Section Two
LANDFILL SITE REMEDIATION
3    COST ALLOCATION AT SUPERFUND SITES
Roy O. Ball, Principal
Elsie F. Millano, Project Engineer
James W. Polich, Principal
Environmental Resources Management-North Central, Inc.
Deerfield, Illinois  60015
INTRODUCTION
The Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CER-
CLA), also known as Superfund, provides the U.S. Environmental Protection Agency (USEPA) with
the authority to undertake remedial actions at hazardous waste disposal sites and to recover the
corresponding clean-up costs from responsible parties. Once the responsible parties are identified, the
remedial actions required at the site are established and approved, and the overall cost of the remedial
actions is known, each responsible party, although liable for all costs, is generally allocated some
fraction of the total.
Cost allocation is often based on the mass or volume transported to the site from a generator. A
more objective approach would also consider the nature of the materials that the parties sent to the
site. Some existing methodologies which consider waste properties as well as quantity require a
number of coefficients or factors and extensive computations, thus complicating the allocation process. This paper presents a simple method for assessing the relative responsibilities of the cost of
remedial action at a Superfund site. A case study, involving a landfill and nine known responsible
parties, is also presented to illustrate the method.
BACKGROUND
The simplest method to allocate the costs of Superfund sites clean-up consists of using the relative
amount of waste contributed to the site by each responsible party as a weighting factor. In this way,
the party which sent more waste to the site pays the highest fraction of the clean-up costs, and vice
versa. This method disregards the impact of the nature of the materials contributed by each responsible party on the clean-up costs and assumes that the quantity of waste sent by each generator can be
defined.
A model developed by Adams et a/.1 takes into account the toxicological, chemical and physical
properties of the wastes, as well as the individual quantities deposited at the site. Using the model
(CCA Model), each of these aspects can be scored based on their relative impact on clean-up costs.
The final output of the model is a probability distribution of the cost allocation factor, i.e., a range of
costs.
The CCA model has the apparent disadvantage of requiring a negotiation process to arrive to the
final cost allocation, using the range of values provided by the model. The values may vary by a factor
of two (for example, between 15% and 30%). The result can therefore be a lengthy process, even after
using the cost allocation model.
Another aspect of the CAA Model is that the scores used for cost allocation appear to be subjectively selected, based on an estimation of the impact of specific properties on clean-up costs'. However, there may not be established relationships between the properties of particular chemicals and the
cost of their removal.
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