exposure under
which the likelihood of adverse effects is sufficiently small to pro-
tect health. Although this evaluation process has not  been rigor-
ously applied to  operation of remedial action at hazardous waste
sites, there is extensive  experience  from the evaluation  of other
types of chemical exposures that can be relied upon in the formula-
tion of an approach appropriate to the objectives of the remedial
action program.1'2
  Thus, the  methodologies described in this paper  are, at least in
their essential components, drawn  directly from those that have
been in use for many years to evaluate air and water contaminants,
pesticides, food additives and occupational agents. However, none
of the methods used for these other  categories of substances can be
taken without modification and be directly applied to environmen-
tal residues  of substances remaining  after  remedial action  at a
hazardous waste site. The evaluation  process described  in this
paper incorporates the necessary modifications and briefly explains
their bases.
  The first step in the evaluation process requires several types of
data and analysis. Information  must be available on the likely
residual concentrations of contaminants in each of the environmen-
tal media to  which human populations will  be exposed following
each of the remedial action alternatives proposed for a given site.
This information can be used to estimate a critical measure of
health effects:  the daily human intake of residual contaminants
from all media. This measure will be referred to as the daily human
dose (DHD). Completion of the first step of the analysis also re-
quires information on the toxic properties of contaminants and a
means to assess the likelihood of adverse effects at the DHD pro-
jected for each remedial action alternative.

DEFINING PUBLIC HEALTH GOALS
FOR REMEDIAL ACTION
Measures of Health Damage
  Data are available from experimental studies and from studies in
exposed human populations to show that many substances present
at hazardous waste sites are capable  of causing various types of
health injury. Some forms of injury are relatively mild and usually
disappear after exposure ceases. Other forms can be quite severe
and can sometimes be life-threatening; many of these forms of in-
jury are progressive and do not disappear even if exposure ceases.
And, of course, other forms fall between these two extremes. For
any form of toxic injury, the extent and severity of health damage
increases as exposure to the toxic agent increases. A description of
the relation between  exposure and injury is the critical element in
the health evaluation process.
  Evaluation of data for purposes of characterizing the toxic at-
tributes of chemical substances and the exposure-response relation-
ship requires experts in the science of toxicology. Such data come in
a wide variety of forms and can vary widely in quality and the ex-
tent to which they can be applied in exposure situations not iden-
tical to those in which they were developed.  Fortunately, most of
the substances likely to be found at hazardous  waste sites have
already been subject  to the necessary expert evaluation, usually in
connection with their regulation in other situations. These expert
evaluations of toxicity data can form the basis for the evaluation
process to be used in connection with remedial action planning, al-
though results of these analyses in other contexts cannot be directly
applied to the present task.
Substances that Are  Not Carcinogenic

  A threshold  dose  is the amount of a  substance  minimally
necessary to produce an adverse  effect. For most substances,  a
threshold in experimental animals can be approximated by the "no
observable adverse effect  level" (NOAEL). The NOAEL is the
maximum experimental dose at which no toxic effects are observed.
  The experimental NOAEL cannot, however, be taken directly as
the human threshold dose. It is known that thresholds vary among
                                                                                   RISK/DECISION ANALYSIS
                                                       401
-------
individuals and that  the variability in  the  human population is
much greater than it is for small populations of experimental sub-
jects.1'2 For this reason, and also to compensate for inadequacies in
the toxicity data and  to adjust for differences between the condi-
tions of exposure under which toxicity data were collected (usually
animals under controlled conditions)  and  the  conditions under
which they will be used (humans under vastly different conditions),
it has become common practice to divide the experimental NOAEL
by an uncertainty factor to estimate the dose considered tolerable
for the general human population. The magnitude of the uncertain-
ty factor varies and is a function of the data available on a specific
substance.3
  For  purposes of the scheme described in  this paper, the accep-
table human intake derived by this procedure will be called the ac-
ceptable daily intake  for the general population (ADI). This term
has long been used to describe acceptable intakes of food and color
additives and pesticide residues.
  The tolerable human dose estimated by this procedure (ADI) is
not  a dividing line between "safe" and "unsafe" exposures. In
fact, there is no way to identify such a dividing line.  It should rather
be thought of as an  estimate of the dose that is likely to  be low
enough to prevent health damage in most members of the general
population under most circumstances, but which has to be  further
adjusted depending upon specific circumstances. In the case  of con-
taminants at hazardous waste sites, additional safety factors may
have to be incorporated to take into account circumstances at a
site.* Moreover, because individuals near  hazardous waste  sites
may be simultaneously exposed through air and water and perhaps
soil, the specific acceptable intakes through each  of these media
will have to be established so that the total human intake from all
media does not exceed the acceptable intake.
   For these reasons, and because the cost-effectiveness of remedial
action  plans  will  be site-dependent,  acceptable  intakes of
substances remaining in various media after remedial action  at
hazardous waste sites will vary from site to site, even though the
general methodology of health evaluation will be the same for all
sites.
 Carcinogens

   Carcinogens, many of which appear to lack definable thresholds,
 are evaluated somewhat differently from threshold agents.1>2'4 The
 evaluation consists first of making an explicit determination of risk
 as a function of dose. Risk is the probability that cancer will be pro-
 duced and thus takes values from zero to one. The application of
 current methods of risk assessment will yield an estimate of risk as a
 function of dose. This is usually expressed as the risk for each unit
 of dose: unit carcinogenic risk (UCR). The  risk at a specific dose
 can  then be easily estimated by multiplying the UCR by the dose.
 The decision on tolerable  intakes then rests on a policy determina-
 tion of the risk thought to be tolerable at a specific site.
   Although carcinogens may pose risks at all finite exposure levels,
 there is a wide range of very low risks usually considered to be of
 negligible health consequence. Moreover, the methods now used to
 estimate carcinogenic risk yield upper bounds on risk and it can
 reasonably be assumed that  the actual  risk will be  lower,  and
 perhaps very much lower, than the estimated risk.4 In any event,
 because there is no sharp division between tolerable and intolerable
 risks, the residual risk from carcinogens can vary from site to site
 depending on  local  circumstances.  Thus, as in the case of non-
 carcinogens and for many of the same reasons, residual acceptable
 environmental concentrations at different  sites  will  vary  even
 though the methods used to arrive at these  concentrations will be
 uniformly applied at all sites.
 •There may be circumstances in which the ADI derived for the general population may be un-
 necessarily Icm Thus, healthy worker populations may be able to tolerate higher doses than the
 genera! population
                                                       Steps in the Evaluation Process
                                                          Given this background, the major steps in the evaluation process
                                                       can be summarized as follows:
                                                       •For each substance to be individually evaluated,}: determine the
                                                        DHD resulting from each alternative remedial action plan.
                                                       •For each substance, consult the toxicity and carcinogenicity data
                                                        and identify the ADI and the UCR.
                                                       •For  each substance, adjust the  ADI to suit  the  specific  cir-
                                                       cumstances at the site.
                                                       •The adjusted ADI will be termed the site-specific acceptable daily
                                                        intake (SADI).
                                                       •For each substance perform the following:
                                                        (1) Compare DHD to the SADI
                                                        (2) For carcinogens,  multiply the DHD times the UCR to cal-
                                                           culate risk
                                                       •Eliminate all remedial action alternatives in  which any one of
                                                        the following conditions holds for any single substance:
                                                        (1) DHD exceed SADI
                                                        (2) Carcinogenic risk exceeds a given level which has been de-
                                                           termined to be tolerable
                                                       •Evaluate all the remaining remedial action alternatives and iden-
                                                        tify the alterative that achieves,  at  lowest cost, the maximum
                                                        difference between:
                                                        (1) DHD and SADI
                                                        (2) Calculated  carcinogenic risk and the selected tolerable car-
                                                           cinogenic risk.

                                                       tit will be shown in later sections of this paper that, while the number and identity of substance! pre-
                                                       sent at the site need to be known, only a selected few of these will have to be Individually evaluated.
                                                       SELECTION OF SUBSTANCES FOR EVALUATION
                                                          Hazardous waste sites contain many substances and it is imprac-
                                                       tical to perform health evaluations on all of those present. Rather,
                                                       evaluations will be conducted on selected substances and the results
                                                       of these then generalized to the entire collection of substances pre-
                                                       sent at a  site and likely to  continue  entering the surrounding en-
                                                       vironment following remedial action.
                                                          Because the only practical approach is the selective one, there is a
                                                       risk that  the likely extent of health damage predicted by  the
                                                       methods presented here will be underestimated. The only practical
                                                       adjustment for this possibility is the addition of safety factors, tne
                                                       magnitude of which depend on the number of substances present
                                                       and any knowledge of specific interactions among these substances
                                                       that might exacerbate their  effects.
                                                          In most circumstances it is probably not practical to select more
                                                       than a few individual substances for evaluation. This determination
                                                       will have to be site-specific and  will have to be made after the
                                                       following preliminary information is gathered:
                                                       •The total number of substances present
                                                       •The quantity of each
                                                       •The likelihood of their escape from the site and their stability in
                                                         the environment
                                                       •Their lexicological characteristics
                                                          Generally, those substances whose chemical identities are well-
                                                       defined, which are present in large amounts, which are likely to
                                                       escape into the environment and  persist  there and which have at
                                                       least  moderate toxicity should be selected for full evaluation. In
                                                       some cases,  substances displaying these  attributes but which IK
                                                       present in relatively small amounts should be selected if their tox-
                                                       icities are high. Specific decision rules for selecting substances for
                                                       evaluation can be devised based on these principles.

                                                       EXPOSURE ANALYSIS: ESTIMATION OF DHD
                                                          The application of various environmental modeling technique*
                                                       will produce estimates of the  concentrations of  each of the
                                                       substances selected for evaluation in air, water and soil in regiOOl
                                                       where human contact is expected  to occur at the time remedial «•
 402
RISK/DECISION ANALYSIS
-------
tion is taken and in the years following such action. These estimates
will have to be produced for each alternative remedial action plan.
These residual environmental concentrations are the starting point
for the  calculation of DHD.  Although  a  discussion of the en-
vironmental modeling techniques is beyond the scope of this paper,
they  have been extensively used and  their  limitations are well
understood.5'6

Environmental Concentrations
  To be useful for the health evaluation, the environmental con-
centrations produced by modeling  exercise will be estimated in
various media at the likely point of human contact. These concen-
trations can be used to estimate the DHD.
Human Dose: Defining Routes of Exposure

  The medium in which a substance is present will determine the
route of human exposure, i.e., the route by which the DHD will be
received. Substances  present  in  water may be  ingested. Con-
taminated water may also lead to inhalation exposure when water is
used for cooking or showering,  although this exposure route is like-
ly to be minor unless the contaminant is poorly water soluble and
highly volatile. Further ingestion may occur if fish are present in
contaminated water and used  as food. Substances present in air
because of volatilization in the environment (outside the home) will
be inhaled. Substances present in soil may be adsorbed through the
skin if there is direct contact with soil, this route may be especially
important for children. Substances in soil may also be taken in by
plants; human exposure could result if these plants are used as food
or if these plants are fed to livestock, the various products of which
are used as food (meat, milk, eggs).5'6
   Some of these routes of exposure may be important and others
 may not; moreover, the relative importance of the various routes
 will depend on circumstances at a specific site. For example, sites
 near areas where there is extensive  farming or commercial or
 recreational fishing will display quite different exposure route pro-
 files than those near heavily populated areas.
   It is for these reasons that the health evaluator must work closely
 with the environmental modeler to identify populations at potential
 risk and the various routes by which they may be exposed. In many
 circumstances the exposure modeler may not be able to predict ex-
 posure  in quantitative terms  but  may,  nevertheless, be able to
 demonstrate  that a particular route of  exposure is likely to occur.
 Such circumstances should always be recorded, because it may be
 necessary to  incorporate additional safety  factors to compensate
 for lack of certainty in these areas.
 Human Dose: Identifying Populations  at Risk

   One of the critical factors in health evaluation is the nature of the
 population at risk. The ADI and the UCR will be determined on the
 assumption that it is the general population that is to be protected
 rather than any special subpopulation (e.g., healthy adult workers).
 It is expected that in most circumstances populations at potential
 risk from hazardous waste sites will be  the general population and
 that no special subgroups will be present and  require special atten-
 tion. Moreover, because it is the individual  that is to be protected,
 it will not  be necessary to collect information on the size of the
 populations  at potential risk. This is probably  the  appropriate
 choice, since it will generally not be possible to predict population
 changes many years into the future.
   There may, however, be circumstances in  which unusual toxic
 properties of certain substances may put certain subpopulations at
 especially high risk. For  each substance to be evaluated,  it is,
 therefore, essential to consult  the toxicological data to determine
 whether any  such special circumstances might exist and whether it
 is, therefore, necessary to make a special effort to determine if
 there are unusually high proportions of individuals at special risk
 among the general population  present near a  specific site.1'7
   Subpopulations at high potential risk because of unusually high
 exposure will be taken into account because the exposure model is
 designed to yield estimates of concentrations  for such groups.
Human Dose: Estimation of Intake (DHD)

  Dose is the amount of a substance taken into the body per unit of
body weight per unit  of  time. The usual expression  of dose is
mg/kg body weight/day. To calculate the DHD for each substance,
the dose obtained by each route of exposure is first calculated, and
then the total dose is obtained by adding the route-specific doses.
There will be some substances for which it is inappropriate to add
doses from different  routes  because the toxic properties of the
substance depend on the route of exposure. A full understanding of
the toxicity is necessary to decide when it is appropriate to combine
exposures from several routes.
  The method for calculating dose depends  on the  route of ex-
posure. For example, to calculate dose from ingestion of a drinking
water contaminant, it is necessary to know the concentration of the
substance in water,  the volume of water consumed each day, the
fraction of the substance present in water that is absorbed through
the walls of the gastrointestinal tract and the weight of the person
consuming  the water. For  substances that are inhaled or that pass
through  the  skin, different  factors  (e.g., breathing rates,  skin
penetration rates, etc.) determine dose.
  There are various methods available to calculate dose for each of
the three routes of exposure. These methods are based on certain
assumptions and data that have long been used in various USEPA
programs and in the programs of the federal health agencies.5'6 The
formulas assume  knowledge of  environmental concentrations
(mg/J. for water; mg/m' for air; and mg/kg for soil and for food).
The DHD is expressed in units of mg/kg body weight/day.

HEALTH EVALUATION

ADI and UCR

  It  will be necessary to  have available toxicity profiles  of the
substances  to be evaluated. The NOAELs, directly available from
experimental data or estimated therefrom, are divided by uncer-
tainty factors to estimate the ADI. The UCR is obtained for car-
cinogens by application of certain mathematical models to car-
cinogenicity dose-response data. Expert toxicologists  are required
to perform the necessary data analyses.
  The units for these measures of toxicity are mg/kg body weight/
day for the ADI and risk for a dose of one (1) mg/kg body weight/
day  for the UCR.  For a few substances, the form of toxicity
depends on the route of exposure (e.g., dusts in nickel refineries
cause lung  cancer when inhaled but nickel and its compounds do
not appear  to display this form of toxicity when ingested). The tox-
icity profiles should note  such  circumstances, should specify the
route(s) of  exposure for which a given ADI or UCR can be con-
sidered appropriate and the routes for which they would be con-
sidered inappropriate.

SADI and Tolerable Carcinogenic Risk

  For  carcinogens,  the dose considered tolerable for exposures
resulting from a given hazardous waste site is a function of the
magnitude  of risk that is considered tolerable given the relative
costs of achieving various  levels of risk. A maximum lifetime risk
goal of 1 in 1,000,000 is chosen as the starting point for the analysis
presented here, although other low risk levels could be selected.
The  relative costs of various remedial options are considered in
relation to  how much they reduce risk  below this level.  Thus, the
goal is to ensure that the risk be below 1 in 1,000,000. The methods
for making this evaluation are presented in the next subsection.
  For non-carcinogens, the minimum goal is the site-specific accep-
table intake (SADI) which is  either equal to or less than the ADI.
The SADI is derived by dividing the ADI by various safety factors.
The conditions present at a specific site determine the magnitude of
the safety factors.
  Perhaps  the most important factor in determining the need for
and the magnitude of  safety factors is the number of substances
present at a site other than those that have been evaluated. The
potential for interactions  having  adverse health consequences in-
                                                                                        RISK/DECISION ANALYSIS
                                                           403
-------
creases as the number of substances to which individuals may be ex-
posed increases. A systematic means for determining the magnitude
of safety factors is needed to compensate for this uncertainty in the
analysis.
  There may be additional factors, such as the presence of specially
sensitive subpopulations, that require the further addition of safety
factors  at  specific sites. The SADI  is  then derived for each
substance at each site.
  Finally, there may be sites at which two or more carcinogens are
present. In such cases, the maximum tolerable risk of 1 in 1,000,000
will be ensured only if the risk produced by each carcinogen is less
than the maximum and  the total produced by all  carcinogens is
equal to or less than 1 in 1,000,000. In the absence of other infor-
mation, it might be assumed that the risks from carcinogens are ad-
ditive.

Evaluation of Alternative Remedial Action Plans

Organization of Data

  The data have  now been assembled to permit determination of
the relative degree of protection offered by each of the remedial ac-
tion plans under  consideration. For each alternative  plan,  the
following comparisons are made:
•For each  substance, the quantitative relationship between DHD
 and SADI
•For each carcinogen, multiply the DHD by the UCR to calculate
 the risk. Add the risks for all carcinogens evaluated and calculate
 the total carcinogenic risk.

Elimination of Inadequate Action Plans

   Any  remedial  action  plan  that does not  meet  the  following
criteria should be  eliminated from consideration:
•DHD  greater than SADI or
•Total  carcinogenic risk greater than 1 in 1,000,000.
  The  criterion of  maximum achieveable health  protection  at
lowest cost requires consideration of the relative degrees of health
protection offered by alternative plans. As the evaluation scheme
has been designed, this determination is relatively straightforward,
at least in concept, and can be summarized as follows:
     Remedial action plans  that  result  in the greatest numerical
     difference between SADI and DHD and between the total
     carcinogenic  risk and a risk of 1  in 1,000,000  provide  the
     greatest degree of protection.
   Because several different substances are ordinarily evaluated,
and because  the numerical differences will be substance-specific,
estimation of differences for the total collection of substances is
complex and requires a means  of integrating such  differences.
                                                         However, such schemes can be developed, based on the principle
                                                         stated above, to rank remedial action plans according to the degree
                                                         of health protection they afford. This ranking can then be used as a
                                                         basis for determining which plans offer the  greatest protection at
                                                         the lowest cost.

                                                         CONCLUSIONS

                                                           In the interest of presenting a practical guide to incorporating a
                                                         public health analysis into remedial action planning, the imperfec-
                                                         tions and uncertainties in the proposed scheme have been ignored.
                                                         However, these imperfections  and uncertainties  are  not much
                                                         greater in the context described here than they are in other areas of
                                                         environmental risk assessments.
                                                           It is better to use an imperfect scheme for the public  health
                                                         evaluation process than to make remedial action decisions without
                                                         explicit regard to the degree of public health  protection being
                                                         achieved. Use of the proposed scheme will not only  permit the
                                                         remedial  action  planner to  state that  the most cost-effective
                                                         scheme—as  judged   by  the  best   available  assessment
                                                         technology—has been found for a specific site, but also that the
                                                         public health has been adequately considered in advance of action.
                                                         If the latter  is not done,  it will be very difficult to substantiate the
                                                         view that a  chosen remedial plan is truly protective of the public
                                                         health.

                                                         REFERENCES

                                                         1. National Academy of Sciences, "Drinking Water and Health." Vol. 3.
                                                           Safe Drinking  Water Commission, National Academy Press,  Wash-
                                                           ington, D.C. 1980.
                                                         2. Food Safety Council, "Quantitative Risk Assessment," Food Cosmet,
                                                           Toxicol. 18, 1980,711-734.
                                                         3. Calabrese, E., Principles of Animal Extrapolation, John Wiley & Sons,
                                                           New York, 1983, 529-566.
                                                         4. National Academy of Sciences, "Risk Assessment in the Federal Gov-
                                                           ernment: Managing the Process," National Academy Press, Washing-
                                                           ton, D.C.  1983.
                                                         5. Baughman, G.L.  and Burno, L.A.,  "Transport and transportation of
                                                           chemicals: a perspective,"  The  Handbook of Environmental Chem-
                                                           istry. Vol. 2. Part A. Hutzinger, A. (ed.) Springer-Verlag, New York,
                                                           1982.
                                                         6. Jenni,  E.A., Ed., Chemical Modeling in Aqueous Systems. ACS Sym-
                                                           posium Services,  No. 93. American Chemical Society, Washington,
                                                           D.C. 1979.
                                                         7. Interagency Regulatory  Liaison  Group, "Scientific basis for identifi-
                                                           cation  of potential carcinogens and estimation of risks," J. Nat. Cancer
                                                           Inst., 63, 1979, 241-268.
404
RISK/DECISION ANALYSIS
-------
  RISK ACCEPTABILITY FOR HANDLING, ANALYSIS AND
               DISPOSAL OF DIOXIN IN A LABORATORY

                                        CHIA SHUN SHIH, Ph.D.
                                   University of Texas at San Antonio
                                            San Antonio, Texas
INTRODUCTION

  Dioxin contamination and cleanup has become one of the most
volatile and controversial issues in the Missouri-Kansas area. This is
due both to the toxicity of the dioxin and its widespread contamina-
tion in over 60 different locations. In addition to pollution of the
environment, there is also the potential risk to laboratory personnel
and the surrounding community near the center which is handling
and processing the dioxin samples.
  In this paper, the author focuses on a method of estimating the
risks and the evaluation of risk acceptability for laboratory person-
nel, co-workers and the surrounding community involved in hand-
ling and analyzing TCDD  samples received  from contaminated
areas. The method,  based on Revealed Preference techniques as
originally proposed by Rowe1 has been utilized with some modifica-
tions.

RISK ACCEPTABILITY
  Risk Acceptability is concerned with the determination of the
specific level of safety measures required by the affected society for
specific risk situations. In this case, the risk situation is the TCDD
sample process and analysis at a regional sample processing and
analysis laboratory.
  To develop  a range of potential risk situations, laboratory pro-
cedures followed were those used by USEPA laboratories and their
contractors, beginning  with sample packaging in the field and con-
tinuing through the final disposal of the TCDD sample residue. In
addition, it was assumed that the laboratory was located  in a
populated office/residential complex. The basic risk elements in-
cluded the following key steps of the risk pathways (Figure 1):
  •Sample packing in the field
•Trans-shipment of packaged sample
•Pre-analysis storage
•Sample cataloguing or inventory
•Extraction and cleaning of the sample  in the laboratory
•Concentration and digestion for 2,3,7,8-TCDD
•GC/MS sample preparation
•Intra-laboratory transport of the prepared concentrates of dioxin
•GC/MS analysis
•Data log-in for the computer
•Disposal of the residue of sample and wastewater
•Contamination of the air in the building and to the surrounding
 community

RISK ESTIMATIONS
  To prepare for the risk estimation analysis, a series of alternative
risk scenarios  was developed (Figure 2). In  developing the risk
scenarios, alternative risk occurrence pathways and exposure situa-
tions for the laboratory personnel, the co-workers in the building
and the surrounding communities were considered.
  To illustrate the risk relationship between potential hazards and
events that may result from contamination to laboratory personnel,
co-workers located in  the same building and the surrounding
populace, a fault tree was constructed.
  Contamination pathways for the dioxin may include one or more
independent pathways.  This is clearly delineated by the separate
pathway columns in the fault tree. The hierarchy of the  fault tree
structure is established by the horizontal levels in the fault tree.
  The mathematical relationship quantifying the probability of
dioxin contamination during its sample analysis was developed
based on the accompanying fault tree and the assigned probability
values of specific  events  as  designated by the alpha-numeric
variables printed next to the event in the fault tree. The  fault tree
formula is as follows:
    P(T)

    WHERE
    P(A2)
 P(A2)+P(A+)+Any  combination  of
 (A2.B2.C2 .   .  .G2)

• P(A2a)[P(A2al/A2a+P(A2a2/A2a)]
  +P(A2b)P(A2bl/A2b)
  +P(A2c)[P(A2cl/A2c)+P(A2c2/A2c)]
  +P(A2c)P(A2cl/A2c) P(A2c2/A2cl)

  P(A+)  = P(B2)+P(B+)
                  3
  P(B2)  = P(B2a)=   p(B2ai/B2a)
                      +P(B2b)  ^=1 P(B2bi/B2b)


                      +P(B2c)  ^=1P(B2ci/B2c)

             P(B+)  =  P(C2)+P(C+)

                      P(C2a)j   P(C2ai/C2a)
             P(C2)    +P(C2bVT(C2bl/C2b)
                      +P(C2c)   =P(C2ci/C2c)

             P(C+)  =  P(D2)+P(D+)

             P(C2)  =  P(D2a) 1L1P(D2ai/D2a)

                      +P(D2b)  P(D2bl/D2b)
                      +P(D2c)  P(D2cl/D2c)
                                                                              RISK/DECISION ANALYSIS
                                                   405
-------
             P(D-t-)  - P(E2) +  P(E+)

             P(E2)  • P(E2a)  I .  P(E2ai/E2a)
                       +P(E2b) P\E2b  /E2b)
                                 2
                       +P(E2c) fml P(E2cl/E2c)

             P(E+)  - P(F2)+P(F+)

             P(F2)  - P(F2a)  £ml P(F2al/F2a)


                       +P(F2b) fml P(F2bi/F2b)
                       +P(F2c) P(F2cl/F2c)
    P(F + )  -  P(G2a)

              +P(G2b)

              +P(G2c)
                                    P(G2ai/G2a)

                                   1 P(G2bi/G2b)

                                     P(G2ci/G2c)
   The variables used to define specific events are consistent with
the designation of tree branches in the event tree (Figure 2). For in-
                                                       stance, A2 designates the event of contamination due to the sample
                                                       packaging and A2a designates the event of contamination caused
                                                       by the contaminated vermiculite and/or plastic bags used  in the
                                                       packing. The only unique events included in the fault tree analysis
                                                       are those events associated with the final consequences of the diox-
                                                       in contamination such as events A2cl or A2c2.
                                                         Based on this fault tree analysis, the probability of occurrence
                                                       for each of the potential dioxin contamination scenarios during its
                                                       routine through the processing laboratory was evaluated. However,
                                                       as historical data which can be directly utilized to provide a basis
                                                       for such assessments is almost non-existent for most of the events,
                                                       many of the values given for each of the individual events are based
                                                       primarily on subjective judgments. Others are based on the values
                                                       used for similar situations in the chemical industry.
Rationale for Assessing Probability Values

  With  few exceptions,  most of the TCDD samples are in solid
form. Because of the TCDD's low solubility and high adhesion to
soil particles, it is not likely to be separated from the soil in any
media. Meanwhile, the undeniable facts do suggest that TCDD is
              Sample Packaging
              on Site
            Trans-shipment of
            Packaged Samples
           Sample Cataloguing
            and Inventory
                                        Extraction & Cleaninc
                                        for Dioxin
                                          Concentration
                                          Digestion for
                                           Dioxin
                                            Intra-Lab
                                            Transport
                                            of Concentrate
                                        Temporary Storage
                     To Storage  •*-
                                                            Sample
                                                            Residue
                                                            Disposal
                                                                                              To Air
                                                                                             I
                                                                                            A1r
                                                                                            Emission
                                                                                            f
                                                                                            GC/MS Sample
                                                                                            Preparation
                                                                                             Intra-Lab
                                                                                             Transport
                                                                                             of Syringes
                               GC/MS
                               Analysis
                                                                                     Computer Data
                                                                                        Incut
                                                                               Hastewater
                                                                               Discharge
                                                                                                            To Sewer
                                                          Figure 1
                                              Elements of Risk for Dioxin Analysis
406
RISK/DECISION ANALYSIS
-------
                                                                                                                    FAULT TREE
                                                     T:  Contamination
                   A2:  ContaalMted
                          Packaging,
GO

\
O
w
o
GO
>— i
O
00

So
h2c: Sample
Damage



A2cl: Con-
taalaated
Venlcullte


A2c2: Cont-
amloatin to
Worker*



-------
                                                        »*™^Q
                                                      Figure 2
                                            Event Tree for Risk Scenarios (1/4)
                                                      Figure 2
                                           Event Tree for Risk Scenarios (2/4)
408      RISK/DECISION ANALYSIS
-------
GC/MS
Analysts
                                                                   Figure 2
                                                   Event Tree for Risk Scenarios (3/4)
Alr/Bater
Discharge
                                                                                                   Contamination  to Voluntary Ubrkcn
                                                                                                   Contamination  to Iftvoluntan
                                                                                                    Co-Workers
                                                                                                  Contamination to IndlvlduaU In
                                                                                                    ttw Surroundlnf Comwiltv


                                                                                                  Cont«AlMlton to th« CnvlroMwnt
                                                                                                                        Contf«ln«tlon to
                                                                                                                          Voluntary Worker*
                                                                                                                                 loA to
                                                                                                                          Involuntary Co-vork*r»

                                                                                                                        Contamination to lndtvl~
                                                                                                                          dualt In th«
                                                                                                                          Surrounding Comnunlty
                                                                                                                        Contanlnatlon to th*
                                                                                                                          Environment
                                                                                                                        Contamination to
                                                                                                                          Voluntary Worker*

                                                                                                                        Contamination to
                                                                                                                          Involuntary Co-Workeri
                                                                                                                        Contamination to Indivi-
                                                                                                                          duals  In the
                                                                                                                          Surrounding Comnunlty
                                                                                                                        Contamination to the
                                                                                                                          Environment

                                                                                                                        Contamination to
                                                                                                                          Voluntary Worken
                                                                                                                        Contamination to
                                                                                                                          Involuntary Co-Workers
                                                                                                                        Contamination to Indivi-
                                                                                                                          duals  In the
                                                                                                                          Surrounding Community

                                                                                                                        Contamination to the
                                                                                                                          Environment
                                                                 Figure 2
                                                  Event Tree for Risk Scenarios (4/4)
                                                                                                        RISK/DECISION ANALYSIS
                                                                                                                                                              409
-------
quite persistent  in  its existence,  and it appears  unlikely to be
degraded by itself. Therefore, the TCDD contamination to any ex-
posed person will generally result from inhalation, ingestion or ab-
sorption through the skin.

Potential Routes of Contamination
  Inhalation
  TCDD contaminated dust and TCDD vapors generated during
the sample analysis procedure may accumulate in the air through
the existing air circulation systems. Levels would  be higher than
those occurring where there is much better ventilation.
Direct Ingestion
  Dust which settles on food or dirt  on hands and is then trans-
ferred to the mouth could be ingested. This route would be of par-
ticular  concern  where  non-voluntary  co-workers,  without the
knowledge  of specific spills  or contamination, are  involved.
However, exposure that occurs via this route may vary considerably
among individuals depending on their behavior regarding protec-
tion of food, washing of hands, etc. The judgmental value of prob-
ability placed upon this direct ingestion route is very shaky and its
accuracy can be seriously questioned.
Absorption through the Skin
  Dust which settles on exposed skin and  direct contact with the
dirt provides opportunities for TCDD to be absorbed through the
skin. However, this route for exposure in the laboratory is affected
by  the following considerations:
•Most of the skin area of the lab personnel is covered by clothing
•The contact time, if any, may be very short
•TCDD cannot pass through the skin  unless it is removed from the
  dust particles. Consequently, this route may be considered mini-
  mal when compared with all of the other  possibilities
Other Potential  Exposures
•Direct contact with TCDD when it is concentrated in the solvents
•Inhalation of fumes of TCDD while  it is being extracted, digested
  and concentrated
                                                       •Direct  contact of  TCDD by non-workers or involuntary co-
                                                        workers because of improper handling of the sample residues or
                                                        the pre-inventory samples
                                                         In view of all the potential routes of the various TCDD exposure
                                                       pathways, the air transport route would probably cause the highest
                                                       or the most severe exposure levels.
                                                       Estimation of TCDD Concentrations in the Air

                                                         Though laboratory and personnel movement play an important
                                                       role, for this exercise the  following are utilized: dust levels inside
                                                       the laboratory building are generally low; the activity of people in-
                                                       side  and outside  the  restricted  rooms is  moderate,  causing
                                                       minimum air turbulence or physical agitation of the dirt and subse-
                                                       quent escape of the dirt from the central area; the building is well
                                                       ventilated, with the supply  air intake  point located downstream
                                                       along the prevailing wind of the exhaust point of the returning air;
                                                       and the ventilation could  create some recycling of the exhaust air
                                                       and accumulation of the contaminated dust particles.
                                                         The TCDD levels in the soil were found to range from 70 to 200
                                                       ppb. It was assumed that the total dust levels ranged from 0.4 to 1.0
                                                       mg/m3. Assuming the TCDD levels  in the dust particles are the
                                                       same as in the soil, the concentration of TCDD in the air =  TCDD
                                                       concentration in soil x total  particulate concentration in air = 3 x
                                                       10-" to 2 x 10-7 mg/m3.
                                                         The low vapor pressure  of TCDD has been widely assumed to in-
                                                       dicate that very little TCDD would evaporate from  contaminated
                                                       soil.  However, many investigators are now discovering that low
                                                       vapor pressure compounds  which  also have low water solubility
                                                       evaporate more readily from  soil, thus TCDD may have  an en-
                                                       hanced ventilation rate from the samples, particularly after it has
                                                       been cleaned,  extracted,  digested and concentrated. For these
                                                       reasons, it was assumed that the vapor pressure of TCDD may be
                                                       much higher than  10~6 mm of  mercury. All these facts suggest that
                                                       TCDD vapors  could cause  exposure inside the poorly ventilated
                                                       rooms.
                                                           Table 1
                                                  Estimate of Probability Values
P{A2a) • 10"3
P(A2al/A2a) •
P(A2a2/A2a) •
P(A2b) • 10'6
P(A2bl/A2b) •
P(A2c) • 10'6
P(A2cl/A2c) •
P(A2c2/A2c)
P(A2c2/A2cl) •

P(B2a) • ID"4
P(B2al/B2a) •
P(B2a2/B2a) •
P(B2a3/B2a) •
P(B2b) • ID'5
P(B2bl/B2b) -
P(B2b2/B2b) •
-10-5
0.1
o.oi-

o.i-
-10-8
o.i-
• n.
• 0.1


10-2-
10-2
10-3

10-2
10-3

0.01
• io-4

0.01

0.01
m- in-4
-o.oi


• 10-3
-10-3
•io-4

-10-3
-io-4
P(B2c) • 10'4
P(B2cl/B2c) -
P(B2c2/B2c) »
P(C2a) * 10'4
P(C2al/C2a) -
P(C2a2/C2a) -
P(C2b) ' lO"6
P(C2bl/C2b) •
P(C2c) • 10'6
P(C2cl/C2c) -
P(C2e2/C2c) •
P(C2c3/C2c) •
P(C2c4/C2c) -
P(02a) • 10'4
P(02al/D2a) -
P(D2a2/D2a) •
P(02b) • 1 -3
10-5
10-2-
io-4-
io-6
lo-1-
10-2-
-10-7
10-3-
-10-7
10-3-
io-4-
10-6-
10-7-
io-6
10-'-
io-3-
lO-5

io-4
IO-6

10-3
10-4

io-4

10-5
ID"6
io-7
10-8
1
10-3
iir*

P(D2bl/02b) '
P(D2c) « ID'3
P(D2cl/D2c) *
P(E2a) « ID'4
P(E2al/E2a) •
P(E2a2/E2a) •
P(E2a3/E2a) •
P(E2b) • 10-2
P(E2bl/E2b) •
P(E2c) - ID'2
P(E2cl/E2c) •
P(E2cl/E2c) •

P(F2a) • ID'3
P(F2al/F2a) •
P(F2a2/F2a) •
P(F2a3/F2a) -
10-3-
io-4
10-2-
io-6
10'1-
10-2-
io-4

10-3

10-2
ID'3
10"4 -lO-5
-10-3

10'1 -10-3
-io-3
io-1 -
lO'1-

-lo-4
ID'2-
lo-1-
10-3-

ID'2
ID'2

P(F2b) • ID'5
P(F2bl/F2b) •
P(F2bR/F?b)
P(F2c) - 10'4
P(F2c1/F2c) •

P(G2a) - 10'1
P(G2al/G2a) •
PG2a2/G2a) •
P(G2b) • 10"3
P(G2bl/G2b) •
P(G2b2/G2b) -
P(G2b3/G2b) •
-ID'6
10-2-

ID'3
« in-3 - io"4
-io-s
10-2-

-10-2
io-3-

10-3


io-4
io"4- io'6
-ID'5
10-3-
10-5-
10"6 -

io-4
ID'6
io-7
P(G2c) • ID'5- 10-6
10-3
ID'3
io-4
P(G2cl/G2c) •
P(G2c2/G2c) •
P(G2c3/G2c) •
, lO"3 -
, 10*5 .
' 10"6 -
io-4
ID'*
io-7
410
RISK/DECISION ANALYSIS
-------
  The toxicity of the TCDD to animals is fairly well documented;
extrapolation of these effects to humans is unknown. Consequent-
ly, the risk ratios of TCDD to human health cannot be quantified.
Therefore, it is assumed that its risk ratio is in the range of 200 to
300, which is the same as the worst ratios for vinyl chloride.
  Estimates  of the probability values are  based on  the  in-
vestigators' perception of the likelihood of occurrence of the events
in consideration and  should lean toward  the conservative  side.
Conditional probability values following each of the key events are
also based on the investigators' judgments. In order to compensate
for the uncertainties of these judgmental  values, a fairly liberal
range is given for each of the probability values. A subsequent sen-
sitivity analysis  for selected events should be conducted to assess
the resultant probability of the contamination to both lab person-
nel and the  community and the sensitivity of the  various assumed
values.
RISK ACCEPTABILITY
   In order to assess the acceptability of the risk associated with the
dioxin laboratory analyses for both the laboratory personnel direct-
ly and  indirectly involved and for the surrounding community,
basic characteristics of the risk in terms of the probability of occur-
rence and the  potential consequent  to both individuals and the
society must be analyzed in detail. First, the basic characteristics of
the risk must be defined and delineated. Second, the incremental
risk acceptance value for each of the risks identified in terms of risk
referent shall be developed. Finally, the objective risk value  com-
puted, based on the potential consequence, should be  compared
with the risk referent  value to determine the  acceptability of the
 current practice.
   Based on the risk classification as outlined in Table 2, the risks
 associated with the dioxin laboratory analysis can be characterized
 as immediate statistical accidents and categorized as follows:
 •Risk for the laboratory personnel specifically assigned to the di-
  oxin analysis: ordinary voluntary risk.
 •Risk  for the co-workers located in the same building: ordinary
  voluntary regulated risk.
 •Risk for the surrounding community  of the USEPA Region VII
  laboratory: ordinary involuntary risk.
                                                      The procedures to be followed for the determination of risk ac-
                                                    ceptability for the TCDD processing centers are:
                                                    •Develop an appropriate risk classification scheme.
                                                    •Determine the risk reference value for each class of risk encoun-
                                                     tered in the dioxin analysis procedures
                                                    •Compute risk referents for each class of risk
                                                    •Compare the estimated risk from fault tree analysis with the risk
                                                     referent values
                                                      In view of the risks confronted by different sectors of population
                                                    in the laboratory and its surroundings, appropriate risk classifica-
                                                    tions developed for each sector of the population are summarized
                                                    in Table 3.  The  dioxin  analysis  is essentially a  typical  man-
                                                    originated,  ordinary event. However,  since the reliability and
                                                    statistical validity  of existing  data characterizing various conse-
                                                    quences of the dioxin exposure accidents are absent, only piecemeal
                                                    information covering personal injuries and immobility could be
                                                    collected and reviewed. Thus, the risk reference value characteriz-
                                                    ing the personal injury in terms of health effects per year is the only
                                                    consequence included in the risk acceptability evaluation as shown
                                                    in Table 3. In fact, based on limited data, personal injury seems to
                                                    be the only visible and pronounced consequence due to dioxin ex-
                                                    posure being reported so far.

                                                                                Table 3
                                                        Summary of Risk References for Dioxin Exposure in Laboratory
                                                    Type of Risk

                                                    Personal injury or
                                                    immobility for laboratory
                                                    workers

                                                    Personal injury or
                                                    immobility for co-workers
                                                    in the laboratory

                                                    Personal injury to the
                                                    population in local
                                                    community
                                                              Risk Classification
                                                              Voluntary, ordinary
                                                              man originated
                                                              ordinary regulated
                                                              voluntary man
                                                              originated

                                                              ordinary involuntary,
                                                              man originated
                                                                          Risk Reference
                                                                          (rath. Eff./Yr.)

                                                                          3 x 10-1
                                                                                       6x 10-2
                                                                          3x 10-5
                            Table 2
         Risk References for Immediate Statistical Accidents
 Ilik
 Cluilfleielon
 naturally
 Occurring!

 Catai tropic i
 Ordinary)
 "an Trigger*!
 Cataitrophic-
 Involuntary
 Volulntary
 Ordinary
 Involuntary
 Voluntary
 'egulated
 Voluntary
ratallttaa
far
Tear
1 z 10
7 X 10
Han Originated
Cataatrophic-
tnvoluntary
Voluntary
>*julatad
Voluntary
Ordinary-
Involuntary
Voluntary
Itgulated
Voluntary

1
2

j

S
1

1

x
x

X

X
X

>

10"7
10"'

10"5

10~*
10"4

10"4
I * 10 '
4 x 10"°

1 x 10"!
1 x 10 J

2 x 10"*
  COA««qU«IlC«>
•••1th Affacts Prop.  Daug*  Reduction of
             $/P«r        Lif« Span
Year          f««r        (Y««r*)
S x 10
4 x 10*
                             S x 10"'
                             2.x 10"s
                                  -5
             1 x 10

             } x 10
             « x 10"'

             C x 10"2
i x io:6
4 xlO 6
0.02
3
                           2 x 10-'
                           .4
                                          1
                                          200
                                          JO
              O.I
1 x 10
0.2
                                           ,-J
                         1 x 10"
                         4 x 10"
                                                      ( x 10
                         1 x 10
                         0.1
                                                      0.1
                                      C x 10"
                         3 x 10
 Source: Rowe, W., An Anatomy of Risk, John Wiley & Sons, New York, 1977.
OBTAINING RISK REFERENT VALUES:
  These risk reference values are estimated directly from historical
and societal risk data that are analogous to the situations and con-
sequences  involved in  dioxin  analysis. Transforming  the risk
reference values into appropriate risk referents requires the follow-
ing four steps:
•Determine the appropriate risk proportionality factor (Fl) which
 incorporates the societal attitude due to its expectations associated
 with the degree of voluntarism of the affected population.
•Determine the appropriate risk proportionality derating factor
 (F2) which discounts the existing societal risk  acceptable  level
 due to the indirect benefit/cost balance considerations for the di-
 oxin exposure via laboratory analysis (Table 4).
•Develop and quantify the risk controllability factor (F3) which
 characterizes the basic control approach,  the degree of control,
 the state of implementation and the judgment of control effective-
 ness (Table 5).
•Determine the referent using  the factors  derived  in the above
 three steps by the formula:
 risk referent = (risk reference) x Fl x F2 x F2

These factors are subjective.
  The first two factors address  the inherent  propensity of effected
populations to take risks and also incorporates the additional deci-
sion  dimension   of  indirect  benefits/cost  balance.  This
acknowledges the tendency of people to accept higher levels of risk
when the potential benefits far outweigh the potential costs. On the
other hand, people may become increasingly risk aversive when the
potential benefits are likely to be offset by the costs.
                                                                                            RISK/DECISION ANALYSIS
                                                                                                                411
-------
  The risk proportionality and its derating factors, as determined
for different sectors of populations, are shown in Table 4. Though
not to the same degree, the controllability factor is also found to be
varied due to the target  population, as shown in Table 5.
  Incorporating all the factors determined above, the appropriate
risk referents for different affected population sectors are derived
as shown  in Table 6.

                            Table 4
    Risk Proportionality and Risk Proportionality Derating Factor
        Factor
        Proportionality Factor
        Derating Factor
          Laboratory Worker
          Co-Worker in the Building
          Surrounding Community
                                       Value
                                       1.0

                                       0.2
                                       0.1
                                       0.1
                            Table 5
                      Controlability Factor
                 Control
                  Approach  Control

 Laboratory Worker   1.0       1.0
 Co-Workers in the
 Building            0.5       1.0
 Surrounding
                           Degree of  State of
                                               Control
                            Implementa. Effectiveness

                            0.5        1.0
 Community
                 0.3
                           0.3
                            0.5
                                     0.1
                                      1.0
                                               0.5
                            Table 6
            Risk Referents and Estimated Maximum Risks
Population
Sector
USEPA Lab
Personnel
USEPA Co-
Workers in the
Same Building
Surrounding
Community
Risk
Reference
3 x 10-1
6x 10-2
3 x 10-5
Risk
Reference
3x 10-2
1.5 x 10-3
1.4 x 10-8
Est. Max.
Risk
3.2 x 10-3
1.2 x 10-3
1.1 x 10-6
RESULTS
   On the basis of the above judgments and limited data, the risk
referent values versus the estimated v???s???c??? the risks for both
laboratory workers and their co-workers in USEPA are considered
to be acceptable. On the other hand, the risks for the surrounding
community may be marginally acceptable.
Sensitivity
  All the values shown in Table 6 are based on a very conservative
judgment for the occurrence of all potential accidents described in
the fault tree. A difference of magnitude in the order of two to
three may still be within the range of cumulative errors. Thus, in
reality, the risk estimated for the community may be too high and it
is therefore considered to be marginally acceptable.
  For the facility considered, the sensitivity analysis for selected
fault events indicates that with minimum modification of sample
inventory, disposal procedures and paniculate air filters, the risk to
the community could be significantly reduced.
  Specifically, the modifications are:
•Collect all liquid wastes from the dioxin analysis laboratory and
 release it into the sewer only after its concentration of dioxin has
 been confirmed  to be below the allowable level.
•Install  efficient filters for the air exhaust system of the analytical
 laboratories used for dioxin.
•Institute and maintain an organized and strict procedure for the
 disposal and inventory of sample residues.
  Based on the investigators'  analysis,  the above modifications
would reduce the risk to the community to 1.1 x 108 which is well
within the acceptable level.  In  addition,  maximum estimated risk
for the co-workers may be lowered from 1.2 x 103 to 2.1 x 104 which
is well below the acceptable  level of 1.5 x 103.
CONCLUSIONS

  Risk assessment for the potential hazards to lab workers, co-
workers in the same building and the surrounding community due
to the handling and analysis of dioxin samples [TCDD] can be con-
ducted based on some piecemeal information characterizing the
consequences and the conservative judgments of the investigators.
However, with a built-in cushion of error allowance, it may be con-
cluded that:
•The risk to both laboratory workers and their co-workers in the
 building is acceptable.
•The risk to the surrounding community may be considered mar-
 ginally acceptable. However, with minimal modifications to the
 facility and to practices,  the risk can be acceptable.
                                                         REFERENCES

                                                          . Rowe, W. An Anatomy of Risk, John Wiley & Sons, New York, 1977.
                                                         2. Shih, C.S. and Ess, T., "Perspectives of Risk Assessment for Haz-
                                                           ardous  Waste Management,-- Proc.,  Third National Conference on
                                                           Uncontrolled Hazardous Waste Sites, Washington, D.C.,  November
                                                           1982, 408-413.
                                                         3. Veseley, W., et at.. Fault Tree Handbook, U.S. Nuclear Regulatory
                                                           Commission, NURGC-0492, 1981.
412
RISK/DECISION ANALYSIS
-------
          MANAGEMENT PLAN  FOR HAZARDOUS WASTE
                         SITE CLEANUPS IN  NEW  JERSEY

                                       MARWAN M. SADAT, Ph.D.
                                             MICHELE MATEO
                                             ANTHONY FARRO
                          New Jersey Department of Environmental Protection
                                             Trenton, New Jersey
INTRODUCTION
  This Management Plan for hazardous waste site mitigation has
been prepared by the Department of Environmental Protection
(DEP), Division of  Waste Management, of the State of New
Jersey, for the period of 1983-1986. The purpose of the plan is to
develop a systematic approach to remedial action at hazardous
waste* sites, to coordinate cleanup and enforcement actions and to
identify future funding needs and sources.
  There are a total of 106 hazardous waste sites identified in the
plan (Table 1). These include: 65 sites on the National Priorities
List (NPL) issued by the USEPA on Dec. 20, 1982 and eligible for
Federal Superfund monies and 41 sites which were not included on
the NPL. Thirty-four drum dump sites listed in the draft plan ap-
proved by USEPA on Apr.  11, 1983, were cleaned  up in 1983.
Those sites not on the NPL will be addressed through New Jersey's
Spill Compensation Fund and Hazardous Discharge Fund as were
the recently cleaned up sites. While cleanup projects are expected to
be initiated within the period of the plan, completion of cleanups at
all scheduled sites will be a seven- to eight-year effort with some
sites requiring maintenance for many years beyond that time.
  As additional sites are approved for Superfund status or as other
sites requiring priority status are identified, the list will be changed
accordingly. For example, in response to the discovery of chemical
contamination with dioxin at some industrial  sites,  four sites**
have recently been added. These discoveries were made as a result
of systematic  investigations conducted by a special Dioxin Task
Force instituted by DEP, and stringent precautions are being taken
to limit human and environmental exposure to the chemical at these
sites. To date, sampling and analyses have been conducted at 11
sites and cleanup has begun in several areas.
  The  plan also lists the 68 hazardous waste sites (Table 2) with
over 10,000 drums cleaned up by DEP since 1980 at a cost of ap-
proximately $3 million. Including the $26 million spent on cleanup
of Chemical Control in Elizabeth and $6 million on Goose Farm in
Plumsted Township, the state's cost for remedial work at these 70
hazardous waste sites is over $35 million  to date.
  The  plan represents the culmination of a review process which
started with an original list of sites ranked by DEP and USEPA ac-
cording to the Federal Hazard Ranking System (HRS). This system
* "Hazardous waste" is being used here as a generic term to include discharges of all hazardous
 materials which pose a threat to public health or the environment.


"Blue Spruce International, Inc.; Chemical Insecticide Corporation, Diamond Alkali/Diamond
  Shamrock Corporation and Givaudan Corporation.
                                                                                                  HAZARDOUS WASTE DUMP SITES

                                                                                                 •    Superfund Sites

                                                                                                 A    Non-Supeifund Sites

                                                                                                      Drum Dump Sites

                                                                                                        August, 1983
                                                                                    Figure 1
                                                                            Hazardous Waste Dump Sites
                                                                                        STATE PROGRAMS
                                                                                                                 413
-------
                                                          Table 1
                                          Sites Included In Management Plan/1983-1986
Site Name
Albert Steel
American Cyanamid*

A.O. Polymer'
Arky Property
Asbestos Dump*
Ashland Company
Barrier Chemical Industry!
Beachwood/Berkeley Wells*
Blue Spruce international Inc.
Bog Creek Farm't
Borne Chemical
Brick Township Landfill*
Bridgeport Rental & Oil
Service* t
Burnt Fly Bog't
Buzby Brothers Landfill t
Caldwell Trucking Co.*
Cheesequake State Park
Chemical Control Corp.*
Chemical Insecticide Corp.
Chemsol, Inc.*
Chipman Chemical
Combe-Fill North Landfill*
Combe-Fill South Landfill*

Cooper Road?
CPS/Madison Industries*
Delilah Road Landfill*
(aka Price's Landfill Site #4)
Denzer & Schafer X-Ray Co.*
Diamond Alkali Co.
D'Imperio Property* t
Dover Municipal Well #4*
Duane Marine
Duck Island Landfill
Ellis Property*
Evor-Phillips*
Fairlawn Wellfield*
T. Fiore Demolition t
Friedman Property* t
Frontage Roadi
OEMS Landfill* t
Oivaudan Corp.
Goose Farm*
Green Acres Landfill}
Hercules, Inc.*
Horseshoe Road Dump)
Ideal Cooperage
Imperial Oil/Champion
Chemical*
Jackson Twp. Landfill't
JIS Landfill't
Kearny Drum Dumps
(Nos. l-5)t
Kin-Buc Landfill*!
King of Prussia Landfill*
Kit Enterprises
Koppers Company
Kramer Sanitary Landfill*
Krysowaly Fann't
Lang Property* t
Lipari Landfill* t
Municipality
Newark
Bridgewater Twp
Bound Brook Boro
Sparta Twp
Marlboro Twp
Passaic Twp
Woodbridge Twp
Vernon Twp
Berkeley Twp
Bound Brook
Howell Twp
Elizabeth City
Brick Twp
Logan Twp

Marlboro Twp
Voorhees Twp
Fairfield Twp
Old Bridge Twp
Elizabeth City
Edison Twp
Piscataway Twp
Middlesex Boro
Mount Olive Twp
Chester Twp/
Washington Twp
Voorhees Twp
Old Bridge Twp
Egg Harbor Twp

Berkeley Twp
Newark City
Hamilton Twp
Dover Twp
Perth Amboy City
Hamilton Twp
Evesham Twp
Old Bridge Twp
Fairlawn Boro
Newark City
Upper Freehold Twp
Newark City
Gloucester Twp
Clifton
Plumsted Twp
Frelinghuysen Twp
Greenwich Twp
Sayreville Boro
Jersey City
Marlboro Twp

Jackson Twp
Monroe Twp
Keamy

Edison Twp
Winslow Twp
Elizabeth City
Kearny Town
Mantua Twp
Hillsborough Twp
Pemberton Twp
Mantua Twp
County
Essex
Somerset

Sussex
Monmouth
Morris
Middlesex
Sussex
Ocean
Somerset
Monmouth
Union
Ocean
Gloucester

Monmouth
Camden
Essex
Middlesex
Union
Middlesex
Middlesex
Middlesex
Morris
Morris

Camden
Middlesex
Atlantic

Ocean
Essex
Atlantic
Morris
Middlesex
Mercer
Burlington
Middlesex
Bergen
Essex
Monmouth
Essex
Camden
Passaic
Ocean
Warren
Gloucester
Middlesex
Hudson
Monmouth

Ocean
Middlesex
Hudson

Middlesex
Camden
Union
Hudson
Gloucester
Somerset
Burlington
Gloucester
Site Name
Lone Pine Landfill* t
Manchester Twp Mile
Marker 28
Manheim Ave. Dump Site*
Maywood Chemical*

Metaltec/Aerosystems*
Minsei Kogyo Shojit
kk America, Inc.
Mirex Dump
Mobil Chemical
Monroe Twp Landfill*
Montgomery Twp Housing
Development*
Myers Property* t
N.L. Industries*
Pepe Field*
Perth Amboy PCB Case
Pijak Farm't
PJP Landfill*
Price's Landfill't
(Nos. 1,2,3)
Quanta Resources
Reich Farm*
Renora, tnc.'t
Ringwood Boro Landfill/
Mines*
Rockaway Borough Wellfield*
Rockaway Township Wells*
Rocky Hill Municipal Well*
Roebling Steel Company*
Roosevelt Drive-In t
Sayreville Landfill*
Sayreville Pesticide Dumpt
Scientific Chemical Processing*
Seaview Square Mall/M & T
Delisa Landfill*
Sharkey's Farm Landfill*

South Brunswick Landfill*
Spence Farm*t
Storer Dumpt
Swope Oil and Chemical* t
Syncon Resins*
Tabernacle Site!
Toms River Chemical Co.*
U.S. Radium Site*
Universal Oil Products*
Vineland State School*
White Chemical Company
Williams Property *t
Woodland Twp Dump *
Woodland Twp Dump Ifl







Municipality
Freehold Twp
Manchester Twp

Galloway Twp
Maywood Twp/
Rochelle Park Boro
Franklin Boro
Woodland Twp

Sayreville Boro
Carteret Boro
Monroe Twp
Montgomery Twp

Franklin Twp
OldmansTwp
Boonton Town
Perth Amboy City
Plumsted Twp
Jersey City
Egg Harbor Twp/
PleasantvUle City
Edgewater
Dover Twp
Edison Twp
Ringwood Boro

Rockaway Boro
Rockaway Twp
Rocky Hill Boro
Florence Twp
Jersey City
Sayreville Boro
Sayreville Boro
Carlstadt Boro
Ocean Twp

Parsippany-Troy Hills
Twp
S. Brunswick Twp
Plumsted Twp
Marlboro Twp
Pennsauken Twp
Kearny Town
Tabernacle Twp
Dover Twp
Orange City
E. Rutherford Boro
Vineland City
Bayonne City
Middle Twp
Woodland Twp
Woodland Twp







County
Monmouth
Ocean

Atlantic
Bergen

Sussex
Burlington

Middlesex
Middlesex
Middlesex
Somerset

Hunterdon
Salem
Morris
Middlesex
Ocean
Hudson
Atlantic

Bergen
Ocean
Middlesex
Passaic

Morris
Morris
Somerset
Burlington
Hudson
Middlesex
Middlesex
Bergen
Monmouth

Morris

Middlesex
Ocean
Monmouth
Camden
Hudson
Burlington
Ocean
Essex
Bergen
Cumberland
Hudson
Cape May
Burlington
Burlington







•Superfund sites included on the proposed National Priorities Lut of 12/20/82
tSites includes on the Hazardous Discharge Bond Act effective 1/6/82
(Drum Dump Sites


414
STATE PROGRAMS
-------
                                                                       Table 2
                                                  Completed Small (Surface) Drum Dump Cleanups
                                                              From 1980 to the Present
Site Name
AUoway Township
Altman Street Drum Dump
Atlantic Development Stage II
A-Z Chemical*
Barnegat Light Boro DPW*
Barone Barrel & Drum Co.
Bayonne DPW*
Bayonne Landfill Drums
Bjomlass Kennels*
Black River Area*
Blue Spruce/Tifa
Boro Garage Route 47
Bubenick Property
Burlington Avenue*
Camden Fire Department*
Carlstadt DPW*
Clinton Place
Cohawkin Road*
Columbus Avenue*
Communipaw Avenue*
Thomas A. Cook
Creekturn Ceramics*
DOT*
DOT Yard*
Doughty Road*
Dover DPW*
314 East Fourth St.
El Cid  Contracting Corp.
Ellis Property*t
  (Drum Removal)
Emerald Trail*
Fish Road
Franklin Mines
Fulton  Street
Glassboro Lab Pack Co.
Gold Leaf Trucking
Gordon Services
Harleigh Cemetery*
 17 Horizon Boulevard
Jackson DPW*
Jersey City Department of
  Public Works Rte 440
Kurtz Residence*
Lab Reagents
Liberty State Park
Madison Circle
Manchester DWP*
Mikropul*
Murray Hill Parkway*
Nash Property*
Newark Stamp & Dye
NJ Turnpike Mile Market 16.7
North Bergen/Keystone Steel
North Hook Road
Northern Fines
Oldham Road
Paterson DPW*
Pleasant Grove Road*
Rahway River Park*
Reimer Street*
Ringwood/West Milford
Township
County
Alloway
Rutherford
Sayreville
New Brunswick
Barnegat
Paterson
Bayonne
Bayonne
Montville
Chester
Bound Brook
Clayton
Piscataway
Delanco
Camden City
Carstadt
Newark
E. Greenwich
Roselle
Jersey City
Newark
Hainesport
Wall Twp
Logan Twp
Egg Harbor Twp
Dover Twp
Plainfield
Howell Twp
Evesham
Bridgewater
Jackson Twp
Franklin
Paterson
Glassboro
Sewaren
Jersey City
Camden City
South Hackensack
Jackson Twp
Jersey City
Woodstown
Burlington
Jersey City
East Rutherford
Manchester
Garwood
E. Rutherford
Buena
Newark
Mantua
North Bergen
Bayonne
Franklin
Wayne
Paterson
Long Valley
Rahway
Mount Holly
Ringwood/West Milford
Salem
Bergen
Middlesex
Middlesex
Ocean
Passaic
Hudson
Hudson
Morris
Morris
Somerset
Gloucester
Middlesex
Burlington
Camden
Bergen
Essex
Gloucester
Union
Hudson
Essex
Burlington
Monmouth
Gloucester
Atlantic
Ocean
Union
Monmouth
Burlington
Somerset
Ocean
Sussex
Passaic
Gloucester
Middlesex
Hudson
Camden
Bergen
Ocean
Hudson
Salem
Burlington
Hudson
Bergen
Ocean
Union
Bergen
Atlantic
Essex
Gloucester
Hudson
Hudson
Sussex
Passaic
Passaic
Morris
Union
Burlington
Passaic
Site Name
Rt.  1-95 Trailer
Samson Tank
South Amboy Water Works*
610 South Thirteenth St.
Swoco
Union Twp. DPW*
Venice Boulevard*
Victoria Lane*
Wilson Farm (Surface
  Cleanup Only)

•Cleanups conducted in April 1983
Township
Jackson
Jersey City
S. Amboy
Newark
Hillsboro
Union Twp
Buena Twp
Hackettstown
Plumsted Twp.
County
Ocean
Hudson
Middlesex
Essex
Somerset
Union
Atlantic
Warren
Ocean
                                                                               Figure 2
                                                     Completed Surface Cleanups from 1980 through August 1983
                                                                                                                  STATE PROGRAMS
                                                                                                                    415
-------
                                                      Table 3
                                               Cleanup Work Schedule
SITE NA*
(in Buc Luruirm
Burnt flf Bog
Lone Pine Landfill
Friedman Property
D'lmnerlo Property
Brld|teport Rental
Oil Service
GEHS Landrlll
Pljak Farm
Spence Far*
Goose Fan*
Chenlcal Control
Price's Landrill
Prlce'n Landfill I
Price' a Landrlll II,
III and IV
Perth Amboy PCB i:os«-
Kramer Landrlll
Combe- rill North
Landfill
Swop* Oil • Chemical
Bog Creek Farn
LI par 1 Landfill
Hockaway Boro
Uelirield
Retch Far*
Combe- Mil South
Landfill
Falrlawn Tup.
WelUleld
Sharkey's Fam
Landfill
Beacnwood/Berkeley
Valirield
Syncon Realns
Kryaowaty Fan
Caldwell Trucking
Brick Township
Landfill
Scientific Chemtral
Processing
Duck lit am]
Landfill
Universal Oil
Products
ftlngwood Boro
Landflll/Hlnes
Woodland Top.
Dump Ho. 11
Haywood Chemical
Barrier Che*lcal
Industry
FEASIBILITY
4th quarter
Completed
Completed
Completed
3rd quarter
Cnapleted
3rd quarter
3rd quarter
3rd quarter
Ird quarter
3rd quarter
4l.h quarter
Completed
4th quarter
4th quarter
4th quarter
4th quarter
4th quarter
4th quarter
STUDY
of '83



of
of
of
of
of
of
of
of
of
of
of
of
of
Completed ISWI
1st quarter of
1st quarter
lat quarter
1st quarter
lat quarter
lat quarter
lat quarter
2nd quarter
2nd quarter
2nd quarter
2nd quarter
2nd quarter
2nd quarter
2nd quarter
3rd quarter
3rd quarter
3rd quarter
3rd quarter
of
of
of
of
of
of
of
of
of
of
of
of
of
of
of
of
of



•B3
•83
•83
•83
•83
•83
•83
•83
•BJ
•83
•83
•83
•83
•84
•84
•84
•84
•84
•84
•84
•84
•84
•84
•84
•84
•84
•84
•84
•84
•84
•84
2nd
4th
lat
3rd
3rd
DESIGN
quarter
quarter
quarter
quarter
quarter
Couple ted
2nd quarter
1st
3rd
3rd
3rd
3rd
3rd
1st
2nd
2nd
4lh
4th
3rd
4th
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
of
of
or
or
or
of
or
or
or
or
or
of
of
or
of
of
of
of
or
Completed (SW)
3rd quarter of
1st
lat
1st
1st
1st
1st
2nd
2nd
2nd
2nd
2nd
2nJ
2nd
1st
1st
1st
3rd
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
quarter
or
of
or
or
or
of
of
or
or
or
or
or
or-
or
or
or
or
'84
•83
•84
•84
•84
•84
'85
'84
•84
•84
•83
•84
•84
•85
•85
•84
•84
•84
•84
•85
•85
•85
•85
•85
•85
•05
•85
•85
•85
•85
'85
•85
85
•86
•86
•86
•85
TREATteNT/REMOVAL
ongoing (141
4th quarter or '84
1st quarter or
2nd quarter or
2nd quarter of
4th quarter of
3rd quarter or
Completed IIA)
4th quarter or
Completed (IA)
2nd quarter or
3rd quarter of
3rd quarter of
3rd quarter of
4th quarter or
2nd quarter of
4th quarter or
4th quarter of
3rd quarter or
2nd quarter or
3rd quarter or
3rd quarter or
4th quarter or
4th quarter or
2nd quarter or
3rd quarter or
Completed (IA)
Completed ISWI
4th quarter or
4th quarter or
4th quarter or
4th quarter or
1st quarter or
'ith quarter of
lat quarter of
3rd quarter of
1st quarter of
4th quarter of
2nd quarter or
2nd quarter or
2nd quarter of
2nd quarter or
2nd quarter or
2nd quarter or
2nd quarter or
2nd quarter or
2nd quarter of
2nd quarter or
•85
•85
•85
•83 (IA)
•85
•84
•85
•85
•85
•85
•83 (IA)
•85
•83 IIA)
•84
•86
•84 (IA)
•86
•83 (IA)
•80
•85
•85
•85
•86
'85
•85
•85
•86
•85
•86
•83 (IA)
•86
•83 IIA)
'86
•86
•86
•86
•86
•86
•88
•88
•88
•86
LEAP"
EPA/OP
DEP
EPA
DEP
EPA
EPA
DEP
DEP
DEP
DEP
EPA
EPA
EPA
DEP
EPA
DEP
EPA
EPA
EPA
DEP
EPA
DEP
DF.P
DEP
DEP
DEP
EPA
DP.P/RP
DEP/HP
F.PA/RP
DEP
DEP/RP
EPA
DEP
EPA
DEP
FUNDING SOURCE**
RP
SF
SF
SF
SF
SF
SF
SF
SF
SF
SF
SF
SF
NS
SF
SF
SF
SF
SF
SF
SF
SF
SF
SF
SF
SF
SF
RP
RP
RP
NS
RP
SF
NS
SF
NS
416
STATE PROGRAMS
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Table 3 (continued)
SITE NAME FEASIBILITY STUDY
Metal lec/Aerosystens 3rd quarter of '84
Lang Property 4th quarter of '84
Manchester Tup. /Mile tth quater of '84
Marker 128
King of Prussia Landfill 4th quarter of '84
Ideal Cooperage 4th quarter of '84
Toms Diver Chemical Irst quarter of '8S
Rockauay Twp. Wells 1st quarter of '85
Chemsol, Inc. 1st quarter of 'B*>
Imperial Oil /Chanplon 2nd quarter of '85
Chemical
Dover Tup. 2nd quarter of '85
Municipal Well 14
Roebllng Steel 2nd quarter of '85
Company
Vlneland State 3rd quarter of '85
School
Williams Property 3rd quarter of -85
Renora, inc. 3rd quarter of '85
Denier H Schafer 3rd quarter of '85
X-Ray Co.
Hercules, Inc. 4th quarter of '85
Arky Property 4th 'tunr'.er of '85
Asbestos Dump/ 4i.h .|Uvler of '85
Mllllngton
Chlpman Chemical 4th quarter of 'B5
Rocky Hill Municipal 4th quarter of '85
Well
Montgomery Twp. 1st quarter of '86
Housing Development
Ashland Chemical \st quarter of '86
Sayrevllle Landfill is( quarter of'H6
Evor-I'hllllps i3t quarter of '86
Mannheim Ave. 1st quarter of '86
Dump .Site
Ellis Property
?nd quarter of '86
?nd quarter of '86
Pepe Field 2nd quarter of '86
Seavlew Square Mall/ 3rd quarter of '86
M t T Dellsa Landfill
Buzby Bros. Ird quarter of '86
Landfill
A.O. Polymer Ird quarter of '86
PJP Landfill 'ith quarter of '86
Horseshoe Road Dumps 4th quarter of '86
Horseshoe Road Dump
Sayrevllle Pesticide
Koppers Co. ^th quarter of '86
Woodland Dump 4th quarter of '86
No. 12
EPA Environmental Protection Agency
'RP Responsible Party
SF Superfund
NS Non-Superfund Sources of fund Ings. In
case of responsible parties. It la expe
that such parlies will finance clean-up
though the site may be on the National
List.
DESIGN
2nd quarter of '85
4th quarter of '85
4th quarter of '85
4th quarter of '85
3rd quarter of '85
3rd quarter of '86
1st quarter of '86
1st quarter of '86
2nd quarter of '66
2nd quarter of '86
1st quarter of '86
3rd quarter of '86
3rd quarter of '86
2nd quarter, of '86
3rd quarter of '86
4th quarter of '86
4th quarter of '86
4th quarter of '86
4th quarter of '86
4th quarter of '86
1st quarter of '87
1st quarter of '87
4th quarter of '86
1st quarter of '87
1st quarter of '87

1st quarter of '87
1st. quarter uf '87
1st quarter of '87
2nd quarter of '87
3rd quarter of '87
2nd quarter of '87
4th quarter of '87
4th quarter of '87
4th quarter of '87
ctlon (IA)
(SW>
the
cted
, even "NOTEi
Priorities
TREATMENT/REMOVAL LEAD FUNDING SOURCES
1st quarter of '86 DEP/RP
4th quarter of '86 EPA
4th quarter of 86 DEP
4th quarter of '86 EPA
2nd quarter of -86 DEP
4th quarter of '87 DEP/np
1st quarter of '87 DEP
1st quarter of '87 DEV/HP
1st quarter of '87 DEP/RP
1st quarter of '87 ngp
4th quarter of '86 DEP
3rd quarter of '87 DEP
3rd quarter of "87 DEP
1st quarter of '87 DEP/RP
2nd quarter of '87 DEP/np
3rd quarter of '87 EPA/RP
3rd quarter of '87 DEP/RP
3rd quarter of '87 EPA
3rd quarter of '87 DEP/RP
3rd quarter of '87 DEP
4th quarter of '87 EPA
4th quarter of '87 EPA
3rd quarter of '87 DEP
4th quarter of '87 DEP
1st quarter of '88 DEP
1st quarter of '88 DEP
Completed (IAI DEP
4th quarter of '87
4th quarter of '83I1A) EPA
4th quarter of '87
4th quarter of "87 DEP
1st quarter of '88 EPA
2nd quarter of '88 DEP
1st quarter of '88 DEP
2nd quarter of '88 DEP
3rd quarter of '88 DEP
4th quarter of 'SB DEP
4th quarter of '88 PEP
Interim Action
Slurry Wall
Dates Indicate project Initiation.
A "Completed" alte Indicate* work hue been
initiated or completed.
RP
SF
NS
SF
NS
np
SF
RP
RP
SF
SF
SF
SF
RP
RP
RP
(IS
SF
NS
SF
SF
SF
NS
SF
SF
SF
SF
SF
SF
SF
NS
SF
SF
SF
NS
NS
                                      STATE PROGRAMS
417
-------
                             Table 4
                Drum Damp Cleanup Work Schedule
Site Nmme
Storcr Dump*
Minsei Kogyo Shoji*
kk America
Frontage Road
Kearny Dumps (Nos. 1-5)
Tabernacle Site
Cooper Road
Green Acres Landfill
Staging*
Sampling
3rd qtr. of '83
4th qlr. of '83
4th qtr. of '83
4th qtr. of '83
1st qtr. of '84
1st qtr. of '84
1st qtr. of '84
Dram Removal &
Disposal
4th qtr. of '83
1st qtr. of '84
1st qtr. of '84
1st qtr. of '84
2nd qtr. of '84
2nd qtr. of '84
2nd qtr. of '84
•Cleanup expected to be conducted by responsible party.
NOTE: Dates indicate project initiation


                             Table S
          Sites Currently Not Scheduled for Cleanup Action
Albert Steel
American Cyanamid*
Blue Spruce
Borne Chemical
Cheesequake State Park
Chemical Insecticide
CPS/Madison Industries*
Duane Marine
T. Fiore Demolition t
Givaudan
Jackson Township Landfill* t

tSites included on the Hazardous Discharge Bond Act
•Sites included on the proposed National Priority List
                       JIS Landfill*!
                       Kit Enterprises
                       Mirex Dump
                                    Mobil Chemical
                       Monroe Township Landfill*
                       N.L. Industries*
                       Quanta Resources Corporation
                       Roosevelt Drive-Int
                       South Brunswick Landfill*
                       White Chemical Company
                             Table 6
  Sites to be Scheduled/Rescheduled Following USEPA Evaluation and
                Ranking for the National Priority List
 Chemical teaman
 Cooper Road*
 Delilah Road*
 DeRewal Chemical Company
 Diamond Alkali
 Ewan Property
 Florence Land Recontouring Inc.
 W.R. Grace and Company
 Hopkins Farm
 L & D Landfill
 Minsei Kogyo Shoji, kk America*

 •Currently in work schedules C or D
                       Nascolite Corporation
                       Radiation Technology
                       Shieldalloy Corporation
                       Tabernacle Drum Dump*
                       Upper Deerfield Two Sanitary Landfill
                       Ventron Velsicol
                       Vineland Chemical Company
                       Wilson Farm (Residual Cleanup)
                       Woodland Twp Route 72 Dump*
                       Woodland Twp Route 532 Dump*
                            Table 7
         Estimated Costs for Projects Scheduled for Cleanup


                1983         1984         19*5         1986

Feasibility Study    $ 6,224,000   $  7,700,000   $ 4,450,000    S 4,100,000

Design*          $ 2,850,000   $10,064,440   $ 2,655,000    $ 4,685,000

Treatment/
  Removal        $13,743,000   $67,276,000   $47,894,000    $60,050,000


Total Costs        $22,817,000   $85,040,440   $54,999,000    $68,835,000

     Total 1983-1986     $231.691,440.00

•Aclual deiign costs presented, if knovn. Estimated design costs equal 10^ of project treatment/
remcnal COM*
is based on potential danger to public health and the environment
and takes into account surface and groundwater pollution as well
as releases of hazardous chemicals into the atmosphere. Emerging
from this  list were 93 sites which,  when further  screened, were
reduced to 72 for submission to  USEPA based on information
available at the time. Of these, 17 sites received high priority ap-
proval in mid-1982. In Dec. 1982,  USEPA identified a total of 65
New Jersey sites which are eligible for Superfund monies. DEP will
continue to evaluate sites which are not now eligible for Superfund
assistance, and some of these sites have been included in the plan.
Currently, 21 sites are being evaluated by USEPA for Superfund
status (Table 6).
Cleanup Ponding
  The three major stages of a hazardous waste site cleanup pro-
cedure are: (1) a feasibility study  to determine the extent of the
problem and to recommend remedial alternatives; (2) an engineer-
ing design  of the selected remedial action to mitigate the problem;
and (3) the remedial  action or actual physical cleanup process, in-
cluding treatment and/or removal.  The  Federal Superfund pro-
gram provides 100% of feasibility study and engineering design
costs and up to 90%  of remedial costs for eligible hazardous waste
sites,  with the state providing the remainder of the monies from
either the New Jersey Spill Compensation Fund or the $100 million
Hazardous Discharge Fund approved by voters in November 1981.
Because of this funding mechanism, New Jersey will need the full
cooperation and assistance of the USEPA,  both in Region II in
New York City,  and from headquarters in Washington. In some
cases, DEP will have responsibility for cleanup programs while in
others,  USEPA will take the lead.
  To  date,  the  state  has entered into  contracts/cooperative
agreements with the USEPA for remedial  action at 15 sites. In ad-
dition,  11  signings for the initiation  of feasibility studies are an-
ticipated in the fall of 1983, and amendments to six of the 15 ex-
isting contracts/cooperative agreements for engineering design and
remedial actions  are expected in 1983.
  The actions proposed in the plan are currently estimated to cost
approximately $232 million (Table 7), although this amount could
increase substantially depending upon further findings and con-
tractor bids. Estimated costs do not include long-term maintenance
costs, such as groundwater pumping and treatment, which may be
required at some sites. In order to estimate project duration and
cost, the sites included in the plan  were considered on the basis of
the anticipated soil and groundwater contamination. The most dif-
ficult, and thus most costly, sites are those exhibiting extensive soil
and groundwater contamination  and  requiring complex and
lengthy procedures for cleanup.

SCHEDULING METHODOLOGY
  DEP has developed a methodology for scheduling cleanup ac-
tivities at both Superfund and non-Superfund sites. This system
provides a means of  tracking progress in cleanup operations.
  Sites  included on the proposed  National Priorities List (NPL)
(Superfund sites) were considered to represent the greatest potential
hazard to public health and/or the environment. The sites included
on  the NPL where remedial action had previously been projected
for initiation were scheduled first (e.g., Burnt Fly Bog, Bridgeport
Rental and Oil Services, etc.) (Table 3). All  other NPL sites were
scheduled in order of the Hazard Ranking System (HRS) score at a
rate of approximately one per month.
  Sites not included on the NPL, such as the Hazardous Discharge
Bond Act sites,  were introduced  into the  schedule concurrently
with those remedial actions proposed as an USEPA lead site and in
order of their HRS scores. This reflects the  additional manpower
available at DEP when USEPA has  the lead for a remedial action
and will provide for more timely cleanup of those sites not eligible
for Superfund monies. All 27 Bond Act sites were included on the
plan.
418
STATE PROGRAMS
-------
  me 11 sites categorized as drum dumps were scheduled separ-
ately (Table 4) because operations at these sites differ from those at
other sites in the plan. It is expected that these surface drum dump
cleanups can be cleaned up more rapidly than remedial action at
other more complex sites. According to Superfund regulations,
responsible parties are liable  for cleanup costs. Accordingly, most
sites currently not scheduled primarily because of their responsible
party enforcement status are shown in Table 5.


DISCUSSION

  The cleanup of hazardous waste sites is an extremely complex
undertaking. The scheduling of remedial actions is dependent upon
many variables such as enforcement status, identification of addi-
tional sites  having higher  priorities,  information  altering  the
relative  potential  public  and  environmental  hazards  of  sites
previously identified, as well as a Federal/State cooperative effort.
Thus, the schedule is  not static and will be  subject to continued
revision.
  Additions, deletions or other schedule changes will  be made
every six months in compliance with USEPA's "Guidance for Up-
dating the National Priorities List". Annual public hearings will be
held on these changes as well as in compliance with P.L. 1982,
c.202, N.J.S.A. 58:10-23.15 (Assembly Bill 285) enacted in  Dec.
1982. This law requires the DEP to prepare a Master List  of all the
known hazardous discharge sites in the State and a ranking of the
sites based  on  criteria recommended by the  Hazardous Waste
Advisory Council  pursuant to P.L. 1983, c.222, N.J.S.A. 58:10-
23.20, (Assembly Bill 1255) enacted on June 27,1983.
  The DEP will continue its program of identification and ranking
of hazardous waste sites in New Jersey. The Hazardous Site Master
List developed by the  Department now consists of over 900 sites
known or suspected to contain hazardous substances. Most of these
sites are still to be evaluated. Although the task is enormous, the
state is committed to a vigorous program of cleanup operations at
hazardous waste sites in order to protect public health and the en-
vironment.
                                                                                                 STATE PROGRAMS
                                                           419
-------
          THE DEVELOPMENT  OF THE MASSACHUSETTS
      CONTINGENCY  PLAN FOR  THE  STATE  SUPERFUND

                                                   YEE CHO
                    Massachusetts Department of Environmental Quality Engineering
                                        Division of Hazardous Waste
                                            Boston, Massachusetts
INTRODUCTION

  The passage of the Massachusetts "Superfund Bill" in March
1983 gives the Commonwealth extensive enforcement powers in
the management of uncontrolled hazardous waste sites and estab-
lishes a $25 million fund for the tasks ahead. The three most im-
portant objectives of the new law are:
•To encourage the prevention of releases of oil and hazardous
 materials (including hazardous waste)
•To ensure that individuals responsible for releases pay the full
 cost of cleanup
•To facilitate the cleanup of releases of oil and hazardous ma-
 terials when responsible parties fail to cleanup
  The fund is to be used by the Commonwealth when all enforce-
ment avenues have been exhausted for the cleanup of spills and
releases of oil and hazardous materials (including hazardous waste
sites) and for the Commonwealth's share of the  federal "Super-
fund" cost-match.
  Central to the implementation of the new law is a Massachu-
setts contingency plan  covering  both emergency response and
remedial actions. The plan will serve as a standard operating pro-
cedure for response to chemical releases and will include emergency
contacts, decision making and site assessment guidance; it will also
establish  a method  for the  priority ranking  of Massachusetts
sites for enforcement or cleanup action. A discussion draft of the
plan should be completed in the fall of 1983.

BACKGROUND

  A program for the  Commonwealth's  abandoned hazardous
waste sites emerged with the publication of a list of potential and
actual (confirmed) abandoned sites by the Department of Environ-
mental Quality Engineering in late 1980. This list was compiled
from information in the Eckhardt report,' the Department's files
especially in the water related programs and the Surface Impound-
ment Assessment2 study completed by the state government. Over
300 potential hazardous waste sites were evaluated in the process.
  Enforcement actions against responsible parties in conjunction
with the State Attorney General's Office were pursued  as part of
the assessment and investigation at the confirmed sites. Almost to
75% of the contamination at the confirmed sites has been resolved
or addressed  by the responsible parties. The state's enforcement
authorities, however, were limited.  In some instances, there were
no incentives for responsible parties to undertake remedial actions
at the contaminated sites themselves.
  Approximately 25%  of the contaminated sites have required
public funds for cleanup. The sources of the state funds for these
sites have been from site specific legislative appropriations and
from a $5 million budget  appropriation for  cleanup known as
                                                   the Capital Outlay Budget of 1979. The single most costly aban-
                                                   doned hazardous waste site cleanup undertaken by the Common-
                                                   wealth has been the Silresim site in Lowell, MA., a five acre chem-
                                                   ical reclamation facility abandoned in Jan. 1978. Approximately
                                                   one million gallons of hazardous material in drum and bulk stor-
                                                   age were left. The state also had funded approximately half a dozen
                                                   additional sites for remedial actions.
                                                     In  1982,  the need for stronger enforcement tools and funding
                                                   was obvious. The 1979 cleanup budget was inadequate and nearly
                                                   exhausted. Site activities under the Comprehensive Environmental
                                                   Response, Compensation and  Liability Act of 1980 were sched-
                                                   uled, but the state could obtain federal assistance only if the cost
                                                   was  shared. There were already 50 confirmed sites requiring re-
                                                   medial action; new sites were being discovered and added to this
                                                   list; 170 sites from the CERCLA notifiers* list were compiled. This
                                                   potential list of sites to be addressed is not yet complete.
                                                   THE MASSACHUSETTS SUPERFUND ACT
                                                     On  Mar. 24, 1983, Governor Michael S. Dukakis signed the
                                                   new "Massachusetts Oil and Hazardous Materials Release Preven-
                                                   tion and  Response  Act."  This Act  (Chapter 7 of the  Acts of
                                                   1983) greatly expanded the Department of Environmental Quality
                                                   Engineering's (DEQE's) authority to protect citizens and the en-
                                                   vironment from hazardous substances. The law encourages the pre-
                                                   vention of releases of oil and hazardous materials, ensures that
                                                   individuals responsible for releases pay the full cost of cleanup and
                                                   provides funds and authority for cleanup when those responsible
                                                   fail to take appropriate action or cannot be identified.
                                                     The statute generally constitutes a state counterpart of the 1980
                                                   federal "Comprehensive Environmental Response, Compensation,
                                                   and Liability Act" (CERCLA). The new Act aims to correct some
                                                   deficiencies in previous state legislation:
                                                   •Existing funding was inadequate to assure state match for all fed-
                                                    eral  Superfund  projects  in  Massachusetts and the Common-
                                                    wealth's ability to  respond to anticipated major hazardous ma-
                                                    terials emergencies in the near future.
                                                   •Existing enabling legislation did not give Massachusetts sufficient
                                                    authority to respond to all types of emergencies involving oil and
                                                    hazardous materials. Prior to the Act, DEQE could only respond
                                                    to releases and threats of release of oil  and hazardous materials
                                                    when an impact on water quality could be demonstrated.
                                                   General Enabling  Authority

                                                     The Act adds to the General Laws a new Chapter 21E which pro-
                                                   vides DEQE with wide-ranging authority to deal with emergency
                                                   situations:
420
STATE PROGRAMS
-------
•DEQE may  take a wide range of actions necessary  to content
 with releases and threats of release of  oil and hazardous  ma-
 terials.
•Immediate notification to DEQE is required when there is a re-
 lease or threat of release of oil or hazardous material.
•There are provisions to prevent, to the extent possible, the Com-
 monwealth from assuming the full costs and responsibilities for
 cleanup.
  Specifically, the new Act expands the categories of people  who
are potentially liable to  both the Commonwealth for  repayment
of DEQE response costs and to other people for damage to or loss
of real or personal property. Subject to narrowly-drawn defenses
and limitations, responsible people are strictly liable, jointly and
severally. Individuals responsible for a release or threat of release
for which the state incurs cleanup costs are strictly liable for up to
three times the state's costs. The law establishes a five-year statute
of limitations for actions brought to recover costs.  The law im-
poses a lien on property owned  by  anyone who may be liable for
cleanup costs. The Superfund lien  would take priority over all
previously recorded mortgages.
Implementation

   In implementing the new  Act, DEQE  faces a complex  set of
issues and many responsibilities. The Department must develop
and implement several sets of plans, regulations and procedures in
the near future. Implementation procedures must be flexible to
 allow DEQE  to respond to problems  raised by unique sites and
 situations and by ever-changing  technology. The major program
 elements include the Massachusetts contingency plan,  the release
 notification regulations,  civil and criminal penalties for violations
 of the new law of $25,000 per violation per day with the potential
 for five years imprisonment for  individuals and administrative ac-
 tions to remedy situations for the DEQE.
   The DEQE is to prepare  a Massachusetts contingency  plan
 covering both emergency response and remedial actions. The  plan
 will include  standard  operating  procedures  for responses  to re-
 leases (decision making and site assessment guidance) and a method
 for the ranking of Massachusetts  sites for  cleanup action.  The
 statute also gives DEQE authority to respond to releases before the
 contingency plan has been developed.
   The new law further gives DEQE authority to regulate activ-
 ities when necessary to prevent  releases of hazardous materials.
 The requirements are  intended to avert the likelihood of releases
 and to enable quick response should releases occur.
 Funding

   The new law establishes a $25 million  general obligation fund
 for state cleanup actions. It also specifies that funds  received as
 fines and penalties under  the Act, as well as funds recovered from
 cleanup actions, shall be applied to payment of debt service on
 short and long-term borrowing under the loan fund.
   The Commonwealth must apply recovered funds to the General
 Fund to offset debt service payments on bonds used to cover the
 $25 million appropriation. The difference  between costs recovered
 for state response actions and the annual  outlays for debt service
 will be collected by fees  imposed on hazardous waste transport-
 ers. Fee levels will be reviewed annually.                         '

 Special Commission
   A special legislative study commission is established to determine
 the adequacy of existing liability provisions, including liability for
 third-party personal injury. The commission, which is composed
 of members of legislature and gubernatorial appointees, is to sub-
 mit its findings and recommendations by Dec. 1983.

 DEVELOPMENT OF THE MASSACHUSETTS
 CONTINGENCY PLAN
   The DEQE under the Massachusetts Superfund Act is required
 to prepare a contingency plan to deal with remedial actions and
emergency response. This plan should comply with and comple-
ment the National  Contingency Plan (NCP) adopted  by  the
USEPA. The  plan,  however,  is not required to  follow  the  na-
tional plan.
  Prior to initiating  the process to develop the plan, the Depart-
ment should be organized on three major levels. First,  it must
examine and mobilize the resources and personnel needed to under-
take the project. Second,  the Department should  be able to pro-
vide the administrative leadership and support necessary for  the
plan to be expeditiously and successfully developed. And third,  the
Department needs  to decide the basis by which the plan will be
developed.

Resources and  Advisory Committee

  The first part of the process, identifying and organizing the re-
sources, is crucial. Without question, staff are required to  coor-
dinate and implement  the development  of the plan. The staff
should be identified and mobilized early on in the process.
  After mobilizing the resources, administrative commitment to
the completion of  the  tasks  is important for continuous pro-
gress throughout the plan development phase. A  six month time
schedule for completion of a  draft contingency plan  is possible
given the full  support and commitment  of resources, personnel
and leadership.
  A document which would be the cornerstone for response  ac-
tions under the State Superfund Act demands the expertise of a
multidisciplinary team consisting of site response and waste man-
agers, engineers,  scientists, health specialists and lawyers. This
team can be assembled into an advisory committee for the initial
phases of the  plan development process.  The membership in this
advisory committee should have basic knowledge  of the scope of
the National Contingency Plan as adopted by the USEPA,  the
nature of hazardous  materials response, the complexities of aban-
doned site response and the intricate interplay of public agencies in
both the same and different levels of government. The member-
ship should include representatives from the different sectors of the
community: academia, industry, environmental and public interest
groups, government and  citizens.
  To be immediately effective, the rules and roles of this  com-
mittee should  be well defined  prior to its assemblage. The rules
on  resolving issues  on  divergent viewpoints within the member-
ship need to be detailed. The  resolution  can  take the form of a
majority vote of the entire membership, majority vote of the mem-
bers present, consensus of the entire membership, etc.
  The role of an advisory committee should be exactly defined.
The committee can serve as a sounding board on  the contents of
the draft plan prior  to its release to the  public for general com-
ments and input. The committee can provide expertise on different
sections of the plan. It would  not be necessary, however, for  the
committee's opinion  to be binding.  The Department can retain the
decision making process throughout the plan development phases.
  An advisory committee is an option for the development of the
plan for Massachusetts. Its value,  however, should not be over-
looked. The Department  has  successfully employed an  advisory
committee in the development of other regulations.

Basis and Guidance
  The State Superfund Act is the counterpart to the federal Super-
fund legislation. Unequivocally, the National Contingency Plan,
especially as it addresses  abandoned  site response, provides  the
basis for the development of the Massachusetts Contingency Plan.
The operating procedures (i.e., contingency plan equivalents) of
other states with similar superfund programs and concerns should
provide valuable guidance to  the development of the Common-
wealth's plan.
  The contents of the National Contingency Plan offer a starting
point for discussions for the Commonwealth's plan. The Depart-
ment will have to decide what  features of the NCP to include  and
exclude in the  Massachusetts Contingency Plan (MCP). The basic
                                                                                               STATE PROGRAMS
                                                          421
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subject categories will most likely be similar to the NCP, but the
levels and types of details within each subject category will prob-
ably vary.  These subject  categories include  site discovery,  site
assessment, remedial action and site orioritization.
  In developing the plan, the Department will endeavor to review
published comments on the NCP. It will be important for the De-
partment to be aware of the concerns different groups have raised
about the NCP. This review would furnish a perspective and basis
for the Department to make its decisions on adopting any parts of
the NCP for its own plan.
  The approaches that other states have taken in their state Super-
fund programs have been useful in the development of the MCP.
A review of California's experience with  their two year old pro-
gram has been valuable. Their approach t6 site prioritization is in-
triguing. They employed a slightly revised version of the USEPA's
Hazard Ranking System (HRS) to prioritize their sites for remed-
ial  action. Their revisions reflect similar concerns that DEQE has
about the federal ranking model. Prioritizing sites for spending the
state Superfund monies in  an  integral part of the Massachusetts
Contingency Plan.
Major Issue
  Before the contingency plan becomes final, there will be num-
erous issues that must be resolved. The one major issue that will
consistently come up throughout the development process centers
around what subject matters and what levels of detail  the MCP
should consist of. The issue is if certain issues should be addressed
only  generally in the MCP and specifically  in the Department
policy guidance,  which would  be separate from, but consistent
with, the MCP.
  There will probably not  be  much disagreement with  the basic
subject categories listed above. The discussions will focus on the
level of details and guidance to be incorporated within the subject
categories. A paucity of details  would permit the Department more
flexibility in the implementation of the state Superfund  response.
It would not confine  the Department in responding  to  problems
that are fairly dynamic. It, however, may not define the Depart-
ment's response action sufficiently for the public to be assured that
the response level and action are sufficient.
  A  more defined  and detailed operating procedures document
could limit the Department's response action. It could mean a rigid
response process that would be difficult to  implement without
hindering progress  on the  remedial actions.  The technologies in
abandoned hazardous waste site response are  new and constantly
changing. Discoveries and improvements are frequent in  this field.
Detailed procedures could ignore this significant parameter.
Other Issues

  The numerous issues involved in the development of the plan
cannot be fully addressed in this paper. There will be issues that can
examine the practicality of a five year spending plan, the process
by  which CERCLA sites are handled  relative to the state Super-
fund priorities and the inter-relationship of the CERCLA program
with the state program. Issues relative to the entire abandoned site
response process will be raised; there will  be discussions on aban-
doned site discovery  attempts,  site assessment procedures  and
policies and remedial action alternatives. Fund-balancing criteria,
the "how clean  is clean?"  question and  operation and mainten-
ance  after the remedial  action will not be ignored. Deliberations
over health and safety requirements for personnel, community rela-
tions, cost recovery and site prioritization can also be included.
Site Prioritization

  A process to rank and prioritize the abandoned hazardous waste
sites in the state can lead the discussion. This process would deter-
mine the priorities by which the Department would spend the state
                                                      Superfund monies for investigation and cleanup. The discussions
                                                      would focus first on whether a mathematical ranking system based
                                                      upon the physical conditions at each site is appropriate and ac-
                                                      ceptable. The advantages of a mathematical model rest on its in-
                                                      herent attempt to be objective. A mathematical model would pro-
                                                      vide the fairest means to prioritize a large number of sites. The
                                                      prioritization  system  would be  sheltered  from the influence of
                                                      politics.
                                                        An alternative to a mathematical model can be a system based
                                                      on "best engineering judgments". This system would, of course, be
                                                      more subjective.
                                                        If the decision is made to employ a mathematical model, the next
                                                      problem would be which mathematical model to adopt. There is al-
                                                      ways the Hazard Ranking System (HRS)  adopted by CERCLA.
                                                      Using  that system would avoid lengthy discussions and justifica-
                                                      tion arguments for the existence of two priority lists—USEPA's
                                                      list and the Department's list. Another advantage of using the HRS
                                                      is that the ranking can be  readily used  for nomination as a
                                                      CERCLA site.
                                                        The disadvantage of using the HRS would initially rest on its in-
                                                      adequacy to address the unique conditions and problems in the
                                                      Commonwealth. The HRS was established for gross ranking of all
                                                      sites nationwide and not for relative ranking of a small number of
                                                      sites (relative to the number of sites nationwide).
                                                        If the  HRS is not adopted, then one of the Department's op-
                                                      tions would be to develop a  new model to consider the  unique-
                                                      ness of Massachusetts. Another option would be to take USEPA's
                                                      model and revise it slightly to more closely meet the Department's
                                                      needs and interests. Nevertheless, selecting the ranking system for
                                                      the prioritization of Massachusetts  hazardous waste sites will be a
                                                      challenge and will be an important decision.

                                                      CONCLUSIONS

                                                        The potential  impact of the Commonwealth's Superfund legis-
                                                      lation has not yet been realized.  It  will undoubtedly be extensive,
                                                      markedly aftering the Commonwealth's approach to the manage-
                                                      ment of abandoned hazardous waste sites. It will be an added com-
                                                      plexity to the lives of many people—people engaged in real or per-
                                                      sonal property transactions: bankers, brokers,  lawyers, insurance
                                                      firms. It will invite industries and those involved in handling haz-
                                                      ardous materials to learn the science and economies of release and
                                                      spill prevention.
                                                        Strong enforcement tools with a triple damage clause are  a major
                                                      part of this legislation. The $25 million fund for remedial action is
                                                      available  to support the  enforcement strategies.  The  Massachu-
                                                      setts Contingency Plan will be the  blueprint for abandoned site
                                                      response clearly establishing, for the first time, the rules, pro-
                                                      cedures and guidance for responding to abandoned sites in the
                                                      Commonwealth. It will provide standardized and structured pro-
                                                      cesses  for the abandoned site program and the beginning of a
                                                      strong abandoned site management program  for the Common-
                                                      wealth.
                                                        Twenty-five million dollars is not a large sum of money for this
                                                      activity, but it is a beginning. The Massachusetts Contingency Plan
                                                      will be the cornerstone in the implementation of the state Super-
                                                      fund program. A state Superfund  legislation guided by an oper-
                                                      ating standards document, such as a contingency plan, and com-
                                                      plemented by  the federal Superfund program is the key  founda-
                                                      tion for  a comprehensive, progressive  and successful abandoned
                                                      hazardous waste site program.

                                                      REFERENCES

                                                      1. "Eckhardt Report", U.S. Congressional Committee on Interstate and
                                                        Foreign Commerce, Oct. 1979.
                                                      2. "Surface Waste  Impoundments in Massachusetts",  Massachusetts
                                                        Department of Environmental Quality Engineering, Nov. 1983.
 422
STATE PROGRAMS
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           STATE OF TEXAS  SUPERFUND PROGRAM AND
                         REVIEW OF TWO SPECIFIC  SITES

                                           JAMES W. TREMBLAY
                                    Lockwood, Andrews & Newman, Inc.
                                                 Houston, Texas
                                                J. CHRIS LIPPE
                                    Texas Department of Water Resources
                                                  Austin, Texas
INTRODUCTION
  The State of Texas is managing its Superfund efforts through
an aggressive program including awarding contracts to Lockwood,
Andrews & Newman, Inc., for remedial action at two sites in
Houston. These two sites, French Limited and Sikes Disposal Pits,
are located within a half mile of each other approximately 20 miles
northeast of downtown Houston near the town of Crosby.
  In this paper, the authors describe the Texas Superfund pro-
gram along with the recent  activities  at these two sites. Develop-
ment of work plan protocols, results  of field activities and con-
clusions are covered.
TEXAS SUPERFUND PROGRAM

  The State of Texas has had an aggressive solid waste program
since enactment of the  Texas Solid Waste Disposal Act in 1969.
In fact,  the waste shipping  manifest and reporting system devel-
oped under the Texas program became the model upon which the
current national system is based. However, until passage of the
Comprehensive Environmental  Response,  Compensation, and
Liability Act (CERCLA) and state legislation establishing the Texas
Disposal  Facility  Response Fund in April of 1981, the state did
not have a means of cleaning up abandoned hazardous waste
sites.
  In February of 1982, the Governor of Texas designated the
Texas Department of Water Resources (TDWR)  as the agency
with authority to develop and  manage the Superfund program.
Because of the strong solid waste program already in existence
and the early passage  of legislation  providing for 10%  match-
ing state funds, Texas has become one of the leading states in the
Superfund program.

Priority List Sites

  The TDWR identified 20 candidate sites to the USEPA in April
1981. Twelve of the original 20 sites had sufficient existing data
to rank  under  the National Hazard  Ranking  System  (HRS) for
submission to USEPA. Of those 12, 8 sites scored high enough to
be included on the National Priority  List and thus were eligible
for remedial action funding under Superfund. Six  of these sites,
including the Sikes Disposal Pits and French Limited Sites, are
in the Houston area.
Staffing
  The total Superfund staff at TDWR consists of nine people
including the  Superfund  unit manager, four  project  officers,  a
candidate site  investigations project  officer, an  accountant,  a
public affairs officer  and a technical  assistant. The four  staff
members designated as project officers are responsible for two
sites each. It appears that the current ratio of two sites per project
officer is a reasonable level, at least for the site investigation and
feasibility study phases of projects.

Federal Funding
  More  than $2,500,000 has been awarded TDWR under cooper-
ative agreements with USEPA for remedial investigations and feas-
ibility studies. The Sikes Disposal Pits  Site Investigation has a
grant budget of $500,000 and the French Limited Site Investiga-
tion and Feasibility Study has a total grant budget of $467,000.

Remedial Action Consultant Selection

  The Sikes Disposal Pits Site Investigation and the French Lim-
ited Site Investigation and Feasibility Study were advertised in the
Texas Register on July 27, 1982, requesting proposals for these
projects from qualified consultants. Following a site visit for inter-
ested consultants in mid-August, proposals were  submitted on
Aug. 31 and Sept. 10 for French Limited and Sikes, respectively.
Nineteen proposals were received for French Limited and 23 for the
Sikes project.
  A panel of four TDWR staff independently reviewed and scored
the proposals using a prepared scoring  form. This form elabor-
ated on the general evaluation criteria of:  (1) company qualifica-
tions, (2) personnel qualifications, (3) technical approach and (4)
management plan. Following the proposal scoring and ranking, the
top three ranking firms (or proposal teams) were invited to make
presentations.
  The outcome of this procedure was that the firm of Lockwood,
Andrews & Newnam, Inc. (LAN) and their subconsultants, En-
vironmental Science  and  Engineering, Inc.  (ESE)  and Harding
Lawson Associates (HLA) were selected  to enter  into contract
negotiations .with TDWR in late November. Contracts  for both
Sikes  and French Limited were signed on Jan.  17, 1983, and
formal notice to proceed was granted to LAN. HLA was respon-
sible for all geotechnical aspects of the site studies; ESE accom-
plished all environmental sampling and analyses. LAN was respon-
sible for overall project management and the feasibility study.
  The time requirement for subsequent Superfund project con-
sultant procurement (from request for proposals to contract sign-
ing) has been reduced to approximately three months as compared
to the six months required for the initial projects. The longer time
requirements  on  earlier projects, such as Sikes and French, are
attributed to  program development.  During this  early procure-
                                                                                         STATE PROGRAMS
                                                      423
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merit period, methods  and procedures had to be developed, the
request  for  proposals, scoring forms  and contracts  were  orig-
inated and numerous legal decisions had to be made.

SITE BACKGROUND
  The French Limited and Sikes Disposal Pits are located in close
proximity to one another near Crosby, Texas  (Figure 1). French
is approximately 22 acres in size and Sikes is approximately 25
acres. The French site has a single 8-acre unlined pit, while Sikes
has one  unlined  main waste pit  and several  small unlined pits
(Figure 2). Both sites are located within the floodplain of the San
Jacinto River. On at least three occasions in the last 15 years, the
sites have been inundated by flood waters from the San Jacinto
River. The Sikes site is ranked 30th and French  25th on the Na-
tional Priority list.
  Both  sites operated  during the  1960s. Petrochemical industry
wastes  deposited at the French site are  believed to  have been
brought to the site in bulk form. During the six-year period end-
ing in  1972, approximately  600,000 barrels of industrial wastes
were received at French. The disposal operation at French was
granted a permit in 1970 with  special  conditions relative to on-
site controls of the wastes. Less than one year later, the state can-
celled the permit at French for failure to comply  with special per-
mit conditions.
  The Sikes site reportedly operated for approximately six years,
ending disposal operations in 1967 when Mr. Sikes died. Bulk and
drummed petrochemical industry wastes were  disposed  at Sikes.
The Sikes operation was never permitted.
  Major concerns for  offsite contamination were for: (1) ground-
water contamination and (2) potential transportation of sludges
and contaminated surface water offsite. The Riverdale subdivision
(approximately  50 to 60 homes) is located less than one-quarter
mile southwest of the disposal pit at French. Some of these homes
depend on the shallow wells for a water supply.
     MtLES    10
          HOUSTON
          INTERCONTINENTAL
          AIRPORT
                                           LAKE HOUSTON
                                                 FRENCH
                                                   SAN JACNTO
                                                   RIVER
                           Figure 1
                    General Location of Sites

  In the 1979 flooding of the sites, the pits overflowed. Sludges
were  deposited  in areas adjacent to the pit on  French,  while
sludges from the main pit on Sikes were transported across a large
(10 to 15 acres) low-lying area east of the main pit and off the
Sikes property. (Figure 2). Lack of maintenance had allowed con-
tainment levees to deteriorate and be breached by the flooding.

SAMPLING

  Both state and federal sampling were conducted at various times
between  1971  and 1981. Sampling at  French was more extensive
                                                                                  Figure 2
                                                                            French and Sikes Sites

                                                       and revealed that the sludges, soils, surface and groundwaters
                                                       were contaminated with  heavy metals  and chlorinated organics,
                                                       including polychlorinated biphenyls (PCBs), benzene, chloroform,
                                                       carbon tetrachloride, trichloroethylene  and vinyl chloride. Samp-
                                                       ling of shallow groundwaters  in  the vicinity of French  in 1981
                                                       showed that a variety of organic compounds were present. The
                                                       limited preliminary sampling at Sikes  in mid-1981 indicated the
                                                       presence  in the waste pits of phenolic compounds, xylene, ben-
                                                       zene, toluene and other organics.
                                                       SITE GEOLOGY/HYDROGEOLOGY
                                                         The shallow aquifer beneath the sites resides in a broad sandy
                                                       aquifer believed to be relatively permeable. Some residences in the
                                                       vicinity of the sites depend  on this shallow aquifer for drinking
                                                       water. In the 1970s, numerous complaints of tastes and odors in
                                                       the drinking water were reported. In  1979 the Harris  County
                                                       Pollution Board reported marked improvement in the overall qual-
                                                       ity of the shallow groundwaters in the site vicinity.

                                                       OBJECTIVES
                                                         The scope of the studies at  the French and Sikes sites  was de-
                                                       fined as follows:
                                                       •French: Conduct a remedial investigation and a feasibility study
                                                       •Sikes: Conduct a remedial investigation only
                                                         The remedial investigation at each site was to characterize the
                                                       site in terms of wastes present, magnitude and extent of contam-
                                                       ination, rate and direction  of  any waste migration, target recep-
                                                       tors, site geology and hydrogeology.
                                                         The  feasibility  study  at French was designed to develop and
                                                       evaluate alternative remedial measures  considering economic fac-
                                                       tors, environmental impacts, regulatory constraints and timeliness
                                                       of completion.

                                                       FIELD PROGRAM PROTOCOL

                                                         The overall objectives  of the field studies at both sites were to
                                                       characterize the sites with respect to  contamination and waste
                                                       migration potential. A separate protocol for each site was devel-
                                                       oped. These protocols were subsequently refined in separate work
                                                       plans  for each site. The  rationale used in selecting sampling sites
                                                       at each site is described below.

                                                       Soil Borings/Groundwater and Surface  Water Sediment Sampling
                                                         The planned soil borings, installation of wells and groundwater/
                                                       surface water and sediment sampling were developed to character-
                                                       ize the site waters and subsurface soils from both a physical and
                                                       chemical viewpoint. Both shallow and deep wells were planned,
                                                       chemical analyses  were  outlined and physical testing of  the sub-
424
STATE PROGRAMS
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surface soils was outlined. The general locations of groundwater
samples is shown in Figure 3.
  Surface water samples were requested to define the levels of
surface water contamination on and around the sites. These sur-
face water  sites were divided into three categories: ponds/pits,
drainageways and the main river channel. Sediment samples were
planned to characterize the on-site and off-site sediment deposits.
The location of surface water and sediment samples is shown in
Figure 4.
Air, Soil, Biota, Core and Waste Sampling

  The environmental  sampling protocols developed for each  site
included air, soil, biota, core and waste sampling. The location
of these samples is shown in Figure 5.
  At the beginning of the field work at each  site, a field recon-
naissance was developed. As indicated, ambient air sampling was
to be accomplished.
                                           CROSBY
                                               8
                          Figure 3
       French and Sikes Soil Borings and Groundwater Samples
                                   FRENCH
                       /•^ SIKES  .  J,
                       fe;p    £*M
                          Figure 4
          French and Sikes Surface and Sediment Samples
                                                                                           Figure 5
                                                                         French and Sikes Soil, Biological and Core Sampling
  Soils sampling was planned only for French. Previous flooding
had left waste sludge residue on the site outside the waste pit and
possibly beyond the site boundaries. In mid-1982,  USEPA re-
moved some of these sludges and placed them back into the waste
pit. The objective of the soils sampling was to determine the levels
and quantities of soil contamination off-site.
  Biological  samples  were planned  for each site.  The samples
collected at French were for three off-site composite fish specimens
to determine if metals and PCBs could be  found in indigenous
fish. The Sikes biological samples consisted  of nine benthos
samples from the nearby bayou/river network. The object of the
Sikes samples was to determine if nearby aquatic ecosystems were
being stressed by contaminants from the site.
  During the 1979 flooding, sludge wastes were transported out-
side  the Sikes main waste pit dikes and across a low-lying area,
approximately 10 to 15 acres, east of the site. The objective of the
15 core samples was to obtain initial physical and chemical char-
acterization of these sludges. Estimates of sludge volume would be
made.
  Ten waste samples were planned for Sikes to cover representative
samples of waste materials found outside the waste pits such as
containerized wastes, other small waste pits, etc.
Hydrogeology

  The  planned  hydrogeological studies at both sites included soil
borings, development of monitoring wells, groundwater level meas-
urements, field permeability tests  and physical  soil analyses. In
addition, geophysical tests were planned for Sikes.
  Groundwater level measurements were  planned at each site us-
ing existing and newly drilled wells. Weekly readings were planned
to collect data on changes in groundwater gradient so that ground-
water flow direction could be determined.  Slug tests were pro-
grammed to determine the permeability of the aquifer.
  Geophysical tests proposed  for the Sikes  site included ground
penetrating radar,  electrical resistivity and electrical borehole log-
ging. Use of geophysical techniques at  French was not planned
because the site inspection indicated that the subsurface contam-
inants were probably so dispersed that they could not be detected
using geophysical techniques. Additionally, there was no evidence
of wastes being buried at French.
  Ground penetrating  radar was planned for use at Sikes to de-
tect the presence of buried drums and to determine the thickness
and  continuity  of  sand and clay layers underlying the site.  Elec-
trical resistivity profiling and sounding was planned to evaluate the
                                                                                                STATE PROGRAMS
                                                          425
-------
extent of a contaminant plume and to correlate stratigraphy. Elec-
trical borehole logging was planned for both sites to obtain a de-
tailed view of the stratigraphy.
PROJECT DELAYS

  The Sikes family, consisting of the widow of the former site
operator,  her two sons and two  grandsons, was residing in the
central area of the site, virtually surrounded  by  waste disposal
areas. The family's relocation was based on a need to protect their
health and safety as well as to reduce the possibility of interfer-
ence by the family with the investigation crews.
  TDWR had earlier established an excellent rapport with the
family. Nevertheless, the family was reluctant to relocate for the
duration of the survey.  The eldest son would agree to move and
then reverse his  decision later. Many  of his concerns seemed to
stem from a fear of his family losing its property. Their owner-
ship had  been established  several years  earlier under squatters'
rights.
  TDWR was finally able to get the family to agree to move into
two new mobile homes furnished by the Federal Emergency Man-
agement Agency (FEMA). The agreement assured the family that
they could remain on their property as the mobile homes would be
located in an uncontaminated corner of the  site. This  created
further problems since the entire site is within the 100 year flood-
plain of the San Jacinto River and there is a county ordinance
against issuing building permits within the floodplain.
  Negotiations between LAN and county officials culminated in
the special hearing and the granting of  the special permit. The
family relocation then went without incident. The family was sat-
isfied, their safety was  assured and investigation crews were un-
encumbered by their presence.
  Initial field work at French was delayed by four weeks. Initial
field activities (soil borings) at Sikes were begun on May 9, a delay
of approximately ten weeks from the original schedule. Environ-
mental sampling  at Sikes was to begin on May 23. However,
between May 21 and May 25 the San Jacinto River flooded and
both the Sikes and French sites were inundated.

FLOOD RESPONSE

  The flooding of the sites in late May resulted in a one-week de-
lay of Sikes field work.  This  incident did afford a unique oppor-
tunity to make first  hand observations of effects and flow patterns
of flood waters.
  The San Jacinto  River flooded as a result of extremely heavy
rainfall at a time when  Lake Houston's  water elevation was very
high. The River reportedly left its banks  from May 21-25. Flood
water elevations  near the sites peaked  on May 24. Most areas on
Sikes were under 6  to 8 ft  of water. French was under 4 to 6 ft
of water. Flood waters receded by the afternoon of May 25.
  LAN made aerial  observations of the flooding on May 23. Flood
waters covered both sites. All waste pits on Sikes and the French
pit  were  inundated. Surface  reconnaissance of both  sites  was
accomplished by LAN and ESE in boats on May 23 and 24.
  This unexpected event presented an  opportunity to observe the
flood flow patterns and better understand the possible spread of
contamination caused by earlier flooding of the sites. Some float-
ing sludge from the  French pit was transported out of the pit dur-
ing the flood.  This  was cleaned up as an emergency response by
USEPA during the first week of June.

REMEDIAL INVESTIGATION RESULTS

  Because of the delays encountered,  the results of the field in-
vestigations at Sikes are not yet available. The results of the French
remedial investigation are presented below.
Groundwater

  The French Limited site is  located in the middle of a filled ox-
bow lake/channel of the San Jacinto River (Figure 6). As uncon-
                                                      fined aquifer (sand layer) underlies the site. Prevailing water levels
                                                      in the main pit at the French Limited site were about 10.6 ft above
                                                      main sea level during April 1983 (Figure 7). These readings are at
                                                      approximately the same elevation as the shallow groundwater table
                                                      in the immediate area of the main pit.
                                                        The shallow aquifer is anticipated to have a slight overall grad-
                                                      ient (approximately 0.001) toward  the San Jacinto River. Over
                                                      short distances,  this gradient could be somewhat higher because
                                                      of various land features. Shallow groundwater flow away from the
                                                      main pit is estimated to be approximately 20 ft per year, prob-
                                                      ably in a radial direction with the shallow contaminant plume elon-
                                                      gated to the south-southwest and the north-northwest.
                                                                                 Figure 6
                                                                           Oxbow Lake Location
                                                                                 Figure?
                                                                      French Site Groundwater Elevations

                                                         The shallow groundwater immediately south of the  site con-
                                                      tained benzene (180 /tg/1), toluene (67 /tg/1), methylene chloride
                                                      (74 /tg/1), carbon tetrachloride (44 /tg/1),  1,1-dichloroethane (130
                                                      /ig/1),  1,2-dichloroethane (440  /tg/1), trans-1,  2-dichloroethane
                                                      (180 /tg/1), tetrachloroethene (910 /tg/1), phenol (32 /tg/1), naph-
                                                      thalene (150 /tg/1)  and  a variety of other organic compounds
                                                      (primarily volatile in nature). Many of these levels are substantial-
                                                      ly above  the recommended 10~s incremental cancer risk criteria
                                                      established for human health protection.
                                                         The other shallow wells at greater distances south of the French
                                                      Limited site were analyzed for indicator parameters (TOC, TOX,
                                                      pH and conductivity) of contamination. Traces of contamination
                                                      may be due to landfills south  of Gulf Pump Road.  Samples from
 426
STATE PROGRAMS
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two residential wells in the Riverdale Subdivision were free of con-
tamination.
  A  deep water-bearing zone was found in a sand  formation
approximately 125 ft beneath the site. An aquitard of lower perme-
ability  clays  and sandy  clays  separates the  upper and  lower
aquifers. The deep aquifer exhibited a pH of 9.2, and water in the
aquitard has a pH of 7.6 to 7.8. In contrast, the shallow aquifer
exhibited pH in the range of  5.4 to 7.1. The deep  aquifer had a
TOCof4.8Mg/I.
Sludges/Sediments
  All floating oily residues at the French Limited site were removed
by USEPA emergency response efforts during 1982 and 1983.
  A deposit  of sludges on the floor of the main pit  was identified
using sub-bottom profiling  geophysical techniques.  The depth of
this sludge deposit is 0.8 to  3 ft (Figure 8). The entire pit contains
about 210,000 ft3 of sludge and contaminated sediments contain-
ing a variety of organic compounds including naphthalene (0.24%
by weight dry), phenanthrene (0.18%), polychlorinated biphenyls
(507 ppm), phenols (22.9 ppm) and several other base/neutral frac-
tion class compounds. Sludges in the main pit contained total ex-
tractable organics (TOE) ranging from 0.78 to 9.26%.
  Between the main pit and U.S. Highway 90 the sludges had TOEs
as high as 9.14% by weight on a wet  basis. Soils from the same
area  had TOE values between 3.7  and 31.3%. The chemistry of
these sludges is similar to those in the main pit.
  The highly soluble, solvent chemicals (benzene, toluene, methy-
lene chloride and others) contained in the sludges and sediments of
the main pit  have the highest potential  for migration into and con-
tamination of the groundwater and surface water environment.

Surface Waters

  Surface waters in the main pit had concentrations  of volatile
organic  compounds  (benzene,  vinyl  chloride, chloroform  and
others) between 2 and 4 /tg/1. One  pesticide,  Lindane,  was found
in the main pit at a concentration of 0.003 /ig/1. The depth of the
main pit averaged 10.6 ft during a  survey in April  1983 and con-
tained an estimated 24,500,000 gal of water.
  Surface waters outside the main pit contained Lindane at 0.045
/tg/1 in the lake south of Gulf Pump  Road and at 0.005 /*g/l in
the slough north of the pit. The slough also had a TOC of  35.7
                                             LEGEND:

                                             SLUDGE DEPTH
                                             f 3 FT DEPTH

                                             fg IS FT DEPTH

                                             ^ 1,0 FT DEPTH

                                             F] 25 FT. DEPTH
                          Figure 8
                      Sub-Bottom Profile
  The surface waters overlying the heavily contaminated sludges
in the main pit were found to contain trade (/ig/1) levels of vola-
tile organic chemicals. Many of the non- volatile  organic  com-
pounds found in the sludges and sediments were either not found
or were detected at  low levels in the overlying waters. Thus, only
low transport rates  from the sludges into the overlying waters are
occurring.

Surface Soils

  A soil  sample off-site south of Gulf  Pump Road had a TOE
value of 1,230 ppm  and total organic halogen (TOX) of 140 ppm.
Another soil sample off-site north of U.S. Highway 90 contained
lower levels of these  indicators (TOE-421 ppm and  TOX-17.2
ppm).
  This contamination is believed to be the result  of  past  flood
events at the  French Limited  site. The landfills and dumps along
Gulf Pump Road may also have made a contribution. The areal
extent of this contamination  beyond the sampling areas is  not
known.

Fish Tissues

  Three fish  tissue  samples from the "fishing hole" beneath the
U.S. Highway 90 bridge north of the site contained PCBs  rang-
ing from  18 to 194 ppb. These levels are well below the FDA 5,000
ppb PCB limit.

CONCLUSIONS

  The State  of Texas Superfund  Program, as administered by
TDWR,  is aggressively pursuing solutions to the State's aban-
doned hazardous waste sites. Although unexpected problems have
developed during the administration of some of the projects, such
as the relocation problem  with the Sikes family and the flooding
at both the French and Sikes sites, TDWR and the consultants have
worked together to minimize their impact on  schedules  and
budgets.
  Detailed protocols for site work were developed in separate site
work plans. Such detail proved to be very useful as only minor
adjustments of the work plan were required. Separate work plans
for each  site  were based  on extensive review of all existing data
and consisted  of detailed  rationale  for all field efforts and assess-
ment of the site hydrology/hydrogeology.
  This preplanning is essential to the successful completion  of a
Remedial Investigation study. The thorough review of all avail-
able background data prior to developing a work plan  can reduce
field sampling changes and ensure that  the final results will sup-
port the follow-on Feasibility Study.
  Based on this specific data on French and the general physical
observations  made  at Sikes to date, follow-on remedial actions
are warranted. Feasibility studies at both sites should be carried to
completion.
                                                                                               STATE PROGRAMS
                                                         427
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                    THE STATES  AND EPA: AN  EVOLVING
                      PARTNERSHIP  UNDER  SUPERFUND

                                                   JAN WINE
                                       Hazardous Site Control Division
                                   U.S. Environmental Protection Agency
                                               Washington, D.C.
                                              HEATHER BURNS
                                        Booz, Allen & Hamilton, Inc.
                                               Washington, D.C.
INTRODUCTION

  The Superfund program, administered by the USEPA, has the
ambitious mission of responding to releases of hazardous materials
and pollutants in order to safeguard the public health, welfare and
the environment. A fund of $1.6 billion was authorized under
the Comprehensive  Environmental, Response Compensation and
Liability Act of 1980 (CERCLA) to finance this activity.
  In passing CERCLA, Congress recognized that success was
possible only if many parties shared responsibilities. Most critical
was a joint role for the Federal government and the states. The
purpose of this paper is to  examine how USEPA and the  states
have shared responsibilities since the program's inception and how
recent Superfund policies and directions signal a more extensive
and flexible role in the future.
  In this paper, the authors  address only one aspect of the Super-
fund program: remedial response. This includes both planning for
and actual implementation of the final remedial action. Relation-
ships between USEPA and the states in conducting other responses
under Superfund, namely immediate or planned  removals,  differ
somewhat and are not discussed here.

THE PARTNERSHIP TO DATE:
SHARED RESPONSIBILITIES

  Participation of the states in the Superfund program is not only
encouraged by USEPA, but also required by CERCLA. Specific-
ally, states have  the following three  responsibilities as part  of
Superfund remedial  actions:
•They must assure  for adequate operation and maintenance of
 remedial measures at the site after a prescribed time
•They must assure the long term availability of a facility for the
 disposal of wastes
•They must contribute a share of costs in certain circumstances
  At a minimum, state participation under the program is limited
to providing these three assurances, and in such cases, USEPA re-
tains primary responsibility for managing site cleanup. The option
for significantly greater  involvement is open to  states, however,
including assumption of full management responsibility for the
remedial action. Many states have assumed these expanded duties.
  The factors a state must consider in deciding the role to be taken
and a description of the specific implications of that decision are
discussed below.

The Decision of Lead Responsibility

  The decision of lead management responsibility is  a complex
one. In weighing the possibility of a lead role, a state must consider
the adequacy of its legal authority and resources and its ability to
mobilize those resources in the prescribed time frame.
                                                   Legal Authority
                                                     States must provide explicit documentation from the Governor
                                                   or Attorney General that they have full legal authority to admin-
                                                   ister and manage CERCLA funded response actions. They must
                                                   be able to undertake responses, receive funds from USEPA and
                                                   obligate monies to other governmental agencies or private con-
                                                   tractors. They also must have the authority to enter into contracts.
                                                     If legal authority is clearly insufficient  or impossible to  obtain
                                                   expeditiously, states may opt to have USEPA manage the remed-
                                                   ial  response.  The importance of expeditious action should be
                                                   stressed, since it can take on special significance in certain circum-
                                                   stances. In Colorado, for example, the legislature  must approve
                                                   each Superfund remedial activity before the state can assume lead-
                                                   ership. Since the legislature's schedule does  not always coincide
                                                   with the needs for remedial site cleanup, the initiation of cleanup
                                                   at a site can be delayed.

                                                   Resources
                                                     States must also consider the availability of staff and monetary
                                                   resources as they determine their preferred management position.
                                                   It must be clear that state technical and  management personnel,
                                                   as well as the systems to support them, are sufficient  to meet the
                                                   exacting demands of the site cleanup.
                                                     Hazardous  waste response  is a massive undertaking involving
                                                   million dollar budgets, technical oversight of cleanup activities and
                                                   strict reporting of accomplishments  and progress. Engineering
                                                   costs for cleanup alone can range from hundreds of thousands to
                                                   millions of dollars. (Containment of hazardous materials at one site
                                                   in California has been under way for five years and planned costs
                                                   already exceed $12 million). Even beyond these costs are those
                                                   associated with the management of the cleanup effort. These typic-
                                                   ally average 10 to 12% of actual site cleanup and pose a consider-
                                                   able extra demand for state management personnel.
                                                     States  typically find that their internal resources are insuffic-
                                                   ient to manage and conduct the response.  Many prefer to augment
                                                   state staff with outside contractor support to ensure an adequate
                                                   level of resources. Contractors  are used in this  way not only for
                                                   remedial design and construction, but also for overall management
                                                   of the response as well.

                                                   Time

                                                     Closely related  to the issue  of resources is another important
                                                   consideration of the states in determining their management role:
                                                   their ability to respond in the necessary time frame. Many states,
                                                   relying on their current staff and their established procedures to
                                                   acquire contractual support, can respond quickly even to time crit-
 428
STATE PROGRAMS
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ical "emergency" releases. It is not always possible, however, for
the state to quickly plan, organize and procure necessary contrac-
tual support. For example, the option of relying on contractors to
augment state staff may be viable only if states can obtain such sup-
port within the time frame  dictated  by the hazardous waste re-
lease. Thus,  lack of existing  state  personnel, compounded by
lengthy procurement procedures, may preclude a state from assum-
ing prime management authority.

Implications of the Leadership Decision

  The decision of Federal or state  lead for  a remedial action has
far-reaching consequences. It directly affects the specific manage-
ment duties and  responsibilities assumed by each party, the legal
instrument that is signed to formalize the  relationship and the
manner in which funds are provided.

Management Responsibilities

  By assuming the lead role for a remedial action, the state assumes
primary management responsibility for all phases of the cleanup
from planning through construction. The specific responsibilities
of different states vary under the terms and  conditions established
with USEPA, but the state will generally accomplish the following
activities:
•Plan the entire  remedial action, which  includes  developing  a
  schedule and setting the level of effort, milestones and specific
  remedial actions to be  undertaken. The workplan is a funda-
  mental component of the cooperative agreement between the state
  and USEPA.
•Obtain necessary staff support for both overall management and
  engineering response at the  site. As mentioned earlier, such sup-
  port may be drawn from existing state rosters or may be obtained
  through private contractors. If contractors  are utilized, the state
  must initiate the procurement process, issue a request for pro-
  posal, screen all candidates and select final contractors.
•Monitor progress at the site and report on progress.  Because  of
  the magnitude of expenditures and the complexity of the technical
  response, rigorous management is essential. Quarterly reports on
  progress must be submitted to USEPA. Included must be: item-
  ized expenditures by task and activity, totals of labor and costs
  incurred since the last report, estimated completion of work com-
  pleted for each  activity and estimated variances in cost and time
  expected at project completion.
•Select individuals to prepare  and implement a community  rela-
  tions plan. To effectively accomplish site cleanup, the public must
  be involved in the decision-making process. To this end, a com-
  munity relations assessment is undertaken to evaluate the history
  of community involvement  and the concerns or issues associated
  with problems at the site. A community relations plan is devel-
  oped to initiate formal and  consistent  contact with interested in-
  dividuals and citizens'  groups. The communications techniques
  used for one site are not necessarily applicable for all sites, but
  each plan should establish  a repository for technical  informa-
  tion and a mechanism for advising citizens living near the site of
  work to  be conducted  by either the state or USEPA. A three-
  week public comment period is required once the feasibility study
  is complete and before a final response action is chosen.
•Prepare safety and quality assurance project plans. The state must
  also assume responsibility for developing  a plan to  ensure the
  safety of both personnel working at the site and residents nearby.
  The objectives of the plan must be clearly stated and specific pre-
  cautions must be detailed, i.e., mandatory training of site work-
  ers. The plan governs the actions of state as well as contractor
  personnel. In addition to the safety plan, the state must  also
  assure the quality of environmental samples taken. A plan must
  be written to specify procedures for sampling, documenting chain
  of custody and labelling sample materials.
  In cases where USEPA assumes the lead for a remedial action,
Agency staff take on responsibility for the activities noted above.
With the exception of quarterly reporting, all functions are basical-
ly the same.

The Legal Instrument Binding the Two Parties

  The decision of a state as opposed to a Federal lead for remed-
ial actions at a site also determines the sort of legal instrument that
will be utilized to formalize each party's responsibilities. Two sep-
arate types of instruments are used:  the cooperative agreement,
which is employed if the state assumes the  lead, and the Super-
fund state contract (SSC) which is signed when USEPA retains
management responsibility. The SSC, it should be noted, is not a
traditional procurement contract,  but rather a binding agreement
that authorizes the USEPA to proceed with remedial response ac-
tivities within state borders.
  Contracts and cooperative agreements have basic similarities:
they are both legally binding instruments that assign responsibil-
ities to the state and USEPA, they both allow the  transfer of funds
and they both are instruments for  obtaining required assurances.
Each provides  for the different management roles discussed earlier
in this paper.
  Despite these similarities, however, the detail and scope of these
vehicles differ. While both contain work plans assigning specific
responsibilities, the cooperative agreement plan  is more specific
and identifies particular tasks,  dates for completion and level of
effort. It ensures the allowability of all costs incurred so the states
may receive full compensation for tasks they undertake.  Such de-
tails are excluded from an SSC, since the costs of management are
incurred by the federal government.

Funding Mechanisms
  Regardless of the assignment of lead responsibility, the USEPA
provides funds equivalent to the total cost of cleanup exclusive of
the state's cost share. Methods of transfer and overall responsibil-
ity  for  financial management differ, however, depending  on
whether the state or EPA leads the action.
  Most significant is the difference in the flow  of  funds. If  the
states take the lead, the USEPA prefers to transfer funds to  the
state via an already established letter of credit. Conversely, if EPA
takes the lead  for cleanup, the flow of funds is reversed, as  the
state pays its share  of costs of EPA via the Superfund state agree-
ment.
  Upon transfer of dollars, the state assumes responsibility  for
establishing and  operating the  cleanup budget,  pays contractors
directly from  this  budget, and reimburses  its own agency and
offices for expenses incurred. Under this arrangement the state has
direct control over its outlays setting its pace in  accordance with
the state budget  cycle. If USEPA leads the action,  separate pay-
ments of cost share are required according to a payment schedule
agreed to by USEPA and the state. Specific terms of such schedules
vary from case to case.


THE FUTURE PARTNERSHIP: MORE FLEXIBLE
STATE PARTICIPATION

  So far,  states  and USEPA have shared responsibilities for re-
medial site response and management over the course of the Super-
fund program. In many cases, states have assumed major respon-
sibility for managing the overall cleanup effort; in other situa-
tions, state involvement has been  more limited and has included
such activities as providing mandatory cost shares, secondary con-
tractor oversight and participating in community relations activ-
ities.
  USEPA has long recognized that state participation is critical to
program success and that a maximum level of involvement should
be encouraged. Policies have been revised to ease  administrative
requirements and to lessen the financial burden  on  state budgets.
These trends,  together with the program's ongoing decentraliza-
tion,  suggest  a  more flexible relationship  with USEPA  in  the
future.
                                                                                                STATE PROGRAMS
                                                         429
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Program Decentralization

  For the first two years of the program, states dealt extensive-
ly with  USEPA Headquarters and the regions, but ultimate de-
cision-making authority resided in Washington. Thus, officials in
the states  worked  closely with  USEPA regional personnel, who
monitored and guided  site cleanups and reviewed draft coopera-
tive agreements and SSCs. States also worked with Headquarters
personnel, receiving policy direction and guidance on procedures.
In addition, final  approval of  cooperative agreements  and con-
tracts was given at the Headquarters level.
  As the program  has  developed, more and more responsibilities
have been delegated to the regions. This shift is expected to re-
duce the number of USEPA personnel with  whom states inter-
act, sharpen lines of authority and bring the administration of the
program physically closer to the states and to the conduct of site
activities. The hope is that decision-making will be expedited and
that, as a result, USEPA as well as state-led remedial actions will
be more timely and responsive.
Relaxed State Cost Share Requirements

  Recent Agency policy has emphasized the need for planning at a
greater  number of  sites to fully  assess the requirements for subse-
quent remedial action. To lessen  state expenses  of an expanded
planning function, USEPA has set policy to reduce state require-
ments for sharing these costs. Thus, states are no longer required
to pay part of the  costs of planning and investigation at privately
owned sites.
  Further, at publicly owned sites they need not pay for planning
until (and only if) USEPA and the states decide that a Superfund
financed remedial action is appropriate. Such action might be pre-
cluded, for example, if a responsible party came forward to finance
the cleanup. In that case, of if for some other reason subsequent
Superfund activity  were not undertaken, the states would incur no
planning costs. The intent of this policy is to encourage state partic-
ipation in remedial  planning.
                                                       Provisions for Multi-Site Planning Cooperative Agreements
                                                         Yet another direction taken by USEPA to encourage state par-
                                                       ticipation with minimum strain on state resources is the proposed
                                                       development of multi-site planning cooperative agreements. These
                                                       agreements would cover state administrative planning activities at
                                                       more than one site and  fund program activities that support the
                                                       state's assumption of the full program. Activities might include the
                                                       preparation of Superfund state contracts and review of Remedial
                                                       Action Master Plans. This policy recognizes that states should re-
                                                       ceive compensation for the expense of planning for  and undertak-
                                                       ing the management of the Superfund program.
                                                       More Flexible Superfund Contracts
                                                         Administrative requirements of Superfund contracts have also
                                                       been relaxed under recent policy since the state is  no longer re-
                                                       quired to cost share during remedial planning. Thus, lengthy pro-
                                                       cedures to develop SSCs for such  planning activities have been
                                                       eliminated.  To expedite site  cleanup, the  state and USEPA now
                                                       simply agree that a remedial investigation and feasibility study are
                                                       needed. The state also identifies a project officer and an individual
                                                       who will participate in community relations activities. USEPA es-
                                                       timates that as  much as three months may be saved by this ex-
                                                       pedited procedure. A  full SSC  is still required once a remedial
                                                       action is initiated to provide state assurances and a mechanism for
                                                       cost share.
                                                       CONCLUSIONS

                                                         The changes in policy noted above suggest a significant evolving
                                                       program direction: greater state involvement with less administra-
                                                       tive and financial burden. The Agency's intent is to further en-
                                                       courage states to expand the roles they have already assumed under
                                                       Superfund and to work closely with USEPA to accomplish effec-
                                                       tive hazardous waste cleanup.
430
STATE PROGRAMS
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                 MINIMIZING LIABILITY EXPOSURE  WHEN
            CONTRACTING  HAZARDOUS WASTE  SERVICES

                                                JOHN C. ROBBINS
                                              EMPAK Services Group
                                              Pennsauken, New  Jersey
INTRODUCTION

  Involvement with hazardous waste subjects generators and their
commercial hazardous waste service contractors to liability from
a number of sources, including:
•Property damage
•Impairment of environmental rights and amenities
•Bodily injury
•Intangibles such as impairment of corporate image
  These sources of liability have frequently involved the use of in-
competent contractors by generators of hazardous wastes.  In this
paper, the author deals specifically with how hazardous waste gen-
erators can minimize their liability of exposure when using out-
side service organizations during hazardous waste remedial action
activities.
  "Remedial action", as used in this paper,  refers  to activities
such as waste removal, transport, detoxification, etc., which are
not normally performed on a routine basis. These activities  can be
scheduled, such as a lagoon closure, Superfund site cleanup or
building decontamination, or unscheduled, such as a spill cleanup.
"Generators" refer to those who either produced, used, owned or
otherwise could be traced to the waste in question.'

BACKGROUND
  The trend  in environmental  enforcement  is  toward  criminal
prosecution of individuals. The imposition of criminal liability is
usually derived from various federal and state statutes. However,
there are recent cases where general criminal statutes such as con-
spiracy or fraud have been used to prosecute corporate officials.
Insulating oneself  from  liability by hiding behind the nameless
corporation is no longer possible,  as illustrated by the USEPA's
RCRA and Consolidated Permit  regulations  which  require the
signature of responsible individuals on permit applications, waste
manifests, etc.
  Civil liability in  the hazardous  waste  field seems  to be in an
uncertain, but definitely expanding, state of flux. Civil liability has
traditionally been used in environmental damage cases as a  means
for the federal and state governments to proceed against the gener-
ator with the most financial resources.
  Personal lawsuits from third parties have traditionally been re-
lated to nuisance and negligence. But now there are a number of

1. At hazardous waste conferences, there invariably is an argument over whether liability passes
along with title to wastes. A broad definition of "generator" is used because-(l) this is an evolving
area of law and (2) there have been some extreme examples under so-called  "joint-and-several
liability", such as generators of non-hazardous wastes, which were commingled with  hazardous
waste, having been brought into a suit.
other theories of laws being developed which increase the individ-
ual's exposure to liability.2 These include liability imposed by:
•Increased risk or future harm
•Mental distress
•Intentional infliction of mental distress
  Moreover, generators of hazardous waste have more than just a
moral obligation to protect the environment;  individual corpor-
ate officials can be held liable for environmental damage as part
of a presently unclear, but evolving, case law.
  The purpose of this paper is to point out to generators of waste
that it is in their own personal interest, as well as their company's
interest, to pay careful attention to the selection of, and contrac-
tual arrangements with, hazardous waste service  organizations.

CONTRACTOR QUALIFICATIONS
  There are organizations available for generators  to contract
services ranging from such seemingly trivial tasks as transporting
metal sludges to such obviously dangerous tasks as detonating gas
cylinders containing highly toxic materials. The  one thing all these
services have in common is that they involve risk of environmental
damage. As such, they subject the contracting party to liability.
The following  represent minimal  contractor qualifications  which
should be considered by generators:

Financial Resources
  A  key element in minimizing risk when contracting hazardous
waste services is assurance that the contractor has sufficient finan-
cial resources to undertake correction of any environmental dam-
age resulting from action involving the generator's waste.
  If  the contractor could be potentially deficient  in financial re-
sources, then the generator should be sure to include contractual
requirements such as insurance, performance bonds, etc.

Performance Record

  The hazardous waste service contractor should have a proven
record in performing hazardous waste cleanup and disposal.
  While this may seem obvious, it is an area which is often taken
for granted. For example, many  of the  major service companies
claim to be able to handle just about any problem that a gener-
ator  might have while, in fact, a  subcontractor is used for many
services. While there is nothing wrong with using  subcontractors,

2. For an excellent synopsis of recent trends in civil liability for environmental damages, the
reader is referred to Individual Civil and Criminal Liability for Environmental Damages, 1982, by
the Hartford Steam Boiler Inspection and Insurance Co., Hartford, CT.
                                                                                              LEGAL LIABILITY
                                                        431
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risk exposure could increase if they do not have adequate per-
formance  records. At the very least, contractors  should indicate
what subcontractors may be used and provide assurance that they
are qualified and reputable (e.g., not on USEPA's listing of barred
companies).
Medical Surveillance Program
  The contractor should have a medical surveillance program for
personnel involved in the direct handling and/or exposure to toxic
materials. The goal of the program is to demonstrate and correct
any job related injury or condition. While some would  argue that
such a program can be a "smoking gun",  it only seems right that
everything possible be done to protect the health and safety of em-
ployees. Medical surveillance programs typically should involve
most of the following:
•Medical history
•Annual general physical to assess person's capability of working
 in respiratory protection equipment
•Blood  and urine laboratory tests to assess status  of kidney, liver
 and nervous system
•Other laboratory tests for known contaminants to which the per-
 son has been exposed (serum lead, PCB, pesticide screen)
  The more comprehensive programs established by some contrac-
tors include EKGs, chest x-rays, frozen specimen storage and other
special procedures.
Attitude Toward Fixed-Priced Contracts
  Most people have heard of at least one instance of  gross cost
overruns on hazardous waste cleanup projects performed on a time
and materials basis. Obviously, there are many situations such as
emergency responses and excavations of unknown materials where
it is not possible to obtain a fixed-price  contract. Nevertheless, the
contractor should at least be willing to try to establish a  fixed price
for as much of the project  as possible. If a contractor is unwill-
ing to do  this, one should ask himself whether he  and/or his con-
tractor  know enough about the problem to  proceed  cost  effec-
tively and safely.
Disposal of Wastes
  The contractor should specify exactly where he intends to dis-
pose of any wastes, should that be part of his responsibility. If one
has any doubts, set up an escrow account to provide an incentive
to dispose at the agreed upon facility. Ideally,  wastes  should be
sent to a facility with an approved  Part B,  RCRA application,
not to a facility with just a RCRA "interim status" permit, un-
less the facility has been audited to one's own satisfaction.
  The contractor should be willing to become the generator and
not just the handler, transporter or disposer, of any wastes to be
removed. While this does not necessarily reduce one's liability, it
tends to increase the contractor's liability, providing an indirect in-
centive to perform properly.
  There may also be some reduction in risk  exposure if wastes can
be sent directly to a facility where wastes become essentially "non-
traceable". Such facilities generally include incinerators,  injec-
tion wells and liquid treatment facilities. The  "traceability"  of
wastes can become more important if one  contracts to someone
who will broker his wastes to a third party. In this instance, one
should insist upon a certificate of disposal showing the ultimate
fate of wastes.
CONTRACT REQUIREMENTS

  When attempting  to contract  for less environmental  risk ex-
posure, the following can be considered:
Insurance

  Most general Liability insurance coverage excludes environmental
damage.  Hence, it is important to require a hazardous  waste
                                                       service contractor to carry more than just comprehensive general
                                                       liability insurance. Furthermore, the process of acquiring environ-
                                                       mental risk insurance with a recognized carrier can itself reduce en-
                                                       vironmental risk exposure. This is a result of the insurance carrier's
                                                       own evaluation of the insured's potential liability.
                                                         The amount of insurance coverage required would vary with the
                                                       amount of risk involved in a specific project. Insurance coverage
                                                       is generally available in the following amounts, which  are also
                                                       recommended as minimum coverage for any contractor with his
                                                       own disposal facility:

                                                       Comprehensive General        $5 to 10 million per  occurrence
                                                         Liability
                                                       Sudden Release Environment     $5 to 10 million per  occurrence
                                                         Impairment Liability
                                                       Non-sudden  Release            $5 to 10 million per  occurrence
                                                         Environment
                                                         Impairment Liability
                                                       Surety Bonds

                                                         The furnishing of surety bonds by the hazardous  waste services
                                                       contractor is a further  guarantee of the faithful performance of
                                                       the contract and the payment of bills for labor and materials. For
                                                       the bonds to have meaning, they must be obligated by a reputable
                                                       financial institution.
                                                         There  are  normally up to three types of  bonds  used: (1) bid
                                                       bonds, (2) performance bonds and, (3) payment bonds. The bid
                                                       bond is usually required only on government  competitive-bid con-
                                                       tracts to assure that bids have been submitted in good faith. The
                                                       performance bond guarantees  that the  contractor will carry out a
                                                       contract  in accordance  with its terms.  The requirement of a per-
                                                       formance bond is  commonly  used  in service and construction
                                                       contracts.  The payment bond simply insures that the  contractor
                                                       will pay  his bills  incurred under a contract,  rendering the owner
                                                       harmless from claims filed after completion of work.
                                                         Surety bonds only minimize financial risk exposure and then
                                                       only in the amount of the bond.  Any  contract inadequacies, en-
                                                       vironmental risks, etc.,  are not covered. Nevertheless,  the use of
                                                       surety bonds offers some direct financial protection as well as in-
                                                       direct protection  by eliminating unqualified contractors from the
                                                       hazardous waste service industry.
                                                       Confidentiality Requirements
                                                         It is often appropriate to protect  information on products,
                                                       processes, customers, etc. In many firms, secrecy  agreements are
                                                       a  routine requirement for contractors; the added dimension of
                                                       public sensitivity to toxic wastes  can make confidentiality even
                                                       more important when dealing with hazardous waste service con-
                                                       tractors.
                                                       SUMMARY
                                                         Liability exposure from hazardous waste service projects can be
                                                       significant.  Because of a possible trend toward individuals being
                                                       held liable for environmental damage, it is important for gener-
                                                       ators to take steps to ensure that their hazardous waste service
                                                       contractors are well qualified.
                                                         The generator should insist on minimal contractor requirements
                                                       for financial resources, performance  record and medical surveil-
                                                       lance program. In addition, generators should insist on fixed-price
                                                       contracts whenever possible. Of paramount importance is obtain-
                                                       ing assurances that disposal of any wastes be clearly agreed upon,
                                                       and that such disposal  represents the  alternative  with  the least
                                                       possible risk exposure which is economically feasible.
                                                         Contractual means of minimizing liability exposure include re-
                                                       quirements  for general and environmental liability insurance, per-
                                                       formance bonds and secrecy agreements.
 432
LEGAl LIABILITY
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                      LEGAL MECHANISMS FOR DEFINING
           APPROPRIATE  EXTENT  OF  REMEDIAL  ACTION

                                         RANDY M. MOTT, ESQUIRE
                                             Breed,  Abbot & Morgan
                                                 Washington. D.C.
INTRODUCTION

  Most private parties identified by federal and state agencies as
"responsible parties" in connection with hazardous waste site in-
vestigations will actively seek settlement of the case. The reasons
for preferring settlement to litigation are obvious as is  the pub-
lic's interest in supplementing CERCLA and state funds with size-
able private funding. A key issue in settling cases and in defining
the amount of financial resources necessary for remedial activities,
is the appropriate extent of cleanup.
  The principal problem in negotiating a conclusion to a hazardous
waste case is how to resolve the uncertainty over the nature and
extent of remedial action needed at the site. It is useful to view this
as a problem of assigning the uncertainty over the scope of relief
necessary; where remedial  activity cannot be defined  with pre-
cision, how can a settlement resolve the obligations of the  defen-
dants?
  This uncertainty is invariably aggravated by the problem of deter-
mining the appropriate extent of remedy, even when the facts are
known. The question, "how clean is clean?" exists, not because of
a lack of data, but rather due to the political difficulties of defin-
ing acceptable or tolerable levels of risk. Completion of the most
extensive site monitoring and feasibility studies will not reduce the
intrinsic necessity of balancing cost and risk. Even where such de-
tailed information is available on a hazardous waste site, the parties
must still face the politically delicate job of defining the appro-
priate degree of remedial activity and, hence, the scope of the de-
fendant's obligation.
  This inherent political problem has now been amplified into a
crisis that threatens to severely constrict the ability of private fund-
ing for remedial activities. Reeling from political wounds, USEPA
is rapidly becoming incapable of the kind of sensitive and careful
weighing of risks  and costs that is crucial to  effectively reach a
consensus on remedial actions.  This immediate,  and  hopefully
temporary, state of affairs has an overwhelming influence on the
types of mechanisms used to settle remedial uncertainties and on
the levels of contamination deemed tolerable as a result of "clean-
up" operations.
  This paper is based on a review of several dozen hazardous waste
settlement agreements, consent decrees and court judgments. The
mechanisms used in these settlements to achieve what lawyers call
"respose" will be classified and critically reviewed.

OVERVIEW
  The focus of this paper is on the means used in the agreements
to define the  scope of a company's obligations where it is obli-
gated to do more than pay a fixed cash amount. The viability of the
settlement process in any case depends upon finding a mutually
agreeable  method of "turning off" the financial  commitment
placed on the company. The open-ended provision requiring a de-
fendant to do everything that is "necessary" remains highly  sus-
pect. In the  current political climate, this type of provision has
been resurrected since it shifts the total burden of uncertainty over
the scope of remedial action onto the company.
  A variety of other provisions have been used in addition to the
blind vow to do all that is "necessary." These provisions range
from the most simple cash "buy-out" to an environmentally-based
performance standard. Creative and  flexible methods  of dealing
with the uncertainty implicit in defining  the extent of remedial ac-
tivities are critical to the successful resolution of most cases.
  Where the parties can reasonably identify the risks intended to
be addressed by the remedy, it seems imperative that more care-
fully worded provisions be used to define the activities agreed upon
to reduce those  risks. Settlements which contain some numerical
objective that adequately reflects cost-risk balancing are obviously
preferable to commitments to do whatever is "necessary" or "ap-
proved by USEPA." Because actual risk from a hazardous waste
site depends  so heavily upon site conditions  unique to each situa-
tion, these performance standards need to be viewed on an ad hoc
basis to avoid  regulatory overkill. Pollutant fate and transport
mechanisms present at a particular site and the number and type of
"receptors"  are the principal determinants of relative risk. These
factors defy generalization since they depend  on site location, geol-
ogy, climate and hydrological conditions.
  Where site-specific numerical objectives or environmental  per-
formance  standards based on  specific risk  assessment cannot be
agreed upon, the parties may be compelled to settle on the basis of
remedial plans to be developed by the company and submitted to
USEPA and the court. A crucial consideration, in that  event,  is
what happens  if the  parties  disagree. Provisions that make
USEPA's position binding unless it is "arbitrary and capricious"
pose very serious problems for settling defendants.
  If  an agreement is not actually  a "settlement," but ends up
only specifying  the procedures to resolve  a dispute,  provisions
surrendering the defendant company's normal evidentiary and sub-
stantive rights should be avoided wherever possible.

THE CASH "BUY-OUT"

  By far the  most preferable settlement  from the defendant's  view
is the cash "buy-out,"  shorthand for a complete release of gov-
ernment claims in exchange for payment  of a specified  cash
                                                                                            LEGAL LIABILITY
                                                       433
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amount. The controversial "buy-out" announced in the Seymour
Recycling  case involved 24 generators paying $7.7  million in ex-
change for a full release  from surface or groundwater cleanup
claims. Other generators not privy to the settlement remained sub-
ject to claims by the government, a key factor in the willingness of
the government to accept  the arrangement. This situation simply
shifts the uncertainty over final cleanup costs onto the nonsettling
defendants.  If all defendants were privy to the agreement, such a
buy-out would place the burden of this uncertainty on the govern-
ment which has generally espoused,  since Seymour,  that  it  will
not accept the burden of uncertainty. See also United States v.
Wade, 3 CHEM. & RAD. WASTE  LIT. REP.  566 (E.D. Pa.,
1981), (where the settling defendants received a release in exchange
for a fixed monetary contribution).
  Cash buy-outs, where a nonsettling  party is not available, typic-
ally lack the finality obtained by the settling defendants in  Wade.
In United States  v. Duracell, the defendants created a $500,000
cleanup fund for removal activities subject to the Government's
right:
  "to bring a subsequent action for injunctive or similar relief con-
  cerning the site including, but not limited to, an action seeking
  additional funds for work contemplated by or of the type con-
templated by this Degree and seeking rehabilitation  of  Beech
  Creek." 1 HAZ.  WASTE LIT. REP.  1817,  1822 (M.D. Tenn.
  1982).
In summary, cash buy-outs have depended not only on the abil-
ity to provide reasonable dollar estimates of remedial action cost,
but also upon the presence of nonsettling defendants who will be
relied upon by the government to provide  any  additional con-
tingency funding.
OBLIGATION TO CONDUCT ACTIVITIES
  Perhaps the most common form of settlement in owner-oper-
ator cases—especially  where wastes are present on the defendant's
premises—is  an agreement to undertake  a list of activities.  For
instance, the Inmont  agreement provided that the completion of
the described activities is  "acceptable to  USEPA as constituting
cleanup of the site...." 1 HAZ. WASTE LIT. REP. 1824(1982).
   Similarly, the consent judgment announced in United States v.
 Velsicol Chemical Corp.,  Civil  No. 82-10303 (E.D. Mich., Con-
sent Judgment, Nov.  18,  1982),  involved detailed plans and pro-
cedures for disposal of Velsicol's wastes  at three Michigan sites.
The Velsicol settlement involves a minimum of uncertainty to the
parties by the use of detailed remedial plans and limited dispute
resolution clauses. In United States  v. American Ecological Re-
cycle Research Corp., Civil No. 80-A-811 (D. Colo., Consent De-
cree, Aug. 15, 1981),  the defendants agreed to segregate drums on
site by waste type, to repackage leaking drums and to provide ade-
quate fire protection, site  security and a closure plan. Any chem-
icals creating an "imminent hazard"  are to be removed from the
site to another approved by EPA. While the American Ecological
list of activities seems finite, the consent decree contains a blanket
removal obligation left to USEPA's unguided discretion.
  The "Bluff Road" consent decree in  United  States v. South
Carolina Recycling and Disposal, Inc. Civil No.  80-1274-6 (D.
S.C., March 23,  1982), contains another example of an activity-
based obligation. One defendant agreed to the "cleanup of a por-
tion of the  surface of the Bluff Road site" and others contrib-
uted  funding—all in  exchange  for a release of surface cleanup
claims.  The release specifically  excluded claims for "contamina-
tion of groundwater  (including drinking water supplies), surface
suit  contamination  which is threatening to contaminate ground-
water and off-site surface water contamination...."  Nonsettling
waste generators were  subsequently sued by the United States.
  The consent  decree in United States v. Energy Systems Com-
pany, Civil No. 81-1-006 (W.D. Ark., 1981), involves a complete
release once all of the  defendant's obligations  have been completed
to the United States'  satisfaction. The obligations undertaken in-
volve cleanup of a drum storage site and upgrading  of lagoons on
                                                      site and bulk waste storage under predefined programs, implemen-
                                                      tation of a fire control plan, removal of tetraethyl lead residues
                                                      and several  other programs.  1  HAZ. WASTE LIT. REP. 481-
                                                      486 (1981). Each activity was defined in an accompanying appen-
                                                      dix.
                                                        The state-initiated consent judgment in Kelley v. Cast Forge Inc.,
                                                      File No. 77-3724-CE (Mich.  Or. Ct., Livingston County,  Con-
                                                      sent Judgment, June 19, 1981), is another variation of this type of
                                                      agreement. Cast Forge agreed to implement a cleanup plan in-
                                                      volving removal of PCB-contaminated material including specified
                                                      soils and sediments. Once completed, the activities are stipulated
                                                      to be sufficient to  bring the company into compliance. See also,
                                                      Kelley v. Hooker Chemicals & Plastic Corp., File No. 79-22878-
                                                      CE (Mich. Cir. Ct., Ingham County,  Consent Judgment, October
                                                      30, 1979), (obligations defined by on-site activities at the Montague
                                                      Michigan site).
                                                        In West Virginia v. Allied Corp., Civil No. 81-C-554N (W. Va.
                                                      Cir. Ct., Marshall  County, Consent  Decree, Oct. 22, 1981), the
                                                      defendant agreed  to  "initiate  corrective measures  to prevent
                                                      further migration of contaminants in the groundwater." 1 HAZ.
                                                      WASTE LIT.  REP. 1967,  1968 (1982). The program described in
                                                      the decree envisions long-term pumping of the groundwater suffic-
                                                      ient to change the normal water table contours.  Compliance with
                                                      the terms of the decree is measured  by the absence of an "off-
                                                      site gradient." This obligation to counterpump is to last for 20
                                                      years and may be augmented by such "corrective measures as are
                                                      necessary to prevent further migration. ..."Id.
                                                        Many of these types of  settlements do not involve definitive
                                                      terms concerning the defendant's obligation; however, provisions
                                                      limiting  the stipulated relief to specified activities have obvious ad-
                                                      vantages to defendants. The use of designated activities as a settle-
                                                      ment device should be seriously explored by the parties, particularly
                                                      in combination with environmental performance standards.

                                                      ENVIRONMENTAL PERFORMANCE STANDARDS
                                                        The stipulation of environmental performance  standards pro-
                                                      vides an even more objective obligation. Numerical objectives that
                                                      define actionable levels of a pollutant under the remedial program
                                                      help eliminate future disputes.
                                                        The drawback to numerical standards is the assumption by many
                                                      that USEPA's water quality criteria  goals should be  utilized for
                                                      this purpose. If the criteria number is  used at  all, it should only be
                                                      at the point of the  "receptor."1 There is a  tendency for agency
                                                      staff to use these  numbers as  a priori groundwater goals. See
                                                      United States  v. Chemcentral/Detroil Corp., 6  CHEM & RAD.
                                                      WASTE LIT.  REP. 298 (E.D. Mich. 1983) (Appendix D and E).
                                                      The applicability of criteria concentration levels cannot be assumed
                                                      by the parties without site specific risk  assessment.
                                                        If environmental fate and transport mechanisms are taken into
                                                      account in developing a cogent, site-specific risk assessment, then
                                                      numerical objectives may present a workable  method of determin-
                                                      ing the  appropriate extent of remedy. If  the critical "receptors"
                                                      can be defined, the application of an objective standard provides
                                                      some protection to both parties. Contrast In the Matter of the
                                                      Receiver of the Water and Wastewater  Technical School, Inc.,
                                                      No. 82-H-033 (USEPA Administrative  Order, Aug.  16, 1982),
                                                      (monitoring site "until such  time as the hazard is eliminated")
                                                      and United States v. American Ecological Recycle, Civil No. 80-A-
                                                      811 (D. Colo., Consent Decree, Aug.  15, 1981), removal of all
                                                      wastes that "are creating or may create an imminent and substan-
                                                      tial endangerment to health and the environment").
                                                        The  good example of  the use of  environmental performance
                                                      standards appears  in  United States v. Spectron, Inc., Civil No.
                                                      HM-80-1552 (D. Md., Settlement Decree,  Mar.  25,  1982).  In
                                                      format, Spectron involves  the obligation to undertake specified
                                                      activities, such as site security and abatement of ongoing poten-
                                                      tial discharges as well as groundwater corrective action. A detailed
                                                      groundwater monitoring program is defined (Para. IV.C.), in con-
                                                      trast to the  generalized obligation to conduct a hydrology study
 434
LEGAL LIABILITY
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contained in many settlements. Ongoing surface water monitoring
is limited to four years after the termination of the groundwater
program. Para. IV.D. The most ambitious obligation is the pump-
ing and "decontamination" of the groundwater. Spectron calls for
a system that "will prevent migration of substantially all the con-
taminated groundwater to  the  creek...." Para.  IV.E.2.b.,  de-
fined by  sampling  for fifteen specific  organic  chemicals at spe-
cified detection limits. A maximum  obligation  of six years from
commencement of the decontamination system is set out, with peri-
odic ability to terminate groundwater  pumping and  treatment
keyed to the concentrations in the Creek.
  The Spectron agreement provides  a useful conceptual method
for identifying the environmental concerns and meeting them by
specific  commitments.  The use  of  performance-based  goals
throughout the agreement should allow for more predictable obli-
gations assumed by the defendant and more definitive protection
of the public. See also United States v.  Solvent Recovery Service
of New England, Inc.,  5  CHEM.  & RAD.  WASTE LIT.  REP.
899 (D. Conn. 1983).

REQUISITE REMEDIAL TECHNOLOGY

   The leading example  of "requisite remedial technology's"  use
in a settlement agreement is United States v. Hooker Chemical &
Plastics Corp., Civil No. 79-989  (W.D.  N.Y., Stipulation and
Judgment Approving Settlement Agreement, Jan. 19,  1981) (Hyde
Park) 1 CHEM. & RADIATION WASTE LIT. REP. 691 (1981).
   The key provisions in the Hyde Park agreement which encom-
pass "requisite remedial technology" are fairly short:
   (a) "The containment, monitoring and maintenance programs
     described in this Judgment have been designed, and have as
     a goal,  to protect against endangerment to  human health
     and the environment in the Hyde Park-Bloody  Run Area
     Utilizing Requisite Remedial Technology to achieve the pur-
     poses set forth in this Judgment.
   (b) "In determining whether a Remedial Technology is  'Req-
     uisite,' consideration shall be  given by the  parties to  the
     following factors: the nature of the endangerment to human
     health and the environment which the Remedial Technology
     is designed to address; the extent to which application of the
     Remedial Technology would reduce such endangerment to
     human health or the environment or would otherwise bene-
     fit human health or the environment; and the economic costs
     required to apply the Remedial Technology...."  1 CHEM.
     & RADIATION WASTE LIT. REP. 696.
   This provision obviously does little to define what the defen-
 dant's obligation actually entails. It is interesting that cost is used
 apparently  to balance  the  benefits  achievable by a  particular
 remedy.
   The most discussed provision of Hyde Park's "Requisite Remed-
 ial Technology" is the  dispute resolution mechanism.  This pro-
 vision reportedly requires the company to show that the use of a
 particular remedy is "arbitrary and capricious" before the court
 may tamper with the government's preferred remedy. Yet, the re-
 strictive standard of review only applies to the cost balancing  de-
 termination. The company may still  challenge a remedy as "un-
 necessary to satisfy the  goal [of protection of human health and
 the environment]," and the burden of proof apparently will  not
 shift to the company.
   The  court  described  the Requisite  Remedial  Technology
 ("RRT") concept as "enormously flexible...with adequate safe-
 guards... [that make] it  a viable, workable solution to  the  prob-
 lem...." 1 CHEM.  & RADIATION WASTE  LIT.  REP.  2,419
 (1982). On the ambiguity of RRT, the court found:
   "The term RRT is necessarily loosely defined,  because at this
   time, it is impossible  for any party or nonparty to know what
   methodology will be appropriate and  will be most successful in
   halting the leaching process." Id.
   Thus, the concept does little more than embellish the notion that
 the defendant will  do whatever is "necessary." See also United
States v. Occidental Petroleum Corp., Civil No. S-79-989 MLS
(E.D. Cal., Stipulation and Judgment Approving Settlement, Feb.
6, 1981) (court determination of "Requisite Remedial Technology"
based on "all relevant factors").

OPEN-ENDED COMMITMENTS

  Several agreements have been signed which basically commit the
defendant to do whatever is  "necessary." Trends  in recent  ad-
ministrative orders by USEPA suggest that this type of general-
ized obligation will be used routinely in unilateral orders as well.
  Some examples of an open-ended commitment illustrate the ten-
dency of USEPA and the Justice Department to shift  the burden of
uncertainty entirely to the defendant. In United States v.  Wau-
kesha County, Civil No.  80-C-1070 (E.D. Wise., Consent Decree,
filed Dec. 1, 1980), any soil or surface water sample above 10 ;tg/l
of 2,4,5-T or trichlorophenol  triggered an obligation to submit a
cleanup plan to USEPA. The scope of the plan is vague:
  "The Defendant shall then formulate a plan which will result in
  removal or containment of the 2,4,5-T and  any dioxin found,
  in  a manner which will eliminate any imminent and substantial
  endangerment to the  public  health and/or the  environment
  caused by its presence." Para. VILA.
The decree  simply provides that the plan will be implemented upon
USEPA's approval. The agency's discretion seems virtually  ab-
solute.
  The agreement in United States v.  W.R. Grace & Co., Civil No.
80-748-C (D. Mass., Final Decree, Oct. 21, 1980), contained a sim-
ilar broad obligation. Government authority under that decree re-
quires that  "[a]ll plans, programs, and proposed actions...shall be
subject to the approval of the federal government parties" to  the
decree.  Para. IV. One of the plans called for requires "an  en-
gineering report for aquifer cleanup and restoration to a fully use-
able  condition...." Para. XII.A. Disputes over  the relief proposed
will be reviewed by the court in light of "the reasonableness in all
the   circumstances of the  relief requested...."  Para. XIII.C.
Reasonableness is defined rather broadly:
  "[A]  remedial action shall be deemed reasonable  if it is neces-
  sary or appropriate,  under all the circumstances to remedy pollu-
  tion for which W.R.  Grace is responsible."
  In United States v.  Gulf Coast Lead, Civil No. 80-1127  (M.D.
Fla., consent decree,) the defendant was directed to prepare a re-
medial plan "necessary  to  successfully isolate  and  contain haz-
ardous  contaminants  in the  shallow groundwater  and possibly
deeper groundwater and soil beneath the  GCL site attributable
to GCL plant operations...."  The defendant is further obliged to
revise the plan to reflect USEPA comments unless it  establishes by
"clear and  convincing evidence that its Plan of Study or the  Re-
medial Plan will successfully isolate and contain hazardous con-
taminants on or beneath the GCL site...." Obviously, the defen-
dant in this situation  has been placed in a difficult position to
argue cost-effectiveness of the relief,  not to mention cost-bene-
fit considerations. See  also United States v. Laskin, Civil No. C79-
7594 (N.D.  Ohio, Consent  Decree,  1980),  (remedial plans to in-
clude "any  reasonable  modifications made by USEPA.")
  The type of commitments undertaken in these agreements gen-
erally require USEPA  approval and provide for restricted judicial
review of disagreements or for no specific review procedure at all.
A superior  method of resolving disputes concerning the "reason-
ableness" ' of a remedial plan is discussed below.

PLANS SUBJECT TO COURT APPROVAL OR CHALLENGE

  In some situations, it may be impossible to agree to do more than
study a site and propose a remedial plan. As discussed above, how-
ever, this type of undertaking can begin to "box in" a company
by making  USEPA or state determinations either  a prerequisite
or presumptively valid. A superior procedure for private parties
follows the first steps, but  then allows a full  de novo review by
the courts in the event of disputes. This is a right that defendants
                                                                                               LEGAL LIABILITY
                                                         435
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should not lightly relinquish and a procedure that remains the best
means of adjudicating factual controversies.
  The type of flexibility that should be sought by defendants is
illustrated by In the Matter of Stauffer Chemical Co., Docket No.
82-1070 (USEPA, May 25, 1982) 1 HAZ. WASTE LIT. REP. 2595
(1982) (the Woburn,  Mass. site). This  administrative agreement,
made under CERCLA Section 106 and RCRA Section 7003, com-
mits the company to an "investigative study" which includes a site
sampling program and development of a "Recommended Remed-
ial Action." The procedure in the event of disagreement over the
scope of the remedial proposal is as follows:
  "If, within sixty (60) days after receipt of USEPA and DEQE's
  disapproval...,  the parties are unable  to agree  on a Recom-
  mended Remedial Action and if Stauffer has complied with all
  preceding paragraphs of this Consent Order, Stauffer's obliga-
  tions regarding this Consent Order shall be satisfied in full and
  Stauffer shall have  no further commitment regarding this Con-
  sent Order, nor shall  Stauffer be released  from  liability....
  USEPA and DEQE retain all rights to require such further ac-
  tion as they deem necessary, including the issuance of further
  orders or the seeking of judicial recourse."
  Similarly, other agreements have provided for full review by the
court in the event that the parties cannot reach a consensus on the
remedial plan proposed by the  defendant. See In  the Matter of
FMC Corp., No. 8371021282 (NYDEC, Order of Consent, Feb.
17, 1982)  1 HAZ.  WASTE LIT.  REP.  2176, 2179 (1982);  United
States v. Vertac Chemical Corp., No.  LR-C-80-109 (E.D. Ark.,
Consent Decree, Jan.  18, 1982).  These arrangements do not sur-
render the government's legal right to proceed nor do they prema-
                                                        turely shift the uncertainty of appropriate relief onto the defen-
                                                        dants.
                                                        CONCLUSION
                                                          The various methods used in settlements to date have dealt with
                                                        the appropriate extent of a defendant's remedial action by several
                                                        broad approaches. Seeking a finite and reasonable ceiling on the
                                                        company's obligation should be the key objective of defense coun-
                                                        sel  in settlement negotiations. The advisability  of any specific
                                                        model for determining the scope of the  defendant's  obligations
                                                        hinges on site specific factors.
                                                        FOOTNOTES

                                                        1. Even use at the receptor point could be inconsistent with the statutory
                                                          provisions of CERCLA where the abatement cost to reduce the level
                                                          at the receptor was wildly disproportionate to the threat presented by
                                                          exceedence of the criteria. See  CERCLA Sections  104(c)(4) and 101
                                                          (24); 47 Fed. Reg. 31217 (1982) (Preamble to NCP) (discussing "cost-
                                                          effectiveness" and effective "mitigation"). Inherent in this formula-
                                                          tion is  the need to examine mitigative measures that address the sub-
                                                          stantive potential threat from a site as well as measures that  remove
                                                          potential threats regardless of their costs  or the severity of the threat.
                                                          That this statutorily-mandated process would lead to a nonquantitive
                                                          but thorough review of relative costs, benefits and  risks was the spe-
                                                          cific intent of Congress. Sponsors of the legislation clearly assumed
                                                          that "cost-benefit considerations [will be taken] into account...in de-
                                                          termining whether and  when  action should be taken at all" at a par-
                                                          ticular site. Colloquium between Senator Helms and Senator Stafford,
                                                          126 Cong. REC. S15.007 (Nov. 24,1980).
436
LEGAL LIABILITY
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                      LIABILITIES  AT COMMON  LAW FOR
                       GROUNDWATER CONTAMINATION

                                        EDWARD I. SELIG, ESQUIRE
                                               DiCara,  Selig & Holt
                                Boston, Massachusetts and Washington,  D.C.
INTRODUCTION

  The scope of this paper can be illustrated by a simple example.
Suppose that an industrial firm deposited hazardous process wastes
on the ground some years ago.  By leaching or leaking,  contam-
inants from that waste pile went below ground, entered  an aqui-
fer and eventually reached a well field some distance away. Health
authorities  ordered the contaminated wells to be shut down. The
owners of these wells,  and certain  individuals who claim to have
consumed contaminated  water from them, bring suit against the
industrial firm, alleging destruction of their water supply and in-
juries to their health.
  The complaint demands both compensation for the personal and
property injuries  suffered by the  plaintiffs  and an  injunction
ordering the defendant to take whatever action  may be neces-
sary to correct or eliminate the cause. In addition to physical causes
and effects linking defendant's waste disposal to injuries suffered
by plaintiffs, the complaint alleges  that the defendant should be
held liable  because he  knew  of the risks he was creating by dis-
posing of his wastes, because he failed to exercise reasonable care
in disposing of them or because  their disposal was an abnormally
dangerous activity which he undertook entirely at his own risk for
any harmful consequences.
  Whether won or lost on the merits,1 such a case illustrates the
three main  functions or goals of the common law system  of rights
and remedies known as tort law: (1) to compensate persons who
have sustained loss or harm  as  the result of another's conduct;
(2) to place the cost of that compensation on those who, in jus-
tice, ought to bear it, but only on such persons; and (3) to pre-
vent future losses and harms.2 For centuries, this system of law has
been and still is being developed more or less independently by
the courts in cases alleging injury to persons or property as a re-
sult of risk-taking activity including—for present purposes—ac-
tivities that  expose other people to environmental hazards.
  Tort liabilities,  as they appear in the environmental (or any
other) field, need  to be distinguished from penalties, injunctions
and cost recoveries authorized by statute against  violators  of
statutorily established standards and regulations. The latter are of
critical importance to environmental protection, but limitations of
space and time prevent their  being addressed  here. This  paper  is
concerned with how the common law of torts applies to redress in-
juries to persons or property  via groundwater contamination that
has resulted from faulty storage or disposal of hazardous wastes.

TORT ACTIONS AT COMMON LAW
  In general, tort liability is  based upon conduct that creates an
unreasonable or unacceptable risk of harm. Such conduct may be
intentional, negligent or so inherently risky that the defendant will
be held liable  even  without fault for any harm that ensues. In
nearly all such cases, the cardinal question is whether the loss or
injury suffered by the plaintiff will be allowed to remain where it
fell or will be shifted back to the defendant, primarily in the form
of compensatory damages, i.e., monetary recompense to be paid by
defendant to plaintiff. The principal elements of tort law may now
be briefly summarized, with particular reference to the paradigm
case outlined above.
Conduct of Defendant
  The requisite intent need not involve any motive to inflict harm
upon the plaintiff. In most cases, intent can be inferred from con-
duct undertaken by an actor who clearly foresees its consequences.
The law presumes  that  one intends the  natural and  probable
consequences of one's acts  in the light of surrounding circum-
stances of which one  must be aware.
  Suppose, for example, that in the paradigm case, the  company
had been forewarned by  a  consultant that land disposal of its
wastes  could eventually jeopardize the aquifer. Since defendant
knew the risk he was taking when he  acted in spite of that advice,
he can be deemed to have inflicted an intentional injury on the
plaintiff when the risk materialized.
  It is  even clearer that he commits an intentional tort if he  per-
sists in  the harmful activity or fails to control its effects after learn-
ing of the actual harm it has begun to cause.3 It is true,  however,
that intent  will be difficult  to show in most  cases involving re-
leases of hazardous waste  or other chemicals, especially where the
causative activity occurred some time ago when its effects could
not have been reasonably foreseen in  the light of the scientific and
technological knowledge existing at that time.
  Negligence is the second major behavioral basis for tort liability.
As enunciated through centuries of judicial case law, negligence is
a breach of duty to  conform to the required standard of care for
protection of others against unreasonable risks of harm. This is
the standard that a prudent person in the defendant's position
would  have observed, considering the  risk his  activity  creates.
And  such a risk is  deemed  unreasonable when the foreseeable
probability and gravity of the harm  outweighs the burden to the
actor of alternative conduct  that would have prevented the harm.
For example, in the  paradigm case, the plaintiff might be able to
prove that other industries comparable to the defendant disposed
of their wastes by safer means at the  same time the defendant was
putting his  on the ground. Cases are  not difficult to find in which
courts  have held industrial  enterprises liable for personal injury
and property damage as a result of negligent releases of hazardous
waste and other contaminants to the environment."
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                                                        437
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  Finally—and most important in the current trend of tort liability
—a standard of strict liability may be imposed upon defendants
who undertake activities of  an ultrahazardous or  abnormally
dangerous nature. This is liability without fault, imputed to the
defendant even though he acted  neither negligently nor intention-
ally with respect to the  consequences of his action. "One who
carries on abnormally dangerous activity is subject to liability for
harm to person, land  or chattels of  another resulting  from the
activity, although he has exercised the utmost care to prevent the
harm.'" An activity may be deemed  abnormally dangerous if it
involves a high degree of risk, or if the  gravity of harm that may
result from it is likely to be great though the risk is small. The
context in which the activity is carried on is relevant to this determ-
ination: i.e., whether  the activity  is not  a matter of common
usage, or is inappropriate to the locale or is not of substantial
value to the community.
  Whether particular  conduct  is "abnormally  dangerous"  for
purposes of strict liability is a question of law for the  courts to
decide, and courts have not  been reluctant to impose strict liabil-
ity for injuries  caused by the release of  toxic chemicals to the en-
vironment.' For example, strict  liability was imposed on a com-
pany for costs of cleaning up waste residues that had leached from
the company's processing plant  into a local stream, even though
the court found that defendant's conduct "was reasonable in light
of the state of knowledge as it then existed."7
  Activities giving rise to strict liability may be socially useful, but
they are so dangerous or unusually  risky that  the  law requires
them to be carried on at the actor's peril. In fact, cases  involving
strict liability should be  viewed  "as special instances of manda-
tory insurance against particular designated risks imposed as a mat-
ter of policy irrespective of fault."1 The rationale is that defen-
dants who engage in such activities are best able  to insure against
the risks they pose,  to allocate the costs of insurance by passing
them on to consumers of their  products and to reduce or warn
against the dangers. In particular, it has been suggested that strict
liability will force generators, disposers and other managers of haz-
ardous wastes to develop and employ the  safest and most effic-
ient practices that ingenuity can invent  and money can buy.'
  Suppose (to complicate the paradigm  case) that the wastes were
deposited on the ground by a disposal  firm to which generators
had shipped them from many miles away and that the hazardous
chemicals in  the waste can  be traced back further to manufac-
turers  of materials used by the generators. How far back  up the
chain of successive sellers and buyers is the plaintiff entitled to go
in search of responsible defendants? A plaintiff may decide to go
all the way  back and sue the manufacturer of  the  original ma-
terial,  even though the latter lacked knowledge or control of the
disposal practice because he was  at two removes from the disposer
and at one from the generator.
  The most promising theory on  which to sustain such a suit is that
a manufacturer may be  held  liable for failing to give  adequate
warning  of  the inherent dangers  of  his product,  including the
dangers that arise from failing to  handle or dispose of it properly.'"
One who sells any product  "in  a defective condition and unrea-
sonably dangerous to the user or consumer or to his property" is
subject to strict product liability  for physical harm thereby caused
to the ultimate  user or consumer, and the defect  may consist pre-
cisely "in the failure to  warn or to provide adequate directions
for use."" A manufacturer knows more about  his  product and
can supply more information concerning its dangers than those
who subsequently handle and dispose of it.
  But what constitutes adequate warning should depend on how
much the manufacturer can be expected to have known at the time
he sold the product, not on any more sophisticated, recently
acquired appreciation of  dangers posed by improper management
of hazardous waste. This could be an important distinction in cases
where the relevant sales took place years before the injury became
manifest.  In  fact, similar discrepancies may arise in the  law of
negligence with respect to evolving standards of care and in the law
                                                       of strict  liability with respect  to  evolving  perceptions of what
                                                       activities  are abnormally dangerous.  Moreover,  manufacturers
                                                       might be  entitled to assume that their customers will properly dis-
                                                       pose of any waste generated in the use of their products, even
                                                       without explicit directions or warnings. It remains to be seen how
                                                       successful plaintiffs will  be in  suing original manufacturers for
                                                       damages caused by improper waste disposal.
                                                         It is another question whether a generator who ships hazardous
                                                       wastes  offsite for disposal will be held liable in tort" for their
                                                       escape  from transportation or disposal facilities. Generators who
                                                       operate outside the manifest system established under RCRA will
                                                       probably  be held liable for such releases,  along  with the trans-
                                                       porter or disposer, since failure to comply with applicable regula-
                                                       tions is prima facie evidence of negligence or culpable intent. It
                                                       will be a  harder case if the shipment of waste offsite occurred a
                                                       number of years ago and was lawful at that time, when the only
                                                       legal requirement may have been to entrust the wastes to a licensed
                                                       transporter. Was the generator negligent back then in having failed
                                                       to foresee and forestall  the  risks of  careless transportation or
                                                       improper disposal?  Or should  he be held strictly  liable  on the
                                                       theory  that, even back then, the shipment of his particular waste
                                                       off-site would have been perceived to be an abnormally dangerous
                                                       activity? These are relevant questions that the courts have yet to
                                                       resolve in such cases.
                                                         Current waste-handling practices may also give rise to hard cases.
                                                       Suppose  that an accident  occurs  in transportation or disposal
                                                       despite the fact  that the generator selected  his  transporter and
                                                       disposer with great care and complied  with all applicable RCRA
                                                       requirements. Will the generator nonetheless be held liable in tort
                                                       for releases of hazardous wastes from sites or facilities over which
                                                       he could  exercise no control? Even if the shipment of hazardous
                                                       wastes  off-site  for disposal were to be  considered an abnormally
                                                       dangerous activity, their mishandling by an independent third party
                                                       may be a supervening cause that delimits the scope of the genera-
                                                       tor's strict liability." There is some precedent, moreover, for not
                                                       considering the disposal  of hazardous waste as  an abnormally
                                                       dangerous activity, insofar as relatively simple precautions (such
                                                       as lining the disposal pit or providing leachate collection systems)
                                                       could be  taken to ensure safe disposal." The scope of the gen-
                                                       erator's liability in tort for off-site releases of hazardous waste will
                                                       no doubt  be hotly contested under state law."

                                                       Compound and Extended Liability
                                                         In most cases  of injury  caused by groundwater contamina-
                                                       tion, there are several potentially responsible parties. The law not
                                                       only anticipates and recognizes  this multiplicity,  but also extends
                                                       the range of possible defendants beyond those who can be shown
                                                       to have caused  or contributed directly  to the injury by disposing
                                                       of their wastes upon the ground.
                                                         Suppose that a landowner's wells are contaminated by discharges
                                                       from one or more of three leaking sites and that the  landowner
                                                       sues all three site owners for loss of his water supply. In such a case,
                                                       it may be difficult to  prove that the pollution was caused by re-
                                                       leases from any particular site or to assess the degree to which each
                                                       of them contributed to the harm. But the plaintiff may be relieved
                                                       of such burdens of proof under the  rule of joint and several lia-
                                                       bility. When the harm complained of is "indivisible", i.e., when
                                                       there is no rational basis for calculating the proportional liability
                                                       shares  of multiple  defendants, this rule  allows  the plaintiff to
                                                       recover all his damages from any one defendant.' •
                                                         Although in most jurisdictions the defendant who actually paid
                                                       the plaintiff has a right  to seek "contribution"  from his OHle-
                                                       fendants  in a separate action, his ability to obtain any money from
                                                       them may depend on whether they are solvent. In other words, the
                                                       rule has the effect of shifting the risk of non-recovery from platar
                                                       tiff to defendant.
                                                         In contrast,  damages will be severally apportioned by the court
                                                       when the harm complained  of is deemed  to be "divisible" to
                                                       accordance with some rational principal." Under these circum-
 438
LEGAL LIABILITY
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stances, the plaintiff bears the risk that one or another defendant
will be unable to satisfy the judgment against him, for when the
rule of joint and several liability does not govern disposition of a
case, no defendant may be forced to pay more than his appor-
tioned share of liability. The trend in environmental case law, how-
ever, favors application of joint and  several liability in most cir-
cumstances where a solvent defendant can be found who contrib-
uted significantly to the plaintiff's injury.
  There are also rules of vicarious liability under which indirectly
responsible parties may be required to pay damages. For example,
a parent company may be held strictly  liable  for the  environ-
mental torts of its subsidiary, where the parent exercises or is in a
position to exercise  control over the activities  of the latter (as
though  overlapping  officers and directors).'8  Nor will a parent
corporation succeed in insulating itself from tort liability by creat-
ing a shell of a subsidiary for that purpose. In such cases, courts
can be expected to "pierce the corporate veil."" For analogous
reasons, if company B acquires the assets of company A and con-
tinues the same line of business,  B  may be held liable  for  the
environmental torts  of A on  a theory of  continuing enterprise
liability;20 a principal may be held liable for the tort of his inde-
pendent contractor in the  course  of performing an  abnormally
dangerous activity (such as hazardous waste  management)  for
which the principal  had hired him;  and a lessor may become
liable for the tort of his lessee upon reversion of the  property to
the lessor.
  Corporate officers may bear vicarious liability for the environ-
mental torts of subordinate employees. The law of negligence sup-
plies the usual standard for determining liability in such cases:
"If the defendant's general responsibility has been delegated
with due care to some responsible subordinate or subordinates,
he is not himself personally at fault and liable for the negligent
performance of this responsibility unless he personally knows
or personally  should know of its  non-performance  or mal-
performance and has nevertheless failed  to cure the risk of
harm."21
  Those who directly supervise the handling of hazardous wastes
will be expected to exercise a  high degree of care in controlling
and monitoring performance by their subordinate employees. In
the upper echelons of corporate management, practical necessity
requires the application of a somewhat more flexible standard. In
general, top executives and directors are  entitled to  rely on the
competence and integrity of their subordinates "until something
occurs to put them on suspicion that  something is wrong. If this
occurs and goes unheeded, then liability of the directors might well
follow...."" Moreover, a corporate supervisor or officer cannot
escape liability by pleading ignorance of facts he ought to know in
the course of discharging his corporate duties. "... [ W] here the duty
to know exists, ignorance resulting from a neglected official duty
creates the same liability as actual knowledge....""

 Damages

  Tort law is concerned not only with  conduct giving rise to liabil-
 ity, but also with the resulting injuries and the means of redress-
 ing them for the benefit  of injured  plaintiffs.  Where personal
 injury is alleged—as  when  a plaintiff claims that his health has
 been impaired by ingestion of contaminated  water—compensa-
 tory money damages may be recovered for such items as cost of
 medical care or monitoring, estimated income loss as a result of
 physical disability and a surcharge for plaintiff's "pain and suffer-
 ing."  In attempting to restore the plaintiff to his pre-injury con-
 dition so far as it is possible to do so with money, the law assumes
 that both economic and noneconomic losses are  capable of being
 translated into dollars.
  Harm to property, such as land and appurtenant groundwater
 rights, may also be  compensable  and can  be measured by the
 difference between the value of the property before and after the
 '«, by the reasonable costs of repairing and restoring it, by its
 value at the time it was irrevocably converted to the defendant's
own use or by the cost of obtaining a substitute (such as an alterna-
tive  source of  water supply).  Private  or  common property re-
sources damaged by releases of hazardous wastes  might include
aquifers, fisheries and  crops for whose  loss a dollar value can be
calculated.
Private and Public Nuisance

  Suits at common law may also seek "equitable" remedies, such
as an  injunction ordering defendant to cease or control his in-
jurious activity, or even to reverse its harmful effects. In environ-
mental litigation, the widest range of equitable remedies appears
in actions brought under the common law of nuisance, a category
of tort that focuses not so much upon the conduct of the defendant
as upon its consequences for the plaintiff.
  A private nuisance is a substantial and unreasonable interference
with the  use  and enjoyment of  an interest in land.  A  public
nuisance is an unreasonable interference with a right common to
the general public, such as the  right to a clean municipal  water
supply.
  When hazardous wastes have been released to the environment,
equitable remedies in a nuisance action may be directed not only to
current and continuing activity of the defendant (should he be
allowed, under any circumstances,  to go on discharging hazardous
wastes?), but also to present consequences of discontinued activity,
such as existing or threatened pollution of an aquifer from a leach-
ate  plume originating  at the  defendant's facility. The defendant
might be required to control the plume by whatever means and at
whatever costs are necessary, to buy out land-use and groundwater
withdrawal rights  from adjacent landowners and to monitor  the
health of potentially injured populations.
  Some outer  limits  of injunctive  relief in litigation over haz-
ardous wastes may already have been reached in the Wilsonville
case,24 where a chemical landfill that had been fully permitted by
both the USEPA and  the Illinois  EPA was nonetheless  enjoined
as a common law nuisance and required to close down, primarily
because of the  possibility that  hazardous waste might  one day
escape from the site and cause substantial future harm. The order
in this case required the defendant  not  only  to cease operations
but also to exhume the buried wastes and to reclaim the site. There
was evidence that the site was not  ideal because of an abandoned
mine that had already caused considerable subsidence in the vicin-
ity, but the risks posed by use of the site had been considered and
found acceptable by the permit-issuing authorities on the basis of
information concerning groundwater,  soil  permeabilities, sub-
sidence and other relevant conditions. The order of the court, how-
ever, rested not upon the likelihood of harm but upon its magni-
tude if it were ever to  materialize. In other words, defendant was
ordered to shut down  "even though the feared harm was uncer-
tain as to occurrence and, in any event, unlikely to occur until the
distant future."25
  Several important lessons can be  learned from the Wilsonville
case: (1) a site for disposal of hazardous waste may be enjoined as
a prospective  nuisance if it poses a small likelihood of causing
substantial future harm; (2) a court may hold, as this one did, that
"a site's  dangers outweigh its utility," despite the urgent need for
new and expanded capacity to dispose of hazardous waste; and (3)
the fact that all necessary permits have been issued for a facility by
state and  federal authorities will not bar a court from ordering  it
to be closed down if there is evidence suggesting that more rigorous
standards of site selection might have been applied by the adminis-
tering agencies in considering whether to issue those permits.
  This last point should be emphasized. Unless  a statute makes  it
clear that administrative regulations and permits are to preempt the
common law on the subject, "courts are reluctant to embrace the
concept of legalized nuisance...[a]nd are not inclined to relinquish
sweeping  powers  to correct technological  and  land use  abuses
unless legislatures unmistakeably dictate the terms of surrender."26
Without  such overriding  action of  the legislature, courts  are re-
                                                                                                  LEGAL LIABILITY
                                                           439
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luctant "to accept evidence of compliance with an administrative
...permit as answering fully an inquiry under nuisance law.""
  In fact,  federal environmental statutes typically aver that they
are intended to establish only minimum requirements for pollution
control and not to preclude a state from establishing stricter ones
of its own with respect to the same subject matter. For example,
§3009 of RCRA provides that federal regulations for hazardous
waste management shall not "be construed to prohibit any State or
political subdivision thereof from imposing any requirements, in-
cluding those of site selection, which are more stringent than those
imposed by such regulations." So far as federal law is considered,
more stringent requirement could be imposed by either the legisla-
ture or the courts of a state.  And as a matter of state law, state
courts are usually authorized to exercise their own judgment in
nuisance cases unless the state legislature has expressed an inten-
tion to preempt the field.

Critique of Common Law Actions
  For  various  reasons, plaintiffs  may have  difficulty recovering
damages in tort actions at common law. Litigation is costly, time-
consuming and uncertain in outcome. Moreover, where personal
injuries are alleged from releases of hazardous  waste, plaintiffs
may confront several peculiarly difficult obstacles to recovery.
  To begin with, a plaintiff may have suffered too small or too
uncertain an injury to attract competent  counsel on a contingent
fee basis. This problem can sometimes be overcome through "class
actions" where numerous persons  who  claim to have suffered
similar injuries are joined as  plaintiffs against a single defendant
or group  of defendants.  Such actions may  arise, for example,
where many  people have used a contaminated water supply. By
aggregating their claims  through class certification, the plaintiffs
can seek together a total sum in damages that is large enough to
warrant expensive  resort to judicial process. However, class ac-
tions can generally be brought only where common questions of
law or fact predominate  over questions affecting only individual
members of the class in a particular case.21
  A second difficulty may be a lapse of a relatively long time be-
tween  the  escape of hazardous wastes from a disposal site, their
migration  into plaintiff's water supply and  the manifestation of
injury to  plaintiff from consuming  the  contaminated  water.
Plaintiff's action may be barred by expiration of the Statute of
Limitations,  which sets  a deadline on  the  filing of suit  after
"injury" occurs—a difficult problem when injury is not suddenly
inflicted  but gradually accrued. Or in  the long latency period be-
tween cause and effect, defendant may have gone out of business
and critical witnesses  disappeared.  In fact, it may not even  be
possible to find  and identify a responsible defendant whom the
plaintiff can sue.
  Moreover, in cases arising  from exposure to hazardous waste,
scientific uncertainties may make it difficult for  plaintiff to meet
the stringent standards of proof by  which causation in tort is de-
termined. There are two focal points of factual uncertainty in many
of these cases: the pathway from the alleged site of release to the
victim's property or person, and (in cases alleging personal injury)
the effects of personal exposure to the contaminant.
"...[B]ecause  of the lack  of scientific certainty, and the several
years lag time between waste release and damage,  it is extremely
difficult  to establish the causal  link.  To establish causation,
the plaintiff must isolate the harm-causing chemical, trace the
pathway from the site to the  victim, and prove medically  that
the chemical caused the injury or disease. This difficulty is ex-
acerbated  by  other factors, such  as the possibility of natural
processes in the soil affecting its composition,  the spread of
leachate,  the  presence of more than  one disposal site which
may have caused the damage, mixture of chemicals at the dis-
posal site, and subsequent exposure of the  plaintiff to other
synergistic hazards which may have added  to his injury. Per-
haps the most difficult element of causation  in a personal in-
jury action is proving that a  certain toxic substance caused a
                                                        certain disease. The determination that X chemical caused Y
                                                        disease is hindered by scientific complications in the evalua-
                                                        tion of the experimental data, use of statistical reports, extrap-
                                                        olation of animal testing to persons, and evaluation of low-
                                                        level exposure.""
                                                          Another commentator has observed:
                                                        "In the case of chemicals which present a risk of cancer, the
                                                        concentrations above which drinking water is considered to be
                                                        'contaminated' are typically levels at which the risk  of getting
                                                        cancer  is very  low — approximately  one-in-a-million  lifetime
                                                        risk. Where the plaintiffs  have been exposed to  such a small
                                                        added risk of cancer, it should be virtually impossible to show
                                                        that any particular case of cancer occurring among users of the
                                                        water  supply is  attributable  to chemical contamination— as
                                                        opposed to any of the plethora of other factors that  can result
                                                        in cancer."30
                                                          For all the foregoing reasons, it is fashionable these days to crit-
                                                        icize tort actions at common law as an inadequate vehicle for re-
                                                        dressing injuries caused by releases  of hazardous wastes to  the
                                                        environment. Such criticism is largely justified. On the other hand,
                                                        as indicated by the rapidly growing  number of reported  judicial
                                                        opinions in this field, tort  liability has been repeatedly imposed
                                                        upon defendants who were responsible for the mishandling of haz-
                                                        ardous  wastes,  especially  where  the plaintiff could  make just
                                                        enough of a  case to get to a sympathetic jury  or  could prove
                                                        damage to property,  an easier undertaking than  proof of injury
                                                        to personal health.
                                                          Moreover, the difficulties of proving causation are not neces-
                                                        sarily a deficiency  of tort  law.  It may  be that  alleged  injuries
                                                        from hazardous waste exposures have been overstated and ought
                                                        not to be accepted as facts  giving rise to substantial monetary  re-
                                                        coveries unless the plaintiff can prove his case by a clear preponder-
                                                        ance of the evidence in a court of law. In this connection, it should
                                                        be noted that courts  are not likely to be  overwhelmed by statis-
                                                        tical evidence  from the environmental and health sciences, includ-
                                                        ing epidemiology. What is generally demanded in tort litigation is
                                                        proof linking the particular injuries suffered by the plaintiff at bar
                                                        with the activities of the particular defendant. This insistence  on
                                                        particular proof may change  with the passage of time, but tort
                                                        liability will seldom be determined by offers of  statistical proof
                                                        unless rules of evidence are modified to that effect by statute.
                                                          Whatever the shortcomings may be of tort action  in this field,
                                                        well publicized cases  in which plaintiffs have recovered substan-
                                                        tial damages have begun to put industrial enterprises on their guard
                                                        against mismanagement of  hazardous waste and have given them
                                                        every incentive to limit damage when  it is  discovered at  uncon-
                                                        trolled  sites. Tort liability is now and will remain a major incen-
                                                        tive  for proper waste management,  even  beyond the minimum
                                                        standards established by regulatory law.

                                                        REFERENCES

                                                         1.  In order to secure recovery, plaintiff must, of course, meet the burden
                                                            of proof on the factual allegations of his complaint.  Even  if plain-
                                                            tiff does or could prove his case, however, he may still lose because of
                                                            procedural  bars, such as the statute of limitations (which sets a time
                                                            limit for bringing suit after the injury occurs), or because of affirm-
                                                            ative defenses such as contributory negligence, consent or assumption
                                                            of the risk.
                                                         2.  E. Kionka, Torts in a Nutshell 6 (1977) [hereinafter cited as Kionka].
                                                         3.  See, e.g., Ewell v. Petro Processors  of Louisiana, Inc., 364 So.  2d
                                                            604  (La. App. 1978), cert, den., 366  So. 2d 575 (1979), in which  de-
                                                            fendant Ethyl Corporation was required to share in cleanup costs from
                                                            a leak in an off-site disposal facility  since  the corporation continued
                                                            to ship hazardous wastes to the site after it acquired knowledge that
                                                            the site was leaking.
                                                         4. Ewell v.  Petro Processors of Louisiana, Inc., supra note 3
                                                            from disposal  facilities to adjacent property and navigable waters);
                                                            Ballantine v. Public Service Corp., 91 A. 95 (N.J. 1914) (leakage of
                                                            industrial waste into groundwater used by plaintiff to make its beerjf
                                                            Hagy v. Allied Chemical and Dye Corp., 122 Cal. App. 2d 361, 265
 440
LEGAL LIABILITY
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   P.2d 86 (1953) (injury to larynx of auto passenger driving through
   sulfuric acid smog emitted from a factory); Reynolds Metals Co. v.
   Yturbide, 258 F.2d 321 (9th Cir. 1958), cert, den., 358 U.S. 840 (1958)
   (fluoride poisoning from aluminum plant emissions).
5. Restatement (Second) of Torts, §519 (1976).
6. Such cases have involved, for example,  discharges from landfills, as
   in Ortega Cabrera v. Municipality of Bayamon, 562 F.2d 91 (1st Cir.
   1977); and  discharges from industrial facilities, as in Cities  Service
   Co. v. State of Florida, 312 So. 2d 799 (Fla. Dist. Ct.  App. 1975) and
   Department of Transportation v. PSC Resources, Inc., 15 Env't Rep.
   Cas. 1053 (Sup. Ct. N. J. 1980).
7. State of New Jersey  Department of Environmental Protection v.
   Ventron Corp., Nos. C-2996-75, C-1954-77, C-l 110-78 (N.J. Superior
   Court, Trial Division, Aug. 27,  1979);  modified  and remanded,  A-
   1395-79;  A-1432-79; A-1446-79;  A-1545-79 (N.J. Superior  Court,
   Appellate Division, Dec. 9, 1981).  The  same principles of liability
   enunciated in public nuisance cases brought by government agencies,
   such as the  Ventron case (and other cited in these footnotes), will also
   be found to apply in  private tort litigation based on similar sets of
   facts.
 8. E. Kionka, supra note 2, at 36.
 9. Note, Strict Liability for Generators, Transporters and Disposers of
   Hazardous  Waste, 64 Minn. L. Rev. 949,  968 (1980).
10. Thus, the government has named Monsanto, a manufacturer of PCBs,
   as co-defendant in a suit brought against an industrial  user  of that
   chemical  from whose plant it was  discharged  into Lake Michigan.
   United States  v. Outboard Marine Corp., Civ. No.  78C-1004 (E.D.
   111., filed July 21, 1980). The complaint alleges that Monsanto failed
   to warn adequately of the dangers  inherent in the use  of hydraulic
   fluids containing PCB in an open hydraulic system. Another example
   isMcKeever v. Shell Oil Co.,  Civ. No.  77-1128 (Sup. Ct. Cal., filed
   Sept. 8, 1980), in which well owners and users sued manufacturers of
   a pesticide, DBCP, that leached into groundwater after being applied
   to crops, allegedly causing widespread groundwater contamination.
11. E. Kionka, supra note 2, at 268.
12. See the discussion in Section II.A below  of generators' liability under
   Section 107 of the Superfund Act.
13. See, for example, Ewell v. Petro Processors of Louisiana, Inc., supra
   note 3, in which generators/customers of a disposal facility were not
   held strictly liable  because the leakage was "caused" by the facility
   owner. The issue in such a case concerns the responsible or so-called
   "proximate"  cause, which is "essentially a question of duty—was the
   defendant under a duty to protect this particular plaintiff against the
   particular event which injured him or the  consequences of that event?"
   See E. Kionka, supra note 2,  at 88.  "Fairness dictates that it liability
   is strict, at least the risk must be consciously assumed...in strict liabil-
   ity  cases  unforeseeable  intervening  cause is a defense." Id. at 48.
   The question would be, then, whether  leakage from a RCRA-per-
   mitted  disposal facility  is  within the foreseeable scope of the  risk
   assumed by the generator/customer.
14. Ewell v. Petro Processors of Louisiana, Inc., supra note 3.
15. When hazardous  wastes were released  from the site of a bankrupt
   company, the State of Michigan sued the generator/customers on the
   theory that they had a "duty to  the public...to dispose of their waste
   products without  threatening the public health  and safety or its even
   more precious natural resources."  Kelly v. Ankersen,  Civ. No.  77-
   151279-CE (Michigan Cir. Ct.,  filed Feb. 19, 1977). This case was
   settled before trial by agreement of the generators  to  remove their
   wastes from the site.
16. See Michie v. Great Lakes Steel Division,  National Steel Corpora-
   tion, 495 F.2d 213, 217 (6th  Cir. 1974), citing Cooley on Torts, and
   holding that multiple  defendants, emitters of air pollutants, could be
    held jointly and severally liable for numerous individual injuries that
    plaintiffs consequently suffered when the pollutants from their respec-
    tive sources mixed in the air so that their effects in causing the par-
    ticular injuries  were impossible to analyze. See also Borel v,  Fibre-
    board Corp., 493 F.2d 1076 (5th Cir. 1973), where a group of asbestos
    insulation manufacturers who  supplied an insulation contractor were
    held jointly and severally liable to an employee of the contractor who
    got asbestosis,  since  each defendant  contributed to the totality of
    exposure that created the disease. See also Hall v. E.I.  DePont de
    Nemours and Co., 345 F. Supp. 353 (E.D.N.Y.  1972), holding a group
    of explosives manufacturers jointly liable in a  products liability case
    on the ground that the individual manufacturer of the explosive caus-
    ing the injury could not be determined.
17.  In Sindell v. Abbot Laboratories, 163 Cal. Rptr.  132, 160 P.2d 924,
    cert, den., 101 S. Ct. 285 (1980), plaintiff alleged that her cancer was
    caused by her mother's having taken the drug DBS, but plaintiff could
    not prove which company manufactured the particular supply of the
    drug so taken.  The court held that  damages  could  be apportioned
    among all the  defendant manufacturers according  to their relative
    market shares.
18.  Department of  Transportation  v. PSC Resources, Inc., 15 Env't Rep.
    Cas. 1053 (Sup. Ct. N.J. 1980);  State of New  Jersey Department of
    Environmental Protection v.  Ventron Corp., supra note 7.
19.  United States v. Ira S. Bushey & Sons, Inc., 363 F. Supp. 110 (D. Vt.
    1973), 487 F.2d  1393 (2d Cir.  1973), cert, den., 417 U.S. 976 (1974).
20.  Cyr v. B. Offen &  Co., 501 F.2d  1145  (1st Cir. 1974); Ray v.  Alad
    Corp., 19 Cal. 3d22, 560P.2d3, 136 Cal. Rptr. 574(1977).
21.  Canter v. Koehring Co.,  283 So. 2d 716, 721,  quoted with approval
    in Shaefer v. D & J Produce, Inc., 62 Ohio App. 2d 53, 403 N.E.2d
    1015(1978).

22.  Graham v. Allis-Chambers Manufacturing Co., 41 Del. Ch. 78, 188
    A.2d 125, 130(1963).
23.  Preston-Thomas Construction  v. Central Leasing Corp.  518  P.2d
    1125 (Okla. 1973).
24.  Village of Witsonville v. SCA Services, Inc., 396 N.E. 2d 552 (1979).
    The decision and order of the Illinois Appellate Court for the Fourth
    District in this case, printed at 13 Env't Rep. Cas. 1908-1821, was up-
    held on May 22, 1981 by the Supreme Court of Illinois.
25.  Id. at  1818.
26.  W. Rodgers, Handbook on Environmental Law 138 (1977).
27.  Id. at  141.
28.  "Applying this  test, the  district in the  Three  Mile  Island  litigation
    held that it would certify the plaintiffs'  economic claims,  as well as
    claims from medical monitoring of the  possible latent  consequences
    of low-level exposures...." Zener, Stakes High in Civil Suit for  Waste
    Damages, Legal Times of Washington, Dec. 22, 1980, at 17.
29.  Meyer, Compensating Hazardous  Waste Victims, 11 Envtl. L. 689,
    714 (Spring 1981).
30.  Zener, supra note 28, at 2. Faced with this difficulty,  plaintiffs  in the
    Three Mile Island suits are demanding that defendants be ordered to
    provide periodic  medical examinations  to persons who may  have
    been exposed to low-level cancer risk as a result of the TMI accident.
    It remains to be seen whether this novel  type of relief will be decreed
    by the court or  be incorporated in any out-of-court settlement by the
    parties.  "The difficulty with this theory of damages is that periodic
    medical examinations are useful to detect illnesses that may result from
    a wide variety  of causes; it  is  not at all obvious that the defendant
    who may have contributed to a slight increase in one of those causes
    should underwrite the entire range of benefits that these  examina-
    tions provide."  Id.
                                                                                                            LEGAL LIABILITY
                                                                 441
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               COMPENSATING  THE  THIRD PARTY FOR A
                          SUPERFUND CLEANUP FAILURE

                                               JULIE C. BECKER
                                              DAVID VAN SLYKE
                                         Booz, Allen & Hamilton, Inc.
                                                Washington, D.C.
INTRODUCTION
  Under the authority of the Comprehensive Environmental Re-
sponse, Compensation, and Liability Act of 1980,' the USEPA
has been taking actions to clean up the nation's worst hazardous
waste sites. Estimates of the total number of hazardous  waste
sites in the United States range up to a high of 50,000.' Thus far,
however, CERCLA action has been taken only for the most seri-
ously polluted sites.
  Three basic approaches to site cleanup are currently being used:
•A USEPA-led cleanup completed by  the U.S. Army Corps  of
 Engineers or a private contractor
•A state-led cleanup, under a Cooperative Agreement, completed
 by a private contractor
•A voluntary responsible party cleanup action completed by a pri-
 vate contractor or, in a "cash  out" type of arrangement, by the
 Army Corps of Engineers or a contractor hired by the USEPA.
  Despite the variety of approaches available to the USEPA, the
policies and procedures for cleanup of hazardous waste sites are
only beginning to emerge. In a few cases, the USEPA has paid for
the relocation of residents living near a hazardous waste site. Clear-
ly, however, relocation will not always be a feasible or cost-effec-
tive alternative,  and many of  the priority sites will  need  to  be
cleaned up while people continue to live and work in the vicinity.
This situation results in important questions regarding government
and contractor liability to a third party  for a removal  or remedial
action failure, questions that the authors begin to address in this
paper.
  Remedial action may fail for a number  of reasons. It may  be
the result of negligent or faulty design or construction, inadequate
investigation into the problems at the site or  intentional acts  or
omissions to act by  the contractor. For example, the site may be-
come contaminated  again by wastes that the contractor knowingly
left on the site or that the USEPA or  the contractor negligently
failed to locate. Contamination may also occur because structures
designed by the USEPA or the state and installed by the contractor
began to leak.
  The only mechanism currently available  to private parties who
seek redress for this problem is a common law cause of action
against the USEPA, the state or the cleanup contractor. The
answer to the question of who will ultimately be liable for a remed-
ial action  failure, however, depends on a combination of factors
including the party or parties responsible for undertaking the clean-
up (design and/or  construction) and the cause of the remedial
action failure. Of course,  indemnification agreements between the
parties involved in the cleanup may shift the liability.
                                                   THE FEDERAL APPROACH
                                                   TO LIABILITY AND INDEMNIFICATION
                                                     The Federal government may be held liable in several different
                                                   situations for injuries caused by remedial action failure. Common
                                                   law tort theories may be invoked, in certain circumstances,1 against
                                                   a Federal agency. In addition, the Federal kgovernment may be
                                                   held  liable if an indemnification arrangement  has  been  created
                                                   between a government contractor and a Federal agency.
                                                     Under the various common law theories,  the USEPA  and/or
                                                   the Army Corps of Engineers may be held liable for faulty de-
                                                   sign or construction of a remedial cleanup project.4 Third party
                                                   recovery under any of the tort theories, however, is not at all guar-
                                                   anteed. A 1972 Report of the Commission on  Government Pro-
                                                   curement, for example, sets forth several criticisms of the Federal
                                                   government's  response  to catastrophic accidents  occurring in
                                                   connection with Government programs. The Commission  reports
                                                   that victims  often have the burden of proving the cause of injury.1
                                                   For those whose injuries result from Superfund  cleanup activities,
                                                   such  burdens may be insurmountable. The action or inaction of a
                                                   contractor which caused a release of chemicals must be pinpointed
                                                   and the link between post and cleanup chemical exposure  and
                                                   injury must be proved. The result can be years of trial prepara-
                                                   tion and significant expense to the plaintiff.'
                                                     The USEPA, as an indemnitor, may also be held  liable for the
                                                   negligent acts of its contractors. The Agency has adopted a policy
                                                   of indemnifying Superfund contractors for any uninsurable liabil-
                                                   ity.' According to the USEPA Office of General Counsel, indem-
                                                   nification is necessary  because the insurance industry does not
                                                   offer affordable long-term insurance coverage for Superfund sites,
                                                   and contractors have expressed reluctance to bid on remedial ac-
                                                   tions unless such an arrangement is available.' Under this pro-
                                                   cedure, if a contractor is found liable for personal injury or
                                                   property damage resulting from cleanup activities, and the injury
                                                   or damage is not (and was not required to be) insured for by the
                                                   contractor,  the United States will pay the victim on behalf of the
                                                   contractor.
                                                     It  would  seem,  therefore,  that Federal indemnification would
                                                   allow a third party to recover for  injuries  or  damages resulting
                                                   from the acts of USEPA contractors. However, several serious
                                                   obstacles still must be  overcome.  First, under the USEPA in-
                                                   demnification procedures, a third party harmed by remedial action
                                                   failure must bring a successful  legal action against the contrac-
                                                   tor before he can  recover from  the Agency. This invokes all the
                                                   problems inherent in obtaining a judgment based on a common law
                                                   cause of action. Another barrier to  recovery from a governmental
442
LEGAL LIABILITY
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indemnitor is the USEPA's inability to indemnify a contractor for
liability resulting from a willfully negligent act. While the courts
do allow indemnification for negligence, public policy considera-
tions have  led them to prohibit indemnification in cases arising
out of the willful misconduct of a contractor.'
  To illustrate the problem suppose the USEPA contracts to have
wastes removed from a Superfund site and the contractor know-
ingly buries several hundred newly discovered barrels of highly
toxic chemicals in an unsecured area,  contrary to the site cleanup
plan. Suppose, in addition, that the contractor has gone bankrupt
since completing the remedial action and residents living near the
site begin to experience health difficulties. Since the  contractor
was willfully negligent, the government is prohibited from paying
damages proved by the residents. Additionally, the contractor's in-
solvency means that the residents will not have a party from which
to recover.
   A final problem with the Federal scheme is the uncertainty re-
garding the availability of funds for  indemnification. The  limi-
tations imposed by  the Anti-Deficiency Act, together with the
"sunset" provisions  of CERCLA, may  prevent even a successful
third party from enforcing a judgement.
   The Anti-Deficiency Act, which  governs Federal indemnifica-
tion, prohibits an agency from  "entering obligations in excess of
funds available."10 Recovery by victims of a  major incident will,
therefore, be limited to whatever funds remain in the CERCLA
Trust Fund at the tune that judgement is entered against the con-
tractor. In this situation, the third party would also be prohibited
from recovering from general revenue  or from the USEPA budget
unless Congress passes a special appropriation.''
   An additional factor here is the CERCLA  "sunset" provisions
that automatically terminate the taxing power of the Fund in
 1985 unless the  Act is reauthorized.12  Should the Act's taxing
power lapse and the Fund be drawn  down by the costs of con-
tinuing response actions, the victim's ability  to recover becomes
even more  uncertain. A major  lawsuit can take years to proceed
through filing of claims, discovery and trial. In addition, remedial
action failure may not become apparent until  years after the  com-
pletion of  clean-up  operations, at which time  the  Trust Fund
may be depleted.
   The Federal Government's approach is designed for the benefit
 of the government and its contractors  but does little to assure that
 third parties will recover. Any one of the factors discussed above
 (common law burdens of proof,  Federal government  limitations
 on indemnification,  contractor insolvency,   the Anti-Deficiency
Act and the Superfund sunset provisions) could serve as a barrier to
 recovery. In short,  there  are no  guarantees  that a decade  after
 site cleanup either the contractor or the Federal government will
 be available as financially viable defendants.

 THE STATE'S APPROACH TO
 LIABILITY AND INDEMNIFICATION
   In the event that the hazardous waste site cleanup is  undertaken
 by a state under a Cooperative Agreement with the USEPA, the
 state is a potential defendant in a  suit  for injuries suffered due
 to failure of a site cleanup. However, the third party plaintiff may
 also find recovery from a state or state-hired Superfund contractor
 problematic. Contractor's  indemnification agreements, common
 law doctrines and Federal constitutional law all tend to protect a
 state government from lawsuits and do little to aid the individual
living or working near a former CERCLA site.

 State Indemnification Agreements
   States  conducting remedial actions, in contrast to the USEPA,
generally have chosen not to indemnify contractors. Instead, state
indemnification schemes are designed  to protect states  from liabil-
ity for the  acts of their agents. Both  New Jersey and California,
 for example, require Superfund contractors to indemnify the state
 against liability to third parties. Several other states are consider-
ing similar contract requirements.'3
  In contrast, the State of Michigan uses a partial indemnifica-
tion scheme in which the state may be held liable for a design-re-
lated  failure but not for  a construction-related  failure.14 This
scheme may result  in several problems for the third party. For
example, the steps involving the removal of waste  from a site are
part of a "construction" and the complete responsibility of the
Michigan contractor. But if a contractor has become insolvent, the
residents will not have a viable party from which to recover.
  Design-related  failure of a remedial  action  designed by the
USEPA  but implemented by the state also poses a problem, as
Michigan only agrees to indemnify contractors if the project has
been designed by the state.  Since the USEPA designed the remed-
ial action, the state could not be held liable based on the faulty
design.  In addition, the USEPA has concluded that,  under the
Grant  Regulations governing Cooperative Agreements, only the
state and its contractors can be held liable should a cleanup oper-
ation  fail.15  Nor could the third party sue the contractor, whose
only responsibility was construction of the remedial project.
State Government Immunity

  Even in states which do not require the contractor to provide
indemnification, the state may otherwise be protected from liabil-
ity. The doctrine of sovereign immunity and the Eleventh Amend-
ment to the  Federal Constitution can be a bar to recovery for the
plaintiff suing for failure of a state-supervised remedial action.
  The Eleventh Amendment  and Supreme Court decisions inter-
preting it,"  protect a state from being sued  in Federal court by
citizens of that state or any other state unless consent is implic-
itly or explicitly given. Although a third party still  has the option
of suing in  state court, states generally  have  stricter discovery
rules, a less  experienced bench and lower  jury awards.  They are,
therefore, a  less  desirable forum.  While many states  do have
statutes consenting to be sued in specific situations, few accept gen-
eral tort liability. In a state that maintains its Eleventh Amend-
ment  immunity, therefore,  the plaintiff must sue  the contractor
directly and hope that the contractor is still in existence  and has
the financial resources to allow a recovery sufficient to compen-
sate for the injury suffered.
  An additional barrier to suit against a state is the common law
doctrine of sovereign immunity. Based on the ancient English tenet
that "the King can do no wrong," it is intended today to protect
the state from burdensome  interference  with  its governmental
(versus proprietary) functions." Whether a state-run cleanup of an
abandoned hazardous waste site is a  "governmental" or "pro-
prietary" function  has not yet  been determined  by any court.
However, given the purpose  of the cleanup (the welfare  of the
citizens of the state) the governmental nature of the action is rea-
sonably clear and, absent consent, suit would likely_be barred.
  To Illustrate the problem of governmental immunity,  consider
the following example. A remedial action  failure occurs following
a state supervised cleanup operation. In a state that has not waived
its Eleventh Amendment immunity for general tort liability, a suit
in Federal court against the  state would be barred.  The  Federal
forum would also not be available for a suit against the contrac-
tor unless  diversity  or  Federal  question jurisdiction could  be
established.18 If, upon bringing suit in the less desirable state court
forum, the site cleanup is determined to be a governmental func-
tion,  suit against the  state would likely be dismissed under the
doctrine of sovereign immunity. A suit against the Superfund con-
tractor  in state  court would generally be the  last resort of the
injured resident. However, even if the plaintiff(s) could afford the
time and expense of a trial and is able to show  causation, recov-
ery will depend on the solvency of the contractor and the extent and
applicability of its insurance coverage.

PROPOSED SOLUTIONS AND RECOMMENDATIONS

  A single, uniform approach to state and Federal response in the
event of a remedial action failure is clearly needed. The approach
should be designed to maximize competition among contractors
                                                                                                 LEGAL LIABILITY
                                                          443
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while allowing the public to recover for personal injuries. Ideally,
this program will include the following elements:
•An administrative process for direct victim compensation
•Preservation of existing common law remedies
•Financial responsibility requirements for Superfund contractors
  The first two points are addressed in a broader sense in the recent
CERCLA section 301(c) report to Congress on victim compensa-
tion."  The authors' recommendations for these three elements,
discussed below,  are focused strictly on  the issue  of compensa-
tion for Superfund cleanup failures.

Recommendation 1: Establish a Federal Administrative Process
for Direct Victim Compensation
  The Commission on Government Procurement recommends that
the Federal Government provide more prompt financial assistance
to victims of disasters  caused  by Federal activities.  In proposing
"the creation  of a speedy and effective"  administrative remedy,
the Superfund Section  301(e) Study Group reaches a similar con-
clusion."
  The  administrative  system  that  we propose would have  the
following elements:
•A Federally managed victim compensation review board to review
  claims of individuals allegedly injured  by  Superfund  cleanup
  failures
•An administrative process for verifying and reviewing claims
•A level of proof that  recognizes the latency and randomness of
  chronic hazardous waste injuries
•A finite (12 month) period of time for agency review of the claim
•A ceiling on the recovery amount per episode
   Each of these elements has  some precedent in Federal disaster
relief programs or other Federal law, as described below.
   The Teton Dam Act" authorized the Secretary of the Interior or
his designee to investigate claims and make compensation for dam-
ages arising out of the failure of the Teton Dam. The regulations
promulgated under the Act set up an administrative review system
to "investigate, consider, ascertain, adjust and settle" any claims
made." Similarly, the Texas City Disaster Relief Act" authorized
the Secretary of the Army or his designee to investigate and settle
claims against the United States resulting from the death, personal
injury  and property damage associated with the explosion and fires
in the  Texas City dock incident.  In addition, Administrators of
Federal agencies  have  been given  the authority to settle general
tort claims."
   Under the Teton Dam Act  and  the Texas City Disaster Relief
Act, once the injured  party presented  his or her claim, the sole
responsibility of the administrative review system was to determine
three items:
 •Whether the losses sustained resulted from the incident
 •The amounts to be paid
 •The person entitled to receive the award
   The system  proposed here would set up a review board to make
awards based using the same criteria.
   The basic  problem  encountered  in applying that system to a
Superfund cleanup failure scenario, however,  is the uncertainty in
determining that the injuries in fact resulted from the failure of the
cleanup. To alleviate that problem, the authors propose a system
that would compensate those persons who suffer injuries from ex-
posure to toxic chemicals from hazardous waste sites but would not
require victims to prove that their  specific  injuries had  been
caused by a CERCLA  cleanup failure. The system would compen-
sate victims of a hazardous waste cleanup failure according to the
exposure received by  each. The exposure received could be de-
termined according to  each victim's location during and following
the cleanup.
   Contrary to available common law remedies, only proof of ex-
posure, not proof of  causation would be required.  The review
board  analyzing these  claims would be charged with determining
which  of the diseases or other injuries were sufficiently related to
the type of particular exposures experienced to warrant compen-
sation.
                                                         For example, anyone who had lived within a certain  radius of
                                                      the site for a certain period of time during or after the cleanup
                                                      would be entitled to full compensation if their particular injury
                                                      was determined to be sufficiently related to the exposure exper-
                                                      ienced, even though the exposure could not be isolated  as the
                                                      cause. This system is somewhat imperfect because it would also
                                                      compensate those persons living near the site during the cleanup
                                                      whose injuries may have originated from problems caused by the
                                                      original waste site, rather than the cleanup failure. Nevertheless,
                                                      the administrative system would avoid the need to select the proper
                                                      party or parties responsible for the release, and the relaxed stand-
                                                      ards of proof would help to assure residents that the government
                                                      will take ultimate responsibility for its activities.
                                                         The proposed system  would also require the review board to
                                                      determine the validity of the claim and the award  amount within
                                                      one year of presenting the claim. Similarly, the Teton Dam Act re-
                                                      quired the Secretary of the Interior to  determine  awards within
                                                      one year after the claim was filed. The Texas City  Disaster Relief
                                                      Act imposed like requirements upon the Secretary of the Army.
                                                         To limit the ultimate liability of the Federal government, ceil-
                                                      ings could be established based on the type and extent of the claims.
                                                      The Price-Anderson  Act," which sets a limit of $560 million per
                                                      accident, might serve as a model for the establishment of a ceiling.
                                                      In the alternative, Congress could set a  limit for  each claimant.
                                                      Both the Teton Dam Act and the Texas  City Disaster Relief Act
                                                      establish limits on the amount an individual may claim.
                                                         Experience with these statutes indicates that the public may view
                                                      a  ceiling on compensation as an indication  that they will not be
                                                      fully compensated for hazardous waste injuries. When balanced
                                                      against the delay and costs of a trial and the problem of proving
                                                      causation, however, an administrative remedy that nevertheless in-
                                                      cludes a limitation on total government liability becomes more
                                                      attractive. In addition, as discussed below, the opportunity to pur-
                                                      sue traditional legal remedies is not foreclosed.
                                                      Recommendation 2: Preservation of Existing
                                                      Common Law Remedies
                                                         The administrative program outlined above is not intended to be
                                                      the exclusive remedy for the victim of a hazardous waste cleanup
                                                      failure. The existing common law tort  remedies should also be
                                                      available,  and victims should be able to bring direct civil actions
                                                      against parties who have allegedly injured them." This scheme is
                                                      similar to that recommended by the Section 301 (e) Study Group in
                                                      its "Tier II" system.
                                                         To alleviate one of the critical problems in traditional toxic torts
                                                      litigation, the Federal legislation  creating the proposed  system
                                                      should also adopt a  statute of limitations that employs the "dis-
                                                      covery rule" and that preempts any state statute of limitation for-
                                                      bidding the maintenance of an action prior to three years  follow-
                                                      ing discovery of an injury."

                                                         Recommendation 3: Financial Responsibility
                                                      Requirements for Superfund Contractors
                                                         To help ensure that Superfund cleanup contractors are reliable
                                                      and financially able to compensate injured parties for at least a
                                                      portion of the damage that might result from a  CERCLA cleanup
                                                      failure, the USEPA may require a contractor  to prove financial
                                                      viability or maintain some type of extended financial protection
                                                      such as pre-paid long term insurance. The Price-Anderson Act,
                                                      for example,  requires Nuclear Regulatory Commission licensees
                                                      to maintain financial protection  in "the amount  of liability in-
                                                      surance available from private sources."2'
                                                         This approach has also been applied to hazardous waste disposal
                                                      in the Resource Conservation and  Recovery Act,  which requires
                                                      disposal facility operators to obtain $6  million of liability cover-
                                                      age." Similar provisions are found in Section  108 of Superfund,
                                                      which requires operators of vessels being used to transport haz-
                                                      ardous wastes  to present  evidence of  financial responsibility
                                                      amounting  to a minimum of $5 million in coverage. This section
                                                      also authorizes  the President to  establish  financial responsibility
 444
LEGAL LIABILITY
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requirements for closure of an approved hazardous waste facility.30
By  imposing  financial responsibility requirements on Superfund
contractors, the government  would be better  able  to ensure re-
covery  to those  who suffer  personal injuries and/or  property
damage resulting from a remedial action failure.

CONCLUSION

  Toxic torts are receiving much attention in  Congress.3' If one
of the bills now  being  considered is  adopted, it should include
some provision for hazardous waste cleanup failure, such as the
program the authors have suggested.
  To implement  the above  recommendations,  Congress would
need to devise a system for resolving claims, establish reasonable
ceilings on recovery, develop  some  means to assure contractor
solvency and  make other basic decisions regarding how best to
compensate the victim of a removal or remedial action failure.
  This paper,  however, is not intended to be a definitive answer
to the problem of  third party recovery. It is  clear, nonetheless,
that hazardous waste cleanup operations pose  a  serious threat to
those living or working nearby and that the common law and state
and federal indemnification schemes currently fail to provide  ade-
quate assurance that the public will be compensated for personal
injuries or property damage resulting from such activities. A more
direct compensation scheme would help to provide a quicker, more
predictable mechanism for third party compensation.

REFERENCES

  1.  42 U.S.C. 9601 etseq. (1980).
  2.  Preliminary Assessment of Cleanup Costs for  National Hazardous
    Waste Problems, USEPA Office of Solid Waste,  Fred C. Hart Assoc.,
    EPA Contract No. 685-01-5063, 1979.
  3.  The Federal Tort Claims Act, 28  U.S.C.§§1346(b), 1402, 2401, 2671-
    2680, is a limited waiver of sovereign immunity, allowing  liability to
    be incurred,  under certain circumstances,  for the  negligence of Fed-
    eral government employees or agents.
  4.  Section 107(d) of Superfund  appears to protect the Federal Govern-
    ment and its contractors from liability. However, in the opinion of the
    USEPA Office of General Counsel, Section 107(d) probably does not
    protect EPA or its contractors from  private  rights of action under
    ordinary tort principles. Nantkes, Donnell L.,  "Indemnification of
    Superfund  Contractors," Internal USEPA Memorandum, June 26,
    1981.
  5.  Report of  the  Commission  on Government  Procurement,  4,  Dec.
    1972, 99-104.
  6.  For  further discussion on the difficulty of invoking common law
    remedies in hazardous waste cases, see Comment, "Hazardous Waste
    Liability and Compensation:  Old  Solutions, New Solutions, No Solu-
    tions," 14 Conn L. Rev. 307 (1982).
  7.  See, Nantkes, supra. Note 4.
  8.  See, Nantkes, supra. Note 4.
 9.  Globus v. Law Research Service, Inc., 418 F.2d 1276, 1288 (2d Cir.
    1969), cert, denied, 397 U.S. 913 (1970); Stamford Board of Educa-
    tion v. Stamford Education Assoc., 697 F.2d 70 (2d Cir. 1982).

10.  31 U.S.C. §665 (a) (1974).
11.  54Comp. Gen. 824, 826-27(1975).
12.  42 U.S.C. §963l(b)(2) (1980); 26 U.S.C. §§ 461 l(d),4661(c) (1980).
13.  Sanders, D.E., Sweeney, F. and Hillenbrand, E., "Protection from
    Long-Term Liability as a  Result of Superfund  Remedial Actions,"
    Proc. of the  National Conference on Management of Uncontrolled
    Hazardous Waste Sites, Nov. 1982, 46M62.
14.  Id.
15.  Id.
16.  See, e.g., Parden v. Terminal K. of Alabama State Docks Dept.,
    377 U.S. 184, reh. denied, 377 U.S. 299 (1964).
17.  While the doctrine is currently in judicial  disfavor, most states have
    enacted legislation to retain some form of  sovereign immunity. For a
    more complete discussion, see Prosser, Torts §131 (4th ed. 1971).
18.  28 U.S.C.  §1331  (1980) (Federal  question jurisdiction); 28 U.S.C.
    §1332 (1976) (diversity jurisdiction).
19.  Senate  Comm. on Environment  and Public Works, Inquiries and
    Damages from Hazardous Wastes—Analysis and Improvement  of
    Legal Remedies—A Report by the Section 301(e) Study Group,  S.
    Doc. No. 12, 97th Cong., 2nd Sess. (1982).
20.  The  301(e) study group proposed a two part system. Tier I, an admin-
    istrative system, is based  on the  use of rebuttable presumptions  to
    prove  causation.  Tier II  keeps intact the traditional common law
    remedies.
21.  Pub L. No. 94-400, 90Stat.l211 (1976).
22.  43 C.F.R. §419(1977).
23.  Pub. L. No. 84-378, 69 Stat.707 (1955).
24.  28 U.S.C. §§2672, 2675 (1966).
25.  Pub. L. No. 85-256, 71 Stat. 576 (1957) (current  version at 42 U.S.C.
    §§2012(i), 2014(j), (m), (p), (q), (t), (w), 2210 (1970 & Supp. V 1975)).
26.  Similar to the procedures instituted in the National Swine Flu Immuni-
    zation Program of 1976, claims should be presented to the adminis-
    trative review board before a legal action is brought. See, 42 U.S.C.
    §247(b) (1976). See also,  28  U.S.C. §2672 (1966) (Administrative
    adjustment of claims under the Federal Tort Claims Act).
27.  SeeH.R. 2330, 98th Cong., 1st Sess. (1983).
28.  42 U.S.C. §2210(b) (Supp. V 1975).
29.  40 C.F.R. §264.147(b), as  revised  in 47 Fed. Reg.  16554 (April  16,
    1982).
30.  42 U.S.C. §9601, 9608(a) and (b) (1980).
31.  See, e.g., S. 917,  98th Cong., 1st  Sess. (1983);  S. 945, 98th Cong.,
    1st Sess. (1983); H.R. 2482, 98th Cong., 1st Sess. (1983);  H.R. 2330,
    98th Cong., 1st Sess. (1983); H.R. 2582, 98th Cong., 1st Sess. (1983).
                                                                                                       LEGAL LIABILITY
                                                              445
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                 INDICATOR METHODS FOR POST-CLOSURE
                        MONITORING OF GROUND WATERS

                                                   IHORLYSYJ
                                       Rockwell International Corporation
                                 Environmental Monitoring & Services Center
                                            Newbury Park, California
INTRODUCTION
  In order to assure protection of groundwater from contamina-
tion  by leachates from hazardous waste  disposal  facilities, the
USEPA has issued two  regulations:  40CFR264  and 40CFR265
covering both legal responsibilities and technical requirements for
such protection. Specifically, these regulations require owners and
operators of waste disposal facilities to design and implement either
detection or implementation programs.
  Detection programs are used at facilities where existence of con-
tamination is unknown, while assessment  programs are directed
at facilities  where groundwater contamination is  known to have
occurred due to the operation of the waste disposal facility. The
detection program is, in essence, a diagnostic measure, while the
assessment  program quantifies  the degree of damage done to
groundwaters. In this paper, the  author addresses the first topic,
that is the detection of groundwater contamination. The discussion
applies equally to monitoring of operating  interim status facilities
and required monitoring during long post-closure periods.

TECHNICAL SCOPE
  The  technical scope of monitoring requirements is defined in
Subpart F of both regulations. This subpart specifically addresses
technical aspects of groundwater monitoring in the context of the
subject regulations. The regulations address three distinct sets of
tests associated with determining groundwater quality:
1. Parameters characterizing the suitability of the water as drink-
   ing water
2. Parameters used to characterize groundwater quality
3. Parameters used as indicators of groundwater contamination
  In the first group of parameters (drinking water suitability),
one  finds a number of metals  which  are known  as toxicants
(arsenic, barium, cadmium, chromium, lead, mercury, selenium
and  silver); two anions (nitrate  and flouride); and a number of
pesticides (Endrin,  Lindane, Methoxychlor,  Toxaphene,  2.-4D,
2,4,5-TP Silvex). Additionally, water is monitored  for its radio-
logical  characteristics (radium, gross alpha and gross beta radia-
tion) as well as coliform bacteria.
  In the second group (general  water quality parameters), there
are two anions (chloride and sulfate), three metals (sodium, iron
and manganese) and one organic compound (phenol).
  The third group (indicator parameters of groundwater contam-
ination) comprises four general water characteristics( pH, specific
conductance,  Total Organic Carbon  (TOC)  and Total Organic
Halogen (TOX). These four indicator parameters reflect changes
in the  organic and inorganic make-up  of groundwater and are
used to detect any effect of facility operation on groundwater qual-
ity. The indicator approach to monitoring groundwater contam-
ination is based on measurement of changes  in respective values
of pH, specific conductance, TOC and TOX, since all ground-
waters possess some nominal values in each category. To be effec-
tive as a tool of monitoring and detection,  the indicator approach
presupposes  that changes and fluctuations in the  pH,  specific
conductance, TOC  and TOX induced by  natural phenomena in
groundwater are minimal and insignificant,  and that the magnitude
of such naturally induced fluctuations can be compensated for and
                                                     statistically differentiated from changes induced by intrusions of
                                                     hazardous and toxic species from waste disposal facilities.

                                                     INDICATOR PARAMETERS
                                                       The basis for indicator parameter selection is a belief that signif-
                                                     icant discharges from hazardous waste management facilities to
                                                     the groundwater will often result in an observable change in at
                                                     least one of the four selected indicators: pH, specific conductance,
                                                     TOC and TOX. It is further believed that there is a small probabil-
                                                     ity that major discharge could occur without significant change in
                                                     at  least one of the four indicators in groundwater samples. The
                                                     conceptual approach to design of indicator monitoring protocol is
                                                     based on responsiveness to a large number of largely undefine-
                                                     able  sets  of  chemical compounds at  unspecified concentration
                                                     levels which can be classed in general terms: ionic, nonionic, organ-
                                                     ic, inorganic and suspended or dissolved in groundwater.
                                                       As described in the  "Groundwater  Monitoring Guidance for
                                                     Owners and Operators of Interim Status Facilities",1 pH and spe-
                                                     cific  conductance were chosen for monitoring of inorganic con-
                                                     stituents because they satisfy all basic requirements for being ac-
                                                     ceptable test procedures, and there are no alternative inorganic
                                                     indicators that can provide equivalent information value. The pH
                                                     affects solubility and mobility of many toxic constituents of waste
                                                     and determines the rate and outcome of chemical reactions the
                                                     pollutant will undergo. Specific  conductance is a numerical ex-
                                                     pression of the summation of contributions from all ions present in
                                                     a solution. Since such a measurement is an additive property, it is
                                                     useful as an  indicator parameter because it can determine  effec-
                                                     tively all ions simultaneously.
                                                       TOC was  chosen as an  indicator parameter for organics be-
                                                     cause of its widespread use, acceptability as an effective test pro-
                                                     cedure and general applicability to all types  of organic contam-
                                                     ination. It is one of the few parameters that provides a  broad
                                                     description of the organic content of water and is replacing chem-
                                                     ical oxygen demand (COD) in groundwater  analysis. TOC pro-
                                                     vides a more direct expression of organic content than COD, is
                                                     more sensitive and is a less difficult procedure.
                                                       TOX was  selected to measure only  those  organic compounds
                                                     containing halogens. Despite the somewhat more limited use of
                                                     TOX, it is included among the four indicators in view of the rela-
                                                     tively large amount of hazardous wastes which may contain halo-
                                                     genated hydrocarbons and  the higher  degree of toxicity usually
                                                     associated with these compounds.
                                                       It must be recognized that the proposed approach of indicator
                                                     parameter monitoring is based on measuring changes in various
                                                     relevant parameters and presupposes that such changes  deriving
                                                     from natural phenomena will be statistically insignificant, while
                                                     parameter changes deriving from intrusions of hazardous and/or
                                                     toxic substances will be statistically significant.  Because of the
                                                     largely statistical justification of the technological validity of the
                                                     proposed approach, the regulations devote significant amounts of
                                                     importance to statistical analysis. It is postulated that the owner or
                                                     operator  of  a facility must perform a statistical analysis of the
                                                     concentrations  or  values of indicator  parameters as determined
                                                     from  the sampling and analysis of required monitoring  weUs.
                                                     Specifically,  the Section 265.92(c)(2) on sampling and analysis re-
446
POST-CLOSURE
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quires mat tne initial background mean and variance for each in-
dicator parameter be  determined by pooling  the replicate meas-
urements for the respective parameter concentrations in samples
obtained from the upgradient well(s) during the first year. Repli-
cate analyses are not required  for downgradient wells during the
first year.
  After the first year of monitoring, the owner or operator is re-
quired to analyze for and calculate the mean and variance of each
indicator parameter (i.e., pH, Specific Conductance, TOC and
TOX),  based on at least four replicate  measurements  on each
sample, for each well in the monitoring system. Results  for each
indicator parameter from each sampling event  (for each and every
well in  the monitoring system)  must be compared with the initial
background mean (i.e., that established for the upgradient well(s)
during  the first  year).  The "Student's t"  test  at the 0.01 level of
significance must be used to determine statistically  significant in-
creases over the initial background values.
  The approach to indicator monitoring for detection of hazardous
and toxic wastes intrusion into groundwater as proposed by the
EPA is practical and based on sound theoretical considerations;
however, physical evidence in a form of supportive data must be
developed to support this concept. The critical element of the pro-
posed scheme is degree and magnitude of background fluctuations
of selected parameters  (pH, specific conductance, TOC and TOX)
induced by natural phenomena and independent of any intrusions
of hazardous waste that might or might not have taken place.
   To satisfy a need for  such supportive evidence, the USEPA is
conducting an effort to determine background groundwater qual-
ity data  for  indicator parameters from  interim status  facilities
across the country in order to establish distribution of concentra-
tions or values of these parameters over a period of time. With this
information  on actual fluctuations in the chemical  content of
groundwaters, the USEPA will be able to determine  the number of
facilities for which the specified statistical compensation procedure
is appropriate and to  further identify alternative data evaluation
and comparison procedures for  those situations where  the pro-
cedures specified in Regulation 265.93 may not be appropriate.
A principal component of this evaluation will be an estimate of
the "false positive"  and "false negative" probabilities for various
statistical procedures in various circumstances of groundwater var-
iability over time.
   This ongoing effort will most likely result  in amendments to
the USEPA regulations regarding monitoring of groundwater (sub-
part F) and revisions in related documents.
   In instances where it is currently known that applicability of the
indicator  monitoring  approach  is  unacceptable   on technical
grounds, the USEPA suggests use of alternative groundwater mon-
itoring schemes. Specifically,  it is stated that: "If an owner or
operator assumes (or knows) that groundwater monitoring of indi-
cator parameters...would show statistically significant increases...
he may install, operate and maintain an alternate groundwater
monitoring system (other than the  one described  in 265.91 and
265.92)."
   This paper addresses potential technical approaches to such al-
ternative indicator parameter monitoring.

DIFFERENTIATING INDICATOR METHODS
   The proposed USEPA methods for indicator parameter moni-
toring  of groundwater are nondifferentiating, i.e., the  methods
cannot  discriminate between fluctuations in  specific parameters
induced by the natural phenomena and those produced by the in-
trusions of hazardous and/or toxic wastes into groundwater. Such
nondifferentiating methods are applicable only to the situations
where normal fluctuations in  background chemistry of ground-
water are minimal and statistically insignificant. They cannot be
used effectively in any other instances.
  In situations where normal background fluctuations in the chem-
istry of groundwater are significant, an indicator method must be
capable of differentiating between fluctuations induced by the
normal natural process and those produced by hazardous waste in-
trusions. The theoretical and practical technological capabilities
for such a differentiation do exist at this time.
  First, the theoretical aspects of this problem will be considered.
The normal and natural organic background content of unpolluted
waters derives mainly  from biomass activity and  decomposition
and decay of vegetable matter. In a series of classic studies, Birge
and Juday2 established almost a half a century ago that natural
organics  found in lakes are composed largely  of carbohydrates,
proteins and lipids. Additional supportive evidence was developed
in the early seventies using the pyrographic  method of analysis
by Lysyj.3  These studies disclosed that while  the  quantitatively
organic content of natural waters fluctuates from source to source
and season to season, it remains similar in qualitative terms. Prin-
cipal classes present in all cases examined were found to be carbo-
hydrates, proteins and lipids.
  Unlike the organic matter derived from natural sources in water,
the organic matter found in  hazardous waste is largely of man-
made origin and is chemically significantly different from that of
natural origin.
  In hazardous wastes, one finds a predominance of hydrocarbons
(both aliphatic and  aromatic), halogen compounds, pesticides,
ketones, aldehydes, substituted aromatic compounds and a variety
of specialty chemicals.
  Consequently, there exists  a significant  qualitative differential
between organics found naturally in the groundwater and those
found in hazardous  wastes. Because of this fact, differentiation
between  types of  organic  matter to be found in contaminated
groundwater is possible using the theory of multicomponent pat-
tern recognition and differentiation.
  This theory postulates that matter of discrete composition can
be characterized qualitatively and defined quantitatively by con-
sidering the overall pattern formed by the individual components
of such composition. For example, in natural waters contaminated
by the intrusion of leachates from a hazardous waste site, one can
expect to find a number of  organic compounds contributed by
hazardous waste and a number of organic compounds derived from
natural sources. The overall patterns  formed by each of two such
compositions of matter will be different and,  when  developed by
physical means, should be differentiable by application of suitable
mathematical techniques.
  In most cases where pollution of groundwater took place,  the
subset of organic matter derived from natural sources will be de-
finable, while subset or organic matter derived from intruding
hazardous waste will be undefinable. The overall effect will be dis-
tortion in a definable pattern of natural organic background of a
given water source. Such a pattern distortion will signify that pollu-
tion of groundwater by man-made chemicals took place. In situa-
tions  where the nature of intruding hazardous waste is known or
suspected, the system could  be calibrated for both subsets  of
naturally derived organics, and the subset of organics derived from
a hazardous waste source and both multicomponent compositions
could be treated quantitatively. The quantitative fluctuations in
the background organic content of a given source of groundwater
will not have  a  detrimental effect on such determination, since
qualitatively the pattern produced by such organics will remain
essentially the same.
Pyrographic Analysis

  The physical means for  making such a water sample examina-
tion  exist. A pyrographic  method of analysis  developed in  the
early  seventies under USEPA sponsorship has  been successfully
used for gross characterization of unpolluted surface water in the
southeast part of the United  States,  as well as  for detection and
characterization of waste discharges into such waters."
  Briefly, the pyrographic method of analysis, as applied to water
analysis, is a multidimensional technique. It permits definition of
both the magnitude and the nature of the phenomena being ob-
served and, as such, is quite suitable as a method for determina-
                                                                                                   POST-CLOSURE
                                                          447
-------
tion of hazardous waste intrusions in  instances when  significant
fluctuations in the background  chemistry  of groundwater are
known to take place.
  Two principal dimensions of the pyrographic method are:
1. Intensity of the signal
2. Pattern of the signal
  The intensity of  the signal relates to concentration, while the
pattern of the signal relates to the qualitative nature of the material
being analyzed. For example, the natural organic content of sur-
face  water could  change by orders of  magnitude between winter
and summer months  in a  temperate climatic zone. When such
waters are analyzed, this change will be reflected in the intensity
of pyrographic peaks, but not in the patterns themselves. The ratio
or proportion of peaks will remain constant, since similar organic
matter (derived from biomass activity) is being analyzed, and only
the amount or quantity of produced matter is being changed.
  Consequently,  programs  reflecting different levels of naturally
derived organic matter will be of different intensity, but constant
in pattern.  When external  pollutants  are  introduced into such
water, both the peak intensity and the peak pattern will change
since, in this case, we are analyzing a sum of two dissimilar com-
positions.  It is  this two-dimensional  capability  of pyrographic
methodology  that provides a  basis for differentiation  between
compositional fluctuations attributable  to natural phenomena and
compositional fluctuations produced by external events.
  There are a number of mathematical and statistical approaches
available for handling and  interpretation of pyrographic data. A
tailor-made approach could  be developed for  meeting the require-
ments.
  A visual examination  of pyrographic patterns provides the sim-
plest  form of detection of  the presence of hazardous waste (or
other man-made  pollutant)  in natural water.  If no pollution (in-
trusion of hazardous waste) took place in groundwater, the pyro-
graphic pattern will match that produced by analysis of unpolluted
water. If ground or surface water has been contaminated  by man-
made organic matter, the  pyrographic pattern will be distorted
and the ratios and magnitudes of the peaks will be different from
those of natural unpolluted waters.
  The next step in the sophistication of pyrographic data handling
is to  calibrate the  pyrographic instrument in terms of principal
classes  of organic matter found in unpolluted waters: carbohy-
drates, proteins and lipids, and then subtract patterns produced by
those three classes of organic matter from the overall (total) pat-
tern produced by water sample analysis. Where there is no intru-
sion of hazardous  substances and  the only contributions  to the
pyrographic pattern are made by naturally derived organic matter,
mathematical manipulation  of the data will produce a blank, i.e.,
a calibrated pattern will  be subtracted from the pattern of analyzed
water, and no peaks will appear on the  graph. Where organic mat-
ter of a man-made nature is to be  found in a water sample con-
taining natural organic background of carbohydrates, proteins and
lipids, mathematical  manipulation of data will  remove natural
organic contributions to the pattern, and much of the pattern will
consist only of contributions  from man-made sources. The pro-
duced pattern will signify intrusions of hazardous  substances into
groundwater. It  could  be  further interpreted in  qualitative and
quantitative terms.
   Where  the nature of the chemical waste present at a given haz-
ardous waste  site is known  and a sample of such  is available for
calibration, a complete qualitative and quantitative analysis of
organic matter in a water sample is possible. The instrumental sys-
tem is calibrated  in the  usual manner for carbohydrates, proteins
and  lipids and additionally  calibrated  for one or more suspected
hazardous waste compositions. After the analysis is performed, the
concentrations of natural organics and contaminants are computed
using calibration constants in the mathematical logic.
  The instrumentation  hardware used for  performance  of pyro-
graphic analysis is relatively simple. The system consists of a spe-
cially designed injector  which  provides for  a  uniform and consis-
                                                        tent mode of introducing a water sample into a pyrolysis tube.
                                                        The pyrolysis tube is made of nickel and is filled with nickel shots.
                                                        It is usually maintained at a temperature of 600 °C in an appro-
                                                        priate heating mantle. The effluent from the pyrolysis tube enters
                                                        the gas chromatographic column where, produced by pyrolysis,
                                                        molecular fragments are separated and then detected by the hydro-
                                                        gen flame ionization detector. The compressed gases required for
                                                        the system operation are high purity hydrogen, nitrogen and oxy-
                                                        gen. The signals produced as a result of pyrographic analysis are
                                                        amplified by an electometer and recorded either in analog or dig-
                                                        ital  form. An Apple II microprocessor was used  for storage of
                                                        mathematical logic, calibration constants and computation of re-
                                                        sults.

                                                        DISCUSSION
                                                          The indicator parameters monitoring approach to detection of
                                                        hazardous waste intrusions into groundwater is theoretically sound
                                                        and practical in terms of operational requirements. It  is designed
                                                        to detect complex chemical compositions of an undefined nature in
                                                        a water matrix. The selected parameters (pH, specific conductance,
                                                        TOC and TOX) represent well established  methodologies, with
                                                        on-the-shelf equipment available. The procedural steps are simple
                                                        and can be performed by personnel with  minimal technical train-
                                                        ing. The alternative approach of detailed chemical analysis  for
                                                        over 300 hazardous chemical species designated under RCRA Reg-
                                                        ulations is neither operationally practical, nor economically feas-
                                                        ible.
                                                          While these considerations lead to the selection of an  indicator
                                                        parameter approach in monitoring groundwater, the limitations of
                                                        the specified techniques cannot  be overlooked. The techniques,
                                                        as proposed, are suitable only in a limited way in situations where
                                                        natural fluctuation in the background chemistry of groundwater is
                                                        minimal and statistically insignificant. There will be many instances
                                                        where this is not the case, and differential approaches  to detec-
                                                        tion of toxic intrusions into groundwater must be explored.
                                                          At this time, it appears that the differentiating approach to de-
                                                        tection of contaminants in groundwater offers the best technical
                                                        avenue in situations where natural fluctuations in the chemistry of
                                                        groundwater are significant. Such an  approach can provide  the
                                                        means for differentiation between fluctuating natural organic back-
                                                        ground of  water and organic matter  intruding from hazardous
                                                        waste sites. Use of multicomponent pattern recognition and  the
                                                        differentiation  theory in conjunction  with pyrographic analysis
                                                        for organic content of water samples makes such a task possible.
                                                          The theoretical foundation and proven instrumental hardware,
                                                        mathematical logic for data handling and computer processing
                                                        methodology for data reduction exist.' The principal problem with
                                                        the use of this approach is that the general public is largely unfamil-
                                                        iar with this methodology, and that the  multicomponent pattern
                                                        recognition and differentiation is conceptually more complex than
                                                        conventional analysis for pH, TOC or TOX.
                                                          In order to  develop practical means  for indicator parameter
                                                        monitoring in the  groundwater,  which fluctuates significantly in
                                                        its chemical  content,  a  practical  demonstration of  proposed
                                                        method capabilities must be performed in the real-life scenario of
                                                        the hazardous waste site environment.

                                                        REFERENCES
                                                        1. "Groundwater  Monitoring Guidance for  Owners and Operators of
                                                          Interim Status Facilities", USEPA, Washington, D.C.  1982.
                                                        2. Birge, E.D., and  Juday, C., Ecological Monographs, 4, No. 9, 1930,
                                                          63.
                                                        3. "Pyrographic Gross Characterization of Waste Contaminants", EPA-
                                                          R2-73-227, USEPA, Washington, D.C., 1973.
                                                        4. Lysyj, I., "Pyrographic Analysis of Waste Waters", Env. Sci. Tech.,
                                                          5,1974,31.
                                                        5. Lysyj,  I., Newton,  P.R.,  and Taylor, W.J., "Instrumental—Com-
                                                          puter System  for Analysis of Multicomponent Organic Mixtures",
                                                          Analytic Chemistry, 43, 1971, 1277.
448
POST-CLOSURE
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            POST-CLOSURE MONITORING RESEARCH NEEDS
                  FOR HAZARDOUS WASTE DISPOSAL SITES

                                         JOHN D. KOUTSANDREAS
                                    U.S. Environmental Protection Agency
                             Office of Monitoring Systems and Quality Assurance
                                               Washington, D.C.
                                          PETER J. MAVRAGANIS
                                        WILLIAM A. BAILEY, Ph.D.
                                            SRA Technologies, Inc.
                                               Arlington, Virginia
 INTRODUCTION

  Monitoring is the most important aspect for compliance assess-
 ment of hazardous waste land disposal facilities. A recent work-
 shop revealed that monitoring systems should be in place at a facil-
 ity prior to the initiation of operations, continue throughout its
 operational life and remain on through the post-closure period for
 as long as public health and the environment is at risk. In Super-
 fund sites subjected to remedial action, this same type of monitor-
 ing  program  is applicable.  The importance of monitoring  haz-
 ardous wastes facilities created a demand to develop improved
 monitoring systems capable of delivering accurate quality-assured
 data over long periods as cost effectively as possible.
  Post-closure monitoring is concerned principally with long term
 monitoring for groundwater protection. This requires that a sys-
 tems approach toward monitoring be employed consisting of an
 adequate mix of monitoring technologies throughout the monitor-
 ing period. These technologies must employ measurement methods
 designed to provide the quality of data necessary to  assure that
 the  risk of groundwater  contamination is minimized. Thus, for
 post-closure monitoring to be effective it is essential that sufficient
 data be acquired during site characterization to provide the con-
 tinuum of data required to determine the status of a site and the
 risk to public health and the environment.
  With this in mind, the USEPA's Office of Research and Devel-
 opment, Office of Monitoring Systems and Quality Assurance has
 embarked on a monitoring research task which will provide guide-
 lines for post-closure monitoring of hazardous waste facilities. As
 part of this task, a report was recently completed which identifies
 monitoring research needed to provide the essential data discussed
 above. The gaps in current monitoring technology were identified
 and research actions designed to fill those gaps were developed.

 RESEARCH NEEDS FOR RCRA
 LAND DISPOSAL MONITORING
  This workshop also revealed the need for long-term monitoring
 at hazardous waste disposal facilities. It was established that mon-
 itoring systems should be  designed and installed prior to the oper-
 ational use of the facility.
  For sites that have been abandoned and subsequently subjected
 to remedial action, many of the same  types of monitoring would
 pertain to the facility.  As a result, these monitoring techniques
 will be  discussed and, where possible, examples will be given.
  Although most of the current research conducted in this  area
focuses on in  situ groundwater monitoring, there is concern that
the research program should actually be addressing groundwater
protection monitoring.  Consequently, this paper also  presents
recommendations on research tasks that will help to  implement
programs that will lead to early detection of contaminants through
monitoring before these pollutants reach the groundwater. These
tasks are identified primarily in the vadose zone (unsaturated zone)
monitoring, geophysical/geochemical and remote sensing research
areas. As toxic gases emanating from  landfill sites may escape to
the ambient air, research into air emissions is also included in this
paper.
  Specific research topics and general research areas concerning
monitoring can be grouped into six general areas:
1.  Groundwater Monitoring in the Saturated Zone
   a. Sampling Procedures
   b. Network Design for Groundwater Monitoring
2.  Vadose Zone Monitoring
3.  Indicator Parameters and Hazardous Constituents
4.  Advanced Monitoring Methods
   a. Geophysical/Geochemical
   b. Remote Sensing
   c. Groundwater Tracers
   d. Leachate Collection Systems Monitoring
5.  Statistical Methods
6.  Air Emission Monitoring

Groundwater Monitoring in the Saturated Zone
  A  number of issues  have  been  identified  as saturated zone
groundwater sampling and analysis problems needing additional re-
search. These issues can be grouped  into the  following general
topics:
1.  Groundwater Sampling Procedures
   •Well drilling methods
   •Well casing and completion methods
   •Well flushing sample preparation (e.g., filtering), and quality
   assurance
2.  Groundwater Monitoring Well Network Design
Sampling Procedures

  The need for continuing research into improved methods  for
sampling groundwater is based on concerns about sample validity
and the cost-effectiveness of available procedures.
  Collection of a groundwater sample  involves several steps: drill-
ing and casing the hole; placing the appropriate well screens and
sealing materials; pumping the well  to purge it  of standing water
and introduced contaminants; collecting, preparing and preserving
the sample; and transporting the sample to the laboratory  for
                                                                                          POST-CLOSURE
                                                    449
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analysis. To ensure that the sample is representative and unadul-
terated, the ability of currently available techniques  to collect a
groundwater sample without adding or removing trace  contam-
inants should be assessed. Candidate materials should be evaluated
through laboratory tests to determine their suitability for sampling
system components. Based  on their suitability, the recommended
components should  be evaluated through actual field tests and
guidance materials prepared.
  Compliance monitoring is accomplished by direct sampling of
groundwater. This implies that appropriate equipment and tech-
niques are currently available to perform each step of the process.
Although some information is available on these topics, little data
exist on the effects of different types of equipment and construc-
tion materials on  trace concentrations in groundwater samples.
For example, PVC pipe is commonly used to case the wells, as well
as (at depths greater than 25 ft) water supply pumps with graphite,
plastic or steel impellers to purge wells and collect samples. It is
known that these materials can alter the concentrations of trace
metals, trace organics and halogenated organics in groundwater
samples, but little quantitative information about the magnitude of
these effects is  available. The only currently available alternative
is the use of Teflon or stainless steel well sets for casing and screen-
ing. However, these materials are many times more expensive than
PVC pipe and,  at present, there are insufficient data  available to
ensure that the materials are adequate for the intended purpose.

Groundwater Monitoring Well Network Design

  Implicit in the  requirement for groundwater monitoring is the
assurance that the upgradient and downgradient monitoring wells
are placed, constructed and operated to provide a high probability
of detecting leachate plumes escaping through facility liners. Two
basic groundwater  hydrology issues affect  the ability to specify
compliance  monitoring well networks: perched aquifers and con-
tinuous well pumping.
  A hydrogeological situation that affects the ability to specify de-
tection and compliance monitoring well networks is the presence
and extent of low permeability lenses of earth materials beneath
disposal facilities. Such lenses can create  perched  water zones
above the "permanent" uppermost aquifer. These lenses may in-
tercept  a  contaminant plume before it  reaches  the  permanent
uppermost aquifer. If the presence and extent  of such lenses are
not specifically known, and if  only the permanent  uppermost
aquifer is monitored, an existing contaminant plume may go unde-
tected.
  Therefore, the technology to adequately define the presence and
extent of such low permeability lenses should be evaluated. Well
number and locations as well as sampling procedures (e.g., fre-
quency and collection methodology) necessary  to ensure ground-
water protection should be addressed.
  Continuous pumping of downgradient wells has been suggested
as a means of  ensuring plume interception. The Agency  recog-
nizes that the use of continuously pumping wells will increase the
radius of influence of the wells and may allow the use of fewer wells
than would be  needed for intermittent sampling.  However, con-
tinuous pumping may also  cause artificial dilution of contami-
nants, thus  yielding measurements of artificially  low concentra-
tions.
Vadose Zone (Unsaturated) Monitoring

  The Agency initially considered requiring that monitoring sys-
tems  be  installed beneath landfills,  surface impoundments and
waste piles in the vadose zone. However, the technical feasibility
and reliability of such systems was not sufficiently proven to be in-
cluded in the regulatory program.  The potential of vadose zone
monitoring as an "early warning system" to detect leakage before
the leachate reaches the aquifer is  being seriously evaluated.  If
feasible,  such early  detection could  allow speedy remedial action
that could significantly reduce the costs of corrective action.
                                                         Some literature  on  vadose zone  sampling  already  exists.1-2
                                                       Equipment,  including suction-cup lysimeters,  geophysical  tech-
                                                       niques and soil sampling techniques, has the potential for provid-
                                                       ing valuable data for detecting and determining the migration of
                                                       hazardous wastes in the subsurface. Research is needed to labor-
                                                       atory test and field demonstrate the application range of selected
                                                       monitoring devices. The monitoring devices for this application
                                                       appear to  include both direct and indirect monitoring techniques
                                                       such as those mentioned above and salinity sensors, tensiometers,
                                                       neutron probes and  electrical resistivity  networks  placed under
                                                       waste units.
                                                       Indicator Parameters and Hazardous Constituents
                                                         The current groundwater regulatory program distinguishes be-
                                                       tween two groups of parameters: indicator  parameters  and haz-
                                                       ardous constituents. Indicator parameters are measured during the
                                                       detection monitoring phase and may include specific conductance,
                                                       total organic carbon (TOC) and total organic halogen (TOX),
                                                       Hazardous constituents are measured during the compliance mon-
                                                       itoring phase. They include all of the 387 constituents identified in
                                                       Appendix  VIII of 40 CFR Part 261, unless the USEPA Regional
                                                       Administrator excludes specific constituents.
                                                         Factors that must be considered when specifying the parameters
                                                       or constituents to be monitored include:
                                                       •Mobility, stability and persistence of waste constituents or  their
                                                        reaction products in the unsaturated zone beneath the facility
                                                       •Detectability of indicator parameters, waste constituents and re-
                                                        action products in groundwater
                                                       •Concentrations  or values and coefficients  of variation in  pro-
                                                        posed monitoring parameters or constituents in the groundwater
                                                        background
                                                         Research is required to provide answers to such basic questions
                                                       as:
                                                       •What  are the correlations observed at actual sites of ground-
                                                        water contamination between the indicator parameters  and  haz-
                                                        ardous constituents of interest?
                                                       •What are the seasonal variations expected from natural causes in
                                                        groundwater parameters such as specific conductance,  total or-
                                                        ganic carbon and total organic halogen?
                                                       •What classes of hazardous constituents will not be detected by the
                                                        indicator  parameters?
                                                       •What  kinds of  indicator parameters  or other field monitoring
                                                        methods can be used to  identify these "missed" classes of haz-
                                                        ardous constituents?
                                                       •For given types  of wastes, what  are appropriate sets of indicator
                                                        parameters and under what conditions are they reliable?
                                                       •How redundant is the information obtained from different  indi-
                                                        cator parameters?
                                                         Currently, for the Appendix VIII compounds, there are insuffic-
                                                       ient quality-assured laboratory analytical techniques available for
                                                       monitoring all of these compounds.  Research is needed in the
                                                       following areas:
                                                       •Development of quality-assured analytical techniques for Appen-
                                                        dix VIII compounds
                                                       •Determination of  whether the number of Appendix VIII com-
                                                        pounds should be reduced or expanded based on latest data from
                                                        hazardous waste site investigations including Consent Decree and
                                                        Superfund.
                                                       Advanced Monitoring Methods
                                                         Implicit in the requirements for groundwater monitoring at land
                                                       disposal facilities are the assumptions that well networks can be de-
                                                       signed at a reasonable cost and will ensure detection of leachates
                                                       leaking through the liners into groundwater. Monitoring wells are
                                                       quite expensive and, without a large number of wells at each facil-
                                                       ity, escaped leachates may go undetected. Also implicit in the re-
                                                       quirements for groundwater monitoring is the assumption that geo-
                                                       logic stratigraphy and the site hydrogeology are well known or can
 450
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be readily ascertained at each site. Groundwater piezometric head
gradients and the direction and speed of groundwater flow are es-
pecially  important. With the drilling of sufficient  holes, this re-
quirement may be achievable. However, advanced methods offer a
means of reducing the costs involved in monitoring and in char-
acterizing the subsurface prior to remedial action and in placement
of the well network.
Geophysical/Geochemical Techniques
  Surface Methods—Leak detection systems installed in landfills
and surface impoundments with double-liners allow the operator
to forego detection monitoring of groundwater. The only such leak
detection systems  addressed in the regulations involve leachate
collection systems  installed in the space between  the two liners.
Certainly such systems can be installed and the technology exists to
build them, but the double-liner construction presents an ideal
geometry for electrical sensing methods which, in many cases,
would be more sensitive than leachate collection and would have a
much faster response. Automation of these electrical systems is en-
tirely feasible. To  date, the  only studies of advanced leak detec-
tion systems have dealt with simple  resistivity tests on single-liner
site designs and microseismic detection schemes intended to pick
up audible noise of liquids moving through soil.
  One of the most promising such methods appears  to be repre-
sented by the four-electrode resistivity system.3 Another method
which appears to have considerable potential in leak detection ap-
plications is  the  electromagnetic conductivity  survey.4'5Surface
geophysical techniques can also be  used to look  for conductive
leachate plumes which might otherwise go undetected  by the mon-
itoring wells.
  Another technique with promise for monitoring landfill and sur-
face impoundment liner leakage employs  fiber optics. Laser-in-
duced fluorescence spectroscopy covering fiber optic cables has re-
cently become both technologically and  economically feasible.
Many hydrocarbons of interest  have fluorescence  signatures.  For
many other substances without fluorescence signatures (for ex-
ample, chloride ions), the reaction of the substance of  interest with
a fiber coating or  other substrate can produce a unique reaction
product that  does fluoresce. Devices  capable of detecting non-
fluorescing substances or measuring physical parameters such as
temperature have been dubbed optrodes (to indicate the optical
analog of ion-specific electrodes). Remote Fiber Fluorimetry (RFF)
apparatus and techniques are currently under development. The
feasibility of detecting dissolved organics has been demonstrated;
optrodes for detection and measurement of chlorides, chlorinated
hydrocarbons and  other substances  are under development. The
measurement of temperature, pH, redox potential, water level  and
even groundwater  flow rates and directions appears  to be feas-
ible. Such RFF methods  could  provide rapid analysis and  could
prove cost-effective since they would  require limited manpower.
They  would also be  a convenient adjunct  to leachate collection
systems. Further research is needed to test the suitability of apply-
ing RFF techniques.
  Downhole Methods—Downhole geophysical/geochemical meth-
ods can be used to ensure that monitoring wells  are completed
(screened) in the right vertical range, as well as to give good in-
dications of the subsurface lithology and considerable  information
on the chemical quality of groundwater. These methods can also
yield information about the direction  and speed of groundwater
flow,  which is essential to  the  design and  operation  of ground-
water monitoring networks.
  Limited work  in the application  of surface/geophysical tech-
niques to hazardous waste site monitoring  has been done, but no
systematic exploration of their use in monitoring programs is avail-
able. The petroleum exploration field has used a variety of down-
hole logging equipment in large-diameter, uncased holes, but there
is no literature on the use of such methods in the monitoring of haz-
ardous waste sites.
Remote Sensing
  The use of remote sensing as  a long-term  monitoring tool  at
hazardous waste landfills has been demonstrated and should be in-
vestigated further. The use of multispectral scanners, spectroradio-
meters, thermal scanners and cameras using special filters and films
can result in the detection of spectral changes in vegetation stressed
by hazardous leachates. Remote sensing with infrared equipment
would also be particularly applicable during the post-closure period
to monitor  for leakage due to cap failure. Spectral changes  in
stressed vegetation can give a clear indication of the location of the
leak and the direction of the leakage flow.  Guidance documents
should be prepared on when and how to use various sensors under
various climatic and geographic conditions.

Groundwater Tracers

  Present regulations require the use of synthetic or clay liners
under landfills and surface impoundments. When liner leaks occur,
it is difficult to undertake remedial action unless the locations of a
leak can be determined. It is often difficult to establish that the
contamination detected is coming from the disposal facility and did
not result from some other source, such as an inadvertent spill or
accidental well contamination from sampling equipment. Thus,
a means of identifying both the contaminants resulting from liner
leakage and the specific area of the leak is needed.
  One means of finding the leak and resultant contaminants if the
placement of easily identified, soluble, non-degradable non-toxic
tracer compounds above specific sections of liner during liner in-
stallation. A rupture of the liner would release the tracer along with
the contaminants. The presence of the tracer would indicate that
liner leakage has  occurred and is  the contaminant source. Exam-
ination of the particular tracer compound would thus pinpoint the
area or areas of leakage.
  The trivalent rare earth compounds are outstanding candidates
for such tracer applications. They are of  low toxicity and can be
detected in extremely low concentrations (ug/1 and lower) in com-
plex chemicalmatrices (such as contaminated groundwater) by us-
ing neutron activation analyses. An initial screening of rare earths
and other potential  tracers  should be conducted and followed up
by pilot and field testing of selected compounds to evaluate prob-
lems related to transport, recovery  and analyses of the tracers.
Leachate Collection System Monitoring

  The RCRA Land Disposal Regulations do not currently require
backup monitoring  of the  leachate collection system. How  does
one know that the collection system will survive and operate after
the site is closed? If no leachates  can be  pumped  out of the sys-
tem, there is no way of determining whether leachates are no longer
being produced or whether the collection system has failed.6
  Research is required on renovation and long-term maintenance
of leachate collection systems and on backup  systems in case of
failure. Innovative approaches to long-term monitoring of the per-
formance of leachate collection systems should be investigated.
Statistical Methods
  Statistical methods are an important element of the Land Dis-
posal Regulations because the decision to implement a compliance
monitoring program is based on finding a significant increase in
indicator parameter values or concentrations of  primary haz-
ardous constituents (PHCs) over background levels. The process
will specify a sampling program, a statistical comparison procedure
and a level  of significance at which the test will be conducted. The
USEPA has proposed some basic statistical procedures which jnay
be replaced with alternative methods. The applicability of existing
statistical procedures for monitoring hazardous waste facilities
needs further study. Currently used statistical procedures  assume
that monitoring data are generally normally distributed. However,
this may not be the case, and there is a possibility of obtaining a
                                                                                                    POST-CLOSURE
                                                          451
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wide range of variations depending upon The specific PHCs and a
log-normal distribution.
  A larger data base on the temporal and  spatial variability of
groundwater quality, particularly that of Appendix VIII constit-
uents, is needed to better understand when observed parameter
concentrations may be attributable to natural variabilities rather
than to landfill leachate.
  Key questions relating to statistical methods are:
•What  statistical  procedures  are appropriate  for  interpreting
 groundwater monitoring data and under what conditions?
•What are the potential consequences of not meeting assumptions
 of random samples, normal distributions, independent means and
 variances and equal variances (homoscedasticity)?
•What transformations of monitoring data should be used and un-
 der what conditions?
•What is the power (ability to reject a false hypothesis) of different
 statistical tests in groundwater monitoring programs?
•What new developments in statistical methods  might be appro-
 priate for groundwater monitoring data?
•What are the major sources of variance in groundwater  monitor-
 ing data (e.g., unexplained error, analytical variability,  sampling
 variability, true variability in groundwater quality)?
  These issues, as they relate  to monitoring of  hazardous waste
facilities under the regulations,  are currently being addressed by the
USEPA. The need in this area is to field test the refined statistical
procedures that are being developed in order to verify their applic-
ability.

Air Emissions Monitoring

  The USEPA had considered the possible need  for air emissions
monitoring at land disposal facilities but concluded that insuffic-
ient air emissions information was available to justify such a regula-
tory requirement at the present time. Several investigators have re-
cently  reported on methods used in monitoring air emissions at
Superfund sites in papers from the Third National Conference on
Management of Uncontrolled Hazardous Waste Sites .7>8>9 Air emis-
sions can be a  serious  concern at certain classes of land disposal
and land treatment facilities.
  The USEPA is currently assessing the problem of toxic air emis-
sions from hazardous waste treatment, storage and disposal facil-
ities. This effort is directed toward providing the documentation
necessary to establish the need  for air emissions regulation  and
monitoring requirements. Needs in this area include documenting
state-of-the-art techniques for measuring emission rates from land
disposal sites, identifying adsorbent materials suitable for ambient
air monitoring, determining the migration potential of toxic gases
in the unsaturated zone and providing quality assurance for am-
bient air monitoring techniques.

ACKNOWLEDGEMENTS
  The efforts of Ms. Kim Smith of SRA Technologies were instru-
mental  in the development  of the final report.  In addition, the
monitoring R&D needs presented are also based  on the results of
a peer review of the draft document, which culminated in a work-
ing meeting held in Arlington, Virginia on Feb. 24, 1983.  OMSQA
would like to thank the following people for their participation in
and/or contribution to this effort:
Philip Malone, Norman Francingues and James Crabtree
U.S. Army Corps of Engineers, Waterways Experiment Station,
Vicksburg, MS
Stephen Ragone
Office of Hazardous Waste Hydrology, U.S. Geological Survey,
Reston, VA

Richard C. Kibler
HQ U.S. Air Force LEEV, Boiling AFB, Washington, DC
Major Stephen TerMaath
U.S. Air Force Engineering and Services Center, Tyndall Air Force
Base, FL
                                                       Eileen Riley-Wiedow
                                                       U.S. Army Toxic and Hazardous Materials Agency, Aberdeen, MD

                                                       Roy Evans and Leslie McMillion
                                                       USEPA, Environmental Monitoring  Systems  Laboratory, Las
                                                       Vegas, NV

                                                       Jerry Thornhill
                                                       USEPA, R.S. Kerr Environmental Research Laboratory, Ada, OK

                                                       William Budde
                                                       USEPA, Environmental Monitoring  and  Support Laboratory,
                                                       Cincinnati, OH
                                                       Jack McGinnity
                                                       USEPA, Office of Air Quality Planning and Standards, Research
                                                       Triangle Park, NC

                                                       Barret Benson
                                                       USEPA, National Enforcement Investigations Center, Denver, CO

                                                       Basil Constantelos
                                                       USEPA, Waste Management Division, Region V, Chicago, IL

                                                       David Mowday
                                                       USEPA, Office of  Technical  and Scientific Assistance,  Region
                                                       IX, San Francisco, CA

                                                       John Warren
                                                       USEPA, Statistical Policy Staff, OPRM, Washington, DC

                                                       Richard Allan, George Dixon,  Mike  Flynn,  David  Freidman,
                                                       Seong Hwang, Lawrence Greenfeld, and Burnell Vincent
                                                       USEPA, Office of Solid Waste, Washington, DC

                                                       Robert Clemens
                                                       USEPA, Office of Waste Programs Enforcement, Washington, DC

                                                       William Lacy, Robert Holmes and Darwin Wright
                                                       USEPA, Office of Research and Development, Office of Monitor-
                                                       ing Systems and Quality Assurance, Washington, DC

                                                         This  project was  conducted under EPA Contract  No. 68-02-
                                                       3778, John D. Koutsandreas, Project Officer.

                                                       REFERENCES
                                                       1. Wilson, L.G., Monitoring in the Vadose Zone: A  Review of Technical
                                                         Elements and Methods, USEPA, 600/7-80-134, 1980.
                                                       2. Everett, L.G., Hoylman, E.W. and Wilson, L.G., Vadose Zone Mon-
                                                         itoring for Hazardous Waste Sites, Final Draft, EPA Contract No.
                                                         68-03-3090, Kaman Tempo, Santa Barbara, CA., 1980.
                                                       3. Peters, W.R.,  Shultz, D.W. and Duff, R.M., "Electrical Resistivity
                                                         Techniques for Locating Liner Leaks," in Proc. of  Third National
                                                         Conference on Management of Uncontrolled Hazardous Waste Sites,
                                                         Nov. 1982,31-35.
                                                       4. White, R.M. and Brandwein,  S.S., "Application of Geophysics to
                                                         Hazardous Waste Site Investigations," in Proc.  of  Third National
                                                         Conference on Management of Uncontrolled Hazardous Waste Sites,
                                                         Nov. 1982,91-93.
                                                       5. Evans, R.B., "Currently Available Geophysical  Methods for Use in
                                                         Hazardous Waste Site Investigations," in Risk Assessment at Haz-
                                                         ardous Waste Sites, ACS  Symposium #204, F.A. Long and G.E.
                                                         Schweitzer, Editors, Washington, D.C., 1982,93-115.
                                                       6. Morrison, A., "USEPA's New Land Disposal Rules—A Closer Look",
                                                         Civil Engineering, 53, Jan. 1983,440-49.
                                                       7. Astle, A.D., Duffee, R.A. and Stankunas, A.R., "Estimating Vapor
                                                         and Odor  Emission Rates  from  Hazardous  Waste Sites," in  Proc.
                                                          Third National Conference on Management of Uncontrolled Hazardous
                                                          Waste Sites, Nov. 1982, 326-330.
                                                       8. Murphy, B.L., "Air Modeling and Monitoring for Site Excavation,"
                                                         in Proc. Third National Conference on Management of Uncontrolled
                                                         Hazardous Waste Sites, Nov. 1982, 331-333.
                                                       9. Schmidt, C.E.,  Balfour, W.D.  and Cox,  R.D.,  "Sampling  Tech-
                                                         niques  for Emissions Measurement at Hazardous Waste Sites," in
                                                         Proc.  Third National Conference on Management of  Uncontrolled
                                                         Hazardous Waste Sites, Nov. 1982, 334-339.
452
POST-CLOSURE
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        FAILURE PREDICTIONS FOR THE POST-CLOSURE
                       LIABILITY TRUST FUND  ANALYSIS
                                           GAYNOR W. DAWSON
                                                C.JOE ENGLISH
                                             PETER GUERRERO
                                    Battelle Pacific Northwest Laboratory
                                             Richland, Washington
INTRODUCTION
  With passage of the Comprehensive Environmental Response
Compensation and Liability Act (CERCLA) of 1980, Congress
created two funds to assist in the restoration of areas contaminated
with hazardous wastes. In addition to the better known "Super-
fund" which helps cover the cost of remedial action at abandoned
or uncontrolled hazardous waste  sites, Congress mandated  the
Post-Closure  Liability Trust Fund  (PCLTF). The  latter fund is
designed to cover the cost of post-closure maintenance, monitoring
and remedial action for sites closed under the Resource Conserva-
tion and Recovery Act (RCRA) regulations. To be eligible, these
sites must have displayed no evidence of contaminant migration
over  a five-year post-closure  period during which they were
monitored according to the RCRA permit conditions. Upon accep-
tance into the fund coverage by USEPA, the federal government
accepts responsibility for remedial action costs, liability claims and
all monitoring and maintenance costs above those required  for
post-closure procedures under the permit.
  When the  fund  was created, Congress  chose to finance  the
PCLTF by imposing a tax on hazardous wastes.  An arbitrary ceil-
ing value of $200 million was placed on the fund. It was mandated
that whenever the fund balance exceeded the ceiling in the previous
year,  the tax would be discontinued for that year. Since the fund
can be invested to generate income, it is possible that it will sustain
itself. On the other hand, if demands are high,  it is also possible
that the fund  will be insufficient to meet the demands placed on it
in any given year. In order to determine the adequacy of the ceiling
value of $200 million, Congress charged USEPA with preparing a
report by Dec. 1983 which would identify required changes in fund-
ing base or the ceiling level to assure fund availability.
  USEPA chose to construct that report on the basis of a coupled
economic and geohydrologic model. The latter would predict when
and how various representative facilities will fail while the former
would estimate what  the subsequent demands  would be on the
fund. The following paper describes the failure prediction module
of the overall model.
GENERAL STRUCTURE
  The failure/exposure preduction elements of the module are
designed within the framework illustrated in Figure 1. In essence,
the functional nodes rely on user supplied data, correlation data
held within captive data banks, programmed analytical constructs
for predicting continuous events (e.g., leachate movement) and
Monte Carlo  simulations to predict discrete probabilistic events
(e.g.,  rainfall  patterns). The individual algorithms employed, data
sources ana assumptions made to render the module operable are
discussed for each structural component.
MODULE INPUTS
  At the initiation of a simulation, the user supplies a base set of
input information. This is supplemented by internally generated
values to create the required suite of data outlined in Table 1. For
inputs supplied by the user, default values have been programmed
into the module and can be utilized whenever the user does not sup-
ply a preferred value. Some inputs are self-explanatory, others are
discussed with respect to their  use and the default value, when ap-
propriate.
  The type of site is required to define the potential source term.
Specifically, the site must be characterized by:
•Number of layers
•Thickness of each layer (in cm)
•Field capacity of each layer (cm/cm)
•Saturation for each layer (cm/cm)
•Probability that  synthetic liners/caps will fail in any given month
•Probability that  synthetic liner/cap  will be punctured during in-
 stallation
  The first four characteristics are either supplied by  the user or
obtained from an  internal data base. To perform the latter option,
the user must identify the site as one of several  standard designs
considered by the  module. The final two characteristics must be put
in by the user. Default values are 0.25 for synthetic membrane
liners, 0.05 for synthetic membrane covers and 0.00  for asphalt
and concrete liners and covers. These values are based upon limited
data reporting actual landfill failures and should be revised over
time to reflect changes in both the data base and  landfill construc-
tion practices as available. An identifier for each layer is assigned to
designate the material type: waste-1, sand-2, clay-3, synthetic (e.g.,
plastic, asphalt, concrete)-4 and soil-5. A separate identifier is used
to denote the presence of a leachate collection system which would
prevent upper layers from becoming saturated.
   If all data are not available tor a given site, the design is specified
from a previous module in the overall model on the basis of pro-
bability functions for seven prototypes such as that illustrated in
Figure 2. If this approach is taken, the thickness of each layer can
be specified independently. Clay lined and capped landfills, with or
without leachate  collection systems,  are the most common site
types selected. Permeability properties for each layer are accounted
for as noted in the narrative on water movement simulation. While
the seven prototype designs are for landfills, land farms and im-
poundments can  also be  evaluated by inputing the proper design
                                                                                             POST-CLOSURE
                                                       453
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                            Figure 1
       Relationship of Components in Failure Prediction Module

dimensions and  characteristics  at  closure.  These sites  are not
modeled during  operation since major  modifications  in waste
characteristics will occur before these facilities can be closed. The
latitude and longitude are input to specify the location of the site.
This allows data to be withdrawn from the national data base from
the appropriate region of the country thus insuring proper con-
sideration of site-specific features.
  USEPA wastes codes must be specified for the wastes expected at
a given site. While the code designation provides no input directly
applicable  to subsequent analyses, it does  identify a discrete waste
type which offers entry to an internal data base. This can subse-
quently specify toxic constituents of concern and their properties
which will  affect transport and fate.
  Dates of opening and closure are specified to indicate:  (1) when
the face is  first opened and, therefore, allowed to collect precipita-
tion, (2) how long the face is open and (3) when the cap is em-
placed. The date when post-closure care  is terminated is equated
with  the time when leachate  collection is terminated and erosion
may  proceed unabated. This assumption  may be changed by  the
user to reflect the fact that leachate collection may cease when the
cap  is emplaced. Leachate generation and  migration will  begin
when  the site opens as will  the  aging process for any synthetic
liners. Waters of infiltration will accumulate at a faster rate while
the site is in operation because of the lack of a low permeability
cap. After closure, the cap will be in place and infiltration will be
reduced. Leachate migration  can be substantial during operation.
Hence, it must be tracked from the opening date. If a breach occurs
prior to closure, the site may not qualify for the PCLTF. At a
minimum,  some form of repair will be required. All breaches are of
direct interest to the analysis.
  The length of  run is specified  by the user upon activating  the
model. This is the period of time following closure that the model
will check for breaches. Simulation will stop at a date equal to the
sum of latest closing date and the length of run.
  The probability of liner failure refers to the density  function to
be employed in determining  when a  synthetic  membrane liner is
likely to fail through natural degradation. This is separate  from the
probability  of improper installation  or  puncturing  during  site
operation (failure at time zero). It addresses the finite life of a prop-
erly installed membrane due to chemical degradation and natural
                                                                                       Table 1
                                                                Standard Inputs Required by the Failure Prediction Module


                                                          User Inputs Needed at the Start of a Run:
                                                          •Number of sites
                                                          •Number of Monte Carlo replications
                                                          •Base year (i.e., the time origin for the run [e.g. 1982])
                                                          •Starting "random" number seed(s)
                                                          Variables that the User Can Rest at the Start of a Run include:
                                                          •The probability that a synthetic cover fails at time zero
                                                          •The probability that a synthetic liner fails during a given month
                                                          •The probability that a synthetic cover fails during a goven month
                                                          •The probability that a synthetic liner fails at time zero
                                                          •The amount of water which defines a breach when the monitoring is
                                                           done inside the site
                                                          For Each Site or Facility the User Must Define the Following:
                                                          •The site type (If the user picks one of the standard site types, then the
                                                           thickness,  field capacity, saturation,  starting water content, probabili-
                                                           ties of synthetic liner failure, number of layers, type of layers [e.g., clay,
                                                           sand, etc.] and drainage are obtained from an internal site data base. If
                                                           the user does not pick one of these standard types, he must supply his
                                                           own values). Field capacity refers to the amount of moisture a medium
                                                           will hold before the water begins to leak into the next lower layer. Starting
                                                           water content refers to the amount of moisture in the layer to begin with.
                                                          •Latitude and longitude
                                                          •Number of wastes in the site and an EPA waste code for each waste
                                                          •Date opened and closed
                                                          •Date when post-closure care ceases
                                                          •Date on which study ends for this site
                                                          •Type of waste package (drum or sludge)
                                                          •Width
                                                          •Length
                                                          •Distance to the monitoring well (which will be set to zero if monitoring is
                                                           to be done at the site boundary)
                                                          The Computer Will Supply All Other Variables. The User, However, Can
                                                          Overrule the Computer and Supply Alternative Values for the Following:
                                                          •Seepage velocity range—velocity range of the  aquifer, speed at which the
                                                           water is moving
                                                          •Distance to the drinking well and/or surface water
                                                          •Choose  to use  the  Blaney-Criddle  Method  over  the  Thornthwaite
                                                           Method to characterize evapotranspiration (if the user does this, he must
                                                           also supply all the parameters needed by the Blaney-Criddle Method)
                                                          •Runoff coefficients—the fraction  of precipitation which runs off the
                                                           surface rather than infiltrates into the soil
                                                          •Erosion
                                                          •Effective porosity range—the range of values defining pore or void space
                                                           in  the soil; this is the space between soil particles through  which soil
                                                           moisture can flow
                                                          •Range of depth to groundwater range
                                                          •Field capacity of the top soil
                                                          •Random number seeds for the climate calculations
                                                          •Water quality of the uppermost aquifer
                                                          •Aquifer thickness
                                                          forces. The user may specify a value for this probability or may
                                                          choose to rely on the programmed default values.
                                                          Internally Held Inputs

                                                            In addition to inputs supplied by the user, the module requires
                                                          waste and geography specific inputs to conduct the analysis. These
                                                          are held in a data base internal to the module itself.
                                                          Waste Specific Data
                                                            The USEPA  waste identifier codes specify the waste  type or
                                                          source. For the analysis required here, information is needed on the
                                                          constituents in those  wastes and their properties with respect to
                                                          transport and fate  in  the environment.  As a consequence, a data
                                                          base has been generated to provide the desired inputs on a call-up
                                                          basis.
                                                            For each waste code,  toxic constituents were identified for the
                                                          purposes  of subsequent modeling of breaches.  For each of the
                                                          above constituents, data  were compiled  on  solubility,  drinking
454
POST-CLOSURE
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                    LANDFILL DESIGN - TYPE 1

           VEGETATED TOP COVER:  	
           DEPTH AT LEAST in". 3-51 SLOPE,
           PLANTED TO MINIMIZE EROSION;
           FOR SLOPE GREATER THAN  St. EROSION
           CAN BE NO MORE THAN ] TONS/ACRE-YEAR
         2. MIDDLE DRAINAGE LAYER: 12*. OVERLAIN BY  .
           GRANULAR OR  SYNTHETIC FABRIC FILTER.  /
           SATURATED HYDRAULIC CONDUCTIVITY OF/
           LAYER MUST BE AT LEAST UT^cm/sec    '   ,
         3. SYNTHETIC MEMBRANE: AT LEAST 20 mil'   f
         «. RECOMPACTED  SOIL (CLAY):  AT LEAST M"
         5. WASTE	•
         6. DRAINAGE LAYER: SAME SPECIFICATIONS AS
         7. LEACHATE DETECTION. COLLECTION, AND  REMOVAL
           SYSTEM:  MUST  KEEP LEACHATE DEPTH BELOW
         «. SYNTHETIC LINER: AT LEAST 30 mil	
                                                              Figure 2
                                                  Prototype Landfill Design—Type 1
water or priority pollutant criteria levels, detection limits, octanol-
water   partition  coefficients*  (organics)  and  Kd  values!
(inorganics).  With  respect  to  toxicity criteria  based  on  car-
cinogenesis, the 10~6 risk level value was used. (The 10~6 risk level
is defined as the concentration at which exposure over a lifetime
would result in one  additional case of cancer in  106 people.) The
above physical constants are found in the "Background Document-
Listing of Hazardous  Wastes,"  Nov.  14, 1980, and  its reference
material: Dawson, G.S., C.J.  English  and S.E. Petty. "Physical-
Chemical Properties of Hazardous Waste Constituents," USEPA,
Mar. 5, 1980 (unpublished).

*An octanol-water partition coefficient represents the degree to which a chemicai will distribute itself
between water and octanol when shaken in a mixture of the two. It is used as a measure of a
chemical's affinity for water as opposed to organic fluids.
f 'Kd" is a parameter used to represent the distribution of a chemical between the soil and water in a
given location at equilibrium,  i.e.,

Kd = concentration in soil
   concentration in water
  Average detection limits of 10/tg/l for organics and 20 /ig/1 for
inorganics were obtained from USEPA's "Guidelines Establishing
Test Procedures for the Analysis of Pollutants; Proposed Regula-
tions," (FederalRegister, 69464-69575, Dec. 3, 1979).
  In addition, data are entered on the taste and odor threshold, the
total dissolved solids (TDSQ and total organic carbon (TOC) levels
associated with all constituents in a waste to  denote when indicator
parameter or organoleptic properties will  lead to  detection of
leakage in monitoring or potable wells.
  The detection of a breach is based on arrival of mobile species at
the point of detection. Detection may  constitute discovery of
positive values during monitoring or the impairment of taste and
odor. Therefore, the most important constituent(s) in each waste
will be the "early arrival" contaminant(s), i.e., those constituents
which  will first arrive at the monitoring  or  potable well in detec-
table or toxic concentrations. Recognizing this, (a) representative
chemical(s) were identified for each waste. This was accomplished
by comparison of solubility, detection limit, toxicity criteria and
data on interactions with soil (attenuation).
  For  consideration  of breaches  defined by arrival of detectable
levels,  the ratio of the  solubility (S) and  the detection limit (DL)
were derived (S/DL) to  indicate how much dilution and attenuation
is necessary for each constituent before leachate will not produce a
detectable level at the monitoring well (it is assumed that all consti-
tuents are leached from the site at their water solubility). Detection
may be by analyses, by taste and odor or by indicator parameter.
Similarly for breaches defined by toxicity considerations, the ratio
of the solutility (S) and toxicity criteria (TC) were derived (S/TC)
to indicate the level of dilution and attentuation necessary to pre-
vent a toxic level from occurring at the monitoring well.
  For organic chemicals, the octanol-water partition coefficient (P)
is converted into Koc** using  the Karichhoff relation (log Koc =
0.02 + 0.94 log P), which is subsequently employed to calculate a
Kd (soil-water  partition  coefficient)  for organic  contaminants
assuming an average soil organic content of 2%. Kds are fed direct-
ly to subsequent modeling algorithms to designate soil attenuation.
The Kd value is specified to indicate soil attenuation for inorganic
constituents. No degradation is  accounted  for in  the  transport
model. It is assumed that groundwater is abiotic (i.e., has no active
biological community as a result of filtration of bacteria by the soil
and potential toxicity of leachate) and, therefore, does not subject
contaminants to biodegradation. Photodegradation (decomposi-
tion sponsored by the presence of light, e.g., sunlight) is  also
eliminated in groundwater systems. Hydrolysis and chemical oxida-
tion may still occur but since the worst case scenario is of primary
interest, degradation is not considered.

**"Kod" is the distribution coefficient adjusted to the organic carbon content of the soil.
Koc  = concentration in soil organic carbon
  '       concentration in water

  For each waste code, the values  [Log (S/DL) - Log (Kd)] and
[Log (S/TC) - log (Kd)] were calculated for each constituent. The
constituents yielding the highest values were designated the "early
arrival"  contaminants  for use in subsequent analyses  since  they
display the greatest speed in  moving through  the  environment.
Therefore, the one or two constituents  with  the highest value are
employed to designate the properties of a given  waste type. For a
site receiving more than one waste, the values are compared be-
tween wastes and the constituents with the greatest  speed employed
for subsequent modeling.  In essence, this process distills the model-
ing effort to one of following the "early arrival"  chemicals. For in-
dicator parameters, the sum  of all constituents' solubilities are
employed.
  In addition, wastes are  characterized by the number of com-
pound classes present and the total organic content. The compound
classes of constituents  in  the  waste are designated as  inorganic,
polar organic and  non-polar organic to assist in predictint  liner
failure. Synthetic liners are often only effective for a single class of
                                                                                                       POST-CLOSURE
                                                                                                                                455
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chemical.  Therefore, synthetic  liner life is shortened when more
than one category of chemicals  is present.  In addition, it has been
reported that clay liners become more permeable when exposed to
organic chemicals.'  Therefore, in sites receiving these materials, a
permeability change of two orders of magnitude is applied.
Geography Specific Data
  Site specific data on environmental factors are housed in the Na-
tional  Data   Base.  This  information  file   contains  pertinent
hydrogeological, geological and meteorological data registered by
longitude and latitude. In this way, when a given site is identified by
its geographic coordinates, the model can access the National Data
Base  to determine  the  appropriate environmental input data.
Specific parameters included in  this data base are listed in Table 2.
                            Table 2
              Inputs Included in the National Data Base
Temperature Profile (°C)—monthly mean and standard deviation
Precipitation Profile (cm/mo)—monthly mean and standard deviation
Depth to Groundwater (cm)
Gradient/Porosity (dimensionless)
Hydraulic Conductivity (cm/sec)
Distance to the Drinking Well or Surface Water (cm)
Overburden Field Capacity (cm/cm)
Erosion Loss (cm/mo)
Runoff Coefficient (dimensionless)
Aquifer Water Quality (/ig/1)
Aquifer Thickness
   A reference file was  added as an additional element in the
geography specific data base. This cross-referened file identifies the
FIPS code (Federal Information Processing System Code) county
and latitude and longitude for the county seat of all counties. This
was necessary to register the erosion loss data which was identified
by FIPS code. The cross reference was retained on the data base to
facilitate  addition of  new  data  not registered by latitude  and
longitude. It can also be utilized to locate sites when only the coun-
ty or FIPS code is given.

RELATIONSHIPS AND FUNCTIONS
   The failure prediction is carried out through a number of rela-
tions and functions  as provided  by the elements  or submodules
described as Weather Simulation, Baseline Analysis, Site Data File
and Water Movement  Simulation in Figure 1.
   The Weather Simulation is accomplished utilizing  a random
draw or Monte Carlo  Technique. The ranges of average monthly
temperature and precipitation  are used to create a normal distribu-
tion of probable occurrence. A pseudo-random number generator
program is then employed to select a value for each month of the
simulation method. This is done for each of the primary weather
stations in the U.S.  The program package utilizes a congruential
method, the entire weather pattern for a simulation can be retained
by putting the starting draw number in memory. (A congruential
method is one in which each successive number is generated by ap-
plying an algorithm  to the preceding number. As such, given the
same starting number,  an identical series can be generated.) In this
way, the same weather pattern is simulated for all sites in the prox-
imity of any given weather station. The output from the weather
simulation is ultimately employed to calculate monthly precipita-
tion and evapotranspiration losses at  a site.
   The Baseline Analysis element is an integration point wherein all
pertinent  input points are assembled for a given site. In addition to
data supplied by the user and  data drawn  from the waste and na-
tional  data bases,  the baseline element provides the starting water
content.
                                                          Water content during the operation is determined by assuming
                                                       that all infiltration during the operational period enters the system
                                                       (i.e., no plants are present to cause evapotranspiration, evapora-
                                                       tion is minor). Water is then distributed throughout the layers of
                                                       the site in a manner described  in the section on water movement
                                                       simulation.
                                                          The Site Data File is merely  a locus wherein the integrated and
                                                       calculated data in puts from the Baseline Analysis are stored for a
                                                       given site. The site file acts as a  tailored data bank for each site
                                                       while subsequent analyses are performed.
                                                          The Water Movement Simulation submodule is the heart of the
                                                       breach  scenario  development  mechanism.  Basically,  this  unit
                                                       models the infiltration of precipitation and subsequent migration
                                                       of leachate to the point of detection. Because of the random nature
                                                       of initiating and  contributing events, the simulation  relies  on
                                                       Monte Carlo techniques. This process begins with the submodule
                                                       accounting for uncertainties in the seepage velocities and dispersion
                                                       values by drawing values from density curves. These values are used
                                                       for the rest of a 50-yr (or more) simulation.
                                                          Having established the initial conditions at a site by either:
                                                       •Reading values in from the data  base
                                                       •Letting  the user define the value
                                                       •Making a stochastic decision (described  above)
                                                       the program simulates water movement over time.  It begins this
                                                       process with the output from the weather simulation.  Having this
                                                       information, the program can now account for the water balance in
                                                       the surface layer, in each month, in the following way:
                                                       •The thickness of the layer is first reduced by an amount indicating
                                                        monthly erosion loss if post-closure monitoring is  no longer ac-
                                                        tive. Erosion loss is  based on user specified values when avail-
                                                        able. If specific loss data are not employed, generalized data for
                                                        each of the seven prototype designs are  taken. Lacking either of
                                                        these, the state average value is employed from the National Data
                                                        Base. In all cases, once post-closure care  is terminated, erosion
                                                        losses are accounted for  by subtraction of a given amount each
                                                        month.
                                                       •The amount of raw infiltration (precipitation-runoff) is calculated
                                                        using a  runoff coefficient from the National Data Base.
                                                       •The potential evapotranspiration is calculated using either the
                                                        Thornthwaite or Blaney-Criddle Method.10 The choice of method
                                                       is dependent on the site's geographic location. If the soil cover has
                                                        been  eroded away,  then the evapotranspiration  is considered
                                                        negligible because of the  subsequent lack of vegetation.
                                                       •The amount of water in the cover layer is reduced if the potential
                                                        evapotranspiration exceeds the raw infiltration.
                                                          If there is a net movement of water into the cover layer beyond
                                                       its field capacity, the water percolates into  the layers below. Like
                                                       the cover material, the underlying layers exhibit a certain capacity
                                                       to hold water. In other words, once the field capacity of any layer is
                                                       reached,  it passes any water it receives to the layer below. The rela-
                                                       tion is depicted conceptually in Figure 3. The water  balance ap-
                                                       proach taken there is analogous to viewing  each layer as a bucket
                                                       with a finite capacity to hold water.  The inflows and  outflows of
                                                       water are  calculated  at each  step.  When  the bucket is  full,  it
                                                       overflows into the next bucket (the underlying layer). This process
                                                       continues until a bucket with a detection site (monitoring well) or
                                                       potable use (potable well or surface water) is encountered. At that
                                                       time, a breach event is recorded.
                                                          This approach implicitly assumes that the  rate at which the layers
                                                       can  accept water is large  enough that, within a time  step (i.e., a
                                                       month),  it can accept all the  water  "offered" to it. This is not
                                                       necessarily a good assumption for either the clay liners or synthetic
                                                       layers. Thus, extra consideration is made for these layers. First an
                                                       estimate  for the hydraulic conductivity as a function of water con-
                                                       tent is found. The driving  force moving the  water downward (head
                                                       gradient) is taken as the distance between the mid-point of the two
                                                       layers. With these values, an estimate of the total amount of water
                                                       which the clay can accept in a month's time can be found. If this
                                                       amount  is less  than the "offered"  amount, then  the  smaller
 456
POST-CLOSURE
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amount is accepted into the clay layer and the rest is redistributed in
the layer(s) above the clay. If a synthetic layer is intact, it causes the
same redistribution of water except that no water is allowed to pass
through the synthetic layer. If an active leachate collection system is
present, all water in excess of the field capacity for the layer that is
not passed by the next lower layer is assumed to be removed by the
collection system.
  At the end of a simulated year's time, the submodule has an
estimate of the volume of water, if any, which has passed through
the site for every month of the simulated eyar. Running sums of the
total amount of leachate and of the total volume of water collected
in the leachate collection system are kept. The latter can be divided
by run time to estimate leachate treatment requirements.  If the
total amount of water is less than a critical value (defined below),
then the  calculation goes on to the next year with no calculation
made for travel time to the monitoring well.  This is because it is
assumed  that the leachate contaminant is held  in the intervening
layers between  the waste layer and  the water  table. Until these
layers are saturated with contaminants, no significant movement  of
waste into the saturated zone will occur. However,  if this critical
value has been exceeded, the waste enters the groundwater system
and dilution effects and travel time to both the monitoring well and
the point of potable use are calculated.
  The hydrologic transport model is composed  of:
•Landfill Leachate Source Model
 (1)  The landfill site is assumed to be a two-dimensional leachate
     source to the unsaturated  soil column beneath the site; ap-
     proximate dimensions of the site are obtained from the input
     site  type.
 (2)  The leachate discharge (concentration and flux) is assumed  to
     be uniformly distributed over the site at any instant in time;
     however, the discharge varies with time according to the mois-
     ture infiltration of the site. Attenuation due to retention on
     soils in  the unsaturated zone is considered  at this point.
•Saturated Zone Transport Model
 (1)  The leachate plume from the unsaturated zone acts as  a two-
     dimensional horizontal area source on the water table sur-
     face to the saturzed zone; it is assumed the water flux from the
     unsaturated zone is  insignificant compared to the water flux
     in the saturated zone. Thus,  only contaminant particles are
     released to the saturated zone.
 (2)  The leachate  plume moves through  the saturated zone ac-
     cording to a constant value seepage velocity and dispersion co-
     efficient influenced by geochemical retardation of flow and
     the dispersion model's attenuation in the system.
 (3)  The transport equation is given by

 3C     ,VX,3C
                 =
  Failure of synthetic liners and covers is determined by Monte
Carlo simulation using a probability distribution curve which varies
over time. In other words, the probability of rupture increases with
the age of the liners. These are: (1) failure due to improper installa-
tion, and (2) failure due to  "aging." Failure due to improper in-
stallation will be calculated  using the user inputed probability of
improper installation. Failure will then occur at randomly selected
sites (based on this probability) beginning at the opening date for
liners or the closing date for covers. Failure due to aging is com-
plicated by the lack of any  data with which to calculate expected
lifetimes. Current USEPA publications describing the behavior and
performance of synthetic liners do not contain sufficient data to ac-
curately  predict liner  life.4'5'7 An average lifetime of 25  years for
synthetic liners and 50 years for synthetic covers is assumed by the
module unless overriden by  user supplied values. This is  based on
expected values for pond liner life reported by Lee6 and on the
20-25 year guarantees that many synthetic manufacturers offer for
their  products.  Liners are  expected to age  faster  than covers
because of interactions with wastes. It has been observed that waste
incompatibility will lead to  increased aging of liners. To account
for this, waste constituents  are classified as polar organics, non-
polar organics, or acids, caustics and salts. If more  than one of
these waste types is  present at a site, it is assumed that the liner will
age twice as  fast as those exposed to a  single constituent type. If
erosion has removed soil over a cover, it is assumed that the cover
will then age at double the normal rate.
  A potential failure mode for clay liners is intrusion by plants and
animals. Work  is  presently being conducted  by  Battelle Pacific
Northwest Laboratories concerning plant and animal intrustion in-
to waste burial grounds. Preliminary results were reviewed as well
as results of Hakoson and Gladney.3 It  was concluded that,  while
plant root intrusion to the depths of the waste cover was  possible,
the effect on permeability would probably be small. The main con-
cern with plant intrusion appears to be with uptake of wastes rather
than increased permeability. Therefore,  it was decided to ignore
plant intrusion.  Preliminary work regarding animal intrusion
shows that this may have a significant effect if the cover is shallow
enough to  be in  the burrowing  zone of  animals. Based  on
preliminary results, it is assumed that animal intrusion will affect
10% of the site area. Using data presented by Moore and Ali8 and
assuming that the effects of animal intrusions are similar to crack-
ing, the chance of cover failure will be increased by a factor of two
following animal intrusion.
  Research being performed at Texas A&M University has shown
that organic  leachates may have  a  significant  effect  on the
permeability  of clay liners. Based on results presented by Ander-
son, Brown and Green,1 the model increases the permeability of
clay liners by two orders of magnitude if organic wastes are present
in leachate.
 where C - C)x,y,z,t) - leachate concentration at position
                     (x,y,z) at time t
 Vx = seepage velocity of water (x-direction)
 Dx = dispersion coefficient of water (x-direction)
 R  = geochemical retardation coefficient of the leachate
This  is  expressed   in  a  simple   three-dimensional  hydrologic
transport model  that  monitors   four   fronts:   (1)  change  in
background indicator parameter  (TDS for inorganics, TOC for
organics) concentrations,  (2) the  detectable concentration of the
first arrival detectable constituent,  (3) the toxic concentration of
the first arrival toxic constituent and (4) the taste and odor concen-
tration of the first  arrival constituent.  Initial concentrations are
assumed  to be at the constituent's solubility level. Dilution and at-
tenuation are accounted for during movement through the soil col-
umn and the aquifer. The initial point of detection is assumed to be
the monitoring well which is located at the downflow perimeter of
the site.
       EVAPOTRANSPIRATI ON
 PRECIPITATION



      —- RUNOFF


| INFLOW 1 • PRECIPITATION - EVAPOTRANSPIRATION - RUNOFF

        | INFLOW 2 =

           INFLOW 1

           FIELD CAPACITY 1
                            Figure 3
           Conceptual Model of Water Balance Calculation

OUTPUT

  The output from each simulation is the probable timing and type
of breach for a given site. Replicate runs are made for each site to
generate a probability value for each type of event for each site.
  Seven breaches are included:
  Breach 1—Indicator parameters arrive at monitoring well
                                                                                                    POST-CLOSURE
                                                           457
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1
X
X
X
X
X
X
X
2
X
X
X
X
X
X
X
3
X
X
X
X
X
X
X
4
X
X
X
X
X
X
X
5
X
X
X
X
X
X
X
6
X
X
X
X
X
X
X
7
X
X
X
X
X
X
X
Breach 2—Detection  levels for specific contaminants arrive at
  monitoring well
Breach 3—Toxic levels for specific contaminants arrive at moni-
  toring well
Breach 4—Taste  and  odor threshold  arrives at potable  well/
  surface water
Breach 5—Detection  levels for specific contaminants arrive at
  potable well/surface water
Breach 6—Toxic  levels for specific contaminants arrive at pot-
  able well/surface water
Breach 7—Infiltration backs up and overflows

                               Site Type
Event
Type
  1
  2
  3
  4
  5
  6
  7

                           Figure 4
                 Example Breach Probability Table

  This information creates a  breach probability table,  Figure 4,
which is passed on to subsequent modules to determine the con-
comitant financial demands that would be put on the PCLFT.
DISCUSSION
  At this  time, the model does not account for acute disruptive
events such  as earthquakes and extreme storms. Review of causes
of hazardous waste mismanagement damage cases showed that
these are probably very minor causes of discharges from hazardous
waste facilities.2
  No special provisions have been made for entry of surface im-
poundments or land treatment facilities in the model. It is assumed
that, when  closed, these facilities will be treated  as landfills if
hazardous residuals remain. If residuals do not remain, no signifi-
cant breach scenarios are evident. Hence, the landfill model will
suffice as long as the  user provides information on the site design,
the moisture content at closing and the nature of the waste.
  No special provisions have been made for sites receiving correc-
tive actions. It is assumed that once corrective actions are specified,
the site can be reentered in the system. As currently envisioned, cor-
rective action will consist of two elements:  cap/liner repair and
withdrawal of contaminated groundwater (counterpumping).
  When cap/liner repair is undertaken, the site should be reentered
in the simulation  as a new site with a design that reflects  the repair
work.  Functionally, the  user  must  specify  the new design. The
model would then reenter the site and complete the simulation. The
default value is to return to the original design for the site.
  Withdrawal wells require slightly different treatment. The model
is too simple to accommodate well fields to withdraw contaminated
                                                        water for treatment. However, the effects of withdrawal would not
                                                        be all that dissimilar to activation of a leachate control system, i.e.,
                                                        termination of all uncontrolled contaminated flows through the
                                                        liner during the period of pumping. The user must specify how long
                                                        pumping will  be performed. The default value is set as a period
                                                        equivalent to the time it took for the breach to be discovered in the
                                                        first place. This is somewhat analagous to the new regulations set-
                                                        ting the compliance period equal to the period of operation  for a
                                                        given site. However, it is still a source of inaccuracy. There is no
                                                        hysteresis effect in such systems. Desorption may well take much
                                                        longer than the original adsorption onto soils depending on pump-
                                                        ing rates and the contaminates involved. A second area of concern
                                                        is the residual  contamination in the unsaturated zone. Flushing the
                                                        aquifer does not impact this zone. Hence, a source of concentration
                                                        would remain  below the liners  which would effectively accelerate
                                                        movement  of  subsequent breaches compared to how the model
                                                        would simulate the post-remedial action period. The effect is prob-
                                                        ably small, but it does constitute  an inaccuracy.
                                                          The model  is currently being exercised to provide quantitative
                                                        output on  probable failure modes and consequences  for  RCRA
                                                        sites in the future.  This will have implications for future landfill
                                                        regulatory programs as well as the adequacy of the PCLTF.


                                                        REFERENCES
                                                         1. Anderson, D., Brown, K.W. and Green, J., "Effect of Organic Fluids
                                                            on the Permeability of Clay Soil  Liners," Proc. of the Eighth Annual
                                                            Symposium on Land Disposal of Hazardous Wastes, 1982.
                                                         2. Fred  C. Hart Associates. Assessment of Hazardous Waste Misman-
                                                            agement Damage Case Histories, Draft, Prepared for USEPA Under
                                                            Contract 68-01-6474, 1981.
                                                         3. Hakonson,  T.E.  and Gladney,  E.S., Biological Intrusion of Low
                                                            Level-Waste Trench Covers, LA-UR-81-2972, Los Alamos National
                                                            Laboratory, New Mexico, 1981.
                                                        4.  Haxo, H.E., "Effects of Liner Materials of Long-Term Exposure in
                                                            Waste Environments," Proc.  of the Eighth Annual Research Sym-
                                                            posium  of Land Disposal: Hazardous  Waste,  EPA-600/9-82-002,
                                                            EPA, Cincinnati, Ohio, 1982,  191-211.
                                                         5. Haxo, H.E., "Durability  of Liner Materials for Hazardous Waste
                                                            Disposal Facilities," Proc. of the Seventh Annual Research Sympos-
                                                            ium on Land Disposal: Hazardous Waste, EPA-600/9-81-0026,  EPA,
                                                            Cincinnati,  Ohio,  1982, 140-156.
                                                         6. Lee, J.,  "Selecting Membrane Pond Liners," Pollut. Engi.,  6, (1),
                                                            1974, 33-40.
                                                         7. Matrecon, Inc., Lining of Waste Impoundment and Disposal Facili-
                                                            ties, SW-870, USEPA, Washington, D.C.  1980.
                                                         8. Moore,  C.A. and Ali, E.M., "Permeability of Cracked Clay Liners,"
                                                            Proc. of the Eighth Annual Symposium on Land Disposal of Haz-
                                                            ardous Wastes, 1982.
                                                         9. Neely, W.B., Chemicals in the  Environment, Marcel Dekker, New
                                                            York, 1980.
                                                        10. Thornthwaite, C.W. and Mather, J.R., "Instructions and Tables for
                                                            Computing Potential Evapotranspiration and the Water  Balance,"
                                                            Publications in Climatology. Laboratory of Climatology, Drexel In-
                                                            stitute of Technology, 3, 1957, 185-311.
458
POST-CLOSURE
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       SUPERFUND AND  RCRA  CLOSURE/POST-CLOSURE:
                               AN  ILLINOIS PERSPECTIVE

                                         ROBERT G. KUYKENDALL
                                        Land Pollution Control Division
                                  Illinois Environmental Protection Agency
INTRODUCTION

  At the present time, state regulatory agencies have gained ex-
perience in the area of facility closure and post  closure. Addi-
tionally, extensive activity has occurred in the cleanup of uncon-
trolled hazardous waste sites under both State and Superfund aus-
pices. There are opportunities and problems in both areas.
  Illinois' experience thus far has shown that technical and legal
problems quickly come to the forefront. Some facilities which had
interim status  under RCRA have ceased their hazardous waste
operations  but may continue to have hazardous wastes on-site
needing cleanup. Other facilities have gone bankrupt or have been
abandoned without having financial instruments accessible to the
State Agency.  An operating facility  with an inactive area (no in-
terim status) is listed as a Superfund site and wishes to close  out
the inactive area.  Sanitary landfills  did and continue to receive
quantities of hazardous wastes, although somewhat reduced by the
small generator requirements. Each  of these presents a different
set of circumstances that must be dealt with from  technical, legal
and public confidence perspectives.
  The  closure/post-closure and  financial  requirements under
RCRA are powerful tools in the prevention of future uncontrolled
hazardous waste sites. An additional operative incentive is a com-
pany's potential liability under CERCLA.
  The closure/post-closure requirements are found in 40 CFR
Part 264-265 Subpart G. The purpose of these regulations is "...to
ensure that all hazardous waste facilities are closed in a manner
that:  (1) minimizes the need  for post-closure maintenance, and
(2) controls, minimizes, or eliminates, to the extent necessary to
protect human health and the environment, post-closure escape of
waste, leachate contaminated rainfall, or waste decomposition pro-
ducts to ground or surface waters, and the atmosphere." The cur-
rent post-closure care period (maintenance and monitoring disposal
sites)  is 30 years. In some instances  this may be adequate and in
others totally inadequate.
  Access to viable financial instruments in conjunction with proper
closure and post-closure care  should prevent the development of
many future Superfund sites such as presently exist.

CURRENT STATUS
  The current  national assessment by USEPA that most compa-
nies do not have approved closure/post-closure plans or valid and
adequate financial instruments in place is correct. This situation
must  be changed  if future Superfund sites are to be prevented
and the public's trust in the regulatory process  restored. Aggres-
sive enforcement by USEPA and states should mitigate this level
of non-compliance in FY 84.
  Starting with the RCRA Part A notification process in Nov.
1980 and continuing to the present time with Part B permit call-
in, many firms have dropped out of the RCRA regulatory scheme.
Many facilities filed protective notifications or misunderstood the
intent of RCRA Sec. 3010. More recently, companies have decided
to cease their hazardous waste management activities and have
chosen not to pursue a Part B permit application. The dropout rate
is approximately 40%  of the Part B permits called in by USEPA.
What has happened to  the hazardous wastes  that were  stored,
treated or disposed at these facilities since Nov. 1980? In many
instances no financial  instruments, closure or post-closure docu-
ments have been submitted. Such facilities are prime targets for in-
vestigation and enforcement.
  Two Illinois hazardous waste land disposal facilities ceased re-
ceipt of hazardous wastes on or before Jan. 26, 1983. In  one in-
stance, groundwater contamination is present and will  require
proper closure and post-closure care  and  monitoring or, if the
situation worsens, possible exhumation given the contaminants and
local geological characteristics. The other  land disposal site has
ceased receipt of hazardous waste but  not non-hazardous  wastes.
This site will supposedly be in a state of suspended animation for a
few years until market conditions improve. The State has inade-
quate financial instruments on file, and further action is being
taken to ensure compliance with the closure/post-closure require-
ments. Litigation may be necessary, but that is less costly to all
parties than use of Superfund.

ABANDONED SITE
  A more vivid example which illustrates several issues is a case in-
volving a hazardous waste treatment company near Chicago which
went bankrupt  and abandoned its site  last fall. Approximately
100,000  gal of water and oil based hazardous and non-hazardous
wastes were left behind in tanks, drums and tank trucks. Neither
closure/post-closure plans nor financial  instruments were on file
with the State which could have provided funds for the abatement
of the situation.  Literally, the  state was responsible for a  vandal-
ized abandoned  problem site in  a residential  area. Subsequent
cleanup  action by USEPA and Illinois required the expenditure of
more than $60,000 from Superfund and the State Hazardous Waste
Fund.

OPERATING SITE

  Illinois finds itself in the midst of a  complex situation in which
an operating chemical company has interim status for the manufac-
turing area but has an  inactive series of lagoons which it is closing
out. This  inactive area is  on the National Priorities List and
                                                                                             POST-CLOSURE
                                                      459
-------
groundwater problems exist. Financial instruments are  in place.
However, the dilemma is whether a  RCRA authorized action
should be required for an inactive and unpermitted sub-unit for
closure or a  consent agreement should be used as the appropriate
instrument.
  Since the  proposed close out of the inactive lagoons is primar-
ily an action to  address the CERCLA listing, the  consent agree-
ment may be preferable.  Questions arise as to the appropriate
cleanup level for groundwater contaminants and the length of the
post-closure  period.  The  implementation of the consent agree-
ment does not, on the surface, provide a means of getting the facil-
ity off the NPL because no  "cleanup" has been completed.  An
additional complicating matter is that two deep injection wells are
operated  on the facility  and will need  an Underground Injec-
tion Control (UIC) permit under  the Safe Drinking Water Act.
The wells have been used to dewater several of the lagoons prior to
their stabilization. Does the consent agreement need to account for
this prior action?

ILLINOIS COMPLIANCE STATUS
  At the present time, 32 closure/post-closures have been sub-
mitted to IEPA for approval.  Fifteen have been approved; two
were rejected; and five need additional information. Four plans
have been withdrawn  for further work at the Agency's suggestion,
and six are under review.  Twenty-eight of the plans received were
from generators with on-site hazardous waste management activ-
ities.
   In the area of financial assurance, approximately 380 facilities
are required to file with IEPA. Three hundred twenty-nine facil-
ities  have filed with  the State. This was only after 200 enforce-
ment letters were sent to the Companies' Presidents or Chairmen
of the Board.  Only 30% of the filings are adequate at this time.
Forty-three companies have filed  on liability insurance but have
filed no documents to guarantee closure costs. Many companies do
not appear to be updating their instruments yearly. Nearly 40% of
the filings so far are generators storing on-site for more  than 90
days. Aggressive action will continue in this area to bring about
compliance by all subject facilities.

CONCLUSION

  Although most of lEPA's attention is focused on Superfund and
hazardous waste site issues, the author believes that the  area of
solid waste landfills (Subtitle D) should not be overlooked. As the
reader is  aware, many Superfund and ERRIS sites are abandoned
sanitary  landfills where hazardous  wastes were  historically dis-
posed or are presently operating sites where small generator ex-
emption level wastes  are being disposed.  Illinois is addressing this
issue by  having  the small  generator cut-off  level  at 100  kg/mo.
and with  the passage  of legislation  requiring closure and post-clos-
ure liability coverage  for all Illinois sanitary landfills. This may not
be the final answer but it is a step in the right direction.
  Both the USEPA and States must pay greater attention to com-
pliance with RCRA  closure/post-closure  and financial  assurance
requirements in order to prevent future Superfund sites from devel-
oping and requiring expenditure of public funds. Regulatory agen-
cies  are  still  on a "learning curve"  in  the implementation of
RCRA, and many activities still require trial and error approaches.
 460
          POST-CLOSURE
-------
                                             1983 EXHIBITORS
AGES Corporation             1604
1151 S. Trooper Road
Norristown                215-666-7404
PA 19403
Full service engineering firm with a
range of technical disciplines including
environmental engineering, ground and
surface water hydrology, soils
engineering, geology, and laboratory
facilities.
Aerial Data Reduction        1701
p. 0. Box 557
Pennsauken,               609-663-7200
NJ  08110
Aerial Data Reduction, Inc., is a
privately owned photogrammetric service
firm organized in April, 1970, to offer
professional services in the field of
aerial photography, photo interpretation,
and stereo-photogrammetric mapping for
consulting engineers, and surveyors,
planners, government, and industry as
well as other related disciplines having
need for precision photogrammetric
services.  ADR also has branch offices in
Hevron, CT., Richmond, VA. , and E.
Providence, HI.
Analect Instruments
1231 Hart Street
Otica, NY 13502
   #1203

315-797-4449
Analect1 s EVM-60 refractively scanning
FTIR gas monitoring system provides
rapid,  real-time analysis for a maximum
of ten  gases from twenty locations.
Alarm capabilities and time-weighted
average computation ensure immediate and
long term site safety for personnel.  A
ruggedized optical bench allows
installation in mobile laboratories for
on-site analysis of liquids, gels, and
gas phase samples.
Analytical Instrument        1203
Development
Route 41 & Newark Road    215-268-3181
Avondale, PA 19311
Analytical Instrument Development
manufactures portable instrumentation for
the determination of trace organic
materials in the environment.  The Model
511 portable gas chromatograph with
electron capture detection for PCB's in
soil will be on exhibit.  In addition
AID'S new Model 590 GC/OVM for total
organic vapors (OVM) or specific
materials (GO in air will be shown.
Other AID instruments for on-site organic
measurements at waste sites will also be
displayed.
At-Sea Incineration          1612 & 614
1930 North Fleet Street
Elizabeth                 201-354-9100
NJ 07201
At-Sea Incineration Inc., offers
America's first fully integrated ocean
incineration system for  destroying
hazardous wastes.  The American-built ASI
incinerator ships meet the highest
standards of safety and  efficiency.
                 Orders are now being accepted for ASI's
                 comprehensive collection, land transport,
                 marine transfer and waste destruction
                 service.  At-Sea Incineration, Inc.   AN
                 AMERICAN SOLUTION TO ONE OF AMERICA'S
                 TOUGHEST PROBLEMS.
                 Biospherics Incorporated
                 4928 Wyaconda Road
                 Rockville, MD 20852
                             1710

                          301-770-7700
                                              #311 & 313
                 CECOS International, Inc.
                 2321 Kenmore Avenue
                 Buffalo, NY 14207         716-873-4200
                 Hazardous waste treatment and disposal of
                 hazardous, toxic and industrial wastes.
CH2M HILL, Inc.              1416
1941 Roland Clark Place
Reston, VA  22091         703-620-5200
Founded in 1946, CH2M HILL is one of the
largest engineering consulting firms in
the United States with a staff of over
2,000 men and women.  We provide
comprehensive study, design and
construction management services for
technological systems that include water,
waste mangement, agriculture, energy,
industry, transportation, and civil
engineering.   Our name is an abbreviation
for the firm of Cornell, Rowland, Hayes
and Merryfield, which merged with Clair
A. Hill s Associates to form CH2M HILL.
                 California Analytical        #906
                 Laboratories,  Inc.
                 5895  Power Inn Road       916-381-5105
                 Sacramento,  CA 95824
                 CAL Labs'  staff (4  PhD and 23 BS/MS  level
                 chemists)  and equipment (6 GC/MS,  15 GC,
                 2 AA, 1 ICP) occupy  16,000 ft
                 laboratory in Sacramento,  CA.  CAL Labs
                 performs analyses of  hazardous wastes for
                 federal and state regulatory agencies as
                 well as for private and industrial
                 clients.  CAL Labs now operates a
                 Finnigan 8222 high resolution GC/MS
                 system, particulary useful for TCDD
                 measurements.
                 Case International Company   1504
                 P. 0. Box 40
                 Roselle, IL 60172         312-625-1250
                 Case International Company is a specialty
                 geotechnical contractor.  Operating
                 nationwide, Case specializes in the
                 installation of slurry cut off walls for
                 ground water control and containment.
                 Case has installed several large slurry
                 cut off walls in hazardous waste
                 environments, including the first
                 "Superfund Slurry Wall" in Nashua, New
                 Hampshire.  Stop by the booth and pick up
                 a complimentary copy of the Case Slurry
                 Wall Technical Information Review, a
                 thirty-seven page booklet.
Clement Associates, Inc.     1805
1515 Wilson Boulevard
Arlington, VA 22209       703-276-7700
Clement Associates, Inc., is a scientific
and engineering consulting firm assisting
clients in solving environmental
problems. Clement does work in and
performs environmental audits, risk
assessments and risk management,
litigation support, permit applications
development, toxicology and pathological
research.
Controls for Environmental   1900
Pollution, Inc.
P. 0. Box 5351            505-982-9841
Santa Fe, NM 87502
Controls for Environmental Pollution,
Inc. (CEP) is a national environmental
consulting and analytical firm.  In
addition to offering a complete
environmental consulting service, the
company maintains a nationally certified
state-of-the-art laboratory.   CEP
specializes in hazardous waste management
programs, radiochemistry, environmental
monitoring programs and AQUATRACE,  an
advanced tracer technology.
Crosby & Overton, Inc.       1308
1610 W. 17th Street
Long Beach, CA 90813      213-432-5445
Crosby & Overston, Inc., is a heavy duty
industrial marine and environmental
cleanup contractor.  Since 1950, Crosby &
Overton has provided superior emergency
response and planned remedial cleanup
activities involving oil and hazardous
chemical substances in all environmental
media.  A full range of services have
been provided to all levels of
governmental agencies  and all types of
industry.   Branch locations are in
California, Oregon and Washington.
Additional field operations are conducted
in eight other western states.
                                            Crown  Zellerbach
                                            Geotextile  Fabrics
                                            One  Bush  St., Rm. 1303
                                            San  Francisco, CA 94104
                             #800

                          415-951-5060
                                            D'Appolonia Waste             #620  S  621
                                            Management Services
                                            10  Duff Road               412-243-3200
                                            Pittsburgh, PA 15235
                                            D'Appolonia will be exhibiting  its
                                            engineering,  scientific  and  construction
                                            services.  These services  cover a  wide
                                            range  of  activities including:   siting
                                            studies,  hydrogeologic  investigations and
                                            contaminant transport studies,  design and
                                            construction  of waste management
                                            facilities and cleanup  of  formerly
                                            utilized  hazardous waste sites.
                                                             Dames  & Moore
                                                             6 Commerce  Drive
                                                             Cranford, NJ   07016
                                                                         *713

                                                                      201-272-8300
                                                                                                     EXHIBITOR LIST    461
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Delaware Container Co.,      11211
Inc.
M. llth Ave. & Valley Rd. 215-383-6600
Coatesville, PA 19320
Delaware Container Company, Inc., is
basically a transfer, treatment, and
disposal company for hazadous wste.
Delaware Container provides and maintains
its own transportation program and
on-site laboratory.  It completes on-site
solidification and stabiliization
procedures.  The company also offers
reuse, recycling, and recovery programs
as well as emergency response and
remedial action designs.  Delaware
Container is a turn-key operation which
supplies a full line of services from
initial sampling to final disposal.
E. c. Jordan Company         1400
P. O. Box 7050
Portland, ME 04112        207-775-5401
Solid and hazardous waste management
servics provided to industry and
government agencies include geophysical
and  geohydrological investigations,
record searches, chemical
characterization, contamination risk
assessment, identification and evaluation
of remedial action alternatives and
implementation plans at hazardous waste
sites.  Hazardous waste TSD facilities
are  developed from initial planning
stages, through site selection and
investigation, design permit application
and  construction management.
 E.  I. du Pont de Nemours      1709
 Tech Lab  (D), Chambers Hks
 Deepwater, NJ 08023       609-299-8098
 Wastewater treatment  service.
 EAL Corporation               1708
 2030 Wright Avenue
 Richmond, CA   94804       415-235-2633
 EAL Corporation,  formerly LFE
 Environmental, provides consulting and
 analytical services  in the  technical
 fields  of environmental science,
 occupational  health  and safety, and
 nuclear science.  EAL's exhibit shows how
 industry and  government agencies, as well
 as the  consulting engineering profession
 can utilize EAL's services  to suppport
 their hazardous waste programs.
EHPAK,  Inc.                   1714
2000 West  Loop South
Suite  1800                713-623-0000
Houston, TX   77027
EMPAK,  Inc.,  offers deep  well injection,
waste  water  treatment,  and remedial
action on-site cleanup  to disposal
customers, as well as,  complete rail car
cleaning services.  EMPAK Disposal and
Cleaning facilities are located on the
Houston ship  channel  in Deer  Park, Texas,
readily accessible by truck,  rail, and
marine vessels.   EMPAK1s  Field Service
office is  located in  Pennsauken, NJ
609-665-6886.
ENRAC Division                11207
Chemical Haste Management
3003 Butterfield Road      312-654-8800
Oak Brook,  IL 60521
The ENRAC  Division of  Chemical  Waste
Management,  Inc., serves waste  generators
and regulatory agencies  in the  cleanup  of
hazardous  waste  sites.   ENRAC's network
of analytical laboratories,
transportation vehicles,
                                    treatment/disposal facilities combined
                                    with past experience support its
                                    capability  to handle situations from
                                    emergency spills to complex, large scale
                                    remedial action.
                                   The  Earth Technology          »410
                                   Corporation
                                   3777 Long Beach  Blvd.      213-595-6611
                                   Long Beach, CA 90807
                                   The  Earth Technology Corporation provides
                                   hydrogeology, geology, geotechnical
                                   engineering, geochemical,  geophysics,
                                   modeling  (hydrologic, geochemical) and
                                   environmental consulting  services that
                                   focus  on defining  and mitigating sources
                                   of existing or potential  ground-water
                                   contamination from hazardous  materials.
                                   The  firm offers  unique in-situ  subsurface
                                   profiling, sampling (gas,  liquid, soil)
                                   and  monitoring capabilities using the
                                   Electronic Cone  Penetrometer  (CPT).
                                    Ecological Analysts,  Inc.     1902
                                    15  Loveton Circle
                                    Sparks, MD 21152          301-771-4950
                                    Ecological Analysts,  Inc. (EA) is an
                                    independent, nationwide,
                                    multidisciplinary environmental
                                    consulting firm of 200 professionals.
                                    Major hazardous waste program areas at EA
                                    include analytical chemistry engineering,
                                    hydrology and geological sciences, and
                                    environmental health  sciences.  Our GC/MS
                                    lab and corporate QA/QC program provide
                                    reliable, high-quality data to EA staff
                                    who are designing landfills, engineering
                                    solutions to effluent and process waste
                                    problems, testing and analyzing
                                    groundwater quality,  and assessing the
                                    health impacts of hazardous and toxic
                                    wastes.
                                    Ecology  & Environment,       1811 & 910
                                    Inc.
                                    P. 0. Box D               716-632-4491
                                    Buffalo, NY  14225
                                    Ecology  and  Environment provides
                                    consulting and analytical services for
                                    all phases of emergency spill response
                                    and cleanup.  Similar services are
                                    provided for waste site evaluation and
                                    remedial action.  Risk analyses on public
                                    and employee health and the environment
                                    are offered  in conjunction with these
                                    services.
                                    Engineering-Science          1705 & 707
                                    57 Executive Park South
                                    Suite  590                 404-325-0770
                                    Atlanta, GA 30329
                                    Engineering-Science is an international
                                    environmental engineering firm offering
                                    full services in hazardous solid waste
                                    management, remedial design and
                                    implementation, air pollution services,
                                    wastewater treatment, hydrological
                                    studies, and laboratory analyses.
                                    Through offices in major cities.
                                    Engineering Science provides services to
                                    clients in the government, military and
                                    private sectors.
                                   Environmental Science and    1315 & 316
                                   Engineering, Inc.
                                   Box ESE                   904-332-3318
                                   Gainesville, PL  32602
                                   ESE,  a full  service  multidisciplinary
                                   environmental engineering firm,  has
                                   performed  work at  more  than  120  hazardous
                                   waste sites  including 15 CERCLA  NCP
                                   sites.   Capabilities include remedial
                                   investigations,  feasibility  studies,
QA/QC plans, safety and health planning
and monitoring, community relations,
analytical services, and expert witness
testimony.
Environmental Testing        11205
and Certification Corp.
284 Raritan Center Pkwy.  201-225-6711
Edison, NJ  08837
Environmental Testing and Certification
Corporation (ETC) tests wastes and
groundwater; helps maintain required
shipment, treatment and disposal records)
and prepares monitoring reports that are
required by laws affecting both solid and
hazardous wastes.  ETC tailors its
services to specific needs.  For example,
Student's t-Test, pollutants trends,
waste shipment histories by generator,
transporter and by treatment or disposal
site and method.
GAI Consultants, Inc.        1602
570 Beatty Road
Monroeville, PA 15146     412-856-6400
GAI Consultants, Inc., provides
engineering consulting services in the
areas of identification, control, and
remedial activities for industrial and
hazardous waste sites.  Over 120
engineers, geologists, and environmental'
specialists are on staff to serve
generators, transporters, disposers and
regulatory agencies.
GCA/Technology Division
213 Burlington Road
Bedford, MA 01730
   1809

617-275-5444
GCA/Technology Division, with a staff of
250, offers a wide range of hazardous
materials services including field
investigation, laboratory analysis and
engineering evaluation and design.
Engineering experience Includes
hydrogeological evaluations, RCRA Part B
permit assistance, evaluation of
hazardous waste control and disposal
technologies.  All services are backed by
a comprehensive quality control system.
GEO-CON, Inc.                1716
P. 0. Box 17380
Pittsburgh, PA 15235      412-244-8200
Specializing in geotechnical
construction, GEO-CON, Inc., exhibits the
Slurry Cutoff Wall technique for
underground pollution control as well as
grouting and related work.
Geo-Physi-Con, Inc.          1908
12860 West Cedar Drive
Suite 201                 303-987-9307
Lakewood, CO 80228
Geo-Physi-Con, Inc., provides the full
range of engineering geophysical service!
and also undertakes research and
development projects.  Our services
include electrical and electromagnetic
surveys, gravity, seismic refraction,
magnetics, and ground penetrating radar
for hazardous waste site investigation
and monitoring.
Geonics Limited              »615
1745 Meyerside Drive,  18
Mississauga, Ontario      416-676-9580
Canada L5T 1C5
Geophysical electromagnetic meters.
 462
EXHIBITOR LIST
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Colder Associates            1703
5125 Peachtree Road
Atlanta,  GA 30341         404-458-9686
Golder Associates,  an international
consulting engineering firm,  has been
responsible for the geotechnical,
geohydrochemical and hydrogeological
aspects of many new and existing waste
disposal facilities including siting,
design, permit assistance,  and
construction inspection.   The present
worldwide staff exceeds 400 members
including approxmately 300  professionals,
located in the United States,  the United
Kingdom,  Canada,  the Caribbean,  and
Australia.
 Greenhorne s O'Mara,  Inc.     |617
 9001 Edmonston Road
 Greenbelt, MD  20770       301-982-2800
 Greenhorne & O'Mara,  Inc.,  is a
 nationally recognized consulting firm of
 engineers, scientists,  photogrammetrists,
 and other professionals providing
 hazardous waste management  services.   Our
 experience includes treatability studies
 design reports, design and  construction
 review, risk analysis,  process
 instrumentation control and design,  life
 cycle cost studies, facilities start-up
 and performance evaluations,  and remote
 sensing capabilities.   Greenhorne &
 O'Mara  provides hazardous  waste
 management consulting services for
 numerous governmental,  industrial and
 private clients.
 Groundwater                  1622
 Decontamination Systems
 12 Industrial Park        201-796-6938
 Waldwick,  NJ  07463
 Introducing Groundwater  Decontamination
 Systems (GDS), the unique new system for
 soil and groundwater decontamination.
 Groundwater Decontamination Systems Inc.
 eliminates hydrocarbon and halogenated
 hydrocrbon contaminants  from the
 groundwater and from the soil through a
 process of accelerated bio-degradation by
 micro-organisms existing in the
 contaminated soil.   Patent awarded.
 Gulf Oil Chemicals Company
 P. 0. Box 3766
 Houston, TX 77253
   1801

713-754-2436
Drums  for storage and transportation of
hazardous materials; HOPE plastic resins
for manufacture of synthetic liners for
landfills, containment ponds or waste
piles; large diameter pipe systems for
transportation of hazardous liquid
wastes.
Gundle Lining  Systems,        1807
Inc.
1340  E.  Richey Road        713-443-8564
Houston, TX  77073
Gundle Lining  Systems,  Inc.,  is a
manufacturer of  high  density  polyethylene
(HOPE)  sheeting  in thicknesses  ranging
from  20  mil  to 100 mil  and widths of 22.5
feet.   These flexible membrane  liners are
used  for applications pertaining to
environmental  protection  such as dams,
reservoirs,  hazardous and nonhazardous
waste  containments.
HMD Systems,  Inc.             #406
160 Charlemont Street
Newton, MA 02161           617-964-6690
Model  301 gas chromatograph - A portable
version of the 301  with DC power/gas
                  supply option provides  field
                  investigation capabilities. This G.C.  can
                  be equipped with both photoionization
                  detector and FID detector which provides
                  field confirmation of unknown  species.
                  Model PI-101 hazardous  waste detector
                  provides immediate indication  of the
                  presence of potential toxic chemicals,
                  even at sub ppm levels,  and gives  a
                  breakdown of existing compounds when used
                  with three available probes.
                 Harmon Engineering and        1110-113
                 Testing, Inc.
                 Auburn Industrial Park     205-821-9250
                 Auburn, AL  36830
                 Harmon Engineering & Testing  (HE&T) will
                 demonstrate a mobile laboratory equipped
                 to perform testing necessary  at hazardous
                 waste remedial action sites.  The GC/MS
                 system, along with support
                 instrumentation, can provide  on-site
                 waste analyses for PCBs, organic
                 solvents, cyanide, phenols, heavy metals
                 and related hazardous compounds.  HE&T
                 will also provide an exhibition
                 describing their hazardous waste
                 management program which includes
                 industrial hygiene consultation (HE&T is
                 an AIHA accredited firm),  site
                 assessments, engineering and  removal
                 activities.
                 HazTech
                 3300 Marjan Drive, N.E.
                 Atlanta, GA  30340
   #307

404-451-5772
                 HazTech will provide speciality
                 engineering and field operations services
                 to:  private industry, architects and
                 engineering firms; hazardous waste
                 treatment, storage, disposal and cleanup
                 contractors; and federal, state, and
                 municipal governments.  Specific
                 operational capabilities include:  site
                 cleanup, contaminated water treatment,
                 borehole drilling, and well installation.
                 ICOS                         #717
                 4 West Fifty-Eighth Street
                 New York, NY  10019       212-688-9216
                                           In-Situ, Inc.
                                           209 Grand Avenue
                                           Laramie, WY  82070
                                              #1209

                                           307-742-8213
                 In-Situ, Inc., is a hydrologic
                 instrumentation and software company.  We
                 are exhibiting the SE-200 Hydrologic
                 Analysis System.  This is a
                 computer-automated field hydrologic
                 analysis system that monitors and records
                 water levels in a maximum of 10 wells
                 simultaneously.  The system also prints a
                 preliminary report in the field that
                 includes graphs of time drawn curves.
                 Also on exhibit is the SE-1000, a solid
                 state simple channel monitor for
                 long-term monitoring of wells.   It is
                 compact, weathertight and contains a
                 long-life battery pack.   Extensive
                 software available from In-Situ includes
                 programs for surface and groundwater,
                 restoration programs,  and oil and gas
                 software.
                 Industrial Marine Service,   t202
                 Inc.
                 1301 Marsh Street, Box 177804-543-5718
                 Norfolk, VA  23501
                 Hazardous material and oil spill
                 contractor.
                  International Minerals &     #802
                  Chemical  Corporation
                  421  East  Hawley Street    312-566-2600
                  Mundelein,  IL 60060
                  IMC  produces  sodium bentonite products
                  for  civil engineering applications;
                  slurry  trenching,  irrigation trenches,
                  cut-off walls,  pond sealing, sewage
                  lagoons,  earthen dams and sanitary
                  landfills.
                 JRB Associates                #403
                 8400 Westpark Drive
                 McLean, VA  22102           703-821-4886
                 JRB is pleased  to  demonstrate its
                 experience  and  expertise  in  the
                 management  of hazardous wastes including
                 site investigations, RCRA "Part B"  Permit
                 applications, chemical industry studies,
                 technology  evaluation for hazardous spill
                 clean up and site  remediation.
                 Additional  services  include  environmental
                 audits, expert  witness testimony and
                 regulatory  development.
                                                                                      K-V Associates               #205
                                                                                      P. 0. Box 574
                                                                                      Falmouth, MA  02541       617-540-0561
                                                                                      K-V Associates, Inc., manufactures
                                                                                      groundwater equipment for the oil
                                                                                      industry, hazardous waste contractors,
                                                                                      civil engineers, and environmental
                                                                                      consultants.  These include groundwater
                                                                                      flowmeters, leachate detectors, and
                                                                                      miniature portable well point samplers.
                                                                                      The flowmeters allow rapid determination
                                                                                      of direction and rate of groundwater and
                                                                                      gasoline product flow.
                 K. W. Brown and Associates   #603
                 707 Texas Avenue South
                 Suite 202D                409-693-8716
                 College Station, TX 77840
                 K. W. Brown and Associates is a
                 consulting firm specializing in
                 soil-related aspects of environmental
                 problems and issues.  Areas of expertise
                 include both hazardous and nonhazardous
                 waste disposal, land treatment, advanced
                 landfill designs, in place closure of
                 surface impoundments, clay line-waste
                 compatability testing and cleanup
                 assessment of chemical spills.
                 Law Engineering Testing      f513
                 Company
                 1140 Hammond Drive        404-396-8000
                 Atlanta, GA 30328

                 Law Engineering is an established
                 environmental consulting firm with
                 extensive experience in contamination
                 investigations and remediation studies.
                 Law has gained valuable knowledge of
                 regional and local geology/hydrology near
                 many existing hazardous waste sites.
                 Years of experience with hazardous waste
                 make Law Engineering a credible firm to
                 help solve contamination problems.
                 Marine Pollution Control
                 8631 West Jefferson Avenue
                 Detroit, MI 48209
                                                                                                                   #500 & 502

                                                                                                                313-849-2333
                 Mead CompuChem               #616
                 P.  0. Box 12652
                 Research Triangle Park,   919-549-8263
                 NC 27709
                 Mead CompuChem combines sophisticated
                 GC/MS (gas chromatography/mass
                 spectrometry) technology with
                 computer-based systems to deliver high
                                                                                                     EXHIBITOR LIST    463
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quality GC/MS analytical testing services
including the analysis of low level
organics.  Inorganic analysis is also
available by AA and ICAP.  Analyses can
be performed on a variety of sample
matrices including air, water, soil,
tissue and hazardous waste for both
clinical and environmental needs.
Med-Tox Associates, Inc.     »305
4020 Birch Street
Suite 202                 714-851-1028
Newport Beach, CA  92660
Med-Tox Associates, Inc., is an
environmental health consulting and
managemnt company.  Med-Tox provides
expertise in the field of hazardous waste
management, environemntal toxicilogy,
industrial hygiene, and  occupational
medicine.  Hazardous waste services
include:  environmental  testing, site
investigations, regulatory compliance,
personal monitoring, and overall
management of waste cleanup operations.
ModuTank, Inc.               (520
29-24 40th Avenue
Long Island City,         212-392-1112
NY  11101
ModuTank provides low cost, above-ground,
bolt-together tanks in a wide range of
sizes and capacities for virtually all
liquid holding needs; as well as
secondary containment dikes and linings
for storage pond.   Also standard
"off-the-shelf" products and custom
designs are available.
NIB/EPA Chemical             1306
Information System
CSC, P. 0. Box 2227       703-237-1333
Falls Church, VA  22042
The NIH/EPA Chemical Information System
is a collection of scientific, emergency
response and regulatory data bases
available world-wide via Telenet or
Tymnet, 24 hours a day, 365 days a year.
This system allows for structure,
substructure and full or partial name
searching for over 250,000 unique
chemical substance and 800,000 synonyms
or trade names.
NUS Corporation              1413 & 415
910 Clopper Road
Gaithersburg, MD  20878   301-258-1299
NUS offers complete hazardous waste
management and RCRA-related services.
The exhibit presents NUS1 consulting,
engineering, analytical, and earth
sciences capabilities, including site
assessement and groundwater monitoring,
chemical waste management, remedial
action services, and sophisticated
laboratory facilities.  Our computerized
Real-Time Emergency Assessment System and
NUS1 High Integrity Container for
hazardous and radioactive wastes are also
displayed.
National Library of          1818
Medicine
8600 Rockville Pike       301-496-1131
Bethesda, MD 20209
The National Library of Medicine Chemical
and Toxicological files are online,
interactive retrieval  services  in
toxicology maintained  by  the Specialized
Information Services Division of the
National Library of Medicine.   The  files
include TDB  (Toxicology Data Bank), RTECS
(Registry of Toxic Effects of Chemical
Substances), TOXLINE (Toxicology
Information Online), and  CHEMLINE
(Chemical Dictionary Online).
New York Testing             M02
Laboratories, Inc.
75 Urban Avenue           516-334-7770
Westbury, NY 11590
New York Testing Laboratories, Inc.
provides management and analysis of
hazardous wastes to the RCRA
requirements, including the screening of
priority pollutants, ignitability,
corrosivity, reactivity and EP toxicity
tests.  Other allied services include
NPDES and SPDES compliance testing,
bioassay, bioaccumulation and toxicity
studies, and complete organic and
inorganic analysis of sediment,
wastewater and sludge samples.
0. H. Materials Co.          1312
P. 0. Box 551
Findlay, OH  45840        419-423-3526
0. H. Materials provides on-site
treatment of a variety of environmental
hazards.  Previous work for public and
private sector clients has included:
hazardous waste site cleanup, groundwater
recovery and cleanup, radiological
cleanup, carbon filtration, consulting,
site assessment biological degradation,
emergency response and complete
analytical services.
Occupational Health          1404
Services, Inc.
515 Madison Avenue        212-752-4530
New York, NY 10023
Occupational Health Services, Inc., is a
subsidiary of P. W. Communications, Inc.,
a leading international medical
communications corporation.  OHS, Inc.,
provides HA2ARDLINE an online,
interactional database designed to
provide occupational/environmental
specialists with the most current
regulatory and risk assessment
information on hazardous substances.
Also online availability is ENVIRONMENTAL
HEALTH NEWS which provides late breaking
news items as they happen from government
regulatory agencies on related court
decisions, emergency occurrences, toxics
research and other events.


Oil Recovery Systems, Inc.   1405
299 Second Avenue
Needham, MA  02194        617-449-5222
Oil Recovery Systems/Groundwater
Technology offers the entire solution to
groundwater contamination by
cost-effectively incorporating
experienced hydrogeologists, local
service, and proven innovative equipment.
We provide laboratory analysis,
scavenger systems, water table depression
pumps, water purification and air
stripping systems, samplers, and
monitoring equipment.
Palco Linings, Inc.          1200
P. 0. Box 526
South Plainfield, NJ 07080201-753-6262
Palco Linings, Inc., has been involved in
the seepage control industry for over 20
years.  The Company has fabricated more
than 100 million square feet of flexible
membrance lining in a wide diversity of
over 1500 projects.  Palco manufactures a
variety of standard and custom linings.
Technical assistance and turn-key
installations are also provided.  For
international and west coast customers
call 714-898-0867, or write to P. 0. Box
919, Stanton, CA  90680
Photovac Incorporated         1506
Unit 2, 134 Doncaster Ave.
Thornhill, Ontario        416-881-8225
Canada L3T 1L3
Photovac Incorporated cordially  invites
all attendees to stop by  the  booth  to
learn how the following chronograph, data
analyzer and air monitoring system  can
help your company in hazardous waste
control:  Photovac 10A10  Portable
Photoionization Gas Chromotograph,
Photovac P1500 Portable Chromotograph
Controller Data Analyzer, Photovac
A-4000/S-9000 Area Air Monitoring System.
QED Environmental Systems,   1702 « 704
Inc.
P. O. Box 7209            313-995-2547
Ann Arbor, MI 48107
The original Well Wizard™ dedicated
groundwater sampling system is designed
for two-inch and larger monitoring wells.
A line of portable, fully pneumatic,
automatic and widely adjustable cycle
controller is available to operate the
system.  The system, available in both
PVC and teflon, sharply reduces the
purging and sampling time requirements
while simultaneously improving sample
integrity.
R. E. Wright Associates      1600
3240 Schoolhouse Road
Middletown, PA 17057      717-944-5501
R. E. Wright Associates, Inc., is an
applied groundwater consulting firm
employing professional scientists in the
fields of hydrogeology, geochemistry,
engineering geology, soil science,
aquatic biology, and geophysics.  Wright
Associates also provides consulting
services for the manufacture, use, and
disposal of hazardous materials to State
and Federal environmental agencies.
REACT                        1517
P. 0. Box 27310
St. Louis, MO 63141       800-325-1398
REACT environmental crisis engineers
offer nationwide 24-hour emergency
response for hazardous material
accidents; environmental crisis
engineering for the containment and
control of hazardous waste sites; and
consulting engineering, including
industrial hygiene, RCRA compliance
audits, SPCC plan preparation and
chemical hazard analysis and evaluation
of health effects from chemical exposure.
REMIC Corporation
726 Middleton Run Road
Elkhart, IN 46516
   1207

219-295-1806
U'nI-COM  , the two-way hands-free
communications headset for increasing
personal safety and communications
efficiency in industrial, commercial,
professional operations and cleanup of
hazardous waste and material situations.
— voice controlled and cordless.
^nl-BASE   for supervisors.  Alert-COH
„, the new personal alert safety system
for use in all personal hazardous
situations.
 464    EXHIBITOR LIST
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Radecca, Inc.                 1606
P.  0. Box 9948
Austin, TX   78766          512-454-1420
Radecca sorbents find  application to
water treatment and  to waste  and  soil
stabilization. Radecca's  KLENSORB fills  a
long existing need for an economic and
effective means of treating water
contaminated with organics and
particularly oil.  LOCKSORB provides
significantly lower  costs in  the
solidification/stabilization  of hazardous
waste; LOCKSORB also retards  leaching of
most organics from the stabilized waste.
Radian Corporation
p. 0. Box  9948
Austin,  TX  78766
   #715

512-454-4797



   1214
Residuals Management
Technology, Inc.
1406 E.  Washington Avenue  608-255-2134
Madison, WI   53703
Consultants in  industrial,  solid  and
hazardous waste management.   Specialties
include:  landfill selection, design, and
construction  management; waste
characterization and analysis;
environmental audits; air  and water
pollution control engineering;
hydrogeologic investigation and
monitoring; regulatory permit analysis;
resource recovery; environmental
mediation; water and waste  laboratory
analysis; and leaching tests.
Resources  Technology          1601
Services,  Inc.
6 Berkeley Road            215-687-4592
Devon,  PA  19333
Resource Technology Services,  Inc.,  is  a
full service  hazardous waste  organization
dedicated  to  the environmentally  sound,
cost-effective disposal  of chemical
wastes.  RTS  offers a complete range of
services including transportation,
storage, consulting, remedial action,
emergency  response and the handling  and
disposal of highly reactive and shock
sensitive  materials.
Rockwell  International        1804  &  806
2421 W. Hillcrest Drive
Newbury Park, CA  91320    805-498-6771
Rockwell  has the technological  base,
engineering expertise and  extensive
environmental program experience
necessary to address all phases of waste
management problems.  Offices are  located
in Newbury Park, CA; Denver,  CO; Chapel
Hill, NC; and Washington,  DC.
Rollins Environmental         1401
Services, Inc.
One Rollins Plaza          302-429-2767
Wilmington, DE 19899
the nation's first and most  experienced
hazardous waste management company,
Rollins continues to lead  in the
development and application  of
state-of-the-art technologies and
services.  From consultation to
destruction, Rollins offers  a complete
spectrum of hazardous waste  management
options at regional facilities  located  in
industrialized areas of  the  country.
Because hazardous waste  management is our
only business, we have the skilled
personnel, equipment and technical
expertise to provide the most
cost-effective treatment,  disposal and
remedial services possible.
                 Roy P. Boston, Inc.           1514
                 Weston Way
                 West Chester, PA   19335    215-692-3030
                 Roy F. Weston, Inc. provides
                 comprehensive environmental energy
                 management  services on an  international
                 scale.  WESTON1s management and
                 technological expertise  is applied in  the
                 areas of:   air resources management;
                 water supply; wastewater;  geosciences;
                 environmental management;  resource
                 development/recovery; technology
                 management;  land use; energy  management;
                 hazardous waste management; and  solid
                 waste management.
SCA Chemical                  1808  &  810
Services, Inc.
5 Middlesex Avenue         617-367-8300
Somerville, MA 02145
SCA is a total service company  geared  to
meet all the needs of hazardous waste  or
PCB generators.  We presently provide
transformer decommissioning  and
decontamination, PCB capacitor  disposal
by EPA approved secure chemical landfill,
transportation with total  liability
protection, and analysis and consultation
on PCB situations or remedial activities.
SCA's Chicago incinerator  has passed all
technical requirements to  incinerate
PCBs.  We expect to receive  our PCB
permit from the Environmental Protection
Agency in September, 1983.
                 SCS Engineers                 1407
                 4014 Long Beach Blvd.
                 Long Beach, CA  90807     213-426-9544
                 SCS Engineers provides consulting  and
                 engineering services to the waste
                 management industry and government
                 agencies.  The company's staff
                 capabilities include all engineering
                 disciplines, complimented by  geologists,
                 soil specialists, chemists, and
                 biologists.  Principal work areas  include
                 landfill/landfarm design, hydrogeologic
                 investigations, permitting/EIS,  landfill
                 gas, incineration, SPCC, expert  testimony
                 and risk management.
                 SMC Martin, Inc.             #521
                 Box 859
                 Valley Forge, PA 19482    215-265-2700
                 SMC Martin provides civil, chemical,
                 design engineering services  in addition
                 to geochemical, geophysics,
                 hydrogeologic, geologic and  soils
                 capabilities to industrial,  governmental,
                 and judicial clients in hazardous waste
                 assessment and remediation.
                 SRW Associates, Inc.          #412
                 2793 Noblestown Road
                 Pittsburgh, PA  15205     412-921-0321
                 SRW Associates, Inc.,  is a geotechnical
                 and environmental engineering  firm
                 specializing  in waste  management and
                 waste engineering for  industry.  Services
                 include design, permitting, ground water
                 monitoring, planning,  site investigation,
                 site closure, soil  laboratory  testing,
                 liner compatibility testing,  and Part B
                 applications.
                 Safety First  Industries,      #210
                 Inc.
                 161 Thorn Hill Road        412-776-2900
                 Warrendale, PA  15086
                 Safety First  Industries is a  manufacturer
                 of safety and firefighting equipment,
                 distributing  the I.L.C. Dover Totally
                 Encapsulating Chemical Suit available
                 with optional aluminizing Kevlar cover
                 flash suit.
                                            Safeware, Inc.                #712
                                            3838 Ironwood Place
                                            Landover, MD  20785        301-322-2800
                                            Products for the safety  and  protection of
                                            people.
Schlegel Lining               #211
Technology, Inc.
P. 0. Box 7730             409-273-3066
The Woodlands, TX 77380
Manufactures and installs  lining systems
of SCHLEGEL sheet, a high  density
polyethylene liner in  single  pieces,  34'
wide and up to 900' long,  and thicknesses
of 60, 80, 100 mils.   The  liner is  seamed
with an extrusion welding  process.
Schlegel is the only company  in the
lining industry offering single-source
responsibility for system.
                                                             Slurry Systems                #700
                                                             7100 Industrial Avenue
                                                             Gary, IN 46406            312-721-9797
                                                             Slurry Systems presents VIBRATED BEAM
                                                             slurry cut off wall technology, specially
                                                             formulatd slurries and ASPEMIX
                                                             resistant to most aggressive  chemicals,
                                                             and MANPOWER with technical  'know-how1
                                                             and hands-on experience   providing a
                                                             successful approach for toxic waste
                                                             containment.
                                            Soletanche & Rodio, Inc.     #201
                                            1340 Old Chain Bridge Road
                                            McLean, VA 22101          703-821-6727
                                            Soletanche and Rodio, Inc., provides
                                            specialty underground construction
                                            techniques for seepage control and waste
                                            isolation including:  soil bentonite and
                                            cement bentonite slurry wall cutoffs, and
                                            all types of soil and rock grouting.
                                            Stablex-Reutter,  Inc.         #904
                                            P.  O.  Box 499
                                            Camden,  NJ  08101         609-541-6700
                                            Stablex-Reutter,  Inc., is a consulting
                                            environmental laboratory specializing in
                                            analysis and characterization of
                                            industrial process waste streams.
                                            Stablex-Reutter's expertise encompasses a
                                            variety of analytical protocols
                                            including:  RCRA testing; priority
                                            pollutants analysis; waste
                                            characterization for manifests; chemical
                                            analysis of raw wastes; field sampling of
                                            drums, spills,  tanks;  and studies of
                                            industrial wastes treatment.
                                            Stokes Division/             #803
                                            Pennwalt Corporation
                                            3 Parkway                 215-587-7618
                                            Philadelphia,  PA 19102
                                            The Stokes Vacuum Solid Recovery System
                                            is a compact,  highly efficient rotary
                                            drying unit that captures 90-95% of spent
                                            solvents from a wide range of slurry and
                                            sludges.  With the Stokes Recovery
                                            System, it is possible to reduce the
                                            residual solvent in the waste to less
                                            than 1% which greatly reduces the
                                            environmental problems connected with
                                            their disposal.
                                            TRC Environmental            #101   109
                                            Consultants, Inc.
                                            800 Connecticut Blvd.     203-289-8631
                                            East Hartford, CT 06108
                                            TRC Environmental Consultants, Inc.,  is
                                            headquartered in East Hartfod,
                                            Connecticut, with offices in Denver,
                                            Colorado, and Washington, D.C.  TRC
                                                                                                       EXHIBITOR LIST    465
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specializes in innovative solutions to
air, water,and hazardous pollution
problems.  Services in  hazardous waste
include determination of contaminated
migration, evaluation and design of
remedial actions, waste management
engineering preparation of RCRA Part B
permit application site audits, and real
timejionitoring of toxic pollutants using
TAGA  , a mobile MS/MS system owned by
TRC Advanced Analytics Inc.
Technos, Inc.                 1414
3333 NW 21st Street
Miami, FL   33142           305-634-4507
Technos Inc., specializes  in  site
investigation at hazardous waste sites
utilizing their state-of-the-art systems
approach for optimum cost-effective
results.
Triangle Resources            1812
Industries
P. 0. Box 370              301-953-9583
Laurel, MD  20707
Operating from  RCRA-permitted facilities
in Maryland, North  Carolina  and
Tennessee,  TRI  is a 90-person service
company offering  (1)  hazardous waste
packaging,  transport and  disposal;  (2)
remedial action cleanup;  (3)  24-hour
emergency response; (4) safety training;
(5)  safety  supplies and packaging
materials;  and  (6)  regulatory compliance
programs.
Trofe  Incineration,  Inc.      1706
Pine Road
Mt. Laurel,  NJ  08054      609-235-3030
Trofe  has  incineration  systems  for  solid
and liquid wastes,  hazardous  or
nonhazadous  including waste heat recovery
and co-generation  capabilities.
US Array Corps  of  Engineers    1310
P. 0.  Box  103
Downtown Station          402-221-7317
Omaha, NE  68101
The  U. S.  Army Corps  of  Engineers  and  the
U. S.  EPA  have joined forces  to clean  up
Federal Lead hazardous waste  sites under
the  Superfund  Program.   The booth  will  be
manned by  Corps'  personnel to assist
architect-engineer  firms and  construction
contractors take  advantage of work
available  to them under  Superfund  through
the  Corps  of Engineers.
US Ecology, Inc.              1301
P. 0. Box  7246
Louisville, KY   40207      502-426-7160
US Ecology operates  low-level radioactive
disposal  landfills  in  Washington and
Nevada, and chemical disposal landfills
in Nevada and Texas.  The company is
affiliated with chemical waste
incinerator facilities in Kentucky and
treatment facilities in Illinois and
Tennessee.  Other services include
disposal of solid PCB materials,
engineering services, laboratory
services, and seminars.
US Environmental             1501 - 507
Protection Agency
Raritan Depot             201-321-6677
Edison, NJ 08837
The USEPA has been actively involved at
all levels of hazardous waste management
with the investigation, categorization,
response activities and remedial actions
at hundreds of uncontrolled hazardous
waste sites.  This display exhibits
products for the protection of response
personnel, and provides information on
current Superfund activities, the latest
response equipment for site
investigation, research and development
for long term remedial action and EPA's
mobile treatment systems.
US Geological Survey         11102-1106
27 Butternut Way
Sterling, VA 22092        703-860-6162
U.S. Geological Survey research
concerning hydro-geologic considerations
for safe disposal of hazardous wastes.
Watersaver Company, Inc.     1512
P. O. Box 16465
Denver, CO 80216          303-623-4111
Watersaver Company is involved in the
fabrication of flexible membrane liners,
both reinforced and unreinforced.
Specializing in PVC, CPE, and HYPALON for
solid waste landfills, surface
impoundments, and hazardous waste
containment.
Wehran Engineering           1215
Corporation
666 East Main Street      914-343-0660
Middletown, NY  10940
Wehran, a multidisciplinary firm
specializing in the field of waste
management, provides engineering and
scientific services from offices located
in the northeast and midwest. With 15
years of hands-on experience in all
facets of land disposal engineering -
from waste sampling exhumation to
subsurface cut-off walls and impermeable
caps   our staff of 150 has earned a
national reputation as a leader in the
practical application of  innovative
technology to solid and hazardous waste
disposal.
Westbay Instruments Ltd.      1814
507 E. Third Steet
North Vancouver, B.C.     604-984-4215
Canada V7L 1G4
Westbay Instruments Ltd.  -  Designers and
manufacturers of the MP System,  a modular
multi-ported groundwater  instrumentation
system for pressure measurements and
groundwater sampling.  Components include
plastic or stainless steel  casing and
couplings, inflatable or  mechanical
packers and pneumatic or  electric
pressure probes and sampling  probes.
Weston Geophysical           1515
Corporation
P. 0. Box 550             617-366-9191
Westhorough, MA  01581
Weston Geophysical Corporation has
provided integrated multidisciplinary
geophysical and geological consulting
services on over 1,000 projects since its
founding in 1957.  We specialize in
state-of-the-art, non-destructive
geophysical techniques which when
combined with our geologic expertise
enable acquisition and interpretation of
data necessary for preliminary, remedial
and feasibility investigations.  Weston
has recently adapted Vertical Seismic
Profiling, an oil industry technique, to
the evaluation of the destribution and
hydrolic conductivity of fracture zones
for analyzing contaminant flow pathways.
World Information Systems    1408
P. 0. Box 535
Cambridge, MA 02238       617-491-5000
Zimpro, Inc.                 1300 « 302
Military Road
Rothschild, WI 54474      715-359-7211
Zimpro Inc., provides wet air oxidaton
systems, PACT units, furnaces, rapid sand
filters for hazardous and toxic
wastewater treatment.  Package units are
available for groundwater and leachate
treatment.  Zimpro has more than 35 units
operating on HTW in the field.  Complete
laboratory, pilot plant, design, and
operation services are available as
required.  The company is based in
Wisconsin, and is a subsidiary of
Sterling Drug Inc.
466    EXHIBITOR LIST
-------
                        PMOMTIES LIST AND PROPOSED UPDATE SITES
UNITED STATES

SITE NAME/LOCATION
ALASKA (10)

ALABAMA (04)
Mowbray Engineering Co., Greenville
Perdido Ground Water Contamination, Perdido
Triana-Tennessee River (formerly Triana
  (Redstone) Arsenal), Limestone/Morgan
  Counties
Ciba-Geigy Corp. (Mclntosh Plant), Mclntosh
Olin Corp. (Mclntosh Plant), Mclntosh
Stauffer Chemical Co. (Cold Creek Plant)
  Bucks
Stauffer Chemical Co. (Lemoyne Plant), Axis

ARKANSAS (06)
Cecil Lindsey, Newport
Crittenden County Landfill8, Marion
Frit Industries, Walnut Ridge
Gurley Pit, Edmondson
Industrial Waste Control, Fort Smith
 Mid-South Wood Products, Mena
 Vertac, Inc., Jacksonville

 AMERICAN SOMOA (09)
Taputimu Farm*, Island of Tutuila

 ARIZONA (09)
 Indian Bend Wash Area, Scottsdale-Tempe-
  Phoenix
 Kingman Airport Industrial AreaP, Kingman
 Litchfield Airport Area, Goodyear/Avondale
Mountain View Mobile Home Estates*,
  (formerly Globe),  Globe
 19th Avenue Landfill, Phoenix
Tuscon Airport Area, Tucson

CALIFORNIA (09)
Aerojet General Corp., Rancho Cordova
Celtor Chemical Works, Hoopa
Coast Wood Preserving,  Ukiah
Iron Mountain Mine, Redding
Jibboom Junkyard,  Sacramento
Liquid Gold Oil Corp., Richmond
MGM Brakes, Cloverdale
McCoIl, Fullerton
Purity Oil Sales, Inc., Malaga
Selma Treating Co., Selma
Stringfellow*,  Glen Avon Heights
Atlas Asbestos Mine, Fresno County
Coalinga Asbestos Mine, Coalinga
NPL Update Total

406   133   546t
 3
 X
 X
 X
 6
 X

 X
 X
 X
 X
 X

 1
 X
 X

 X

 X
 X
 X

11
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X
       X
       X

       X
       X
—    1
       —    5
     19
       X
       X
t Includes seven sites proposed in Dec. 1982 on which rulemaking is pending.
* Designated as State's top priority.
c Not included because site was cleaned up.
P Rulemaking pending.
s Not included because proposed score was revised.
I Not included because no longer designated as State's top priority.
(00) EPA Regions
                                            NPL Update Total

Del Norte County Pesticide Storage Area,
  Crescent City                                      X
Koppers Co., Inc. (Oroville Plant), Oroville             X
San Gabriel Valley (Area 1), El Monte                  X
San Gabriel Valley (Area 2), Baldwin
  Park Area                                        X
San Gabriel Valley (Area 3), Alhambra                  X
San Gabriel Valley (Area 4), La Puente                  X

NORTHERN MARIANA ISLANDS (09)
PCB Warehouse, Saipan

COLORADO (08)                             6      3
California Gulch, Leadville                     X
Central City-Clear Creak,  Idaho Springs          X
Denver Radium, Denver                       X
Marshall Landfill*, Boulder County              X
Sand Creek Industrial, Commerce City           X
Woodbury Chemical Co.,  Commerce City        X
Broderick Wood Products, Denver              ,       X
Lincoln Park, Canon City                             X
Lowry Landfill, Arapahoe County                      X

CONNECTICUT (01)                         4      2
Beacon Heights Landfill, Beacon Falls            X
Laurel Park, Inc. (formerly Laurel Park
  Landfill), Naugatuck Borough                X
Solvents Recovery Service of New England
  Southington                                X
Yaworski Waste Lagoon, Canterbury             X
Kellogg-Deering Well Field, Norwalk                   X
Old Southington Landfill,  Southington                 X

DISTRICT OF COLUMBIA (03)                —    —

DELAWARE (03)                             8      1
Army Creek Landfill (formerly Delaware
  Sand & Gravel—Llangollen Army Creek
  Landfills), New Castle County                X
Delaware City PVC Plant (formerly Stauffer
  Chemical Co.), Delaware City                 X
Delaware Sand & Gravel Landfill (formerly
  Delaware Sandd & Gravel—Llangollen
  Army Creek Landfills), New Castle County     X
Harvey & Knott Drum, Inc., Kirkwood           X
New Castle Spill (formerly Tris Spill), New
  Castle County                               X
New Castle Steel, New Castle County             X
Tybouts Corner Landfill*, New Castle County     X
Wildcat Landfill, Dover                        X
Old Brine Sludge Landfill, Delaware City               X
                FLORIDA (04)                              25
                Alpha Chemical Corp., Galloway                X
                American Creosote Works, Pensacola            X
                Brown Wood Preserving, Live Oak              X
                Coleman-Evans Wood Preserving Co.,
                  Whitehouse                                x
                Davie Landfill (formerly Broward County
                  Solid Waste Disposal Facility), Davie           X
                Florida Steel Corp., Indiantown                 X
                Gold Coast Oil Corp., Miami                   X
                                                       29
                                                                                       NATIONAL PRIORITIES LIST
                                                                                  467
-------
Hollingsworth Solderless Terminal Co.,
  Fort Lauderdale
Kassauf Kimerling Battery (formerly Timber
  Lake Battery Disposal),  Tampa
Miami  Drum Services (formerly a part of
  Biscayne Aquifer), Miami
Munisport Landfill, North Miami
Northwest 58th Street Landfill (formerly a
  part  of Biscayne Aquifer), Hialeah
Parramore Surplus, Mount Pleasant
Pickettville Road Landfill, Jacksonville
Pioneer Sand Co., Warrington
Reeves Southeastern Galvanizing Corp., Tampa
Sapp Battery Salvage, Cottondale
Schuylkil) Metals Corp., Plant City
Sherwood Medical Industries, Deland
62nd Street Dump, Tampa
Taylor Road Landfill, Seffner
Tower Chemical Co., Clermont
Varsol Spill (formerly a part of
  Biscayne Aquifer), Miami
Whitehouse Oil Pits, Whitehouse
Zellwood Ground Water Contamination,
  Zellwood
Cabot/Koppers, Gainesville
Hipps  Road Landfill, Duval County
Pepper Steel & Alloys, Inc.,  Medley
Tri-City Oil Conservationist, Inc., Temple
  Terrace

GEORGIA (04)
Hercules 009 Landfill, Brunswick
Monsanto Corp.  (Augusta Plant), Augusta
Olin Corp. (Areas 1, 2 & 4), Augusta
Powersville, Peach County

GUAM (09)
Ordot  Landfill*,  Ordot

HAWAII (09)

IOWA (07)
Aidex  Corp.", Council Bluffs
Des Moines TCE (formerly DICO),
  Des  Moines
Labounty, Charles City

IDAHO (10)
Arrcom (Drexler Enterprises), Rathdrum
Bunker Hill Mining & Metallurgical,
  Smelterville
Flynn  Lumber Co.s, Caldwell
Pacific Hide & Fur Recycling Co., Pocatello
Union Pacific Railroad  Co., Pocatello

ILLINOIS (05)
A & F Materials  Reclaiming, Inc., Greenup
Acme  Solvent Reclaiming, Inc.,Morristown
Belvidere Municipal Landfill, Belvidere
Byron  Salvage Yard, Byron
Cross Brothers Pail Recycling, Pembrook Twp
Galesburg/Koppers, Galesburg
Johns-Manville Corp., Waukegan
Lasalle Electric Utilities, La Salle
Outboard Marine Corp.*, Waukegan
Velsicol Chemical Corp. (Marshall Plant),
  Marshall
Wauconda Sand  & Gravel, Wauconda
                                             NPL Update Total
                                    X
                                    X

                                    X
                                    X
                                    X
                                    X
                                    X
                                    X
                                    X
                                    X
                                    X
                                    X
                                    X

                                    X
                                    X
                                    1
                                    X
                                    3
                                    X

                                    X
                                    X

                                    2
                                    X
                                   11
                                    X
                                    X
                                    X
                                    X
                                    X
                                    X
                                    X
                                    X
                                    X

                                    X
                                    X
                                          X
                                          X
                                          X
                                          4     4
                                          X
                                          X
                                          X
                                          X

                                          —     1
X
X
—   11
                                                              NPL Update Total
                 INDIANA (OS)                                12      5     17
                 Envirochem Corp., Zionsville                    X
                 Fisher Calo, LaPorte                           X
                 Lake Sandy Jo (M&M Landfill), Gary            X
                 Lemon Lane Landfill, Bloomington              X
                 Main Street Well Field, Elkhart                  X
                 Marion (Bragg) Dump, Marion                  X
                 Midco I, Gary                                 X
                 Neal's Landfill, Bloomington                    X
                 Ninth Avenue Dump, Gary                      X
                  Parrot Road Dump9, Seymour
                 Seymour Recycling Corp.*, Seymour             X
                 Wayne Waste Oil, Columbia City                X
                 Wedzeb Enterprises, Inc., Lebanon               X
                 American Chemical Service, Griffith                    X
                 Bennett Stone Quarry, Bloomington                     X
                 Northside Sanitary Landfill, Zionsville                   X
                 Poer Farm, Hancock County                           X
                 Reilly Tar & Chemical Corp.,  Indianapolis               X

                 KANSAS (07)                                  4—4
                 Arkansas City  Dump*, Arkansas City            X
                 Cherokee County (formerly TAR Creek),
                   Cherokee County                            X
                 Doepke Disposal (Holliday), Johnson County      X
                 Johns' Sludge Pond, Wichita                    X

                 KENTUCKY (04)                              6—6
                 A.L. Taylor (Valley of the Drums)*, Brooks       X
                 AircoP, Calvert
                 B.F. Goodrich, Calvert City                     X
                 Distler Brickyard, West Point                    X
                 Distler Farm, Jefferson County                  X
                 Lee's Lane Landfill, Louisville                  X
                 Newport Dump, Newport                       X

                 LOUISIANA (06)                              3      1     4
                 Bayou Bonfouca,  Slidell                         X
                 Bayou SorrelP, Bayou  Sorrel
                 Cleve Reber, Sorrento                          X
                 Old Inger Oil Refinery*,  Darrow                 X
                 Petro-Processors,  Scotlandville
MASSACHUSETTS (01)                       14
Baird & McGuire, Holbrook                     X
Cannon Engineering Corp. (CEC),
  Bridgewater                                  X
Charles George Reclamation Trust Landfill,
  Tyngsborough                                X
Groveland Wells, Groveland                     X
Hocomonco Pond, Westborough                 X
Industri-Plex 128 (formerly Mark Phillip
  Trust), Woburn                              X
New Bedford*, New Bedford                    X
Nyanza Chemical Waste Dump, Ashland          X
PSC Resources, Palmer                         x
Plymouth Harbor/Cannon Engineering Corp.,
  Plymouth                                   x
Re-Solve, Inc., Dartmouth                      x
Silresim Chemical Corp., Lowell                 x
W.R. Grace & Co., Inc. (Acton Plant),
  Acton                                       x
Wells G4H, Woburn                           X
Iron Horse  Park, Billerica
Sullivan's Ledge,  New Bedford
X

2
                                                                          16
468
NATIONAL PRIORITIES LIST
-------
MARYLAND (03)
Limestone Road, Cumberland
Middletown Road Dump, Annapolis
Sand, Gravel & Stone, Elkton

MAINE (01)
F. O'Connor Site, Augusta
McKin Co., Gray
Pinette's Salvage Yard, Washburn
Saco Tannery Waste Pits, Saco
Winthrop Landfill, Winthrop

MICHIGAN (05)
Anderson Development Co., Adrian
Auto Ion Chemicals, Inc.,  Kalamazoo
Berlin & Farro, Swartz Creek
Butterworth No. 2 Landfill, Grand Rapids
Cemetery Dump, Rose Center
Cbarlevoix Municipal Well, Charlevoix
Chem Central, Wyoming Twp
Qare Water SupplyP, Clare
Cliff /Dow Dump, Marquette
Duell & Gardner Landfill,  Dal ton Twp
ElectrovoiceP, Buchanan
Forest Waste Products, Otisville
 G&H Landfill, Utica
 Grand Traverse Overall Supply Co.,
  Greilickville
 Gratiot County Golf Coursec, St. Louis
 Gratiot County Landfill*, St. Louis
 Hedblum Industries, Oscoda
 Ionia City Landfill,  Ionia
 K & L Avenue Landfill,  Oshtemo Twp
 Kentwood Landfill,  Kent wood
 Liquid Disposal, Inc., Utica
 Littlefield Township DumpP, Oden
 Mason County Landfill, Pere Marquette Twp
 McGraw Edison Corp., Albion
 Northernaire Plating, Cadillac
 Novaco Industries, Temperance
 Organic Chemicals,  Inc., Grandville
 Ossineke Ground Water Contamination,
  Ossineke
 Ott/Story/Cordova  Chemical Co., Dalton Twp
 Packaging Corp. of America, Filer City
 Petoskey  Municipal  Well Field, Petoskey
 Rasmussen's Dump, Green Oak Twp
 Rose Township Dump, Rose Twp
 SCA Independent Landfill, Muskegon Heights
 Shiawassee River, Howell
 Southwest Ottawa County  Landfill, Park Twp
Sparta Landfill,  Sparta Twp
Spartan Chemical Co., Wyoming
Spiegelberg Landfill, Green Oak Twp
Springfield Township Dump, Davisburg
Tar Lake, Mancelona  Twp
U.S. Aviex, Howard Twp
Velsicol Chemical Corp. (St. Louis Plant),
  St. Louis
Verona Well Field, Butler Creek
Wash King Laundry, Pleasant Plains
  Township
Whitehall Well FieldP, Whitehall
Burrows Sanitation, Hartford
Metamora Landfill, Metamora
Sturgis Municipal Wells, Sturgis
NPL Update Total
 3     -    3
 X
 X
 X
 5
 X
 X
 X
 X
 X

41
 X
 X
 X
 X
 X
 X
 X

 X
 X

 X
 X

 X

 X
 X
 X
 X
 X
 X

 X
 X
 X
 X
 X

 X
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X

 X
 X

 X
       —    5
44
       X
       X
       X
                                              NPL Update Total
MINNESOTA (05)                             10    13    23
Burlington Northern, Brainerd/Baxter             X
FMC Corp. (Fridley Plant), Fridley               X
Koppers Coke, St. Paul                          X
Lehillier/Mankato, Lehillier/Mankato             X
NL Industries/Taracorp/Golden Auto,
  St. Louis Park                                X
New Brighton/Arden Hills, New Brighton         X
Oakdale Dump, Oakdale                         X
Reilly Tar & Chemical Corp.*, St. Louis Park      X
South Andover (formerly Andover Sites),
  Andover                                     X
Waste Disposal Engineering, Andover             X
Arrowhead Refinery Co., Hermantown                  X
Boise Cascade/Onan/Medtronics, Fridley                X
General Mills/Henkel Corp., Minneapolis                X
Joslyn Manufacturing & Supply Co., Brooklyn
  Center                                             X
MacGillis & Gibbs Co./Bell Lumber & Pole
  Co., New Brighton                                  X
Morris Arsenic Dump, Morris                           X
Nutting Truck & Caster Co., Faribault                   X
Perham Arsenic, Perham                               X
St. Louis River, St. Louis County                       X
St. Regis Paper Co., Cass Lake                         X
Union Scrap, Minneapolis                              X
Washington County Landfill, Lake Elmo                 X
Whittaker Corp., Minneapolis                           X

MISSOURI (07)                                6      1     7
Ellisville*, Ellisville                             X
Fulbright Landfill, Springfield                    X
Minker/Stout/Romaine Creek (formerly
  Arena 2: Fills 1 & 2), Imperial                 X
Shenandoah Stables (formerly Arena 1:
  Shenandoah Stables), Moscow Mills            X
Syntex Facility, Verona                         X
Times Beach, Times Beach                       X
Quail Run Mobile Manor, Gray Summit                X

MISSISSIPPI (04)                              —    1     1
Plastifax, Inc.1, Gulfport
Flowood*, Flowood                                  X

MONTANA (08)                               4      1     5
Anaconda Smelter, Anaconda                    X
Libby Ground Water Contamination, Libby       X
Mill town Reservoir Sediments, Milltown          X
Silver Bow Creek, Silver Bow/Deer Lodge
  Counties                                    X
East Helena Smelter, East Helena                      X

NORTH CAROLINA (04)                       3—3
Chemtronics,  Inc., Swannanoa                   X
Martin Marietta, Sodyedo,  Inc., Charlotte         X
PCB Spills*, 210 Miles of Roads                 X

NORTH DAKOTA (08)                         1     —    1
Arsenic Trioxide*, Southeastern                  X

NEBRASKA (07)                               —    —    —
Phillips Chemical Co.s, Beatrice

NEW HAMPSHIRE (01)                        7     3     10
Auburn Road Landfill, Londonderry             X
Dover Municipal Landfill, Dover                 X
Keefe Environmental Services (KES), Epping      X
                                                                                           NATIONAL PRIORITIES LIST
                                                                                      469
-------
Ottati & Gogs/Kingston Steel Drum, Kingston
Somersworth Sanitary Landfill, Somersworth
Sylvester", Nashua
Tinkham Garage, Londonderry
Kearsage Metallurgical Corp., Conway
Savage Municipal Water Supply, Milford
South Municipal Water Supply Well,
  Peterborough

NEW JERSEY (02)
A.O. Polymer, Sparta Twp
American Cyanamid Co., Bound Brook
Asbestos Dump, Millington
Beachwood/Berkley Wells, Berkley Twp
Bog Creek Farm, Howell Twp
Brick Township Landfill, Brick Twp
Bridgeport Rental & Oil Services, Bridgeport
Burnt Fly Bog, Marlboro Twp
Caldwell Trucking Co., Fairfield
Chemical Control, Elizabeth
Chemsol, Inc., Piscataway
Combe Fill North Landfill, Mount Olive Twp
Combe Fill South Landfill, Mount Olive Twp
CPS/Madison Industries, Old Bridge Twp
D'lmperio Property, Hamilton Twp
Denzer & Schafer X-Ray Co., Bayville
Dover Municipal Well 4, Dover Twp
Ellis Property, Evesham Twp
Evor Phillips Leasing, Old Bridge Twp
Fair Lawn Well Field, Fair Lawn
Friedman Property (formerly Upper Freehold
  Site), Upper Freehold Twp
Gems Landfill, Gloucester Twp
Goose Farm, Plumstead Twp
Helen  Kramer Landfill, Mantua Twp
Hercules, Inc. (Gibbstown Plant), Gibbstown
Imperial Oil Co., Inc./Champion Chemicals
  (formerly Imperial Oil Co., Inc.),
  Morgan ville
JIS Landfill,  Jamesburg/South Brunswick Twp
Jackson Township Landfill, Jackson Twp
Kin-Buc  Landfill, Edison Twp
King of Prussia, Winslow Twp
Krysowaty Farm, Hillsborough
Lang Property, Pemberton Twp
Lipari Landfill, Pitman
Lone Pine Landfill, Freehold Twp
MAT Delisa Landfill, Asbury Park
Mannheim Avenue Dump, Galloway Twp
May wood Chemical Co., Maywood/Rochelle
  Park
Metaltec/Aerosystems, Monroe Twp
Monroe Township Landfill, Monroe Twp
Montgomery Township Housing Development
  Montgomery Twp
Myers Property, Franklin Twp
NL Industries, Pedricktown
PJP Landfill, Jersey City
Pepe Field, Boonton
Pijak Farm, Plumstead Twp
Price Landfill*, Pleasantville
Reich  Farms, Pleasant Plains
Renora,  Inc., Edison Twp
Ringwood Mines/Landfill,  Ringwood Borough
Rockaway Borough Well Field, Rockaway Twp
                                 NPL Update Total
                                  X
                                  X
                                  X
                                  X
                                        X
                                        X
                                 65
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X
                                  X

                                  X
                                  X
                                  X
                                  X
                                  X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X

                                   X
                                   X
                                   X

                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                       20    85
                                            NPL Update Total
Rockaway Township Wells, Rockaway            X
Rocky Hill Municipal Wen, Rocky Hill
  Borough                                   X
Roebling Steel Co., Florence                    X
Sayreville Landfill, Sayreville                    X
Scientific Chemical Processing, Inc., Carlstadt     X
Sharkey Landfill, Parsippany/Troy Hills          X
South Brunswick Landfill, South Brunswick       X
Spence Farm, Plumstead Twp                   X
Swope Oil & Chemical Co., Pennsauken          X
Syncon Resins, South Kearny                    X
Toms River Chemical, Toms River               X
U.S. Radium Corp., Orange                    X
Universal Oil Products (Chemical Division),
  East Rutherford                             X
Vineland State School, Vineland                 X
Williams Property, Swainton                    X
Chemical Leaman Tank Liners, Inc.,
  Bridgeport                                        X
Cooper Road, Voorhees Twp                          X
De Rewal Chemical Co., Kingwood Twp                X
Delilah Road, Egg Harbor Twp                        X
Diamond Alkali Co., Newark                          X
Ewan Property,  Shamong Twp                         X
Florence Land Recontouring, Inc.,  Landfill,
  Florence Twp                                     X
Hopkins Farm, Plumstead Twp                        X
Landfill & Development Co., Mount Holly              X
Nascolite Corp., Millville                              X
Radiation Technology, Inc., Rockaway Twp             X
Shieldalloy Corp., Newfield Borough                    X
Tabernacle Drum Dump, Tabernacle Twp               X
Upper Deerfield Township Sanitary Landfill,
  Upper Deerfield Twp                               X
Ventron/Velsicol, Woodridge Borough                  X
Vineland Chemical Co., Inc., Vineland                  X
W.R. Grace & Co., Inc. (Wayne Plant),
  Wayne Twp                                       X
Wilson Farm, Plumstead Twp                         X
Woodland Route 532 Dump, Woodland Twp             X
Woodland Route 72 Dump, Woodland Twp             X
NEW MEXICO (06)                           4
AT & SF/Clovis, Clovis                        X
Homestake Mining Co., Milan                   X
South Valley*, Albuquerque                     X
United Nuclear Corp., Church Rock              X

NEVADA (09)                                —

NEW YORK (02)                             27
American Thermostt Co., South Cairo            X
Batavia Landfill, Batavia                       X
Brewster Well Field, Putnam County             X
Facet Enterprises, Inc., Elmira                   X
Fulton Terminals, Fulton                       X
GE Moreau, South  Glens Falls                   X
Hooker (Hyde Park), Niagara Falls              X
Hooker (102nd Street), Niagara Falls             X
Hooker (S-Area), Niagara Falls                  X
Kentucky Avenue Well Field, Horseheads         X
Love Canal, Niagara Falls                      X
Lndlow Sand & Gravel, Clayville                X
Marathon Battery Corp., Cold Springs            X
Mercury Refining, Inc., Colonie                 X
—    4
     29
 470
NATIONAL PRIORITIES LIST
-------
Niagara County Refuse, Wheatfield
Old Bethpage Landfill, Oyster Bay
Olean Well Field, Olean
Pollution Abatement Services (PAS)*, Oswego
Port Washington Landfill, Port Washington
Ramapo Landfill, Ramapo
Sinclair Refinery, Wellsville
Solvent Savers, Lincklaen
Syosset Landfill, Oyster Bay
Vestal Water Supply Well 1-1, Vestal
Vestal Water Supply Well 4-2, Vestal
  (formerly one site)
Wide Beach Development, Brant
York Oil Co., Moria
General Motors/Central Foundry Division,
  Massena
Hudson River PCBs, Hudson River

OHIO (05)
Allied Chemical & Ironton Coke, Ironton
Arcanum Iron & Metal, Darke County
Big D Campground, Kingsville
Bowers Landfill, Circleville
Buckeye Reclamation, St. Clairsville
Chem-Dyne*, Hamilton
Coshocton Landfill, Franklin Twp
E.H. Schilling Landfill, Hamilton Twp
Fields Brook, Ashtabula
Fultz Landfill, Jackson Twp
Luskin/Poplar Oil Co. (formerly Poplar Oil
  Co.), Jefferson Twp
Nease Chemical, Salem
New Lyme Landfill, New Lyme
Old Mill (formerly Rock  Creek/Jack Webb),
  Rock Creek
Pristine, Inc., Reading
Skinner Landfill, West Chester
Summit National, Deerfield Township
Van Dale Junkyard3, Marietta
Zanesville Well Field, Zanesville
Miami County Incinerator, Troy
Powell Road Landfill, Dayton
South Point Plant,  South Point
United Scrap Lead Co., Inc., Troy

OKLAHOMA (06)
Hardage/Criner, Criner
Tar Creek (Ottawa County), Ottawa County
Compass Industries, Tulsa
Sand Springs Petrochemical Complex,
  Sand Springs

OREGON (10)
Gould, Inc., Portland
Teledyne Wah Chang (Albany),  Albany
United Chrome Products, Inc.,  Corvalis

PENNSYLVANIA (03)
Blosenski Landfill, West  Cain Twp
Brodhead Creek, Stoudsburg
Bruin Lagoon, Bruin Borough
Centre County Kepone, State College Borough
Craig Farm Drum, Parker
Douglassville Disposal, Douglassville
Drake Chemical, Lock Haven
 NFL Update Total
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X

 X
 X

       X
       X
18
 X
 X
 X
 X
 X
 X
 X
 X
 X
 X

 X
 X
 X

 X
 X
 X
 X
 X
 X
 2
 X
 X
 2
 X
 X


30
 X
 X
 X
 X
 X
 X
 X
22
       X
       X
       X
       X
       X

       X
       1
39
                                              NPL Update Total
Enterprise Avenue, Philadelphia                  X
Fischer & Porter Co., Warminster                X
Havertown PCP, Haverford                     X
Heleva Landfill, North Whitehall Twp            X
Hranica Landfill, Buffalo Twp                   X
Kimberton, Kimberton Borough                  X
Lackawanna Refuse, Old Forge Borough          X
Lehigh Electric & Engineering Co., Old Forge
  Borough                                    X
Llndane Dump, Harrison Twp                   X
Lord-Shope Landfill, Girard Twp                X
Malvern TCE, Malvern                         X
McAdoo Associates*, McAdoo Borough/Kline
  Twp                                        X
Metal Banks, Philadelphia                       X
Meyers Landfill, Eagleville                      X
Old City of York Landfill, Seven Valleys          X
Osborne Landfill,  Grove City                    X
Palmerton Zinc  Pile, Palmerton                  X
Presque Isle, Erie                               X
Resin Disposal,  Jefferson Borough               X
Stanley Kessler,  King of Prussia                  X
Voortman Farm, Upper Saucon Twp              X
Wade (ABM) (formerly ABM-Wade), Chester      X
Westline, Westline                              X
Berks Sand Pit,  Longswamp Twp                       X
Dorney Road Landfill, Upper MacungieTwp             X
East Mount Zion,  Springettsbury Twp                  X
Henderson Road, Upper Merion Twp                   X
Mill Creek Dump, Erie                                X
Industrial Lane, Williams Twp                         X
Taylor Borough Dump, Taylor Borough                 X
Tysons Dump, Upper Merion Twp                     X
Walsh Landfill,  Honeybrook Twp                      X

PUERTO  RICO (02)                            538
Barceloneta Landfill, Florida Afuera              X
Frontera Creek, Rio Abajo                      X
GE Wiring Devices, Juana Diaz                  X
Juncos Landfill, Juncos                         X
RCA Del Caribe, Barceloneta                    X
Fibers Public Supply Wells, Jobos                      X
Upjohn Facility, Barceloneta                           X
Vega Alta Public Supply Wells, Vega Alta               X

RHODE ISLAND (01)                          6—6
Davis Liquid Waste, Smithfield                   X
Landfill & Resource Recovery, Inc. (L & RR),
  North Smithfield                             X
Peterson-Puritan, Inc., Lincoln/Cumberland       X
Picillo Farm*, Coventry                         X
Stamina Mills, Inc. (formerly Forestdale-
  Stamina Mills, Inc.), North Smithfield          X
Western Sand & Grave), Burrillville               X

SOUTH CAROLINA (04)                       3     7    10
Carolawn, Inc., Fort Lawn                      X
SCRDI Bluff Road*, Columbia                  X
SCRDI Dixiana, Cayce                         X
Geiger (C&M Oil), Rantoules                          X
Independent Nail Co., Beaufort                        X
Kalama Specialty Chemicals, Beaufort                  X
Koppers Co., Inc. (Florence Plant), Florence             X
Leonard Chemical Co., Inc., Rock Hill                 X
                                                                                           NATIONAL PRIORITIES LIST
                                                                                      471
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Palmetto Wood Preserving, Dixianna
Wamchem, Inc., Burton

SOUTH DAKOTA (08)
Whitewood Creek*, Whitewood

TENNESSEE (04)
Amnlcola Dump, Chattanooga
Gallaway Pits, Gallaway
Lewisburg Dump, Lewisburg
Murray-Ohio Damp, Lawrenceburg
North Hollywood Dump*, Memphis
Velsicol Chemical Corp. (Hardeman County),
  Toone

TRUST TERRITORIES (09)
PCB Wastes*, Trust Territory of the
  Pacific Islands

TEXAS (06)
Bio-Ecology Systems, Inc., Grand Prairie
Crystal Chemical Co., Houston
French, Ltd., Crosby
Harris (Farley Street), Houston
Highlands Acid Pit, Highlands
Motco, Inc.*, La Marque
Slkes Disposal Pits, Crosby
Triangle Chemical Co., Bridge City
Geneva Industries (Fuhrmann Energy Corp.),
  Houston
Pig Road, New Waverly
United Creosoting Co., Conroe

UTAH (08)
Rose Park Sludge Pit*, Salt Lake City

VIRGINIA (04)
Cbisman Creek, York County
Matthews Electroplating*, Roanoke County
Saltville Waste Disposal Ponds, Saltville
U.S. Titanium, Piney River

VIRGIN ISLANDS (02)

VERMONT (01)
Old Springfield Landfill, Springfield
Pine Street Canal*, Burlington

WASHINGTON  (10)
Colbert Landfill, Colbert
Commencement Bay, Near Shore/Tideflats,
  Pierce County
                                   NFL UpUte Total
                                         X
                                         X
1
X

6
X
X
X
X
X
                                   X
                                   1     —
                                   8     3
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X

                                         X
                                         X
                                         X

                                   1     —
                                   X
                                         —    1
                                   4
                                   X
                                   X
                                   X
                                   X
                                   2
                                   X
                                   X

                                   10
                                   X
                                         —    6
           11
      —    4
      —    2
           14
                                             NPL Update Total
Commencement Bay, South Tacoma Channel,
  Tacoma                                     X
FMC Corp. (Yakima), Yakima                   X
Frontier Hard Chrome, Inc., Vancouver           X
Harbor Island (Lead), Seattle                    X
Kaiser Aluminum (Mead Works), Mead           X
Lake wood, Lakewood                           X
Pesticide Lab (Yakima), Yakima                  X
Western Processing Co., Inc., Kent               X
American Lake Gardens, Tacoma                       X
Greenacres Landfill,  Spokane County                   X
Queen City Farms, Maple Valley                        X
Rosch Property, Roy                                 X

WISCONSIN (05)                               —    20    20
City Disposal Corp Landfill, Dunn                      X
Delavan Municipal Well No. 4, Delavan                 X
Eau Claire Municipal Well Field, Eau Claire
  City                                               X
Janesville Ash Beds,  Janesville                         X
Janesville Old Landfill, Janesville                       X
Kohler Co. Landfill,  Sheboygan                        X
Lauer I Sanitary Landfill, Menomonee  Falls             X
Lemberger Transport & Recycling, Inc.,
  Franklin Twp                                      X
Master Disposal Service, Inc., Landfill,
  Brookfield                                         X
Mid-State Disposal, Inc. Landfill, Cleveland
Twp                                                X
Moss-American (Kerr-McGee Oil Co.),
  Milwaukee                                         X
Muskego Sanitary Landfill, Muskego                    X
Northern Engraving Co., Sparta                        X
Oconomowoc Electroplating Co., Inc.,
  Ashippin                                           X
Omega Hills  North Landfill,  Germantown               X
Onalaska Municipal Landfill, Onalaska                 X
Schmalz Dump, Harrison                              X
Scrap Processing Co., Inc., Medford                    X
Waste Research &  Reclamation Co., Eau Claire          X
Wheeler Pit,  La Prairie Twp                           X

WEST  VIRGINIA (03)                          4—4
Fike Chemical, Inc.,  Nitro                       X
Follansbee, Follansbee                           X
Leetown Pesticide, Leetown                      X
West Virginia Ordance*, Point Pleasant           X

WYOMING  (08)                               1      —     1
Baxter/Union Pacific Tie Treating, Laramie       X
472
NATIONAL PRIORITIES LIST
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