Simulation Problem: Hickory Woods

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Simulation ProblemHickory Woods

• Team 3
• Jack Jia
• Mike Kooshoian
• Heath Miller
• Karen Riedesel

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Cleanup Process

• The Superfund Cleanup process begins with site
  discovery or notification to the EPA of possible
  releases of hazardous substances.
• Sites are discovered by
• Citizens
• State Agencies
• EPA Regional Offices

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Hickory Woods

• Site Name Abby Street Hickory Wood Subdivision,
  Buffalo, NY 14220
• EPA ID NYSFN0204229
• EPA Region 02
• In October 1998, a city inspector observed black,
  cindery soil and an oozing orange substance
  coming out of the ground in a basement being
  excavated at 267 Mystic Street. The City of
  Buffalo contacted the EPA.

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

• Once discovered, sites are entered into the
  CERCLIS Database
• The Database is a computerized inventory of
  hazardous waste sites, potentially hazardous
  waste sites, and remedial activities across the
  nation.
• See www.epa.gov/superfund/sites/cursites/index.htm

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Preliminary Assessment/ Site Inspection (PA/SI)

• Site conditions are investigated and the
  potential for release of hazardous substances
  from a site is investigated.

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Preliminary Assessment

• Performed on every CERCLIS site
• It is a limited-scope investigation that collects
  readily-available information about a site and
  its surroundings
• It distinguishes, based on limited data, between
  sites that pose little or no threat to human
  health and the environment and sites that may
  pose a threat and require further investigations
• It also identifies sites requiring assessment for
  possible emergency response actions
• See Guidance for Performing Preliminary
  Assessments under CERCLA, Sept. 1991

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Site Inspection

• Only performed if PA results in a recommendation
  for further information
• Environmental and waste samples are collected to
  determine what hazardous substances are present
  at a site
• Determines if hazardous substances are being
  released to the environment and assesses if they
  have reached nearby targets
• Provides the necessary data for a Hazard Ranking
  Score (HRS)
• See Guidance for Performing Site Inspections
  under CERCLA, Sept. 1992

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Hickory Woods

• The Preliminary Assessment recommended a Site
  Inspection be done
• Pat Blake (see readings) has dug holes in his
  backyard to prepare for the EPAs visit

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Hazard Ranking Score (HRS)

• Calculated from information gathered during the
  PA SI
• There is a screening mechanism used to place
  sites on the National Priorities List (NPL)
• HRS of 28.50 or above means the site is eligible
  for NPL site listing and requires preparation of
  an HRS scoring package

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NPL Site Listing Process

• Authorized by Section 105(a)(8)(B) of CERCLA
• This is a list of the most serious sites that
  have been identified for possible long-term
  cleanup
• The process identifies what CERCLA-financed
  remedial actions may be appropriate it also
  notifies the public of sites that the EPA
  believes warrant further investigation
• Also serves as notice to potentially responsible
  parties that the EPA may initiate CERCLA-financed
  remedial action

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Hickory Woods

• NPL status Not on the NPL
• Non-NPL status Removal-Only Site (No Site
  Assessment work needed)

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Impacts on the residents if Hickory Woods is
listed as a superfund site

• Further depressed or destroyed property values
• Industrial/commercial redevelopment will probably
  shift to greenfields sites
• The unemployment rate may rise
• Segregation along racial and class lines may
  increase

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Impacts cont.

• The tax base may decline due to fewer residents
  and lower property values
• There will be additional toxic tort litigation
• The quality of life for the residents will decline

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Jurisdiction

• If the USEPA has determined that this is an
  emergency and that they are the only ones who can
  respond in a timely manner, they will do so.
  Otherwise, the USEPA will consult with the NYDEC
  before determining the appropriate remedial
  action to be taken.

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Jurisdiction cont.

• In order for the NYDEC to assert jurisdiction,
  they must enter into a contract or cooperative
  agreement with the USEPA, providing assurances
  that the EPA deems adequate that the DEC will
• Assure all future maintenance of the removal and
  remedial actions provided for the expected life
  of such actions as determined by the USEPA
• Assure the availability of a hazardous waste
  disposal facility acceptable to the USEPA and in
  compliance with the Solid Waste Disposal Act
• Agree that the State will pay 10 of the costs,
  including all future maintenance of the site, if
  the Superfund Trust Fund is being used to pay for
  cleanup

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Jurisdiction cont.

• States may participate in a deferral program that
  encourages qualified states/tribes to address,
  using their own laws, hazardous waste sites that
  are currently being considered for the NPL. The
  goal is to accelerate cleanup, minimize
  duplication of Federal State efforts, and
  encourage the polluters to participate in the
  cleanup.
• Sites proposed for deferral must be included in
  CERCLIS.
• In general, states have to pay for cleanup costs
  themselves, although in limited circumstances,
  states may receive funds through cooperative
  agreements to conduct site-specific activities or
  to develop their own capacity to participate in
  the deferral program.

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DEC Procedure to determine if a site should be
listed as a state Superfund site

• The State procedure is very similar to the USEPA
  procedure. It is called the Inactive Hazardous
  Waste Disposal Site (IHWDS) Program and consists
  of
• Preliminary Site Assessment
• Remedial Investigation/Feasibility Study
• Design and Construction of a Cleanup Plan

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• Preliminary Site Assessment occurs when the
  State is made aware of potential hazardous waste
  contamination. Either the DEC or Potentially
  Responsible Party (PRP) performs the PSA.
• Remedial Investigation Sites that receive a PSA
  classification of 2 and represent a significant
  threat to the environment or public health
  undergo a more detailed investigation. A
  significant threat is
• A significantly increased risk to the public
  health
• A significantly adverse impact to fish and
  wildlife
• A significant adverse impact due to a fire,
  spill, explosion, or the generation of toxic
  gases or
• Other significant environmental damage.

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Site Cleanup

• Each class 2 site is assigned a project manager
  who oversees the investigation and evaluation of
  cleanup options. They write the Proposed Remedial
  Action Plan (PRAP) and presents it at a public
  meeting. After a PRAP is approved, the manager
  may help oversee its implementation. If a PRP can
  be found, they usually pay for the cleanup,
  otherwise the State pays out of the 1986
  Environmental Quality Bond Act, or State
  Superfund.

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Remediation

• NY State has more of an incentive to clean up
  sites and protect its citizens to keep people in
  NY and increase its tax base by increasing
  property values through clean-up
• Whoever has the most manpower and financial
  resources could make a difference
• Local agencies might have more expertise in what
  an area needs during the cleanup process

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