CERCLA sites

The aquatic fate of contaminants released from the CERCLA site as well as those transferred to surface water from other media beyond site boundaries must be considered. 

The technical differences between site problems at RCRA facilities and CERCLA sites sometimes may be difficult to distinguish, owing to similarities in present or past uses of the site, in hydrogeologic setting, and/or in the types of substances disposed, spilled, or otherwise managed at the site. Consequently, many technical aspects of the study and remediation of releases of hazardous wastes and constituents from RCRA facilities often will closely parallel those at Superfund sites, and cleanups under both statutes must achieve similar goals for protection of public health and the environment. Additionally, activities which would be termed removal actions or expedited response actions under CERCLA may be undertaken by owners and operators under RCRA. In the RCRA context, such actions are termed interim measures, as will be discussed in subsequent chapters. 

CERCLA Site Discharges to POTWs Treatability Manual, August 1990 540/2-90-007 ERIC W570 NTIS PB91-921269 Disk PB91-507236. 

CERCLA Site Discharges to POTWs CERCLA Site Sampling Program -Detailed Data Report, May 1990 540/2-90-008 ERIC W515 NTIS PB91-921270. 

For other CERCLA sites the proeess ean be very different from the typieal DOE site. The proeess may start with various phases of site assessments. The intermediate step may be a pilot study, followed by a pilot plant operation, or possibly a removal aetion or other alternative. The final steps may vary widely. However, just as in DOE sites, the appropriate rule or requirement depends on the site-speeifie faeility or operation, the assoeiated hazards, and the potential for worker exposure to the hazards. For the Army Corps of Engineers eleanup or oversight, the rules will most likely be even more stringent than for OSHA or DOE. 

Once hazardous wastes are transported from a CERCLA site, they are subject to full RCRA regulation. Therefore, all transportation and TSD requirements under RCRA must be followed. This means that off-site shipments must be accompanied by a manifest. In particular, the off-site disposal of hazardous wastes can occur only at an RCRA facility in a unit in full compliance with the requirements. U.S. EPA policy requires that the disposal facility be inspected six months prior to receiving the waste. 

For off-site land disposal of wastes resulting from a CERCLA activity, the program contains two additional requirements. First, the unit in which the wastes are to be disposed must not be releasing hazardous wastes or constituents into groundwater, surface water, or soil. Second, any releases from other units of the facility must be under an approved RCRA corrective action program. This policy assures that wastes shipped off-site from CERCLA sites are sent to environmentally sound waste management facilities. 

Both removal and remedial actions may be carried out at the same site. To accomplish these tasks, CERCLA has given cleanup authority to U.S. EPA, has established the Hazardous Substance Response Trust Fund (Superfund) to finance the remedial actions at CERCLA sites, has initiated a procedure for the emergency response to accidental spills, and has imposed cleanup liability on those responsible. The National Contingency Plan (NCP) was developed in 1982 and in 1985 as the regulatory framework to guide these responses. 

The RCRA and SDWA groundwater quality standards are considered applicable, relevant and appropriate requirements for purposes of CERCLA cleanups. Thus, the EPA may require CERCLA sites to be cleaned up to the degree that groundwater quality around the site meets the RCRA and SDWA groundwater quality standards. 

Forrester Environmental Services, Inc. s heavy-metal stabilization technologies have been issued several U.S. patents and are commercially available in the United States and Japan. The vendor claims these technologies have been permitted by the U.S. Environmental Protection Agency (EPA) and have been used at resource conservation and recovery act (RCRA) and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) sites in several states. In addition, these technologies have been implemented at U.S. Department of Defense (DOD) facilities. 

First of all, the CERCLA requires all hazardous waste releases over a prescribed threshold, known as reportable quantities (RQs), to be reported to National Response Center. Action is taken from that point to determine if it will be a CERCLA site. The CERCLA also established development of a National Contingency Plan. This plan includes all procedures for handling hazardous waste in the United States. The act also requires the creation of an uncontrolled hazardous waste site ranking system (HRS). The HRS determines if a site should be placed on the National Priorities List (NPL), which is a list of all the Superfund sites. 

The USEPA established a National Remedy Review Board in 1995 to review all remedies. This board has saved an estimated 31 million, and future cost reductions of more than 725 million are expected (USEPA, 1998b). The remedial investigation (RI) will also include identification of "applicable or relevant and appropriate requirements" (ARARs). These are remediation standards, standards of control, or other criteria or limitations developed by federal or state law. Applicable requirements are those that have been previously used at a CERCLA site for the same waste. Relevant and appropriate requirements are those not formerly used for waste at a CERCLA site but which address the problem. Advisories and guidance to be considered can also be issued, but they are not as binding. 

USEPA] US Environmental Protection Agency. 2002. Guidance for comparing background and chemical concentrations in soil for CERCLA sites. Washington Technical report EPA 540-R-01-003, OSWER9285.7-41. 

Establishment of Cleanup levels for CERCLA Site with Radioactive Contamination OSWER Directive 92004.18 ERA 1997b... 

EPA. 1997b. U.S. Environmental Protection Agency. Establishment of cleanup levels for CERCLA sites with radioactive contamination (memorandum and attachments). OSWER No. 9200.4-18. Office of Solid Waste and Emergency Response. Office of Emergency and Remedial Response. http //www.epa.gov/superfund/... 

In addition to releases from the various components or activities that make up the production and distribution system for petroleum products (the oil system), many older waste sites show TPH-related site contamination. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) site descriptions often mention petroleum, oil and grease, or petroleum, oil, and lubricants (POL) as present at a former waste disposal site. An example is given below for a waste oil recycling site, where TPH-type chemicals were obviously a common site contaminant. The CERCLA clean-up actions, however, focus on a range of specific hazardous or toxic chemicals. Some of the specific chemicals (e.g., toluene) would show up in a TPH test, but the chlorinated solvents and metals do not. Since a site cannot be prioritized for CERCLA attention if the only problem involves TPH site... 

Waste disposal from CERCLA sites must be managed in accordance with regulations outlined in subtitle C of RCRA. For instance, generator/regulator statutes would regulate wastes taken off-site for treatment. This would entail the proper labeling of all material as well as hazardous-waste manifests. In addition, any waste treated or stored on-site must be handled in accordance with TSDFs. 

Figure 14.1. Most commonly encountered metals at Superfund (CERCLA) sites in the United States. The numbers represent the sites, and % indicates the percentage of sites relative to the total Superfund sites assessed. (Data from Ma and Kingscott, 1997 Green and Hoffnagle, 2004.)...

Figure 14.3. Remedial actions undertaken at Superfund (CERCLA) sites (1982-2002) for source control. The numbers in parentheses reflect the number of sites where remediation has been conducted, and % is the proportion relative to the total remediated. (From U.S. EPA, 2004b.)...

CERCLA Site Discharges to POTWs Treatability Manual... 

These criteria are used to determine the feasibility of using the electrokinetic technology at CERCLA sites. Electrokinetic technologies are expected to protect human health and the environment by concentration, removal, or destruction of contaminants in soils, sediments, and groundwater. Overall reduction of human health risk should be evaluated on a site-specific basis because contaminants may change speciation or mobility. For example, volatile organic compounds (VOCs) could be stripped from the soil during treatment and could increase soil vapor... 

CERCLA site cleanups require that other environmental laws be considered as appropriate to protect human health and the environment. 

A summary of U.S. groundwater analyses from both federal and state studies reported that tetrachloroethylene was detected in 14-26% of all samples analyzed (Dykson and Hess 1982). In a comparison of groundwater data from 178 CERCLA sites, tetrachloroethylene was detected in 36% of the samples and was the second most frequently detected organic groundwater contaminant in the CERCLA database (Plumb 1987). Tetrachloroethylene was detected in 179 of 421 groundwater samples in New Jersey between 1977 and 1979, at a maximum concentration of 90.6 ppb (Page 1981). 

CH2M Hill (1991) House dust remediation report for the Bunker Hill CERCLA site populated areas RI/FS. Idaho Department of Health and Welfare, Boise, ID. 

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