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2 Magnitude of the Problem This chapter focuses on the first topic of the Committee’s statement of task: assessing the size of the groundwater contamination problem caused by residual subsurface contaminants. Specifically, in this chapter the Com- mittee strives to answer three primary questions: (1) at how many sites does residual contamination remain such that site closure is not yet possible, (2) at what percentage of these sites does residual contamination in ground- water threaten public water systems,1 and (3) what are the projected costs for reaching site closure or for long-term management? To answer these questions, the Committee gathered information on the major federal and state regulatory programs under which hazardous waste is cleaned up to determine the size and scope of these programs and relevant trends over time. The chapter also includes a discussion on “closed” sites (the mean- ing of which varies by program), because such sites may contain residual contamination at levels exceeding those allowing for unlimited use and unrestricted exposure (UU/UE). NUMBER OF U.S. HAZARDOUS WASTE SITES The Committee sought the following types of information to assess the magnitude of the nation’s hazardous waste problem: 1 The Safe Drinking Water Act defines public water systems as consisting of community water supply systems; transient, non-community water supply systems; and non-transient, non-community water supply systems—all of which can range in size from those that serve as few as 25 people to those that serve several million. 37
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38 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES • Number of sites characterized by progress through the major phases of remediation from site discovery to site closure, as outlined in Table 1-1, • Principal chemicals of concern, and • Status of “closed” sites with respect to the potential presence of residual contamination. At a national level, information was gathered from the U.S. Environmental Protection Agency (EPA) for sites that fall under the Comprehensive En- vironmental Response, Compensation, and Liability Act (CERCLA), Re- source Conservation and Recovery Act (RCRA), or Underground Storage Tank (UST) programs using publicly available databases and via conversa- tions with EPA program officers. Department of Defense (DoD) sites were explored with the aid of the online Annual Reports to Congress and via conversations with DoD staff. Information from the Department of Energy (DOE) and other federal agencies was collected from published literature. Another large group of sites includes those that fall under state purview, such as state Superfund, voluntary cleanup programs, Brownfields, and some dry cleaning sites. Information about such sites was gathered from a variety of sources, including state websites and databases, third-party web- sites, published literature, and conversations with state program managers. The numbers in this chapter reflect the Committee’s best efforts to com- pile available data on the magnitude of the problem, but there is significant uncertainty associated with some of the data. First, some of the reported data reflect detailed analyses (e.g., DoD, CERCLA, RCRA) while other data are only estimates. Second, there are differences in accounting across the programs that make it difficult to assess the magnitude of the hazardous waste problem on a consistent basis. In particular, CERCLA and RCRA’s best available data are for facilities that could and often do contain many individual contaminated sites. To make matters even more confusing, the term “site” is used by the CERCLA and RCRA programs to mean an entire facility, while other programs use the term “site” to represent an individual contaminant release within a larger facility. In this report the term “site” refers to an individual area of contamination within a facility; to avoid confusion, the term “Superfund site” is not used when referring to a facility on the Superfund list. Finally, the statement of task requests information on the numbers of sites that have yet to reach “site closure”—a term that is defined differently by each of the large federal cleanup programs as well as by state agencies. Considering these sources of uncertainty (estimates vs. real data, sum- ming of facilities and individual sites, and the varying definitions of site closure), the overall total should be considered as a rough idea of the magnitude of the problem. Though it can be argued that there is limited
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MAGNITUDE OF THE PROBLEM 39 utility in tallying the numbers of sites given these sources of uncertainty, this is done at the end of the chapter to provide the reader with an order- of-magnitude estimate of the size of the country’s burden for cleanup of hazardous waste sites. Department of Defense The DoD environmental remediation program, measured by the num- ber of facilities, is the largest such program in the United States, and perhaps the world. In budgetary terms, it is only exceeded by the U.S. Department of Energy’s Environmental Management Program. The Installation Restora- tion Program (IRP), which addresses toxic and radioactive wastes as well as building demolition and debris removal, is responsible for 3,486 installa- tions containing over 29,000 contaminated sites at active, Base Relocation and Closure (BRAC), and Formerly Used Defense Site (FUDS) properties (see Table 2-1). The Military Munitions Response Program, which focuses on unexploded ordnance and discarded military munitions, is beyond the scope of this report and is not discussed further here, although its future expenses are greater than those anticipated for the IRP. Additionally, DoD has responsibility for sites that are not included in the IRP totals, including 67 properties (primarily private waste disposal sites) in 31 states (OUSD, 2011). In total, the DoD has 141 installations that have been listed on the TABLE 2-1 DoD Installation Restoration Program Installations, Sites, Expenses to Date, and Cost to Completea Costs Through Cost to Number of Number FY10 Complete IRP Installations of Sites (1000s) (1000s) Active 1,622 21,528 $19,693,452 $7,230,071 Base Realignment and 228 5,127 $8,085,265 $2,706,374 Closure(BRAC) Formerly Used 1,636 2,921 $3,136,362 $2,820,145 Defense Site (FUDS) Total 3,486 29,576 $30,915,079b $12,756,590 a According to the DERP Annual Report to Congress for FY 2010, the cost to complete (CTC) is derived from site-level funding information and can be impacted by prioritization, input from regulators and other stakeholders, the complexity of the cleanup, and the technologies that are available and chosen (DoD, 2012). The cost numbers are not adjusted for inflation. b An additional $97.9 million was spent on remediation of sites not included in the Installation Restoration Program through 2010 (OUSD, 2011, p. E9-1). SOURCE: OUSD (2011).
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40 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES FIGURE 2-1 DoD CERCLA environmental restoration phases and milestones. SOURCE: Adapted from OUSD (2011). Figure 2-1 Bitmapped National Priorities List (NPL) because they contain at least one very con- taminated site, thus qualifying the entire installation for the NPL. The phases and milestones used by the DoD to measure progress are shown in Figure 2-1. The DoD has established a performance goal for ac- tive and BRAC installations to achieve either the remedy-in-place or the response-complete milestone by 2014.2 FUDS are supposed to achieve those milestones by 2020. As shown in Table 2-2, 79 percent of Installa- tion Restoration Program sites have met that goal as of FY 2010. While impressive, these numbers should not be taken to imply that the remaining sites will be remediated at the same pace. This is because the bulk of the response-complete sites to date have been “low-hanging fruit,” completed with little remediation activity. Indeed, at least 62 percent of the Installation Restoration Program sites that have achieved response complete (14,302 sites) did so without reporting a remedy in place (Deborah Morefield, DoD, personal communication, January 2011). Furthermore, in July 2011 DoD established more demanding goals based upon moving sites from remedy in place to response complete (Conger, 2011), such that success has been redefined within the agency to mean that 95 percent of Installation Restora- tion Program sites must achieve response complete by 2021. The Defense Department’s task is formidable because the remaining 2 2015 for Legacy BRAC sites.
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MAGNITUDE OF THE PROBLEM 41 site portfolio consists primarily of the largest and most complex sites, such as groundwater plumes containing difficult-to-remediate substances such as chlorinated solvents that can be present in the subsurface as dense nonaqueous phase liquids (DNAPLs). In the Committee’s experience, these account for many of the 1,933 Installation Restoration Program sites where remedies are in place but which have not achieved response complete (Table 2-2), as well as many of the sites still undergoing study. DoD counts nearly 1,400 sites in the Long-Term Management phase, when the active response is complete, but where residual contamination remains above levels allow- ing for UU/UE. These sites may be subject to land use restrictions, periodic reviews, monitoring, and/or maintenance. Thus, the known number of DoD Installation Restoration Program sites with residual contamination in place is 4,329 (2,931 + 1,398). (Sites with a remedy in place or which are response complete are not included in this total because it would be impossible to know whether they contain residual contamination without considering each site.) A snapshot of the DoD’s contaminated sites is provided by a 2006 survey of occurrence data of hazardous contaminants at 440 installations for which the armed services had electronic records (Hunter, 2006). These installations accounted for about two-thirds of the total Installation Resto- ration Program’s sites. The researchers reported that trichloroethene (TCE) has been found in groundwater at concentrations above the preliminary re- mediation goal at 69 percent of those installations. Another volatile solvent, tetrachloroethene (PCE), was found above its preliminary remediation goal at 57 percent of the 440 installations. Naphthalene, a key component of jet fuel, was found above its preliminary remediation goal at 48 percent of the installations. They also reported the widespread presence of toxic met- als such as lead, arsenic, and nickel at high levels, but noted that most of those concentrations were consistent with naturally occurring background concentrations. TABLE 2-2 DoD Installation Restoration Program Sites by Select Cleanup Phases or Milestones (see Figure 2-1) Cleanup Long-Term Planned or Remedy Response Management IRP Under Way in Place Complete Under Way Active 2,083 1,530 17,053 905 BRAC 529 396 4,065 403 FUDS 319 7 2,110 50 Total 2,931 1,933 23,228 1,398 NOTE: Remedy in Place is a subset of Cleanup Planned or Under Way and Long-Term Man- agement Under Way is a subset of Response Complete. SOURCE: OUSD (2011).
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42 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES CERCLA The CERCLA program was established to address hazardous sub- stances at abandoned or uncontrolled hazardous waste sites. Through the CERCLA program, the EPA has developed the National Priorities List (NPL), which is periodically updated to reflect facilities with the highest priority hazardous waste sites.3 The remedial actions at most nongovern- mental CERCLA facilities are implemented by potentially responsible par- ties (PRPs) through legally enforceable administrative orders or settlement agreements, with EPA being the main agency responsible for enforcing the program. Where there are no viable nongovernmental PRPs, EPA performs the remediation pursuant to federal funds (i.e., the so-called Superfund, a term that has come to define the entire program). At governmental facili- ties, other federal agencies such as the DoD and DOE are responsible for cleaning up their sites in accordance with CERCLA requirements. States can also take the lead in determining remedial alternatives and contracting for the design and remediation of a site. Table 2-3 shows the phases of the CERCLA program, including the major milestones. There are 1,723 facilities that have been on the NPL, including 59 that have been proposed by the EPA and are currently awaiting final agency ac- tion. Table 2-4 below shows a breakdown of these by status and milestone. As of June 2012, 359 of the 1,723 facilities have been “deleted” from the NPL, which means the EPA has determined that no further response is required to protect human health or the environment; 1,364 remain on the NPL. About 80 of those deleted facilities had contaminated groundwater and were evaluated more extensively by the Committee (see later section on closed sites and Appendix C). Facilities that have been deleted from the NPL are eligible for future Superfund-financed remedial action in the event of future conditions warranting the action. To provide some temporal perspective on these numbers, in 2004 there were 1,244 NPL facilities. At that time, 274 had been deleted from the NPL or referred for response to another authority. Statistics from EPA (2004) illustrate the typical complexity of haz- ardous waste sites at facilities on the NPL. Volatile organic compounds (VOCs) are present at 78 percent of NPL facilities, metals at 77 percent, and semivolatile organic compounds (SVOCs) at 71 percent. All three contaminant groups are found at 52 percent of NPL facilities, and two of the groups at 76 percent of facilities (but not necessarily in the same ma- trix, i.e., soil, groundwater, sediment). In 1993, EPA (1993) reported that 3 See http://www.epa.gov/superfund/programs/npl_hrs/nplon.htm for a description of how facilities are placed on the NPL. Note that CERCLA refers to facilities/installations as “sites” and smaller units within those facilities as “operable units”—terminology which is not used in this report unless an EPA CERCLA source is being cited, like Tables 2-3 and 2-4.
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MAGNITUDE OF THE PROBLEM 43 TABLE 2-3 Definition of CERCLA Milestones PA/SI Preliminary Assessment/Site Inspection Investigations of site conditions. If the release of hazardous substances requires immediate or short-term response actions, these are addressed under the Emergency Response program of CERCLA. NPL Listing National Priorities List (NPL) Site Listing Process A list of the most serious sites identified for possible long-term cleanup. RI/FS Remedial Investigation/Feasibility Study Determines the nature and extent of contamination. Assesses the treatability of site contamination and evaluates the potential performance and cost of treatment technologies. ROD Records of Decision Explains which cleanup alternatives will be used at a given NPL facility. When remedies exceed $25 million, they are reviewed by the National Remedy Review Board. RD/RA Remedial Design/Remedial Action Preparation and implementation of plans and specifications for applying site remedies. The bulk of the cleanup usually occurs during this phase. Construction Construction Completion Completion Identifies completion of physical cleanup construction, although this does not necessarily indicate whether final cleanup levels have been achieved. Post Construction Post Construction Completion Completion Ensures that CERCLA response actions provide for the long- term protection of human health and the environment. Included here are long-term response actions, operation and maintenance, institutional controls, five-year reviews, and remedy optimization. NPL Deletion National Priorities List Deletion Removes a site from the NPL once all response actions are complete and all cleanup goals have been achieved. Reuse Site Reuse/Redevelopment Information on how the CERCLA program is working with communities and other partners to return hazardous waste sites to safe and productive use without adversely affecting the remedy. SOURCE: Adapted from http://www.epa.gov/superfund/cleanup/index.htm. DNAPLs, which commonly include TCE and PCE, were observed directly in the subsurface at 44 of 712 NPL facilities examined. EPA (1993) also concluded that approximately 60 percent of NPL facilities at that time (1991) exhibited a medium-to-high likelihood of having DNAPL present as a source of subsurface contamination. Of the facilities on the NPL as of
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44 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES TABLE 2-4 National Priority List Site Status Status Non-Federal Federal Total Proposed Sites 55 4 59 Final Sites 1,147 158 1,305 Deleted Sites 344 15 359 Total 1,546 177 1,723 Milestonesa Non-Federal Federal Total Partial Deletionsb 40 17 57 Construction Completionsc 1,053 70 1,123 a Sites that have achieved these milestones are included in one of the three NPL status cat- egories (i.e., proposed, final, deleted). b Partial deletion reflects the deletion from the NPL of specific operable units within a larger CERCLA facility. The EPA recognizes partial deletions to “communicate the completion of successful partial cleanups” and “help promote the economic redevelopment of Superfund sites” (60 FR 55466). c “Construction completions” indicates completion of the physical construction of the rem- edy, although this does not necessarily indicate whether final remedial objectives have been achieved. SOURCE: Modified from EPA’s list of NPL Site Totals by Status and Milestone, as of June 1, 2012. http://www.epa.gov/superfund/sites/query/queryhtm/npltotal.htm 2004, 83 percent require remediation of groundwater, 78 percent soil, 32 percent sediment, and 11 percent sludge (EPA, 2004). CERCLA uses additional metrics than those in Tables 2-3 and 2-4 to describe the program’s progress. According to the Superfund National Ac- complishments Summary Fiscal Year 2010 (http://www.epa.gov/superfund/ accomp/numbers10.html), the program has controlled potential or actual exposure risk to humans at 1,338 NPL facilities and has controlled the mi- gration of contaminated groundwater at 1,030 NPL facilities. At 66 NPL facilities all long-term protections necessary for anticipated use, including institutional controls, are in place and 475 facilities are classified as ready for anticipated reuse. RCRA Corrective Action Program Among other objectives, the Resource Conservation and Recovery Act (RCRA) governs the management of hazardous wastes at operating facilities that handle or handled hazardous waste. RCRA assigns the facil- ity owners and operators the responsibility for corrective action, and it delegates oversight authority to the states (for those states that the EPA has authorized to implement the program). Because the RCRA program also
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MAGNITUDE OF THE PROBLEM 45 TABLE 2-5 Universe of RCRA Facilities RCRA Milestone Number of Facilities CA 725 - Current Human Exposures Under Control 2,821 CA 750 - Groundwater Releases Controlled 2,465 CA 550 - Remedy Constructed 1,506 CA 900 - Corrective Action Performance Standards Attained 903 (Controls Required or No Controls Necessary) or CA 999 - Corrective Action Process Terminateda a CA 900 is the newer RCRA metric for corrective action complete. It is a voluntary report- ing element, however, and not all EPA regions are using this metric at this time. CA 999 was used by some EPA regions in the past, but with differing definitions. This, too, was voluntary and has not been used for all facilities that meet its criteria. The cumulative number of CA 900 and CA 999 is 903. SOURCE: Sara Rasmussen, EPA RCRA Office, personal communication, August 11, 2011 and September 7, 2011. CA denotes “corrective action.” governs waste generation and management, remediation to unlimited use and unrestricted exposure is not necessarily the focus as it is in CERCLA (although remediation under RCRA corrective action or CERCLA will substantively satisfy the requirements of both programs [EPA, 1996a]). Furthermore, RCRA remedies are not statutorily bound to comply with the nine criteria of the National Contingency Plan. Rather, EPA has emphasized the need to protect human health and the environment by dealing expedi- tiously with those sites that present the greatest risks. Beginning in the late 1990s, the program emphasized achievement of two interim milestones: (1) the human exposures environmental indicator “ensures that people near a particular site are not exposed to unacceptable levels of contaminants,” and (2) the groundwater environmental indica- tor “ensures that contaminated groundwater does not spread and further contaminate groundwater resources.”4 These indicators have now been satisfied at most of the highest-priority sites (see Table 2-5). Note that the points of compliance where cleanup objectives must be met at operating RCRA facilities may be defined by the property boundaries. The program has recently expanded its focus to include implementing more permanent solutions, and has created the milestone of final remedy construction, which is similar to the CERCLA milestone construction complete. Although tens of thousands of waste handlers are potentially subject to RCRA, currently EPA has authority to impose corrective action on 3,747 4 See also http://www.epa.gov/epawaste/hazard/correctiveaction/programs.htm.
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46 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES RCRA hazardous waste facilities in the United States (deemed the “2020 Universe”).5 Federal facilities (primarily DoD or DOE) represent 5 percent of the 2020 Universe. The 2020 Universe contains a wide variety of facili- ties, including heavily contaminated properties yet to be cleaned up, others that have been cleaned up, and some that have not been fully investigated yet and may require little or no remediation. Multiple hazardous waste sites, designated as solid waste management units (SWMUs), may exist inside RCRA facilities, but numbers of SWMUs are not compiled by EPA headquarters. Table 2-5 presents the national accomplishments and status of these facilities as of August 11, 2011. In terms of the number that have reached “closure,” 903 RCRA facilities are categorized as either “Corrective Action Performance Standards Attained (Controls Required or No Controls Nec- essary) or “Corrective Action Process Terminated,” leaving 2,844 needing additional remediation efforts. Underground Storage Tank Program In 1984, Congress recognized the unique and widespread problem posed by leaking underground storage tanks by adding Subtitle I to RCRA. This led to the creation of EPA’s Office of Underground Storage Tanks (OUST) and the development and implementation of a regulatory program for UST systems. UST contaminants are typically light nonaqueous phase liquids (LNAPLs) such as petroleum hydrocarbons and fuel additives. Re- sponsibility for the UST program has been delegated to the states (or even local oversight agencies such as a county or a water utility with basin management programs), which set specific cleanup standards and approve specific corrective action plans and the application of particular technolo- gies at sites. This is true even for petroleum-only USTs on military bases, a few of which have hundreds of such tanks. At the end of 2011, there were 590,104 active tanks in the UST pro- gram (EPA, 2011a). Active tanks are registered with the state subject to the Subtitle I regulations, but they do not necessarily have releases. Currently, there are 87,983 leaking tanks that have contaminated surrounding soil and groundwater, the so-called “backlog.” The backlog number represents the cumulative number of confirmed releases (501,723) minus the cumulative number of completed cleanups (413,740). Since the mid-1990s the number of open releases has been declining, yet the pace at which the EPA cleans up the backlog has also slowed (EPA, 2009a). In a study of unaddressed con- firmed releases from USTs in 14 states, EPA (2011b) reported that almost 5 See http://www.epa.gov/osw/hazard/correctiveaction/ facility/index.htm#2020.
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MAGNITUDE OF THE PROBLEM 47 half the releases in the backlog are over 15 years old, and that 78 percent of the releases in the backlog have groundwater contamination. Department of Energy The DOE faces the task of cleaning up the legacy of environmental contamination from activities to develop nuclear weapons during World War II and the Cold War. Contaminants include short-lived and long-lived radioactive wastes, toxic substances such as chlorinated solvents, “mixed wastes” that include both toxic substances and radionuclides, and, at a handful of facilities, unexploded ordnance. Much like the military, a given DOE facility or installation will tend to have multiple sites where con- taminants may have been spilled, disposed of, or abandoned that can be variously regulated by CERCLA, RCRA, or the UST program. The DOE Environmental Management program, established in 1989 to address sev- eral decades of nuclear weapons production, “is the largest in the world, originally involving two million acres at 107 sites in 35 states and some of the most dangerous materials known to man” (DOE, 2012a). Since 1989, DOE has also operated an office to develop scientific and technological advancements to meet environmental management challenges, called the Office of Engineering and Technology. In 2003, the Office of Legacy Man- agement was established to focus on long-term care of legacy liabilities from former nuclear production areas following cleanup at each site. Given that major DOE sites tend to be more challenging than typical DoD sites, it is not surprising that the scope of future remediation is sub- stantial (NRC, 2009). Furthermore, because many DOE sites date back 50 years, contaminants have diffused into the subsurface matrix, considerably complicating remediation. Several previous NRC reports have summarized the nature and extent of contamination at DOE sites (for example, NRC, 1999). There are examples of success stories, such as the 2005 decommis- sioning of the Rocky Flats Site, arguably once the nation’s most highly contaminated plutonium site. DOE’s Environmental Management has historically been responsible for restoration at 134 installations that have about 10,000 release sites, although 21 installations were transferred to the U.S. Army Corps of En- gineers in 2004 and one installation was added in 2001 (EPA, 2004). EPA (2004) reported that DOE had completed active remediation at about half of its release sites, leaving about 5,000 sites where cleanup had not been completed. More recent reports suggest that about 7,000 individual release sites out of 10,645 historical release sites have been “completed,” which means at least that a remedy is in place (DOE, 2011, pp. 52 ff), leaving approximately 3,650 sites remaining. In 2004, DOE estimated that almost all installations would require long-term stewardship (EPA, 2004).
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64 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES where groundwater was contaminated. This review revealed that these sites vary widely in the extent to which they contain contaminant levels that are actually higher than MCLs or other levels that would allow for unlimited use and unrestricted exposure. The Committee found that there was no publicly available mechanism for tracking these sites subsequent to closure, nor do the federal programs maintain a central repository of information about their closed sites (except for NPL-delisted facilities). Thus, little quan- titative data or information are available to assess such sites. It is clear that the definition of site closure varies from program to program, such that a site closed under one program would not necessar- ily be closed under another, even for the same type of waste site. Perhaps the most prominent example of this is the way that the states have defined site closure for underground storage tanks. Cleanup goals for tanks have often been expressed as removal of contaminants “to the maximum extent practicable,” which, as discussed earlier in the context of UST remediation, can be interpreted many different ways—from no interpretation at all to a maximum allowable LNAPL thickness in a monitoring well (e.g., sheen or 1/8-inch thickness). The ITRC’s recent survey of state UST programs (ITRC, 2009) revealed that many states rely solely on best professional judgment of maximum extent practicable (which would obviously vary from site to site within the state), while a few others are starting to consider site-specific risk. Still other states close USTs when contaminant levels are no longer “detectable.” The potential for misunderstanding in the labeling of sites as “suc- cesses” is illustrated by an EPA (2009c) review of 13 DNAPL sites—some CERCLA, one RCRA, and some state sites. These sites were chosen be- cause they are examples of where source reduction has contributed to a site meeting remedial objectives (such as groundwater MCLs). However, closer inspection of the 13 sites by this Committee revealed that five of the sites reported only soil contamination and thus the Committee could not determine if they were examples of the more intractable problems found at groundwater sites. Of the remaining eight sites with contaminated ground- water, EPA’s report states that only three sites were “able to achieve MCLs onsite” although two others achieved MCLs at an offsite point of compli- ance [see EPA (2009c), Table D-1 in Appendix D]. This Committee conducted a more in-depth analysis of 80 Superfund facilities (identified by EPA personnel) that had groundwater contamination that were eventually deleted from the NPL. For each of the 80, the Com- mittee analyzed five-year review reports, site closure documents, RODs, and fact sheets produced by EPA; the full analysis can be found in Appendix C. Sixty percent were industrial facilities, 22 percent were landfills, and the rest were potable well fields, military bases, or other facility types. As would be expected of complex Superfund facilities, almost all of the 80 had
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MAGNITUDE OF THE PROBLEM 65 groundwater contaminated by VOCs, SVOCs, metals, or some combina- tion thereof. The Committee first determined what the remedial action objectives were for each delisted NPL facility. Of the 80, 45 had remedial objectives that specified a contaminant concentration goal for groundwater, either MCLs or some other level. For seven, the stated objectives involved some other specific metric (such as prevention of contaminated groundwater migration, exposure prevention, etc.). Finally, 28 had no explicitly stated objective other than the goal of “protecting human health and the environ- ment.” This broad goal statement was most typical of NPL facilities delisted early in the program; indeed, for many of these early delisted facilities a later ROD amendment, consent decree, or five-year review report appears to establish that there were numeric concentration goals for groundwater. For the Committee’s subsequent analysis (see below), for any facility where groundwater contaminant concentrations were compared to MCLs in five- year review reports, the facilities were categorized as either meeting or not meeting MCLs, even if this was not an original goal of the ROD. The primary objective of the Committee’s analysis was to determine the extent to which the 80 delisted facilities had actually met MCLs in ground- water. According to information that could be easily gleaned from EPA’s CERCLIS database, 37 of the 80 reported achieving MCLs prior to deleting the facility from the NPL (see Figure 2-6). Of this subgroup, 14 achieved MCLs after some length of time operating an active remedy (like pump and MCL Characterization Not a Groundwater Site 5 MCLs Achieved: MCL Achievement Unknown 14 Active Remedy, No LTM 6 Remedial Objective other than Meeting MCLs (such as TI zone, pathway interruption like MCLs Achieved: containment or provision of 4 Active Remedy, LTM 12 alternative drinking water supply, prevent migration of contamination offsite or to another aquifer, etc.) MCLs Not Achieved: Deleted 4 MCLs Achieved: Based on Risk Assessment, LTM 19 2 No Active Remedy, MCLs Not Achieved: Deleted No LTM Based on Risk Assessment, No LTM 14 MCLs Not Achieved: LTM FIGURE 2-6 Pie chart of 80 groundwater facilities delisted from the NPL catego- rized by whether they reached MCLs and whether long-term monitoring is in place. LTM = long-term monitoring. Figure 2-6
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66 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES treat or thermal treatment) and no longer require long-term monitoring. Four facilities deleted from the NPL have achieved MCLs and still have long-term monitoring in place. At 19 the MCLs were achieved without an active remedy (thus, no long-term monitoring is in place), suggesting that either there was no substantial groundwater contamination when the facil- ity was added to the NPL or that natural attenuation occurred during the RI/FS process to significantly reduce contaminant concentrations. More interesting are the 20 facilities with contaminated groundwater that were deleted from the NPL where MCLs have not been met (as of Au- gust 2011 and as related in readily accessible EPA documents). Fourteen of these have been shown to have contaminant concentrations that are trend- ing downward, and thus must continue to do five-year reviews. Six were deleted after a site-specific risk assessment demonstrated that the risks were below an acceptable threshold, even if contaminant concentrations were above MCLs, and four of the six must do long-term monitoring. Twelve of the 80 were delisted after successfully installing containment or another protective remedy and thus could not be considered as having met or not met MCLs, because that was not the goal of the remedy. For example, at Schofield Barracks in Hawaii, the Army was able to delist the facility after providing an alternative source of water to local residents and determining that the contamination present in the subsurface was no lon- ger presenting a human health risk (see Box 2-2). Because contamination remains in place, the facility must undergo five-year reviews in perpetuity, but this facility is anecdotally referred to as “closed.” Also included in this category are facilities that were granted a Technical Impracticability waiver for some portion of the facility (at which MCLs are waived). Thus, it would be impossible to consider the sites as having achieved MCLs or not. For six facilities there was insufficient information in the documenta- tion available from EPA to determine if MCLs were met or not. Presumably, these six could have been binned into one of the other categories if further information had been sought from EPA regional offices. Finally, five facilities did not appear to have ever had groundwater contamination. The Committee cautions that there is some amount of uncertainty associated with this analysis due to the uneven and sparse nature of the documentation available on delisted NPL facilities from the EPA website. In particular, frequently found statements such as “a site is meeting health- based standards” were difficult to interpret as having met MCLs or not. The documents for a given facility were not necessarily consistent with one another, especially with respect to the statement of remedial goals. For the purposes of the analysis, the most recent documents were weighted more heavily. Despite these uncertainties, only half of groundwater-contaminated facilities deleted from the NPL, which are considered success stories for
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MAGNITUDE OF THE PROBLEM 67 BOX 2-2 Schofield Barracks, HI, Case Study This site is an example of a delisted NPL facility at which restoration was con- sidered not practical and that will require long-term management and monitoring. Schofield Barracks is a U.S. Army post located in the City and County of Honolulu and in the Wahiawa District of the island of Oahu, Hawaii. Established in 1908, the 17,725-acre facility served as a major support facility during World War II and is the largest Army base outside the contiguous United States. The hydrogeology at Schofield is complex, including a highly fractured basalt aquifer that causes extreme heterogeneity on a local scale. Depth to groundwater is 500–600 feet from the surface. Contaminated sites include a former landfill on 35 acres that contains solid, domestic waste; industrial waste from vehicle equip- ment and maintenance, solvents, and sewage sludge; medical waste; explosives (both ordnance and unexploded); and construction and demolition waste from various military installations. Contaminants detected at levels above MCLs in the groundwater system beneath the landfill were TCE and carbon tetrachloride (CCl4), antimony, and manganese. Other chlorinated VOCs such as PCE were de- tected at low levels (less than MCLs). The precise source for these contaminants in the groundwater remains unidentified. In 1985, high levels of TCE (as much as 100 ppb) were found to be contaminat- ing wells that supplied water to about 25,000 people living at Schofield Barracks, which was the catalyst for the site being listed on the NPL (EPA, 2010a; U.S. Army Environmental Command, 2007). As a result, there was a temporary switch from well water to city and county water supplies. In 1986, an air stripping treatment unit was established to treat water from the four existing production wells to reduce concentrations of TCE in the drinking water used at the base. Public drinking water wells that serve 55,000 people are located within three miles of the base, but they do not appear to have been affected by the contamination. The Army divided the site into four Operable Units (OU2 is the groundwater plume and OU4 is the former landfill), for which a ROD was signed in 1996 (EPA, 1996b). Because of the difficult hydrogeologic conditions and the inability to con- clusively locate the source of contamination, the Army applied for and received a Technical Impracticability waiver for the site. Treatment for the drinking water wells has maintained an average concentration of TCE below 5 μg/L since air strippers were installed in 1986. The installation was delisted from the NPL in 2000. The Army is conducting the five-year reviews, the second of which was completed in 2007. Site inspection shows that the remedies (for both contaminated groundwater and the landfill) are functioning properly (U.S. Army Environmental Command, 2007). site closure, have actually achieved MCLs. Of course, at all of the deleted facilities, human health and the environment are currently protected. What is also clear from this analysis is that many site-specific, pragmatic factors come into play when decisions are made on the future of the facility (i.e., no further action or some kind of long-term management).
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68 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES As discussed further in Chapter 3, the cleanup goals of the federal pro- grams range from preventing or minimizing exposure, to meeting engineer- ing milestones (such as remedy selection, design completion, completing construction, completing the active remedy), to attaining the ultimate goal of achieving UU/UE conditions at a site. The military’s primary goal is to achieve remedy in place or response complete at its sites by 2014, with little mention of site closure or attaining unrestricted use of the site. All of these issues suggest that there can be no generalizations about the condition of sites referred to as “closed,” particularly assumptions that they are “clean,” meaning available for unlimited use and unrestricted exposure. Indeed, the experience of the Committee in researching “closed sites” sug- gests that many of them contain contaminant levels above those allowing for unlimited use and unrestricted exposure, even in those situations where there is “no further action” required. Rather, site closure may simply mark the beginning of a long-term operation and maintenance phase involving oversight of institutional controls. Furthermore, it is clear that states are not tracking their caseload at the level of detail needed to ensure that risks are being controlled subsequent to “site closure.” Thus, reports of cleanup success should be viewed with caution. CONCLUSIONS AND RECOMMENDATIONS The Committee’s rough estimate of the number of sites remaining to be addressed and their associated future costs is presented in Table 2-6, which lists the latest available information on the number of facilities (for CERCLA and RCRA) and contaminated sites (for the other programs) that have not yet reached closure, and the estimated costs to remediate the re- maining sites. The Committee used these data to estimate the total number of complex sites with residual contamination, as described below. At least 126,000 sites across the country have been documented that have residual contamination at levels preventing them from reaching clo- sure. This number is likely to be an underestimate of the extent of con- tamination in the United States for a number of reasons. First, for some programs data are available only for contaminated facilities rather than individual sites; for example, RCRA officials declined to provide an average number of solid waste management units per facility, noting that it ranged from 1 to “scores.” CERCLA facilities frequently contain more than one in- dividual release site. The total does not include DoD sites that have reached remedy in place or response complete, although some such sites may indeed contain residual contamination. Finally, the total does not include sites that likely exist but have not yet been identified, such as dry cleaners or small chemical-intensive businesses (e.g., electroplating, furniture refinishing) that
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MAGNITUDE OF THE PROBLEM 69 TABLE 2-6 Rough Estimate of the Total Number of Currently Known Facilities or Contaminated Sites That Have Not Reached Closure and Estimated Costs to Complete Number of Number of Contaminated Contaminated Estimated Program/Agency Facilities Sites Cost to Completea DoD 4,329 $12.8 billion CERCLA 1,364 $16–23 billion RCRA 2,844 $32.4 billion UST 87,983 $11 billion DOE 3,650 $17.3–20.9 billion Other Federal Sites > 3,000 $15–22 billion State Sites >23,000 $5 billionb Total >126,000 $110–127 billionc NOTE: Munitions were excluded from the DoD numbers, but some munitions are found under RCRA. aCost figures are undiscounted 2010 dollars. The Committee’s cost-to-complete estimate is lower than EPA (2004) because some activities were excluded by the Committee (e.g., MMRP). bFor State sites, assumed $20K/site. cData presented as a range to reflect ranges presented in the original data sets. However, many programs simply provided a single estimate. have not been investigated for possible contamination. There is overlap between some of the categories (e.g., some sites are counted under both the CERCLA and DoD or DOE categories), but in the Committee’s opinion this overlap is not significant enough to dismiss the conclusion that the total number of 126,000 is an underestimate. If more accurate numbers were desired, consistent information would need to be collected on the number of contaminated sites across the various programs. No information is available on the total number of sites with contami- nation in place above levels allowing for unlimited use and unrestricted exposure, although the total is certainly greater than the number of sites tallied in Table 2-6. For the CERCLA program, many facilities have been delisted with contamination remaining in place at levels above unlimited use and unrestricted exposure (as much as half according to the Commit- tee’s analysis of 80 delisted NPL facilities with groundwater contamina- tion). Depending on state closure requirements, USTs are often closed with contamination remaining due to the biodegradability of petroleum hydro- carbons. Most of the DOE sites, including those labeled as “completed,”
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70 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES contain recalcitrant contamination that in some cases could take hundreds of years to reach UU/UE levels. A small percentage (about 12,000 or less than 10 percent) of the 126,000 sites are estimated by the Committee to be complex from a hy- drogeologic and contaminant perspective. This total represents the sum of the remaining DoD, CERCLA, RCRA, and DOE sites and facilities, based on the assumption that many of the simpler sites in these programs have already been dealt with. Although the complexity of the typical RCRA facility can be debated, there are undoubtedly some UST, state, and other federal sites with complex hydrogeologic conditions or contaminants that were not included. This estimate is admittedly uncertain and based largely on the Committee’s experience with a wide range of hazardous waste sites. Data on the complexity of sites has not been tallied by any of the programs, and can only be gathered accurately through site-specific data from a ran- dom sampling of sites. Approximately 10 percent of CERCLA facilities affect or significantly threaten public water supply systems, but similar information from other programs is largely unavailable. Surveys of groundwater quality report that 0.34 to 1 percent of raw water samples from wells used for drinking water (including public supply and private wells) contain mean VOC concentra- tions greater than the MCL, although there are no data linking these MCL exceedances to specific hazardous waste sites. The percentage of drinking water wells with samples containing low-level VOC concentrations is likely to be higher for areas in close proximity to contaminated sites, for urban rather than rural areas, and in shallow unconfined sandy aquifers. Information on cleanup costs incurred to date and estimates of future costs, as shown in Table 2-6, are highly uncertain. Despite this uncertainty, the estimated “cost to complete” of $110-$127 billion is likely an under- estimate of future liabilities. Remaining sites include some of the most dif- ficult to remediate sites, for which the effectiveness of planned remediation remains uncertain given their complex site conditions. Furthermore, many of the estimated costs (e.g., the CERCLA figure) do not fully consider the cost of long-term management of sites that will have contamination remain- ing in place at high levels for the foreseeable future. The nomenclature for the phases of site cleanup and cleanup progress are inconsistent between federal agencies, between the states and federal government, and in the private sector. Partly because of these inconsisten- cies, members of the public and other stakeholders can and have confused the concept of “site closure” and NPL deletion with achieving UU/UE goals
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MAGNITUDE OF THE PROBLEM 71 for the site, such that no further monitoring or oversight is needed. In fact, many sites thought of as “closed” and considered “successes” will require oversight and funding for decades and in some cases hundreds of years to remain protective. CERCLA and other programs have reduced public health risk from groundwater contamination by preventing unacceptable exposures in water or air, but not necessarily by reducing contamination to levels allowing for unlimited use and unrestricted exposure for every contaminant throughout the affected aquifers. More consistent and transparent terminology that simply and clearly differentiates the discrete phases of remediation and facilitates logical track- ing of progress would improve communication with the public. Improve- ments in terminology among state and federal regulators and PRPs are particularly important in the later stages of remediation. For example, once a remedy has been implemented and operated for some time, classifying the site as a “long-term management site,” rather than deleting it from the NPL or classifying it as “closed,” would more accurately communicate its status. Sites that attain contaminant concentrations consistent with unlimited use and unrestricted exposure could be classified as “unrestricted-use sites.” These classifications would directly reflect progress toward the goals of most state and federal groundwater cleanup programs. REFERENCES Canter, L. W., and D. A. Sabatini. 1994. Contamination of public ground water supplies by Superfund sites. International Journal of Environmental Studies 46(1):35-57. Conger, J. 2011. Memo: New goals for DERP. July 18, 2011. DEPARC. 2010. Fiscal Year 2009 Defense Environmental Programs Annual Report to Con- gress, April. Page C-1-1. DeSimone, L. A., P. A. Hamilton, and R. J. Gilliom. 2009. Quality of water from domestic wells in principal aquifers of the United States, 1991–2004. Overview of major findings. U.S. Geological Survey Circular 1332, 48 pp. DoD (Department of Defense). 2012. Manual Number 4715.20. Defense Environmental Restoration Program (DERP) Management. DOE (Department of Energy). 2011. FY2011 Budget Vol. 5 (pages 60-71). DOE. 2012a. FY2012 Budget Vol. 5 (page 12). DOE. 2012b. FY2012 Budget Vol. 2 (page 74). DOE. 2012c. FY2012 Budget Vol. 1 (page 282). EPA (U.S. Environmental Protection Agency). 1993. Evaluation of the Likelihood of DNAPL Presence at NPL Sites: National Results. EPA 540R-93-073. Washington, DC: EPA Office of Solid Waste and Emergency Response. EPA. 1996a. Memorandum from Steven A. Herman, Assistant Administrator, Office of En- forcement and Compliance Assurance, and Elliot Laws, Assistant Administrator for Solid Waste and Emergency Response, to EPA Regions. Re: Coordination between RCRA Corrective Action and Closure and CERCLA Site Activities at 2 (September 24, 1996). EPA. 1996b. EPA Superfund Record of Decision for Schofield Barracks.
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72 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES EPA. 2000. National Water Quality Inventory: 2000 Report. http://www.epa. gov/305b/2000report/. EPA. 2002. Community Water System Survey 2000. EPA 815-R-02-005B. Washington, DC: EPA Office of Water. EPA. 2004. Cleaning up the Nation’s Waste Sites: Markets and Technology Trends. Washing- ton, DC: EPA Office of Solid Waste and Emergency Response. EPA. 2007. Technologies for Site Cleanup: Annual Status Report (Twelfth Edition). EPA- 542-R-07-012. Washington, DC: EPA Office of Solid Waste and Emergency Response. EPA. 2008. Facilities on the RCRA 2008 GPRA Corrective Action Baseline. http://www.epa. gov/epawaste/hazard/correctiveaction/pdfs/base08fc.pdf. Accessed August 16, 2012. EPA. 2009a. Semi-Annual Report of UST Performance Measures End of Fiscal Year 2009. http://www.epa.gov/oust/cat/ca_09_34.pdf. EPA. 2009b. The Analysis of Regulated Contaminant Occurrence Data from Public Water Systems in Support of the Second Six-Year Review of National Primary Drinking Water Regulations. EPA 815-B-09-006. Washington, DC: EPA. EPA. 2009c. DNAPL Remediation: Selected Projects Where Regulatory Closure Goals Have Been Achieved. EPA 542/R-09/008. Washington, DC: EPA Office of Solid Waste and Emergency Response. EPA. 2010a. Region 9 Online Site Description. http://yosemite.epa.gov/r9/sfund/r9sfdocw.nsf /7508188dd3c99a2a8825742600743735/1818fba2414310dc88257007005e9452!Open Document#descr. Accessed August 2010. EPA. 2010b. Superfund Remedy Report, Thirteen Edition. EPA 542-R-10-004. Washington, DC: EPA Office of Solid Waste and Emergency Response. EPA. 2011a. Semi-Annual Report of UST Performance Measures End of Fiscal Year 2011. http://www.epa.gov/oust/cat/ca_11_34.pdf. EPA. 2011b. The National LUST Cleanup Backlog: A Study of Opportunities. Washington, DC: EPA OUST. EPA. 2011c. Close Out Procedures for National Priorities List Sites at 1-2. OSWER Directive 9320.222. http://epa.gov/superfund/programs/npl_hrs/closeout/pdf/2011guidance.pdf. GAO (Government Accountability Office). 2008. Hardrock Mining. Information on Aban- doned Mines and Value and Coverage of Financial Assurances on BLM Land. GAO-08- 574T. Washington, DC: GAO. GAO. 2009. Superfund: Litigation Has Decreased and EPA Needs Better Information on Site Cleanup and Cost Issues to Estimate Future Program Funding Requirements. GAO-09- 656. Washington, DC: GAO. Georgia Environmental Protection Division. 2010. Hazardous Site Inventory Introductory Information. http://www.georgiaepd.org/Files_PDF/gaenviron/hazwaste/intro.pdf. Hunter, P. 2006. DoD-Wide Occurrence of Emerging COCs in Groundwater & Soil. SERDP- ESTCP Partners Symposium 2006, Washington, DC, November. ITRC (Interstate Technology and Regulatory Council). 2009. Evaluating LNAPL Remedial Technologies for Achieving Project Goals. Washington, DC: ITRC. Land, M., J. T. Kulongoski, and K. Belitz. 2011. Status of Groundwater Quality in the San Fernando–San Gabriel Study Unit, 2005. California GAMA Priority Basin Project. Sci- entific Investigations Report 2011–5206. U.S. Geological Survey. NRC (National Research Council). 1999. Groundwater and Soil Cleanup. Washington, DC: National Academy Press. NRC. 2009. Advice on the Department of Energy’s Cleanup Technology Roadmap. Washing- ton, DC: The National Academies Press. OUSD (Office of the Under Secretary of Defense for Acquisition, Technology and Logistics). 2011. FY10 Defense Environmental Programs Annual Report to Congress: Final Report, July 2011.
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MAGNITUDE OF THE PROBLEM 73 Rowe, B. L., P. L. Toccalino, M. J. Moran, J. S. Zogorski, and C. V. Price. 2007. Occur- rence and potential human-health relevance of volatile organic compounds in drinking water from domestic wells in the United States. Environmental Health Perspectives 115(11):1539-1546. SCRD (State Coalition for the Remediation of Dry Cleaners). 2010a. May 2010 newsletter. http://www.drycleancoalition.org/download/news0510.pdf. SCRD. 2010b. December 2010 newsletter. http://drycleancoalition.org/download/news1210. pdf. Toccalino, P. L., and J. A. Hopple. 2010. The Quality of Our Nation’s Waters—Quality of Water from Public-Supply Wells in the United States, 1993–2007—Overview of major findings. U S. Geological Survey Circular 1346, 58 pp. Toccalino, P. L., J. E. Norman, and K. J. Hitt. 2010. Quality of Source Water from Public- Supply Wells in the United States, 1993–2007. U.S. Geological Survey Scientific Investiga- tions Report 2010-5024, 206 pp. U.S. Army Environmental Command. 2007. Second Five-Year Review Report for Operable Units 2 and 4, Schofield Army Barracks, Sites 12 and 19. Zogorski, J. S., J. M. Carter, T. Ivahnenko, W. W. Lapham, M. J. Moran, B. L. Rowe, P. J. Suillace, and P. L. Toccalino. 2006. The Quality of Our Nation’s Waters—Volatile Or- ganic Compounds in the Nation’s Ground Water and Drinking-Water Supply Wells. U.S. Geological Survey Circular 1292, 101 pp.
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