stalled the implementation of numerous remedial measures designed to control surface and groundwater contamination from the

site. For example, funds were not available throughout the winter of 1982-83 to pump and haul contaminated water from several on-site wells and downgradient interceptor wells.161 As a result, the plume of contaminated groundwater migrated further toward the Glen Avon water supply,162 and the concentration of toxic wastes in the contaminated plume increased significantly.163 From February, 1982, to February, 1983, the concentration of trichloroethylene (TCE), one of the suspect human carcinogens present at the Stringfellow site, tripled in the groundwater at a location between the Acid Pits and Glen Avon.164

In addition, the State of California failed to complete necessary erosion control measures prior to the winter of 1982-83 because of a lack of funds.165 Consequently, heavy rains occurring in early 1983 caused significant erosion of the cover material, providing a pathway for surface waters to enter the contaminated wastes.166 The contaminated surface waters entered the adjacent community via Pyrite Creek, a local stream.167

Unfortunately, the pace of remedial efforts at the Stringfellow site has not increased substantially since the award of the Superfund grant for the site in July, 1983. EPA officials failed to authorize the extraction of contaminated groundwater from two important interceptor wells (IW-2 and IW-3) downgradient from the Stringfellow site until late March, 1984,168 more more than two years after the California Regional Water Quality Control Board had approved the initiation of such pumping.169 According to an October, 1982,

158(continued)

February 23, 1981 to receive early FY-81 Superfund supplemental funds for special investigation and feasibility studies." In addition, in July, 1981, both the Office of Emergency and Remedial Response and the Office of Federal Activities had agreed that "the potential for the next rainy season to cause release of hazardous waste is significant enough" for the Stringfellow site to qualify for special consideration under the National Environmental Policy Act. Memorandum from William N. Hedeman to Jake Mackenzie, Superfund Coordinator, Region IX, July 20, 1981.

159 Ibid.

160 Id., p. 640. 161 Interview Interview with with Thomas Bailey, Acting Chief, Site Cleanup and Emergency Response Section, Toxic Substances Control Division, California Department of Health Services, March 30, 1983 (hereinafter cited as Bailey Interview); Interview with Laurel Chun, Environmental Engineer, Region IX, Environmental Protection Agency, March 28, 1983 (Footnote continued)

consultant's report which was submitted to the Water Quality Control Board, the pumping of the interceptor well was essential "to remove the contaminated ground water ... before it contaminates the downstream potable Glen Avon ground water basin."170

The State of California also has moved at an extremely slow pace in implementing the activities funded under its Cooperative Agreement with EPA. The State did not award the contract for the remedial investigation/feasibility study until April, 1984, nine months after the award of the Cooperative Agreement.171 According to EPA officials, the delay of this study has stalled "long-term remedial action" for final site closure.172

In addition, a recent contractor report, prepared for OTA by G. J. Tresak, highlights the potential for delay inherent in the current approach of EPA and the State at the Stringfellow site. The report states that:

...

[A]n entire program of study and cleanup action [was conducted by the State of California] prior to the implementation of the standard EPA cooperative agreement procedure involving a feasibility study of suitable remedial action alternatives. Consequently, because much is already known about the characteristics of the site and its problems both from the original Water Quality Control Board-initiated James Montgomery studies and recent EPA studies, a serious question exists as to the need and prudency of additional studies, particularly of the type being proposed.173

161(continued)

(hereinafter cited as Chun Interview I); Telephone Interview with Laurel Chun, Environmental Engineer, Region IX, Environmental Protection Agency, March 27, 1984 (hereinafter cited as Chun Interview II).

162 Bailey Interview; Chun Interview II.

163 Chun Interview II.

164 Stringfellow Complaint, pp. 4-5.

165 Bailey Interview; Chun Interview I.

166 Ibid.

167 Chun Interview II.

168 Memorandum from William N. Hedeman, Jr., Director, EPA's Office of Emergency and Remedial Response, to Harry Seraydarian, Director, Toxic and Waste Management Division, EPA Region IX, March, 1984.

According to Russel H. Wyer, the Director of EPA's Hazardous Site Control Division, EPA delayed the pumping of the interceptor wells because the Agency did not know the correct rate of pumping to authorize. Mr. Wyer stated that pumping (Footnote continued)

Moreover, the Tresak Case Study contends that the current remedial efforts of EPA and the State of California at the Stringfellow site are inadequate and that proposed actions may actually worsen the problems at the site.174 According to the report, JRB Associates, the contractor under the cooperative agreement, is focusing its remedial investigation/feasibility study on options which seek seek to contain, rather than to eliminate, the source of groundwater contamination.175 Yet, the report emphasizes that "[c]ontainment approaches at a site of complex geology site of complex geology like Stringfellow have a high potential for failure."176

168(continued)

and hauling of the contaminated groundwater is very expensive, and therefore, the Agency wanted to know the proper rate of pumping so it would not pump and haul more water than necessary.

However, knowledgeable parties have indicated that EPA could have determined the proper rate of pumping by simply initiating some test pumping of the interceptor wells. When questioned about this alternative, Mr. Wyer cited the expense of this approach as a concern. Interview with Russel H. Wyer, Director, Hazardous Site Control Division, June 29, 1984.

169 Telephone Interview with James W. Anderson, Executive Officer, California Regional Water Quality Control Board, Santa Ana Region, May 24, 1984; Stringfellow Hearing, p. 104 (unpublished transcript); Meeting Minutes, California Regional Water Quality Control Board, Santa Ana Region, December 11, 1981, p. 4; James M. Montgomery, Consulting Engineers, Inc., An Evaluation of Ground Water Disposal Alternatives and Post-Closure Monitoring for Stringfellow Class I Hazardous Waste Disposal Site, October, 1981, p. 1-3 (hereinafter cited as Montgomery Report).

170 Montgomery Report, p. 1-3.

171 Hedeman Interview.

172 Letter from Harry Seraydarian, Director, Toxics and Waste Management Division, EPA Region IX, to Joel Moskowitz, Deputy Director, California Department of Health Services, February 24, 1984.

173 Tresak Case Study, p. 61.

174 Id., pp. 1-2, 9-10.

175 Id., pp. 9-10, 87-90, 113-14. 176 Id., p. 107.

The continuous delays in implementing remedial measures at the Stringfellow site are particularly serious in view of the rapid spread of groundwater contamination from the site. According to the contractor report, "the contaminant [groundwater] plume has now migrated to the edge of the Chino Basin [and] it appears that the plume will enter the main flow of the basin within the next twelve to eighteen months. "177

In view of the urgency of these problems, the Chairman of the Subcommittee has joined with Congressman James J. Florio, the Chairman of the Subcommittee on Commerce, Transportation, and Tourism, and Congressman George Brown, who represents Glen Avon, California, in a recent letter to EPA Administrator William Ruckelshaus concerning the Stringfellow site. That letter transmitted a copy of the recently completed Trezak Report to the Agency and requests Mr. Ruckelshaus to "take actions necessary to address the problems raised."178

C.

Reilly Tar and Chemical Corporation Site, St. Louis Park,
Minnesota

As Subcommittee Member Gerry Sikorski has emphasized, EPA delays in initiating cleanup measures at the Reilly Tar hazardous waste site have "increased the real threat to the health and safety of thousands of Minnesotans.179 This site, located in St. Louis Park, Minnesota, is a major source of concern because of its contamination of an extremely important groundwater acquifer.180

The wastes identified at the Reilly Tar site include polynuclear aromatic hydrocarbons (PAHs), some of which are carcinogenic.181 As a result of PAH contamination, St. Louis Park has been forced to close six of the drinking water wells serving its 45,000 residents, and the adjacent suburb of Hopkins has closed another municipal well.182 According to EPA officials, contamination of additional drinking water plies in St. Louis Park and adjacent communities is anticipated unless preventive measures are taken.183 This public health threat is extremely serious because "[a] total population of about 100,000 people use groundwater for drinking in the immediate vicinity of St. Louis Park."184 Without remedial action, leaching and migration of groundwater will con

177 Id., p. 8.

178 Letter from John D. Dingell, James J. Florio, and George Brown to William Ruckelshaus, EPA Administrator,

August 6, 1984.

179 Hearings 3, p. 626.

180 Id., pp. 650-51, 656.

181 Id., p. 656.

182 Id., pp. 588, 656.

183 Id., p. 589.

184 Id., p. 588.

tinue to move hazardous chemicals from the Reilly Tar site into the Prairie du Chien-Jordan acquifer, which supplies 80 percent of the groundwater utilized for drinking in the Minneapolis-St. Paul metropolitan area. 185

As a result of EPA foot-dragging in obligating Federal funds for the Reilly Tar site in 1982, the Agency needlessly increased the public health risks posed by the site in several ways. First, the lack of funds forced the State of Minnesota to suspend cleanup operations, including its well reconstruction and abandonment program, for several months.186 The suspension of the well abandonment and reconstruction program was extremely damaging because because "improperly constructed and deteriorating wells provide the primary route for migration of contamination to drinking water acquifers" at the Reilly Tar site.187 One of the well reconstruction activities which was curtailed abruptly because of the funding delay was a project to remove coal tar wastes and replace leaking casing at well 23, a major source of PAH contamination,188 As a result, additional groundwater contamination occurred which would not have continued had the cleanup work proceeded on schedule.189

Secondly, EPA's inaction resulted in a six-month delay in the initiation of work by the United States Geological Survey (USGS) to model and test a proposed groundwater gradient control system.190 In 1981, a contractor proposed a pumping program to intercept the flow of contaminants leaving the Reilly Tar site.191 The USGS contract was designed to model and test the pumping scheme proposed by the contractor before initiating the pumping and drilling of new wells.192 Since the USGS modeling project was a precondition to the implementation of the pumping program, the six-month postponement in the USGS work stalled efforts to control the off-site spread of serious groundwater contaminants.193 Clearly, if EPA actions had not slowed cleanup of the Reilly Tar site, significant additional groundwater contamination would have been avoided.