Are We Cleaning Up? 10 Superfund Case Studies June 1988 NTIS order #PB89-139018 Recommended Citation: U.S. Congress, Office of Technology Assessment, Are We Cleaning Up? 10 Super- fund Case Studies–Specia] Report, OTA-ITE-362 (Washington, DC: U.S. Government Printing Office, June 1988). Library of Congress Catalog Card Number 88-600545 For sale by the Superintendent of Documents U.S. Government Printing Office, Washington, DC 20402-9325 (order form can be found in the back of this report) Foreword In a few years, Superfund became part of the American vocabulary because so many people feel so strongly about toxic waste. and cleanup of contaminated sites. They remain worried about environmental and health effects, but a new con- cern has come to the fore: the enormous amount of money and the long times to clean up an ever-growing list of Superfund sites. Yet, even while the public de- mands effective cleanups, nearly everyone speaking and writing about Superfund seems to feel that serious problems exist. And the focus of public attention has shifted from how much money ought to go to Superfund to how to achieve environ- mental results and efficiency. Right now there are more questions than answers about diagnosing and f!xing Superfund. Four committees of Congress asked the Office of Technology Assessment to assess how Superfund is being implemented under the 1986 Superfund Amend- ments and Reauthorization Act. They asked OTA to examine a number of technical issues that arise near the beginning of the complex Superfund process. The study was to assess the impacts of statutory provisions and program policies on environ- mental effectiveness and economic efficiency. The requesting committees were: the House Committee on Public Works and Transportation and its Investigation and Oversight Subcommittee; the House Energy and Commerce Committee and its Oversight and Investigations, and Transportation, Tourism, and Hazardous Ma- terials Subcommittees; the Subcommittee on Superfund and Environmental Over- sight of the Senate Environment and Public Works Committee; and the Subcom- mittee on Environment, Energy, and Natural Resources of the House Government Operations Committee. During our Superfund Implementation assessment we realized that we could learn much by finding out how sites progress through the Superfund program and how—and when—critical decisions about their cleanup are being made. Before we could answer tough but general questions about making Superfund work better, we had to know more about what was actually going on. This special report presents 10 case studies of recent Superfund decisions at sites which OTA believes, from surveying over 100 recent cleanup decisions, to be representative of a broad range of contamination problems and cleanup technologies. We hope that everyone af- fected by Superfund can learn as much as we have from these case studies. Many people have helped OTA with these case studies, especially Environmental Protection Agency staff around the country who provided us with primary infor- mation about the sites. Several companies that are responsible parties at sites also provided key documents. Responsibility for the contents of this document, of course, rests with OTA, JOHN H. GIBBONS Director . Ill Superfund Implementation Advisory Panel David Marks, Panel Chairman Massachusetts Institute of Technology Kirk Brown Robert G. Kisse]] Texas A&M University E.I. du Pent de Nemours & Co., Inc. Richard Brownell Steve Lester Malcolm Pirnie, Inc. Citizens Clearinghouse for Hazardous Waste William Child William Librizzi Illinois Environmental Protection &encv“ New Jersey Dqpt. of Environmental Henry Cole Protection Clean Water Action and National Campaign Against Toxic Hazards George Muhlebach Ciba-Geigy Corp. E. William Colglazier Waste Management Institute Robert N. Ogg University of Tennessee CH2M Hill William B, DeVille Robert B. Pojasek Louisiana Department of Environmental ChemCycle Corp. Quality Frank J. Veale, Jr. Deborah Hankins Texas Instruments, Inc. General Electric Corp. James N. Welsh Bob Harris Thermal Kinetics ENVIRON Corp. William N. Hedeman Beveridge & Diamond, P.C. NOTE: OTA appreciates and is grateful for the valuable assistance and thoughtful critiques provided by the advisory panel members. The panel does not, however, necessarily approve, disapprove, or endorse this report. OTA assumes full responsibility for the report and the accuracy of its contents, iv OTA Project Staff–Are We Cleaning Up: 10 Superfund Case Studies Lionel S. Johns, Assistant Director, OTA Energy, Materials, and International Security Division Audrey B. Buyrn, Manager Industry, Technology, and Employment Program Joel S. Hirschhorn, Project Director Kirsten U. Oldenburg, Deputy Project Director David A. Dorau, Analyst Karen L. Jordan, Research Assistant Lynn M. Powers, Editor Administrative Staff Edna M. Thompson, Administrative Assistant Diane D. White, Administrative Secretary v Page Summary and Analysis. I Introduction . 1 The Importance of the Record of Decision . z The Usefulness of Case Studies . 2 Superfund’s Better Side. 5 Summary of Trends From 10Case Studies . 7 IO Case Studies . 16 Introduction . 16 Methodology . 16 Format for Case Studies . 16 Case Study l: Chemical Control Corp., Elizabeth, NJ; EPA Region 2 . 18 Case Study 2: Compass Industries, Tulsa County, Oklahoma; EPA Region 6 . 25 Case Study S: Conservation Chemical Company, Kansas City, Missouri, EPA Region 7 . 29 Case Study 4: Crystal City Airport, Crystal City, Texas, EPA Region 6 ......, 34 Case Study5: Industrial Excess Landfill Uniontown, Ohio, EPA Region 5 . 41 Case Study6: Pristine, Incv Reading, Ohio, EPA Region5 . 44 Case Study7: Renora, Inc; Edison Township, New Jersey, EPA Region 2... 55 Case Study 8:Sand Springs, Petrochemical Complex, Tulsa County, Oklahoma, EPA Region6 . 59 Case Study 9: Schmalz Dump Site, Harrison, Wisconsin, EPA Region 5...... 66 Case Study 10: Tacoma Tar Pits, Tacoma, Washington, EPA Region 10.. 71 Boxes Box Page l. How Does Superfund Operate? . 3 2. 10)Case Study Sites With Capsule Findings . 9 Table Table Page l. Times for Sites To Reach Points in the Superfund Process . 13 SUMMARY AND ANALYSIS Introduction cover what is wrong and fix it. Whether Super- fund will work cost-effectively over the long term depends on how cleanup technologies are Are we cleaning up the mess or messing up evaluated, matched to cleanup goals, selected, the cleanup? In the eighth year of Superfund, and implemented and how permanent the clean- this central question is still being asked. These ups will be. People want their cleanups—the 10 case studies illustrate how the Environmental ones they live near or pay for—to last. Improv- Protection Agency (EPA) is implementing the ing public confidence in Superfund can be ap- Superfund Amendments and Reauthorization proached from different directions, including Act (SARA) of 1986. OTA has examined a great the one taken in this report: making better de- many more sites and believes these case studies cisions about cleanup technology. are representative of what is happening nation- wide in the Superfund program. Too much flexibility and lack of central man- agement control are working against an effec- This report examines two fundamental ques- tive, efficient Superfund program. EPA Regions, tions about using technology to cleanup toxic contractor companies, and workers have sub- waste sites. First, is the Superfund program stantial autonomy. In principle, flexibility can consistently selecting permanently effective lead to benefits. But the case studies show the treatment technologies which, according to Superfund program as a loose assembly of dis- SARA, are preferable because they reduce “tox- parate working parts; it is a system of divided icity, mobility, or volume” of hazardous wastes? responsibilities and dispersed operations. There The answer OTA finds is that it is not. is no assurance of consistently high quality Second, are land disposal and containment, studies, decisions, and field work or of active both impermanent technologies, still being fre- information transfer. The need for cleanups, quently used? The answer we find is yes. Fu- the newness of the technological challenge, and ture cleanups are likely for the wastes left in the growth of Superfund mask the inexperience the ground or shipped to landfills. and mobility of the work force. Program man- agers have not offset inexperience in technical The Superfund program promised a lot. Peo- areas and management with tight management ple’s expectations have been high, perhaps too controls and intensive educational programs high for such a new, complicated, large-scale for government and contractor workers. Over- effort. Frustration often makes it difficult to see simplified “bean counting” of results instead real Superfund accomplishments. Since its in- of evaluations of what those results mean tech- ception at the end of 1980, Superfund has re- nically and what they accomplish environ- ceived a great deal of money, over $5 billion mentally provides too little incentive for qual- so far, to clean up the Nation’s worst toxic waste ity work. The current decentralized system also sites. But OTA’S research, analysis, and case does not assure higher levels of program effi- studies support the view shared by most ob- ciency over time, even though some workers servers—including people in affected communi- and offices may become much more effective ties and people in industry paying for cleanups and efficient. —that Superfund remains largely