PFAS Experts Symposium: Statements on regulatory policy,chemistry and analytics,toxicology, transport/fate,and remediation for per‐ and polyfluoroalkyl substances (PFAS) contamination issues

Sixty leading members of the scientific, engineering, regulatory, and legal communities assembled for the PFAS Experts Symposium in Arlington, Virginia on May 20 and 21, 2019 to discuss issues related to per‐ and polyfluoroalkyl substances (PFAS) based on the quickly evolving developments of PFAS regulations, chemistry and analytics, transport and fate concepts, toxicology, and remediation technologies.  The Symposium created a venue for experts with various specialized skills to provide opinions and trade perspectives on existing and new approaches to PFAS assessment and remediation in light of lessons learned managing other contaminants encountered over the past four decades. The following summarizes several consensus points developed as an outcome of the Symposium:

• Regulatory and policy issues: The response by many states and the US Environmental Protection Agency (USEPA) to media exposure and public pressure related to PFAS contamination is to relatively quickly initiate programs to regulate PFAS sites. This includes the USEPA establishing relatively low lifetime health advisory levels for PFAS in drinking water and even more stringent guidance and standards in several states. In addition, if PFAS are designated as hazardous substances at the federal level, as proposed by several Congressional bills, there could be wide‐reaching effects including listing of new Superfund sites solely for PFAS, application of stringent state standards, additional characterization and remediation at existing sites, reopening of closed sites, and cost renegotiation among PRPs.
• Chemistry and analytics: PFAS analysis is confounded by the lack of regulatory‐approved methods for most PFAS in water and all PFAS in solid media and air, interference with current water‐based analytical methods if samples contain high levels of suspended solids, and sample collection and analytical interference due to the presence of PFAS in common consumer products, sampling equipment, and laboratory materials.
• Toxicology and risk: Uncertainties remain related to human health and ecological effects for most PFAS; however, regulatory standards and guidance are being established incorporating safety factors that result in part per trillion (ppt) cleanup objectives. Given the thousands of PFAS that may be present in the environment, a more appropriate paradigm may be to develop toxicity criteria for groups of PFAS rather than individual PFAS.
• Transport and fate: The recalcitrance of many perfluoroalkyl compounds and the capability of some fluorotelomers to transform into perfluoroalkyl compounds complicate conceptual site models at many PFAS sites, particularly those involving complex mixtures, such as firefighting foams. Research is warranted to better understand the physicochemical properties and corresponding transport and fate of most PFAS, of branched and linear isomers of the same compounds, and of the interactions of PFAS with other co‐contaminants such as nonaqueous phase liquids. Many PFAS exhibit complex transport mechanisms, particularly at the air/water interface, and it is uncertain whether traditional transport principles apply to the ppt levels important to PFAS projects. Existing analytical methods are sufficient when combined with the many advances in site characterization techniques to move rapidly forward at selected sites to develop and test process‐based conceptual site models.
• Existing remediation technologies and research: Current technologies largely focus on separation (sorption, ion exchange, or sequestration). Due to diversity in PFAS properties, effective treatment will likely require treatment trains. Monitored natural attenuation will not likely involve destructive reactions, but be driven by processes such as matrix diffusion, sorption, dispersion, and dilution.

The consensus message from the Symposium participants is that PFAS present far more complex challenges to the environmental community than prior contaminants. This is because, in contrast to chlorinated solvents, PFAS are severely complicated by their mobility, persistence, toxicological uncertainties, and technical obstacles to remediation—all under the backdrop of stringent regulatory and policy developments that vary by state and will be further driven by USEPA. Concern was expressed about the time, expense, and complexity required to remediate PFAS sites and whether the challenges of PFAS warrant alternative approaches to site cleanups, including the notion that adaptive management and technical impracticability waivers may be warranted at sites with expansive PFAS plumes. A paradigm shift towards receptor protection rather than broad scale groundwater/aquifer remediation may be appropriate.     

A Slice of Guidance Provides Some Insight to Addressing Contaminated Sediments

The U.S. Environmental Protection Agency (EPA) has issued guidance to improve cleanup risk management decisions at sites involving contaminated sediments. The guidance is titled Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites and is important because sediment cleanup decisions are often very technical and complex. While the guidance is not a step‐by‐step “how to” document, it does provide the framework for risk‐based decision making and national consistency. Although it does not answer the more technical questions associated with remediation, it will likely provide site managers with greater certainty related to their decisions and help determine what questions need to be asked for many complex issues. Additional and forthcoming EPA reports, seminars, and products will be useful in building upon this framework. This article provides an overview of the risk management principles presented in the guidance. © 2002 Wiley Periodicals, Inc.     

Removal,Handling, and Thermal Desorption Treatment Techniques for Manufactured Gas Plant Wastes

Due to the nature of contamination typically found at former MGP (manufactured gas plant) sites, excavation and thermal desorption of MGP wastes has proven to be an effective method for the remediation of MGP‐contaminated soil. The use of on‐site thermal desorption enables MGP sites to be quickly remediated at a low cost. Tar pits, holders, and other underground storage structures typically contain coal tar residuals and waste from former operations, and the areas around these structures are often significantly contaminated. Thus, excavation techniques, odor and vapor management, and material preparation for the treatment method are important factors to consider when developing a site remediation strategy. This article reviews typical excavation and handling methods associated with the remediation of former MGP sites and discusses the treatment of MGP wastes using on‐site thermal desorption technology. © 2001 John Wiley & Sons, Inc.     

Comparing the Adoption of Contaminated Land Remediation Technologies in the United States,United Kingdom,and China

In many locations across the world, land contamination poses a serious threat to human health and the wider environment. For instance, a report published on April 17, 2014, revealed that China now has 16.1 percent of its land contaminated by various organic and inorganic contaminants, posing a range of challenges from human health risk to food security. The innovation and adoption of suitable remediation technologies is critical for solving land contamination issues. However, little is known about the pattern of remediation technology adoption, as well as its determining factors. This study uses a questionnaire survey in the United States, United Kingdom, and China to examine the spatial variation of remediation technology adoption. It further explores the temporal trend of remediation technology adoption using secondary data from the U.S. Superfund program. The study identified significant differences in remediation technology adoption among these countries, which are attributed to the different environmental, social, economic, and regulatory contexts. It is argued that the full implications of remediation technology adoption to sustainable development should be further studied, and policy instruments should be designed accordingly to promote those remediation technologies that align the best with long‐term sustainability. Technology developers may also use these implications to adjust their research and development priorities. © 2014 Wiley Periodicals, Inc.     

Incorporating ecology and ecological risk into long‐term stewardship on contaminated sites

The long‐term management of environmental contamination will be a major activity at many sites in the foreseeable future. While human health issues often drive decisions about cleanup, restoration, and long‐term stewardship, ecological considerations are also major driving forces and are of paramount importance to the public. Incorporation of ecological considerations into decisions about environmental protection, both short term and long term, requires (1) understanding public perceptions of ecological values, including aesthetics and existence values, (2) understanding contamination issues within a context of the structure and functioning of ecosystems, (3) developing bioindicators of ecological health (including human), (4) developing indicators of ecosystem functioning, and (5) developing and implementing a biomonitoring plan before, during, and after remediation so that adverse effects can be ascertained before they become irreversible. Both remediation/restoration and long‐term stewardship goals must be informed by public policy mandates that include public participation and healthy human and ecological systems. This article examines these issues as they relate to cost‐effective, long‐term protection of human and ecological health on contaminated lands. © 2002 Wiley Periodicals, Inc.     

End‐state land uses,sustainably protective systems,and risk management: A challenge for remediation and multigenerational stewardship

This article discusses creating a sustainably protective engineered and human management system in perpetuity for sites with long‐lived radiological and chemical hazards. This is essential at this time because the federal government is evaluating its property as assets and attempting to reduce its holdings, while seeking to assure that health and ecosystems are not put at risk. To assist those who have a stake in the remediation, management, and stewardship of these and analogous privately owned sites, this article discusses current end‐state planning by reviewing the federal government's accelerated efforts to reduce its footprint and how those efforts relate to sustainability. The article also provides a list of questions organized around six elements of risk management and primary, secondary, and tertiary disease and injury prevention. Throughout the article, the U.S. Department of Energy (DOE) is used as an example of an organization that seeks to reduce its footprint, manage its budget, and be a steward of the sites that it is responsible for. However, the approach and questions are appropriate for land controlled by the Department of Defense (DOD), the General Services Administration (GSA), and other public and private owners of sites with residual contamination. © 2005 Wiley Periodicals, Inc.     

Comparing PFAS to other groundwater contaminants: Implications for remediation

Established groundwater contaminants such as chlorinated solvents and hydrocarbons have impacted groundwater at hundreds of thousands of sites around the United States and have been responsible for multibillion dollar remediation expenditures. An important question is whether groundwater remediation for the emerging contaminant class comprised of per‐ and polyfluoroalkyl substances (PFAS) will be a smaller, similar, or a larger‐scale problem than the established groundwater contaminants. A two‐pronged approach was used to evaluate this question in this paper. First, nine quantitative scale‐of‐remediation metrics were used to compare PFAS to four established contaminants: chlorinated solvents, benzene, 1,4‐dioxane, and methyl tert‐butyl ether. These metrics reflected the prevalence of the contaminants in the U.S., attenuation potential, remediation difficulty, and research intensity. Second, several key challenges identified with PFAS remediation were evaluated to see similar situations (qualitative analogs) that have been addressed by the remediation field in the past. The results of the analysis show that four out of nine of the evaluated quantitative metrics (production, number of potential sites, detection frequency, required destruction/removal efficiency) indicate that the scale of PFAS groundwater remediation may be smaller compared to the current scale of remediation for conventional groundwater contaminants. One attenuation metric, median plume length, suggests that overall PFAS remediation could pose a greater challenge compared to hydrocarbon sites, but only slightly larger than chlorinated volatile organic compounds sites. The second attenuation metric, hydrophobic sorption, was not definitive regarding the potential scale of PFAS remediation. The final three metrics (regulatory criteria, in‐situ remediation capability, and research intensity) all indicate that PFAS remediation might end up being a larger scale problem than the established contaminants. An assessment of the evolution of groundwater remediation capabilities for established contaminants identified five qualitative analogs for key PFAS groundwater remediation issues: (a) low‐level detection analytical capabilities; (b) methods to assess the risk of complex chemical mixtures; (c) nonaqueous phase dissolution as an analog for partitioning, precursors, and back diffusion at PFAS sites; (d) predictions of long plume lengths for emerging contaminants; and (e) monitored natural attenuation protocols for other non‐degrading groundwater contaminants. Overall the evaluation of these five analogs provided some comfort that, while remediating the potential universe of PFAS sites will be extremely challenging, the groundwater community has relevant past experience that may prove useful. The quantitative metrics and the qualitative analogs suggest a different combination of remediation approaches may be needed to deal with PFAS sites and may include source control, natural attenuation, in‐situ sequestration, containment, and point‐of‐use treatment. However, as with many chlorinated solvent sites, while complete restoration of PFAS sites may be uncommon, it should be possible to prevent excessive exposure of PFAS to human and ecological receptors.     

Integrating the Social Dimension in Remediation Decision‐Making: State of the Practice and Way Forward

Sustainable remediation guidance, frameworks, and case studies have been published at an international level illustrating established sustainability assessment methodologies and successful implementation. Though the terminology and indicators evaluated may differ, one common theme among international organizations and regulatory bodies is more comprehensive and transparent methods are needed to evaluate the social sphere of sustainable remediation. Based on a literature review and stakeholder input, this paper focused on three main areas: (1) status quo of how the social element of sustainable remediation is assessed among various countries and organizations; (2) methodologies to quantitatively and qualitatively evaluate societal impacts; and (3) findings from this research, including challenges, obstacles, and a path forward. In conclusion, several existing social impact assessment techniques are readily available for use by the remediation community, including rating and scoring system evaluations, enhanced cost benefit analysis, surveys/interviews, social network analysis, and multicriteria decision analysis. In addition, a list of 10 main social indicator categories were developed: health and safety, economic stimulation, stakeholder collaboration, benefits community at large, alleviate undesirable community impacts, equality issues, value of ecosystem services and natural resources, risk‐based land management and remedial solutions, regional and global societal impacts, and contributions to other policies. Evaluation of the social element of remedial activities is not without challenges and knowledge gaps. Identification of obstacles and gaps during the project planning process is essential to defining sustainability objectives and choosing the appropriate tool and methodology to conduct an assessment. Challenges identified include meaningful stakeholder engagement, risk perception of stakeholders, and trade‐offs among the various triple bottom line dimensions. ©2015 Wiley Periodicals, Inc.     

Approaches for assessing hazards and risks to workers and the public from contaminated land

Many public agencies and private entities are faced with assessing the risks to humans from contamination on their lands. The United States Department of Energy (US DOE) and Department of Defense are responsible for large holdings of contaminated land and face a long‐term and costly challenge to assure sustainable protectiveness. With increasing interest in the conversion of brownfields to productive uses, many former industrial properties must also be assessed to determine compatible future land uses. In the United States, many cleanup plans or actions are based on the Comprehensive Environmental Responsibility, Compensation, and Liability Act, which provides important but incomplete coverage of these issues, although many applications have tried to involve stakeholders at multiple steps. Where there is the potential for exposure to workers, the public, and the environment from either cleanup or leaving residual contamination in place, there is a need for a more comprehensive approach to evaluate and balance the present and future risk(s) from existing contamination, from remediation actions, as well as from postremediation residual contamination. This article focuses on the US DOE, the agency with the largest hazardous waste remediation task in the world. Presented is a framework extending from preliminary assessment, risk assessment and balancing, epidemiology, monitoring, communication, and stakeholder involvement useful for assessing risk to workers and site neighbors. Provided are examples of those who eat fish, meat, or fruit from contaminated habitats. The US DOE's contaminated sites are unique in a number of ways: (1) huge physical footprint size, (2) types of waste (mixed radiation/chemical), and (3) quantities of waste. Proposed future land uses provide goals for remediation, but since some contamination is of a type or magnitude that cannot be cleaned up with existing technology, this in turn constrains future land use options, requiring an iterative approach. The risk approaches must fit a range of future land uses and end‐states from leave‐in‐place to complete cleanup. This will include not only traditional risk methodologies, but also the assessment and surveillance necessary for stewards for long‐term monitoring of risk from historic and future exposure to maintain sustainable protectiveness. Because of the distinctiveness of DOE sites, application of the methodologies developed here to other waste site situations requires site‐specific evaluation © 2007 Wiley Periodicals, Inc.     

Application of the operating window concept to remediation‐option selection

An Erratum has been published for this article in Remediation 14(4) 2004, 141. The selection of remediation options for the management of unacceptable risks at contaminated sites is hindered by insufficient information on their performance under different site conditions. Therefore, there is a need to define “operating windows” for individual remediation options to summarize their performance under a variety of site conditions. The concept of the “operating window” has been applied as both a performance optimization tool and decision support tool in a number of different industries. Remediation‐option operating windows could be used as decision support tools during the “options appraisal” stage of the Model Procedures (CLR 11), proposed by the Environment Agency (EA) for England and Wales, to enhance the identification of “feasible remediation options” for “relevant pollutant linkages.” The development of remediation‐option operating windows involves: 1) the determination of relationships between site conditions (“critical variables”) and option performance parameters (e.g., contaminant degradation or removal rates) and 2) the identification of upper‐ and lower‐limit values (“operational limits”) for these variables that define the ranges of site conditions over which option performance is likely to be sufficient (the “operating window”) and insufficient (the “operating wall”) for managing risk. Some research has used case study data to determine relationships between critical variables and subsurface natural attenuation (NA) process rates. Despite the various challenges associated with the approach, these studies suggest that available case study data can be used to develop operating windows for monitored natural attenuation (MNA) and, indeed, other remediation options. It is envisaged that the development of remediation‐option operating windows will encourage the application of more innovative remediation options as opposed to excavation and disposal to landfill and/or on‐site containment, which remain the most commonly employed options in many countries. © 2004 Wiley Periodicals, Inc.     

Yardsticks to Integrate Risk Assessment,Risk Management,and Groundwater Remediation

Remediation of contaminated sites has focused largely on restoration of groundwater aquifers. Often the stated remedial goal is to achieve conditions allowing unrestricted use and unrestricted exposure. Such total groundwater cleanup has occurred at some sites, but is the exception rather than the rule. At the same time, significant effort occurs to perform risk assessments for potential exposure to contaminants in groundwater at sites, both before and after remediation. The logical synergy between risk assessment and remediation is for risk management to seek opportunities for optimal use of groundwater based upon realistic expectations of cleanup technologies and the relevant acceptable residual (postremediation) levels of contaminants. This article explores an approach to improve this synergistic relationship between risk assessment, risk management, and remediation for groundwater cleanups. ©2015 Wiley Periodicals, Inc.     

Managing contaminated sites and the role of domestic and international forums

Domestic and international cooperation in the field of contaminated‐site management has increased dramatically in the past decade. The expected benefits of this cooperation include the reduction of duplication in remediation efforts, the coordination of contaminated‐site research, improved synergy between various stakeholders, enhanced policy development, and better information dissemination and technology transfer. This article identifies and briefly discusses key domestic and international collaborations, partnerships, and networks relating to contaminated‐site management and remediation. Also provided is information on how the forums can be accessed. Common themes identified across the forums discussed in this article include (1) the development and demonstration of innovative technologies, (2) the use of risk assessment, (3) the use of toxicology, bioavailability, and ecotoxicity testing, and (4) the increasing need to find holistic approaches for managing contaminated sites, such as guaranteed remediation programs and transfer of environment liability, and the need for understanding implications of remediation financing mechanisms. © 2001 John Wiley & Sons, Inc.     

Remediation,land use,and risk at Hanford

U.S. Department of Energy (US DOE) remediation responsibilities include the Hanford site in Washington State. Cleanup is governed by the Tri‐Party Agreement (TPA) between the US DOE as the responsible party and the U.S. Environmental Protection Agency and Washington State Department of Ecology as joint regulators. In 2003, the US DOE desired to implement a “Risk‐Based End State” (RBES) policy at Hanford, with remediation measures driven by acceptable risk standards using exposure scenarios based on the 1999 Hanford Comprehensive Land‐Use Plan. Facing resistance from regulators and stakeholders, the US DOE solicited public input on its policy. This led to a Hanford Site End State Vision in 2005 and a commitment that the TPA would continue to control remediation. This article describes how regulator and public participation modified RBES to an end‐state vision. © 2010 Wiley Periodicals, Inc.     

Brownfield Sites Remediation Technology Overview,Trends, and Opportunities in China

Over decades of economic development, China's industrialization has led to significant environmental issues due to unregulated discharges into air, water, and soil. As cities continue to expand (i.e., urbanization trend) and awareness/concerns about environmental pollution rises, many industrial facilities along the edge of or within the city boundaries have been relocated or closed. This urbanization trend leaves behind idled and abandoned land that is contaminated from the former industrial activities and unregulated discharges. China released its first nationwide soil quality survey in April 2014, and the survey suggests that soil conditions in China represent a significant challenge. China has encouraged local engineering firms to demonstrate soil treatment technologies through pilot‐scale studies, but the outcomes of many demonstrations have not been promising due to the lack of remediation experience and underdeveloped technical guidelines that are needed to guide the remediation processes. During the past decade, some local soil remediation experience has been established, but it is limited for certain technologies that address their primary contaminants of concern: heavy metals and persistent organic pollutants. In 2014, national technical guidelines were published regarding environmental investigation, risk assessment, monitoring, and remediation; however, regulations and funding systems are still underdeveloped. Thus, the remediation processes that should maximize economic and environmental benefits are not streamlined. This article provides an overview of the latest regulatory developments, remediation technologies applied, technology trends, and market opportunities in China. The provided information aims to allow international remediation practitioners to better understand and appreciate this unique and emerging remediation market, which is growing fast, and to highlight the importance of developing a sustainable model that not only provides for cleanup of the environment but also supports economic development. ©2015 Wiley Periodicals, Inc.     

Choosing remediation and waste management options at hazardous and radioactive waste sites

This article discusses a process for finding insights that will allow federal agencies and environmental professionals to more effectively manage contaminated sites. The process is built around what Etzioni (1968) called mixed‐scanning, that is, perpetually doing both comprehensive and detailed analyses and periodically re‐scanning for new circumstances that change the decision‐making environment. The article offers a checklist of 127 items, which is one part of the multiple‐stage scanning process. The checklist includes questions about technology; public, worker, and ecological health; economic cost and benefits; social impacts; and legal issues. While developed for a DOE high‐level radioactive waste application, the decision‐making framework and specific questions can be used for other large‐scale remediation and management projects. © 2002 Wiley Periodicals, Inc.     

Ambient levels of PFOS and PFOA in multiple environmental media

Making remediation and risk management decisions for widely‐distributed chemicals is a challenging aspect of contaminated site management. The objective of this study is to present an initial evaluation of the ubiquitous, ambient environmental distribution of poly‐ and perfluoroalkyl substances (PFAS) within the context of environmental decision‐making at contaminated sites. PFAS are anthropogenic contaminants of emerging concern with a wide variety of consumer and industrial sources and uses that result in multiple exposure routes for humans. The combination of widespread prevalence and low screening levels introduces considerable uncertainty and potential costs in the environmental management of PFAS. PFAS are not naturally‐occurring, but are frequently detected in environmental media independent of site‐specific (i.e., point source) contamination. Information was collected on background and ambient levels of two predominant PFAS, perfluorooctane sulfonate and perfluorooctanoate, in North America in both abiotic media (soil, sediment, surface water, and public drinking water supplies) and selected biotic media (human tissues, fish, and shellfish). The background or ambient information was compiled from multiple published sources, organized by medium and concentration ranges, and evaluated for geographical trends and, when available, also compared to health‐based screening levels. Data coverage and quality varied from wide‐ranging and well‐documented for soil, surface water, and serum data to more localized and less well‐documented for sediment and fish and shellfish tissues and some uncertainties in the data were noted. Widespread ambient soil and sediment concentrations were noted but were well below human health‐protective thresholds for direct contact exposures. Surface water, drinking water supply waters (representing a combination of groundwater and surface water), fish and shellfish tissue, and human serum levels ranged from less than to greater than available health‐based threshold values. This evaluation highlights the need for incorporating literature‐based or site‐specific background into PFAS site evaluation and decision‐making, so that source identification, risk management, and remediation goals are properly focused and to also inform general policy development for PFAS management.     

Estimating Remediation and Contaminant Respiration Emissions for Alternatives Comparisons at Petroleum Spill Sites

Greenhouse gas emissions assessments for site cleanups typically quantify emissions associated with remediation and not those from contaminant biodegradation. Yet, at petroleum spill sites, these emissions can be significant, and some remedial actions can decrease this additional component of the environmental footprint. This article demonstrates an emissions assessment for a hypothetical site, using the following technologies as examples: excavation with disposal to a landfill, light nonaqueous‐phase liquid (LNAPL) recovery with and without recovered product recycling, passive bioventing, and monitored natural attenuation (MNA). While the emissions associated with remediation for LNAPL recovery are greater than the other considered alternatives, this technology is comparable to excavation when a credit associated with product recycling is counted. Passive bioventing, a green remedial alternative, has greater remedial emissions than MNA, but unlike MNA can decrease contaminant‐related emissions by converting subsurface methane to carbon dioxide. For the presented example, passive bioventing has the lowest total emissions of all technologies considered. This illustrates the value in estimating both remediation and contaminant respiration emissions for petroleum spill sites, so that the benefit of green remedial approaches can be quantified at the remedial alternatives selection stage rather than simply as best management practices. ©2015 Wiley Periodicals, Inc.     

Superfund site remediation by landfilling—overview of landfill design,operation, closure,and postclosure issues

This article discusses the appropriateness of using landfills as part of remediating hazardous chemical and Superfund sites, with particular emphasis on providing for true long‐term public health and environmental protection from the wastes and contaminated soils that are placed in the landfills. On‐site landfilling or capping of existing wastes is typically the least expensive approach for gaining some remediation of existing hazardous chemical/Superfund sites. The issues of the deficiencies in US EPA and state landfilling approaches discussed herein are also applicable to the landfilling of municipal and industrial solid “nonhazardous” wastes. These deficiencies were presented in part as “Problems with Landfills for Superfund Site Remediation” at the US EPA National Superfund Technical Assistance Grant Workshop held in Albuquerque, New Mexico, in February 2003. They are based on the author's experience in investigating the properties of landfill liners and the characteristics of today's landfills, relative to their ability to prevent groundwater pollution and to cause other environmental impacts. Discussed are issues related to both solid and hazardous waste landfills and approaches for improving the ability of landfills to contain wastes and monitor for leachate escape from the landfill for as long as the wastes in the landfill will be a threat. © 2004 Wiley Periodicals, Inc.     

California's Low‐Threat LUFT Site Closure Policy: Looking Forward

California's regulatory agencies have historically been at the forefront of national efforts to address environmental concerns. In 2012, California's agency for addressing leaking underground fuel tanks (LUFTs) adopted a policy that identifies low‐threat conditions warranting closure of an LUFT case. That development clearly fulfills the role of risk management in the risk assessment–risk management paradigm inherent in environmental remediation. It also encourages identification of additional categories of sites and other circumstances that are “low threat” to develop similar guidance on closure to apply to those sites. ©2015 Wiley Periodicals, Inc.     

Successful contracting based on candor,realism, and common goals

This article is intended to provide an overview of the issues involved in remediation contracting, from general principles of contract law and negotiation, to specific contract provisions of interest to the remediation community, to the practical consequences of including or not including these provisions on disputes arising under the contract. This article does not treat every potential issue arising in contracts concerning remediation, but hopefully it discusses many of these issues and provides an overview that will be helpful to the reader.