Free Notice of Additional Authority - District Court of Federal Claims - federal

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Systematic planning is a process based on the scientific method for developing a framework for the effective use of dynamic work strategies and real-time field measurement and analytical technologies. It is a process for developing defensible site decisions by managing the uncertainties or unknowns that could cause decision errors. A typical systematic site plan would include collaboration of decision-makers with stakeholders, a clear statement of project goals, a multi-disciplinary technical team to develop realistic technical objectives that will achieve the goals, and the development of one or more conceptual site models that depict what is already known about the site and identifies what additional information and analysis will be needed to achieve the project's goals. The CSM can be used to direct field work, as a tool for planning and organizing work and interpreting data, and as a communication device. The integration of systematic planning, dynamic work strategies, and real-time measurement technologies is often referred to as the Triad approach to planning and implementing data collection and technical decision-making at hazardous waste sites. More information on the theory and application of the Triad is available on an EPA web site (http://www.cluin.org/triad). Exhibit 13-2. Examples of Common Field Analytical Technologies

Technology

Description
Sample Analysis Tools

Test Kits

Measures select organic chemicals and classes of chemicals using immunoassay colorimetric techniques. Measures inorganic cations and anions and some organic chemicals in water using colorimetric techniques. Measures the presence or absence of DNAPL chemicals using dyes. Inorganic colorimetric techniques that use spectrophotometers are generally quantitative techniques. Immunoassay are generally semi-quantitative. Measures selected cations and anions in water. Can be deployed in situ or ex situ. In-situ measurements of the presence of chemicals or classes of chemicals using chemical specific cladding placed in water or exposed to vapors. Generally considered semi-quantitative. Measures the presence of volatile and semivolatile organics and some inorganics in soil gas (volatiles), soil, and water. Depending upon level of sample preparation and QA/QC imposed can be quantitative or semiquantitative. Is used in soil and water analysis for total extractable hydrocarbon analysis in the field.

Ion Specific Electrodes Fiber Optic Chemical Sensors

Gas Chromatography

Infrared Spectroscopy

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Exhibit 13-2. Examples of Common Field Analytical Technologies (Continued)

Technology
Open Path Air measurements

Description
In open-path Fourier transform infrared spectroscopy can provide a quantitative average of various chemical concentrations in air over a predetermined distance. In open-path UV differential absorption can provide a quantitative average concentration of a limited number of chemicals in air over a predetermined distance. In open-path differential absorption lidar can provide a quantitative concentration of a limited number of chemicals (one at a time) in air at a predetermined distance which allows the construction of isopleth contour maps. In open-path Raman spectroscopy can, at close distance, detect a variety of chemicals in air (average concentration) or on a soil or building surface. Generally employed as a tool for locating petroleum hydrocarbons (polycyclic aromatics) in situ, using direct push technologies to drive it into the subsurface. Can be used in conjunction with a GC to provide quantitative speciation of organic chemicals in gases, soil, and water. As a stand alone instrument employing ion trap mass spectrometry, it is used to measure organic compounds brought to the surface by a membrane interface probe mounted on a CPT rig. Depending on the rigor of the sample preparation technique used provides screening to semi-quantitative determinations of metals in soil and water. In the screening application the metal concentrations can be measured in situ at the ground surface with little sample preparation. Has had very uneven success in locating LNAPL plumes and is not chemical specific. In specific settings can be used to delineate the extent of an electrically conductive plume.

Laser-Induced Fluorescence Mass Spectrometry

X-Ray Fluorescence

Ground Penetrating Radar Electromagnetics/ Resistivity for Environmental Applications

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Exhibit 13-2. Examples of Common Field Analytical Technologies (Continued)

Technology

Description
Sample Access and Collection Tools

Direct-Push Analytical Systems (using rig)

Laser induced fluorescence probe uses fluorescence intensities to determine the relative presence of petroleum hydrocarbons (polycyclic aromatics) in soil. Membrane interface probe uses a heated permeable membrane to volatilize chemicals in soil and groundwater while applying a vacuum that brings them to the surface for analysis. Halogen specific probe uses a heated membrane to volatilize chemicals in soil and groundwater while applying a vacuum that draws them across a halogen specific detector located in the probe. Conductivity probe used to determine changes in lithology or conductivity changes that may be related to a change in the chemical makeup of soil and water. Single point systems that are capable of providing access to groundwater at a predetermined depth. The groundwater is recovered by bailer or pump and brought to the surface for subsequent analysis. The system has to be withdrawn and cleaned before it can be driven to another depth. Multi-point systems that are capable of providing a vertical profile of groundwater at a single station. The groundwater is sampled using a pump and the system is driven further into the subsurface. A sample probe in driven or vibrated into the ground using a hammer or hand held driver. A vacuum is applied to the probe and soil gas is drawn to the surface. The gas can be measured directly at the probe using a syringe and portable GC or can be collected in a container for subsequent analysis by GC or GC/MS instruments located on- or off- site.

Direct-Push Geotechnical Sensors Direct-Push Groundwater Samplers

Direct Push Soil-Gas Samplers (without rig)

Geophysical Tools
Electromagnetic An electromagnetic field is introduced into the ground which causes a current to flow that in turn produce a secondary electromagnetic field which is measured by a receiving unit. Most of the instruments in this class essentially measure a change in subsurface conductivity and are used to aid in conceptualizing the subsurface stratigraphy, identifying potential leachate groundwater plumes, and in some modes locating buried drums and piping. Methods include terrain conductivity, horizontal loop, very low frequency em, and time domain. Electrical currents are injected into the ground and the patterns of subsurface flow indicate the resistivity or conductivity of the material the current is flowing through. This technique is generally used to aid in conceptualizing the subsurface stratigraphy. This method measures the change in the subsurface magnetic field as the instrument is moved across a site. Its primary use is in locating magnetic objects such as buried drums.

Resistivity/ Conductivity

Magnetics

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Exhibit 13-2. Examples of Common Field Analytical Technologies (Continued)

Technology
Ground Penetrating Radar

Description
In this method electromagnetic energy is pulsed into the ground where some of the energy is reflected by a change in strata while the rest passes through the layer. The instrument relates the time of reflection to the depth of the reflector and a cross section of subsurface reflectors is plotted. GPR can be used to locate the groundwater table, find buried objects, and contribute to the conceptualization of the subsurface stratigraphy. An acoustical wave is generated in one area. The wave propagates through the subsurface with some of it being reflected or refracted when there are changes in the subsurface and the rest continue on. Geophones are used to measure the time of arrival of the reflected or refracted sound and this is used to plot changes in the stratigraphy. These techniques are generally used to aid in conceptualizing the subsurface stratigraphy.

Seismic

13.3 Factors Affecting Demand
To understand the direction of the market for site characterization technologies, it is important to examine the factors that are driving the demand for these technologies. · Because site characterization is a critical component of all remediation efforts it is expected to account for a significant amount of work, although it is only a minor portion of the over $200 billion cleanup market. The overall demand for remediation services is expected to be stable over the next decade. · The strong market for redevelopment of Superfund, brownfields, and other sites will likely foster demand for additional site assessments. · The growing practice in the real estate industry (property purchasers, developers, and
lenders) of conducting site assessments as part of standard due diligence activities at
commercial properties may increase the demand for site assessment, primarily Phase One
and Two type assessments.
· A number of case studies have demonstrated that the use of field analytical technologies can substantially reduce the cost and time to complete site investigations and improve the confidence of the results (Exhibit 13-3). Because these technologies have lower costs per sample, they permit higher sampling densities than is affordable using traditional laboratory analysis. Higher densities generally lead to a more complete and appropriate CSMs that facilitate effective remedy design and implementation.

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· When combined with systematic planning and dynamic work strategies, real-time field measurement and analytical technologies can significantly reduce the overall cleanup costs at many sites and provide better site characterizations. For example, during remedial action, field technologies can provide accurate data that allow the site crew to rapidly adapt to new information, thereby realizing significant savings in dollars and time. Exhibit 13-3 provides examples of successes of newer approaches at specific sites. Exhibit 13-3 Examples of Projects with Savings and Efficiency Improvements Associated With Advanced Site Characterization Technologies
· The site characterization and cleanup approach used at the Wenatchee Tree Fruit Test Plot, resulted in savings of 50% over traditional site characterization and remediation methods which rely on fixed-based laboratory analysis with multiple rounds of mobilization and demobilization. The approach used a combination of field analytical technologies, a dynamic work plan, and systematic site management. (U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Innovation in Site Characterization Case Study: Site Cleanup of Wenatchee Tree Fruit Test Plot Site Using a Dynamic Work Plan, EPA 5420R-00-009, August 2000. http://clu-in.org/char1_edu.cfm#site_char). · At the Hanscom Air Force Base in Middlesex County, Massachusetts, the original site investigation failed to find some contamination sources. As a result, a pump-and-treat system was operated for five years without achieving a sufficient reduction in pollutant concentrations. To better characterize the site, site investigators used field analytical instruments in the context of a dynamic work plan that relied on an adaptive sampling and analysis strategy. The project demonstrated that this approach could substantially reduce the cost and time and improve the confidence of the results of site investigations. (U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Innovation in Site Characterization Case Study: Hanscom Air Force Base Operable Unit 1 (Sites 1, 2, and 3), EPA-543-R-98-006, September 1998. http://clu-in.org/download/char/hafbcs2.pdf). · A demonstration of several surface geophysical and direct push technologies at New York State Electric & Gas Company's Court Street Manufactured Gas Plant Site in Binghamton, New York, concluded, in part, that CPT/DP offered an excellent alternative to traditional investigation methods both in terms of cost per borehole and the information provided (EPA 2002). · At Florida drycleaning sites, site characterization costs have been reduced by an estimated 30 to 50 percent when compared to conventional assessments. The state conducts rapid site characterizations using on-site mobile laboratories and direct push technologies to characterize soil and groundwater contamination, assess cleanup options, and install permanent monitoring wells, all in an average of 10 days per site (Applegate 1998). · Argonne National Laboratory's Adaptive Sampling and Analysis Programs (ASAP) makes hazardous waste site characterization and remediation more effective and efficient by relying on real-time data collection and field-based decision-making within the framework of dynamic work plans. Argonne has documented cost savings of more than 50 percent as compared to more traditional sampling programs (U.S. DOE 2002). · ASAP data collection efforts have been used at Sandia National Laboratories and Kirtland Air Force Base in New Mexico; Brookhaven National Laboratory in New York; Argonne National Laboratory and Joliet Army Ammunition Plant in Illinois; and several Formerly Utilized Sites Remedial Action Program (FUSRAP) sites. In addition to providing better characterizations than traditional approaches, these programs cost 30% to 70% less (U.S. DOE 2002). · DOE reports that recent work at the Fernald site as part of its soil excavation program has shown that the use of real-time data collection technologies and decision support techniques will save the site more than $20 million over the life of the project. In addition to analysis cost savings, these approaches have resulted in reduced excavation schedules and soil disposal costs, and superior overall soil characterization compared with conventional sampling and analysis. · DOE reports that a precision excavation project at the FUSRAP Ashland 2 site that used adaptive sampling and analysis techniques resulted in an estimated $10 million savings. Data collection efforts were particularly effective when integrated within remedial designs.

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· The ability to reduce uncertainty in decisions can reduce the perceived financial risk of site
owners, developers, and communities, thereby contributing to revitalization of many
properties. The newer characterization approaches can reduce uncertainty by enabling site
investigators to increase the sampling density at reasonable cost.
· Although real-time field measurement and analytical technologies, dynamic work strategies, and systematic planning techniques have been known for some time, their acceptance has been slow, primarily because of a conservative engineering and regulatory atmosphere that appears to favor the established methods for conducting site characterizations. · To help overcome this inertia, EPA, DOE, DOD, and other organizations have been promoting the use of the new technologies and strategies for characterizing, cleaning up, and monitoring hazardous waste sites. · The use of field analytical technologies is expected to increase relative to traditional
approaches, for several reasons:

÷ EPA, DOE, DOD, and other organizations have been sponsoring research on and
promoting the use of the newer approaches.
÷ Newer approaches have been shown to mitigate deficiencies in groundwater characterization at many sites that relied on conventional approaches, which have lead to inadequate remedial designs. ÷ The demand for revitalization of brownfields and UST sites implies a requirement to conduct many site assessments, often at small- and medium-size sites. These activities will lead to further site investigation and cleanup for some percentage of these sites. ÷ The demand for due diligence by property purchasers, developers, and lenders implies a significant demand for Phase I and, possibly, Phase II assessments. ÷ The demand to redevelop sites provides a powerful economic incentive for faster site assessments and cleanups. Developers, property owners, and investors are under serious time constraints to get plans approved and secure financing and insurance. The integration of field analytics, dynamic work strategies, and systematic planning will allow investors to more expeditiously proceed with their projects.

Based on these factors, it is expected that the newer technologies will replace older technologies at many future and some existing sites. Although some newer technologies may not be appropriate for all sites, they are likely to reduce overall remediation costs at many sites, thereby allowing more sites to be cleaned up. Most of the major remediation programs are constrained by budgets, and not by the amount of cleanup work. Thus, if average site cleanup costs are reduced, more cleanups would be possible.

13.4 Number of Sites That Will Need Characterization
All potential hazardous waste sites will require some sort of site characterization. In addition, there is a healthy market for site characterization resulting from due diligence investigations conducted in support of real estate and other business transactions. However, no single source provides definitive information on the number and characteristics of sites that may require site characterization. The type and amount of characterization work needed varies widely from one
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site to another, depending on the nature and extent of the contaminant release, geology and hydrogeology of the site and surrounding area, source of contamination, size of the site, and other factors. Exhibit 13-4 presents estimates of the potential number of sites that may require site characterization under the Superfund, RCRA Corrective Action, and other remediation programs described earlier in this report. As described in Chapter 1 and subsequent chapters, the definition of the term "site" differs somewhat from one market segment to another. In this report, the term is used to indicate an individual area of contamination, which can be small or large. This term is not to be confused with the terms "facility" and "installation," which identify an entire tract, including all contiguous land within the borders of a property. A "facility" may contain one or more contaminated areas or "sites." For this exhibit, the Superfund sites are counted as operable units (OUs) rather than sites. As described in Section 13.1, Phase One site assessments do not generally include sampling, chemical analysis, and similar activities. Nevertheless, sites undergoing these assessments are of interest to this study because they comprise the universe of sites from which sites needing further study will be drawn. This is the largest market, amounting to 11.8 million Phase One assessments over 30 years, and costing $23 billion. Most of these assessments are in support of due diligence responsibilities in real estate and business transactions. The other phases are potential markets for both conventional and new sampling and analysis technologies. Over the next 30 years, it is estimated that 1.2-2.3 million Phase Two assessments and 285,000 Phase Three assessments will be conducted. Sampling and analysis will also be needed during 392,000 remedial actions. The sampling and analysis required during remedial actions can be quite variable. If unforseen conditions arise at a site, extensive supplemental sampling and analysis may be called for. The sampling and analysis during O&M is also highly variable, with some sites needing none or minimal amounts, while others such as the Superfund and RCRA sites, are likely to require more comprehensive sampling and analysis. Thus the estimate of 507,000 sites likely to need sampling and analysis during O&M represents the middle value of a wide range of activities among the sites.

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Exhibit 13-4. Estimated Number of Sites to Require Sampling and Analysis
Phase One
Superfund RCRA-CA UST DOE
e f g (OUs) c d

Phase Two
658 1,269 NA 1,425 NA NA h 1.2 - 2.3 mil. 1.2 - 2.3 mil.

Phase Three
832 < 3,827 125,000 4,774 NA NA 150,000 NA 285,433

Remedial Action a
1,700 3,800 223,000 8,800 5,000 NA 150,000 NA 392,300

O&M b
2,500 3,800 320,000 18,400 8,000 NA 155,000 NA 507,700

658 0 NA NA NA NA h 11.5 mil. 11.8 mil.

DOD

Civ. Agencies States Total
J h i

Private

NA Estimate not available; a Assumes all sites will require at least some sampling and analysis during remedial action; however the amount needed will vary widely from site-to-site. b Total number of sites cleaned up. Some, but not all, of these sites will require sampling and analysis on a continuing or periodic basis. Some will require only minimal amounts and some will require more. c Superfund: Operable units (OUs) were counted rather than sites. Phases 1 - 2 will only be needed at future sites to be listed (280 sites with an estimated 658 OUs). Phase 3 will be needed at the same 658 OUs plus 174 OUs (from Exhibit 3-2) that have not begun remedial assessment (658 + 174 = 832). Remedial action (RA) from 2004-2013 will be needed at 1,731 (658+1073) OUs. (The 1,073 OUs are at the 456 already listed sites that have not begun RA (Exhibit 3-2)). The 1,731 estimate does not include sites already in RA. It is assumed that O&M will be needed by 80% of all completed OUs, based on the facts developed in Chapters 2 and 3 that 83% of NPL sites have contaminated groundwater and 95% of groundwater remediations use monitored natural attenuation (MNA), P&T, or both (0.83 X 0.95 = 0.8) Thus, combining the above figures, it is estimated that 2,523 OUs will need O&M (1,731 OUs plus 1,399 OUs that have completed or are in RA = 3,130 X 0.8 = 2,504). d RCRA: The 1,269 RCRA Corrective Action sites have not yet received priority ranking. The 3,827 sites represent all those likely to require site investigation and/or cleanup. Some of these investigations have already begun, although only a small portion of the cleanups have actually begun. e UST: It is assumed that tank sites to be reported in the future will not do Phase 1 and 2 assessments, but will go straight to phase 3. Phase 3 is assumed to include all future cleanups, which equals 35,000 already confirmed releases where cleanups have not been initiated (Exhibit 5-5) plus 90,000 (average of range in Exhibit 5-5) projected future releases. The Remedial action estimates are based on the assumption that 60% of all sites in RA will require some sort of confirmation sampling. This assumption is derived from the estimates in Chapter 5 that 79% of UST groundwater sites use MNA or P&T. Assuming that 80% of the sites have groundwater contamination, about 60% will need O&M. Adding sites yet to complete remediation (125,000 that will need Phase 3 + 98,000 initiated but not complete = 223,000) to sites with cleanups completed (311,000 from Chapter 5) and multiplying by 0.6 gives a total of 320,000 (534,000 X 0.6) sites that will ultimately require monitoring. f DOD: Future investigation is planned at 1,425 sites, underway at 4,774 sites, and 2,775 sites are already in remediation. The O&M estimate includes all previously remediated sites times 0.8 (from the percentage of NPL sites that will require O&M). g DOE: has completed construction at 5,000 release sites; and 8,000 sites (10,000 X 0.8) may need O&M. h States: From Chapter 9, (estimated 5,000 sites annually X 30 years plus 44,000 with cleanups completed through 2003 = 194,000 X 0.8 = 155,000). Phase 1 and 2 figures are included with estimate for private sites. I Private Sites: Industry sources have estimated that the number of Phase I (ASTM definition) site assessments averaged 235,000 per year between 1999 and 2001 (EAS 2002). Summing this amount over 30 years, and assuming a 3% annual growth rate (which is approximately the growth rate of the GDP over the past 50 years), this would total 11.5 million Phase 1s. It is assumed that 10-20% of Phase 1s will need a Phase 2, based on industry history. These figures incorporates brownfields and voluntary cleanup programs. J Excludes civilian federal agency and some DOE sites, because data could not be disaggregated.

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13.5 Estimated Site Characterization Costs
Any estimate of the value of the site characterization market is hampered by the extremely wide range of potential situations involving the use of sampling and analysis tools and the paucity of program-wide data on costs. Many cleanup programs do not record expenditures by type of action. For example, EPA has not kept track of its own Fund-lead expenditures on specific actions, such as RD or RA. The Agency has no simple way of determining how much is spent on specific types of actions, such as site investigation. Cost estimates in RODs, which are done prior to remedy design, are estimates which serve as only general indicators of potential cost. A 2001 Resources for the Future study (Probst, 2001) used expenditure data from EPA's financial management system to estimate the average dollars spent for Fund-lead RI/FSs, RDs, and RAs at the operable unit level for sites between 1992 and 1999. These costs are primarily extramural costs and do not cover other site-specific costs such as community and state involvement, nor other program costs, such as rent. Nevertheless, they provide an approximation of the relationship of site investigation costs to remedial design and remedial action costs. These cost comparisons are shown in Exhibit 13-5. The average RI/FS expenditures over all Fund-lead Superfund sites averaged 10 percent of combined costs for RI/FS, RD, and RA, which together account for most site expenditures. Since this estimate does not include the sampling and analysis work that occurs during remedial action, long-term remedial actions, and O&M, it represents a conservative estimate of the extent of site characterization work needed. Exhibit 13-5. Estimated Major Components of Superfund Costs
Expenditure Category RI/FS RD RA Total Cost per Fund-Lead Operable Unit ($000) 1,363 1,331 11,059 13,753 Percent of Total Expenditures 9.9 9.7 80.4 100.0

Notes: · RI/FS costs do not include site characterization work conducted during remediations, O&M and long-term remedial actions. · Average for non-federal Superfund Fund-lead sites from 1992 to 1999. These data do not include costs for long-term remedial actions and O&M. Source: Probst, Katherine N. & David M. Konisky, et. al., 2001. Superfund's Future, What Will It Cost, Resources For the Future, Washington, D.C. 2001.

The data also indicate that site characterization cost as a percent of total cleanup cost is larger for smaller sites, than for larger sites (Exhibit 3-6). Site investigation costs are 7 percent of total site costs for "mega" Superfund sites (those with over $50 million in cost) and 15.5 percent for nonmega Superfund sites. Data are also available for drycleaner sites, which are almost all small and provide a useful comparison. On average, 28.2 percent of drycleaner site cleanup costs are for
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site investigations. The drycleaner data, from a sample of 50 drycleaner sites from the State Coalition for Remediation of Drycleaners database, also indicate the extent of site investigation costs (See Chapter 12, Drycleaner Sites). The site investigation costs cited in this section do not include site characterization work that is often undertaken during remedial action and O&M. Almost 17 percent of drycleaner site cleanup costs were for O&M. Exhibit 13-6. Remediation Cost and Site Size
Site Type Mega Superfund (per OU) Non-Mega Superfund (per OU) Drycleaner Average Total Cleanup Cost $36,652,000 $6,750.000 $402,000 Site Investigation Cost $2,582 $1,047 $113,000 Percent 7.0% 15.5% 28.2%

Notes: · Includes Total market value over 30 years. · Does not include site characterization work conducted during remediations and O&M. Source: Probst, Katherine N. & David M. Konisky, et. al., 2001. Superfund's Future, What Will It Cost, Resources For the Future, Washington, D.C. 2001; and Exhibit 12-2.

Applying these ratios to the estimated 30­year market values of each of the seven major remediation programs, the site characterization market is likely to be $21 billion over the next 30 years (Exhibit 13-7). Because this estimate does not include site characterization work that is undertaken during remedial action and O&M, it may underestimate the total amount of sampling and analysis work needed. Exhibit 13-7. Estimated Site Characterization Costs
Total Remediation Market Market Segment Number of Sites 16,000 Value ($Billions) 145 Percent for Site Investigation Value of Site Characterization a Market ($Billions)

Medium and Large Sites (Superfund, RCRA Corrective Action, DOD, & DOE) Small Sites (UST, Civilian Agencies, and States) Total
a

10

14.5

278,000 294,000

64 209

16

6.5 21.0

Because this estimate does not include site characterization work that is undertaken during remedial action and O&M, it may underestimate the total amount of sampling and analysis work needed.

Source: Exhibits 1-1, 1-2, 12-2, 13-6.

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13.6 Market Entry Conditions
The characterization market can generally be divided into two vendor groups: architecture and engineering (A&E) firms who generally provide technical investigation expertise (e.g., geologists, chemists, project managers) and equipment and analytical vendors who provide the drill rigs, geophysical equipment, and analytical equipment use to carry out site characterization. Although the two types of firms usually operate differently, there is some overlap. Some A&E firms have their own equipment and some vendors that provide interpretation services for some of the innovative direct push probes. The exception to this generalization are very small specialized firms that might do site characterization only, or risk assessments only, and firms that primarily work in the UST area. In recent years, there has been a great deal of consolidation in the A&E area. Firms that were once considered large players in the environmental characterization field have been merged into even larger firms. For example, URS-Griner acquired Woodward-Clyde, Dames and Moore, and EG&E. Consolidation is also occurring in the analytical laboratories sector. It has, however, not been as extensive in the heavy equipment operator business. Drill rigs and direct push rigs are generally supplied by large firms with many small offices around the country or small drilling firms that do environmental work as a supplement to their construction and water well business. Because of high mobilization costs, companies located closer to the site have a cost advantage. Large corporations and government agencies (e.g., DOE and DOD) with large complex contaminated sites tend to rely on the large A&E firms. This is also true for some government agencies and companies that have many smaller sites around the country. Nevertheless, there are opportunities for smaller vendors to subcontract. Since the larger A&E firms generally view field equipment as a subcontract issue, companies that can provide services such as direct push with various ancillary detection equipment, as well as traditional drilling rigs, are more likely to prevail in contract award. In the larger facility market, there is increasing regulatory pressure to perform better site characterizations than have been done in the past as well as pressure from the facility owners to keep costs down. This presents an excellent opportunity for new characterization technologies and site management approaches that are geared towards better and potentially less expensive site investigations and site management approaches (Section 3.2). The USEPA make this point in their Dynamic Field Activities and Triad initiatives (see web pages at http://www.epa.gov/superfund/programs/dfa/index.htm and http://www.epa.gov/tio/triad). The cleanup market involving smaller hazardous waste handlers and generators, USTs, and commercial property transfers is somewhat more fragmented in terms of vendor participation. Smaller waste generators, such as drycleaners and independent UST owners (as opposed to those owned by the major oil companies), and real estate owners and developers are more likely to employ specialty firms (e.g., tank investigations only) or smaller A&E firms that can perform Phase 1 and Phase 2 assessments but are unlikely to have a robust RI/FS practice. In addition, many of the larger A&E firms are not interested in this type of work because of their higher overhead costs and the relatively small profit margin that smaller jobs entail.

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The cleanup budgets for the smaller facilities are much smaller and their environmental problems are generally better defined, such as a leaking tank or a PCE release at a drycleaner. Innovative specialty tools such as LIF, MIP, or the halogen specific probe can, in most cases, perform a complete characterization for relatively little cost. These capabilities should be a good selling point for specialty contractors or the smaller A&E firms that undertake this type of work. Significant portions of this market can be accessed through local and state governments and prime contractors. Finally, commercial property transactions, especially for those properties with a history of handling hazardous materials/wastes, generally have very low budgets for Phase 2 characterizations. Nevertheless, the characterization results often carry with them a high degree of financial liability. This market would be receptive to technologies that provide analytical results that are more representative of true site conditions at a reasonable cost. Firms practicing dynamic field activities and the Triad approach need to bring together professionals with many disciplines, such as project management, statistical and geostatistical sampling design, and analytical chemistry. To achieve the appropriate disciplinary mix, some firms may partner with analytical service providers, statisticians, and other disciplines.

13.7 References
Applegate, J.L. and D.M. Fitton, 1998. "Rapid Site Assessment Applied to the Florida Department of Environmental Protection's Drycleaning Solvent Cleanup Program," in Proceedings Volume for the First International Symposium on Integrated Technical Approaches to Site Characterization, Argonne National Laboratory, pp. 77-92, http://cluin.org/char1_edu.cfm#mode_expe. Business Information Services, 2001. "ISO 14015 Finalized, New Site Assessment Standard for the International Community," Environmental Site Assessment Report, Southport, CT, December 2001. Business Information Services, 2002. "Market Radar," in Environmental Site Assessment Report, Southport, CT, January 2002. Crumbling, D.M., 2001a. Applying the Concept of Effective Data to Environmental Analyses for Contaminated Sites, EPA-542-R-01-013, U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Technology Innovation Office, October 2001. Crumbling, D.M., 2001b. Using the Triad Approach to Improve the Cost-Effectiveness of Hazardous Waste Site Cleanups, EPA-542-R-01-016, U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Technology Innovation Office, October 2001. FRTR, 1998. Field Sampling and Analysis Technologies Matrix. A publication of the Federal Remediation Technologies Roundtable. http://www.frtr.gov/site/analysismatrix.html

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Probst, Katherine N. & David M. Konisky, et. al., 2001. Superfund's Future, What Will It Cost, Resources For the Future, Washington, D.C. 2001. U.S. DOE, 2002. Adaptive Sampling and Analysis Programs (ASAP) web page, U. S. Department of Energy. http://www.Ead.anl.gov/project/dsp_topicdetail.cfm?topicid=23 U.S. EPA (Environmental Protection Agency), 1998. Innovation in Site Characterization Case Study: Hanscom Air Force Base Operable Unit 1 (Sites 1, 2, and 3), EPA-543-R-98-006, U.S. Environmental Protection Agency, September 1998. http://clu-in.org/download/char/hafbcs2.pdf. U.S. EPA, 2000. Innovation in Site Characterization Case Study: Site Cleanup of Wenatchee Tree Fruit Test Plot Site Using a Dynamic Work Plan, EPA 5420R-00-009. Washington, D.C., August 2000. Http://clu-in.org/char1_edu.cfm#site_char U.S. EPA and USACE, 2001a. Dynamic Data Collection Strategy Using Systematic Planning and Innovative Field-Based Measurement Technologies, Seminar sponsored by U.S. Army Corps of Engineers and U.S. Environmental Protection Agency's Technology Innovation Office, March 15, 2001. U.S. EPA, 2001b. Site Characterization for Subsurface Remediation, EPA/625/4-91/026, Office of Research and Development, November 2001. U.S. EPA, 2002. Report on Innovative Approaches to Manufactured Gas Plant Site Characterization, EPA-542-R-01-003, Office of Solid Waste and Emergency Response, Washington, D.C. October, 2002 U.S. EPA, 2003. Using Dynamic Field Activities for On-Site Decision Making: A Guide for Project Managers, EPA-540-R-03-002, Office of Solid Waste and Emergency Response, Washington, D.C. May 2003. http://fate.clu-in.org U.S. EPA, web site. Field Analytic Technologies Encyclopedia (FATE). http://fate.clu-in.org U.S. EPA, web site. Field Sampling and Analysis Technologies Matrix, Version 1.0. http://www.frtr.gov/scrntools.htm U.S. EPA, web site. Dynamic Field Activities Internet Web Site, http://www.epa.gov/superfund/programs/dfa U.S. GAO, 2000. Analysis of Costs at Five Superfund Sites, GAO/RCED-00-22, U.S. General Accounting Office, January, 2000.

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Chapter 14 DNAPLs at Hazardous Waste Sites
Dense non-aqueous phase liquids (DNAPLs) are chemicals that are denser than water and are only slightly soluble. Because of their physical and chemical properties, characterization and remediation of DNAPL-contaminated sites can pose significant challenges to site managers. Contamination of soil and groundwater by DNAPLs is associated with many hazardous waste sites and many industries, and has posed serious environmental problems for many years. This chapter describes the nature of the DNAPL problem and estimates of the extent of the market for its remediation. Because of their density and low solubility, DNAPLs are often present in the subsurface in an undissolved phase. Most DNAPLs undergo only limited degradation in the subsurface, and persist for long periods of time while slowly releasing soluble organic constituents to groundwater. The most frequently applied remediation approach has been to use groundwater pump-and-treat systems primarily to contain the dissolved phase plume and not treat the source zone.1 However, it has been shown that this approach has not been successful in achieving cleanup goals at many sites (NRC 1994). Efforts to remove free-phase and residual DNAPLs face the challenge of our limited capability to delineate the source zones. If some of the freephase or residual DNAPLs remain, the deposit may continue to dissolve into the groundwater. Whether to treat or remove free-phase or residual DNAPLs involves tradeoffs between long-term and short-term site management options and costs. There is a debate in the scientific and engineering community regarding how much mass must be removed to have an effect on the groundwater concentration profile and on the duration of post-treatment containment activities. DNAPL compounds are encountered in most industries and under all the remediation programs, including Superfund, RCRA Corrective Action, UST, DOD, DOE, and other cleanup programs. Thus, the market estimates in this chapter should not be added to those in the previous chapters of this report. Adding these estimates would be double-counting sites and, therefore, overestimating the scope of the market.

14.1 Market Description
While no compilation of the number of sites with DNAPLs exists, the extent of the problem can be described in terms of the occurrence of DNAPL-related chemical compounds at waste sites, the types of industrial activities that have resulted in free-phase DNAPLs, and the frequency of occurrence of those chemicals in the seven major remediation market segments.

1

A source zone is that portion of the subsurface where immiscible liquids (free-phase or residual DNAPLs) are present either above or below the water table. The contaminated material in the source zone acts as a reservoir for the continued migration of contamination to surrounding environmental media or as a source for direct exposure (ITRC 2002). Chapter 14: DNAPLs Page 14-1

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14.1.1 DNAPLs in the Environment Because DNAPLs are marginally soluble in, and heavier than, water, they can migrate to depths well below the water table. As they migrate, they can leave behind ganglia or microglobules in pore spaces of the soil matrix. When the sinking DNAPLs encounter a low-permeability layer, such as clay or bedrock, they can accumulate, or "pool" and spread laterally, until they encounter a fracture or other path toward deeper zones. Globules can also enter pores and be held there in capillary suspension. All these forms of undissolved chemicals (ganglia, globules, and pools) effectively serve as long-term sources of groundwater pollution. They can slowly dissolve in the surrounding groundwater and form contamination plumes. These plumes can have varying levels of concentration, such as narrow bands of high-concentration and bands of low-concentration. Because DNAPLs have very low solubility points, they can continue to release small, but environmentally important, quantities of contaminants into the groundwater for centuries. As a result of this complex pattern of subsurface transport, the distribution of DNAPLs can be difficult to delineate. In addition, very few sites report direct observation of DNAPLs in the subsurface. Many DNAPLs are colorless liquids which, when present as residuals in soil pores, are difficult to visually observe.2 14.1.2 Chemical Compounds that are DNAPLs DNAPLs include halogenated organic solvents such as trichloroethylene (TCE), 1,1,1trichloroethane (TCA), perchloroethylene (PCE), carbon tetrachloride, substituted aromatics, phthalates, polychlorinated biphenyl (PCB) mixtures, coal and process tars, creosote, and some pesticides. Exhibit 14-1 shows some of the common DNAPLs. A more comprehensive list of chemical compounds that are DNAPLs are found in various sources (Cohen and Mercer 1993, EPA 1992, 1993). DNAPLs are often complex mixtures of the listed chemicals, and many sites are contaminated with various combinations of DNAPLs, LNAPLs, metals and/or radionuclides. These compounds are also among the most common contaminants at Superfund, DOD, RCRA, and DOE sites. Specific data for the other market segments are not available. State and brownfield sites, which include many former industrial properties, are likely to have a similar profile of chemical usage. The presence of these chemicals does not guarantee that DNAPLs are present in free or residual phase. The occurrence of DNAPLs is a function of whether compounds were discharged to the environment in dissolved or free-phase liquid form, the material, waste management practices, volume and pattern of releases, and hydrogeological characteristics. Many early site investigations may have missed the presence of DNAPLs or presumed that the source of any dissolved-phase DNAPLs was from points of discharge on the surface. The presence and location of DNAPLs are usually not obvious, and EPA has produced reports and fact sheets to help site investigators estimate the potential occurrence of DNAPLs (U.S. EPA 1992).

They can be identified through the use of reactive dyes that turn colors in the presence of DNAPLs or shaking a soil sample in a jar of water and observing DNAPLs as a second phase at the bottom of the jar. Chapter 14: DNAPLs Page 14-2

2

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Exhibit 14-1. Common DNAPL-Related Chemicals
Halogenated VOCs
Chlorobenzene 1,2,-Dichloropropane 1,1,-Dichloroethane 1,1,-Dichloroethylene 1,2,-Dichloroethane Trans-1,2,-Dichloroethylene Cis-1,2,-Dichloroethylene 1,1,1-Trichloroethane Methylene Chloride 1,1,2-Trichloroethane Trichloroethylene Chloroform Carbon Tetrachloride 1,1,2,2-Tetrachloroethane Tetrachloroethylene Ethylene Dibromide

Halogenated SVOCs
1,4-Dichlorobenzene 1,2-Dichlorobenzene Aroclor 1242, 1254, 1260 Chlordane Diedrin 2,3,4,6-Tetrachlorophenol Pentachlorophenol

Non-Halogenated SVOCs
2-Methyl Napthalene o-Cresol p-Cresol 2,4-Dimethylphenol --Cresol Phenol

Napthalene Benzo(a)Anthracene Fluorene Acenapthene Anthracene Dibenzo(a,h)Anthracene Fluoranthene Pyrene Chrysene 2,4-Dinitrophenol Other polynuclear aromatic hydrocarbons

Miscellaneous
Coal tar Creosote

Note: Many of these chemicals are found mixed with other chemicals or carrier oils.
Source: U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Estimating
Potential Occurrence of DNAPLs at Superfund Sites, Publication 9355.4-07S, January 1992.


14.1.3 Industrial Activities One of the most accurate indicators of probable releases of DNAPLs at a site is the site's history--the types of industries that operated on the site, industrial processes, and waste management practices. The text box lists industries that have a high probability of DNAPL releases, based on the materials they use or discharge and historical industrial and waste management practices. Industrial or waste disposal processes with a high probability of DNAPL release include metal cleaning and degreasing, tool-and die operations; machinery, equipment, and instrument repair and maintenance; paint removing and stripping; storage of solvents in underground storage tanks; storage of drummed solvents in uncontained storage areas; solvents loading and unloading; disposal of mixed chemical waste in landfills; and treatment of mixed chemical waste in lagoons or ponds.
Industries With High Probability of Past DNAPLs Release
C Wood preservation
C Manufactured gas plants C Electronics and electrical equipment manufacturing C Transportation equipment manufacturing (e.g., aircraft, automobiles, and engines) C Fabricated metal products manufacturing C Solvent manufacturing, distribution, packaging, and recycling C Pesticide and herbicide manufacturing, packaging, and distribution C Organic chemical manufacturing, distribution, packaging, and recycling C Equipment maintenance C Drycleaning C Instrument manufacturing C Transformer oil production/reprocessing C Coking operations C Pipeline compressor stations C Departments of Defense and Energy maintenance and training activities.

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14.1.4 Hydrogeological Characteristics Because of its tendency to migrate to the lowest possible level and pool, DNAPL transport in the subsurface is very sensitive to the geological media through which it passes. Site geology can affect many aspects of DNAPL contamination, including the likelihood that the DNAPL will reach the saturated zone, ultimate depth of the DNAPL travel, extent of lateral travel, likelihood that pools will form and their shape, and the spatial distribution of the dissolved-phase plume. These factors will also affect the nature and probable success of the site characterization and remediation work that will be needed. Previous research indicates that the nature of DNAPL deposits are most likely to be influenced by local and site-specific geological formations, rather than overall hydrogeological regions (U.S. EPA 1993a). Approaches to DNAPL characterization and remediation differ significantly depending on whether DNAPL source zones are shallow or deep. Examples of situations encountered with shallow source zones are:

C Sites with installed pump-and-treat systems that have inadequately contained plumes, whether or not they have addressed the source zones. Additional characterization and decisions regarding revisions to the remedies may be called for, either to address the plume, the source zone, or both; C A continuing market where pump and treat and permeable reactive barriers (PRBs) will be
used as part of remediation;
C Old and new sites with undefined source zones. The remediation approaches used at these
sites will depend on regulatory policy, available technology, and economics in affecting
tradeoffs between source reduction and containment.

In all these situations, there appears to be an expanding market for the new technologies that provide on-site characterization. It is likely that characterization of deep source areas and bedrock will continue to use "traditional" technologies, such as drilling rigs, in the near future. Research and development in this area is needed to develop more effective characterization and remediation approaches.

14.2 Factors Affecting Demand for Remediation Services
The proportion of DNAPL sites that will be subject to containment and how many will undergo source zone treatment is uncertain. A number of factors may affect the decision to attempt to strike a balance between remediating a source zone and long-term pump and treat at a DNAPL site, and hence the potential demand for remediation services. These factors, which are not mutually exclusive, include:

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C Regulatory requirements at some sites may call for achieving groundwater MCLs in the source zone. In some cases, regulatory requirements may be so stringent that property owners and PRPs seek alternatives, such as technical impracticability waivers, to source reduction or removal. C The CERCLA process of remedy selection includes a preference for remedies that provide "permanence and treatment" to the extent practicable. This implies that, to the extent practicable, contaminants are to be treated and/or destroyed. C The ability to economically delineate the DNAPL source zones varies from site to site, and is especially difficult in fractured rock. C The ability to show that source reduction will significantly reduce the long-term costs of containment also varies from one site to another. C The effective combinations of technologies have the potential for performance and cost advantages. However, sometimes the need to apply more than one cleanup technology may increase the complexity, cost, and uncertainty of a remediation. C Potential contamination at uncharacterized, or undiscovered sites, such as MGP sites, former drycleaners sites, or other brownfields sites, may increase the number of sites that need characterization and/or remediation. C Development and acceptance of innovative remedial and characterization technologies. Effective technologies are especially needed for deep sources. Characterization and remediation of deep sources are more costly and usually produce less certain results than those of shallower sources. C A number of states have recognized the need to consider newer site characterization and remediation technologies prior to granting waivers from ARARs for technical impracticability (ITRC 2002). C Reuse considerations at a site may drive the type of remediation approach selected and/or generate a need for a faster cleanup at a site. For example, a developer may not be able to use a property that has pump-and-treat equipment in important locations on the property, or institutional controls that limit the property's intended use. In some situations, it may be possible to place treatment system features in locations more compatible with the intended reuse, or use a different treatment approach.
Some prospective property purchasers may need the property cleaned up faster than is possible with a pump-and-treat system. An alternative, such as a protective cap may be installed more quickly than a groundwater treatment system, thereby enabling the property to be put into productive use more quickly. On the other hand, a cap may not be compatible with some reasonably anticipated future site uses, and usually will be accompanied by institutional controls.

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14.3 Number and Types of Sites
Based on the types of contaminants found at hazardous waste sites and other factors, it is likely that a significant number of sites have a DNAPL problem. However, no single source provides definitive information on the number and characteristics of sites that may require DNAPL remediation. The type and amount of DNAPL remediation work needed vary widely from one site to another, depending on the nature and extent of the contaminant release, geology and hydrogeology of the area, source of contamination, size of the site, and other factors. Exhibit 14 2 summarizes data on the incidence of VOCs and SVOCs, many of which are DNAPL chemicals. About 78 percent of NPL sites contain VOCs (69 percent halogenated) and 71 percent contain SVOCs ( 44 percent PAHs, 28 percent pesticides, 27 percent PCBs, and 26 percent halogenated SVOCs). Many NPL sites have combinations of these compounds. About 64 percent of DOD sites contain VOCs (49 percent halogenated, 32 percent non-halogenated). Fifty-seven percent of DOD sites contain SVOCS, including PAHs (16 percent) organic pesticides or herbicides (15 percent), halogenated SVOCs (8 percent), and PCBs (6 percent) (Exhibit 14-2). Based on data from 214 RCRA Corrective Action sites collected in the early 1990s, 60 percent contained halogenated VOCs, 18 percent PAHs, 11 percent non-halogenated SVOCs, 11 percent halogenated SVOCs, and 9 percent unspecified VOCs and SVOCs. Halogenated compounds are often DNAPLs. Based on a 1993 EPA evaluation of 79 treatment, storage, and disposal facilities, 9 of the 19 predominant constituents projected above action levels in groundwater are DNAPL chemicals (U.S. EPA 1994). The use of DNAPL compounds at a site does not guarantee that DNAPLs are present in freephase or residual form. The nature and extent of the DNAPL deposits also depend upon the form, pattern, and volume of release, hydrological conditions and other factors. Exhibit 14-2. Occurrence of VOCs and SVOCs at Contaminated Sites
Remediation Program NPL RCRA Corrective Action DOD DOE VOCs 78% 60% + 64% 38%* SVOCs 71% 18% + 57% 38%*

C * DOE figure combines SVOCs and VOCs. This figure is based on data in early 1990s. C About 69% of NPL sites contain halogenated VOCs, 44% PAHs, 28% pesticides, 27% PCBs, and 26% halogenated SVOCs. C About 49% of DOD sites contain halogenated VOCs, 32% non-halogenated SVOCs, 16% PAHs, 15% organic pesticides or herbicides, 8% halogenated SVOCs, and 6% PCBs. C The RCRA VOCs figure is for halogenated VOCs, since the data were not aggregated into major contaminant groups. About 32% of RCRA sites also contain other non-halogenated VOCs, and 11% contain BTEX. The SVOCs figure for RCRA Corrective Action sites is for PAHs, since the data were not aggregated into major contaminant groups. About 11% contained non-halogenated SVOCs, 11% halogenated SVOCs, 9% unspecified VOCs and SVOCs, and 36% contain other unspecified contaminants.
Source: Chapters 3, 4, and 6.

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Although the occurrence of halogenated compounds is a strong indication that the site 29-45% of NPL sites, or an average of 37%, are likely to have free-phase or may have DNAPLs, it does not guarantee that residual DNAPLs present in the it will. The occurrence of DNAPLs is also subsurface. These estimates incorporate influenced by industrial practices, form and several approximations and simplifying volume of releases, and hydrogeological assumptions as described in the text. conditions, among other factors. A 1993 EPA study considered these factors to estimate the likelihood of free-phase DNAPL presence at NPL sites (U.S. EPA 1993a). This study concluded that approximately 57 percent of NPL sites with organics contamination in groundwater either have, or could be expected to have a medium to high potential of DNAPLs presence, which could provide a source of groundwater contamination in the subsurface. The remainder of the sites could be expected to fall within the category of "low to unlikely" to have DNAPLs present. (The percentages were: 100% potential = 5%, high potential = 32%, medium potential = 20%, low potential = 27%, and zero potential = 16%). Based on interpolation of data in this report (U.S. EPA 1993a), it is estimated that 29-45 percent of all NPL sites, or an average of 37 percent are likely to have free-phase or residual DNAPLs. Many of the compounds found at these sites are also found at many non-Superfund sites, such as RCRA sites. Based on information about previous site uses, it is likely that these chemicals are also present at contaminated brownfields sites. Conclusions regarding UST sites are less certain. There are an estimated 25,000 USTs containing hazardous substances and many are likely to contain solvents. Although it is likely that a significant number of these contain solvents, there are no recent data regarding the specific chemicals contained in USTs. Petroleum-containing USTs are more likely to contribute to the presence of BTEX, which are LNAPLs. DNAPL-related chemicals are also released to the environment by the drycleaning industry and were released by the now defunct manufactured gas industry. The characteristics of drycleaner sites are described in Chapter 12. Based on that discussion, over 15,000 active drycleaner sites will probably need site investigation and remediation. About 90 percent of these facilities use perchloroethylene (PCE) as their primary drycleaning solvent. In addition, there may be 9,000 to 90,000 "inactive" sites, which are former or closed drycleaning facilities. Older facilities used more drycleaning solvent than newer ones and tended to have more releases. Most of these sites tend to be remediated under a state mandated or voluntary control program. They are not counted separately in the above estimates, but are probably a component of the state site figure. The cleanup of former manufactured gas plants (MGPs) and other coal tar sites may be addressed under any of the remediation programs, such as Superfund, RCRA, or a state environmental program, depending on the nature and extent of the contamination and other sitespecific factors. The characteristics of MGPs and other coal tar sites are discussed in Chapter 10. Based on the estimates presented in that chapter, there may be 30,000 to 45,000 former MGP sites. These sites varied in size from less than one acre to approximately 200 acres. Because of the nature of the gas manufacturing process and the practices at the time, releases of contaminated materials to the environment were common. A small percentage of these sites have been, or are being, cleaned up under one or more of the seven major market segments. For
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example, 12 MGP sites are on the NPL and some have been reported under state cleanup programs. Because these sites may be managed under any of the remediation programs, the estimates of the MGP market should not be added to those of the seven major market segments above. Adding these estimates would be double-counting sites and cleanup costs, thereby overestimating the market's scope. Summarizing this information, it is estimated that, 37 percent of non-federal NPL sites, 28 percent of RCRA, 28 percent of state, 30 percent of DOD, and 30 percent of DOE sites are likely to have a DNAPL problem. Although there are possibly thousands of UST sites with DNAPLs (e.g., tanks containing solvents), there are insufficient data on the number of tanks that contain them to make a meaningful estimate. These percentages result in the estimates presented in Exhibit 14-3. The estimated percentage of sites with DNAPLs is interpolated from data in the EPA study (U.S. EPA 1993a) and adjusted for the percentage of sites with groundwater contamination (83 percent). The NPL percentages are applied to the other market segments based on the occurrence of organics in those segments relative to the NPL segment. In addition to sites that have not yet begun remediation, there may be old sites (those with ongoing or completed remedy construction) where a DNAPL problem has not yet been discovered, where operating pump-and-treat systems are not adequately containing the plumes, and/or where addressing the source zones have not been attempted. As new characterization and remediation approaches become practicable, the remedies at these sites may be revisited. Exhibit 14-3. Estimated Number of Sites With DNAPLs
Cleanup Market Segments NPL (non-federal) RCRA UST DOD DOE Civilian Agencies State & Private Total Estimated No. of Sites to be a Cleaned up 736 3,800 125,000 6,400 5000 > 3,000 150,000 293,936 Estimated Percent With DNAPLs (%) Range 29 ­ 44 22 ­ 34 NA 24 ­ 37 24 ­ 37 NA 22 ­ 34 Average 37 28 NA 30 30 NA 28 Estimated Number of Sites With DNAPLs Range 213 ­ 324 836 ­ 1,292 NA 1,536 ­ 2,368 1,200 ­ 1,850 NA 33,000 ­ 51,000 37,260 ­ 54,814 Average 538 1,052 NA 1,819 1,469 NA 41,200 46,078

NA Not available a From Exhibit 1-1. Source: Analysis of data in Evaluation of the Likelihood of DNAPL Presence at NPL Sites, National Results, OSWER Publication 9335.4-13, EPA 540-R-93-073, PB93-963343, Office of Solid Waste and Emergency Response, September, 1993.

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These estimates are approximations that incorporate a number of simplifying assumptions as described above. For example, evidence of discharge of a compound does not necessarily mean it remains in free-phase or residual form. The compounds could be dissolved, in which case this methodology would overstate the number of sites with free-phase or residual DNAPLs. On the other hand, since not all compounds associated with DNAPLs were included in previous studies, the estimate may be understating the extent of the DNAPL problem.

14.4 Estimated Remediation Costs
Any estimate of the value of the site ch