An evaluation of the role of risk-based decision-making in a former manufactured gas plant site remediation

Environmental remediation decisions are driven by the need to minimize human health and ecological risks posed by environmental releases. The Risk Assessment Guidance for Superfund Sites enunciates the principles of exposure and risk assessment that are to be used for reaching remediation decisions for sites under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Experience with remediation management under CERCLA has led to recognition of some crucial infirmities in the processes for managing remediation: cleanup management policies are ad hoc in character, mandates and practices are strongly conservative, and contaminant risk management occurs in an artificially narrow context. The purpose of this case study is to show how a policy of risk-based decision-making was used to avoid customary pitfalls in site remediation. This case study describes the risk-based decision-making process in a remedial action program at a former manufactured gas plant site that successfully achieved timely and effective cleanup. The remediation process operated outside the confines of the CERCLA process under an administrative consent order between the utility and the New Jersey Department of Environmental Protection. A residential use end state was negotiated as part of this agreement. The attendant uncertainties, complications, and unexpected contingencies were overcome by using the likely exposures associated with the desired end state to structure all of the remediation management decisions and by collecting site-specific information from the very outset to obtain a detailed and realistic characterization of human health risks that needed to be mitigated. The lessons from this case study are generalizable to more complicated remediation cases, when supported by correspondingly sophisticated technical approaches.     

Development of Cleanup Standards at Superfund Sites: An Evaluation of Consistency

The Washington Department of Ecology (WDOE) recently developed a regulatory program for determining cleanup standards at hazardous waste sites. One of WDOE's first tasks in the development of a cleanup standards program was to evaluate how standards have been developed and implemented under Superfund.

The evaluation of cleanup standards revealed: (1) a great deal of variation among sites, both in the magnitude of the standards set for some contaminants and the basis on which they were set, and (2) that there is no consistent decision-making approach for determining how standards should be set. This lack of consistency and guidance has the potential to result in overly stringent or underprotective cleanup requirements and inefficient standard development.

Washington State has adopted an approach that allows for implementing uniform numerical cleanup standards at relatively straightforward sites and provides a process for establishing site-specific cleanup levels at more complex sites. This approach is expected to facilitate development of standards that offer appropriate human health and ecological protection while minimizing private and public sector site management and cleanup costs.     

Some Heavy-Metal Pollutants in the Air of Naples

ABSTRACT

In this paper, assumptions regarding future land use as a key uncertainty is considered and its impact on risk analysis for contaminated sites is assessed. Risks are assessed for two land use scenarios (current-use industrial and future-use residential) using probabilistic models that incorporate uncertainty and variability in the exposure parameters. Residual risks are calculated for both industrial and residential cleanup standards. A Superfund site in northern California is considered.

In general, for the unremediated case, the future-use residential scenarios produce larger risks (1 to 3 orders of magnitude) than current- (continued) use industrial scenarios. For the Superfund site studied, the residual risks calculated for the remedy selected was not sufficiently protective of future-use residents in that it did not meet .S. Environmental Protection Agency (EPA) risk goals, but was protective of current-use workers, even though the cleanup criteria were based on residential use. Alternative risk management practices, such as deed restrictions, can be used in such cases.     

Risk-based Decision Process for Arsenic in Soils: Implications of Conservative Protocols

Making defensible risk-based decisions is a complex process that incorporates risk assessment into a risk management framework. Many site investigations require additional study, negotiations and/or actions for arsenic detected in soil samples, in many cases where no process related sources are identified and no other chemicals of concern are identified. Regulatory agencies develop guidance to standardize approaches to risk-based site investigations that focus on achieving "safe" concentrations. For arsenic, the action level is frequently in the "gray region", a U.S. Environmental Protection Agency (USEPA) term associated with a region of high uncertainty for risk management decisions in the "decision performance curve" associated with the data quality objective (DQO) process. Recognizing the conservative nature of the risk-based screening value for arsenic, approaches to enforce this level (or proof of comparability to natural background) may have numerous consequences including ineffective use of resources, stigmas on properties or actions at industrial or hazardous sites that are inconsistent with their regional setting. Florida has developed regulations and guidance on investigation of brownfield sites and has supported a study by the University of Florida (UF) to evaluate natural background concentrations in Florida soils. This paper discusses the sources of uncertainty near the soil cleanup target levels (SCTLs) in the Florida decision-making framework.     

Risk-based Decision Process for Arsenic in Soils: Implications of Conservative Protocols

Making defensible risk-based decisions is a complex process that incorporates risk assessment into a risk management framework. Many site investigations require additional study, negotiations and/or actions for arsenic detected in soil samples, in many cases where no process related sources are identified and no other chemicals of concern are identified. Regulatory agencies develop guidance to standardize approaches to risk-based site investigations that focus on achieving “safe” concentrations. For arsenic, the action level is frequently in the “gray region”, a U.S. Environmental Protection Agency (USEPA) term associated with a region of high uncertainty for risk management decisions in the “decision performance curve” associated with the data quality objective (DQO) process. Recognizing the conservative nature of the risk-based screening value for arsenic, approaches to enforce this level (or proof of comparability to natural background) may have numerous consequences including ineffective use of resources, stigmas on properties or actions at industrial or hazardous sites that are inconsistent with their regional setting. Florida has developed regulations and guidance on investigation of brownfield sites and has supported a study by the University of Florida (UF) to evaluate natural background concentrations in Florida soils. This paper discusses the sources of uncertainty near the soil cleanup target levels (SCTLs) in the Florida decision-making framework.     

The Use of Health Risk Assessment to Estimate Desirable Sampling Detection Limits

Abstract

The inclusion of non-detected chemicals in a health risk assessment may lead, in some cases, to estimated risks that exceed regulatory thresholds, because one must use the detection limit or half of the detection limit. This study presents a methodology which will allow one to estimate appropriate detection limits by conducting a health risk assessment prior to the source sampling program. The advantages and shortcomings of various levels of detail in the risk assessment to determine those detection limits are discussed. The application of the methodology is demonstrated with a case study of the potential health effects of power plant stack emissions.     

Remedial Strategies for Municipal Solid Waste Management in China

ABSTRACT

The purpose of this investigation is to evaluate the current status and to identify the problems of municipal solid waste (MSW) management in China to determine appropriate remedial strategies. This is the second of two papers proposed on this topic. Major problems or difficulties identified in MSW management in China include MSW land, air, and water pollution, commingled collection, poor administration, shortage of funds, lack of facilities, and problems of training and public awareness.

In order to solve these problems and to improve MSW management in China, remedial strategies in three areas are recommended: institutional reform, technology development, and legislation and administrative improvement. The primary principle involved in institutional reform is unifying legislative responsibilities into one body and developing a market mechanism for handling MSW. Composting, landfills, and incineration should be equally developed in accordance with China's needs. The feasibility of developing technology to handle MSW in China is discussed. Also recommended is the establishment of sound regulatory systems, including a service fee system, a source separation system, and a training program. China is presently undergoing economic and institutional reform at the national and local levels. Results of this study will provide useful information on MSW management in China.     

A Discussion of Regulatory Requirements and Air Dispersion Modeling Approaches Applicable to U.S. Chemical Demilitarization Facilities

ABSTRACT

Owners of hazardous waste treatment, storage, and disposal facilities, and certain major air pollution sources, must conduct several separate ambient air dispersion modeling analyses before beginning construction of new facilities or modifying existing facilities. These analyses are critical components of the environmental permitting and facility certification processes and must be completed to the satisfaction of federal, state, and local regulatory authorities.

The U.S. Army has conducted air dispersion modeling for its proposed chemical agent disposal facilities to fulfill the following environmental regulatory and risk management requirements: (1) Resource Conservation and Recovery Act human health and ecological risk assessment analysis for the hazardous waste treatment and storage permit applications, (2) Quantitative Risk Assessment to support the site-specific risk management programs, and (3) Prevention of Significant Deterioration ambient air impact analysis for the air permit applications. The purpose of these air dispersion modeling studies is to show that the potential impacts on human health and the environment, due to operation of the chemical agent disposal facilities, are acceptable. This paper describes and compares the types of air dispersion models, modeling input data requirements, modeling algorithms, and approaches used to satisfy the three environmental regulatory and risk management requirements listed above. Although this paper discusses only one industry (i.e., chemical demilitarization), the information it contains could help those in other industries who need to communicate to the public the purpose and objectives of each modeling analysis. It may also be useful in integrating the results of each analysis into an overarching summary of compliance and potential risks.     

Thermal Encapsulation of Metals in Superfund Soils

Abstract

Superfund sites frequently contain both heavy metals and organic hazardous waste. If not properly controlled, the metals may be changed to a more leachable form and may also be emitted to the atmosphere via the exhaust stack. This paper documents a batch kiln R&D test program to solve these metal-related problems. It was performed under the U.S. EPA’s SITE (Superfund Innovative Technology Evaluation) Emerging Technology Program. Allis Mineral Systems has developed the Thermal Encapsulation Process. Metals with limits set by EPA’s TCLP (Toxicity Characteristic Leaching Procedure) test and BIF (boiler and industrial furnace) stack emission regulations, such as cadmium, chromium, and lead, are the initial target of this process. This process, while unproven in these areas, may also apply to mixed waste (EPA hazardous waste/low-level radioactive wastes) and may also benefit commercial hazardous waste or Superfund thermal treatment systems. The results of the SITE tests were positive: strong, durable nodules were produced with excellent crush strength and improved resistance to leaching. Feed preparation, particularly control of moisture content, was found to be a key element in initiation of agglomeration. A good correlation was found between decreasing TCLP metals leachate levels and increasing crush strength.     

1990 Thermal Remediation Industry Contractor Survey

The treatment of soil contaminated with organics and inorganics is becoming a major industry in the United States and Europe. The soil cleanup bill for the United States could run as high as $200 to $300 billion over the next 30 to 40 years. European soil cleanup costs could run as high as $130 billion.¹

The types of sites in the United States that will require soil treatment can be broken down into the following categories: ? CERCLA (Superfund) Actions

? RCRA Corrective Actions

? RCRA Closures

? Underground Storage Tanks

? Real Estate Transfers

? Spill Clean-ups.

The cleanup of sites in each of these categories, with the exception of the Real Estate Transfer category, is being driven by different sets of Federal regulations. Real Estate Transfer type regulations were first instituted in New Jersey and have now been promulgated in a number of other states.

The eventual cleanup cost for the Superfund sites will be close to $200 billion. Estimated costs for the industrial sector Superfund are $25 to $50 billion and the estimated cost for the Department of Energy sites is over $150 billion.2 An early RCRA Corrective Action cleanup estimate is $25 billion.3 This estimate may well be low, however, since the permitting, cleanup and delisting criteria are still not clearly defined. The EPA’s RCRA Corrective Action cost estimate is $7.4 billion. However, the Office of Management and Budget feels that this estimate is low.⁴

The potential magnitude of the cleanup costs has resulted in the development and implementation of many technologies for the decontamination of soils. Of the available remedial technologies, thermal treatment has perhaps had the most field testing. The purpose of this paper is to focus on the full scale site remediations which have been or are being conducted using thermal processing equipment. Projects which have been completed, are on-going, or have been contracted for, through January of 1990 are described.     

Removal of PCBs from a Contaminated Soil Using CF-Systems® Solvent Extraction Process

ABSTRACT

The U.S. Environmental Protection Agency’s (EPA) Superfund Technical Assistance Response Team (START) in cooperation with EPA’s Superfund Innovative Technology Evaluation (SITE) program evaluated a pilot scale solvent extraction process developed by CF-Systems. This process uses liquefied propane to extract organic contaminants from soils, sludges, and sediments. A pilot-scale evaluation was conducted in Golden, CO at Hazen Research, Inc., using CF-Systems’ trailer-mounted organics extraction unit. Approximately 1,000 pounds of soil, with an average poly-chlorinated biphenyl (PCB) concentration of 260 mg/kg, was obtained from a remote Superfund site. Six 100-pound batches of the contaminated soil were extracted using multiple extraction sequences. Three of the six batch runs were subjected to three extraction sequences each, so that process variability could be evaluated. Results showed that PCB removal efficiencies varied between 91.4 and 99.4%, with the propane-extracted soils retaining low concentrations of PCBs (19.0–1.8 mg/kg). Removal efficiencies of oil and grease (O&G) were found to be 96.0 to 99.6% with propane-extracted soils retaining O&G concentrations from 279 to <20 mg/kg. Overall extraction efficiency was found to be dependant upon the numberof extraction cycles used.     

Legal aspects of pesticides and toxic substances testing requirements

Abstract

The United States Environmental Protection Agency administers several laws and progrms through which it reviews the hazard potential of pesticides and other toxic substances which may present a risk to human health or the environment. The Agency's ability to assess hazard as required by law depends in part on test data developed through testing standards in Agency regulations. In reviewing the Agency's actions in this regard, the courts emphasize the importance of reasoned regulatory decisions. The legal requirements to assess risk and provide reasoned decisions in this regard establish the legal importance of testing guidelines and test data, and indicate that sound test methodology is as important legally as it is scientifically.     

The Use of Electrokinetics for Hazardous Waste Site Remediation

The Superfund Innovative Technology Evaluation (SITE) program was authorized as part of the 1986 amendments to the Superfund legislation. It represents a joint effort between U.S. EPA’s Office of Research and Development and Office of Solid Waste and Emergency Response. The program is designed to assist and encourage the development of waste treatment technologies that would contribute to more solutions to our hazardous waste problems.

Recently, EPA, through the SITE program, issued a work assignment to assess the “stateof- the-art” of electroklnetically enhanced contaminant removal from soils. Prior research efforts, both laboratory and field, have demonstrated that electroosmosis has the potential to be effective In facilitating the removal of certain types of hazardous wastes from soils. Particularly encouraging results have been achieved with inorganics in fine-grained soils where more traditional removal alternatives are less effective.

Although the results of various studies suggest that electrokinetics is a promising technology, further testing Is needed at both the laboratory and field levels to fully develop this technology for site remediation. A conceptual test program Is presented based on best available data which incorporates system design and operating parameters used in previous applications of this technology In the use of electrokinetics treatment as a remediation technique at hazardous waste sites.     

Control Technologies for Remediation of Contaminated Soil and Waste Deposits at Superf und Lead Battery Recycling Sites

This paper primarily addresses remediation of contaminated soils and waste deposits at defunct lead-acid battery recycling sites (LBRS) via immobilization and separation processes. A defunct LBRS is a facility at which battery breaking, secondary lead smelting, or both operations were performed for the primary purpose of reclaiming lead from spent lead-acid batteries. Metallic lead and lead compounds are generally the principal contaminants of concern in soils and waste deposits (i.e., buried, piled, landfilled waste) at these sites. Other metals (e.g., cadmium, copper, arsenic, antimony, and selenium) are often present at LBRS, but usually at much lower concentrations than lead and often present below hazardous concentrations. This article is primarily based on experience gained from: (1) Superfund site investigation, removal, and remedial actions, and (2) development and demonstration of control technologies under the Superfund Innovative Technology Evaluation (SITE) Program. The primary remedial options for lead contaminated soils and waste deposits include: (1) no action, (2) off-site disposal, (3) containment, (4) immobilization, (5) separation with resource recovery, and (6) separation without resource recovery. In spite of the toxicity of lead at low concentrations, the relative immobility of lead and site-specific risk assessments can still result in the selection of no action or containment remedies. Solidification/stabilization of lead-contaminated soils has been implemented at three Superfund sites and is the selected remedy at several others. Separation technologies (e.g., screening, extraction) are attractive because, if successful, they actually remove the contaminant from the environmental media. Separation technologies also offer the possibility that a valuable product (e.g., lead, plastic, energy) can be recovered, but careful consideration of economic and technical factors are required. Compared to the implementation of containment and solidification I stabilization remedies, separation technologies tend to be relatively novel, complex, and costly.     

Alternating Current Electrocoagulation for Superfund Site Remediation

Abstract

The Superfund Innovative Technology Evaluation (SITE) Emerging Technology (ET) Program, authorized under the Superfund Amendments and Reauthorization Act (SARA) of 1986, implements the goal of the SITE Program to promote, accelerate the development of, and make commercially available alternative innovative treatment technologies for use at Superfund sites.

Under this program, the technical and economical feasibility of alternating current electrocoagulation (ACE) developed by Electro-Pure Systems, Inc., was evaluated for a two-year period. ACE is an electrochemical technology where highly-charged aluminum polyhydroxide species are introduced into aqueous media for the removal of suspended solids, oil droplets and soluble ionic pollutants. ACE can break stable aqueous colloidal suspensions of up to 10 percent total solids and stable emulsions containing up to 5 percent oil.

Major operating parameters have been defined for different classes of effluents based on experimental results using complex synthetic soil slurries and metals. Test results indicate that ACE produces aqueous and solid separations comparable to those produced by chemical flocculent additions, but with reduced filtration times and sludge volumes. The technology has application where removal of soluble and suspended pollutants from effluents is required, and in the recovery of fine-grained products from process streams. The technology, however, has not yet been demonstrated at full-scale for Superfund site remediation. The principal results of the SITE research program, and results of ACE treatment on some different classes of industrial effluents not part of the SITE Program, are summarized.     

Protecting Off-Site Populations and Site Workers from Vapor Discharges during Shallow Soil Mixing at the North Carolina State University National Priorities List Site

Abstract

Although vapor monitoring is generally a component of remedial action activities, most sites do not have routine gaseous releases or vapor clouds erupting from the soil during implementation of the cleanup process (or during cleanup of the site). At the North Carolina State University Lot 86 National Priorities List Site, over 8410 m³ (11,000 yd³) of chemical waste was disposed at the Site, including organic solvents and shock-sensitive and airand water-reactive compounds. During the Remedial Action, it was imperative to protect site workers and off-site populations from potential inhalation exposures. Engineering controls were incorporated into the shallow soil mixing process to limit the release of gaseous compounds. To quantify potential exposures to on-site and off-site receptors, modeling was conducted to evaluate potential exposure routes and migration pathways. To demonstrate acceptable levels of airborne constituents, a multifaceted air sampling and monitoring program was implemented. To ensure that potential exposures could be quantified, passive dosimeters, continuous real-time monitoring, time-weighted whole air sampling, and grab samples of vapor clouds were all critical components of the air monitoring program. After the successful completion of the Remedial Action, the pre-Resource Conservation and Recovery Act (RCRA) chemical waste generated from the University’s educational and research laboratories was entirely encapsulated and neither on-site workers nor off-site populations were exposed to analyzed compounds above any health-based action level (i.e., 15-min short-term exposure limit [STEL], 8-hr threshold limit value, or time-weighted average permissible exposure limit)     

Product Guide/1988

Investigation, mitigation, and clean-up of hazardous materials at Superfund sites normally requires on-site workers to perform hazardous and sometimes potentially dangerous functions. Such functions include site surveys and the reconnaissance for airborne and buried toxic environmental contaminants. Airborne contaminants of concern usually emanate from spilled materials and require monitoring the air at the perimeter and throughout the clean-up site to ascertain the extent of contamination. Buried contaminants of major concern are often the result of leaking underground drums containing toxic wastes and require "reconnaissance excavations" to determine their location. Workers conducting on-site air monitoring risk dermal, ocular and inhalation exposure to hazardous chemicals, while those performing excavations also risk the potential exposure to fire, explosion, and other physical injury. EPA's current efforts to protect its workers and mitigate these risks include the use of robotic devices. Using robots offers the ultimate in personnel protection by removing the worker from the site of potential exposure, especially during site investigations, when there is almost always a certain encounter with unknown chemical wastes having unknown toxicity.

This paper describes the demonstration of a commercially-available robotic plat form modified and equipped for air monitoring and the ongoing research for the development of a ground penetrating radar (GPR) system to detect buried chemical waste drums. These robotic devices can ultimately be routinely deployed in the field for the purpose of conducting inherently safe reconnaissance activities during Superfund / SARA remedial operations.     

In Situ Determination of the Rate of Unassisted Degradation of Saturated-Zone Hydrocarbon Contamination

Abstract

A method to measure the in situ degradation rate of dissolved hydrocarbon contamination has been developed and applied at two locations at a field site. The method uses the rates of downward diffusion of oxygen and upward diffusion of carbon dioxide through the unsaturated zone, as calculated from vertical soil-gas concentration gradients, combined with stoichiometry to obtain two degradation rates in hydrocarbon mass per water table surface area per time. Values of 0.385 gram per m² per day and 0.52 gram per m² per day (based upon oxygen data) and 0.056 gram per m² per day and 0.12 gram per m² per day (based upon carbon dioxide data) were calculated at a field site with dissolved fuel contamination. This result of lower values from ground-air carbon dioxide concentrations is consistent with a significant fraction of the carbon dioxide produced being lost to the aqueous phase. Based upon a single-stage equilibrium phase-transfer model, gas/water volume ratios of 0.02 and 0.2 for the capillary fringe were calculated. Groundwater carbon dioxide fugacities and soil-gas carbon dioxide concentrations were used at the two locations and a third to determine whether the source of elevated soil carbon dioxide concentrations were unsaturated-zone hydrocarbon degradation or a saturated-zone process. This technique has potential applicability in setting risk-based remedial criteria and in allowing inclusion of the contribution of in situ degradation in remedial design. This can result in major remedial cost savings.     

Health Effects of Fine Particulate Air Pollution: Lines that Connect

Abstract

Efforts to understand and mitigate the health effects of particulate matter (PM) air pollution have a rich and interesting history. This review focuses on six substantial lines of research that have been pursued since 1997 that have helped elucidate our understanding about the effects of PM on human health. There has been substantial progress in the evaluation of PM health effects at different time-scales of exposure and in the exploration of the shape of the concentration-response function. There has also been emerging evidence of PM-related cardiovascular health effects and growing knowledge regarding interconnected general pathophysiological pathways that link PM exposure with cardiopulmonary morbidity and mortality. Despite important gaps in scientific knowledge and continued reasons for some skepticism, a comprehensive evaluation of the research findings provides persuasive evidence that exposure to fine particulate air pollution has adverse effects on cardiopulmonary health. Although much of this research has been motivated by environmental public health policy, these results have important scientific, medical, and public health implications that are broader than debates over legally mandated air quality standards.