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Office of Solid Waste EPA 542-R-04-015 

And Emergency Response September 2004 

(5102G) www.epa.gov/tio 

clu-in.org/marketstudy 

Cleaning Up the Nation’s 

Waste Sites: Markets and 

Technology Trends 

2004 Edition
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Notice

Preparation of this report has been funded wholly or in part by the United States Environmental 

Protection Agency (EPA) under contract number 68-W-03-038. Mention of trade names or 

commercial products does not constitute endorsement or recommendations for use. This document is 

intended for information purposes and does not create new nor alter existing Agency policy or 

guidance. The document does not impose any requirements or obligations on EPA, states, other 

federal agencies, or the regulated community. 

A limited number of printed copies of Cleaning Up the Nation’s Waste Sites: Markets and 

Technology Trends, 2004 Edition is available free of charge by mail or by facsimile from: 

U.S. EPA/National Service Center for Environmental Publications (NSCEP) 

P.O. Box 42419

Cincinnati, OH 45242-2419

Telephone: 513-489-8190 or 800-490-9198

Fax: 513-489-8695

A portable document format (PDF) version of this report is available for viewing or downloading 

from the Hazardous Waste Cleanup Information (CLU-IN) web site at http://clu-in.org/marketstudy. 

Printed copies can also be ordered through that web address, subject to availability. 

For More Information 

For more information about remediation markets, including tools to help advance technologies 

through all stages of product development from bench scale to full commercialization, visit the EPA 

web site http://www.epa.gov/tio/vendor.

Page iii 
Acknowledgments 

This document was prepared for the U.S. Environmental Protection Agency's Technology Innovation 

and Field Services Division (TIFSD). The report would not have been possible without the assistance 

of staff throughout EPA, the Department of Defense (DOD), and the Department of Energy (DOE). 

Special thanks go to staff in EPA's Office of Superfund Remediation and Technology Innovation; 

Office of Solid Waste; Office of Underground Storage Tanks; Federal Facilities Restoration and 

Reuse Office; and Office of Federal Facilities Enforcement; and Office of Brownfields Cleanup and 

Redevelopment. DOD's Office of the Assistant Under Secretary of Defense for Environmental 

Security, and DOE's Office of Environmental Restoration were exceptionally generous with their 

time and expertise. Important contributions were also received from a number of other parties 

identified in various sections of the report. 

Page iv 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Executive Summary

Over the next several decades, federal, state, and 

local governments and private industry will commit 

billions of dollars annually to clean up sites 

contaminated with hazardous waste and petroleum 

products from a variety of industrial sources. This 

commitment will result in a continuing demand for 

hazardous waste site remediation services and 

technologies. 

Hundreds of small, medium, and large companies 

across the nation will respond to this demand, 

supplying skilled professionals and advanced 

technologies to address contaminated sites. 

Researchers and technology developers will 

continue working to provide smarter and cheaper 

solutions to the complex environmental 

contamination problems still to be addressed. 

Investors will seek to identify technologies that 

provide the most promising technical and financial 

future. Universities continually seek to adjust their 

environmental sciences and engineering curricula to 

ensure that their future graduates are prepared for 

the challenges they will face in this field. 

To make cost-effective and sound investment 

decisions, all these groups will need information on 

the nature and extent of the future cleanup market. 

With this need in mind, EPA has produced this 

overview of the site characterization and 

remediation market. EPA believes that information 

on the Nation’s cleanup needs will help industry 

and government officials develop better and more 

targeted research, development, and business 

strategies. 

Background

EPA’s mission includes the important goal of 

restoring contaminated land to productive use, and 

the Agency has established ambitious targets.1

 The 

Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA, or 

Superfund) and the Resource Conservation and 

2003-2008 EPA Strategic Plan, Objective 3, Land 

Preservation and Restoration. 

http://www.epa.gov/ocfo/plan/2003sp.pdf 

Recovery Act (RCRA) provide the legal authority 

for most of EPA’s work toward this goal. 

Cleanups are also generally required to comply 

with a number of other state and federal statutes. To 

achieve this goal, EPA works with many partners at 

all levels of government to ensure that appropriate 

cleanup tools are used; that resources, activities, 

and outcomes are coordinated with partners and 

stakeholders and effectively communicated to the 

public; and that cleanups are protective and 

contribute to community revitalization. 

EPA is a leader in influencing how hazardous waste 

site cleanups are conducted in all cleanup programs. 

The agency directly conducts many cleanups and 

removals under the Superfund program. In addition, 

it conducts oversight of state, tribal, and federal 

facility cleanup programs; develops regulations, 

policies, guidances, and technical publications; and 

promotes technology innovation. In its efforts to 

coordinate across the various programs, EPA seeks 

to recognize the need for cleanup tools that will 

have wide applicability. 

In developing this report, EPA has identified seven 

major cleanup programs or market segments that 

make up the national cleanup market:

 • National Priorities List (NPL, or Superfund)

 • Resource Conservation and Recovery Act

(RCRA) Corrective Action

 • Underground Storage Tanks (UST)

 • Department of Defense (DOD)

 • Department of Energy (DOE)

 • Other (Civilian) Federal Agencies

 • States and Private Parties (including

brownfields)

While segmentation is necessary to better 

understand each market, the parties involved in site 

characterization and remediation require a unified 

picture of the market in order to make better 

informed investment, marketing, and other strategic 

decisions. This study provides both perspectives—it 

sums up the entire market based on a thorough 

analysis of each segment. Smarter investments by 

all involved parties will result in more costExecutive Summary Page v 

1 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Executive Summary Page vi

effective remediation technologies, thereby

reducing the cost burden for the nation as a whole

as it works to recover contaminated land and

groundwater and protect the public’s health.

Study Approach

This report updates and expands a 1996 analysis

that brought together valuable information on site

characteristics, market size, and other factors that

affect the demand for remediation services.2

 As

with the previous report, the focus of this study is

on the potential future applications of remediation

technologies.

To provide a useful estimate of future needs, the

demand estimates focus on remaining cleanup work

at sites where the remedies have not yet been

chosen, and do not include projects that are

underway or completed. While the report considers

a broad range of remediation services required in

the future, its purpose is to provide insight into the

potential for the application of new treatment and

site characterization technologies.

This report is not a budgeting analysis. Most of the

cleanups are typically funded by the public and

private owners of the properties and those who are

potentially responsible for the contamination. A

small percentage of cleanups are likely to be

conducted by EPA. The report’s time horizon,

approximately 30 years, is beyond the budgeting

period of most private and public institutions.

Moreover, the uncertainties in many of the market

estimates, including who will conduct, oversee, and

pay for the needed cleanups, make it impossible to

convert these estimates to resource needs for

specific government or private organizations.

In addition to providing a unified perspective of the

nature and scope of the Nation’s contaminated

property cleanup needs, this report includes a more

in-depth analysis of the seven major programs or

market segments identified earlier, covering areas

such as their structure, operation, and regulatory

requirements. Information and analyses of the

following are provided for each segment:

 • Factors Affecting Demand—the economic,

political, and technical factors and trends that

may influence the size, timing, or

characteristics of the market segment (market

drivers); 

 • Numbers and Characteristics of Sites—

measures of the market in terms of the number

of sites to be remediated, occurrence of

contaminants, and extent of remediation work

needed; 

 • Estimated Cleanup Costs—remediation cost

estimates, or the value of the market; 

 • Market Entry Conditions—considerations that

may benefit vendors and researchers, such as

contracting practices, competition, and

information sources; 

 • Technology Issues and R&D—technologies

used in a specific market segment and relevant

research and development.

The study also includes analyses of remediation

needs in three market “niches,” each of which

presents a specific set of remediation

challenges—the cleanup of former manufactured

gas plant (MGP) and other coal tar sites, mining

sites, and drycleaner sites. It also addresses two

specific issues that affect hazardous waste sites in

most remediation programs—site characterization

technology, and the remediation of dense nonaqueous phase liquids (DNAPLs). These niches cut

across all seven market segments. 

The data used for this report are from federal

databases, such as the Comprehensive

Environmental Response, Compensation, and

Liability Information System (CERCLIS), RCRA

Info, and DOD’s Restoration Management

Information System (RMIS), published studies,

guidance documents, and web sites; commercial

information; and other sources. Some are current

through fiscal years (FY) 2001 and 2002, while

others are current through 2003 and the first part of

2004. Because many hazardous waste sites are still

undergoing evaluation, data availability differs from

one market segment to another. Each chapter of the

2 U.S. Environmental Protection Agency, Office of

Solid Waste and Emergency Response, Technology

Innovation Office, Cleaning Up the Nation's Waste

Sites: Markets and Technology Trends, EPA 542-R-96-

005, April 1997.
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

report includes an explanation of the analytical 

methodology, information sources, and 

assumptions, and a detailed list of references. 

Supporting information is included in the 

appendices, as well as in explanations in the 

narrative, footnotes, and figures. 

Study Limitations

The reliability and detail of the estimates in this 

report are a function of the availability and quality 

of data, and, obviously, the innate uncertainties in 

forecasting future events. In addition, each of the 

seven programs have somewhat different 

operational practices and use varying definitions of 

terms such as “sites,” “facilities,” “installations,” 

and “operable units.” Although most of the 

activities underlying this cost estimate are for 

remedial action and site evaluation, they also 

include some administrative work where costs are 

not reported separately. 

It cannot be overemphasized that the estimates in 

this report are just estimates. It is likely that 

assumptions about the future, which are based on 

historical experience, will be more reliable for the 

earlier years than the later years. Likewise, 

estimates for sites already in a state or federal 

cleanup program would be more reliable than those 

for sites that have yet to be discovered. 

Nevertheless, the resulting estimates provide a 

plausible range of the likely extent of the nation’s 

site cleanup needs. 

The estimate of the total cost of each cleanup 

market segment is based on estimates of historical 

averages for each market segment and these may 

change in the future. Future cleanups may turn out 

to be more or less complex, or applications of 

advanced site characterization and cleanup 

technologies may improve the cleanup costeffectiveness. 

Predictions of potential future site discoveries and 

additions to the NPL are also based on recent 

history. The cleanup market includes sites that are 

not yet enrolled in a cleanup program, or have not 

yet been discovered. The ultimate number of 

additions to the NPL or discoveries of non-NPL 

sites depend upon several factors which are difficult 

to predict. Nevertheless, these sites are expected to 

be an important component of the market. 

The limitations and uncertainties of the market 

estimates vary from one market segment to another. 

For example, the forecast of future releases from 

USTs is hampered by a paucity of data with which 

to estimate leakage rates; the estimate of the 

number and potential cost of mining site cleanups is 

presented as a wide range of values and reflects an 

attempt to develop a consensus of a number of 

industry and government sources; and the estimate 

of the number of potential manufactured gas plant 

sites needing cleanup is based on studies that have 

estimated the number of original facilities that cause 

the contamination and assumptions regarding their 

disposition since their operations ceased many 

years ago. Although DOD and DOE have clearly 

identified most of the contamination problems at 

their installations and facilities, there are 

technological uncertainties at some DOE sites 

which may cause the estimates to be overstated or 

understated. 

Although this report estimates the potential scope of 

the market, it does not explicitly estimate the timing 

of the cleanup work. As in most economic 

activities, one cannot simply assume that the 

cleanup work will be conducted at a constant pace 

from year to year. The schedule of any project can 

be expedited or retarded by the availability of funds 

in any given year; technical uncertainties; 

difficulties in achieving agreements among 

stakeholders on a number of issues, such as cleanup 

approach and target end states, who will pay, who 

is responsible for damages, and how the site will be 

reused. In addition, long-term stewardship will be 

needed at many sites. 

Executive Summary Page vii 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Major Findings

Although substantial progress has been made over • Under current regulations and practices a total 

the past quarter century, a considerable amount of of 235,000-355,000 sites (average 294,000) 

cleanup work remains. At current levels of site will need to be cleaned up in all seven 

cleanup activity in the U.S. (About $6-8 billion programs (Exhibit). More than 90 percent of 

annually), it would take 30 to 35 years to complete these sites are in programs that tend to have 

most of the work needed. smaller, less-complex cleanup projects, such as 

UST sites and sites managed under state 

Quantifying the amount and nature of future work cleanup programs. The sites in the remaining 

is subject to the limitations and uncertainties programs, such as Superfund, DOD, and DOE, 

described above and requires making a number of tend to be larger and more complex, on 

assumptions. Users of the report will reap the average. 

greatest benefit if they carefully review the • These cleanups are estimated to cost $170-250 

discussions of how the estimates were developed, billion (average $209 billion). Most of this cost 

which are included throughout the report. Given will be borne by the owners of the properties 

these limitations, the following are some of the (private and public entities) and those 

major findings: potentially responsible for the contamination.

Estimated Number of Hazardous Waste Sites 

and Cleanup Costs: 2004-2033 

• The estimated number of sites (294,000) estimated number of future sites (mostly NPL, 

includes sites that have already been discovered UST and sites managed under state programs) 

(77,000) plus an estimate of the number of sites is based on the rate of new sites discovered in 

to be discovered in the future (217,000). The the late 1990s and early 2000s: 

Executive Summary Page viii 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

÷ Between 1993 and 2003 an average of 28 

sites per year were listed on the NPL. This 

report assumes that this rate will continue 

for 10 years. Although listings may 

continue beyond 10 years, they are not 

included because of uncertainties in 

predicting NPL listings. 

÷ The estimated number of future UST site 

discoveries is based on the annual rate of 

new releases in recent years (6,000-12,000) 

and the assumption that this rate will 

continue for 10 years. Although tank 

releases may continue beyond 10 years and 

leakage rates may decline, these scenarios 

are not included because of uncertainties in 

predicting these trends. 

÷ The estimated number of sites to be 

discovered under state mandatory and 

voluntary cleanup programs is based on an 

average of 5,000 cleanups completed 

annually in recent years. Because studies 

indicate that there are many sites yet to be 

discovered, it is assumed that this activity 

level will continue for at least 30 years.

 • Most cleanup programs have similar 

contaminants: solvents and other organics, 

metals, and petroleum products.

 • Over the next 30 years, there will be a need to 

address many smaller sites, primarily 125,000 

UST and 150,000 state and private party sites 

(including brownfields). There is also a need to 

screen many more sites to determine whether or 

not they have contamination problems. 

• The demand for cleanup of many sites will be 

influenced by real estate development activity 

as well as regulatory requirements. Some sites 

do not come to the attention of state or federal 

cleanup programs until they are investigated in 

the course of development activity or real estate 

transactions. For some properties, developers or 

prospective site users may assume all or part of 

the cleanup costs.

 • Non-DOD and non-DOE federal agencies that 

have contaminated sites, including the 

Departments of Interior, Agriculture, and 

Transportation, combined, have been spending 

less than $200 million annually for site 

cleanups. They have an estimated $15-21 

billion of cleanup work yet to be completed.

 • Improved approaches to site characterization 

have been demonstrated to lead to faster, 

cheaper, and better cleanups. For example, 

newer site characterization approaches have 

made the removal and treatment of DNAPLs at 

some sites more cost effective than containing 

the material in the subsurface. 

• The trend toward risk-based cleanups, which is 

found throughout the remediation market, may 

influence the remedy selection process, foster 

more flexibility in site reuse, and provide 

incentives for property owners to bring more 

sites into remediation programs. It is difficult to 

predict the impact of these developments on the 

use of specific remedy types.

 • The need for monitoring and long-term

operation and maintenance of remedy

components is expected to increase in most

market segments.

At current public and private spending levels for 

site cleanups, it will take several decades to 

complete all the cleanup work estimated in this 

report. As with most cleanups requiring technically 

complex solutions and coordination of multiple 

stakeholders, the work load will probably fluctuate 

from year to year. Most of these costs will be borne 

by private companies, and owners of state and 

federal facilities, such as DOD and DOE. This 

market represents a significant opportunity for 

continued development and implementation of 

cleanup approaches and technologies that will result 

in better, cheaper, and faster site cleanups, as well 

as technologies that enable us to better address 

challenging contamination problems such 

characterizing NAPLs in the subsurface. 

Technical solutions to a particular contaminated site 

problem are generally similar, regardless of the 

regulatory program under which they are 

implemented. While individual markets may not 

support certain investment decisions, the aggregate 

demand across all markets might justify the upfront investment in a technology that ultimately 

drives down the cost of moving contaminated sites 

into productive use. By recognizing this potential 

for economies of scale in cleanup technology 

markets, the information in this report contributes to 

better investment decisions across all markets. 

Executive Summary Page ix 
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Executive Summary Page x
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Table of Contents Page xi

Table of Contents

Page

Notice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

Chapter 1. Introduction and Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

1.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

1.2 Using This Document . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2

1.3 Study Approach and Limitations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2

1.4 Market Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4

1.5 Hazardous Waste Site Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-13

1.5.1 Contaminated Media . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-14

1.5.2 Contaminants of Concern . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-14

1.6 Cleanup Program Status and Factors Affecting Demand . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-16

1.6.1 Superfund Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-17

1.6.2 RCRA Corrective Action Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-18

1.6.3 Underground Storage Tank Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-19

1.6.4 Department of Defense Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-20

1.6.5 Department of Energy Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-20

1.6.6 Civilian Federal Agency Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-21

1.6.7 State and Private Party Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-22

1.6.8 Manufactured Gas Plant Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-23

1.6.9 Mining Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-24

1.6.10 Drycleaner Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-24

1.6.11 Site Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-25

1.6.12 DNAPLs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-25

1.7 Implications for Site Characterization and Cleanup . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-26

Chapter 2. Remediation Technologies Used At National Priorities List Sites . . . . . . . . . . . . . . . . 2-1

2.1 Definitions of Remediation Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

2.2 Historical Use of Remediation Technologies at Superfund Sites . . . . . . . . . . . . . . . . . . . . . . . 2-2

2.2.1 Containment and Disposal Technologies for Source Control . . . . . . . . . . . . . . . . . . . . . 2-4

2.2.2 Treatment Technologies for Source Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5

2.2.3 Groundwater Remedies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6

2.3 Advancing Remediation and Characterization Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7

2.4 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Page 

Chapter 3. Demand For Remediation of National Priorities List Sites ...................... 3-1

3.1 The Superfund Program ...................................................... 3-1

3.1.1 The National Contingency Plan ............................................ 3-1

3.1.2 The Superfund Process .................................................. 3-2

3.1.3 Program Status ......................................................... 3-3

3.2 Factors Affecting Demand for Cleanup ........................................... 3-3

3.3 Number of Sites ............................................................. 3-5

3.4 Site Characteristics .......................................................... 3-7

3.4.1 Types of Contaminated Matrices ........................................... 3-8

3.4.2 Types of Contaminants .................................................. 3-8

3.4.3 Estimated Quantities of Contaminated Material .............................. 3-11

3.5 Estimated Cleanup Costs ..................................................... 3-13

3.6 Market Entry Considerations .................................................. 3-15

3.6.1 Market Considerations During Remedy Selection ............................. 3-16

3.6.2 Market Considerations During Design and Procurement ....................... 3-17

3.6.3 Research, Development, and Demonstration ................................. 3-18

3.7 References ................................................................ 3-19

Chapter 4. Demand for Remediation of RCRA Corrective Action Sites .................... 4-1

4.1 Program Description ......................................................... 4-2

4.1.1 Regulatory History ...................................................... 4-2

4.1.2 Corrective Action Process ................................................ 4-7

4.1.3 Corrective Action Implementation .......................................... 4-8

4.2 Factors Affecting Demand for Cleanup .......................................... 4-10

4.3 Number and Characteristics of RCRA Sites ...................................... 4-11

4.3.1 Number of RCRA Sites ................................................. 4-11

4.3.2 Types of RCRA Sites ................................................... 4-13

4.4 Estimated Cleanup Costs ..................................................... 4-16

4.5 Market Entry Considerations .................................................. 4-17

4.6 Remediation Technologies ................................................... 4-17

4.7 References ................................................................ 4-19

Chapter 5. Demand for Remediation of Underground Storage Tank Sites .................. 5-1

5.1 Federal Program Description ................................................... 5-2

5.2 Factors Affecting Demand for Cleanup ........................................... 5-4

5.2.1 General Trends ......................................................... 5-4

5.2.2 State Regulations and Funding Sources ...................................... 5-6

5.2.3 2002 Brownfields Legislation and EPA’s USTfields Initiative .................... 5-7

5.2.4 MTBE Contamination and the Remediation Market ............................ 5-7

5.2.5 State Performance-Based Environmental Cleanup Programs ..................... 5-8

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Page 

5.3 Number and Location of USTs ................................................. 5-9

5.3.1 Population of UST Sites in the U.S.......................................... 5-9

5.3.2 Location of Regulated Tanks ............................................. 5-10

5.3.3 Potential Number of Sites to be Cleaned Up ................................. 5-10

5.4 Estimated Cleanup Costs ..................................................... 5-12

5.5 Market Entry Considerations .................................................. 5-12

5.6 Remediation Technologies ................................................... 5-13

5.7 References ................................................................ 5-15

Chapter 6. Demand For Remediation of Department of Defense Sites ...................... 6-1

6.1 Program Description ......................................................... 6-2

6.1.1 Installation Restoration Program ........................................... 6-2

6.1.2 Base Realignment and Closure (BRAC) ..................................... 6-4

6.1.3 The Military Munitions Response Program ................................... 6-5

6.2 Factors Affecting the Demand for Cleanup ........................................ 6-5

6.3 Number and Characteristics of Sites ............................................. 6-6

6.3.1 Number and Types of Sites ............................................... 6-6

6.3.2 Contaminated Matrices .................................................. 6-9

6.3.3 Types of Contaminants ................................................. 6-11

6.4 Estimated Cleanup Costs ..................................................... 6-13

6.5 Market Entry Considerations .................................................. 6-14

6.6 Remediation Technologies ................................................... 6-16

6.6.1 Technologies Used at DOD Sites .......................................... 6-16

6.6.2 Research, Development, and Demonstration ................................. 6-16

6.7 References ................................................................ 6-18

Chapter 7. Demand For Remediation of Department of Energy Sites ...................... 7-1

7.1 Program Description ......................................................... 7-2

7.1.1 Deactivation and Decommissioning of Surplus Facilities ........................ 7-3

7.1.2 Remedial Actions ....................................................... 7-4

7.1.3 Long-Term Surveillance and Maintenance ................................... 7-5

7.1.4 Stabilization of High-Risk Materials ........................................ 7-6

7.1.5 Regulatory Requirements and Other Program Drivers .......................... 7-6

7.1.6 Policy Initiatives: The Top-to-Bottom Review ................................ 7-7

7.2 Factors Affecting Demand for Cleanup ........................................... 7-7

7.3 Number and Characteristics of Sites ............................................. 7-9

7.4 Estimated Cleanup Costs ..................................................... 7-12

7.4.1 Life Cycle Costs ....................................................... 7-12

7.4.2 Timing of Expenditures ................................................. 7-14

7.5 Market Entry Considerations .................................................. 7-14

7.6 Remediation Technologies ................................................... 7-17

7.6.1 Private Sector Involvement: Mechanisms ................................... 7-20

7.6.2 Private Sector Involvement: Programs ...................................... 7-21

7.7 References ................................................................. 7-24

Table of Contents Page xiii
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Page 

Chapter 8. Demand for Remediation of Sites Managed By Civilian Federal Agencies ......... 8-1

8.1 Civilian Federal Agency Cleanup Programs ....................................... 8-2

8.2 Factors Affecting Demand for Cleanup ........................................... 8-3

8.3 Number of Facilities and Sites .................................................. 8-4

8.4 Site Characteristics .......................................................... 8-7

8.5 Estimated Cleanup Costs ...................................................... 8-8

8.6 Remediation Technologies ................................................... 8-11

8.7 References ................................................................ 8-11

Chapter 9. Demand for Remediation of States and Private Party Sites ..................... 9-1

9.1 Programs Addressing State Sites ................................................ 9-2

9.1.1 State Hazardous Waste Cleanup Programs ................................... 9-2

9.1.2 Voluntary Cleanup and Brownfield Programs ................................. 9-4

9.1.3 Federal Initiatives Affecting State Cleanups .................................. 9-6

9.2 Factors Affecting Demand for Cleanups .......................................... 9-7

9.3 Number and Characteristics of Sites ............................................. 9-9

9.3.1 State Mandatory Hazardous Waste Programs ................................. 9-9

9.3.2 Voluntary Cleanup and Brownfield Programs ................................ 9-12

9.3.3 Contaminants and Media ................................................ 9-13

9.4 Estimated Cleanup Costs ..................................................... 9-15

9.4.1 Status and Capacity of State Cleanup Funds ................................. 9-15

9.4.2 Annual and Projected Cleanup Costs ....................................... 9-18

9.5 Market Entry Conditions ..................................................... 9-19

9.6 Remediation Technologies ................................................... 9-21

9.7 References ................................................................ 9-22

Chapter 10. Demand for Remediation of Manufactured Gas Plants and 

Related Coal Tar Sites .................................................. 10-1

10.1 History .................................................................. 10-1

10.2 Gas Manufacturing Processes ................................................ 10-2

10.3 Number and Characteristics of Sites ........................................... 10-2

10.4 Waste Types and Quantities ................................................. 10-7

10.5 Remediation Technologies .................................................. 10-9

10.6 Estimated Cleanup Costs ................................................... 10-13

10.7 References .............................................................. 10-15

Table of Contents Page xiv 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Page 

Chapter 11. Demand for Remediation of Mining Sites .................................. 11-1

11.1 Industry Description ....................................................... 11-1

11.1.1 Types of Mining ...................................................... 11-2

11.1.2 Mining Processes ..................................................... 11-2

11.1.3 Types of Wastes ...................................................... 11-4

11.1.4 Regulatory Programs .................................................. 11-5

11.1.5 Mines on Federal Lands ................................................ 11-7

11.2 Factors Affecting Demand ................................................... 11-8

11.3 Number of Sites ........................................................... 11-9

11.4 Market Entry Conditions ................................................... 11-12

11.5 Estimated Cleanup Costs ................................................... 11-12

11.6 Remediation Technologies ................................................. 11-13

11.7 Research and Development ................................................. 11-14

11.8 References .............................................................. 11-15

Chapter 12. Demand for Remediation of Drycleaner Sites .............................. 12-1

12.1 Industry Description ....................................................... 12-1

12.1.1 Drycleaning Processes ................................................. 12-2

12.1.2 Types of Wastes and Waste Management Practices .......................... 12-5

12.1.3 State and Industry Drycleaner Site Cleanup Programs ........................ 12-6

12.2 Factors Affecting Demand for Remediation ..................................... 12-7

12.3 Number and Characteristics of Sites ........................................... 12-8

12.3.1 Active Drycleaning Facilities ............................................ 12-8

12.3.2 Inactive Drycleaning Facilities ......................................... 12-10

12.4 Market Entry Considerations ................................................ 12-11

12.5 Estimated Cleanup Costs .................................................. 12-11

12.6 Remediation Technologies ................................................. 12-11

12.6.1 Site Assessment Technologies .......................................... 12-13

12.6.2 Remediation Technologies ............................................. 12-14

12.7 References .............................................................. 12-15

Chapter 13. Demand for Site Characterization Services ................................ 13-1

13.1 Market Description ........................................................ 13-1

13.2 Site Characterization Tools .................................................. 13-5

13.2.1 Sample Access and Collection Technologies ............................... 13-6

13.2.2 Sample Analysis Technologies .......................................... 13-6

13.2.3 Field Technologies .................................................... 13-7

13.2.4 Adaptive Site Management Approaches ................................... 13-7

13.3 Factors Affecting Demand .................................................. 13-11

13.4 Number of Sites That Will Need Characterization ............................... 13-13

13.5 Estimated Value of Site Characterization Market ................................ 13-16

13.6 Market Entry Conditions ................................................... 13-18

13.7 References .............................................................. 13-19

Table of Contents Page xv
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Page 

Chapter 14. DNAPLs at Hazardous Waste Sites ....................................... 14-1

14.1 Market Description ........................................................ 14-1

14.1.1 DNAPLs in the Environment ............................................ 14-2

14.1.2 Chemical Compounds that are DNAPLs ................................... 14-2

14.1.3 Industrial Activities ................................................... 14-3

14.1.4 Hydrogeological Characteristics ......................................... 14-4

14.2 Factors Affecting Demand for Remediation Services .............................. 14-4

14.3 Number and Types of Sites .................................................. 14-6

14.4 Estimated Cleanup Costs .................................................... 14-9

14.4.1 Pump-and-Treat System Costs ........................................... 14-9

14.5 Remediation Technologies ................................................. 14-13

14.5.1 Site Characterization ................................................. 14-13

14.5.2 Treatment Technologies ............................................... 14-14

14.5.3 Balancing Source Removal/Treatment vs. Containment ...................... 14-15

14.6 References .............................................................. 14-16

Appendix A. Supporting Data for Analysis of National Priorities List Sites ................. A-1

Appendix B. Supporting Data for Analysis of Underground Storage Tank Sites ............. B-1

Appendix C. Supporting Data for Analysis of Department of Defense Sites ................. C-1

Appendix D. Supporting Data for Analysis of Manufactured Gas Plant Sites ............... D-1

Appendix E. Federal and State Programs ............................................. E-1

Appendix F. Acronyms ............................................................ F-1

Table of Contents Page xvi 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

List of Exhibits 

Exhibit Page

 1-1 Estimated Number of Sites to be Remediated ...................................... 1-5

 1-2 Estimated Remaining Remediation Cost ($Billions) ................................ 1-6

 1-3 Media to be Remediated ..................................................... 1-14

 1-4 Contaminant Groups to be Remediated ......................................... 1-15

 2-1 Treatment Technologies ...................................................... 2-3

 2-2 Remedy Types Selected or Used for Source Control at NPL Sites, FY 1982-2002 ......... 2-4

 2-3 Superfund Remedial Actions at Source Control Treatment Projects FY 1982-2002 ........ 2-6

 2-4 Groundwater and Other Remedy Types Selected or Used at NPL Sites, FY 1982-2002 ..... 2-7

 2-5 Superfund Sites With P&T, In-situ Treatment, or MNA 

as Part of a Groundwater Remedy FY 1982-2002 ............................... 2-8

 3-1 Location of NPL Sites With Planned Remedial Actions by State and EPA Region ........ 3-5

 3-2 Phase of Remediation of Operable Units at Non-Federal NPL Sites 

with Planned Remedial Actions ............................................. 3-6

 3-3 Frequencies of Contaminated Matrices at NPL Sites With RODs ...................... 3-8

 3-4 Frequencies of Major Contaminant Groups at NPL Sites With RODs ................... 3-9

 3-5 Frequencies of Major Contaminant Subgroups at NPL Sites With RODs ............... 3-10

 3-6 Frequencies of the Most Common Contaminants at NPL Sites With RODs ............. 3-11

 3-7 Distribution of Quantities of Contaminated Soil, Sediment, and Sludge 

at NPL Sites With RODs ................................................. 3-12

 3-8 Estimated Quantity of Contaminated Soil, Sediment, and Sludge for Major

Contaminant Groups at NPL Sites With Planned Remedial Actions ............... 3-13

 3-9 Estimated Cleanup Costs for NPL Sites ......................................... 3-14

 4-1 Location of RCRA Sites Subject to Corrective Action by State and EPA Region ......... 4-12

 4-2 Priority Ranking of RCRA Sites Subject to Corrective Action ....................... 4-13

 4-3 Location of RCRA Sites Likely to Require Corrective Action by State and EPA Region . . . 4-14

 4-4 Major Waste Management Processes at RCRA Facilities ........................... 4-14

 4-5 Estimated RCRA Corrective Action Costs ($Millions) ............................. 4-17

 4-6 Remedies Selected for Soil at 86 RCRA Corrective Action Facilities .................. 4-18

 5-1 Backlog of UST Site Cleanups to be Completed ................................... 5-4

 5-2 Confirmed Releases at UST Sites ............................................... 5-4

 5-3 Compliance Status of USTs by Region ........................................... 5-5

 5-4 UST Site Cleanup Progress 1991-2002 ......................................... 5-10

 5-5 Estimated Number of UST Sites Needing Remediation ............................. 5-11

 5-6 Types and Frequencies of Soil Remediation Technologies at LUST Sites ............... 5-13

 5-7 Type and Frequency of Groundwater Remediation Technologies at LUST Sites ......... 5-14

Table of Contents Page xvii
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit Page

 6-1 Number of DOD Sites by Status ................................................ 6-7

 6-2 Number of DOD Sites and Installations Needing Cleanup ............................ 6-8

 6-3 Location of DOD Sites Needing Cleanup ......................................... 6-8

 6-4 Most Common Types of DOD Sites Needing Cleanup .............................. 6-9

 6-5 Frequency of Contaminated Matrices at DOD Sites Needing Cleanup ................. 6-10

 6-6 Frequency of Contaminated Matrices by Site Type at DOD Sites Needing Cleanup ....... 6-10

 6-7 Major Contaminant Groups by Matrix at DOD Sites Needing Cleanup ................. 6-11

 6-8 Major Contaminant Groups by DOD Component at Sites Needing Cleanup ............. 6-12

 6-9 Frequency of Major Contaminant Groups 

for the Most Common DOD Site Types Needing Cleanup ........................... 6-13

 6-10 DOD Cleanup Expenditures: FY 2001-2005 ..................................... 6-13

 6-11 Treatment Technologies Used at DOD Sites ..................................... 6-17

 7-1 Remaining Release Sites and D&D Facilities by Location ........................... 7-11

 7-2 Estimated Remaining Life Cycle Cost for DOE Site Restoration by Installation .......... 7-13

 7-3 Actual and Planned EM and Site Restoration Budget: FY 2000-2004 .................. 7-14

 7-4 DOE Environmental Management Expenditures 2002-2004 ($000) ................... 7-15

 7-5 Examples of Innovative Technologies Useful to DOE .............................. 7-18

 8-1 Number of Civilian Federal Facilities Potentially Requiring Cleanup ................... 8-5

 8-2 DOI Allocation of the Central Hazardous Materials Fund ............................ 8-6

 8-3 Examples of Types of Contaminated Facilities at Civilian Federal Agencies ............. 8-8

 8-4 Estimate Cleanup Cost for Civilian Federal Agencies ............................... 8-9

 9-1 State Cleanup Program Summary ............................................... 9-3

 9-2 Sites in State Hazardous Waste Programs ....................................... 9-10

 9-3 Number of Non-NPL State Hazardous Waste Sites ................................ 9-11

 9-4 Voluntary and Mandatory Cleanup Program Status ................................ 9-13

 9-5 Contaminants Found at a Sample of Brownfield Sites .............................. 9-14

 9-6 State Fund Activity 1995, 1997, and 2000 ($ millions) ............................. 9-16

 9-7 State Hazardous Waste Funds Expenditures and Balances 2000 and 1997 .............. 9-17

 9-8 Estimated Total Cost of State Site Cleanups ($Millions) ............................ 9-19

 9-9 Remediation Techniques Used at a Sample of Brownfield Sites ...................... 9-22

 10-1 Types and Numbers of Former Manufactured Gas Plants 

& Related Coal Tar Facilities in the U.S. ..................................... 10-4

 10-2 Estimated Magnitude & Disposition of Former Manufactured Gas Plants

& Other Coal Tar Sites in the U.S .......................................... 10-6

 10-3 Estimated Quantities of Residuals and Wastes Released

at Former MGP & Other Coal Tar Sites in the U.S. ............................. 10-8

 10-4 Remediation Alternatives by Category of Waste 

at Former Manufactured Gas Plants ........................................ 10-11

 10-5 Estimated Average Remediation Cost by Site Type ............................... 10-14

 11-1 Number of Active Mining Sites - 2001 ......................................... 11-10

 11-2 Comparison of Estimates of Number of Abandoned Hard Rock Mining Sites .......... 11-11

 11-3 Estimated Remediation Costs for U.S. Hardrock Mines ............................ 11-13

Table of Contents Page xviii
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Table of Contents Page xix

Page

 12-1 Number and Types of Active Drycleaners in the United States . . . . . . . . . . . . . . . . . . . . . . . 12-9

 12-2 Estimated Drycleaner Site Remediation Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12-12

 12-3 Site Assessment Technologies Used at Drycleaner Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . 12-13

 12-4 Site Remediation Technologies Used at Drycleaner Sites . . . . . . . . . . . . . . . . . . . . . . . . . . 12-14

 13-1 Major Characterization Technology Subcategories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13-6

 13-2 Examples of Common Field Analytical Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13-8

 13-3 Examples of Projects with Savings and Efficiency Improvements

Associated With Advanced Site Characterization Technologies . . . . . . . . . . . . . . . . . . . . . 13-12

 13-4 Estimated Number of Sites to Require Sampling and Analysis . . . . . . . . . . . . . . . . . . . . . . 13-15

 13-5 Estimated Major Components of Superfund Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13-16

 13-6 Remediation Cost and Site Size ($millions) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13-17

 13-7 Estimated Site Characterization Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13-17

 14-1 Common DNAPL-Related Chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14-3

 14-2 Occurrence of VOCs and SVOCs at Contaminated Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14-6

 14-3 Estimated Number of Sites With DNAPLs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14-8

 14-4 Cleanup Costs for Selected Pump-and-Treat Projects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14-10

 14-5 Comparison of Pump-and-Treat Costs for Selected Projects . . . . . . . . . . . . . . . . . . . . . . . . 14-11

 A-2 Contaminant Groups and Subgroups for the Analysis of Contaminants 

at NPL and DOD Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-3

 A-2 Superfund Remedial Action Contractors (RACs) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-13

 B-1 UST Corrective Action Measures Mid-Year FY 2004 (As of March 31, 2004) . . . . . . . . . . . B-2

 C-1 Location of DOD Sites Needing Cleanup . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-2

 C-2 Definitions of DOD Site Types . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-4

 C-3 DOD Site Types Needing Cleanup . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-10

 C-4 Frequency of Matrices by DOD Site Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-12

 C-5 Frequency of Major Contaminant Groups by Matrix and DOD Component . . . . . . . . . . . . . C-14

 C-6 Frequency of Major Contaminant Groups by DOD Site Type . . . . . . . . . . . . . . . . . . . . . . . . C-16

 C-7 Frequency of Contaminant Subgroup by Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-18

 D-1 Estimated Disposition of Former Manufactured Gas Plants 

& Other Coal Tar Sites in the U.S. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-2

 D-2 Estimated Typical Remediation Cost by Site Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-4
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Table of Contents Page xx
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Chapter 1 

Introduction and Summary 

1.1 Introduction

Over the next several decades, federal, state, and local governments and private industry will 

commit billions of dollars annually to clean up sites contaminated with hazardous waste and 

petroleum products. This commitment will result in a continuing demand for site remediation 

services and technologies. This report provides an overview of the site characterization and 

remediation market to help industry and government officials develop research, development, 

and business strategies. It was prepared to aid those who are developing, commercializing, and 

marketing new technologies to meet the future cleanup demand. 

This report updates and expands a 1996 analysis that brought together valuable information on 

site characteristics, market size, and other factors that affect the demand for remediation 

services.1

 As with the previous report, the focus of this study is on the potential future 

applications of remediation technologies. To provide a realistic estimate of future needs, the 

estimates of demand focus on remaining cleanup work at sites where cleanup technologies have 

not yet been chosen, and exclude projects that are underway or completed. While the report 

considers a broad range of remediation services required in the future, its purpose is to provide 

insight into the potential application of new treatment and site characterization technologies. 

In addition to providing a unified perspective of the characteristics and scope of the nation’s 

contaminated property cleanup needs, this report provides a more in-depth analysis of the seven 

major cleanup programs or market segments: 

• National Priorities List (NPL, or Superfund)

 • Resource Conservation and Recovery Act (RCRA) Corrective Action

 • Underground Storage Tanks (UST)

 • Department of Defense (DOD)

 • Department of Energy (DOE)

 • Other (Civilian) Federal Agencies

 • States and Private Parties (including brownfields) 

In addition to providing updates and new information relating to these seven market segments, 

this report also includes analyses of remediation needs in three market “niches,” each of which 

presents a specific set of remediation challenges—the cleanup of former manufactured gas plant 

(MGP) and other coal tar sites, mining sites, and drycleaner sites; and two specific issues that 

affect hazardous waste sites in most remediation programs—site characterization technology and 

the remediation of dense non-aqueous phase liquids (DNAPLs). 

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Technology Innovation 

Office, Cleaning Up the Nation's Waste Sites: Markets and Technology Trends, EPA 542-R-96-005, April 1997 

Chapter 1: Introduction and Summary Page 1-1 

1 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

1.2 Using This Document

This chapter contains a summary of the findings of this report. Chapter 2 describes the recent 

trends in the use of remedial technologies at Superfund sites. Because many contamination 

problems are similar across the seven market segments, the Superfund technology information is 

useful to help understand potential technology trends in the other markets. Chapters 3 through 9 

address each of the seven market segments listed above. These seven segments can be added to 

arrive at the total remediation market. 

Chapters 10 through 14 address five specialized portions of the remediation market. The 

analyses in these chapters are from a different perspective than the first seven market segments, 

and the estimates of market size and value are not additive to those in chapters 3 through 9. The 

five topics include manufactured gas plant sites (MGPs), mining sites, drycleaner sites, site 

characterization, and dense non-aqueous phase liquids (DNAPLs). 

For most market segments, seven areas are addressed within each chapter: 

• Program or Market Segment Description—the structure, operation, and regulatory

requirements of the program; 

• Factors Affecting Demand—the economic, political, and technical factors and trends that

influence the size, timing, or characteristics of the market segment (market drivers); 

• Numbers and Characteristics of Sites—measures of the market in terms of the number of 

sites to be remediated, occurrence of contaminants, and extent of remediation work needed; 

• Estimated Cleanup Costs—remediation cost estimates, or the value of the market; 

• Market Entry Conditions—considerations that may benefit vendors and researchers, such as 

contracting practices, competition, and information sources; 

• Technology Issues and Research and Development (R&D)—technologies used in a specific 

market segment and relevant research and development; and 

• References—citations are referenced at the end of each chapter. 

Appendices A through F contain supporting data, sources for additional information on the 

remediation market and technologies, and definitions of terms used in this report. The acronyms 

are on the last four pages of the document (Appendix F). 

1.3 Study Approach and Limitations 

The data used for this report are from federal databases, such as the Comprehensive 

Environmental Response, Compensation, and Liability Information System (CERCLIS), RCRA 

Info, and DOD’s Restoration Management Information System (RMIS), published studies, 

guidance documents, and web sites; commercial information; and other sources. Some are 

Chapter 1: Introduction and Summary Page 1-2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

current through fiscal years (FY) 2001 and 2002, while others are current through 2003 and the 

first part of 2004. Because many sites are still undergoing evaluation, data availability differs 

from one market segment to another. Each chapter includes an explanation of the analytical 

methodology, information sources, and assumptions, and a list of references. Supporting 

information is included in the appendices. 

This report is not a budgeting analysis. Most of the cleanups are typically funded by the public 

and private owners of the properties and those who are potentially responsible for the 

contamination. A small percentage of cleanups are likely to be conducted by EPA. The report’s 

time horizon, approximately 30 years, is beyond the budgeting period of most private and public 

institutions. Moreover, the uncertainties in many of the market estimates, including who will 

conduct, oversee, and pay for the needed cleanups, make it impossible to convert these estimates 

to resource needs for specific government or private organizations. 

It cannot be overemphasized that the estimates in this report are just estimates. It is likely that 

assumptions about the future, which are influenced by historical experience, will be more 

reliable for the earlier years than the later years. Likewise, estimates for sites already in a state or 

federal cleanup program would be more reliable than those for sites that have yet to be 

discovered. Nevertheless, the resulting estimates provide a plausible picture of the likely extent 

of the nation’s hazardous waste site cleanup needs. 

The limitations and uncertainties of the market estimates vary from one market segment to 

another. For example, the forecast of future releases from USTs is hampered by a paucity of data 

with which to estimate leakage rates; the estimate of the number and potential cost of mining site 

cleanups is presented as a wide range of values and reflects an attempt to develop a consensus of 

a number of industry sources; and the estimate of the number of potential manufactured gas plant 

sites needing cleanup is based on studies that have estimated the number of original facilities that 

caused the contamination and assumptions regarding their disposition since their operations 

ceased many years ago. Although DOD and DOE have clearly identified much of the 

contamination problems at their installations and facilities, there are a significant number of 

DOE sites that have not yet been fully characterized. The analysis is further complicated by the 

fact that the definitions of sites and facilities differ somewhat from one market segment to 

another. In this report, the term “site” is used to indicate an individual area of contamination, 

which can be small or large. The terms “facility” and “installation” identify an entire tract, 

including contiguous land within the borders of a property, and may contain more than one site. 

Although this report estimates the potential scope of the market, it does not explicitly estimate 

the timing of the cleanup work. As in most economic activities, one cannot simply assume that 

the cleanup work will be conducted at a constant pace from year to year. The schedule of any 

project can be expedited or retarded by the availability of funds in any given year; technical 

uncertainties; difficulties in achieving agreements among stakeholders on a number of issues, 

such as cleanup approach and target end states, who will pay, who is responsible for damages, 

and how the site will be reused. In addition, long-term stewardship will be needed at many sites. 

Chapter 1: Introduction and Summary Page 1-3 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

1.4 Market Size

Under current regulatory requirements and practices, an estimated 294,000 sites (range 235,000 -

355,000) in the seven market segments will need to be cleaned up (Exhibit 1-1). This estimate

does not include sites where cleanup is completed or ongoing. 

More than 90 percent of these sites are in programs that tend to have relatively smaller, lesscomplex cleanup projects, such as the UST program (125,000 sites) and state voluntary and

mandatory cleanup programs (150,000). The sites in the remaining programs, such as Superfund,

DOD, and DOE, tend to be larger and more complex, on average. 

The 294,000 sites estimate includes 77,000 sites that have already been discovered plus an

estimated 217,000 sites estimated to be discovered in the future. The estimate of the number of

future sites is based on the rate of new site discoveries in recent years and is expected to be

highly variable from year to year. Future discoveries could very well turn out to be higher or

lower than in the past. Most of these “future” sites would be managed under the UST and state

mandatory and voluntary cleanup programs, including brownfields. 

This analysis assumes that EPA will add new sites to the NPL for another 10 years, UST site

discoveries will continue for 10 years, and new state and private party site discoveries will

continue for 30 years. Although new site discoveries may very well continue much longer, these

longer-term scenarios are not included in the above estimates because of uncertainties regarding

such long-term predictions. In addition to the initial site cleanup work, many sites will require

long-term stewardship and groundwater treatment or monitoring for many years.

DOD and DOE, have identified most of the contaminated sites on their properties. Nevertheless,

new ones continue to be reported each year, but at a declining rate. In addition, there is evidence

that there may be thousands of sites from

previous industrial activities, such as mining,

gas manufacturing, and drycleaning, that may For four of the seven cleanup programs, 

need to be cleaned up. Estimates for these regulatory authorities have identified most 

hazardous waste sites. There may be several sectors are not included in the above figures. hundred thousand contaminated state, private 

party, and UST sites yet to be identified, and

The estimated cost to clean up the 294,000 additions to the NPL are continuing. 

sites is about $209 billion (Exhibit 1-2). Most 

of this cost will be borne by the owners of the 

properties (private and public entities) and 

those potentially responsible for the contamination. This estimate represents the midpoint of a 

range that results from uncertainty regarding the extent and type of contamination at many sites, 

the number of sites that will be identified in the future, and the average per-site cost of 

remediation in some markets. 

Although most of the activities underlying this cost estimate are for remedial action and site 

evaluation, they also include some administrative work where costs are not reported separately. 

Because this estimate does not include inflation for future years, the amounts actually to be 

expended probably will be higher in future-year dollars. 

Chapter 1: Introduction and Summary Page 1-4 
Exhibit 1-1. Estimated Number of Sites to be Remediated 

Sites 

Market Segment 

Remaining 

to be 

Remediated 

Explanation 

Superfund The number of sites includes non-federal proposed and final National Priorities List (NP• Current Sites 456 require at least one further remedial action (RA). The NPL also includes 177 federally-o• Projected Sites 280 are addressed in the DOD, DOE, and civilian federal agencies market segments below• Subtotal, NPL 736 currently listed sites, it is assumed that EPA will add an average of 23-49 sites to the N

the next 10 years (Expected value 28). 

RCRA Corrective Action 

3,800 

Although it is likely that construction of remedies at most of these cleanups can be commany more decades may be needed for monitoring and groundwater treatment. RCRA sites related to large federal facilities are included in the DOD, DOE, and civilian federasegments below. 

Underground Storage Tanks (USTs) 125,000 

Includes 35,000 sites already identified as of March 2004, and 60,000-120,000 sites (aare projected to leak over the next 10 years The already identified sites may be underesites where "cleanups are initiated" are not included, even though some of these site ddesignated cleanup contractors. Although UST cleanups are expected to continue beyonew leaks occur, and leakage rates may decrease in the future, these scenarios are noestimate. 

DOD 6,400 DOD originally identified over 30,000 sites on over 1,700 installations. Of these, respon

completed or cleanups are planned or underway at about 24,000 sites. 

DOE 5,000 

DOE has completed active cleanup of contaminated soil, debris, and structures at half 10,000 release sites. Groundwater remediation is expected to continue at many sites, astewardship will be needed at 129 DOE installations. The estimates also are based on that there will be a greater emphasis on containment than on treatment and other reme

Civilian This figure does not include an estimated 8,000-31,000 abandoned mine sites. Federal Agencies > 3,000 

Represents 23,000 sites already identified and 127,000 new sites projected to be ident

States 150,000 30 years in state mandated programs, voluntary cleanup programs, and brownfield pro

sites may be discovered beyond the 30 years. 

Total 294,000 The total is the most likely value within a range of 235,000 to 355,000 sites. It represen

cleanup, and excludes sites where cleanup work is ongoing or complete. 

Chapter 1: Introduction and Summary Page 1-5 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 1-2. Estimated Remaining Remediation Cost ($Billions) 

Market Segment 

Cost to Clean Up 

Remaining Sites 

Middle Comments

Value Range 

Superfund 

• Current Sites 

• Projected Sites 

• Subtotal, NPL 

19.4 

12.7 

32.1

 16 - 23 

8 - 27

 24 - 50 

The current sites estimate is for currently listed sites not owned 

by the federal government that still need remedial action. The 

projected sites figure is based on an assumed 28 new additions 

to the NPL annually (range 23-49) over the next 10 years. 

RCRA, Corrective 

Action 

44.5 31 - 58 

Does not include long-term monitoring and groundwater 

treatment. RCRA Corrective Action costs related to large federal 

facilities are included in the DOD, DOE, and civilian federal 

agencies market segments. 

RCRA, UST 15.6 12 - 19 

Includes 35,000 sites already identified as of March 2004, and 

60,000-120,000 sites (average 90,000) that are projected to leak 

over the next 10 years. Additional tank leaks will probably 

continue beyond 10 years. 

DOD 33.2 NA This figure includes some costs for sites where cleanup work has 

begun. 

DOE 35.0 NA 

Does not include the cost long-term stewardship, which is 

needed at 129 DOE installations; and the cost of cleaning up 

wastes for which no proven practical cleanup approach is 

currently available, such as contamination at nuclear test sites 

and certain groundwater and surface water. 

Civilian 

Federal Agencies 18.5 15 - 22 

Does not include the potential $18-51 billion cost for cleaning up 

8,000-31,000 abandoned mine sites, most of which are on lands 

for which a federal agency is responsible for cleanup. 

States 30.0 24 - 36 There is a potential of several hundred thousand additional sites 

beyond the 30 years. 

Total 208.9 174 - 253 

The total represents estimated cost for the cleanup of sites 

required under current regulations and practices, and excludes 

sites where cleanup work has begun or is complete. 

Although this study estimates the long-term need for site cleanups, it does not estimate the pace 

of cleanup, which is likely to fluctuate from year to year, depending on private and public 

funding, who is paying for the cleanups, and other factors. However, Chapters 3 through 14 

include discussions of the factors that affect the extent and timing of the cleanup work. Most of 

the cleanup program work considered in the above estimates will take 30-35 years to complete. 

The estimates for each market segment are described below. 

Superfund Sites 

The 456 NPL sites not owned by the federal government (non-federal) that require one or more 

future remedial actions (RAs) make up a relatively well-defined market for remediation 

technologies. The NPL also includes 177 federally-owned sites with future RAs planned. These 

sites are included in the market estimates for federal agencies. The number of future listings, 

which are expected to be primarily non-federal sites, was assumed to average 28 sites annually, 

Chapter 1: Introduction and Summary Page 1-6 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

which is the average for 1993-2003. This average listing rate is within a range estimated in a 

2001 study by Resources for the Future (RFF), a non-profit environmental research group. The 

RFF study predicted that listings would average between 23 and 49 sites per year over a 10-year 

period, with a most likely value of 35. In the three years since that study, the listing rate has 

averaged 23. Most new listings are not federal sites. Although listings may continue beyond 10 

years, they are not included in this analysis because of uncertainties in predicting them. 

The estimated cost for the 456 non-federal already listed Superfund sites that have not begun RA 

is $16-23 billion, with a middle value of $19 billion (2003 dollars). This estimate is based on an 

average cost per operable unit (OU) of $1.4 million for remedial investigations/feasibility studies 

(RI/FS), $1.4 million for remedial design (RD), $11.9 million for remedial action (RA), and 

$10.3 million for long-term remedial action (LTRA) for sites that require long-term treatment to 

restore groundwater or surface water. The range in values result from varying the RA costs by 

plus and minus 20 percent. The details of these calculations and data sources are provided in 

Section 3.5. 

This estimate is more than twice that of a similar estimate in the 1997 edition of this report. The 

difference is explained by an 18 percent increase in the general price level, the fact that the 

remaining sites on the NPL that have not begun RA are expected to be more complex and have 

more OUs than the average for previous NPL sites, and the fact that LTRA costs were not 

included in the previous report. Although construction has been completed at many sites since 

the 1996 edition, about 200 sites have since been added to the NPL. 

Using the same unit cost estimates per OU, and assuming 23-49 sites will be listed annually, the 

230-490 sites assumed to be listed over the next 10 years will cost $8-27 billion. At the most 

likely listing rate of 28 sites annually, the cleanups would cost $13 billion. If more or fewer sites 

are listed, this total would be adjusted accordingly. This estimate is based upon the above 

assumptions plus the expectation that future sites will be more complex, larger, and have more 

OUs per site than the average NPL site in the past. 

RCRA Corrective Action Sites 

EPA estimates that 3,800 regulated hazardous waste treatment, storage, and disposal facilities 

(TSDFs) eventually will require remediation under the RCRA Corrective Action program. This 

number is more than half of the approximately 6,670 TSDFs that currently operate or have 

operated and are subject to the corrective action regulations. The emphasis in the short term is on 

stabilization remedies for risk reduction at about 1,700 of the 3,800 sites. Over the longer term, 

additional remedies may be required at most of the 3,800 RCRA Corrective Action sites. 

Under current regulations, cleanup of the 3,800 sites that are likely to require corrective action 

will cost between $31 billion and $58 billion, with a middle value of $44.5 billion, or $11.4 

million per facility. Approximately 41 percent of the total cost will be incurred by nine percent 

of the facilities with cleanup costs of greater than $50 million. The average cost-per-site estimate 

is based on cost data in an economic analysis in support of the development of the Corrective 

Action Management Unit (CAMU) Rule in 2000. Approximately 80-90 percent of this amount 

will be incurred by privately-owned facilities and the remainder by federal facilities. This 

Chapter 1: Introduction and Summary Page 1-7 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

estimate does not include costs for the large DOD and DOE facilities. However, since it includes 

costs for some smaller ones, there is some overlap with the estimates for DOD and DOE below. 

This estimated average cost per site is about 20 percent lower than that estimated in the 1993 

Regulatory Impact Analysis (RIA) for Subpart S. This difference reflects a variety of changes 

since that RIA, including more efficient site characterization and cleanup approaches, the use of 

risk-based cleanup approaches, and savings due to the CAMU policies described in Section 4.1. 

Over the past few years, implementation of the Corrective Action program has shifted toward 

more flexible, risk-based cleanups and away from the regulatory approach modeled in the 1993 

RIA. In addition, the near-term costs of the program are likely to reflect the program’s emphasis 

in the short term on stabilization remedies rather than permanent remedies. 

Underground Storage Tank Sites 

EPA estimates that 95,000 to 155,000 UST sites (middle value, 125,000) will require cleanup 

under the RCRA underground storage tank regulations over the next 30 years. This estimate 

includes 35,000 already identified sites that have not yet been cleaned up plus 60,000-120,000 

projected releases over a 10-year period 

(6,000-12,000 per year). The 35,000-site Although USTs account for 43% of all cleanup figure may understate the actual market sites, they account for only 7% of estimated 

because it does not include all sites without national cleanup costs. These sites are typically 

designated cleanup contractors. Some sites among the smallest and least costly to remediate. 

reported as “cleanups initiated” actually have 

not yet selected remediation technologies or 

contractors. UST sites average an estimated 2.7 tanks per site, although the number varies widely 

from one site to another. Although USTs account for 43 percent of sites to be cleaned up, they 

account for only 7 percent of the above-estimated national cleanup costs. Tank sites are typically 

the smallest and least costly to remediate, There may be some overlap with the estimated 

number of state and private sites, which includes brownfield sites and UST sites. 

The UST cleanup market could reach $12-19 billion, with a middle-value of $16 billion, or an 

average of $125,000 per UST site. This estimate does not include costs related to replacing, 

testing, or upgrading tanks, pipes, and related equipment. The availability of funds for UST 

cleanups is somewhat less dependent on public appropriations. Most of the UST costs are paid 

by property owners, state and local governments, and special trust funds, often based on 

dedicated taxes, such as fuel taxes. 

Department of Defense Sites 

The DOD estimated that, as of September 2003, remedies had not been selected for 6,400 sites 

on hundreds of installations and other locations that require remediation of contaminated 

materials. Cleanups are being planned or are underway at another almost 2,700 sites, bringing 

the total number of active DOD sites to about 9,000. These sites are distributed almost evenly 

among the Air Force, Army, Navy, and formerly used defense sites (FUDS). DOD estimates that 

all of these sites will be cleaned up by 2015. Of all DOD installations, including those where 

remedial action has begun, 146 are on the NPL. 

Chapter 1: Introduction and Summary Page 1-8 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

DOD estimates that the cost of completing all 

Federal and state agencies have increased the remaining remediation work at all DOD their emphasis on cleaning up sites needed for sites from FY 2003 onward will be about $33 the closure or reassignment of government billion. Although most of these funds will go to facilities or economic development. 

sites that have not yet selected remedies, they 

also include some expenditures at sites already 

in remedial design or remedial action. About $16.4 billion of these funds are for cleanups at sites 

being realigned or closed (BRAC) as well as non-BRAC installations. The remaining $16.8 

billion is for the cost to complete over 1,700 sites that may contain unexploded ordnance or 

waste military munitions. About 20 percent of DOD’s FY 2004 planned cleanup expenditures of 

about $1.7 billion is for evaluating and cleaning up properties that are to be transferred to other 

federal, state, or local government agencies or private parties (BRAC) sites. This percentage has 

ranged from 20 to 37 percent between 2000 and 2004 and averaged almost 30 percent. 

Department of Energy Sites 

The DOE has identified about 5,000 contaminated sites on 39 installations and other locations 

that require remediation. DOE is responsible for 19 currently listed NPL sites in 13 states. The 

Department expects to have almost all its sites cleaned up by 2035, although monitoring and 

groundwater treatment may continue beyond that period. In addition, no remedy is yet available 

for some of DOE’s wastes. DOE estimates that long-term stewardship will be needed at up to 

129 installations and has established the Office of Legacy Management to address this need. 

The DOE estimates that environmental restoration of 

The DOE market estimates utilize several its properties will cost $35 billion and take until 2035 critical assumptions, which make them to complete active remediation at most of its sites.2 

sensitive to budget fluctuations, cleanup The estimates do not include the cost of cleaning up standards, and further site investigations. wastes for which no proven cleanup technology 

currently exists, such as wastes at nuclear test sites 

and much of the groundwater contamination the agency is responsible for addressing. The 

estimates also are based on the assumption that there will be greater emphasis on containment 

than on treatment and other remediation strategies. Five installations account for 71 percent of 

the value of the remediation work: Rocky Flats Environmental Technology Site, Colorado; Idaho 

National Engineering Laboratory, Idaho; Savannah River Site, South Carolina; Oak Ridge 

Reservation, Tennessee; and Hanford Reservation, Washington. These costs include those for all 

environmental restoration required under the CERCLA, RCRA, other federal statutes, and state 

laws. About $2.2 billion of DOE's FY 2004 requested budget of $7.8 billion is likely to go for 

site cleanup. 

Environmental restoration accounts for about one-third of DOE’s estimated environmental program. DOE 

anticipates spending $111 billion on environmental management by 2035. The other two-thirds of DOE's 

environmental management costs are for the following types of activities: waste management, nuclear material and 

facility stabilization, national program planning and management, landlord activities, and technology development. 

DOE’s FY 2004 budget for environmental management is $7.2 billion, of which $2.4 billion is for restoration. 

Chapter 1: Introduction and Summary Page 1-9 

2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Civilian Federal Agency Sites 

As of April 1995, over 3,000 contaminated sites on 700 facilities, distributed among 17 nonDOD and non-DOE federal agencies, were potentially in need of remediation. A facility may 

contain one or more contaminated areas or “sites.” Because investigations of many of these 

facilities are not complete, the exact number of facilities and sites to be remediated has yet to be 

determined. The Department of Interior (DOI), Department of Agriculture (USDA), and 

National Aeronautics and Space Administration (NASA) together account for about 70 percent 

of the civilian federal facilities reported to EPA as potentially needing remediation. Although 

3,000 sites have been identified by these agencies, there are probably more that have not yet 

been reported, including an estimated 8,000-31,000 abandoned mine sites, most of which are on 

federal lands. 

The $15-22 billion estimated cost for the cleanup of at least 3,000 civilian federal sites is based 

on estimates from various officials and reports from DOI, USDA, and NASA, which combined 

account for most civilian federal contaminated sites, and extrapolated to all federal agencies. The 

level and timing of these expenditures will depend upon the availability of resources and 

technologies. At current funding levels, about $100-200 million annually, it could take 100-200 

years to clean up all these sites. The transfer of public properties to private use may require 

agencies to reallocate resources to clean up properties designated for transfer. 

State, Private Party, and Brownfield Sites 

It is estimated that total annual expenditures for state and private cleanups has averaged about $1 

billion and that about 5,000 cleanups are typically completed annually under all mandatory and 

voluntary state programs. At this rate, 150,000 sites can be completed in 30 years, at a cost of 

$30 billion. Estimates beyond 30 years are not provided in this report, although there are 

probably several hundred thousand additional potentially contaminated sites that have not been 

identified. Sites tend to become identified and studied when a health or safety hazard becomes 

known, when a real estate transaction occurs, or when development proposals are being 

evaluated. These activities trigger development studies and due diligence investigations. Thus, 

increases in economic activity and redevelopment projects could lead to an increase in the 

number of cleanups needed at any given time. 

About half of state site cleanups in recent years have been under mandated state programs and 

half have been under voluntary cleanup and brownfields programs. In addition, there may be 

several hundred thousand additional brownfield sites yet to be identified. EPA defines 

Brownfields as “real property, the expansion, redevelopment, or reuse of which may be 

complicated by the presence or potential presence of a hazardous substance, pollutant or 

contaminant.” Although the definition can vary from state to state, they are usually abandoned, 

idled, or under-used industrial and commercial facilities. EPA's investment in brownfields, more 

than $700 million since 1995, has leveraged more than $5.1 billion in cleanup and 

redevelopment funding and financed the assessment of more than 4,300 properties. The cleanup 

of most of these sites will be the responsibility of the property owners and will probably be 

conducted in conjunction with state voluntary cleanup programs. Over the past decade, interest 

in the redevelopment of potentially contaminated sites has grown. In this situation, the 

availability of funds will be on a site-specific basis. If states want to accelerate the pace of work, 

Chapter 1: Introduction and Summary Page 1-10 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

they will have to rely on non-budget sources of funds, such as private party actions, voluntary 

cleanups, and cost recovery/cost sharing. 

Manufactured Gas Plant (MGP) Sites 

There is no separate remediation program for the characterization and remediation of MGP and 

other coal tar sites, and no line item for this category of sites in the above exhibits. MGP 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. Because these sites may be managed under different remediation programs, the 

estimates of the MGP market should not be added to those in the seven major market segments 

above. Adding these estimates would be double-counting sites and costs, thereby overestimating 

the scope of the market. 

Before the United States had a network of natural gas pipelines and electricity, fuel for lighting, 

heating, and cooking was manufactured from coal and petroleum at thousands of manufacturing 

facilities across the country. As a result of these activities, hazardous materials are likely to be 

present in the subsurface and groundwater at thousands of locations. While some of these sites, 

especially those currently owned and operated by large gas and electric utility companies, are 

being addressed, most of the former manufactured gas sites have not been identified. 

It is estimated that from 1800 to the mid-1900s between 36,000 and 55,000 manufactured gas 

plants and related coal tar sites were built in the United States. 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, almost all these plants released contaminated materials to 

the environment. It is estimated that 30,000-45,000 of these sites that probably had releases of 

hazardous substances have not been investigated and many may need to be cleaned up. 

MGP cleanup costs have been documented to range from a few hundred thousand dollars to $86 

million for a single site. Most tend to be in the $3-10 million dollar range. Should all 30,000-

45,000 sites be need cleanup, the estimated cost would be $26-128 billion. 

Mining Sites 

There are about 14,500 active coal, metal, and nonmetal mineral mines in the United States, 

between 100,000 and 500,000 abandoned hard rock (metals and nonmetal minerals) mines on 

private, state, and federal lands in the west, and approximately 13,000 abandoned coal mines, 

mostly small and mid-sized, in the east. Many of these properties continue to threaten human 

health and the environment because of the materials left behind and because mined-out areas are 

exposed to the elements. Most of the mine sites are on land for which the federal government is 

responsible, primarily DOI and USDA. Most of the mining budgets of these agencies are 

directed to safety and water quality issues, and a smaller portion is available for site remediation. 

Mining 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 site-specific factors. Therefore, the estimates of the mining-site market 

should not be added to those of the seven major market segments. Adding these estimates would 

be double-counting sites and, therefore, overestimating the scope of the market. 

Chapter 1: Introduction and Summary Page 1-11 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

There is a wide range of estimates and opinions on how many mining properties pose a serious 

risk to the environment and are likely candidates for remediation. The most promising estimates 

indicate that about 8,000-31,000 abandoned mine sites pose a significant risk to the environment 

and human health. The estimated cost for hardrock mining sites alone is $20-54 billion. 

Drycleaner Sites 

Almost 16,000 active drycleaner sites will probably need site investigation and remediation at an 

estimated cost of $6 billion. Cleanup costs are estimated to average $403,000 per site and range 

from $19,000 to over $3 million. About 28 percent of the costs are for site characterization. 

These estimates do not include cleanup work There may be 9,000 to 90,000 sites that were that may be needed at a potential 9,000-90,000 formerly occupied by drycleaners and that are “inactive” sites. Inactive sites are properties likely to have released drycleaning chemicals to 

that do not currently have a drycleaning the environment. 

operation, but did have one in the past. Older 

drycleaners used more cleaning compounds per 

garment and tended to have more releases of chemicals to the environment than newer ones. 

Over the past several decades, the amount of perchloroethylene used by the industry has 

decreased more than 80 percent. Less than 10 percent of drycleaners still use petroleum solvents. 

Site Characterization 

Although the type and amount of site characterization work needed varies widely from site to 

site, all potential hazardous waste sites require some sort of site investigation. Despite the 

variability, it is useful to estimate an approximation of the number of sites that will need 

sampling and analysis work (see box). The phases of site assessment shown in the box are 

similar to, but not precisely those, used in American Society for Testing Materials (ASTM) 

standards. Approximations were made to align phases of RCRA, Superfund and other programs. 

The cost of this work is estimated based on the 

ratio of RI/FS cost in the Superfund program to 

total cleanup cost. Remedial Investigation/ 

Feasibility Studies (RI/FS) have accounted for 

about 10 percent of total Superfund site 

expenditures and 16 percent for smaller sites. 

Applying these averages to the total site 

remediation market, and assuming historical 

site characterization practices continue, about 

$21 billion will be needed for site 

characterization work over the next 30 years. 

However, given the growing use of advanced 

site characterization approaches–including 

Estimated Sampling and Analysis 

Needs Over 30 Years (Number of Sites) 

Phase I 

Phase II 

Phase III 

Remedial Action 

O&M and Long-Term 

Remedial Action 

0 

1.2 million

285,000 

392,000 

508,000 

field analytical technologies, systematic planning, and dynamic work plans–site managers may 

allocate greater proportions of their budgets for site characterization in the future. Better site 

characterization can reduce the overall cost and improve the effectiveness of cleanups. 

Chapter 1: Introduction and Summary Page 1-12 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Sampling and analysis technologies are used during all phases of site work, except Phase I site 

assessments (estimated market of almost 12 million assessments over the next 30 years). The 

sampling and analysis required during remedial actions varies widely from one site to another. 

Remedial actions often require confirmation sampling and sometimes major additional site 

characterization. A significant amount of sampling and analysis is also needed during O&M and 

long-term remediation of groundwater and surface water. Thus the 508,000 site estimate is an 

upper-bound estimate for sites that will need continued sampling and analysis during O&M and, 

at a number of sites, long-term remediation. 

DNAPLs 

This report provides a general indication of the number of sites likely to have a DNAPL 

problem. It is estimated that 29-44 percent of NPL sites are likely to have free-phase liquid or 

residual DNAPLs present in the subsurface, or an average of 37 percent. The estimates are 28 

percent for RCRA Corrective Action and state sites, and 30 percent for DOD and DOE sites. 

Applying these percentages, it is estimated that these four program areas have a combined 

48,000 sites with a medium to high potential to have a DNAPL problem. For the other market 

segments, the data on the types of compounds used or constituents of releases were too sparse to 

develop an estimate. 

Any estimate of the value of the DNAPL cleanup work needed is hampered by the extremely 

wide range of potential site conditions and the paucity of program-wide data on costs that pertain 

to specific DNAPL remediations. However, an indication of the level of costs is provided by 

studies of pump-and-treat (P&T) costs, a major expense in DNAPL cleanups. A 2001 EPA 

study found that the average annual O&M costs of pump-and-treat systems at 79 fund-financed 

sites is approximately $570,000, and the median is $350,000. This difference is due to a small 

number of systems with relatively high costs that raise the average. The periods of operation of 

these systems as well as the costs vary widely from site to site. The average pump-and-treat 

system in the EPA study operated for 18 years, for an average cost of $10 million. Pump-andtreat systems at some sites with DNAPLs may need to operate for considerably longer periods. 

1.5 Hazardous Waste Site Characteristics

The selection of remedies at contaminated sites depends largely on the types of media and 

contaminants present. This section describes the types of contaminants and media that are to be 

remediated in the various market segments. 

The data used to develop these estimates vary widely among the market segments. The 

Superfund (NPL) data are available from the Records of Decision (RODs) for over 1,100 sites. 

The characteristics of these sites are assumed to be representative of all NPL sites, including 

those needing further remediation. The DOD media and contaminant data are based on 

information from over 6,000 sites to be remediated as of September 2001. The RCRA estimates 

are based on data from fewer than 300 of the estimated 3,800 sites to be remediated. Although 

the DOE estimates are based on data from over 100 installations, the data do not include 

information from all 10,500 sites at these installations and other properties. The DOE and RCRA 

data are from data collected in the early and mid-1990s. 

Chapter 1: Introduction and Summary Page 1-13 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

1.5.1 Contaminated Media

Groundwater and soil are the most prevalent More than three-fourths of sites have contaminated media. In addition, large contaminated soil or groundwater, or both. quantities of other contaminated material, Contaminated sediment, sludge, and surface such as sediments, landfill waste, and sludge, water also are present, but at fewer sites.

are present at many sites. Exhibit 1-3 shows 

the most common contaminated media for 

each of four market segments. More than 

three-quarters of NPL, RCRA, DOD, and DOE sites have contaminated soil or groundwater, or 

both. Contaminated sediment, sludge, and surface water also are present, but at fewer sites. Soil 

and groundwater also are a primary concern for UST sites, although comprehensive programwide data are not available. 

Exhibit 1-3. Media to be Remediated 

Percent of Sites 

Remediation Program Groundwater Soil Sediment 

NPL Sites 83% 78% 32% 

RCRA Corrective Action Sites 82% 61% 6% 

DOD Sites 63% 77% 18% 

DOE Sites 72% 72% 72% 

Notes: 

• 11% of NPL sites contain contaminated sludge; 11% of the surveyed RCRA sites contain contaminated sludge 

and 10% contain contaminated surface water; 9% of DOE sites contain contaminated surface water, and about 

half of the DOE installations contain contaminated rubble and debris. 

• The DOE soil percentages also contain sediment and sludge. 

1.5.2 Contaminants of Concern

Many contamination problems and technology needs are similar across the major remediation

programs. For example, solvents, petroleum products, and metals are common to most programs.

Some markets also have more specialized needs arising from wastes that are unique to a

particular industrial practice. For example,

DOE has a need for technologies to VOCs, the most frequently occurring characterize, treat, and dispose of mixed waste; contaminant type, are present at more than remediate radioactive tank waste; stabilize two-thirds of Superfund, RCRA, and DOD sites, 

and almost half of the DOE installations. VOCs 

(BTEX) also are the primary contaminants at 

landfills; and deactivate facilities. DOD is 

concerned with remediating soil contaminated UST sites. with explosives, unexploded ordnance, and 

perchlorate. 

Chapter 1: Introduction and Summary Page 1-14 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 1-4 shows the frequency of 

occurrence of the most prevalent Almost all of the market sectors have 

substantial numbers of sites with metals and contaminant groups. VOCs, the most VOCs. frequently occurring contaminant type, are 

present at more than two-thirds of 

Superfund, RCRA, and DOD sites, and 

almost half of the DOE sites. 

VOCs, primarily in the form of BTEX (benzene, toluene, ethylbenzene, and xylenes) also are 

primary contaminants at UST sites. Many sites to be remediated by civilian federal agencies and 

states also are believed to contain VOCs, but only sparse data for these programs are available. 

Metals are prevalent in almost all of the major market sectors. Metals, not including radioactive 

metals, are present at about three-quarters of the Superfund and DOD sites, and about half of the 

RCRA and DOE sites. They also are likely to be found in the other market segments. Of the 12 

contaminants most frequently found at Superfund and DOD sites, more than half are metals, 

primarily arsenic, chromium, lead, zinc, nickel, and cadmium. 

Exhibit 1-4. Contaminant Groups to be Remediated 

Remediation Program 

Percent of Sites 

VOCs Metals SVOCs 

NPL Sites 78% 77% 71% 

RCRA Corrective Action Sites 67% 46% 32% 

DOD Sites 64% 72% 57% 

DOE Sites 38% 55% 38% 

Notes: 

• DOE figures for VOCs and SVOCs are combined. 90% of DOE sites contain radioactive elements. 

• About 19% of DOD sites yet to be investigated and/or cleaned up may contain unexploded ordnance or waste 

military munitions. 

The contamination characteristics of each market segment are discussed below. 

For NPL sites, VOCs is the most common contaminant group remediated, followed by metals, 

and SVOCs. Most sites are complex, requiring remediation for more than one of these 

contaminant groups: 24 percent of the sites contain two contaminant groups and 52 percent 

contain all three. These contaminants are not necessarily in the same contaminated medium. 

Halogenated VOCs are by far the most common subgroup of organic contaminants, followed by 

BTEX, non-halogenated VOCs, polynuclear aromatic hydrocarbons (PAHs), non-halogenated 

SVOCs, phenols, pesticides, and polychlorinated biphenyls (PCBs). The most common metal 

cleaned up at NPL sites is arsenic, followed by chromium and lead. NPL data are based on 

contaminants for which remedies have been selected in the past. 

Chapter 1: Introduction and Summary Page 1-15 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

The most common contaminant groups at RCRA sites are halogenated VOCs, found at 60 

percent of sites; metals, found at 46 percent of sites; and non-halogenated VOCs, found at 32 

percent of sites. These estimates are based on two studies in the early 1990s that used data from 

fewer than nine percent of all the likely corrective action projects. 

Approximately 96 percent of USTs contain petroleum products including used oil and less than 

four percent contain hazardous substances. For USTs containing petroleum products, gasoline 

accounts for 66 percent and diesel fuel for 21 percent. The most likely constituents of concern in 

these products are BTEX and SVOCs, such as PAHs, creosols, and phenols. 

Based on information on over 6,000 DOD 

Hundreds of DOD sites contain explosives and sites that needed remediation as of September one percent contain radioactive contaminants. 2001, metals are found at 72 percent of the In addition, information from some installations 

sites, followed by VOCs at 64 percent, and indicates that the presence of unexploded 

SVOCs at 57 percent. Although many similar ordnance may be significantly greater than 

these percentages indicate. contaminants also are frequently found at 

non-defense related sites, some DOD sites 

contain contaminants that present unique 

problems for selecting remediation 

approaches. For example, hundreds of DOD sites with available data contain explosives, and 

about one percent contain radioactive contaminants. 

Radioactive contaminants are found at 90 percent of DOE installations and include uranium, 

tritium, thorium, and plutonium. The most frequently present non-radioactive metals, which are 

found at 55 percent of the installations, include lead, beryllium, mercury, arsenic, and chromium. 

Organic chemicals are found at 38 percent of DOE installations and include PCBs, hydrocarbons 

from fuel and other petroleum products, and TCE. Mixed waste, containing radioactive and 

hazardous contaminants, also is a problem at 

many installations. The available data do not Radioactive contaminants are found at 90 indicate if a specific contaminant has been percent of the DOE installations and nonradioactive metals are found at 55 percent. identified at only one site or at more than one 

site on an installation. 

Waste at civilian federal agency and state sites is typical of industrial facilities and include 

organic chemicals, metals, and solvents. However, no national compilation of the specific 

contaminants at these sites is available. 

Based on a limited data from samples of state sites, the most prevalent pollutant categories are 

organic chemicals, especially VOCs, SVOCs (PAHs and PCBs), solvents, and petroleum 

products. 

1.6 Cleanup Program Status and Factors Affecting Demand

The demand for remediation services is driven largely by federal and state requirements, public 

and private expenditures, and activity in the real estate and property development industries. 

Chapter 1: Introduction and Summary Page 1-16 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Changes in these factors will affect each of the market segments in a different way, since each 

market has its own priorities and operating procedures. Thus, successful planning for technology 

development and marketing of remediation services should include consideration of the program 

structure, requirements, and site characteristics of the specific market sectors as well as the 

shifting requirements and budgets. The most prevalent factors that could alter the scope of the 

cleanup effort, as well as the technologies to be used in each market, are described below. 

1.6.1 Superfund Sites

The Superfund program is the federal program to clean up releases of hazardous substances at 

abandoned or uncontrolled hazardous waste sites. As of September 30, 2003, EPA had listed 

1,518 sites on the NPL, and proposed another 54. Of these, 274 sites were deleted from the list or 

referred for response to another authority, leaving a total of 1,244 final NPL sites. As additional 

sites are studied and ranked, they may be added to the NPL. The scope of the cleanup effort, as 

well as the technologies to be used in the future, will be influenced by the following factors: 

• Between 1993 and 2003, EPA listed 305 sites, or an average of 28 sites per year. This report 

assumes that future listings will average 28 sites per year from 2004 to 2013. At this rate, 

280 additional sites would be listed by 2013. If more “NPL-eligible” sites are found and 

evaluated, they may be addressed by other programs, such as RCRA Corrective Action or a 

state program, or may continue to await evaluation and/or cleanup. Because the decision on 

whether to list a site is complex, depending on many variables and input from many 

stakeholders, there is some uncertainty inherent in any such prediction. 

• Based on information from two GAO reports (1998 and 1999) there appears to be a 

sufficient supply of Superfund-eligible sites and potentially-eligible sites in EPA’s 

CERCLIS database to supply the aforementioned 280 sites. GAO identified 1,800 sites that 

have a Hazardous Ranking System (HRS) score of at least 28.5, which make them eligible 

for consideration for listing on the NPL and estimated that another 3,800 sites in CERCLIS 

are in earlier stages of the Superfund pipeline. Evaluations of the later sites have not 

progressed to the point where their NPL eligibility could be determined. Estimates of state 

and federal program managers have varied widely regarding the percentage of these sites 

that will ultimately be listed. Thus, we can only conclude that some portion of the 5,600 

(1,800 + 3,800) sites awaiting a listing decision will eventually be listed on the NPL. In 

addition, from time to time, new site discoveries lead to new proposed listings. Thus the 

potential supply is not inconsistent with the 280-site assumption. 

• Current resources appropriated to the program may be insufficient to fully implement the 

program, as defined above—to continue work on currently listed sites, address other 

CERCLA programs, such as removals, and begin the process of listing, evaluating, and 

cleaning up additional sites. The FY 2004 budget request to manage the Superfund program 

is about $1.4 billion. According to the 2001 RFF study, Superfund faces an average annual 

budget shortfall of approximately $100-200 million over a 10-year period. Depending on 

how the budget is allocated, this shortfall may or may not affect the sites where remedies 

have not yet been selected (the focus of this report). To address a number of long-term 

Superfund issues, EPA is working with the National Advisory Council for Environmental 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Policy and Technology (NACEPT) to develop consensus on the issues and identify the 

future direction of the Superfund Program. In April 2004, The Superfund Subcommittee 

submitted its final report to the full NACEPT committee.

 • State and PRP funding for Superfund site cleanups may fluctuate in the future. Many states 

are facing serious budget shortfalls in 2003 and 2004 and many PRPs face difficult business 

conditions. The PRPs have historically paid for 70 percent of Superfund site remediations. 

For Superfund remedial actions, the states contribute 50 percent of the construction and 

operation costs where they own the site and significant amounts of operation and 

maintenance (O&M) costs for certain Superfund actions in their state. In addition, as more 

Fund-lead NPL sites complete 10 years of long-term remedial actions, states will become 

responsible for continuing the LTRA work.

 • In planning and implementing cleanups, EPA coordinates extensively with various EPA 

offices, PRPs, state and local governments, planning authorities, and local communities and 

developers. These requirements may influence the sequence of work, types of cleanup 

technologies selected for a site, and the number of sites to be listed on the NPL in the future. 

1.6.2 RCRA Corrective Action Sites

The cleanup of RCRA Corrective Action sites is influenced by the regulatory and sitemanagement refinements that EPA and the states have been building into the cleanup process, 

federal funding of state oversight, and improved field technologies which can lead to better site 

characterization, improved remedy design, lower cleanup costs, and better and faster cleanups.

 • The RCRA Cleanup Baseline sites that are striving to meet 2005 interim Government 

Performance and Results Act (GPRA) goals represent the most immediate actions to be 

taken at RCRA sites. While these sites represent the readily identified, near-term cleanup 

market, many other RCRA sites with less immediate human health concerns will also need 

cleanup. 

• Revisions to the Subtitle C requirement for cleaning up some hazardous waste implemented 

over the past decade are likely to encourage treatment and removal as compared to leaving 

waste in place.

 • Refinements in site characterization technologies during the last decade have begun to

decrease site-assessment costs, improve data quality and remedy design, and expand the

applicability of less traditional remedies. 

• The pace of the cleanups is affected by the availability of funds to pay for state and federal 

oversight. Many states are facing budget deficits in FY 2003 and 2004, and staffing levels 

and budgets for hazardous waste remediation in most states have not increased in about a 

decade. 

Chapter 1: Introduction and Summary Page 1-18 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

• Land development trends are also likely to affect the pace and nature of RCRA cleanups. 

Redevelopment or transfer of commercial and industrial properties usually require site 

assessments and, if necessary, remediation. The 2002 brownfields law, (The Small Business 

Liability Relief and Brownfields Revitalization Act—P.L. 107-118), the Superfund 

Redevelopment Program, and the RCRA Brownfields Initiative are encouraging the reuse of 

former industrial and other properties. These programs have implemented policy changes 

and demonstrated many approaches that foster the cleanup and redevelopment of 

contaminated properties, including a number where waste has been left on site. 

1.6.3 Underground Storage Tank Sites

The demand for remediation services at contaminated UST sites primarily will be influenced by 

federal and state requirements, and the number of releases occurring at old and new tanks. The 

timing of these cleanups will be influenced by the availability of state and federal funds 

for site assessment and cleanup and the pace of economic development. 

• Since 1998, there has been a more than 50 percent drop in the number of new releases

reported. As more tanks come into compliance with the new requirements, the number of

new releases is expected to continue to drop. 

• Even if the current backlog of all known sites is eliminated, there will always be additional 

releases at some sites in the future. Many older tanks still exist, many tanks are not in full 

compliance, some new or upgraded tanks leak due to failure of components or spills, many 

tanks are not operated and maintained properly, and over half of the states are not inspecting 

all of their tanks at the minimum recommended rate. The GAO has estimated that 76,000 

active regulated tanks may not be upgraded, which implies that there is a backlog of 

potentially contaminated sites that may 

be discovered over a period of time as Although the number of releases has declined they are replaced or removed. significantly, tanks continue to leak, because 

older tanks still exist, many tanks are not in full 

• The pace of the cleanups is affected by compliance with upgrade requirements, and 

the availability of funds. many are not operated properly. 

Appropriations from one source of 

funds, the federal Leaking 

Underground Storage Tank Fund 

(LUST Trust Fund) have been about $70-80 million annually. At the end of 2003, the fund 

had a balance of $2.1 billion. The gasoline tax that supports the fund is scheduled to expire 

in 2005. The other two major funding sources–state tank trust funds and direct 

appropriations, and property owners or responsible parties–are stable.

 • The 2002 brownfields law and EPA’s USTfields initiative may lead to an increase in the

number of UST sites identified as needing cleanup as well as the pace of cleanups. 

• Concerns about methyl tertiary-butyl ether (MTBE) contamination may influence the

amount and timing of UST cleanups in some states. Some states have passed legislation

addressing MTBE. These activities will lead to more site evaluations and/or cleanups.

Chapter 1: Introduction and Summary Page 1-19
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

1.6.4 Department of Defense Sites

DOD installations typically have multiple contaminated sites regulated by either CERCLA, 

RCRA, state laws, federal statutes that mandate base realignments and closings, or a 

combination of these. The following factors strongly influence the nature of the cleanup needed. 

• The pace of remediation is subject to change in response to budgetary and political 

developments. The FY 2004 planned DOD budget for restoration is almost $1.7 billion. Of 

these funds, approximately $328 million, or 20 percent, is allocated to closing (BRAC) sites. 

An additional BRAC round is scheduled 

for 2005. The DOD cleanup budget has remained 

steady, and is expected to continue at its 

current level. The proportion of the cleanup 

budget going to the cleanup of facilities 

• The proportion of the environmental 

restoration budget allocated to cleanup scheduled to close has fluctuated from 20 to at active installations and FUDS 37% between 2000 and 2005. continues to increase (69% in FY 2003) 

relative to study and investigation 

funding. 

• Although DOD believes that most sites have been located, new sites continue to be 

identified. The recently established munitions program has led to an increased the number of 

new sites. Between FY 2001 and FY 2003, DOD identified approximately 1,700 additional 

sites. Of these, about 1,000 are munitions program sites. 

• In determining the priorities for funding at all sites, DOD generally addresses the worst sites 

first. As of the end of FY 2002, DOD has reduced the number of high relative risk sites at 

active installations and FUDS properties by 58 percent. DOD anticipates achieving remedy 

in place or remedy completes at all high relative-risk sites by 2007. In implementing its 

priorities, DOD may assign varying levels of priority to different sites on a given 

installation. This policy may lead to acceleration of some projects at a given installation 

while other projects at the same installation are postponed.

 • The rate of base closures and realignments will affect the sequencing of cleanup for all

sites. New schedules will need to be generated for the FY 2005 round of closures.

1.6.5 Department of Energy Sites 

DOE is responsible for cleaning up installations and other locations that have been used for 

nuclear weapons research, development, and production for over five decades. The following 

policy, regulatory, economic, and technical factors will significantly affect the scope, schedule, 

and cost of DOE's remediation effort. 

• Based upon a 2002 critical assessment of its program—the Top-to-Bottom Review–DOE 

began a major initiative to accelerate cleanup of its installations and other locations by at 

least 30 years, prioritize risks, improve its contracting practices, and reduce program costs. 

DOE expects this initiative to profoundly affect the scope and scheduling of its cleanups. 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

• Under the initiative, DOE is promoting a In 2002, DOE began a major initiative to new "risk-based" cleanup strategy that accelerate cleanup of its sites by at least 30 would assist in prioritizing risk—and years, prioritize risks, improve contracting 

thereby prioritize cleanups—among the practices, and reduce program costs. 

various sites on a DOE-wide basis. The 

initiative also has the potential to 

increase the use of remediation 

approaches that leave more waste on site, compared to treatment and other active 

remediation approaches than previously planned, thereby reducing remediation costs for 

some projects.

 • Cleanup schedules are heavily dependent upon the availability of funds. DOE's estimate that 

it can complete legacy waste cleanup at all DOE properties by 2035 could be lengthened or 

shortened, depending on the funds appropriated by Congress.

 • At many sites it is difficult to forecast the extent of cleanup work needed, because remedy 

decisions usually require balancing potential land uses with the alternative cleanup options 

and long-term stewardship approaches, and collaboration with many stakeholders. 

• Groundwater remediation is expected to 

DOE estimates that long-term stewardship will continue at many sites, and long-term be needed at up to 129 installations and has stewardship will be needed at 129 DOE established the Office of Legacy Management installations. The Department has to address this need. established the Office of Legacy 

Management to address this need.

 • There is a potential market for cleanup at sites for which there is no current feasible 

remediation approach. The costs for these activities are excluded from the above cost 

estimates, though applicable stewardship and monitoring costs for these sites are included. 

For example, costs are excluded for the nuclear explosion test grounds at the Nevada Test 

Site; large surface water bodies, including the Clinch and Columbia rivers; and most 

contaminated groundwater for which, even with treatment, future use will remain restricted. 

These factors indicate that, despite significant progress in establishing the scope of work for 

DOE's cleanup program, there are uncertainties inherent in the remediation of DOE properties. 

The DOE cleanup market estimates rely on several critical assumptions, which makes them 

particularly sensitive to budget fluctuations, cleanup standards, and further site investigations 

1.6.6 Civilian Federal Agency Sites 

The responsibility to clean up non-DOD and non-DOE contaminated sites falls to 17 federal 

agencies. Because these programs are more fragmented throughout the government, detailed site 

characteristics data are limited and more site investigation is needed to fully identify cleanup 

needs. Three primary factors influence the market for remediation of civilian federal agency 

sites. 

Chapter 1: Introduction and Summary Page 1-21
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

• Lack of funds constrains federal agency site remediation programs. Based on current and 

recent budgets, it would take 100 to 200 years to clean up all of the identified sites, under 

current environmental regulations. The limited resources available for site cleanups provide 

these agencies with incentives to prioritize efforts; encourage and eliminate barriers to the 

use of less costly innovative technologies; use more cost-effective contracting procedures; 

streamline management structures and processes; and seek cost recovery from other parties.

 • Changes in federal and state environmental regulations and standards often impact the scope 

and pace of cleanup required at civilian federal facilities.

 • The transfer of public properties to private use may require agencies to reallocate resources 

for cleaning up properties designated for transfer.

 • Civilian federal agencies may be responsible for cleaning up between 8,000 and 31,000

abandoned mine sites, most of which have not been evaluated. The potential cost for this

effort is not included in the discussion of the civilian agency budgets above.

1.6.7 State and Private Party Sites 

Sites not owned by federal agencies that require cleanup, but cannot be addressed under the 

federal cleanup programs, are addressed by state cleanup programs. The cleanup of these sites 

are generally financed by the states or private parties. To manage the cleanup of contaminated 

sites, most states have created two types of programs—mandated cleanup programs and 

voluntary cleanup and brownfield programs. The mandated programs, which are roughly 

patterned after the federal Superfund 

program, generally include enforcement 

authority and state funds to finance the The financial and legal commitments to site 

restoration vary from state to state. Almost all remediation of abandoned waste sites. The 

states have programs to encourage voluntary extent and pace of these programs are cleanups and develop brownfield properties. determined by states’ financial and legal 

commitment to environmental restoration. 

Voluntary cleanup programs (VCPs) and brownfield programs encourage private parties to 

voluntarily clean up sites rather than expend state resources on enforcement actions or 

remediations. Fifty states and territories have VCPs and 31 have established brownfield 

programs that are separate from their VCPs. It is often difficult to distinguish between a 

brownfield program and a VCP. Many brownfield sites are addressed by volunteers.

 • The state market for remediation services is largely dependent upon the commitment and 

ability of states and private companies to establish and manage hazardous waste programs, 

to finance cleanups, and to encourage or compel responsible parties to clean up sites. 

Funding and staff levels of state cleanup programs have remained steady for about a decade. 

Chapter 1: Introduction and Summary Page 1-22
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

• The Brownfields Revitalization Act is expected to expand the number of sites to be assessed 

and/or cleaned up. The law greatly mitigates the potential liability of innocent (not 

responsible for pollution) property owners, reduces financial uncertainties for investors and 

property owners, and directly funds various projects and programs, which serve as 

examples, case histories, and lessons learned for other sites.

 • Over approximately the past decade, the U.S. capacity to address brownfields has grown 

enormously. Today, there is a growing cadre of developers, planners, consultants, 

engineering and construction firms, attorneys, and public officials with the expertise to 

evaluate, clean up, and revitalize brownfield properties. The growing acceptance of the 

practicability of cleaning up and revitalizing brownfield sites has the potential for enlarging 

the market for site characterization and cleanup services. 

• The pace of development in a region will influence the number of brownfield and voluntary 

sites that need to be evaluated. It is estimated that only 10-15 percent, of the estimated onehalf to one million brownfield sites, have been identified. Most of the remaining sites have 

not been identified, primarily because they are vacant or underused and the owners do not 

wish to become involved in the complicated and costly world of remediation.

 • The growing popularity of smart growth policies are likely to advance the demand for the 

state and brownfield cleanups, since infill development and the preservation of greenfields 

are primary components of smart growth programs.

 • Forty-one states have long-term stewardship programs for one or more of their cleanup

programs. These programs are important because of the widespread use of remedies that

allow hazardous substances to remain on site. 

1.6.8 Manufactured Gas Plant Sites

Most of the cleanups at MGP sites have involved those owned or operated by utilities. Because 

the original commercial MGPs were in good locations, close to population or commercial 

centers, the utilities that owned them simply reused the property for modern facilities, such as 

natural gas or electricity distribution. Thus, there is a known history and chain of ownership. 

Many utilities are aware of the potential environmental problems associated with their properties 

and are conducting monitoring or cleanups under RCRA or a state program. However, the 

location and disposition of many of the other types of MGP sites is less defined. 

Former manufactured gas plants, or their waste products, may be discovered over many years, in 

conjunction with other cleanup programs, such as RCRA, Superfund, or Brownfields. There is 

no dedicated effort to search for them. 

Site investigators and remediation planners could benefit from knowledge of the history and 

operations of this defunct industry. When combined with the growing body of literature on site 

characterization and remediation techniques, they would be able to develop the most effective 

and practicable cleanups. 

Chapter 1: Introduction and Summary Page 1-23
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

1.6.9 Mining Sites

The following primary factors influence the market for remediation of mine lands.

 • The reclamation budgets of the federal and state agencies that manage mine lands are small 

in comparison to the magnitude of the abandoned mine waste problem.

 • Growing markets for first or second homes and recreational activities in previously sparselypopulated mining areas may foster increased demand for cleanup of some sites or 

restrictions on park use.

 • The transfer of properties in mining areas where complete control of the source of the 

pollution has not been achieved may require institutional controls. Thus, there is a growing 

need for methods to ensure compliance with institutional controls.

 • A number of the over 14,000 active and inactive mine sites that are not abandoned also may 

require remediation. Releases of contaminants into the environment can result from 

inadequately designed facilities such as tailings dams, accidents, leaks and spills, or failure 

to properly operate a facility. Thus some portion of these sites are likely to require 

remediation of soil, groundwater, and/or surface water, among other things.

 • The passage of Good Samaritan legislation would probably encourage more state and local 

governments to undertake some remediation. 

1.6.10 Drycleaner Sites 

The use of drycleaning solvents has been decreasing, primarily because the industry has been 

switching to new more efficient machines and, to a lesser extent, the use of alternative solvents. 

Nevertheless, there remain thousands of sites from previous operations.

 • The declining use of perchloroethylene by drycleaners will mean fewer discharges to the

environment in the future.

 • For the 12 states with dedicated drycleaner remediation funds, the money available to the

funds appears to be stable. 

• For other states, general availability of state cleanup funds, will be a critical factor for many 

cleanups. Drycleaners have average revenues of about $250,000; remediation costs can run 

hundreds of thousands of dollars, and several have cost over a million. Even a moderate-cost 

cleanup can amount to several years of profit for the average drycleaner.

 • In addition to active drycleaner facilities, many inactive facilities (properties that currently 

do not have a drycleaner, but did in the past) have not yet been discovered. Many of these 

facilities may have released hazardous substances to the environment that resulted in 

contaminated soil and groundwater. Although data on these facilities are sparse, it is 

estimated that there are between 9,000 and 90,000 sites. 

Chapter 1: Introduction and Summary Page 1-24 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

• The level of assessment and cleanup is directly related to the cleanup standards adopted by 

the states. Many states have adopted risk-based cleanup standards for soil and groundwater. 

1.6.11 Site Characterization

Although it averages only about 10 percent of cleanup costs, site characterization is a major 

determinant of the ultimate effectiveness, schedule, and cost of remedial actions. The following 

factors are driving the demand for sampling and analysis technologies:

 • The use of field analytical technologies is expected to increase relative to traditional 

approaches. There is a growing body of evidence that indicates that substantial cost and time 

savings and better site characterizations are usually achieved with the use of field 

technologies, especially when combined with dynamic work plans and systematic planning. 

Field technologies can also foster significant savings in dollars and time during remedial 

action, because they provide accurate site characterization data and allow site crews to adapt 

to new information on a daily basis.

 • The demand for revitalization of brownfields and UST sites implies a requirement to 

conduct many Phase I and Phase II type site assessments. A smaller percentage will require 

further site investigation and cleanup.

 • The demand for due diligence by property purchasers, developers, and lenders also 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 and investors usually operate under serious time 

constraints to implement projects. The combination of field analytics, dynamic work plans, 

and systematic planning may allow development to proceed more expeditiously. 

Based on these factors, it is expected that the use of newer characterization approaches will grow 

relative to older ones. To the extent that improved site characterizations reduce overall 

remediation costs, they would allow more sites to be cleaned up. Improved cost-effectiveness of 

cleanups is especially important, given the finite resources available for most cleanup programs. 

1.6.12 DNAPLs

The CERCLA remedy selection process and NCP include a preference for remedies that provide 

“permanence and treatment.” to the extent practicable. However, the ability to economically 

delineate the DNAPL source zones varies from site to site. Similarly, the ability to show that 

source reduction will dramatically reduce long-term costs of containment also varies from one 

site to another. Thus, the proportion of DNAPL sites that will be subject to containment and the 

number that will undergo source zone treatment is uncertain. A number of factors may affect 

decisions that attempt to strike a balance between remediating a source zone and long-term pump 

and treat at DNAPL sites, and hence the potential demand for remediation services. These 

factors, which are not mutually exclusive, include: 

Chapter 1: Introduction and Summary Page 1-25
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

• Potential contamination at uncharacterized or undiscovered sites, such as MGP sites, former 

drycleaners sites, or other types of sites, may lead to continued additions to the number of 

sites that need to be assessed and/or cleaned up.

 • A number of states have recognized the need to consider newer site characterization and

remediation technologies prior to granting ARAR waivers for technical impracticability.

 • Reuse considerations at a site may drive the need for faster cleanups. Developers may need 

the properties that might otherwise be encumbered by pump-and-treat equipment or 

institutional controls related to the contamination and remedy..

 • Continued advances in site characterization techniques that allow a better definition of the 

source zone, which is especially needed for deep sources, offer the potential to reduce 

remediation costs. Such advances may be enhanced when coupled with more effective use 

of innovative in-situ technologies for the removal or destruction of DNAPL sources, and 

may contribute to increased use of treatment versus long-term containment remedies. 

1.7 Implications for Site Characterization and Cleanup

Although substantial progress has been made over the past quarter century, a considerable 

amount of cleanup work, which will take 30 to 35 years to complete, remains. As with most 

cleanups requiring technically complex solutions and coordination of multiple stakeholders, the 

work load will fluctuate from year to year. Most of the costs will be borne by private and public 

owners of contaminated properties and responsible parties. This work includes the cleanup of a 

number of very large, complex sites as well as the assessment and, when necessary, cleanup of 

many small sites. The needed work represents a significant opportunity for the continued 

development and implementation of site characterization and cleanup approaches and 

technologies that can result in better, cheaper, and faster cleanups, as well as technologies that 

enable us to better address challenging contamination problems such characterizing NAPLs in 

the subsurface. 

Technical solutions to a particular contaminated site problem are generally similar, regardless of 

the regulatory program under which they are implemented. While individual markets may not 

support certain important investment decisions, the aggregate demand across all markets might 

justify the up-front investment in a technology that ultimately drives down the cost of moving 

contaminated sites into productive use. By recognizing this potential for economies of scale in 

cleanup technology markets, the information in this report contributes to better investment 

decisions across all market segments. 

Chapter 1: Introduction and Summary Page 1-26
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Chapter 2 

Remediation Technologies Used 

At National Priorities List Sites 

The U.S. faces significant technological challenges as it seeks the most efficient and effective 

approaches to clean up its contaminated waste sites. This chapter examines trends in the use of 

remediation technologies at hazardous waste cleanup sites covered under the Comprehensive 

Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), commonly 

known as Superfund. 

Although Superfund sites are a small percentage of all contaminated sites, the program has been 

in the forefront in selecting and applying new site characterization and remediation technologies 

that are less costly and more effective. Developments in the Superfund sector tend to influence 

technology selection in other market segments. Many of the remediation projects in recent years 

involve technologies that were not even 

available when the law was 

reauthorized. The development of new 

technologies has been driven, in part, 

by a preference for “permanence and 

treatment” in the 1986 reauthorized law 

and the resulting quest for more costeffective processes. 

2.1 Definitions of

Remediation Technologies 

The text box summarizes the major 

types of remedies used at hazardous 

waste sites. Most Superfund records of 

decision (RODs) for remedial action 

address the source of contamination, 

such a soil, sediment, sludge, and solidmatrix wastes. Such “source control” 

RODs select “source control 

technologies.” Groundwater remedial 

actions, also known as “non-source 

control actions,” may be a component 

of a “source control” ROD and the 

treatment technologies chosen for 

groundwater remediation are referred 

to as “groundwater technologies.” 

Superfund Remedy Types 

Source Control Remedy Types 

• 

or ex situ, including technologies such as chemical 

• Containment of a 

contaminant source using caps, liners, covers, on-site and 

off-site landfilling, or other means. 

• Other forms of remediation of a 

monitoring, and population relocation. 

Groundwater Remedy Types 

• 

technologies such as air stripping and ion exchange. 

• 

wi

as air sparging and permeable reactive barriers. 

• 

attenuation processes, wi

controlled and monitored approach to site cleanup to 

achieve site-specific remediation objectives within a time 

• 

subsurface 

pumping. 

• 

Source Control Treatment: Treatment of any source in situ 

treatment and thermal desorption. 

Source Control Containment:

Other Source Control:

contaminant source, such as institutional controls, 

Pump and treat: Extraction of groundwater from an aquifer 

and treatment above ground. Treatment can include 

In-Situ Treatment: Treatment of groundwater in place 

thout extracting it from an aquifer, using technologies such 

Monitored Natural Attenuation: The reliance on natural 

thin the context of a carefully 

frame that is reasonable compared to other alternatives. 

Groundwater Containment: Containment of groundwater 

through the use of a vertical engineered impermeable 

barrier, or a hydraulic barrier created by 

Other Groundwater Remedies: Groundwater remedies 

that do not fall into the above categories, such as water-use 

restrictions and the provision of alternative water supplies. 

Chapter 2: Remediation Technologies Page 2-1 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

The term “treatment technology” means any unit operation or series of unit operations that alters 

the composition of a hazardous substance, pollutant or contaminant through chemical, biological, 

or physical means to reduce the toxicity, mobility, or volume of the contaminated materials 

being treated. Treatment technologies are an alternative to land disposal of hazardous wastes 

without treatment (see “definitions” at 40 CFR 300.5, 55 Federal Register 8819, March 8, 1990). 

Established technologies are those for which cost and performance information is readily 

available. The most frequently used established technologies are on- and off-site incineration, 

solidification/stabilization (S/S), soil vapor extraction (SVE), thermal desorption, and pump-andtreat (P&T) technologies for groundwater. Technologies used to treat groundwater after it has 

been pumped to the surface usually involve traditional water treatment approaches, which are 

considered established technologies. 

Innovative treatment technologies are alternative treatment technologies with a limited number 

of field applications and limited data on cost and performance. Often, these technologies are 

established in other fields, such as chemical manufacturing or hazardous waste treatment. In 

such cases, it is the application of a technology or process at a waste site (to soil, sediments, 

sludge, and solid-matrix waste, or groundwater) that is innovative, not the technology itself. 

Both innovative and established technologies are grouped as source control treatment or in-situ 

groundwater treatment technologies on the basis of the type of application most commonly 

associated with the technology. Some technologies can be used for both source control and insitu groundwater treatment. 

Exhibit 2-1 lists 17 types of source control (primarily soil) technologies, 10 types of in-situ 

groundwater treatment technologies, eight types of groundwater P&T technologies, as well as 

other approaches, such as monitored natural attenuation (MNA) for groundwater, and 

groundwater containment. The definitions of these technologies may be found in the EPA report 

Treatment Technologies For Site Cleanup: Annual Status Report (Eleventh Edition) (EPA, 

2004a). They are based on the Remediation Technologies Screening Matrix Reference Guide, 

Version 3 (FRTR 2003a). Technologies that are applicable to both source control and 

groundwater treatment are also indicated. For P&T technologies, this report focuses on the 

treatment portion of the technology. 

2.2 Historical Use of Remediation Technologies at Superfund Sites

This section reviews the types of hazardous waste remediation technologies that tend to be used 

at NPL sites. Most of the discussion on the selection and use of innovative and established 

technologies is derived from a more detailed analysis in the Annual Status Report which contains 

information on each planned, ongoing, and completed treatment technology project selected for 

use in the Superfund program through fiscal year (FY) 2002 (U.S. EPA 2004a). The analysis is 

based on data from RODs signed between FYs 1982 and 2002, which ended on September 30, 

2002. During this period, EPA made cleanup decisions in 2,610 RODs for over 1,200 NPL sites. 

It also contains data on a limited number of non-Superfund federal facility sites. 

Chapter 2: Remediation Technologies Page 2-2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 2-1. Treatment Technologies 

Source Control Treatment 

Technologies 

• Bioremediation 

• Chemical Treatment 

• Electrokinetics 

• Flushing 

• Incineration (on-site and off-site) 

• Mechanical Soil Aeration 

• Multi-Phase Extraction 

• Neutralization 

• Open Burn (OB) and Open Detonation (OD) 

• Physical Separation 

• Phytoremediation 

• Soil Vapor Extraction 

• Soil Washing 

• Solidification/Stabilization 

• Solvent Extraction 

• Thermal Desorption 

• Thermally Enhanced Recovery 

• Vitrification 

In-situ Groundwater Treatment 

Technologies 

• Air Sparging 

• Bioremediation (also a source control technology) 

• Chemical Treatment (also a source control 

Technology) 

• Electrokinetics (also a source control technology) 

• Flushing (also a source control Technology) 

• In-well Air Stripping 

• Multi-phase Extraction 

• Permeable Reactive Barriers 

• Phytoremediation (also a source control 

technology) 

• Thermally Enhanced Recovery (also a source 

control technology) 

Pump-and-treat Technologies (Ex-Situ 

Treatment) 

• Adsorption 

• Air Stripping (also a source control technology) 

• Bioremediation 

• Chemical Treatment (also a source control 

technology) 

• Filtration 

• Ion Exchange 

• Metals Precipitation 

• Membrane Filtration 

Monitored Natural Attenuation for 

Groundwater 

• Includes a variety of physical, chemical, or biological 

processes, such as biodegradation; dispersion; 

dilution; sorption; volatilization; radioactive decay; and 

chemical or biological stabilization, transformation, or 

destruction of contaminants. 

In-situ Groundwater Containment 

• Vertical engineered subsurface impermeable barrier 

• Hydraulic Barrier created by pumping 

Other Groundwater 

• Groundwater Use Restrictions 

• Alternative Water Supply 

• Groundwater remedies that do not fall into above 

categories 

Source: U.S. EPA, Office of Solid Waste and Emergency Response, Treatment Technologies For Site Cleanup: 

Annual Status Report (Eleventh Edition), EPA-542-R-03-009, February 2004. http://www.clu-in.org/asr; and The 

Remedial Technologies Development Matrix and Reference Guide web site maintained by the Federal 

Remediation Technology Roundtable. http://clu-in.org/remed1.cfm#tech_sele 

Chapter 2: Remediation Technologies Page 2-3 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

2.2.1 Containment and Disposal Technologies for Source Control 

Exhibit 2-2 shows the remedy types for source control implemented or planned over the life of 

the Superfund program. These data are based on an analysis of the RODs signed between 1982 

and 2002. A source control remedy has been implemented or planned at 70 percent of NPL sites. 

Fifty-two percent of all source control sites have selected treatment of a source, such as 

contaminated soil or sediment. Fifty-five percent of sites have implemented or plan to implement 

containment or off-site disposal of a source. 

Exhibit 2-2. Source Control Remedy Types 

Selected or Used for at NPL Sites, FY 1982-2002 

Remedy Type Number of Sites 

Percent of Sites with 

Source Control 

Treatment of a Source 541 52% 

Containment or Off-site Disposal of a Source 576 55% 

Institutional Controls of a Source 525 49% 

Other Source Control 457 44% 

Total Source Control Sites 1,046 100% 

Notes:

 • ROD = Record of Decision.

 • Data for FY 2002 includes an estimated 70 percent of FY 2002 RODs.

 • 1,046 sites with source control. More than one remediation application may be used at a site. 

Source: U.S. EPA, Office of Solid Waste and Emergency Response, Treatment Technologies For Site Cleanup: 

Annual Status Report (Eleventh Edition), EPA-542-R-03-009, February 2004. http://www.clu-in.org/asr. 

Prior to 1987, the most common methods for remediating hazardous waste were to excavate the 

contaminated material and dispose of it in an off-site landfill, or to contain the waste on site by 

means of containment systems (e.g., caps or slurry walls). In the late 1980s and early 1990s, the 

number of remedies that included treatment began to increase. Later, in the second half of the 

1990s, the percentage decreased. According to the Annual Status Report, the percentage of 

source control treatment RODs was generally higher from FY 1988 through FY 1996 (59 to 75 

percent of the RODs) than for the period FY 1997 through FY 2002 (39 to 51 percent of the 

RODs) (U.S. EPA 2004a). 

Many factors contribute to the selection of remedies at hazardous waste sites. Although the 

Superfund Amendments and Reauthorization Act of 1986 (SARA) requires a preference for the 

use of permanent remedies, existing regulations provide site managers with flexibility in remedy 

selection, so long as they meet the principle requirements for the selection of remedies. Remedy 

decisions may also be influenced by EPA’s policies for considering cost (U.S. EPA 1996b) and 

land use (U.S. EPA 1995, 2001c) in remedy selection, new developments in remediation 

technologies, and changing knowledge and experience with technologies used for site 

Chapter 2: Remediation Technologies Page 2-4 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

characterization, containment, and treatment. By considering land use and cost-effectiveness, 

decision-makers may have the flexibility to base remedy selection on restricted, rather than 

unrestricted land uses. Thus, nontreatment remedies, such as containment and institutional 

controls, may be protective of human health and the environment at some sites, while other sites 

will require other remedies. 

2.2.2 Treatment Technologies for Source Control

Between 1982 and 2002, 863 applications of treatment technologies were implemented or 

planned for source control at 638 Superfund sites. More than one type of technology may have 

been selected at a site. Exhibit 2-3 provides an overview of the in-situ and ex-situ technologies 

selected for source control. As the figure shows, 42 percent of all treatments selected for source 

control at Superfund remedial action sites were in-situ technologies. Soil vapor extraction (SVE) 

(213 projects, 25 percent), bioremediation (48 projects, 6 percent), and 

solidification/stabilization (48 projects, 6 percent) are the most common in-situ technologies, 

together accounting for 85 percent of all in-situ source control treatment projects. 

The most common ex-situ technologies are solidification/stabilization (157 projects, 18 percent); 

incineration (147 projects, 17 percent); thermal desorption (69 projects, 8 percent); and 

bioremediation (54 projects, 6 percent). These technologies together account for 86 percent of 

ex-situ source control treatment projects. 

The Annual Status Report, which is available on line, provides a detailed description of the 

trends in the use of these technologies from 1982 through 2002 (U.S. EPA 2004a). An appendix 

to the report lists treatment technology projects for source control at remedial sites by EPA 

region. While in-situ technologies as a percent of all treatment technologies tend to fluctuate 

from year-to-year, the general trend since 1985 has been an increase in their use. In-situ 

treatments as a percent of source control treatments increased from 31percent for the FY 1985 to 

FY 1989 period to 49 percent for the FY 1998 to FY 2002 period. Some of the key factors that 

have influenced this upward trend include:

 • In-situ technologies are often more cost-effective than ex-situ approaches which require

excavation and materials handling, especially for large sites.

 • Because in-situ technologies require no excavation, the levels of exposure to contaminated 

substances is reduced, compared to that associated with ex-situ methods.

 • As in-situ treatment technologies are used more frequently, site managers and other 

remediation professionals are more willing to accept them as a viable and reliable approach. 

Chapter 2: Remediation Technologies Page 2-5 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 2-3. Superfund Remedial Actions 

at Source Control Treatment Projects 

FY 1982-2002 (Total Projects = 863) 

2.2.3 Groundwater Remedies 

Groundwater treatment technologies are designed to remove or immobilize contamination in an 

aquifer. Groundwater remedies can be grouped into five general types: remedies specifying 

extraction of groundwater, usually by pumping, followed by aboveground treatment (pump and 

treat); remedies specifying in-situ treatment; remedies specifying MNA; remedies specifying 

containment using subsurface vertical engineered impermeable barriers or hydraulic barriers 

created by pumping; and other actions, such as groundwater use restrictions, drilling 

prohibitions, and other land use (institutional) controls (Exhibit 2-1). 

Exhibits 2-4 and 2-5 display the application of groundwater remedies on a site basis. These data 

are based on an analysis of the 2,610 RODs and supplementary documents signed between 1982 

and 2002. More than one type of remedy may have been selected at a site or in a specific ROD. 

At some sites, several applications of the same type of groundwater remedy may have been 

specified. At sites for which several types of groundwater remedies were selected, the 

remediation may not have occurred in the same aquifer or groundwater plume. 

A groundwater remedy has been implemented or is planned at 71 percent of the NPL sites. Pump 

and treat has been implemented or planned at 67 percent, in-situ treatment at 13 percent, and 

Chapter 2: Remediation Technologies Page 2-6 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

MNA at 19 percent of NPL groundwater sites. At many sites, more than one type of groundwater 

remedy is planned or implemented. 

Exhibit 2-4. Groundwater Remedy Types 

Selected or Used at NPL Sites, FY 1982-2002 

Remedy Type Number of Sites Percent of Sites 

Groundwater Pump and treat 713 67% 

In-situ Treatment of Groundwater 135 13% 

MNA of Groundwater 201 19% 

Institutional Controls for Groundwater 515 48% 

Other Groundwater (includes other and VEB) 735 69% 

Total Groundwater Sites 1,062 100% 

Notes:

 • ROD = Record of Decision; VEB = vertical engineered barrier

 • Data for FY 2002 includes an estimated 70 percent of FY 2002 RODs.

 • 1,062 groundwater sites. Pump and treat, in-situ treatment, or MNA has been used or selected as part of the 

remedy for 851 sites. More than one remediation application may be used at a site. 

Source: U.S. EPA, Office of Solid Waste and Emergency Response, Treatment Technologies For Site Cleanup: 

Annual Status Report (Eleventh Edition), EPA-542-R-03-009, February 2004. http://www.clu-in.org/asr 

Exhibit 2-5 shows the results of an analysis of the use of pump and treat, in-situ treatment, and 

MNA for groundwater, both alone and in combination with other remedies. This analysis focuses 

on these three remedies because they are intended to result in the reduction or immobilization of 

contaminants. Of the 851 sites, pump and treat alone was used in 556 (65 percent) of the sites, 

and in combination with other technologies at 713 (84 percent) sites; MNA alone at 96 sites (11 

percent); and in-situ groundwater treatment alone at 31 sites (4 percent). In-situ treatment alone, 

or in combination with other technologies, was selected at 135 sites (16 percent) and MNA 

alone, or in combination with other technologies, was selected at 201 (24 percent) of the sites. 

2.3 Advancing Remediation and Characterization Technologies

Opportunities exist for technology vendors who want to work cooperatively with EPA, and other 

federal agencies, such as the Departments of Defense (DOD) and Energy (DOE). In many cases 

the programs involve other industry partners as well. A number of programs are available to 

support the development and use of advanced technologies through research, development, 

testing, and evaluation, and through information sharing and networking about experiences with 

remediation technologies. Many of these programs also include resources to help vendors 

publicize the capabilities of their technologies to all interested parties. Some of the more 

important efforts are listed below: 

Chapter 2: Remediation Technologies Page 2-7 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 2-5. Superfund Sites With P&T, In-situ Treatment, 

or MNA as Part of a Groundwater Remedy FY 1982-2002

 • Clean-Up Information System (CLU-IN). This web site, maintained by EPA’s 

Technology Innovation and Field Services Division (TIFSD), provides information about 

innovative treatment and site characterization technologies and acts as a forum for all waste 

remediation stakeholders. It also provides tools to assist technology developers and vendors 

demonstrate and bring their technologies to market. Most of the resources referred to in this 

report and cited below are available for downloading from this web site. http://www.cluin.org

 • Superfund Innovative Technology Evaluation (SITE) Program. The EPA established the 

SITE Program to help promote the use of innovative remediation and monitoring and 

measurement technologies at hazardous waste sites. The program, which is administered by 

ORD's National Risk Management Research Laboratory, headquartered in Cincinnati, Ohio, 

offers a mechanism where the performance and costs of innovative technologies can be 

demonstrated and evaluated by an independent third party at a particular hazardous waste 

site. The demonstration projects allow participation by private entities, state environmental 

agencies and federal agencies. Under this program, EPA enables the field testing of 

technologies and provides reports on completed technology evaluations. The web site 

describes the current technologies of interest, how to participate in the program, and 

provides the publication SITE Technology Profiles for downloading. This publication 

describes each project and lists available reports. http://www.epa.gov/ORD/SITE

Chapter 2: Remediation Technologies Page 2-8 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

• EPA REACH IT. This EPA web site allows vendors to search, view, download and print 

information about innovative remediation and characterization technologies. It provides 

users access to comprehensive information about treatment and characterization 

technologies and their applications. It combines information submitted by technology 

service providers about remediation and characterization technologies with information 

from EPA, the U.S. Department of Defense (DOD), the U.S. Department of Energy (DOE), 

and state project managers about sites at which innovative technologies are being deployed. 

Those sources together provide up-to-date information, not only about technologies one can 

use to characterize or remediate a site, but also about sites at which those technologies are 

being used and the service providers that offer them. As of October 2002, REACH IT 

contained information on 607 remediation technology vendors; 1,380 technologies; and 

1,564 sites at which remediation technologies have been applied. It also contained 

information on 128 characterization technology vendors; 209 technologies; and 232 sites at 

which characterization technologies have been applied. http://www.epareachit.org.

 • Groundwater Remediation Technologies Analysis Center (GWRTAC). In 1995, EPA 

established GWRTAC at the National Environmental Technologies Applications Center 

(NETAC) in association with the University of Pittsburgh. This center develops and 

disseminates information on current research, development, and demonstration efforts 

related to in-situ groundwater technologies. The Center also analyzes trends in technology 

development. http://www.gwrtac.org.

 • Remediation Technologies Development Forum (RTDF). The RTDF was established in 

1992 after industry approached the EPA to identify what they could do together to develop 

and improve the environmental technologies needed to address their mutual cleanup 

problems in the safest, most cost-effective manner. The RTDF is a public-private 

partnership created to undertake research, development, demonstration, and evaluation 

efforts focused on finding innovative solutions to high priority problems. The RTDF 

includes partners from industry, several federal and state government agencies, and 

academia who voluntarily share knowledge, experience, equipment, facilities, and even 

proprietary technology to achieve common cleanup goals. http://www.rtdf.org.

 • Federal Remediation Technologies Roundtable (FRTR). The FRTR works to build a 

collaborative atmosphere among federal agencies involved in hazardous waste site cleanup. 

FRTR was established in 1990 to bring together top federal cleanup program managers and 

other remediation community representatives to share information and learn about 

technology-related efforts of mutual interest; discuss future directions of the national site 

remediation programs and their impact on the technology market; interact with similar state 

and private industry technology development programs; and form partnerships to pursue 

subjects of mutual interest. http://www.frtr.gov.

Since these sources are often used in the preparation of lists of cleanup alternatives or bid 

documents, it is important that technology vendors and developers ensure that information on 

their products and services are represented. In addition, joining and participating in activities of 

various professional societies and trade groups may help a vendor promote specific capabilities. 

Chapter 2: Remediation Technologies Page 2-9
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

2.4 References

FRTR, 2003a. Remedial Technologies Development Matrix and Reference Guide web site 

including a user-friendly tool to screen for technologies for a remediation project. Federal 

Remediation Technology Roundtable. http://clu-in.org/remed1.cfm#tech_sele 

FRTR, 2003b. Technology Cost and Performance, web site covering case studies and cost and 

performance information on site characterization, remediation, and monitoring technologies, 

Federal Remediation Technology Roundtable. http://www.frtr.gov/

U.S. EPA (Environmental Protection Agency), 1995. Land Use in the CERCLA Remedy 

Selection Process, OSWER Directive 9355.7-04, Office of Solid Waste and Emergency 

Response, May 1995. 

U.S. EPA, 1996a. Initiatives to Promote Innovative Technology in Waste Management, OSWER 

Directive 9380.0-25, Office of Solid Waste and Emergency Response, April 29, 1996. 

U.S. EPA, 1996b. The Role of Cost in the Superfund Remedy Selection Process, EPA 540-F-96-

018, Solid Waste and Emergency Response, September 1996. 

http://www.epa.gov/superfund/resources/cost_dir 

U.S. EPA, 1999. Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action, 

and Underground Storage Tank Sites, OSWER Directive 9200.4-17P, Office of Solid Waste and 

Emergency Response, April 21, 1999. 

U.S. EPA, 2001a. Abstracts of Remediation Case Studies Volume 5, EPA-542-R-01-008, Federal 

Remediation Technologies Roundtable, May 2001. 

U.S. EPA, 2001b. Groundwater Pump-and-Treat Systems: Summary of Selected Cost and 

Performance Information, EPA 542-R-01-0219, Office of Solid Waste and Emergency 

Response, Technology Innovation Office, December 2001. 

U.S. EPA. 2001c. Reuse Assessments: A Tool to Implement the Superfund Land Use Directive, 

(OSWER Directive No. 9355.7-06P), June 2001. 

http://www.epa.gov/superfund/resources/reusefinal.pdf 

U.S. EPA, 2002a. Groundwater Remedies Selected at Superfund Sites, EPA 542-R-01-022, Office of 

Solid Waste and Emergency Response, Technology Innovation Office, January 2002. 

U.S. EPA, 2002b. Abstracts of Remediation Case Studies Volume 6, EPA-542-R-02-006, Federal 

Remediation Technologies Roundtable, June 2002. 

U.S. EPA, 2003a. Publications on Remediation., web site managed by EPA’s Office of Solid 

Waste and Emergency Response, Technology Innovation Office. 

http://www.epa.gov/swertio1/pubitech.htm 

Chapter 2: Remediation Technologies Page 2-10 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

U.S. EPA, 2003b. Vendor Support, web site maintained by Office of Superfund Remediation and 

Technology Innovation to provide tools to help remediation technology vendors and developers 

advance and implement their technologies. http://clu-in.org/vendor.

U.S. EPA, 2004a. Treatment Technologies For Site Cleanup: Annual Status Report (Eleventh 

Edition), EPA-542-R-03-009, Office of Solid Waste and Emergency Response, February 2004. 

http://www.clu-in.org/asr 

U.S. EPA, 2004b. Annual Status Report Remediation Database, Office of Solid Waste and 

Emergency Response, Technology Innovation Office, http://epa.gov/tio/technologies

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Chapter 3 

Demand for Remediation of 

National Priorities List Sites 

This chapter presents estimates of the number, location, size, characteristics, and cleanup costs 

of hazardous waste sites that have been or will be placed on the Superfund National Priorities 

List (NPL), but for which a remedy has yet to be selected. It also describes the implications of a 

number of technical, regulatory, and economic factors for the demand for cleanup technologies. 

Because many Superfund sites have undergone detailed site assessments, much information is 

available on their characteristics. In addition, the remediation technologies used for the 

Superfund program are likely to reflect needs in other programs with similar cleanup challenges. 

3.1 The Superfund Program 

Superfund is the federal program, 

administered by EPA, to clean up releases 

of hazardous substances at abandoned or 

uncontrolled hazardous waste sites. In 

addition to establishing enforcement 

authorities, the Comprehensive 

Environmental Response, Compensation, 

and Liability Act (CERCLA) created a trust 

fund to be used for site identification and 

cleanup. CERCLA was substantially altered 

by the Superfund Amendments and 

Reauthorization Act of 1986 (SARA), 

which made three changes to the Superfund 

program that are of particular significance 

to technology vendors: (1) it stressed the 

importance of permanent remedies; (2) it 

supported the use of new treatment 

technologies to achieve permanent 

remedies; and (3) it expanded research and 

demonstrations to promote the development 

of innovative treatment technologies. 

3.1.1 The National Contingency Plan 

Highlights 

• 

complete at 886 of the 1,518 NPL sites. EPA had 

5,000 sites. 

• 

remedial action. Estimated cleanup cost for these 

• 

• 

• i

allocated among the various projects. 

• 

selected, and NPL listings. 

• 

11% of sludge. 

• 

than half the sites have all three. 

As of September 2003, remedial construction was 

conducted more than 7,000 removal actions at over 

As of May 2003, 456 proposed and final NPL sites 

not owned by the federal government still require 

sites are $16–23 billion (most likely $19 billion). 

Between 1993 and 2003, EPA added an average of 

28 sites annually to the NPL. 

If 28 sites per year are added to the NPL for the next 

10 years, the additional cost would be $13 billion. 

(The range of estimates is 23-49 sites annually for 10 

years at an estimated cost of $8–27 billion). 

EPA is working w th an advisory council to address 

the future direction of the program. These 

deliberations may impact how Superfund’s budget is 

The need to balance the interests of diverse 

stakeholders and consider redevelopment issues 

may influence the sequence of work, technologies 

About 83% percent of NPL sites require remediation 

of groundwater, 78% of soil, 32% of sediments, and 

VOCs are to be remediated at 78% of NPL sites, 

followed by metals (77%) and SVOCs (71%). More 

The procedures for implementing CERCLA are spelled out in the National Oil and Hazardous 

Substances Pollution Contingency Plan, commonly referred to as the National Contingency Plan 

(NCP). The NCP outlines the steps that EPA and other federal agencies must follow in 

responding to releases of hazardous substances or oil into the environment. Among other things, 

Chapter 3: National Priority List (NPL) Sites Page 3-1 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

the NCP addresses selecting remedies that protect human health and the environment, 

maintaining protection over time, and minimizing untreated waste. With regard to treatment 

technologies, the NCP specifies several treatment expectations, including the following: 

• Principal threats are to be treated wherever practical;

 • Combination of treatment with containment, as necessary; and

 • Consideration of innovative treatment technologies to the maximum extent practicable. 

3.1.2 The Superfund Process 

The site characterization and cleanup process established by the NCP begins with the discovery 

of a potential hazardous waste site, and includes the following general steps: 

 1) A “preliminary assessment” (PA) is conducted to determine the existence of potential 

threats to human health or the environment that require a “removal action” or further study. 

If the PA indicates an emergency requiring immediate or short-term action to reduce the risk 

to the public, a removal action is conducted to stabilize or clean up the site.

 2) If a hazard is identified or remains after a removal action is performed, a “site inspection” 

(SI) is conducted to determine whether a site warrants scoring under the Hazard Ranking 

System (HRS). EPA uses the HRS to score sites on the basis of their potential effects on 

human health and the environment and to determine a site's eligibility for the National 

Priorities List (NPL), EPA’s list of sites with the worst contamination problems. Sites that 

score above a threshold may be considered for proposal for the NPL. Inclusion on the NPL 

authorizes EPA to respond to the site by either pursuing enforcement against responsible 

parties or paying for a response using the Superfund funds. 

 3) When a site is added to the NPL, an in-depth planning and investigation phase begins, 

during which the nature and extent of contamination and site risks are determined, and 

treatment alternatives are evaluated. This phase is known as the “remedial investigation/feasibility study” (RI/FS). EPA requires the results of the RI/FS, including the 

rationale for selecting a remedy, to be presented to the public, and documented in a “Record 

of Decision” (ROD). Some sites require a series of RI/FSs and RODs to address different 

“operable units (OUs),” which are portions of a site reflecting pathways of exposure (e.g., 

soil, water) that require separate cleanup actions. 

RODs provide useful information for technology vendors interested in gaining access to the 

hazardous waste cleanup market. First, RODs specify the technology type determined to be 

the appropriate remedy for a site. Second, technology vendors can use RODs to determine 

why EPA selected or rejected a specific remedy. EPA must consider nine criteria for remedy 

selection: overall protectiveness; compliance with other environmental laws and regulations; 

long-term effectiveness and permanence; short-term effectiveness; implementability; cost; 

reduction of toxicity, mobility, or volume of wastes; state acceptance; and community 

acceptance. 

Chapter 3: National Priority List (NPL) Sites Page 3-2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

 4) Following the ROD, detailed engineering specifications for the selected cleanup approach 

are developed. This phase is called “remedial design” (RD). The designs are used to solicit 

competitive bids to perform the “remedial action” (RA). In the RA phase, waste is actually 

treated, disposed, or contained. If necessary, “operation and maintenance” (O&M) begins at 

the conclusion of the RA. This phase can include such actions as groundwater monitoring 

and periodic site inspections to ensure continued effectiveness of remedies. The final step in 

the process is to delete the site from the NPL. This step is initiated when all necessary 

cleanup responses under CERCLA are completed. 

At any point in this process, an emergency requiring a removal action can occur at a site. In 

addition, community involvement activities take place throughout the process to ensure that all 

interested parties participate in the decision-making process. Enforcement actions that compel 

those responsible for the contamination to clean up the site also occur throughout the cleanup 

process to ensure optimal use of Superfund resources. 

As part of its responsibility for implementing the Superfund program, EPA is responsible for 

determining the best way to clean up each site. Other federal agencies such as the Department of 

Defense (DOD) and Department of Energy (DOE) are responsible for cleaning up NPL sites at 

their facilities in accordance with the requirements of the NCP and with EPA concurrence. 

Under the Superfund program, states also may take the lead to determine remedial alternatives 

and contract for the design and remediation of a site. 

3.1.3 Program Status 

Since its beginning in 1980, efforts under Superfund have included the identification and ranking 

of sites, detailed site investigation, mitigation of immediate threats, and selection and 

implementation of remedies to clean up the worst sites (those listed on the NPL). Over the life of 

the program, the number of sites that have progressed from study and evaluation to actual 

cleanup has grown. As of September 2003, EPA had listed 1,518 sites on the NPL and proposed 

another 54. Of these, 274 sites were deleted from the NPL, or referred for response to another 

authority, leaving a total of 1,244 final NPL sites. In addition, EPA had conducted over 7,000 

removal actions at over 5,000 sites, over 80 percent of which are not NPL sites. 

By September 30, 2003, remedial construction activity was complete at 886 sites and 375 

remedial construction projects were underway at NPL sites (U.S. EPA 2004c). Another 230 sites 

were in the RD phase and the remainder were in various stages of site investigation or remedy 

selection. As additional sites are studied and ranked, they may be added to the NPL. 

3.2 Factors Affecting Demand for Cleanup

Many technical, economic, public policy, and legal factors have combined to determine the 

number of sites currently included in the Superfund program, the cleanup standards and 

technologies to be used, and cleanup work schedule. Some factors that could influence the scope 

of the cleanup effort, as well as the technologies to be used in the future, are described below. 

Chapter 3: National Priority List (NPL) Sites Page 3-3
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• The number of sites added to the NPL, which is difficult to forecast. Listing a site is 

ultimately a decision made by the Assistant Administrator of OSWER, typically, after 

consulting with state and EPA regional officials, potentially responsible parties (PRPs), 

local government, and the governor. Earlier in the program, new additions to the NPL 

fluctuated substantially from zero to over 400 in a single year. However between 1993 and 

2003, the range has been much narrower (13 to 43) and averaged 28 per year. A 2001 study 

by an environmental research group predicted that it would range between 23 and 49 per 

year over the next decade, with a middle value of 35 (Probst & Konisky 2001). The average 

for the three years since that study has been 23. Listing rates of this magnitude are not 

inconsistent with the potential supply of “NPL-caliber” sites. Section 3.3 (Number of Sites) 

describes listing rate scenarios. If more “NPL-eligible” sites are found, they may be 

addressed through other programs, such as RCRA Corrective Action or a state program, or 

may continue to await evaluation and/or cleanup. Because the decision on whether to list a 

site is complex, depending on many variables and input from many stakeholders, there is 

some uncertainty inherent in any such prediction. 

• Although the Superfund Trust Fund now accounts for a small portion of revenues, the 

Superfund operating budget has been relatively stable. Budget authority is $1.31 billion, 

$1.27 billion, and $1.39 billion (requested) for FY 2002, 2003, and 2004 (requested), 

respectively.

 • State and PRP funding for Superfund site cleanups may fluctuate in the future. Many states 

are facing serious budget shortfalls in 2003 and 2004. For Superfund remedial actions, the 

states contribute 50 percent of the construction costs where they own the site and all 

operations and maintenance (O&M) costs for fund-financed sites in their state. For fundfinanced remedies that involve long-term treatment or other measures to restore 

groundwater or surface water quality, CERCLA requires that states assume the costs after 

10-years. The management of many of these sites are now being transferred to states. To 

improve O&M performance and ease the potential cost burden of these projects, EPA has 

been conducting studies on pump-and-treat systems to develop recommended optimization 

practices prior to takeover (U.S. EPA 2001). 

PRP contributions to site remediation may be affected by business conditions and EPA's 

enforcement program activities. State staffing and budgets for both Superfund and nonSuperfund hazardous waste sites programs have been at about the same level in nominal 

dollars for at least seven years (See Chapter 9, State and Private Party Sites).

 • Current resources appropriated to the program may be insufficient to fully implement the 

program. According to a 2001 Resources for the Future study, Superfund faces an average 

annual budget shortfall of approximately $100-200 million over a 10-year period (Probst & 

Konisky 2001). To address this and other long-term Superfund issues, EPA is working with 

the National Advisory Council for Environmental Policy and Technology (NACEPT) to 

help guide the future direction of the Superfund Program. While the work of this group 

cannot yet be quantified in terms of a market projection, it would be helpful for remediation 

service providers to keep abreast of developments in this area (U.S. EPA 2004c). 

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• In planning and implementing its cleanups, EPA coordinates extensively with its regions, 

potentially responsible parties (PRPs), state and local governments, planning authorities, 

local communities, and developers to ensure that the remedies protect public health and the 

environment and are consistent with the anticipated future use of the site. Balancing the 

considerations of these stakeholders may influence the sequence of work, types of 

technologies selected for a site, and the number of sites to be listed on the NPL in the future. 

3.3 Number of Sites

The market for cleanup at NPL sites includes sites where remedial action (RA) is planned but 

has not yet begun. Remedial action is the phase of cleanup that typically involves construction, 

and in some cases operation, of the remediation technology. As of May 30, 2003, 456 proposed 

and final NPL sites not owned by the federal government and 177 NPL sites located at federal 

facilities still required at least one further remedial action (U.S. EPA 2003a). Federal facilities on 

the NPL are addressed in Chapters 6, 7, and 8. Exhibit 3-1 presents the geographical distribution 

of the 456 NPL sites for which future RAs are planned among states and EPA regions. The data 

reflect the industrialized nature of these regions which have many abandoned industrial facilities. 

New Jersey, Pennsylvania, New York, California, Texas and Florida alone account for 

approximately 45 percent of these NPL sites. 

For some of the 456 sites EPA has identified more than one operable unit (OU) or part of the site 

for which an RA is planned. The total number of OUs with planned RAs is 1,073. There may be 

more than one remediation or site investigation technology employed at a given OU. Forty-eight 

percent of these OUs are undergoing remedial investigations and feasibility studies (RI/FSs), and 

Exhibit 3-1. Location of NPL Sites With Planned Remedial Actions 

by State and EPA Region

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still awaiting the selection of remedial technologies (Exhibit 3-2). For 52 percent, remedies have 

been selected, but not implemented (i.e., RA has not begun). Although the specific technologies 

selected are not included in this report, Chapter 2 enumerates the treatment technologies 

previously selected at NPL sites and provides references for additional site-specific information. 

Exhibit 3-2. Phase of Remediation of Operable Units at 

Non-Federal NPL Sites with Planned Remedial Actions 

Remedial 

Assessment 

Not Begun 

Study

 Under Way 

Remedy 

Selected 

Design

 Under Way 

Total 

Operable 

Units 

174 (16%) 346 (32%) 70 (7%) 483 (45%) 1,073 (100%) 

Note:Total sites equals 456; each site may contain more than one operable unit. There may be more than one 

remediation or site investigation technology employed at a given OU. 

Source: Office of Emergency and Remedial Response, CERCLA Information System, June 2003. 

Cleanup contractors for EPA-lead sites typically are selected after the remedial design (RD) has 

been completed. For PRP-lead sites, some PRPs may select a vendor to conduct both the RD and 

RA. Historically, PRPs have conducted RDs and RAs at about 70 percent of Superfund sites. 

This report does not estimate the smaller market for remediation technologies in the Superfund 

removal program. As of the end of FY 2003, EPA had conducted over 7,000 removal actions at 

over 5,000 sites, over 80 percent of which are not currently NPL sites. It is difficult, to predict 

the number, type, and timing of the cleanup of these sites. Removals are usually limited to one 

year and $2 million, and historically have relied little on innovative technologies. 

Future NPL Sites 

The above estimate of the number of NPL sites to be remediated does not include future listings 

on the NPL, which also represents a market for remediation technologies. The number of sites 

that eventually will be listed is uncertain and may depend upon several factors which are 

difficult to predict. Most regions and states do not have a proactive site discovery process aimed 

at developing a complete inventory, which would provide information for such predictions. From 

time to time, there are “pop-up” sites that are a surprise. The estimate of future listings is based 

on recent listing trends. In addition, an examination of the potential supply of hazardous waste 

sites was conducted to ensure that the projected listing rate is feasible. 

Between 1993 and 2003, EPA listed 305 sites, or an average of 28 per year. This report assumes 

that listings will average 28 sites per year from 2004 to 2013, totaling 280 additional sites by 

2013. If more “NPL-eligible” sites are found and evaluated, they may be addressed by other 

programs, such as RCRA Corrective Action or a state program, or may continue to await 

evaluation and/or cleanup. Because the decision on whether to list a site is complex, depending 

on many variables and input from many stakeholders, there is some uncertainty inherent in any 

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such prediction. Although EPA may continue to add sites to the NPL beyond 2013, longer-term 

scenarios are not included in this analysis because of uncertainties in making these predictions. 

The 28-site per year estimate is within a range of estimates developed by a private environmental 

research group in 2001 (Probst & Konisky 2001). Based on interviews with EPA regions and 

nine states and an analysis of listing trends, this study predicted that new listings would range 

from 23 to 49 annually over a decade, with a most probable value of 35. In the three years since 

that study listings have averaged 23. 

Based on information from two GAO reports (U.S. GAO 1998 and 1999) there appears to be a 

sufficient supply of Superfund-eligible and potentially-eligible sites in EPA’s CERCLIS 

database to supply the assumed number of sites for listing. GAO identified 1,800 sites that have 

a Hazardous Ranking System (HRS) score of at least 28.5, which makes them eligible for 

consideration for listing. GAO also estimated that another 3,800 sites in CERCLIS are in earlier 

stages of the Superfund pipeline. Evaluations of the later sites have not progressed to the point 

where their NPL eligibility could be determined. Estimates of state and federal program 

managers have varied widely regarding the percentage of these sites that will ultimately be 

listed. Thus, we can only conclude that some portion of the 5,600 (1,800 + 3,800) sites awaiting 

a listing decision will eventually be listed on the NPL. In addition, from time to time, new site 

discoveries lead to new proposed listings. Thus the potential supply is not inconsistent with the 

280-site assumption. 

The characteristics of NPL sites vary with the basis for listing and when the listing occurs. The 

three basic mechanisms for adding sites to the NPL are the following: 

• Each state may nominate a total of one site without regard to its Hazard Ranking System

(HRS) score;

 • The Agency may propose listing sites recommended by the Agency for Toxic Substances

and Disease Registry; and

 • A site may be evaluated with the HRS, and if the score is above 28.5, that score could be

used to support adding that site to the NPL. 

This third mechanism is the primary one used to add sites. In the earlier years of the program, 

sites listed on the NPL were ranked under the original HRS, which emphasized exposure to 

contaminated groundwater. The revised HRS also considers soil and sediment exposure and 

additional pathways (U.S. EPA 1990). 

3.4 Site Characteristics 

This section describes how frequently certain waste matrices and contaminants are being 

remediated at NPL sites. This information can be used to provide insight on the potential for the 

applications of certain remedial technologies at NPL sites where RAs are planned. Technologies 

that tend to be used at NPL sites are discussed in Chapter 2. 

The analysis is based on a study of sites with signed RODs. As of May 2003, data on 

contaminants and contaminated matrices were available for 1,105 sites (U.S. EPA 2003a). Data 

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are not available for another approximately 50 sites with RODs, many of which had “No Action” 

RODs which do not call for remediation. Because these 1,105 sites represent 79 percent of the 

1,395 non-federally owned sites ever listed or proposed for listing on the NPL as of May 2003, 

EPA believes that their characteristics are likely to be representative of those of other NPL sites. 

3.4.1 Types of Contaminated Matrices 

Exhibit 3-3 shows the percentage of NPL sites remediated for various contaminated matrices: 83 

percent of sites require remediation of groundwater, 78 percent of soil, 32 percent of sediments, 

and 11 percent of sludge. Because too few RODs contain data on other types of wastes, such as 

waste piles and mine tailings, a meaningful analysis for those types of wastes could not be done. 

Exhibit 3-3. Frequencies of Contaminated 

Matrices at NPL Sites With RODs 

3.4.2 Types of Contaminants 

Sites with RODs were analyzed for the presence of three major contaminant groups: volatile 

organic compounds (VOCs), semivolatile organic compounds (SVOCs), and metals. These broad 

groups of contaminants were further divided into more specific treatability subgroups that better 

coincide with the application of certain technologies, such as bioremediation. The 12 most 

frequently occurring contaminants also are identified. Appendix A, Exhibit A-1 lists common 

chemicals in each group. Chemicals and elements are grouped in accordance with EPA test 

methods for evaluating solid waste and standard chemical references, which are also identified in 

the exhibit. 

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Major Contaminant Groups 

Exhibit 3-4 presents the frequency of cleanup of the major contaminant groups. VOCs, alone or 

in combination with other contaminant groups, are to be remediated at 78 percent of sites, 

followed by metals (77 percent) and SVOCs (71 percent). For this analysis the occurrence of a 

contaminant group at a site is counted only once, whether or not it was found in more than one 

matrix. These data also indicate that the NPL sites tend to be complex: all three groups (VOCs, 

SVOCs, and metals) are to be remediated at 52 percent of the sites and two groups are to be 

remediated at 24 percent of the sites, but not necessarily in the same matrix. The sites listed as 

“others” only contain contaminants described as radioactive elements, non-metallic inorganics 

such as nitric oxides, explosives and asbestos, or unspecified organics or inorganics. 

Exhibit 3-4. Frequencies of Major Contaminant 

Groups at NPL Sites With RODs 

Subgroups of Volatile and Semivolatile Organics 

Two of the major contaminant groups, VOCs and SVOCs, were subdivided into more specific 

treatability subgroups that better coincide with the application of certain technologies, such as 

bioremediation. Exhibit 3-5 shows the frequency of cleanup of these subgroups as well as the 

metals group. The subgroups are described below, grouped according to the three major 

contaminant groups: 

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Exhibit 3-5. Frequencies of Major Contaminant 

Subgroups at NPL Sites With RODs

 • VOCs include: halogenated, BTEX (benzene, toluene, ethylbenzene, xylene), and other nonhalogenated VOCs (ketones and alcohols). The most prevalent class of organics, 

halogenated VOCs, which are widely used as solvents, are being remediated at 675 (69 

percent) of the sites. With regard to BTEX, although many of these compounds result from 

petroleum products, CERCLA prohibits listing sites on the NPL that are contaminated with 

petroleum products alone. 

• SVOCs include: polychlorinated biphenyls (PCBs), polynuclear aromatic hydrocarbons 

(PAHs), pesticides, phenols (including pentachlorophenol), and other SVOCs, which 

include chlorobenzene and phthalates. The most common SVOCs are PAHs and phenols, to 

be addressed at 49 percent and 32 percent of sites, respectively.

 • Metals include: lead, arsenic, chromium, cadmium, zinc, nickel, and other less frequently

found metals.

For this analysis, each subgroup was counted only once per site, regardless of whether it 

occurred alone, with other types of contaminants, or in more than one matrix. Because more than 

one contaminant subgroup can be present at a site, the total number of occurrences is greater 

than the total number of sites. 

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Most Common Individual Contaminants 

Exhibit 3-6 shows the 12 contaminants most commonly found to need remediation at NPL sites. 

The list contains six VOCs and six metals. Again, a contaminant is only counted once for each 

site, even if it occurs in more than one matrix; and more than one contaminant can occur per site. 

Exhibit 3-6. Frequencies of the Most Common 

Contaminants at NPL Sites With RODs 

3.4.3 Estimated Quantities of Contaminated Material 

The market also can be described in terms of the quantity of contaminated material to be 

remediated. Fewer RODs contain quantity data than the number that contain contaminant and 

matrix information. The RODs for 42 percent of the 1,105 sites with RODs contain information 

on the quantities of soil, sludge, or sediment to be remediated using any method (i.e., treatment, 

containment, or off-site disposal). The data from these sites are used to characterize the 

quantities of material requiring some type of remediation. 

Distribution of Quantities 

Exhibit 3-7 presents the distribution of the total quantities per site of contaminated soil, 

sediment, and sludge requiring remediation. Based on these estimates, almost 44 percent of the 

sites are expected to contain 10,000 or fewer cubic yards, and less than 17 percent of the sites are 

expected to contain 100,000 or more cubic yards of contaminated material. These data indicate 

an appreciable market for technologies that can effectively treat small quantities of 

contaminated media, as well as a number of sites with larger quantities. These data include all 

available data on material to be treated, contained, or disposed. However, because reviews of 

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RODs indicate that quantities of waste to be capped often are not documented in the ROD, the 

proportion of sites that contain large quantities of wastes may be greater than the data indicate. 

The quantity distributions for soil, sediment, and sludge shown in Exhibit 3-7 involve primarily 

contaminated soil to be remediated. 

Exhibit 3-7. Distribution of Quantities of Contaminated 

Soil, Sediment, and Sludge at NPL Sites With RODs 

Estimated 

Quantities 

(Cubic Yards) 

Number of NPL Sites With Data By Matrix 

Soil Sediment Sludge 

Federal 

Facilities 

Non-fed. 

Facilities 

Federal 

Facilities 

Non-fed. 

Facilities 

Federal 

Facilities 

Non-fed. 

Facilities 

Federal 

Fac. 

Total 

Non-fed. 

Fac. 

< 1,000 10 44 2 29 1 9 13 82 

1,000 - 5,000 10 82 2 28 0 11 12 121 

5,001 - 10,000 7 57 0 16 0 5 7 78 

10,001 - 30, 000 9 95 3 14 1 14 13 123 

30,001 - 50,000 10 52 2 10 1 11 13 73 

50,001 - 100,000 6 39 2 9 0 12 8 60 

> 100,000 14 75 2 16 2 10 18 101 

Total 66 444 13 122 5 72 84 638 

Note: Data are from 714 NPL sites. 

Source: U.S. EPA, Office of Emergency and Remedial Response, CERCLA Information System, June, 2003. 

Quantities by Major Contaminant Group 

The quantities of contaminated material (soil, sediment, and sludge) at the 456 non-federal NPL 

sites with planned RAs were estimated for the three major contaminant groups (i.e., VOCs, 

SVOCs, and metals) from estimates contained in the RODs for sites with similar contaminants. 

The average quantity for each contaminant group at the sites with ROD data was multiplied by 

the estimated number of sites that contain the same contaminant groups based on the percentages 

in Exhibit 3-4. 

Exhibit 3-8 indicates the estimated quantities of contaminated materials at NPL sites by 

contaminant group. An estimated 74 million cubic yards of soil, sludge, and sediment are to be 

remediated at the sites. Much of this material, 66 million cubic yards, is accounted for by 

materials contaminated by metals alone, and in combination with other contaminants. VOCs, 

alone and combined with other contaminants, total 38 million cubic yards; and SVOCs total 60 

million cubic yards. 

In developing these estimates, it was assumed that all of the contaminated material at a site 

contained the contaminant groups present. The average site quantities by contaminant group 

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varied from a low of 45,000 cubic yards for a single group (other) to a high of 682,000 cubic 

yards for SVOCs and metals. 

Exhibit 3-8. Estimated Quantity of Contaminated Soil, Sediment, and Sludge for 

Major Contaminant Groups at NPL Sites With Planned Remedial Actions 

Contaminant 

Group 

No. of Sites 

With Data 

Average Based on 

Available Data 

(Cu. Yds.) 

Number of Sites 

With Planned 

Remedial Action a 

Projected Total 

Quantity 

(Cu. Yds.) b 

Single Contaminant Group 

Metals 46 230,920 46 10,622,320 

VOCs 9 53,267 36 1,917,612 

SVOCs 24 247,116 14 3,459,624 

Others 5 45,556 9 410,004 

Multiple Contaminant Groups 

VOCs & Metals 27 46,450 41 1,904,450 

SVOCs & Metals 40 681,618 32 21,811,776 

VOCs & SVOCs 46 53,527 41 2,194,607 

VOCs, SVOCs & 

Metals 

255 135,683 237 32,156,871 

Totals 452 1,494,137 456 74,477,264 

Notes:

 a Based on the distribution of contaminant groups among the 976 sites with contaminant data shown in Exhibit 3­

4. Each site is placed in one subgroup only.

 b The total for each subgroup is calculated by multiplying columns (3) and (4). 

Source: U.S. RODs, fiscal years 1982-2003. Site-specific data are not available for all quantities of material to be 

remediated at all sites with planned remedial actions. 

3.5 Estimated Cleanup Costs 

EPA has estimated the value of the market for the 456 non-federal facility NPL sites with 

planned RAs. The estimated cost for non-federal already listed Superfund sites that have not 

begun RA is $15.5-23.3 billion in 2003 dollars. This estimate is based on an average cost per 

OU of $14.7 million ($1.4 million for RI/FS + $1.4 million for RD + $11.9 million for RA), and 

$10.3 million for long-term remedial action (LTRA) for sites that require long-term treatment to 

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restore groundwater and surface water (2003 dollars).1 The range in values result from varying 

the RA costs by plus and minus 20 percent. The calculations are shown in Exhibit 3-9. 

The unit cost estimates are applied to the 1,073 OUs that have not yet begun RA, as well as to 

the assumed 230-490 future NPL sites. It was assumed that 50 percent of sites with RD 

underway have already incurred the RD costs, 50 percent of sites with study underway already 

have incurred RI/FS costs, and 45 percent of all sites will require LTRA. 

Exhibit 3-9. Estimated Cleanup Costs for NPL Sites a 

Low Medium High 

Existing Pre-RA Sites (In the Relevant Market) b 

No. of Sites 456 456 456 

No. of OUs 1,073 1,073 1,073 

Total Cost $15,516 mil $19,395 mil $23,274 mil 

Assumed New NPL Listings 2004 - 2013 a 

No. of Sites Per Year 23 c 28 d 49 e 

Total over 10 years 230 280 490 

Number of OUs 541 658 1,152 

Total Cost $8,363 mil $12,726 mil $26,725 mil 

Total NPL a, b 

Current & Future NPL Sites $23,879 mil $32,121 mil $50,000 mil 

Notes: 

Low Cost of RI/FS+RD+RA = $11.6 million per OU (from text above) and 230 additional sites to the NPL. 

Medium Cost of RI/FS+RD+RA= $14.7 million per OU (from text above) and 280 additional sites to the NPL. 

High Cost of RI/FS+RD+RA= $17.6 million per OU (from text above) and 490 additional sites to the NPL. 

NA Not applicable 

LCC Life Cycle Cost, or cost to complete 

a For purposes of this analysis, it is assumed that listings cease after 10 years, although cleanup work is likely to 

continue many years beyond. Although new sites may be added to the NPL beyond 10 years, they are not 

included because of uncertainties in predicting NPL listings. 

b Does not include costs for sites that have begun RA. 

c Low case in the Resources for the Future study, derived from the average for 1996-1999 (Probst & Konisky, 

2001) 

d Average of 1993-2003 actual additions to the NPL 

e High case in the Resources for the Future study (Probst & Konisky 2001) 

These 2003 figures are adjusted from 1999 dollars reported in the 2001 Resources for the Future study ($1.3 

million each for RI/FS and RD, 11.0 million for RD) ± 20% (Probst & Konisky, 2001). The average LTRA cost per OU 

was reported in a 2001 EPA study using data from 79 LTRA projects as $10.0 million and adjusted to 2003 dollars 

(U.S. EPA 2001). Price adjustments are based on the gross domestic product (GDP) price deflator. 

Chapter 3: National Priority List (NPL) Sites Page 3-14 

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This estimate does not include (a) costs for federal facility NPL sites, which are described in 

Chapters 6 through 8, (b) the cost of continuing work at NPL sites that have already begun 

remedial action, and (c) costs for site assessments, removals, administrative costs such as 

payrolls, other federal agency support, oversight of potentially responsible party (PRP)-lead 

cleanups, and enforcement activities. This estimate is more than twice that of a similar estimate 

in the 1997 edition of this report. The difference is explained by an 18 percent increase in the 

general price level, the fact that the remaining sites on the NPL that have not begun RA are 

expected to be more complex and have more OUs than the average for previous NPL sites, and 

the fact that LTRA costs were not included in the previous report. 

Using the same unit cost estimates per OU, and assuming 23-49 sites will be listed annually, the 

230-490 sites assumed to be listed over the next 10 years will cost $8.7-26.7 billion (at the 

assumed most-likely value of 28 sites annually for 10 years, the cost would be $12.7 billion). If 

more or fewer sites are listed, this total would be adjusted accordingly. This estimate is based 

upon the above assumptions plus the expectation that future sites will be more complex, larger, 

and have more OUs per site than the average NPL site in the past. 

Another indication of the amount of cleanup effort likely to be undertaken is the size of the EPA 

Superfund budget. During the mid-1990s, Congress allocated $1.4 billion annually. By 2002, 

budget authority had dropped to $1.27 billion (excluding a post-911 appropriation), and by 2003, 

it was $1.24 billion. For 2004, EPA has requested $1.39 billion. The EPA budget does not 

include costs incurred by PRPs, states, or other federal agencies. Although the Superfund budget 

has been relatively stable in nominal dollars, it has declined about 15 percent between 2000 and 

2003 in real (adjusted for inflation) dollars. 

Although it is useful to examine the trends in the Superfund budget, these figures do not coincide 

with total national expenditures for site work. Since the EPA budget does not include costs 

incurred by PRPs, states, or other parties, the budget data do not compare with the above market 

value estimates. The market estimates include both cleanup costs incurred by PRPs and other 

parties and direct costs paid by EPA for sites for which there is no available responsible party. 

The amount paid by responsible parties compared to EPA varies from project to project and is 

difficult to forecast. 

In addition to site work at Fund-paid sites, EPA’s Superfund budget also pays for activities that 

are not for direct site work, such as administration and management, cost recoveries, 

enforcement, removals and other short-term actions, oversight of PRP activities, and research 

and development. About 25-35 percent of the EPA Superfund budget typically goes to long-term 

site remediation activities. Thus, the above market value estimates were not developed to be used 

for budget analysis or planning. 

3.6 Market Entry Considerations 

Technology decisions for Superfund sites are based on the specific information available for 

each site and the state-of-the-art of the available technologies. Information on new technologies 

is particularly critical at two points in the decision-making process: during remedy selection, and 

during remedy design and procurement. This section describes how technology vendors can 

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benefit from understanding how site managers consider their options during these two cleanup 

phases.2 

3.6.1 Market Considerations During Remedy Selection 

The Superfund RI/FS process is an integrated, phased approach to characterizing the site risks 

and evaluating remedial alternatives. Early in the RI/FS stage, technologies are identified and 

screened with respect to technical implementability, effectiveness, and relative cost. To ensure 

that Superfund site managers and consulting engineers consider a given technology, it is 

important to make them aware of the technology at this early stage. During the final technology 

evaluation, later in the RI/FS, technologies are compared and evaluated using the nine evaluation 

criteria specified in the National Contingency Plan (NCP). Information on technology 

performance and cost is particularly important during this final evaluation. EPA and engineering 

consulting firms (who usually conduct the RI/FSs for EPA, states, and PRPs) use a variety of 

information sources, many of which are described in Section 2.3, to identify potential 

technologies and to make their capabilities more widely known. Since information for innovative 

technologies may be limited, treatability studies or on-site demonstrations may be used to assess 

cost and performance. 

While Superfund policies encourage the selection and implementation of new technologies, the 

Superfund remedy selection process can present some hurdles for innovative technology vendors 

because:

 • Information on innovative technologies is often limited. Superfund site managers and 

consulting engineers may not have as much information on the performance and cost of an 

innovative technology as for an established technology. Reports and databases about 

established remedial technologies have already been developed. Superfund site managers 

may have difficulty comparing the merits of an innovative to a conventional technology if 

they do not have information on a technology's cost, implementability, short- and long-term 

effectiveness, and ability to reduce the toxicity, volume, or mobility of the contaminants.

 • Treatability studies and on-site demonstrations may be impractical. The NCP and EPA 

policy encourage the use of bench- or pilot-scale treatability studies, when appropriate and 

practical (EPA, 1990). EPA policy stipulates that: promising new technologies should not be 

eliminated from consideration solely because of uncertainties in their performance and cost, 

particularly when timely treatability study could resolve those uncertainties (U.S. EPA 

1996a). In reality, the funding and schedule for site cleanup, as well as contracting and 

regulatory impediments, may preclude the use of studies and demonstrations. 

• The RI/FS contractor may be prohibited from bidding on the RA. For example, at EPA-lead 

and state-lead sites, the remedial design contractor at a site usually does not conduct the 

remedial action. A technology vendor that has the capability to provide both RI/FS and 

A useful source for tools to help technology vendors advance and implement their technologies is the Vendor 

Support web site maintained by OSRTI, http://clu-in.org/vendor/. 

Chapter 3: National Priority List (NPL) Sites Page 3-16 

2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

RD/RA services should determine the relative value of the two opportunities before 

deciding which service to provide. 

To make their capabilities more widely known, technology vendors may consider participating 

in the programs cited in Section 2.3, and contacting remedial project managers (RPMs) and 

consulting engineers. A vendor who is interested in a particular NPL site, may contact the 

assigned EPA RPM for more information. The appropriate EPA regional office or web site, 

listed in Appendix A, can provide the identity of the RPM for a specific site. Also, information 

on specific technologies may be provided to consulting engineers for their consideration in the 

analysis of cleanup options. Appendix A also includes a list of current regional service contracts 

(RACs). 

3.6.2 Market Considerations During Design and Procurement 

Once a remedy has been selected and documented in a ROD, the project enters the design 

process, where the details of the cleanup, such as waste quantities and performance standards, 

are more clearly defined. At this stage, federal and state agencies can make use of technology 

information for preparing requests for proposals and evaluating bids. 

All Superfund sites requiring cleanup for which EPA has the lead currently are funded by one of 

the following mechanisms:

 • Remedial Action Contracts (RACs): The RACs provide professional architect/engineering 

services to EPA to support response planning and oversight of CERCLA. These services 

include: program support (management); remedial investigation and feasibility studies; 

engineering services to design remedial actions; engineering evaluations and cost analyses 

for non-time-critical removal actions, including issuing and managing subcontracts for 

construction of the selected remedy, and engineering services for construction oversight. 

RAC services also include enforcement support, such as negotiation support, and oversight 

of RI/FS studies, remedial designs, and remedial actions; and other technical assistance, 

including community relations, sampling and analysis, and pre-design investigations. 

Services may also include technical and management services supporting EPA's 

coordination and/or oversight of remedial activities performed by a State, the U.S. Army 

Corps of Engineers, or responsible parties. 

• Emergency and Rapid Response Services (ERRS) Contracts: The ERRS contracts provide 

emergency, time-critical removal, and quick remedial response cleanup services for the 

CERCLA, Oil Pollution Act (OPA), and Underground Storage Tank (UST) programs. They 

provide cleanup personnel, equipment, and materials to contain, recover, or dispose of 

hazardous substances, analyze samples, and restore sites. Because of the broad range of 

cleanup services needed and the rapid time frame within which the contractors must 

respond, it is likely that the contractors will do substantial subcontracting.

 • Interagency Agreements (IAGs): EPA enters into agreements with the U.S. Army Corps of 

Engineers, Bureau of Reclamation, or other federal agencies. 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

• Cooperative Agreements (CAs): EPA enters into agreements with states, political 

subdivisions, or Native American Tribes. The state performs work with its own resources, or 

by contracting for needed goods and services with private firms. 

As previously stated, a list of regional service contracts is included in Appendix A, Exhibit A-2. 

The most definitive sources of information on selected remedies for sites entering RD and RA 

are the RODs, Treatment Technologies For Site Cleanup: Annual Status Report (Eleventh 

Edition) (U.S. EPA 2004a), and the Annual Status Report Remediation Database (U.S. EPA 

2004b). The RODs provide detailed information on the site contaminants and risks posed, the 

selected remedy, estimated costs, and associated cleanup levels. ROD information is also 

available on the EPA web site (http://www.epa.gov/superfund/sites/rods/index.htm). A copy of 

the ROD and other site background documents can also be obtained by contacting the Regional 

Community Involvement Coordinator (CIC) for the site and by visiting the site information 

repository. The location of the site information repository may be obtained from the EPA web 

site or the CIC. The Superfund Public Information System (SPIS), available on CD ROM, also 

contains ROD documents and abstracts as well as CERCLIS and Archive data. The SPIS is 

available on CD-ROM from the National Technical Information Services (NTIS), (telephone 1-

800-553-6847) or from their web site at order@NTIS.gov. Their product number is SUB-5462. 

For information on innovative treatment and selected established technologies, the Annual 

Status Report Remediation Database (U.S. EPA 2004b) provides the most current summary 

information on the contaminants and media to be remediated, anticipated or actual cleanup 

schedules, and expected site lead (EPA, state, PRP). 

A vendor may use these publications to identify opportunities or assess remediation service or 

technology needs. Vendors also may provide cost, performance, and availability information to 

the EPA RPM or state site manager and the site remedial design firm or agency. Vendors can 

enhance their responsiveness to requests for proposals (RFPs) for site remedial actions by 

keeping abreast of site activities. Once an RFP has been issued, the award of a contract may take 

weeks or months. 

3.6.3 Research, Development, and Demonstration 

Technology vendors, property owners, A/E firms, site managers, and other stakeholders may 

benefit from new applications that are currently in various stages of research, development, 

testing an evaluation. Likewise, some vendors or technology developers may need help to 

disseminate information about their technologies and services. Section 2.3 describes the major 

programs that conduct or support RD&D, as well as sources to help vendors publicize to all 

stakeholders the capabilities of their technologies. 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

3.7 References 

Probst, Katherine N. & David M. Konisky, et. al., 2001. Superfund’s Future, What Will It Cost, 

Resources For the Future, Washington, D.C. 2001. 

Russell, Milton, et. al., 2001. Superfund Remediation Decisions: Quantitative Analysis of 

Experience, 1987-2000 and Policy Implications- Phase I Report, Joint Institute for Energy and 

Environment, Knoxville, TN, October 2001. 

U.S. EPA (Environmental Protection Agency), 1990. “Hazard Ranking System; Final Rule,” 55 

Federal Register 51532, Vol. 55, No. 241, Part II, December 14, 1990. 

U.S. EPA, 1992. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, Third 

Edition, Proposal Update II, PB94-170321, Office of Solid Waste and Emergency Response, 

November 1992. 

U.S. EPA, 1996a. Initiatives to Promote Innovative Technology in Waste Management, OSWER 

Directive 9380.0-25, Office of Solid Waste and Emergency Response, April 29, 1996. 

U. S. EPA, 1996b. The Facts Speak For Themselves: A Fundamentally Different Superfund 

Program, Office of Emergency and Remedial Response, November 1996. 

U.S. EPA, 2001. Groundwater Pump and Treat Systems: Summary of Selected Cost and 

Performance Information at Superfund-financed Sites, EPA-542-R-01-021b, Office of Solid 

Waste and Emergency Response, December 2001. http://www.clu-in.org

U. S. EPA, 2002. Records of Decision (RODs), 1982-2002, on CD-ROM, PB96-593551, Office 

of Emergency and Remedial Response, 2002. 

U.S. EPA, 2003a. CERCLA Information System (CERCLIS), Office of Emergency and 

Remedial Response, June 2003. 

U.S. EPA, 2004a. Treatment Technologies For Site Cleanup: Annual Status Report (Eleventh 

Edition), EPA-542-R-03-009, Office of Solid Waste and Emergency Response, February 2004. 

http://www.clu-in.org/asr 

U.S. EPA, 2004b. Annual Status Report Remediation Database, Office of Solid Waste and 

Emergency Response. http://epa.gov/tio/technologies

U.S. EPA, 2004c. National Advisory Council for Environmental Policy and Technology 

(NACEPT), web site. http://www.epa.gov/oswer/SFsub.htm

U.S. EPA, 2004d. Superfund: Building on the Past, Looking to the Future, (“120-day study”), 

April 22, 2004. 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

U.S. EPA, 2004e. Vendor Support, web site maintained by Office of Superfund Remediation and 

Technology Innovation to provide tools to help remediation technology vendors advance and 

implements their technologies. http://cluin.org/vendor

U.S. GAO, 1998. Hazardous Waste, Information on Potential Superfund Sites, GAO/RECD-99-

22, U.S. General Accounting Office, November 1998. 

U.S. GAO, 1999a. Superfund: Progress Problems, and Future Outlook, GAO/T-RCED-99-128, 

U.S. General Accounting Office, March 23, 1999. 

U.S. GAO, 1999b. Superfund Progress and Challenges, Statement for the Record by David G. 

Wood, Associate Director, Environmental Protection Issues, Resources, Community, and 

Economic Development Division, GAO/RCED-99-202, U.S. General Accounting Office, May 

25, 1999. 

U.S. GAO, 1999c. Hazardous Waste, Observations on EPA’s Cleanup Program and Budget 

Management Practices, GAO/T-RCED-99-168, U.S. General Accounting Office, April 29, 

1999. 

U.S. GAO, 1999d. Superfund: Half the Sites Have All Cleanup Remedies in Place or Completed, 

GAO/T-RCED-99-245, U.S. General Accounting Office, July 1999. 

U.S. GAO, 2001. EPA’s Expenditures to Clean Up the Bunker Hill Superfund Site, GAO-01-

431R, U.S. General Accounting Office, March 28, 2001. 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Chapter 4 

Demand for Remediation of 

RCRA Corrective Action Sites 

Prior to the passage of the Resource Conservation and Recovery Act (RCRA) (42 U.S.C. 

§§6901-6922k), facilities that treated, stored, or disposed of hazardous waste, and occasionally 

waste generators and transporters (collectively known as waste handlers) often experienced 

releases of waste into the environment. Much of that waste, which is similar to the hazardous 

waste found at Superfund sites, was disposed of intentionally or unintentionally on the land. A 

number of RCRA sites have remediation needs that equal or exceed those of many Superfund 

sites. Although not all RCRA sites will require cleanup, this program represents a substantial 

market for environmental site characterization and cleanup services. 

RCRA assigns the responsibility of 

corrective action to facility owners and 

operators and authorizes EPA to oversee 

corrective action. Unlike Superfund, 

oversight responsibility is delegated to 

authorized states. EPA estimates that the 

universe of RCRA hazardous waste handlers 

subject to corrective action exceeds 6,600 

sites. EPA has discretionary or statutory 

authority to impose corrective action on 

these sites, when necessary. Of the 6,600 

sites, about 3,800 are likely to require 

corrective action. These sites have had a 

preliminary evaluation by a regulatory 

authority and, based on these evaluations, 

are required to undergo further investigation 

and/or cleanup. EPA and the states are 

examining the extent of that contamination 

and the scope of corrective action needed at 

these sites. 

Although RCRA requires that all sites in 

need of corrective action be cleaned up, EPA 

has set ambitious interim cleanup targets for 

1,714 sites identified by EPA and the states 

as warranting early action. EPA and the 

authorized states selected these sites, known 

collectively as the RCRA Cleanup Baseline, because they pose potential unacceptable exposures 

of contaminants to humans and/or are likely to spread groundwater contamination. By 2005, 95 

percent of these baseline sites will have controlled the potential for human exposure, and 70 

Highlights 

• EPA and the states have identified 3,829 sites 

that are likely to require corrective action. 

• EPA and the states have identified 1,714 sites, 

• 

site characterization methods have been 

resulting in reduced site-assessment costs, 

less traditional remedies, and improved remedy 

design. 

• 

by fluctuations in state budgets. State staffing 

levels and budgets (in nominal dollars) for 

not increased in about a decade. 

• Land development trends are also likely to 

affect the pace and nature of RCRA cleanups, 

since property transfers or redevelopment 

generally require site assessments and, if 

necessary, remediation. 

• 

RCRA sites require remediation of 

• 

known collectively as the RCRA Cleanup 

Baseline, that warrant early action to control 

current human exposures and migration of 

contaminated groundwater. 

During the past five to ten years, refinements in 

improved data quality, expanded applicability of 

The pace of the cleanups is likely to be affected 

hazardous waste remediation and oversight has 

Based on limited samples of sites, over 80% of 

groundwater, 60% of soil, 10% each of sludge 

and surface water, and 6% of sediments. 

Based on limited samples of sites, VOCs are to 

be remediated at 60% of sites, followed by 

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percent of them will have controlled the migration of contaminated groundwater thereby 

decreasing the immediate health risks from these sites. Achieving these goals will enable the 

Agency to meet its interim goals for corrective action set under the Government Performance 

and Results Act (GPRA) of 1993. Nevertheless, in most cases, the interim goals are not the final 

remedy. While achieving final cleanups is not likely to occur as quickly as meeting the interim 

goals, the steps taken to attain interim goals are directing attention to cleanup at most baseline 

sites. 

4.1 Program Description

RCRA has a long and complex regulatory history that has led to a performance-based approach 

to evaluating and cleaning up contaminated sites. To develop a practical understanding of this 

market, it is useful to understand this history, the general process that has evolved for managing 

RCRA sites, and how these steps are implemented by EPA and authorized states. 

4.1.1 Regulatory History 

RCRA mandates several regulatory programs, but the largest is the waste management program, 

known as Subtitle C. Subtitle C sets forth comprehensive national requirements for managing the 

treatment, storage, disposal, and recycling of solid and hazardous waste. Among other provisions, Subtitle C establishes a management system to control new hazardous waste from the time 

it is generated to its ultimate disposal (“cradle-to-grave”). In addition to its primary purpose of 

preventing releases of process waste into the environment by minimizing waste generation and 

by creating reuse and recycling incentives, Subtitle C contains important requirements that 

address releases of contaminants into the environment from RCRA sites. It is these requirements 

that influence the nature and amount of nationwide cleanup activities. 

Releases of contamination at RCRA sites are addressed under the RCRA Corrective Action 

program, which is administered by EPA’s Office of Solid Waste (OSW), EPA regional offices, 

and states that EPA has authorized to implement the program. Congress initially authorized EPA 

to promulgate requirements for monitoring and remediating only on-site releases to groundwater 

from hazardous waste management units, such as landfills. Later, with enactment of the 1984 

Hazardous and Solid Waste Amendments (HSWA) of RCRA, Congress greatly expanded EPA’s 

corrective action authority to include releases to all environmental media from regulated solid 

waste management units (SWMUs) at treatment, storage, and disposal facilities (TSDFs) seeking 

permits under Subtitle C. A solid waste management unit is a discernible unit in which solid 

waste has been placed at any time, irrespective of whether the unit was intended for the 

management of solid or hazardous waste. This definition includes any area of a facility at which 

solid waste has been routinely and systematically released. A release may include intentional or 

accidental spillage, leakage, pumping, pouring, emitting, emptying, discarding, injecting, 

escaping, leaching, dumping, or disposal of hazardous waste into the environment. It also may 

include the abandonment or discarding of barrels, containers, and other closed receptacles 

containing hazardous waste or hazardous constituents. RCRA Corrective Action can be 

conducted at any RCRA facility that handles hazardous waste. 

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In 1990, EPA proposed detailed regulations intended to govern the technical and procedural 

aspects of corrective action (40 CFR Part 264 Subpart S) (EPA 1990a) and in 1996, published an 

Advance Notice of Proposed Rulemaking (ANPR) that established guidance on areas of the 

program not addressed by the 1990 proposed regulations (U.S. EPA 1996a). Many provisions in 

these proposed rules were withdrawn, and only the ANPR continues to serve as EPA’s primary 

corrective action implementation guidance. 

In implementing the program, EPA and the authorized states have revised the basic approach to 

corrective action by (a) establishing interim goals that rely on near-term actions to reduce 

imminent threats and prevent further spread of contamination that had been released into the 

environment; (b) establishing long-term remediation goals; (c) streamlining the procedures for 

addressing newly generated waste that previously posed unintended barriers to cleaning up 

RCRA sites (remediation waste); (d) increasing emphasis on using risk-based approaches and 

parity with Superfund program requirements in determining appropriate cleanup levels; and (e) 

implementing a number of reforms to streamline program administration. EPA’s intent has been 

to limit the regulatory barriers impeding timely and cost-effective cleanups, control present risks 

posed by RCRA sites, and allow EPA and authorized states to exercise considerable flexibility 

throughout the site management process. 

Interim Goals 

In conjunction with the proposed Subpart S regulations of 1990, EPA issued the RCRA 

Implementation Study. This report addressed the long-term goal of cleaning up RCRA sites but 

emphasized the importance of interim environmental actions to reduce imminent threats and 

prevent further spread of contamination that had been released into the environment (U.S. EPA 

1990b). Soon after, EPA established procedures in the 1992 RCRA Stabilization Strategy for 

implementing near-term actions to prevent the migration of contamination within and outside 

facility boundaries (U.S. EPA 1991). 

In 1993, EPA merged the Agency’s near-term strategic interests in preventing human exposures 

and the spread of contamination with the GPRA goals. EPA also considered stakeholder 

concerns that the Corrective Action program was focused more on the process of cleanup than on 

outcomes. Therefore, in 1994, EPA established environmental indicators to measure near-term 

results at RCRA sites, effectively moving the focus of the Corrective Action program from 

process to outcomes. The two environmental indicators against which progress towards the 2005 

GPRA goals are being measured are (1) the control of current human exposures, and (2) the 

control of migration of contaminated groundwater. These indicators provide a means of evaluating and reporting on current site conditions rather than on the conditions of sites following 

final cleanup. Considerable progress has been made toward this end. EPA and the states have 

identified 1,714 sites that warrant early action. See EPA’s Corrective Action web site for the 

latest information on specific sites and progress at http://www.epa.gov/epaoswer/hazwaste/ca/

facility.htm. 

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Long-Term Goals 

Meeting the interim environmental indicator goals generally represents only a small component 

of a typical site’s final corrective action. The ultimate goal of RCRA Corrective Action is to 

achieve final remedies that are appropriate for reasonably anticipated future land uses. EPA, the 

states, and other stakeholders are developing specific long-term goals for corrective action and 

are continuing to streamline the administrative process in anticipation of cleaning up all high, 

medium, and low-priority RCRA sites in the decade ahead. EPA and the states have identified 

3,829 sites that are likely to require corrective action. 

Remediation Waste 

Early in the 1990s, EPA recognized that several Subtitle C regulations, which control newly 

generated waste, also pose unintended barriers to managing “remediation waste,” which is waste 

generated during RCRA Corrective Action. To minimize or eliminate these and other barriers, 

the Agency and authorized states, with advice from stakeholders, took several actions. 

In 1993, EPA proposed the Corrective Action Management Unit (CAMU) rule allowing sites to 

place waste generated during a cleanup into a CAMU or a temporary unit without first having to 

treat it. CAMUs are physical, geographic areas within a facility designated during cleanups for 

the treatment, storage, or disposal of remediation waste. Temporary units are tanks or container 

storage areas designated during cleanups for use solely to treat or store remediation waste. The 

CAMU rule eased the land disposal restrictions for remediation waste generated during a 

cleanup, thus exempting these units from the Subtitle C land disposal unit minimum technology 

requirements (§264.552 (a)(2)) (U.S. EPA 1993a). The CAMU rule established general 

performance-based standards to accommodate the variety of site situations that exist in the 

RCRA program and granted EPA and authorized states considerable regulatory relief and 

flexibility in the use of CAMUs and temporary units. 

The rule was intended to result in more expeditious on-site treatment of greater volumes of 

remediation waste at less cost. However, in spite of broad support, the rule was challenged in 

court due in large part to concern that it lacked explicit waste treatment and unit design requirements for CAMUs. Following this challenge, EPA agreed to re-examine the CAMU rule in the 

context of developing the 1996 proposed Hazardous Remediation Waste Management 

Requirements (HWIR-Media) rule, and the litigation was stayed pending the outcome of this 

rulemaking process. 

When EPA published the final HWIR-Media rule (63 FR 65874) in 1998, the specific provisions 

of the rule did not address the basic concerns of the litigants (U.S. EPA 1998a). To remove the 

litigation cloud that had been deterring the use of CAMUs in the field since 1993, EPA agreed in 

2000 to amend the 1993 rule by imposing several minimal waste treatment and design standards 

and limits on the types of waste that may be managed in a CAMU. The CAMU definition was 

also modified to specify that CAMUs be located within contiguous property under the control of 

the owner/operator where the waste originated. The final amendments to the CAMU Rule 

became effective in January 2002 (U.S. EPA 2002a). 

In 1998, EPA finalized selected portions of the 1996 proposed Hazardous Remediation Waste 

Management Requirements (HWIR-Media) rule (U.S. EPA 1998a). Although the final rule does 

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not provide the broad reforms proposed in the 1996 HWIR-media rule (U.S. EPA 1996b), it does 

offer relief from some of the Subtitle C requirements on TSDFs during cleanup operations. It 

also makes available a special form of RCRA permit, called a remedial action plan (RAP), for 

the treatment, storage, or disposal of waste generated during cleanup activities. RAPs provide an 

alternative to traditional permits and help expedite cleanup. 

Until that time, the treatment, storage, or re-disposal of hazardous remediation waste required the 

same type of traditional, facility-wide RCRA permit (Part B permit) as a TSDF engaged in 

managing process waste. Obtaining such a permit can take several years. The final HWIR-Media 

rule removed the facility-wide corrective action requirements and made available flexible 

performance-based standards that may be imposed via a traditional Part B permit or a RAP for 

remediation waste management sites. The new performance-based standards may be applied in 

lieu of 40 CFR 264 Subparts B, C, D, and 264.101. 

The final HWIR-Media rule also contained a number of important provisions, including the 

creation of a new kind of waste management unit called a staging pile for storing (not treating) 

waste, which then is not subject to land disposal restrictions (LDRs) or minimum technology 

requirements (MTRs). The rule excludes dredged materials from RCRA Subtitle C regulations if 

the materials are managed by an appropriate permit under the Clean Water Act or the Marine 

Protection Research and Protection Act. The rule also simplifies the procedures states must 

follow when seeking authorization to manage their RCRA programs. 

In 1998, EPA established alternative treatment standards under Phase IV of the LDR for 

contaminated soil produced during cleanup operations. If remediation waste is not amenable to 

waste-specific standards specified in the LDR (§268.40), a facility may apply the alternative 

treatment standards (§268.49; 63 FR 28556; May 26, 1998) promulgated pursuant to the 1984 

HSWA (U.S. EPA 1998b). These standards are less stringent than those in §268.40. 

Also in 1998, EPA amended the rule that specified the requirements for closing land disposal 

units containing hazardous waste. The amendment allowed EPA and authorized states to use a 

variety of authorities to impose requirements on non-permitted land disposal units requiring 

post-closure care and allowed for the closure of certain land-based units with released hazardous 

constituents to be addressed through the Corrective Action program (U.S. EPA 1998c). These 

changes give regulators increased flexibility to use alternate mechanisms under a variety of 

authorities to address closure requirements based on the particular needs of the facility. 

As part of ongoing efforts to improve program coordination, the Agency issued a final memorandum entitled Risk-Based Clean Closure in 1998. The Risk-Based Clean Closure memorandum 

provides additional guidance on EPA’s interpretation of clean closure, specifically with respect 

to the amount of residual contamination that may remain in an environmental medium while still 

meeting the clean closure standards (U.S. EPA 1998d). Further guidance on “restricted-use clean 

closure” is available in Final Guidance on Completion of Corrective Action Activities at RCRA 

Facilities, which guides EPA and authorized states through the process of determining when a 

cleanup is complete (U.S. EPA 2003a). 

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Risk-Based Corrective Action 

EPA issued a parity policy in 1996 between the CERCLA (Superfund) and RCRA Corrective 

Action programs, entitled Coordination Between RCRA Corrective Action and Closure and 

CERCLA Site Activities (U.S. EPA 1996c). This guidance describes the conditions under which 

acceptance of decisions made by other remedial programs may be used. It recommends riskbased approaches when developing cleanup levels for RCRA regulated units and establishes the 

general principle that RCRA and CERCLA cleanups will achieve similar environmental results, 

thereby establishing a policy that cleanups under one program will be acceptable to the other 

program. It also identifies situations when deferral of activities to other programs is appropriate, 

and encourages coordination among the various cleanup programs at the federal and state levels. 

Risk-based corrective action provides an alternative to the use of strict numeric standards for 

specific contaminants as endpoints for cleanup activity, which is generally less cost effective. 

RCRA Cleanup Reforms 

Through a series of administrative reforms, known as the RCRA Cleanup Reforms, EPA 

continues to work with the states and stakeholders to develop new results-oriented cleanup 

guidelines, foster outreach and training to encourage flexible approaches to corrective action, 

and enhance community involvement. The RCRA Cleanup Reforms are expected to nurture 

creative, practical approaches which, in the field, means eliminating unnecessary administrative 

or technical steps, evaluating sites for overall risk, and applying appropriate risk-based facilitywide corrective action measures. 

Several guidance documents have been issued since 1999 to promote effective cleanup results 

and enhance public involvement. For instance, EPA’s final Handbook of Groundwater 

Protection and Cleanup Policies for RCRA Corrective Action, issued in 2002, is intended to help 

regulators, owners and operators of RCRA sites, and the public locate and understand EPA 

policies on groundwater use, protection, and cleanup within the framework of applicable state 

requirements (U.S. EPA 2002b). The Results-Based Approaches and Tailored Oversight 

Guidance for Facilities Subject to Corrective Action Under Subtitile C of the Resources 

Conservation and Recovery Act encourages technical and administrative innovation to achieve 

environmentally protective cleanups on a facility-specific basis (U.S. EPA 2003c). The 

approaches discussed in the document offer regulators flexibility in setting cleanup goals, 

planning data collection efforts, and letting owners/operators undertake cleanup actions with 

reduced Agency oversight when appropriate. A January 2001 memorandum discusses a variety 

of new enforcement approaches, such as reduced agency oversight and flexible compliance 

schedules, that are available to EPA and authorized states to help accomplish timely, protective, 

and efficient corrective action (U.S. EPA 2001). 

EPA has also expanded outreach and developed comprehensive training as part of the 1999 

reforms. Some of the training gives EPA and state regulators the opportunity to learn from their 

peers about successful cleanup approaches. EPA has also begun piloting the most innovative of 

these approaches at the site level. Twenty-five pilots were launched in the first year. Creating 

partnerships, training, connecting communities with cleanups, and capitalizing on the redevelopment potential of RCRA sites are likely to increase the number of cleanups started during this 

decade. 

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4.1.2 Corrective Action Process

A rigid process-oriented framework, such as that proposed in Subpart S (U.S. EPA 1990a) and 

the 1994 Corrective Action Plan (U.S. EPA 1994a), is not always applicable to the wide range of 

contamination problems at the diverse types of RCRA sites. The 1996 Advanced Notice of 

Proposed Rulemaking (ANPR), EPA’s primary corrective action implementation guidance, 

emphasizes a performance-based approach and asserts that the elements of the process should 

not become ends in themselves (U.S. EPA 1996a). EPA recommends that cleanups be guided by 

several operating principles:

 • Corrective action decisions should be based on risk;

 • Corrective action should focus on results rather than process;

 • Interim actions and stabilization should be used to reduce risks and prevent exposure;

 • Corrective action activities should be phased to focus resources on the areas or exposure

pathways of highest concern;

 • Corrective action requirements should be addressed using the most appropriate authority,

including state authorities, for any given facility (In certain cases, the states may rely on

non-RCRA state authorities to satisfy correction action requirements); and

 • Corrective action implementation should provide for meaningful inclusion of all

stakeholders through full, fair, and equitable public participation.

Although the implementation of corrective action varies from site to site, it generally begins with 

an evaluation of existing site conditions, including information from the initial site assessment, 

called a RCRA facility assessment (RFA). EPA or an authorized state conducts the RFA, which 

involves examining a facility’s SWMUs to determine if a release has occurred or if the potential 

for a release exists. 

While site characterization is underway for the final cleanup, the owner or operator of a facility 

may be required to conduct an interim action, such as stabilizing contaminated waste to prevent 

the spread of contamination or providing an alternative source of drinking water if actual or 

potential contamination of drinking water supplies exists. Although an interim action typically 

occurs early during the investigation of the site, it may take place at any time prior to completion 

of the final remedy. 

When additional site information is necessary to support an interim action, cleanup decision, or 

achievement of environmental indicators, the facility owner or operator may conduct a RCRA 

facility investigation (RFI). The RFI involves sampling, modeling, and other testing to determine 

the nature and extent of contamination and to characterize the site’s geological and hydrological 

conditions. 

If a corrective action is needed, a site owner will conduct a corrective measures study (CMS) to 

evaluate alternative remediation approaches and select a preferred alternative as the remedy. 

Sometimes, the CMS, which is the responsibility of the facility owner or operator with oversight 

from EPA or the state, can be conducted concurrently with the RFI. In cases where EPA or a 

state is using performance standards or a similar approach, or where the preferred remedy is 

apparent early in the process, the CMS may be highly focused. Upon approval of a remedy by 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

the regulatory agency, the owner or operator may begin corrective measures implementation 

(CMI), which involves designing, constructing, maintaining, and monitoring the remedial 

measure. EPA recommends that current and reasonably expected future land uses be considered 

when selecting corrective action remedies. 

4.1.3 Corrective Action Implementation

State Authorization 

States are the primary implementors of the RCRA program, including RCRA Corrective Action. 

EPA provides several million dollars annually in grants to states for state oversight of cleanup at 

RCRA sites. As of April 17, 2003, EPA has authorized 48 states, some territories, and the 

District of Columbia to manage their own base programs for waste management and prevention. 

Thirty-nine states and one territory are authorized to oversee RCRA Corrective Action. EPA 

regional offices have the lead responsibility for implementing the program in Indian Territories 

and in states that have yet to be authorized for corrective action. Many other states have for some 

time been operating similar corrective action programs under their own authorities. The states 

have no RCRA universe of their own that is not reported to EPA. EPA’s State Authorization 

Tracking System (StATS) tracks the status of each state and territory in establishing and 

maintaining RCRA authorized hazardous waste programs, including corrective action (see 

http://www.epa.gov/epaoswer/hazwaste/state/stats/stats.htm). 

Prior to granting a state or territory full authorization for corrective action, EPA regional offices 

may develop grants and cooperative agreements under RCRA §3011 giving the state the lead for 

corrective action oversight at specific sites. Although authorized state programs must meet the 

minimum federal requirements, a state may adopt regulations that are more stringent than the 

federal requirement. 

Permitting and Enforcement 

Corrective action may be implemented through the RCRA permit process, state or federal 

enforcement orders, or voluntarily. All sites that are required to have RCRA permits, such as 

TSDFs, and those sites where EPA or a state has discretionary authority under RCRA to impose 

corrective action, are subject to corrective action requirements. About 86 percent of RCRA sites 

subject to corrective action are TSDFs. Corrective action may be imposed to clean up on-site 

contamination, offsite contamination, and one-time spills. 

EPA or an authorized state permits all TSDFs to treat, store, or dispose of hazardous waste. 

Section 3004(u) of HSWA, which is directed specifically toward controlling releases from 

SWMUs, is the primary authority requiring corrective action at permitted TSDFs. It compels a 

facility owner or operator to address SWMU releases due to past disposal or recent contamination whenever seeking a RCRA permit. Additional authority is available under §3004(v) of 

HSWA to require a permitted TSDF to clean up contamination beyond the facility boundary. 

Thus, HSWA requires all hazardous waste facilities that obtain a RCRA permit after November 

8, 1984, to take corrective action for any releases from past disposal or recent contamination 

from the facility, including all SWMU and off-site releases. For a TSDF operating under interim 

status rather than a RCRA permit, EPA can invoke HSWA §3008(h), which provides for 

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enforcement orders, or state orders in an authorized state, to address any release of hazardous 

waste. The corrective action process for both permitting and enforcement orders is similar. 

For actual or potential releases not originating from a SWMU, such as a one-time spill from a 

vehicle traveling across a facility, or for releases at RCRA sites with permits that pre-date 

HSWA, EPA may impose its omnibus permitting authority pursuant to HSWA §3005(c)(3). This 

provision allows EPA to modify the facility’s permit as necessary, requiring corrective action for 

any potential threat to human health or the environment. Also, HSWA §7003 gives EPA broad 

authority to seek injunctive relief in the appropriate U.S. District Court or to issue administrative 

corrective action orders for any waste from any source, including SWMUs, where the handling, 

storage, treatment, transportation, or disposal of solid or hazardous waste may pose an imminent 

and substantial danger to public health or the environment. 

To minimize the regulatory burden of RCRA Corrective Action without endangering public 

health or the environment, EPA created exemptions and special permits. For example, EPA 

conditionally exempts from the Subtitle C hazardous waste regulations any waste samples 

collected solely for the purpose of monitoring or testing the characteristics or composition of 

RCRA facility contamination. Referred to as the Treatability Studies Sample Exemption Rule 

(CFR 261.4(e) and (f)), the exemption places limits on the quantity of contaminated media than 

can be shipped, stored at a laboratory or testing facility, and treated there (U.S. EPA 1994b). The 

exemption rule also limits the amount of time the contaminated media may be retained for 

analysis or treatment. Although EPA encourages authorized states to adopt exemptions and 

special permits, the states are not required to adopt them because they are less stringent than 

existing federal requirements. 

Special permits and modifications are available to facilitate the development and application of 

innovative technologies. For example, facility owners or operators may obtain RCRA research, 

development, and demonstration (RD&D) permits for pilot-scale evaluations of treatment technologies. EPA, in collaboration with the state, has the authority to modify a permit or enforcement order to allow on-site technology demonstrations at corrective action sites. In this case, 

EPA may grant a site-specific treatability variance for contaminated soils and debris when the 

facility cannot achieve the stringent technology-based treatment standards in the land disposal 

restrictions. Other permitting options are available through the Subpart X rule of RCRA, titled 

“Miscellaneous Units,” which addresses hazardous waste management units that do not fit the 

current RCRA definition of container, tank, surface impoundment, pile, land treatment unit, 

landfill, incinerator, boiler, industrial furnace, or underground injection well (U.S. EPA 1987). 

For instance, EPA and the Department of Defense have worked together to dispose of munitions 

using the permitting options available for pilot-scale RD&D and the Subpart X rule. 

The remedial action plan (RAP), a special type of RCRA permit, made available in the final 

HWIR-media rule (1998) as an alternative to traditional permits, can be used for the treatment, 

storage, or disposal of waste generated during remediation activities. RAPs can be used for 

cleaning up contaminated areas or areas in close proximity to the contamination, and they may 

be used for cleaning up offsite locations when treating, storing, or disposing of the waste off site 

is more protective than on site. 

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4.2 Factors Affecting Demand for Cleanup

The extent and timing of the cleanup of RCRA Corrective Action sites is significantly influenced 

by the regulatory and site-management refinements that EPA and the states have been building 

into the cleanup process; federal funding of state oversight; and improvements in field technologies that better characterize contamination, improve remedy design, lower overall cleanup 

costs, and improve the quality and pace of site cleanups. These factors create incentives for 

owners and operators in the broader market to consider actual cleanup over containment.

 • The RCRA Cleanup Baseline sites that are striving to meet their 2005 interim GPRA goals 

represent the most immediate actions to be taken at RCRA sites. While these sites represent 

the readily identified, near-term market for cleanup, many other RCRA sites with less 

immediate human health concerns will also need to be cleaned up.

 • Revisions to the Subtitle C requirement for cleaning up some hazardous waste implemented 

over the past decade are likely to encourage treatment and removal as compared to leaving 

waste in place. As described in section 4.1.1, the revisions most likely to impact the market 

include introducing alternative standards for CAMUs, temporary units, and staging piles 

specifically to handle remediation waste that is no longer considered newly-generated 

hazardous waste; defining LDR alternative treatment standards for cleanups; harmonizing 

the sometimes duplicative closure and corrective action requirements; streamlining permit 

requirements for cleanup activities; and removing the obligation for facility-wide corrective 

action. 

Before these changes occurred, the stringent Subtitle C requirement was frequently counterproductive when applied to the cleanup of individual sites because it imposed unnecessary 

costs and delays and limited cleanup options. Even if treating or permanently removing the 

waste was the preferred option, parties sometimes decided not to clean up certain sites or 

sought to leave the waste in place at others. Such actions may lead to increased long-term 

risk of human exposure to contamination and the potential that the contamination will 

spread offsite or to groundwater.

 • The 1999 and 2001 cleanup reforms are intended to increase the number and efficiency of 

cleanups and establish aggressive national cleanup goals. The reforms established more 

flexible, facility-specific approaches to account for the variety of conditions at RCRA sites.

 • Refinements in field technologies and methods used to characterize site contamination and 

its likely movement in the environment and to improve remedy design are changing the 

cleanup market. Refinements in these technologies during the last five to ten years have 

begun to decrease site-assessment costs, improve data quality, and expand the applicability 

of less traditional remedies. For instance, in the past, a semi-permanent well had to be installed to sample groundwater quality and a drill rig was needed to obtain soil borings at depth. 

While these technologies still have their place, newer technologies, such as the hydropunch 

and cone penetrometer, are available at a dramatically lower cost. Also available are geophysical technologies, such as remote sensing, to determine subsurface conditions. Almost 

30 percent of all sites EPA sampled in a study of RCRA Corrective Action implementation 

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used some type of innovative characterization approach (U.S. EPA 2002c). Low-priority 

sites were more likely than medium and high priority sites to employ these approaches. Site 

characterization, conducted at less cost, often results in better designed remedies for particular site conditions, rather than in over-designed remedies intended to account for the many 

unknowns associated with a site.

 • The pace of the cleanups is affected by the availability of funds to pay for state and federal 

oversight. Many states have been facing budget deficits in 2003 and 2004 and, on average, 

state staffing levels and budgets for hazardous waste remediation has not increased in about 

a decade. Section 9.4 (State and Private Party Sites) includes a description of trends in state 

capabilities. 

• Land development trends are also likely to affect the pace and nature of RCRA cleanups. If 

there is demand for the redevelopment or transfer of commercial and industrial properties, 

they will require site assessments and, if necessary, remediation. The 2002 brownfields law, 

titled “The Small Business Liability Relief and Brownfields Revitalization Act (P.L. 

107-118),” the Superfund Redevelopment Program, and the RCRA Brownfields Initiative 

are encouraging the reuse of former industrial and other properties. These programs have 

implemented policy changes and demonstrated many approaches and ideas that foster the 

cleanup and redevelopment of contaminated properties, including a number where waste has 

been left on site. By publicizing the potential for reusing tainted properties, these activities 

may have the impact of increasing the pace of cleanup of corrective action sites. (See 

Section 9.1.2, Voluntary Cleanup and Brownfield Programs). 

4.3 Number and Characteristics of RCRA Sites

All RCRA sites requiring permits and those where EPA or a state has discretionary authority to 

impose corrective action are subject to corrective action requirements. However, not all of these 

sites will actually require corrective action, and until further study is conducted, the number of 

RCRA sites that will require cleanup can only be estimated. Nevertheless, EPA’s RCRAInfo 

electronic database and two previous EPA studies, can be used to estimate the potential extent of 

future cleanups. 

4.3.1 Number of RCRA Sites

As of March 31, 2003, EPA’s RCRAInfo database, a national program management and inventory system on hazardous waste handlers, contained information on 6,677 RCRA sites where 

EPA has discretionary or statutory authority to impose corrective action when necessary (U.S. 

EPA 2003b). Exhibit 4-1 shows the distribution among the states of the RCRA sites subject to 

corrective action. Exhibit 4-2 contains the current numbers of sites in this universe in EPA’s ten 

regions. EPA and the states have identified approximately 29 percent high-priority sites, 24 

percent medium-ranked sites, 29 percent low-ranked sites, and have not ranked 19 percent of the 

sites. A RCRA facility investigation (RFI) has been imposed at 38 percent of the sites subject to 

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corrective action. The RFI involves sampling, modeling, and other testing to determine the 

nature and extent of environmental contamination and to characterize the site’s geological and 

hydrological conditions. A RFI has been imposed at 79 percent of the high-priority sites, 38 

percent of the medium-priority sites, and 20 percent of the low-priority sites. While about 20 

percent of the sites in this universe are implementing stabilization measures, only 10 percent of 

them have selected a remedy. 

Exhibit 4-1. Location of RCRA Sites Subject to Corrective Action 

by State and EPA Region 

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Exhibit 4-2. Priority Ranking of RCRA Sites 

Subject to Corrective Action 

EPA 

Region 

Ranking Total 

Facilities 

High Medium Low Unranked 

1 176 85 43 83 387 

2 188 208 267 23 686 

3 308 46 62 87 503 

4 272 196 151 268 887 

5 355 445 691 486 1,977 

6 236 204 228 114 782 

7 99 146 126 19 390 

8 58 68 126 108 360 

9 140 123 236 45 544 

10 78 46 29 8 161 

Total 1,910 1,567 1,959 1,241 6,677 

Source: U.S. EPA, Office of Solid Waste, RCRAInfo database, March 28, 2003 

A subset of this universe represents 3,829 sites that are required to undergo further site investigation and or cleanup. These sites are most likely to require some sort of remedial action in the 

near term and already may be involved in some phase of corrective action. Approximately eight 

percent of these sites are federal facilities. Exhibit 4-3 shows the distribution among the states of 

the RCRA sites in this universe, which is called the “corrective action workload universe.” Most 

states have fewer than 100 of these sites. 

4.3.2 Types of RCRA Sites 

The type of activities that have occurred at a site may lend insight into the nature of the cleanup 

needed. A TSDF may operate one or more types of hazardous waste management processes. 

Typical management processes include land disposal, such as landfills, land treatment units, 

surface impoundments, waste piles, and underground injection wells; incineration; treatment, 

storage in tanks; and boilers and industrial furnaces. A waste pile is any non-containerized 

accumulation of solid, nonflowing hazardous waste that is used for treatment or storage. The 

definitions of the other processes may be found in 40 CFR §260.10 (U.S. EPA 1980). 

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Exhibit 4-3. Location of RCRA Sites Likely to Require 

Corrective Action by State and EPA Region 

Exhibit 4-4. Major Waste Management

Exhibit 4-4 presents the major processes Processes at RCRA Facilities 

operated now or in the past by RCRA 

facilities in EPA’s RCRAInfo database. 

Because each facility may be performing 

more than one process, the total number 

of processes exceeds the number of 

facilities. Storage and treatment account 

for 72 percent of the processes reported, 

followed by land disposal at 23 percent, 

and incineration at four percent. 

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In one study, EPA’s Technology Innovation Office obtained information on a total of 275 

TSDFs in 1992 and 1993 for the purpose of identifying relationships between site characteristics 

and the use of innovative technologies at RCRA Corrective Action sites (U.S. EPA 1994c). At 

the 214 TSDFs where contamination data were available, halogenated volatile organic 

compounds (VOCs), the most prevalent of all contaminant groups reported, were present at a 

majority of the TSDFs, followed by heavy metals, and nonhalogenated VOCs. Groundwater 

contamination was reported at 82 percent and soil contamination at 61 percent of the 256 TSDFs 

for which media data were available. 

A second study is EPA’s 1993 regulatory impact analysis (RIA), developed to support the 

corrective action rule, Subpart S (U.S. EPA 1993b). EPA analyzed information on a sample of 

79 TSDFs to estimate contamination likely to be present in soil or groundwater at concentration 

levels that would require action. Of the 2,600 facilities, estimated at the time of the 1993 RIA to 

require corrective action, about 80 percent appeared to have significant releases to on-site 

groundwater and 30 percent were likely to have significant off-site groundwater contamination. 

This estimate is close to the 82 percent observed in EPA’s study of 275 TSDFs (U.S. EPA 

1994c). 

Contaminants in groundwater and soil at RCRA facilities were estimated in the RIA. The top ten 

contaminants expected in groundwater at concentrations that were high enough in 1990 to trigger 

concern are, in order of frequency, chromium, benzene, methylene chloride, arsenic, lead, 

tetrachloroethylene, trichloroethylene, naphthalene, 1,1,2-trichloroethane, 1,1-dichloroethylene. 

Based on this data on-site soil contaminant concentrations above EPA action levels are expected 

to occur at about 68 percent of the 2,600 facilities estimated at the time of the study to require 

corrective action. In soil, tetrachloroethylene, trichloroethylene, chromium, and arsenic were 

expected to be at concentration levels above EPA’s 1990 action levels. 

In 1997, EPA developed a snapshot on corrective action implementation nationwide based on a 

statistically representative sample of 84 facilities among 889 corrective action sites that had final 

remedies selected or stabilization measures in place. The site data reflected the universe of 

RCRA facilities subject to corrective action in 1990. EPA surveyed Agency regional and state 

regulators responsible for the selected facilities and received 62 responses. The survey results 

were compiled into the RCRA Corrective Action Implementation Database (RCAID) (U.S. EPA 

2002c). 

The majority of facilities in the extrapolated RCAID universe were manufacturing industries. 

Although spills were estimated to be a major concern at over half of the facilities, landfills, 

surface impoundments, and underground storage tanks also contributed significantly to facility 

contamination. Nearly all of the facilities had both soil and groundwater contamination, and the 

contamination had migrated beyond the facility boundary at about half of the sites. Using the 

extrapolated data, OSW estimated that 84 percent of the facilities with a final remedy and/or 

stabilization measure in place had VOCs, 41 percent had SVOCs, 23 percent had metals, 10 

percent had polychlorinated biphenyls, 5 percent had pesticides, and 20 percent had other types 

of contaminants, such as radionuclides and phenol. 

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Another study of treatment experiences at RCRA corrective actions involved 30 sites identified 

from readily available information sources in 2000 (U.S. EPA 2000a). EPA’s Technology 

Innovation Office, which conducted the study, selected sites that were illustrative of the types of 

cleanups conducted at RCRA corrective actions. They were not necessarily representative of the 

entire universe of RCRA cleanups. The sites, which varied in size and complexity, had 

chlorinated solvents, polycyclic aromatic hydrocarbons (PAHs), benzene, toluene, ethylbenzene, 

and xylenes (BTEX), other VOCs and SVOCs, and petroleum hydrocarbons. 

Information on contaminants and contaminated media at 99 RCRA sites was found in the 

statements of basis completed before 2000 (most were signed before 1995). A statement of basis 

is similar to a Superfund ROD. The number of sites reporting groundwater contamination 

exceeded 70 percent and was similar to the number reporting soil contamination. Nearly 70 

percent of the sites in the database reported VOCs, about 40 percent reported SVOCs (including 

halogenated, nonhalogenated, PAHs, PCBs, phenols, and pesticides), and nearly 50 percent 

reported metals. Dense non-aqueous phase liquids (DNAPLs) were found at 53 sites; the most 

common were 1,1,1-trichloroethane (1,1,1-TCA), 1,1-dichloroethene, tetrachloroethylene and 

(PCE), and 1,1-dichloroethane. 

4.4 Estimated Cleanup Costs

All known estimates of the ultimate cost of the RCRA Corrective Action program are subject to 

uncertainties inherent in predicting the course of a large multi-year program. The types and sizes 

of sites are quite diverse, and detailed data are available on only a sample of sites. The most 

appropriate estimate was prepared in the background work for the proposed amendments to the 

CAMU Rule in 2000 (U.S. EPA 2000b). This estimate is based on the RCAID survey data 

described in Section 4.3.3. EPA surveyed EPA regional and state regulators responsible for the 

selected facilities and received 62 responses. The cleanup cost varied widely from site to site, 

from under $1 million to over $50 million. Over half the facilities had cleanup costs under $5 

million, and 9 percent had costs over $50 million. The data were reported in terms of ranges and 

precise average cost per site was not provided. However, by taking the upper and lower cost 

value of each range, a reasonable approximation of an upper and lower limit of the estimated 

costs were developed. These calculations appear in Exhibit 4-5. 

Based on these estimates, cleanup of the 3,829 sites that are likely to require corrective action 

will cost between $31 billion and $58 billion, with a middle-value of $44 billion, or $11.4 

million per facility. Approximately 41 percent of the total cost will be incurred by nine percent 

of the facilities. These estimated corrective action costs do not include those of the very large 

DOD and DOE facilities, although it may include some smaller ones. 

This estimated average cost per site is about 20 percent lower (in 2003 dollars) than that 

estimated in the 1993 Regulatory Impact Analysis for Subpart S. This difference reflects a 

variety of changes since that RIA, including more efficient site characterization and cleanup 

approaches, the use of risk-based cleanup approaches, and savings due to the CAMU policies 

described in Section 4.1. Over the past few years, implementation of the Corrective Action 

program has shifted toward more flexible, risk-based cleanups and away from the regulatory 

approach modeled 

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in the 1993 RIA. In addition, the near-term costs of the program are likely to be reduced due to 

the program’s emphasis in the short-term on stabilization remedies rather than permanent 

remedies. 

Exhibit 4-5. Estimated RCRA Corrective Action Costs ($Millions) 

Cost Per Site a Total Cost c 

Cost % of Sites Low High No. of Sites b Low High Average 

< 1.0 32 0 1.0 1,225 245 1,225 735

 1 - 5 24 1 5.0 919 919 4,595 2,757

 5 - 10 13 5 10.0 498 2,489 4,978 3,734

 10 - 25 20 10 25.0 766 7,658 19,145 13,402

 25- 50 2 25 50 .0 77 1,915 3,829 2,872

 > 50 9 51 70 .0 345 17,575 24,123 20,849

 Total 100 3,829 30,800 57,895 44,347 

a The lowest ($200,000) and highest ($70 million) values are conservative assumptions 

b Sites likely to require corrective action, from Section 3.4.3. 

c Number of sites multiplied by cost per site 

Source: U.S. EPA, 2000c, Economic Analysis of the Proposed Amendments to the Corrective Action Management 

Unit Rule (Background Document), Office of Solid Waste, August 7, 2000. 

4.5 Market Entry Considerations 

The responsibility for RCRA corrective action at individual sites lies with the owners and 

operators who contract directly with commercial vendors for services. RCRA requires that 

owners and operators be aware of technologies that may be used and those that are subject to 

restrictions or are banned. Although vendors interested in the corrective action market can obtain 

some information about specific sites by querying RCRAInfo on line, they will have to contact 

specific owners or operators to obtain information on an individual facility’s corrective action 

requirements, waste characteristics, and cleanup needs. The RCRAInfo query form is at 

http://www.epa.gov/enviro/html/rcris/rcris_query_java.html. Many state hazardous waste

agencies, and to a lesser degree EPA regional offices, have additional information about the 

corrective action needs of sites in their areas. 

4.6 Remediation Technologies

Remedies selected for a given site may attain media cleanup standards through various combinations of removal, treatment, engineering, and institutional controls. While EPA maintains current 

information on the general characteristics of RCRA sites in the RCRAInfo database, it has not 

compiled information on remedial action decisions at sites undergoing cleanup. 

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Data on technology applications for 186 RCRA facilities are available from an EPA study 

completed in 1994 (U.S. EPA 1994c). Of 133 facilities treating groundwater, pump and treat was 

selected for 116 sites (87 percent) and innovative technologies were selected for nine sites 

(seven percent). The innovative technologies were in-situ bioremediation at four sites, ex-situ 

bioremediation for two sites, and unspecified bioremediation, thermal desorption, and chemical 

treatment for one site 

each. Of 86 sites Exhibit 4-6. Remedies Selected for Soil requiring soil treatment, at 86 RCRA Corrective Action Facilities established technologies 

were selected for 55 sites 

(64 percent), including 

capping and off-site 

disposal at 51 sites, 

incineration for one site, 

and other technologies 

for three sites. 

Innovative technologies, 

such as soil vapor 

extraction (SVE), 

bioremediation, and 

chemical treatment, were 

selected for 31 (39 

percent) of the sites 

requiring soil treatment. 

Of the innovative 

technologies selected for 

contaminated soil, most were likely to be used to remediate halogenated and non-halogenated 

VOCs. Exhibit 4-6 summarizes specific innovative and established technologies applied or likely 

to be applied to soil contamination at the 86 sites requiring soil treatment. 

Another EPA study is available on remedies selected for 30 RCRA Corrective Action sites, 18 of 

which had ongoing cleanups while 12 had completed cleanups (U.S. EPA 2000c). EPA selected 

these sites from information readily available in 2000 on cleanups that had occurred or were 

underway between 1986 and 2000. The selected sites include a wide range of industries, such as 

wood treaters, chemical plants, refineries, paper mills, manufacturing facilities, and waste 

treatment plants, that vary in size, complexity, and contaminants. Seven of these sites selected 

soil vapor extraction—the most frequently used soil cleanup technology. Far less frequently 

selected in-situ technologies were bioremediation of soil and groundwater, bioventing, chemical 

oxidation, permeable reactive barriers, and air sparging. The ex-situ technologies selected 

included pump and treat, bioremediation, and thermal desorption. 

Projected remedies selected for facilities in the RCAID database were based on site characterization data collected in 1992 and 1993 (U.S. EPA 2002c). The final remedy information on 78 

solid waste management units in RCAID showed that pump and treat (15 percent) and cap/cover 

(31 percent) were selected most often. Barrier walls were selected for 13 percent of the units, and 

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soil vapor extraction was selected for nine percent. Pump and treat and cap/cover were also the 

most common stabilization measures taken at many facilities prior to selecting the final remedy. 

Information on final remedies selected for RCRA sites was found in 99 statements of basis. Most 

of the remedy or stabilization decisions reported in these documents were made in the mid1990s. The most frequently selected remedies or stabilization measures for soil were excavation 

with off-site disposal, capping or cover, and in-situ soil vapor extraction. The remedies selected 

most frequently for groundwater were pump and treat and containment wall. 

4.7 References

U.S. EPA (Environmental Protection Agency), 1980. 40 CFR Part 260.10, U.S. Environmental 

Protection Agency, 45 Federal Register, p. 33066, May 19. 

U.S. EPA, 1987. Hazardous Waste Miscellaneous Units, Applicable to Owners and Operators; 

Final Rule, U.S. Environmental Protection Agency, Office of Solid Waste, 52 Federal Register, 

p. 46946, December 10, 1987. 

U.S. EPA, 1990a. Corrective Action for Solid Waste Management Units (SWMUs) at Hazardous 

Waste Management Facilities; Proposed Rule (40 CFR Parts 265, 265, 270, and 217), U.S. 

Environmental Protection Agency, Office of Solid Waste, 55 Federal Register 145, pp. 30798­

30884, July 27, 1990. 

U.S. EPA, 1990b. The Nation’s Hazardous Waste Management Program at a Crossroads: The 

RCRA Implementation Study, U.S. Environmental Protection Agency, Office of Solid Waste and 

Emergency Response, EPA/530-SW-90-069. 

U.S. EPA, 1991. RCRA Stabilization Strategy, U.S. Environmental Protection Agency, Office of 

Solid Waste, October 25, 1991. 

U.S. EPA, 1993a. Corrective Action Management Units and Temporary Units; Corrective Action 

Provisions Under Subtitle C; Final Rule, U.S. Environmental Protection Agency, Office of Solid 

Waste, 58 Federal Register, p. 8658, February 16, 1993. 

U.S. EPA, 1993b. Draft Regulatory Impact Analysis for the Final Rulemaking on Corrective 

Action for Solid Waste Management Units Proposed Methodology for Analysis, U.S. 

Environmental Protection Agency, Office of Solid Waste, March 1993. 

U.S. EPA, 1994a. RCRA Corrective Action Plan (Final), U.S. Environmental Protection Agency, 

Office of Solid Waste, Directive 9902.3-2A, May, 1994. 

U.S. EPA, 1994b. Hazardous Waste Management System: Identification and Listing of 

Hazardous Waste; Treatability Studies Sample Exclusion, Final Rule (40 CFR Part 261), U.S. 

Environmental Protection Agency, Office of Solid Waste, 59 Federal Register 34, p. 8362, 

February 18, 1994. 

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U.S. EPA, 1994c. Draft Analysis of Facility Corrective Action Data, U.S. Environmental 

Protection Agency, Office of Solid Waste and Emergency Response, Technology Innovation 

Office, January 1994. 

U.S. EPA, 1996a. Corrective Action for Releases from Solid Waste Management Units at 

Hazardous Waste Management Facilities; Advanced Notice of Proposed Rulemaking, ANPR, 40 

CFR, U.S. Environmental Protection Agency, Office of Solid Waste, 61 Federal Register 85, pp. 

19431-19464, May 1, 1996. 

U.S. EPA, 1996b. Hazardous Waste Identification Rule; Proposed Rule, U.S. Environmental 

Protection Agency, 61 Federal Register, p. 18780, April 29, 1996. 

U.S. EPA, 1996c. Coordination Between RCRA Corrective Action and Closure and CERCLA 

Site Activities, U.S. Environmental Protection Agency, Office of Solid Waste and Emergency 

Response, September 24, 1996. http://ww.epa.gov/swerffrr/doc/924memo.htm 

U.S. EPA, 1998a. Hazardous Remediation Waste Identification Rule (HWIR-Media) Final Rule, 

40 CFR Parts 260, 261, 264, 265, 268, 270 and 271, U.S. Environmental Protection Agency, 

Office of Solid Waste and Emergency Response, 63 Federal Register 229, p. 65874, November 

30, 1998. 

U.S. EPA, 1998b. Land Disposal Restrictions Phase IV: Final Rule Promulgating Treatment 

Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary 

Materials and Bevill Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion 

of Recycled Wood Preserving Wastewaters, U.S. Environmental Protection Agency, 63 Federal 

Register 100, p.28555-28604, May 26, 1998. 

U.S. EPA, 1998c. Standards Applicable to Owners and Operators of Closed and Closing 

Hazardous Waste Management Facilities: Post-Closure Permit Requirement and Closure 

Process; Final Rule (40 CFR Parts 264, 265, 270, and 271), U.S. Environmental Protection 

Agency, Office of Solid Waste, 63 Federal Register 204, pp. 56710-56714, October 22, 1998. 

U.S. EPA, 1998d. Risk-Based Clean Closure, memorandum, U.S. Environmental Protection 

Agency, Office of Solid Waste, March 16, 1998. 

U.S. EPA, 2000a. Treatment Experiences at RCRA Corrective Actions, U.S. Environmental 

Protection Agency, EPA 542-F-00-020, Office of Solid Waste and Emergency Response, 

December 2000. 

U.S. EPA, 2000b. Economic Analysis of the Proposed Amendments to the Corrective Action 

Management Unit Rule (Background document), Office of Solid Waste, August 7, 2000. 

U.S. EPA, 2001. Transmittal of Guidance on Enforcement Approaches for Expediting RCRA 

Corrective Action, U.S. Environmental Protection Agency, Office of Enforcement and 

Compliance Assurance, January 2, 2001. 

Chapter 4. RCRA Corrective Action Sites Page 4-20 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

U.S. EPA, 2002a. Amendments to the Corrective Action Management Unit Rule, U.S. 

Environmental Protection Agency, Office of Solid Waste, 67 Federal Register 14, p. 2961-3029, 

January 22, 2002. 

U.S. EPA, 2002b. Handbook of Groundwater Protection and Cleanup Policies for RCRA 

Corrective Action for Facilities Subject to Corrective Action Under Subtitle C of the Resource 

Conservation and Recovery Act, U.S. Environmental Protection Agency, Office of Solid Waste 

and Emergency Response, EPA/530/R-01/015, October 17, 2001, 66 Federal Register, pp. 

52762-52763, September 2002. 

U.S. EPA, 2002c. A Study of the Implementation of the RCRA Corrective Action Program, and 

Highlights from A Study of the Implementation of the RCRA Corrective Action Program, 

Environmental Protection Agency, Office of Solid Waste, April 9, 2002. 

U.S. EPA, 2003a. Final Completion of Corrective Action Activities at RCRA Facilities, U.S. 

Environmental Protection Agency, Office of Solid Waste, 68 Federal Register 37, p. 8757, 

February 25, 2003. 

U.S. EPA, 2003b. RCRAInfo electronic database, U.S. Environmental Protection Agency, Office 

of Solid Waste, March 2003. 

U.S. EPA, 2003c. Results-Based Approaches and Tailored Oversight Guidance for Facilities 

Subject to Corrective Action Under Subtitle C of the Resource Conservation and Recovery Act, 

U.S. Environmental Protection Agency, Office of Solid Waste, September 2003. 

Chapter 4. RCRA Corrective Action Sites Page 4-21 
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Chapter 5 

Underground Storage Tank Sites 

Underground storage tanks (USTs) are used by a wide variety of industries, such as petroleum 

and chemical manufacturing and distribution, transportation, agriculture, and government. About 

680,000 active tanks are currently subject to federal regulations. Ninety-six percent of these 

contain petroleum products, including used oil. Less than four percent contain hazardous 

substances. In addition, more than 1.5 million federally regulated USTs have been closed. 

Subtitle I of the Hazardous and Solid Waste 

Amendments to the Resource Conservation 

and Recovery Act (RCRA) was enacted in 

1984 to control and prevent leaks and spills 

from USTs. Subtitle I governs USTs storing 

regulated substances, including gasoline, 

aviation fuel, diesel fuel, other petroleum 

products, and hazardous substances defined 

under the Superfund program. Pursuant to 

Subtitle I, EPA has promulgated regulations 

requiring, among other things, that leaks and 

spills be remediated and future releases be 

prevented. These regulations have compelled 

cleanup activities at many UST sites, 

providing opportunities for the application of 

a variety of remediation technologies. 

Releases of petroleum or hazardous 

substances can result from a spill during tank 

filling operations, leaks in the tank or pipes 

attached to the tank due to corrosion, 

structural failure, or faulty installation. As of 

March 31, 2004, more than 443,000 releases 

from federally regulated USTs had been 

confirmed (U.S. EPA 2004). These releases 

can contaminate soil and groundwater and 

cause fire or explosions. While considerable 

progress has been made in cleaning up 

contamination from underground storage 

tanks during the last decade—more than 

311,000 contaminated sites have been 

cleaned up—many more remain to be 

remediated. 

Highlights 

• Although considerable progress has been made 

in cleaning up UST sites over the past decade, 

it is estimated that 95,000 to 155,000 UST sites 

underground storage tank regulations. 

• 

sites that have not yet been cleaned up plus an 

estimated 60,000-120,000 sites that may have 

future releases over a 10-year period. 

• 

contaminants from tanks may continue beyond 

10 years and tank leakage rates may decline, 

these scenarios are not included in this report 

because of uncertainties in predicting these 

trends. 

• 

billion. This estimate does not include costs 

related to replacing, testing, or upgrading tanks, 

pipes, and related equipment. 

• 

from public and private sources; the failure rate 

of tank systems; cleanup cost savings through 

approaches; and additional site characterization 

and remediation costs that may result from sites 

that are difficult to remediate (e.g., MTBE). 

• 

reported to EPA has been declining. 

future. 

• 

cleaned up. 

• 

less costly to remediate than those of most 

will require cleanup under the RCRA 

This estimate includes 35,000 already identified 

Although new reported releases of 

The cost of these cleanups could reach $12-19 

The year-to-year fluctuations in the number of 

cleanups will depend on the availability of funds 

the growing use of newer site management 

Since 1998, the number of confirmed releases 

Nevertheless, it is expected that there will 

always be some additional releases in the 

UST tank sites account for over 43% of all 

waste sites estimated in this report to be 

The average UST site is typically smaller and 

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5.1 Federal Program Description

The federal regulatory program is implemented by EPA’s Office of Underground Storage Tanks 

(OUST). The federal UST technical requirements and state program approval regulations were 

promulgated in September 1988 and became effective on December 22, 1988 (U. S. EPA 1988). 

These regulations, to a large extent, determine the size of the market for cleanup services. 

The regulations apply to any UST, except those specifically exempted, excluded, or deferred, 

used to store petroleum products or substances defined as hazardous under the Comprehensive 

Environmental Response, Compensation, and Liability Act (CERCLA). The regulations do not 

apply to tanks storing hazardous wastes regulated under Subtitle C of RCRA. An UST is defined 

as any tank that has at least 10 percent of its volume buried below ground, including piping 

connected to the tank. Generally, the requirements for tanks containing chemicals are somewhat 

more stringent than those containing petroleum products. 

The basic federal requirements include:

 • A tank owner must register his or her tank(s) with the state authority by completing a

notification form about the characteristics and contents of the UST.

 • A tank owner must institute a periodic leak detection program to actively seek out releases. 

For tanks installed after December 1988, leak detection requirements become effective at 

the time of installation. For older tanks, the requirements were phased in over time with a 

final completion date of December 1993.

 • A tank owner must maintain records of leak detection activities, corrosion protection system 

inspections, repair and maintenance activities, and closure site assessments.

 • A tank owner must notify the appropriate regulatory authority of all suspected or confirmed 

releases as well as follow-up actions taken or planned. Suspected leaks must be investigated 

immediately to determine if they are real. If evidence of environmental damage is the cause 

for suspicion, it must be reported immediately to the regulatory authority.

 • If a leak or spill is confirmed, tank owners must: (a) take immediate action to stop and 

contain the leak or spill; (b) notify the regulatory authority within 24 hours or other 

reasonable time period specified by the implementing agency; and (c) take action to mitigate 

further damage to people and the environment.

 • All USTs must be protected from corrosion and have devices that prevent spills and

overfills, in accordance with EPA’s upgrade and new tank standards. 

• A tank owner closing an UST must notify the regulatory authority 30 days before permanent 

closure. 

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The following kinds of tanks are currently exempt or excluded from the regulations:

 • Farm and residential tanks holding 1,100 gallons or less of motor fuel used for noncommercial purposes.

 • Tanks storing heating oil for use on the premises.

 • Storage tanks on or above the floor of areas such as basements or tunnels.

 • Septic tanks.

 • Storm-water and waste-water collection systems.

 • Flow-through process tanks.

 • Tanks holding 110 gallons or less.

 • Emergency spill and overflow containment UST system.

 • Certain pipeline facilities, including gathering lines regulated under other federal or state

statutes.

 • Surface impoundments, pits, ponds, or lagoons.

 • Liquid traps or associated gathering lines directly related to oil or gas production and

gathering operations.

 • UST systems holding hazardous substances listed or identified under Subtitle C of RCRA.

 • Any wastewater treatment tank system that is part of a wastewater treatment facility

regulated under Section 401 or 307(b) of the Clean Water Act (CWA).

 • Equipment or machinery that contains regulated substances for operational purposes, such 

as hydraulic lift tanks and electrical equipment tanks.

 • Any UST system that contains a de minimis concentration of regulated substances. 

In addition, certain categories of tanks, known as deferred USTs, are not yet subject to the full 

federal UST regulations. Until EPA decides how to regulate these USTs fully, the only 

regulations that apply are Subpart A (Interim Prohibition) and Subpart F (release, response, and 

corrective action). Examples of deferred tanks include underground, field-constructed, bulk 

storage tanks, and UST systems that contain radioactive wastes. 

Changes in the types of tanks covered by the regulations could significantly impact the potential 

size of the market. However, EPA is not contemplating any such changes at this time. Although 

these categories of tanks are currently excluded from federal regulations, some of them may be 

subject to state regulations. 

EPA designed the UST program to be implemented by the states. Authority to implement the 

program is delegated to states through either the formal process of obtaining state program 

approval (SPA) or a cooperative agreement. Thirty-three states, the District of Columbia, and 

Puerto Rico have all been approved to act in lieu of the federal program. Most of the other states 

operate their own program under their own laws with limited federal oversight. The Act also 

allows for states to have more stringent requirements than that of the federal regulations. For 

example, some states may include home heating oil tanks in their program. EPA supports state 

programs by providing resources from the federal Leaking Underground Storage Tank Fund 

(LUST Trust Fund), grants to states and tribal programs, technical assistance, training, and 

information exchange. 

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5.2 Factors Affecting Demand for Cleanup

The demand for remediation services at contaminated UST sites primarily will be influenced by 

federal regulations, state requirements, and the number of releases occurring at old and new 

tanks. The timing of these cleanups will be influenced by the availability of state and federal 

funds for site assessment and cleanup of UST sites and the pace of economic development. 

5.2.1 General Trends Exhibit 5-1. Backlog of UST Site 

In October 2002, EPA 

established a national goal of 

completing between 18,000 

and 23,000 cleanups each year 

for the fiscal years 2003-2007. 

If EPA is able to meet this 

goal, the backlog of sites 

needing remediation, which 

has remained steady over the 

past decade, will be halved by 

2007. Exhibit 5-1 shows the 

number of sites in the backlog 

since 1991 (U.S. EPA 2003c). 

Cleanups to be Completed 

A number of factors led to an increase in the number of confirmed releases in 1997 and 1998, 

including the implementation of leak detection requirements (which became effective in 1993); 

tank upgrading requirements to prevent spills, overfills, and corrosion (which became effective 

in 1998); and reporting 

requirements. Since 1998, the Exhibit 5-2. Confirmed Releases at UST Sites number of confirmed releases 

has almost steadily declined 

from 29,600 to 12,000 (Exhibit 

5-2). During the last three 

years, they have ranged from 

6,000 to 12,000 and averaged 

9,000. As more tanks come 

into compliance, the number of 

new releases is expected to 

continue to drop. However, it 

is expected that there will 

always be releases in the 

future. Many older tanks still 

exist and many older, as well 

as upgraded tanks, are not in 

full compliance. 

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The failure rate of tank systems is determined by such factors as tank age, material of 

construction, corrosion protection systems in place, and other design and site-specific factors 

such as soil type, weather, and operations and maintenance practices. Because information on 

these factors is limited, estimates of market size are subject to some uncertainty. The following 

observations have been made about some of the factors that influence tank failure rates.

 • While none of the states 

are in full compliance

with EPA’s leak

detection and upgrading

requirements, most of the

tanks that states monitor

had the required leak

prevention and detection

equipment installed as of

September 2003. The

compliance rates were 79

percent for release

prevention and 72 percent

for leak detection. Region

9 had the highest

percentage of operational

compliance with release

prevention requirements

(93%), while Region 3

had the lowest (69%). For

leak detection

requirements, the range

was from 89 percent (Region 9) to 55 percent (Regions 1 and 10). However, there is

variation in the reporting by the states, since some states’ reports are based on more

stringent requirements. (Exhibit 5-3)

Exhibit 5-3. Compliance Status of USTs by Region 

• According to a 2003 GAO report (based on data collected in 2001 and 2002), 29 percent of 

tanks are not operated and maintained properly, thus increasing the chance of leaks and 

posing health risks. In addition, over half of the states are not inspecting all of their tanks at 

the minimum rate of at least once every three years recommended by EPA (U.S. GAO 2001, 

and 2003). This implies that even if the backlog of all known sites is eliminated, there are 

likely to be additional releases at some sites in the future.

 • GAO also estimates that 11 percent (76,000) of the active regulated tanks that states monitor 

and 30 percent of tanks on tribal lands, may not be upgraded (U.S. GAO 2003). Most of 

these tanks are believed to be empty or inactive. States reported to GAO that they generally 

do not discover tank leaks or contamination around tanks until the empty tanks are removed 

from the ground during replacement or closure. Thus, there is a backlog of potentially 

contaminated sites that may be discovered over a period of time as they are replaced or 

removed. 

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• Despite the upgraded equipment, a number of states reported to GAO that upgraded tanks 

leaked. GAO cites that researchers have concluded that tanks with upgraded equipment and 

monitoring systems do not provide complete protection against leaks. However, the extent 

of this problem is unknown. 

5.2.2 State Regulations and Funding Sources 

Some states have promulgated requirements that are more stringent than the federal standards, 

such as a requirement for double-lined tanks, more stringent monitoring procedures, or earlier 

upgrading compliance dates. 

The pace of the cleanups is affected by the availability of funds to pay for cleanups and 

oversight. UST cleanups are primarily financed from three sources:

 • The federal Leaking Underground Storage Tank Fund (LUST Trust Fund). Revenues from 

the fund are derived from a gasoline tax of 0.1 cent per gallon. Appropriations from the fund 

have been about $70-80 million annually.1

 • State tank trust funds or direct appropriations are generally used to assist owners and PRPs 

in paying for cleanups. A number of these are also financed by gasoline taxes. Between 

1999 and 2003, the annual revenues of these funds averaged $1.3 billion and they paid out 

an average of about $1.1 billion annually. 

• PRPs and site owners. 

State Tank Funds 1999-2003 (Billions of Dollars) 

1999 2000 2001 2002 2003 Average 

Revenues 1.38 1.19 1.21 1.34 1.37 1.30 

Approximate amount paid 0.70 1.49 0.68 1.49 1.16 1.10 

Source: Association of State and Territorial Solid and Hazardous Waste Management Officials, State Fund 

Survey Results 2003. 

EPA regulations that limit the liability of lenders for corrective action in many situations help to 

encourage the extension of credit to credit-worthy UST owners. The availability of credit to UST 

owners, especially the many small businesses that operate USTs, is necessary to assist them in 

meeting their obligations to upgrade, maintain, and otherwise comply with RCRA Subtitle I and 

The gasoline tax is scheduled to expire in 2005. The federal LUST Trust Fund helps states oversee corrective 

action and pay for cleanups at UST sites where the owner or operator is unknown, unwilling, or unable to respond, or 

which require emergency action. Most of the money appropriated from the fund goes to states, which use the funds to 

oversee corrective action by responsible parties, to clean up sites where no responsible party can be found, and for 

enforcement and administration. As of the end of 2003, the balance was $2.1 billion. 

Chapter 5: Underground Storage Tank Sites Page 5-6

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

related environmental requirements. Under these regulations, which were promulgated in 1995, 

any person or lending institution that guarantees loans secured by real estate containing an UST 

or UST system may not be liable for the required corrective action, so long as the lender is not 

otherwise engaged in petroleum production, refining, or marketing (U.S. EPA 1995b). 

5.2.3 2002 Brownfields Legislation and EPA’s USTfields Initiative 

The 2002 brownfields law, titled “The Small Business Liability Relief and Brownfields 

Revitalization Act (P.L. 107-118),” and EPA’s USTfields initiative may lead to an increase in 

the total number of UST sites identified as needing cleanup as well as the pace of cleanups. This 

potential increase would result from the increased number of site assessments completed. The 

increased pace of cleanups could result from additional funds made available under the new law. 

As many as 200,000 of the estimated 500,000 brownfield sites across the country are impacted 

by petroleum leaking from USTs, and many of these sites are gas stations that have shut down 

because they could not comply with the 1998 federal UST upgrade requirements (NEMW 2001). 

These properties pose threats to public health and the environment, and pose challenges for the 

redevelopment plans of the communities in which they are located. 

Many UST cleanups are funded using state assurance funds, which usually do not have sufficient 

money to clean up all of the eligible sites in a given year. This scarcity of money has contributed 

to the backlog of over 136,000 sites nationwide that have not completed cleanup. The new 

brownfields law may help address this backlog. This law expands the current EPA Brownfields 

program and for the first time, allows “low-risk” petroleum sites to be eligible for assessment 

and cleanup grant funding under the Brownfields program. Prior to the new law, petroleum 

contamination was not eligible for Brownfields funding. The law authorizes up to 25 percent in 

grant awards annually through 2006 for the assessment and cleanup of brownfields contaminated 

with petroleum. In FY 2003, EPA awarded 103 new Brownfield Petroleum grants totaling $22.3 

million. This new authority builds upon and complements EPA’s USTfields Initiative, which 

addressed “high-priority” petroleum-contaminated properties and awards funds to states, tribes, 

and intertribal consortia. Under the USTfields Initiative, $4.8 million in grants were awarded to 

36 states and three tribes to cleanup properties contaminated from leaking USTs. Although no 

further USTfields grants are planned, the petroleum grants under the Brownfields program 

continues to encourage further site assessments, cleanup, and redevelopment. 

5.2.4 MTBE Contamination and the Remediation Market 

Concerns about methyl tertiary-butyl ether (MTBE) contamination may influence the amount 

and timing of UST cleanups in some states. According to a 2003 survey of 50 states conducted 

by The New England Interstate Water Pollution Control Commission (NEIWPCC 2003), MTBE 

is detected in gasoline releases to groundwater 60 percent of the time, averaged among the states. 

Most states do not intend to open closed sites to look for MTBE or tertiary-butyl alcohol (TBA), 

unless they have reason to suspect a problem. Most states say there are very few cases where 

MTBE is the only concern. Thirty-three states say that MTBE drives cleanup and investigative 

efforts less than 20 percent of the time, or never. BTEX and free-product is the primary 

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remediation driver in these states. In most states, less than 10 percent of the sites have situations 

where BTEX has been successfully remediated but MTBE remains. 

Nevertheless, some states, such as California and New York, indicated that MTBE 

contamination drives remediation at LUST sites more than 80 percent of the time. Connecticut, 

Maryland, Nevada, and New Jersey indicated that MTBE drives remediation more than 60 

percent of the time; Maine and New Hampshire indicated that MTBE drives remediation more 

than 40 percent of the time; and Delaware and Vermont indicated that MTBE drives remediation 

more than 20 percent of the time. 

In this survey, Delaware indicated that the threat of lawsuits is a potential driver for remediation 

at sites where MTBE contamination is present. Illinois indicated that once it adopts new 

legislation to address MTBE contamination, it expects to see an increase in the number of LUST 

remediation cases at sites where MTBE is the only concern. New York indicated that its high 

percentage of sites where MTBE is the only concern is a reflection of the fact that more than 193 

spills have impacted more than 860 private water supply wells, requiring alternate water 

supplies. 

5.2.5 State Performance-Based Environmental Cleanup Programs 

Traditionally, environmental cleanups have been completed using time and materials (T&M) 

reimbursable contracts. Under these T&M cleanups, contractors bill their clients for hours 

worked and the cost of materials. Historically, these types of contracts provide very few 

incentives for contractors to meet any performance standards and conduct the cleanup in a timely 

and cost effective manner. In addition, there is little incentive for contractors to use the best 

technologies or to develop innovative practices. 

Many states are moving toward performance-based cleanup programs to reduce cleanup costs 

and improve accountability for cleanup performance at UST sites. These “Pay For Performance” 

(PFP) contracts include the following basic elements: 1) a firm fixed price; 2) a fixed time limit 

for achieving the environmental goals of the cleanup; 3) cleanup goals specified in terms of 

specific contamination levels detected at specific locations; 4) criteria for system start-up and 

contamination reduction milestone payments, including closure; 5) provisions for the state to 

take additional contamination measurements at its own expense and discretion; and, 6) escape 

clauses specifying conditions under which the contractor can be released from the contract. 

Useful information on the background of pay-for-performance and implementation tools are 

available on the U.S. EPA web site. http://www.epa.gov/swerust1/pfp/

States with experience using both T&M and PFP contracting report that LUST site cleanups are 

being done faster and cheaper at PFP sites. In addition, state officials report a greater use of 

innovative cleanup technologies and more aggressive approaches to cleaning up “hot spots” at 

PFP sites. States also have reported that their paperwork burden is reduced substantially under 

PFP because they no longer monitor the details of a contractor's expenditures. Oklahoma 

estimates that $6,629,000 of unnecessary expenses were incurred prior to obtaining cleanup 

guarantees using its Pay-For-Performance program (Oklahoma, 2001). 

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Contractors who conduct PFP cleanups have the opportunity to realize greater profit under a PFP 

contract than under a T&M contract because the contractor assumes some of the risk of the 

cleanup. PFP frees them to manage their sites more efficiently, lowers paperwork costs, allows 

the contractor to purchase equipment that can be reused on other jobs, and allows the 

government to pay the contractor in a more timely manner. In fact, PFP contractors in pioneering 

states, such as California, Florida, South Carolina, and Oklahoma, are generally doing quite well 

and most are looking for more PFP business. 

The cost savings associated with PFP programs can be leveraged to conduct more cleanups in 

states with PFP programs. In addition, PFP programs encourage the use of innovative 

technologies, which may help drive the market for some newer remediation technologies 

applicable to LUST sites. 

5.3 Number and Location of USTs

The data on the number and status of currently registered USTs are derived from data that EPA 

compiles semi-annually from reports it receives from 56 states and territories. The states compile 

their data from information received from tank owners. Reporting quality varies from state-tostate and has resulted in some under-reporting of the number of tanks subject to the regulations. 

EPA estimates that there is an average of 2.65 tanks per UST site, although this number actually 

varies widely from one site to another. 

5.3.1 Population of UST Sites in the U.S. 

The number of potential corrective actions are related to the population of active and closed 

tanks subject to the federal regulations. EPA reports that as of March 31, 2004, 679,249 active 

tanks and 1,582,638 closed tanks have been registered in the U.S. (U.S. EPA 2003d). Nearly all 

contain petroleum. These sites include marketers who sell gasoline to the public (such as service 

stations and convenience stores) and non-marketers who use tanks solely for their own needs 

(such as fleet service operators and local governments). EPA estimates about 25,000 tanks hold 

hazardous substances covered by the UST regulations. Using EPA’s estimated average of the 

2.65 tanks per site, over 256,000 active sites with USTs are subject to the UST corrective action

regulations. 

In 1988, EPA estimated that there were between 5 and 7 million USTs (U.S. EPA 1988). Taking 

the midpoint of this range implies a total UST population of 6 million, of which 2.2 million 

active and closed USTs are currently subject to the regulations. The remaining 3.8 million tanks 

are exempt from the federal regulations and are not included as part of the market for 

remediation services in this report. Section 5.1 identifies the seven exempt categories of tanks. 

Although the exempt tanks are not quantified in this report, they nevertheless represent a 

potential for cleanup work in selected states where state regulations include some federally 

exempt tanks. 

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5.3.2 Location of Regulated Tanks 

Appendix B lists the number of regulated tank sites by state, as reported to EPA in September 

2003. Texas, California, Florida, New York, North Carolina, Michigan, Illinois, and 

Pennsylvania contain almost 40 percent of all active and closed tanks. The location data should 

be used with caution because a state’s tank population may not be correlated with the number of 

releases, and cleanup program requirements, reporting practices, and data quality vary by state. 

5.3.3 Potential Number of Sites to be Cleaned Up 

By September 2003, 439,385 

confirmed releases were reported 

to EPA. Remedial design or 

remedial action had been initiated 

at 403,558 sites and completed at 

303,120 (Exhibit 5-4). Thus, 

cleanup has not been completed 

at 136,265 sites. Of these, 

cleanup has been initiated at 

100,438 sites and no cleanup 

action has been taken at the 

remaining 35,827 sites. A cleanup 

is considered “initiated” if a state 

or responsible party has evaluated 

the site and initiated one or more 

of the following five types of 

activities: management of 

Exhibit 5-4. UST Site Cleanup Progress 1991-2002 

contaminated soil, removal of 

free-product, management or 

treatment of dissolved petroleum contamination, monitoring of the groundwater or soil being 

remediated by natural attenuation, or the state has determined that no further actions are 

necessary to protect human health or the environment. At this stage, some physical activity (such 

as pumping, soil removal, recovery well installation) has usually begun at a site. Thus, the term 

“cleanup initiated” covers a range of situations. EPA’s data does not indicate the extent of work 

done. Although many of these sites have substantial amounts of work yet to be done, including 

these sites in the market for future cleanup work may overstate somewhat the true market 

potential. Remediation contractors for some of these sites may already have been selected. 

The total number of UST sites to be cleaned up in the future includes the already identified sites 

plus sites that will be reported in the future due to new releases or existing releases that have not 

yet been reported. Exhibit 5-5 displays the estimate of the number of UST sites likely to be 

cleaned up in the future. This exhibit, which uses data as of March 31, 2004, shows that there are 

34,734 already confirmed releases for which cleanup has not begun (EPA 2004). In addition, as 

stated previously, there are likely to be new releases reported due to leaks in the future. The 

number of projected future releases can come from the active tank universe, the inactive 

universe, and unregulated tanks. There are numerous abandoned and empty tanks, many of 

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which are not identified, that may need to be cleaned up. The estimated number of future UST 

site discoveries is based on the annual rate of new releases in recent years and the assumption 

that this rate will continue for 10 years. Although tank releases may continue beyond 10 years, 

and leakage rates may decline, these scenarios are not included because of uncertainties in 

predicting these trends. 

Exhibit 5-5. Estimated Number of UST Sites Needing Remediation 

Reported to EPA 

Through 3/31/04 

Estimated Future 

Releases (2004-2033) a Total b 

(2004-2013) 

Confirmed Releases 443,568 60,000 - 120,000 503,568-563,568 

Cleanups Completed Through 

March 31, 2004 311,125 NA 311,125 

Cleanups Initiated but Not 

Completed as of 3/31/04 c 97,709 NA 97,709 

Releases Reported as of 

3/31/04, but cleanups not 

initiated

 34,734 d NA 34,734 

Future Cleanups Required, but 

not initiated (2004 -2033) 34,734 d 60,000 - 120,000 

94,734-154,734 c 

(Average 124,734) 

Notes: 

NA Not applicable 

a Assumes 6,000-12,000 confirmed releases annually for 10 years, which is the range for 2001, 2002, and 2003. b Although tank releases may continue beyond 10 years, and leakage rates may decline, these scenarios are not 

included because of uncertainties in predicting these trends. 

c Some of these sites may have designated cleanup contractors and some do not, but the number that already 

have contractors is unknown. To allow for a conservative market estimate, it is assumed that they all have 

selected contractors. 

d This figure is derived by subtracting “cleanups initiated” and “cleanups completed” from “confirmed releases.” 

Between 2001 and 2003, the number of confirmed releases ranged from over 6,000 to over 

12,000, with no specific increasing or decreasing trend (although these figures are about half 

what they were in 1998). Based on these figures, it is estimated that an average of 6,000-12,000 

new releases will be reported per year over the next 10 years. Thus, an estimated 94,734-154,734 

sites will need to be remediated over at least 10 years, with a middle value of 124,734.2 

Although the size of the entire market has been estimated, the year-to-year fluctuations in 

cleanup efforts are difficult to predict. The difference between confirmed releases and cleanups 

initiated has averaged over 47,000 for the past four years. Exhibit 5-4 shows the comparison 

between the number of confirmed releases and cleanups initiated each year. During the first half 

of FY 2004, about 8,000 cleanups were completed. However, the year-to-year fluctuations in 

activity would depend upon the factors discussed in Section 5.2, such as the availability of 

private and public funds and real estate development activity. 

6,000-12,000 X 10 years + 34,734 backlog as of March 31, 2004. 

Chapter 5: Underground Storage Tank Sites Page 5-11 

2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

5.4 Estimated Cleanup Costs

Site characterization and cleanup costs vary widely from one site to another and EPA does not 

have a precise average cost per site.3

 Nevertheless, EPA estimates that the average remediation 

cost per site is $125,000. This cost estimate typically includes activities such as site 

investigations, feasibility studies, and treatment or disposal of soil and groundwater. Multiplying 

this average by the number of sites that will need remediation (94,734–154,734), the projected 

total remediation cost is $11.8–19.2 billion (average $15.6 billion). The presence of MTBE or 

other factors that may make remediation more difficult at these sites can boost the remediation 

cost (See section 5.2.3). 

5.5 Market Entry Considerations 

The following factors will be important to the success of vendors operating in the UST 

remediation market. 

• Site work is primarily the responsibility of owners and operators of establishments such as 

retail gasoline stations, petroleum and chemical marketing operations, fleet maintenance and 

auto repair shops, and manufacturing or transportation facilities. 

• Most work is contracted locally. However, some large firms and government agencies will 

use national contractors. Many of the national contractors tend to subcontract to local firms.

 • States also issue contracts to cover large areas over a period of time for work done directly 

by the states.

 • EPA is responsible for administering the program on tribal lands.

 • The level of enforcement activity varies from one state to another. In addition, some states 

regulate tanks that are not regulated under RCRA. Information on these activities generally 

are available through state authorities. An indication of a state’s commitment to its tank 

program can be obtained from its compliance rate with federal tank standards. EPA 

publishes a semi-annual report on its web site which provides the percent of tanks in each 

state that are in significant operational compliance with federal release prevention 

requirements and with leak detection requirements (U.S. EPA 2003c, 2004b).

 • As tank testing and other requirements are implemented, the extent of cleanup activities and 

costs per site probably will decrease. Thus, economical ways to remediate smaller releases 

may be needed. 

Based on a review of literature and data, the University of Tennessee reported that the cost of remediating UST 

sites had varied widely, generally between $2,000 to over $400,000. Costs at individual sites can exceed a million 

dollars (Bueckman & Russell, 1991). If only a small amount of soil needs to be removed or treated, cleanup costs can 

run as low as $10,000. Corrective action for leaks that affect groundwater can cost from $100,000 to over $1 million, 

depending on the extent of contamination. 

Chapter 5: Underground Storage Tank Sites Page 5-12 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

5.6 Remediation Technologies 

Data on the kinds of innovative technologies used to remediate contaminated UST sites have not 

been centralized. However, a survey conducted in 2001 by the University of Massachusetts 

provided information on the use of remediation technologies for contaminated groundwater and 

soils at LUST sites (Kostecki and Nascarella 2001). Thirty five states responded to this 12­

question survey. The questions dealt with the types of technologies used, use of technologies by 

site, changes in technology use over time, barriers to implementation, and the impact of 

monitored natural attenuation. The survey results were compared with similar data collected 

from 45 states in a 1995 University of Massachusetts survey. Comparisons were made based on 

a percentage of total sites for each survey (Exhibit 5-6). 

As the exhibit shows, 

landfilling continued to be the Exhibit 5-6. Types and Frequencies of Soil 

most frequently selected option 

for soil remediation at LUST 

sites (about one-third of the 

sites), although most 

environmentalists agree that it 

is not an ideal option because it 

transfers waste from one site to 

another. The percentage of UST 

sites using landfilling is 

considerably higher than occurs 

at NPL sites. Over the 2000 

through 2002 period, only 23 

percent of NPL sites used 

containment or off-site disposal 

(the data do not provide a 

separate figure for landfilling). 

The next two most commonly 

used treatment technologies, 

soil vapor extraction (SVE) and low-temperature thermal desorption (LTTD), have grown in 

popularity between the 1995 and 2001 surveys. SVE use grew from 9 percent of LUST sites in 

1995 to 18 percent in 2001. This is considerably greater than the SVE usage at NPL sites, where 

SVE was selected for only 8 percent of the sites between 2000 and 2002 (U.S. EPA 2004a). 

Remediation Technologies at LUST Sites 

The use of low-temperature thermal desorption (LTTD) at LUST sites has been growing steadily 

since the early 1990s. In a 1995 study, industry representatives reported that thermal desorption 

was only used on a limited basis in the early 1990s. By 1995 it was used at numerous sites in 

almost every state (Tremblay 1995). The 2001 data indicate that use of LTTD at LUST sites has 

continued to grow from 3 percent of sites in 1995 to 16 percent in 2001. This is considerably 

higher than the usage rates at NPL sites (11 percent of NPL sites between 2000 and 2002 used 

either low- or high-temperature thermal desorption). 

Chapter 5: Underground Storage Tank Sites Page 5-13 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Although monitored natural attenuation (MNA) and biopiles showed great promise for 

remediating soil at LUST sites in the early 1990s, their use declined from 28 to 19 percent and 

from 16 to 3 percent, respectively between 1995 and 2001. The decline in biopile use could be 

attributed to a lack of confidence in the technology while the decline in MNA is attributed to the 

fact that this method of cleanup takes too long and partly to an EPA Office of Solid Waste and 

Emergency Response (OSWER) directive, The Use of Monitored Natural Attenuation at 

Superfund, RCRA Corrective Action, and Underground Storage Tanks Sites. During the same 

period, the use of landfarming increased by 2 percent. It remains as popular in 2001 as it was in 

1985 (Kostecki & Nascarella 2003). 

The 2001 survey results indicate that MNA continues to be the most common option for 

remediating groundwater at LUST sites (Exhibit 5-7). Between 1995 and 2001, MNA use grew 

from 49 to 67 percent of sites while the use of pump and treat declined from 30 to 12 percent. 

The MNA usage rate is substantially higher than that of NPL sites. MNA-only RODs have 

hovered around 20 percent of groundwater RODs between 1999 and 2001, and dropped to only 7 

percent in 2002. Pump and treat, which has been selected at 67 percent of NPL sites between 

1982 and 2002 (U.S. EPA 2004a), has been declining at LUST sites (from 30 percent in 1995 to 

12 percent in 2001). The decline of pump and treat may be attributed to the fact that it takes a 

long time to achieve cleanup 

goals, it has been demonstrated 

to spread contamination in Exhibit 5-7. Type and Frequency of Groundwater 

some cases, and it is expensive 

to operate and maintain. 

In-situ bioremediation and air 

sparging are the other two 

most common technologies 

used at LUST sites (Kostecki 

& Nascarella 2003). 

Bioremediation use at LUST 

sites is significantly lower than 

at NPL sites (9 percent in 2001 

compared to a range of 8 to 36 

percent of NPL sites between 

1997 and 2002). 

The results of the 2001 survey 

indicate that, except for lowtemperature thermal 

desorption, the older soil 

remediation technologies such as SVE and landfarming, are growing in popularity for soil 

remediation, while MNA continues to grow as the technology of choice for groundwater 

remediation. An interesting result of this study is that no new soil- or groundwater-remediation 

technologies has been developed in the past decade, according to respondents in 35 states. 

Remediation Technologies at LUST Sites 

Chapter 5: Underground Storage Tank Sites Page 5-14 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

5.7 References

Bueckman & Russell, 1991. Underground Storage Tanks: Resource Requirements for Corrective 

Action, Bueckman, D. S., S. Kumar, and M. Russell, University of Tennessee, Waste 

Management Research and Education Institute, Knoxville, TN, December 1991. 

Kostecki & Nascarella, 2003. “Lust Cleanup Landscape Changing: Landfilling Still In, Pump 

and Treat on the Way Out,” Kostecki, Paul, and Marc Nascarella, Contaminated Soil Sediment 

and Water, January/February 2003. 

NEMW, 2002. Recycling America’s Gas Stations: The Value and Promise of Revitalizing 

Petroleum Contaminated Properties Northeast-Midwest Institute and National Association of 

Local Government Environment Professionals, 2002. 

NEIWPCC, 2003. A Survey of State Experiences With MTBE and Other Oxygenate 

Contamination at LUST Sites, New England Interstate Water Pollution Control Commission, 

August 2003. 

Oklahoma, 2001. Oklahoma’s Pay-For-Performance Program, Petroleum Storage Tank 

Division, Oklahoma Corporation Commission, April 2001. 

http://www.nga.org/cda/files/OKPAYFORPERF.pdf 

Tremblay et al, 1995. "Innovation Skyrockets at 50,000 LUST Sites," Deborah, L., D. S. Tulis, 

P. Kostecki, and K. Ewald, Soil and Groundwater Cleanup, December 1995. 

U. S. EPA (Environmental Protection Agency), 1988. Technical Requirements and State 

Program Approval; Final Rule, 53 FR No. 185, Office of Underground Storage Tanks, 

September 23, 1988. 

U. S. EPA, 1991. Survey of Underground Storage Tanks, Office of Underground Storage Tanks, 

Spring 1991. 

U. S. EPA. 1992a. TC [Toxicity Characteristic] Study of Contaminated Media and Debris, Draft, 

Office of Underground Storage Tanks, July 1992. 

U.S. EPA, 1992b. Technologies and Options for UST Corrective Actions: Overview and Current 

Practice, EPA/ 542/ R-92/010, Office of Underground Storage Tanks and Technology 

Innovation Office, August 1992. 

U. S. EPA, 1993. An Overview of Underground Storage Tank Remediation Options, EPA 510-F93-029, Office of Underground Storage Tanks, October 1993. 

U. S. EPA, 1995a. How to Evaluate Alternative Cleanup Technologies for UST Sites: A Guide 

for Corrective Action Plan Reviewers, EPA-510-B-95-007, Office of Underground Storage 

Tanks, May 1995. 

Chapter 5: Underground Storage Tank Sites Page 5-15 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

U. S. EPA, 1995b. Underground Storage Tanks: Lender Liability; Final Rule, 40 CFR Parts 280 

and 281, Federal Register, Vol. 60, p. 46692, September 7, 1995. 

U.S. EPA, 1996. Pay for Performance Cleanups, Effectively Managing Underground Storage 

Tank Cleanups, EPA 510-B-96-002, Office of Solid Waste and Emergency Response, June 1996. 

U. S. EPA, 1997. Expedited Site Assessment Tools for USTs: A Guide for Regulators, 

EPA-510-B97-001, Office of Underground Storage Tanks, March 1997. 

U. S. EPA, 1999. The Use of Monitored Natural Attenuation at Superfund, RCRA Corrective 

Action, and Underground Storage Tanks Sites, OSWER Directive 9200.4-17P, Office of Solid 

Waste and Emergency Response, April 21, 1999. 

U.S. EPA, 2000. Underground Storage Tank Program: Regional and State Contacts, EPA 510-

F-00-00, Office of Solid Waste and Emergency Response, January 2000. 

U. S. EPA, 2003a. Cleanup Information Web site (CLU-IN), Office of Solid Waste and 

Emergency Response, (http:// www.cluin.org).

U. S. EPA, 2003b. Office of Underground Storage Tanks web site, Office of Solid Waste and 

Emergency Response. http://www.epa.gov/swerust1

U.S. EPA, 2003c. Semi-Annual Activity Report, Second Half (September 30 2003), Office of 

Underground Storage Tanks. http://www.epa.gov/swerust1/cat/camarchv.htm 

U.S. EPA, 2004a. Treatment Technologies For Site Cleanup: Annual Status Report (Eleventh 

Edition), Office of Solid Waste and Emergency Response, Technology Innovation Office, EPA542-R-03-009, February 2004. http://www.clu-in.org/asr

U.S. EPA, 2004b. Semi-Annual Activity Report, First Half ( March 31, 2004), Office of 

Underground Storage Tanks. http://www.epa.gov/swerust1/cat/camarchv.htm 

U.S. GAO, 2001. Environmental Protection: Improved Inspections in Enforcement Would Better 

Ensure the Safety of Underground Storage Tanks, GAO-01-464, U.S. General Accounting 

Office, Report to Congress, May 2001. 

U.S. GAO, 2002. Environmental Protection: Improved Inspections and Enforcement Would 

Ensure Safer Underground Storage Tanks, GAO-02-712T, U.S. General Accounting Office, 

May 8, 2002. 

U.S. GAO, 2003. Environmental Protection: Recommendations for Improving the Underground 

Storage Tank Program, GAO-03-529T, U.S. General Accounting Office, March 5, 2003. 

Chapter 5: Underground Storage Tank Sites Page 5-16 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Chapter 6 

Demand for Remediation of 

Department of Defense Sites 

The Department of Defense (DOD) has undertaken the task of cleaning up wastes that have 

resulted from numerous industrial, commercial, training, and weapons activities, as well as 

cleaning up closing military bases so that the properties can be transferred to local communities 

for economic revitalization. DOD has estimated that of the approximately 9,000 sites it has 

remaining in the cleanup process or with future preliminary assessment starts planned, almost 

6,400 of these sites have yet to start and/or complete evaluation and more than 2,600 sites have 

remedial design or other remedial action underway or planned for future completion. These sites 

contain hazardous waste contamination involving soil, groundwater, and other media. Typical 

contaminants include petroleum products, solvents, heavy metals, explosives and munitions 

residue, polychlorinated biphenyls (PCBs), and pesticides. 

Over more than two decades, DOD has made 

considerable progress in locating, 

investigating, and cleaning up thousands of 

contaminated sites. DOD has identified more 

than 30,000 sites on over 1,700 installations. 

Of these, over 21,000 sites were cleaned up 

or found to require no further remedial 

action. To address sites in its cleanup 

program, DOD uses a prioritization scheme 

for sequencing work based on the relative 

risk of individual sites. Under this 

management approach, decisions regarding 

such issues as cleanup standards, remedy 

selection, and no further action 

determinations are made site-by-site rather 

than for an entire installation. Decisions on 

these issues are made on a risk management 

approach that considers the relative threat to 

human health and the environment, reasonable anticipated land use, cost-effectiveness, and 

speed of cleanup, and depend on early and meaningful public participation. DOD works with the 

regulatory agencies and other interested parties to streamline and find economies in the 

environmental restoration process. 

Highlights 

• 

remediation process. 

• ill cost $16.4 billion to 

complete cleanup of its active installations, 

BRAC and FUDS sites. 

• for 

Military Munitions Response sites. The full 

scope of MMRP cleanup is still uncertain. 

• ill complete remediation 

of all of its sites up by 2015. 

• 

receiving adequate funding. 

• 

realignments scheduled to begin in FY 2005 

could alter the sequence of the cleanup effort. 

• 

some sites have yet to be determined. 

Approximately 9,000 DOD sites remain in the 

DOD estimates that it w

An additional $16.8 billion is projected 

DOD estimates that it w

Achieving the above goals is contingent upon 

An additional round of base closures and 

The nature and magnitude of contamination at 

To accomplish site characterization and cleanups, DOD needs the services of firms that can 

clean up wastes similar to those found at private sector industrial facilities as well as firms that 

can remediate wastes that are unique to DOD, such as unexploded ordnance (UXO). These 

environmental service firms will have to understand DOD operating procedures and keep abreast 

of the overall direction of its environmental programs. 

Chapter 6: Department of Defense Sites Page 6-1 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

6.1 Program Description

The DOD created the Installation Restoration program (IRP) in 1975 to investigate and 

remediate contaminated sites resulting from past DOD activities. The Comprehensive 

Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), and the 

Resources Conservation and Recovery Act (RCRA) are the primary federal laws that govern the 

identification, investigation, and cleanup of DOD contaminated sites. Congress formally 

established the Defense Environmental Restoration Program (DERP) and its funding mechanism, 

the Defense Environmental Restoration Account (DERA) in 1986. DERP uses the CERCLA 

framework for DOD cleanup. Also during the 1980s, Congress recognized the need to close or 

reduce the size of many installations, and authorized four rounds of base realignment and 

closures (BRAC) in 1988, 1991, 1993, and 1995 (U.S. Congress, 1998). The FY 2002 Defense 

Authorization Act authorized another round of closures for FY 2005. 

DOD installations typically have multiple contaminated sites regulated by CERCLA, RCRA 

corrective action provisions, RCRA underground storage tank (UST) provisions, or all three. 

Through Executive Order 12580, signed in January 1987, the President delegated to the 

Secretary of Defense Presidential CERCLA authorities for investigation and cleanup measures 

for releases of hazardous substances from facilities under the jurisdiction of the Secretary. The 

interface between CERCLA and RCRA authorities is determined by the circumstances at 

specific sites, including factors such as the source and cause of the contamination, the status of 

the installation as either a National Priorities List (NPL) or non-NPL site, and whether the 

installation has or is seeking a RCRA permit to manage hazardous wastes. DOD cleanups must 

also consider the requirements of state laws and the BRAC acts. Partnering efforts allow DOD, 

EPA, and the states to reconcile overlaps and inconsistencies in regulatory requirements to 

ensure the most effective and timely cleanups. A detailed description of their remediation 

programs is included in the Defense Environmental Restoration Program Annual Report to 

Congress (U.S. DOD, 2002a). 

The implementation process for the DOD cleanup program generally follows those of the 

environmental statutes. Although the regulatory framework of CERCLA and RCRA differ in 

many ways, their implementation processes generally parallel one another. Each requires 

assessments and investigations to determine the need for cleanup, and the selection and design of 

appropriate remedies to ensure protection of human health and the environment. However, each 

program has its own nomenclature for the various phases of study, design, and cleanup. 

6.1.1 Installation Restoration Program

DERP is the DOD program for the evaluation and cleanup of past contamination at DOD sites. 

The Deputy Undersecretary of Defense for Installations and Environment or ODUSD (I&E) 

oversees environmental restoration activities, including work conducted at BRAC installations. 

DOD refers to the program for meeting its responsibilities under CERCLA as the IRP. Under 

IRP, DOD cleans up all contaminated sites for which cleanup is required by environmental 

statutes, whether or not the sites are on the NPL. Although policy direction and oversight of IRP 

are the responsibility of the ODUSD (I&E), each individual DOD Component (Army, Navy, Air 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Force, and Defense Logistics Agency) is responsible for program implementation. The Army 

Corps of Engineers (Corps) is the execution agent for all Formerly Used Defense Sites (FUDS) 

as well as for the Defense and State Memorandum of Agreement (DSMOA) program which 

funds states and territories for technical services they provide to support the cleanup of DOD 

facilities. In 2001 DOD established the Military Munitions Response Program (MMRP) to 

manage cleanup of unexploded ordnance (UXO) and waste military munitions (WMM) at areas 

other than operational ranges. The DERP Management Guidance (U.S. DOD, 2001a) defined 

and established the MMRP, laying out specific requirements for the DOD components. 

Each installation works toward completing its environmental restoration requirements by 

developing and maintaining a management action plan (MAP) or a base realignment and closure 

(BRAC) cleanup plan (BCP). A MAP contains information about an active installation’s past 

activities and current status, presents a vision for future site-level requirements, establishes 

schedules, and identifies future funding requirements through completion. A BCP is the 

equivalent document for an installation undergoing base closure and transfer of property to the 

community. Each installation updates its MAP or BCP at least once a year. 

DERP has specified procedures for evaluating sites and procuring cleanup services under the 

IRP that conform to the regulatory requirements of the National Oil and Hazardous Substances 

Contingency Plan (NCP). These procedures cover all the phases of site operations, including 

preliminary assessment (PA), site inspection (SI), remedial investigation/feasibility study 

(RI/FS), remedial design (RD), and remedial action (RA). In most cases, activities related to 

preliminary assessment through remedial design are conducted by different contractors than are 

those related to remedial action. Activities conducted under IRP are classified as follows:

 • Investigation: Analysis to characterize the nature, extent, and risk of releases of hazardous 

substances to the environment and to develop and select cleanup remedy.

 • Interim Action: Early measure to reduce the risk of releases of hazardous substances before 

the initiation of more complicated, comprehensive, and long-term cleanup remedies. For 

example, placing fences around contaminated areas or removing and treating or disposing of 

contaminated soil.

 • Design: Performance specifications or detailed engineering plans and specifications to

construct and implement a final cleanup remedy.

 • Cleanup: Action to construct and implement a final cleanup remedy. 

In selecting and designing remedies at NPL sites, DOD officials coordinate with EPA regional 

officials to ensure that cleanup goals meet regulatory requirements. Most contracting is done by 

installations, either through centralized contracting service centers or directly with the 

installation. Although the DOD Components follow the general procedures specified by DERP, 

each DOD Component procures its own cleanup services. Section 6.5 describes typical 

procurement practices. 

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6.1.2 Base Realignment and Closure (BRAC)

Additional procedures and expedited timetables have been established for the cleanup of bases 

being closed or realigned. These procedures, known as DOD’s Fast Track Cleanup Program, 

have influenced the sequence of work to be conducted. This BRAC cleanup approach balances 

reuse needs and priorities with environmental requirements in prioritizing and sequencing 

cleanup of sites. In the past, most restoration projects included the same overall cleanup time line 

for an entire installation, regardless of the relative threat to human health and the environment 

that individual sites caused. In implementing the relative risk approach, DOD is working with 

EPA, the states, and the public to review the prioritization process. 

A major influence on the selection of projects for remediation is DOD’s effort to speed the 

economic recovery of communities with closed installations. In prioritizing sites and developing 

cleanup plans DOD considers the potential for local job creation and economic development, and 

the accelerated pace of site investigation, evaluation, and cleanup efforts. The key features of the 

program are:

 • A BRAC Cleanup Team (BCT) is established at each installation slated for closure, to

enhance environmental decision-making at the installation. Each BCT includes

representatives from the installation, state environmental regulatory agency, and EPA

Regional Office. These teams have the authority, responsibility, and accountability for

environmental restoration programs at those installations.

 • A BRAC Cleanup Plan (BCP) is prepared for each installation slated for closure and 

updated annually to reflect new information and changing conditions. The BCP serves as a 

comprehensive and consolidated statement of the status of the installation and strategy to 

expedite its cleanup. The BCT is responsible for the preparation of this plan.

 • A Restoration Advisory Board (RAB) is established in communities where interest is 

sufficient to warrant it. RABs are intended to bring together people who reflect diverse 

interests within the community, in order to foster the early and continual flow of information 

between the affected community, the installation, and the state and federal regulatory 

agencies (U.S. DOD, 1994).

 • An Environmental Baseline Survey (EBS) is conducted for each closing installation, as 

mandated the Community Environmental Response Facilitation Act (CERFA), which is an 

amendment to CERCLA. The CERFA requires DOD to identify and document all 

uncontaminated parcels of land and installations undergoing closure. These properties 

quickly can be turned over to communities for economic reuse. 

The BRAC environmental program encompasses more than environmental restoration efforts. 

BRAC environmental funding also addresses closure-related environmental compliance, which 

includes such actions as the removal of USTs, closure of hazardous waste treatment, storage, and 

disposal facilities (TSDFs), radon surveys, and asbestos abatement. 

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6.1.3 The Military Munitions Response Program 

Decades of military training, weapons system testing, and munitions production has resulted in 

the presence of UXO, discarded munitions, and munitions residue on ranges where training and 

testing occurred. In addition, excess, obsolete, and damaged munitions have been disposed of at 

numerous military installations. In 2001 DOD established the Military Munitions Response 

program (MMRP) to manage the cleanup of UXO, waste military munitions (WMM), and 

chemical residues of munitions at areas other than operational ranges. DOD has been addressing 

these issues since the inception of the IRP and will continue to conduct some incidental 

munitions response activities under the IRP. Sites within the MMRP are those where the firing or 

disposal of munitions has occurred during training exercises and were not addressed under the 

IRP. The 2001 Management Guidance for the Defense Environmental Restoration Program 

defines the requirements for the MMRP. The guidance specifies the eligibility, identification, 

characterization, tracking and reporting on munitions response sites that is similar to the IRP, 

including adding the MMRP data in the Restoration Management Information System (RMIS) 

database. 

6.2 Factors Affecting the Demand for Cleanup

The following factors could alter the scope of the cleanup as well as the technologies used:

 • The pace of remediation is subject to change in response to budgetary and political

developments. The entire FY 2003 DOD budget for environmental restoration is

approximately $2.07 billion. Of these funds, $760.6 million, or approximately 37 percent,

represent BRAC funds (U.S. DOD, 2004).

 • The proportion of the environmental restoration budget allocated for cleanup at active 

installations and FUDS continues to increase while study and investigation funding 

decreases. The FY 2003 budget obligated approximately 59 percent of the funds to cleanup 

and 26 percent to studies and investigations. The FY 2005 planned budget estimates that 

approximately 70 percent of the funds will go toward cleanup.

 • Although DOD believes that most sites have been located, new sites continue to be

identified. The recently established MMRP may impact on the number of new sites.

 • DOD classifies all IRP sites in terms of a relative-risk framework, evaluating each site based 

on three factors: the nature and extent of the contaminant, the potential for it to migrate, and 

receptors that could be impacted by the contamination. The resulting evaluation is not an 

estimate of absolute risk or a substitute for a baseline risk or health assessment. It serves as a 

basis for discussing the relative risk of sites with involved stakeholders.

 • In determining the priorities for funding at all sites, DOD generally addresses the worst sites 

first. The projected time line for the remediation of high relative-risk sites is significantly 

shorter than the time lines for medium or low risk sites. As of the end of FY 2002, DOD has 

achieved its goal of reaching remedy in place (RIP) or response complete (RC) status at 50 

percent of its high-relative risk sites. In implementing its priorities, DOD may assign 

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varying levels of priority to different sites on a given installation. This policy may lead to 

acceleration of some projects at a given installation while other projects at the same 

installation are postponed.

 • At closing installations, DOD has been working to complete remediation at all of the current 

BRAC sites by the end of FY 2005. However, the department does not anticipate reaching 

this goal. It does expect to achieve RIP or RC at 83 percent of BRAC IRP sites. In addition, 

for the FY 2005 round of closures the schedule and sequencing of sites may change at the 

affected installations.

 • DOD policy calls for extensive consultation with EPA, state environmental authorities, local 

communities, local planning authorities, and other interested parties in planning and 

implementing its cleanup programs. These requirements may influence the sequence of 

work and types of technologies selected for a site.

 • Changes in regulatory requirements also may affect cleanup goals, technologies used, and

cost.

 • Cleanup requirements at many identified sites are uncertain because the nature and 

magnitude of contamination is only partially known. As DOD continues to characterize the 

contamination problem and accumulate data from site investigations, cleanup needs will 

become more clearly defined. 

6.3 Number and Characteristics of Sites

Site characteristics data presented in this chapter are based on information in the Defense 

Environmental Restoration Program: Annual Report to Congress for Fiscal Year 2003 (U.S. 

DOD, 2004) and an analysis of DOD’s Restoration Management Information System (RMIS), 

which is an important tool DOD uses for program management and oversight. RMIS contains 

data provided by the Components on the status of DOD sites for which they are responsible 

(U.S. DOD, 2001b). This report uses data from two separate tabulations of RMIS data – one 

based on the program status as of September 30, 2003 and one based on the program status as of 

September 30, 2001 (U.S. DOD 2004 and 2002a). The 2003 data are presented only at the total 

program and component levels. The 2001 data provide more detail regarding the types of sites, 

media, and contaminants being addressed by DOD. 

6.3.1 Number and Types of Sites 

As of September 30, 2003, DOD has identified 30,273 sites (including 3,091 sites on FUDS 

properties) located on over 1,700 installations and facilities, that have or had potential hazardous 

waste contamination involving soil, groundwater or other media. This total includes 2,817 

MMRP sites, mostly on FUDS properties (U.S. DOD, 2004). Response actions were completed 

at 21,213 sites (18,584 sites on DOD installations and facilities and 2,629 FUDS). Of the 

remaining 9,060 sites (6,827 DOD sites and 2,233 FUDS sites, including MMRP) 6,396 were 

planning for or in various phases of investigation, and 2,664 are planning for or are in various 

stages of cleanup. The remaining sites also include 1,729 MMRP sites. Exhibit 6-1 shows the 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

status of these sites by component. Exhibit 6-2 shows the breakdown of the 9,060 sites needing 

cleanup by component. The most significant change in number of sites between 2001 and 2003 

is an almost 85 percent increase in the number of identified MMRP sites. 

Exhibit 6-1. Number of DOD Sites by Status 

DOD 

Component 

Sites Identified 

Responses 

Completed a 

Sites Needing Cleanup a 

IRP 

Sites 

MMRP 

Sites 

Total 

Sites 

Cleanup 

Planned 

or Under 

way 

Investigation 

Planned or 

Under way Total 

Army 

Navy 

Air Force 

DLA 

DTRA 

FUDS 

12,266 560 12,826 

4,715 225 4,940 

6,830 261 7,091 

553 0 553 

1 0 1 

3,091 1,771 4,862 

10,927 

3,220 

3,984 

453 

0 

2,629 

398 1,501 1,899 

536 1,184 1,720 

1,089 2,018 3,107 

64 36 100 

1 0 1 

576 1,657 2,233 

TOTAL 27,456 2,817 30,273 21,213 2,664 6,396 9,060 

Notes: 

a Includes MMRP sites

 IRP = Installation Restoration Program; MMRP = Military Munitions Response Program

 DTRA = Defense Threat Reduction Agency

 Source: U.S. DOD, 2004, Defense Environmental Restoration Program, Annual Report to Congress, Fiscal Year 

2003, Spring 2004 

DOD derived the estimates on the types and characteristics of sites in the remainder of this 

chapter from a combination of data in RMIS, and information provided by the DOD Components 

as of September 30, 2001. Although the total number of sites in these tabulations is slightly 

lower than the FY 2003 sites indicated above, they depict typical DOD site characteristics. 

However, because SIs and RI/FSs have not been completed at a number of these sites, these 

estimates, as well as program cost estimates, may be revised either up or down over the next 

several years as more information becomes available. Exhibit 6-3 shows the geographic 

distribution of these sites, and Appendix Exhibit C-1 shows the breakdown by DOD component 

and state. California, with 2,011 sites has the most DOD sites needing cleanup. 

Chapter 6: Department of Defense Sites Page 6-7 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 6-2. Number of DOD Sites 

and Installations Needing Cleanup 

Exhibit 6-3. Location of DOD Sites Needing Cleanup 

Chapter 6: Department of Defense Sites Page 6-8
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DOD categorizes its sites Exhibit 6-4. Most Common Types of DOD into 44 types, which are 

different than the site types 

used to categorize the NPL 

sites in Chapter 3 of this 

report. The DOD system of 

site nomenclature uses 

categories that include both 

activities and physical 

descriptions. Exhibit 6-4 

shows the number of sites 

for each of the 10 most 

common site types that 

need cleanup. These sites 

account for 71 percent of 

all DOD sites needing 

remediation. Although 

some sites may have 

resulted from more than 

one type of activity, each 

site is counted in only one 

category. The definitions 

of all the site types are 

Sites Needing Cleanup 

provided in Appendix 

Exhibit C-2. Appendix Exhibit C-3 details, by DOD Component, the number of each site type 

requiring remediation. 

6.3.2 Contaminated Matrices

Of the 8,974 sites estimated to need cleanup in FY 2001, data that identified the type of matrix 

(contaminated soil, groundwater, surface water, and sediment) were available for 6,119 sites, or 

77 percent. Exhibit 6-5 shows, by DOD Component, the number of sites that contain each type 

of matrix. Sixty three percent of the sites have contaminated groundwater and 77 percent have 

contaminated soil. Contaminated surface water and sediment are associated with only 15 percent 

and 18 percent of the sites, respectively. The totals add to up to more than the number of sites, 

since a site may contain more than one type of contaminated media. 

The relevant media vary from one site type to another (Exhibit 6-6). For example, contaminated 

groundwater was found at 85 percent of fire/crash area sites, but only 42 percent of the storage 

area sites. Likewise, 61 percent of underground storage tank sites had soil contamination, 

compared to 100 percent of pesticide shop sites and 91 percent of storage area sites. However, 

the amount of available data varies from one site type to another. Of the top 10 site types, data 

were available for a low of 9 percent of unexploded ordnance sites to a high of 91 percent of 

surface disposal areas. Appendix Exhibit C-4 provides the matrices associated with all 44 site 

types. 

Chapter 6: Department of Defense Sites Page 6-9 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 6-5. Frequency of Contaminated 

Matrices at DOD Sites Needing Cleanup 

Exhibit 6-6. Frequency of Contaminated Matrices 

by Site Type at DOD Sites Needing Cleanup 

Site Type 

No. of 

Sites 

No. of Sites 

w/Data 

Groundwater Soil Surface 

Water Sediment 

Spill Area 

Landfill 

Und. Storage Tanks 

Other 

Unexploded Munitions/Ord. 

Surface Disposal Area 

Storage Area 

Contaminated Groundwater 

Disposal Pit/ Dry Well 

Fire/Crash 

Training Area 

1,107 874 (79%) 58% 78% 12% 13% 

974 850 (87%) 74% 74% 27% 26% 

840 459 (55%) 80% 61% 5% 7% 

734 121 (16%) 8% 14% 2% 3% 

588 54 (9%) 5% 7% 2% 2% 

563 512 (91%) 53% 82% 16% 22% 

477 417 (87%) 42% 91% 10% 14% 

418 321 (77%) 90% 54% 17% 14% 

414 352 (85%) 54% 64% 13% 18% 

249 208 (84%) 85% 85% 19% 19% 

Notes: The 10 most common site types account for 6,364 or 71% of the 8,974 DOD sites to be remediated as of 

September 30, 2001. Appendix Exhibit C-4 lists the frequency of contaminated matrices for all 44 site types to 

be remediated. 

Source: DOD Office of the Deputy Under Secretary of Defense (Installations & Environment), Restoration Management 

Information System (RMIS), data as of September 2001. 

Chapter 6: Department of Defense Sites Page 6-10 
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6.3.3 Types of Contaminants 

For this study, using available data, the contaminants were grouped into five categories: volatile 

organic compounds (VOCs), semivolatile organic compounds (SVOCs), metals, explosives and 

propellants, and “other.” “Other” primarily includes inorganic elements and compounds such as 

asbestos, arsenic, inorganic cyanides, corrosives, pesticides, and herbicides. Exhibits 6-7 and 6­

8 show the major contaminant groups by matrix and DOD Component. The data used to create 

these exhibits are in Appendix Exhibit C-5. 

The most prevalent contaminant groups in groundwater are VOCs and metals, which appear in 

74 percent and 63 percent of DOD groundwater sites, respectively (Appendix Exhibit C-5). 

However, while metals appear in the majority of sites in all matrices, VOCs are present in only 

45 percent and 49 percent of the soil and surface water sites, respectively. SVOCs and metals 

were more consistent across different media than VOCs. SVOCs were found at between 49 and 

64 percent of the sites, and metals were found at between 63 and 79 percent of the sites. 

Exhibit 6-7. Major Contaminant Groups 

by Matrix at DOD Sites Needing Cleanup 

The most frequently occurring group–metals– is found at 72 percent of all sites with available 

contaminant data, followed by VOCs at 64 percent, and SVOCs at 57 percent. VOCs are found 

at most sites in all the components, except at DLA sites, where VOCs account for only 41 

percent of the sites. These waste groups also are frequently found at sites related to non-defense 

Chapter 6: Department of Defense Sites Page 6-11 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

industrial facilities. In addition, some sites contain contaminants that are found less frequently in 

industry and that present unique problems for selecting remediation approaches. For example, 

over 6 percent of DOD sites contain explosives and some contain low-level radiation. Explosives 

are found at 13 percent of Army sites, but at 1 percent of Navy and Air Force sites. Appendix 

Exhibit C-5 shows a breakdown of these data into the frequencies of the most common 

contaminant groups for each medium and DOD Component. 

Exhibit 6-8. Major Contaminant Groups 

By DOD Component at Sites Needing Cleanup 

The frequency of occurrence of contaminants also varies by site type. Exhibit 6-9 shows the 

relative frequency of occurrence of the major contaminant groups for five of the seven most 

common site types. The “other” site type is not shown nor is the fifth most common site type

 unexploded munitions/ordnance since data for this site type is sparse. Metals and VOCs are 

common to all five site types, although the frequencies vary. For example the occurrence of 

metals ranges from 48 percent of underground storage tanks to 88 percent of landfills. Appendix 

Exhibit C-6 shows contaminant group occurrences for all 44 site types. 

Chapter 6: Department of Defense Sites Page 6-12 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 6-9. Frequency of Major Contaminant Groups 

for the Most Common DOD Site Types Needing Cleanup 

6.4 Estimated Cleanup Costs

DOD annual funding for DERP 

and BRAC combined peaked at 

$2.5 billion in FY 1994. The FY 

2003 funding was $2.1 billion 

and planned expenditures for FY 

2004 are $1.7 billion. BRAC 

accounts for $344 million, or 20 

percent of the planned budget 

(Exhibit 6-10). Between 2000 

and 2005 (estimated), the BRAC 

percentage has ranged from 20 to 

37 percent. However, BRAC 

expenditures may need to 

increase again with the addition 

of installations from the next 

round of BRAC scheduled for 

FY 2005. Also, because the 

environmental issues at a BRAC 

Exhibit 6-10. DOD Cleanup 

Expenditures: FY 2001-2005 

installation require more 

Chapter 6: Department of Defense Sites Page 6-13 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

extensive consideration than active installations, BRAC cost-to-complete estimates are not 

declining at the same rate as the estimates for active installations. 

It should be noted that not all BRAC environmental funds are used for site investigation and 

remediation. They may also be used for other closure-related environmental expenses such as 

environmental compliance and planning. Compliance efforts may include actions such as the 

removal of underground storage tanks, closure of hazardous waste TSDFs, and radon surveys. 

Planning may involve environmental analyses required under NEPA, or decision-making with 

regard to property reuse and redevelopment. On the other hand, BRAC funding is not limited to 

the designated amounts. 

In the past 19 years, DOD has spent approximately $25 billion on environmental restoration 

(U.S. DOD 2004). DOD estimates that, as of September 2003, cost to complete of the 9,060 

active installation, FUDS, and BRAC IRP sites still in progress or with anticipated future 

assessments planned will be approximately $16.4 billion. The cost to complete for the 987 

MMRP sites with investigation or cleanup in progress or where future activity is anticipated is 

estimated to be approximately $16.8 billion. Most of these funds are for sites that have not yet 

begun remedial action, although some are for sites that have already selected remedies. These 

cost-to-completion estimates do not include program management, DTRA, or other 

miscellaneous overhead and support costs. Approximately $1.26 billion of the $16.4 billion IRP 

estimate is designated for investigation and approximately $2.55 billion of the $16.8 billion 

MMRP estimate is designated for investigation. As the MMRP develops, DOD’s MMRP cost-tocomplete estimates may change. 

DOD’s goal is to have remedial action complete at active installations by the end of FY 2014 

and at the end of FY 2005 for most of the BRAC sites from pre-2005 BRAC rounds. Because 

completion dates have not been determined for some FUDS properties, it is more difficult to 

approximate a final cleanup date. With the MMRP still in development, it would be premature to 

deal with cleanup time tables. 

6.5 Market Entry Considerations 

Although policy is determined centrally by the Deputy Under Secretary of Defense (Installations 

and Environment), each service is responsible for investigating and restoring its own sites and 

manages its own efforts to perform this work. Almost all DOD site assessments and remedial 

actions are done by contractors. Generally, there are two groups of contractors: those that work 

on site investigations and assessments and those that do remedial actions. Contractors in the first 

group seldom do the construction work. Vendors seeking markets for innovative technologies 

should take action to ensure that their technologies are considered at the earlier stages of site 

investigation and assessment. For example, even if a vendor is precluded from working on the 

RI/FS of a particular site, he or she may provide information on their technology to the DOD 

officials and contractors working on the RI/FS. References and links to the various DOD offices 

involved in technology development and contracting appear at the end of this report. The 

following is a summary of the practices of each DOD Component. 

Chapter 6: Department of Defense Sites Page 6-14 
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Army 

The Army’s environmental restoration program is managed under the Assistant Secretary of the 

Army (Installations and Environment) (ASA(I&E)) and the Assistant Chief of Staff for 

Installation Management (ACSIM). In addition to managing active installations and BRAC 

environmental restoration programs, the ASA(I&E) and ACSIM oversee the management of the 

FUDS program. Execution of the cleanup is decentralized, with centralized oversight. In both the 

active installations and the BRAC programs, the Army installations are the focal point for 

restoration activity. The installation environmental coordinator manages the day-to-day 

activities, which are executed primarily through the U.S. Army Corps of Engineers (USACE). 

The Corps also implements remediation programs for DLA and the Air Force, and supports EPA, 

other federal agencies, and states in environmental restoration activities. The Army 

Environmental Center (USAEC), a field-operating agency under ACSIM, provides program 

management support and oversight for ACSIM, while the Center for Health Promotion and 

Preventive Medicine plays a key role in providing risk assessment expertise and review of 

decision documents. For additional information on these Army programs as well as details on the 

contracting process, opportunities, and contacts see the links in section 6.7. 

Navy 

The Navy’s environmental restoration program, begins with the Assistant Secretary of the Navy 

(Installations and Environment). Under the Assistant Secretary, the Chief of Naval Operations 

and the Commandant of the Marine Corps rely on a host of internal and external organizations to 

accomplish their DERP goals. The Naval Facilities Engineering Command (NAVFAC) and its 

eight Engineering Field Divisions and Activities (EFD/As) nationwide execute the Navy’s 

restoration program. Remedial project managers (RPMs) are assigned for each installation in 

each of the geographic regions. The RPMs reside at the EFD/As but work closely with the 

installations and the regulators in planning, setting priorities, establishing budgets, and 

coordinating project execution. RPMs and the support staff at the EFD/As manage contracting, 

technical coordination, direction, and execution of the work on a regional basis. Installations 

maintain ultimate responsibility for their respective restoration programs. Detailed information 

and opportunities are available on the NAVFAC web site by command (link in section 6.7). 

The Naval Facilities Engineering Service Center (NFESC) provides the Navy with specialized 

engineering, scientific, and technical products and services. It is the hub for the Navy’s 

innovative environmental remedial technology demonstrations, evaluations, and technology 

information transfer efforts. NFESC encourages vendors and innovators to submit abstracts on 

their environmental technologies for potential application throughout the Navy and DOD. FY 

2001 awards for field application projects totaled approximately $3.7 million. The Navy 

disseminates this information through regular technical seminars and collaborative efforts with 

other agencies and organizations involved in remediation technologies. For additional 

information on NFESC, see the link in section 6.7. 

Air Force 

The Air Force’s environmental restoration program begins with the Assistant Secretary for 

Installations, Environment and Logistics, with a Deputy Assistant for Installations and another 

Deputy Assistant for Environment, Safety, and Occupational Health. The IRP is decentralized 

and executed by the nine Force Major Commands. The Air Force Center for Environmental 

Chapter 6: Department of Defense Sites Page 6-15 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Excellence (AFCEE), headquartered at Brooks Air Force Base, Texas, is a field operating 

agency of the Civil Engineers of the Air Force. It has seven business lines, each with its own 

technical and support staff. AFCEE provides environmental, planning and construction 

management services and products. Small businesses can list themselves with the Air Force 

Small Business Environmental Database (AFSBED) managed by AFCEE. Information from 

AFSBED is available to small and minority businesses, government buyers, and large prime 

contractors who use the database regularly. The AFCEE also lists requests for proposal (RFPs) 

on its web site as well as on the federal government’s general business opportunities site. Air 

Force HQ also has a web site dedicated to contracting procedures and opportunities. For more 

detailed information, see the links in section 6.7. 

6.6 Remediation Technologies

DOD uses a variety of remediation technologies at its hazardous waste sites and actively 

conducts and supports research and demonstrations to meet its environmental restoration needs 

more efficiently and effectively. 

6.6.1 Technologies Used at DOD Sites

EPA’s treatment technologies database details the types of treatment technologies used at DOD 

NPL sites (EPA 2004). Comprehensive data on technology use at other DOD sites are not 

available. The available data from NPL sites may also be indicative of the types of approaches 

that might be needed for non-NPL DOD sites. Exhibit 6-11 lists the types of treatment 

technologies used in 153 source control applications at DOD sites and 164 groundwater projects. 

The most prevalent source control treatment technologies are SVE (31% of applications), in-situ 

bioremediation (15%), ex-situ bioremediation (10%), and ex-situ solidification/stabilization 

(10%).

 DOD groundwater applications fall into three general approaches: monitored natural attenuation 

(40% of applications), pump and treat (33%), and in-situ treatment technologies (27%). The 

most frequently used groundwater treatments were air sparging (44% of in-situ treatment 

applications), in-situ bioremediation (20%), dual-phase extraction (13%), and chemical treatment 

(7%). 

6.6.2 Research, Development and Demonstration

The Department’s efforts predominantly focus on three major areas: 

• Technology transfer, 

• Demonstration and certification of emerging technologies, and 

• Development of new technologies. 

Technology Transfer 

DOD uses the latest communications technologies to disseminate information, including the 

World Wide Web. In addition to DOD’s own web sites, each of the services has at least one site 

dedicated to providing information on cleanup programs and technologies. The Army sites 

Chapter 6: Department of Defense Sites Page 6-16 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

include the U.S. Army Corps of Engineers (USACE) and the U.S. Army Environmental Center 

(USAEC). The Navy sites include the Navy Environmental Leadership Program (NELP) and the 

Naval Facilities Engineering Service Center (NFESC). The Air Force Center for Environmental 

Excellence (AFCEE) is the key site for information on Air Force programs and technologies. 

These sites also provide information and links for innovators and vendors to contact the services 

and potentially become part of the military’s cleanup process. 

Exhibit 6-11. Treatment Technologies Used at DOD Sites 

Remediation Approach Type 

Number 

of 

Projects 

Remediation Approach Type 

Number 

of 

Projects 

Source Control Treatment Technologies In-Situ Groundwater Treatment Technologies 

Bioremediation Ex Situ 16 Air Sparging In Situ 20 

Bioremediation In Situ 23 Bioremediation In Situ 9 

Chemical Treatment Ex Situ 1 Chemical Treatment In Situ 3 

Chemical Treatment In Situ 1 Dual-Phase Extraction In Situ 6 

Dual-Phase Extraction In Situ 1 In-Well Air Stripping In Situ 1 

Flushing In Situ 1 Permeable Reactive Barrier In Situ 3 

Incineration Ex Situ 19 Phytoremediation In Situ 2 

Open Burn/Open 

Detonation 

Ex Situ 2 Thermally Enhanced Recovery In Situ 1 

Physical Separation Ex Situ 5 Total In-Situ Treatment 

Groundwater Technologies 

45 

Phytoremediation Ex Situ 1 

Groundwater Approaches Summary 

Phytoremediation In Situ 1 

Soil Vapor Extraction In Situ 48 

Soil Washing Ex Situ 2 Pump and Treat 54 

Solidification/Stabilization Ex Situ 15 In-Situ Groundwater 45 

Solidification/Stabilization In Situ 3 Monitored Natural Attenuation 65 

Thermal Desorption Ex Situ 11 Total Groundwater 164 

Thermally Enhanced 

Recovery 

In Situ 3 

Total Source Control 

Treatment Technologies 

153 

Source: U.S. EPA, 2003. Annual Status Report Remediation Database, Office of Solid Waste and Emergency 

Response, Technology Innovation Office, http://epa.gov/tio/technologies 

Chapter 6: Department of Defense Sites Page 6-17 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

DOD has been active in facilitating technology transfer among development and demonstration 

programs and technology users. For example, DOD is working with the Federal Remediation 

Technologies Roundtable (FRTR), an interagency organization created to facilitate collaboration 

among federal agencies, such as the Department of Energy (DOE) and EPA, which also have a 

stake in technology development. The FRTR publishes a variety of documents on remediation 

technologies, including tool guides, case studies, and reports which are available on their web 

site. 

Demonstrations and Certification of Emerging Technologies 

The Department has two programs that research and assess technologies, the Strategic 

Environmental Research and Development Program (SERDP) and the Environmental Security 

Technology Certification Program (ESTCP). SERDP is a program in partnership with EPA and 

DOE which focuses on identifying, developing, and implementing environmental restoration 

technologies that minimize or eliminate the environmental impacts of DOD’s activities. ESTCP 

is a program that demonstrates, tests, and validates new technologies. Each program introduces 

several cutting-edge restoration technologies. For example, in FY 2001 DOD supported a system 

that combines soil washing with phytoremediation to clean lead-contaminated soil from small 

arms ranges, and extended a successful pilot biowall treatment trench to clean up 

trichloroethene-contaminated hot spots. 

With the increased attention to munitions cleanup, the Department plans to continue its 

significant investment in advancing the state of munitions response technology. To date, the 

focus has been on technologies related to site characterization. The Department is now planning 

to expand its technology development to address the hardware, methods, and scientific 

understanding to address other aspects of munitions response. In addition to the OSD programs, 

SERDP and ESTCP, that determine areas for technology investment, the Army, as the lead 

service for UXO technology development, is investing in research on improvements to detection 

hardware systems. 

Each of the services also maintains technology development and demonstration programs. The 

Army Environmental Center, the Naval Facilities Engineering Service Center, and the Air Force 

Center for Environmental Excellence are leaders in cleanup technology demonstrations. 

6.7 References

U.S. Congress, 1988, 1990. Base Realignment and Closure Acts of 1988, P.L. 100-526 (BRAC 

88) and 1990, P.L. 101-510 (BRAC 91, 93, and 95). 

http://www.dtic.mil/envirodod/brac/index.html 

U.S. DOD, 1994. Restoration Advisory Board (RAB) Implementation Guidelines, Memorandum 

Deputy Under Secretary of Defense (Environmental Security), U.S. Department of Defense, 

October 13, 1994. 

U.S. DOD, 1999. Relative Risk Site Evaluation, U.S. Department of Defense, Deputy Under 

Secretary of Defense (Installations and Environment), July 1999. 

Chapter 6: Department of Defense Sites Page 6-18 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

U.S. DOD, 2001a. Management Guidance for the Defense Environmental Restoration Program, 

U.S. Department of Defense, Deputy Under Secretary of Defense (Installations and 

Environment), September 2001. http://www.dtic.mil/envirodod/ 

U.S. DOD, 2001b. Restoration Management Information System (RMIS), U.S. Department of 

Defense, Deputy Under Secretary of Defense (Installations and Environment). 

U.S. DOD, 2002a. Defense Environmental Restoration Program: Annual Report to Congress for 

Fiscal Year 2001, U.S. Department of Defense, Deputy Under Secretary of Defense 

(Installations and Environment), Spring 2002. http://www.dtic.mil/envirodod 

U.S. DOD, 2002b. DOD Environmental Technology Program: A Report to Congress for Fiscal 

Year 2001, U.S. Department of Defense, Deputy Under Secretary of Defense (Installations and 

Environment), March 2002. http://63.88.245.60/Derparc_FY01/DERP/indexEight.htm 

U.S. DOD, 2002c. Restoration Management Information System (RMIS) Data Dictionary, U.S. 

Department of Defense, Deputy Under Secretary of Defense (Installations and Environment), 

April 2002. http://www.dtic.mil/envirodod 

U.S. DOD, 2004. Defense Environmental Restoration Program: Annual Report to Congress for 

Fiscal Year 2003, U.S. Department of Defense, Deputy Under Secretary of Defense 

(Installations and Environment), Spring 2004. http://www.dtic.mil/envirodod/ 

U.S. EPA (Environmental Protection Agency), et al, June 2000. Site Remediation Technology 

InfoBase: A Guide to Federal Programs, Information Resources, and Publication on 

Contaminated Site Technologies, 2nd Edition, prepared by the member agencies of the Federal 

Remediation Technologies Roundtable. http://www.frtr.gov

U.S. EPA, et al, December 2001. Federal Remediation Technologies Roundtable: Creating 

Tools for the Hazardous Waste Cleanup Community, prepared by the member agencies of the 

Federal Remediation Technologies Roundtable, December 2001. http://www.frtr.gov

U.S. EPA, et al, April 2002. Remediation Technologies Screening Matrix, 4th Edition, prepared 

by the member agencies of the Federal Remediation Technologies Roundtable. 

http://www.frtr.gov 

U.S. EPA, et al, 2002. Abstracts of Remediation Case Studies, 1995-2002, Volumes 1 - 6, 

prepared by the member agencies of the Federal Remediation Technologies Roundtable. 

http://www.frtr.gov 

U.S. EPA, 2003. Annual Status Report Remediation Database, tabulation done in June 2003, 

Office of Solid Waste and Emergency Response. http://epa.gov/tio/technologies

Chapter 6: Department of Defense Sites Page 6-19 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Related Links: 

DOD documents on environmental cleanup: 

Office of the Secretary of Defense - Cleanup: http://www.dtic.mil/envirodod/ 

Defense Environmental Network & Information System: http://www.denix.osd.mil 

DOD business opportunities: 

Federal registry of business opportunities: http://www.fedbizopps.gov

DOD central contractor registration: http://www.dodbusopps.com/egov/dod.ccr.html

National Environmental Technology Test Sites (NETTS) Program:

http://www.serdp.org/NETTS/

Environmental Security Technology Certification Program: http://www.estcp.org

Army 

US Army Environmental Center: http://www.aec.army.mil

US Army Corps of Engineers: - http://www.usa00.army.mil

USACE Environmental Programs Contracting Opportunities:

http://www.hq.environmental.usace.army.mil/tools

Navy 

Naval Facilities Engineering Service Center: http://www.nfesc.navy.mil

Naval Facilities Engineering Command: http://www.navfac.navy.mil

Naval Environmental Leadership Program (NELP): http://nelp.navy.mil/

Air Force 

Air Force Center for Environmental Excellence: http://www.afcee.brooks.af.mil/ 

Air Force Small Business Environmental Database: http://www.brookssmallbusiness.com/afsbed.htm 

Air Force HQ Contracting: http://www.safaq.hq.af.mil/contracting 

Air Force HQ Environmental Restoration Branch: http://www.il.hq.af.mil/ilevr.html 

Chapter 6: Department of Defense Sites Page 6-20 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Chapter 7: Department of Energy Sites Page 7-1

Chapter 7

Demand for Remediation of

Department of Energy Sites

One of the most serious and costly environmental remediation tasks facing the federal

government is the cleanup and restoration of more than 100 installations and other locations that

are the responsibility of the U.S. Department of Energy (DOE). DOE's "legacy" of

environmental contamination at these sites has resulted from activities related to the

development and production of nuclear weapons and other technologies that began in the 1940s

with the Manhattan Project and continued through the Cold War. Nuclear weapons production

halted in the United States in 1989, initially to correct widespread environmental and safety

problems; later it was stopped indefinitely because of the end of the Cold War (U.S. DOE

1996a). 

DOE properties contain unique radiation

hazards, huge volumes of contaminated

soil and water, and a large number of

contaminated structures ranging from

evaporation ponds to nuclear reactors to

chemical plants used for the extraction of

nuclear materials (U.S. DOE 1996b).

DOE estimates that as of the end of

fiscal year (FY) 2004, the remaining cost

for restoration of its legacy sites would

be $111 billion (U.S. DOE 2004).

Hazardous waste remediation, including

the cleanup of buried waste, soil,

groundwater, surface water, and facility

decontamination and decommissioning

(D&D) account for about one-third of

the total, or about $35 billion. DOE's

most recent estimate for cleaning up its

contaminated sites, under its accelerated

cleanup initiative, aims for the

completion of cleanup at all release sites

by 2035. These costs are significantly

lower than estimates in the FY 2002 and

2003 budgets because of a cost reduction

made possible by management and

organizational reforms within DOE. The

remainder of DOE's environmental management costs are for activities such as waste

management; facility stabilization; nuclear material stabilization, packaging, and transportation;

program planning and management; landlord activities; and technology development.

Highlights

• DOE has estimated that the cost to complete active

remediation of wastes at most of its legacy sites will be

$35 billion, although this figure is probably an

underestimate because it does not include the cost of

addressing contamination problems that currently lack

viable cleanup technologies.

• DOE aims to complete active cleanup at most of its

sites by 2035.

• Five installations account for 73% of expected costs.

• An estimated 40 million cubic meters of soil and 1.7

trillion gallons of groundwater will require remediation.

• Approximately 3,000 surplus DOE facilities await D&D.

• Long-term stewardship will be needed at up to 129

installations and DOE has established the Office of

Legacy Management to address this need.

• In 2002, DOE began a major initiative to accelerate

cleanup of its sites, prioritize risks, improve contracting

practices, and reduce program costs. This initiative will

profoundly affect the scope and scheduling of cleanup

work, and the types of remediation technologies used.

• Achievement of DOE’s cleanup goals is largely

contingent upon receipt of additional funding yet to be

approved by Congress in future years.

• The full extent of the cleanup needed is still uncertain

because the nature and extent of contamination at

some sites have not been characterized and final

remedial action or regulatory decisions have not been

made for many sites still awaiting cleanup.
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

These figures are likely an underestimate of the total DOE cleanup cost because they do not 

include all cleanup activities needed, such as the cost of cleaning up new releases of 

contaminants, remediating facilities that are still in operation, or contamination problems that 

currently lack viable cleanup technologies, such as certain groundwater contamination and 

nuclear test sites. Nor does the current estimate include the costs of monitoring and maintaining 

site remedies over the thousands of years that radioactive hazards will remain. DOE's 

environmental cleanup program offers an enormous opportunity for firms that provide 

remediation services. 

7.1 Program Description

Between the inception of its environmental management program in 1989 and FY 2003, DOE 

has spent over $70 billion on establishing the cleanup program, developing the management and 

remediation approaches to be employed, and cleaning up the less complex sites (U.S. DOE 

2002d, 2003a, and 2004). The program constitutes nearly a third of the Department's budget, and 

remediation and restoration account for about a third of the cleanup program budget. 

Programs to clean up environmental damage resulting from Cold War nuclear weapons 

development are managed by DOE's Office of Environmental Management (EM), established in 

1989. In 2003, DOE established an Office of Legacy Management to focus on the long-term care 

of legacy liabilities of former nuclear weapons production areas following cleanup completion of 

the surface areas at each site. In the 2005 Budget Request to Congress, the Department proposes 

to create the Office of Future Liabilities, which will focus on the cleanup of facilities and 

contaminated media at active sites that fall outside the EM scope. 

Information on the program’s activities are available in the justifications in DOE's budget 

requests to Congress for the fiscal years from 2000 to 2005. Additional background is available 

from DOE's Baseline Environmental Management Report (BEMR), a multi-volume study 

published in 1995 and 1996.1 

EM must ensure that environmental legacies of the Cold War are addressed and resolved in a 

manner that does not impede future national security missions, and that the nation's radioactive 

wastes are disposed of permanently and safely (U.S. DOE Web 2003b). The EM program 

historically has been managed as a loose association of individual field sites (U.S. DOE 2002d). 

EM provides budget and program support to nine Operations/Field Offices, each of which has 

the responsibility for directing cleanup work at one or more sites (U.S. DOE 1998). The offices 

are located in Albuquerque (NM), Chicago (IL), Idaho Falls (ID), Las Vegas (NV), Oakland 

(CA), Oak Ridge (TN), Miamisburg (OH), Rocky Flats (CO), Richland (WA), and Aiken (SC). 

The Field and Operations Offices oversee all activities to assess and clean up inactive hazardous 

and radioactive facilities—such as reactors, laboratories, equipment, buildings, pipelines, waste 

 The BEMR report was a key source of information for the 1996 edition of this study. The BEMR combined an 

analysis of current environmental management data with estimates of the future costs of the EM program. This 

analysis was replaced by the Accelerating Cleanup: Paths to Closure report, which established a baseline schedule 

and cost for each project. The information in Paths to Closure was updated in 1999 and 2000, but no comparably 

detailed information has been published since the introduction of DOE’s Central Internet Database in 2000. 

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treatment systems, and storage tanks—and sites at all DOE installations, as well as at some 

non-DOE locations that have been specified by Congress. 

The Albuquerque, Chicago, Nevada, Oakland, Ohio, Oak Ridge, Rocky Flats, and Small Sites 

Closure Offices are responsible for cleanup, facility decommissioning, and/or waste packaging at 

110 (Fiori & Jones 2000) of DOE's 114 geographic sites. Many of these sites will have no 

continuing DOE presence after closure, except for stewardship activities. DOE presence will 

continue long term at the Idaho and Savannah River Sites and Hanford's Office of River 

Protection and Richland Operations Office, where the mission encompasses remediation of 

contaminated land, disposition of facilities for alternate uses, final decontamination and 

decommissioning, and operational oversight (as landlord) for the facilities and programs. 

Environmental restoration of the DOE complex involves the following activities: 

• Deactivation and decommissioning—decontamination and safe disposition of deactivated

and surplus equipment, buildings, and other facilities;

 • Remedial actions—site characterization to identify the contaminants and physical properties 

at a site, and remediation activities to stabilize, reduce, or remove site contaminants;

 • Long-term surveillance and maintenance (S&M)—monitoring the site to ensure that 

contamination has been successfully addressed and providing maintenance services to 

ensure the long-term integrity of containment remedies or continued effective operation of 

pump-and-treat remedies; and

 • Stabilization of high-risk materials—treatment and/or packaging of highly radioactive

materials.

These restoration activities are described in greater detail in the following subsections. 

7.1.1 Deactivation and Decommissioning of Surplus Facilities 

DOE constructed over 20,000 facilities to support nuclear weapons production and other 

activities. More than 3,800 of them have been declared surplus to date, and approximately 3,000 

await D&D. These facilities have exceeded their design life and no longer serve a mission for 

DOE. Many of them are contaminated with radioactive materials, hazardous chemicals, asbestos, 

and lead, including lead-based paint. Because of the potential for release of radioactive and 

hazardous materials to the environment, these surplus facilities must be monitored, maintained, 

and guarded. Four major types of structures require deactivation and decommissioning–reactor 

facilities, radionuclide separation facilities, fuel and weapons component fabrication facilities, 

and laboratories. 

Deactivation involves actions that render a facility safe and stable until it can be 

decommissioned. It includes processes used to place nuclear materials and chemicals, 

equipment, and operating systems into a low-risk, low-cost and mostly passive condition. 

Decommissioning, which takes place after deactivation, includes surveillance and maintenance, 

decontamination, and/or dismantlement. It involves stabilizing, reducing, or removing 

radioactive and/or other types of contamination, and can consist of dismantling a facility, 

entombing or covering part or all of the facility, or converting a facility for other uses. 

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Based on the FY 2005 DOE Congressional Budget Request (U.S. DOE 2004) the remaining cost 

(remaining life cycle cost) for decontamination and decommissioning at legacy waste sites is 

about $20 billion, as of the end of FY 2004. 

EM typically performs decommissioning under CERCLA as a "non-time-critical removal 

action." In fact, there are few regulatory compliance agreements for D&D at DOE sites. Most 

sites' Federal Facility Agreements deal with waste from weapons production, such as high-level 

waste, transuranics, mixed low-level waste, and contaminated soil and groundwater problems, 

not with contaminated buildings or other structures (U.S. DOE Web 2002). 

7.1.2 Remedial Actions 

Remedial actions involve the containment, treatment, or removal of radioactive and/or hazardous 

materials and pollutants in free product form or in soil, sediment, fractured bedrock, and 

groundwater. An estimated 3 million cubic meters of solid radioactive and hazardous wastes 

have been buried or otherwise released to the subsurface throughout the DOE complex. As a 

result of the release of these materials, an estimated 40 million cubic meters of soil and 1.7 

trillion gallons of groundwater contain contaminants above an action level and will require 

remediation (U.S. DOE 2000). The largest 

contamination challenges are found at the 

Idaho, Oak Ridge, Hanford, Rocky Flats, 

and Savannah River sites (U.S. DOE 

2002e). 

The typical wastes found at DOE sites are 

shown in the text box. Contaminants include 

hazardous metals such as chromium, 

mercury, and lead; radioactive laboratory 

and processing waste; explosive and 

pyrophoric materials; solvents; and 

numerous radionuclides. 

Sources of contaminants include plumes 

emanating from seepage basins, cribs, 

leaking tanks, and landfills; airborne 

releases deposited on the soil surface by 

wind or precipitation; wells used for 

underground injection of wastes; and 

waste-disposal areas with contaminants 

mobilized by precipitation, groundwater, or 

surface water flowing through the site. 

Burial of low-level radioactive waste, 

mercury, lead, spent solvents, explosives, 

and contaminated equipment has resulted in 

large inventories of poorly characterized 

land-stored waste. 

hazardous—containing hazardous constituents 

but no radionuclides; 

mixed—containing both hazardous and 

radioactive materials 

—radioactive waste not classified as 

high-level waste, TRU, or spent nuclear fuel. 

"Low" does not refer to its level of radioactivity 

—mill tailings containing 

very low concentrations of naturally occurring 

alpha-emitting radionuclides in large volumes of 

generally soil-like materials 

—those waste streams for 

which disposal pathways have not been 

identified; 

transuranic (TRU)—containing plutonium, 

americium, and other elements with atomic 

numbers higher than uranium; and 

—defined based on its source rather 

Includes fission products, traces of uranium and 

DOE Waste Types: 

low-level

11e(2) byproducts

"orphan waste"

high-level

than its constituents and their concentrations. 

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DOE considers cleanup at a site "complete" when it meets the following conditions:

 • Deactivation or decommissioning of all facilities listed in the EM program has been

completed, excluding any long-term surveillance and monitoring; 

• All releases to the environment have been cleaned up in accordance with agreed-upon

cleanup standards;

 • Groundwater contamination has been contained, and long-term treatment or monitoring is in 

place;

 • Nuclear material and spent fuel have been stabilized and/or placed in safe long-term storage; 

and 

• Legacy waste (i.e., waste produced by past nuclear weapons production activities, with the 

exception of high-level waste) has been disposed of in an approved manner. 

After closure, many DOE sites will require long-term surveillance and maintenance. 

7.1.3 Long-Term Surveillance and Maintenance

Even after site closure, DOE will maintain a presence at most sites to ensure that the remedy 

remains effective, an important responsibility at sites where contaminants have been reduced or 

contained, but not eliminated. DOE has estimated that up to 129 geographic locations (e.g., 

installations) will require long-term stewardship (U.S. DOE 2001c). Such long-term stewardship 

will be active at the majority of sites with groundwater monitoring and/or treatment, containment 

systems such as covers and subsurface barriers, and passive or active institutional controls. At 

sites released for unrestricted use, stewardship will be passive, involving only maintenance of 

records. The extent of long-term stewardship to be conducted is determined by DOE and other 

stakeholders based on the end state reached at each site. In some cases, the cleanup plan 

addresses an entire geographic site; in other cases, long-term stewardship may occur at a portion 

of a large site long before cleanup of the entire area is completed.2 

The Office of Legacy Management (LM) has responsibility for sites that have been closed and 

no longer support DOE's ongoing national security, energy, and science missions, such as the 

EM closure sites (Pinellas Plant, Weldon Spring), Uranium Mill Tailings Remedial Action 

(UMTRA) sites, and Formerly Utilized Sites Remedial Action Program (FUSRAP) locations 

where remediation is complete. As more sites are successfully remediated and closed, LM will 

manage the land and associated resources as a federal trustee, preserve records and information, 

perform surveillance and maintenance associated with environmental remedies, such as 

long-term pump and treat, and manage post-closure liabilities. 

 DOE also conducts surveillance and maintenance activities during the environmental restoration process. For 

example, S&M activities may be conducted to prevent worker, public, and environmental exposure to potential 

hazards at a site awaiting D&D. For some facilities – particularly reactors and large processing canyons – an initial 

“interim” phase of long-term stewardship is needed after a facility has been stabilized, but where further remedial 

action or D&D is not expected to occur for a significant period of time (U.S. DOE 2001b). 

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7.1.4 Stabilization of High-Risk Materials 

One of the most costly and dangerous components of DOE's cleanup effort—the stabilization of 

high-risk materials—presents a challenge unique in environmental restoration. High-risk 

materials include all highly radioactive wastes stored in tanks, spent nuclear fuel, all special 

nuclear materials, and some transuranic waste. A major cost driver in the EM complex is the 

plan to retrieve, treat, and vitrify waste in the tank farms, which alone is projected to cost $20 

billion (U.S. DOE 2004). Special nuclear materials, primarily plutonium metals and oxides and 

highly enriched uranium, must be stabilized and then packaged for long-term storage. All spent 

nuclear fuel must be treated and/or packaged and placed in dry storage. Some transuranic waste 

must be treated to remove organics before it is packaged for shipment and stored in the Waste 

Isolation Pilot Plant. Additionally, all the structures from which high-risk materials have been 

removed must undergo decontamination and decommissioning (U.S. DOE 2002d). 

7.1.5 Regulatory Requirements and Compliance Agreements 

DOE installations typically have multiple areas of contamination regulated by either CERCLA, 

RCRA Corrective Action provisions, RCRA underground storage tank provisions, or all three. 

DOE also is required to consult with EPA and consider state environmental requirements and the 

needs of all stakeholders in designing and conducting remediations at facilities for which it is 

responsible. The interface between the regulatory authorities is determined by circumstances at 

specific sites, such as the sources and causes of the contamination, whether the installation is an 

NPL site (DOE has 19 currently on the NPL and 2 deleted), whether it is operating under a 

RCRA permit to manage hazardous waste, the anticipated future land use, the interest of nearby 

communities, and state actions and laws. DOE works with all stakeholders at its facilities to 

integrate and reconcile all the requirements and agree on an approach to address the 

environmental problems. The agreements are typically summarized in a compliance agreement, 

which is used for the majority of DOE cleanup work. 

Compliance agreements provide for establishing legally enforceable schedule milestones that 

govern the work to be done and include, but are not limited to, Federal Facility Agreements, 

Interagency Agreements, settlement agreements, consent orders, and compliance orders. The 70 

compliance agreements at DOE sites vary greatly but can be divided into three main types: (1) 

agreements specifically required by CERCLA to address cleanup of federal NPL sites or by 

RCRA to address the management of mixed radioactive and hazardous waste at DOE facilities, 

(2) court-ordered agreements resulting from lawsuits initiated primarily by states, and (3) other 

agreements, including state administrative orders enforcing state hazardous waste management 

laws (U.S. GAO 2002a). 

Compliance agreements are site-specific and are not intended to provide a mechanism for DOE 

to use in prioritizing risks among the various sites. The agreements reflect local DOE and 

community priorities for addressing environmental contamination at individual sites and are not 

designed or developed to consider environmental risk from a DOE-wide perspective. 

The first class of compliance agreements, those specifically required by CERCLA or by RCRA, 

are in effect at all of DOE's major sites. They tend to cover a relatively large number of cleanup 

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activities and include most of the schedule milestones that DOE must meet. By contrast, 

agreements that implement court-ordered settlements exist at only a few DOE sites, tend to focus 

on a specific issue or concern, and have fewer schedule milestones. These agreements are 

typically between DOE and one or more states. The remaining agreements are based on state or 

federal environmental laws and address a variety of needs, such as cleaning up hazardous 

materials spills or remediating groundwater contamination. Some of these agreements may 

specify only a few milestones, while others incorporate detailed schedules and approaches. 

7.1.6 Policy Initiatives: The Top-to-Bottom Review 

Early in 2002, EM completed a critical assessment of its program—the “Top-to-Bottom 

Review.” The Review's major observation was that EM had been oriented toward managing risks 

rather than actually reducing them. Based upon the Review's recommendations, DOE began a 

major initiative to accelerate cleanup of its legacy wastes by at least 30 years, prioritize risks, 

improve its contracting practices, and reduce program costs. Under this initiative, DOE would 

complete cleanup projects at some sites more quickly; revise other cleanup plans, such as 

reclassifying certain wastes to different risk categories to speed cleanup and reduce cost; and 

concentrate funding more on cleanup and less on maintenance and non-cleanup activities (U.S. 

GAO 2002b). 

DOE expects this initiative to profoundly affect the scope and scheduling of its cleanups. As of 

mid-2004, DOE has signed letters of intent with state and federal regulators that outline an 

agreement in principle to accelerate cleanup at Amchitka Island (AK), Hanford (WA), Idaho 

National Engineering Laboratories (ID), Oak Ridge Reservation (TN), Nevada Test Site (NV), 

Paducah (KY), Pantex (TX), Pinellas (FL), and Savannah River (SC). Increased funding has 

been approved for this purpose. Of the remaining sites, some will not be able to accelerate the 

cleanup schedule, either for technical reasons or because closure is already near term. 

Under the initiative, DOE is promoting a new "risk-based" cleanup strategy that would assist in 

prioritizing risk—and thereby prioritize cleanups—among the various sites on a DOE-wide 

basis. If implemented, this approach could alter the funding balance among DOE sites. 

The initiative also has the potential to increase the use of remediation approaches that leave more 

wastes on site than previously planned, thereby reducing remediation costs at some projects. For 

example, one proposal is to change the current practice of classifying waste as high level, based 

on the treatment process that created it, to classifying the waste based on its actual composition. 

This change would result in the reclassification of much of DOE's high-level waste into 

low-level mixed or transuranic waste, which would significantly affect the cost of treatment and 

packaging and disposition. 

7.2 Factors Affecting Demand for Cleanup 

The nature, extent, and timing of the DOE cleanups is determined by the annual budget provided 

by Congress, DOE policy and resource allocation, the types of waste and contaminated media at 

DOE properties, compliance agreements with states and other stakeholders, and the provisions of 

CERCLA, RCRA, and other federal and state environmental statutes. 

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• DOE expects its accelerated site cleanup initiative (Section 7.1.6) to profoundly affect the 

scope and scheduling of its cleanups. DOE has signed letters of intent with a number of state 

and federal regulators, and is prioritizing risks, improving its contracting practices, and 

implementing other measures to reduce program costs and accelerate cleanups. These 

measures may lead to the reclassification of some waste to a different risk category and 

concentrate funding more on cleanup and less on maintenance and non-cleanup activities.

 • Under the initiative, DOE is promoting a "risk-based" cleanup strategy that would assist in 

prioritizing risk among the various sites on a DOE-wide basis. In addition, it is likely to 

affect the types of remedies selected, such as increasing the use of remediation approaches 

that leave more wastes on site than previously planned.

 • DOE may need to renegotiate and modify compliance agreements to implement many 

aspects of the new initiatives. Federal facility compliance agreements as well as 

environmental laws and regulations drive DOE's cleanup decisions. The effect of 

compliance agreements on certain aspects of DOE's initiative, especially its proposal to 

reclassify waste into different risk categories to increase disposal options, is unclear. 

Reclassifying the waste may involve the concurrence of the Nuclear Regulatory 

Commission, EPA, and other regulatory agencies. Securing the concurrence of all parties, 

plus potential legal challenges by stakeholders, can delay or alter cleanup decisions.

 • Cleanup schedules are heavily dependent upon the availability of funds. DOE's estimate that 

it can complete remediation of legacy wastes at all DOE properties by 2035 could be 

lengthened or shortened, depending on the funds appropriated by Congress. A lack of funds 

could limit DOE's ability to meet milestones of some existing compliance agreements 

between DOE and other stakeholders, as well as limit DOE's ability to commit to new 

agreements. In 2002, Congress increased the EM appropriation by $800 million (in a special 

Cleanup Reform Account) to help DOE meet its 2035 cleanup completion goal. 

Achievement of the accelerated cleanup goals is largely contingent upon receipt of 

additional funding, yet to be approved by Congress, in future years (U.S. DOE 2003b). If 

milestones cannot be achieved because of budget shortfalls, stakeholders may renegotiate 

compliance plans.

 • The type and extent of remediation to be undertaken will be affected by the cleanup 

standards/end states that are to be applied. At many sites, it is difficult to define the extent of 

cleanup work needed. The decision usually requires balancing potential land uses with the 

feasibility of alternative cleanup and long-term stewardship approaches. DOE determines 

end-state goals for a site only after consulting with the regulatory agencies, state and local 

authorities, and other affected parties. Communities must address how the land is to be used, 

and regulators must determine an acceptable level of residual contamination. 

• Current site assumptions about planned end states do not rule out future decisions to change 

the target end state from that envisioned under those assumptions. The ultimate end state of 

a site may be revised due to the development of new technologies, more economical cleanup 

approaches, the availability of additional resources, and changes in the cleanup agreements. 

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• Uncertainty about the nature and extent of contamination at some sites contributes to the 

difficulty in defining the extent of cleanup work needed. Though nearly all of the release 

sites have been at least partially characterized, final remedial action and/or regulatory 

decisions have not been made for most sites still awaiting cleanup. In estimating the 

environmental liability related to each site, DOE used site-specific assumptions regarding 

the amount and type of contamination and remediation technologies that will be employed 

(U.S. DOE 2003b). 

• DOE assumes only existing (baseline) technologies, such as groundwater pump and treat, to 

be available for estimating cleanup costs where they are applicable. Estimates are based on 

remedies considered technically and environmentally reasonable and achievable. Estimated 

cleanup costs at sites for which there is no current feasible remediation approach are 

excluded from the baseline estimates, though applicable stewardship and monitoring costs 

for these sites are included. The cost estimate would be higher if some remediation were 

assumed for these areas; however, absent effective remedial technologies for the sites, no 

basis for estimating costs is available. Significant areas for which cleanup costs are excluded 

include the nuclear explosion test grounds at the Nevada Test Site; large surface water 

bodies, including the Clinch and Columbia rivers; and contaminated groundwater for which, 

even with treatment, future use will remain restricted (U.S. DOE 2003b). 

• The program scope may increase in the future due to the transfer of additional facilities 

and/or sites, further affecting the uncertainty of out-year work scope and schedules. For 

example, DOE sought and received funding and authority from Congress in 2001 to 

remediate a uranium mill tailings site at the former Atlas mill near Moab, Utah. The cleanup 

will be conducted under the Uranium Mill Tailings Radiation Control Act of 1978, which is 

the same authority used for the 22 sites that were remediated in the DOE UMTRA Project. 

These factors indicate that there are many uncertainties inherent in the remediation of the 

facilities for which DOE is responsible, despite significant efforts in recent years to establish the 

scope of work for DOE's environmental management program. The work scope projections 

address long periods of time, which compounds the uncertainty. 

7.3 Number and Characteristics of Sites 

EM historically has been responsible for environmental restoration at 134 "geographic sites," 

which are distinct locations that generated waste or were contaminated by DOE or predecessor 

agency activities. Geographic sites range in size from as small as a football field to larger than 

the state of Rhode Island, and usually correspond to a DOE installation or campus, such as the 

Hanford Reservation in Washington or Oak Ridge Reservation in Tennessee. Altogether, they 

encompass an area of over two million acres—equal to the size of Rhode Island and Delaware 

combined. At the beginning of 1998, cleanup responsibility for 21 sites managed by EM under 

FUSRAP was transferred to the U.S. Army Corps of Engineers, leaving 113 geographic sites in 

the EM program (Applegate & Dycus 1998). The addition in 2001 of the former Atlas uranium 

mill site brought the number to 114 geographic sites located in 31 states and one territory (U.S. 

DOE 2000). 

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DOE uses the term "release site" to mean a specific area where contaminants may have been 

spilled, disposed of, or abandoned at an installation. A geographic site can contain many release 

sites, or it may contain none at all; for example, the contaminated areas at the General Electric 

site (CA) consist of a hot cell and a glove box enclosure. According to DOE's 2003 budget 

request to Congress, of the 10,5273

 release sites identified so far, 5,227 of them were cleaned up 

by the end of 2002. Completion of active cleanup signifies that mobilization to remove or treat 

contaminated soil, debris, and structures has ended. It does not necessarily signify that the site 

has been completely cleaned up. Groundwater cleanup, which could take decades, might yet 

remain to be accomplished. 

Despite the complexity and size of the challenge, substantial progress has been made in cleaning 

up many sites over the past decade. For example, DOE's UMTRA project successfully concluded 

surface cleanup with the remediation of the 22nd and final uranium mill tailings site at Maybell, 

Colorado, in 1998; a second phase of the project aims to achieve groundwater compliance at the 

sites. At the beginning of FY 2003, DOE had completed active cleanup at 76 of the 114 

geographic sites. Extensive work remains to be completed at some of the 38 remaining locations, 

particularly at the Hanford facility and the Savannah River Site. 

DOE plans to complete cleanup at an additional 13 geographic sites by the end of FY 2006. At 

the sites remaining after 2006, which includes the largest ones, DOE will continue treatment of 

the remaining legacy waste streams and management of legacy nuclear materials, including 

nuclear material stabilization and disposition. To protect human health and the environment, the 

Department will implement long-term stewardship activities after active cleanup is completed at 

the sites. DOE expects to complete most high-risk work by 2012 and all currently defined work 

by 2035 (U.S. DOE 2003b). 

Exhibit 7-1 shows the major DOE installations where cleanup of release sites and/or facilities 

has not been completed.4

 The locations that have only wastes to package, with no release sites or 

facilities to remediate, do not appear in the exhibit. About half of the release sites have been 

cleaned up, and roughly 905 of the remaining sites are expected to have cleanup completed by 

2015, 250 more by 2025, and the remaining 3,135 by 2035. Estimates for several hundred release 

sites are not available. The Nevada Test Sites and the Hanford facility (including the Office of 

River Protection) account for 59 percent of the release sites remaining to be remediated. Other 

installations with large numbers of release sites include Los Alamos National Laboratory (795 

sites), the Oak Ridge Reservation (374 sites), and the Savannah River Site (198 sites). 

3 DOE estimates of the number of release sites discovered to date vary: the number is reported as 9,995, 10,527, 

10,082, and 10,374 in the 2002, 2003, 2004, and 2005 budget requests, respectively. 

4 The numbers of release sites shown in Exhibit 7-1 are slightly lower than reported above because specific data 

for the "Other" category were not available. 

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Exhibit 7-1. Remaining Release Sites and D&D Facilities by Location 

Installation 

No. of 

Release 

Sites 

No. of 

Facili 

ties 

Sites 

Completed by 

2004 

Facilities 

Completed 

by 2004 

Release 

Sites 

Remaining 

Facilities 

Remaining 

Estimated 

Completion Date 

Lab for Energy-Rel. Health Res. 17 1 17 1 0 0 2005 

Ashtabula Env. Mgmt. Proj., OH 3 32 0 21 3 11 2006 

Columbus Env. Mgmt. Proj., OH 2 15 1 14 1 1 2006 

Fernald Env. Mgmt. Proj., OH 6 30 2 24 4 6 2006 

Kansas City Plant 43 0 42 0 1 0 2006 

Lawrence Berkeley Natl. Lab 181 0 166 0 15 0 2006 

Lawrence Livermore Natl. Lab 120 0 112 0 8 0 2006 

Mound/Miamisburg Mgmt. Proj., OH 178 135 121 96 57 39 2006 

Rocky Flats Env. Tech. Center, CO 240 377 205 269 35 108 2006 

Sandia National Labs 263 1 192 1 71 0 2006 

Stanford Linear Accelerator Ctr. 20 0 19 0 1 0 2006 

Energy Technology Eng. Center 10 26 7 23 3 3 2007 

Brookhaven National Lab, NY 76 10 68 4 8 6 2008 

Lawrence Livermore Site 300 73 0 65 0 8 0 2008 

Pantex Plant 237 5 76 1 161 4 2008 

Argonne National Lab, East 443 78 443 63 0 15 2009 

Atlas Site (Moab) 1 0 0 0 1 0 2011 

West Valley Demo. Proj., OH 1 0 0 0 1 0 2012 

General Electric Vallecitos 0 1 0 0 0 1 2014 

Separations Process Research Unit 6 4 0 0 6 4 2014 

Los Alamos National Lab 2,124 1 1,329 0 795 1 2015 

Oak Ridge Reservation, TN 654 248 280 114 374 134 2015 

Portsmouth GDP, OH 163 0 149 0 14 0 2025 

Savannah River Site 515 837 317 56 198 781 2025 

Nevada Test Site & Off-Sites 2,082 0 762 0 1,320 0 2027 

Paducah GDP, KY 237 2 87 0 150 2 2030 

Hanford Site 1,618 1,382 302 173 1,316 1,209 2035 

Idaho Nat. Eng. & Env. Lab 270 365 145 77 125 288 2035 

Office of River Protection (Hanford) 322 148 5 0 317 148 2035 

Total 9,905 3,698 4,912 937 4,993 2,761 

Notes: 

• Completed sites are not listed, nor sites where closure is near term or the work involves only waste packaging 

and/or disposal: e.g., Argonne National Lab - West; General Atomics, CA; Salmon Site, MS; South Valley 

Superfund Site, NM; Princeton Plasma Physics Lab, NJ; Amchitka Island, AK; and the Inhalation Toxicology 

Lab, NM. 

• The number of release sites in this table will be slightly different from that reported in other sources because 

specific data for the "Other" category were not available, and because of rounding. 

Source: Department of Energy, FY 2005 Budget Request to Congress, Environmental Management. 

Despite the size of the DOE complex, most of this land is uncontaminated. Less than 15 percent 

of the land at the five major sites (Hanford, Savannah River, the Idaho National Engineering and 

Environmental Laboratory, Rocky Flats, and the Oak Ridge Reservation) is contaminated. 

However, the contamination that does exist presents extraordinary technical challenges because 

of the presence of radionuclides (Probst 2000). 

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Contaminants of concern across the complex generally include radionuclides, metals, and dense 

non-aqueous phase liquids (DNAPLs). More specifically, key contaminants fall into the 

following groupings (U.S. DOE 2002c).

 • Radionuclides: plutonium, strontium-90, cesium-137, isotopes of uranium, tritium, thorium, 

technetium-99, radium, and iodine-129.

 • Metals: lead, chromium VI, mercury, zinc, beryllium, arsenic, cadmium, and copper.

 • DNAPLs: carbon tetrachloride, trichloroethene, dichloroethene, tetrachloroethene,

chloroform, dichloromethane, and polychlorinated biphenyls.

7.4 Estimated Cleanup Costs 

DOE has estimated the cost to complete cleanup at all sites that are currently in its program. 

However, because of uncertainties that DOE has recognized, these estimates are based on a 

number of critical assumptions, and revisions to these assumptions could raise or lower the 

probable cost. This section presents the cost estimate and describes the critical assumptions. 

7.4.1 Life Cycle Costs 

DOE estimates that, as of the end of FY 2004, it will cost about $111 billion to complete the 

cleanup of the remaining legacy release sites currently in EM's program, and that it will complete 

active cleanup at most of its release sites by 2035 (U.S. DOE 2004).5

 About $35 billion of this 

total is anticipated to be for remediation. Environmental management funds not spent for site 

remediation are used for national program planning and management, landlord activities, waste 

management, facility stabilization, technology development, and nuclear material stabilization, 

packaging, and transportation. 

The estimate relies on several critical assumptions. It does not include all cleanup activities 

needed, and hence is likely to underestimate the ultimate total cost of cleanup. DOE has yet to 

determine the cost of remediating facilities that are still in operation (for which cleanup and 

closure could become the responsibility of either the Office of Future Liabilities or the office 

operating the facility), or the cost of addressing one-of-a-kind or first-of-a-kind contamination 

problems that currently lack viable cleanup technologies, such as groundwater contaminated 

with metals, chlorinated organics, and/or radioactive isotopes. Nor does the current estimate 

include the costs of monitoring and maintaining site remedies over the thousands of years that 

radioactive hazards will remain. Thus the ultimate cost of cleaning up properties for which DOE 

is responsible may be greater than the estimates indicate. 

The estimated life-cycle costs and remaining costs as of the end of FY 2004 for each of the 

major installations are shown in Exhibit 7-2. Two sites account for 55 percent of the program's 

life-cycle cost, and five sites account for 73 percent. DOE anticipates that by completing site 

cleanup more quickly, it will reduce the length of time it must bear the fixed costs associated 

This estimate is considerably lower than the $220 billion estimate in the 2002 top-to-bottom review because 

DOE has undertaken a major effort to accelerate cleanup, improve business practices, and reduce restoration costs 

(U.S. DOE 2003a and 2004).

Chapter 7: Department of Energy Sites Page 7-12 

5 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

with maintaining the infrastructure of a site (a major component of DOE's overall costs). Hence, 

the Department intends to complete as much cleanup as possible in the near term. 

Exhibit 7-2. Estimated Remaining Life Cycle Cost for 

DOE Site Restoration by Installation 

Installation 

Release 

Sites 

Remaining 

Facilities 

Remaining 

Est. 

Completion 

Date 

Est. Total LifeCycle Cost 

($000) 

Est. Remaining 

Life-Cycle Cost 

($000) 

Lab. for Energy-Related Health Res. 0 0 2005 40,577 967 

Ashtabula Env. Mgmt. Project, OH 3 11 2006 156,923 33,605 

Columbus Env. Mgmt. Proj., OH 1 1 2006 163,259 33,851 

Fernald Env. Mgmt. Proj., OH 4 6 2006 3,553,013 1,324,958 

Kansas City Plant 1 0 2006 28,660 7,373 

Lawrence Berkeley Nat. Lab. 15 0 2006 33,758 7,028 

Lawrence Livermore Nat. Lab/ 

LLNL Site 300 

8 

8 

0 

0 

2006 

2008 

514,673 

0 

44,530 

Mound/Miamisburg Proj., OH 57 39 2006 1,503,413 771,800 

Rocky Flats Env. Tech. Center 35 108 2006 9,297,868 4,555,884 

Sandia National Laboratories 71 0 2006 230,721 30,018 

Stanford Linear Accelerator Center 1 0 2006 20,599 3,316 

Energy Technology Eng. Center 3 3 2007 204,976 67,746 

Brookhaven National Lab 8 6 2008 373,359 154,055 

Pantex Plant 161 4 2008 192,291 81,559 

Argonne National Lab, East 0 15 2009 63,221 8,233 

Atlas Site (Moab) 1 0 2011 186,034 172,388 

West Valley Demo. Proj, OH 1 0 2012 1,366,841 933,942 

General Electric Vallecitos b 0 1 2014 0 0 

Separations Process Unit 6 4 2014 245,815 234,439 

Los Alamos National Laboratory 795 1 2015 1,529,522 858,700 

Oak Ridge Reservation 374 134 2015 7,351,982 3,290,155 

Portsmouth GDP 14 0 2025 6,258,959 5,306,287 

Savannah River Site 198 781 2025 28,643,636 17,859,407 

Nevada Test Site & Off-Sites 1,320 0 2010-2027 2,317,170 1,655,160 

Paducah GDP 150 2 2030 4,694,101 3,996,310 

Hanford / River Protection 1,633 1,357 2035 56,184,732 43,765,834 

Idaho Nat. Eng. & Env. Lab 125 288 2035 14,415,224 9,907,649 

Waste Isolation Plant NA NA NA 6,278,763 4,486,913 

Completed 1,077,277 0 

Subtotal, installations 4,993 2,761 NA 146,927,367 99,592,107 

Other (unspecified) 11,520,380 11,520,380 

Total 4,993 2,761 158,447,747 111,112,487 

Notes: 

• "Completed" includes life-cycle costs for sites completed prior to FY 2005, as well as life-cycle costs for various 

field activities that cannot be credibly allocated to their respective sites. 

• "Other" includes life-cycle costs for technology development and deployment, decontamination and 

decommissioning contributions & offsets, program direction, and headquarters activities. 

• This table includes non-remediation work, such as waste packaging and waste management. Remediation is 

about one-third of this figure. 

Source: DOE FY 2005 Budget Request 

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7.4.2 Timing of Expenditures

The ultimate cost of DOE's cleanup will depend on annual funding levels and achievement of the 

work as scheduled. Higher annual funding tends to accelerate cleanup work and reduce total lifecycle costs in the long run; lower annual funding tends to delay work and increase total costs. 

Actual or anticipated EM 

expenditures for FY 2001 through Exhibit 7-3. Actual and Planned EM and FY 2005 are shown in Exhibit 7-3. 

Expenditures are expected to 

increase about 14 percent between 

FY 2001 and FY 2005. DOE 

anticipates that these current 

increases ultimately will lead to 

earlier completion of many sites 

and lower life-cycle costs. After 

2005, EM’s annual site restoration 

expenditures are expected to 

decline (U.S. DOE 2004). 

Exhibit 7-4 shows actual or 

anticipated EM expenditures for 

FY 2002 through FY 2005 by 

major DOE activity type. 

Stabilization of high-risk materials 

alone consumed almost half of the 

EM budget in recent years. Remediation of soil and water took about one-tenth, and D&D of 

contaminated facilities took a little over one-sixth. The estimates do not include estimates of 

cleanup costs for facilities currently in use, since they are not part of the EM program. 

Site Restoration Budget: FY 2000-2004 

The completion of cleanup work at release sites is the key measure of success for environmental 

management, but site cleanup is a very complex task, generally involving numerous activities 

over many years. The annual budget request, usually available on the DOE web site, contains 

information on EM program performance, such as the volume of waste treated and disposed of, 

number of release site cleanups completed and facilities decommissioned, quantity of nuclear 

material stabilized, quantity of spent nuclear fuel moved to dry storage and prepared and shipped 

for consolidation, and number and type of innovative technologies deployed. 

7.5 Market Entry Considerations 

DOE is the largest single U.S. purchaser of remediation services (over $2 billion annually), 

accounting for over one-third of the U.S. remediation market in recent years. DOE also is the 

largest civilian contracting agency in the federal government; about 90 percent of its annual 

Chapter 7: Department of Energy Sites Page 7-14 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 7-4. DOE Environmental Management 

Expenditures 2002-2004 ($000) 

Activity 

FY 2002 

Comparable 

Appropriation 

FY 2003 

Comparable 

Appropriation 

FY 2004 

Comparable 

Appropriation 

FY 2005 

Budget 

Request 

Nuclear Material Stabilization and 

Disposition 

592,338 579,663 713,337 725,004 

Spent Nuclear Fuel Stabilization 

and Disposition 

403,617 402,307 358,176 244,681 

Solid Waste Stabilization and 

Disposition 

949,848 968,350 1,078,195 1,065,887 

Radioactive Liquid Waste 

Stabilization and Disposition 

863,087 1,002,371 1,049,629 1,261,084 

Radioactive Liquid Waste 

Stabilization and Disposition: Major 

Construction 

665,000 690,000 686,036 690,000 

Safeguards and Security 244,361 254,747 291,124 265,059 

Soil and Water Remediation 680,542 782,475 807,501 987,154 

Nuclear Facility Decontamination & 

Decommissioning 

1,095,039 1,167,695 1,257,843 1,206,800 

Non-Nuclear Facility 

Decontamination & 

Decommissioning 

31,264 21,085 55,025 47,183 

Operate Waste Disposal Facility 154,916 176,663 153,577 174,637 

Waste and Material Transportation 43,522 13,631 43,994 40,751 

Technology Development 200,189 113,679 66,116 60,142 

Community and Regulatory 

Support 

43,763 38,589 41,217 39,854 

Program Direction 301,422 279,723 276,510 271,059 

Federal Contribution to the 

Uranium Enrichment D&D Fund 

420,000 432,731 449,333 463,000 

Pre-2004 Completions 105,392 11,786 0 0 

Other 236,977 338,741 322,856 354,501 

Total, EM 7,031,277 7,274,236 7,650,469 7,896,796 

Note: The EM budget request also includes offsets, such as the Uranium Enrichment D&D fund, which are not 

shown above. 

Source: DOE FY 2004 and 2005 Congressional Budget Requests (U.S. DOE 2003b and 2004). 

Chapter 7: Department of Energy Sites Page 7-15 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

budget is spent on contracts. DOE relies primarily on contractors (100,940 in 2002, according to 

the 2002 performance report) to operate its facilities and carry out its diverse missions (U.S. 

GAO 2003), including a small army of nearly 36,000 contractors to rectify the environmental 

hazards resulting from five decades of nuclear weapons production (Probst 2000). 

Characteristics of DOE Contractors 

Most of EM's work is accomplished through large prime contractor companies. In 2002, more 

than 60 percent of over $5 billion in EM contracting was managed by just three firms: Bechtel 

Group International, Washington Group International/Westinghouse, and Fluor Corporation. Of 

course, some of that money went to subcontractors. Another 30 percent of the total EM contract 

revenues flowed through four prime contractors: CH2M Hill, British Nuclear Fuel (BNFL), 

BWX Technologies, and Jacobs Engineering (Paterson 2002). Few new entrants have found a 

way to be competitive. A DOE study (Analysis of the DOE Contractor Base, 2001) reported that 

the number of potential bidders for major DOE contracts diminished from 20 to 30 companies a 

decade ago to about 10 companies in 2001. Recent procurements for multi-billion dollar site 

management contracts have received only one or two proposals (e.g., the Office of River 

Protection Tank Waste Remediation System, Fernald Environmental Management Project, and 

Savannah River Site)(YAHSGS 2002). 

The consolidation of DOE remediation contractors reflects a general market trend in the 

remediation services industry, as noted by Farkas Berkowitz in a 2000 comparison of market 

shares. In 1994 the top ten companies claimed 38 percent of the remediation market; by 2000 the 

top five companies claimed 50 percent of the market (YAHSGS 2002). The reluctance of 

contractors to bid on major DOE procurements is based upon a combination of low profit 

margins and the difficulty of competing with incumbent contractors. The consolidation of firms 

and a diversification of firms into other, more profitable commercial markets means that EM 

now faces a smaller contractor base with less "risk-bearing capacity" as it seeks to accelerate 

cleanup (Tomlinson & Paterson 2002). 

Increasing Emphasis on Performance-Based Contracting 

DOE has committed to increasing its use of performance-based contracting as a means of 

achieving risk mitigation and to strengthen its business practices. In 1994, two-thirds of 

remediation contracts were based on time and materials (YAHSGS 2002). If DOE is successful 

in its effort to integrate performance-based approaches into all levels of its contracting system, 

companies providing risk-related services such as risk-based corrective action (RBCA) will 

continue to be a major factor in determining remediation technology applications as well as 

market share over the coming decade (U.S. DOE 2003a & 2002d). 

EM's push to increase the use of pay-for-performance contracting is an important element in 

advancing its environmental restoration program. To implement this initiative, DOE must 

compete with commercial markets for the best contractors and contractor personnel. The 

Department also must alter internal business practices that are not yet consistent with a 

comprehensive pay-for-performance approach (YAHSGS 2002). 

Chapter 7: Department of Energy Sites Page 7-16 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

DOE’s Accelerated Cleanup Schedules 

In response to the top-to-bottom review, DOE EM has opted to move forward more rapidly with 

its cleanup activities. EM is reviewing remediation plans at many installations and negotiating 

with regulators and other parties. It is expected that end state goals, remediation approaches, and 

schedules will be revised, perhaps more than once, at many sites. This expected change in the 

business approach may offer opportunities to a cleanup contractor who is flexible, resourceful, 

and efficient in meeting these challenges. 

Growing Need for Long-Term Stewardship 

In the long run, DOE's program strategy anticipates that activities will shift from cleanup to 

long-term stewardship, including monitoring, maintenance, and repair of properties where waste 

has been left on site. For example, many nuclear sites (e.g., FUSRAP sites, low-level waste and 

mixed-waste burial grounds, closed mine and mine tailings sites) may require long-term 

attention. The required monitoring and maintenance work may be more suitable to smaller 

contractors than to those involved in the management and cleanup of DOE's large installations. 

Monitoring and stewardship programs also should open the door to new instruments and 

measurement technologies coupled with remote information management systems to maintain 

perpetual vigilance over past cleanups (YAHSGS 2002). 

Encouraging the Use of Advanced Technologies 

The contract reform mechanisms sought within EM may affect contractor incentives to use 

advanced remediation techniques. A cleanup contractor's willingness to deploy an innovative or 

emerging cleanup technology requires that the benefits achieved through deployment (e.g., 

reduced cost and schedule) substantially outweigh the down-side risk of failure and recovery due 

to the greater uncertainties associated with new technologies. In the interest of finding better 

cleanup approaches, demonstration projects can be structured so that the prime contractor's fees 

are not affected by success or failure of the demonstrations (YAHSGS 2002). DOE has shown its 

interest in emerging technologies by funding their development and deploying remedies such as 

phytoremediation and permeable reactive barriers at its sites, as has been documented in EPA's 

Treatment Technologies for Site Cleanup, Annual Status Report, 11th Edition. 

7.6 Remediation Technologies and Research, Development, and

Demonstration 

Even for many experts in the environmental field, the terms and issues at DOE sites can differ 

significantly from what most environmental engineers encounter at privately owned sites that are 

subject to CERCLA or RCRA requirements. The presence of radioactive products resulting from 

nuclear fuel cycles and nuclear weapons production complicates the cleanup of the more familiar 

contaminants and hazardous wastes (Probst 2000) and present special hazards with regard to 

worker health and safety. Exhibit 7-5 describes technologies DOE has found useful to the 

cleanup effort. 

Chapter 7: Department of Energy Sites Page 7-17 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 7-5. Examples of Innovative Technologies Useful to DOE 

Technology Analysis 

Soil Remediation Barometrically Enhanced Remediation Technology (BERTTM) — Passively capitalizes 

on wind effects and the vertical soil-gas movement resulting from natural barometric 

pressure oscillations and harnesses this mechanism to ensure a net-upward, vertical 

soil-gas flux in contaminated soil. Applicable to sites where contaminants are volatile 

under standard conditions, close to the soil surface, and at concentrations low enough to 

eliminate the need for off-gas treatment. BERTTM has been deployed at DOE’s Idaho 

Engineering and Environmental National Laboratory. (DOE/EM-0516) 

Well Injection Depth Extraction (WIDE) — A hybrid soil flushing/soil gas extraction 

system developed by researchers from North Carolina State University. WIDE uses 

prefabricated vertical wells for the in-situ remediation of contaminated fine-grained soils. A 

WIDE demonstration of trichloroethene removal took place in Ohio at DOE's Ashtabula 

Environmental Management Project in 1999. (DOE/EM-0577) 

in-situ Gaseous Reduction (ISGR) — Reduction and immobilization of hexavalent 

chromium or other redox-sensitive metals in soils by injection of a low-concentration 

hydrogen sulfide gas mixture. The oxidized metals are reduced and immobilized as either 

an insoluble oxyhydroxide or sulfide. ISGR was demonstrated in1998 at White Sands 

Missile Range, New Mexico, in a cooperative DOE/DoD effort. (DOE/EM-0521) 

Groundwater 

Remediation 

Hydrous Pyrolysis Oxidation/Dynamic Underground Stripping (HPO/DUS) — A 

combination of steam and oxygen injection, electrical heating (if required), soil vapor 

extraction, in-situ bioremediation, electrical resistance tomography, and conventional 

pump-and-treat technologies that removes organics (e.g., DNAPLS) from soil and 

groundwater. DUS volatilizes contaminants, which are carried by the steam to a central 

extraction well. HPO is a chemical process for destroying contaminants in place in the 

subsurface. HPO/DUS was applied to full-scale cleanup at the Visalia Superfund Site in 

Visalia, CA, from 1997 to 1999. The technology is available for licensing. (DOE/EM-0504) 

Enhanced in-situ Bioremediation — Involves electron-donor injection to stimulate 

indigenous microbes, groundwater pumping, air stripping, and monitoring. The patented 

use of sodium lactate (or similar electron donors) at high concentrations to enhance 

bioavailability is marketed as Bioavailability Enhancement TechnologyTM, or BETTM. A 

1999-2000 demonstration to treat the source area of a TCE plume in the groundwater at 

Idaho National Engineering and Environmental Laboratory worked so well that the Record 

of Decision was amended in 2001 to incorporate the technology. (DOE/EM-624) 

In-Well Vapor Stripping Technology — Represented in the United States by four types 

of commercial in-well vapor stripping systems: NoVOCsTM, Density Driven Convection 

(DDC), Unterdruck-Verdampfer-Brunnen (UVB) Vacuum Vaporizer Well and Coaxial 

Groundwater Circulation (KGB), and C-Sparger®. Specially designed wells pump water or 

vapor through a screened interval and recirculate it back into the aquifer through a 

separate interval. Treatment occurs below ground within the well casing, which reduces 

costs. A UVB system successfully removed chlorinated solvents from groundwater at 

Brookhaven National Laboratory from 1999 through 2001. (DOE/EM-0626) 

Permeable Reactive Barrier (PRB) — A zone of reactive material placed in the path of a 

groundwater plume to reduce concentrations of dissolved organics or inorganics as the 

water flows through. The reactive medium selected varies with the contaminant(s) requiring 

treatment, though elemental iron filings are used most frequently. DOE has installed PRBs 

at many sites, including the Monticello Mill Tailings Site in Utah, the Kansas City Plant in 

Missouri, the Rocky Flats Mound Site in Colorado, and the Oak Ridge Reservation Y-12 

Site in Tennessee. (DOE/EM-0557, DOE/EM-0623) 

Chapter 7: Department of Energy Sites Page 7-18 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 7-5: Examples of Innovative Technologies Useful to DOE (continued) 

Technology Analysis 

Facilities 

Deactivation 

Modified Brokk Demolition Machine With Remote Operator Console — A commercially 

available robotic machine purchased for deactivation and decommissioning (D&D) of 

nuclear facilities. At Idaho Engineering and Environmental Laboratory (INEEL), a Brokk 250 

demolition system was demonstrated in 1999 in various D&D activities and was modified 

and demonstrated again in 2000. It is now part of the general INEEL D&D equipment pool. 

(DOE/EM-0597) 

Tank Waste 

Stabilization 

Thermal Denitration — Uses high temperatures and a carbon-based reductant (e.g., 

sugar) to decompose the nitrate and nitrite salts in aqueous sodium-bearing acidic waste to 

nitrogen gas and oxides of nitrogen. The three-step process calls for evaporation of the 

acidic liquid, decomposition of the highly volatile components, and chemical interaction of 

the waste components and the added mixture to form a solid. DOE has over 1,000,000 

gallons of sodium-bearing acidic waste to denitrify, solidify, and dispose of. Demonstrated at 

Pacific Northwest National Laboratory. (DOE/EM-0616) 

Mixed Waste 

Stabilization 

Solidification of Radioactive Waste Oils — Products for free-liquid control in storage, 

transport, and disposal of radioactive and RCRA-defined waste oils. A polymer solidifying 

agent, Nochar Petrobond®, was demonstrated in 1999 at the Mound Large-Scale 

Demonstration and Deployment Project, in Miamisburg, Ohio, to absorb and solidify 

high-activity tritium-contaminated vacuum-pump oils. (DOE/EM-0598) 

Nuclear Materials 

Processing 

Real-Time Monitor for Transuranics in Glass — An optical sensor for remotely assaying 

transuranic elements in molten glass as it flows into containers during the vitrification 

process. The technology was demonstrated at the Savannah River Site three times between 

1997 and 1999. (DOE/EM-0561) 

Characterization Tomographic Site Characterization Using CPT, ERT, and GPR — A geophysical system 

delivered via cone penetrometer technology (CPT) that incorporates results from electrical 

resistivity tomography (ERT) and ground penetrating radar (GPR). ERT can be used to 

monitor or detect subsurface processes such as water infiltration, underground tank leaks, 

and steam or electrical heating during soil cleanup operations. Data from GPR are used to 

produce a cross-sectional profile or record of subsurface features. Demonstrated at a test 

site in Vermont and at the Savannah River Site. (DOE/EM-0517) 

Containment Alternative Landfill Cover — A regulatory-acceptable alternative to the prescriptive RCRA 

Subtitle C and D cover design. To identify covers with cost and performance advantages 

over the prescriptive baseline covers at an arid or semi-arid site, DOE is monitoring an 

alternative landfill cover demonstration at Sandia National Laboratories in New Mexico to 

document the performance of four different alternative landfill covers. (DOE/EM-0558) 

SEAtraceTM Monitoring System — A low-cost, early detection system to verify the initial 

and long-term integrity of subsurface containment barriers by gaseous tracer injection, 

automated multipoint sampling, and real-time global optimization modeling. The system 

characterizes the integrity of impermeable barriers constructed above the water table and 

determines the size and location of leaks. Demonstrated at Dover Air Force Base, Naval Air 

Station Brunswick, and Brookhaven National Laboratories. (DOE/EM-0549) 

Source: U.S. Department of Energy, the Innovative Technology Summary Report series. Available through DOE's 

Information Bridge at http://www.osti.gov/bridge/ or at apps.em.doe.gov/OST/itsrall.asp. 

Chapter 7: Department of Energy Sites Page 7-19 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

7.6.1 Private Sector Involvement: Mechanisms 

DOE uses different mechanisms to invite the private sector to participate in its technology 

research and development programs. These include specific request for proposals (RFPs) issued 

in Federal Business Opportunities or the Federal Register and broad announcements designed to 

collect "best-in-class" technology providers (U.S. DOE Web 2003a). 

Technology transfer can mean many things: technical assistance to solve a specific problem, use 

of unique facilities, access to patents and software, exchange of personnel, and cooperative 

research. The most appropriate mechanism will depend on the objective of each partner. A brief 

description of several technology transfer mechanisms appears below. 

Cooperative agreements: instruments entered into by the government with industry, 

universities, and others to support or stimulate research. Agreements are generally cost-shared 

with the nonfederal participant. 

Cooperative Research and Development Agreements (CRADAs): an incentive for 

collaborative research and development. CRADAs are agreements between a specific DOE 

laboratory and a non-federal source to conduct mutually beneficial research and development 

that is consistent with the laboratory's mission. CRADAs can be funded either entirely by the 

partner or by DOE/partner cost sharing. CRADA partnerships can be developed by identifying 

the specific area for research and development, the intellectual property owned, and the 

laboratories/facilities technology areas that best match the needs, and then contacting that 

laboratory/facility technology transfer office. 

Cost-shared contracts/sub-contracts: collaboration through a procurement of mutual benefit to 

industry and to government. Often the government can agree not to disseminate, for a limited 

period of time, commercially valuable data that are generated under a cost-shared contract. 

Licensing: the transfer of less than ownership rights in intellectual property, such as a patent or 

software copyright, to permit its use by the licensee. Licenses can be exclusive or for a specific 

field of use or for a specific geographical area. The potential licensee must present plans for 

commercialization. The DOE Invention Licensing Home Page and its associated databases 

provide information on Department-owned patents available for license for commercial use. 

(http://www.osti.gov/dublincore/gencncl/)

Personnel exchange programs: arrangements allowing government or laboratory staff to work 

in industry facilities and industry personnel to work in government laboratories and facilities to 

enhance technical capacities and support research in specific areas. Costs are borne by the 

organization sending the personnel. Intellectual property arrangements can be addressed in 

exchange agreements. 

R&D consortia: arrangements involving multiple federal and non-federal parties working 

together for a common R&D objective. Funding for R&D consortia can be shared, but usually no 

funds are exchanged between participants. 

Chapter 7: Department of Energy Sites Page 7-20 
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Technical assistance to small business: undertaken by DOE/laboratory/facility personnel in 

response to an inquiry from an individual or organization seeking to further knowledge, solve a 

specific problem, or improve a process or product. 

User facility agreements: arrangements permitting private parties to conduct research and 

development at a laboratory. For proprietary R&D, the laboratory is paid for the full cost of the 

activity. If the work will be published, cost can be adjusted. Intellectual property rights generally 

belong to the user. 

Work for Others (WFO): arrangements permitting private parties to conduct research and 

development at a laboratory for either a federal agency or a non-federal entity. In this 

arrangement, the private entity pays the laboratory's full costs for performing a research project. 

A WFO arrangement permits a developer to gain access to highly specialized or unique DOE 

facilities, services, or technical expertise. A technology developer can acquire a WFO by 

identifying the unique expertise required, identifying the laboratories/facilities technology areas 

that best match the technology development need, and contacting the laboratory/facility 

technology transfer office. For proprietary R&D, the laboratory is paid for the full cost of the 

activity. If the work will be published, cost can be adjusted. Intellectual property rights generally 

belong to the user. 

7.6.2 Private Sector Involvement: Programs 

Among DOE's many technology development programs, the following are particularly useful to 

developers of environmental technologies. 

The Environmental Management Science Program (EMSP), sponsored by the Office of 

Science (SC), is designed to inspire breakthroughs in areas critical to the EM mission through 

basic research, and to fulfill DOE's continuing commitment to the cleanup of environmental 

liabilities. The program was initiated in FY 1996 to address long-term technical issues and 

provide EM with near-term fundamental data critical to the advancement of technologies that are 

under development, but not yet at full scale nor implemented. Proposed basic research should 

contribute to environmental management activities that would decrease risk for the public and 

workers, provide opportunities for major cost reductions, reduce time required to achieve EM's 

mission goals, and, in general, address problems that are considered intractable without new 

knowledge (NRC 2000). The EM Science Program's solicitations are published in the Federal 

Register. (http://emsp.em.doe.gov/) 

Since 1996, the Program has held six competitions and has awarded over $290 million in 

funding for 361 research projects. A breakdown of the EMSP awards by year is as follows:

 • 1996 and 1997: 202 awards totaling $160 million targeted at a broad spectrum of basic

science cleanup and waste management issues.

 • 1998: 33 awards totaling $30 million focused on high-level radioactive waste and

decontamination and decommissioning issues.

 • 1999: 39 awards totaling $30 million fostered basic research in the areas of vadose zone

contamination and low dose radiation.

Chapter 7: Department of Energy Sites Page 7-21 
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• 2000: 42 awards totaling $30 million in research renewals for 1996 and 1997 funded

projects.

 • 2001: 45 awards totaling $39 million focused on additional high-level radioactive waste and 

decontamination and decommissioning issues (DOE 2002c). 

• 2002: 38 awards totaling $33 million for research on subsurface contamination in the vadose 

and saturated zones. 

The Natural and Accelerated Bioremediation Research Program (NABIR) is sponsored by 

DOE's Office of Biological & Environmental Research within SC to increase understanding and 

utilization of contaminant bioremediation processes. (http://www.lbl.gov/NABIR/)

The Small Business Innovation Research (SBIR) and Small Business Technology Transfer 

(STTR) programs are designed to stimulate and foster scientific and technological innovation in 

the private sector, strengthen the role of small businesses in meeting federal research and 

development needs, and increase the commercial application of innovations derived from 

federally funded research. SBIR defines a small business as a for-profit enterprise operating in 

the United States with majority domestic ownership and with no more than 500 employees. 

Phase I SBIR awards up to $100,000 are awarded to explore the feasibility of innovative 

concepts for nine months. Phase II is the principal research or R&D effort, with awards up to 

$750,000 over a two-year period. DOE funds approximately 200 Phase I projects and about 90 

Phase II projects per year. In Phase III, non-federal capital should be used by the small business 

concern to pursue commercial applications of the R&D. To aid awardees seeking follow-on 

funding for Phase III, DOE sponsors a Commercialization Assistance Project that provides 

individual assistance in developing business plans and preparing presentations to potential 

investment sponsors. The STTR pilot program is closely modeled on SBIR, with an additional 

requirement of co-participation by a research institution such as a university, non-profit institute, 

or contractor-operated, federally funded research and development center. Not less than 40 

percent of the work conducted under an STTR award must be performed by the small business 

concern, and not less than 30 percent of the work must be performed by the non-profit research 

institution. The STTR awards are fixed-price grants of approximately $100K under Phase I, 

rising to about $500K in Phase II, given continued successful program performance. University 

or other non-profit involvement in a project does not limit the applicant to STTR only; 

application can be made under SBIR alternatively. (http://sbir.er.doe.gov/sbir/)

Within EM, the Office of Science and Technology program provides direct technical solutions 

to closure sites, which are DOE facilities whose primary mission has been completed or 

terminated and where current activities are focused solely on site remediation. At the start of 

each fiscal year, "alternative projects" will be identified that target immediate and specific 

cleanup needs at the sites. Department-wide competitive grant and contract regulations apply. 

(http://www.em.doe.gov/ost) 

The National Energy Technologies Laboratory (NETL) supports cleanup by implementing 

several extramural technology development and deployment programs, with emphasis on 

technologies for deactivation and decommissioning, and minimization and/or abatement of 

environmental problems associated with the development and use of the nation's energy supply 

Chapter 7: Department of Energy Sites Page 7-22
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

(e.g., fly ash from coal-burning facilities). NETL contracts with private-sector industrial and 

academic organizations for technology development. (http://www.netl.doe.gov/business/solicit/)

The Strategic Environmental Research and Development Program (SERDP) is the 

Department of Defense's corporate environmental R&D program, planned and executed in full 

partnership with DOE and EPA, with participation by numerous other federal and non-federal 

organizations. (http://www.serdp.org)

DOE encourages organizations and individuals to submit proposals that are relevant to the DOE 

research and development mission either in response to formal DOE solicitations or through 

self-generated unsolicited proposals. An Unsolicited Proposal is an application for support of an 

idea, method, or approach submitted by individuals, businesses, or organizations solely on the 

proposer's initiative, rather than in response to a formal government solicitation. Funding of 

Unsolicited Proposals is considered a noncompetitive action. A 50-page detailed booklet titled 

Guide for the Submission of Unsolicited Proposals outlines the Unsolicited Proposals process 

and is available at 

http://professionals.pr.doe.gov/ma5/MA-5Web.nsf/WebPages/Proposal+System?OpenDocument 

In 1994, EM's Office of Science and Technology implemented the Technology Focus Area 

approach as a strategy to leverage resources and facilitate sound technology development 

decisions in the following technology problem areas: deactivation and decommissioning, 

subsurface contaminants, transuranic and mixed waste, and tanks. The Focus Area approach 

sought to optimize resources by streamlining technology management activities into a single 

focus team for each major problem area. A National Research Council report, Decision Making 

in the U.S. Department of Energy's Environmental Management Office of Science and 

Technology (NRC 1999), provides an extensive overview of the aims and organization of the 

Technology Focus and Cross-Cutting Technology Areas. As a result of the reorganization 

brought about by the 2002 top-to-bottom review, EM is working to accelerate cleanup at specific 

sites and has refocused the science and technology program to address a limited number of 

critical site-specific cleanup needs, deliver expert services, and provide potentially high payback 

solutions. DOE terminated the Focus Area and most of the Cross-Cutting Technology Area 

programs at the end of FY 2002. 

Numerous reports exploring DOE's environmental technology research and development needs 

have been produced by the National Research Council (see the extended bibliography in the 

appendix). Also, a collaborative effort to draft DOE's Long-Term Stewardship Science and 

Technology Roadmap will define the strategic path forward for the critical science and 

technology required to support the long-term stewardship program with regard to near-term 

(5-10 year), intermediate-term (10-20 year), and long-term (20-50 year) general environmental 

research and development needs (U.S. DOE 2002b). 

Chapter 7: Department of Energy Sites Page 7-23 
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7.7 References

Applegate, John and Stephen Dycus, 1998. "Institutional Controls or Emperor's Clothes? 

Long-Term Stewardship of the Nuclear Weapons Complex," Environmental Law Reporter: 

News & Analysis, 28(11):10631-10652. 

EBI, 2002. "Industry Overview 2002," Environmental Business Journal, 14:7-8, Environmental 

Business International, Inc. 

Fiore, James J. and Marcus E. Jones, 2000. "The New Office of Environmental Management's 

Site Closure Program," Waste Management 2000 Symposium, February 29, 2000, Tucson, AZ. 

HR, 2000. Incinerating Cash: The Department of Energy's Failure to Develop & Use Innovative 

Technologies to Clean Up the Nuclear Waste Legacy, U.S. House of Representatives, a staff 

report prepared for the use of the Committee on Commerce. 

NRC, 1999. Decision Making in the U.S. Department of Energy's Environmental Management 

Office of Science and Technology, National Research Council, National Academy Press, 

Washington, DC, ISBN: 0309063477. 

NRC, 2000. Research Needs in Subsurface Science: U.S. Department of Energy's Environmental 

Management Science Program, National Research Council, National Academy Press, 

Washington, DC. 

Paterson, Andrew, 2002. "New Approach in the Works for DOE," Environmental Business 

Journal, 14(11-12):18-19. 

Probst, Katherine and Adam Lowes, 2000. Cleaning up the Nuclear Weapons Complex: Does 

Anybody Care? Resources for the Future, Washington, DC. 

Tomlinson, R. and A. Paterson, 2002. "Overview: Reengineering EM for 2003, What’s Going 

On?" Briefing for ITRC Board of Directors, February 19, 2002. 

U.S. DOE, 1996a. The 1996 Baseline Environmental Management Report, U.S. Department of 

Energy, Office of Environmental Management, DOE/EM-0290. 

U.S. DOE, 1996b. Closing the Circle on the Splitting of the Atom, U.S. Department of Energy, 

Office of Environmental Management, DOE/EM-0266. 

U.S. DOE, 1998. Accelerating Cleanup: Paths to Closure, U.S. Department of Energy, Office of 

Environmental Management, DOE/EM-0362. 

U.S. DOE, 2000. Strategic Plan: Strength through Science—Powering the 21st Century, U.S. 

Department of Energy. 

Chapter 7: Department of Energy Sites Page 7-24 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

U.S. DOE, 2001a. Analysis of the DOE Contractor Base: Readiness, Willingness, Profitability 

and Trends, U.S. Department of Energy, Contract Reform and Privatization Project Office. 

U.S. DOE, 2001b. Long-Term Stewardship Study, U.S. Department of Energy, Office of 

Environmental Management. 

U.S. DOE, 2001c. Report to Congress on Long-Term Stewardship. Volume 1: Summary Report; 

Volume 2: Site Summaries, U.S. Department of Energy, Office of Long-Term Stewardship, 

DOE/EM-0563, January 2001. 

U.S. DOE, 2002a. "Environmental Management: Executive Summary," FY 2003 Budget Request 

to Congress, U.S. Department of Energy. 

U.S. DOE, 2002b. Long-Term Stewardship Science and Technology Roadmap (Draft), U.S. 

Department of Energy, Long-Term Stewardship Science and Technology Roadmap Executive 

Committee and Workgroups, Idaho Operations Office, DOE/ID-10926, October 2002. 

U.S. DOE, 2002c. "Office of Science Financial Assistance Program Notice 02-03; 

Environmental Management Science Program (EMSP): Research Related to Subsurface 

Contamination in the Vadose and Saturated Zones," U.S. Department of Energy, Federal 

Register, 67(4):719-725, January 7, 2002. 

U.S. DOE, 2002d. A Review of the Environmental Management Program, United States 

Department of Energy, Presented to the Assistant Secretary for Environmental Management by 

the Top-to-Bottom Review Team, U.S. Department of Energy, February 4, 2002. 

U.S. DOE, 2002e. "About OST," U.S. Department of Energy, Office of Environmental 

Management, Office of Science and Technology web site, June 11, 2002. 

http://apps.em.doe.gov/OST/aboutmain.asp 

U.S. DOE, 2003a. "Environmental Management: Executive Summary," FY 2004 Budget Request 

to Congress, U.S. Department of Energy. 

U.S. DOE, 2003b. Performance and Accountability Report for FY 2002, U.S. Department of 

Energy, DOE/ME-0014. 

U.S. DOE, 2004. Department of Energy FY 2005 Budget Request, DOE/ME-0036, Vol. 5, U.S. 

Department of Energy, February, 2004. 

U.S. DOE Web, 2003a, "Technology Partnership Gateway," U.S. Department of Energy web 

site, March 1, 2003. http://www.energy.gov/business/partners/ttwg.mechanisms.html 

U.S. DOE Web, 2003b. "Inside the DOE—About Us: Our Mission," U.S. Department of Energy 

web site, March 1, 2003. 

Chapter 7: Department of Energy Sites Page 7-25 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

U.S. GAO, 2002a. Waste Cleanup: Implications of Compliance Agreements on DOE's Cleanup 

Program, U.S. General Accounting Office, GAO-02-852T, July 19, 2002. 

U.S. GAO, 2002b. Waste Cleanup: Status and Implications of DOE's Compliance Agreements, 

U.S. General Accounting Office, GAO-02-567, May 2002. 

U.S. GAO, 2003. Major Management Challenges and Program Risks: Department of Energy, 

U.S. General Accounting Office, GAO-03-100, January 2003. 

YAHSGS, 2002. Assessment of the 2000 and 2001 Environmental Management Industry: The 

Times They Are A-Changin', Prepared by YAHSGS LLC, Richland, WA, for the U.S. 

Department of Energy, Washington, DC. 

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Chapter 8 

Demand for Remediation of Sites 

Managed By Civilian Federal Agencies 

This chapter describes the market for cleanup of sites owned or operated by “civilian” federal 

agencies, which includes all federal agencies except the Departments of Energy and Defense. 

Civilian agencies are collectively responsible for the management of millions of acres of land 

and may ultimately be responsible for site characterization and remedial actions at thousands of 

sites.1 

The most comprehensive source of 

information on contaminated facilities for 

which civilian agencies are responsible is the 

“Federal Agency Hazardous Waste 

Compliance Docket” (“the docket”) (U.S. EPA 

2003a). Section 120(c) of the Comprehensive 

Environmental Response, Compensation, and 

Liability Act (CERCLA), as amended by the 

Superfund Amendments and Reauthorization 

Act (SARA), requires EPA to maintain the 

docket as a repository for information about 

federal facilities that manage hazardous waste 

or from which hazardous substances have 

been, or may be, released. As of January 2003, 

1,099 facilities, distributed among 18 civilian 

federal agencies, were listed on the docket. It 

is estimated that approximately 70 percent of 

these facilities may require environmental 

cleanup. 

Although an overall estimate of the potential 

cost of cleaning up these facilities is 

unavailable, estimates are available for 

agencies managing a significant portion of the 

facilities listed on the docket and for which 

Highlights 

C About 70% of civilian federal agency 

contaminated sites are on lands managed by the 

DOI and USDA. These agencies combined 

manage over 700 million acres of land, about a 

third of U.S. land. 

C DOI and USDA have identified at least 3,000 

contaminated sites that will require cleanup. In 

are responsible. 

C The cost to complete cleanup at civilian federal 

agency sites is estimated to be $15-22 billion. 

This estimate does not include all of the mining 

sites. Mining sites are addressed in Chapter 11. 

C The 17 federal agencies on EPA’s docket 

typically spend an estimated $100-200 million 

annually for contaminated site cleanup at their 

properties. This figure may underestimate the 

includes only some of the potential cost recovery 

and cost sharing. 

C Based on the above annual funding level, it will 

contaminated sites at civilian federal agencies. 

C Given the types of environmental problems 

present, remediation approaches at civilian 

federal sites are likely to be similar to those used 

in other programs, such at RCRA and NPL sites. 

addition, between 5,000 and 25,000 abandoned 

mine sites are on lands for which these agencies 

total remediation expenditures, because it 

take between 100 and 200 years to clean up the 

selected information is available: the U.S.

Department of Interior (DOI), U.S. Department of Agriculture (USDA), U.S. Department of

Transportation (DOT), and National Aeronautics and Space Administration (NASA). These

Throughout this chapter, the term “site” is used to indicate an individual area of contamination. The term “facility” 

identifies an entire tract, including contiguous land, that is the responsibility of the subject agency. A “facility” may 

contain one or more contaminated areas or “sites.” 

Chapter 8: Civilian Federal Agency Sites Page 8-1 

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agencies together account for 75 percent of the civilian federal agency facilities listed on the 

docket. These agencies are also entrusted with managing vast amounts of public land. The 

largest federal land holder, DOI, is responsible for 507 million acres of surface land, or about 

one-fifth of the land in the United States; and the U.S. Forest Service (part of USDA) manages 

192 million acres of national forest and grasslands. 

8.1 Civilian Federal Agency Cleanup Programs 

Cleanup at hazardous waste sites is regulated in large part by CERCLA/SARA and the Resource 

Conservation and Recovery Act (RCRA). Federal agencies must comply with CERCLA and 

RCRA provisions in the same manner as private parties, and are liable for cleaning up 

contaminated waste at currently- or formerly-owned facilities. Under SARA, the federal agencies 

also may be liable for cleaning up contaminated waste at facilities acquired through foreclosure 

or other means and at facilities purchased with federal loans. To meet these requirements, 

civilian federal agencies implement various programs for assessing potentially contaminated 

sites and conducting any needed cleanup actions. Some agencies have established central offices 

to manage these programs, while others have adopted a decentralized approach involving the 

organization of programs by function or geographic location. 

For example, DOI’s Office of Environmental Policy and Compliance coordinates and develops 

the agency’s environmental policy and programs through three teams and eight regional offices 

to address: (1) requirements of the National Environmental Policy Act and Council on 

Environmental Quality; (2) remedial and corrective actions involving hazardous materials; and 

(3) requirements of the National Oil and 

Hazardous Substances Pollution 

Contingency Plan (NCP). In 1995, DOI 

established the Central Hazardous Materials 

Fund (CHF) to fund medium- to long-term 

CERCLA cleanup actions. Each year, 

bureaus and offices within DOI nominate 

projects for funding that impact sites on 

DOI land or that impact DOI resources. 

Between 1995 and 2002, the CHF, which is 

administered by the Bureau of Land 

Management (BLM), received $87.4 million 

in appropriated funds. An additional $84 

million was added through cost sharing and 

cost recovery. Appropriations for FY 2003 

are expected to be about $10 million. This fund may be used for site investigations, feasibility 

studies, and cleanups at sites for which DOI is responsible. Additional cleanup activities may be 

funded through the appropriations of the various DOI offices and bureaus. The major landmanagement components of DOI are shown in the box. 

: 

Bureau of Land Management: 262 million acres 

National Park Service: 84 million acres 

Bureau of Indian Affairs: 56 million acres 

Bureau of Reclamation: 9 million acres 

DOI Agencies Manage 507 Million Acres, 

One Fifth of U.S. Land

Fish and Wildlife Service: 96 million acres 

USDA’s Hazardous Materials Policy Council (HMPC) provides overall departmental leadership, 

in addressing issues relating to hazardous waste management and site cleanup. The council, 

which consists of senior policy representatives from the major affected offices and agencies 

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within USDA, was established in 1999 to improve consistency across USDA service areas, and 

consists of senior policy representatives from those areas. The implementation of the hazardous 

waste-related activities is the responsibility of the Department’s Hazardous Materials 

Management Program (HMMP). In addition to direct funding, HMMP receives funds from the 

Hazardous Materials Management Appropriation, which was established in 1988 to provide 

targeted funding for priority hazardous material cleanup projects on facilities and lands under 

USDA’s jurisdiction, custody, or control and for USDA’s share of the costs for cleanup projects 

on non-USDA property where USDA activities may have contributed to the pollution. The 

appropriation has been about $15.7 million over the past two years. An additional $26.7 million 

annually is available for the department’s environmental mission from direct USDA funds. 

NASA’s Environmental Compliance and Restoration Program (ECR) is managed from NASA 

Headquarters under the Office of Management Systems. ECR serves as a centralized lead for 

ensuring environmental stewardship and sustainability of the agency’s facilities. NASA’s 

environmental cleanup and compliance activities are implemented through 10 research or space 

flight centers located across the country. 

DOT consists of 13 operating administrations responsible for different transportation sectors (as 

of 2002). Each administration holds responsibility for restoration activities at its operational 

facilities, including identification, investigation, and cleanup. In addition to its national mission 

to protect the navigable water of the U.S., the U.S. Coast Guard provides DOT’s short- and longterm emergency response to hazardous substance or oil spills covered under CERCLA/SARA 

and the NCP. Coast Guard operations were transferred from DOT to the U.S. Department of 

Homeland Security in 2002. 

8.2 Factors Affecting Demand for Cleanup

Four primary factors influence the market for remediation of civilian federal agency 

contaminated waste sites. 

• Budget considerations constrain all federal agencies planning site remediation. Although 

agencies may request funds for contaminated site management and remediation, Congress 

may not provide the necessary funding. Agencies have intensified their efforts to prioritize 

cleanup activities within and across facilities by more effectively evaluating alternative 

future land uses, estimating and prioritizing risks to human health and the environment, 

evaluating a broad range of remediation technologies, and analyzing the relative costs and 

benefits of various approaches to cleanup. 

In addition, the federal budget process has created incentives for agencies to implement 

management reforms that will reduce the costs of operations. Some of these include 

encouraging and eliminating barriers to the use of less costly, innovative remediation 

technologies; using more cost-effective contracting procedures; streamlining management 

structures and processes; and using the “lessons learned” from other agencies and the private 

sector (U.S. CEQ 1995). 

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• Federal agencies are subject to the CERCLA “Lender Liability Rule,” which assigns 

responsibility for cleaning up contamination at acquired properties. Although federal 

agencies that involuntarily acquire contaminated property (through foreclosure or other 

mechanisms) generally are exempt from CERCLA liability, an agency may be liable for 

remediating a hazardous waste site if it loans money to, and actively participates in 

management of, an organization using or generating the hazardous waste. Federal liability is 

determined on a case-by-case basis for each site that is acquired involuntarily. 

Changes in federal and state environmental regulations and standards often impact the level 

and pace of cleanup required at civilian federal facilities. If cleanup standards become more 

rigorous in the future, the market may require more advanced technologies or longer-term 

and more intensive use of existing technologies than anticipated currently. Conversely, if 

standards become less stringent, the market for new remedial technologies could decrease. 

In January 2002, for example, EPA amended regulations covering corrective action 

management units (CAMUs) created under RCRA to facilitate treatment, storage, and 

disposal of hazardous wastes managed for implementing cleanup. The revised regulations 

established more detailed minimum design and operating standards for CAMUs and 

outlined treatment requirements for wastes that are placed in CAMUs without violation of 

RCRA land disposal restrictions. In addition, the amendment established specific 

information requirements for CAMU applications, including opportunity for public 

comment. The U.S. General Accounting Office reviewed the proposed regulations and 

determined that the process for requesting and obtaining CAMU approval would increase 

the time and cost of site cleanups (U.S. GAO 2000).

 • The transfer of public properties to private use may require agencies to reallocate resources 

for cleaning up properties designated for transfer. Recent years have witnessed an increase 

in public-to-private transfers of large properties, many of which are managed for a period of 

time by the General Services Administration. 

8.3 Number of Facilities and Sites

Estimates of the number of civilian federal facilities that will require some type of remedial 

action can be derived from the docket. CERCLA requires that the docket be updated every six 

months to reflect newly characterized sites. In January 2003, the docket reflected a total of 1,099 

facilities (Exhibit 8-1). The docket contains information submitted by civilian agencies under 

CERCLA Section 103(a), which requires that the National Response Center be notified of a 

hazardous substance release or potential release. The docket also contains information submitted 

to EPA by the agencies under RCRA Sections 3005, 3010, and 3016, which addresses facility 

permitting, notification of hazardous waste activity, and each agency’s biennial inventory of 

hazardous waste activities. 

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Exhibit 8-1. Number of Civilian Federal Facilities Potentially Requiring Cleanup 

Agency Facilities Listed on Docket 

Department of Agriculture 201 

Architect of the Capitol 1 

Central Intelligence Agency 1 

Department of Commerce 10 

Army Corps of Engineers 50 

Environmental Protection Agency 23 

General Services Administration 38 

Department of Health and Human Services 10 

Department of Housing and Urban Development 3 

Department of the Interior 468 

Department of Justice 27 

Department of Labor 3 

National Aeronautics and Space Administration 17 

U.S. Postal Service 26 

Tennessee Valley Authority 45 

Department of Transportation 134 

Department of the Treasury 9 

Veterans Administration 33 

Total 1099 

Notes: 

a The number of “sites” (individual areas of contamination) at each facility is not included in the docket. b The U.S. Army Corps of Engineers manages environmental cleanup projects for a variety of civilian federal 

agencies as well as the Department of Defense and Department of Energy. 

Source: 

U.S. Environmental Protection Agency. “Federal Agency Hazardous Waste Compliance Docket,” 68 Federal 

Register 107, January 2, 2003. 

Although it is the most comprehensive source available, the docket provides only broad 

indications of the remediation market. Some of the factors that limit its utility for market analysis 

are: many sites listed on the docket do not require remediation; sites that have undergone 

remediation are not removed from the docket; the docket does not indicate the number of 

contaminated sites at each facility (a facility can have one or more sites or areas of 

contamination); and many sites at federal facilities remain to be inventoried and characterized. 

In addition, the docket excludes federal facilities that have been sold, private facilities where the 

Chapter 8: Civilian Federal Agency Sites Page 8-5 
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federal government may have contributed to site contamination, and facilities that generate small 

quantities of hazardous waste. Thus, the docket may not account for all potentially contaminated 

sites on land for which civilian federal agencies are responsible. 

In accordance with CERCLA Section 120(d), a preliminary assessment (PA) is conducted for 

each facility listed on the docket to evaluate the threat they pose to public health and the 

environment. If warranted, a site inspection is conducted to determine if CERCLA response 

actions are necessary. If further actions are warranted, an evaluation is conducted to determine 

whether the site should be placed on the National Priorities List (NPL) for long-term evaluation 

and remedial response. As of October 2001, 15 civilian federal agency sites had been added, 

proposed, or deleted from the NPL (U.S. EPA 2003b). 

Approximately 30 percent of the docket facilities listed pursuant to CERCLA Section 103 

require no further EPA actions, and accordingly are designated “no further remedial action 

planned” (NFRAP). Although the NFRAP designation means that the contamination at a site is 

not severe enough to warrant listing the site on the NPL and remediation under the Superfund 

program, the site still may require cleanup under other environmental programs, such as a state 

regulation. 

DOI estimates that about 1,000 sites under DOI stewardship require restoration. (U.S .DOI 

2003b). By 2005, DOI aims to increase its cumulative number of restoration projects to 135 and 

the cumulative amount of damage settlement funds within the DOI Restoration Fund to $200 

Exhibit 8-2. DOI Allocation of the Central 

Hazardous Materials Fund 

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million. For example, DOI allocated approximately $10 million of Central Hazardous Materials 

Fund (CHF) money during 2001 to 35 projects spread among five bureaus: 14 projects in the 

Bureau of Land Management (BLM); 13 projects in the National Park Service; 4 projects in the 

Fish and Wildlife Service; 3 projects in the Bureau of Indian Affairs; and 1 project in the U.S. 

Geological Survey (U.S. DOI 2003a). The geographic distribution of these projects are shown in 

Exhibit 8-2. By 2005, DOI also plans to have completed cleanup of its 1,000th BLM hazardous 

material site (U.S. DOI 2003b). 

In addition to hazardous waste sites it has already identified, other sites may be discovered on its 

properties in the future. An estimated 3.5 million acres under the Department’s stewardship are 

in need of restoration. DOI plans to restore about 1.1 million of these acres by 2005. This land 

includes mined lands, wildlife refuges, park lands, and forests. In the course of implementing 

this task, additional remediation needs are likely to arise. For example, BLM estimates that 

between 5,000 and 25,000 abandoned mines on public lands the Bureau administers have caused 

or could cause environmental damage, mostly from water pollution. In a typical year, DOI works 

on between 50 and 150 remediation sites. 

In 2001, USDA estimated that over 2,000 sites with releases or threatened releases of hazardous 

substances remained to be addressed over the next 50 years, at an estimated cost of $4 billion 

(USDA 2001). From 2003 to the end of 2007, USDA anticipates completing 150 CERCLA 

cleanups. During 2003 alone, USDA planned to complete 68 CERCLA site assessments, 59 

CERCLA cleanup plans, and 6 RCRA cleanups. (In contrast, the agency targeted 17 CERCLA 

cleanups during fiscal year 2002.) More than half of the agency’s CERCLA cleanups planned for 

2003 involve mining sites (USDA 2003). USDA recognizes that preparation of cleanup plans is 

emerging as a potential “bottleneck.” While 137 CERCLA cleanups were completed in fiscal 

years 1998-2001, only 84 cleanup plans were completed during that time. 

DOT has made significant progress in remediating its contaminated sites. In fiscal year 2002, 

DOT reported that 91 of its facilities required no further remedial actions under SARA, and that 

all SARA cleanup efforts were completed (U.S. DOT 2002). This leaves 43 DOT facilities that 

require remediation. The Coast Guard received DOT funding to conduct response and cleanup 

activities required of the DOT under CERCLA/SARA. Continued restoration activity is 

anticipated at three Coast Guard facilities for several years. In addition, the Federal Aviation 

Administration plans continued cleanup activities at several facilities, and replacement of 

outdated underground storage tanks and cleaning or removal of unused tanks at decommissioned 

facilities. DOT uses a “worst first” prioritization system to address problems posed by DOT 

facilities where significant pollution problems are identified. 

8.4 Site Characteristics

The types of contamination problems at civilian federal agency facilities vary from agency to 

agency. Exhibit 8-3 provides examples of the types of contaminated facilities managed by 

agencies listed most often on the docket. Contaminated facilities owned or operated by other 

civilian federal agencies encompass research laboratories, properties acquired through 

foreclosure, and operational facilities such as the Department of Justice federal penitentiaries, 

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Tennessee Valley Authority power generating plants, and Department of Veterans Affairs 

medical centers. 

Exhibit 8-3. Examples of Types of Contaminated 

Facilities at Civilian Federal Agencies 

Department of Interior 

Bureau of Land Management Landfills (approximately 3,400 closed sites) 

Abandoned mining operations 

Unauthorized hazardous waste sites 

Bureau of Reclamation Reservoirs and drinking water supplies contaminated with 

agricultural runoff 

National Park Service Landfills and dumps (inherited with acquired land) 

Abandoned mining operations 

Fish and Wildlife Service Contaminated sites resulting from agricultural runoff or upstream 

industrial operations 

Inherited land previously used for industrial or defense purposes 

Department of Agriculture 

Forest Service Abandoned mining sites 

Sanitary landfills and aboveground dumps 

Wood preservation sites and laboratories 

Agricultural Research Service Research laboratories 

Commodity Credit Corporation Grain storage facilities 

Farmers Home Administration Farms (acquired through foreclosure) where pesticides and other 

hazardous materials may have been disposed 

Department of 

Transportation 

Federal Aviation Administration FAA Technical Center, with soil and groundwater contamination 

(FAA) of 22 areas 

Airfields with hazardous solvent or oil spills 

U.S. Coast Guard Fuel storage and operation/maintenance facilities 

National Aeronautics and 

Space Administration Research laboratories, industrial plants 

8.5 Estimated Cleanup Costs

Detailed site information for developing accurate cleanup cost estimates for civilian federal 

agency sites is not readily available from the agencies. EPA’s FEDPLAN-PC information system 

has been discontinued and information sources on environmental activities of the agencies are 

scattered among their bureaus and offices. To provide insight into the probable cost of 

completing cleanup at federal civilian sites, it is useful to examine (a) the probable cost of all 

sites that have been or are likely to be discovered, given current regulatory requirements, and (b) 

the probable funding likely to be committed to remediation. 

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Estimated Cost To Complete Cleanup 

Because information on contaminated sites at most agencies is fragmented, it is difficult to 

develop a clear picture of the cost to complete cleanups at civilian federal agencies. The U.S. 

General Accounting Office’s (GAO) recent study of the issue of environmental liabilities of 

federal agencies indicates the nature of this difficulty. In an effort to improve the Congressional 

budgetary process for federal agencies’ environmental liabilities, the GAO recently studied the 

problems posed by the waste-producing assets of these agencies. GAO recommended that the 

Office of Management and Budget require federal agencies to include in their budget requests 

supplemental information on estimated environmental cleanup/disposal costs for new 

acquisitions (U.S. GAO 2003). This requirement implies that agencies will be required to 

conduct Phase I and Phase II type site assessments when contemplating real estate transactions. 

It will also ensure that agencies explicitly recognize the financial cost of their potential 

environmental liabilities. 

GAO also assessed the efforts that federal agencies with major cleanup responsibilities have 

made in setting priorities for spending limited cleanup funds at the sites posing the highest risks 

(U.S. GAO 1999). GAO found that EPA and USDA had made progress in setting priorities on 

the basis of site risks, but that additional efforts were required by DOI to complete a site 

inventory and establish a risk-based prioritization of its sites. 

Despite these difficulties, DOI, USDA, and NASA planning and budgetary information indicate 

that cleanup of sites covered under CERCLA, RCRA, and other environmental regulations will 

continue to require extensive resources over many years. The following points summarize an 

estimate of the cost to complete remediation at contaminated federal civilian agency sites. 

Exhibit 8-4. Estimate Cleanup Cost for Civilian Federal Agencies 

Agency 

Cost to Complete 

($ Billions) Explanation/Limitations 

DOI $4.7-9.8 Over 1,000 sites identified on 468 facilities. It could require over 

100 years to address these sites. DOI reports it could have as 

many 25,000 sites. (U.S. DOI 2003a and U.S. CEQ 1995). 

USDA $4.2 Over 2,000 sites with releases or threatened releases of hazardous 

substances (USDA 2001). USDA expects this work to take about 

50 years. 

NASA $1.3 Environmental remediation of NASA’s research and space flight 

centers could require an additional 80 years to complete. 

Subtotal $10.2-15.3 These agencies account for 70% of the facilities on the docket. 

Total, all 

agencies $14.6-21.9 Divide previous figure by 0.7. 

Sources: See explanation in text and references above . 

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Available Funding 

Given the magnitude of the cost to complete cleanups at civilian federal sites, it is useful to 

examine the level of recent funding. 

Between 1995 and 2002, DOI received $87.4 million in direct funding and an additional $84 

million in cost sharing or cost recovery to address sites with hazardous materials. The direct 

funding comes from the Central Hazardous Materials Fund described in Section 8.1. In 

recent years, annual CHF funding has been $10 million. These funds may be supplemented 

through cost sharing and cost recovery from responsible parties or business operators. 

Historically, about one dollar of PRP funds becomes available for each dollar of direct 

appropriations. 

DOI’s BLM was appropriated $1 million in FY 1997, $3 million in FY 1998, and $10 

million in fiscal years 1999, 2000, and 2001 for water quality-related cleanup actions at 

abandoned mine land sites. In addition, states obligated $10.2 million and the Office of 

Surface Mining obligated $5.9 million for emergency reclamation projects at abandoned 

mine lands during 2001. The Office of Surface Mining also distributed $6.9 million to 12 

states for elimination of environmental problems caused by acid mine drainage from 

abandoned coal mines. Although most of these appropriations, which total $33 million, are 

for land reclamation, safety hazards and other non-remediation activities, a portion of these 

funds, perhaps 20 percent ($6 million) is likely to be used for site remediation. Thus, the 

funds available to DOI for remediation of contaminated sites are likely to amount to $26 

million annually ($10 million from CHF + $10 million from cost recovery and cost sharing 

+ $6 million directly funded by bureau programs).

 • USDA funding for priority CERCLA and RCRA activities are supplemented by Hazardous 

Materials Management Appropriations (HMMA). For fiscal year 2003, the department 

requested $15.7 million in HMMA funding, 47 percent ($7.3 million) of which covered 

actual cleanup work. This request is about equal to HMMA appropriations for fiscal years 

2000 and 2001, each of which totaled $15.7 million. Approximately $5.1 million of the 

HMMA request targeted cleanup of abandoned and inactive mine sites on national forest 

lands. Of the total HMMA budget request, approximately 88 percent covered CERCLA 

activities. The remaining 12 percent was allocated to RCRA regulatory compliance, 

including the removal of underground storage tanks. 

A total of $26.7 million in USDA funds also were committed to meet the agency’s 

environmental mission. USDA anticipates that, between 2003 to the end of 2007, it will 

complete 150 CERCLA cleanups. Thus, the upper-bound of funds likely to be available to 

USDA for remediation of contaminated sites is estimated to be about $34 million annually 

($7.3 + $26.7 million).

 • NASA anticipates that 80 percent of its $41 million annual environmental restoration budget 

anticipated for fiscal years 2004-2008, or $32.8 million, will be used for remediation of 

contaminated sites (NASA 2003). 

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• The total anticipated annual budget for the three agencies is $92.8 million, and extrapolating 

this figure to all 17 agencies on the docket results in an estimated annual budget of $133 

million for contaminated site remediation at federal agencies. This figure may underestimate 

the total remediation expenditures, because it includes only some of the potential cost 

recovery and cost sharing that will be available. 

Based on the above analysis, and the assumption that funding remains at $133 million annually, 

it will take 130 to 160 years to remediate the contaminated sites at civilian federal agencies. 

8.6 Remediation Technologies

Little information is available on the technologies used to clean up facilities owned or operated 

by civilian federal agencies. Given the types of environmental problems present, the remediation 

approaches are likely to be similar to those used in other programs, such at RCRA and NPL 

sites. A useful EPA publication Innovative Treatment Technologies: Annual Status Report 

(Eleventh Edition) describes trends in technologies used at NPL, Department of Defense, and 

Department of Energy sites (U.S. EPA 2004). Many of those technologies, in particular those 

implemented at NPL industrial and mining sites, may be implemented at civilian federal agency 

sites. 

To stimulate the use of innovative technologies at federal, including civilian, contaminated sites, 

EPA is fostering the use of federal facilities as testing and demonstration centers. For example, 

several new cleanup technologies are under demonstration at the Kennedy Space Center in 

Florida as part of EPA’s Superfund Innovative Technology Evaluation Program. These 

demonstrations will help to identify cost-effective and easily-implemented technologies for 

treating groundwater contaminated with dense non-aqueous phase liquids. Also, in an effort to 

reduce regulatory and institutional barriers to innovative technology development, EPA is 

working with DOI and the Western Governor’s Association to develop innovative technologies 

for use at mining sites. 

8.7 References

NASA, 2003. Fiscal Year 2004 - Congressional Budget, U.S. National Aeronautics and Space 

Administration, 2004. http://www.ifmp.nasa.gov/codeb/budget 

U.S. CEQ, 1995. Improving Federal Facilities Cleanup, Council on Environmental Quality, 

Office of Management and Budget, October 1995. 

USDA, 2001. USDA Hazardous Materials Management Program: Strategic Plan. U.S. 

Department of Agriculture, December 2001. http://www.usda.gov/da/hmmg 

USDA, 2003. Hazardous Materials Management: Annual Performance Plans, FY 2003, 2001, 

2000. U.S. Department of Agriculture. http://www.usda.gov/da/hmmg 

U.S. DOI, 2001. U.S. Strategic Plan: FY 2000-2005, U.S. Department of the Interior. 

http://www.doi.gov/gpra/doioverviewstratplanv6 

Chapter 8: Civilian Federal Agency Sites Page 8-11
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

U.S. DOI, 2003a. U.S. Department of Interior, Office of Environmental Policy and Compliance 

web site. http://www.doi.gov/oepc

U.S. DOI, 2003b. FY 2003 Annual Performance Plan; FY 2001 Annual Performance Report, 

U.S. Department of Interior. http://www.doi.gov/gpra/2003/01apr03app 

U.S. DOI, 2003c. U.S. Department of Interior. Office of Surface Mining web site. 

http://www.blm.gov/aml 

U.S. DOT, 2002. Performance and Accountability Report: Fiscal Year 2002, U.S. Department of 

Transportation. http://www.dot.gov/perfacc 

U.S. EPA (Environmental Protection Agency), 2003a. “Federal Agency Hazardous Waste 

Compliance Docket.” U.S. Environmental Protection Agency, 68 Federal Register 107, January 

2, 2003. 

U.S. EPA, 2003b. CERCLA Information System, U.S. Environmental Protection Agency, Office 

of Solid Waste and Emergency Response 2003. 

U.S. EPA, 2004. Treatment Technologies For Site Cleanup: Annual Status Report (Eleventh 

Edition), Office of Solid Waste and Emergency Response, Technology Innovation Office, EPA542-R--03-009, February 2004. http://www.clu-in.org/asr

U.S. GAO, 1999. Progress Made by EPA and Other Federal Agencies to Resolve Program 

Management Issues, U.S. General Accounting Office, GAO/RCED-99-111, April 1999. 

U.S. GAO, 2000. U. S. Hazardous Waste: Effect of Proposed Rule’s Extra Cleanup 

Requirements is Uncertain, U.S. General Accounting Office, GAO-01-67, October 2000. 

U.S. GAO, 2003. Long-Term Commitments: Improving the Budgetary Focus on Environmental 

Liabilities, U.S. General Accounting Office, GAO-03-219, January 2003. 

U.S. OMB, 1995. Improving Federal Facilities Cleanup. Office of Management and Budget, 

October 1995. clinton2.nara.gov/OMB/inforeg/iffc-2.html

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Chapter 9 

Demand for Remediation of 

States and Private Party Sites 

The cleanup market includes thousands of sites managed by states and private parties. Nonfederal agency sites that are not being cleaned up under the Comprehensive Environmental 

Response, Compensation, Liability Act (CERCLA), Resource Conservation and Recovery Act 

(RCRA) Corrective Action, and Underground Storage Tank (UST) Programs, but still need 

attention, become the responsibility of state cleanup programs, private parties, or local 

jurisdictions. Most private party sites are remediated under state voluntary cleanup programs 

(VCPs). State sites can vary from sites that are similar to NPL sites to small sites with low levels 

of contamination. 

The majority of states have enforcement 

authority to compel cleanups and state 

cleanup funding mechanisms dedicated to 

financing the cleanup of abandoned sites. It 

has been estimated that as of December 

2000, about 23,000 non-National Priority 

List (NPL) sites were known or suspected 

to be contaminated and need further 

attention requiring additional evaluation 

and/or some level of cleanup (ELI 2002). 

The extent of contamination at these sites is 

largely unknown. However, information in 

this chapter about state sites that have been 

remediated indicates the likely 

characteristics of these sites. 

In addition to direct state cleanups, many 

state sites are cleaned up by private parties 

in accordance with state cleanup standards. 

To encourage private party cleanups, almost 

all states have created voluntary cleanup 

programs that often provide incentives for 

private parties to assess and cleanup their 

sites, with state oversight. Most states have 

also created brownfield programs that target 

the cleanup and redevelopment of 

properties that have been abandoned or are 

underused because of the potential for 

contamination. 

Highlights 

• 

or cleaned up. 

• brownfields grant 

projects, 350,000 to 700,000 of these may require 

• 

annually under state mandatory and voluntary 

control programs. At this rate, 150,000 sites can 

be completed in 30 years. 

• 

estimated to average about $1 billion. If states 

wi

actions, voluntary cleanups, and cost recovery. 

• 

and cleaned up. 

• 

catalyst for other development that use private, 

state, and local funds. EPA's investment in 

has leveraged more than $5 billion in cleanup and 

redevelopment funding. 

• 

coordination of many disciplines and stakeholders, 

with firms and consultants with other specialties. 

• 

data are scant. 

• 

There may be as many as 1⁄2 to1 million brownfield 

sites, 85–90% of which have not been evaluated 

Based on data from EPA’s 

cleanup. The exact percentage is unknown. 

About 5,000 cleanups are typically completed 

Annual expenditures for these cleanups are 

th limited funds want to accelerate the pace of 

work, they will likely have to rely on private party 

The Brownfields Revitalization Act will likely lead 

to an expansion in the number of sites assessed 

The federal brownfields program has served as a 

brownfields, more than $700 million since 1995, 

State site cleanup and redevelopment involves 

which has led remediation firms to form alliances 

The use of advanced remediation techniques 

appears to have grown in recent years, although 

There is a need to screen many sites to determine 

whether or not they have contamination problems. 

Chapter 9: State and Private Sites Page 9-1 
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In recent years, an average of about 5,000 cleanups have been completed annually under direct 

state cleanups, voluntary cleanup programs, and brownfield programs. During 2000, states spent 

more than $505.6 million (38 states reporting) for remediation of NPL and non-NPL sites. Most 

of these funds were for direct state cleanups at non-NPL sites. Despite this progress in 

completing cleanups, the backlog of sites to be cleaned up has been stable, primarily because 

new sites are still being identified. 

9.1 Programs Addressing State Sites

The cleanup of state and private party sites is strongly influenced by a myriad of state and 

federal programs that seek to encourage site investigations, cleanup, and redevelopment. The 

structure and operations of these programs vary widely from state-to-state and many of them 

preexist the federal brownfield program. These programs typically can require cleanups of 

certain types of contamination and provide incentives for cleanup, redevelopment, and long-term 

stewardship. There are two types of state hazardous waste programs: programs that primarily 

address enforcement issues and oversee cleanups of abandoned sites, and state voluntary cleanup 

and brownfield programs. In addition, federal programs actively encourage and assist states in 

their efforts to evaluate and clean up contaminated sites. 

9.1.1 State Hazardous Waste Cleanup Programs 

Almost all states have established hazardous waste programs to ensure that potentially 

contaminated sites are assessed and, if necessary, cleaned up. Information on these state 

programs, numbers of contaminated sites, and the status of those sites has been derived from 

existing published information and state web sites. Contacting individual states to obtain data 

was outside the scope of this study. 

Three key sources provide extensive information about the state programs, An Analysis of State 

Superfund Programs: 50-State Study, 2001 Update, and An Analysis of State Superfund 

Programs: 50-State Study, 1998 Update, and An Analysis of State Superfund Programs: 50-State 

Study, 1995 Update. These studies, prepared by EPA and the Environmental Law Institute are 

based on information collected from the 50 states, Puerto Rico, and the District of Columbia. For 

convenience, these are referred to as 52 “states.” These studies describe each of the states’ 

programs, including enabling legislation, enforcement provisions, staffing levels, funding, and 

other aspects of the programs. Exhibit 9-1, which is based on data in the 50-State Study 

summarizes the prevalence of the major state programs. 

Unlike some environmental statutes which mandate minimum national standards that could be 

administered by the states after their programs are approved by a federal agency, each state 

cleanup program is developed according to the state’s criteria. Nevertheless, most state 

hazardous waste programs include authorities similar to the federal Superfund program. They 

typically include provisions for emergency response and long-term remedial actions; cleanup 

funds or other mechanisms to finance site investigation and remedial activities; enforcement 

authorities to compel responsible parties to conduct or pay for studies and site remediations; staff 

to administer state-lead cleanup activities and to oversee remediations conducted by other 

parties; and efforts to ensure public participation in decision-making regarding site cleanup and 

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reuse. About half the states also authorize long-term stewardship under their statutes (ELI 2002). 

Many states have been cleaning up land contaminated by hazardous substances, or overseeing 

such cleanups, for about two decades. 

Exhibit 9-1. State Cleanup Program Summary a 

State Program Number of States Explanation 

Cleanup Funds 49 Idaho, Nebraska, and the District of Columbia do not 

have cleanup funds. 

Voluntary Cleanup 

Program (VCP) 

50 North Dakota and Vermont do not have formal 

programs; however, they allow private parties to 

initiate voluntary cleanups. 

Brownfields Program 31 In addition to the 31 states with formal brownfield 

programs, 14 target brownfields through their VCPs. 

Long-term Stewardship 

Program 

41 Most of these states have committed scant 

resources to date. 

a Based on 50 states plus Puerto Rico and the District of Columbia, referred to as “52 states.” 

Sources: U.S. EPA, 2002, An Analysis of State Superfund Programs: 50-State Study, 2001 Update, November 

2002. 

State Cleanup Funds 

As of December 2000, 49 states, including Puerto Rico, have established cleanup funds or 

provide another mechanism to pay for the cleanup of non-NPL sites where no responsible party 

is available, able, or willing to do so. Only Idaho, Nebraska, and the District of Columbia do not 

have an authorized state cleanup fund. Thirty-six states have more than one fund for cleaning up 

contaminated waste sites, resulting in a total of 117 state cleanup funds. There are a variety of 

reasons that states have more than one fund. A state may have multiple funds to differentiate 

sources or uses of funds. For example, funds may receive money through appropriations, 

penalties, cost recoveries, or proceeds from a hazardous waste fee. Some funds may apply only 

to specific uses, such as for emergency response, brownfields, a voluntary cleanup program, or a 

specific type of site or waste. For example, a number of states have established funds dedicated 

to dry cleaning sites. 

State Site Databases 

State site lists are a potential source with which to evaluate the extent of the state remediation 

market. Many state statutes authorize the development of a priority list, inventory, or registry of 

state sites. Some states use these compilations to determine the order in which sites will be 

cleaned up. By the end of 2000, about 40 states had some kind of list, registry, or inventory, with 

a total of 15,000 sites. However, because the approaches and definitions used by the states vary 

widely, the aggregation of these data is neither useful for this market assessment nor to make 

comparison among states. Some states list all known and suspected sites, others include only 

those that have completed a long evaluation process, and others include only sites where cleanup 

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is funded directly by the state. Some states’ lists may be useful for contractors seeking 

opportunities for site investigation or remediation work in selected states. 

Long-Term Stewardship 

Forty-one state cleanup programs explicitly address long-term stewardship for sites where 

hazardous substances are to remain in place at levels that do not allow for unrestricted use. The 

statutes of these states are designed to protect the public health, safety, and the environment at 

such sites. Institutional controls are the most common mechanism used for long-term 

stewardship. These include property-law-based restrictions such as restrictive covenants and 

easements; information systems such as signs, educational materials, published notices, warnings 

about consumption of fish or wildlife, and site databases; and governmental controls such as 

zoning, local ordinances, building permits, and groundwater and well-drilling restrictions. 

Although forty-one states have long-term stewardship programs for one or more of their cleanup 

programs, most states have committed scant resources to monitoring institutional controls. 

Liability 

Most state statutes provide a means for charging parties, such as owners, operators, generators, 

and transporters, with liability for cleanups. These are the same parties usually charged under 

CERCLA. Liability may be charged under state hazardous waste laws or under another statute, 

such as a solid waste, water pollution control, or imminent danger statutes. 

Many state statutes include provisions for retroactive, strict, and/or joint and several liability 

(CERCLA has all three). Forty-three states impose retroactive liability. That is, the state can 

impose liability for cleanup of hazardous substances disposed of prior to the enactment of the 

statute. Forty-one states have strict liability standards and 36 states use joint and several liability 

to allocate liability among multiple responsible parties. Under a strict liability standard, liability 

is based solely on the occurrence of a release and does not require proof of fault, such as through 

negligence. Under joint and several liability, the state may pursue one or more responsible party 

for the full amount of the cleanup. These provisions are potentially powerful incentives for 

companies to undertake site remediations. 

Given the prevalence of strict, joint and several, and retroactive liability, the potential for 

cleanup cost liability is a significant obstacle to redevelopment and, in some cases, to cleanup. 

Many state voluntary cleanup and brownfield programs include mechanisms for mitigating the 

potential liability of responsible parties, prospective purchasers, owners, and developers. These 

programs are described in the next section. 

9.1.2 Voluntary Cleanup and Brownfield Programs 

Voluntary cleanup programs, a major component of state cleanup efforts, encourage private 

parties to voluntarily clean up sites rather than expend state resources or cleanup fund money on 

enforcement actions or remediations. VCPs are designed to reduce factors that tend to discourage 

voluntary cleanups, such as liability for cleanups, lack of control over the remediation, and cost. 

These programs began as innovative programs created by states to respond to requests by 

landowners and others for state assistance in facilitating private cleanups of their sites. By the 

end of 2000, 50 states (including the District of Columbia and Puerto Rico) had established 

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formal VCPs through statute, regulation, or policy. Although the structure, formality, and 

operating practices of VCPs differ from state-to-state, there are a number of common elements. 

States will generally establish eligibility requirements for participation, clear cleanup standards, 

and closure procedures; provide timely oversight; and offer incentives to encourage 

participation. 

The most common forms of incentives are liability release mechanisms, an expedited cleanup 

oversight process, and financial incentives, such as low-interest loans, grants, and tax credits. 

Liability protection is the most common of these incentives. Liability protection is provided by 

covenants not to sue, no further action letters, certificates of completion, and other mechanisms. 

States typically limit the protection only to contamination addressed by the cleanup activities, 

excluding unknown or pre-existing contamination, or new releases of hazardous substances. The 

Small Business Liability Relief and Brownfields Revitalization Act, signed into law in January 

2002, clarifies state and federal roles for overseeing cleanups by providing federal CERCLA 

liability protection for parties who conduct a cleanup of certain properties under a state response 

program designed specifically for protection of human health and the environment. Prior to this 

provision, a state could provide state liability protection for brownfields cleaned up under its 

own laws, but a state could not provide federal liability protection. 

Most states require a participant to reimburse the state for the cost of overseeing a voluntary 

cleanup. Most states also supplement the fees with state and federal funds. The 2002 brownfields 

law also provides states with new resources for VCPs. As much as $50 million may be 

appropriated annually over the next four years to states and tribes to help them establish and 

enhance VCPs and similar response programs. 

Of the 50 states that have VCPs, 14 target brownfields through their VCPs, and 31 states have 

established brownfield programs that are separate from their VCPs. States define brownfields in 

a variety of ways, but the term typically refers to industrial or commercial facilities that are 

abandoned or underutilized due, in part, to environmental contamination or fear of 

contamination. This differs somewhat from the definition under the 2002 brownfields law (See 

Section 9.1.3 below). The scope of the various state programs also vary. States use a wide range 

of approaches and tools to facilitate the investigation and cleanup of brownfields. For example, 

some states emphasize site investigations or financial incentives, but do not authorize cleanups, 

while others may take a more active role in remediations. 

It is often difficult to distinguish between a brownfield program and a VCP. Many brownfield 

sites are addressed by volunteers. Also, some states are reluctant to identify brownfields that are 

not already being remediated because property owners are concerned about the stigma associated 

with this designation, which may affect property values. This reluctance has led some states to 

carefully control lists or to not publish a list of sites. State brownfield programs are 

supplemented by a substantial federal brownfields initiative, which is described in the next 

section. 

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9.1.3 Federal Initiatives Affecting State Cleanups 

The federal government has actively encouraged and assisted states in their efforts to clean up 

their contaminated properties. EPA’s program dedicated to help states address brownfields has 

already affected a large number of sites and will probably affect many more in the future. EPA 

defines “brownfield” as “real property, the expansion, redevelopment, or reuse of which may be 

complicated by the presence or potential presence of a hazardous substance, pollutant, or 

contaminant.” These sites are usually abandoned, idled, or under-used industrial and commercial 

facilities. Many brownfields are located in urban areas and are generally associated with ­

declining property values, increased unemployment, and movement of industries to the suburbs. 

EPA estimates that there are between 500,000 and one million brownfield sites. 

Where past use of a site raises the possibility that the site may be contaminated, fear of being 

caught in the Superfund liability net often stymies further development at the site. Lenders, 

developers, and prospective purchasers are discouraged from getting involved with a site 

because of the risk of a delay in site development or having to pay cleanup costs. Current 

brownfield owners often are not willing to conduct an assessment of their sites for fear of finding 

contamination that may have been a result of their activities or those of past owners. Many 

brownfields end up as the property of local governments through foreclosure. 

The central focus of the federal effort is the Brownfields Program and Small Business Liability 

Relief and Brownfield Revitalization Act, which was signed into law in January 2002. 

Brownfields Program 

The EPA Brownfields Program provides technical and financial support for brownfields 

revitalization. EPA's brownfields efforts are based on four themes: protecting the environment; 

promoting partnerships; strengthening the marketplace; and sustaining reuse. EPA's investment 

in brownfields, more than $700 million since 1993, has leveraged more than $5.1 billion in 

cleanup and redevelopment funding, generated more an 25,000 jobs and assessed more than 

4,300 properties. The Small Business Liability Relief and Brownfields Revitalization Act (2002) 

provides the Brownfields Program with Congressional authorization, increased funding, 

strengthened liability protections for certain property owners, and expanded assistance for State 

and Tribal response programs. 

First, the Brownfields Program protects the environment by providing grants for assessment and 

cleanup to states, tribes, local governments, redevelopment authorities, and in some cases, nonprofit organizations. Assessment grants of up to $200,000 per entity can fund efforts to 

inventory, characterize, assess, and conduct planning and community involvement related to 

brownfields. Cleanup Revolving Loan Fund grants of up to $1million per eligible entity help 

capitalize local funds that can provide both loans and subgrants for property cleanup. Direct 

cleanup grants were added by the brownfields law and provide up to $200,000 per site to public 

and nonprofit entities, who must own the site to be eligible. The brownfields law added 

petroleum contamination to the list of sites eligible for brownfields funding and directed that 25 

percent of brownfields funds be used for petroleum sites. The Brownfields Program also gives 

technical assistance and targeted assessments to help communities. 

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Partnership efforts are a second key aspect of the Brownfields Program. At the federal level, the 

Brownfields National Partnership brings together more than 20 federal agencies to help 

communities with issues related to brownfields revitalization. For example, the Department of 

Housing and Urban Development and the Economic Development Administration provides 

funds to help with the redevelopment activities beyond EPA's programs, such as acquiring 

property and helping rebuild infrastructure. The National Oceanic and Atmospheric 

Administration leads an interagency "Portfields" project that focuses on interagency 

collaboration to revitalize port and waterfront areas. The Brownfields Program provides $50 

million a year to support state and tribal response programs and has signed Memoranda of 

Agreement with many states to clarify regulatory responsibilities. The Brownfields Program 

works with a wide range of organizations to conduct research, training, and technical assistance 

for communities, including grants of up to $200,000 to communities for Brownfields Job 

Training. The annual Brownfields Conference, co-sponsored by EPA, brings together the entire 

range of stakeholders—more than 4,200 people attended Brownfields 2003 in Portland, Oregon. 

Third, the Brownfields Program works to strengthen the private sector marketplace for 

brownfields. The brownfields law provides liability protections for innocent landowners, 

prospective purchasers and contiguous property owners. Enforcement policies and tools have 

helped change perceptions that discouraged brownfields revitalization. As required under the 

brownfields law, EPA is developing regulatory standards for "all appropriate inquiries" that will 

specify actions property developers and owners must take prior to a property transfer to qualify 

for liability protections. The private sector is further supported by financial tools such as 

brownfields tax incentives and new insurance and risk management vehicles. 

Lastly, the Brownfields Program is a strong force for sustainable development. A study 

conducted by George Washington University shows that every acre of brownfields redeveloped 

saves 4.5 acres of greenspace. The Brownfields Program has worked closely with Smart Growth 

advocates and Green Building experts to conduct pilot projects and encourage redevelopment 

that provides long-term economic and environmental benefits. 

9.2 Factors Affecting Demand for Cleanups

The state market for remediation services is largely dependent upon the pace of development, the 

commitment and ability of states and private companies to establish and manage hazardous 

waste programs and to finance cleanups, and the extent of state and federal efforts to encourage 

or compel responsible parties to clean up sites. 

• Increases and decreases in state cleanup funds will affect the number and complexity of 

remedial actions undertaken by the states. Total funding to state cleanup funds has remained 

steady in recent years, which indicates that many states will have to rely on their ability to 

either compel private parties or encourage voluntary cleanup actions. State assurance funds 

may be impacted by economic and political conditions that influence state revenues.1 

In a survey of 231 cities of all sizes published in 2000, 90 percent of the cities identified lack of funding for 

cleanup as the most important impediment to cleanup and redevelopment. (U.S. Conference of Mayors 2000). 

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• Although total funding to state cleanup funds has remained steady, there have been shifts in 

funding levels among different types of funds. For example, dry cleaner funds have grown 

in recent years.

 • The Brownfields Revitalization Act is expected to expand the number of sites to be assessed 

and/or cleaned up. The law greatly mitigates the potential liability of innocent (not 

responsible for pollution) property owners; reduces financial uncertainties for investors and 

property owners; and directly funds various projects and programs, which serve as 

examples, case histories, and lessons learned for other sites.

 • By removing obstacles that cause investment capital to flee from brownfields, the 

Brownfields Revitalization Act is expected to foster new opportunities for site 

characterization, cleanup, and redevelopment, especially in the following situations: 

÷ Communities that use smart growth and infill strategies, and that are seeking to improve 

community-wide quality of life; 

÷ Sites with “relatively low risk” petroleum contamination, which previously were 

generally not eligible for federal assistance; 

÷ Sites where cleanup and development have been hampered by an inability to obtain 

financing or insurance because of uncertainties in remediation costs; 

÷ States without effective voluntary and other cleanup programs or those whose programs 

have been hampered by a lack of funding; and 

÷ Sites where cleanup and redevelopment had previously been hampered by a potential 

for Superfund liability.

 • The new law strengthens liability protections for innocent purchasers, contiguous property 

owners, and prospective purchasers, thereby encouraging more brownfield site assessments, 

cleanups, and redevelopment. The 1986 amendments to CERCLA (SARA) attempted to 

provide protection to “innocent landowners” through the addition of Section 101(35). This 

provision applies if a party that acquired real property after the disposal of hazardous 

substances did not know about the hazardous substances on, in, or at the property when it 

was acquired. However, this authority was used only infrequently because it was difficult to 

establish a legal defense. The new brownfields amendments provide significant statutory 

changes affecting the potential liability of owners, developers, and prospective purchasers of 

real estate. It is expected that the law will reduce the potential liability and transaction costs 

of owners, developers, and prospective purchasers of brownfield sites.

 • The pace of development in a community or region will influence the number of brownfield 

and voluntary sites that need to be evaluated and/or cleaned up. Because there are an 

estimated hundreds of thousands of potentially contaminated brownfield sites that have not 

been located, most development in populated areas are likely to encounter contaminated 

sites from time-to-time. 

• As neighborhoods become revitalized and as communities grow, the demand for, and price 

of, land will increase. Higher property values can support more investments in site cleanups. 

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• Given the potentially large number of brownfields compared to the number of voluntary 

cleanup program and brownfield sites addressed in recent years (7,100 cleanups underway 

and 2,200 completed in FY 2000), brownfield cleanups are likely to continue for many 

years.

 • The growing popularity of smart growth policies is likely to advance the demand for the 

state and brownfield cleanups, since infill development and the preservation of greenfields 

are primary components of smart growth programs.

 • Forty-one states have long-term stewardship programs for one or more of their cleanup 

programs. These programs are important because of the widespread use of remedies that 

allow hazardous substances to remain on site, so long as land-use restrictions are 

implemented. States have been establishing and enhancing their long-term stewardship 

programs. One of the greatest needs are systems to keep track of sites requiring stewardship.

 • Considering the growing use of risk-based corrective action and the practice of leaving 

waste on site, there is a perceived need for enhancement of long-term stewardship programs. 

Over approximately the past decade, the U.S. capacity to address brownfields has grown 

enormously. A decade ago, few developers and investors were willing to consider potentially 

contaminated properties. Today, there is an expanding cadre of developers, planners, consultants, 

engineering and construction firms, attorneys, and public officials with the expertise to evaluate, 

cleanup, and revitalize brownfield properties. The increasing acceptance of the practicability of 

cleaning up and revitalizing brownfield sites has the potential for enlarging the market for site 

characterization and cleanup services. 

9.3 Number and Characteristics of Sites 

This subsection presents estimates of the number of state and private party sites expected to 

require remediation under state mandatory hazardous waste remediation programs and voluntary 

cleanup and brownfield programs. 

9.3.1 State Mandatory Hazardous Waste Programs 

The 50-State Studies present the results of surveys in which each state was asked to identify the 

total number of “known and suspected sites” and “sites needing attention.” The number of 

known and suspected sites generally is the largest number of potentially contaminated sites 

known to the state and includes, in some states, sites that have not yet undergone any type of 

assessment. This category is useful in determining the outer limit of the universe of state sites. 

The sites needing attention are known and suspected sites that have been evaluated by the state 

and determined to require some level of further evaluation or cleanup. This category is the best 

indicator of the workload facing each state’s cleanup program. The studies do not present 

estimates of the number of sites that definitely require remedial action. Exhibit 9-2 presents 

trends in these variables and Exhibit 9-3 shows each state's estimate for both categories of sites. 

Chapter 9: State and Private Sites Page 9-9
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

The total number of known and suspected sites reported in 2000 was 63,000 (up from 59,0002 

in 1997 and down from 79,000 in 1995). Because a number of states have reclassified their sites 

over the years, it is difficult to establish a firm trend. However, it appears that the universe of 

sites is stable and that the states are continuing to identify new sites. The number of known and 

suspected sites ranges from zero to 5,416 (Connecticut). Twenty-six states reported increases in 

known and suspected sites while eight reported decreases. The states with the largest increases 

between 1997 and 2000 were Connecticut, Florida, Louisiana, Missouri, New Mexico, Oregon, 

Rhode Island and South Carolina; and the states with the largest decreases were Alaska, Arizona, 

New Jersey, Washington, and Wisconsin. 

Although states are Exhibit 9-2. Sites in State 

progressing to clean up 

their sites, they continue 

to identify new ones. The 

total number of sites 

needing further attention 

in 2000 was 23,000, an 

increase from 19,000 in 

1997.3

 During this time, 

states completed cleanup 

of over 19,000 sites. 

While some of the data 

reflects progress in 

completing cleanups, it 

also reflects 

reclassification of sites by 

some states and a decline 

in the number of states 

reporting. The number of 

sites needing attention 

ranges from zero to 3,900 (New Jersey).Only five states report having more than 1,000 sites 

needing attention– Connecticut, Florida, Kentucky, Massachusetts, and New Jersey. 

Hazardous Waste Programs 

Of the sites reporting in both 1997 and 2000, 23 had increases and 12 states had decreases in 

sites needing attention. The states with the largest increases between 1997 and 2000 were 

Connecticut, Florida, Georgia, Kentucky, and South Carolina. The states with the largest 

decreases were Alaska, Arizona, New Jersey, Washington, and Wisconsin. After considering 

reporting discrepancies, such as those in the footnotes, it appears the total universe of sites 

needing attention is stable, or growing slightly. (50-State Study 2000). 

2 The 1998 50-State Study reported 69,000. However since then, the State of New Jersey subtracted 10,000 

home-owner tanks sites from the list. 

3 The 1998 50-State Study reported 23,000; however, the 2000 study revised the data, primarily because of 

reclassification of sites and because two states that reported in 1997 did not report in 2000. Counting only the states 

that provided data in both years, the total for 1997 is 20,100 and the total for 2000 is 22,700. 

Chapter 9: State and Private Sites Page 9-10 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 9-3. Number of Non-NPL State Hazardous Waste Sites 

Known & Suspected Sitesa Sites Needing Attentionb 

State 1997 2000 1997 2000 

Alabama 700 730 125 125 

Alaska 1,625 968 1,206 783 

Arizona 900 71 75 38 

Arkansas 363 415 98 67 

California 3,247 3,603 420 522 

Colorado 624 495 178 200 

Connecticut 3,029 5,416 668 2,107 

Delaware 600 532 185 331 

District of Columbia NA NA NA NA 

Florida 1,900 2,646 1,094 2,460 

Georgia 1,012 1,280 126 422 

Hawaii 524 558 103 105 

Idaho NA NA NA NA 

Illinois 5,000 5,000 140 159 

Indiana NA 200 NA 61 

Iowa 400 475 200 210 

Kansas 720 NA 484 NA 

Kentucky 1,900 2,200 850 1,500 

Louisiana 410 730 120 130 

Maine 465 475 128 83 

Maryland 440 440 33 33 

Massachusetts 2,679 2,305 2,679 2,305 

Michigan NA NA 2,789 NA 

Minnesota 3,000 3,000 219 100 

Mississippi 960 1,100 500 500 

Missouri 1,475 2,321 225 250 

Montana NA NA 187 288 

Nebraska 400 475 200 225 

Nevada 129 112 129 12 

New Hampshire 474 388 474 388 

New Jersey c 5,177 5,000 4,915 3,900 

New Mexico 344 1,210 133 153 

New York 1,567 1,628 769 851 

North Carolina 1,040 1,122 793 730 

North Dakota NA NA NA NA 

Ohio 1,460 1,884 403 403 

Oklahoma 793 850 124 170 

Oregon 1,933 2,469 306 499 

Pennsylvania 50 50 20 20 

Puerto Rico NA NA NA NA 

Rhode Island 400 1,200 100 150 

South Carolina 603 1,037 150 516 

South Dakota 1,424 1,342 NA 229 

Tennessee 1,360 1,501 234 210 

Texas 388 611 52 48 

Utah 325 390 40 50 

Chapter 9: State and Private Sites Page 9-11 
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Exhibit 9-3. Number of Non-NPL State Hazardous Waste Sites (Continued) 

Known & Suspected Sitesa Sites Needing Attentionb 

State 1997 2000 1997 2000 

Vermont 362 390 255 250 

Virginia 2,015 2,015 411 411 

Washington 1,493 946 1,006 623 

West Virginia 600 NA 150 NA 

Wisconsin 5,000 3,000 600 NA 

Wyoming 140 NA NA NA 

Total 59,450 62,580 24,096 22,617 

Notes: 

a Known and suspected sites are those that states have identified as being potentially contaminated. Many of these sites 

will not require action beyond a preliminary assessment. Site numbers are derived from Table IV-3 of the 2001 50-

State Study and Table V-3 of the 1997 50-State Study, unless otherwise noted. The totals include an unknown, but 

small, percentage of UST and RCRA sites. b Sites needing attention are those known and suspected sites that have been assessed and determined to require 

further assessment or cleanup. Many of these sites will require removal or remedial actions. Site numbers are derived 

from Table IV-3 of the 2001 50-State Study and Table IV-3 of the 1997 50-State Study, unless otherwise noted. The 

totals include an unknown, but small, percentage of UST and RCRA sites. c The 1998 50-state Study reported 69,000 sites in New Jersey. However, since then, the state subtracted 10,000 

homeowner tank sites from the list. 

NA Indicates that data were not provided. 

Sources: 

Environmental Law Institute, An Analysis of State Superfund Programs: 50-State Study, 2001 Update, November 

2002. 

Environmental Law Institute, An Analysis of State Superfund Programs: 50-State Study, 1998 Update. 

The total number of sites determined to need further attention includes an unknown but small 

percentage of RCRA and UST sites, which are addressed in Chapters 4 and 5 of this report. 

During collection of data from the states, authors of the 50-State Study requested that the states 

exclude RCRA and UST sites from their reports, if they could. However, some states were 

unable to separate the RCRA and UST site data from other hazardous waste sites. 

9.3.2 Voluntary Cleanup and Brownfield Programs 

The 50-State Studies also asked states to report the number of voluntary cleanup and brownfield 

sites. Exhibit 9-4 presents the national totals from the survey data. Since the inception of their 

programs, states have completed cleanup at 11,600 sites under their voluntary programs and 

17,300 sites under their mandatory programs. In FY 2000, states completed 2,200 voluntary 

cleanups and 2,400 mandatory-program cleanups, and had a total of 15,600 cleanups underway. 

By the end of 2000, the reporting states had identified 18,700 brownfields, had cleanups 

underway at over 1,000 brownfield sites, and had redeveloped over 700 sites. To avoid double 

counting some sites, this study does not add the data on brownfield sites to the above figures, 

since many are cleaned up under voluntary and mandatory programs. Nevertheless, many sites 

identified by a brownfields program may not have been reported on a voluntary or mandatory 

program list. Thus, the estimates of total state and private party site market may be understated 

somewhat. Another factor that may contribute to the underestimation of brownfields sites is the 

fact that some states are reluctant to identify brownfields that are not already being remediated 

Chapter 9: State and Private Sites Page 9-12 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

because property owners are concerned about the stigma associated with this designation, which 

may affect property values. 

Based on these data, total state cleanups under all state programs has averaged approximately 

5,000 per year in recent years. Despite the progress in completing many cleanups in recent years, 

the known number of sites listed as needing attention or entered into a voluntary program has 

remained approximately stable. As of the end of FY 2000, this inventory of sites was about 

30,000 (22,600 from Exhibit 9-3 +7,100 from Exhibit 9-4). This apparent discrepancy is 

attributed to the fact that state 

regulatory agencies are Exhibit 9-4. Voluntary and Mandatory 

continuing to identify new sites 

and new sites are continuing to 

enter voluntary and brownfields 

programs. In addition, some of 

the 18,700 brownfield sites 

identified by states are not 

included in this figure, in order to 

avoid potential double-counting 

of some sites. Thus, the currently 

identified inventory of sites likely 

to need remediation (30,000) is 

probably underestimated. 

Based on the above data, about 

44,500 state sites have been 

identified, including those that 

have completed or are undergoing 

remediation. Although it is 

anticipated that many brownfields 

will not require remediation, the actual number is unknown. An indication of the percentage of 

sites needing cleanup is provided from data EPA has collected from recipients of EPA 

brownfields pilot grants. Of 5,000 sites targeted by previous grants, about two-thirds required 

further investigation and/or remediation beyond a Phase I and Phase II site assessment (EPA 

2003). This figure implies that, even if the percentage of future sites needing cleanup is lower, it 

is still likely to represent a substantial number of sites; and at the current rate of 5,000 cleanup 

completion annually in all state programs, it will take many years to remediate all the brownfield 

sites. 

Cleanup Program Status 

9.3.3 Contaminants and Media

A central source of information on the types and quantities of contaminants and media found at 

state sites is not available. Three sources provide information on technologies used at state sites 

across the country. Although none of these sources is based on a comprehensive survey, they 

provide a picture of the types of contaminants and technologies likely to be found at state sites. 

In addition, some information on contaminants found are available from a number of states. 

Chapter 9: State and Private Sites Page 9-13 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

The first source, The XL Environmental Land Reuse Report 2002, and The XL Environmental 

Land Reuse Report 2001, are reports on a unique data collection conducted by XL 

Environmental, Inc. and the International Economic Development Council. These studies are 

based on a literature search of media coverage of brownfield-related stories. The researchers 

used online newspaper and journal archives, such as Lexis-Nexis, to search for articles that 

mention brownfields issues. The search identified 331 brownfield-related articles between July 

2001 and June 2002 discussing 428 brownfield sites; and 317 articles between July 2000 and 

May 2001 discussing 346 sites. Chemicals, metals, and petroleum are the most frequently 

mentioned contaminants. Solvents and pesticides were also an issue at some sites. (Exhibit 9-5) 

The second source is the Brownfields Management System, a database containing information 

about brownfield properties that are in EPA’s grant programs. As of December 2002, 

contaminant data are available for only approximately 90 sites. Metals are the most frequently 

identified category of pollutant. VOCs, SVOCs (including PAHs and PCBs) and petroleum 

products were also frequently identified. 

Exhibit 9-5. Contaminants Found at a Sample of Brownfield Sites 

Contaminant 2001 2002 Total 

Number Percent Number Percent Number Percent 

Chemicals 86 25% 56 13% 142 18% 

Metals 61 18% 25 6% 86 11% 

Other 55 16% 43 10% 98 13% 

Petroleum 35 10% 50 12% 85 11% 

Solvents 13 4% 10 2% 23 3% 

Pesticides 4 1% 3 1% 7 1% 

No. of Sites in 

sample a 346 428 774 

a Not all articles provided information on contaminants. Thus, this data is an indication of the types of contaminants 

and perhaps their relative frequency, rather than a precise accounting. There may be more than one contaminant 

reported per site. 

Source: XL Insurance, Inc. and the International Economic Development Council, The XL Environmental Land 

Reuse Report 2002, and The XL Environmental Land Reuse Report 2001. XL Environmental, Inc. 

The types of contaminants present at some state sites can also be inferred from sites listed in 

EPA's CERCLA Information System (CERCLIS), EPA's database of potentially contaminated 

sites. EPA has performed preliminary assessments at these sites to screen them for potential 

listing on the federal NPL. The majority of these sites (those not listed on the NPL) are deferred 

to the states for action. CERCLIS data show that the most prevalent wastes at these sites are 

organic chemicals, metals, solvents, and oily waste (U.S. EPA 1991). 

Chapter 9: State and Private Sites Page 9-14 
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In addition to national data sources, some states with established, well-funded programs are able 

to produce this type of information. For example, the California Department of Toxic Substances 

Control, within the state's Environmental Protection Agency, publishes extensive information 

about its site mitigation programs as well as access to its Site Mitigation and Brownfields Reuse 

Program Database on its web site. The database contains information on almost 10,000 potential 

and known sites (CALEPA 2003). 

9.4 Estimated Cleanup Costs

The cost of cleaning up state mandatory and voluntary cleanup program sites is determined by 

the number of state sites and the amount of remediation work at each site. As described in 

Section 9.3, the number of potential state sites is so large relative to state and private resources 

that it is likely to take a number of decades to complete all the cleanups. Thus, a key determinant 

of cleanup activity in a given year will be resources available, primarily in state cleanup funds, 

which account for most state-funded cleanups. This section describes the trends in state 

expenditures, the status of state cleanup funds, and an estimate of the total cost to complete the 

cleanup of all known and likely to be discovered state sites over a period of 30 years. 

9.4.1 Status and Capacity of State Cleanup Funds 

A fund is an essential element of a state's program to clean up sites. It is a readily available 

source of money separated from other state operations that allows activities to continue without 

the need for annual appropriations or other legislation. It allows a state to avoid disruptions to 

cleanups and to investigate, plan, design, and conduct emergency response and remedial actions 

at sites where immediate action is required or where responsible parties are unavailable, unable, 

or unwilling to conduct or pay for remedial actions. Forty-nine states have established cleanup 

funds or provided a mechanism for the state agency to pay for one or more types of cleanup 

activities at non-NPL sites. Idaho, Nebraska and the District of Columbia are the only states 

without cleanup funds that are authorized to pay for cleanups. Although most state-financed 

cleanups are paid from a state cleanup fund, some are funded by direct appropriations. Thus, the 

estimate of state expenditures may understate the actual expenditures. 

The combination of fund balances, additions to funds, and expenditures can indicate the 

capability and stability of a state cleanup program. Exhibit 9-6 compares the fund balances, 

additions to funds, and expenditures of the states in 1995, 1997, and 2000. Total fund balances 

for all states in 2000 was $1.2 billion. The trends in fund balances are confounded by the fact 

that in each survey there are some states that do not provide data and they differ from one survey 

to another. Comparing only the states that provided data in both 1997 and 2000, the decrease 

would be about 10 percent. Fund balances have been declining since 1990. 

Most of the state fund balances (including bonding authority) are concentrated in a relatively few 

states. In 2000, eight states (Alaska, California, Massachusetts, Michigan, New Jersey, New 

York, Pennsylvania, and Texas) accounted for $909 million (73.5 percent) of the total fund 

balances for all states. This concentration has been observed since this survey was first 

conducted in 1991. The annual contributions to state funds fluctuated from year to year, but have 

Chapter 9: State and Private Sites Page 9-15 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

averaged between $400 and $500 million. As with fund balances, the amounts added to funds are 

concentrated in a relatively few states. 

Exhibit 9-6. State Fund Activity 

1995, 1997, and 2000 ($ millions) 

1995 1997 2000 

Total Fund Balances a $1,464.9 $1,413.0 $1,240.0 

Additions to Funds $444.6 $538.3 $436.2 

Expenditures $386.1 $565.1 $505.6 

Obligations $363.4 $448.0 $564.4 

Number of Known and Suspected Sites 79,387 59,000 63,000 

Number of Sites Needing Attention 29,000 24,000 23,000 

a Fund balances include both money in the fund and authority to sell bonds to raise additional monies. The 

expenditures and obligations totals are likely to be understated for two reasons: Between 35 and 38 states out 

of 49 provided 2000 data for most of these items. The response rate for 1997 was higher. In addition, some 

states did not report expenditures for all their funds. 

Exhibit 9-7 presents the Superfund balances for each state as of December 2000 and 1997 and 

provides the total expenditures and obligations of funds by each state for hazardous waste 

activities in 2000 and 1997. The state fund balances totaled $1.2 billion in 2000, including bond 

authorizations (authority by state law to issue bonds and spend the proceeds on cleanups). While 

the average state site cleanup costs less than a quarter million dollars, many sites can cost more 

than $1 million. While almost all states have some cleanup funds, fund balances in some states 

are quite small. These funds could pay for little more than emergency responses and removal 

actions. At the end of 2000, 6 states had fund balances of less than $1 million (Alabama, Iowa, 

Mississippi, North Dakota, Oklahoma, and Utah). Another 8 states had balances between $1 

million and $5 million; 3 between $5 million and $10 million; 15 between $10 million and $50 

million; and 8 had balances over $50 million. 

Although a state's fund balance indicates its ability to pay for a cleanup at any given time, this 

indication is only an approximation of cleanup activity in a state in a given year. The level of 

cleanup activity also depends on the rate that funds flow into and out of the fund, which differs 

from one state to another. Thus a state that rapidly replenishes its funds, for example by 

recovering cleanup costs from responsible parties, would have a high level of cleanup activity 

relative to the balance of the fund at any given time. Also, states may supplement funds with 

appropriations for specific projects. 

Another indication of state’s ability to manage mandatory cleanups and oversee voluntary 

cleanup programs is the level of state cleanup program staffing. In 2000, total state cleanup 

program staffing (3,344) was about the same level as in 1991 (3,394). Over those years, they 

have fluctuated only within a range of about 3 percent. 

Chapter 9: State and Private Sites Page 9-16 
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Exhibit 9-7. State Hazardous Waste Funds 

Expenditures and Balances 2000 and 1997 

Expenditures a Fund Balances b 

State 1997 2000 1997 2000 

Alabama 199,290 332,700 615,590 450,000 

Alaska 20,830,212 7,720,413 76,154,222 64,955,963 

Arizona 4,488,566 15,275,703 813,192 17,895,429 

Arkansas 201,174 c 8,798,191 c 

California 228,000 c 2,411,121 84,548,000 

Colorado 1,200,000 2,452,380 19,000,000 16,119,065 

Connecticut c c 13,500,000 24,170,610 

Delaware 2,670,000 3,500,000 8,400,000 13,000,000 

District of Columbia c c c c 

Florida 22,199,865 4,337,746 24,529,984 15,006,808 

Georgia 17,589,411 10,484,945 1,073,451 12,762,010 

Hawaii 711,096 1,200,288 225,000 1,981,063 

Idaho c c c c 

Illinois 8,800,000 17,452,500 21,900,000 24,033,600 

Indiana 4,284,377 12,514,959 24,511,554 41,350,404 

Iowa 650,391 328,080 1,060,868 89,484 

Kansas 1,516,000 c c c 

Kentucky 1,800,000 700,000 4,000,000 1,500,000 

Louisiana 200,790 6,497,001 1,693,995 3,851,299 

Maine 2,267,436 1,991,420 7,400,000 9,270,375 

Maryland c 7,000 500,000 1,816,898 

Massachusetts 7,100,000 35,900,000 86,300,000 53,900,000 

Michigan 40,088,000 46,330,000 7,644,000 133,172,000 

Minnesota 5,144,005 7,897,000 5,300,398 12,800,000 

Mississippi 2,280,000 2,681,383 750,000 112,800 

Missouri 2,700,000 3,500,000 (1,300,000) 2,900,000 

Montana 7,312,614 7,312,614 14,506,467 14,506,467 

Nebraska c c c c 

Nevada 300,000 c 1,000,000 c 

New Hampshire 1,700,000 2,100,000 1,500,000 7,800,000 

New Jersey 81,300,000 25,130,961 114,700,000 189,093,523 

New Mexico 230,412 440,836 1,659,814 1,623,000 

New York 158,794,899 122,081,213 612,041,042 215,009,586 

North Carolina 938,311 582,972 4,823,533 10,430,858 

North Dakota c c 160,000 163,000 

Ohio 16,841,377 c 31,081,540 c 

Oklahoma 877,718 1,339,036 17,168 313,451 

Oregon 11,080,828 13,625,860 12,142,352 21,242,558 

Pennsylvania 37,397,633 39,000,000 120,026,484 110,000,000 

Puerto Rico c c c c 

Rhode Island 300,000 c 50,000 c 

South Carolina 630,613 3,100,000 25,077,100 5,000,000 

South Dakota c 1,183,092 1,750,000 2,835,732 

Tennessee 7,209,656 11,316,640 9,559,569 12,082,752 

Texas 41,242,559 24,002,551 69,898,478 55,721,609 

Utah 500,000 0 1,500,000 400,000 

Vermont 5,200,000 7,219,000 4,800,000 1,696,000 

Virginia 123,422 6,500 3,569,781 0 

Washington 42,682,982 28,731,105 44,867,955 14,374,009 

Chapter 9: State and Private Sites Page 9-17 
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Exhibit 9-7. State Hazardous Waste Funds 

Expenditures and Balances 2000 and 1997 (Continued)

 Expenditures a Fund Balances b 

State 1997 2000 1997 2000 

West Virginia 758,585 c 1,800,000 c 

Wisconsin 2,567,000 9,076,600 21,381,000 26,542,200 

Wyoming c c c c 

Total 565,137,222 477,352,498 1,413,193,849 1,224,520,553 

Notes: 

a Includes funds spent by the states in 1997 and 2000 for NPL and non-NPL site cleanups. Totals differ slightly from 

those in the 2001 50-State Study because of rounding. b Includes bonding authority. Totals differ slightly from those in the 2001 50-State Study because of rounding.

 c Indicates that data were not provided 

Sources: Environmental Law Institute, An Analysis of State Superfund Programs: 50-State Study, 2001 Update, 

November 2002. 

Environmental Law Institute, An Analysis of State Superfund Programs: 50-State Study, 1998 Update. 

9.4.2 Annual and Projected Cleanup Costs

The estimate of the cost of cleanup is based on trends in state and private party cleanups over the 

past six years.

 • It has been estimated that there are between 1⁄2 and 1 million brownfield sites in the U.S. 

(Section 9.1.3). However, the percentage of sites that will need cleanup is unknown. About 

70 percent of the 5,400 properties that have been part of a federal brownfield assistance 

program and that have completed site assessments require cleanup activities. However, this 

percentage is likely to be lower for sites not yet in a federal brownfields program. Thus, the 

70 percent (or 350,000 to 700,000 sites) is the estimated upper limit of the potential market. 

• Non-NPL cleanup expenditures by states have typically been about $500 million annually. 

This figure is the total of mostly non-NPL expenditures for 37 states that reported this item 

separately in the 2001 50 State Study (ELI 2002a). This figure does not include 13 states for 

which data are not available, nor does it include direct appropriations for specific cleanup 

projects. On the other hand the total includes some costs for administration and Superfund 

site cleanups.

 • Responsible party expenditures are estimated to be equal to state expenditures, based on a 

1994 EPA/ASTSWMO study (U.S. EPA 1994). Cost data submitted for 3,395 sites listed in 

CERCLIS during the period 1980-1992 indicated that responsible parties paid $555 million 

and the states paid $650 million to clean up these sites. Responsible parties’ expenditures 

appear to be roughly equal to state expenditures at state sites. No centralized source of data 

are available that includes private party expenditures for cleanups through the states' 

voluntary cleanup or brownfield programs. 

Chapter 9: State and Private Sites Page 9-18 
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• Adding the above figures indicates that total cleanup expenditures at state sites has been 

averaging about $1 billion annually in recent years. During this same period, cleanup has 

been completed at about 5,000 state and private party sites annually. At this rate, about 

150,000 sites can be completed over the next 30 years, at a cost of $30 billion (Exhibit 9-8). 

• This level of effort may or may not be sufficient to address cleanup at all state sites within 

30 years. If a small percentage of the 1⁄2 to 1 million brownfield sites require cleanup, this 

level of effort may be sufficient to clean up all state sites. However, if the percentage of sites 

that require remediation approaches those in the EPA brownfield assistance programs (70 

percent), this level of funding will only pay for 1⁄4 to 1⁄2 of the required cleanups. 

Thus, total expenditures for both state and privately-funded remediation is estimated to be $30 

billion (Exhibit 9-8). If more than 150,000 sites need cleanup it will likely take more than 30 

years, unless additional funding becomes available. There may also be sites addressed by private 

parties which are not under the auspices of a state or federal program. Nationwide data on these 

sites are not available. 

Exhibit 9-8. Estimated Total Cost of State Site Cleanups ($Millions) 

Annual Average 30-Year Total 

State Expenditures $500 $15,000 

Private Expenditures $500 $15,000 

Total Expenditures $1,000 $30,000 

Source: See explanation in text. 

9.5 Market Entry Conditions 

The following factors will be important to the success of vendors seeking to operate in the state 

and brownfield site characterization and cleanup market:

 • By the end of 2000, about 40 states had some kind of list, registry, or inventory of state 

sites, with a combined total of 15,000 sites (ELI 2002). Some states use these compilations 

to determine the order in which sites will be cleaned up. Some states list all known and 

suspected sites, others include only those that have completed a long evaluation process, and 

others include only sites where cleanup is funded directly by the state. Some states’ lists 

may be useful for contractors seeking opportunities for site investigation or remediation 

work in selected states. 

Chapter 9: State and Private Sites Page 9-19
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• The Brownfields Revitalization Act mandates that, as a prerequisite for certain CERCLA 

liability protections provided to certain sites cleaned up under state response programs, and 

to receive certain federal assistance funds, states must maintain a public record of sites 

addressed through their brownfield programs. These records, once established, may serve as 

a source for vendors to review for prospective remediation needs. Some existing state site 

lists do not include all sites that are likely to require investigation and cleanup. Nevertheless 

they provide a method to quickly identify potential projects and issues.

 • The operating practices of state cleanup, brownfields, and voluntary programs vary from 

state-to-state. Remediation technology vendors could benefit by knowledge of the practices 

and trends in each state, and perhaps forming alliances and partnerships with developers in 

specific areas. Much development is done by local or regional firms with knowledge of local 

markets. Information on state programs is available in several publications by the NortheastMidwest Institute, EPA, the General Accounting Office, and the state web sites (Bartch 

2000, Bartch 2002, GAO 2000, EPA 2002a).

 • Some states have cleanup funds, such as an emergency response fund or a drycleaning site 

fund. These funds are potential sources of information about potential cleanup projects and 

technology needs.

 • Companies interested in R&D, site assessment, cleanup, or revitalization at a brownfield site 

may encourage their communities or state to apply for funds from one or more of the federal 

or state programs. 

• Often, the site investigation and cleanup is only a small portion of the total cost of a 

development project. A site may not even enter into a cleanup program until development 

occurs in the area. For example, a public works project such as a pipeline or sewer line may 

call for environmental assessments which result in the discovery of contaminated materials. 

Remediation vendors would benefit from comprehensive knowledge of development 

projects in their areas.

 • Development of brownfields often involves the integration of diverse disciplines (urban and 

transportation planners, developers, real estate professionals, environmental engineers, 

remediation experts, community involvement experts) and cooperation of many stakeholder 

groups (developers, residents, local businesses, state and federal environmental regulators, 

local zoning and planning officials). Thus, firms that specialize in remediation may form 

alliances with firms that specialize in other aspects of brownfield projects. A number of 

firms with both remediation and development capabilities have emerged over the past 

decade. 

Chapter 9: State and Private Sites Page 9-20
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

9.6 Remediation Technologies

Three sources provide information on technologies used at state sites. Although none of these 

sources is based on a comprehensive survey, they provide a picture of the types of contaminants 

and technologies likely to be found at state sites. 

The first source, The XL Environmental Land Reuse Report 2002 and The XL Environmental 

Land Reuse Report 2001, are reports on a unique data collection conducted by XL 

Environmental, Inc. and International Economic Development Council. These studies are based 

on a literature search of media coverage of brownfield-related stories. The researchers used 

online newspaper and journal archives, such as Lexis-Nexis, to search for articles that mention 

brownfield issues. The search identified 331 brownfield-related articles between July 2001 and 

June 2002 discussing 428 brownfield sites; and 317 articles between July 2000 and May 2001 

discussing 346 sites. The most frequently used remediation approaches are shown in Exhibit 9-9. 

Demolition, excavation, and capping were the most frequently used techniques. Lead paint and 

asbestos are the most common contaminants in buildings. Excavation is the removal and offsite 

disposal of contaminated soil from the property. Capping was used on many sites intended for 

public recreation or ecological use, such as ballparks, golf courses, and nature reserves. About 

one-third of the capping applications were on former landfills. More advanced methods, such as 

SVE, thermal desorption, and bioremediation were mentioned infrequently. These approaches 

are fairly new, and are more difficult for most developers and communities to understand. 

However, the incidence of the use of innovative technologies at brownfield sites may be 

understated in the source articles because reporters have chosen not to address the remediation 

aspects of the projects. Because most of the articles are written for the general public, 

remediation techniques and technical details are not the main focus of many articles. 

Since there are numerous potential site characterization and cleanup situations that may arise at a 

given state site, and since many of the sites to eventually be cleaned up are still unidentified, it is 

impossible to detail the specific technologies that will be needed. Technologies that will 

accelerate the pace of development or reduce remediation costs or the total cost of a project will 

be needed. Real estate developers put a premium on saving time and completing projects 

quickly. Delays tend to be very expensive, since they can drive up the cost of projects. EPA’s 

Technology Innovation Program has published a useful reference to help developers, 

communities, and remediation professionals engage the process of cleanup and redevelopment. 

This document, Road Map to Understanding Innovative Technology Options for Brownfields 

Investigation and Cleanup, is available from the EPA web site (U.S. EPA 2001). The document 

also provides links to state brownfield programs. 

Chapter 9: State and Private Sites Page 9-21 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 9-9. Remediation Techniques Used at a Sample of Brownfield Sites 

Remediation 2001 2002 Total 

Technique Number Percent Number Percent Number Percent 

Demolition 46 38 31 46 77 41 

Excavation/ Removal 44 36 16 23 60 32 

Caps 17 14 14 21 31 17 

SVE 5 4 1 2 6 3 

Natural Attenuation 3 2 1 2 4 2 

Soil Flushing 2 2 1 2 3 2 

Thermal Desorption 2 2 1 2 3 2 

Solvent Extraction 1 1 NA NA 1 1 

Slurry Walls 1 1 NA NA 1 1 

Bioremediation NA NA 1 2 NA NA 

No. of Sites Reporting a 121 100% 66 100% 187 100% 

a Not all articles provided information on remediation technologies. Out of 772 sites, technology information was 

available for 187 sites. Thus, this data is an indication of the types of approaches rather than a precise 

accounting. 

Source: XL Environmental, Inc. and the International Economic Development Council. The XL Environmental Land 

Reuse Report 2002, and The XL Environmental Land Reuse Report 2001. 

9.7 References

Bartch, Charles and Bridget Dorfman, 2000. Guide to Federal Brownfields Programs, 

Northeast-Midwest Institute, Washington, D.C. October 2000. 

Bartch, Charles and Rachel Deane, 2002. Brownfields State of the States, An End of Session 

Review of Initiatives and Program Impacts in the 50 States, Northeast-Midwest Institute, 

Washington, D.C. December 2002. 

California Environmental Protection Agency (CALEPA 2003) Department of Toxic Substances 

Control, Site Mitigation and Brownfields Reuse Program Database. http://www.dtsc.ca.gov/ 

SiteCleanup/Brownfields/index.html#Voluntary%20Cleanup%20Program 

ELI (Environmental Law Institute and U.S. EPA), 1996. An Analysis of State Superfund 

Programs: 50-State Study, 1995 Update, EPA-540-R-96-036, PB96-963249, July 1996. 

ELI (Environmental Law Institute and U.S. EPA), 1998. An Analysis of State Superfund 

Programs: 50-State Study, 1998 Update. 

ELI (Environmental Law Institute and U.S. EPA), 2002a. An Analysis of State Superfund 

Programs: 50-State Study, 2001 Update, November 2002. 

Chapter 9: State and Private Sites Page 9-22 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

National Association of Environmental Professionals (NAEP), 2003. Environmental Practice, 

Special Issue on Brownfields, March 2003, ISSN 1466-0466. http://www.envpra.oupjournals.org 

U.S. Conference of Mayors, 2000. Recycling America’s Lands: A National Report on 

Brownfields Redevelopment, Volume III, February 2000. 

U.S. Congress, 2002. Small Business Liability Relief and Brownfields Revitalization Act of 2001 

(PL 107-118, 11 January 2002). http://www.epa.gov/brownfields/sblrbra.htm

U.S. EPA, 1991. Superfund CERCLIS Characterization Project: National Results, EPA/540/8-

91/080, U.S. Environmental Protection Agency, Office of Emergency and Remedial Response, 

November 1991. 

U.S. EPA, 1994. A Report on State/Territory Non-NPL Hazardous Waste Site Cleanup Efforts 

for the Period 1980-1992, OSWER Pub. 9242.2-09, EPA/540/R-94/001, U.S. Environmental 

Protection Agency, Office of Solid Waste and Emergency Response and Association of State 

and Territorial Solid Waste Management Officials, July 1994. 

U.S. EPA, 2001. Road Map to Understanding Innovative Technology Options for Brownfields 

Investigation and Cleanup, Third Edition, EPA-B-01-001, U.S. Environmental Protection 

Agency, Office of Emergency and Remedial Response. 

U.S. EPA, 2002. President Signs Legislation to Clean Environment and Create Jobs, U.S. 

Environmental Protection Agency press release January 11, 2002. 

U.S. EPA, 2003. Brownfields Management System, U.S. Environmental Protection Agency, 

tabulation, June, 2003. 

U.S. GAO, 1995. Community Development: Reuse of Urban Industrial Sites, RCED-95-172, 

U.S. General Accounting Office, June 1995.

U.S. GAO, 2000. Brownfields, Information on the Programs of EPA and Selected States, GAO01-52, U.S. General Accounting Office, December 2000. 

XL Environmental, Inc. and the International Economic Development Council, 2001. The XL 

Environmental Land Reuse Report 2001. 

XL Environmental, Inc. and the International Economic Development Council, 2002. The XL 

Environmental Land Reuse Report 2002. 

Yount, Kristen R, 2003. “What Are Brownfields? Finding a Conceptual Definition,” 

Environmental Practice, March 2003. ISSN 1466-0466. http://www.envpra.oupjournals.org. 

Chapter 9: State and Private Sites Page 9-23 
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Chapter 9: State and Private Sites Page 9-24
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Chapter 10 

Demand for Remediation of Manufactured 

Gas Plants and Related Coal Tar Sites 

Before the United States had a network of natural gas pipelines and electricity, fuel for lighting, 

heating, and cooking was manufactured from coal and petroleum at thousands of manufacturing 

facilities across the country. As a result of these activities, hazardous materials are likely to be 

present in the subsurface and groundwater at thousands of locations. While some of these sites, 

especially those currently owned and operated by large gas and electric utility companies, are 

being addressed, most of the former manufactured gas sites have not been identified. 

There is no separate remediation program for the characterization and remediation of MGP and 

other coal tar sites. MGP 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 site-specific factors. Because these sites may be managed under 

different remediation programs, the estimates of the MGP market 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. 

This chapter provides information to help vendors, regulators, and other stakeholders understand 

the potential sources of risk to people and the environment that may have resulted from past 

MGP operations. It provides background for site investigators to understand potential sources of 

NAPLs, coal tars and other pollutants. The effectiveness and efficiency of site investigations and 

remdiations could benefit from a good understanding of this defunct industry. 

10.1 History

From the early 1800s through the mid-1900s manufactured gas plants (MGP) were operated 

nationwide to provide gas from coal or petroleum for lighting, heating, and cooking. The first 

manufactured gas plant built in the United States was in Baltimore in 1816. By the turn of the 

20th century almost every good-sized city had its own manufactured gas plant (Gonzalo, 1995). 

Larger cities had more than one plant. 

A 2003 EPA report estimated that as many as 50,000 plants were built during the over 140 years 

of MGP operations (U.S. EPA 2003). The first plants were located in downtown areas adjacent 

to waterways and rail spurs for easy access to coal (EI Digest, 1995). As the technology 

developed, it became a common source of light, heat and fuel for a variety of industrial and 

commercial facilities and residences. After electricity and piped in natural gas became common, 

many of the larger MGP properties were converted for new uses by the utilities and other 

companies that owned them. In addition to the commercial MGPs, many railroad companies, 

military installations, large institutions (e.g. hotels, hospitals, prisons, schools), industrial 

facilities, and large private homes were equipped with gas plants (Heritage Research, 2002). 

Chapter 10: Manufactured Gas Plant Sites Page 10-1 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

The manufacturing practices at the time left an environmental legacy of hazardous waste 

contamination in groundwater, soil, sediment, sludge, and surface water. Because almost all 

MGPs were decommissioned over 50 years ago, prior to most federal environmental regulations, 

it is difficult to assess the nature and scope of the environmental legacy left behind. MGP sites 

represent a potentially significant market for site characterization and remediation technologies. 

10.2 Gas Manufacturing Processes

Manufactured gas was produced primarily by three processes; coal carbonization, carburetted 

water gas, and oil gas (NYDEC, 2003). Coal carbonization, was used exclusively until 1875. In 

this process, the coal was heated in a closed oven with limited air contact. The volatile products 

of this oxygen-deficient heating was driven off as a gas which was collected, cooled, and 

purified for use. The gas was then measured, stored, and delivered to customers via underground 

pipes. The solid remains would become coke, a fuel which burned hotter and more cleanly than 

coal. 

The carburetted water gas process was introduced in the 1875. The process involved heating 

coal or coke in a closed vessel into which steam was injected. This resulted in a flammable gas 

mixture of methane and carbon monoxide. Then gas works napthalene or light oil petroleum 

products were sprayed into this gas mixture, resulting in petroleum constituents that were 

cracked to form methane, a gas that burned hotter and brighter. 

The most common oil gas process was patented in 1889. It is similar to the carburetted water gas 

process with a vaporizer replacing the carburetor. Oil is added to the reactor thereby generating 

more heat. The oil vapors are thermally cracked and fixed into gases. 

After 1928 the Northeast was subjected to shortages of both coke and light carbureting oils and a 

wide variety of newly developed oil-based gas manufacturing processes came into being. These 

processes were prominent until the 1950s when reliable supplies of natural gas were in place. 

10.3 Number and Characteristics of Sites

As with other types of sites, former MGP sites are subject to current environmental regulations, 

and, when discovered, may be managed under either the federal Superfund, RCRA Corrective 

Action, Underground Storage Tank, or other federal or state programs. However, no single 

source provides definitive information on the number and characteristics of former MGP sites, 

nor on the number that may require remediation. Until further investigation is conducted, the 

number of MGP facilities that are likely to require remediation can only be estimated. 

According to the U.S. Bureau of the Census’ 1910 Manufactures Report for Principal Industries, 

there were 1,296 MGP plants, mostly owned by corporations and municipalities, selling 

manufactured gas in the country. Most of the sites were in the Northeast quadrant of the United 

States (Heritage Research, 2002). In 1985 EPA estimated that there were a total of 1,500 MGP 

plants in North America (Brown’s Directory of North American Gas Plants - from 1887). This 

tally however did not include plants that were not members of gas associations, those that did not 

report information to the directory’s publisher, or multiple plants owned by the same entity. A 

Chapter 10: Manufactured Gas Plant Sites Page 10-2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

more recent estimate by the Electric Power Research Institute (1995) indicates that there may be 

as many as 2,500 MGP sites that are now associated with modern electric and gas utility 

properties. Con Edison estimates that in New York State alone there are approximately 250 

former gas manufacturing sites related to utility operations. An extensive proprietary database 

with data on approximately 7,000 MGP and other coal tar sites provides additional information 

on the potential universe of sites that may still require some sort of site characterizations and/or 

remediation (Hatheway 1997). 

Based on these sources, it is estimated that from 1800 to the mid-1900s between 36,000 and 

55,000 manufactured gas plants and related coal tar sites operated in the United States. These 

sites varied in size from less than one acre to approximately 200 acres. Exhibit 10-1 identifies 

the types of sites, their typical sizes, and an estimate of the number of sites for each site type. 

These site types vary greatly in size, volume of releases, and location. For example, commercial 

MGPs tended to be medium-to-large plants located in urban areas where they piped gas to 

consumers, businesses, and municipalities. This gas was primarily used for lighting, heating, 

and cooking. In contrast, there were many more institutional and residential gas machines 

owned by hotels, hospitals, universities, private estates, and other entities, that manufactured gas 

for their own use. These sites ranged from several hundred square feet to a few acres. 

Although most of the former MGP properties are now vacant or being used for other purposes, 

many of them have not been investigated for potential soil or groundwater contamination 

resulting from previous MGP activities. Nevertheless, based on the manufacturing practices at 

the time, it is believed that most of these facilities had releases of contaminants to the 

environment. The aforementioned sources were reviewed to estimate how many of the 36,000 to 

55,000 sites were likely to have had releases and the number of those that had not been 

investigated or remediated. 

By subtracting the estimated number of sites that have been 

found to require no further action planned (NFRAP), those Estimated Land Use 

that are enrolled in a state voluntary cleanup program (VCP), Around MPG Sites 

and those that have completed remediation under a federal or 

Industrial/commercial 50% state program, the balance of the sites represent those that Residential 30% have not been investigated, and are likely to require Recreational & vacant 20% 

characterization and remediation work.1

 These estimates are 

shown in Exhibit 10-2 and the calculations in Appendix 

Exhibit D-1. As the exhibit indicates, approximately 88 percent of the sites are suspected to have 

had releases of contaminated materials to the environment. It is estimated that only a small 

percentage of these sites have been identified and entered into a federal or state remediation 

program. Thus it is likely that the remaining 30,000 to 45,000 sites have not been investigated 

and represent a significant potential for site characterization and remediation work. 

Approximately 50 percent of these sites are in industrial/commercial areas, 30 percent are in 

residential areas, and the balance are in recreational and vacant areas (Appendix Exhibit D-1). 

A keyword search of EPA’s CERCLIS database indicated that about 800 NFRAP sites were former MGP and 

coal tar sites. Although these sites did not become candidates for listing on the NPL, they may still require 

remediation under other environmental authorities such as RCRA or state laws. 

Chapter 10: Manufactured Gas Plant Sites Page 10-3 

1 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 10-1. Types and Numbers of Former Manufactured 

Gas Plants & Related Coal Tar Facilities in the U.S. 

Site Type Description/Use 

Site Size 

Range & 

(Average) 

Time 

frame 

Number of 

Sites 

Commercial MGPs Produced and sold gas for 

lighting, heating & cooking 

Small: <5 million cu ft per yr. 

Med. : 5-100 mil. cu ft per yr. 

Large: >100 mil. cu ft per yr. 

1-3 acres (2) 

3-10 (5) 

10-100 (40) 

1816­

1950s 

3,500 

District Gas Held & distributed gas beyond 

Holders commercial MGPs original 1-4 acres (1.5) 1860-1910 500 - 1,500 

distribution radius 

Rail Yard Pintsch Produced illuminating gas for 0.5- 1.5 acres 1873-1960 100-150 

Oil-Gas Plants rail passenger cars (1) 

Military Gas Plants Produced illuminating and fuel 

gas for use at military posts, 

naval stations, arsenals, and 

munitions plants 

0.5-1.5 acres 

(1) 1849-1993 150-250 

Ice & Refrigeration Commercial block ice and 1-2 acres 

Plants with Gas commodity refrigeration; used (1.5) 1870-1940 200-400 

Producers coal-gas ammonia as a 

refrigerant 

Institutional Gas Hotels, resorts, hospitals, 500-1500 sq ft 

Machines universities, asylums, (700 sq ft); 1850-1950 5,000-10,000 

monasteries, private schools Mostly indoors 

Domestic/Resident Mansions and country estates 400-1000 sq ft 

ial Gas Machines (600 sq ft); 1890-1950 10,000-15,000 

Basements & 

exterior bldg 

Captive Gas Fuel gas for wide variety of 600 to 30,000 

Producers (both industrial plants with sq ft; highly 1880-1950 11,000-15,000 

Pressure furnaces/kilns and smelters Variable; Most 

&Suction) enclosed 

Bottled 

Manufactured Gas 

Plants 

Manufactured oil-enriched 

water gas or solvent vapor 

gas 

1-3 acres (1.5); 

Variable; most 

enclosed 

1912-1940 100 

Kerosene Refiners Distilled lamp oil from soft 

coal 

1-2 acres (1.5) 1850-1870 100-150 

Compressed Fuel Bound by-product with tars 1-2 acres (1.5) 

Briquette Plants and compressed solid fuel Variable; 1910-1950 100 

enclosed 

Chapter 10: Manufactured Gas Plant Sites Page 10-4 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 10-1. Types and Numbers of Former Manufactured 

Gas Plants & Related Coal Tar Facilities in the U.S. (Continued) 

Site Type Description/Use 

Site Size 

Range & 

(Average) 

Time 

frame 

Number of 

Sites 

Beehive Coke 

Works 

Produced coke without 

recovery of by-products 

40-100 acres; 

Highly variable 

1800-1930 2,000-4,000 

Merchant and 

Utility Coke Works 

Produced coke with recovery 

of coal tar by-products 

40-100 acres; 

variable 

1890-1996 250-300 

Charcoal Plants Produced charcoal as fuel 10-100 acres 

(25); Highly 

variable 

1820-1960 2,000-3,000 

Tar Distilleries Converted tar residues to 

industrial chemicals 

10-100 acres 

(15); 

Variable 

1900-1960 200-400 

WWI Federal 

Wood-Tar 

Distillation Plants 

Produced cellulose acetate 

aircraft fabric dope 

40-200 acres 

(80); Variable 1918-1921 11 

WWI Federal 

Toluene Plants 

Produced munitions and fuelgrade toluene from gas-works 

benzol 

80-200 acres 

(100); Variable 1918-1920 10 

Wood Preservation 

Plants 

Pressure and non-pressure 

impregnation of timber with 

coal tar products 

10-200 acres 

(40); Highly 

variable 

1880-1960 800-1,000 

U.S. Bureau of 

Mines coal 

Gasification Plants 

coal gasification plants to 

exploit WWII German 

technologies; operated mainly 

by universities and industrial 

grantees 

10-40 acres 

(20); 

Variable 1947-1990 37-55 

U.S. Department of 

Energy Coal 

Gasification Plants 

Coal & oil shale gasification 

pilot projects 

10-40 acres 

(20); Variable 1970-1985 63-75 

Total 36,121 -55,001 

Notes: 

• Acetylene gas plants were common from 1890 to 1940, for use in rural small-town, business and residential 

markets. These plants are not included in these tabulations since they are not regarded as having produced or 

left environmentally-hazardous wastes. 

Source: Hatheway, Allen W. “Estimated Number of Manufactured Gas and Other Coal-Tar Sites in the United 

States,” Environmental Engineering Geoscience, Vol. III, No. 1, Spring 1997, pp. 141-142 and personal 

communication with the author, February-March 2003. The data are based on Dr. Hatheway’s database on MGPs 

which includes information on approximately 7,000 sites, assembled from Brown’s Directory of North American 

Gas Plants, historic gas industry literature, Sandborn Fire Insurance maps, state agencies, and direct on-site 

observations. 

Chapter 10: Manufactured Gas Plant Sites Page 10-5 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 10-2. Estimated Magnitude & Disposition of Former Manufactured 

Gas Plants & Other Coal Tar Sites in the U.S. 

Site Type a 

Original Number

 of Sites 

Number of 

Sites w/Releases 

No. of Sites Not 

Yet Investigated 

Commercial MGPs 3,500 3,500 2,275+ 

District Gas Holders 500-1,500 500-1,500 450-1,350+ 

Rail Yard Pintsch Oil-Gas Plants 100-150 100-150 >85-129 

Military Gas Plants 150-250 150-250 150-250-

Ice & Refrigeration Plants w/Gas 

Producer 

200-400 150-300 143-285 

Institutional Gas Machines 5,000-10,000 2,500-5,000 2,375-4,750 

Domestic/Residential Gas Machines 10,000-15,000 10,000-15,000 9,800-14,700+ 

Captive Gas Producers - Pressure & 

Suction 

11,000-15,000 11,000-15,000 10,450-14,250 

Bottled Manufactured Gas Plants 100 50 50 

Kerosene Refiners 100-150 100-150 93-140+ 

Compressed Fuel Briquette Plants 100 50 50 

Beehive Coke Works 2,000-4,000 2,000-4,000 1,800-3,600+ 

Merchant & Utility Coke Works 250-300 250-300 125-150 

Charcoal Plants 2,000-3,000 2,000-3,000 1,800-2,700 

Tar Distilleries 200-400 200-400 160-320 

WWI Federal Wood Tar Distillation 

Plants 

11 11 6 

WWI Federal Toluene Plants 10 10 5 

Wood Preservation Plants 800-1,000 800-1,000 440-550 

U.S. Bureau of Mines - Coal 

Gasification Plants 

37-55 37-55 33-49 

U.S. Dept. of Energy - Coal 

Gasification Plants 

63-75 63-75 57-67 

Total 36,121-55,001 33,471- 49,801 29,975-44,926 

a See Table 1 for descriptions of the site types. 

Source: Hatheway, Allen W, “Estimated Number of Manufactured Gas and Other Coal-Tar Sites in the United States,” 

Environmental Engineering Geoscience, Vol. III, No. 1, Spring 1997, pp. 141-142 and personal communication with the 

author, February-March 2003. The data are based on Dr. Hatheway’s database on MGPs which includes information on 

approximately 7,000 sites, assembled from Brown’s Directory of North American Gas Plants, historic gas industry literature, 

Sandborn Fire Insurance maps, state agencies, and direct on-site observations. 

Chapter 10: Manufactured Gas Plant Sites Page 10-6 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

10.4 Waste Types and Quantities 

The gas manufacturing processes resulted in a variety of residuals, some of which were 

converted to by-products, while others, many of which are hazardous, were managed as wastes. 

Some of the by-products were sold to other industries. For example, coke was sold to the steel 

industry. Others materials were transported offsite for disposal. It was common practice to dump 

coal tar and other wastes into on-site pits or ponds, bury it, or use it as fill to adjust the grade of 

the gas yard. The gas manufacturing process also involved the use of wood chips and iron filings 

to remove sulfur and cyanide from the gas. These chips and filings were also disposed of in pits 

or buried. As a result of these practices, wastes from manufactured gas processing can be found 

in soil, sediment, groundwater and surface water. 

These wastes pose potential risks to humans and the environment. A critical concern with regard 

to coal tar is the fact that less than 40 percent of the mass of coal tar constituents can be 

quantified using common organic chemistry extraction and chromatographic techniques. The 

remaining 60 percent known as “pitch” are comprised of aromatic compounds with high 

molecular weight and relatively low aqueous solubility. The compounds that make up this pitch 

are of concern since many are suspected to cause mutagenic and/or carcinogenic effects. In 

addition, the presence of pitch can influence the rates of release of the more soluble coal tar 

constituents. Some researchers who are now looking at tar as a “supercompound” with a potent 

combination of carcinogens, much like cigarette smoke, instead of studying its individual 

constituents (WDNR, 1999). 

The types of wastes produced depended upon the production processes and the period in which 

the plants operated. Coal tar, a by-product of all MGP sites, is a dense, non-aqueous phase 

liquid (DNAPL). When released into an aquifer, it migrates downward until it encounters a lowpermeability layer. This dense substance does not dissolve in the aquifer and releases 

constituents into the water. The lighter oil by-products (LNAPLs) of the manufactured gas 

process migrate through the groundwater. They tend to float on top of the water, contaminating 

it from above. 

Exhibit 10-3 shows the types and estimated quantities of residuals and wastes remaining in the 

soil and groundwater at MGP and coal tar sites. The most common releases are liquids, solids, 

sludges, and tar. The quantity estimates are based on information from public and private 

databases cited in the footnote to the exhibit. 

From 1880 to 1950, MGPs produced approximately 15 trillion cubic feet of gas and 

approximately 11 billion gallons of tar as a by-product resulting in thousands of contaminated 

acres of land and millions of gallons of impacted water (Fischer et al, 1999). 

Chapter 10: Manufactured Gas Plant Sites Page 10-7 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 10-3. Estimated Quantities of Residuals and Wastes 

Released at Former MGP & Other Coal Tar Sites in the U.S. 

Original Number of Volume of 

Site Type a Number Sites With Type of Releases Residuals/Waste 

of Sites Releases Per Site (000) 

Commercial MGPs 3,500 3,500 Liquids & Solids 2,000-50,000 m3 

District Gas Holders 500-1,500 500-1,500 Liquid Leaks, 

Solids inside 

100 -500 m3 

Rail Yard Pintsch OilGas Plants 100-150 100-150 Liquids & Solids 500-10,000 m3 

Military Gas Plants 150-250 150-250 Liquids & Solids 500-1,000 m3 

Ice & Refrigeration 200-400 150-300 Liquids & Limited 500-1,000 m3 

Plants w/Gas Solids 

Producer 

Institutional Gas 

Machines 

5,000-10,000 2,500-5,000 Liquids <100 m3 

Domestic/Residential 

Gas Machines 

10,000-15,000 10,000-15,000 Limited Liquidsb 

&Solids 

<50 m3 

Captive Gas 11,000-15,000 11,000-15,000 Tars & Solids 100-10,000 m3 

Producers - Pressure 

& Suction 

Bottled Manufactured 

Gas Plants 

100 50 Limited Sludges 100-500 m3 

Kerosene Refiners 100-150 100-150 Liquids & Sludges 100-1,000 m3 

Compressed Fuel 

Briquette Plants 

100 50 Limited Liquids & 

Sludges 

100-1,000 m3 

Beehive Coke Works 2,000-4,000 2,000-4,000 Tars 1,000-10,000 m3 

Merchant & Utility 

Coke Works 

250-300 250-300 Tars & Solids 5,000-

100,000 m3 

Charcoal Plants 2,000-3,000 2,000-3,000 Tars 1,000-5,000 m3 

Tar Distilleries 200-400 200-400 Liquids & Tar 

Sludges 

1,000-

100,000 m3 

WWI Federal Wood 

Tar Distillation Plants 

11 11 Liquids & Tar 

Sludges 

1,000-10,000 m3 

WWI Federal 

Toluene Plants 

10 10 Liquids & Sludges 1,000-10,000 m3 

Wood Preservation 

Plants 

800-1,000 800-1,000 Liquids & Sludges 1,000-10,000 m3 

Chapter 10: Manufactured Gas Plant Sites Page 10-8 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 10-3. Estimated Quantities of Residuals and Wastes 

Released at Former MGP & Other Coal Tar Sites in the U.S. (Continued) 

Site Type a 

Original 

Number

 of Sites 

Number of 

Sites With 

Releases 

Type of Releases 

Volume of 

Residuals/Waste 

Per Site (000) 

U.S. Bureau of 

Mines-Coal 

Gasification Plants 

37-55 37-55 Liquids & Sludges 500-1,000 m3 

U.S. Department of 

Energy-Coal 

Gasification Plants 

63-75 63-75 Limited Liquids & 

Sludges 

500-1,000 m3 

Total 36,121-55,001 33,471-49,801 

Notes: 

a See Exhibit 10-1 for definitions of site types. 

b Limited connotes a few hundred to one thousand gallons over the period of weeks to a few months. 

Source: Hatheway, Allen W, “Estimated Number of Manufactured Gas and Other Coal-Tar Sites in the United 

States,” Environmental Engineering Geoscience, Vol. III, No. 1, Spring 1997, pp. 141-142 and personal 

communication with the author, February-March 2003. The data are based on Dr. Hatheway’s database on MGPs 

which includes information on approximately 7,000 sites, assembled from Brown’s Directory of North American 

Gas Plants, historic gas industry literature, Sandborn Fire Insurance maps, state agencies, and direct on-site 

observations. 

Six major constituent classes are potentially present in MGP residuals (Middleton, 1995):

 • polynuclear aromatic hydrocarbons (PAHs);

 • volatile aromatics (BTEX);

 • phenolics;

 • inorganic nitrogen (including cyanide compounds);

 • inorganic sulfur; and

 • trace metals. 

10.5 Remediation Technologies

Investigation and remediation at many MGP sites are complicated by the:

 • Nature and variety of waste materials and media, including the fact that the constituents of 

concern tend to interact differently in different media; 

• Location of the sites (i.e near waterways or in the heart of residential neighborhoods); and

 • Condition of the sites (i.e. infrastructure at the sites, lack of surface features and mixed

debris is subsurface).

A variety of site investigation techniques are available to address some of these complications. 

They include ground penetrating radar (GPR), Electromagnetic (EM) Induction, Infrared 

Monitoring (IM), and Seismic Reflection and Refraction to detect and measure buried debris or 

other subsurface anomalies. Direct Push Sampling and Seismic Reflection and Refraction may 

Chapter 10: Manufactured Gas Plant Sites Page 10-9 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

be used to produce a geophysical profile of the subsurface. Flame Ionization Detectors (FID) 

and Photoionization Detectors (PID) are used to screen soil for contamination. Once the location 

and profile of the waste is determined, many of the same sampling techniques are employed to 

test both soil and water. These include Direct Push sampling which can be used for any 

constituent, drilling both for the collection of samples and the installation of groundwater wells; 

Immunoassay test fits to detect and quantify contaminants by measuring compound reactions; 

Laser-Induced Fluorescence/Cone Penetrometry using a fiber optics-based chemical system to 

screen primarily for petroleum contamination in the field; and, X-ray Fluorescence (XRF) to 

detect and quantify individual metals in the field. In addition, soil gas surveys are used to 

identify and quantify individual organic compounds (VOCs and SVOCs) that occur between 

particles of the earth and soil with the help of a portable gas chromatograph (Fischer 1999). 

Both established and innovative technologies are being used to remediate former MGPs. Most 

of the technologies involve thermal desorption, biological processes, and/or chemical oxidation 

processes (Brown et al, 1995). A number of the technologies can be applied either in situ or ex 

situ. In some cases, these technologies serve to recover fuels for recycling. 

A variety of remediation alternatives are available for use at former MGP sites. Exhibit 10-4 

enumerates many of these alternatives and their application by waste stream category and 

contaminant/media. According to the Institute for Gas Technology, wastes from former MGP 

sites fall into six major categories; pumpable liquid free product (free tars & oils); organic waste 

or tar/oil-contaminated waters; organic waste or tar-contaminated soil and sediments; nonpumpable tars and sludges; purifier box (or spent oxide) waste; and, demolition debris (Fischer 

1999). 

Chapter 10: Manufactured Gas Plant Sites Page 10-10 
Exhibit 10-4. Remediation Alternatives by Category 

of Waste at Former Manufactured Gas Plants 

Waste Category Remediation Alternatives Contaminants and 

Organic waste or TarContaminated Soils and Sediments 

Soil vapor extraction - use of vacuum to separate contaminants from soil Bioremediation (in-situ or ex-situ) 

VOCs and some SVOCs PAHs 

Bioventing (combines SVE and Bioremediation) Petroleum products Excavation & Aeration VOCs, some SVOCs Low Temperature Thermal Desorption VOC, SVOC, & petroleum contaminaHigh Temperature Thermal Desorption SVOCs in impacted soil, some VOCIncineration VOCs & SVOCs in impacted soil Soil washing Metals, gasoline, & fuel oils Solvent extraction PCBs, VOCs, halogenated organics

soil, sediments, & sludges 

Soil flushing Heavy metals, halogenated organicsClean Soil Process (CSP) Coal Tar 

Non-pumpable tars and Excavation & soil mixing - to dilute the concentration of Petroleum hydrocarbons sludges TPAHs - removal to RCRA class D landfill - daily cover 

Purifier box (or spent oxide) Spent wood chips - burnt and ash dumped Other spent purification media waste 

Spent oxides - some sold for Vitriol - most removed to Sulphur-related PH conditions that cRCRA class D landfill 

Demolition Debris Scanned and steam cleaned - removal to RCRA Class D NA 

landfill 

Chapter 10: Manufactured Gas Plant Sites Page 10-11 
Chapter 10: Manufactured Gas Plant Sites Page 10-12 Exhibit 10-4. Remediation Alternatives by Category of Waste at Former Manufactured Gas Plants (Continued) Waste Category Remediation Alternatives Contaminants and M

Pumpable liquids (free tars & oils)source material Solvent extraction (separates or removes hazardous organic contaminants) Surfactant flushing - increases solubility and mobility of contaminants in water Sediments, sludges, soil with primary 

contaminants (PCBs, VOCs, halogencompounds) Groundwater with NAPLs Organic waste or tar/oil- contaminated waters Bioremediation (in-situ or ex-situ) (use of microorganisms to break down hazardous substances) Air sparging - captures contaminants by vapor extraction Treatment wall Groundwater extraction using a system of wells and pumps w/ UV oxidation, activated carbon treatment, or air stripping Surfactant flushing PAHs Volatile contaminants Chlorinated solvents, metals or radiocontaminants VOCs and SVOCs NAPLs Sources: • Fischer, Corey L.J., Schmitter, Robert D., and Lane, Eliesh O’Neil, 1999, Manufactured Gas Plants: The Environmental Legacy, South 

Hazardous Substance Research Center, Georgia Institute of Technology, Atlanta, GA, November. • Personal communication with Allen W. Hatheway. 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Chapter 10: Manufactured Gas Plant Sites Page 10-13

10.6 Estimated Cleanup Costs

MGP cleanup costs have been documented to range from a few hundred thousand dollars to $86

million for a single site. No single source provides a total nation-wide estimate of MGP cleanup

costs. To estimate the potential value of the market for cleaning up MGP and other coal tar sites,

estimates of ranges of costs for each site type were developed and multiplied by the estimated

number of sites of each type. The estimates of average costs were developed from published

information on MGP remediation costs and from analysis of data in a proprietary database

containing data on thousands of MGP and other coal tar sites (Hatheway, 1997).

The published sources provide cleanup costs for specific projects or averages for specific utility

companies that have a number of MGP sites. In 1995 the Electric Power Research Institute

estimated that cleanup and containment costs for approximately 2,500 former MGP properties to

be between $25 and 75 billion and that it would take over 30 years to clean them up (Murarka,

1995). The MGP sites in this study are those that are now part of modern utilities. This report

implies an average cost of $10-30 million per site. Other reports estimate that most per site

cleanups fall in the $3-10 million range. For example, a 2001 article reports that per site cleanup

for MGPs are in the $3-5 million range, although many sites have run much higher (Ginsburg,

2001). In 1995, the Niagara Mohawk Power Corporation of New York estimated its

environmental liability from the legacy of 55 sites in 24 cities and towns to be more than $200

million, or an average of $3.6 million per site (Neuhauser, 1995). The estimated cost varied

widely from site to site, with the cost of one site estimated as high as $86 million (Ginsburg,

2001). The Atlanta Gas Light Company is expected to spend $186 million to clean up 12 MGP

sites in Florida and Georgia, or $15.5 million per site.

The Hatheway database provided ranges of costs for a number of sites for the various site types

(Hatheway, 1997). Some engineering judgement was used to apply these to the various site

types, and to eliminate outliers (i.e., the few cases that have extremely high costs and tend to bias

the average). These estimates do not include the cost of contamination resulting from activities at

the sites after the MGP operations were closed down, nor do they consider legal costs or awards

for potential damages. The published data generally confirmed the data from this database.

The results of this analysis is presented in

Exhibit 10-5, which shows the range of

estimated average remediation cost for each

site type, along with the typical contaminants

and contaminated media. The estimated

number of sites that have yet to be

investigated is taken from Exhibit 10-2.

Based on these estimates, the cleanup of between 30,000 and 45,000 MGP and other coal tar

sites would cost between $26 billion and $128 billion. Captive gas producer plants account for

44 percent of the total and commercial plants account for 23 percent. Although the average

cleanup cost for captive producer plants is about a third of that of commercial plants, there are 5

to 7 times as many captive plants sites.

It is estimated that should the 30,000-

45,000 MGP and other coal tar sites

require cleanup, it could cost $26-$128

billion.
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 10-5. Estimated Average Remediation Cost by Site Type 

Site Type Range of Site Size Number of Sites 

Not Investigated 

Average Per Site 

Remediation Cost 

$ Millions 

Commercial MGPs small (1-100 acres) 2,275+ 3.0 - 100.0 

District Gas Holders 1-4 acres 450-1350+ 0.25 - 1.5 

Rail Yard Pintsch Oil-Gas 

Plants 

0.5-1.5 acre 95-142 0.5 - 5.0 

Military Gas Plants 0.5-1.5 acre 150-250 1.0 - 4.0 

Ice & Refrigeration Plants 

with Gas Producers 

1-2 acres 147-294 0.5 - 1.5 

Institutional Gas Machines 500-1500 ft2 2,450-4,900 0.2 - 0.75 

Domestic Residential Gas 

Machines 

400-1000 ft2 9,800-14,700 0.05 

Captive Gas Producers 

(Pressure & Suction) 

20/30 ft to 50x600 ft 10,450-14,250 1.0 - 10.0 

Bottled Manufactured Gas 

Plants 

1-3 acres 50 0.2 - 0.5 

Kerosene Refiners 1-2 acres 95-142 1.0 - 5.0 

Compressed Fuel Briquette 

Plants 

1-2 acres 50 0.5 - 1.0 

Beehive Coke Works 40-100 acres 1,900-3,800 0.5 - 2.0 

Merchant & Utility Coke 

Works 

40-100 acres 100-120 10.0 - 100.0 

Charcoal Plants 10-100 acres 1,900-2,850 0.5 - 2.0 

Tar Distilleries 10-100 acres 150-300 10.0 - 100.0 

WWI Federal Wood Tar 

Distillation Plantsc,d 

40-200 acres 11 1.0 - 2.0 

WWI Federal Toluene 

Plantsc,d 

80-200 acres 10 1.0 - 5.0 

Wood Preservation Plants 10-200 acres 480-600 5.0 - 20.0 

U.S. Bureau of Mines ­

Coal Gasification Plantsc 

10-40 acres 33-49 1.0 - 2.0 

U.S. Department of Energy 

- Coal Gasification Plantsc 

10-40 acres 57-67 1.0 - 2.0 

Source: Appendix Table D-2. 

Chapter 10: Manufactured Gas Plant Sites Page 10-14 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

These data provide a reasonable estimate of a range of probable cleanup costs for all MGPs, 

should they require cleanup. However, because these costs vary widely, and because the above 

values of the number of MGP sites remaining to be cleaned up are estimates, the cost estimates 

provided here are considered a general indication of the market size. 

10.7 References

American City & County, 2001. “The Problem of Manufactured Gas Plants,” roundtable 

discussion, American City & County, March 1, 2001. 

http://www.americancityandcounty.com/ar/government_problem_manufactured_gas 

Brown, Richard A., M. Jackson, and M. Loucy, 1995. “A Rational Approach to the Remediation 

of Soil and Groundwater at Manufactured Gas Plants,” Land Contamination & Reclamation, 

Vol. III, No. 4. 

EI Digest, 1995. “Manufactured Gas Plants,” EI Digest, p.1, May 1995. 

Fischer, et. al., 1999. Manufactured Gas Plants: The Environmental Legacy, Fisher, Corey L.J., 

Schmitter, Robert D., and Lane, Eliesh O’Neil, South & Southwest Hazardous Substance 

Research Center, Georgia Institute of Technology, Atlanta, GA, November, 1999. 

http://www.hsrc.org/hsrc/html/tosc/sswtosc/mgp.html 

Ginsburg, Janet, 2001. “A Deadly Legacy of Poisons from the Past,” Business Online, July 2, 

2001. http://www.businessweek.com/magazine/content/01_27/b3739186.htm 

Hatheway, Allen W., 1997. “Estimated Number of Manufactured Gas and Other Coal-Tar Sites 

in the United States,” Environmental & Engineering Geoscience, Vol. III, No. 1, Spring, pp. 

141-142 (and 2003 updated and expanded version). http://www.allen@hatheway.net

Hatheway, Allen W., 2002. “Geoenvironmental protocol for site and waste characterization of 

former manufactured gas plants; worldwide remediation challenge in semi-volatile organic 

wastes,” Engineering Geology 64, pp. 317-338. 

Heritage Research Center, Ltd., 2002. A Brief History of the Manufactured Gas Industry in the 

United States. http://www.heritageresearch.com/manufactured_gas_F.htm 

Middleton, Andrew C., 1995. “Historical Overview of Manufactured Gas Processes Used in the 

United States,” Land Contamination & Reclamation, Vol. III, No. 4. 

Mon, Gonzalo J., 1995. “History of the Manufactured Gas Business in the United States,” in 

“International Symposium and Trade Fair on the Clean-up of Manufactured Gas Plants,” Land 

Contamination & Reclamation, Vol. III, No. 4. 

Murarka, Ishwar P., 1995. “Site Management Trends and Research Directions in the United 

States of America,” Land Contamination & Reclamation, Vol. III, No. 4. 

Chapter 10: Manufactured Gas Plant Sites Page 10-15 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Neuhauser, Edward, 1995. “Manufactured Gas Plant Site Ownership in the 1990s,” Land 

Contamination & Reclamation, Vol. III, No. 4. 

NYDEC, 2003. New York State Department of Environmental Conservation, web site on 

General Information About MGPs. http://www.dec.state.ny.us/website/der/mgp/mgp_faq.html 

U.S. EPA, 2003. Report on the Innovative Approaches to Manufactured Gas Plant Site 

Characterization, EPA-542-R-01/003, U.S. Environmental Protection Agency, Office of Solid 

Waste and Emergency Response, Technology Innovation Office. 

WDNR, 1999. Wisconsin Department of Natural Resources, Contaminants of Concern from 

MGP Waste and By-products. 

http://www.dnr.state.wi.us/org/water/wm/wqs/sediment/assessment/mgp 

Chapter 10: Manufactured Gas Plant Sites Page 10-16 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Chapter 11 

Demand for Remediation of Mining Sites 

The thousands of abandoned, inactive, and operating mines in the United States present serious 

potential risks to human health and the environment. The extraction and processing of metals, 

nonmetal minerals, and coal result in the generation of large quantities of contaminated solid 

wastes, wastewater, and air emissions which cause significant environmental impacts, including 

groundwater and surface water contamination, soil erosion, and soil contamination. Mining 

wastes have been detected many miles downstream from their source. This Chapter presents 

estimates of the extent of mining waste environmental problems in the U.S. and its implications 

for the demand for remediation technologies. 

There is no separate remediation program for the characterization and remediation of mining 

sites. Mining sites may be addressed under one or more of the major remediation programs, such 

as Superfund, RCRA, or a state environmental program, depending on the nature and extent of 

the contamination and other site-specific factors. Because these sites may be managed under 

different remediation programs, the estimates of the market 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. Addressing mining sites across all remediation 

programs provides vendors and regulators information from the unique perspective addressing 

the hazardous waste challenges facing a specific industrial sector. 

The Mine Safety and Health Administration reports that, as of 2001, there were approximately 

14,500 operating coal, metal, and nonmetal mineral mines in the U.S. The Bureau of Land 

Management (BLM), a component of the Department of Interior, estimates that there are 

between 100,000 and over 500,000 small and mid-sized abandoned hard rock (metals and 

nonmetal minerals) mines on private, state and federal lands in the west and approximately 

13,000 abandoned coal mines, mostly small and mid-sized, in the east. Many of these properties 

continue to threaten human health and the environment because of the materials left behind and 

because mined-out areas and materials are exposed to the elements. There is a wide range of 

estimates and opinions on how many of these properties pose a serious environmental risk and 

are likely candidates for remediation. The most promising estimates indicate that approximately 

5 to 10 percent of abandoned mines pose a significant risk to the environment and people. 

11.1 Industry Description 

Identifying, prioritizing, and implementing the necessary cleanup actions at thousands of sites 

across the country is expected to take many years. To understand the nature of and potential 

extent of the cleanup effort, it is necessary to understand the nature of mining operations in the 

U.S. This section summarizes the basic characteristics of mining operation in the U.S. and their 

environmental impacts, including the types of mines, common production processes and their 

likely waste streams, and the regulatory programs that address them. 

Chapter 11. Mining Sites Page 11-1 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

11.1.1 Types of Mining 

The Department of Commerce identifies three major segments of the mining industry: metal ore 

mining, nonmetallic mineral mining, and coal mining. The term “mining” is used in the broad 

sense to include ore extraction, quarrying, and beneficiation (e.g., crushing, screening, washing, 

sizing, concentrating, and floatation), customarily done at the mine site. The term “hardrock 

mining” refers primarily to the extraction and processing of metals (e.g., copper, gold, iron, lead, 

magnesium, silver, uranium, zinc) and nonmetallic, non-fuel minerals (e.g., asbestos, gypsum, 

phosphate rock, sulfur). Hardrock minerals are key raw materials used in many industrial 

products. Non-hardrock mineral mines, such as sand, gravel, and limestone are not addressed in 

this study. 

Most of the minerals and coal extraction in this country is done with surface mining techniques, 

primarily open pit mining. Underground techniques may be used when the deposits are hundreds 

or thousands of feet below surface level. Non-metallic mineral deposits generally have far less 

waste rock and foreign materials associated with them than metallic deposits. Wastes associated 

with non-metallic minerals and waste rock are generally of lower toxicity and more manageable 

than those associated with hardrock or coal mining wastes. 

11.1.2 Mining Processes

Mining generally involves three basic processes–extraction, beneficiation, and processing–each 

of which can seriously impact the environment and human health (U.S. EPA 2000). 

Extraction is the removal of rock and other materials that contain the target ore/mineral. There 

are three basic types of extraction used today: surface, underground, and in-situ solution mining. 

A fourth type, placer mining, is no longer used in the U.S.

 • Surface mining accounts for the greatest volume of mined materials in the U.S. It involves 

rock removal, blasting, mucking (removal and transport of ore), crushing, and hauling. The 

open pit method is the most common form of surface mining. This technique allows access 

to the ore bodies by removing the surface covering (overburden) of soil and rock. Orebearing rock is then removed for further processing to extract the target mineral. After the 

ore body is exhausted, open pits and huge mounds of finely-ground tailings and coarser 

waste rock are usually left behind. The extraction process generates large volumes of waste 

rock because of the high waste-to-product ratios associated with most ores. 

Strip mining is likely to be used to extract horizontal, close to the surface deposits. It has 

been used for phosphate mining and coal mining. The strip mining technique is usually more 

efficient but also more environmentally destructive than underground mining. In this 

process, the soil and rock above the seam of coal or other target mineral are removed. The 

seam is then blasted, the target material is scooped up by huge front end loaders or power 

shovels and transported to a processing plant where it is subjected to physical and/or 

chemical processes to separate the target material from waste rock and other materials. The 

coarser waste rock is piled up adjacent to the mined out area, and the finer tailings from the 

plant are discharged as a thick slurry into an impoundment. After the mining operations 

Chapter 11. Mining Sites Page 11-2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

have ceased, the mine is reclaimed by regrading waste rock and other wastes to approximate 

the original contours of the land and replanting the area with native vegetation. Mountaintop 

mining, a relatively new variant of strip mining, is common in locations where valleys 

adjacent to the areas being mined can serve as repositories for the soil and waste rock.

 • Underground mining involves digging tunnels and shafts to reach mineral-rich ore. The 

most common scenario is to sink vertical shafts or dig adits (horizontal entrances into 

hillsides) to reach into the mineral deposit and then bore a series of horizontal tunnels to 

access the entire deposit. Underground techniques may be used when the deposits are 

hundreds or thousands of feet below surface level. After the ore body is exhausted, 

underground tunnel complexes are left behind. In order to support the roof rock of coal 

tunnels, about 50 percent of the coal is often left behind in the form of pillars. A variant of 

this technique, in which hydraulic jacks are used to support the roof, allows for an 80 to 90 

percent recovery rate; although this technique can result in subsidence once the equipment 

is removed. Tunneling generates considerable amounts of waste rock which are either 

disposed of underground or are placed in waste rock piles.

 • Underground mining is more expensive than surface mining, requiring more skilled workers 

and specialized equipment. Coal, salt, and potash are often mined underground. As with 

hardrock mining, the minerals must be separated from the waste rock.

 • in-situ solution mining involves drilling wells and circulating a solvent into an ore body left 

in place to extract minerals. Although this causes little surface physical disturbance, the 

solvents and pumping may adversely affect groundwater quality.

 • Placer mining, a gold mining technique that was once common in the United States, is still 

being used to extract surface deposits of gold in Alaska. In this technique, miners dam small 

streams and dig up and process stream sediments to extract gold. 

Beneficiation involves separating the target ore from waste rock. Beneficiation activities 

generally do not change the mineral values themselves other than by reducing (e.g. crushing or 

grinding) or enlarging (pelletizing or briquetting) particle size to facilitate processing. Some 

common types of beneficiation include:

 • Gravity separation relies on large differences in density between the target metal and the 

surrounding materials. This techniques utilizes devices such as trommels, sluices, cyclones, 

jigs, and shaker tables. 

• Magnetic separation is applied in the ore milling industry for iron, columbium and tantalum, 

and tungsten. Among other things, it is used for the separation of multiple valuable minerals 

recovered from complex ores.

 • Electrostatic separation involves taking ore that is charged and dropping the charged

particles onto a conductive rotating drum. The particles lose the charge quickly and are

thrown off and collected.

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• Flotation, the most common beneficiation method, involves adding a reagent chemical to ore 

slurry causing minerals to become less dense than the waste rock or other worthless material 

and rise to the top of the tank. 

• Leaching involves extracting a soluble metallic compound by dissolving the ore with a

solvent, such as sulfuric acid (copper) or sodium cyanide solution (gold).

Processing is the refining of ore after beneficiation to extract the target material. Mineral 

processing operations can be based on high temperatures (i.e. smelting, roasting), 

hydrometallurgical (the use of liquid reagents in the treatment or reduction of ores), or 

electrometallurgical techniques (the use of electric and electrolytic processes to purify metals or 

reduce metallic compounds to metals). The most common of these processes is smelting which 

involves applying heat to a batch of ore to separate and refine the metal. 

11.1.3 Types of Wastes 

The extraction, beneficiation, and processing steps can result in four types of wastes: mine water, 

waste rock, overburden, and tailings. 

Mine water consists of all water that collects in mine works, both surface and underground, as a 

result of inflow from precipitation and surface water and groundwater seepage. In active mining 

operations this water can be pumped out and used for other mining activities or discharged to 

surface water under a water discharge permit. At inactive or abandoned mines the water 

accumulates in the mine pit and saturates the fill material. Depending on the source of the water 

and the regional and hydrological conditions, this mine water can have high concentrations of 

heavy metals and total dissolved solids as well as elevated temperatures and altered pH, which 

may contaminate down-gradient groundwater and surface water. 

Waste rock consists of non-mineralized and low-grade mineralized rock removed from an ore 

body during extraction. It includes granular, broken rock that range in size from fine sand to 

large boulders and is typically piled or disposed in piles or dumps near the point of extraction. 

The geochemistry of waste rock varies widely from mine to mine and may even vary 

significantly at individual mines over time. Generally, waste rock contains some concentration of 

the target mineral, along with other metals and minerals. Waste rock can be a source of acid rock 

drainage and heavy metals such as arsenic. Acid rock drainage occurs when precipitation or 

runoff leaches sulfuric and other materials from waste rock. The resulting contaminated water 

can flow offsite, where it may contaminate soil, surface waters, and groundwater. 

Overburden is the surface rock and soil removed to expose the ore at surface mines. As long as 

this material is salvaged and returned to the mine site during closure or decommissioning it is 

exempt from Resource Conservation and Recovery Act (RCRA) regulations. 

Tailings are the coarsely and finely ground waste portions of mined material remaining after 

beneficiation. The physical and chemical characteristics of tailings vary according to the ore 

being mined and the beneficiation process used. Tailings have traditionally been disposed of in a 

variety of configurations including impoundments, piles, in backfill for underground mines, and 

under water. Subaqueous disposal is currently prohibited by the Clean Water Act (CWA). 

Chapter 11. Mining Sites Page 11-4
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Like mineral mining, coal mining generates large quantities of solid waste materials which are 

piled on the surface and subject to saturation and runoff resulting in an increase of total 

suspended solids in water bodies, acid drainage into surface and groundwater, and increased 

build-up of sediments in local waters. At the processing stage, the impurities removed during the 

screening and washing of the coal are also placed in waste piles, thereby adding to the hazardous 

waste problems of the coal mining process. Coal piles are flammable, susceptible to spontaneous 

combustion, and prone to erosion which leads to highly acidic runoff and seepage. 

11.1.4 Regulatory Programs 

Mining activities, including the investigation and cleanup of abandoned mine sites, are managed 

in accordance with a complex web of jurisdictions, laws, and regulations covering several 

environmental media. Generally, the Comprehensive Environmental Response Compensation 

and Liability Act (CERCLA) and CWA are the most prevalent statutes that are applicable to 

mine cleanup programs. For coal mining, the Surface Mining Control and Reclamation Act of 

1977 is the primary authority on mining operations and reclamation. Depending on the 

circumstances of any specific mine site, its operations and/or cleanup may also be governed by 

the provisions of RCRA, National Environmental Policy Act (NEPA), the Clean Air Act, the 

Emergency Planning and Community Right to know Act, the Safe Drinking Water Act, the 

Atomic Energy Act, the Toxic Substances Control Act, and state or local statutes. Cleanup 

requirements may further be complicated by land ownership and tenancy issues, such as whether 

it is on federal, state, or tribal land. 

This document concentrates on the environmental aspects of mining sites. Many mine sites also 

contain physical hazards, such as open shafts and unstable slopes and buildings. Although these 

safety hazards are not the focus of this report, they also deserve consideration in developing site 

management strategies since they are part of the overall responsibility of site owners. 

CERCLA. CERCLA’s main applicability to mining activities is that it provides EPA with the 

authority to conduct or require a private party to conduct a removal or remedial activity. Federal 

agencies that are responsible for land must comply in the same manner as private parties with the 

provisions of CERCLA (and RCRA). This responsibility is especially important for the 

Department of Interior (BLM, Fish and Wildlife Service, National Park Service, Bureau of 

Indian Affairs, and Bureau of Reclamation) and USDA (U.S. Forest Service), DOD, and DOE, 

each of which is responsible for management of mining sites. Their responsibilities also extend 

to many non-NPL mining sites. Where a site crosses property boundaries between private and 

federal ownership, all parties generally coordinate to develop agreements that specify the 

responsibilities of all parties. Inactive sites classified as having the most severe environmental 

problems are placed on the NPL. As of December 2002, close to 90 mining and processing sites 

were listed on the NPL. 

Under CERCLA, EPA can require compliance with appropriate regulations adopted under other 

relevant and appropriate regulations (ARARs), which may include state standards as well as 

other federal regulations such as RCRA. EPA has published a manual outlining all potential 

federal ARARs that may be requirements at Superfund sites (CERCLA Compliance With Other 

Laws Manual, Part I, August, 1988, and Part II, August 1989). 

Chapter 11. Mining Sites Page 11-5 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Clean Water Act (CWA). The CWA provides a mandate for controlling discharges from point 

sources and non-point sources of pollution. The Act prohibits any pollution discharges from 

“point sources” into navigable waters of the United States (33 U.S.C. § 1251-1387). A point 

source includes any “discernible, confined, and discrete conveyance, including such structures as 

pipes, ditches, and channels.” All point source discharges to surface waters must be permitted by 

EPA or authorized states, in accordance with the National Pollutant Discharge Elimination 

System (NPDES). This requirement is especially important to the mining industry, since waters 

coming into contact with mining materials often become acidic or contaminated with other 

materials. The CWA also regulates the construction of impoundments that serve as repositories 

for tailings and treatment of waste from mining and mineral processing operations. Although 

mining permits are issued by the states, EPA’s Office of Water may review these permits to 

ensure compliance and proper application of guidelines. A landowner is liable for pollution 

stemming from activities that took place prior to his/her ownership of the land. 

RCRA. Section 3001(b)(3)(A)(ii) of RCRA excluded certain solid wastes from mining and 

processing from regulation as a hazardous waste under Subtitle C, pending certain studies by 

EPA. Congress included this provision, also known as the “Bevill Amendment,” to apply to 

“high-volume, low-hazard waste.”1

 In 1989 EPA promulgated regulations defining the criteria 

for “high volume, low hazard” and published a list of waste types that are no longer excluded. 

EPA also stated that it may conduct evaluations of additional waste streams in the future to 

determine whether they should remain excluded (40 CFR Part 26, Mining Waste Exclusion, 54 

FR 36592, September 1, 1989). The rule does not impose Subtitle C requirements on mineral 

processing wastes that were disposed prior to the effective date of the rule. 

As a result of these regulatory proceedings, wastes from the extraction and beneficiation 

processes continue to be excluded from Subtitle C requirements. Only 20 wastes from mineral 

processing are exempt from RCRA (40 CFR 261.4(b)(7)). Today, relatively little mining waste is 

subject to RCRA regulation as hazardous waste. Overburden is exempt from RCRA regulations, 

so long as it is returned to the mine site. 

Surface Mining Control and Reclamation Act (SMCRA). The SMCRA was passed in 1977 

to ensure that coal mines are operated in a manner that protects citizens and the environment 

during mining, ensure that the land is restored to beneficial use following mining, and mitigate 

the effects of past mining by aggressively pursuing reclamation of abandoned mine lands. The 

Surface Mining Law gives primary responsibility for regulating surface coal mine reclamation to 

the states, a responsibility that 31 states have chosen to exercise. 

The Office of Surface Mining (OSM) was established within the Department of the Interior to 

help carry out the SMCRA. The OSM handles enforcement on federal lands and Indian 

Reservations and in coal states that have not set up regulatory programs. Funds for reclamation 

of abandoned mines come from tonnage-based fees paid by active coal mines - 35¢/ton of 

surface mined coal, 15¢/ton of coal mined underground, and 10¢/ton of lignite. The fund consists 

of fees, contributions, late payment interest, penalties, administrative charges, and interest earned 

The Bevill Amendment was Section 7 of Public Law 96-482, which was enacted on October 21, 1980, to include 

several amendments to RCRA. 

Chapter 11. Mining Sites Page 11-6 

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on investment of principal. From January 1978 when the first fees were paid through March 

2003 over $6.7 billion has been collected. As of March 2003 the balance of unappropriated 

funds is in excess of $1.4 billion (DOI, 2003). States that have completed the reclamation of coal 

mines can apply unused funds for the remediation of safety and environmental hazards at 

hardrock and other non-coal sites. 

11.1.5 Mines on Federal Lands

Hardrock and non-coal mining exist in all 50 states. A significant number of both active and 

abandoned mines are located on public lands. Three of the four major land managing agencies ­

the Bureau of Land Management, the National Park Service, and the Fish and Wildlife Service ­

are part of the Department of the Interior. The fourth agency, the Forest Service (USFS), is part 

of the Department of Agriculture (USDA). Most federal lands are managed by the BLM and the 

USFS. 

Most of the BLM-managed 264 million acres are in 12 western states, and 90 percent of this land 

is open to mining. The Bureau administers 700 million acres of sub-surface mineral assets 

throughout the nation. The Bureau has a budget of $1.8 billion and a workforce of about 9,000 

employees. The USFS manages 163 million acres in the west of which about 80 percent is open 

to mining. Together, the two land management agencies are responsible for 38 percent of the 

total area of the western states. These lands are important for their minerals, timber, and grazing 

resources; as a source of clean water; as a location for recreational activities; and as wildlife 

habitats and scenic areas, among other purposes. Regulations promulgated by the BLM (1980) 

and the Forest Service (1974), require that once mining activities are completed, mine operators 

must reclaim all areas disturbed by their operations (U.S. GAO, 1996). Prior to these 

regulations, state laws required reclamation of mined sites. 

With regard to coal mines, OSM is responsible for enforcement of SMCRA on federal lands and 

Indian reservations and in coal states that have not set up regulatory programs. As noted above, 

the Surface Mining Law gives primary responsibility for regulating surface coal mine 

reclamation to the states, a responsibility that 31 states have chosen to exercise. 

Funding Cleanups 

Unlike coal mining, there is no single source of federal funding for the reclamation of abandoned 

hardrock mining lands. However, as noted above, states with both coal and non-coal mines may 

use funds left over from the coal mining reclamation funds for non-coal mining remediation. 

There have been a number of efforts over the years to pass Good Samaritan and/or a hardrock 

mines reclamation fund legislation.2

 A bill proposed in 2002 (HR 4078) would have created a 

sliding scale fee on existing mining operations and a permit program detailing cleanup 

A “Good Samaritan” provision would protect a remediating agency or "Good Samaritan" who does not otherwise have 

liability for abandoned or inactive mine sites, and that attempts to improve the conditions at these sites even though all impacts 

from the site will not be eliminated, from becoming legally responsible, under section 301(a) and section 402 of the Clean Water 

Act, for any continuing discharges from the mined land after completion of a cleanup project. This potential liability is an 

overwhelming disincentive to voluntary remedial activities financed or conducted by public entities to address the serious 

problems associated with abandoned or inactive mined lands. 

Chapter 11. Mining Sites Page 11-7 

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requirements and liability limits of parties undertaking voluntary cleanup of the sites. Proponents 

of this legislation estimate that the program outlined in this bill would generate approximately 

$45 million annually to clean up abandoned mines. At least one other proposal in committee 

excludes the funds and focuses solely on the Good Samaritan issue. 

The Role of Watershed Management 

In the 1990s, the DOI and USDA, in conjunction with the EPA, began to focus environmental 

remediation on the nation’s watersheds and the problems caused by abandoned mines on 

federally administered lands. Investigations into watersheds involve surface and groundwater 

sampling, adit discharges, surface runoff, mine wastes, and surrounding rock to locate and 

characterize the contamination. Biological assessments are conducted on local species, 

engineering cost estimates for reclamation are developed, and searches are performed to identify 

potentially responsible parties. This interagency effort eventually led to a cooperative agreement 

between the National Mining Association, Western Governors Association and Department of 

Energy resulting in the establishment of the Abandoned Mine Land Initiative. The goal of this 

Initiative is to increase public and private investment in remediation and consolidate financial 

resources and technological expertise to promote cleanup. By 1999 DOE’s Federal Energy 

Technology Center, now known as the National Energy Technology Laboratory, signed an 

agreement with the Office of Surface Mining to share technical services, expertise, and 

information on mining and environmental issues (Greeley, 1999). 

11.2 Factors Affecting Demand

The following primary factors influence the market for remediation of mine lands.

 • Federal and state agencies that manage mine lands are constrained by budget considerations. 

The reclamation budgets for the federal agencies are small in comparison to the magnitude 

of the abandoned mine waste problem. The OSM fund is designated primarily for coal 

mines, and there is very little left for non-coal mining. In addition, the law mandates that 

priority be given to addressing safety, health and general welfare rather than environmental 

problems.

 • A growing market for first or second homes in previously sparsely-populated mining areas 

may foster increased demand for cleanup of some sites. Because mine wastes can travel long 

distances, contamination from abandoned mines can affect areas many miles downstream 

from the source. 

• Increase of recreational activities on public lands, in the vicinity of many abandoned mine 

sites, may spark increased demand for cleanup or restrictions on park use.

 • The transfer of properties in mining areas where complete control of the source of the 

pollution has not been achieved may require institutional controls to ensure that prospective 

purchasers or developers are aware of any potential risks resulting from a mining operation. 

Thus, there is a growing need for methods to ensure compliance with institutional controls. 

Chapter 11. Mining Sites Page 11-8 
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• A number of the over 14,000 active and inactive mine sites that are not abandoned also may 

require remediation. Releases of contaminants into the environment can result from 

inadequately designed facilities such as tailings dams, accidents, leaks and spills, or failure 

to properly operate a facility. Thus some portion of these sites are likely to require 

remediation of soil, groundwater, and/or surface water, among other things.

 • The passage of Good Samaritan legislation would probably encourage more state and local 

governments to undertake some remediation. This point is explained in Section 11.1.5. 

11.3 Number of Sites

All mining operations have the potential for releasing hazardous materials to the environment. 

However because data collection practices vary widely among various sources, it is difficult to 

establish the number of mines in the U.S. Moreover, not all of these facilities will actually 

require remediation. Until further investigation, the number of mining sites and the number of 

these sites that are likely to require remediation can only be estimated. 

Active Mines 

Information on the numbers and production levels of active mines are available in Department of 

Interior, Department of Energy, Department of Labor and the National Mining Association data. 

Exhibit 11-1 summarizes these numbers by type of mining operation for the year 2001. The 

1,714 active coal mines operating in 26 states produced a total of 1,121.3 million short tons, 66.2 

percent at surface mines and 33.8 percent at underground mines. The fees that these mines pay 

into the Office of Surface Mining reclamation fund for abandoned mines is based on this 

tonnage. Almost 92 percent of active non-coal mines are stone and sand/gravel operations. Metal 

and non-metal mineral mines account for 1,039 sites, or almost 8 percent the mines and 

processing facilities. Nevertheless, these non-coal mining activities, which operate in all fifty 

states, are responsible for the production of between 1 and 2 billion tons of mine waste annually. 

In the nine western states, where most of the hardrock mines are concentrated, the industry is 

responsible for polluting 3,400 miles of streams and over 440,000 acres of land (U.S. EPA 

2000b). Although remediation will probably be needed at active mines, no quantitative estimate 

is available. 

Abandoned Mines 

There are an estimated 13,000 abandoned coal mines, mostly small and mid-sized in the east 

(Stone, 2001). Reclamation work at these sites may be funded in part by the Abandoned Mine 

Land Fund. However, by law, the bulk of the funding (86 percent in FY 2002) is given to 

priority 1 and 2 sites, sites with problems that pose a threat to the health, safety and general 

welfare of people. Only 16 percent in FY 2002 went to funding priority 3, environmental 

hazards. If a state has completed its 1 and 2 priority sites, funding can be applied to priority 3 

sites. According to the 2002 annual report, $13.9 million went to funding watershed projects and 

another $1.6 million in the form of watershed cooperative agreements for acid mine drainage 

treatment programs. 

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Exhibit 11-1. Number of Active Mining Sites - 2001 

Underground 

Mines 

Surface 

Mines 

Total 

Active Mines 

Processing 

Facilities Total 

Coal 777 937 1,714 418 2,122 

Metal 78 124 202 72 274 

Non-metal 

mineral 

44 542 586 179 765 

Stone 113 3,914 4,027 228 4,255 

Sand/Gravel NA 7,069 7,069 NA 7,069 

Total 1,012 12,586 13,416 897 14,485 

Source: National Mining Association, (updated 2003), reprinted from the U.S. Department of Labor, Mine Safety & 

Health Administration, Number of Coal and Non-Fuel Mineral Operations in the United States 

Since the definition of abandoned hardrock and non-metal mineral mines is slightly different 

from state to state and from agency to agency, it is difficult to accurately establish the number of 

these mines around the U.S. In some states, multiple shafts and openings in one location are 

considered a single mine. In other cases, each opening, shaft, or disturbance is considered a 

separate mine. Several organizations have attempted to estimate the number of mines, mostly 

based on data from individual states, federal agencies, and USGS maps. However, these numbers 

cannot be added for an estimate of the total number of sites. Because of the built-in uncertainties, 

most analyses of the scope of the abandoned mine problem are presented in terms of ranges 

(Exhibit 11-2). 

The BLM estimates that 5 percent (5,000-25,000) of the 100,000 - 500,000 abandoned hard rock 

mines on the public lands which the Bureau administers, has caused or could cause 

environmental damage, mostly in the form of water pollution (Stone, 2001). The Forest Service 

estimated that 5 percent of the approximately 25,000 - 35,000 abandoned mine sites on its lands 

would require cleanup under CERCLA and about 12 percent would require remediation of nonCERCLA water quality problems (Greeley, 1999 and U.S.GAO, 1996). The Mineral Policy 

Center estimates that approximately 15,000 of the 557,000 sites have surface or groundwater 

contamination, and an undetermined number have other environmental hazards (Lyon et al, 1993 

and 2003). Based on discussions with officials at land management agencies, states, and EPA 

regional staff, EPA estimates that approximately 5 to 10 percent of abandoned mine lands 

require site investigation and cleanup. 

Given these data, between, 7,700 and 31,000 abandoned mining sites are likely to require 

cleanup. This wide range in the estimate is due primarily to the fact that most sites have not been 

evaluated and, therefore, there is a wide range of estimates regarding how many will require 

remediation. 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit 11-2. Comparison of Estimates of 

Number of Abandoned Hard Rock Mining Sites 

Source 

Estimated Number 

of Sites Explanations/Comments 

Federal Agencies 

Bureau of Land Management 

(Department of Interior) 

1996, 2003 

100,000-500,000 On lands managed by BLM; based on 

targeted surveys conducted by BLM 

and states, and the Abandoned Mine 

Land Inventory which is not yet 

completed. 

Forest Service 

(Department of Agriculture) 

1996, 1999 

25,000-34,500 On lands within FS boundaries; based 

on aerial photos, fieldwork, and Dept. of 

Agriculture data. 

National Park Service 

(Department of Interior) 1996 

2,500 Actual count in some states, not 

including Alaska and part of California 

Fish and Wildlife 

(Department of Interior) 1996 

240 Based on department files and field 

office confirmation 

Bureau of Mines 

(defunct agency) 1996 

15,300 on Dept. of Interior 

lands; 12,500 on Dept. of 

Agriculture lands 

Based on database of past mineral 

deposit activities 

US Geological Survey 

(Department of Interior) 1996 

88,000 on Dept. of Interior 

lands 

Based on data assembled from 

agencies and Western Governors’ 

Association estimates 

Other Organizations 

Mineral Policy Center 

1993, 2003 

557,700 Based on 32 western states; compiled 

from state databases and records 

Western Governors’ 

Association 

1998, 2003 

No total estimates given Estimates for 13 of the 15 states 

involved, if added would total 263,000; 

some state numbers based on 

inventory; range from 150 in North 

Dakota to 100,000 in Arizona; wide 

variations in definition of mines. 

Sources: 

• U.S. GAO, 1996. Federal Land Management, Information on Efforts to Inventory Abandoned Hard Rock Mines, 

GAO-RCED-96-30, February 1996. 

• Stone, George, 2001. Bureau of Land Management, Overview of Mining in the USA , Abandoned Mines. 

Problems, Issues and Policy Challenges for Decision Makers, Santiago, Chile (Updated in conversation in May 

2003). 

• Greeley, Michael N., 1999. US Department of Agriculture - Forest Service, National Reclamation of Abandoned 

Lands. 

• Western Governors Association (1998 ), Cleaning Up Abandoned Mines: A Western Partnership (Updated in 

conversation in May 2003). 

• Lyon, James S., Hilliard, Thomas J., and Bethell, Thomas N., 1993, Burden of Gilt. Mineral Policy Center, 

(Updated in 2003 draft report on Cleaning Up Western Watersheds). 

Chapter 11. Mining Sites Page 11-11 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

11.4 Market Entry Conditions 

The great majority of the sites will be cleaned up under state and local programs, or by private 

parties. Federal agencies, since they are often the land managers, will also be involved. Although 

their remediation budgets are small, they may participate in negotiations with stakeholders, seek 

cost recovery, or may participate in cost sharing. 

Superfund site contracting may differ depending on whether the cleanup is fund-lead or PRPlead. For fund-lead sites, the EPA or state site manager will have information on the status of the 

site, the characterization already done on the site, any treatability studies that might be needed, 

and contracting plans and options. For PRP-lead sites, the RPM will be able to refer a vendor to 

the PRPs and their contractors. Large PRP-lead sites are usually handled by national 

architectural and engineering firms who tend to contract out elements of the cleanup to local 

operators. Technology vendors might contact these firms directly for targeted opportunities 

within larger cleanup efforts. 

11.5 Estimated Cleanup Costs

No single source provides information on remediation costs for mining sites. Some sources deal 

with a specific category of sites, while others fold mining remediation costs into an overall 

estimate for total reclamation. Because most of the latter category of estimates include costs for 

activities beyond remediation, such as correcting safety hazards and landscaping, the amount of 

the costs attributable to remediation is unknown.3 

The Mineral Policy Center does break down cleanup costs by category and provides estimates 

for surface and groundwater cleanup and for cleanup of Superfund sites. According to the MPC, 

cleanup of 14,400 surface water contaminated sites would run $1-3 million per site, cleanup of 

500 groundwater contaminated sites would run $7.5-12.5 million per site, and Superfund sites 

would run $250-350 million per site. However, the MPC analysis does not consider other media, 

its estimates are based on only 32 states, and the per site range of cost estimated for Superfund 

sites is considerably higher than estimates from other sources both inside and outside of the 

EPA. A reasonable estimate can be developed by combining the MPC’s non-Superfund estimates 

with per site Superfund cleanup estimates derived from Resources for the Future and EPA 

records. These estimates are derived from data from EPA’s regional offices. Based on these data, 

the cost of remediating all hardrock mines is estimated to be between $20 and $54 billion. NPL 

sites account for about $3.5 billion of this amount. These estimates are shown in Exhibit 11-3. 

These estimates represents costs necessary to clean up sites according to current regulatory 

standards and practices. However, if current levels of funding at the federal, state, and local 

levels continue, these sites are not likely to be cleaned up in 30 years. Total federal, state, and 

PRP outlays for mining site remediation has been averaging no more than $100-150 million 

Nevertheless, these data provide some useful insight. These estimates range from $165 million for the National 

Park Service, $4.7 billion for the Forest Service, and $4 to $35.3 billion for the Bureau of Mines (GAO, 1996). The 

Mine Waste Technology Program Annual Report for 2000 contains estimated remediation costs for all abandoned 

non-coal mine sites in the 15 western states (EPA 2000b). The report estimates that the cost of cleaning up these 

sites will be between $4 and $45 billion. 

Chapter 11. Mining Sites Page 11-12 

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annually in recent years. At this rate of expenditures, no more than 8-20 percent of all the 

cleanup work could be complete in 30 years. 

Exhibit 11-3. Estimated Remediation Costs for U.S. Hardrock Mines 

Type of Site 

Number of 

Sites 

Average Cost Per 

site ($Millions) 

Cost 

($Billions) 

Surface water contaminationa 14,400 1 - 3 14.4 - 43.2 

Groundwater contaminationa 500 7.5 - 12.5 2.5 - 7.5 

Superfund Mega sitesb 20 100 2.0 

Superfund Non-mega sitesb 70 22c 1.5 

Total 20.4 - 54.2 

a Source: Lyon, James S., Hilliard, Thomas J., and Bethell, Thomas N.,, Burden of Gilt. Mineral Policy Center, 

Washington, D.C., 1993. This estimate may not include costs for soil and debris remediation. 

b Source: Approximation based on EPA report, supplemented with updated data (EPA 2000a) c Source: Probst, Katherine N., Konisky, David M., Hersh, Robert, Batz, Michael B., and Walker, Katherine D., 

(2001). Superfund’s Future What Will It Cost?, Resources for the Future, Washington, D.C. 

11.6 Remediation Technologies

There are a number of conventional technologies, both treatment and containment/diversion, that 

have become standard practice in the mining and mineral processing industries. Treatment 

technologies which involve changing the composition of the contaminant or limiting its mobility 

include chemical treatment (i.e. lime to neutralize acid drainage), stabilization (i.e pH 

adjustment), solidification (i.e. solidifying contaminant using cement), solvent extraction (i.e. 

leaching), soil washing, and soil flushing. When treatment technologies cannot control the 

contaminants to an acceptable level, collection, diversion, and containment technologies are 

used. These include landfill disposal, a variety of cutoff walls (i.e. slurry, cement, sheet piling), 

pumping groundwater for treatment, capping, diversion and erosion controls. 

The prevalent technology today for the single most addressed issue in the remediation of mining 

waste is physical/chemical treatment of wastewater using settling agents in clarifying tanks to 

precipitate the heavy metals. This treatment costs between $0.5 to $1.00 per thousand gallons 

treated. A similar but somewhat less expensive and less successful method involves adding the 

chemicals to wastewater in a settling pond. A more innovative technology, mostly still in pilot or 

field scale operation, is the anaerobic bioreactor. This process involves adding biological 

nutrients to stimulate natural bioorganisms to stabilize heavy metals. Thus far, this technology 

has not caught on, probably because early models of the technology failed. The estimated costs 

for this treatment is $0.05 per 1,000 gallons. 

Chapter 11. Mining Sites Page 11-13 
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Chapter 11. Mining Sites Page 11-14

11.7 Research and Development

There are two distinct EPA sponsored programs that focus on mining and mine waste. They

work jointly on some projects and with other government, academic and private entities on a

variety of research programs.

The Mine Waste Technology Program (MWTP) in Butte Montana is funded by EPA and jointly

administered by EPA and DOE. MSE Technology Applications, Inc. is the principal contractor

for the MWTP, with Montana Tech serving as a subcontractor for many of the projects. The

Bureau of Land Management and Forest Service provide sites for demonstrations of

technologies. The objective of the program is to develop and prove technologies that provide

satisfactory short- and long-term solutions to the remedial problems facing abandoned mines and

the ongoing compliance problems associated with active mines. Its activities include testing and

evaluation at bench- and pilot-scale and education in training and technology transfer. Priority

areas for research include source control technologies such as sulfate-reducing bacteria and

transport control/pathway interruption techniques; short-term end-of-pipe treatment options for

immediate alleviation of severe environmental problems; and, resource recovery options.

http://www.mtech.edu; and http://www.epa.gov/ord/nrmrl/std/mtb/mwtpannual00.pdf

The Rocky Mountain Regional Hazardous Substance Research Center in Denver, with oversight

from U.S. EPA Region 8, consists of a consortium made up of Colorado State University,

Colorado School of Mines, Montana Tech, and a variety of participants from academe and the

private sector from all over the U.S. and Canada. The center focuses on geochemical, biological,

hydrological/mineralogical and engineering aspects of environmental problems associated with

mining and mine waste. Research is divided into five areas including site characterization and

contaminant transport/transformation; surface water and sediment transport; treatment processes;

technologies; and, ecological and human health toxicity. http://www.engr.colostate.edu/hsrc/

In addition to the targeted mining programs, EPA sponsors the Superfund Innovative

Technology Evaluation (SITE), administered by EPA’s ORD National Risk Management

Research Laboratory. SITE encourages the development and implementation of innovative

treatment technologies for hazardous waste site remediation and monitoring and measuring.

Technology is field tested on hazardous waste materials and engineering and cost data are

gathered so that potential users can assess the technology’s applicability to a particular site. EPA

prepares reports evaluating all available information on the technology. SITE works closely with

Montana Tech, helping to leverage funding for projects. http://www.epa.gov/ord/site/

U.S. DOE’s, National Energy Technology Laboratory conducts in-house and contracted

research and development including on technologies that identify and treat sources of water and

air contamination at coal sites and watershed mapping. It works jointly with EPA on the Mine

Waste Technology Program. http://www.netl.doe.gov

The National Mine Land Reclamation Center (NMLRC), headquartered at West Virginia

University, addresses reclamation issues for both abandoned and active coal mine sites. Program

participants perform research on acid mine drainage, prime farmland restoration, subsidence
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

control, and groundwater purification. The NMLRC provides technical support to local 

watershed initiatives. www.nrcce.wvu.edu/nmlrc 

11.8 References

Barringer, S. 1999. Mining Regulatory Programs in the Western United States: A Survey of State 

Laws and Regulations. Unpublished, 87 pp. 

Buck, Stuart and David Gerard, 2001. Cleaning Up Mining Waste, Political Economy Research

Center. http://www.perc.org/pdf/rs01_1.pdf

BLM, 1999. Surface Management Regulations for Locatable Mineral Operations: Draft 

Environmental Impact Statement, U.S. Department of Interior, Bureau of Land Management. 

Clean Air Task Force, 2001. Cradle to Grave: The Environmental Impacts from Coal. 

http://www.catf.us/publications/reports/cradle_to_grave.php 

Custer, Kelly, 2003. Cleaning up Western Watersheds, Mineral Policy Center, May 2003. 

Greeley, Michael N., 1999. National Reclamation of Abandoned Lands, U.S. Department of 

Agriculture, U.S. Forest Service. http://www.fs.fed.us/geology/amlpaper.htm 

Heritage Research Center, 2003. Mining and the Environment. http://www.heritageresearch.com

Interstate Mining Compact Commission, 1997. Noncoal Mineral Resource Report. 

Kodish, Jeffrey A., 2002. Restoring Inactive and Abandoned Mine Sites: A Guide to Managing 

Environmental Liabilities, http://www.restorationtrust.org/legal_guide.pdf

Lyon, James S., et. al., 1993. Burden of Gilt. (Updated in 2003 draft report on Cleaning Up 

Western Watersheds), James S. Lyon, Hilliard, Thomas J., and Bethell, Thomas N., Mineral

Policy Center.

McElfish, J. M., T. Bernstein, S. P. Bass, and E. Sheldon, 1996. Hard Rock Mining: State

Approaches to Environmental Protection, Environmental Law Institute, Washington, D.C.

National Research Council, 1999. Hardrock Mining on Federal Lands, National Academy Press,

Washington, D.C.

Northwest Mining Association, 1997. Permitting Directory for Hard Rock Mineral Exploration.

Spokane, Washington.

Probst, Katherine N., D.M. Konisky, R. Hersh, M.B. Batz, and K.D. Walker, 2001. Superfund’s

Future What Will It Cost?, Resources for the Future, Washington, D.C.

Chapter 11. Mining Sites Page 11-15 
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Stone, George, Bureau of Land Management, 2001. overview of mining in the USA at the 

Abandoned Mines Problems, Issues and Policy Challenges for Decision Makers Conference, 

Santiago, Chile. www.mineralresourcesforum.org/news_events/release/abandmines1001.htm 

U.S. DOI, 2003. Personal communication, U.S. Department of Interior, Office of Surface Mining 

Reclamation and Enforcement (OSMRE), June 2003. 

U.S. EPA (Environmental Protection Agency), 1989. Mining Waste Exclusion, 40 CFR Part 26, 

54 FR 36592, September 1, 1989. 

U.S. EPA, 1997. National Hardrock Mining Framework, Mine Waste Task Force. 

U.S. EPA, 2000a. Abandoned Mine Site Characterization and Cleanup Handbook, EPA 910-B00-001, http://www.epa.gov/oerrpage/superfund/resources/remedy/pdf/amscch.pdf 

U.S. EPA, 2000b. The Mine Waste Technology Program Annual Report, 

http://www.epa.gov/ord/nrmrl/std/mtb/mwtpannual00.pdf 

U.S. EPA, 2003. EPA and Hardrock Mining: A Source book for Industry in the Northwest and 

Alaska, Region 10, January 2003. 

U.S. EPA, Office of Wastewater Management publications on mining, mining wastes, 

environmental impact, and regulations, http://www.epa.gov/npdes/pubs

U.S. GAO, 1996. Federal Land Management, Information on Efforts to Inventory Abandoned 

Hard Rock Mines, GAO-RCED-96-30, U.S. General Accounting Office, February 1996. 

Western Governors’ Association, 1998. Cleaning Up Abandoned Mines: A Western Partnership. 

 http://www.westgov.org/wga/initiatives/aml/aml.htm 

General Web Sites on Mining 

Mineral Policy Center at http://www.mineralpolicy.org 

National Mining Association at http://www.nma.org 

U.S. Department of Energy, Energy Information Administration.http://www.eia.doe.gov 

U.S. DOI, Office of Surface Mining Reclamation and Enforcement: information on coal mining 

and the Abandoned Mine Lands Program including the inventory system, AML grants, the AML 

fund, and annual reports. http://www.osmre.gov 

U.S. DOI, Bureau of Land Management: information on the Abandoned Mine Lands Program in 

the western states, including project descriptions and the inventory system, 

http://www.blm.gov/aml 

U.S. Department of Labor, Mine Safety and Health Administration at http://www.msha.gov 

Chapter 11. Mining Sites Page 11-16 
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Chapter 12 

Demand for Remediation 

of Drycleaner Sites 

There are approximately 30,000 active commercial drycleaning facilities in the United States 

(IFI, 2003). It has been estimated that soil and groundwater contaminated with drycleaning 

solvent are associated with about 75 percent of these facilities (Schmidt, 1999). This does not 

imply that all of these facilities will require active remediation, but that further investigation is 

warranted. In addition, there is an undetermined number of inactive, or former drycleaning 

locations, many of which have not been identified. Because most drycleaning facilities are in 

urban and suburban areas, drycleaning solvent contamination has impacted many water supply 

wells and threatens many others. Addressing this problem will require the deployment of site 

characterization and remediation technologies at many diverse locations. 

Drycleaning 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 site-specific 

factors. Because these sites may be managed 

under different remediation programs, the 

estimates of the drycleaning site remediation 

market 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. 

12.1 Industry Description 

Drycleaning is the washing of fabrics in nonaqueous solvents. The drycleaning industry 

provides garment cleaning, pressing, 

finishing, and related services, primarily to 

households. Although the sizes of drycleaning 

facilities vary, most are single-facility, 

family-owned businesses. This section 

summarizes the types of drycleaning 

processes, wastes produced, regulatory 

programs that affect demand, and 

industry efforts to address the contamination issues. 

• 

cleanup at an estimated cost of $6.3 billion. 

• 

sites (the facilities closed, moved, or otherwise 

disappeared) that have not been discovered. 

• 

their primary solvent. Older facilities used 

• 

$19,000 to $3 million per site and average 

sites with completed remediations. 

• 

site assessment. 

• 

cleanup funds for drycleaners and several other 

states participate in industry activities through 

other environmental programs in their states. 

• 

states with dedicated drycleanling programs 

have fostered the sharing of substantial 

amounts of information about site 

characterization and cleanup technologies and 

costs, state cleanup program operating 

practices, and drycleaning industry trends. 

Highlights 

An estimated 15,750 active drycleaners require 

In addition to active drycleaners, there may be 

between 9,000 and 90,000 inactive drycleaner 

About 90% of active drycleaners use PCE as 

petroleum solvents, which are LNAPLs. 

Cleanup costs at drycleaner sites range from 

$402,000, based on expenditure data from 50 

On average, about 28% of cleanup costs are for 

Twelve states have dedicated programs and 

The cooperative efforts between EPA and 

Chapter 12: Drycleaning Facility Sites Page 12-1 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

12.1.1 Drycleaning Processes 

Drycleaning operations generally consist of three processes: precleaning, drycleaning, and 

finishing. In addition, many drycleaning establishments also do conventional laundering. 

Precleaning 

Prior to being dry cleaned, heavily stained garments are usually pre-cleaned, or “spotted.” Spot 

cleaning may also be performed after fabrics are drycleaned and stains still remain on the fabric. 

A wide variety of chemicals may be used in spotting, depending on the type of stain and fabric. 

Spotting is generally done on a “spotting board,” where spotting agents, steam, and compressed 

air are used to clean stained fabrics. The board is supplied with steam and compressed air to 

allow steam or warm air to be applied to fabrics. Wastes are disposed of through a vacuum line 

and a drain receptacle mounted on the base of the spotting board. The spotting agents are 

contained in bowls or containers placed on or mounted on the board. The chemicals used depend 

on the type of stain and fabric being cleaned. There are three general types:

 • Agents to clean water-soluble stains, 

including synthetic detergents; alkaline

agents such as lye, ammonia, potassium

hydroxide, and sodium hydroxide; and

protein formula detergents containing

digester enzymes and acid agents, such

as acetic acid, hydrofluoric acid, glycolic

acid, and sulfuric acid;

 • Non-aqueous solvents and alcohols, such

as tetrachloroethylene (PCE),

trichloroethylene (TCE), trichloroethane

(TCA), carbon tetrachloride, methylene

chloride, amyl acetate, and petroleum

solvents. These solvents tend to be of

great concern from an environmental and

regulatory standpoint.

 • Bleaches, such as sodium perborate,

hydrogen peroxide, sodium percarbonate,

sodium hypochlorite, sodium bisulfite,

sodium hydrosulfite, titanium sulfate,

and oxalic acid.

Drycleaning Machine Processing 

The drycleaning process is physically similar to the home laundry process, except that clothes 

are washed in a non-aqueous solvent instead of water. Drycleaning is usually done in a 

drycleaning machine that agitates the fabric in solvent, extracts the solvent by spinning it, and 

dries it through a combination of aeration, heat, and tumbling. Over the past century and a half, a 

number of different solvents and machines have been used (See text box on the history of dry 

cleaning). Today, about 80 percent of the drycleaning machines use PCE as the solvent. Solvent 

Facts About PCE 

• 

Industries, Ineos Chlor Americas (Perklone). 

• 

and moisture, or other chlorinated compounds, such 

spotting agents. 

• 

• 

impurities include methyl

and butyl

Manufacturers: Dow Chemical (trade name 

DowPer) Vulcan Chemicals (PerSec), PPG 

Although not normally corrosive, PCE can cause 

corrosive problems when in the presence of heat 

as trichloroethane (TCA), which has been used in 

To mitigate corrosion, small quantities (0.05-0.2% 

by volume) of stabilizers, such as 

nemethylmorpholine, diallylamine, tripropylene, 

cyclohexene oxide, benzotiriazeole, and 

betaethoxypropylnitrile are used. 

PCE used in dry cleaning may also be accompanied 

by other potential pollutants, since some dry 

cleaners may use reclaimed PCE, which can 

contain 1-5% impurities (SCRD 2001).Typical 

 ethyl ketone, mineral 

spirits, toluene, TCA, other chlorinated solvents, 

ated hydroxytoluene (BHT). Non-reclaimed 

PCE is generally 99.9% pure. The impurities are 

other chlorinated hydrocarbons. 

Chapter 12: Drycleaning Facility Sites Page 12-2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

usage has become significantly more efficient over the years, declining from 82 pounds of PCE 

to 10 pounds to clean 1,000 pounds of clothing (National Clothesline, 2002). Coin operated 

drycleaning machines, introduced in the 1960s by Whirlpool Corporation, are no longer being 

manufactured. However, they are still being used, primarily in laundromats. 

History of Drycleaning

i

ith 

i

1920s:

i

bacterial inhibitor. 

1920s-1960s:

• 

(SCRD, 2001). 

• l

• l

2003). 

butyl ether), liquid carbon dioxide, GreenEarthTM (a silicone-based solvent called 

perfluorocarbons). 

Nineteenth Century: The drycleaning industry first emerged in Europe in the first half of the nineteenth century. 

Over the years, a number of different compounds have been used as drycleaning solvents, most of them 

petroleum-based. The most w dely used solvents were petroleum naphtha, benzene, kerosene, and white 

gasoline. White gasoline was the predominant drycleaning solvent in the United States from the late 1800s until 

the early 1920s. Because of the high volatility of gasoline, many fires and explosions were associated w

drycleaning operations. Drycleaning facilities were unable to obtain insurance and many cities banned 

drycleaning operations w thin their city limits. 

 During the 1920s, drycleaners began using Stoddard solvent, a less volatile petroleum solvent (flash 

point of 100 degrees Fahrenheit). From the late 1920s until the 1950s, Stoddard solvent was the predominant 

drycleaning solvent in the United States. This solvent is a mixture of petroleum distillate fractions (petroleum 

naphtha) which is composed of over 200 different compounds. These solvents are composed primarily of 

alkanes and cycloalkanes, w th some aromatic compounds. Over the years, the trend has been toward the 

introduction of higher flash point solvents which have very low aromatics content. 

To mitigate biodegradation of petroleum drycleaning solvents, bacteriacides or biocides are added to the 

system, usually in detergents. The biocides used today are similar to those used in shampoos, laundry products 

and cosmetics (SCRD, 2001). In the past, perchloroethylene (PCE) was added to drycleaning soaps as a 

 From the 1920s until the early 1960s, a number of chlorinated solvents were introduced into 

drycleaning operations. 

Carbon tetrachloride was used in the United States from the 1920s until early 1950s. Because of its high 

toxicity and tendency to corrode equipment, carbon tetrachloride is no longer used as a drycleaning solvent 

Trichloroethylene (TCE) was introduced as a dryc eaning solvent in 1930. Because it causes bleeding of 

some acetate dyes, it is no longer used as a primary drycleaning solvent (SCRD, 2001). 

Perchloroety ene was introduced as a drycleaning solvent in 1934. In 1948, PCE surpassed carbon 

tetrachloride use in drycleaning operations. By the early 1960s, PCE had become the predominant 

drycleaning solvent in the U.S. (Linn, 2002b). 

Today: It is estimated that over 90 percent of the commercial drycleaners in the United States use PCE (IFI, 

Over the years, several other drycleaning solvents have been marketed, but never attained a large market 

share. For example, in the late 1960s, Dupont began marketing a chlorofluorocarbon as a drycleaning agent 

(trade name: valclene, also known as fluorocarbon 113). These are no longer being manufactured, largely 

because of the restrictions on chlorofluorocarbons in the Montreal Protocols. In the early 1980s, Dow Chemical 

introduced TCA as a solvent. It was used by only a small number of drycleaners, particularly for leather 

cleaning. This solvent proved to be unstable and to cause equipment corrosion. It is no longer being used as a 

drycleaning solvent. 

Beginning in the 1990s, several new solvents were developed, including TYNEX (dipropylene glycol tertiarydecameethylcyclopentasiloxane), and PureDry (a mixture of petroleum hydrocarbons, hydrofluoroethanes, and 

Chapter 12: Drycleaning Facility Sites Page 12-3 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

An important influence on the design of drycleaning machines, drycleaning practices, and 

solvent usage are regulations promulgated under the Clean Air Act (CAA) Amendments of 1990. 

The primary CAA regulatory standards for controlling airborne emissions of PCE are the 

National Emission Standards for Hazardous Air Pollutants (NESHAP), which was promulgated 

in September 1993. These regulations require mandates for retrofitting or replacing certain types 

of drycleaning equipment that are based on PCE, record keeping, inspections, and reporting. 

They have encouraged the upgrading or replacement of much equipment in the industry. The 

newer drycleaning machines use considerably less solvent per pound of clothing than older 

machines. Detergents are also used in the drycleaning process to aid in the removal of watersoluble soil, to suspend the soil after it has been removed from the fabric, and as a spotting agent 

to penetrate the fabric, thereby allowing the solvent and water to remove stains. Detergents are 

added to comprise typically 1-2 percent of the drycleaning solvent. The earliest drycleaning 

detergents were soaps, usually composed of surfactant, Stoddard Solvent (see box), free fatty 

acids, and some water to create an emulsion. By the early 1950s, liquid soaps were rapidly being 

replaced by synthetic detergents. 

Finishing 

After drycleaning, fabrics are generally pressed with a steam press. The press is supplied with 

steam lines and serviced by vacuum lines which create a partial vacuum at the bottom of the 

press to hold fabrics in place. Steam from the pressing operation is vented to the atmosphere and 

steam condensate is collected in a tank. 

In addition to pressing, a drycleaner’s service may include the application of one or more 

garment-treating chemicals, including sizing, waterproofing, flame retardants, stain repellants, 

and fabric conditioners. Sizing is a finish used to impart body to a fabric. It is usually applied by 

textile and garment manufacturers, but becomes depleted after several cleanings. Sizing used in 

drycleaning operations consists of polymers or polymer blends and often uses a petroleum 

naphtha carrier. Often, anti-static agents and optical brighteners are added to sizing. The sizing 

can be applied in the drycleaning machine, by dipping fabrics in a tank of sizing, or by spraying 

in an aerosol form. 

Waterproofing agents are usually wax-based products and the predominant carrying agents 

utilized have been PCE and petroleum solvent. Some of the chemicals used in flame retardants 

include decabromodiphenyl oxide (DBDPO), organo-phosphates, phosphate salts, and 

phosphated esters. Stain retardants are generally silicon based and the carrying agents are 

trichloroethane (TCA) or petroleum naphtha (IFI, 1994). These agents may be applied by several 

methods, such as immersion in a dip tank, spraying in the form of an aerosol spray, and in an 

auxiliary tank in the drycleaning machine. Drycleaning solvent may also be used as the carrying 

agent. 

Conventional Laundry Operations 

Many drycleaning establishments also have conventional laundries. If clothing is pre-cleaned 

with solvents prior to laundering, the washwater may contain solvents. 

Chapter 12: Drycleaning Facility Sites Page 12-4 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

12.1.2 Types of Wastes and Waste Management Practices 

The wide variety of chemicals and processes at drycleaning facilities results in a variety of 

wastes. Most of the wastes, especially those from chlorinated solvent drycleaning operations, are 

hazardous (Linn, 2002a). Releases of these wastes to the environment have caused soil and 

groundwater contamination at drycleaning sites. Prior to the enactment of the RCRA in 1980, 

almost none of the waste generated at drycleaning facilities was regulated. The primary wastes 

that contain hazardous materials include the following: 

Contact Water. Contact water is any water that has come into contact with drycleaning 

solvents, solvent vapors or other hazardous materials. The primary sources of contact water are:

 • Separator water. Separator water is generated during solvent recovery processes such as 

distillation. Distillation is used to capture solvent vapors and purify spent solvent. The 

distillation unit is usually incorporated into the modern drycleaning machines, although it is 

a separate piece of equipment in some older machines.

 • Vacuum Water. Vacuum water results from the steam and condensate from steam pressing. 

This water generally contains drycleaning solvent. Vacuum water samples collected from 

PCE drycleaning operations generally contain PCE in concentrations in the tens of parts per 

billion range, although some samples have exceeded 100 parts per billion (Linn p. 2002b).

 • Mop water. It is common to have spills and leaks within a drycleaning facility. When the

floors are mopped, the solvent and other residues will saturate the mop water.

 • Boiler Blowdown Water. This is water from water and steam used to clean the boilers daily. 

Because some drycleaners have disposed of separator water to the boiler, solvent residues 

can remain in the boiler.

 • Conventional Laundry Water. As previously mentioned, the washwater may contain

residues from pre-cleaning chemicals.

Historically, sanitary sewers and septic tanks have been the most common discharge points for 

contact water. Over 70.7 percent of 909 respondents to a 1988 survey conducted by the 

International Fabricare Institute indicated that separator water was being discharged either to a 

sanitary sewer or septic tank (Linn, 2002a). A study of drycleaning contamination in California 

in the early 1990s concluded that “the main discharge point for drycleaners is the sewer line” 

(Izzo, 1992). Studies in California have found evidence of free-phase PCE in sewer lines serving 

drycleaner facilities. Since sewers, especially older ones, have been known to leak, this could be 

a conduit for discharge of PCE and other chemicals to the environment. 

Other disposal practices for contact water have included discharge to the ground, storm sewers, 

soakage pits, blind drains, cooling towers, and boilers at the drycleaning plant. Separator water 

has also been known to be used to mop floors (Linn 2002a). Contact water can also be filtered, 

followed by evaporation or misting to the atmosphere; or removed by a hazardous waste 

management firm. Filtering materials are usually granular activated carbon or polymers, which, 

after use, are considered hazardous waste. 

Still Bottoms. Still bottoms and cooked powder residues are generated from the distillation 

process. They contain grease, oil, detergent, dyes, sizing, waxes, filter materials, and non-volatile 

Chapter 12: Drycleaning Facility Sites Page 12-5 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

residues. Distillation residues can contain up to 75 percent solvent by weight and are hazardous 

waste managed under RCRA. Prior to the mid-1980s, most of these wastes were either disposed 

of in landfills or discharged to the ground (Linn 2002b). 

Muck. Muck is the filter waste generated by the purification and recovery of spent solvents by 

filtration using a powder filtering material. Muck, which can contain considerable solvent, is 

usually produced at petroleum-solvent drycleaning operations. Prior to the mid-1980s, most of 

these wastes were either disposed of in landfills or discharged to the ground. 

Spent Filters. Spent cartridge filters can contain up to a gallon of solvent. Spent filters can be 

allowed to drain in a drycleaning machine overnight prior to being changed. Because this 

practice is not always followed, spent solvent is often spilled during filter changes. In the past, 

spent cartridge filters were stored in cardboard boxes or on the ground outside the facility prior 

to being discarded in the trash. Solvent tends to drain from these discarded filters if they have not 

been drained prior to disposal. 

Spent Solvent. Spent solvents are those used as carriers for finishing agents (e.g., PCE) and 

petroleum solvents that have biodegraded. At drycleaning operations that use PCE as a carrier 

for waterproofing or other agents, oils, fats, and other non-volatile residues from the fabrics 

would accumulate in the dip tank and periodically the spent waterproofing agent, which contains 

solvent, would have to be discarded. 

Spent Vapors. A considerable amount of solvent is lost to the atmosphere in the form of vapors 

from the drycleaning machine. 

Spotting Residues. These wastes are generated from the leaks, splashes, and spills during 

spotting operations, and can contain a wide variety of solvents, bleaches, detergents, and other 

agents. These wastes have been discharged to floor drains, which usually go to a sanitary sewer, 

septic tanks, or into the ground. 

Lint. Lint is generated at various points in drycleaning operations, such as from the button trap 

or pump strainer. Historically, the lint, which contains drycleaning solvent, has been disposed of 

with trash or discharged to the ground on the property. 

12.1.3 State and Industry Drycleaner Site Cleanup Programs 

Like other generally small sites, drycleaner sites may be remediated under one or more state or 

federal cleanup programs, such as RCRA Corrective Action, Superfund, and state mandatory or 

voluntary cleanup programs. A number of states have established programs dedicated to 

drycleaner sites and some of these programs include funds earmarked for the investigation and 

cleanup of these sites. Twelve states have legislation specific to the investigation and 

remediation of drycleaner sites (Alabama, Florida, Illinois, Kansas, Minnesota, Missouri, North 

Carolina, Oregon, South Carolina, Tennessee, Texas, and Wisconsin). 

The 12 states with dedicated drycleaner programs comprise the State Coalition for Remediation 

of Drycleaners (SCRD), formed in 1998 to provide a forum, share information, and encourage 

Chapter 12: Drycleaning Facility Sites Page 12-6 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

the use of innovative technologies in drycleaner site remediation. Also active in the Coalition are 

California and New York, which do not have formal drycleaner programs, but are active in 

drycleaner remediation under other authorities. One-third of the nation's drycleaners are located 

in states that are participating in SCRD. SCRD, which operates with support from the U.S. 

EPA’s Office of Superfund Remediation and Technology Innovation and the National Ground 

Water Association, provides a valuable forum for states to share programmatic, technical and 

environmental information to improve the characterization and remediation of drycleaner sites 

(http://www.drycleancoalition.org/). Much of the information in this chapter is derived from 

their research, analysis and forums. 

Although the practices and procedures of each state program differ, they all share the same basic 

premise: drycleaners and, in some states, solvent suppliers pay fees in exchange for financial 

relief and/or liability protection, to clean up contaminated sites. The level of financial relief, type 

and amount of fees, and who conducts the site investigations and cleanups differ from one state 

to another. Some states, such as Florida and Kansas, hire and direct the activities of an 

environmental contractor that investigates and remediates drycleaner sites. Most states develop 

some sort of scoring system to prioritize sites. In other states, such as Wisconsin, the program is 

a reimbursement or insurance program in which the drycleaner is responsible for investigating 

and remediating the site. Usually, there is some cap on the amount of reimbursement per site 

and, sometimes, a deductible. 

Some states require drycleaner facilities to register with the state, while others require licenses. 

Each state program also includes requirements for pollution prevention measures. Most states 

also charge drycleaner facilities annual fees, usually based on gross receipts from drycleaner 

services, and solvents fees per gallon of solvent used. The solvent fee has also provided an 

incentive for drycleaners to use solvents as efficiently as possible. 

Drycleaner sites in other states or sites that are not eligible for these state drycleaner programs 

are investigated and remediated under other state authorities, such as state superfund, RCRA, 

brownfield, or voluntary cleanup programs. These programs are described in other chapters of 

this report. 

12.2 Factors Affecting Demand for Remediation

 • The declining use of PCE by drycleaners will mean fewer discharges to the environment in 

the future. The decline is the result of several developments: First, newer drycleaning 

machines require substantially less PCE per pound of fabric cleaned than older machines. 

Second, a number of new drycleaning solvents have become available in the last decade 

(Section 12.1.1). Third, there are movements in a number of communities around the 

country to ban the use of PCE in drycleaning. For example, California’s South Coast Air 

Quality Management District has voted to phase out PCE by 2020. A bill has been 

introduced in the California Legislature to increase fees on PCE and provide grants for 

drycleaners to switch to non-PCE cleaning processes. In February, 2003, Environment 

Canada published new regulations for PCE drycleaners that, among other things, requires 

that new cleaning machines have a “manufacturer’s design rating” of PCE consumption 

Chapter 12: Drycleaning Facility Sites Page 12-7 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

equal to less than 10 kilograms, or 6.2 liters, per 1,000 kilograms of clothing cleaned. This is 

equivalent to 1,350 pounds of clothing per gallon of solvent. 

The use of solvents has been decreasing primarily by the industry’s switching to new more 

efficient machines that use significantly less solvent. Perchloroethylene use by drycleaners 

dropped from 268 million pounds in 1985 to 47 million pounds in 2002 (National 

Clothesline, 2003). These data are based on a survey conducted by the Textile Care Allied 

Trades Association. Most of this decrease is due to conversion to newer drycleaning 

machines, although a smaller portion of the change may be due to the use of alternative 

solvents.

 • For the 12 states with drycleaner remediation funds, the money available to the fund will

influence the pace of site investigation and remediation work. 

• For other states, general availability of state cleanup funds, as discussed in Chapter 9 (State 

Sites), will be the deciding factor for many cleanups. Drycleaners have average revenues of 

about $250,000; remediation costs can run hundreds of thousands of dollars; and several 

have cost over a million dollars. Even a moderate-cost cleanup can amount to several years 

of profit for the average drycleaner.

 • In addition to active drycleaner facilities, many inactive facilities may have had releases of 

hazardous substances to the environment that have resulted in contaminated soil and 

groundwater that have not been discovered. Although data on these facilities are sparse, 

estimates range from 9,000 to 90,000 sites (See Section 12.3.2).

 • The level of assessment and cleanup is directly related to the cleanup standards adopted by 

the individual states. Many states have adopted risk-based cleanup standards for soil and 

groundwater. 

12.3 Number and Characteristics of Sites

12.3.1 Active Drycleaning Facilities 

The drycleaning industry includes three types of operations: commercial, industrial, and coinoperated. The commercial facilities are by far the most prevalent and include full-service, retail 

operations located in shopping centers, urban neighborhoods, and other densely populated areas. 

Commercial facilities typically clean small quantities of garments from individuals and only a 

small minority clean furs or leathers. Exhibit 12-1 indicates the scale of the various types of 

operations. Commercial laundries tend to be located in urban areas because of the greater 

demand for drycleaning in these areas. 

According to the International Fabricare Institute, there are about 30,000 active drycleaning 

facilities in the U.S. Almost all of these are commercial facilities, which are primarily small, 

neighborhood businesses whose primary customers are individuals. Based on data for a “model” 

drycleaning plant in a 1998 EPA study, it is assumed that the average commercial drycleaner 

facility cleans 26 tons of fabric, and produces 660 gallons of hazardous waste annually, mostly 

Chapter 12: Drycleaning Facility Sites Page 12-8 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

PCE and PCE-containing materials from distillation residues and from filters (EPA 1998). Based 

on information from a hazardous waste treater, EPA estimated that this waste is, on average, 40 

percent PCE.1 

Exhibit 12-1. Number and Types of Active Drycleaners in the United States 

No. of 

Facilities 

Average Tons Per 

Facility/year 

Hazardous Waste 

Average Gal./Year 

Hazardous Waste 

Total Gal./Year 

Commercial 30,000 a 26 b 660 b 19,800,000 c 

Industrial 325 d 578 d 14,672 e 4,768,000 c 

Coin-Operated 100 d 1.6 d 40 d 4,000 c 

Total 24,572,000 

Notes: 

a International Fabricare Institute, web site, 2003, http://www.IFI.org b EPA, 1998 c Product of Column 2 and column 4 

d EPA, 1995 e Based on gallons per output for commercial facilities 

Industrial drycleaners, which tend to be larger than commercial facilities, clean uniforms, 

restaurant linens, wiping towels, floor mats, work gloves and other items for institutional, 

professional, and industrial customers. In many cases, industrial drycleaning firms also rent 

uniforms and other industrial clothing. Based on a 1995 EPA report, these facilities are assumed 

to average 578 tons of clothing annually (U.S. EPA1995). Assuming the same ratios of waste to 

output as for commercial cleaners, industrial cleaners average 14,672 gallons of hazardous waste 

annually. Industrial drycleaning is included within the Census category Industrial Laundry 

Services. About one-quarter of these establishments include drycleaning. The remainder are 

exclusively wet laundries. 

Coin-operated drycleaners use machines that are self-service or are run by an attendant in selfservice laundromats. Coin operated machines, which were introduced in the 1960s by Whirlpool 

Corporation, are no longer being manufactured. In 1993, EPA estimated that there were 3,000 

coin-operated drycleaners (U.S. EPA 1993), although a 1995 EPA report speculated that there 

are fewer than 100 in operation (U.S. EPA 1995). For this report, it is assumed that there are 

100. Based on the same ratios used for commercial cleaners above, the average coin-operated 

facility would average 40 gallons of hazardous waste annually. 

There are a number of uncertainties associated with these averages. Discharges vary widely from one 

drycleaning facility to another, because of differing processing technology, equipment, and operating practices. Thus, 

releases from a specific facility in the real world may not compare with these averages. Moreover, equipment and 

practices at many facilities have changed since the data upon which these estimates are based were collected (early 

1990s). Nevertheless, these averages reflect the approximate discharges to be expected. 

Chapter 12: Drycleaning Facility Sites Page 12-9 

1 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Another potential source of groundwater, surface water, and soil contamination is contact 

wastewater discharges. Most drycleaning contact water is discharged to sewer systems or 

directly to the ground. Because many sewer systems are known to leak, PCE can contaminate 

groundwater downstream from drycleaning facilities. 

A 1999 study by SCRD estimates that about 75 percent of active commercial drycleaners have 

some level of contamination. Although not all of these sites will require remediation, they will 

probably require site investigation. Assuming that 70 percent of these will ultimately require 

remediation, there are about 15,750 active sites that will need remediation.2 This estimate does 

not include inactive sites. 

12.3.2 Inactive Drycleaning Facilities 

In addition to releases of hazardous materials by active drycleaning facilities, there are a 

substantial number of sites that were formerly occupied by drycleaners that have moved or gone 

out of business. Some drycleaners have moved within the same shopping center or city block, 

thereby confounding site investigations. 

Another factor that may complicate site 

investigations and remediations is the fact 

that many drycleaners have changed the 

cleaning processes over the years, including 

changes in the solvents, other chemicals, and 

In addition to about 30,000 active drycleaners, 

there may be between 9,000 and 90,000 

inactive drycleaner sites that have not been 

discovered. 

equipment, especially drycleaning machines. 

One indication of the number of inactive sites can be discerned by observing trends in the 

number of drycleaner facilities. According to the Economic Census, the number of drycleaner 

facilities has fluctuated over time, from a peak of 30,525 in 1967 to a low of 21,257 in 1987, 

before growing to 27,939 in 1997.3

 This implies that at least 9,268 sites have closed over time 

(30,525 - 21,257). Since it is unlikely that newer establishments opened in the same location as 

the old ones, these figures imply that there are at least 9,000 inactive facilities. There are 

probably more than 9,000 facilities because the Census data do not indicate how many have 

moved or been replaced by another nearby dry cleaner. There are no data regarding how many of 

these may have been remediated over the years. Compounding these uncertainties is the fact that 

Census does not account for the fact that a drycleaning facility may move within the same 

shopping center or block, a fact that can easily elude site investigation efforts. Moreover, Census 

did not collect information on drycleaners prior to the 1960s and many drycleaners probably 

moved or closed before that time. Thus, there are at least, and probably many more than, 9,000 

inactive sites that have not been explicitly identified. Some estimates, which are based on field 

experience with drycleaner sites, indicate that there could be 3 to 5 times as many inactive sites 

2 The 70% estimate is based on conversations with four states with active drycleaner programs (Florida, Kansas, 

Oregon, and Wisconsin). 

3 This figure differs from the other estimate used in this report for currently active facilities (30,000) because of 

differences in survey methodology and industry definitions. 

Chapter 12: Drycleaning Facility Sites Page 12-10 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

as active sites.4 Older dry cleaners consumed, and released to the environment, substantially 

more solvent per pound of clothing processed than newer ones. The older dry cleaners tended to 

use more petroleum solvent and less PCE. 

12.4 Market Entry Considerations

 • The operating practices of drycleaner site cleanup programs vary from state to state. Some 

states have a fund dedicated to drycleaner site investigations and cleanups. These programs 

often have considerable information about potential drycleaner site projects and technology 

needs. 

• Some states engage one or more contractors to address all sites under their drycleaner sites 

program. In other states, the property owner or operator is responsible for conducting the 

cleanup.

 • Most states, including states that do not have formal drycleaner remediation programs, have 

drycleaner trade associations, which are a potential source of contacts and information on 

potential cleanups needed. Most of these are available through links available on the SCRD 

web site. http://www.drycleancoalition.org/links.cfm#industry 

12.5 Estimated Cleanup Costs

To estimate the value of the drycleaner remediation market, EPA estimated the average 

remediation cost actually incurred from a sample of sites and multiplied this average by the 

estimated number of drycleaner sites likely to require remediation (15,750 sites estimated in 

Section 12.3). Only active sites were considered, since data on inactive sites are sparse. 

EPA analyzed data on 50 drycleaner sites that reported total site cost data, as well as other site 

information to the SCRD. Total cost data includes site assessment, remediation, and O&M. 

While this sample was not scientifically designed, it is drawn from a number of different states 

and represents a wide variety of site conditions, and site assessment and remediation 

technologies. The costs vary from $19,000 to over $3 million, and average $402,400 per site 

(Exhibit 12-2). 

Based on this average, the total value of the U.S. drycleaner remediation market would be $6.3 

billion. This estimate does not include the potentially thousands of inactive drycleaner 

sites–properties that are either vacant or are being used for other purposes. 

12.6 Remediation Technologies

Drycleaner sites have unique characteristics that need to be considered in site characterization 

and remediation work. A drycleaning facility may have used a chlorinated solvent, such as PCE, 

petroleum hydrocarbons, or a combination of chemicals. Sometimes the current owner may not 

Based on personal communications with four members of SCRD (Florida, Kansas, Oregon, and Wisconsin). 

Chapter 12: Drycleaning Facility Sites Page 12-11 

4 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

know what solvents were used in the past at the site, especially if it is an old facility. PCE, TCE, 

carbon tetrachloride, TCA, and Freon113 are DNAPLs and petroleum hydrocarbons are 

LNAPLs. A knowledge of the history of drycleaning processes may help identify what to look 

for. For example, earlier petroleum hydrocarbon solvents contained aromatic compounds. Over 

the years, the proportion of these compounds have been reduced, and the later petroleum 

drycleaning solvents contain little or no aromatic compounds (SCRD, 2001). 

Exhibit 12-2. Estimated Drycleaner Site Remediation Costs 

Average of 50 sites $402,400 50 sites reporting 

Range $19,000 - 3.3 million 50 sites reporting 

Percent Site Assessment Cost 28.2% 38 sites reporting 

Percent O&M Cost 16.8% 38 sites reporting 

Estimated National Total (active 

drycleaners requiring cleanup) a $6.3 billion 15,750 sites estimated a 

Range Detail 

Total Cleanup Cost Number of Sites Percent 

$5,000 - 100,000 11 sites 22% 

$100,000 - 250,000 17 sites 34% 

$250,000 - 500,000 16 sites 32% 

$500,000 - 1 million 3 sites 6% 

Over $1 million 3 sites 6% 

a Estimate from Section 12.3. No estimate is provided for inactive sites, as described in the text, though there 

may be thousands of them. 

Source: Analysis of site profile data from State Coalition for Remediation of Drycleaners (SCRD, 2003) 

Site investigators often use information on the location of the discharge point of contaminants to 

facilitate identification of the contaminant source areas. However, for inactive sites where the 

building has been razed or is being used for a different purpose, it may be impossible to locate 

these discharge points. Sampling and analysis for the above types of contaminants often must be 

conducted in and around active businesses, usually retail. To accommodate these businesses, the 

work may be scheduled after business hours or on weekends. Work space is often limited and 

samples must be collected from beneath building floor slabs. 

In addition, a site investigation or remediation may need to address contaminated groundwater 

that has migrated off site. A study of site assessments conducted at 150 contaminated drycleaner 

sites in Florida found that contaminated groundwater had migrated off the property at about 57 

percent of the sites (Linn 2002b). In an urban or suburban area, this could require obtaining site 

Chapter 12: Drycleaning Facility Sites Page 12-12 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

access to public areas, such as roads and parks, as well as other commercial or residential 

properties. 

12.6.1 Site Assessment Technologies

In 1999, the SCRD conducted a survey of all states to determine what site investigation and 

remediation technologies were used at drycleaner sites (Jurgens, 1999). The 28 states that 

responded reported that they have employed 18 site assessment technologies (Exhibit 12-3). 

These include five media sampling techniques, such as gas surveys and direct push; five 

geophysical techniques, such as ground penetrating radar, soil conductivity analysis, and induced 

laser fluoroscopy, to assist in interpreting subsurface conditions; five sample analysis 

approaches, such as fixed laboratories, mobile laboratories, and portable gas chromatography, to 

determine the relative or actual concentrations of contaminants in the sampled media; and three 

techniques for the analysis of DNAPLs. 

Exhibit 12-3. Site Assessment Technologies Used at Drycleaner Sites 

Technology Percent of States 

Sampling Tools 

Monitoring Well/boring 91 

Direct Push 87 

Active Soil Gas 78 

Passive Soil Gas 39 

Microwells 26 

Geophysical Techniques 

Soil Conductivity Surveys 39 

Ground Penetrating Radar 30 

Magnetometer 30 

Induced Laser Fluoroscopy 17 

Electrical Resistivity Survey 13 

Analytical Techniques 

Fixed Laboratory 91 

Mobile Laboratory 61 

Portable Gas Chromatography 48 

Immunoassay 30 

Colorimetric Tube 17 

DNAPL Detection 

Ultraviolet Fluorescence 17 

Hydrophobic Dye 17 

Partition Interwell Tracer Set 4 

Source: Jurgens, Bob, et. al. Study of Assessment and Remediation Technologies for Drycleaner Sites, State 

Coalition for Remediation of Drycleaners, with support from the Technology Innovation Office, U.S. Environmental 

Protection Agency, 1999. 

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Chapter 12: Drycleaning Facility Sites Page 12-14

In addition, the respondents identified several other techniques that could be used. These

techniques include fracture trace analysis, an inexpensive method of identifying fracture zones

with aerial photographs and knowledge of area geology; sonic drilling, an expensive method of

drilling that can penetrate consolidated and unconsolidated formations; and video cameras to

inspect the inside of sewer lines to help identify joints, cracks, or holes in the lines that may

allow the release of solvent-contaminated waste water. Cameras are also used in boreholes to

identify fractures and dissolution zones (Jurgens, 1999).

12.6.2 Remediation Technologies

The SCRD survey also identified 18 remediation technologies that had been employed in the

states (Exhibit 12-4). These include three soil remediation techniques, five general groundwater

remediation techniques, six groundwater techniques that use bioremediation or chemical

oxidation, and four groundwater techniques that use in-situ flushing or thermal treatment.

Exhibit 12-4. Site Remediation Technologies Used at Drycleaner Sites

Technology Percent of States

Soil Remediation 

Excavation 86

Soil Vapor Extraction 86

Bioventing 29

Groundwater Remediation: General

Natural Attenuation 71

Air Sparging 67

Multi-Phase Extraction 33

Permeable Wall 14

Recirculating Well 14

Groundwater Remediation: Bioremediation & Chemical Oxidation

Hydrogen Release Compound (HRC) 29

Hydrogen Peroxide 24

Potassium Permanganate 19

Organic Release Compounds (ORC) 10

Recirculating Well 10

Potassium Permanganate 5

Groundwater Remediation: In-Situ Flushing & Treatment

Surfactant Flush 14

Co-Solvent Flush 5

Steam Injection 5

Electrical Heating 5

Source: Jurgens, Bob, et. al. Study of Assessment and Remediation Technologies for Drycleaner Sites, State

Coalition for Remediation of Drycleaners, with support from the Technology Innovation Office, U.S. Environmental

Protection Agency, 1999.
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

12.7 References

Cardimone, 2001. Drycleaner Remediation Programs: An Overview and Case Studies, U.S. 

Environmental Protection Agency, Technology Innovation Office, August 2001. 

HSIA, 2003. Amended Rule 1421 – Control of Perchloroethylene Emissions from Dry Cleaning 

Operations, Halogenated Solvents Industry Alliance. http://www.hsia.org/scaqmd.htm 

IFI, 2003. Profile of the Fabricare Industry, International Fabricare Industry, web site. 

http://www.ifi.org/industry/industry-profile.html 

Jurgens, Bob, et.al., 1999. Study of Assessment and Remediation Technologies for Drycleaner 

Sites, State Coalition for Remediation of Drycleaners, with support from the Technology 

Innovation Office, U.S. Environmental Protection Agency. 

http://www.drycleancoalition.org/tech 

Linn, William J. and K. Mixell, 2002a. Leaks, Spills, and Discharges At Florida Drycleaning 

Sites, State Coalition for Remediation of Drycleaners. 

http://www.drycleancoalition.org/download/leaks 

Linn, William, et. al., 2002b. Conducting Contaminant Assessment Work at Drycleaning Sites, 

State Coalition for Remediation of Drycleaners. http://www.drycleancoalition.org/chemicals 

National Clothesline, 2002. “Cleaners’ Perc use Continues to Decline,” National Clothesline, 

August 2002. http://www.natclo.com/0208/aa10.htm 

National Clothesline, 2003. “PERC Demand Continues 17-Year Decline,” National Clothesline, 

August 2003. http://www.natclo.com/0308/aa90.htm 

Schmidt, Robin, R. DeZeeuw, L. Henning, and D. Trippler, 1999. State Programs to Clean Up 

Drycleaner, State Coalition for Remediation of Drycleaners. 

http://www.drycleancoalition.org/survey 

SCRD, 2002. Chemicals Used in Drycleaning Operations, State Coalition for Remediation of 

Drycleaners, January, 2002. 

SCRD, 2003. Site Profiles, State Coalition for Remediation of Drycleaners. 

http://www.drycleancoalition.org/profiles 

U.S. Census Bureau, 1998. Economic Census: Comparative Statistics of the United States for 

Service Industries, U.S. Department of Commerce. 

U.S. EPA, 1991. Dry Cleaning Facilities - Background Information for Proposed Standards, 

Draft EIA, U.S. Environmental Protection Agency, Office of Air Quality Planning and 

Standards, November 1991. 

Chapter 12: Drycleaning Facility Sites Page 12-15 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

U.S. EPA, 1993. Economic Analysis of Regulatory Controls in the Dry Cleaning Industry, Final, 

EPA 450/3-91-021b, U.S. Environmental Protection Agency, September, 1993. 

U.S. EPA, 1995. EPA Office of Compliance Sector Notebook Project Profile of the Dry Cleaning 

Industry, EPA/310-R-95-001, U.S. Environmental Protection Agency, Office of Enforcement 

and Compliance Assistance, September, 1995. 

U.S. EPA, 1998. Cleaner Technologies Substitutes Assessment: Professional Fabricare 

Processes, U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxic 

Substances, Washington, D.C., June 1998. 

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Chapter 13 

Demand for Site 

Characterization Services 

Site characterization is usually the first step in the remediation of soil and groundwater pollution 

and continues throughout all aspects of the cleanup process. Site characteristics data are crucial 

to locating the sources of contamination, predicting where chemicals may migrate, developing 

risk assessments and remediation strategies, influencing community reactions, evaluating reuse 

options, monitoring progress of remediation efforts, and conducting long-term monitoring. 

Although site characterization is usually a small part of total remediation costs, it lays the 

foundation for the entire project and can substantially affect the total project effectiveness, cost, 

and schedule. 

This chapter examines the market for sampling and analysis technologies used to investigate the 

nature and extent of contamination at hazardous waste sites in the U.S. and its implications for 

the continued demand for newer, streamlined technologies. Sampling and analysis is an integral 

component of all site investigations and remediations, whether the work is conducted under 

Superfund, RCRA, or another cleanup program. 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. 

In recent years, the use of more timely and more accurate site characterization approaches has 

been growing. Many analyses that previously were conducted in laboratories can now be done in 

the field. Better methods can reduce the time and cost needed to evaluate sites and result in more 

efficient remediation designs. These new technologies can be applied in conjunction with 

systematic planning and dynamic work plans that are used to manage the site from initial site 

assessment through remediation and closeout. The integration of these three strategies is referred 

to as the Triad approach to hazardous waste site cleanups. The use of the Triad approach has 

significantly reduced the overall cleanup costs and time at many sites. 

13.1 Market Description

Site characterization is the process of identifying, quantifying and describing the nature, extent, 

and fate and transport of hazardous substances released into the environment to detect their 

impacts on human health and the environment. The information developed in site 

characterization studies have a profound influence on all future activities at a site. For example, 

underestimation of the nature and extent of the contamination, or inaccurate description of 

geological conditions, may lead to response actions that are inadequate to protect human health 

and the environment. If additional contamination is discovered during remedial action, costly 

construction delays and redesign of the remedy may be necessary. Conversely, if the nature and 

extent of contamination is overestimated, the remedy may be over-designed, causing greater 

remediation expenditures than necessary to protect human health and the environment. A more 

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effective site characterization, even if greater sampling and analysis costs are incurred, can lead 

to lower total cleanup costs. 

Site characterization information affects all stages of site management, from site discovery to 

close out. Specifically, site characterization is an important component in the following five 

steps of the site management process. 

Phase One Site Assessment. The purpose of a Phase One site assessment is to determine the 

likelihood of environmental contamination at a property. This type of assessment is often done 

when a site is reported to a regulatory authority or in conjunction with the development, 

purchase, lease, sale, or other means of transfer of a property. Property purchasers and lenders 

hire environmental firms to conduct these assessments as part of their due diligence 

responsibility. A Phase One assessment is not expected to provide a detailed description of the 

contamination; its function is to indicate whether further study is warranted. Environmental 

samples are rarely collected at this point. This phase is approximately, but not precisely, 

equivalent to the 1994 American Society of Testing Materials (ASTM) industry standard E-1527 

for Phase I environmental site assessments. 

The structure and role of the ASTM standard may change as a result of new requirements under 

the Small Business Liability Relief and Revitalization Act (the “Brownfields Law”) of 2002. 

Among other things, the law revises some of the provisions of CERCLA Section 101(35) 

clarifying requirements necessary to establish the innocent landowner defense under CERCLA 

and provides Superfund liability limitations for bona fide prospective purchasers and contiguous 

property owners. Among the requirements added to CERCLA is the requirement that such 

parties undertake “all appropriate inquiry” into prior ownership and use of a property at the time 

at which a party acquires the property. EPA plans to promulgate federal standards for “all 

appropriate inquiry.” These standards may replace the ASTM standards in many, if not most, 

real estate industry practices. 

The Phase One site assessment is similar to, but not precisely equivalent to, the Preliminary 

Assessment (PA) which is performed on every site listed in the CERCLA Information System 

(CERCLIS), and the RCRA Facility Assessment (RFA). The RFA is conducted for hazardous 

waste treatment, storage, and disposal facilities and other locations that may be subject to 

corrective action under the RCRA Corrective Action program. PAs are generally conducted by a 

state, or federal agency to distinguish, based on limited data, between sites that clearly pose little 

or no threat to human health or the environment and sites that may pose a threat and require 

further investigation. The PA also identifies sites requiring assessment for possible emergency 

response actions. If the PA results in a recommendation for further investigation, a Site 

Inspection is performed. 

RFA’s are conducted or directed by a state or federal regulatory agency to identify solid waste 

management units (SWMUs) that are, or are suspected to be, the source of a release to the 

environment. This information is used to determine whether a RCRA Facility Investigation 

(RFI), interim measures, or other corrective measures are needed. 

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Phase One assessments generally include the following components:

 • Review of fundamental information about the site, such as that available from aerial

photography, public information, and other sources;

 • A review of historical documents and records search to determine whether there is any

publicly available information on actual or potential contamination on or related to the

property; 

• A physical tour of the property to record visual, olfactory, and tactile observations. The tour 

may include interviews with on-site personnel who may have knowledge of past and present 

environmental practices; and

 • A written report documenting the process and results of the Phase One assessment. 

In addition to serving as a screening mechanism, the information collected during Phase One can 

be used to develop a preliminary conceptual site model (CSM), which is generally refined as 

work at the site continues. A CSM is a planning tool that organizes what is already known about 

the site and helps the site management team identify additional information needed to make the 

decisions that will achieve the project’s goals. 

Phase Two Site Assessment. The Phase Two site assessment includes further investigation of 

possible contamination discovered during phase one to confirm the presence of contamination. It 

may include on-site environmental testing and laboratory analysis. The investigation may require 

extensive sampling and analysis in several stages to obtain the required information. The ASTM 

standard appears in E 1903, Standard Guide for Environmental Site Assessments: Phase II 

Environmental Site Assessment Process. The Phase Two site assessment is similar to, but not 

precisely equivalent to, the Site Inspection (SI) which is often, but not always, performed on 

sites listed in CERCLIS; the sampling portion of the RFA, which is conducted for hazardous 

waste treatment, storage, and disposal facilities and other locations that may be subject to 

corrective action under the RCRA Corrective Action program; and tier evaluations of a riskbased corrective action (RBCA) at UST sites. 

SIs are generally conducted by a state or federal agency to provide or augment the data needed 

for Hazard Ranking System (HRS) scoring and documentation. The HRS score is an important 

input to the decision of whether to list a site on the NPL. If a site receives an HRS score greater 

than 28.5, it is eligible for listing on the NPL. SI investigators may collect samples of soil, water, 

free product, and other media to determine if hazardous substances are present, and if there is 

human exposure or contamination of sensitive environments. The EPA publication Guidance for 

Performing Site Inspections Under CERCLA; Interim Final, September 1992, (NTIS PB92­

963375, EPA 9345.1-05) provides more information on conducting SIs. This publication may be 

found at: http://www.epa.gov/superfund/whatissf/sfproces/pasi.htm

Phase Two assessments generally include one or more of the following components:

 • Soil sampling to determine if a release has impacted site soil;

 • Groundwater sampling to determine if a release has impacted groundwater;

 • Drums and waste materials testing; 

• Asbestos testing; 

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• Indoor air quality testing;

 • Underground tank testing to determine whether tanks and associated piping have leaked or 

are likely to leak, and whether the tanks meet federal and state requirements; and

 • A written report documenting the process, quality assurance procedures, and results of the

Phase Two assessment.

Phase Three Site Assessment. A Phase Three site assessment is generally required if the results 

of Phase Two reveal the presence of contamination. The purpose of the Phase Three analysis is 

to quantify and characterize the full extent of the contamination, determine the risk, and select an 

appropriate remedy. The Phase Three site assessment is approximately, but not precisely, 

equivalent to the Remedial Investigation/Feasibility Study (RI/FS) which is performed on 

Superfund sites and the RFI/Corrective Measures Study (CMS) which is conducted for facilities 

that may be subject to corrective action under the RCRA Corrective Action program. 

RI/FSs are generally conducted by potentially responsible parties, states, or EPA after a site is 

listed on the NPL. RFIs/CMS are generally conducted by the facility owners or operators, with 

oversight by a state or federal regulatory agency. For state voluntary cleanup program or 

underground storage tank sites the Phase Three assessment is generally conducted by the facility 

owners, with state oversight. 

The RI and FS are generally done interactively. The RI serves as the mechanism for collecting 

data to characterize site conditions and further refine the conceptual site model; determine the 

nature of the waste; assess risk to human health and the environment; and provide data necessary 

for treatability studies. The FS is the mechanism for the development, screening, and detailed 

evaluation of alternative remedial actions. Data collected in the RI influence the development of 

remedial alternatives in the FS, which in turn affect the data needs and scope of treatability 

studies and additional field investigations. Treatability testing is conducted under the FS to 

evaluate the potential performance and cost of the treatment technologies being considered. This 

interactive approach encourages the continual scoping of the site characterization effort, which 

minimizes the collection of unnecessary data and maximizes data usability. 

Generally, the more thorough and accurate the conceptual site model developed during the RI or 

RFI, the more cost effective the cleanup will be. The greater the uncertainty in the CSM, the 

greater the likelihood that problems will arise during the implementation of the remedy. For 

example, if the sampling plan during the RI caused investigators to overlook contaminated 

material, the contamination might be discovered during construction of the remedy. The 

contractor would then have to conduct additional sampling and analysis, revise cleanup plans 

and, perhaps, select different treatment technologies. These activities would cause delays and 

drive up cleanup costs. 

It is generally impossible to completely collect and document information about all aspects of a 

site with 100 percent certainty because an RI or RFI can be expensive and time-consuming. Site 

investigators must address both sampling uncertainty and analytic uncertainty. Sampling 

uncertainty refers to the ability of the sample to represent the true site conditions, and generally 

is directly related to the density of sampling points and number of samples taken. Analytic 

uncertainty refers to the ability of the sample analysis techniques to accurately describe the 

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constituents in the sample. Typically, site investigators and managers use their best judgement to 

determine how much effort to put into characterization on a case-by-case basis. There is a 

tradeoff between the level of effort invested in characterization and the probability of missing 

contaminants that may cause unforseen problems during remediation or uncorrected health risks. 

Remedial Design and Construction. Although it may not be explicitly regarded as site 

characterization, sampling and analysis is necessary during remedy design and construction or 

other corrective measures at most sites. Sampling is used to confirm that various aspects of the 

remediation were successful and, sometimes, to revise the original site characterization plans 

based on site conditions that were not anticipated prior to construction. Site characterization 

during remedial design and construction would generally use sampling and analysis technologies 

that are similar to those used during the Phase Three site investigations. 

Operations and Maintenance (O&M). The use of site characterization technologies also may 

occur during the O&M phase of the site. O&M measures related to waste containment and 

control are initiated after the remedy has been constructed in accordance with the ROD or other 

site agreements and is determined to be operational and functional based on state and federal 

agreement. For Superfund-lead sites, remedies are considered operational and functional either 

one year after construction is complete or when the remedy is functioning properly and 

performing as designed, whichever is earlier. 

Typical remedy components requiring long-term O&M measures include landfill covers and 

liners; gas extraction, treatment, and monitoring systems; water collection, treatment, and 

monitoring systems; and permeable reactive barriers. The remedy and reuse plans must allow for 

access necessary for sampling, inspection, and repair of these components. O&M monitoring 

may include five types of activities: inspection, sampling and analysis, routine maintenance and 

small repairs, reporting, and five-year reviews. The five-year reviews are primarily a 

requirement for some Superfund sites. The most likely demands for site characterization 

technologies include periodic topographic surveys to measure the rate of movement or 

settlement, the collection and chemical analysis of gas, air, and water samples from wells, probes 

and other collection means. 

13.2 Site Characterization Tools

Site characterization technologies can be grouped into those related to accessing, collecting, and 

analyzing samples and environmental data and geophysical tools that can sometimes be used to 

directly locate contamination such as a leachate plume or buried drums but are more often used 

to refine the CSM with regards to site stratigraphy. These technologies are supported by 

computer software and other decision support tools that facilitate efficient and effective data 

management, interpretation, and decision making as data are collected and analyzed. In addition, 

it is important to consider how the deployment of each technology is integrated into a 

characterization program, and ultimately into the general site management process. A number of 

newer characterization technologies have made possible more efficient and flexible site 

management processes. Conversely, site managers are using scientifically designed, systematic 

approaches to planning and conducting site investigations and cleanups which optimize the 

effectiveness of the technologies. A systematic approach to site characterization can ensure that 

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data collected are appropriate, reduce the time and cost it takes to initiate cleanup, and reduce 

overall remediation costs. 

The large number of characterization 

techniques makes it impossible to describe 

them all in this report. Exhibit 13-1 lists the 

major groups of tools. The publications Field 

Sampling and Analysis Technologies Matrix 

(FRTR 1998, http://www.frtr.gov/site) and

Field Analytical Technologies Encyclopedia 

(EPA 2003) provide more detailed 

descriptions of the categories, the commonly 

used and proven techniques, conditions under 

which they tend to be used, and other useful 

information. The following four subsections 

provide an overview of these technologies. 

13.2.1 Sample Access and Collection

Technologies 

The access and collection techniques enable 

site investigators to access soil, groundwater 

and other media for the purpose of collecting 

samples; physically remove samples; and 

directly extract contaminants of concern from 

soil for subsequent analysis. Exhibit 13-1 

above lists the major types of access and 

collection techniques. 

13.2.2 Sample Analysis Technologies 

Qualitative chemical analysis is used to 

determine whether chemicals of concern are 

present in a sample. Once it is known that 

chemicals of concern may be present, 

quantitative analysis is used to determine the 

identities and concentrations of the chemicals 

in the sample. To determine the extent and 

type of analyte to collect and the extent of 

quantitative analysis to conduct, site 

investigators first develop explicit data 

quality objectives (DQOs) early in the 

project. Exhibit 13-1 above lists the major 

types of sample analysis techniques. 

Exhibit 13-1: Major Characterization 

Technology Subcategories 

Sample Access Tool Groups 

• Drilling methods - unconsolidated materials 

• Drilling methods - consolidated materials 

• Drive methods utilize a hydraulic device 

• Sampling installations for portable samplers 

• Portable in-situ groundwater samplers 

• Fixed in-situ samplers cover 

• Destructive sampling methods 

Sample Collection Tool Groups 

• Hand-held methods (soil) 

• Portable positive displacement pumps 

• Other portable groundwater sampling pumps 

• Portable grab samplers (water) 

• Extractive collection methods 

• Gas/air collection methods 

Sample Analysis Tool Groups 

• Ex-situ methods for analyzing VOCs and 

SVOCs 

• In-situ methods for analyzing VOCs and 

SVOCs 

• Ex-situ methods for analyzing metals 

• Ex-situ and in-situ methods for analyzing 

radionuclides 

• Ex-situ methods for analyzing explosives 

Geophysical Tools 

• Electromagnetic 

• Resistivity 

• Conductance 

• Ground Penetrating Radar 

• Seismic 

Decision Support Tool Groups 

• Computer software to aid decision-tree 

analysis for CSMs 

• Software that integrates geographic information 

systems, global positioning systems, imaging, 

analytical technologies, and databases to 

assist in modeling of site conditions and 

evolution of the CSM 

• Statistical methods or sampling design and 

analysis 

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13.2.3 Field Technologies

The technology groups listed in Exhibit 13-1 include both “traditional” technologies and newer 

technologies. In the traditional phased engineering approach samples are collected, shipped 

offsite for analysis, and the data are returned long after the sample collection staff have gone. 

The newer technologies allow sampling and analysis of groundwater and soil to be done on site 

to a greater extent, and more rapidly, than ever before. These newer approaches have been made 

possible by technological advances such as computerization, microfabrication, and 

biotechnology. Site investigators now have the capability to conduct analyses in the field that 

previously could only be done in a laboratory. By rapidly characterizing contaminated soil and 

groundwater on site, site staff are able to make immediate decisions which can guide 

characterization efforts, accelerate site assessment schedules, monitor progress of remediation 

efforts, and conduct confirmation sampling at closeout at reduced cost. Field analytical 

technologies also provide greater flexibility in responding to changes in conditions that are 

discovered during construction of the remedy. 

Examples of the common field technologies are listed in Exhibit 13-2. Because of the advantages 

of field analytical technologies, especially when combined with adaptive site management 

strategies (described below), their use has been growing over the past decade. EPA has been 

promoting their use as a means of achieving faster, better, and more efficient cleanups, and 

expects them to replace the traditional phased engineering approach in many future cleanup 

projects. 

13.2.4 Adaptive Site Management Approaches

Field analytical technologies provide site staff with the capability to use an adaptive sampling 

strategy, which feeds the previous day's results into the decision-making process to help direct 

the collection of the next round of samples. This 

strategy is typically implemented through a 

systematic planning process that relies on 

dynamic work strategies that are carefully aligned 

to provide data to support on-site decisions. A 

dynamic work strategy incorporates all known 

information about the site into a conceptual site 

model (CSM) and decision-making framework, 

such as a decision tree. This approach permits 

rapid location and definition of hot spots, guides 

the removal or treatment of contaminated media, 

and quickly identifies when enough information has been collected to address the site decision. It 

also helps avoid unnecessary treatment and the collection and analysis of uninformative samples, 

and to determine when enough information has been collected to meet site management goals. 

The use of field technologies, combined with a dynamic work strategy often allow some projects 

to be completed in only one field mobilization. 

By rapidly characterizing contaminated 

soil and groundwater on site, site staff are 

able to make immediate decisions which 

can guide characterization efforts, 

accelerate site assessment schedules, 

monitor progress of remediation efforts, 

and conduct confirmation sampling at 

closeout at reduced cost. 

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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. 

Ion Specific 

Electrodes 

Measures selected cations and anions in water. Can be deployed in situ or ex 

situ. 

Fiber Optic 

Chemical Sensors 

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. 

Gas 

Chromatography 

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. 

Infrared 

Spectroscopy 

Is used in soil and water analysis for total extractable hydrocarbon analysis in 

the field. 

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

Technology Description 

Open Path Air 

measurements 

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. 

Laser-Induced 

Fluorescence 

Generally employed as a tool for locating petroleum hydrocarbons (polycyclic 

aromatics) in situ, using direct push technologies to drive it into the 

subsurface. 

Mass Spectrometry 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. 

X-Ray Fluorescence 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. 

Ground Penetrating 

Radar 

Has had very uneven success in locating LNAPL plumes and is not chemical 

specific. 

Electromagnetics/ 

Resistivity for 

Environmental 

Applications 

In specific settings can be used to delineate the extent of an electrically 

conductive plume. 

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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. 

Direct-Push 

Geotechnical 

Sensors 

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. 

Direct-Push 

Groundwater 

Samplers 

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. 

Direct Push Soil-Gas 

Samplers (without 

rig) 

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. 

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. 

Resistivity/ 

Conductivity 

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. 

Magnetics 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. 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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

Technology Description 

Ground Penetrating 

Radar 

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. 

Seismic 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. 

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. 

Chapter 13: Site Characterization Page 13-11 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

• 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 

• 

Site Using a Dynamic Work Plan, 

• 

Innovation in 

• 

• 

• )

 • 

; )

 • 

• 

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 

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, 

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. 

Chapter 13: Site Characterization Page 13-12
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

• 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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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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 

Phase 

Two 

Phase 

Three Remedial Action a O&M b 

Superfund (OUs) c 658 658 832 1,700 2,500 

RCRA-CA d 0 1,269 < 3,827 3,800 3,800 

UST e NA NA 125,000 223,000 320,000 

DOD f NA 1,425 4,774 8,800 18,400 

DOE g NA NA NA 5,000 8,000 

Civ. Agencies NA NA NA NA NA 

States h h h 150,000 150,000 155,000 

Private i 11.5 mil. 1.2 - 2.3 mil. NA NA NA 

Total J 11.8 mil. 1.2 - 2.3 mil. 285,433 392,300 507,700 

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. 

Chapter 13: Site Characterization Page 13-15 
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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 

Cost per Fund-Lead 

Operable Unit ($000) 

Percent of Total Expenditures

 RI/FS 1,363 9.9

 RD 1,331 9.7

 RA 11,059 80.4

 Total 13,753 100.0 

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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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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 Average Total Cleanup Cost Site Investigation Cost Percent 

Mega Superfund (per OU) $36,652,000 $2,582 7.0% 

Non-Mega Superfund (per OU) $6,750.000 $1,047 15.5% 

Drycleaner $402,000 $113,000 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 30–year 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 

Market Segment 

Total Remediation Market 

Percent 

for Site 

Investigation 

Value of Site 

Characterization 

Market ($Billions) Number a

of Sites 

Value 

($Billions) 

Medium and Large Sites 

(Superfund, RCRA 

Corrective Action, DOD, & 

DOE) 

16,000 145 10 14.5 

Small Sites (UST, Civilian 

Agencies, and States) 

278,000 64 16 6.5 

Total 294,000 209 21.0 

a 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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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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. 

Chapter 13: Site Characterization Page 13-18 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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 

Chapter 13: Site Characterization Page 13-19 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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. 

Chapter 13: Site Characterization Page 13-20 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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. 

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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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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), 1,1,1-

trichloroethane (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 

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Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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. 

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. 

Industries With High Probability of Past 

DNAPLs Release 

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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: 

Chapter 14: DNAPLs Page 14-4 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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. 

Chapter 14: DNAPLs Page 14-5 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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 VOCs SVOCs 

NPL 78% 71% 

RCRA Corrective Action 60% + 18% + 

DOD 64% 57% 

DOE 38%* 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. 

Chapter 14: DNAPLs Page 14-6 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Although the occurrence of halogenated 

compounds is a strong indication that the site 

may have DNAPLs, it does not guarantee that 

it will. The occurrence of DNAPLs is also 

influenced by industrial practices, form and 

volume of releases, and hydrogeological 

conditions, among other factors. A 1993 

EPA study considered these factors to 

29-45% of NPL sites, or an average of 

37%, are likely to have free-phase or 

residual DNAPLs present in the 

subsurface. These estimates incorporate 

several approximations and simplifying 

assumptions as described in the text. 

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 

Chapter 14: DNAPLs Page 14-7 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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 

Estimated 

No. of Sites to be 

Cleaned up a 

Estimated Percent 

With DNAPLs (%) 

Estimated Number of Sites 

With DNAPLs 

Range Average Range Average 

NPL (non-federal) 736 29 – 44 37 213 – 324 538 

RCRA 3,800 22 – 34 28 836 – 1,292 1,052 

UST 125,000 NA NA NA NA 

DOD 6,400 24 – 37 30 1,536 – 2,368 1,819 

DOE 5000 24 – 37 30 1,200 – 1,850 1,469 

Civilian Agencies > 3,000 NA NA NA NA 

State & Private 150,000 22 – 34 28 33,000 – 51,000 41,200 

Total 293,936 37,260 – 54,814 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. 

Chapter 14: DNAPLs Page 14-8 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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 characterization market is hampered by the extremely wide 

range of potential site conditions and the paucity of program-wide data on costs that pertain to 

specific DNAPL remediations. Most cleanup programs do not compile data on expenditures 

pertaining to specific contaminants or pollutants, or specific actions such as pump-and-treat 

operations, excavations, or laboratory analyses in a manner that can be aggregated or used to 

compute averages. Many sites are being remediated for more than one contaminant and medium. 

Even if total remediation cost for a site is known, the specific costs attributable to DNAPL 

remediation would be difficult to determine. Cost estimates in RODs, which are done prior to 

remedy design, are estimates which serve as only general indicators of potential cost. 

Remediation costs for DNAPLs are primarily affected by costs involved in removing or reducing 

source zones and costs incurred in addressing dissolved phase plumes. Because pump-and-treat 

systems have often been a major part of both types of DNAPL remediations, it is useful to 

examine the historical experience with their costs. In reviewing historical cost data, it is 

important to bear in mind that the study of many existing sites is complicated by the fact that 

many previous pump-and-treat systems were installed and began operations before the existence 

of a subsurface DNAPL source zone was suspected. Thus, historical cost data from these sites 

may not be reflective of ultimate costs at future sites. 

14.4.1 Pump-and-Treat System Costs 

Historically, pump-and-treat systems have been the principal remedy at DNAPL sites. 

Information on the cost of pump-and-treat systems from three EPA studies provides useful 

insight into the potential magnitude and variability of these costs. In a 1999 study of 26 pumpand-treat remediations and two PRB systems, EPA estimated that the average capital cost for 

pump-and-treat systems was $3.5 million and the average annual operating cost was $670,000 

(U.S. EPA 1999). Some of these expenditures may include costs for source control remedies, 

such as slurry walls, when the source control was an integral part of the groundwater cleanup. 

Comparing these costs on a per volume of water treated basis, the estimates were $250 capital 

and $31 O&M per 1,000 gallons per year, respectively (Exhibit 14-4). A 2001 EPA study 

indicated similar results (U.S. EPA 2001c). 

Chapter 14: DNAPLs Page 14-9 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Mean 

(000) 

1,000 Median 

(000) 

1,000 Mean 

(000) 

1,000 Median 

(000) 

1,000 

Gall. Mean Med 

26 Project Sample (U.S. EPA 1999) b 

ites 670 31 190 18 3,500 250 1,900 96 63 21 

32 Project Sample (U.S. EPA 2001c) 

770 32 260 16 4,900 280 2,000 78 120 30 

79 Project Sample (U.S. EPA 2001a) 

NA NA NA NA NA NA NA NA 

Sites wi NA NA NA NA NA NA NA NA 

Sites With NA NA NA NA NA NA NA NA 

b 

source: U.S. EPA. 1999. l ites, EPA 542-R-99-006, Office of Solid 

ites,

December 2001; U.S. EPA. 2001. l

Exhibit 14-4. Cleanup Costs for Selected Pump-and-Treat Projects 

Annual O&M Costs Capital Costs 

Millions of 

Gallons/Year 

Per 

Gallons 

Annually 

Per 

Gallons 

Annually 

Per 

Gallons 

Annually 

Per 

Ann 

All 26 S

All 32 sites 

All 79 Sites 570 350 

th Observed 

NAPLs 

736 402 

Suspected NAPLs 

568 285 

Does not include two sites where PRBs were used as the only remediation technology. 

NA Not available 

Groundwater C eanup: Overview of Operating Experience at 28 S

Waste and Emergency Response, September 1999; U.S. EPA. 2001. Groundwater Pump and Treat Systems: Summary of Selected 

Cost and Performance Information at Superfund-financed S EPA 542-R-01-021b, Office of Solid Waste and Emergency Response, 

Cost Analysis for Selected Groundwater C eanup Projects: Pump and Treat Systems and Permeable 

Reactive Barriers, EPA 542-R-01-013, Office of Solid Waste and Emergency Response, February 2001. 

The 2001 study, which used data from the above 26 sites plus 6 additional pump-and-treat sites, 

indicated significant economies of scale, (decreasing cost per gallon of water treated) for systems 

that pump and treat up to 20 million gallons per year. As system sizes exceed 20 million gallons 

per year, there is little change in cost per gallon. However, because the systems studied represent 

several different technologies, contaminants, and site conditions, some of the variation in unit 

costs may be due to variations between sites using different technologies or treating for different 

contaminants. There were not enough data points to develop meaningful separate cost curves for 

each technology and set of site conditions. 

Nevertheless, these data imply a general 

tendency of decreasing unit costs up to a 

point. To the extent that economies of scale 

exist, it is likely that per gallon pump-andtreat costs at most state and private sites will 

probably be higher than at most Superfund, 

RCRA, DOD and DOE sites, which tend to 

be larger (Exhibit 14-5). 

Because of potential economies of scale in P&T 

sites, are likely to have higher unit P&T costs, 

on average, than most Superfund, RCRA, 

DOD, and DOE sites. 

systems, most smaller sites, such as most state 

The exhibit also shows that the type of contaminant group and type of aboveground treatment 

affects the operating cost of a pump-and-treat system. Sites at which chlorinated solvents, alone 

or with other VOCs, were present had lower operating costs and capital costs than sites with 

Chapter 14: DNAPLs Page 14-10 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

other combinations of contaminants (average of $26 per 1,000 gallons per year compared to $53, 

and median of $12 compared to $39). Similarly, treating for chlorinated solvents, alone or with 

other VOCs, using air stripping or granulated activated carbon only, the average O&M cost was 

substantially lower than the average for sites treating for these contaminants plus other 

combinations of contaminants, such as solvents, BTEX, metals, PCBs, or PAHs (median of $3 

per 1,000 gallons per year compared to $40). 

Exhibit 14-5. Comparison of Pump-and-Treat Costs for Selected Projects 

Site Characteristic 

Ave. O&M 

Cost per 

Thous. Gal. 

Annually 

Median O&M 

Cost per 

Thous. Gal. 

Annually 

Ave. Capital 

Cost per 

Thous. Gal. 

Annually 

Median 

Capital Cost 

per Thous. 

Gal. Annually 

# 20 million gallons per year (14 sites) 62 42 580 440 

$ 20 million gallons per year (18 sites) 10 5 49 24 

Sites with chlorinated solvents alone or with 

other VOCs (18 sites) 

26 12 3,600,000 1,900,000 

Sites with other combinations of 

contaminants (solvents, BTEX, metals, 

PCBs, or PHBs) (9 sites) 

53 39 8,900,000 7,400,000 

Sites with chlorinated solvents alone or with 

other VOCs that use air stripping and/or GAC 

(11 sites) 

NA 3 NA NA 

Sites with other combinations of treatment 

technologies (7 sites) 

NA 40 NA NA 

Notes: GAC: Granulated activated carbon 

NA: Data not available 

These results should be interpreted with caution. First, the sites were not selected for this study 

to be a statistically representative sample of groundwater remediation projects, although they 

include a range of system types and situations at Superfund and RCRA Corrective Action sites. 

Second, the unit cost (per 1,000 gallons treated) is highly dependent on site-specific factors, such 

as the specific treatment technology used, complexity of the aquifer, types and mix of 

contaminants targeted for treatment, water and air discharge limits, and restoration goals. Third, 

the data are presented primarily as annual O&M costs and initial capital costs. These data are 

necessary, but insufficient to make decisions on selecting technologies for a given site. Decisions 

about which technology is less expensive are typically based on life-cycle costs. Estimating lifecycle costs requires information on the duration of the system and repair and replacement 

requirements in the out years, which were not available in these studies. 

The third study, a 2001 EPA study of 79 Superfund-financed sites, estimated that the average 

annual O&M costs of a pump-and-treat system is approximately $570,000, and the median is 

$350,000 (U.S. EPA 2001a). This difference is due to a small number of systems with relatively 

Chapter 14: DNAPLs Page 14-11 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

high costs that raise the average. Factoring in 

estimated durations of the pump-and-treat 

systems obtained from an RPM survey, the 

study estimated average life-cycle cost to reach 

remediation completion for the average Fundlead pump-and-treat system is approximately 

$10 million without discounting and $6 million 

with discounting (i.e., present value).3

 The study 

also indicated that average annual pump-andtreat cost for sites where NAPLs (the report did 

not differentiate between LNAPLs and 

DNAPLs) were observed is 29 percent higher 

than for all sites. Exhibit 14-4 displays the 

estimated average costs from these studies. 

In applying this information to understand the 

potential cost of DNAPL cleanups it is 

important to understand that these estimates may understate future costs of the systems studied. 

Regional staff surveyed may have assigned a default value of 30 years to systems for which the 

expected system duration was unknown. While the practice of using 30 years as a default value 

has been used in many engineering cost applications, some pump-and-treat systems may need to 

operate many decades, or centuries beyond. EPA guidance on cost analysis for feasibility studies 

states that the period of analysis “should not necessarily be limited to the commonly-used 

assumption of 30 years”(U.S. EPA 200b). There is an increased likelihood that, over long 

periods, additional maintenance and replacement of system components and reactive materials 

will be needed. In addition, the cost of replacing system components during the initial 30 years 

may have not been included. These uncounted costs may be significant. 

The average life-cycle cost for pump-andtreat systems at Fund-lead sites has been 

estimated to be $10 million and have a net 

present value of $6 million. This average 

may be higher if systems continue to operate 

beyond 30 years, which is likely to be the 

case for sites with appreciable unaddressed 

NAPL contamination. 

The O&M costs per 1,000 gallons of water 

treated per year with pump-and-treat 

systems appears to decline with increasing 

volume of water treated until about 20 million 

gallons per year. Above 20 million gallons, 

there is little change in unit cost as volume 

increases. 

Also not included in the above cost estimates is the potential cost of revising remedies at older 

sites where the original remedy design did not adequately consider the existence of free-phase or 

residual DNAPLs in the subsurface. The case studies indicate that there may be such situations, 

because the groundwater pump-and-treat systems at some sites began before the existence of 

subsurface DNAPL source zones were suspected. 

Knowledge about the present value of the future O&M costs is an important factor in 

determining the balance between containment and treatment at a site. Present value estimates can 

be compared to the cost of additional source removal in the short term (which is usually not 

discounted since it is an early, short-term cost). Similar calculations might be used by state or 

federal regulators in ensuring that adequate funds are available to continue O&M at a site. In 

Because funds not spent at present can be invested at a rate that exceeds inflation, current funds can yield 

additional money for future expenditures, thereby making present-day dollars worth more than future dollars. As a 

result, future costs are often discounted and reported as present value. The discount rate, which is similar to an 

interest rate and differs from project to project, is primarily a function of the cost of capital to the responsible entity, or, 

in the case of some federal rulemakings and expenditures, a “social discount rate.” The discount rate used in the 

2001 study is 5 percent and all figures are reported in 2001 dollars. 

Chapter 14: DNAPLs Page 14-12 

3 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

addition to examining discounted costs and performance, decision makers are also advised to 

examine undiscounted costs in comparing alternative remedies. 

The data in these studies demonstrate the highly variable nature of the costs among sites. 

Because of this variability and because of the small sample sizes, the estimates are presented as a 

general overview of pump-and-treat costs, and are not meant to be used to guide cost estimates 

for any specific project. 

14.5 Remediation Technologies and R&D

Effectively remediating DNAPLs requires adequate means of finding and delineating them 

(characterization) and treating them (remediation). In the past, both characterization and 

remediation have tended to be expensive. As a result, many potentially responsible parties have 

not characterized source zones but rather have chosen dissolved plume containment while 

seeking a “technical impracticability waiver” for the actual cleanup of the source zone. The 

dissolved plume containment has generally consisted of a groundwater pump-and-treat system 

and more recently of some form of permeable reactive barrier (PRB) such as zero valent iron for 

TCE. A pump-and-treat system is relatively inexpensive to install but incurs relatively high 

operation and maintenance costs over the life of the system. PRBs are relatively expensive to 

install and their effective lifetime before requiring replacement is uncertain. 

Despite the many groundwater pump-and-treat projects, many sites have not achieved cleanup 

goals, largely due to the infeasibility of recovering more mass by continued pump and treat. A 

1994 study by the National Academy of Sciences concluded that 42 of 77 sites examined, were 

unlikely to achieve cleanup to drinking water standards. At 29 sites, cleanup to drinking water 

standards is possible but subject to significant uncertainties. For these later sites, partial cleanup 

was offered as a possibly more realistic scenario (NRC 1994). Without treatment of the source 

zone, these systems will be required to function for many years, perhaps decades or centuries at 

some DNAPL sites, as the sources slowly dissolve into the groundwater. 

14.5.1 Site Characterization Technologies

Characterization of a DNAPL source zone has traditionally been problematic. For the most part, 

characterization in unconsolidated formations calls for a relatively refined description of the site 

stratigraphy and vertical and horizontal profiling of dissolved DNAPL concentrations in the 

groundwater. This characterization information, in conjunction with a knowledge of the site 

history, is then used to determine where to drill for the DNAPLs. Since DNAPL subsurface 

architecture can be very complex, with many thin lenses of pure phase with randomly occurring 

residual areas, continuous coring and screening/testing of the cores is a prevalent practice. When 

the coring is done using a hollow stem auger it is slow and costly. This cost of characterization 

has in some cases led to an inadequate delineation of the source area and dissolved plume and, 

subsequently, to the installation of containment systems that inadvertently do not address the 

source area nor the entire plume. 

In the past ten years a number of characterization technologies have become available that 

greatly reduce the difficulty, and sometimes cost, of finding DNAPLs in the shallow (less than 

Chapter 14: DNAPLs Page 14-13 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

60 feet) subsurface. Most of these advances have come as a result of direct push technology 

(DPT) and provide either direct in-situ sampling (near continuous groundwater sampling for 

vertical profiling, membrane interface probe for near continuous contaminant sampling ) or insitu measurement of contaminants (e.g., induced fluorescence, halogen probe). Also, dual tube 

DPT rigs can provide a relatively inexpensive way to collect continuous cores for surface 

contaminant screening by portable instruments and hydrophobic dye tests. The degree of 

characterization needed also depends on the remediation technology under consideration. 

However, the corollary is also true: Because they make possible more accurate delineation of 

contamination plumes and DNAPL source areas, the newer characterization technologies can 

improve the effectiveness of some of the older remediation technologies and enable the 

application of the newer approaches. 

14.5.2 Treatment Technologies

A number of in-situ remediation technologies have recently been developed to address DNAPL 

contamination. These technologies generally fall into one of three categories: thermal, oxidation, 

or surfactant and cosolvent flushing. Thermal technologies (steam and electrical) rely on 

elevating the temperature of the subsurface to make the contaminants more mobile so they can 

be captured by collection devices. The elevated heat can also cause direct chemical destruction 

or destruction by hydrous pyrolysis. Since thermal technologies treat general areas, the precise 

location of DNAPL masses is not as important as it is for the other technologies. 

Oxidation techniques rely on the injection of oxidizing chemicals, such as permanganates or 

hydrogen peroxide, into the subsurface where they react with the DNAPLs and destroy them. 

Since the main expense with oxidizing technologies is the cost of the oxidant, information on 

quantities of contamination and the extent of naturally-occurring oxidant demand (NOD) are 

important. There is a growing body of full-scale remedial experience where this very approach 

has been approved by regulators and resulted in the issuance of no-further action letters. 

Nevertheless, contact between oxidizing agents and contaminants is required for effective 

treatment and achieving adequate contact is problematic in low-permeability and /or 

heterogenous media. 

Finally, flushing can be accomplished using cosolvents (alcohols), surfactants, or hot/cold water. 

Otherwise stationary contaminant masses are mobilized by the flushing agent and both are 

captured by a collection well(s). With the exception of hot/cold flushing, the above technologies 

have been shown to be able to capture or destroy between 60 and 90 percent of the 

contamination. 

There is a great deal of discussion in the remediation community as to whether removal of 60 to 

90 percent of a DNAPL mass is worth the cost. Because the remaining mass will continue to be a 

source of groundwater contamination, containment may still be needed to prevent risk of 

exposure. Some argue that by creatively structuring a treatment train across a site using 

aggressive source removal followed by downstream passive polishing techniques, such as 

bioremediation, natural attenuation could then be used instead of pump and treat to address the 

dissolved phase plume. This is an area where more research is required to determine which 

sources might be amenable to this approach. The research is needed to better define mass flux 

Chapter 14: DNAPLs Page 14-14 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

rates from reduced source zones and the potential for early shut down of pump-and-treat 

systems. There is also a need to develop better tools for both characterizing and remediating 

deep DNAPL sources, particularly those found in fractured bedrock. 

14.5.3 Balancing Source Removal/Treatment vs. Containment 

The extent to which site managers will continue to rely on containment approaches compared to 

source zone reduction will depend on decisions made at individual sites. These decisions will be 

based on technical, financial, and reuse considerations for the site, as well as regulatory 

requirements and policy. 

Through most of the 1990s, EPA policy recognized the difficulties of remediating sites 

containing DNAPL source zones and associated groundwater plumes, although the Agency 

continued to encourage aggressive cleanup of DNAPL source areas to the extent feasible. As a 

result, EPA policy has incorporated an implicit presumption that removal of DNAPLs from the 

subsurface is not practicable in many situations. In its 1993 guidance on “technical 

impracticability” EPA recognized that current technology was not capable of removing DNAPL 

mass (U.S. EPA 1993b). EPA policy has also suggested that waivers due to technical 

impracticability would be a presumptive remedy at DNAPL sites (U.S. EPA 1995 and 1996). 

Since then, progress has been made in both site characterization and remediation technologies 

that can affect DNAPL site management. Improved site characterization approaches may be used 

to improve the effectiveness and cost of plume management and treatment and treatment of the 

source zone. Thus, there is a growing awareness that accelerated groundwater restoration may be 

cost effective at many sites. 

A number of states have recognized the potential of the newer characterization and treatment 

tools in their regulatory policies regarding DNAPLs (ITRC 2002). They encourage the use of 

these tools to reduce the DNAPL source zone through removal and/or treatment of free-phase or 

residual DNAPLs. Their policy is to not grant ARAR waivers due to technical impracticability 

without serious consideration of innovative and emerging source reduction technologies. 

In conjunction with the state and federal regulatory policies, remediation professionals generally 

compare the costs and relative effectiveness of alternative approaches to reducing risks. For most 

DNAPL sites, the choice will be between a high initial cost and low future annual cost, on the 

one hand, and lower initial costs and moderate annual O&M costs for many years, perhaps 

decades or centuries, on the other. This tradeoff will be influenced by the discount rate used to 

compare future expenses to current expenses. Although EPA guidance provides “rules of thumb” 

for the selection of the discount rate, decision makers may use a lower or higher discount rate if 

there is justification for it (U.S. EPA 2000b). Some additional critical factors to be considered 

include life-cycle cost of all alternatives in both discounted and undiscounted dollars, including 

all probable costs, such as replacement of equipment and reactive materials, projected repairs, 

and O&M; and probable performance of each technology considered, given the site’s history, 

type and form of contaminants, manner and form of contaminant releases, and hydrogeologic 

characteristics. Regulators, responsible parties, and site owners will need to carefully structure 

these evaluations to ensure that funds will be available to continue O&M as long as necessary to 

protect human health and the environment. 

Chapter 14: DNAPLs Page 14-15 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

14.6 References

FRTR, 2004. Technology Cost and Performance, a database maintained by the Federal 

Remediation Technologies Roundtable (FRTR). http://costperformance.org/search.cfm 

ITRC, 2002. DNAPL Source Reduction: Facing the Challenge, Interstate Technology and 

Regulatory Council, April, 2002. 

ITRC, 2003a. Technical and Regulatory Guidance for Surfactant/Cosolvent Flushing of DNAPL 

Source Zones, Interstate Technology and Regulatory Council, April 2003. 

ITRC, 2003b. An Introduction to Characterizing Sites Contaminated with DNAPLs, Interstate 

Technology and Regulatory Council, September 2003. 

Kram, Keller, Rossabi, & Everett, 2001. “DNAPL Characterization Methods and Approaches, 

Part 1: Performance Comparisons,” Mark L Kram, A.A. Keller, J. Rossabi, and L.G. Everett, 

Ground Water Monitoring & Remediation, Fall 2001, pp. 109-123. 

http://www.cluin.org/download/char/GWMR_Fall_109-123.pdf 

Kram, Keller, Rossabi, & Everett, 2002. “DNAPL Characterization Methods and Approaches, 

Part 2: Cost Comparisons,” Mark L Kram, A.A. Keller, J. Rossabi, and L.G. Everett, Ground 

Water Monitoring & Remediation, Winter 2002, pp. 46-61. 

http://www.cluin.org/download/char/GWMR_W_02_46-61.pdf 

NRC, 1994. Alternatives for Groundwater Cleanup, National Research Council, National 

Academy Press, Washington, D.C., 1994. 

SERDP, 2001. Final Report, SERDP/ESTCP Expert Panel Workshop on Research and 

Development Needs for Cleanup of Chlorinated Solvent Sites, Strategic Environmental Research 

and Development Program sponsored by U.S. DOD, U.S. DOE, and U.S. EPA. 

http://www.serdp.org/news/other_events/2001/chlorsolv/chlorsolvcleanup.pdf 

U.S. EPA (Environmental Protection Agency), 1993a. 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. 

U.S. EPA, 1993b. Guidance for Evaluating Technical Impracticability of Groundwater 

Restoration, OSWER Directive 9234.2-25. 

U.S. EPA, 1994. Draft Analysis of Facility Corrective Action Data, Office of Solid Waste and 

Emergency Response, Technology Innovation Office, January 1994. 

U.S. EPA, 1995. Superfund Ground Water RODS: Implementing Change This Fiscal Year, 

OSWER Memorandum 9335.5-03P, EPA/540-F-99-005, Office of Solid Waste and Emergency 

Response. 

Chapter 14: DNAPLs Page 14-16 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

U.S. EPA, 1996. Presumptive Response Strategy and Ex-Situ Treatment Technologies for 

Contaminated Groundwater at CERCLA sites, OSWER Directive 9283.1-12, Office of Solid 

Waste and Emergency Response. 

U.S. EPA 1997a. Cleaning Up the Nation's Waste Sites: Markets and Technology Trends, EPA 

542-R-96-005. Office of Solid Waste and Emergency Response, Technology Innovation Office, 

April 1997. 

U.S. EPA, 1997b. Field Analytical and Site Characterization Technologies: Summary of 

Applications, EPA 542-R-97-011. http://www.epa.gov/swerust1/cat/fasc.pdf 

U.S. EPA, 1999. Groundwater Cleanup: Overview of Operating Experience at 28 Sites, EPA 

542-R-99-006, Office of Solid Waste and Emergency Response, September 1999. 

U.S. EPA, 2000a. Innovative Remediation Technologies: Field-Scale Demonstration Projects in 

North America, 2nd Edition Year 2000 Report, EPA/542/B-00-004, Office of Solid Waste and 

Emergency Response. http://www.epa.gov/tio/download/remed/nairt_2000.pdf 

U.S. EPA, 2000b. Remedy Cost Estimating Manual, A Guide to Developing and Documenting 

Remedial Alternative Cost Estimates During the Feasibility Study, EPA 540 R-DO-002, OSWER 

9355.0-75, Office of Solid Waste and Emergency Response. 

U.S. EPA, 2001a. Groundwater Pump and Treat Systems: Summary of Selected Cost and 

Performance Information at Superfund-financed Sites, EPA 542-R-01-021b, Office of Solid 

Waste and Emergency Response, December 2001. 

U.S. EPA, 2001b. State of the Practice of Characterization and Remediation of Contaminated 

Ground Water at Fractured Rock Sites, EPA 542-R-01-010, Office of Solid Waste and 

Emergency Response, July 2001. 

U.S. EPA, 2001c. Cost Analysis for Selected Groundwater Cleanup Projects: Pump and Treat 

Systems and Permeable Reactive Barriers, EPA 542-R-00-013, Office of Solid Waste and 

Emergency Response, February 2001. 

U.S. EPA, 2003. Report on Innovative Approaches to Manufactured Gas Plant Site 

Characterization, EPA/542/R-01/003, Office of Solid Waste and Emergency Response, 

Technology Innovation Office. 

Chapter 14: DNAPLs Page 14-17 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Web Sites 

Chemical Oxidation Site Profiles 

http://www.cluin.org/products/chemox/search/chem_search.cfm 

Fractured Bedrock Site Profiles and Other Links 

http://www.cluin.org/fracrock/ 

In Situ Thermal Treatment Site Profiles 

http://www.cluin.org/products/thermal/ 

Remediation Technology Cost and Performance Information 

http://www.frtr.gov/costperf.htm 

Field Analytic Technologies Information 

http://fate.clu-in.org/ 

Chapter 14: DNAPLs Page 14-18 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Appendix A. Supporting Data for National Priority List Sites Page A-1

Appendix A

Supporting Data for Analysis of

National Priority List Sites
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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Appendix A. Supporting Data for National Priority List Sites Page A-2
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit A-1. Contaminant Groups 

and Subgroups for the Analysis of 

Contaminants at NPL and DOD Sites 

This appendix contains the definitions of the chemical groups and subgroups used for the 

analyses of chemicals of concern found at NPL and DOD sites in chapters 3 and 6 of this report. 

The table on this page indicates the major chemical groups and subgroups, and the following 

pages list the individual chemicals that belong to each group and subgroup. This taxonomy was 

developed by grouping chemicals and elements in accordance with EPA test methods for 

evaluating solid waste and other standard chemical references listed on page A-11 of this 

appendix. 

Breakdown of Contaminant Groups and Subgroups 

Contaminant Group Contaminant Subgroup 

Individual 

Contaminants 

1. Volatile organic 

compounds (VOCs) 

Halogenated 

Non-halogenated 

BTEX 

See pages A-4 and A-5 

2. Semivolatile organic 

compounds (SVOCs) 

Halogenated 

Non-halogenated 

PAHs 

Pesticides 

Phenols 

PCBs 

See pages A-6 through 

A-10 

3. Metals No subgroup See page A-10 

4. Fuels & other 

petroleum distillates 

Fuels and distillates 

Solvents 

See page A-10 

5. Explosives & 

propellants 

No subgroup See page A-11 

6. Other Miscellaneous inorganic elements and 

compounds 

Radioactive materials 

Other Organic (coal tar, creosote) 

Unspecified Solvents 

See page A-11 

Sources: See page A-11 

Appendix A. Supporting Data for National Priority List Sites Page A-3 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

1. VOLATILE ORGANIC COMPOUNDS (VOCs) 

Halogenated VOCs 

1,1-Dichloroethane 75-34-3 

1,1-Dichloroethene 75-35-4 

1,1,1-Trichloroethane 71-55-6 

1,1,1,2-Tetrachloroethane 630-20-6 

1,1,2-Trichloro-1,2,2-Trifluoroethane 76-13-1 

1,1,2-Trichloroethane 79-00-5 

1,1,2,2-Tetrachloro-1,2-difluoroethane 76-12-0 

1,1,2,2-Tetrachloroethane 79-34-5 

1,2-Dibromo-3-chloropropane 96-12-8 

1,2-Dibromoethane 106-93-4 

1,2-Dichloro-1,1,2,2-Tetrafluoroethane 76-14-2 

1,2-Dichlorobenzene 95-50-1 

1,2-Dichloroethane 107-06-2 

1,2-Dichloropropane 78-87-5 

1,2,3-Trichloropropane 96-18-4 

1,2,3-Trichlorbenzene 87-61-6 

1,2,4-Trichlorobenzene 120-82-1 

1,3-Dichloro-2-propanol 96-23-1 

1,3-Dichlorobenzene 541-73-1 

1,4-Dichlorobenzene 106-46-7 

1,4-Difluorobenzene (IS) 540-36-3 

2-Chloroethanol 107-07-3 

2-Chloroethyl vinyl ether 110-75-8 

2-Picoline 109-06-8 

3-Chloropropionitrile 542-76-7 I 

4-Bromofluorobenzene (surr) 460-00-4 

4-Chlorophenyl phenyl ether 7005-72-3 

Allyl chloride 107-05-1 

Benzyl chloride 100-44-7 

Bis(2-chloroethoxy)methane 111-91-1 

Bis(2-chloroethyl) ether 111-44-4 

Bis(2-chloroethyl)sulfide 505-60-2 

Bis(2-chloroisopropyl) ether 108-60-1 

Bromoacetone 598-31-2 

Bromochloromethane 74-97-5 

Bromodichloromethane 75-27-4 

Bromoform 75-25-2 

Bromomethane 74-83-9 

Carbon tetrachloride 56-23-5 

Chloral hydrate 302-17-0 

Chlorobenzene 108-90-7 

Chlorodibromomethane 124-48-1 

Chloroethane 75-00-3 

Chloroform 67-66-3 

Chloromethane 74-87-3 

Chloroprene 126-99-8 

cis-1,3-Dichloropropene 10061-01-5 

cis-1,4-Dichloro-2-butene 1476-11-5 

cis-1,2-Dichloroethene 156-59-2 

Dibromochloromethane 124-48-1 

Dibromomethane 74-95-3 

Dichlorodifluoromethane 75-71-8 

Difluoromethane 

Epichlorohydrin 106-89-8 I 

Fluorobenzene (IS) 462-06-6 

Hexachlorobutadiene 87-68-3 

Hexachloroethane 67-72-1 I 

Iodomethane 74-88-4 

Methylene chloride 75-09-2 

Pentachloroethane 76-01-7 I 

Tetrachloroethene 127-18-4 

trans-1,2-Dichloroethene 156-60-5 

trans-1,3-Dichloropropene 10061-02-6 

trans-1,4-Dichloro-2-butene 110-57-6 

Trichloroethene 79-01-6 

Trichlorofluoromethane 75-69-4 

Vinyl chloride 75-01-4 

Non-halogenated VOCs 

110-86-1 I β-Propiolactone 57-57-8 

1-Propanol 71-23-8 

1,2,3,4-Diepoxybutane 1464-53-5 

1,4-Dioxane 123-91-1 

2-Butanone (MEK) 78-93-3 

2-Hexanone 591-78-6 

2-Hydroxypropionitrile 78-97-7 I 

2-Nitropropane 79-46-9 

2-Pentanone 107-87-9 

2-Propanol 67-63-0 

2,5-Dimethylbenzaldehyde 5779-94-2 

4-Methyl-2-pentanone (MIBK) 108-10-1 

Acetone 67-64-1 

Acetonitrile 75-05-8 

Acrolein (Propenal) 107-02-8 

Acrylonitrile 107-13-1 

Allyl alcohol 107-18-6 

Benzaldehyde 100-52-7 

Butanal (Butyraldehyde) 123-72-8 

Carbon disulfide 75-15-0 

Croton aldehyde 4170-30-3 

Croton aldehyde 123-73-9 

Cyclohexene 110-82-7 

Cyclohexanone 108-94-1 

Decanal 112-31-2 

Diethyl ether 60-29-7 

Ethanol 64-17-5 I 

Ethyl methacrylate 97-63-2 

Ethyl acetate 141-78-6 I 

Ethylene oxide 75-21-8 

Formaldehyde 50-00-0 

Heptanal 111-71-7 

Appendix A. Supporting Data for National Priority List Sites Page A-4 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Hexanal (Hexaldehyde) 66-25-1 

Isobutyl alcohol 78-83-1 

Isopropylbenzene 98-82-8 

Isovaleraldehyde 590-86-3 

m-Tolualdehyde 620-23-5 

Malononitrile 109-77-3 

Methacrylonitrile 126-98-7 

Methane 74-82-8 

Methanol 67-56-1 I 

Methyl Acetate 79-20-9 

Methylcyclohexane 108-87-2 

Methyl methacrylate 80-62-6 

Methyl-tert-butyl ether 1634-04-4 

n-Butanol 71-36-3 

N-Nitroso-di-n-butylamine 924-16-3 

n-Propylamine 107-10-8 

Naphthalene 91-20-3 

Nitrobenzene 98-95-3 

Nonanal 124-19-6 

o-Tolualdehyde 529-20-4 

o-Toluidine 95-53-4 

Notes (VOCs): 

Octanal 124-13-0 

p-Tolualdehyde 104-87-0Paraldehyde 123-63-7 

Pentanal (Valeraldehyde) 110-62-3 

Propanal (Propionaldehyde) 123-38-6 

Propargyl alcohol 107-19-7 

Propionitrile (ethyl cyanide) 107-12-0 

Pyridine 

Styrene 100-42-5 

Tetrahydrofuran 109-99-9 

t-Butyl alcohol 75-65-0 

Vinyl acetate 108-05-4 

BTEX 

Benzene 71-43-2 

Toluene 108-88-3 

Ethylbenzene 100-41-4 

m-Xylene 108-38-3 

o-Xylene 95-47-6 

p-Xylene 106-42-3 

List compiled from SW-846, CLP Target Compound List, Drinking Water Standard, Priority Pollutant 

List. 

Appendix A. Supporting Data for National Priority List Sites Page A-5 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

2. SEMIVOLATILE ORGANIC COMPOUNDS (SVOCs) 

Halogenated SVOCs 

1-Chloronaphthalene 90-13-1 

1,2-Dibromo-3-chloropropane 96-12-8 

1,2-Dichlorobenzene 95-50-1 

1,2,3,4,5,6,7,8-Octachlorodibenzofuran (OCDF) 39001-02-0 

1,2,3,4,5,6,7,8-Octachlorodibenzo-p-dioxin (OCDD) 3268-87-9 

1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin (HpCDD) 35822-46-9 

1,2,3,4,6,7,8-Heptachlorodibenzofuran (HpCDF) 67562-39-4 

1,2,3,4,7,8-Hexachlorodibenzo-p-dioxin (HxCDD) 39227-28-6 

1,2,3,4,7,8-Hexachlorodibenzofuran (HxCDF) 70648-26-9 

1,2,3,4,7,8,9-Heptachlorodibenzofuran (HpCDF) 55673-89-7 

1,2,3,6,7,8-Hexachlorodibenzofuran (HxCDF) 57117-44-9 

1,2,3,6,7,8-Hexachlorodibenzo-p-dioxin (HxCDD) 57653-85-7 

1,2,3,7,8-Pentachlorodibenzo-p-dioxin (PeCDD) 40321-76-4 

1,2,3,7,8-Pentachlorodibenzofuran (PeCDF) 57117-41-6 

1,2,3,7,8,9-Hexachlorodibenzofuran (HxCDF) 72918-21-9 

1,2,3,7,8,9-Hexachlorodibenzo-p-dioxin (HxCDD) 19408-74-3 

1,2,4-Trichlorobenzene 120-82-1 

1,2,4,5-Tetrachlorobenzene 95-94-3 

1,3-Dichlorobenzene 541-73-1 

1,4-Dichlorobenzene 106-46-7 

2-Chloroaniline 101-14-4 

2-Chloronaphthalene 91-58-7 

2,3,4,6-Tetrachlorophenol 58-90-2 

2,3,4,6,7,8-Hexachlorodibenzofuran (HxCDF) 60851-34-5 

2,3,4,7,8-Pentachlorodibenzofuran (PeCDF) 57117-31-4 

2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD) 1746-01-6 

2,3,7,8-Tetrachlorodibenzofuran (TCDF) 51207-31-9 

3-(Chloromethyl)pyridine 6959-48-4 

3-Methylcholanthrene 56-49-5 

3,3'-Dichlorobenzidine 91-94-1 

4-Bromophenyl phenyl ether 101-55-3 

4-Chloro-1,2-phenylenediamine 95-83-0 

4-Chloro-1,3-phenylenediamine 5131-60-2 

4-Chloroaniline 106-47-8 

4-Chlorophenyl phenyl ether 7005-72-3 

4,4'-Methylenebis (2-chloroaniline) 101-14-4 

5-Chloro-2-methylaniline 95-79-4 

Bis(2-chloroethoxy)methane 111-91-1 

Bis(2-chloroethyl) ether 111-44-4 

Bis(2-chloroisopropyl) ether 108-60-1 

Chlorobenzilate 510-15-6 

p-Chloro-m-creosol 

Hexachlorobenzene 118-74-1 

Hexachlorobutadiene 87-68-3 

Hexachlorocyclopentadiene 77-47-4 

Hexachloroethane 67-72-1 

Hexachlorophene 70-30-4 

Hexachloropropene 1888-71-7 

Hexamethylphosphoramide 680-31-9 

Appendix A. Supporting Data for National Priority List Sites Page A-6 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Hydrochloride 6959-48-4 

Pentachlorobenzene 608-93-5 

Pentachloronitrobenzene 82-68-8 

Total Heptachlorodibenzo-p-dioxin (HpCDD) 37871-00-4 

Total Tetrachlorodibenzo-p-dioxin (TCDD) 41903-57-5 

Total Pentachlorodibenzo-p-dioxin (PeCDD) 36088-22-9 

Total Hexachlorodibenzo-p-dioxin (HxCDD) 34465-46-8 

Total Tetrachlorodibenzofuran (TCDF) 55722-27-5 

Total Pentachlorodibenzofuran (PeCDF) 30402-15-4 

Total Hexachlorodibenzofuran (HxCDF) 55684-94-1 

Total Heptachlorodibenzofuran (HpCDF) 38998-75-3 

Tris(2,3-dibromopropyl) phosphate 126-72-7 

Non-halogenated SVOCs 

N,N-dimethylaniline 101-61-1 

α,α-Dimethylphenethylamine 122-09-8 

1-Acetyl-2-thiourea 591-08-2 

1-Naphthylamine 134-32-7 

1,2-Dinitrobenzene 528-29-0 

1,2-Diphenylhydrazine 122-66-7 

1,3-Dinitrobenzene 99-65-0 

1,3,5-Trinitrobenzene 99-35-4 

1,4-Dinitrobenzene 100-25-4 

1,4-Naphthoquinone 130-15-4 

1,4-Phenylenediamine 106-50-3 

2-Acetylaminofluorene 53-96-3 

2-Amino-4, 6-dinitrotoluene 35572-78-2 

2-Aminoanthraquinone 117-79-3 

4-Bromophenyl phenyl ether 101-55-3 

2-Naphthylamine 91-59-8 

2-Nitroaniline 88-74-4 

2-Nitrotoluene 88-72-2 

2-Picoline (2-Methylpyridine) 109-06-8 

2,4-Diaminotoluene 95-80-7 

2,4-Dinitrotoluene 121-14-2 

2,4,5-Trimethylaniline 137-17-7 

2,4,6-Trinitrotoluene 118-96-7 

2,6-Dinitrotoluene 606-20-2 

3-Amino-9-ethylcarbazole 132-32-1 

3-Nitroaniline 99-09-2 

3-Nitrotoluene 99-08-1 

3,3'-Dimethoxybenzidine 119-90-4 

3,3'-Dimethylbenzidine 119-93-7 

4-Amino-2,6-dinitrotoluene 1946-51-0 

4-Aminobiphenyl 92-67-1 

4-Nitroaniline 100-01-6 

4-Nitrobiphenyl 92-93-3 

4-Nitrotoluene 99-99-0 

4,4'-Methylenebis (2-chloroaniline)

 101-14-4 

4,4'-Oxydianiline 101-80-4 

4,6-Dinitro-2-methylphenol 534-52-1 

5-Nitro-o-anisidine 99-59-2 

5-Nitro-o-toluidine 99-55-8 

5-Nitroacenaphthene 602-87-9 

5,5-Diphenylhydantoin 57-41-0 

Acetophenone 98-86-2 

Aminoazobenzene 60-09-3 

Anilazine 101-05-3 

Aniline 62-53-3 

Benzidine 92-87-5 

Benzoic acid 65-85-0 

Benzyl alcohol 100-51-6 

Bis(2-chloroethoxy)methane 111-91-1 

Bis(2-chloroethyl)ether 111-44-4 

Bis(2-chloroisopropyl)ether 108-60-1 

Bis(2-ethylhexyl) phthalate 117-81-7 

Butyl benzyl phthalate 85-68-7 

Carbazole 86-74-8 

Di-n-butyl phthalate 84-74-2 

Di-n-octyl phthalate 117-84-0 

Dibenzofuran 132-64-9 

Diethyl phthalate 84-66-2 

Diethyl sulfate 64-67-5 

Diethylstilbestrol 56-53-1 

Dihydrosaffrole 56312-13-1 

Dimethyl phthalate 131-11-3 

Dimethylaminoazobenzene 60-11-7 

Diphenylamine 122-39-4 

Ethyl methanesulfonate 62-50-0 

Hexahydro-1,3,5-trinitro-1,3,5-triazine

 (RDX) 121-82-4 

Hydroquinone 123-31-9 

Isophorone 78-59-1 

Isosafrole 120-58-1 

Appendix A. Supporting Data for National Priority List Sites Page A-7 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Non-halogenated SVOCs (Continued) 

Maleic anhydride 108-31-6 

Mestranol 72-33-3 

Methapyrilene 91-80-5 

Methyl methanesulfonate 66-27-3 

Methyl-2,4,6-trinitrophenylnitramine 

(Tetryl) 479-45-8 

N-Nitrosodi-n-butylamine 924-16-3 

N-Nitrosodi-n-propylamine 621-64-7 

N-Nitrosodiethylamine 55-18-5 

N-Nitrosodimethylamine 62-75-9 

N-Nitrosodiphenylamine 86-30-6 

N-Nitrosomethylethylamine 10595-95-6 

N-Nitrosomorpholine 59-89-2 

N-Nitrosopiperidine 100-75-4 

N-Nitrosopyrrolidine 930-55-2 

Nicotine 54-11-5 

Nitrobenzene 98-95-3 

Nitroquinoline-1-oxide 56-57-5 

o-Anisidine 90-04-0 

o-Toluidine 95-53-4 

Octahydro-1,3,5,7-tetranitro-1,3,5,7-tetrazocine 

(HMX) 2691-41-0 

Octamethyl pyrophosphoramide 152-16-9 

O,O,O-Triethyl phosphorothioate 126-68-1 

p-Benzoquinone 106-51-4 

p-Cresidine 120-71-8 

Phenacetin 62-44-2Phenobarbital 50-06-6 

Phthalic anhydride 85-44-9 

Piperonyl sulfoxide 120-62-7 

Pronamide 23950-58-5 

Propylthiouracil 51-52-5 

Pyridine 110-86-1 

Resorcinol 108-46-3 

Tetraethyl dithiopyrophosphate 3689-24-5 

Tetraethyl pyrophosphate 107-49-3 

Toluene diisocyanate 584-84-9 

Tri-p-tolyl phosphate 78-32-0 

Trimethyl phosphate 512-56-1 

Polynuclear Aromatic Hydrocarbons (PAHs) 

Acenaphthene 83-32-9 

Acenaphthylene 208-96-8 

Anthracene 120-12-7 

Benzo(a)anthracene 56-55-3 

Benzo(a)pyrene 50-32-8 

Benzo(b)fluoranthene 205-99-2 

Benzo(j)fluoranthene 205-83-3 

Benzo(k)fluoranthene 207-08-9 

Benzo(ghi)perylene 191-24-2 

Chrysene 218-01-9 

Dibenz(a,h)acridine 226-36-8 

Dibenz(a,j)acridine 224-42-0 

Dibenzo(a,h)anthracene 53-70-3 

Dibenzo(a,e)pyrene 192-65-4 

Dibenzo(a,h)pyrene 189-64-0 

Dibenzo(a,i)pyrene 189-55-9 

Fluoranthene 206-44-0 

Fluorene 86-73-7 

Indeno(1,2,3-cd)pyrene 193-39-5 

3-Methylcholanthrene 56-49-5 

Naphthalene 91-20-3 

Phenanthrene 85-01-8 

Pyrene 129-00-0 

7,12-Dimethylbenz(a)anthracene 57-97-6 

2-Methylnaphthalene 91-57-6 

Pesticides 

α-BHC 319-84-6 

α-Chlordane 5103-71-9 

β-BHC 319-85-7 

γ-BHC (Lindane) 58-89-9 

γ-Chlordane 5103-74-2 

δ-BHC 319-86-8 

2,4-D 94-75-7 

2,4-DB 94-82-6 

2,4,5-T 93-76-5 

2,4,5-TP (Silvex) 93-72-1 

3-Hydroxycarbofuran 16655-82-6 

4-Nitrophenol 100-02-1 

4,4'-DDD 72-54-8 

4,4'-DDE 72-55-9 

4,4'-DDT 50-29-3 

Aldicarb 

Aldicarb (Temik) 116-06-3 

Aldicarb Sulfone 1646-88-4 

Aldicarb Sulfoxide 

Aldrin 309-00-2 

Aramite 140-57-8 

Aspon, 3244-90-4 

Atrazine 1912-24-9 

Azinphos-ethyl 2642-71-9 

Azinphos-methyl 86-50-0 

Barban 101-27-9 

Bolstar (Sulprofos) 35400-43-2 

Bromoxynil 1689-84-5 

Captafol 2425-06-1 

Captan 133-06-2 

Carbaryl (Sevin) 63-25-2 

Carbofuran (Furadan) 1563-66-2 

Carbophenothion 786-19-6 

Chlordane - not otherwise specified 57-74-9 

Chlorfenvinphos 470-90-6 

Appendix A. Supporting Data for National Priority List Sites Page A-8 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Pesticides (Continued) 

Chlorobenzilate 510-15-6 

Chlorpyrifos 2921-88-2 

Chlorpyrifos methyl 5598-13-0 

Coumaphos 56-72-4 

Crotoxyphos 7700-17-6 

Dalapon 75-99-0 

Dibromochloropropane (DBCP) 96-12-8 

Demeton 8065-48-3 

Diallate (cis or trans) 2303-16-4 

Diazinon 333-41-5 

Dicamba 1918-00-9 

Dichlone 117-80-6 

Dichlorofenthion 97-17-6 

Dichloroprop 120-36-5 

Dichlorvos (DDVP) 62-73-7 

Dicrotophos 141-66-2 

Dieldrin 60-57-1 

Dimethoate 60-51-5 

Dinocap 39300-45-3 

Dinoseb 88-85-7 

Dioxacarb 6988-21-2 

Dioxathion 78-34-2 

Diquat 2764-72-9 

Diuron 330-54-1 

Disulfoton 298-04-4 

Endosulfan I 959-98-8 

Endosulfan sulfate 1031-07-8 

Endosulfan II 33213-65-9 

Endrin 72-20-8 

Endrin ketone 53494-70-5 

Endrin aldehyde 7421-93-4 

EPN 2104-64-5 

Ethion 563-12-2 

Ethoprop 13194-48-4 

Ethyl carbamate 51-79-6 

Ethyl parathion 56-38-2 

Famphur 52-85-7 a 

Fenitrothion 122-14-5 

Fensulfothion 115-90-2 

Fenthion 55-38-9 

Fluchloralin 33245-39-5 

Fonophos 944-22-9 

Heptachlor epoxide 1024-57-3 

Heptachlor 76-44-8 

Hexachlorobenzene 118-74-1 

Hexachlorocyclopentadiene 77-47-4 

Hexamethylphosphoramide (HMPA) 680-31-9 

Isodrin 465-73-6 

Kepone 143-50-0 

Leptophos 21609-90-5 

Linuron 330-55-2 

Malathion 121-75-5 

MCPA 94-74-6 

MCPP 93-65-2 

Merphos 150-50-5 

Methiocarb (Mesurol) 2032-65-7 

Methomyl (Lannate) 16752-77-5 

Methoxychlor 72-43-5 

Methyl parathion 298-00-0 

Mevinphos 7786-34-7 

Mexacarbate 315-18-4 

Mirex 2385-85-5 

Monocrotophos 6923-22-4 

Monuron 150-68-5 

Naled 300-76-5 

Nitrofen 1836-75-5 

Parathion 56-38-2 

Parathion, methyl 298-00-0 

Pentachlorophenol 87-86-5 

Phorate 298-02-2 

Phosalone 2310-17-0 

Phosmet 732-11-6 

Phosphamidon 13171-21-6 

Picloram 1918-02-1 

Promecarb 2631-37-0 

Propoxur (Baygon) 114-26-1 

Ronnel 299-84-3 

Rotenone 83-79-4 

Safrole 94-59-7 

Siduron 1982-49-6 

Simazine 122-34-9 

Stirophos (Tetrachlorovinphos) 22248-79-9 

Strychnine 57-24-9 

Sulfallate 95-06-7 

Sulfotepp 3689-24-5 

TEPP 21646-99-1 

Terbufos 13071-79-9 

Tetrachlorvinphos 961-11-5 

Tetraethyl dithiopyrophosphate 3689-24-5 

Tetraethyl pyrophosphate 107-49-3 

Thionazin (Zinophos) 297-97-2 

Thiophenol (Benzenethiol) 108-98-5 

Tokuthion (Protothiofos) 34643-46-4 

Toxaphene 8001-35-2 

Tri-o-cresylphosphate (TOCP) 78-30-8 

Triazine Herbicides (NPD only) 

Trichlorfon 52-68-6 

Trichloronate 327-98-0 

Trifluralin 1582-09-8 

Appendix A. Supporting Data for National Priority List Sites Page A-9 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Appendix A. Supporting Data for National Priority List Sites Page A-10

Phenols

2-Chlorophenol 95-57-8

2-Cyclohexyl-4,6-dinitrophenol 131-89-5

2-Methyl-4,6-dinitrophenol 534-52-1

2-Methylphenol (o-Cresol) 95-48-7

2-Nitrophenol 88-75-5

2,3,4,5-Tetrachlorophenol 4901-51-3

2,3,4,6-Tetrachlorophenol 58-90-2

2,3,5,6-Tetrachlorophenol 935-95-5

2,4-Dichlorophenol 120-83-2

2,4-Dimethylphenol 105-67-9

2,4-Dinitrophenol 51-28-5

2,4,5-Trichlorophenol 95-95-4

2,4,6-Trichlorophenol 88-06-2

2,6-Dichlorophenol 87-65-0

3-Methylphenol (m-Cresol) 108-39-4

4-Chloro-3-methylphenol 59-50-7

4-Methylphenol (p-Cresol) 106-44-5

4-Nitrophenol 100-02-7

Dinoseb (DNBP) 88-85-7

(2-(Sec-butyl)-4,6-dinitrophenol)

Pentachlorophenol 87-86-5

Phenol 108-95-2 DC(28)

Polychlorinatedbiphenyls (PCBs)

Aroclor 1016 12674-11-2 -

Aroclor 1221 11104-28-2 -

Aroclor 1232 11141-16-5 -

Aroclor 1242 53469-21-9 -

Aroclor 1248 12672-29-6 -

Aroclor 1254 11097-69-1 -

Aroclor 1260 11096-82-5 -

2-Chlorobiphenyl 2051-60-7 1

2,3-Dichlorobiphenyl 16605-91-7 5

2,2',5-Trichlorobiphenyl 37680-65-2 18

2,4',5-Trichlorobiphenyl 16606-02-3 31

2,2',3,5'-Tetrachlorobiphenyl 41464-39-5 44

2,2',5,5'-Tetrachlorobiphenyl 35693-99-3 52

2,3',4,4'-Tetrachlorobiphenyl 32598-10-0 66

2,2',3,4,5'-Pentachlorobiphenyl 38380-02-8 87

2,2',4,5,5'-Pentachlorobiphenyl 37680-73-2 101

2,3,3',4',6-Pentachlorobiphenyl 38380-03-9 110

2,2',3,4,4',5'-Hexachlorobiphenyl 35065-28-2 138

2,2',3,4,5,5'-Hexachlorobiphenyl 52712-04-6 141

2,2',3,5,5',6-Hexachlorobiphenyl 52663-63-5 151

2,2',4,4',5,5'-Hexachlorobiphenyl 35065-27-1 153

2,2',3,3',4,4',5-Heptachlorobiphenyl 35065-30-6 170

2,2',3,4,4',5,5'-Heptachlorobiphenyl 35065-29-3 180

2,2',3,4,4',5',6-Heptachlorobiphenyl 52663-69-1 183

2,2',3,4',5,5',6-Heptachlorobiphenyl 52663-68-0 187

2,2',3,3',4,4',5,5',6-Nonachlorobiphenyl 40186-72-9

3. METALS

Aluminum 

Antimony

Arsenic

Barium

Beryllium

Boron

Cadmium

Calcium

Chromium

Cobalt

Copper

Iron

Lead

Lithium

Magnesium

Manganese

Mercury

Molybdenum

Nickel

Potassium

Selenium

Silver

Sodium

Strontium

Thallium

Tin

Vanadium

Zinc

Note (metals):

The above are either TAL metals, drinking water

primary or secondary metals, or have toxicity values

associated with the Region 9 preliminary cleanup goals

list

4. FUELS AND OTHER

 PETROLEUM DISTILLATES

Diesel Fuel

Gasoline

JP-4

JP-5

Kerosene

No. 2 Fuel oil

Unspecified fuel

Solvents

Mineral Spirits

Stoddard solvent 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Appendix A. Supporting Data for National Priority List Sites Page A-11

5. EXPLOSIVES AND

PROPELLANTS

Explosives

Propellants

6. OTHER WASTES

Miscellaneous Inorganic Elements and

Compounds (Misc. Organics)

Ammonia

Asbestos

Copper Chromated Arsenic

Chloride

Hydrazine

Hydrofluoric acid

Inorganic cyanides

Nitrate

Nitrite

Perchlorate

Phosphine

Phosphorus

Silicon tetrafluoride

Sulfides

Radioactive Materials

Americium

Cesium 137 Cobalt 60

Curium

Iodine 131

Lead 210

Neptunium

Plutonium

Polonium 210

Radium

Radon

Strontium 90

Technetium

Thorium

Tritium

Uranium

Other Organic Substances

Coal Tar

Creosote

Unspecified organic materials

Unspecified solvents 

7. REFERENCES

Greenberg, A. et al., editors. 1985. Standard Methods for

the Examination of Water and Wastewater, American

Public Health Association.

U.S. Congress. Code of Federal Regulations: 40 CFR 136

Guidelines Establishing Test Procedures for the Analysis

of Pollutants. 

U.S. EPA, 1997. Test Methods for Evaluating Solid

Waste, Physical/Chemical Methods,” Third Edition,

Office of Solid Waste and Emergency Response, June 13,

1997. 

U.S. EPA, 1998. Test Methods for Evaluating Solid

Waste, Physical/Chemical Methods Draft Update IVA,

Office of Solid Waste and Emergency Response, May

1998, http://www.epa.gov/epaoswer/

hazwaste/test/sw846.htm 

U.S. EPA, 1999. Multi-Media, Multi-Concentration

Organics Analysis OLM04.2, Office of Solid Waste and

Emergency Response, Fall 1999.

U.S. EPA, 2000. Test Methods for Evaluating Solid

Waste, Physical/Chemical Methods Draft Update IVB,

Office of Solid Waste and Emergency Response, 

November 2000. http://www.

epa.gov/epaoswer/hazwaste/test/sw846.htm 

U.S. EPA, 2002a. Multi-Media, Multi-Concentration

Dioxins and Furans Analysis, DLM01.4 (a Non-Routine

Analytical Service) Statement of Work, Office of Solid

Waste and Emergency Response, January 2002.

U.S. EPA, 2002b. Multi-Media, Multi-Concentration

Inorganic Analysis ILM05.2, Office of Solid Waste and

Emergency Response, September 2002.
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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Appendix A. Supporting Data for National Priority List Sites Page A-12
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit A-2. Superfund Remedial 

Action Contractors (RACs) 

Region 1 Tetra Tech/Black and Veatch (joint venture) 

56 West Main Street 

Tetra Tech NUS, Inc. Christiana, DE 19702 

55 Jonspin Road Contact: Dr. Carl Hsu 

Wilmington, MA 01887 302-738-7551 

Contact: George Gardner email: carl.hsu@tetratech.com 

508-658-7899 

email: bbrd680@b-r.com CDM Federal Programs Corp. 

13135 Lee Jackson Memorial Highway 

Metcalf and Eddy, Inc. Suite 200 

30 Harvard Mill Square Fairfax, VA 22033 

P.O. Box

Wakefield, MA 01880 

Contact: Neville Chung 

617-224-6385 

email: neville_chung@metcalfeddy.com 

Contact: Joan Knapp 

703-968-0200 ex. 358 

email: knappjo@cdm.com 

Region 4 

Region 2 

Foster Wheeler Environmental Corp. 

1000 The American Road 

Morris Plains, NJ 07950 

Contact: William Colvin 

973-630-8554 

email: wcolvin@fwenc.com 

Black & Veatch Special Project Corp. 

1145 Sanctuary Parkway, Suite 475 

Alpharetta, GA 30004 

Contact: Harvey B. Coppage 

770-751-7517 

email: coppagehb@bv.com 

Region 5 

CDM Federal Programs Corp. 

125 Maiden Lane - 5th Floor 

New York, NY 10038 

Contact: Robert Goltz 

212-785-9123 

email: goltz.rd@cdm.com 

CH2MHILL 

135 South 84th St., Suite 325 

Milwaukee, WI 53214 

Contact: Isaac Johnson 

414-272-2426 

email: ijohnson@ch2m.com 

Region 3 Weston Solutions, Inc. 

750 E. Bunker Court, Suite 500 

Tetra Tech NUS, Inc. Vernon Hills, IL 60061-1450 

661 Andersen Drive Contact: James M. Burton 

Pittsburgh, PA 15220 847-918-4000 

Contact: Don Senovich email: james.burton@westonsolutions.com 

412-921-7090 

email: dsenovich@b-r.com 

Appendix A. Supporting Data for National Priority List Sites Page A-13 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Region 6

CH2MHILL

10th Floor

12377 Merit Drive

Dallas, TX 75251

Contact: Al Sloan

972-980-2170

email: asloan@ch2m.com

Tetra Tech Environmental Management,

Inc.

1 Dallas Center

350 N. St. Paul St., Suite 2600

Dallas, TX 75201

Contact: Lou Barinka

214-740-2014

email: barinkal@ttemi.com

Region 7

Black & Veatch

6601 College Blvd.

Overland Park, KS 66211

Contact: Ray Herzog

913-458-6600

email: herzogrh@bv.com

Region 8

CDM Federal Programs

1331 17th Street, Suite 1050

Denver, CO 80202

Contact: Richard Culver

303-295-1237

email: culverrl@cdm.com

Region 9

CH2MHILL

155 Grand Avenue, Suite 1000

Oakland CA 94612

Contact: Udai Singh

510-587-7555

email: usingh@ch2m.com

Region 10

URS Greiner, Inc.

2401 4th Avenue, Suite 1000

Seattle, WA 98121-1459

Contact: Vivianne Larkin

206-674-1871

email: vivianne_larkin@urscorp.com

Appendix A. Supporting Data for National Priority List Sites Page A-14
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Appendix B. Supporting Data for Underground Storage Tank Sites Page B-1

Appendix B

Supporting Data for Analysis of 

Underground Storage Tank Sites
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit B-1. UST Corrective Action Measures 

Mid-Year FY 2004 (As of March 31, 2004) 

Region/ 

State 

Active 

Tanks 

Closed 

Tanks 

Confirmed 

Released 

Cleanups 

Initiated 

Cleanups 

Completed 

Cleanup 

Backlog 

Emergency 

Responses 

Region One 

CT 12,358 191 49 2,388 2,344 1,538 850 110 

MA 11,489 21,689 5,958 5,745 4,525 1,433 4,868 

ME 3,443 11,963 2,080 2,029 1,948 132 370 

NH 3,027 10,639 2,141 2,141 1,292 849 606 

RI 1,720 7,041 1,199 1,199 942 257 26 

VT 2,967 5,104 1,897 1,885 1,086 811 261 

Subtotal 35,004 75,585 15,663 15,343 11,331 4,332 6,241 

Region Two 

NJ 18,836 52,720 9,257 8,400 5,466 3,791 51 

NY 29,683 78,126 19,719 19,130 17,264 2,455 410 

PR 4,684 5,202 999 843 380 619 168 

VI 124 278 14 14 0 14 14 

Subtotal 53,327 136,326 29,989 28,387 23,110 6,879 643 

Region Three 

DC 723 2,998 781 781 528 253 228 

DE 1,560 6,378 2,204 2,142 1,889 315 390 

MD 9,369 27,639 11,999 10,420 8,661 3,338 330 

PA 26,739 57,841 13,445 13,331 9,090 4,355 28 

VA 28,024 48,907 9,988 9,714 9,083 905 63 

WV 6,267 18,198 2,801 2,632 1,584 1,217 9 

Subtotal 72,682 161,961 41,218 39,020 30,835 10,383 1,048 

Region Four 

AL 18,194 28,236 10,688 10,587 8,987 1,701 276 

FL 32,786 91,252 25,220 14,012 7,606 17,614 204 

GA 38,725 43,707 10,443 9,904 7,321 3,122 10 

KY 13,452 34,284 12,744 12,739 10,176 2,568 148 

MS 8,994 21,351 6,357 6,207 6,061 296 114 

NC 30,932 61,902 23,090 22,290 16,053 7,037 503 

SC 12,325 30,999 8,490 8,101 4,912 3,578 94 

TN 16,550 31,726 12,359 11,697 11,092 1,267 68 

Subtotal 171,958 343,457 109,391 95,537 72,208 37,183 1,417 

Appendix B. Supporting Data for Underground Storage Tank Sites Page B-2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit B-1. UST Corrective Action Measures (Continued) 

Mid-Year FY 2004 (As of March 31, 2004) 

Region/ 

State 

Active 

Tanks 

Closed 

Tanks 

Confirmed 

Released 

Cleanups 

Initiated 

Cleanups 

Completed 

Cleanup 

Backlog 

Emergency 

Responses 

Region Five 

IL 23,373 60,961 21,895 20,499 13,158 8,737 1,755 

IN 14,299 34,673 7,943 6,994 4,347 3,596 226 

MI 21,493 63,453 20,242 19,867 11,296 8,946 87 

MN 14,077 28,025 9,311 8,816 8,054 1,257 432 

OH 24,758 41,311 23,288 22,891 19,698 3,590 417 

WI 14,149 63,672 18,038 17,123 14,464 3,574 388 

Subtotal 112,149 292,095 100,717 96,190 71,017 29,700 3,305 

Region Six 

AR 9,952 19,554 1,205 927 877 328 12 

LA 14,913 30,709 2,595 1,894 1,584 1,011 691 

NM 4,189 12,086 2,419 1,660 1,502 917 79 

OK 11,890 23,908 3,902 3,902 3,395 507 89 

TX 58,218 106,926 23,585 21,499 18,186 5,399 500 

Subtotal 99,162 193,183 33,706 29,882 25,544 8,162 1,371 

Region Seven 

LA 7,846 21,699 5,708 5,492 3,603 2,105 0 

KS 7,556 19,055 4,526 4,255 2,438 2,088 115 

MO 10,328 27,847 5,995 5,621 4,562 1,433 329 

NE 6,962 13,926 5,890 3,837 3,524 2,366 10 

Subtotal 32,692 82,527 22,119 19,205 14,127 7,992 454 

Region Eight 

CO 8,225 20,453 6,291 6,066 5,241 1,050 41 

MT 3,584 12,894 3,045 2,289 1,880 1,165 48 

ND 2,194 6,892 811 800 756 55 3 

SD 3,084 6,522 2,307 2,258 2,039 268 21 

UT 4,042 12,355 4,038 3,852 3,518 520 3 

WY 2,073 7,695 1,978 1,212 955 1,023 62 

Subtotal 23,202 66,811 18,470 16,477 14,389 4,081 178 

Appendix B. Supporting Data for Underground Storage Tank Sites Page B-3 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit B-1. UST Corrective Action Measures (Continued) 

Mid-Year FY 2004 (As of March 31, 2004) 

Region/ 

State

 Tanks Closed 

Tanks 

Confirmed 

Released 

Cleanups 

Initiated 

Cleanups 

Completed 

Cleanup 

Backlog 

Emergency 

Responses 

Region Nine 

AZ 8,303 19,584 8,085 5,550 5,512 2,573 2 

CA 41,005 117,655 42,487 42,487 27,245 15,242 0 

HI 1,835 4,921 1,776 1,680 1,414 362 0 

NV 3,695 6,613 2,420 2,410 2,133 287 52 

CNMI 79 19 9 8 2 7 0 

GU 280 398 132 132 108 24 0 

AS 12 52 7 7 6 1 1 

Subtotal 55,209 149,242 54,916 52,274 36,420 18,496 55 

Region Ten 

AK 1,086 6,151 2,300 2,163 1,292 1,008 95 

ID 3,527 9,169 1,315 1,284 1,135 180 12 

OR 6,629 25,861 6,760 6,407 5,167 1,593 56 

WA 9,939 35,014 5,977 5,742 3,956 2,021 37 

Subtotal 21,181 76,195 16,352 15,596 11,550 4,802 200 

Regional Corrective Actions for Indian Country 

Region 1 4 2 0 0 0 0 0 

Region 2 179 21 7 1 0 7 2 

Region 3 NA NA NA NA NA NA NA 

Region 4 58 55 10 10 4 6 0 

Region 5 374 996 191 188 124 67 0 

Region 6 301 195 34 34 30 4 1 

1Region 7 88 91 20 15 8 12 0 

Region 8 571 1,885 436 397 215 221 5 

Region 9 708 1,165 181 136 101 80 0 

Region 10 400 846 148 142 112 36 0 

Subtotal 2,683 5,256 1,027 923 594 433 8 

National Totals 

Active 

Tanks 

Closed 

Tanks 

Confirmed 

Released 

Cleanups 

Initiated 

Cleanups 

Completed 

Cleanup 

Backlog 

Emergency 

Responses 

National 

Total 

679,249 1,582,638 443,568 408,834 311,125 132,443 14,920 

Source: U.S. Environmental Protection Agency, Office of Underground Storage Tanks, Semi-Annual Activity 

Report, First Half ( March 31, 2004). http://www.epa.gov/swerust1/cat/camarchv.htm 

Appendix B. Supporting Data for Underground Storage Tank Sites Page B-4 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Appendix C: Department of Defense Sites Page C-1

Appendix C

Supporting Data for Analysis of

Department of Defense Sites
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

EPA Region 

One 

Two 

Three 

Four 

Five 

Six 

Exhibit C-1: Location of DOD Sites Needing Cleanup 

State 

DOD 

Installations 

DOD

 Sites 

Army 

Sites 

Navy 

Sites 

Air Force 

Sites 

DLA 

Sites 

CT 16 51 7 27 8 0 

MA 56 153 34 10 56 0 

ME 39 67 1 9 15 0 

NH 9 36 6 10 17 0 

RI 27 60 9 15 1 0 

VT 5 10 0 0 5 0 

Subtotal 152 377 57 71 102 0 

NJ 44 268 173 32 19 1 

NY 89 260 60 6 80 8 

PR 12 60 0 48 2 0 

VI 1 1 0 0 0 0 

Subtotal 146 589 233 86 101 9 

DC 29 63 3 26 7 0 

DE 7 44 0 0 39 0 

MD 30 357 174 140 26 4 

PA 34 135 73 19 10 10 

VA 43 318 62 202 20 9 

WV 6 39 0 13 0 1 

Subtotal 149 956 312 400 102 24 

AL 24 217 180 0 18 0 

FL 96 462 0 161 217 0 

GA 26 163 75 10 64 0 

KY 8 74 63 3 0 0 

MS 24 61 0 16 25 0 

NC 31 168 15 82 45 0 

SC 29 163 19 68 53 0 

TN 21 140 46 16 24 39 

Subtotal 259 1,448 398 356 446 39 

IL 55 247 89 23 69 0 

IN 18 124 62 33 10 0 

MI 31 120 0 0 80 0 

MN 10 37 20 3 5 0 

OH 33 148 35 0 50 1 

WI 19 36 9 0 11 0 

Subtotal 166 712 215 59 225 1 

AR 11 49 12 0 19 0 

LA 13 31 5 1 11 7 

NM 124 184 20 0 32 0 

OK 41 123 25 0 47 0 

TX 125 359 67 48 122 1 

Subtotal 314 746 129 49 231 8 

FUDS 

Sites 

9 

53 

42 

3 

35 

5 

147 

4 

106 

10 

1 

160 

27 

5 

13 

23 

25 

25 

118 

19 

84 

14 

8 

20 

26 

23 

15 

209 

66 

19 

40 

9 

62 

16 

212 

18 

7 

132 

51 

121 

329 

Appendix C: Department of Defense Sites Page C-2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit C-1: Location of DOD Sites Needing Cleanup (Continued) 

EPA Region State 

DOD 

Installations 

DOD

 Sites 

Army 

Sites 

Navy 

Sites 

Air Force 

Sites 

DLA 

Sites 

FUDS 

Sites 

Seven IA 8 33 23 0 2 0 8 

KS 55 164 83 0 8 0 73 

MO 24 85 22 0 37 0 26 

NE 41 69 3 0 17 0 49 

Subtotal 128 351 131 0 64 0 156 

Eight CO 28 226 154 1 47 0 24 

MT 6 18 0 0 12 0 6 

ND 3 6 1 0 5 0 0 

SD 19 30 0 0 11 0 19 

UT 24 227 159 0 35 6 27 

WY 21 37 0 0 17 0 20 

Subtotal 101 544 314 1 127 6 96 

Nine AS 6 6 0 0 0 0 6 

AZ 87 140 39 2 20 0 79 

CA 402 2,011 68 653 830 44 416 

CN 15 18 0 0 0 0 18 

GM 13 14 0 0 0 0 14 

GU 8 49 0 28 21 0 0 

HI 73 251 12 109 67 0 63 

JQ 2 8 0 0 7 0 0 

MQ 1 1 0 1 0 0 0 

NV 29 78 18 20 11 0 29 

WQ 1 37 0 0 37 0 0 

Subtotal 637 2,613 137 813 993 44 625 

Ten AK 120 454 24 0 293 0 137 

ID 9 32 0 17 8 0 7 

OR 17 33 4 0 14 0 15 

WA 36 119 25 41 31 0 22 

Subtotal 182 638 53 58 346 0 181 

Total 2,234 8,974 1,979 1,893 2,737 131 2,233 

Notes:

 • Needing Cleanup means sites that have not achieved Response Complete (RC) status.

 • The column for DOD Installations and Sites includes one Defense Threat Reduction Agency (DTRA) site at Johnston Atoll 

(JQ).

 • JQ = Johnston Atoll; AS = American Samoa; GM/GU = Guam; WQ = Wake Island; MQ = Midway; CN = Marianas; VI = Virgin 

Islands. 

Source: DOD, Office of the Under Secretary of Defense (Installations & Environment), Restoration Management Information 

System (RMIS), data as of September 2001. 

Appendix C: Department of Defense Sites Page C-3 
Exhibit C-2: Definitions of DOD Site Types 

Site Type Site Description Primary Con

Underground Underground storage tank sites result from the release of substances from • POLs •SolveStorage Tank underground storage tanks and any associated piping. • POL sludges • Me

Spill Area Spill areas are small areas where spills from drums, tanks, and other waste • POLs • Slud

units have taken place. • PCBs • Me

 • Solvents 

Landfill Landfill sites are typically areas formerly used to dispose of both domestic • POLs •Pest

and industrial hazardous waste. • Solvents • Me

 Paint • Or

Unexploded Unexploded munitions and ordnance areas are areas that have been used • UXO • ExMunitions/Ordnance for munitions and ordnance training. • Metals • OrArea 

Surface Disposal Surface disposal area sites consist of small areas formerly used for disposal • POLs •MetaArea of solid wastes with little or no free liquids. Typical materials include rags, • Solvents • Ac

filters, paint cans, small capacitors, and batteries. • Paints • PC

 • Pesticides 

Disposal Pit/Dry Well Disposal pit/dry well sites consist of small unlined excavations and structures • POLs •Acids 

that were used over a period of time to dispose of small quantities of liquid wastes.

 • Metals • So

 • Ordnance compoun

 • Explosive chemical

Storage Area Storage areas are areas where spills and leaks occurred from stored • POLs •Meta

containers or equipment. • Solvents • Ac

 • POL sludge • PC

Contaminated Groundwater 

Contaminated groundwater results from various types of releases of known or unknown origin, such as migration of leachate from disposal areas and migration of substances from contaminated surface and subsurface soils.

 • Metals • PO • Chlorinated solvent

• Explosive chemical

 • Non-chlorinated so

Appendix C: Department of Defense Sites Page C-4 
Exhibit C-2: Definitions of DOD Site Types (Continued) 

Site Type Site Description Primary Cont

Fire/Crash Training Fire and crash rescue training areas consist of trenches and/or pits where • POLs • POArea flammable materials were ignited periodically for demonstrations and training • Solvents • M

exercises.

Building Demolition/ Building demolition and debris removal sites consist of buildings and/or debris that • Asbestos • LeDebris Removal are unsafe or must be removed. • Construction debris 

Surface Surface impoundments and lagoons consist of unlined depressions, • POLs • MeImpoundment/ excavations, or diked areas which were used to accumulate liquid waste, • Solvents • OrLagoon waste containing free liquid, or industrial wastewaters. • Explosive chemicals 

• Industrial wastewater 

Aboveground Aboveground storage tank sites result from release of substances to • POLs Storage Tanks surrounding areas from aboveground tanks, containers, and any 

associated piping.

Contaminated Fill Contaminated fill areas consist of contaminated material resulting from • POLs • Ex

excavations for construction, tanks, and other purposes. • Metals • Pa

 • Ordnance compounds 

Contaminated Building 

Contaminated building sites result from releases within or on the outside of a structure of a substance that has been contained within the building.

 • POL • A • Plating waste • P • Metals • P • POL sludge • S • PCBs • A

Burn Area Burn area sites consist of pits or surface areas that were used for open-air • POLs • E

incineration of waste. • Propellants • O

 • Solvents 

Contaminated Contaminated sediments include sediments of bodies of water that have • POLs • MSediments been contaminated by surface runoff, subsurface migration, or direct • PCBs • S

discharge of contaminants. • Pesticides • E

Appendix C: Department of Defense Sites Page C-5 
Exhibit C-2: Definitions of DOD Site Types (Continued) 

Site Type Site Description Primary Conta

Explosive/Ordnance Explosive ordnance disposal areas consist of open-air areas that were • Unexploded • MeDisposal Area used to detonate, demilitarize, bury, or dispose of explosives. • Ordnance (UXO)

 • Ordnance compounds • Explosive chemicals 

Waste Line Waste lines are underground piping used to carry industrial wastes from 

shop facilities to a wastewater treatment plant.

 • Solvents • M • Plating sludges • Pe • Explosive chemicals 

Waste Treatment Plant 

Wastewater treatment plant sites result from releases of substances at plants that were used to treat and dispose of domestic and/or industrial wastewater.

 • POLs • Ind • Solvents w • Plating sludges • Explosive chemicals 

Sewage Treatment Plant 

Sewage treatment plants typically consist of a complex of tanks, piping, and sludge management areas used to treat sanitary sewage generated at an installation. The unit may use chemical or biological treatment methods. Lagoons associated with the biological treatment of sewage currently may be considered to be separate units.

 • Metals • Industrial wastewater • Solvents • POLs 

Petroleum, Oil, Lubricant (POL) Distribution Line 

Petroleum, oil, lubricant distribution lines are used to transport POL products from storage to dispensing facilities.

 • POLs • POL sludge 

Underground Storage Tank Farm 

Underground storage tank farm sites result from the release of substances from multiple, typically large, underground storage tanks and associated piping which make up a tank farm complex.

 • POLs • So • POL sludges • Me

Firing Range Firing ranges consist of large areas of land used for practice firing of 

large artillery or mortars, or as a practice bombing range for aircraft. 

These areas are typically contaminated with unexploded ordnance, which may be found on and below the ground surface.

 • Metals • UX • Ord. compounds • Explosives 

• Radionuclides 

Soil Contaminated This unit consists of soil that has been removed during a tank removal • POLsAfter Tank Removal operation and staged prior to treatment. • POL sludge 

Appendix C: Department of Defense Sites Page C-6 
Exhibit C-2: Definitions of DOD Site Types (Continued) 

Site Type Site Description Primary Conta

Storm Drain Storm drains typically consist of a natural or man-made drain used as a • POLs • Pest

runoff control structure for rainfall. The unit also may be used from runoff • Metals • Indusfrom other sources such as process operations. Man-made units may be • POL sludge • Solveconcrete lined.

Oil/Water Separator Oil/water separators are typically small units that skim oil from storm-water 

runoff. The oil/water separator consists of the unit, and any associated piping.

 • POLs • PCB • Solvents • Industrial wastewater 

Maintenance Yard Maintenance yards consist of paved or unpaved areas where vehicles and 

other maintenance equipment is stored and often serviced. Typically, maintenance supplies are stored at these units.

 • POLs • Solv • Metals 

Low-level Low-level radioactive waste areas consist of areas used to store or dispose • Low-level radioactive wRadioactive Waste of low-level radioactive materials of various types (for example, radium Area paint, and radioactive instruments and propellants).

Washrack Washrack sites typically consist of a building designed for washing 

vehicles such as tanks, aircraft, and other military vehicles. This unit also 

may consist of a paved area where washing of vehicles occurs.

 • POLs 

Drainage Ditch Drainage units typically consist of a natural or a man-made ditch used as a 

runoff control structure for rainfall. The unit also may be used for runoff from other sources such as process operations. Man-made units may be concrete lined.

 • POLs • Meta • Solvents • PCBs • Explosive chemicals 

Small Arms Range Small arms ranges are typically located outdoors and used for target 

practice of small arms, usually 50 caliber or less. The unit may include a 

• Metals

 • Ordnance compounds 

soil or sandbag berm, or hill located behind the targets to prevent bullets 

from traveling outside the range area.

Incinerator Incinerators typically consist of a furnace and stack unit used for a variety 

of disposal activities including the incineration of medical waste, or an installation's dunnage. These units vary in size and may either be freestanding or part of other operations such as hospitals.

 • Ash • Metals • Ordnance compounds 

Appendix C: Department of Defense Sites Page C-7 
Exhibit C-2: Definitions of DOD Site Types (Continued) 

Site Type Site Description Primary Conta

Contaminated This unit consists of soil that has been staged after an excavation activity. • POLs • SolveSoil Piles • Sludge • PCBs

 • Metals • Ord. 

Mixed Waste Mixed waste areas consist of areas used to store or dispose of hazardous • SolventsArea wastes that have been mixed with or contaminated by radioisotopes. • Mixed waste Pistol Range Pistol ranges may be located indoors or outdoors and are used for target • Metals 

practice. Outdoor units include a soil or sandbag berm located behind the targets to prevent bullets from traveling outside the range area.

Chemical Disposal 

Chemical disposal units are areas that have been used for the disposal of 

chemicals, typically of an unknown type. The unit may be a burial area where bottles or packages of chemicals were placed or an area where liquids were disposed of on the soil.

 • POLs • Metals • Solvents • Explosive chemicals 

Pesticide Shop Pesticide shops typically are used to store and prepare large volumes of 

pesticides and solvents for maintenance. The units may be located in a freestanding building or attached to another building. Areas near the unit may have been used for the disposal of off-specification pesticides.

 • Pesticides • Metals • POLs 

Industrial Industrial discharge units consist of a pipe system used to discharge industrial • MetalsDischarge effluent to the environment. The unit may discharge to a natural or man-made • Industrial wastewater 

water body, dry creek bed or some other natural feature.

Surface Runoff Surface runoff is an area with runoff from rain which may occur anywhere • POLs • Solve

within a facility, particularly adjacent to industrial areas and airfield aprons. • Metals • Explo

Leach Field Leach fields typically consist of a subsurface area generally associated with 

septic tanks. The unit serves the purpose of biologically treating sanitary sewage, however, in cases where these units were used at industrial facilities, 

there also is contamination from non-biodegradable industrial contaminants.

 • Metals • Solvents 

Appendix C: Department of Defense Sites Page C-8 
Exhibit C-2: Definitions of DOD Site Types (Continued) 

Site Type Site Description Primary Conta

Plating Shop Plating shops typically consist of a building or room within a building used 

for coating metal parts. The unit contains several tanks of solvents which are used in the plating process.

 • Metals • Solvents

 • Acids

 • Industrial wastewater 

Sewage Effluent Settling Pond 

Sewage effluent settling ponds consist of a lagoon used for the settling of solids and/or biological treatment of sewage. The units also may be used as infiltration galleries.

 • Metals • Ordnance compounds

 • Solvents 

Dip Tank Dip tanks are typically metal or concrete units located in coating shops that 

range in size from 50 to more than 500 gallons. The tanks are used to clean parts prior to treatment, or to coat parts with various materials including metals and plastics.

 • POLs • Chlorinated solvents

 • Metals

 • Acids 

Notes: POLs = Petroleum, oil, lubricants and POL sludge; PCB = Polychlorinated Biphenyls; Ord. = Ordnance Source: DOD, Office of the Deputy Under Secretary of Defense (Environmental Security), Defense Environmental Restoratio

Report to Congress, for Fiscal Year 2001, Appendix G. 

Appendix C: Department of Defense Sites Page C-9 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit C-3: DOD Site Types Needing Cleanup 

Site Type Army Navy Air Force DLA FUDS Total 

Spill Site Area 145 151 789 9 12 1,107 

Landfill 300 231 373 8 62 974 

Underground Storage Tanks 75 237 311 14 203 840 

Other 25 38 1 4 666 734 

Unexploded Munitions and Ordnance Area 48 24 17 0 499 588 

Surface Disposal Area 110 246 179 8 20 563 

Storage Area 171 190 77 21 18 477 

Contaminated Groundwater 143 65 44 16 150 418 

Disposal Pit and Dry Well 97 65 216 24 12 414 

Fire/Crash Training Area 29 59 153 1 7 249 

Surface Impoundment/Lagoon 97 37 25 2 13 174 

Aboveground Storage Tank 26 52 40 1 48 167 

Explosive Ordnance Disposal Area 51 32 12 0 68 163 

Burn Area 93 31 10 0 20 159 

Contaminated Buildings 105 32 5 2 12 156 

Building Demolition/Debris Removal 7 11 22 5 111 151 

Contaminated Sediments 38 63 16 0 33 150 

POL (Petroleum/Oil/Lubricants) Lines 12 38 77 2 8 137 

Firing Range 17 3 8 0 76 104 

Contaminated Fill 18 12 5 3 61 99 

Industrial Discharge 66 11 11 0 3 91 

Storm Drain 2 13 70 1 2 88 

Waste Lines 22 38 25 0 2 87 

Chemical Disposal 48 6 20 0 6 80 

Soil Contamination After Tank Removal 10 7 6 5 52 80 

Maintenance Yard 26 31 18 1 2 78 

Underground Tank Farm 14 43 14 0 7 78 

Waste Treatment Plant 29 18 26 0 3 76 

Oil/Water Separator 10 13 30 0 0 53 

Sewage Treatment Plant 11 5 26 0 2 44 

Drainage Ditch 13 11 18 1 1 44 

Small Arms Range 10 4 12 0 17 43 

Mixed Waste Area 5 20 8 0 8 41 

Washrack 23 4 13 0 1 41 

Radioactive Waste Area 5 2 26 0 6 39 

Contaminated Soil Piles 14 7 4 0 12 37 

Appendix C: Department of Defense Sites Page C-10 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit C-3: DOD Site Types Needing Cleanup (Continued) 

Site Type Army Navy Air Force DLA FUDS Total 

Leach Field 19 8 7 1 0 35 

Incinerator 18 6 2 0 3 29 

Pesticide Shop 10 9 5 0 1 25 

Surface Runoff 5 1 8 1 2 17 

Plating Shop 2 13 2 0 0 17 

Dip Tank 3 4 4 0 0 11 

Pistol Range 6 1 1 1 2 1 

Sewage Effluent Settling Ponds 1 1 1 0 2 5 

Total 1,979 1,893 2,737 131 861 8,974 

Note 1: The column for Total DOD includes one Defense Threat Reduction Agency (DTRA) site at Johnston Atoll (JQ). 

Note 2: Needing cleanup is interpreted as sites that have not achieved Response Complete (RC) status. 

Source: DOD, Office of the Deputy Under Secretary of Defense (Installations & Environment), Restoration Management 

Information System (RMIS), data as of September 2001 

Appendix C: Department of Defense Sites Page C-11 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit C-4: Frequency of Matrices by DOD Site Type 

Site Type 

No. of Sites 

with Data 

Groundwater Soil Surface 

Water Sediment 

Spill Site Area 874 507 681 105 114 

Landfill 850 629 630 229 217 

Surface Disposal Area 512 271 420 82 112 

Underground Storage Tanks 459 366 280 23 32 

Storage Area 417 176 379 41 57 

Disposal Pit and Dry Well 352 223 266 54 74 

Contaminated Groundwater 321 288 172 53 45 

Fire/Crash Training Area 208 176 176 40 40 

Surface Impoundment/Lagoon 156 105 110 44 62 

Burn Area 146 89 133 30 35 

Contaminated Buildings 145 68 131 11 23 

Contaminated Sediments 132 49 70 39 73 

Other 121 56 102 16 20 

Aboveground Storage Tank 106 51 94 7 8 

POL (Petroleum/Oil/Lubricants) Lines 103 75 69 3 9 

Explosive Ordnance Disposal Area 91 49 81 19 14 

Contaminated Fill 85 44 80 13 16 

Industrial Discharge 79 60 60 19 30 

Waste Lines 76 51 56 6 12 

Waste Treatment Plant 68 41 52 4 13 

Maintenance Yard 68 33 60 4 10 

Chemical Disposal 67 38 57 6 11 

Underground Tank Farm 66 61 37 7 9 

Storm Drain 63 44 28 14 17 

Soil Contamination After Tank Removal 57 43 48 5 3 

Unexploded Munitions and Ordnance Area 54 30 44 12 10 

Oil/Water Separator 45 25 39 3 7 

Drainage Ditch 38 16 23 10 10 

Washrack 36 26 30 6 5 

Contaminated Soil Piles 35 16 34 3 2 

Sewage Treatment Plant 34 19 31 6 6 

Mixed Waste Area 32 15 26 5 7 

Leach Field 28 20 20 2 2 

Incinerator 27 9 26 2 3 

Radioactive Waste Area 23 12 22 3 2 

Pesticide Shop 23 12 23 1 4 

Firing Range 23 5 22 2 0 

Appendix C: Department of Defense Sites Page C-12 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit C-4: Frequency of Matrices by DOD Site Type (Continued) 

No. of Sites Ground- Surface 

Site Type with Data water Soil Water Sediment 

Small Arms Range 22 7 20 1 2 

Building Demolition/Debris Removal 22 6 20 1 2 

Plating Shop 16 16 15 2 2 

Surface Runoff 14 8 9 4 4 

Dip Tank 11 3 11 0 0 

Pistol Range 9 3 8 0 2 

Sewage Effluent Settling Ponds 5 5 4 1 1 

Total 6,119 3,846 4,699 938 1,127 

Notes: The numbers in this table represent only those sites for which media data is available. The total count for a site type may 

exceed the number of sites with data for the site type because a site may have more than one contaminated matrix. The 

total includes 1 DTRA site. 

Source: OD, Office of the Deputy Under Secretary of Defense (Installations & Environment), Restoration Management Information 

System (RMIS), Data as of September 2001. 

Appendix C: Department of Defense Sites Page C-13 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit C-5: Frequency of Major Contaminant Groups 

by Matrix and DOD Component 

Component Contaminant Ground- Sediment Soil Surface Total % Sites 

Group water Water All Media w/Data 

Army VOCs 696 80 389 114 

SVOCs 410 217 792 110 

900 

1065 

49% 

57% 

Metals 724 315 1135 225 1447 78% 

Other 345 118 340 86 672 36% 

Explosives and 

Propellants 

124 17 142 28 

No Group Determined 0 0 0 0 

VOCs & SVOCs 74 11 63 10 

234 

0 

140 

13% 

0% 

8% 

VOCs & Metals 197 17 61 32 279 15% 

SVOCs & Metals 90 123 362 49 519 28% 

VOCs, SVOCs, & 

Metals 

180 43 188 44 331 18% 

No. Sites with Data 1114 389 1458 279 1854 

Navy VOCs 877 147 734 108 

SVOCs 610 249 862 115 

1240 

1165 

68% 

64% 

Metals 785 295 1043 192 1341 74% 

Other 587 218 638 123 930 51% 

Explosives and 

Propellants 

44 15 49 13 

No Group Determined 0 1 7 0 

VOCs & SVOCs 95 9 81 8 

90 

8 

169 

1% 

0% 

9% 

VOCs & Metals 172 16 84 34 269 15% 

SVOCs & Metals 70 116 268 35 418 23% 

VOCs, SVOCs & 

Metals 

419 118 397 58 649 36% 

No. Sites with Data 1096 331 1417 229 1812 

Air Force VOCs 1059 117 784 204 1458 75% 

SVOCs 447 192 680 108 947 49% 

Metals 699 222 859 213 1231 63% 

Other 441 91 329 87 690 35% 

Explosives and 

Propellants 

15 2 11 3 

No Group Determined 2 0 0 0 

VOCs & SVOCs 132 21 113 17 

27 

2 

249 

1% 

0% 

13% 

VOCs & Metals 227 12 124 70 374 19% 

SVOCs & Metals 44 105 178 43 308 16% 

VOCs, SVOCs, & 

Metals 

242 58 268 42 470 24% 

No. Sites with Data 1321 305 1385 321 1945 

Appendix C: Department of Defense Sites Page C-14 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit C-5. Frequency of Major Contaminant Groups 

by Matrix and DOD Component (Continued) 

Component Contaminant 

Group 

Groundwater Sediment Soil Surface 

Water 

Total 

All Media 

% Sites 

w/Data 

DLA VOCs 21 2 16 1 33 41% 

SVOCs 5 9 33 1 41 51% 

Metals 8 2 52 4 59 74% 

Other 6 1 8 1 15 19% 

Explosives and 

Propellants 

0 0 1 0 1 1% 

No Group Determined 0 0 0 0 0 0% 

VOCs & SVOCs 4 2 1 0 7 9% 

VOCs & Metals 5 0 3 1 8 10% 

SVOCs & Metals 0 1 20 1 22 28% 

VOCs, SVOCs, & 

Metals 

1 0 6 0 7 9% 

No. Sites with Data 23 10 65 4 80 

FUDS VOCs 211 29 181 33 290 68% 

SVOCs 119 51 208 34 263 62% 

Metals 207 79 295 93 337 79% 

Other 87 23 99 26 155 36% 

Explosives and 

Propellants 

25 4 31 7 45 11% 

No Group Determined 0 0 0 0 0 0% 

VOCs & SVOCs 33 2 31 2 57 13% 

VOCs & Metals 68 4 41 11 110 26% 

SVOCs & Metals 18 36 76 22 117 27% 

VOCs, SVOCs & 

Metals 

63 21 81 13 123 29% 

No. Sites with Data 292 91 373 104 427 

Total DOD VOCs 2864 375 2104 460 3921 64% 

SVOCs 1591 718 2575 368 3481 57% 

Metals 2423 913 3384 727 4415 72% 

Other 1466 451 1414 323 2462 40% 

Explosives and 

Propellants 

208 38 234 51 397 6% 

No Group Determined 2 1 7 0 10 0% 

VOCs & SVOCs 338 45 289 37 622 10% 

VOCs * Metals 669 49 313 148 1040 17% 

VOCs, SVOCs & 

Metals 

905 240 940 157 1580 26% 

No. Sites with Data 3846 1126 4698 937 6118 

Notes: 

• FUDS = Formerly Used Defense Sites; DLA - Defense Logistics Agency; VOCs - Volatile Organic Compounds; 

SVOCs = Semivolatile Organic Compounds. 

• The total amount for a matrix or contaminant groups may exceed the number of sites with data, because a site 

may have more than one contaminant group or contaminated matrix.

 • Source: DOD, Office of the Deputy Under Secretary of Defense (Installations & Environment), Restoration 

Management Information System (RMIS), data as of September 2001. 

Appendix C: Department of Defense Sites Page C-15 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit C-6: Frequency of Major Contaminant 

Groups by DOD Site Type 

Site Type Total No. 

No. of 

Sites VOCs Metals SVOCs Other 

Explosives 

& No Group 

of Sites w/Data Propellants Determined 

Spill Site Area 1,107 874 619 478 462 274 35 0 

Landfill 974 850 535 748 516 444 45 1 

Underground Storage 

Tanks 

840 459 408 219 213 130 4 1 

Other 734 121 75 90 74 45 12 0 

Unexploded Munitions 

and Ordnance Area 

588 54 26 47 34 28 18 0 

Surface Disposal Area 563 512 289 402 282 225 25 0 

Storage Area 477 417 215 300 266 161 10 2 

Contaminated 418 321 271 203 143 127 15 0 

Groundwater 

Disposal Pit and Dry Well 414 352 231 273 208 154 14 0 

Fire/Crash Training Area 249 208 178 168 153 118 7 1 

Surface 174 156 83 142 95 90 34 0 

Impoundment/Lagoon 

Aboveground Storage 167 106 77 60 53 27 3 0 

Tank 

Explosive Ordnance 

Disposal Area 

163 91 26 79 53 35 33 0 

Burn Area 159 146 82 120 99 68 41 0 

Contaminated Buildings 156 145 53 111 101 43 25 0 

Building 151 22 4 20 16 11 2 0 

Demolition/Debris 

Removal 

Contaminated Sediments 150 132 52 110 87 57 12 0 

POL 137 103 89 56 63 30 2 0 

(Petroleum/Oil/Lubricants) 

Lines 

Firing Range 104 23 5 21 8 7 2 0 

Contaminated Fill 99 85 46 67 54 25 2 0 

Industrial Discharge 91 79 44 55 56 31 18 2 

Storm Drain 88 63 47 46 28 32 0 1 

Waste Lines 87 76 42 65 43 31 10 1 

Chemical Disposal 80 67 32 54 18 16 5 0 

Soil Contamination After 80 57 48 33 31 22 2 0 

Tank Removal 

Maintenance Yard 78 68 50 44 34 31 0 0 

Underground Tank Farm 78 66 64 40 43 18 0 0 

Waste Treatment Plant 76 68 40 56 48 31 6 0 

Oil/Water Separator 53 45 35 35 26 22 0 0 

Drainage Ditch 44 38 19 26 22 9 3 0 

Sewage Treatment Plant 44 34 20 24 18 8 0 0 

Small Arms Range 43 22 4 22 4 8 0 0 

Mixed Waste Area 41 32 17 27 21 16 0 0 

Washrack 41 36 23 30 19 13 1 0 

Appendix C: Department of Defense Sites Page C-16 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit C-6: Frequency of Major Contaminant Groups 

by DOD Site Type (Continued) 

Site Type Total No. 

of Sites 

No. of 

Sites 

w/Data 

VOCs Metals SVOCs Other 

Explosives 

& 

Propellants 

No Group 

Determined 

Radioactive Waste Area 39 23 4 8 7 20 1 0 

Contaminated Soil Piles 37 35 11 31 15 12 2 0 

Leach Field 35 28 12 22 12 8 1 1 

Incinerator 29 27 7 21 8 7 3 0 

Pesticide Shop 25 23 8 16 21 8 1 0 

Plating Shop 17 16 12 16 9 12 1 0 

Surface Runoff 17 14 8 9 9 3 1 0 

Dip Tank 11 11 5 10 4 3 0 0 

Pistol Range 11 9 1 9 2 2 0 0 

Sewage Effluent Settling 

Ponds 

5 5 4 2 3 1 1 0 

TOTAL 8,974 6,119 3,921 4,415 3,481 2,463 397 10 

Notes a Number of sites needing remediation; data were available for 6,119 of the sites needing remediation, including 

1 DTRA site. 

POL = petroleum, oil, lubricant 

The total count for a site type may exceed the number of sites with data for the site type, because a site may have 

more than one contaminant group. 

Source: DOD, Office of the Deputy Under Secretary of Defense (Installations & Environment), Restoration Management 

Information System (RMIS), data as of September 2001. 

Appendix C: Department of Defense Sites Page C-17 
Exhibit C-7. Frequency of Contaminant Subgroup by Matrix 

Percent of Sites With Data 

Contaminant Sub Group 

Groundwater GW % Sediment Sediment % Soil Soil % Surfa

Wat

Metals 2423 63.00 913 81.01 3384 72.02 72Halogenated VOCs 2151 55.93 211 18.72 1052 22.39 33BTEX 1465 38.09 151 13.40 1218 25.92 14Miscellaneous Inorganic Elements and Compounds (Misc. Organics) 

1418 36.87 449 39.84 1361 28.96 31

Non-halogenated VOCs 1307 33.98 263 23.34 1282 27.28 18Non-halogenated SVOCs 847 22.02 242 21.47 973 20.71 18Polynuclear Aromatic Hydrocarbons (PAHs) 638 16.59 445 39.49 1450 30.86 80 Pesticides 458 11.91 369 32.74 988 21.03 14Phenols 315 8.19 84 7.45 218 4.64 62 Halogenated SVOCs 288 7.49 58 5.15 214 4.55 27 Explosives and Propellants 208 5.41 38 3.37 234 4.98 51 Polychlorinated biphenyls (PCBs) 84 2.18 165 14.64 602 12.81 29 Radioactive Materials 46 1.20 3 0.27 42 0.89 6 Other 18 0.47 2 0.18 25 0.53 1 Other Organic (Coal Tar, Creosote) 10 0.26 4 0.35 6 0.13 4 No Group Determined 2 0.05 1 0.09 7 0.15 0 

Notes: VOC = Volatile Organic Compound; SVOC - Semivolatile Organic Compound; BTEX = Benzene, Toluene, Ethylbenzene, Xyl

Data were available for 6,119 sites 

Source: DOD, Office of the Under Secretary of Defense (Installations & Environment), Restoration Management Information System (

as of September 2001. 

Appendix C: Department of Defense Sites Page C-18 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Appendix D

Supporting Data for Analysis of

Manufactured Gas Plant Sites

Appendix D. Supporting Data for Manufactured Gas Plant Sites Page D-1 
Exhibit D-1. Estimated Disposition of Former Manufactured 

Gas Plants & Other Coal Tar Sites in the U.S. 

Site Type a Original 

Sites 

Sites 

With 

Releases 

Number of Sites 

Sites 

Previously 

NFRAPDb 

In State 

Cleanup 

Program 

Studied 

and Remediated 

Not Yet 

Investigated 

Estimated Current Land U

Industrial/ 

Commercial 

Residential Recre

tiona

Commercial MGPs 3,500 3,500 <700 >175 <350 2,275+ 2,450 350 350 District Gas Holders 

500-1,500 

500-1,500 25-75+ 0 <25-75 450-

1,350+ 

300-900+ 75-225 75-22

Rail Yard Pintsch Oil-Gas Plants 

100-150 100-150 <5-7 <5-7 <5-7 >85-129 85-127+ <5-7 <5-7 

Military Gas Plants 150-250 150-250 0 0 0 150-250- 120-200+ <7-12 <15-2Ice & Refrigeration 200-400 150-300 7-15 0 0 143-285 90+ <5 0+ Plants w/Gas Producer Institutional Gas Machines 

5,000-10,000 

2,500-

5,000 

125-250 0 0+ 2,375-

4,750 

>75 <10 <5 

Domestic/Residen- 10,000- 10,000- 0 0 <200-300 9,800- 0 9,000- <500tial Gas Machines 15,000 15,000 14,700+ 13,500 750 

Captive Gas 11,000- 11,000- <550-750 0 <550-750 9,900- >8,800- <550- <550Producers - 15,000 15,000 13,500 12,000 750 750 Pressure & Suction Bottled Gas Plants 100 50 0 0 <2 50 >80 <5 <5 

Kerosene Refiners 100-150 100-150 <5-7 0 <2-3 93-140+ >90-135 <5-7 0+ Compressed Fuel Briquette Plants 

100 50 0 0 0 50 >95 0 0 

Beehive Coke 2,000- 2,000- <100-200 0 <100-200 >1,800- 200-400 100- 100-2Works 4,000 4,000 3,600 200 

Appendix D. Supporting Data for Manufactured Gas Plant Sites Page D-2 
Exhibit D-1. Estimated Disposition of Former Manufactured 

Gas Plants & Other Coal Tar Sites in the U.S. (Continued) 

Appendix D. Supporting Data for Manufactured Gas Plant Sites Page D-3 Site Type a Number of Sites Original Sites Sites With Releases Sites Previously NFRAPDb in State Cleanup Program Studied and Rem- ediated Sites Not Yet Inves- tigated Estimated Current Land 

Industrial/ Commercial Resi- dential Rec

tio

Merchant & Utility Coke Works 250-300 250-300 25-30 25-30 75-90 125-150 225-285 0 Charcoal Plants 2,000- 3,000 2,000- 3,000 <100-150 0 <100-150 1,800- 2,700 900-1,350 100­ 150 100

Tar Distilleries 200-400 200-400 20-40 10-20 10-20 160-320 160-320 10-20 10WWI Federal Wood Tar Distillation Plants 11 11 0 0 <5 6 95 <5 <WWI Federal Toluene Plants 10 10 0 0 <5 5 95 <5 <Wood Preservation Plants 800- 1,000 800-1,000 240-300 <80-100 <40-50 440-550 640-800 40-50 40

U.S. BOM Coal Gasification Plants 37-55 37-55 2-3 2-3 0 33-49 17-25 0 U.S. DOE Coal Gasification Plants Total 63-75 36,121- 55,001 63-75 33,471- 49,801 3-4 1,907- 2,531 3-4 300-339 0 1,469- 2,007 57-67 29,975- 44,926 28-34 14,545- 19,556 0 10,272- 15,300 

1,7

2,

Notes: Volume of releases includes present-day bodies of contaminated soil in the subsurface, not otherwise visible at ground surface a See Exhibit 10-1 for definitions b No Further Remedial Action Planned Source: Allen W. Hatheway, “Estimated Number of Manufactured Gas and Other Coal-Tar Sites in the United States,” Environmental E

Geoscience, Vol. III, No. 1, Spring 1997, pp. 141-142 and personal communication with the author, February-March 2003. The 

on Dr. Hatheway’s database on MGPs which includes information on approximately 7,000 sites, assembled from Brown’s DireAmerican Gas Plants, historic gas industry literature, Sandborn Fire Insurance maps, state agencies, and direct on-site observ
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit D-2 

Estimated Typical Remediation Cost by Site Type 

Site Type 

Range of Site 

Size 

Number of Sites 

Not Investigated 

Typical 

Contaminants 

&Contaminated 

Media a Release 

Volume Per 

Site (000) b 

Ave. 

Remediation 

Cost Per Site 

($ Millions) 

Commercial 

MGPs 

small - 1-3 acres 

medium - 3-10 

2,275+ Soil: Tars stored in 

subsurface vessels 

2,000-50,000 

m3 

small - 3.0 - 5.0 

medium - 4.0 ­

acres 

large - 10-100 

acres 

or discharged to 

surface/subsurf. 

Spent Box Waste. 

PAH- cont. solid 

10.0 

large - 10.0 -

100.0 

waste. 

District Gas 1-4 acres 450-1350+ Soil: Leaks in 100-500 m3 0.25 - 1.5 

Holders below-ground 

holders. Tars in 

abandoned 

subsurface. 

Holder tanks ­

basins pits. 

Rail Yard Pintsch 

Oil-Gas Plants 

0.5-1.5 acre 95-142 Soil: Dumped 

sludge & lampblack 

500-10,000 m3 0.5 - 5.0 

Military Gas 

Plants 

0.5-1.5 acre 150-250 Soil: Tars stored in 

subsurface vessels 

500-1,000 m3 1.0 - 4.0 

and discharged to 

surface/subsurf. . 

Spent Box Waste. 

PAH - cont. solid 

waste. 

Ice & 1-2 acres 147-294 Soil: Tars stored in 500-1,000 m3 0.5 - 1.5 

Refrigeration subsurface vessels 

Plants with Gas and discharged to 

Producers surface/subsurf. 

Institutional Gas 

Machines 

500-1500 ft2 2,450-4,900 Soil <100 m3 0.2 - 0.75 

Domestic 400-1000 ft2 9,800-14,700 Soil <50 m3 0.05 

Residential Gas 

Machines 

Appendix D. Supporting Data for Manufactured Gas Plant Sites Page D-4 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit D-2 

Estimated Typical Remediation Cost by Site Type (Continued) 

Site Type 

Range of Site 

Size 

Number of Sites 

Not Investigated 

Typical 

Contaminants 

&Contaminated 

Media a 

Release 

Volume 

Per Site (000) b 

Ave. 

Remediation 

Cost Per Site 

($ Millions) 

Captive Gas 

Producers 

20/30 to 50x600 

ft 

10,450-14,250 Soil: Tars stored in 

subsurface vessels 

100-10,000 m3 1.0 - 10.0 

(Pressure & 

Suction) 

and discharged to 

surface/subsurf. 

Spent Box Waste. 

PAH cont. solid 

waste. 

Bottled 1-3 acres 50 Soil: Tars stored in 100-500 m3 0.2 - 0.5 

Manufactured subsurface vessels 

Gas Plants & discharged to 

surface/subsurf. 

Spent Box Waste. 

Kerosene 1-2 acres 95-142 Soil: Tars stored in 100-1,000 m3 1.0 -5.0 

Refiners subsurface vessels 

& discharge to 

surface/subsurf.. 

Filtration sludges 

from recovery 

Compressed 

Fuel Briquette 

Plants 

1-2 acres 50 Soil: Tars stored in 

subsurface vessels 

& discharged to 

surface/subsurf.. 

Coal, coke, 

100-1,000 m3 0.5 - 1.0 

lampblack, fines 

secondarily cont. 

w/PAH. 

Beehive Coke 

Works 

40-100 acres 1,900-3,800 Tar &/or light oil in 

soil. PAH-cont. 

solid waste. 

1,000-10,000 

m3 

0.5 - 2.0 

Merchant & 

Utility Coke 

Works 

40-100 acres 100-120 Soil: Tars stored in 

subsurface vessels 

& discharged to 

surface/subsurface 

5,000-100,000 

m3 

10.0 - 100.0 

. 

Spent Box Waste. 

PAH-contaminated 

solid waste. 

Appendix D. Supporting Data for Manufactured Gas Plant Sites Page D-5 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit D-2 

Estimated Typical Remediation Cost by Site Type (Continued) 

Typical Ave. 

Number of Sites Contaminants Remediation 

Site Type 

Range of Site 

Size 

Not Investigated &Contaminated 

Media a Release 

Volume 

Per Site (000) b 

Cost Per Site 

($ Millions) 

Charcoal Plants 10-100 acres 1,900-2,850 Tars and/or light oil 

in soil. 

1,000-5,000 m3 0.5 - 2.0 

PAH-contaminated 

solid waste. 

Tar Distilleries 10-100 acres 150-300 Soil: Tars stored in 

subsurface vessels 

1,000-100,000 

m3 

10.0 - 100.0 

& discharged to 

surface/subsurf. 

Filtration sludges 

from recovery 

process. 

WWI Federal 

Wood Tar 

40-200 acres 11 Soil: Tars stored in 

subsurface vessels 

1,000-10,000 

m3 

1.01 - 2.0 

Distillation 

Plantsc,,d 

& discharged to 

surface/subsurf. 

Filtration sludges 

from recovery 

process. 

WWI Federal 

Toluene Plantsc,d 

80-200 acres 10 Soil: Tars stored in 

subsurface vessels 

1,000-10,000 

m3 

1.0 - 5.0 

& discharged to 

surface/subsurf. 

Filtration sludges 

from recovery 

process. 

PAH-contaminated 

solid waste. 

Wood 

Preservation 

10-200 acres 480-600 Soil: Tars stored in 

subsurface 

1,000-10,000 

m3 

5.0 - 20.0 

Plants vessels, 

discharged to 

surface/subsurf, or 

in abandoned 

lagoons; 

PAH-contaminated 

solid waste. 

Appendix D. Supporting Data for Manufactured Gas Plant Sites Page D-6 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Exhibit D-2 

Estimated Typical Remediation Cost by Site Type (Continued) 

Site Type 

Range of Site 

Size 

Number of Sites 

Not Investigated 

Typical 

Contaminants 

&Contaminated 

Media a Release 

Volume 

Per Site (000) b 

Ave. 

Remediation 

Cost Per Site 

($ Millions) 

U.S. Bureau of 

Mines ­

Coal Gasification 

Plantsc 

10-40 acres 33-49 Soil: Tars stored in 

subsurface 

vessels. Tars 

discharged to 

surface/subsurface 

. 

PAH-contaminated 

solid waste. 

500-1,000 m3 1.0 - 2.0 

U.S. Department 

of Energy - Coal 

Gasification 

Plantsc 

10-40 acres 57-67 Soil: Tars stored in 

subsurface 

vessels. Tars 

discharged to 

surface/subsurface 

. 

PAH-contaminated 

solid waste. 

500-1,000 m3 1.0 - 2.0 

Assumptions: 

• Cleanup cost estimates are inferred from sites that have been fully characterized, based on knowledge of actual site operation 

history and reasonable exploration of depth and breadth of subsurface conditions reflecting the presence of MGP residuals. 

• Estimates do not consider the presence of post-operational contaminants not typically associated with MGP operations. 

• Estimates do not reflect the costs of litigation judgements involving human health and gas works hazardous or toxic residuals at 

sites. 

• It is assumed that 35% of the commercial plants are small, 35% are medium, and 30% are large, and that the average highestimate costs for these size groups are $4 million, $7 million, and $13 million, respectively. 

Footnotes: 

a This table includes nominal groundwater contamination primarily associated with LNAPLs. It does not include solids lodged in 

the matrix of an aquifer (DNAPLs). Sites with solids lodged in the aquifer are difficult to predict, highly site specific, and 

potentially very costly to remediate. 

b Volume of releases consider only highly-contaminated soil requiring direct or indirect treatment on site or placement in a RCRA 

Class C facility. Other more lightly contaminated soils are expected to be present and possibly subject to placement in a RCRA 

Class D facility. 

c Estimates are based on analogous sites. 

d These plants were constructed as a WWI emergency measure. Some were barely operational at war’s end. Others were 

operated after the war for commercial purposes and will bear higher remediation costs. 

Appendix D. Supporting Data for Manufactured Gas Plant Sites Page D-7 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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Appendix D. Supporting Data for Manufactured Gas Plant Sites Page D-8
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Appendix E

Federal and State Agency Programs

Appendix E. Federal and State Agency Programs Page E-1 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

State and Federal Agency Contacts 

EPA Regional Offices 

EPA Region 1 (ME, NH, VT, MA, RI, CT) 

http://www.epa.gov/region01/ 

EPA Region 2 (NY, NJ, PR, VI). 

http://www.epa.gov/Region2/ 

Region 3 (PA, DE, DC, MD, VA, WV). 

http://www.epa.gov/region03/ 

EPA Region 4 (KY, TN, NC, SC, MS, AL, 

GA, FL). http://www.epa.gov/region4/

EPA Region 5 (MN, WI, IL, MI, IN, OH). 

http://www.epa.gov/Region5/ 

EPA Region 6 (NM, TX, OK, AR, LA). 

http://www.epa.gov/earth1r6/ 

EPA Region 7 (NE, KS, IA, MO). 

http://www.epa.gov/region07/ 

EPA Region 8 (MT, ND, WY, SD, UT, 

CO). http://www.epa.gov/region08/

EPA Region 9 (CA, NV, AZ, HI). 

http://www.epa.gov/region09/ 

EPA Region 10 (WA, OR, ID, AK). 

http://www.epa.gov/r10earth/ 

State Agencies 

Links to U.S. states and territories 

http://www.epa.gov/epaoswer/osw/stateweb. 

htm 

RCRA State Authorizaton Status 

http://www.epa.gov/epaoswer/hazwaste/stat 

e/stats/stats_bystate.htm 

UST State and Territory Program Directory 

http://www.epa.gov/swerust1/states/statcon1 

.htm 

Appendix E. Federal and State Agency Programs Page E-2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Civilian Federal Agencies 

Department of Agriculture 

http://www.nrcs.usda.gov/ 

Agricultural Research Service 

http://www.ars.usda.gov/ 

U.S. Forest Services

http://www.fs.fed.us/ 

National Resources Conservation Service 

http://www.nrcs.usda.gov 

United States Geological Survey 

http://toxics.usgs.gov/topics/remediation.html 

Department of Interior 

National Park Service 

http://www.nps.gov/ 

Fish and Wildlife Service 

http://www.fws.gov/ 

Bureau of Land Management 

http://www.blm.gov/nhp/index.htm 

Office of Surface Mining 

http://www.osmre.gov/ 

Bureau of Reclamation 

http://www.usbr.gov/main/index.html 

Bureau of Indian Affairs 

http://www.doi.gov/bureau-indian-affairs.html 

Office of Environmental Policy and 

Compliance 

Solid and Hazardous Materials 

Management Team 

http://www.doi.gov/oepc/shazmat.html 

Natural Resource Damage Assessment and 

Restoration Program 

http://restoration.doi.gov/ 

United States postal Service 

http://www.usps.com/ 

National Aeronautics and Space 

Administration (NASA) 

http://www.hq.nasa.gov/office/codej/codeje/je 

_site/about_us/about_us.html 

Tennessee Valley Authority 

http://www.tva.gov/environment/envservices/i 

ndex.htm 

Department of Transportation 

http://www.dot.gov/ 

Department of the Treasury 

http://www.treas.gov/ 

Department of Veterans Affairs 

http://www.va.gov/ 

Appendix E. Federal and State Agency Programs Page E-3 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

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Appendix E. Federal and State Agency Programs Page E-4
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

Appendix F 

Acronyms 

ACSIM Assistant Chief of Staff for Installation Management (DOD) 

A&E Architectural and Engineering 

AFCEE Air Force Center for Environmental Excellence 

AFSBED Air Force Small Business Environmental Database 

ANPR Advanced Notice of Public Rulemaking 

ARARs Applicable or relevant and appropriate requirements 

ASTM American Society of Testing Materials 

ASTSWMO Association of State and Territorial Solid Waste Management Officials 

ATSDR Agency for Toxic Substances and Disease Registry 

BCP BRAC Cleanup Plan 

BCT BRAC Cleanup Team 

BEMR Baseline Environmental Management Report 

BLM Bureau of Land Management 

BRAC Base Realignment and Closures 

BTEX Benzene, Toluene, Ethylbenzene, and Xylene 

CA Cooperative Agreement 

CA RCRA Corrective Action Program under the Resource Conservation and Recovery Act 

CAMU Corrective Action Management Unit 

CBO Congressional Budget Office 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CERCLIS CERCLA Information System 

CERFA Community Environmental Response Facilitation Act 

CFAs Civilian Federal Agencies 

CFR Code of Federal Regulations 

CHF Central Hazardous Materials Fund (DOI) 

CHP Central Hazardous Materials Fund 

CIC Community Involvement Coordinator 

CID Central Internet Database (DOE) 

CLU-IN Clean-Up Information System 

CMI Corrective Measures Implementation (RCRA) 

CMS Corrective Measures Study (RCRA) 

CSM Conceptual Site Model 

CRADA Cooperative Research and Development Agreement (DOE) 

CWA Clean Water Act 

D&D Deactivation and Decommissioning 

DERA Defense Environmental Restoration Account 

DERP Defense Environmental Restoration Program 

DLA Defense Logistics Agency 

DNAPL Dense Non-Aqueous Phase Liquid 

DOD Department of Defense 

DOE Department of Energy 

DOI Department of Interior 

DOT Department of Transportation 

DQO Data Quality Objectives 

DRE Destruction and Removal Efficiency 

Appendix F: Acronyms Page F-1 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

DSMOA Defense and State Memorandum of Agreement

DTRA Defense Threat Reduction Agency

EBS Environmental Baseline Survey

ECR Environmental Compliance and Restoration Program (NASA)

EM Environmental Management

EMSP Environmental Management Science Program

EOU Excess, Obsolete or Unserviceable

EPA Environmental Protection Agency

ERRS Emergency and Rapid Response Services

ESTCP Environmental Security Technology Certification Program

FAA Federal Aviation Administration

FR Federal Register

FRTR Federal Remediation Technologies Roundtable

FUDS Formerly Used Defense Sites

FUSRAP Formerly Utilized Sites Remedial Action Program

FY Fiscal Year

GAC Granulated Activated Carbon

GAO General Accounting Office

GPRA Government Performance and Results Act

GWRTAC Groundwater Remediation Technologies Analysis Center

HMMA Hazardous Materials Management Appropriations

HMMP Hazardous Materials Management Program (USDA)

HMPC Hazardous Materials Policy Council (USDA)

HRS Hazard Ranking System (Superfund)

HSWA Hazardous and Solid Waste Amendments of RCRA

HWIR-Media Hazardous Waste Identification Rule - Media

IAG Interagency Agreement

IRP Installation Restoration Program (DOD)

LDRs Land Disposal Restrictions

LM Office of Legacy Management (DOE)

LNAPLs Light Non-Aqueous Phase Liquids

LTTD Low Temperature Thermal Desorption

LUSTs Leaking Underground Storage Tanks

MAP Management Action Plan

MCL Maximum Contaminant Level

MGP Manufactured Gas Plant

MMRP Military Munitions Response Program

MNA Monitored Natural Attentuation

MTBE Methyl Tertiary-butyl Ether

MTRs Minimum Technology Requirements

MWTP Mine Waste Technology Program

NABIR Natural and Accelerated Bioremediation Research Program

NACEPT National Advisory Council for Environmental Policy and Technology

NAPLs Non-Aqueous Phase Liquids

NASA National Aeronautics and Space Administration

NAVFAC Naval Facilities Engineering Command

NCP National Oil and Hazardous Substances Contingency Plan

Appendix F: Acronyms Page F-2 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

NELP Naval Environmental Leadership Program 

NEPA National Environmental Policy Act 

NETAC National Environmental Technologies Applications Center 

NETL National Energy Technologies Laboratory 

NETTS National Environmental Technology Test Sites Program 

NFESC Naval Facilities Engineering Service Center 

NFRAP No Further Action Planned 

NMLRC National Mine Land Reclamation Center 

NPDES National Pollutant Discharge Elimination System 

NPL National Priorities List 

NTIS National Technical Information Services 

O&M Operations and Maintenance 

OB Open Burn 

OD Open Detonation 

ODUSD (I&E) Office of Deputy Undersecretary of Defense (Installations & Environment) 

OERR Office of Emergency and Remedial Response 

OPA Oil Pollution Act 

ORD Office of Research and Development 

OSM Office of Surface Mining 

OSMRE Office of Surface Mining Reclamation and Enforcement 

OSW Office of Solid Waste 

OSWER Office of Solid Waste and Emergency Response 

OU Operable Unit 

OUST Office of Underground Storage Tanks 

PA Preliminary Assessment 

PAHs Polynuclear Aromatic Hydrocarbons 

PCBs Polychlorinated Biphenyls 

PCE Perchloroethylene 

PFP Pay for Performance 

POL Petroleum, Oil, and Lubricants 

PRP Potentially Responsible Party 

P&T Pump and Treat 

RA Remedial Action 

RAB Restoration Advisory Board 

RACS Remedial Action Contracting Strategy 

RAP Remedial Action Plan 

RBCA Risk-Based Corrective Action 

RC Response Complete (DOD) 

RCAID RCRA Action Implementation Database 

RCRA Resource Conservation and Recovery Act of 1976 

RCRA CA RCRA Corrective Action Program 

RD Remedial Design 

RD&D Research, Development and Demonstrations 

RFA RCRA Facility Assessment 

RFI RCRA Facility Investigation 

RFP Request for Proposals 

RIA Regulatory Impact Analysis 

RI/FS Remedial Investigation and Feasibility Study 

RIP Remedy In Place (DoD) 

RIS RCRA Implementation Study 

RMIS Restoration Management Information System (DOD) 

ROD Record of Decision 

Appendix F: Acronyms Page F-3 
Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends 

RP Responsible Party 

RPM Remedial Project Manager 

RTDF Remediation Technologies Development Forum 

SARA Superfund Amendment and Reauthorization Act of 1986 

SBIR Small Business Innovation Research 

SCRD State Coalition for Remediation of Drycleaners 

SERDP Strategic Environmental Research and Development Program 

SI Site Inspection 

SITE Superfund Innovative Technology Evaluation 

S&M Surveillance and Maintenance 

SMCRA Surface Mining Control and Reclamation Act 

S/S Solidification/Stabilization 

StATS State Authorization Tracking System 

STTR Small Business Technology Transfer 

SVE Soil Vapor Extraction 

SVOC Semi-Volatile Organic Compound 

SWMU Solid Waste Management Unit 

TCE Trichloroethylene 

TIO Technology Innovation Office 

T&M Time and Materials 

TRU Transuranic 

TSDF Treatment, Storage, and Disposal Facility 

UMTRA Uranium Mill Tailings Remedial Action 

USACE United States Army Corps of Engineers 

USAEC United States Army Environmental Center 

USDA United Department of Agriculture 

USFS United States Forest Service 

USGS United States Geological Survey 

UST Underground Storage Tanks 

UV Ultraviolet 

UXO Unexploded Ordnance 

VCP Voluntary Cleanup Program 

VEB Vertical Engineered Barrier 

VOC Volatile Organic Compound 

WFO Work for Others 

WMM Waste Military Munitions 

Appendix F: Acronyms Page F-4