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OCR for page 37
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.
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