EPA - CERLA Overview
EPA Superfund Basics
National Priorities List
HRS Toolbox
EPA Region 2 Superfund
NJ Superfund Sites
EPA Superfund Price's Landfill Site
EPA Drinking Water Contaminants Information Page
EPA - Landfills
Solid Waste Assoc of North America (SWANA)
Pump & Treat Method
Monday, April 25, 2011
References and Resource Links
Donohue, J. (1979, December 18). Price’s Pit Evolution of a Dump Site. The Press of Atlantic City, pp. 1, 3.
Donohue, J. (1980, December 17). Toxic Chemicals Seep Towards Water Supply. The Press of Atlantic City, pp. 1, 10.
Donohue, J. (1983, March, 24). EPA Plans All New Wells for Resort. The Press of Atlantic City, pp. 1, 18.
Environmental Protection Agency. (1986). EPA Superfund Record of Decision: Price’s Landfill (EPA/ROD/R02-86/035). New York, NY: EPA Region 2 Office.
Environmental Protection Agency. (2010). Price’s Landfill: Site Summary (EPA ID#: NJD070281175). New York, NY: EPA Region 2 Office.
Environmental Protection Agency. (2010). Community Update: Price’s Landfill Superfund Site (December 2010). New York, NY: EPA Region 2 Office.
Environmental Protection Agency. (February 28, 2011). Superfund – Basic Information. Retrieved April 2, 2011, from http://www.epa.gov/superfund/about.htm
Environmental Protection Agency. (February 28, 2011). Superfund – Cleanup Process. Retrieved April 2, 2011, from http://www.epa.gov/superfund/cleanup/index.htm
Environmental Protection Agency. (October 20, 2008). Lead Health Effects. Retrieved April 2, 2011, from http://www.epa.gov/reg5rcra/ptb/lead/healtheffects.htm
Environmental Protection Agency. (November 6, 2007). Methyl chloroform (1,1,1-Trichloroethane). Retrieved April 2, 2011, from http://www.epa.gov/ttnatw01/hlthef/trichlor.html
Environmental Protection Agency. (October 13, 2010). Basic Information about Dichloromethane in Drinking Water. Retrieved April 2, 2011, from http://water.epa.gov/drink/contaminants/basicinformation/dichloromethane.cfm
Environmental Protection Agency. (June 14, 2010). Basic Information about Benzene in Drinking Water. Retrieved April 2, 2011, from http://water.epa.gov/drink/contaminants/basicinformation/benzene.cfm
Environmental Protection Agency. (October 13, 2010). Basic Information about Vinyl Chloride in Drinking Water. Retrieved April 2, 2011, from
http://water.epa.gov/drink/contaminants/basicinformation/vinyl-chloride.cfm
Environmental Protection Agency. Consumer Fact Sheet on: Cadmium. Retrieved April 2, 2011, from http://www.epa.gov/ogwdw000/pdfs/factsheets/ioc/cadmium.pdf
Environmental Protection Agency. (March 25, 2011). CERCLA Overview. Retrieved April 2, 2011, from http://www.epa.gov/superfund/policy/cercla.htm
Environmental Protection Agency. (March 25, 2011). How Sites are Placed on the NPL. Retrieved April 2, 2011, from http://www.epa.gov/superfund/programs/npl_hrs/nplon.htm
Environmental Protection Agency. (March 25, 2011). Introduction to the Hazard Ranking System. Retrieved April 2, 2011, from http://www.epa.gov/superfund/programs/npl_hrs/hrsint.htm
Grady, D. (1982, March). Troubled Waters in Atlantic City. Discover, 76-79.
Harper, D. (2010, May 26). Federal stimulus funds to build $16.4 million cleanup plant for Pleasantville's 'Price's Pit,' a former Superfund site. The Press of Atlantic City.
Harper, D. (2010, June 8). As cleanup nears, neighbors of Price's Pit superfund site still worry about long-term health effects. The Press of Atlantic City.
Janson, D. (1981, November 3). Atlantic City Rushing to Move Wells. The New York Times, pp. B1, B2.
My Take On Superfund and the Remediation of Price's Pit
While the $16 million provided for site remediation is substantial, that these costs were not able to be covered under the Superfund pool or from those responsible for the contamination is suspect. In 1988 those deemed responsible for the contamination on site, including Price, A.G.A., and generators of the waste, such as DuPont, Proctor & Gamble, and Union Carbide settled for $17.5 million to be paid out for the cost of site remediation (Janson, 1981) (Harper, 2010). The long duration between the settlement in 1988 and the final construction certainly increased cost for the construction of the system, and due to its high profile at the time of the discovery of the sites toxicity and the recent passage of Superfund, Price’s Pit should have been ideal to receive funding from the taxes collected under Superfund, to provide the remainder of the costs of remediation not covered through litigation with responsible parties.
The Superfund program was designed specifically with sites such as Price’s Pit in mind. The site directly impacted neighboring residents through contamination of their drinking water wells and posed an immediate threat to nearby well fields of Atlantic City. In addition to the threats posed by Price’s Pit, the site also demonstrated the preexisting sources that appear to have motivated Superfund program. The site was a former solid waste dump, prior to regulation, which also accepted chemical wastes. While the site was operating as a landfill, the effects of solid waste and industrial chemicals buried under the ground was largely unknown, making directly culpability of the impacts much less clear than modern cases in which those who generate or illegally dump the waste are held responsible (N. Goldfine, personal communication, April 16, 2011).
While the Superfund program seems able to identify sites that need remediation, develop remediation methods, and secure funding for the efforts, the case of Price’s Pit is an illustration that all programs have flaws. Based on EPA records, press on the site, and interviews with various parties involved in the cleanup (including Perry Katz, the EPA project manager for the site, Richard Dovey, President of the ACUA, Neil Goldfine, Executive Director of the ACMUA, and Joseph Donohue, former writer for the Atlantic City Press) it is apparent that the lengthy period from the listing of the site until present day, with remediation still yet to be completed, is a result of numerous internal and external problems impacting Superfund.
Initially the project appeared to receive very high priority and national attention in the media. Due to this one would have assume action on the site would have been swift. To some extent this is correct, as from the time the project was listed in 1983, access to public drinking water for neighboring residents and relocation of ACMUA well fields occurred by 1985. While this was in many ways the key aspect of the site remediation in that eliminated the most immediate threat posed by the site, it did not actually clean up the site by any means. Perhaps this was a significant cause for the delays in remediation, as once the serious threats were averted the priority for the site in the minds of the public, regulatory officials, and elected officials faded. Additionally, the site remains unique as the EPA and Superfund do not typically use relocation as a means of site remediation, but prefer treatment options. As a unique case, this could have contributed to the site dropping out of the priorities of the various parties concerned.
In addition to the notion that Price’s Pit became less relevant due to lack of immediate threats, it is also bureaucratic and public malaise that have contributed to the lack of completion of site remediation. While the environmental movement in the United States has been reinvigorated in the early part of the 21st century, toxic sites do not draw the level of outrage they did in the 1970s when the impacts of these sites were just being discovered. When remediation of a site drags on for over 15 years, and clear and present dangers are no longer in the public consciousness, apathy can set in. While once the public outcry was the motivating factor for the cleanup of these sites in the wake of Love Canal, now they seem to be of little consequence, and do not merit front page or national attention.
Delays and Current Updates
As of 2010 the additional pump and treatment of contaminated groundwater on site has finally just begun construction. Several factors had contributed to the lengthy delay of the remediation since the issuance of the Record of Decision in 1986 to the start of work in 2010. The design for the pump and treat system was nearly completed when the ACMUA refused to accept the treated discharge from the system. The NJDEP then reevaluated the using of infiltration basins for the discharge of treated water in 1993, creating another delay in process. The NJDEP then studied infiltration basin size and the impacts for the discharging the treated groundwater and monitor its effects on the treatment system from 1997 to 1999. Ultimately the study found that the infiltration basins were not effective methods for receiving the discharge, and it was abandoned. However the treatment system monitoring proved effective in addressing the contaminants in the groundwater. In 1999 design for a remediation pilot plant was completed by NJDEP and in 2001, construction was completed and testing began on the treatment pilot plan, with testing completed in mid-2002. The NJDEP began design work on the final remediation system in 2003, with the first phase of the design completed in 2005 and final completion of remediation design in 2010 (EPA, 2010).
In addition to the lengthy design period and hesitancy of where to discharge the treated water, other obstacles contributed to the delay implementation of the remediation efforts at the site. The change in leadership impacted how the project was implemented. As previously noted, many scenarios and methods were considered, and as new administrations were in control at NJDEP, their preferences for the site would often lead to modifications in the remediation design, contributing to the delays. As well as challenges in Trenton with NJDEP, discharging the treated water in the Atlantic County Utilities Authority’s (ACUA) system was not a simple solution either. The discharge of flows would be incurred onto a municipality’s flow rate, and determining if Pleasantville or Egg Harbor Township would claim the additional flows was one obstacle to overcome, in addition to meeting contaminant level requirements for tying into the ACUA’s system. Additionally, public apathy began to set in over time, while this was once a prominent issue that received national attention, the relocation of the ACMUA well field and city water service installation for local residents removed the immediate threats to public health, reducing the public’s concern over the following 15 years (Dovey, 2010).
In 2009 $16.3 million in American Reinvestment and Recovery Act (ARRA) funds had been granted to the Price’s Pit remediation process, as final design for the system was nearing completion and work set to finally begin. In late 2010 work began at the site including installation of piping discharge the water treated on site into the ACUA’s system (EPA, 2010). Construction on the system is expected to take two years. Once completed the system is expected to treat approximately 500,000 gallons per day and pump into the ACUA system. The treatment system will take 20 years to remediate the site, at which point the various wells could potentially be reclaimed by the ACMUA (Harper, 2010).
Initital Recomendations and Actions
In September of 1983 the site was added to the NPL. The site was added to the list based on the threat to the health of residents and that of the ACMUA well field. The threat of the groundwater contamination was so severe that the EPA called the risk “… the most severe environmental problem in the country” (Janson, 1981). Due to the severity of the problem Price’s Pit did not require HRS ranking or State declaration to be listed as other sites have required. Considering this significant threat, in addition to fencing off the site, the ACMUA well fields were recommended to be abandoned, and in the mean time a treatment system set up should the plume reach the field prior to new wells being online, and local residents using wells were provided with bottled water and then access to local city water (EPA, 1986). These control implemented prior to site remediation show the severity of the problem, since the potable water near the site was abandoned for use. In fact the abandonment and relocation of the ACMUA well field was a priority enough that the ACMUA began relocation efforts prior to acknowledgement of reimbursement from Superfund or other sources (Janson, 1981). Though the contamination of groundwater led the complete abandonment of the area for potable water purposes, residents and businesses remain in close proximity to the site.
The Record of Decision’s recommendation to relocate the ACMUA well field to a new location outside of the range of the plume from Price’s Pit also include four (4) alternative remediation methods for the site. The first alternative was to take no action, however considering the contaminants in the plume and its modeled path through the groundwater this was not considered a viable option. The second alternative required abetment of the plume via numerous groundwater pumps which would prevent the plume from reaching the well field, but would ultimately still allow significant levels of contaminants into nearby waterways and some of the wells, at which time these wells would be temporarily shut down until contaminant levels reached suitable concentrations. Options three and four both featured a containment wall, plume abatement, and option four added in flushing of the system. These options feature the method used in option two, as well as construction of an 80 foot deep containment wall to isolate the majority of the contaminant source at the landfill. Option four’s flushing system would reinject the treated water pumped from the groundwater wells back into the landfill, speeding up the natural processes of chemical leaching from the landfill (EPA, 1986).
These methods all had significant issues, either due to not sufficiently treating the problem, or the unreliability of the technologies when compared to the relocation of the well field. Ultimately the recommended alternative method was option two, which featured plume abatement. This was deemed preferable to no action since it prevented the deterioration of the aquifer under option one, and was more reliable and cost effective than options three and four, which provided additional mitigation, but at higher costs that did were not justifiable based on expected results. Additionally, with the relocation of the well field concern about concentrations of contaminants above required levels for drinking water were no longer at issue (EPA, 1986).
Example of a pump and treat system - National Academies Press
The initial remediation action for the site was the relocation of the ACMUA well field, this process, as previous discussed, was originally undertaken at the cost of the ACMUA without assurances from EPA or NJDEP of reimbursement on the relocation costs prior to the Record of Decision being released, and was completed by 1985 at a cost of nearly $10 million (Donohue, 1983). Additionally, the relocation of wells, as opposed to pump and treat options, has not typically been funded by the Superfund process, however, since this site work occurred recently after the implementation of Superfund, various political pressures caused the reimbursement of well relocation by EPA and NJDEP to occur, such that a prominent and successful case could be shown, which would not have occurred had pump and treat been the only mitigation option at Price’s Pit (N. Goldfine, personal communication, April 18, 2011).
Pollutants Found On Site
The EPA began remedial investigation at the site in January of 1982, lasting until May 1983 (EPA, 1986). Based on the initial investigation by the EPA the site was found to contain the following priority contaminants in the groundwater; heavy metals including lead and cadmium, and VOCs including benzene, chloroform, vinyl chloride, and methylene chloride (EPA, 2010). These hazardous substances were the result of landfilling both MSW and liquid chemical waste. These pollutants, especially due to the liquid nature of much of the waste traveled from the site in the groundwater plume had already reached residents neighboring Price’s Pit and were threatening to move to the nearby ACMUA well field.
Of the heavy metals found to be contaminating the site and groundwater, lead is a strong neurotoxin, which is especially dangerous to the cognitive development of young children, and can also cause significant kidney damages, and death in high enough doses (EPA, 2008). Cadmium has been found to cause the nausea, vomiting, diarrhea, cramps, convulsions, sensory and liver damage, and shock during short term exposure to elevated levels. Long term exposure to elevated cadmium levels has been found to cause severe kidney, liver, bone, and blood problems (EPA, 2011).
The VOCs found to be contaminating the groundwater at Price’s Pit have been found to have several known health impacts. Benzene is known to cause anemia or a decrease in blood platelets, Vinyl Chloride and Methylene Chloride have been found to cause liver damage, and all three pose significantly increased cancer risk (EPA, 2010). Chloroform has several known human health impacts, including hypotension, mild hepatic effects, motor impairment, lightheadedness, dizziness, nausea, vomiting, diarrhea, loss of consciousness, and decreased blood pressure occur from acute exposure. While chronic exposure to Chloroform does not have any known effects due to low level exposure, however animal testing has indicated that increased liver and neurological damage is likely as well as increased risk of cancer from longer term exposure (EPA, 2007).
Price's Pit History
The Superfund process appears in many ways to be long, complicated, and thorough process; a polluted site is not simply brought into the Superfund program once hazardous materials are discovered on site. Price’s Pit is an excellent example of the lengthy process involved when a site enters the Superfund program. The Price’s Pit site is located on 26 acres of Egg Harbor Township and Pleasantville along Mill Road, in Atlantic County, NJ. The site was originally used for a sand and gravel excavation business owned by Charles Price. Price’s excavation operations ceased in 1968, as the excavation had come to within two feet of the groundwater table (EPA, 1986). After the termination of excavation operations, in 1969 Price opened the site up as a solid waste landfill for municipalities in the area, Absecon, Atlantic City, Brigantine, Ventnor, Pleasantville, and Egg Harbor Township. At the time effects on the environment of landfilling household garbage (MSW) as well as other chemicals was largely unknown to both the regulatory community and the public at large (R. Dovey, personal communication, April 12, 2011). Therefore unlike other Superfund sites where the disposal of hazardous waste was largely unknown while it was occurring, and may not have been discovered until environmental impacts were observed, this site was always known to contain waste substances.
In addition to the MSW received at Price’s Pit, the site also began to receive liquid wastes, including oil, sludge, greases, septic wastes, and industrial chemicals in 1971. These chemicals were disposed of via both drummed (though often leaking) containers and directly poured into the landfill. Over 9.1 million gallons of chemical waste are estimated to have been disposed of at the site (EPA, 1986). The site ceased operations in 1976 under direction of the State and Price ultimately sold the site in 1979 to A.G.A Partnership. Both of these parties, including Price’s wife and brother who also held a stake in the site, were brought up on charges in 1980 holding them responsible for the cleanup costs of the site (Diamond, 1980). Since the site was always publicly known to be taking solid waste, and discovered to be taking liquid and chemical waste in the early 1970s, it wasn’t until well samples taken at the site in 1973, 1974, and 1976 indentified several state water quality violations that the site began to gain significant attention (Donohue, 1979) (Janson, 1981) (Grady, 1982). In 1980, tests of surrounding residential wells found significant contamination from Volatile Organic Compounds (VOCs) and the Atlantic County Health Department recommended that the residents no longer use these wells for potable water (EPA, 1986). In addition to the impacts on the local residential wells from the contamination, the Atlantic City Municipal Utilities Authority (ACMUA) had a large well field in the vicinity; the closest of the ACMUA’s 13 wells was only 4,000 feet from the contaminated site. The well field provided Atlantic City with its needed potable water supply, over 11 million gallons daily. At the time the site began to receive significant in national attention the well field had not yet been contaminated (Donohue, 1980), however studies indicated the toxic plume from Price’s Pit would reach the well field by 1983 (Janson, 1981).
What is Superfund
When established the Superfund program initiated a tax on chemical and petroleum industries to, thus creating a “super-fund” to cover the costs of cleaning up abandoned or otherwise unsupervised hazardous waste sites throughout the country. (EPA, 2011) CERCLA provides authority to the Environmental Protection Agency’s (EPA) Office of Solid Waste and Emergency Response (OSWER) to remediate sites under the Superfund program. In addition to creating the fund for cleanup of these sites (when the responsible person(s) are not identifiable, unavailable or, unable to provide clean up) CERCLA also creates rules and restrictions for closed and abandoned hazardous sites, as well as rules of liability for responsible parties to the contamination to assist in the cleanup process. The program is able to respond to both short term emergency threats that need immediate action, as well as longer term programs, which may require significant site remediation, but do not pose an immediate threat to the lives of residents in close proximity to the site. (EPA, 2011)
For sites to be remediated under the CERCLA and the Superfund process, they must be placed on the National Priorities List (NPL). There are three methods by which a site can be placed on the NPL; the first is the Hazard Ranking System (HRS). The HRS examines both risk and pathways of contamination to determine through a complex formula to what extent a site poses a threat to human health. These risks include; the possibility that the site has or will release hazardous substances into the environment, the type and quantity of the materials disposed on site, characteristics of the waste (e.g. toxicity and waste quantity), and the potential number of people impacted by an existing or future release. In addition to the risk assessment the HRS also examines the pathways of contamination; ground and surface waters, soil, and air. (EPA, 2011)
In addition to the ranking received via the HRS sites can also be placed on the NPL based on two other mechanisms. State or Territorial authorities are able to designate one site on to the NPL, regardless of how it is scored on the HRS. Lastly, sites can be placed on the NPL if they meet the following three criteria; a health advisory is issued by the Public Health Services recommending evacuating residents from the site, the EPA deems the site as posing a health threat, and the EPA determines it to be more cost effective to remediate the site via Superfund than to remove effected residents. (EPA, 2011)
The Superfund process has many steps, and can be very lengthy, from discovery of a site through final remediation and delisting from the NPL. After a site is initially identified it first goes through a Preliminary Assessment and Inspection to determine the extent of release of hazardous compounds, and if an immediate emergency response is required. If an immediate response is not required the site goes for review if it should be placed on the NPL, under the processes previously discussed. Once placed on the NPL the site will undergo a feasibility study for remedial work, to determine the specific causes and severity of the pollution on site, what methods can be used to treat the contamination, the costs of the remediation. After these studies are complete a Record of Decision is issued indicating what remediation methods will be used at the site and why. (EPA, 2011)
At this point the site enters into the remediation design and action phase, in which the chosen method for cleanup is undertaken from a technical perspective both design engineering of the process and actual, physical work at the site. After the remediation action is finished the site is designated “Construction Complete” this indicates that the onsite work is completed, however the full remediation of the site may yet to be achieved to designated levels of contamination. From this point the site moves into post-construction action, assuring the future protection of the site and long term plans, to maintain the site, with site reviews at designated intervals. If at this point the remediation actions have been successful the site can be removed from the NPL and redevelopment of the site can occur to extent that is suitable in each specific situation. (EPA 2011)
Introduction
The industrialization and commercialization of modern society has resulted in many benefits to the average person and human wellness as a whole; longer life spans, increased quality and availability of healthcare, more leisure time, and ever increasing technology to make our lives more efficient. However, in addition to all the of the benefits industrialization and commercialization have had on our society there have been many unintended negative consequences, specifically the side effects that have come to be known that these industrial and manufacturing processes have on our environment and people in general. As many of these consequences have been discovered, controls have been put in place to mitigate their impacts on human health and the environment. Perhaps one of the most difficult consequences to tackle has been the proper handling and disposal of our waste. Both ordinary household waste and various forms of industrial waste pose a threat to our health and the environment if not properly handled.
Since the beginning of the industrial age the typical methods for removing waste, both household and commercial had been to bury it (now known as landfilling) or burn it (incineration). These processes were initially done with little knowledge of their impacts on the environment, and in turn how those impacts affected human health. Burning the waste would release many of the chemicals found in the material into the air, which pose human respiratory risks. Landfilling the waste was done in an unregulated fashion, with generators of the waste often oblivious to where the material was going, and what happened to it once it was buried in the landfill. The material deposited in these landfills, either industrial or household waste, would leach harmful compounds into the surrounding soil and more dangerously, the groundwater, which posed a significant threat to anyone who lived in the surrounding area and used well water.
(Rendering of a modern landfill - Solid Waste Authority of Central Ohio)
The beginning of the environmental movement in the 1970s sparked a great deal of public concern for our impacts on the environment and consequently our own health. One of the programs to come from this increased concern was the Superfund Program or CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act). Superfund was established in December of 1980 as a method for the government to respond to threats to the environment or public health from contaminated sites. Specifically, the program was instituted after the Love Canal and Times Beach toxic sites discoveries in the 1970s. (Environmental Protection Agency [EPA], 2011) In Southern New Jersey, one of the earliest sites to receive attention of the Superfund program was Price’s Landfill (also known as Price’s Pit), former gravel pit turned landfill which was located along the border of Egg Harbor Township and Pleasantville, and was very close to several public drinking water wells. The proximity of these wells to the drinking supply of Atlantic City made the site a national headline (Janson, 1981).
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