An Evaluation of the Oregon State Cleanup Program

Abstract

This paper discusses the factors that impact contaminated site cleanup duration at the state level, focusing on the Oregon Department of Environmental Quality cleanup program. The factors of interest are regional divisions, organizational administration, and prior operations on-site. The duration to achieve cleanup, defined by a “No Further Action” determination, was quantified from the publicly available Oregon Environmental Cleanup Site Information database. A “No Further Action” determination is a regulatory agency action, typically following investigative or cleanup activities, to determine that all or part of a site poses no unacceptable risks to human health or the environment. The analysis of variance (ANOVA) statistical method was used to determine whether there was any statistically significant difference between populations, grouped by regional division, organization administration, and prior operations. Follow-up analyses were conducted on the three regional division populations via a simple comparison of the mean durations and organizational administration populations via a one-way t-test to specifically compare 1) the independent cleanup program to the voluntary cleanup program, and 2) the voluntary cleanup program to the site response program. The results indicated that regional divisions, organizational administration and prior operations have an impact on the length of time required to complete a site cleanup. Research on the staffing, budget resources, and workload allocated to each region may shed further light on the duration variation between the Eastern (average duration 3.5 years), Northwestern (4.5 years), and Western (5.5 years) regions. This analysis shows that site response program has a longer duration to cleanup than the voluntary cleanup program, whereas no statistically significant difference was noted between the independent cleanup program and the voluntary cleanup program. As a caveat, the site response program may be employed to address sites with higher risk and complexity than the voluntary cleanup program, which would potentially result in longer timeframes to achieve cleanup completion. However, the voluntary cleanup program has a reputation of taking a more cooperative approach between regulatory agency and responsible party; this may explain the shorter duration to complete site cleanup. To address the types of operations that may cause a lag in the cleanup process, state agencies may consider forming technical groups for similar sites and standardized methods for investigation, risk assessment or remediation for certain types of sites.