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Ranking Hazardous-Waste Sites for Remedial Action RANKING HAZARDOUS-WASTE SITES FOR REMEDIAL ACTION Committee on Remedial Action Priorities for Hazardous Waste Sites Board on Environmental Studies and Toxicology Commission on Geosciences, Environment, and Resources National Research Council NATIONAL ACADEMY PRESS WASHINGTON, D.C. 1994
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Ranking Hazardous-Waste Sites for Remedial Action NATIONAL ACADEMY PRESS 2101 Constitution Ave., N.W. Washington, D.C. 20418 NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competencies and with regard for appropriate balance. This report has been reviewed by a group other than the authors according to procedures approved by a Report Review Committee consisting of members of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The National Academy of Sciences is a private, non-profit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Bruce Alberts is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Robert M. White is president of the National Academy of Engineering. The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Kenneth I. Shine is president of the Institute of Medicine. The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy's purposes of furthering knowledge and advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Bruce Alberts and Dr. Robert M. White are chairman and vice chairman, respectively, of the National Research Council. The project was supported by the Department of Defense, the Department of Energy, the Environmental Protection Agency, the American Petroleum Institute, the Monsanto Company, and the Coalition on Superfund. Contract #NAS90-191. Library of Congress Catalog Card No. 94-66574 International Standard Book No. 0-309-05092-8 Additional copies of this book are available from the National Academy Press, 1-800-624-6242. Cover art by Terry Parmelee. Parmelee, a Washington, D.C., artist, considers herself stylistically influenced by the Washington Color School of abstraction that was in its heydey when she was earning her MFA at The American University in 1967. Parmelee is represented by the Jane Haslem Gallery in Washington, D.C. Copyright 1994 by the National Academy of Sciences. All rights reserved. Printed in the United States of America
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Ranking Hazardous-Waste Sites for Remedial Action COMMITTEE ON REMEDIAL ACTION PRIORITIES FOR HAZARDOUS WASTE SITES PERRY L. MCCARTY (Chairman), Stanford University, Stanford, Calif. YORAM COHEN (Vice Chairman), University of California, Los Angeles, Calif. MARK M. BASHOR, Agency for Toxic Substances and Disease Registry, Atlanta, Ga. KIRK W. BROWN, Texas A&M University, College Station, Tex. JAMES W. GILLETT, Cornell University, Ithaca, N.Y. ALAN J. GOLDMAN, The Johns Hopkins University, Baltimore, Md. MICHAEL R. GREENBERG, Rutgers University, New Brunswick, N.J. ROBERT E. HAZEN, New Jersey Department of Environmental Protection and Energy, Trenton, N.J. GLENN PAULSON, Illinois Institute of Technology, Chicago, Ill. MITCHELL J. SMALL, Carnegie Mellon University, Pittsburgh, Pa. LOUIS J. THIBODEAUX, Louisiana State University, Baton Rouge, La. CURTIS C. TRAVIS, Oak Ridge National Laboratory, Oak Ridge, Tenn. VICTORIA J. TSCHINKEL, Landers and Parsons, Tallahassee, Fla. JULIAN WOLPERT, Princeton University, Princeton, N.J. JEFFREY J. WONG, California Environmental Protection Agency, Sacramento, Calif.
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Ranking Hazardous-Waste Sites for Remedial Action Project Staff RAYMOND A. WASSEL, Project Director and Program Director ROBERT J. CROSSGROVE, Editor ANNE M. SPRAGUE, Information Specialist ADRIENNE L. DAVIS, Senior Project Assistant RUTH P. DANOFF, Program Assistant
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Ranking Hazardous-Waste Sites for Remedial Action BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY PAUL G. RISSER (Chair), University of Miami, Oxford, Ohio FREDERICK R. ANDERSON, Cadwalader, Wickersham & Taft, Washington, D.C. MICHAEL J. BEAN, Environmental Defense Fund, Washington, D.C. EULA BINGHAM, University of Cincinnati, Cincinnati, Ohio EDWIN H. CLARK, Clean Sites, Inc., Alexandria, Va. ALLAN H. CONNEY, Rutgers University, N.J. JOHN L. EMMERSON, Eli Lilly & Company, Greenfield, Ind. ROBERT C. FORNEY, Unionville, Pa. ROBERT A. FROSCH, Harvard University, Cambridge, Mass. KAI LEE, Williams College, Williamstown, Mass. JANE LUBCHENCO, Oregon State University, Corvallis, Ore. GORDON ORIANS, University of Washington, Seattle, Wash. FRANK L. PARKER, Vanderbilt University, Nashville, Tenn., and Clemson University, Anderson, S.Car. GEOFFREY PLACE, Hilton Head, S.Car. DAVID P. RALL, Washington, D.C. LESLIE A. REAL, Indiana University, Bloomington, Ind. KRISTIN SHRADER-FRECHETTE, University of South Florida, Tampa, Fla. GERALD VAN BELLE, University of Washington, Seattle, Wash. BAILUS WALKER, JR., University of Oklahoma, Oklahoma City, Okla.
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Ranking Hazardous-Waste Sites for Remedial Action Staff Program Directors JAMES J. REISA, Director DAVID J. POLICANSK, Associate Director and Program Director for Natural Resources and Applied Ecology KULBIR BAKSHI, Program Director, Committee on Toxicology GAIL CHARNLLEY, Acting Program Director for Human Toxicology and Risk Assessment LEE R. PAULSON, Program Director for Information Systems and Statistics RAYMOND A. WASSEL, Program Director for Environmental Sciences and Engineering
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Ranking Hazardous-Waste Sites for Remedial Action COMMISSION ON GEOSCIENCES, ENVIRONMENT AND RESOURCES M. GORDON WOLMAN (Chair), Johns Hopkins University, Baltimore, Md. PATRICK R. ATKINS, Aluminum Company of America, Pittsburgh, Penn. EDITH BROWN WEISS, Georgetown University Law Center, Washington, D.C. EDWARD A. FRIEMAN, Scripps Institution of Oceanography, La Jolla, Calif. W. BARCLAY KAMB, California Institute of Technology, Pasadena, Calif. RAYMOND A. PRICE, Queen's University at Kingston, Canada THOMAS C. SCHELLING, University of Maryland, College Park, Md. ELLEN K. SILBERGELD, Environmental Defense Fund, Washington, D.C. STEVEN M. STANLEY, Johns Hopkins University, Baltimore, Md. VICTORIA J. TSCHINKEL, Landers and Parsons, Tallahassee, Fla. WARREN WASHINGTON, National Center for Atmospheric Research, Boulder, Colo. Commission Staff STEPHEN RATTIEN, Executive Director STEPHEN D. PARKER, Associate Executive Director MORGAN GOPNIK, Assistant Executive Director JEANETTE SPOON, Administrative Officer SANDRA FITZPATRICK, Administrative Associate
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Ranking Hazardous-Waste Sites for Remedial Action OTHER RECENT REPORTS OF THE BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY Science and Judgment in Risk Assessment (1994) Health Effects of Ingested Fluoride (1993) Pesticides in the Diets of Infants and Children (1993) Issues in Risk Assessment (1993) Setting Priorities for Land Conservation (1993) Protecting Visibility in National Parks and Wilderness Areas 1993) Biologic Markers in Immunotoxicology (1992) Dolphins and the Tuna Industry (1992) Environmental Neurotoxicology (1992) Hazardous Materials on the Public Lands (1992) Science and the National Parks (1992) Animals as Sentinels of Environmental Health Hazards (1991) Assessment of the U.S. Outer Continental Shelf Environmental Studies Program, Volumes I-IV (1991-1993) Human Exposure Assessment for Airborne Pollutants (1991) Monitoring Human Tissues for Toxic Substances (1991) Rethinking the Ozone Problem in Urban and Regional Air Pollution (1991) Decline of the Sea Turtles (1990) Tracking Toxic Substances at Industrial Facilities (1990) Biologic Markers in Pulmonary Toxicology (1989) Biologic Markers in Reproductive Toxicology (1989) Copies of these reports may be ordered from the National Academy Press (800) 624-6242 (202) 334-3313
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Ranking Hazardous-Waste Sites for Remedial Action PREFACE The National Research Council established the Committee on Remedial Action Priorities for Hazardous Waste Sites in 1991. The committee was asked to examine the principal ranking methods being used or considered by federal and state agencies to rank hazardous-waste sites for remedial priority. Among the issues to be considered were the technical and policy purposes of the ranking methods, the effectiveness of the methods in achieving their intended purposes, the assumptions embodied within the methods, the uncertainties in the methods' results, and the methods' flexibility for considering new information and for analyzing and comparing the cost effectiveness of remediation. The project was supported by the U.S. Department of Defense (DOD), the U.S. Department of Energy (DOE), the U.S. Environmental Protection Agency (EPA), the American Petroleum Institute, Monsanto, and the Coalition on Superfund. In response to a request from DOD, an interim report—completed in June 1992—assessed the methods, assumptions, and constraints of DOD's Defense Priority Model (DPM), which was being developed to assist in decision making for hazardous-waste site restoration. This final report contains the results of a broader, more comprehensive study, not only of DOD's DPM, but also of EPA's Hazard Ranking System (HRS), DOE's proposed Environmental Restoration Priority System (ERPS), and to some extent, systems being used by various states. Estimates of costs to meet the current national goals of cleaning up hazardous-waste sites extend beyond hundreds of billions of dollars. Serious questions are being raised as to whether the United States can afford to remediate all these sites. Regardless of whether priority setting is achieved explicitly in a manner open to public scrutiny, or implicitly in some obscure manner, priorities
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Ranking Hazardous-Waste Sites for Remedial Action are certainly being A reliable system is needed to manage this expensive remedial effort in order to provide adequate protection of human health and the environment while making efficient use of financial resources. In this study, the committee examined the approaches being used by different agencies, assessed their effectiveness, and developed recommendations for the future. During its initial meetings, the committee received information about the ranking models and overall priority-setting systems being used or developed by several federal and state agencies. The committee found no written descriptions of priority-setting systems that are used in the private sector to make remedial decisions. The committee was not asked to determine, nor did it conclude, whether any of the models was better than the others. The committee considered the possible use of a unified national approach to improve the decision process for hazardous-waste site remediation in the future. Arguments for and against a unified procedure are presented in this report. The committee would like to extend its appreciation for the cooperation provided by many individuals who furnished the committee with information about the different priority-setting systems. We especially would like to thank Marcia Read, Kevin Doxey, and Thomas Baca with the U.S. Department of Defense, and Judith Hushon with Environmental Resources Management Company, who devoted considerable time and effort to assist our review of the DPM and DOD's priority setting process. In addition, they participated in the scoring exercise of the five restoration sites. From the U.S. Environmental Protection Agency, we would especially like to thank Dorothy Canter, David Evans, Stephen Caldwell, and James McMaster for informing the committee about EPA's priority setting with the HRS. In addition, Lawrence Zaragoza of EPA assisted in the scoring exercise. From the U.S. Department of Energy, valuable input for the ERPS evaluation was provided by R. Patrick Whitfield, Thomas Longo, Frank Baxter, and Thomas Cotton (J. K. Associates). John Pendergrass of the Environmental Law Institute provided the committee with
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Ranking Hazardous-Waste Sites for Remedial Action information on the numerous approaches being used in priority setting by various state agencies. Others who provided valuable assistance in the scoring exercise were Jill Morris (Oak Ridge National Laboratory), Michael Gresalfi (SAIC), and Stuart Haus (MITRE). In such an effort, a great deal of coordination is required for committee meetings, much information must be gathered, and documents must be typed, distributed, integrated, and edited. For this, a great share of appreciation must go to Raymond Wassel, the NRC staff officer for this project. He not only expedited the interactions between committee members and provided valuable input to the report itself, but also consistently reminded the committee members of their duties and responsibilities. The committee also extends its appreciation to others on the BEST staff for their assistance, including James Reisa, director of the Board on Environmental Studies and Toxicology; William Lipscomb, research assistant; Felita Buckner, Adrienne Davis, and Ruth Dan-off, Program Assistants; and Anne Sprague, information specialist. I would also like to thank others on the BEST staff who provided assistance for this effort and Robert J. Crossgrove, editor of this report. Finally, I would like to thank the members of the committee, who devoted so much of their time to this effort. Their backgrounds are diverse and their perspectives about the issues under consideration varied considerably. They provided a stimulating environment for addressing the issues of importance. I believe the results of their efforts provide an excellent framework for priority setting in the future. PERRY L. McCARTY Chairman
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Ranking Hazardous-Waste Sites for Remedial Action CONTENTS EXECUTIVE SUMMARY 1 1 HAZARDOUS-WASTE SITE PROBLEMS IN THE UNITED STATES 23 Introduction and Charge to the Committee, 23 U.S. Environmental Protection Agency Superfund Program, 25 U.S. Departments of Defense and Energy Programs, 34 Other Federal and State Programs, 39 Setting Priorities, 46 Discussion, 51 Scope of the Report, 54 2 PRIORITY-SETTING PROCESSES 57 Basis For Developing a Priority-Setting Approach, 57 Desirable Features of a Priority-Setting System, 59 3 CLASSIFICATION OF PRIORITY-SETTING APPROACHES 65 Introduction, 65 Environmental Evaluation, 66 Risk Analysis, 68 Environmental Impact Analysis, 75 Structured Value-Scoring Methods, 78 Multiattribute Approaches, 80 Cost-Benefit and Cost-Effectiveness Approaches, 82
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Ranking Hazardous-Waste Sites for Remedial Action 4 EPA's PRIORITY SETTING 85 Background and History, 86 Role of the HRS in the Superfund Program, 89 Model Structure and Components, 93 The Effect of the 1990 HRS Revisions, 122 Priority Setting at Later Stages of Superfund, 125 Proposals for Improving Superfund Site Selection and Priority Setting, 126 Summary Evaluation on EPA Priority Setting for Hazardous-Waste Sites, 130 5 DOD's PRIORITY SETTING 135 Introduction, 135 Background and History, 136 The DPM Structure, 137 Pathway Scoring, 146 Contaminant-Hazard Scoring, 153 Receptor Scoring, 160 Socioeconomic Issues, 163 Scoring Methodology and Aggregation, 165 Validation, 167 Sensitivity and Uncertainty Analyses, 168 Summary, 172 6 DOE's PRIORITY SETTING 177 Background and History, 179 The Environmental Restoration Priority System, 182 Summary Evaluation of DOE's Priority Setting for Hazardous Waste Sites, 205
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Ranking Hazardous-Waste Sites for Remedial Action 7 STATE PRIORITY SETTING 211 Introduction, 211 States with Ranking Systems Similar to the EPA Hazard-Ranking System, 212 Other Numeric Ranking Systems, 220 States with Ranking by Broad Category, 221 Discussion, 222 8 COMPARING FEDERAL RANKING MODELS 225 The Decision-Making Processes, 225 Comparative Scoring Exercise of Federal Ranking Models, 230 General Conclusions, 249 9 TOWARD A UNIFIED NATIONAL APPROACH 251 Advantages and Disadvantages of a Unified Approach, 252 Proposed Unified National Process for Setting Priorities, 259 10 CONCLUSIONS AND RECOMMENDATIONS 267 Need for Priority-Setting Process, 267 Current Priority-Setting, 268 Improving the Priority-Setting Process, 270 Current Ranking Models Used in Priority-Setting, 272 Improving the Models, 275 REFERENCES 279
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Ranking Hazardous-Waste Sites for Remedial Action RANKING HAZARDOUS-WASTE SITES FOR REMEDIAL ACTION
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