Improving public health and environmental protection resulting from Superfund site investigation/remediation

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<ul><li><p>33</p><p>REMEDIATION Spring 2004</p><p>A discussion of some of the deficiencies of Superfund and hazardous chemical site investigation</p><p>and remediation is presented. Of concern is the adequacy of defining the constituents of con-</p><p>cern; stormwater-runoff monitoring; evaluating excessive bioaccumulation of hazardous chemi-</p><p>cals in edible organisms; the extent and degree of groundwater pollution; modeling of pollutant</p><p>transport in the vadose zone; translocation of subsurface pollutants to surface via plant roots,</p><p>leaves, and flowers; protection of groundwater quality for nonpriority pollutants that impact aes-</p><p>thetic quality; and deficiencies in the quality of site data reports. Examples of these types of prob-</p><p>lems are discussed with suggestions on the approach that should be followed to improve the</p><p>quality of site investigation and remediation. 2004 Wiley Periodicals, Inc.</p><p>The authors have been involved in the review of a number of Superfund sites with respectto the adequacy of investigation and remediation relative to providing a high degree ofpublic health and environmental protection for as long as the wastes and other hazardouschemicals present at the site are a threat.We have found that Superfund/hazardous chem-ical site investigations do not necessarily obtain the technical information needed toadequately assess the hazards to public health and the environment. Further, there is pres-sure on the USEPA and state regulatory agencies to relax Superfund site investigation andremediation requirements, especially as they relate to redevelopment of brownfields sites.However, Lee and Jones (1991a,b), Lee and Jones-Lee (1994, 1997, 1998, 1999, 2000a),and Lee (1997) have discussed problems with approaches that are being used in Superfundand hazardous chemical site remediation and brownfields redevelopment of hazardouschemical sites.</p><p>Some of these problems arise from the fact that there are a number of hazardouschemical site remediation issues that are not now being adequately addressed in con-ventional USEPA and state regulatory agency Superfund and hazardous chemical siteinvestigation/remediation guidance and implementation. The General AccountingOffice (GAO; 1994) reported on inconsistencies in the approach used at differentSuperfund sites in following USEPA guidance. The authors have found that this is stilloccurring today, where two different National Priority List (NPL) Superfund sites,both administered through USEPA Region 9, are following significantly different ap-proaches with respect to investigating the translocation of hazardous chemicals fromthe soils to the surface through terrestrial vegetation. At one site, translocation isbeing explored as a means of site remediation. At another, it is being largely ignored,even though, as discussed below, there is evidence of translocation of hazardous</p><p> 2004 Wiley Periodicals, Inc.Published online in Wiley Interscience (www.interscience.wiley.com). DOI: 10.1002/rem.20001</p><p>G. Fred Lee</p><p>Anne Jones-Lee</p><p>Improving Public Health and Environmental Protection Resulting from Superfund Site Investigation/Remediation</p></li><li><p>chemicals at the site. The USEPA (1988a) Superfund site investigation guidance needsto be brought up to date and expanded to more adequately address many of the is-sues discussed herein.</p><p>The situation of relying on regulatory agencies to conduct the comprehensive s-tudies needed at Superfund/hazardous chemical sites is mixed, with respect to thedetail that agencies and their staff will follow. Often, regulatory agencies find them-selves in the position of having more work/responsibility than they can carry out withthe resources available.This tends to lead to a situation where some regulatory agen-cies and their staff do not look for additional work/problems. Often, they willinterpret the regulatory requirements in such a way as to do the minimum necessaryto just fulfill their interpretation of the requirements. Examples of this situation arediscussed in this article.</p><p>This article is based primarily on the experience that the authors have gainedthrough serving as the USEPA-supported Technical Assistance Grant (TAG) advisorsto the public (Davis South Campus Superfund Oversight Committee) at theUniversity of California-Davis (UCD) Department of Energy (DOE) Laboratory forEnergy-Related Health Research (LEHR) national Superfund site. This site contains amixture of radioactive and hazardous chemicals, as well as other solid wastes arisingfrom UCD education and research operations. The LEHR site began operating at itspresent location in 1958. Research at LEHR through the mid-1980s focused on thehealth effects from chronic exposure to radionuclides, primarily radium-226 (Ra-226) and strontium-90 (Sr-90).</p><p>The radioactive wastes at this site arose primarily from Atomic Energy Commission-sponsored research that involved feeding low-level strontium-90 and radium-226 todogs (beagles). Some of the wastes from these operations were disposed of in shallowpits dug around the periphery of the dog pens.This approach was followed even thoughthe University of California-Berkeley faculty had determined in the 1950s that wastedisposal in the Central Valley of California by land burial would lead to groundwaterpollution.This situation was sufficiently well known by the late 1950s that the AmericanSociety of Civil Engineers (ASCE, 1959) developed a landfilling manual that specificallydiscussed this type of problem.</p><p>These radioactive wastes include scintillation vials containing carbon-14 and tri-tium. Also, it appears that appreciable amounts of tritiated compounds were disposed ofin one or more disposal pits, thus contaminating the groundwater underlying the sitewith sufficient tritium to require remediation.</p><p>The wastes from the animal hospitals/laboratories where the dogs were maintainedafter receiving the radioactivity were treated to some degree in Imhoff tanks, and the wasteeffluent from these tanks was disposed of by percolation in dry wells constructed at the site.</p><p>Campus wastes from both residential and laboratory facilities were also buried atthis site. UCD constructed three campus landfills at this site and utilized a number ofdisposal pits.These landfills/pits received radioactive and hazardous chemicals, as wellas a variety of so-called nonhazardous waste. One of the major pollutants at theLEHR site arose from UCD dumping waste chloroform into a pit located in one of thelandfills.This waste chloroform has generated a plume of chloroform that extends off-site between half a mile to a mile from the point of disposal in one of the importantaquifers underlying the site.This aquifer is used for both domestic and agricultural</p><p>Improving Public Health and Environmental Protection</p><p> 2004 Wiley Periodicals, Inc.34</p><p>Often, regulatory agenciesfind themselves in the po-sition of having morework/responsibility thanthey can carry out with theresources available.</p></li><li><p>water supplies. A second deeper aquifer was also apparently contaminated by chloro-form, primarily through interaquifer transport in wells that penetrate both aquifers.</p><p>In addition to the radioactive and other wastes mentioned above, the LEHR site alsocontains chlorinated hydrocarbon pesticides, such as chlordane, which were used to con-trol fleas on the dogs. Some of the soils at the LEHR site are highly contaminated bychlordane through its handling and use.</p><p>Past and current UCD administrations have attempted to manage the campusliquid and solid wastes through the universitys landfill and wastewater treatmentplant facilities, rather than using public facilities. The approach used by the univer-sity administration was to attempt to dispose of the campus wastes at the least possi-ble cost, largely ignoring the potential problems of burying wastes in shallow pitswith respect to future groundwater pollution. This approach, while saving the uni-versity administration a small amount of funds at the time of disposal, is now cost-ing the U.S./California public many tens of millions of dollars in site cleanup/remediation. Unfortunately, this approach is still being used today by the currentuniversity administration in managing campus solid wastes.</p><p>The contamination of soils and groundwaters at the site was discovered and docu-mented in the mid-1980s, and the site was put on the NPL in 1994. In 1995, the DavisSouth Campus Superfund Oversight Committee (DSCSOC) was organized, with Ms.Julie Roth as its executive director. Drs. G. Fred Lee and Anne Jones-Lee were appoint-ed as TAG advisors to the DSCSOC in 1995.They have been active participants in siteinvestigation and remediation since that time.</p><p>While the focus of this article is on the LEHR site, the issues discussed have far widerimplications for evaluating the adequacy of Superfund site/hazardous chemical site investi-gation and remediation. It is the authors experience that problems of the type encounteredat LEHR occur in both the federal and state Superfund programs.Throughout this article,when the term hazardous chemical site is used, this terminology is designed to address bothnational and state Superfund sites, as well as other areas where there are hazardous or dele-terious chemicals that can be adverse to public health and/or the environment.</p><p>REGULATORY OVERVIEW</p><p>The regulation of the LEHR Superfund site investigation and remediation is being con-ducted under the supervision of USEPA Region 9 and several state of California agenciesincluding the California Department of Toxic Substances Control, the CaliforniaDepartment of Health Services, and the Central Valley Regional Water Quality ControlBoard. USEPA Region 9 and the California Department of Toxic Substances Control areresponsible for the overall Superfund site investigation/remediation.The Department ofHealth Services is responsible for overseeing the radiological site investigation/remedia-tion.The Central Valley Regional Water Quality Control Board is primarily responsiblefor groundwater quality investigation/remediation.</p><p>The investigation of the site has been jointly conducted by the Department ofEnergy, through its contractors, and the University of California-Davis, through its con-tractors. At about monthly intervals, the remediation program managers (RPMs) hold ameeting to discuss the results of the previous months activities and the plans for the nextmonth.The DSCSOC representatives and their TAG advisor participate in these meetings.</p><p>REMEDIATION Spring 2004</p><p> 2004 Wiley Periodicals, Inc. 35</p><p>It is the authors experiencethat problems of the typeencountered at LEHR occurin both the federal andstate Superfund programs.</p></li><li><p>They have generated numerous reports on deficiencies in the site investigation.These areavailable at the DSCSOC Web site, http://members.aol.com/dscsoc/dscsoc.htm.</p><p>PUBLIC PARTICIPATION IN SITE INVESTIGATION/REMEDIATION</p><p>At the USEPA national TAG meeting in Albuquerque, New Mexico, in late February2003, a number of TAG groups indicated that they had experienced opposition to a TAGgroup representative(s) participating in RPM meetings.The DSCSOC also experiencedthis problem at the LEHR site where the University of California-Davis opposed DSC-SOC participation in these meetings.With support of USEPA and the other site RPMs,the DSCSOC has been included in the RPM meetings. Since, ultimately, the publicshould support the Records of Decision (RODs) for site remediation, it is far better tohave the TAG group (or its equivalent, for non-TAG sites) representatives be active par-ticipants in the site investigation and planning of implementation as well as post-RODmonitoring and maintenance, including the five-year reviews of the site.</p><p>INADEQUATE DEFINITION OF CONSTITUENTS OF CONCERN</p><p>One of the most common significant problems with Superfund/hazardous chemical siteinvestigation/remediation is that regulatory agencies at both the federal and state levelsallow a very narrow definition of constituents of concern (COCs) compared to the poten-tial arena of hazardous or otherwise deleterious chemical constituents that could bepresent at the site. At sites like the LEHR site, where there is a wide variety of campus lab-oratory wastes that have been deposited at the site over many years, there can readily be asubstantial number of hazardous chemicals that are not on the Priority Pollutant list, aswell as those that are analyzed by conventional gas chromatography/mass spectrometry(GC/MS) procedures.There are about 85,000 chemicals in commerce today. A thousandnew chemicals are added each year.Typical waste investigations show that only a very smallpart of the total organic carbon present in wastes and groundwaters is identified.TypicalSuperfund site investigations focus on a few hundred potentially hazardous chemicals (pri-marily the Priority Pollutants) and largely ignore the many thousands of chemicals thatcould be present at the site that could be adverse to public health and the environment.</p><p>The Priority Pollutant list was developed without adequate professional and publicreview. It focuses largely on rodent carcinogens (chlorinated chemicals).The use of thislist by regulatory agencies is contrary to providing public health and environmental pro-tection, since it leads to a complacency on the part of the regulatory agencies in assumingthat, if the Priority Pollutants are not found in examining the site, then the site must notcontain any of the many tens of thousands of chemicals that could exist at the site.</p><p>Also, the approach that is used is to focus on chemical concentrations of a fewchemicals, failing to incorporate chemical impact assessment.There are a variety of bi-ological assessment techniques for potential carcinogens, teratogens, and mutagensthat have not been incorporated into Superfund site investigation/remediation.TheUSEPA held a conference devoted in part to Biological Test Methods (USEPA,1988b; Friedman, 1990) that reviewed the various approaches that were available toevaluate the potential biological impacts of hazardous chemicals.Testing proceduressuch as the Ames test, impacts on DNA, etc., could and should be incorporated intosite investigation and evaluation of the adequacy of remediation.</p><p>Improving Public Health and Environmental Protection</p><p> 2004 Wiley Periodicals, Inc.36</p><p>Typical waste investiga-tions show that only a verysmall part of the total or-ganic carbon present inwastes and groundwatersis identified.</p></li><li><p>Lee and Jones-Lee (1994) have discussed the significant underregulation of Super-fund site investigation/remediation arising out of following a narrow scope of definingconstituents of concern.The chemical concentration approach typically used at Super-fund sites can also lead to significant overregulation by focusing on total concentrationsof constituents, rather than toxic, available, and mobile forms. Far greater use of biolog-ical evaluation techniques should be made in Superfund/hazardous chemical siteinvestigation and evaluating the adequacy of remediation than is being done today.</p><p>Recently, perchlorate has r...</p></li></ul>

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