Saving Superfund Proposed changes to the Superfund process based on the relative successes and problems of Tar Creek and other Superfund sites
Research Objectives • Review the process for site clean ups established by CERCLA • Analyze the actions taken at Tar Creek and other Superfund sites for successes and problems • Recommend implementation of additional procedures
Methods • Researched Tar Creek Superfund Site • Gathered information on CERCLA guidelines and procedures • Researched other Superfund Sites that have been successfully treated and deleted from the NPL
Background Information The Mining of the Tar Creek Area
Tar Creek Background Information • Part of the Tri-State Mining District • Kansas, Missouri • All Superfund Sites • Lead, Zinc, and Cadmium
Effects of Mining • Open shafts • Underground caverns • Allowed to fill with water • Minerals and metals leached from rock • Chat and tailings • left in piles • left in floatation pools
Effects of Mining • Water became contaminated • Reddish color noticed • Chat removed from mining site and used • Pavement • Playground surfaces • Parking lots • Residential Driveways
EPA & DEQ Response
Timeline of Events: OU1 • 1983 - EPA names Tar Creek Superfund Site to National Priorities List. • 1984 - EPA begins work on OU1 • Address surface water contamination from discharge of mine water and threat of contamination to Roubidoux Aquifer from opened abandoned wells. • 1984-1986 - Plugged 83 abandoned wells, built dikes, divert surface water around mines and collapsed mine shafts.
Timeline of Events: OU2 • 1995 - IHS reports high blood lead levels in Indian children • 35% had elevated levels • Countywide testing shows >30% had elevated levels • EPA finds tailings in residential properties • 1995-2003 - Soil samples collected, remediation on properties carried out • $100 million on over 2,000 locations • Reduced blood levels result
Timeline of Events: OU3 • 1989-1999 - Quapaw Tribe requests EPA investigate the abandoned Eagle Picher Industries mining lab. • 120 deteriorating containers of lead recovery chemicals found • Containers disposed of • Cost $55,000
Timeline of Events: OU4 • Recent - EPA and US Department of Justice begin remedial investigation and feasibility study (2000) • With Department of Interior, Blue Ter, and Gold Fields • 1st action to identify nature and extent of contamination and evaluate options for clean up
Overview of the Superfund Process
The Superfund Process Hazard Ranking & NPL Remedial Investigation & Feasibility Study Preliminary Assessment / Site Inspection Site Discovery Select Remedy Operation & Maintenance Remedial Action Remedial Design NPL Deletion
The Superfund Process • Enforcement and Public Participation occur throughout the process • Removal and Remedial Action occur throughout process as necessary • Removal action: removing substances, excavating contaminated soil, installing security measures, providing alternate drinking water • Remedial action: study, design, constructing long term actions for permanent remedy. Include constructing underground walls to control groundwater movement, incinerating waste, applying bioremediation.
General Observations • Superfund process is not rigid • Allows for flexibility for multiple problems • Allows for some important aspects to be overlooked
Successful Programs Implemented at Tar Creek
Community Education Program • EPA/DEQ began campaign to inform residents of hazards • Hand Washing • No swimming and or playing in creek • No drinking from wells/natural sources until water supply was tested • Brought in alternate water supply for testing period (Removal Action)
Community Education Program • Effects • Blood lead levels decreased • Potentially hazardous activities decreased or stopped, lowering risk of exposure • Problems • Started late into the process
Suggestion • A Community Education Program should be one of the firsts steps of a Superfund Process • Community has a right to be informed of what is going on, and educated in how to minimize effect, as soon as potential problems are identified
Chat Removal • Chat coverings were removed and replaced • Chat piles shrank as chat was sold for use in cement and concrete • Effects • Reduced Blood Lead Levels • Removing chat will improve groundwater quality • Cannot be used by people for recreation, and wind will not lead to further contamination
Chat Removal - Problems • Chat Removal Process did not start until 1995 • Cherokee Creek, KS • Quapaw have only recently been allowed to sell chat • Though piles are shrinking, they still exist
First Suggestion • When a site is discovered, air, wind, soil, and human blood level testing should be performed at the outset • Information should be collected to check for exportation of hazardous materials
Second Suggestion • “Temporary Cover” of areas that are contaminated and cannot be removed • Due to size or governmental issues • Temporary seepage limited, and materials used for cover can be re-used to cap the area under the piles • Silver Bow Creek, Chisman Creek, Ohio River park
Negative Aspects of the Processes Used at Tar Creek and Superfund Policy
State Intervention • Is usually a beneficial aspect for any Superfund Site • It started years after problem was identified • Usually due to lack of progress • Eventually occurs at sites where a PRP is not found • Improves funding and public awareness
Suggestions • Once a site is listed on the NPL, bring the issue to State Legislature • Begin public awareness and funding drive immediately • States should adopt emergency funding measures in case of a hazardous release • Currently 431 schemes in 44 states, with $3.2 billion revenue
Remedial Investigation and Feasibility Study • RI/FS currently has three goals • Reduce Toxicity • Reduce Mobility • Reduce Volume • Aims to control acute threats immediately
RI/FS Problems • Sometimes focuses on fixing the problem, rather than preventing the problem from increasing or spreading • Does not have a policy outline for chronic threats
Suggestions • Divide RI/FS into two parts • One group focuses on treating problems that exist • Second group focuses on preventing problem from spreading or increasing • Implement a policy for treating chronic threats, based on how long the population has already been exposed
Communication and Division Between Regions • EPA is divided into several regions • Oklahoma is in a separate region than Missouri and Kansas • Separate districts treating the same problem in different ways • Cherokee Creek – removed contaminated soil first
Resulting Problems • A beneficial action may be taken in one area, but not be considered in another area with the same problem • Funding for research and remediation is split among parties, becoming less effective • Several completely different solutions may be implemented partially to treat one problem
Suggestions • When a problem affects multiple regions, the regions involved should try to cooperate as a group, and focus on the entire problem • States should try to collaborate in funding and researching solutions • When an action is taken in one area, and proven beneficial, other states and regions with similar problems should be alerted
Summary • Superfund does not have a rigid structure • Good for flexibility • Could result in important aspects being overlooked • Several additional measures could be implemented to the Superfund Process to increase effectiveness in preserving human health and treating pollution
Summary of Proposed Suggestions • Community Education Programs should be implemented once a site is placed on the NPL • When contamination is noticed in one medium, air, soil, water, and human exposure levels should be investigated immediately to determine cross contamination
Summary of Proposed Suggestions • Extent of removal of hazardous materials should be investigated • Contaminants that will take time to remove due to size or restrictions should be treated with a temporary cover systems • State legislatures should be notified of areas on the NPL
Summary of Proposed Suggestions • States should begin raising funds and notifying public immediately, regardless of presence of PRP • Divide RI/FS into two parts, one focusing on treatment, the other on prevention of further contamination • Construct a policy for treating chronic threats
Summary of Proposed Suggestions • Superfund sites with similar problems should collaborate to research effective treatments, raise funds, and educate the public • Communication between similar or related sites should be increased
Conclusion • Several new steps could be added to the Superfund Process to increase the program effectiveness • Superfund sites should be constantly reviewed in order to determine new beneficial measures that could be added to the Superfund treatment process • Always treat Superfund as a work in progress
References • Ranking Hazardous Waste Sites National Resource Council • Beyond Superfailure D. Mazmanian and D. Morell • Rethinking Superfund A.J. Obadal et al, NLCPI • Cleaning Up the Mess T. Church and R. Nakamura • Fixing Superfund Lloyd S. Dixon • An Analysis of State superfund Programs:50 State Study, 1990 Update EPA September 1990 • Private sector Cleanup Expenditures and Transaction Costs at 18 Superfund Sites L. Dixon, D. Drezner, J. Hammitt • Superfund Program Implementation Manual, FY 1993 EPA 1993 • The Superfund Program: 10 Years of Progress EPA 1991 • Environmental Protection at the State Level E. J Ringquist
Special Thanks • Dr. Deborah Dalton • Dr. Bob Nairn • Judy Duncan • Mary Ellen Turris
Questions?
