EPA 910/9-91-045 United States Environmental Protection Agency Region 10 1200 Sixth Avenue Seattle WA 98101 Hazardous Waste Division Supertund Branch ftEFA Superfund: Progress in Region 10 Alaska Idaho Oregon Washington September 1991 ------- Super Fund: Progress In Region 10 Executive Summary The purpose of this report is to provide perspective on the successes and challenges of the Environmental Protection Agency (EPA) Region 10 Superfund program. Superfund, the Federal program to clean up hazardous waste sites, is the focus of substantial activity in Region 10. Fifty of the oven 100 sites investigated by Region 10 are listed among the most hazardous in the nation. Superfund is now an established program. Its ambitious task and unique liability scheme gave the program an extended adolescence. Now Superfund shows rtselftobe a strong program to protect people and the environment. EPA has worked closely with States, communities, and other interested parties to develop effective Superfund cleanup remedies. Citizens, environmental groups, State and local officials, and industry representatives have participated in cleanup decisions. EPA Region 10 has used a variety of approaches, including newsletters, public meetings, and community workgroups, to inform and involve the public in its Superfund activities. Public involvement has contributed significantly to the successes of Region 10's program. Region 10Targeted Approach. The Region 10 Superfund program has aggressively moved to protect human health and the environment: • Sites are investigated quickly and early actions are taken to protect people and the environment. • The worst sitesareaddressedfirst, and evencomplicated sites are being cleaned up. Complex sites are stabilized quicklyto protect human health until a complete cleanup is undertaken. • The majority of cleanup work is financed by parties responsible for pollution at Superfund sites. Thefirststepinthe Superfund program is to makesites safe for people and theenvironment. At 63 sites inthe Northwest, EPAhas immediately removed hazardous wasteortaken other actions to stabilize and secure sites. In many cases, EPA'semergencycleanupsorother immediate actions do more than provide safety - they succeed in completely cleaning up the site. • Initial Investigations and Quick Cleanups Are a Priority. Region 10hasinvestigated'oven, 100'sites reported to it and performed emergency cleanups at 63 sites, many of which resulted in clean sites. Over 700 of the sites reported, those not posing the most serious threats, have been referred to States for further action if necessary. Superfund'snext step is to cleanup sites, tackling the worst sites first. Site characterization is an important activity. By determining the source and pathways for exposure to people and the environment, EPA can identify the worst sites and at least stabilize them until cleanup can occur. EPA has foundthat by breaking large sites into afew smaller units, it can attack first the most contaminated areaon-site or prevent the contamination from moving. The smaller units are more rapidly characterized, which means that cleanup can start sooner. • Focus on Smaller Bites for Clean Sites. Consistent with the national strategy for Superfund, Region 10 initiates early cleanups to reduce exposure to people and the environment. In Region 10, 23 emergency actions and 28 cleanup activities (6 initiated early to address significant threats) are underway or completed at the National Priorities List (NPL) sites managed by EPA. EPA uses strong enforcement to ensure that those responsible for the pollution clean it up at their own cost. • Superfund Leverages Cleanup by Responsible Parties. In Region 10, more than 50 percent of the emergency cleanups and 90 percent of the interim and final cleanups are being performed by responsible parties. Their contribution toward emergency cleanups, site studies, and cleanups is worth over $300 million, four times what has been spent in Federal Superfund dollars. Hazardous waste problems created in the past 40 or 50 years cannot be cleaned up overnight. The folbwing pages provide a brief overview of cleanup progress to date in Region 10. The structure of the report follows the Superfund cleanup process: • First Steps: Investigating Threats, Quick Cleanups • Long-Term Cleanups: NPL Sites • Enforcement: Polluters Clean Up or Pay Up • Conclusion: Superfund: Successful, Not Perfect AllinformationinthisreportappliestoEPA'sNorthwestRegion(Regipn 10): Alaska, Washington, Idaho,andOregon. The jnformationcoversRegion10SuperfurdsiteslistBdontheNationalPrioritiesList(NPU,exceptNPLsitesmanagedbyStates and by Federal facilities, e.g., those operated by the Departments of Defense and Energy. ------- el Super Fund: Progress in Region 10 First Steps: Investigating Threats, Quick Cleanups Finding the Worst Problems Over 1,100 of the 1,176 potential Superfund sites identified in the Northwest have been investigated by EPA Region 10. These sites were reported as possible threats by local governments, police or fire departments, nearby businesses, neighboring residents, or State or EPA inspectors. EPA's site investigations are comprehensive - - they combine on-site sampling and inspections with detailed investigations of business records of past activities. Fifty of these sites pose serious long-term threats, and EPA listed them on the National Priorities List (NPL). Another63 sites have been cleaned upor stabilized by EPA with short-term immediate work (called emergency cleanups or "removals"). Over 700 of the reported sites do not meet the criteria for listing on the Superfund National Priorities List (NPL) and are referred to State and local agencies for their appropriate follow-up, if needed. Sites in the screening process will continueto be added to the National Priority List. New listing criteria will increase the number of sites listed because of environmental concerns. Protecting A Community's Water Supply In 1981, EPA discovered that two major wells of the Lakewood Water District, which serves more than 10,000 people south of Tacoma, Washington, were contaminated with chlorinated organic chemicals. The Lakewood Water District took the wells out of production and notified its customers of the problem. Customers were requested to follow a water conservation plan. From 1981 to 1983, EPA investigated the site to determine the source of the contamination. EPA found that the contamination was coming from a commercial dry-cleaner. TheStateissuedanenforcementorderrequiringthecleaner to cease dumping solvent-containing matenals into the septic system. EPAnextstudiedtTBatmentsystems which would provide water to the water district and restrict the spread of contaminants in the aquifer. Lakewood Water District was concerned that the two shut wells were critical for providing drinking water and fire protection to 600 residents. EPA decided to construct aeration towers at the two wells to remove the organic solvents. The treated water was then distributed through the existing public water supply. The towers wereconstructed and in operation within six months. Following a more detailed investigation of the soil and groundwatercontaminationatthesitein 1985, EPAdecided to add a treatment system to extract solvents from contaminated soil. The groundwater and soils treatment systems are expected to complete the site cleanup next year. Figure 1: Region 10 Site Reporting and Investigation Many sites are reported. Not all require cleanup, but steps must be taken to determine how each reported site must be dealt with. (Sites Cleaned Up or Stabllbed) ------- Super Fund: Progress in Region 10 Protecting People and the Environment from Urgent Threats. EPA addresses the most urgent threats immediately. EPA's emergency crews remove hazardous materials and stabilize and secure sites. If drinking water is contaminated, EPA provides bottled water immediately and connects homes to a safe water supply as soon as possible. While emergency cleanups are fast responses, they also can be significant efforts. Barrels with mysterious contents must be sampled, and safely removed in case of dangerous reactions or explosions. Proper disposal or recycling must also be assured before removal from the site. EPA directly and through enforcement actions has performed emergency cleanups at 86sites (23 atNPL sites, 63 at non-NPL sites) in the Northwest. Many times, an emergency cleanup is all that is necessary to clean up a site. Whether for accidental spills ordeliberatedumping, EPAcanoften remove contamination completely, especially if it is concentrated. While EPA moves quickly to remove the hazardous materials, EPA takes time to ensure the action is thorough. Emergency cleanups then result in a clean, safe site. A typical emergency cleanup costs between $250 thousand and $2 million and takes from several weeks to a year to complete. In most cases, the site is then clean enough for use. Cleaning Up an Illegal Dump In January 1990, EPA's Office ofCriminal Investigators notified Region 10'sSuperfundprogram aboutpossible illegal disposal of hazardous wasteat Ditch Creek Ranch in Wimer, Oregon. This information was forwarded from the State of Oregon DepartmentofEnvironmentalQuality. Superfund's site assessment discovered hazardous sludge and soils. Because of high levels of lead and copper, the site was determined to present an imminent threat to human health and the environment The emergency cleanup began with a community meeting that led to an investigation of the whole ranch. Duetoprevious gold mininginthearea, itwas difficulttodistinguish between mining disturbances anddisturbances causedby illegaldisposal of hazardous waste. Site activities included testing of 16 domestic wells to ascertain the threat posed to neighbors, 117 soil samples, 42 surface water samples, electromagnetic surveys, ground penetrating radar, xray florescence, aerial photo interpretation, and surface geology. Most of these activities were conducted between April and August, 1990. In September, EPA authorized emergency cleanup actions to address the contaminated areas. The owner of the ranch, who also owned Rogue Valley Circuits, a printed circuit board manufacturing and electroplating company, agreed to perform further studies on the extent ol'contamination, to remove the waste, and clean up the site under EPA Order and supervision. Emergency cleanup activities began in November 1990. Soil was excavated, debris sorted out, and all contaminated material removed. The dump area was covered with hay and planted with seeds and conifer saplings for slope stabilization. Wastewatergenerated'during cleaning and decontamination was transported to a licensed facility. Since the ranch includes the recharge area for the local drinking water aquifer, groundwater monitoring was installed for regular sampling. The neighboringwellshaveyettoshowcontamination.Atotalof35truckloadsofsoiT,and5truckloadsofdebris,wereremoved, treated, and disposed at a hazardous waste landfill. The last truck left the site in January, 1991. On May 28,1991, the PRP was found guilty of illegal transport and disposal of hazardous waste and penalized almost $1 million. This included$960,000forthe cleanup anda criminal'fine o1'$20,000. ------- Super Fund: Progress in Region 10 Long-Term Cleanups: NPL Sites Fifty sites listed on the NPL are in EPA Region 10 (excluding Federal facilities). Consistent with EPA'shistory ofastrong Federal-State partnership, States have assumed management of 14 of these sites, the majority in the State of Washington. The long-term cleanup of these NPL sites includes: (1) a comprehensive study of the contamination and the technologies to clean it up; (2) the .design of the chosen technology, and (3) the construction and operation ofthetreatmentsystem. Contaminated soil andgroundwater may take many years of treatment until a site meets cleanup standards. In Region 10, manysites are well onthewaytocleanup. Region 10 and responsible parties have completed or are conducting 66 site investigations and 28 separate cleanup actions at the 36 sites managed by EPA. In all, 31 of the 36 NPL sites managed by EPA are actively being worked on. Of the four sites where action is pending, three were just listed on the NPL in August, 1991. One of the 36 sites is completely clean, verified by final sampling, and the site is no longer on the NPL. Mega-Sites Region 10 has been aggressive in listing very large sites on the NPL in special circumstances. These "mega-sites" allow EPA to more effectively address a variety of public health and environmental problems not covered by other State or Federal laws. However, these sites also present management and communication challenges, since site investigationorcleanupmayoccursimultaneousryatdifferent units of the site. The Superfund program is generally designed to deal with relatively small discrete problems, such as abandoned and leaking drums of toxic waste. In Region 10, we have listed several of these "mega-sites" on the NPL: • Commencement Bay (Tacoma, Washington) • South Tacoma Channel (Tacoma, Washington) • Eagle Harbor (Bainbridge Island, Washington) • Harbor Island (Seattle, Washington) • Bunker Hill (Silver Valley, Idaho) Figure 2: Region 10 NPL Site Cleanups NPL Region 3$ sites (EPA * Shows activities underway or completed. In Region 10, several large or complex NPL sites are managed as more than one cleanup site. Significant action has taken place at 32 of 36 NPL sites under EPA jurisdiction. (including one NPL deletion) Smaller Bites for Clean Sites Region 10 is breaking mega-sites and other Superfund sites into smaller, more manageable pieces. It often makes sense to identify parts of the larger site where early cleanups can be done to greatly reduce public or environmental exposure. Contamination in these areas is easier to characterize and the cleanup remedy is easierto design and implement This means actual cleanup can start sooner and progress more efficiently. This also means that Region 10 can work on the worst sites first, consistent with the national strategy for Superfund. Anotherresultisthatthenumberof sites Region Wdeals with is significantly largerthan the 36 EPA-managed sites on the NPL For example, the Tacoma Tarpits site is an independent cleanup unit within the larger Commencement Bay site. The Tarpits is a 30 acre site containing coal gasification wasfes, lead, and PCBs. Each cleanup unit presents unique technical and legal challenges. ------- Super Fund: Progress in Region 10 \ Early Cleanups Make Sites Safe in the Interim Not all NPL cleanups need to wait for completion of the comprehensive site study. EPAtackles the worst problems at each site first, often beginning some early cleanup action while site studies are still underway. EPA Region 10 reviews NPL sites to determine whether an emergency cleanupor interim action is necessary to make the site safe until final cleanup can occur. Interim cleanup actions tend to be larger-scale activities to stabilize the site. Many times emergency or interim cleanup actions are performed by the responsible parties. To date, 23 emergency response actions havebeeninitiatedorcompletedtocontrolimmediate threats at NPL sites. In addition, of the 28 cleanup actions described above, 6 were interim cleanup actions performed by EPA Region 10 or responsible parties. These early cleanups ensure that NPL sites pose no immediatethreats to public health orthe environment, and they speed up the long term cleanup of the sites. Early Cleanup at an NPL Site The Commencement Bay South Tacoma Channel site covers 2.5 square miles in Tacoma, Washington. The site includes thteemajorcleanupareas, one of which is adrinking water wellfield. Well12Aistheprincipalwellofthe 13 wells used by Tacoma to meet peak summer and emergency water demands. Aproduction well, it can produce 5 million gallons per day. The well wasremovedfromservicein 1981 when the City of Tacoma found chlorinated solvents contaminating the well. EPA proposed the site for listing in 1981 and listed itin 1983. Studiesofthewellfield area in 1982 showed that Well 12A was contaminated by previous nearby activities, including waste oil and solvent reclamations processes. Because of Tacoma's reliance on Well 12A, the City requested that action occur as sopnasppssible. In January 1983, EPA evaluated treatment options. In March, EPA selected a large five tower air stripping unit Design and construction followed immediately. Operation began in July 1983. Well 12A, whose treated water now met drinkingwaterstandards, was returned to service. While the site itself needed further cleanup, Tacoma could once again rely onWell12A. Cleanup activities continued. Site studies of other areas demonstrated the extent of the contamination and the sources. This enabled EPA to pursue litigation against responsible parties, take action to prevent further contamination, and address cleanup of the entire site. Litigation against Burlington Northern Railroad, owner of one of the properties contaminating Well 12A, resulted in a 1985 setttementwhereby Burlington Northemagreedtoexcavate and dispose of contaminated soil at acostbetween$500,000and costs. While pursuing litigation, EPA took actions to halt the spread of contamination and undertake long-term cleanup of the site. To prevent further migration of contaminants toward Well 12A, EPA constructed a carbon adsorption groundwater treatment system near the Time Oil property. The system began operation in 1988 and its successful continuous operation has kept the plume in check. Over200 million gallons of groundwater have been treated and over 7,500 pounds of organic chemicals removed to date. ContaminantlevelsbetweenthesystemandWell12Ahavebeenreducedbytwoordersofmagnitudeand levels in Well 12A by one-fifth. EPA will install the final cleanup measure, a soil aeration system, this fall. A network of 23 vacuum extraction wells will be hooked up to blowers. Air will pass through contaminated soil, evaporatingthe solvents. The contaminated air will be captured in the vacuum wells and treated aboveground to recover the solvents. Final site cleanup is expected to be complete in 1997. ------- Super Fund: Progress in Region 10 Cleanups Involve Large Quantities of Toxic Waste Cleanups frequently entail removing hazardous materials from the site, emptying lagoons of hazardous liquids, dealing with large volumes of contaminated soil, proper disposal of these materials, building watertreatment units andtemporary storage facilities, or bring ing in mobile incineration units. Even at small sites, these activities can be major construction projects. Large quantities of contaminated material must be addressed at Super-fund sites. Once hazardous material contaminates soil, surface water, or groundwater, the soil or water frequently becomes hazardous material as well. Over time, the contamination may spread across large areas, all of which is addressed in the cleanup. One indicatorof Region 10's cleanup progess is the enormous volume of hazardous material treated or removed from Superfund sites. Figure 3: Region 10 Cleanups Address Contamination Estimated Amount of Hazardous Materials Treated or Removed from Sites (through September 1990) 3.7 Million Gallons Liquid Waste 52 Million Lbs. Contaminated Debris Groundwater 226,000 Cu. Yd. Soil 5.2 Million Gallons per Day Treated Groundwater ------- Super Fund: Progress in Region 10 Enforcement: Polluters Clean Up or Pay Up The very name "Superfund" conjures up a picture of publicly fundedcteanupsfinanced by thespecial Superfund taxes. But EPA has been remarkably effective at using enforcement to produce far more cleanup work by responsible partiesthan would be possible using just public funds. In Region 10, for every dollar that has been spent from public funds, responsible parties have spent four dollars on cleanup work under EPA enforcement orders or judicial decrees. Region 10 Superfund enforcement has resulted in $305 million of cleanup and investigation. Flgun 4: Region 10 Superfund Dollars Leverage Cleanup by Responsible Parties* - mment Cleanup Costs Estimated Value of Work Performed by Responsible Parties Through EPA Enforcement Includes removals, site studies, cleanups, and miscellaneous costs reimbursed or paid in advance to EPA Region 10 has been successful in obtaining responsible party cleanups. Region 10 uses its Superfund resources to focuson emergency cleanups, wherethe need for speed is greatest, and on site studies, often establishing the basis for later negotiations with responsible parties. Asshowninthe graph following, responsible parties have then supplied morethan90 percent ofthe resources forNPLsitecleanups, the most expensive step in the process. Flgun 5: Responsible Parties Pay for Cleanups in Region 10 200 Removals Site Studies Cleanups When EPA cannot pursuade responsible parties to perform removals or long-term cleanups, EPA uses Superfundtoensurethatprogresstowardcleanupatthesite continues. EPA closely documents its expenditures at the site, including overhead. EPA then sues responsibleparties to recoverthese costs. Region 10 has been very successful in its efforts to recover its costs. In addition to the cleanup cost shown in Rgure 5, responsible parties have also reimbursed the Federal government $20 million for emergency cleanups, site studies, cleanups, and EPA oversight to date. In addition, responsible parties have paid $12 million in advance toward EPA cleanups. ------- Super Fund: Progress in Region 10 Conclusion Superfund: Successful, Not Perfect Region 10's Superfund program has significant successes to its credit: • Preliminary investigation of 94 percent of the over 1,100 sites reported to Region 10 to date. • Responsible parties paying for 90 percent of interim and final Superfund site cleanups in Region 10. • Cleanup efforts targeted to addressing the most significant threats to people and the environment, with 29 early cleanup actions (23 emergency cleanups and 6 interim cleanup actions) u nderway or completed at the 36 NPL sites managed by EPA. Despite.this progress, Region 10 still faces a number of challenges: large and complex sites; complextechnical and legal issues; reducing contractoroverhead costs; and continuing an aggressive prog ram to address the worst site problems first and to ensure that responsible parties pay their fair share of cleanup costs. Region 10 is committed to maintain its successful efforts, and to aggressively address problems as they are identified. We will continue to work with States, affected communities, responsible parties, and others as appropriate to devefoptimely and effective Superfund cleanups. Looking ahead, Region 10willcontinueto look fornew ways to speed upthe Superfund investigation and clean up process, improve contracts management, and continue a strong enforcement program, including dealing fairly and effectively with smaller responsible parties. ------- Setting the Record Straight TheSuperfundprogram has received much scrutiny. Some concerns are validandEPA isworkingto improve the program Otr^rs may be based on incomplete inforntation or reflect a lack of understanding of iMmplex legal andtechnicalissues. ' "Super-fund Spends Lots of Money, But Nothing Ever Gets Cleaned Up" • Just counting deletions from the National Priorities List does not tell the whole story. • Thereare28cleanupscompletedorinprogressherein Region 10 alone. • AlthoughthereisonlyonedeletionfromtheNationalPrioritiesListinRegion 10 and only 36 nationally, deletions do not measureprogressinsitecleanup. Many NPL sites involve contaminated groundwater which can take yearsto correct even when au other work at the site is completed. EPA established very stringent criteria fordeletions, including careful study and public comment • EPA continues to push forward to clean up the most hazardous parts of Superfund sites first "Superfund Is Not Making the Polluter Pay for Cleanup." • In Region 10, for every dollar that has been spent from public funds, responsible parties have spent four dollars on investigation or cleanup work through EPA enforcement • Responsible parties have contributed 90 percent of the costs of NPL site cleanups in Region 10. Too Much of Superfund Goes to Pay Contractors" • Region lObpayinghigherthananticpatedcontractoroverheadcosts, duetoanenforcementprogramthathasbeen very successful, resulting in significant cleanup by responsible parties. • Several years ago, EPA signed contracts with cleanup firms for work financed by Superfund taxes. These contracts guaranteed a minimumamountofworktothecontractors, basedon EPA's experience that Superfund would have to be used to clean up most sites. • Since the contracts were signed, EPA enforcement has encouraged responsible parties to step forward at an unprecedented rate, resulting in less contractor work. • EPA must still pay contract overhead costs, because of the terms of the contracts. EPA is actively working to cut these costs • one price of enforcement success. "Can Groundwater Really Be Cleaned Up?" • The Superfund program spends a considerable amount of time and money in cleaning up and protecting groundwater sources for future generations. Thousands of pounds of contaminants have been removed from important aquifers. • Improving the effectiveness of techniques to clean up aquifers is the subject of intense EPA research. • Thestandardmethodtocleanpollutedgroundwateristoinstalla well to pump and treat the water, releasing ittp drinking water systems, rivers, or back to the aquifer. This process does effectively clean the treated water. However, it is not as effective at cleaning up the aquifer itself. Some of the contaminants tend to stick to the rock or soil of the aquifer. Cleaning theaquiferissomewhatlikecleaningsoapoutofasponge;itrequiresalotofrinsing. Rightnow,hcaneasitytake20years to "rinse'an aquifer, and some will never be totally clean. EPA will continue to search for improvements to this technology. "Superfund Is Overkill. The Time and Money Just Aren't Worth It," • Somepeoplefeelthis way, especiallythosethatareaskedtopayforcleanupsbecauseoftheirpastinvolvementatasite. • CongressplacedstringentcleanupcriteriaonSuperfundsiteswhenthelawwasreauthorizedin 1986. These cleanup standards are intended to ensure that Superfund sites are as clean as possible, and that public health is protected. EPA typically is required to clean sites to a point where the threat of disease, especially cancer, is virtually eliminated. • People who live near Superfund sites generally feel that cleanup is worth the costto protect their health. ------- |