&EPA
United States
Environmental Protection
Agency
Office of Solid Waste and
Emergency Response
Washington. DC 20460
9272.0-08
PB96-963309
EPA/540/R-96/020
August 1996
Remedy Selection and
Land Use at Federal
Facilities
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PB96-963309
EPA/540/R-96/020
August 1996
Remedy Selection and Land Use
at Federal Facilities
Federal Facilities Restoration and Reuse Office
Office of Solid Waste and Emergency Response
U.S Environmental Protection Agency
Washington, DC 20460
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The policies and procedures set forth here are intended as
information to the Agency and other government employees. They
do not constitute rulemaking by the Agency, and may not be relied
on to create a substantive or procedural right enforceable by any
other people. The Government may take action that is at variance
with policies and procedures in this manual.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY
CHAPTER 1 INTRODUCTION
I 0 INTRODUCTION AND PURPOSE ..
1 1
1 2
Data Sources
Methodology
Page
v
. I
1
1
2
CHAPTER 2 REMEDY SELECTION AND REMEDY COST AT FEDERAL FACILITIES
20 REMEDY SELECTION AND COST .
21 Overview of Remedy Selection Data from the FFSS
2 2 Remedial Cost Analysis
2 2 1 O&M Cost Analysis
222 Cost Drivers ... . .
23 Influence of DNAPLs ...
2 4 Innovative Technologies .
CHAPTER 3 IDENTIFICATION OF POTENTIAL FUTURE LAND USE AND ITS RELATIONSHIP
TO REMEDY SELECTION
30
IDENTIFICATION OF POTENTIAL FUTURE LAND USE
31 Overview of Future Land Use . . .
3 2 Understanding the Data ....
3 2 I Role of Ground-water Protection in Remedy Selection and Identification of
Potential Future Land Use
322 Restricted Use and Residential Future Land Use
3.2.3 Relationship of Human Health Risk Assessment to Residential Future Land Use
33 Factors Affecting Selection of Future Land Use . . .
3 3 I Current Land Use .
332 Minor Incremental Cost .. ...
333 Role of States ....
334 Uncertainty Regarding Future Operational Status
3 3 5 Other Factors Examined as Potential Influence on Future Land Use
3 4 Conclusions . . . ....
Appendix A Federal Facility Superfund Survey on Signed Records of Decision-Blank Survey Form
and Instructions ...
Appendix B RODs Included in the FFSS Data Base . ...
Appendix C: Federal Facilities Telephone Follow-up Survey Questionnaire and Interview Results
Appendix D FFSS Study Methodology
Appendix E Cost Effects of Land Use Assumptions
5
8
11
11
11
11
15
15
15
17
18
18
18
22
22
22
22
23
24
25
27
41
49
59
67
in
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LIST OF TABLES
Page
Results of Follow-Up Telephone Calls to Selected Residential Future Land Use Sues . 19
LIST OF FIGURES
1 Summary of Data Set . . . 3
2 Percent of Sites for Which Specific Remedies are Identified Non-Landfill Sites . . 6
3 Percent of Sites for @ch Specific Remedies are Identified1 Landfill Action Sites 6
4 Source Control Remedy Selection at Non-Landfill Sites . 7
5 Ground-water Treatment Remedy Selection at Landfill and Non-Landfill Sites Involving Ground-water
Management ..... . .7
6 Overall Remedy Cost Distribution for All Action Sues .. 9
7 Remedy Cost Distribution for All Action Sites by Land Use 9
8 Remedy Cost Distribution for All Action Sites by Ground-water Category . 10
9 Percentage of DOD and DOE Sites in Each Remedy Cost Range . 10
10 Operation & Management Cost by Site Type . . .12
11 Principal Cost Drivers . . . .12
12 Comparison of Principal Cost Drivers by Future Land Use . 14
13 Consideration of Innovative Treatment Technologies at DOD and DOE Sites 14
14 Future Land Use Selection at Federal Facilities . . 16
15 Current Land Use at Source Control Sites with a Future Land Use of Residential 23
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EXECUTIVE SUMMARY
BACKGROUND
This report presents the results of an examination of remedy selection at Federal Facility Superfund sues on
the National Priorities List (NPL) Because a great deal of debate in the Superfund reauthonzation process has
centered around the role of land use in remedy selection and assertions that future residential land use is too frequently
chosen as the basis for a protective remedy, particular emphasis was placed on the relationship between potential future
land use at the sites and the role that it plays in determining the nature of the remedy Other factors affecting remedy
selection and the types of remedies and their costs were also examined Information to support the analysis was
collected from Federal Facility Remedial Project Managers (RPMS) in all 10 U S Environmental Protection Agency
(EPA) Regions The data collection covered approximately 98 percent of the interim and final source control Records
of Decision (RODS) that had been signed at Federal Facilities on the NPL from the beginning of the Superfund
program through August 1995
The primary tool for the study was a survey questionnaire that was mailed to all EPA Regions to collect
information on the cleanup remedies selected at Federal Facilities and the factors that influenced the selection of these
remedies '
The survey was supplemented by follow-up telephone interviews at 27 percent of those sites that selected a
potential future land use of residential In all, 297 surveys were received from 85 Federal Facilities representing 245
operable units The data discussed in this report relate to the individual sites or multiple sites for which a single survey
provided information For convenience sake, however, the term site is used to refer to the number of surveys
Of 297 surveys for which a response was received, 6 referred to petroleum sites, 65 involved only no action
sites, and 226 selected remedial action Of the 226 sites which involved some sort of remedial action, 61 involved only
ground-water cleanup (e g, ground-water 'pump and treat1 with no source control), 3 did not provide enough data, 120
had an action that included ground-water remediation and source control, while 45 had an action that only involved
source control, with no ground-water remedy
FINDINGS
Remedy Selection and Cost:
The results of the analysis of cleanup remedies at Federal Facilities revealed that
D Twenty-nine percent of the remedies and over half (57 percent) of the remedies that do not involve ground-
water treatment involve on-site management (i e , treatment, disposal, or containment)
0 Thirty-three percent of the sites show a ground-water remedy Of these, almost two-thirds employ an active
'Many RODs contain multiple, discrete areas of concerns (sites) in one operable unit (OU) Respondents
to the Federal Facility Superfund Survey (FFSS) were instructed to complete a separate survey for all sites within an
OU that were "geographically distinct areas and with different land uses and remedies " Therefore, each individual
survey may refer to an individual site or multiple sites with the same remedy selection and related factors For
convenience sake, the work "site" in this report is used to refer to an individual completed survey and may encompass
more than one site
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ground-water treatment remedy
D Over two-thirds or the sites selected remedies costing less than S3 million, with 24 percent costing less than
$500,000 Twenty-two percent were over $10 million 2
D The results suggest that remedies involving active ground-water treatment are typically more expensive than
remedies involving passive ground-water management or nonground-water remedies No conclusions can
be drawn that this is due to the costs of the ground-water remedy In Tact, for the most costly remedies (i e ,
more than $50 million), the cost of ground-water remediation is minimal when compared to other cost drivers
such as volume of waste material The need for a ground-water remedy may be reflective of the complexity
of the site, which may also drive the cost
D Examination of residential land use shows no discernible pattern of relationships to the overall cost of the
remedy for the universe as a whole Residential land use is likely to have an impact at individual sites
However, because no unit cost data or data comparing costs for a residential versus nonresidential scenario
at the same site are available, that impact is not documented in this study
Future Land Use
The results of this study show that a variety of future land use designations are operative at Federal Facilities
The following results are for surface/source control remedies that are not ground-water only remedies A total of 165
sites fell into this category The most frequently chosen future land uses are residential (45 percent (i e., 75 sites)),
landfills (15 percent (i e , 25 sites)), and industrial/military (about 20 percent (i e., 34 sites)) However, a telephone
survey provided a closer examination of the sites that chose a residential future land use and revealed that a significant
percentage (15 percent of the total (about 26 sites)) are considered suitable for a future land use of residential, but the
remedial action (and cleanup to levels suitable for residential use) was chosen to be protective of ground water In
other words, addressing the source of ground-water contamination was the driver of the remedy, not future land use
The residential future land use designation was a result of the cleanup, not a cause In addition, 7 percent (i e , 11 sites)
are landfills which had a future land use designated as residential Presumably, however, these landfill sites will not
be cleaned to unrestricted use Consequently, an extrapolation based on the telephone survey suggest that the
percentage of sites for which the remedy is based on a truly residential future use scenario is only about 24 percent
(about 40 sites)
Examination of FFSS statistics and follow-up telephone interviews suggest that there is a great deal of
confusion about what is being asked when the question is posed~"What is the future land use of the site on which the
remedy is based7' This confusion appears to have a number of sources, one of which is the apparent lack of a clear,
written definition of residential land use Therefore, study results described above are based on an integration of survey
and telephone interview data, particularly with regard to the designation of residential future land use For the purposes
of this study, the authors used a definition that reflects the national policy debate on this issue, and that is commonly
accepted Namely, that protectiveness to residential land use is defined as protection to human health levels that allow
unrestricted use of the sue. This definition is consistent with residential exposure assumptions, and with requirements
to review sites every 5 years if waste above unrestncted use levels has been left onsite In addition, the survey clearly
asked that the future land use that is identified be the one on which the remedy selected is based Yet, regional responses
to the survey showed substantial inconsistency over the definition of residential land use and interpretation of what it
*The survey asked respondents to identify the "estimated cost of the selected remedy " As a result, depending
on the interpretation of the responder, the cost data may only include capital cost, it may or may not be present value
costs, it may or may not include operation and maintenance (O&M) cost, etc Cost data presented in this report,
therefore, should be evaluated somewhat cautiously.
VI
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means to base the protectiveness of the remedy on a particular land use This confusion was reflected in the survey
results with identification of future land use as residential at sites where the basis of the remedy was cleanup of the site
to be protective of ground water, where landfill surfaces were made safe for nearby residents to walk upon or otherwise
recreate, and, in some cases, where the ground-water remedy was designed to clean up the ground water to d@g water
levels (and the remedy had nothing do so with the surface use of the land) This confusion regarding the definition of
residential land use does not mean that poor decisions are being made In fact, the evidence suggests that the assertion
that Federal Facilities are too frequently asked 10 clean up to residential land use is based partly on this confusion rather
than fact
Raw data responses indicate that 45 percent of the remedies selected were based on a residential future use
scenario Most of these remedies were at Department of Defense (DOD) installations Further analysis suggests that
this percentage is overstated (perhaps by as much as SO percent) for several reasons, including
D Surface cleanup to protect ground water resulting in residential land use designations.
D Designation of large landfills as residential land use.
Reasons why cleanup is based on residential future land use at Federal Facilities include
D Uncertainty over the future use of military bases in the face of the Base Realignment and Closure
(BRAC) process over the past several years This uncertainty may have a substantial influence on the two
other factors listed below, as well
D Proximity of military Base personnel or off-site residences to the site (i e , residential use nearby) may have
led to a 'residential' cleanup designation although the remedial site is currently intended for recreational or other
use
D Site-specific decisions that the cost of cleanup to residential levels may have a low incremental cost over
a cleanup to industrial or commercial levels and should, therefore, proceed. Cleanup to reduce future
liabilities (e.g., operation and maintenance costs) and 5-year reviews, and to ensure the property could be
transferred in the face of a future property transfer also plays a role Federal Facilities may contain a number
of smaller, less complex sites that lend themselves to a simple remedial action which are, in turn, designated
as residential
D Anticipation by the Federal Facility of a residential cleanup scenario such that other options may not
have been fully explored.
D State preferences for residential land use in selected States. There is evidence from EPA Regional RPM
interviews that State regulators play a significant role in determining cleanup levels at NPL sues Survey data
supports this anecdotal data
ORGANIZATION OF THE REPORT
The report that follows is organized into three chapters and a series of appendices Chapter I presents an
introduction to the report, and summarizes the data sources and analytical methodology Chapter 2 discusses remedy
selection and remedy cost at Federal Facilities Chapter 3 presents the results of the study regarding land use selection
at Federal Facilities The document also contains the following appendices
D Appendix A - Contains a blank copy of the survey form and instructions,
0 Appendix B - Lists the RODs for surveys that were received,
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D Appendix C - Presents the Follow-up telephone survey questionnaire as well as the detailed results of the
interviews,
D Appendix D - Outlines the FFSS analytical methodology, and
D Appendix E-Presents an analysis of the effects of land use assumptions on remedy cost [Note This analysis
was previously prepared under EPA Contract No 68-D3-0013, Work Assignment 10 ]
VIII
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CHAPTER 1. INTRODUCTION
1.0 INTRODUCTION AND PURPOSE
Ms report presents the results of an analysis of the National Priorities List (NPL) Federal Facility Superfund
Survey (FFSS) questionnaire data on remedy selection. The purpose of the survey was to develop a broad understanding
of the kinds of remedies selected as cleanup options at Federal Facilities on the NPL, and the factors that influenced the
selection of these remedies including future land use A great deal of debate in the Superfund reauihonzauon process
has focused on the role of land use in remedy selection and assertions that residential land use is extensively chosen,
resulting in expensive cleanups Therefore, particular emphasis was placed on gathering data on the role that land use
plays in determining the nature of the remedy Other factors affecting remedy selection and the types of remedies and
their costs were also examined Information to support the analysis was collected from Federal Facility Remedial Project
Managers (RPMS) in all 10 U S Environmental Protection Agency (EPA) Regions The data collected covered
approximately 98 percent of the interim and final source control Records of Decision (RODS) that had been signed at
Federal Facilities on the NPL from the beginning of the Superfund program through August 1995 In all, 297 surveys
were received representing 85 Federal Facilities.1
1.1 Data Sources
Two mam sources of data were used to prepare this report The first is a data base created from the results of
the FFSS The second is a series of follow-up telephone interviews directed at over 25 percent of the sites where
residential future land use was identified The survey was modeled, in part, on the RPM Site Evaluation Survey
conducted of all Superfund sites in August 1993, which was used in a similar study of land use at private party sites"
To create the FFSS, however, additional questions were added to the RPM survey regarding issues that appeared to
require further clarification The FFSS was distributed by EPA Headquarters to Federal Facility managers in each EPA
Region The manager then provided the questionnaires to the EPA site managers Appendix A contains a copy of the
FFSS form and the instructions for completing the survey form
RPMs were requested to complete a survey for all operable units (OUs) for which an interim or final ROD had
been signed Using EPA's Comprehensive Environmental Response, Compensation, and Liability Information System
(CERCLIS) data base, a preliminary listing of RODs was developed and sent to each Region Information was requested
on 251 RODS RPMs were asked to complete a separate survey whenever the information in the survey was different
for different sites within the OU Survey forms were returned for 98 percent of the RODS Two-hundred ninety-seven
responses were received for 245 OUs on 85 Federal Facilities Approximately 70 percent of these surveys were from
Department of Defense (DOD) facilities, 23 percent were Department of Energy (DOE) facilities, and 7 percent were
"other" Federal agency facilities. Six responses could not be used because they were incomplete or petroleum only sites
Appendix B contains a listing of the RODs for which information was requested, and indicates those for which a
completed survey was received
3Many RODs contain multiple, discrete areas of concerns (sites) in one operable unit (OU) The 297 surveys
represent many more sites than the number of surveys received However, for convenience sake, the term "site" is used
in this report to refer to the number of completed surveys
'Land Use Decisions in the Remedial Process, U S Environmental Protection Agency, Office of Solid Waste
and Emergency Response OSWER 9355 0-55 EPA/540/R-95/037 PB95-963230 March 1995
1
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The term site in this report is used to refer to the number of surveys, not the actual number of sites. Some
of the surveys represent more than one site; therefore, the results based on the actual number of sites may be
different than those presented in this report. However, a limited analysis of future land use selection based on the
number of sites at source control surveys was very similar to the same analysis based on number of surveys.
In addition, a telephone follow-up survey of 20 sites (each reflecting one or more sites) with a future land
use of residential was conducted. The 20 sites were selected from those source control sites identified in the FFSS
with a future land use of residential. They were selected randomly, but roughly proportionate to two factors that
appeared to have a strong influence on the selection of projected future land use — involvement of ground-water
protection in cleanup and regional location. (Regional location was used as a surrogate for State location because
a focus on States in the selection of sites for follow-up would have had too small a number of sites in most States.)
Information collected during the telephone interviews was not entered into the data base, but was used to enlighten
and clarify the findings and conclusions contained in this report. In addition, telephone interview data were
extrapolated to all sites for which potential future residential land use was identified. Appendix C contains a copy
of the telephone interview questionnaire and the detailed results of the telephone interviews, including the type of
questions asked of respondents. (The follow-up interviews were interactive, and as a result, the exact questions
vaned from interview to interview.)
1.2 Methodology
This section presents a brief description of the key elements of the study methodology. A detailed
description of the study methodology is contained in Appendix D.
Of 297 sites, 6 sites were removed from the data base. These six sites dealt strictly with petroleum sites,
which are not managed under the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), or did not have a signed ROD. Of the remaining 291 sites, 65 were "no action" RODs; these were
removed from the study universe, resulting in a total of 226 sites.
Remedy Selection and Cost Analyses. For the remedy selection and remedy cost analyses, data from
all OUs/sites covered by an action ROD were included (i.e., 226 sites).
Land Use Analyses. This analysis assumed that the surface land use will generally have no bearing on the
remedy selection process at a site that only involves ground water (i.e., no surface source control), 61 such
"ground-water only" sites were removed from most of the analyses involving land use (e.g., current land use,
surrounding land use, future land use). The remaining 165 sites are referred to as "source control" sites. Only sites
that involved source control were included in the land use analyses.
Highlight 1 provides key definitions of the various site types. Figure 1 summarizes the data sets used for
the various analyses.
Highlight 1: Key Definitions to Remember
• Source control sites - Sites where some surface remediation is involved; may or may not also involve
ground-water treatment.
• Ground-water only sites - Sites that involve ground-water treatment only (i.e., no surface remediation).
• All sites or all "action" sites - All sites received, except for sites with all no action sites (i.e., all source
control and ground-water only sites).
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245
RODs/OUs,
Represented
297
Sites1
165
Source Control
Sites?
61
Ground-Water
Only Sites
Used for Land
Use
Analyses
226
Sites
Used for Remedy
Selection
and Cost
Analyses
65 No Action
Sites
6 Not CERCLA
Eligible Sites
1The term site is used 1o refer to a completed survey and may represent more than one site
2Source control only or ground-water remediation and source control.
Figure 1. Summary of Data Set
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Hierarchy Of Identified Land Uses. Because respondents to the FFSS were given the opportunity to
identify all applicable land uses, most responses to the land use questions contain multiple identified land uses (e g , sites
with identified future land uses of residential, recreational, and commercial) Because of the endless possible
combinations of land uses, analysis of land use, and its impact, using multiple responses would be difficult, if not
impossible In order to alleviate this problem, a two-step process was employed First, all landfills were placed into a
separate grouping Landfills were considered unique because they are typically 'managed1 differently than non-landfill
sites in that, at virtually all landfills waste is contained (e g , covered with a protective cap to reduce infiltration to ground
water) and left in place For non-landfill sites, a hierarchical scheme was created to place sites with multiple identified
land uses into a single category Basically, the hierarchical scheme, detailed in Appendix D, evaluates all the identified
land uses and assigns the site to the land use category that would typically result in the most restrictive exposure
assumptions Based on this, the hierarchy assumed the following order from most conservative to least conservative
residential, industrial/commercial,5 military, recreational, agricultural, and other For example, if the future land uses
were identified as residential, industrial, and recreational, the site would be assigned a future land use of residential for
the purpose of analysis because residential exposure scenarios are typically more restrictive (i e , result in a higher
calculated risk) than either industrial or recreational scenarios
'For the purpose of this study, industrial and commercial land uses were assumed to lead to the same or very
similar exposure assumptions and, therefore, were combined into a single "industrial" group
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CHAPTER 2. REMEDY SELECTION AND REMEDY COST
AT FEDERAL FACILITIES
2.0 REMEDY SELECTION AND COST
This chapter presents the detailed results of the analysis of remedy selection at Federal Facility sites in the
survey The relationship between remedy and cost will also be discussed in the following sections
2.1 Overview of Remedy Selection Data from the FFSS
An overview analysis of remedy selection reveals that landfills are more likely to chose on-site management
with institutional controls Landfill sites are less likely to select ofT-site management than non-landfills Specifically,
Figure 2 presents the FFSS results on remedy selection at all non-landfill "action1 sites (i e , excluding landfills and no
action sites) based on the percentage of sites that chose each remedy type, and Figure 3 shows the remedies selected at
landfills in the FFSS survey based on the percentage of landfill sites that chose each remedy type
A closer look at remedy selection at source control sites shows that Tor landfills the remedy is significantly more
likely to be on-site management as compared to non-landfill sites For example, Figure 4 shows that at 45 percent or
the non-landfill source control remedies (i e, do not include ground-water pump and treat only sites)6 wastes are
managed onsite, and thai wastes are managed either offsile only or both onsite and ofTsite at 32 percent ofthe sites. On
the other hand, Figure 4 suggests that none ofthe landfill source control remedies involve off-site waste management
exclusively, and only 3 percent involve any off-site management
It is important to remember that trie FFSS remedy selection question allowed respondents to check all
applicable answers, therefore, specific sites are often represented in more than one category For example, if an RPM
checked ground-water pump and treat and on-site treatment, the site would be represented in both categories
Figure 5 presents the results of the analysis of ground-water treatment remedy selection at non-landfill and
landfill sites Figure 5 shows that when a ground-water remedy is selected at non-landfills, the remedy is an active
ground-water remedy' 56 percent of the time, a passive remedy 23 percent ofthe lime, and a combination of an active
and passive remedy 21 percent ofthe lime At landfills, however, the numbers are substantially different (Figure S)
Ground-water remedies al landfills are passive 47 percent of ihe time and active only 29 percent ofthe lime There are
several potential explanations for this One possibility is that because the source at landfills is capped rather than
removed, active pump and treat to cleanup ground water is often not practical, whereas containment of the ground water
or natural attenuation may be
The percents shown on these figures only include nonground-waier remedies, however, due to the struclure
of Ihe remedy selection questions in the FFSS, if respondents indicated a ground-water remedy and also indicated a
source remedy (e g, on-site treatment) for the ground-water portion of the remedy, these have been inadvertently
included
'The designation of "active" and "passive" ground-water treatment/management was based on FFSS
responses Active treatment included' ground-water pump and treat, ground-water pump and discharge; ground-water
biological treatment, and ground-water chemical/physical treatment Passive management included ground-water
natural attenuation, ground-water containment, and ground-water engineering controls
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50%
40%
43%
Active
Ground-walsr
Treatment
Passive
Ground-water
Treatment
Management
Off-lite
Management
Institutional
Controls
Other2
Remedy Type
Management includes treatment, disposal, and untatnmeiii
^Other includes: recover and reuse, resident lelocation, and other spccifv
Percentages do not add up 10 100% because each site rim have multiple remedy components
fe g.. active grotmdwater treatment and on •Ale management.)
Number of
185
Figure 2. Percent of Sites for Which Specific Remedies are Identified:
Non-Landfill Sites3
10%
o%
Active Passive On-sile Oft-lite
Ground-waler Ground-water Management Management
Treatment Treatment
Institutional
Controls
Other2
Remedy Type
Management includes treatment, disposal, and containment.
Other includes' recover and reuse, resident relocation, and other specify
I'ereentayes do not add up to I DO*'* because each sue may have multiple remedy components (e.g.. active jjroundwater treatment and
oil-site management.)
Number of Sites = 41
Figure 3. Percent of Sites for Which Specific Remedies are Identified:
Landfill Action Sites3
6
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100%
80%
o
"C
00%
«*
d
a:
Man-Landfills (1?3 Si tM)
0»s
Maria jjft
Only
institutional
Mnnfi c m er» t On-S Ha and Controls On ly
Only
Duly
tr cadi catenary f «te c^epiy oel the p«i««a J«f
iJ«»l Retccsion, andOiteSpxify
Figure 4, Swurcc Control Remedy Selection il Landfills and Nan-Landfill Sites
3
V9
G0%
50%
40%
30%
«ffi
20%
10%
56%
Key
Lsndlills
Ken-Landfills (123 Si Its)
Active £ Passive
Wansigeinsr.1
2AabilTtCM«iC
nj
nip
rai
awdl C
skal *j*K%
Number of '§ises«-»
Figure 5, €roiitici-wat«r Treatment Remedy Selection at Landfill and
ites Invalvlng Oroend-water Managcitioit
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2.2 Remedial Cost Analysis
As shown in Figure 6, 69 percent of the remedies are estimated to cost less than SS million, and less than
7 percent of die remedies are estimated to cost more than $50 million During the follow-up telephone survey, more than
half of the RPMs contacted indicated (hat cost, whether remedial cost or operation and maintenance (O&M) costs, played
a role in remedy selection Presented below are the results of some detailed analyses of remedy cost
Based on Survey Results, There Is No Major Difference in Remedy Cost Between
Sites with a Designated Future Land Use of Residential vs. Nonresidential. One
might expect that future land use would have a major impact on the cost ofihe remedy for a site As shown in Figure
7, however, the FFSS results indicate that there is no identifiable difference in the cost of the remedies at future land use
residential and nonresidential sites At any individual site, the choice of future land use may play a role in the cost of a
remedy, but there was no nationally discernible pattern in this regard In addition, many other site-specific factors affect
the cost of the remedy (e g., volume of waste, actual cleanup levels, need lo protect ground water, specific type of remedy
chosen), and in some cases, the residual nsk level on which the cleanup level is based may play a larger role in the final
remedy cost than the future land use For example, the cleanup levels from an industrial IO"6 risk scenario may, in fact,
be lower (i e , more stringent), and therefore, result in a higher cost than the cleanup levels from a residential J 0J risk
scenarios8 (See Appendix E )
Selection of an Active Ground-water Treatment May Play a Role in Overall
Remedy Cost. As shown in Figure 8, analysis of the impact of ground-water treatment with respect to remedy
cost suggests that remedies involving active ground-water treatment typically cost more compared to remedies involving
either passive ground-water treatment only or remedies not involving any ground-water treatment For example,
although 52 percent of the sites representing active ground-water remedies had remedial costs of less than $5 million,
fully 94 percent of the sites with passive ground-water remedies and 76 percent of the sites with nonground-water
remedies had remedial costs of less than $5 million. In addition, 56 percent of the passive ground-water sites and 48
percent of the nonground-water sites cost less than $ 1 million, but only 14 percent of the active ground-water sues cost
less than $1 million
It is difficult lo draw clear conclusions from the survey on the impact of ground water on the cost of remedies
Total remedy costs are summarized on each site and may reflect the combined costs of several types of remedies The
higher cost of remedies from sites with active ground-water remediation may, in pan, reflect the complexity of a sue
cleanup that has affected ground water It may also reflect the costs associated with long-term operation and maintenance
ofgrouixl-water pump and treat systems At the highest end of the cost range, ground water is often not involved, and
costs probably reflect high volumes of waste material or soil.
DOE Has More "High End" Remedies Than DOD. Additional cost analysis was conducted
comparing DOD to DOE As shown in Figure 9, DOE had a much higher percentage of higher cost remedies In fact,
45 percent of DOE responses had remedial costs exceeding S10 million, compared to only 16 percent of DOD responses
Because DOD sites are more likely to involve a residential future land use, this disparity further amplifies the lack of a
pattern regarding costs associated with residential land use It should be emphasized that the ratio of
*Terms such as 10* and 10J are common terms used to express the results of a human health risk assessment
A I O"6 scenario represents a 1 in I million excess cancer nsk, and a 10J scenario represents a 1 in 10,000 excess
cancer nsk. The range from lO^to IOJ is typically considered to be the "acceptable" nsk range.
8
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v>
o>
No Cost $1,000
$10 $50 $100 $500 $1,000
Remedy Cost Range (i $1,000,000)
'Percentages do not add to 100 because of rounding.
Number of Sites = 226
Figure 6. Overall Remedy Cost Distribution for All Action Sites1
No Cost <$0.6 $0.5- $1- $6- $10- $50- $100- $500- > $1,000
Data
$5
$10
$59 $100 $500 $1,000
Remedy Cost Range (x $1.000,000)
Percentages do not add to 100 because of rounding.
Number of Sites-226
Figure 7. Remedy Cost Distribution for All Action Sites by Landuse1
9
-------
No Cost <$0.5 $0.5-
Data $1
$1-
$5
$5- $10-
$11 $50
Remedy Cost Range (x $1,000,000)
'Percentages do not add to 100 because of rounding.
$50- $1M- $500- >$1,000
$100 $500 $1,000
Number of Sites = 226
Figure 8. Remedy Cost Distribution for All Action Sites by Ground-water Category!
40%
35%
30%
M
.2
«5 25%
"S
S>20%
^m
"H
15%
10%
5%
0%
Number of DOD Sites- 150
Number of DOE Sites - 45
£
36%
>$100
Remedy Cost Range (x $1,000,000)
'Percentages do not add to 100 because of rounding.
Number of Sites =195
Figure 9. Percentage of DOD and DOE Sites in Each Remedy Cost Range
10
-------
DOD lo DOE sites is over 2 5 to 1, as a result, DOE results are much more sensitive to the mfluence of outliers' High
cleanup cosls at DOE sites might be attributable to relatively more complex (e g , radioactive or mixed) wastes that are
not as frequently found on DOD sites as well as to high volumes of waste material to be managed
2.2.1 O&M COSt Analysis. Part of the FFSS asked respondents about operation and maintenance cost for
remedies Of the 226 action sites, 46 percent had O&M costs greater than $60,000 per year Figure 10 shows the
breakdown of the O&M costs by "type" (i e, source control for soils, source control for ground water, source control
for soils and ground water, and ground-water pump and treat sites) The figure suggests that ground-water treatment
plays a significant role in O&M cost In fact, of the I03 sites that have O&M costs greater than $60,000 per year, 88
percent involve ground water
2.2.2 Cost Drivers. Another FFSS question asked respondents to identify the 'principal cost driver of the
cleanup' The breakdown of the principal cost drivers for all action sites is depicted in Figure II It is important to note
that because the RPMs were allowed to select multiple responses for this question, the percentages reflect the number
of responses, not sites The cost to treat large volumes of waste was selected the most frequently (40 percent of the
responses), unique waste/complex site characteristics were selected 28 percent of the time, and treatment/disposal cost
and other at 19 percent and 13 percent, respectively
As shown in Figure 12, the cost dn vers for all residential future land use sites and nonresidenlial future land
use sites are quite similar However, residential future land use sites are slightly more likely than nonresidential uses
(that are not landfills) to identify large waste volumes as a cost driver, and nonresidential future land use sites are slightly
more likely to identify treatment/disposal costs as a cost driver On the other hand, large waste volumes and
treatment/disposal costs (presumably of large waste volumes) are the major cost drivers at landfills
2.3 Influence of DNAPLs
Dense Nonaqueous Phase Liquids (DNAPL) issues did not appear to play a signi (leant role in remedy selection
at the sites in this survey. Of the 108 sites that involved a ground-water remedy, only 17 indicated that DNAPLs were
involved at the site None of these 17 DNAPL sites signed a contingent ROD or implemented a technical impractibility
(Tl) applicable or relevant and appropriate requirements (ARARS) waiver In addition, 12 of these RODs involved
active ground-water remedies, and S (29 percent) involved only passive ground-water remedies
2.4 Innovative Technologies
Data from the FFSS indicate that 114 (50 percent) of the 226 action sites considered innovative alternative
technologies in the development of alternatives However, only 87 (38 percent) of the 226 action sites formally
considered innovative alternative technologies in the detailed analysis of alternatives The FFSS does not contain data
on the number of times an innovative technology was chosen
Consideration of Innovative Technologies at DOD Versus DOE Sites. The innovative
alternative treatment technologies analysis was broken down one step further, comparing the DOD sites to DOE
'Of the 226 action sites, 159 (70 percent) are at DOD facilities, 51 (23 percent) are at DOE facilities, and
16 (7 percent) are at other Federal agency facilities The analysis discussed in this subsection and presented in Figure
9 does not include the 16 other agency sites In addition, the analysis only includes sites for which cost data were
available As a result, 150 DOD sues and 45 DOE sites were evaluated in this portion of the study
II
-------
Do
Not
Know
$0
$0.50-
Sl
S1-
S10
510-
820
$20- $40-
$40 $60
0 & M Cost Ranges (x $1 .Ofia-Year/
-22i'
1 Thrnrf :ii: .-> d .I ZM04 |tfOVtds c.v:• ii' i«l.ii.:
Figure 10. Operation & Management Cost by site Type
Otheri
13%
Unique
Waste/Complex
Site
Characteristics
28%
Large Waste
Volume tost
40%
Treatment/Disposal
Cost
19%
Xttpccae*.'- i5M>
t'igure II. Prini;i|jal<:«st Drivers
12
-------
sites As shown in Figure 13, both DOD and DOE sites considered innovative alternative technologies roughly SO
percent of the time in the development of treatment alternatives, however, there is a much larger disparity between the
two agencies in the formal consideration of innovative alternative technologies in the detailed analysis of alternatives (42
percent for DOD versus 27 percent for DOE)
13
-------
50%
40e/<
Large Waste Treatment/Disposal Unique Waste/Complex
Volume Cost Cost Site Characteristics
Other
'Percentages do not add up to 100% because each survey may have
identified multiple cost drivers (e.g., large waste volumes and treatment costs.)
Figure 12. Comparison of Principal Cost Drivers by Future Land Use1
60%
50%
H
.-= 40%
CO
30%
o>
5 20%
£
10%
0%
51%
Development of Alternatives
Number of DOD Sites = 150
Number of DOE Sites = 45
Detailed Analysis of Alternatives
Number of Sites = 195
Figure 13. Consideration of Innovative Treatment Technologies at DOD and DOE Sites
14
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CHAPTER 3. IDENTIFICATION OF POTENTIAL FUTURE LAND USE AND ITS
RELATIONSHIP TO REMEDY SELECTION
3.0 IDENTIFICATION OF POTENTIAL FUTURE LAND USE
The identification of a projected Future land use at a Superfund site plays a potentially imponant role at two
key points of the process First, current and future land uses are evaluated to determine the need for cleanup action The
National Contingency Plan (NCP) asks that assessment of the current and future risks associated with a site be based
upon current and potential exposures under "reasonable maximum exposure scenarios " This baseline risk assessment
is used to determine if action is necessary to protect current and future users against exposure to site contaminants
Second, risk management decisions made in the remedy selection process are designed to protect current and future users
from exposure Identification of future land use is used to determine the exposure calculations to set cleanup levels
Residential land use is considered the most restrictive land use Exposure assumptions that go into calculation of cleanup
levels to support residential land use generally assume unrestricted access to surface and near surface waste Therefore,
residential cleanup levels assume that no waste is left on the site that could result in exposure during intrusive activities
such as housing construction or to children who may play in exposed areas
For the purposes of this report, Residential Future Land Use is defined as a surface use of the land that supports
unrestricted use of the land such that a residence can be safely built on the land with no institutional controls (e g , deed
restrictions) and no waste left onsite to be managed above levels that are protective of human health and the environment.
In this definition, Residential Land Use has nothing to do with the use of ground water beneath the site. What
became clear in the course of the investigation into the role of future land use on remedy selection is that there is no
single accepted definition of residential land use, and that regional responses to questions concerning "what is the
potential future land use of the site" may have different interpretations than the definition given above
The sections that follow present the detailed results of the analysis of potential future land uses selected
at Federal Facility sites as of August 199S.
3.1 Overview of Future Land Use
As shown in Figure 14, a residential future land use was chosen 45 percent of the time, 16 percent selected
other (e g, recreational or open space), 15 percent were nonresidential landfills (i e , landfills with a future land use other
than residential), industrial was chosen 13 percent of the time, and military use 7 percent of the time However, as also
shown in Figure 14, the telephone survey analyzing the nature of future land use choices at Federal Facilities suggests
that IS percent of the sites indicated that the site may be suitable for future residential land use, but the cleanup levels
selected were not a result of a projected future residential land use In these cases, removal of sources of contamination
to levels required to protect and/or remediate ground water to achieve drinking water standards (i e, maximum
contaminant levels (MCLs)) is typically below levels required to be protective for residential land use on the surface of
the land In these instances, RPMs filling out the survey questionnaire identified the potential future land use as
residential Interviews with RPMs and a closer understanding of the role of groundwater in driving remedy selections
lead to a conclusion that, in these cases, the identification of residential
15
-------
future Iliad use is a result of the level of cleanup achieved, not a cause.5* "These siscs arc shown oil Figure 14
its "GfouiKi-watco'Sourcti Cfialrol (Residotlial)* site*, la addition. 7 pcrcc.it of the site* aie huulfl Us with a future
land use of rtsiJential, which, in most cases, one would aa*um& would not be ckaaed up in unrestricted u. net a&J fci 109 Istfcsujw o f mufisi in;",
nciiuif*' Oih«f Snacily. Rcn SpttcoT^atitK' Pic.»crve.
KS cf Srtw •
Figure 14. Future Land Use Selection at Federal Facilities1
•'"The data in this section arc based «jxsa the je-vult^ of ih« FFSS «s niodificd by she results of :he telephone
data described in Stctinn 3.2. The iXKxfifiaitioo was completed with t simple cxtrapohtion of the
-------
3.2 Understanding the Data
For the purposes of this report, cleanups that are protective of a residential future land use are assumed
to clean up the site to an unrestricted use This means that the surface media (i e , soil) on the site will remain protective
no matter what the future use of the sue is, and will not require institutional controls to maintain this protectiveness This
definition is consistent with the national level policy debate on the role of land use in remedy selection It also mirrors
the circumstances for sites to be identified as requiring a 5-year review
A particularly sinking outcome of this analysis is the apparent lack of national consensus on the definition of
residential land use. This does not mean that poor decisions are being made In fact, the evidence suggests that the
assertion that Federal Facilities are too frequently asked to clean up to residential land use is based, partly on confusion
rather than fact
Residential land use is clearly identified in the NCP as the most conservative reasonable maximum exposure
scenario Conservative residential exposure assumptions for contaminated soil found in risk assessment guidance are
based on the ingestion of soil by children for a duration that generally reflects the assumption that children are living
onsite This duration assumption may be varied according to the climate (e g , the amount of expected time over the
course of a year that children will be expected to be exposed to soil — due to snow cover or other climatological
conditions) Anecdotally, it appears that regional risk assessors differ in the depth of contaminated soil to which they
apply these assumptions These differences may depend upon the nature of the housing stock, existence of basements,
etc
From a national policy perspective, the term residential land use usually refers to a use of the land that is
unrestricted in nature (i e , no waste is left onsite to be managed into the future) However, this definition doe-, not
appear to be written anywhere - or at least it is not wntten in a widely accessible location
The lack of common understanding as to the nature of the debate on land use becomes evident when the EPA
regional RPMs' responses to the question concerning the future land use on which the protectiveness of the remedy is
based are analyzed in detail Regional responses included
D Assignment of residential land use status to municipal landfill sites In most cases, it appeared as though this
assignment had nothing to do with the remedy, or with the actual potential use of the land Residences were
nearby, and residential users may recreate or trespass on the land
D Assignment of residential land use status when ground water is cleaned up to drinking water levels (i e ,
MCLS) In some cases, this cleanup involves source removal that may result in land being considered
protective for residential use In these cases, cleanup to be protective for residential use is a result, not a cause,
of the remedy In other cases, the assignment of the residential land use category refers to the residential use
of ground water (i.e, as drinking water).
In the survey, regional RPMs were asked to identify the "future land use decision on which the protectiveness
of the remedy is based." Residential land use was identified at 45 percent of the action sites for which data were received
A follow-up telephone survey was conducted of 27 percent (20 sites) of the sites-selected at randoml2~that fell into the
category of residential future land use Of these 20 sites, 2 were landfills The first survey consists of two landfills that
have been remediated so that nearby residences can use the site for recreational use and, therefore, should have been
coded as recreational. At the other landfill site, a residential land use was chosen because of fears that the site would
be used residentially by the Native Americans to whom it was being turned over The surface of the land was safe for
12 For a further discussion of the methodology for selection of the sites for the telephone interviews, see
Appendix D
17
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residences for which there was no intrusive activity Of the 18 non-landfills contacted, 39 percent (7 sites) stated that
the source control actions were designed to achieve MCLs in ground water. One site was miscoded by the RPM It was
a ground-water cleanup site involving no source control At another site, the cleanup was driven by the need to meet
surface water National Pollutant Discharge Elimination System (NPDES) discharge levels Therefore, at 55 percent of
the sites in the telephone follow-up survey, the selection of residential land use was either a result of the cleanup
determination needed to protect water or a mistake
Table I summarizes the interview results, and Appendix C contains a detailed summary of each interview
3.2.1 Role of Ground-water Protection in Remedy Selection and Identification of
Potential Future Land Use. At 39 percent of the non-landfill sites contacted during the telephone interviews,
ground-water protection and the need to meet MCLs were the major factors in remedy selection and formed the bases
of cleanup Tins is supported by a closer look at the survey data, which show that, when source control involves ground-
water protection, residential land use is more likely to be identified as the potential future land use
During the telephone interviews, some RPMs stated that in order to achieve MCLs in the ground water, the
surface soils must be cleaned beyond residential protection levels In other words, protection or cleanup of ground water
drives the selection of residential cleanup levels, not the actual or projected surface use of the site (i e, the residential
cleanup levels are the result - not the cause) Others said that MCLs are based on being able to drink the water, and that
drinking water equates to a residential land use In those cases, the categorization of a site as a residential land use site
refers to the use of water beneath the ground, not unrestricted use of land above the ground "
In addition, the FFSS results show that 33 percent of the future land use residential source control sites
identified MCLs as a basis for cleanup, but only 21 percent of the nonresidcntial future land use source control sites
identified MCLs as a basis for cleanup.
3.2.2 Restricted Use and Residential Future Land Use. AS discussed above, residential land
use is considered to be a designation that supports unrestricted use of the land surface Exposure assumptions that
establish cleanup levels are designed to ensure that if housing is built, children and adults living on the property will not
be exposed to contaminated soil Yet, in the FFSS, 31 percent of the landfill source control sites (7 percent of the total
number of source control sites), for which the remedy is containment of waste onsite, identified a future land use of
residential These clearly are not being remediated to unrestricted residential use
3.2.3 Relationship of Human Health Risk Assessment to Residential Future Land Use. One
question in the survey asked respondents to identify the basis of the cleanup decision Specifically, the instructions told
respondents to identify the factors on which a decision to remediate the site was made Categories included human
health risk assessment (quantitative or qualitative), Federal or State applicable or relevant and appropriate requirements
(ARARS) and to be considered requirements (TBCs), citizen and State concerns, and MCLs or maximum contaminant
level goals (MCLGs) Because human health risk assessments are based on future use scenarios (a "reasonable"
maximum exposure to receptors under the use scenario chosen), the future surface land use scenario will play a major
role in the derivation of cleanup levels and in the risk management decisions that emerge from the Human Health Risk
Assessment when the cleanup is designed to be protective of a surface land
"Given that only 20 sites were included in the follow-up telephone survey, a decision was made not to change
responses in the FFSS data base as a result of information obtained during the telephone interviews
18
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Table 1. Results of Follow-up Telephone Calls to Selected Residential ftiture Land Use Sites
Region
1
t
3
4
4
4
EPA ID
ME9570024522
NH75TO024847
WVD980713036
GA7170023694
KY889(XX>a982
TN3890090003
ou
2
8
2
S
8
2
Facility
Loring AFB
Pease AFB
West Virginia
Ordnance Work*
USMC Logistics Base
Paducah Gaseous
Diffusion Plant
Oak Ridge Reservation
Reason for Residential
FLU Selection
Current and surrounding
bod use; and
uncertainly of FLU
Source control to
protect GW will achieve
residential levels
Uncertainty of FLU
(probably)
Uncertainly of FLU
Source control (o
protect GW will achieve
residential levels
Source control driven
by need to achieve 5W
discharge levels
Driving Force in
Cleanup
Air Force
MCLs
Unknown
State
MCLs
State NPDES
discharge levels
Did Cost Impact
Remedy Selection?
No; however, die remedy
(elected involved
consolidation of waste*
from other sitea on the
base, thereby saving
money lor the cleanup of
the base as a whole.
O&M cost dU; remedial
cods did not.
Yes
Unknown
Unknown
Unknown
Comments
The ale is two old bndBIU;
'restricted" residential use was
baaed on nirroundiag area and
BRAC (tatui, RPM probably should
haw identified a recreational FLU.
Basis of cleanup is MCLs, not
surface u«e.
Residential FLU used in risk
assessment as wont ease scenario;
FLU decisions made before RPM
became involved at the site.
State policy to consider residential
at all limes; incremental cost to
clean up to residential levels
relatively small as compared to
industrial levels.
Basis of cleanup is MCLs, not
surface use.
Need to achieve NPDES surface
water discharge levels required
removal of all wastes, and NPDES
discharge levels arc "drinking
water' levels; RPM, therefore,
selected residential FLU
(unrestricted use). The site is, and
will remain, industrial.
VO
-------
Table 1 (continued)
Region
5
5
6
7
8
8
9
9
EPA ID
IL32 10020803
MN7213820908
OK1573724391
M03210090004
SD2S71924644
UT9210020922
AZ7S70028582
CA8210020832
ou
I
8
2
1
1
1
1
1
Facility
Savannah Array Depot
New Brighton/Aidea
Hills
Tinker AFB
Wcldon Springs
Ellsworth AFB
Ogden Defense Depot
Williams AFB
Sharps Army Depot
Reason tor Residential
FLU Selection
Uncertainly of FLU;
remedy achieved
residential levels
anyway
Uncertainty of FLU;
remedy achieved
residential levels
anyway
Current and surrounding
land use; uncertainly of
FLU
Uncertainty of FLU
Uncertainty of FLU;
source control to protect
GW will achieve
residential levels
Uncertainty of FLU
Uncertainty of FLU;
source control to protect
GW will achieve
residential levels
GW pump and treat
Driving Force in
Cleanup
Army, State
Army, Region
Air Force
State, Army, Region
Air Force, State,
MCLs
Region
State for GW, Region
far Soil
MCLs
Did Cost Impact
Remedy Selection?
No
Yes
No
Yes
O&M costs did, remedial
coiti did not
Yes
Yes
Comments
Regional policy at the time of the
ROD was to consider residential at
all sites; in addition, residential
FLU was chosen due to BRAC
concerns at this facility, site
location (prime residential rites if
not owned by military), and
incremental costs to clean up to
residential levels were minimal.
Since (he issue of the ROD, FLU
policy for this facility has changed,
land use will now be industrial;
however, incremental cost to clean
up to residential levels is minimal.
Remediation goal in ROD is to
achieve residential levels, if
possible; actual land use is
recreational.
Basis of cleanup it MCLs, not
nirface use.
Residential FLU across base.
Potential for residential use by
nearby Native American Tribe.
Basil of cleanup is MCLs, not
surface use.
Survey was incorrectly filled out;
no lource control; only GW pump
and treat.
-------
Table 1 (continued)
Region
9
10
10
10
10
10
EPA ID
CA0210020780
AK8S70028649
HM890008952
WAI 170023419
WA7210090067
WA9S71924647
OU
3
4
18
2
2
1
Facility
Sacramento Amy
Depot
Elmcndorf AFB
IN EL
Naval Undersea
Warfare Center
Fort Lewis Logistics
Center
Fairchild AFB
Reason for Residential
FLU Selection
Remedy will achieve
residential levels
anyway
Uncertainty of FLU;
source control to protect
GW will achieve
residential levels
Uncertainty of FLU
Uncertainty of FLU;
source control to protect
GW will achieve
residential levels
Source control to
protect GW will achieve
residential levels
Source control to
protect GW will achieve
residential levels
Driving Force in
Cleanup
Technology
Region, Stale, MCLs
State, Site Advisory
Board
State, MCLs
Army, MCLs
MCLs
Did Cost Impact
Remedy Selection?
No
Yes
No
Yea
Unknown
Yes
Codidotciits
Best technology was (elected;
minimal incremental cost to achieve
residential leveli.
Residential FLU across base;
residential FLU used in risk
assessment as worst case scenario,
if GW had not been issue,
residential land use would still be
chosen.
Considered potential residential
100+ years in the future.
Bads of cleanup is MCLs, not
oirfaceuse.
MCLs for landfill portion of OU;
base wonted unrestricted vie for
non-landfill portion of OU.
Basis of cleanup u MCU, not
surface use.
Key:
FLU
GW
OU
SW
MCLs
NPDES
BRAC
RPM
ROD
Future Land Use
Ground Water
Operable Unit
Surface Water
Maximum Contamination Levels
National Pollutant Discharge Elimination System
Base Realignment and Closure
Remedial Project Manager
Record of Decision
-------
use. Although 83 percent of the sites that identified residential future land use in the FFSS identified the Human Health
Risk Assessment as a primary factor for the cleanup decision, analysis of the relationship of ground water to residential
land use suggests that the real influence may be overstated. Normally, when a source is remediated to protect or to
achieve drinking water levels in ground water, the degree of source control required will be based on modeling of the
source to establish (he transport of contaminants and their fate in ground water in relation standards (i e , MCLS) rather
than a baseline risk assessment
3.3 Factors Affecting Selection of Future Land Use
The selection of future land use is dn ven by a variety of factors The significance of these factors will often
be different when residential land use is selected, than when another land use is selected (e g, industrial, military,
recreational, or other) The results of the telephone interviews and the survey suggest that major considerations are
D Current land use,
D Minor incremental costs of residential future land use over industrial/commercial,
D Role of States, and
D Uncertainty regarding the future operational status of the facilities
3.3.1 Current Land Use. Current land use is clearly more significant at nonresident la) land use sites than at
residential land use sites The current and future land use are the same at almost half (49 percent) of the source control
sites with a nonresidential future land use In contrast, only 11 percent of the future land use residential source control
sites also have a current land use of residential'" As shown in Figure 15, for most of the future land use residential
source control sites, the current land use identified is military (47 percent), industrial (15 percent), and landfills (IS
percent)
Major factors influencing the switch from a nonresidential current land use to a future land use of residential
are described below
3.3.2 Minor Incremental Cost. The telephone survey data suggest that residential land use is frequently
chosen when the incremental cost of achieving residential land use is minimal in comparison to achieving industrial land
use In fact, minimal incremental cost between cleaning up to a residenti.il versus a industrial future land use scenario
was cited as a factor in the selection of a residential future land use by 20 percent of the RPMs contacted (four sites) in
the telephone survey In these cases, decisions were made to reduce future liabilities by cleaning up to unrestricted uses.
3.3.3 Role Of States. The results of the survey and the follow-up telephone interviews also indicate that, in
selected States, the influence of the State in future land use selection can be significant The FFSS shows that State
concerns were identified as a primary factor influencing future land use selection at 22 percent of the future land use
residential source control sites, but at only 13 percent of the future land use nonresidential source control sites A closer
analysis of survey data, in conjunction with telephone interview information, suggests that the FFSS information may
understate the influence of the States
"When residential land use is the current land use, the future land use chosen is almost always residential,
however, relatively few of the sites have a current residential land use.
22
-------
Of die 31 States represented in the FFSS, 5 Su*e» (California, Idaho, Maine, UUh, and Washington)
account for 61 percent of the future land use residential source control sJte*, but only 41 percent of nil source
coot ml xiten. Furthermore, UtAh uid Washington alone account (in $6 percent of the source control future land
mw residential site*, but only 22 percent of all source control she*.
Do Not Know
1%
Residential
11%
Industrial
15%
Other?
12%
landfill
15%
Military
47%
PcKCfltagcf do not add to 100 because of rrwniling.
Other include* Rcc««ioi»l. Open Sjiicc/Ntiurc I*ttserve, and Oihf r Specify.
Number of Sire* * 75
Figure IS. rurrent Land U«e at Source Control Sites with a
Future Land Use of Residential
In addition, in follow-up telephone interviews. RPMc smid that when residential land me wx< selected, (be
State pl;.y«d K major role in (he cdoccion of the future land UM mow than 35 percent of the time. As shown in
Table I, the State wat identi^ed u a driving force in the cleanup at 8 of the 20 sites.
3.3.4 Uncertainty Regarding Future Operational Status. Although analysis of «irv«y daudo*i
not depict a significant different* be
-------
During an initial examination of residential land use data, an attempt was made to use survey statistics to
analyze the role of uncertainty and, in particular, the BRAC process, on the identification of projected future land use
In this analysis, uncertainty was cited as a primary factor in future land use selection at 33 percent of the future land use
residential source control sites, but at only 17 percent of future land use nonresidemtal source control sites
OF the source control sites in the FFSS, 32 percent are at BRAC facilities, and the remaining 68 percent are
at non-BRAC facilities. BRAC source control sites are slightly more likely than non-BRAC sites to select a residential
future land use (51 percent at BRAC source control sites versus only 43 percent at non-BRAC source control sites) In
addition, DOD sites showed a significant preference for residential future land use over DOE sites This is interesting
because DOD sites are potential closure candidates under BRAC Uncertainty regarding the future BRAC status of the
DOD facilities may play a much larger role at DOD facilities than at DOE facilities
Dunng the telephone interviews conducted to follow-up FFSS information at residential future land use sites,
RPMs indicated that the potential of BRAC may exert as strong an influence over the selection of a potential residential
future land use as the actual identification of a facility as BRAC Over 50 percent of the RPMs (12 of 20) cited the need
to be protective in the face of uncertainly as a reason for selecting a residential future land use Many RPMs felt that,
given the recent base realignments and closures, bases may not always be under Federal Government control Others
noted that Federal agencies are often not able to enforce use restnction on lands cleaned up to less than residential
(unrestricted) use Still others noted that uncertainties regarding future use may encourage the military to clean up sites
to unrestricted (i e, residential) use to facilitate potential transfers to nonmihlary uses. In some cases, the cost of cleanup
to residential may not be significantly greater than the cost to cleanup to a different land use In these cases, the base
operators opt for cleaning up the site to residential levels in hopes of ridding themselves and the military of future
liabilities
3.3.5 Other Factors Examined as Potential Influence on Future Land Use
Surrounding Land Use Appears To Play a Minor Role in Future Land Use Selection. Analysis
of the FFSS data on surrounding land use reveals that 56 percent of the source control sites with a residential future land
use have a surrounding land use of residential. However, although surrounding land use was identified as a primary
factor in future land use selection at 52 percent of the future land use residential source control sues, it was mentioned
as a factor for future land use selection by only 10 percent of the RPMs during the follow-up telephone survey." It is
clear, on a site-specific basis, that surrounding land use can play a major role in future land use selection For the
universe as a whole, however it appears to play a less important role as compared to uncertainly and proteclion of
ground water
ROD Signature Date Does Not Appear To Play a Role in Future Land Use Selection, in order
lo determine if the future land use preferences changed from fiscal year to fiscal year, an analysis based on the ROD
signature date was performed Although conclusions must be tempered by the small number of RODs in most years,
the ROD signature dale does not appear to play a role in future land use selection Fi fty-five percent of the source control
RODs were signed in fiscal years (FY) 1989 through 1993, 44 percent of these were residenlial future land uses The
remaining 44 percent of the source control RODs were signed in FY 1994 and 1995,47 percent of these were residential
future land uses Conclusions of any trend, however, are difficult to support because the partial FY 1995 results may
not be reflective ofFY 1995 as a whole.
l5As part of the follow-up survey, RPMs were asked how, in terms of geographic distance, they interpreted
the term "surrounding" land use Responses ranged from less than 1/4 mile to over 10 miles The majority of the
respondents assumed that surrounding meant about I mile or less
24
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3.4 Conclusions
The selection of a residential future land use is less frequently the driver behind remedy selection than current
debate indicates When a residential future land use is selected, factors that influenced that selection may have included
minimal incremental cost of residential over industrial (or some other use) such that it appears 'worth while" to
participants in the remedy process to eliminate future liabilities Other important factors are State preference and
uncertainty concerning the future use of the site When residential land use is not a 'driver,' it is sometimes identified
when a source is cleaned to below residential levels due to the need to protect ground water, or when the ground water
itself is cleaned to drinking water levels In these cases, cleanup to residential use is incidental to the remedy, but does
not affect remedy selection
25
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26
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APPENDIX A
FEDERAL FACILITY SUPERFUND SURVEY ON SIGNED
RECORDS OF DECISION
BLANK SURVEY FORM AND INSTRUCTIONS
27
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28
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Federal Facility Superfund Survey
Signed Records of Decision
INSTRUCTIONS
Enclosed you will find the Federal Facility Superfund Survey for Signed Records of
Decision. The survey contains 5 pages. The first page is a cover page for the survey
and asks administrative questions concerning the name of the federal facility, its EPA
CERCLIS Identification Number, the Operable Unit (OU) number, etc. The next three
pages are more site specific and deal with factors that went into the ROD's development
and the remedial activities that took place, or are planned to take place, at the site. The
last page is a continuation sheet for all questions for which the answer is other
(specify), or for answers where additional explanation or information would be helpful.
Petroleum sites not managed under CERCLA should not be included in this survey. If
you have any questions regarding the administration of the survey (e.g., due dates,
etc.), please contact Jim Woolford at (202) 260-1606. Technical questions regarding
the survey should be directed to John Newton of Versar, Inc. at (703) 642-6785.
The source of information for this Survey should be the appropriate decision document
(e.g., ROD, explanation of significant differences, ROD amendment) or the various support
documents containing more detailed information (e.g., RI/FS).
Part 1 - Federal Facility Suoerfund Survey Cover Page
Question Information Required
1. The CERCLIS ID Number for the federal facility.
2. The Region in which the federal facility is located.
3. The federal facility's Name.
4. Has the federal facility appeared on any of the 1988, 1991, 1993, or 1995
Base Realignment and Closure (BRAG) lists?
5. The Name of the EPA Remedial Program Manager (RPM).
6. The RPM's phone number.
7. The OU number.
8. The name or a brief description of the OU.
29
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9. The date of the ROD'S signature.
10. For many federal facilities, OUs contain geographically distinct sites (i.e.,
landfills, spill sites, waste areas, etc.) that have been lumped together.
If the OU in question contains more than one site, the answer to question
10 should be "Yes."
If the answer to question 1 0 was "Yes," then identify the sites which
make up the OU by providing a site number (i.e., 1, 2, LF10, etc.) and a
short descriptor such as landfill, spill site, lagoon, etc.
Pages 2 through 4 are to be filled out for each of the sites identified in Question 10 that
are geographically distinct and have different land uses and remedies. It is not
necessary to fill out separate questionnaires for sites with identical answers. Again, it
is also not necessary to fill out the survey for petroleum sites not managed under
CERCLA. If the number of sites in the OU exceeds 1 0 and it is not possible to provide
the required information, or an extension is needed, please contact Jim Woolford at
(202)260-1606.
Part 2 - Land Use and Basis for Cleanup Information
Question Information Required
1. The CERCLIS ID number for the federal facility.
2. The OU number.
3. The site descriptor for the particular site (i.e., should be identical to the
information provided on page 1).
4. The site number for the particular site (i.e., should be identical to the
information provided on page 1).
5. Media/Material. This is a two-part question in which the media/materials
addressed and of concern should be identified. Media/materials
addressed include only those media/materials which were, or will be,
remediated during remedial actions. The media/materials of concern
include all media/materials that were contaminated at the site or which
potential contamination drove the remedy, including those that are not
addressed in the remediation itself. For example, if both soils and ground
water are contaminated, but only the soils are remediated (e.g.,
30
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Part 2 - Land Use and Basis for Cleanup Information cont.
Question Information Required
removal of contaminated soils and natural attenuation for the ground
water), both would be of concern but only the soils would be addressed.
Check all answers that are applicable.
6. Current Land Use of Site or OU at time of ROD signature. How was the
site being used as of the ROD signature date? Check all answers that
are applicable.
7. Current Surrounding Land Use at the time of ROD signature. How was
the land surrounding the site being used at the time of ROD signature?
Although no specific radius is specified, responses should include uses
both on the off the facility which were sufficiently close to the site that
such use may have effected the uses considered in the baseline risk
assessment or the selected future land use on which the protectiveness
of the remedy was based. Check all answers that are applicable.
8. Basis for Cleanup. On what basis was a decision to remediate the site
made? If there were more than one reason, choose all that are
applicable, numbering them in sequential order from the most important
factor to the least important to the degree practicable or known. [Note: ff
a human health risk assessment was the basis for cleanup, or a basis for
cleanup, please identify whether a quantitative or qualitative human health
risk assessment was conducted. For example, interim actions may be
based on a qualitative rather than quantitative risk assessment.]
9. Future Land Use(s) Considered in Baseline Risk Assessment. Indicate
all of the future use scenarios that were considered during the baseline
risk assessment. Check all answers that are applicable.
10. Future Land Use Decision on which Protectiveness of Remedy is Based.
What future land use was chosen in the risk management process as the
exposure scenario on which cleanup levels are based? Respondents
should also indicate whether the selected future land use played a key
role in the selection of the remedy. Check all answers that are
applicable.
11. What was the primary factor on which the future land use decision was
based? Identify the factor (or several factors) which played the largest
role in determining the future land use selected for the site. The "Final
31
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Part 2 - Land Use and Basis for Cleanup Information cant.
Question Information Required
Reuse Plan" answer should only be chosen if a formal BRAC reuse plan
has been finalized, not if the reuse plan is interim or draft. Check all
answers that are applicable.
12. Who is the presumed future user(s) of the site? Identify the agency or
group(s) that will be occupying the site once remediation has been
completed. The answer "New Federal Agency" should be chosen if a
federal group, different than the current owner, is planning to utilize the
site in the future. Choose the answer "McKinny Act" if the McKinny Act,
which provides for use of the site by the homeless, played a role in
determining the future user of the site. Check all answers that are
applicable.
Part 3 - Remedy Information
Question Information Required
14. These questions are carried over from the previous page.
13. Source Control for Soil/Surface Cleanup or Management. Indicate
whether the cleanup remedy for the soil/surface (i.e., non-ground water)
was an interim or a final source control remedial action.
14. Source Control to Protect Ground Water. Indicate whether the cleanup
remedy was an interim or a final source control remedial action intended
primarily to protect the ground water.
15. Ground-water Remediation. Indicate whether the cleanup remedy for the
ground water was an interim or a final remedial action.
16. Cleanup Levels - Carcinogens. If the (or a) cleanup level is based on risk
due to carcinogens, indicate the cleanup level to be achieved for each
media to be remediated. If the cleanup level is not based on
carcinogenic risk, leave blank.
17. Cleanup Levels - Noncarcinogens. If the (or a) cleanup level is based on
noncarcinogenic risk, specify those media for which the cleanup level to
be achieved is a hazard index or hazard quotient of less than 1. If the
cleanup level is not based on noncarcinogenic risk, leave blank.
32
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Part 3 - Remedy Information cont.
Question Information Required
18. Cleanup Levels - Other (Specify). If the (or a) cleanup level is based on
something other than carcinogenic or noncarcinogenic risk (e.g., State
soils cleanup levels), specify the cleanup level type/source and, if
applicable, the cleanup level to be achieved for each media to be
remediated. If this question is not applicable, leave blank.
19. Site Remedy. Identify the remedy that was selected the site, as well as,
those remediation alternatives that were considered in the detailed
analysis of alternatives. Check all answers that are applicable.
20. Cost of Remedy. What is the estimated cost of the selected remedial
action?
21. Estimated Cost Range of the Remedies Considered. Identify the range
of costs for the various alternatives considered, if known (i.e., the bottom
of the range should be the estimated cost of the least expensive
alternative considered, and the top of the range should be the cost of the
most expensive alternative considered).
22. Was an innovative or alternative technology considered during the
development of alternatives? Even if not formally considered, if an
innovative technology was evaluated as a potential remedy, the response
should be "Yes."
23. Was an innovative alternative technology formally considered in the
detailed analysis of alternatives?
24. Human Heath Risk Assessment Performed? Was a human health risk
assessment conducted? This question should be answered "Yes" even
if the risk assessment was not the (or a) basis of cleanup.
25. Ecological Risk Assessment Performed? Was an ecological risk
assessment conducted?
26. Did the site contaminants include Dense Non-Aqueous Phase Liquids
(DNAPLs)? If "No," skip to Question 29. If "Yes," answer Questions 27
and 28.
33
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Part 3 - Remedy Information cont.
Question Information Required
27. If DNAPLs were one of the site contaminants, was a Contingent ROD
signed?
28. If DNAPLs were one of the site contaminants, was a Technical
Impracticability Waiver included in the ROD?
29. Indicate whether the ground water at the site is a current and/or future
drinking water source.
30. O&M Cost. What is the annual Operation and Maintenance (O&M) cost
for the selected remedy? Circle one answer, if known.
31. O&M Years. How long will the selected remedy of the site have to be
maintained? Circle one answer, if known.
32. Principal Cost Driver of Cleanup. What factor(s) played the largest
role(s) in determining the cost of the remediation? Check all answers that
are applicable.
33. Decision Document Source of Questionnaire. The information in this
questionnaire should be based on the most recent decision document
issued for the site. In response to this question, please do not identify
support documents (e.g., RI/FS) which may have been the actual source
of a specific piece of information. Instead, identify the latest decision
document.
34
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Federal Facility Superfund Survey
Signed Records of Decision
1. EPA ID Number: [_
3. Facility Name: I
2. Region [ |
4. la Thts Facility on any of the BRAC Lists (Y/N)? Q
5. RPM Name: [
8. Phone Number: [
7. OU Number: (
8. OU Name: [
9. Date of ROD Signature:
10. Does this OU contain multiple sites IY/NJ7 | )
If Y. please give the Bite number and a short descriptor foi each of tKe sites (i.e. LF10 Landfill)
Site 1
Site 2
Site3
Site 4
Site S
Site 6
Site?
SiteS
Sites
Site 10
Site 1 Descriptor: |_
Site 2 Descriptor: Q
Site 3 Deacriptor: [[
Site 4 Descriptor: £
Site 5 Descriptor: |_
Site 9 Deacriptor f
Site 7 Descriptor: _
Site 8 Descriptor: Q
Site 9 Descriptor: £
Site 10 Descriptor: [
For each of the sites identified above that are geographically distinct areas and with different
land uses and remedies, please fill out pages 2-4. Please make additional copies as
necessary. It is not necessary to fill out a separate questionnaire if the answers are the same
for each site within the OU. Petroleum sites not managed under CERCLA should not be
included. If the number of sites in the OU exceeds 10 and it is not possible to provide the
required Information, or an extension Is needed, please contact Jim Woolford at (202) 260-
1606.
Note: Page 5 is a continuation sheet on which expanded responses can be written.
Note. This page is to be filled out for the entire OU.
-------
1. EPA ID Number:
2. Operable
Unit Number:
3. Site Dascripton \_
4. Site Number: F
Land Use + Basis for Cleanup Information
5. Media / Materials
(Check All Applicable) Addressed Of Concern
Air D D
Groundwater LI LI
Surface water LJ LJ
Sediment D D
Debris D D
Liquid Waste D D
Soil D D
Sludge D D
Solid Waste D D
Mixed Waste D D
6. Current Land Use of Site or OU
(Check All Applicable)
Agricultural Q Commercial O
Educational Q Industrial LJ
Residential D Recreational D
Military D Lflndfi" °
If Military, ia the site used aa a
1 . Fire Training Area
2. Radar
3. Ammunition Depot
4. Bombing Range
5. Aviation
6. Other (Specify)
Open Space / Nature Preserve LJ
Vacant Q If Vacant, former use:
1
Othar (Spaelfyl fl
7. Current Surrounding Lend Use
(Check All Applicable)
Agricultural O Commercial Q
Educational d Industrial Q
Residential O Recreational O
Military D Landfill D
If Military, Is the site used as a
1 . Fire Training Area
2. Radar
3. Ammunition Depot
4. Bombing Range
5. Aviation
6. Other (Specify)
Open Space / Nature Preserve O
Vacant D If Vacant, former use:
I |
Other (Specify) LJ
8. Basis For Cleanup
(Number In order of significance to remedy selection, with 1 first)
Human Health Quantitative Risk Assessment (~~| Federal TBC |_J
^ State TBC fj
Human Health Qualitative Risk Assessment i — i
1 — ' State ARAR | |
Ecologioa. Risk Assessment Q |f State ARAR>
MCL Q
MCLG fj
Federal ARAR d
Future User Concern |_ I
State or Local Government Comments | |
Other (Specify) | j
State MCL Q
Other State GW , — ,
Requirement | |
State Soil Level | |
Citizen Comments P_^j
9. Future Land Use(s) Considered in Baseline Risk
(Check All Applicable)
Agricultural LJ
Educational LI
Residential O
Military Q
If Military, ia the site used as a
1 . Rre Training Area
2. Radar
3. Ammunition Depot
4. Bombing Range
5. Aviation
6. Other (Specify)
Assessment
Commercial Q
Industrial EH
Recreational LJ
Landfill D
Open Space / _
Nature Preserve LJ
Vacant D Other (Specify) D
10. Future Land Use Decision on which Protectlv
(Check All Applicable)
D Commercial L
D Industrial E
_ Residential L
Military Q
_ . . . . Recreational L
If Military, is the site used as a
I.Fife Training Area otne
2. Radar
3. Ammunition Depot
4. Bombing Range
5. Aviation
6. Other (Soeclfv)
sness of Remedy is Based
] Open Space / j— i
Nature "-1
] Preserve
] Vacant D
J Landfill D
r (Specify) O
Did The presumed Future Land Use have e strong influence on i— i
the selection of the remedy (Y/N) If "No", please explain? "— '
36
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. EPA ID Number: | | 2. Operable | |
Unit Number: ' '
Land Use + Basis for Cleanup Information
3. Site Descriptor:
4. Site Number:
_|
I
11. What was the primary factor on which Future Land use decision was based?
CD Active facility plans for Future use of site L~D Use of land surrounding the site
CD Final reuse plan for a closing facility
CD Current use of the ate
Lj Community concerns
CD State concerns
Lj Potential current or future plans for
closure of the facility
CD Need to be protective in the face of CD Other (Specify)
uncertainty
12. Who is the presumed future user of the site?
CD Current User
CD Tennant Activity
CD New Federal Agency
LJ State Government
LJ Local Government
CD Private
D McKinnyAct
LJ Native American
D Other [Specify)
37
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1. EPA ID Number:
2. Oparabla
Unit Number:
3. Site Descriptor:
4. Site Number: I
Remedy Information
13. Source Control for Soil /Surface Cleanup or Management 1. Interim
(Circle one) 2- RnBl
14. Souroo Control to Protect Groundwaier 1. Interim
(Circle one] 2- fina)
1 5. Ground water Remediation 1 . Interim
(Circle one) 2- Rnal
1 6. Cleanup Levels - Carcinogens
Soil / Surface Groundwater Surface Water Air
Above 10-4 n n D n
10-4 D D DO
10-5 n n D n
io-« n n n n
Below 10-6 D D D D
17. Cleanup Levels - Nonearcinogens
Soil / Surface Groundwater Surface Water Air
Hi/HQ>i? n n n n
1 8. Cleanup Levels - Other (Specify)
Soil /Surface D 1 1
Graundwatar Q 1 1
Surface Water D | 1
Air LJ 1 1
1 9. Site Remedy
[Chock oil that apply) Selected Considered
1 . GW • Pump * Trent Q Q
2. GW • Pump + Discharge D D
3. GW • Biological Treatment D D
4. GW - Chemical/Physical Treatment D D
6. GW - Natural Attenuation D D
6. GW • Containment D D
7. GW • Engineering Controls D D
8. On-Bit* Disposal D D
9. Off-site Disposal D D
1O. On-site Treatment O Q
ll.Ofl-elto Treatment D D
12. Recover and Reuse O CD
13. On-slte Containment (Capping) Q Q
14. Off-site Containment CD D
IS. Institutional Controls CD D
1 6. Resident Relocation D O
17. Other Q Q
Specrfy: | | |
18. No Further Action D D
19. No Action Q Q
20. Cost of Remedy l») |
I
21. Estimated Cost Range of Remedios Considered (4)
1
22. Was an innovative alternative technology T~\
considered in the development of alternativos? (Y/N)
23. Was an innovative alternative technology formally t~~l
considered in the detailed analysis of alternatives? (Y/N)
24. Human Riek Assessment Performed? (Y/N) Cl
25. Ecological Risk Assessment Performed? (Y/N)
n
26. Were DNAPU involved? (Y/N) D
27. If the answer to Cues. 26 is "Y", was a p-i
Contingent Rod signed? (Y/N) •->
28. If the answer to Ques. 26 is "Y"r was a Technical r—i
Impracticability Waiver included in the ROD? (Y/N) L- '
Current
29. Is the ground water a r—i
drinking water source? (Y/N) L-1
30. Annual O + M Cost 1 J0
(If kno wn. circle one) 2! »800- S 1 .OOO
3. $1.000-$ 10.000
4. SI 0.000-820.000
5. «20.000-«40.000
6. $40.00O-C60,OOO
7. > 8 60,000
31. O + M Years 1.0-3
(If known, circle one) 2. 4-10
3. 1 1-20
4. 21-30
5. >30
Future
D
32. Principal Cost Driver of Cleanup
(Check all that apply)
Q 1 . Large Volume of Soil/Sludge/SoGd Waste
Q 2. Large Volume of Groundwater
Q 3. Munitions
Q 4. Complex Hydrology
Q3 S. Complex Mixture of Contaminants
Q 6. High Cost of Treatment
Q 7. Radioactive Waste
Q 8. Off-site Disposal / Treatment
n 9- Biological / Chemical Weapons Waste
Q 10. Hazardous Waste
G 11. Other (Specify)
1
1
33. Decision Document Source Q Record of Decision (ROD) H Explanation of Significant Differences D Rno1 RetJ»° Pin"
of Ouestionnoire Information
(Check all that apply) Q ROD Amendment G Other (Specify)
38
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1 EPA ID Number 2 Operabla 3 Site Descriptor
Unit Number. 4 Site Number
Federal Facility Superfund Survey
Signed Records of Decision
Continuation Sheet (Identify corresponding question number)
-------
40
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APPENDIX B
RODs INCLUDED IN THE FFSS DATA BASE
41
-------
42
-------
Federal Facilities of the Federal Facilities Superfund Survey
OTIS AIR NATIONAL GUARD
OTIS AIR NATIONAL GUARD
BRUNSWICK NAVAL AIR STATION
BRUNSWICK NAVAL AIR STATION
BRUNSWICK NAVAL AIR STATION
BRUNSWICK NAVAL AIR STATION
BRUNSWICK NAVAL AIR STATION
LORING AIR FORCE BASE
LORING AIR FORCE BASE
LORING AIR FORCE BASE
PEASE AIR FORCE BASE
PEASE AIR FORCE BASE
PEASE AIR FORCE BASE
PEASE AIR FORCE BASE
PEASE AIR FORCE BASE
DAVIS NAVAL CONSTRUCTION BATTALION
NAVAL EDUCATION & TRAINING CENTER
NAVAL EDUCATION A TRAINING CENTER
FORT DIX LANDFILL SITE, NJ
P1CATINNY ARSENAL
NAVAL AIR ENGINEERING STATION. LAKEHURST. NJ.
NAVAL AIR ENGINEERING STATION, LAKEHURST, NJ.
2 NJ7170023744
2 NJ7170023744 NAVAL AIR ENGINEERING STATION, LAKEHURST. NJ.
NJ7170023744 NAVAL AIR ENGINEERING STATION, LAKEHURST, NJ.
NJ7170023744 (NAVAL AIR ENGINEERING STATION, LAKEHURST, NJ.
2 NJ7170023744 1NAVALAIRENGINEERINC3[STATION. LAKEHURST, NJ
2^7170023744 JNAVAL AIR ENGINEERING STATION, LAKEHURST, NJ
2INJ9690S10020 FAA TECHNICAL CENTER
FAA TECHNICAL CENTER
2 NJ9690510020
2 NY4571924774 PLATTSBURGH AFB
2 NY4571924774
PLATTSBURGH AFB
PLATTSBURGH AFB
2 NY4571924774
3 DE8570024010 DOVE AIR FORCE BASE
3 DE8570024010 DOVE AIR FORCE BASE
43
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Federal Facilities of the Federal Facilities Superfund Survey
Region
EPA ID
Name
OU
SITE
DE8S70024010
DOVE AIR FORCE BASE
DES570024010
DOVE AIR FORCE BASE
MD2210020036
ABERDEEN PROVING GROUNDS (EDGEWOOO AREA)
MD2210020036
ABERDEEN PROVING GROUNDS (EDGEWOOD AREA)
MD3210021365
ABERDEEN PROVING GROUNDS (MICHAELSVILLE If)
M03210021355 ABERDEEN PROVING GROUNDS (MICHAELSVILLE LF)
PA6170024S45 NAVAL AIR DEVELOPMENT CENTER (8 AREAS)
PA6170024545
NAVAL AIR DEVELOPMENT CENTER (8 AREAS)
PA6213820503
LETTERKENNYARMY DEPOT. SE AREA
WEST VIRGINIA ORDNANCE WORKS
WEST VIRGINIA ORDNANCE WORKS
ANNISTONARMYDEP01
NAVAL AIR STATION JACKSONVILLE
NAVAL AIR STATION JACKSONVILLE
NAVAL AIR STATION JACKSONVILLE
FL7S70024037
USAF HOMESTEAD AFB
FL7570024037
USAf HOMESTEAD AFB
SS-3
GA1S70024330
ROBINS AIR FORCE BASE
GA1S70024330
ROBINS AIR FORCE BASE
GA7170023894
USMC LOGISTICS BASE
PSC 3
GA7170023694
USMC LOGISTICS BASE
PSC 16,17
GA71700236S4
USMC LOGISTICS BASE
PSC B
KY8890008982
PADUCAH GASEOUS DIFFUSION PLANT
KY6890008982
PADUCAH GASEOUS DIFFUSION PLANT
KY8890008982
PADUCAH GASEOUS DIFFUSION PLANT
KY8890008982
PADUCAH GASEOUS DIFFUSION PLANT
NC6170022S80
USMC CAMP LEJEUNE
NC6170022580
USMC CAMP LEJEUNE
4 NC6170022580
4 NC6170022580
JSMC CAMP LEJEUNE
uliMCCAMP LEJEUNE
2 SITES 1-3
6 SITE 2
SC1890008S89
DOE SAVANAH RIVER SITE
SC1890008389
DOS SAVANAH RIVER SITE
SC1890008989
DOE SAVANAH RiVER SITE
SC1890008989
DOE SAVANAH RIVER SITE
SC1890008989
DOE SAVANAH RIVER SITE
SC1890008989
DOE SAVANAH RIVER SITE
SC1890008989
DOE SAVANAH RIVER SITE
SC1890008989
DOE SAVANAH RIVER SITE
29
SCI890008989
DOE SAVANAH RIVER SITE
30
SC1890008989
DOE SAVANAH RIVER SITE
33
SCI890008989
DOE SAVANAH RIVER SITE
34
SC1890008989
DOE SAVANAH RIVER SITE
35
TN0210020582
MILAN ARMY AMMUNITION PLANT
TN0210020582
MILAN ARMY AMMUNITION PLANT
TN0210020582
MILAN ARMY AMMUNITION PLANT
14
TN3890090003
OAK RIDGE RESERVATION
TN3890090003
OAK RIDGE RESERVATION
TN3890090003
OAK RIDGE RESERVATION
TN3890090003
OAK RIDGE RESERVATION
TN3890090003
OAK RIDGE RESERVATION
4 TN38W090003
OAK RIDGE RESERVATION
4 TN3890090003 OAK RIDGE RESERVATION
rN3890090003 OAK RIDGE RESERVATION
44
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Federal Facilities of the Federal Facilities Superfund Survey
SAVANNA ARMY DEPOT ACTIVITY
H.8143S09487
SANGAMO ELECTRIC QUMP/CRAS ORCHARD
15,22,29
1L8143809487
SANGAMO ELECTRIC DUMP7 CRAB ORCHARD
ALL
5 MN31T0022914
NAVAL INDUSTRIAL RESERVE ORDNANCE PLANT (MROP)
5 MN7213820908
NEW BRIGHTON / ARDEN HILIS (TCAAP)
5 MN7213820908
NEW BRIGHTON / ARDEN HILLS fTCAAP)
MN7213820908
NEW BRIGHTON / ARDEN HILLS {TCAAP)
MN7213820908
NEW BRIGHTON /ARDEN HILLS (TCAAP)
MN7213820908
MEW BRIGHTON /ARDEN HILLS (TCAAP)
5 MN8570024275
TWIN CITIES AIR FORCE BASE (SMALL ARMS RANGE IF)
5 OH6S9000S976
US. OOE FEED MATERIALS PRODUCTION CENTER
OH6890008976
U.S. OOE FEED MATERIALS PRODUCTION CENTER
OH6S90008976
U.S. DOE FEED MATERIALS PRODUCTION CENTER
OH6S90008976
U.S. DOE FEED MATERIALS PRODUCTION CENTER
OH6890008984
U.S. DOE MOUND PLANT
LF8,10
OK1573724391
TINKER AFB
ALL
OK1573724391
TINKER AFB
TXC213820529
LONGHORM ARMY AMMUNITION PLANT
2 ALL
M032100S0004
WELDON SPRING SITE REMEDIAL ACTION PROJECT
1
SITES 1-3
MO3210090004
,WELDON SPRING SITE REMEDIAL ACTION PROJECT
NE2213820234
CORNHUSKER ARMY AMMUNITION PLANT
C01571S24130
LOWRYAFB
IRA-2
C01571524130
LOWRYAFB
IRA-1
C05210020769
ROCKY MOUNTAIN ARSENAL
C05210020769
ROCKY MOUNTAIN ARSENAL
17
C05210020769
ROCKY MOUNTAIN ARSENAL
18
C05210020769
ROCKY MOUNTAIN ARSENAL
19
CQ5210020769
ROCKY MOUNTAIN ARSENAL
20
COS210020769
ROCKY MOUNTAIN ARSENAL
21
C 05210020769
ROCKY MOUNTAIN ARSENAL
22
COS210020769
ROCKY MOUNTAIN ARSENAL
23
C05210020769
ROCKY MOUNTAIN ARSENAL
26
1-4
COS210020769
ROCKY MOUNTAIN ARSENAL
27
C05210020769
ROCKY MOUNTAIN ARSENAL
28
CO5210020769
ROCKY MOUNTAIN ARSENAL
29
C07S90010526
ROCKY FLATS PLANT
119.1
SD2571924S44
ELLSWORTH AIR FORCE BASE
SD2571924644
ELLSWORTH AIR FORCE BASE
UT0571724350
HILL AIR FORCE BASE
6 UT0571724350
HJL1. AIR FORCE BASE
8 UT3213820894
TOOELE ARMY DEPOT (NORTH AREA!
3ST04
LJT3213820894
TOOELE ARMY DEPOT (NORTH AREA)^
10
41
UT389009003S
MONTICELLO MILL TAILINGS SITE
8 UT3890090035
MONTICELLO MILL TAILINGS SITE
45
-------
Federal Facilities of the Federal Facilities Superfund Survey
Region
EPA ID
Name
01)
SITE
8
UT9210020922
OQOEN DEFENSE DEPOT
UT9210020922
OGDEN DEFENSE DEPOT
UT9210020822
OGDEN DEFENSE DEPOT
1.2.3
UT9210020922
OGDEN DEFENSE DEPOT
44A-E
UTD980667208
MONTICELLO RADIOACTIVE CONTAMINATED PROPERTIES
AZ75700285B2
WILLIAMS AIR FORCE BASE
QUA
DP13
0 AZ7570028582
WILLIAMS AtR FORCE BASE
LF04
AZ757002B582
WILLIAMS AIR FORCE BASE
ST12
AZ7570028582
WILLIAMS AIR FORCE BASE
ST12
CA0210020780
SACRAMENTO ARMY DEPOT ACTIVITY (SADA)
CA0210C20780
SACRAMENTO ARMY DEPOT ACTIVITY (SAOA)
CA0210020780
SACRAMENTO ARMY DEPOT ACTIVITY (SADA)
CA0210020780
SACRAMENTO ARMY DEPOT ACTIVITY (SADA)
CA0210020730
SACRAMENTO ARMY DEPOT ACTIVITY (SADA)
CA2570024453
GEORGEAFB
CA2S60012584
LAWRENCE LIVERMORE NATJONAL LABORATORY MAIN SITE
ALL SITES
CA3570024S51
CASTLE AFB
CA3570024551
CASTLE AFB
CA4570024337
MCCLELLAN AIR FORCE BASE
BASEWIDE
CA4570024337
MCCLELLAN AIR FORCE BASE
ALL
CA4570024345
NORTON AIR FORCE BASE
JA4971520334
DDRW-TRACY
9
CA7210020876
FTORD
9 CA7210020676
FTORD
CA7210020759
RIVERBANK ARMY AMMUNITION PLANT
ALL
CA72100207S9
RIVERBANK ARMY AMMUNITION PLANT
CA7210020759
RIVERBANK ARMY AMMUNITION PLANT
CA8210020832
DDRW SHARPE SITE (SHARPS ARMY DEPOT)
CAS570024143
MATHER AIR FORCE BASE
CA8570024143
MATHER AIR FORCE BASE
2,3.4
CA8570024143
MATHER AIR FORCE BASE
25
CA8570024143
MATHER AIR FORCE BASE
AC4W
10
AK417Q024323
N AW AIR FACILITY ADAK
10
AK4170024323
NAW AIR FACILITY ADAK
10
AK8570028649
ELMENDORF AIR FORCE BASE
10
AKS570028649
ELMENDORF AIR FORCE BASE
ST41
AK857002B649
ELMENDORF AIR FORCE BASE
AX857002BS49
ELMENDORF AIR FORCE BASE
ST37
10
AK8570026649
ELMENDORF AIR FORCE BASE
IDAHO NATIONAL ENGINEERING LABORATORY
IDAHO NATIONAL ENGINEERING LABORATORY
46
-------
Federal Facilities of the Federal Facilities Superfund Survey
IDAHO NATIONAL ENGINEERING LABORATORY
IDAHO NATIONAL ENGINEERING LABORATORY
IDAHO NATIONAL ENGINEERING LABORATORY
IDAHO NATIONAL ENGINEERING LABORATORY
IDAHO NATIONAL ENGINEERING LABORATORY
10 ID4890008962
IDAHO NATIONAL ENGINEERING LABORATORY
IDAHO NATIONAL ENGINEERING LABORATORY
10 OR6213820917
UMATILLA ARMY DEPOT
UMATILLA ARMY DEPOT
UMATILLA ARMY DEPOT
UMATILLA ARMY DEPOT
UMATILLA ARMY DEPOT
UMATILLA ARMY DEPOT
NAVAL UNDERSEA WARFARE CENTER, KEYPORT
NAVAL UNDERSEA WARFARE CENTER, KEYPORT
HANFORD 200-AREA (USDOE)
KANFORD 200-AREA (USDOE)
BONNEVILLE POWER ADMINISTRATION/ROSS COMPLEX
BONNEVILLE POWER ADMINISTRATION/ROSS COMPLEX
BONNEVILLE POWER ADMINISTRATION/ROSS COMPLEX
HANFORD 100-AREA USDOE
PORT HADLOCK DETACHMENT- USN
HANFORD 1100-AREA (USDOE)
NAVAL SUBMARINE BASE, BANGOR
NAVAL SUBMARINE BASE. BANGOR
101WA5170027291 NAVAL SUBMARINE BASE, BANGOR
10 WA5170090059 HAS WHIDBEY ISLAND, AULT FIELD
NASWHIDBEY ISLAND, AULT FIELD
NAS WKIDBEY ISLAND, AULT FIELD
NASWHIDBEY ISLAND, AULT FIELD
NAS WHIDBEY ISLAND, AULT FIELD
NAS WHIDBEY ISLAND, AULT FIELD
NAS WHIDBEY ISLAND, AULT FIELD
NAS WHIDBEY SEAPLANE BASE
FORT LEWIS LOGISTICS CENTER
10 WA7210090087
FORT LEWIS LOGISTICS CENTER
FORT LEWIS LOGISTICS CENTER
10 WA7210090067
FORT LEWIS LOGISTICS CENTER
10 WA7210090087
FORT LEWIS LOGISTICS CENTER
10 WA8570024200
MCCHORD AFB WASHRACK TREATMENT AREA
10 WA9571924647
47
-------
Federal Facilities of the Federal Facilities Superfund Survey
Region
10
10
10
10
10
10
EPA ID
WA9571 924647
WA9571824647
WA9S71924647
WA9571924647
WA9571S24647
WAD980833065
Name
FAIRCHILOAFB
FAIRCHILOAFB
FAIRCHILOAFB
FAIRCHILDAFB
FAIRCHILOAFB
MCCHORD AFB AMERICAN LAKE GARDENS TRACT
Total
Shaded areas denote No Action RODs
OU
2
2
2
2
2
1
291 sites
SITE
PS2
FT1
IS1
WW1
SW1.PS6&8
48
-------
APPENDIX C
FEDERAL FACILITIES TELEPHONE FOLLOW-UP
SURVEY QUESTIONNAIRE AND
INTERVIEW RESULTS
49
-------
50
-------
Federal Facilities Telephone Questionnaire Follow-up
1. In an effort to better understand choices related to residential land use,
a. What were the factors that drove the selection of the future land use upon
which the protectiveness of the remedy is based?
- State, EPA, Local government or community, Base decision, Marginal cost
increase of the remedy, already cleaning soil-to-ground water pathway,
surrounding land use...
- what role did EPA, versus the State, versus the Base play in making the
decision?
b. If there were multiple sites for this OU, were the remedies and land use
choices the same for each site, or were the answers provided for the OU in
a summation of site-specific answers?
c. If multiple future land uses were identified as scenarios for which the remedy
is protective, is it correct to assume that the most stringent land use
(residential) can be met throughout the site or OU?
d. What is the distance you used to delimit the surrounding land use?
Is it activity
- immediately adjacent to the site?
- within a near radius on the base (e.g., 114 mile, 112 mile, etc.)?
- off base, near the fenceline?
- off base, away from the fenceline?
e. What role did protecting the ground water play on the selection of future land
use?
Did the need to clean the site to protect ground water cause the selection of
a residential use, since low cleanup levels were required?
2. In an effort to better define the relationship of land use to remedy selection,
a. What was the influence of the future land use on the remedy selected?
- Was the remedy chosen because of the need to cleanup to residential use,
or was the remedy driven by engineering considerations, but would result in
residential levels anyway?
- Were other land uses seriously considered?
b. The presumed future user(s) at your site was (were) . How did this
impact the remedy selection? If the presumed user was not the current user,
what was the basis for the presumed future user(s)?
51
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3. In an effort to better understand the relationship between the basis of cleanup at a site
and the remedy selected,
a. Please describe how the different factors identified were used as the basis for cleanup
(e.g., MCLS, Health Risk Assessment, etc.).
b. If Human Health Risk Assessment and MCLs were chosen as the basis of cleanup,
regardless of the order they were selected, what information was derived from the risk
assessment that was not readily seen from the cleanup to MCLS?
c. If state regulators pushed for residential land use, were ARARs involved7
4. What role did cost play in the selection of the remedy'
a. Did cost play a factor in eliminating remedies for consideration? For selection?
b. What was the cost differential between the highest-costing and the lowest-costing
realistic remedies?
c. If other and uses (nonresidential) were seriously considered, what would have been
the cost?
52
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Telephone Interview Summaries
Site 1: Pease AFB, OU 8 Date of Interview: 30 NOV 95
RPM: Michael Daly
Synopsis:
OU 8 consists of multiple sites a municipal waste landfill, a dump, a ditch, and a hobby shop The remedy consisted
of digging up the landfill and disposing of it in another site on the base The dump was capped, and its cover maintained
The remedy driver was ensuring that the leachale from the landfill did not contaminate the ground water. MCLs were
the basis of cleanup, not a human health risk assessment A future land use of residential was chosen because the GW
was to be kept clean to MCL standards, not because the site would ever be used for residential purposes The future
reuse plan calls for the site to be open space A future land use of commercial was also chosen because of surrounding
land use in the area. Remedial cost for the site is driven by the O&M cost
Site 2: Paducha Gaseous Diffusion Plant, OU 8 Date of Interview: I DEC 95
RPM: Tony Able
Synopsis:
OU 8 is an interim action site consisting of a uranium and TCE contaminated landfill and a closed RCRA landfill (no
further action site) The landfill was capped to prevent leaching of contaminants to GW, which is being handled as a
separate OU due to contamination from various sites at the facility Because the GW will be protected to MCLS, the sjle
cleanup is to residential levels, however, no future residences are anticipated Multiple future land uses the result of the
impact of surrounding land use Remedial cost for the site includes O&M costs
Site 3: Oak Ridge Reservation, OU 2 Date of Interview: I DEC 95
RPM: Tony Able
Synopsis:
OU 2 is an interim action site designed to reduce the mercury contamination from Ihree tanks from entering nearby SW
Hazardous waste, water, and sediment were sent offsite for storage and/or treatment Residential future land use was
chosen because the cleanup standards for the nearby SW were based on NPDES limns, which were at a residential level
The site is considered to be industrial and will remain that way
Site 4: Elmendorf AFB, OU 4 Date of Interview: 7 DEC 95
RPM: Marcia Combe
Synopsis:
OU 4 is a final action site that contains an asphalt drum storage area, a Tire training area, and several aircraft
maintenance hangars Residential future land use was chosen because Region 10 guidance requires sites to evaluate
residential future land use to establish a baseline or worst case scenario If the human health risk for such a scenario
falls between 10' and 10-', decisions are then based on a residential land use Residential future land use is being
considered across the base at Elmendorf Another driving factor of the residential future land use scenario was the
location of the site. The site is near Anchorage and is considered prime real estate if the base should ever close
However, if the base should continue to operate as scheduled, the sue will not be residential because it is near the end
53
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of a runway State ARARs and MCLs were established as cleanup levels because they are clear and established levels
With regard to GW, although the State considers all GW aquifers a source of drinking water, the shallow aquifer
at Elmendorf is not considered a future DW source because it is contaminated and does not have a high yield
Cost played a large role in the choice of remedies. The difference in costs between the chosen remedy for GW (natural
attenuation) and alternatives was millions of dollars, however, cost was not a factor in the choice of future land use
Current surrounding land use (CSLU) choices were determined for locations adjacent to the site
Site 5: Ft Lewis Logistics Center, OU 2 Date of Interview: 7 DEC 95
RPM:BobKievit
Synopsis:
OU 2 consists of a landfill and a solvent refined coal pilot project (SRCPP) The driving factor in the choice of the
remedy at the landfill site was GW contamination The area is close to a drinking water source Soil was cleaned so
as to prevent further GW contamination, and the GW was allowed to naturally attenuate to MCL levels Future land
use did not play a role in the selection of the remedy, however, at the SRCPP, the site was cleaned for unlimited use
based on a future land use decision by the facility CSLU choices were determined for locations in the immediate
vicinity
Site 6: Tinker AFB, OU 2 Date of Interview: 7 DEC 95
RPM: Susan Webster
Synopsis:
OU 2 is surface water contamination to Soldier Creek that runs off base through a number of residential and
recreational areas Future land use was determined based on the surrounding areas (residential and recreational) that
the creek runs through A risk assessment was performed, and no threat to human health was determined Currently,
an ecological risk assessment is being performed. CSLU was determined for the area near the base fencelme Cost
was not a factor for the selection of remedies at this site
Site 7: Ogden Defense Depot, OU 1 Date of Interview: 7 DEC 95
RPM: Sandra Bourgeios
Synopsis:
OU 1 consists of a canal and two burial sites where the Fill used was contaminated Future land use of residential is
consistent throughout the Ogden Defense Depot because it is very likely that the site will be used for future residential
use The remedy for the site consisted of excavating the contaminated Till and sending it to a hazardous waste facility
GW is treated by a pump and treat unit The State and local government played a minimal role in the selection of the
future land use EPA was considered the main driving force behind the decision Future land use based on residential
land use scenario was based on Region 8 policy, which has been passed down from EPA HQ Cost was an important
factor in the selection of the remedy CSLU was considered on the outskirts of the site
54
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Site 8: Naval Undersea Warfare Center, OU 2 Date of Interview: 7 DEC 95
RPM: Patricia McGrath
Synopsis:
OU 2, Area 8 was the site of plating shop operations that had contaminated the surrounding soil. The remedy for the
site was soil excavation and GW momtonng When the BRAC lists were developed, the facility was chosen for
realignment. There was some concern that the facility would close in the future Due to this uncertainly of the base's
future and to protect the GW in the event that it should be used as a future DW source, a future land use of residential
was chosen The State played a major role in the selection of the remedy and the future land use because of concerns
about the facility's future Cost played a major role in the selection of the remedy Because the GW confining layer
was relatively deep (> ISO feet), GW treatment was not considered appropriate. Removal of the soil causing GW
contamination, and GW monitoring were considered the most cost-effective way to treat the site CSLU was
considered directly next to the site
Site 9: Sharpe Army Depot, OU I Date of Interview: 7 DEC 95
RPM: Richard Seraydanan
Synopsis:
Site was a source control to protect the GW site, which involved only a GW pump and treat remedy Future land use
did not play a significant role in the selection of the remedy The contaminant plume had migrated offsite A future
land use of residential was chosen because the GW was used as a source of DW and because of the off-site property
use Cleanup was to MCLS. The State played a significant role not in the selection of the remedy, but in the treatment
levels from the GW treatment facility
Site 10: Sacramento Army Depot, OU 3 Date of Interview: 7 DEC 95
RPM: Marlon Mezquita (discussion with Richard Seraydanan)
Synopsis:
OU 3 is a tank area where the tanks had leaked and caused soil contamination The remedy for the site was soil vapor
extraction (SVE) The future land use did not play a role in the selection of the remedy SVE was considered the best
remedy for cleaning up the soil, regardless of its land use, based on its implementability The SVE treatment worked
so well and so quickly that the system was used to clean up beyond the human health risk levels that had been
established The cost of the remedy had no impact on the remedy selection
Site 11: Williams AFB, OU 1 Date of Interview: 7 DEC 95
RPM: Ramone Mendoza
Synopsis:
OU I consists of a closed landfill and a series of no action sites The landfill has been capped, and GW monitoring
is in place A human health risk assessment was conducted, and a future land use of residential was chosen because
there were no guarantees that the site would not be used for residential purposes in the future, because the site is being
handed over to the surrounding Native Amencan community. Cost played a factor in the selection of the remedy
Initially, an impermeable cap was proposed, costing millions of dollars A more inexpensive soil cover was chosen
for the selected remedy and implemented. State ARARs were the driving factor in the selection of the GW monitoring
requirements CSLU was based on activities bordering the site
55
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Site 12: Fairchild AFB, OU 1 Date of Interview: 8 DEC 95
RPM: Cami Grandmetti
Synopsis:
OU 1 consists of an old landfill that lies approximately 4 blocks off base TCE contamination from the landfill caused
the local aquifer, a sole source aquifer used as DW, to become contaminated A cap was placed over the landfill, and
a GW containment barrier was constructed Future land use of residential was driven by the MCLs and GW protection
CSLU was evaluated within 1/2 mile of the site
Site 13: New Brighton / Arden Hills, OU 8 Date of Interview: 8 DEC 95
RPM: Tom Baroums
Synopsis:
OU 8 consists of PCB contaminated soil (approximately 1,400 cubic yards) that was removed and incinerated The
site was then capped, and an ISV system installed after the capping At the time the ROD was signed, there was some
concern that the site may have unrestricted access and that it should be cleaned to residential land use standards Both
the Army and EPA concurred on this Since that time, however, there has been a change in the philosophy at the
facility Future land use for the remaining sites at the facility will be considered industrial because of surrounding land
use. The future land use of this site will also probably be industrial
There was no real cost differential in the choice of cleanup to residential versus industrial future land use Cost did
play a role in the remedy selection though, because an intermediate-cost remedy was selected CSLU was considered
to be around the site's perimeter
Site 14: Lonng AFB, OU 2 Date of Interview: 15 DEC 95
RPM: Mike Nalipmski
Synopsis:
Site is a combination of two landfills, one 9 acres, the other 17 acres The future land use for the site will probably be
recreational (snowmobile area), although there are residential and commercial buildings surrounding the site Possible
trailer park could be placed on the fringes of the site The site, however, is not to be cleaned to unrestricted use The
remedy consisted of construction of a RCRA Level C cap to protect the GW GW contamination is being handled in
another ROD Cost was not a factor in the selection of the remedy for this site in that the site would have to be capped,
however, the remedy consists of placing excavated soils from other sites in the landfills This impacted the base-wide
remedy cost, reducing it by $10 million CSLU was considered to be within 1/2 mile of the site
Site 15: Ellsworth AFB, OU 1 Date of Interview: 15 DEC 95
RPM: Peter Ismert
Synopsis:
The site is a fire protection training area The surrounding land use includes residential A developer wants to make
the land directly south of the site residential. This, coupled with future uncertainty about the site, led the RPM to select
a future land use of residential The remedy consists of SVE and GW pump and treat. This remedy is an interim
action, with the final action just being an expansion of the interim action Cost was not a factor in the selection of the
remedy Long-term O&M costs, however, would have been higher if the site had not been remediated and GW
56
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containment had been selected as the remedy The site is being cleaned up to unrestricted use levels This is driven
by the AF and is only true if the land is released from AF custody If the AF continues to maintain the site, the site
would be under restricted use The State ARARs and State soil levels are for petroleum (TPH) cleanup and are being
used to protect the GW to MCLs CSLU was considered to be within I mile of the base
Site 16: Weldon Springs Site Remedial Action Project, OU 1 Date of Interview: 15 DEC 95
RPM: Dan Wall
Synopsis:
Site is a former processing plant and consists of pits, a chemical plant, and wildlife areas The future land use is
anticipated to be only recreational This is the cleanup criteria for the site, however, the cleanup goal of the site is to
test the technological capabilities and limitations of the remedy and clean the site to unrestricted use levels (a
residential scenario). A re-evaluation of the site, the remedy's treatment performance, and the potential risk the site
poses will be conducted after the site has been cleaned A general consensus among the concerned parties on the
residential future land use was considered to be the impetus for such cleanup levels In general, all parties felt a need
for unrestricted use on the site because of uncertainty in the site's future use Cost of the remedies made off-site cleanup
prohibitive So, the site went with the cheapest remedy that would meet the cleanup goals The on-site disposal cell
is still under construction The State played a large role in most aspects of the remedial process CSLU was
considered to be within 3 miles of the site
Site 17: West Virginia Ordnance Works, OU 2 Date of Interview: 18 DEC 95
RPM: Bill Arguto
Synopsis:
Site was formerly used for TNT manufacturing, consisting of a red water acids pond and a yellow water pond The
land was deeded to the State as a wildlife refuge (2,300 of 8,000 acres used by the wildlife) The ponds were capped
and the site cleaned up to residential levels, but the land use is not unrestricted Currently, the remedy consists of GW
pump and treat The construction is nearly complete Capping the site was nsk driven, and the future land use of
residential was used to determine the remedy for the site Initially, a future land use of residential was used to
determine the baseline nsk and the remedy The sites could be used for residential purposes, although industrial was
considered the most prevalent future land use. The GW is also a possible drinking water source The ROD for the
site will have to be amended because the cap is not suitable for such high levels of GW contamination The CSLU was
a conglomeration of what was surrounding the OU and the base
Site IS: Savannah Army Depot Activity, OU 1 Date of Interview: 18 DEC 95
RPM: David Seely
Synopsis:
Site is a TNT washout lagoon with contaminated soils The future land use of residential was chosen based on base closure
uncertainties as well as access to the site if the base were to remain operational This, coupled with an incremental cost
to clean up the soils to residential cleanup levels, drove the remedy selection The remedy for the site is incineration of
the soils and backfilling the lagoons with clean fill This would make the site cleaned to unrestricted levels, however, GW
restrictions would be in place because the GW situation is scheduled to be looked at in the future. Cost played no role in
the selection of the remedy Federal ARARs referred to in the survey stem from the fact that the soils excavated from the
lagoon were considered RCRA hazardous waste and needed to be treated before they could be landfilled CSLU was
57
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difficult to determine because the site is 13,000 acres The CSLU is a combination of operations on surrounding the base
and was considered within 1 mile
Site 19: Idaho National Engineering Lab, OU 18 Date of Interview: 18 DEC 95
RPM: Wayne Pierre
Synopsis:
The site is a contaminated pit used by DOE to treat radioactive waste The future land use Tor the site is considered
residential after 100 years. For the next 100 years, however, the base, the State, and a site-specific advisory board agree
that the site will remain a DOE site Cost played a small role in the selection of the remedy All wastes initially were to
be hauled oiTsite, regardless of cost, however, the remedy at the sue is a technology development project involving a
plasma torch and robotic measures The CSLU was considered around the facility
Site 20: USMC Logistics Base, OU 5 Date of Interview: 17 JAN 96
RPM: Robert Pope
Synopsis:
The site consists of a gnt disposal area and a wastewater treatment plant located at a Marine logistics base A Future land
use of residential was agreed upon by EPA, the State, and the base, but was dnven primarily by the State due to Future
uncertainties as to the site's use A residential Future land use was considered the most protective and the cleanup levels
were easy to attain, because the remedy was excavation was oFF-site disposal. GW was not involved in the cleanup The
impact of cost on the remedy selection was unknown (the ROD was signed prior to the current RPM's involvement)
Cleanup levels were based on a human health risk assessment CSLU was considered next to the site
58
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APPENDIX D
FFSS STUDY METHODOLOGY
59
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60
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METHODOLOGY
INTRODUCTION
This Appendix presents the methodology used to generate the data upon which the conclusions and observations
contained in the body of this report are based
Appendix A contains a copy of the Federal Facilities Superfund Survey (FFSS) form that was sent to the various
regional Remedial Project Manager (RPMS) to obtain information on the 251 Federal Facility Operable Units (OUs) for
which Records of Decision (RODS) had been signed as of June 30, 1995 An additional 17 surveys for OUs not contained
on the mailing list (7 of which had ROD signature dates @r June 30, 1995) were also returned and incorporated into the
study Appendix B provides a listing of the RODs that were included in the FFSS Appendix C is a copy of the
questionnaire used during the follow-up telephone interviews (to be discussed later in this appendix)
As mentioned above, the FFSS form was sent to the regional RPMs to obtain information on 251 Federal Facility
OUs with signed (interim or final) RODS The survey was divided into three sections a general section, a land use and
basis for cleanup section, and a remedy section The general section requested facility-specific information about the OU,
including the number of sites that comprised the OU and the designation for the respective sites The land use and basis
for cleanup section and the remedy section requested site-specific information on the land use and remedies that were
selected at each site RPMs were requested to fill out additional surveys when the land use information for the sites that
made up an OU were different
Prior to sending the FFSS to the regional RPMS, the survey was pretested on an RPM from the U S
Environmental Protection Agency's Region I The pretest was performed to determine the clarity of the questions that were
being posed and the ability of the survey to obtain the desired information Comments and suggestions on how to better
improve the survey were obtained from the pretested RPM and were incorporated into the final version of the survey
The FFSS was conducted during the late summer and fall of 1995 Two hundred and ninety-seven surveys,
detailing information on 245 OUs, and 85 facilities, were returned for analysis The information from the FFSS was placed
into three separate data base files using a Microsoft Access v. 2.0 format. The first data base file (called FED) contained
information from the general section of the FFSS form The second and third data base (lies (called Land Use and
Remedy, respectively) contained the site-specific information on the OU's land use and remedy Each record in the Land
Use and Remedy data bases was given a unique identification number so that the two files could be linked at a later time
for analysis
After the information was input into the data base, 10 percent (29) of the surveys were randomly selected from
the files and were given quality assurance/quality control checks (QA/QC) to determine the amount of error occurring from
data entry Because the questions contained in the land use and basis of cleanup and the remedy sections were those used
for trend analysis, they were the only questions counted in determining the error rate due to data input There were a total
of 29 questions in these two sections, allowing for 841 data enlnes. Fifteen data entry errors were detected during the
QA/QC process, accounting for a I 8 percent error rate Because the error rate due to data entry was less than 5 percent,
a more detailed QA/QC was deemed unnecessary.
Surveys that pertained to petroleum sites not managed under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) or sites with unsigned RODs were removed from the analysis. Six surveys
were removed from the data base on this basis, resulting in a data base containing information on 291 sites
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No Action and No Further Action sites were removed from the data base files and placed in a separate
category. These sites were identified by examining the Remedy data base and searching for those records which
identified No Action or No Further Action as Che selected remedy. Sixty-five No Action or No Further Action sites
were identified.
In an attempt to identify trends that may be occurring among Federal Facilities, the remaining sites were
divided into three subdivisions of categories for analysis: BRAG and Non-BRAC facilities; DOD, DOE, and Other
government agencies; and Source Control for Soils, Source Control for Soils and Ground Water, and Source Control
of Ground Water. BRAC and Non-BRAC facilities were identified readily by answers on the general section of
the questionnaire. DOD, DOE, and Other facilities were identified by using information from CERCLJS data base.
The third grouping (Source Control for Soils, Source Control for Soils and Ground Water, and Source
Control for Ground Water) was divided by examining answers to Questions 13, 14, and 15 of the Remedy section
of the questionnaire. Those sites that answered interim or final source control for soil/surface cleanup (Question
13) and did not answer interim or final source control to protect the ground water {Question 14) and did not answer
interim or final ground-water remediation (Question 15), were placed in the Source Control for Soils category.
Those sites that answered interim or final for Questions 14 and/or 15 and did not answer interim or final Tor
Question 13 were placed in the Source Control for Ground Water category. Those sites that answered interim or
final to Question 13 and interim or final for Questions 14 and/or 15 were placed in Source Control for Soils and
Ground Water group.
A fourth grouping, Ground-water Treatment Only sites, was also identified. These sites were identified
by examining the remedy selected and the media addressed questions in (he remedy and land use sections of the
questionnaire. Ground-water Treatment Only sites were identified as sites where 'Ground Water" was the only
medium addressed or of concern, and where the site remedy selected or considered only involved "Ground Water -
Pump and Treat,* 'Ground Water - Pump and Discharge,* 'Ground Water - Biological Treatment,' 'Ground
Water - Chemical Treatment,' Ground Water - Natural Attenuation,' "Ground Water - Containment,* or Ground
Water - Engineering Controls." Because these sites involved only ground-water treatment, and did not involve a
form of source control (i.e., soil removal or treatment), one would not expect a relationship between land use and
the remedy selection. Therefore, these sites were removed for hind use analysis, but were retained for remedy
analysis. Sixty-one sites were removed from land use analysis because they were identified as Ground-water
Treatment Only sites.
Profiles of the category breakdowns for land use analysis and for remedy analysis are provided below.
Table 1. Category Breakdowns
Category
BRAC
Non-BRAC
DOD
DOE
Other
Number of Sites
Land Use Analysis
53
112
109
42
14
Number of Sites
Remedy Analysis
68
158
159
51
16
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Table 1 (continued)
Category
Source Control for Soils
Source Control for Ground Water
Ground-water Remediation
Ground-water Treatment Only
Number of Sites
Land Use Analysis
44
103
IS
Number of Sites
Remedy Analysis
44
103
IS
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LAND USE AND BASIS FOR CLEANUP SECTION METHODOLOGY
The land use and basis for cleanup section of the FFSS attempted to determine the specific nature of the
land use decisions that were being made at Federal Facility sites. The section focused questions on: media/materials
addressed at the site; media/materials of concern at the site; the current, current surrounding, and future land uses
at the site; the basis for cleanup at the site; factors that influenced the future land use decision at the site; and the
presumed future use of a site.
Land Use. Four categories of land use were captured in the analysis: the current land use of the site;
the current surrounding land use at a site; the future land use for a site considered in the baseline risk assessment;
and the future land use for a site on which the protectiveness of the remedy is based. Again, if an OU consisted
of more than one site, and the land use data were different for these sites, RPMs were asked to fill out a form for
each site.
Because multiple land uses were frequently reported, a hierarchy of land uses was created that established
how the findings were grouped. The hierarchy was: residential, educational, military, commercial, industrial,
recreational, landfill, agricultural, other, open space/nature preserve, vacant, and do not know.
To simplify matters further, these land uses were then grouped into five categories: residential, military,
industrial, other, and do not know. The breakdown of the categories was as follows:
• Residential category included residential land use and educational land use;
• Military category included military land use;
• Industrial category included commercial and industrial land uses;
• Other category included the recreational, landfill, agricultural, other, open space/nature preserve, and
vacant land uses; and
• Do not know category included the do not know land use.
State and regional land use analyses were performed by using the facility's CERCLJS number and by using
regional information contained in the general section of the survey.
Basis for Cleanup. The Basis for Cleanup portion of the survey asked the RPM to identify, in order
of significance, the basis for cleanup at the site, whether it be the risk assessment, maximum contaminant levels
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(MCLs), Federal or State ARARS, or other influences When RPMs provided multiple answers, but did not rank
them in order of significance, a ranking of 1 was given to all choices selected
Raw counts were tallied for the basis of cleanup answers, which were ranked as a 1, 2, or 3 The raw counts were
then grouped into six categories health risk assessment, MCLS, State ARARS, future user concerns, ecological nsk
assessment, and other The breakdown of the categories was as follows-
D Health nsk assessment included human health quantitative and qualitative nsk assessments If a site had both
answers m the top three rankings, the health nsk assessment category was only counted once to prevent double-
counting
0 D MCLs included MCLs and maximum contaminant level goals (MCLGs)
0 State ARARs included State ARARS, as well as looking at the breakdown of the State ARAR, whether it be a
State MCL, a State soil level, or some other form of State ground-water requirement
0 D Future user concerns included future user concerns.
D Ecological risk assessment included ecological nsk assessment
D Other included all Federal and State to be considered (TBCs), Federal ARARS, State or local government
comments, citizen comments, or other concerns
REMEDY SECTION METHODOLOGY
The remedy section of the FFSS was designed to elicit information about the remedies considered and
implemented at the site This section asked questions about cleanup levels, remedies considered and selected, remedy
cost, O&M data, the principal cost driver of the cleanup, and other miscellaneous information about the remedy (e g , risk
assessments performed, dense nonaqueous phase liquids (DNAPL) status, drinking water considerations, etc )
Raw counts were tallied for the information from this section Remedial trends that may have occurred for sites
with the same type of future land use were also examined As mentioned earlier, unique identification numbers were used
to link information in the land use data base with information about the remedies for these sites Trends in future land use
versus cleanup levels, future land use versus cost, and future land use versus cost drivers were all analyzed
Cost analysis was also performed on a remedy basis Sites were categorized into one of four remedial action
groups sites with active ground-water treatment remedies (e g , pump and treat, pump and discharge, biological treatment,
and chemical treatment), sites with passive ground-water treatment remedies (e g , natural attenuation, containment, and
engineering controls), sites that only treated soil or surface waste, and No Action RODS Cost analyses included
determining the minimum and maximum of the estimated cost range of the remedies considered, as well as the minimum,
maximum, and average costs for the remedies chosen Remedy costs with zero values were removed when determining
the minimum and average values for the estimated cost range of the remedies considered and the cost of the remedy chosen
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FOLLOW-UP TELEPHONE INTERVIEWS
Because of conflicting answers in a number of surveys and in an effort to better understand the logic that RPMs
were using when filling out the FFSS, 20 sites of the surveys with a future land use of residential were chosen for follow-up
telephone interviews Sites were chosen randomly, but reflected the number of surveys received by region and the number
of sites with ground-water contamination. The questionnaire used during the follow-up interviews is contained in
Appendix C
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APPENDIX E
COST EFFECTS OF LAND USE ASSUMPTIONS
(This paper was prepared under
EPA Contract No. 68-D3-0013, Task 10)
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COST EFFECTS OF LAND USE ASSUMPTIONS
OVERVIEW
A methodology has been developed for estimating the possible cost reduction benefits of increased soil cleanup
levels as would be possible by using an industrial land use scenario These increased cleanup levels could, presumably,
result from alternative exposure assumptions (i e, industrial versus residential) The cost savings resulting from increasing
cleanup levels is equal to the sum of the savings resulting from treating a reduced volume plus the potential cost reduction
associated with achieving a less stringent treatment standard
Changes in unit cost arc beyond the scope of the approach described here. The several factors that could
affect the unit cost of treatment (including disposal) arc discussed briefly below under Other Cost Reduction
Issues.
The methodology, therefore, is intended to illustrate possible soil volume reduction benefits associated with
increasing cleanup levels Obviously, for any given site where contaminant distribution has been determined, the actual
volume reduction can be calculated. For a hypothetical site or to arrive at an estimate of reductions at an actual site without
a detailed analysis, however, contaminant distribution must be assumed
ASSUMPTIONS
D Contaminated soils comprise one contiguous area with the maximum contamination at the center and decreasing
to the cleanup level at the perimeter For ease of calculation, the shape of the contaminated soil area is assumed
to be a circle of unit thickness The result of increasing the cleanup level, then, is to reduce the size of the circle
The band between the circle representing the higher (industrial exposure) represents the area or volume
reduction
D The distribution of contamination from a maximum at the center of the circle to the cleanup level at the perimeter
was assumed to take two different shapes for the purposes of comparison, linear and logarithmic These types
of distribution seem logical if contamination was deposited at the center of the site and migrated by natural means
over time.
Assumptions were tested for hypothetical site situations to evaluate the effect of size of site, ratio of maximum
contamination to cleanup level, and distribution of contamination Those analyses illustrated that the assumptions related
to distribution of contamination had a significant impact on the result (It may be possible, however, to make reasonable
contaminant distribution assumptions with minimal site information, i e, site history, contaminants of concern)
Based on the methodology described above, Figure 1 is a curve representing percent volume reduction versus
increased cleanup levels represented as multiples of the original cleanup level if the contaminant level decreases
logarithmically from the center. Figure 2 is the same plot for a linear or straight line contaminant level decrease It is
readily apparent that contaminant distribution has a significant effect on the volume reduction achievable from increased
cleanup levels For the logarithmic distribution, a five times increase results in a 70 percent reduction, for the linear case,
it results in only an 18 percent reduction The logarithmic case can be considered representative of sites with a large area
of contamination only slightly above the cleanup level The linear distribution may be appropriate for a site where
contamination decreases quickly to zero from the maximum value.
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80
C
0
O
13
60
CD
or
CD
°'l
"5
xO
o^
40
20
0
Soil Volume Reduction from Increased Cleanup Levels
Linear Contaminant Distribution
Industrial
Carcinogen
Industrial
Non-carcinogen
0
5 10 15 20
Multiples of Residential Cleanup Level
25
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120
g
"t
100
CD
oc
2
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RISK SCENARIOS
Residential versus Industrial The general form of the equation for carcinogenic risk or a noncarcmogenic hazard
quotient as described in Risk Assessment Guidance Tor Superfund (RAGS) is usually used to calculate cleanup levels
If only the ingesuon pathway is assumed, which is not uncommon for surface soil cleanups, the ratio of cleanup levels for
residential versus industrial scenarios is equal to the ratio of soils ingested under each scenario. Using the standard
assumptions, this ratio is 4 47 for carcinogens and 12.76 for noncarcmogens These multiples are identified on Figures
I and 2 to illustrate the impact of choice of land use If only the ingestion pathway is considered, these ratios apply,
regardless of chemical or site conditions If, however, an inhalation pathway is also considered, the ratio would be
chemical-specific because the equation would become a polynomial with two independent dose-response relationships
Range of Risk The acceptable nsk range for Superfund remediation, from the National Contingency Plan, is
\Q'4 to 10"6 Figures 1 and 2 assumed a 10"* nsk for residential as well as industrial scenarios, however, the impact of
increasing the nsk level is obvious from these figures For example, 10'5 nsk is 10 times the action level calculated at 1O"6
and IQ-'is 100 times
OTHER COST REDUCTION ISSUES
In order to evaluate the total effect on cost of increased cleanup levels, other factors must be evaluated that could
have the effect of reducing or conversely increasing cost reduction benefits
1 Reducing the volume to be treated or disposed will increase the unit cost, because many costs are fixed (e g ,
design or mobilization) This will reduce the cost reduction benefit.
2 An increased cleanup level may allow the use of an alternative less-costly technology or reduce the cost of
the application of a technology, thereby increasing the cost benefit of volume reduction Altered unit cost
can be applied to adjusted volumes to obtain the additional cost savings attributable to the different
technology
3 If the waste is RCRA listed waste, treatment levels based on best demonstrated available technology (BOAT)
may be well below cleanup levels, thereby negating any possible treatment cost benefits These off-sets to
cost reduction are outside the scope of this methodology
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