Mt. Dioxin
Author(s):
Edmond Tsang, John Reis
Edmund Tsang Mechanical Engineering
Department University of South Alabama Mobile, AL
36688
John Reis Aerospace Engineering
Embry`Riddle Aeronautical University Prescott, AZ
86301
This case is suitable for a junior level
fluid mechanics class, or a senior level course on ethics and
professionalism.
Abstract
This fictional case study involves an actual Superfund
cleanup of an abandoned wood treating facility adjacent to
several African American residential neighborhoods in the
southeastern United States. At the heart of this study are the
ethical issues involved in making decisions with insufficient
data. Here, these issues are presented from three different
perspectives: that of the Site Manager from the Environmental
Protection Agency (EPA), who must make decisions that affect
real people's lives; the regional EPA engineer who recommends
policy and makes decisions guided by legislation; and an
engineer working for a private consulting company contracted to
excavate the contaminated soil. (His job, obviously, depends on
the employer.) The case history, soil sampling data and
excerpts from EPA documents are included, together with
numerical as well as ethical problems.
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Introduction
One obstacle to effective instruction on engineering ethics
is the lack of resources such as numerical problems. But
ethical issues encountered in the practice of engineering can
be integrated throughout the curriculum. Instruction in ethics
is a requirement for accreditation for undergraduate
engineering programs 1, and it is a curriculum goal of recent reports on
Engineering Education for the 21st Century (e.g., the report
issued in 1994 by the Engineering Deans Council and the
Business Roundtable of the American Society for Engineering
Education 2.)
In response to the need for more numerical problems to teach
engineering ethics, in August 1995 the Texas A & M
University hosted a workshop in which 38 faculty members from
engineering colleges in the US and one professor from
Monterrey, Mexico, gathered for one week to develop numerical
problems associated with ethics cases for use in the
undergraduate engineering curriculum. Details of the one week
workshop, which was supported partially by the National Science
Foundation, have been published in the 1996 Proceedings of ASEE
Annual Conference 3.
This paper describes one case developed at that
workshop.
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Case History
ETC is a former wood-treating company. The facility occupies
26 acres in an industrial area. Four African American
residential neighborhoods are in the immediate vicinity. The
site was first developed for creosote wood preserving in 1941;
since 1963, penta-chlorophenol (PCP) had been used as a
preservative at the ETC site and was the only preservative used
after 1970. Manufacturing activities had not taken place at the
facility since October, 1982, and the site was officially
abandoned in bankruptcy proceedings during February of
1991.
The RCRA (Resource Conservation and Recovery Act) inspection
report of ETC in February, 1981 showed that the wood treating
facility was cited for many non-compliances, including no
inspection log, no personnel training records, no groundwater
monitoring, no protective covers and inspections of surface
impoundments, and no inspection schedules.
In June, 1990, during remedial investigation and feasibility
study (Rl/FS) of a Superfund site (the Agrico Chemical
site-located 3,000 feet to the northeast of ETC), a contaminant
found in the groundwater under Agrico Chemical was traced to
ETC. In April, 1991, preliminary assessment began at the ETC
site to determine the extent of contamination. Soil sampling
using PCP as an indication of contamination is summarized in
Table 1.
Table 1. PCP Analytical Results for Soil Samples at ETC
| Locations |
Concentration (mg/kg) |
| SWMU-11 |
140,000 |
| SEMU-15 |
21,000 |
| SWMU-16 @ 8' |
2,900 |
| SEMU-16 @ 3' |
88 |
| SEMU-21A (surface) |
2,500 |
| SEMU-21A @ 1-1.5' |
650 |
| SWMU-21A @ 3' |
320 |
| SWMU-21B @ 1-1.5' |
6,300 |
| SWMU-21B @ 3' |
320 |
| SWMU-21C (surface) |
17,000 |
| SWMU-21C @ 0.5-1' |
5,800 |
| SWMU-21C @ 4.5' |
91 |
| SWMU-3 (surface) |
580 |
| SWMU-3 @ 3-3.5' |
480 |
| SWMU-24A (surface) |
71,000 |
| SWMU-24A @ 1.5' |
1,700 |
| SWMU-24A @ 2.4' |
3,300 |
| SWMU-24B (surface) |
320,000 |
| SEMU-25 @1-3' |
93 |
| SWMU-25 @ 4-6' |
4,200 |
High concentrations of creosote, dioxin, benzene, lead and
arsenic were detected on the site. No samples were collected
below 8 feet. Sampling also showed creosote and PCP were
detected in groundwater under the ETC property see Figure
1.
Based on this sampling, EPA began soil excavation under the
Emergency Removal provision of the Superfund law, which allows
it to begin work without first publishing a public notice.
According to an action memo to EPA dated April, 1991, the
EPA site manager for ETC requested $1.3 million, of which $1
million was for the ERCS (Emergency Removal/Corrective Service)
contractor. In January, 1992, the ETC site manager wrote
another memo to the regional EPA engineer requesting funding be
raised to $2 million, with $1.4 million allotted for the ERCS
contractor. He also reported that although approximately 54,000
cubic yards of waste sludge and soil had been excavated so far,
the volume of waste material had been greatly
underestimated.
By the time when excavation was finally stopped in November,
1992, $5 million (with $4.3 million for the ERCS contractor)
had been spent, and approximately 260,000 cubic yards of PCP,
creosote, and dioxin contaminated soil was removed and
stockpiled on site. Because treating the contaminated soil
would cost $43 million, which was more than twice the yearly
budget for the Regional Removal Program, the stockpiled soil
was wrapped in a vinyl tarp and left on the grounds of the
former ETC facility see Figure 2.
Security around the ETC site was lax, and the local
newspaper reported that children were discovered using the
30`foot vinyl covered "Mt. Dioxin" as a giant slide.
The neighboring residents of ETC did not know about the soil
excavation until it was well on its way, releasing both
contaminant-carrying dust particles and volatile chemicals into
the air. The residents complained of respiratory problems as
well as other health problems, such as skin rashes and fatigue.
Figure 3 shows a map of the residential neighborhoods
surrounding ETC and other industrial facilities.
[Creosote, PCP, and dioxin compounds have a number of
toxicological effects and adverse health effects on humans.
Acute health effects include severe eye, skin and respiratory
irritation, chloracne, burning of exposed skin. erythema,
anorexia, nausea, and dyspepnea. The chronic health threats
range from carcinogenicity, mutagenicity, teratogenicity, and
long-term respiratory impairment to death.]
The ETC site was not placed on the Superfund National
Priority List (NPL) for cleanup until December, 1994. Presently
(May, 1996) the final cleanup plan is expected to be ready by
early 1997, and EPA has agreed to relocate residents of
Rosewood Terrace even though contaminants from the ETC and the
Agrico Superfund sites have been detected in other nearby
residential neighborhoods, according to the limited number of
soil samplings that have been performed see Table 2.
ETC Contaminants in Oak Park and Escambia Arms
| Contaminant |
Residential |
Safe |
| Dioxin TEQ |
2,589 ppt |
2 ppt |
| Dieldrin |
1,300 ppb |
40 ppb |
| Benzo(a)pyrene |
1,133 ppb |
88 ppb |
| Arsenic |
9,400 ppb |
370 ppb |
Agrico Contaminants in Goulding
| Contaminant |
Residential |
Safe |
| Dioxin TEQ |
125 ppt |
2 ppt |
| Dieldrin |
2,000 ppb |
40 ppb |
| Benzo(a)pyrene |
24,705 ppb |
88 ppb |
| Arsenic |
48,000 ppb |
370 ppb |
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Numerical Problems
- Estimate the minimum amount of contaminated soil to be
removed, based on data in Table 1 and Figure 1.
- ETC is located in an area where hurricanes occur. In
1995, two hurricanes with wind gusts up to 90 mph passed
through the city where "Mt. Dioxin" is located. Calculate the
lift on the vinyl tarp due to an average wind gust of 75 mph.
Design an anchoring system for the tarp.
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Ethics Problem
Ethics problems are presented from three different
perspectives:
- Assume you are the EPA Site Manager. Under organization
pressure and a looming deadline, you must make a decision
concerning immediate soil excavation. The contaminants pose a
continual threat to the groundwater. But you are also
constrained by budget and incomplete soil sampling data. a)
The deadline to file a request for Emergency Removal is two
days away. Under the Superfund legislation, work performed
under the Emergency Removal provision of the law can begin
immediately without first publishing a public notice. What
should you do?
- You know from experience that it generally takes
about ten years to clean up a Superfund site. With a
limited budget, what course(s) of action could you take
during the intervening ten years in relation to the
residents living in the four communities near ETC and
Agrico Chemical Superfund sites?
- Assume you are an engineer working for the ERCS
contractor.
Based on your experience, you know that the volume of
contaminated soil that must be excavated is more than the
amount initially budgeted by the EPA site manager, and that
soil excavation would release volatile chemicals and dust
particles carrying the contaminants.
But the contractor is hesitant about spending money on
dust suppression and other precautions because of profit
margin. What recommendation(s) would you make to the
contractor?
Here, you are faced with a conflict between being loyal
to your employer and being loyal to the public ` the
residents living near ETC. Is there a way to be faithful to
both?
- Assume you are the regional manager for EPA overseeing
the ETC cleanup.
You are aware that funding priority for cleanup depends
on a site being placed on the National Priority List (NPL)
and the ETC site has not been placed on the NPL. You also
know that the cost of cleaning up ETC would most likely
exceed the regional budget. However, the ETC contaminants
pose a continual threat to groundwater.
- How might you justify approval for funding to
excavate soil at ETC under the Emergency Removal
provision of the Superfund legislation?
- With no plan for cleanup, can you justify approving
soil excavation?
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References
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These problems were originally developed as part of an
NSF-funded project to create numerical problems that raise
ethical issues for use in engineering and other course
assignments. The problems presented here have been edited
slightly for clarity.