Facilitating brownfields transactions using Triad and environmental insurance

A significant hindrance to reuse of brownfields properties is the risk associated with redevelopment,specifically the uncertainty associated with environmental cleanup. This article explores an approach tomanaging environmental risk through a combination of risk quantification, environmental insurance, and theTriad Approach to site sampling and data interpretation. The expected costs of environmental liabilities areestimated using the Marsh Peer ReviewSM risk quantification process that employs statistical techniques andhighly experienced technical staff. The outputs of the process indicate premiums and attachment points forinsurance products, but they also point to “critical uncertainties” that drive the insurancepremiums. Insurance premiums are often linked to site delineation deficiencies, such as the magnitude ofimpacted soil or the size of a groundwater plume. The Triad Approach is an integrated site characterizationprocess developed by the Environmental Protection Agency that combines systematic planning, dynamic or adaptivefield decision making and field analytical methods (FAMs). The real‐time data produced by FAMsallow for in‐field resolution of uncertainty about sample location, which in turn provides morerepresentative delineation of contaminant distribution. The trade‐off of using slightly less accuratebut substantially lower cost FAMs is an increase in sampling frequency or density, thereby reducing the risk ofincomplete detection or delineation while yielding a “data set” that is more powerful than fewerindividual data points analyzed through traditional methods. Employing the Triad Approach to analyze the“critical uncertainties” identified in the Peer Review Process can impact insurance premiums andallow for better terms of coverage. The combination of using the Triad Approach and environmental insuranceproducts can lead to more predictable and profitable Brownfield transactions. © 2003 Wiley Peridicals,Inc.     

Accelerating environmental cleanup at DOE sites: Monitored natural attenuation/enhanced attenuation—A basis for a new paradigm

The U.S. Department of Energy is conducting a project to accelerate remediation through the use of monitored natural attenuation and enhanced attenuation for chlorinated ethenes in soils and groundwater. Better monitoring practices, improved scientific understanding, and an advanced regulatory framework are being sought through a team effort that engages technology developers from academia, private industry, and government laboratories; site cleanup managers; stakeholders; and federal and state regulators. The team works collaboratively toward the common goals of reducing risk, accelerating cleanup, reducing cost, and minimizing environmental disruption. Cutting‐edge scientific advances are being combined with experience and sound environmental engineering in a broadly integrated and comprehensive approach that exemplifies socalled “third‐generation R&D.” The project is potentially a model for other cleanup activities. © 2004 Wiley Periodicals, Inc.     

Nature,frequency, and cost of environmental remediation at onshore oil and gas exploration and production sites

This article quantifies the nature, frequency, and cost of environmental remediation activities for onshore oil and gas operations, as determined from over 4,100 environmental remediation cases in Texas, Kansas, New Mexico, and Colorado. For the purpose of this article, “remediation'' refers to cleanup efforts that entail longer‐term site characterization, monitoring, and remedial action beyond the initial spill cleanup or emergency response stage. In addition, data are also presented regarding short‐term spill cleanup activities in two of the four states. © 2011 Wiley Periodicals, Inc.     

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.     

Rocky Flats,plutonium, and controversy: Citizen activists provide institutional memory

The U.S. Atomic Energy Commission (AEC) selected Rocky Flats, east of the Rocky Mountains, as the site to fabricate “plutonium pits,” triggers for H‐bombs, and operations began in 1952. Press reports revealed the plant's connection to atomic weapons in 1956. Denver is downwind and “downslope” by about 16 miles. As western suburbs moved closer to Rocky Flats over time, plant accidents sent plutonium and other contaminants offsite. In 1989, armed agents of the U.S. Environmental Protection Agency (EPA) and Federal Bureau of Investigation raided the facility, and the plant operator, Rockwell International, subsequently pleaded guilty to criminal environmental violations. By this time, the U.S. Department of Energy had inherited responsibility for Rocky Flats and atomic weapons production. In 1993, the primary mission at Rocky Flats became cleanup of contamination from plutonium and other hazardous substances. Under Energy's “Accelerated Cleanup” plan, remediation was certified complete in 2005 by the Department's cleanup regulators, EPA, and the Colorado Department of Public Health. But planned uses for the “buffer zone” around the facility's central industrial area, and for off‐site areas continued to generate public controversy. This article examines the controversy and reports on general “stewardship” concepts for long‐term waste management.     

Arsenic and thallium data in environmental samples: Fact or fiction?

Matrix effects may increasingly lead to erroneous environmental decisions as regulatory limits or risk‐based concentrations of concern for trace metals move lower toward the limits of analytical detection. A U.S. Environmental Protection Agency Office of Technical Standards Alert estimated that environmental data reported using inductively coupled plasma spectrometry (ICP‐AES) has a false‐positive rate for thallium of 99.9 percent and for arsenic of 25 to 50 percent. Although this does not seem to be widely known in the environmental community, using three case studies, this article presents data in environmental samples that demonstrate severe matrix effects on the accuracy of arsenic and thallium results. Case Study 1 involves soil results with concentrations that approached or exceeded the applicable regulatory soil cleanup objectives of 13 mg/kg for arsenic and 2 mg/kg for thallium. Reanalysis using ICP coupled with a mass spectrometer (ICP‐MS) confirmed all thallium results were false positives and all arsenic results were biased high, concluding no action was required for soil remediation. Case Study 2 involves groundwater results for thallium at a Superfund site, where thallium was detected in groundwater up to 21.6 μ g/L using ICP‐AES. Reanalysis by ICP‐MS reported thallium as nondetect below the applicable regulatory level in all samples. ICP‐MS is usually a more definitive and accurate method of analysis compared to ICP‐AES; however, this is not always the case, as we demonstrate in Case Study 3, using data from groundwater samples at an industrial site. Through a weight‐of‐evidence approach, it is demonstrated that although method quality control results were acceptable, interferences in some groundwater samples caused biased high results for arsenic using ICP‐MS, which were significantly lower when reanalyzed using hydride generation atomic fluorescence spectrometry. Causes of these interference effects and conclusions from the three case studies to obtain accurate metal data for site assessment, risk characterization, and remedy selection are discussed. © 2010 Wiley Periodicals, Inc.     

Characterizing a Brownfields recreational reuse scenario using the Triad Approach–Assunpink Creek Greenways project

Since the early 1990s the U.S. government has been developing and implementing public policies that advance the redevelopment of brownfields, and the recent passage of the Small Business Liability Relief and Brownfields Revitalization Act (SBLRBRA) will significantly advance efforts to integrate environmental contamination mitigation and redevelopment. Experience has demonstrated that successful redevelopment requires the collection, analysis, and interpretation of environmental data in a timely and cost‐effective manner in order to allow developers and lenders to efficiently use cleanup resources, develop response strategies that integrate cleanup with redevelopment, and support meaningful outreach to involved stakeholders. Recent advances in the science and technology of site characterization hold the promise of improved site characterization outcomes while saving time and money. One such advancement, the Triad Approach, combines systematic up‐front planning with the use of a dynamic field investigation process and the generation of real time data to allow in‐field decision making on sample location selection. This article describes an application of the Triad Approach to redevelopment of an urban greenway in Trenton, New Jersey. The Triad Approach, initiated through a partnership between the City of Trenton, New Jersey Department of Environmental Protection, New Jersey Institute of Technology, and the U.S. Environmental Protection Agency, demonstrated that this approach could accelerate the characterization of the 60‐acre, 11‐parcel project area. Environmental issues that were solved using the Triad Approach included the delineation of the extent of historic fill, determination of no further action for several areas of concern, detailed investigation of specific impacted areas and the acquisition of sufficient data to allow the city to make important decisions regarding remediation costs and property acquisition. © 2003 Wiley Periodicals, Inc.     

A Practical Guide to Estimating Cleanup Costs

Cost estimates are frequently developed to evaluate hazardous‐waste‐site cleanup options in support of a site investigation, remedy selection decision, or assessment of environmental liabilities. The accuracy of the cost estimate depends largely on the quality of the information available at the time it is prepared. This article presents a practical guide to developing a cleanup cost estimate. It includes information on how to document assumptions, use the latest technical resources, and perform basic adjustments to account for uncertainty and the time value of money. The content is based upon a recent guidance document issued by the U.S. Environmental Protection Agency and U.S. Army Corps of Engineers entitled A Guide to Developing and Documenting Cost Estimates during the Feasibility Study (USEPA, 2000). © 2001 John Wiley & Sons, Inc.     

The Triad approach: A catalyst for maturing remediation practice

Many individual scientific and technical disciplines contribute to the multidisciplinary field of remediation science and practice. Because of the relative youth of this enterprise, disciplinary interests sometimes compete and conflict with the primary goal of achieving protective, cost‐effective, efficient projects. Convergence of viewpoints toward a more mature, common vision is needed. In addition, cleanup programs are changing under the influence of Brownfields initiatives and the needs of environmental insurance underwriters. Investigations and cleanups increasingly need to be affordable, yet transparent and defensible. Disciplinary goals and terminology need to better reflect real‐world site conditions while being more supportive of project needs. Yet, technical considerations alone will not ensure project success; better integration of human factors into project management is also required. The Triad approach is well placed to catalyze maturation of the remediation field because it emphasizes (1) a central theme of managing decision uncertainty; (2) unambiguous technical communications; (3) shortened project life‐cycles and multidisciplinary interactions that rapidly build professional expertise and provide feedback to test and perfect programmatic and field practices; and (4) concepts from “softer” sciences (such as economics, cognitive psychology, and decision theory) to capture important human factors. Triad pushes the cleanup industry toward an integrated, practical, second‐generation paradigm that can successfully manage the complexities of today's cleanup projects. © 2004 Wiley Periodicals, Inc.     

Enhanced attenuation: Its place in the remediation of chlorinated solvents

The development and regulatory acceptance of monitored natural attenuation (MNA) as a remedial strategy has forever changed the field of environmental cleanup. MNA is continuing to develop but it is challenged by a lack of a clear definition for the appropriate application of the MNA strategy. This challenge has resulted in the lack of a significant record of restoration and site closure. Environmental professionals face challenges in providing guidance that addresses how to manage these sites when technologies, performance monitoring, and even environmental conditions are subject to further development, refinement, and/or altered perspectives. As our experience and institutional knowledge grows around the implementation of MNA, we have the opportunity to develop “second‐generation” management tools and procedures for optimizing sites utilizing MNA as a part of a comprehensive site management plan. This opportunity is the focus of the Enhanced Attenuation: Chlorinated Organics (EACO) Team of the Interstate Technology Regulatory Council (ITRC). The development of the “second‐generation” tools/procedures has included defining EA and evaluating, through the use of a national survey of state regulators, the experience with MNA and interest in EA. The results of these two efforts formed the basis for developing a framework that provides a “bridge” from active treatment to MNA. © 2007 Wiley Periodicals, Inc.     

Treatment technologies for 1,4‐Dioxane: Fundamentals and field applications

1,4‐Dioxane is a synthetic industrial chemical frequently found at contaminated sites where 1,1,1‐trichloroethane was used for degreasing. It is a probable human carcinogen and has been found in groundwater at sites throughout the United States. The physical and chemical properties and behavior of 1,4‐dioxane create challenges for its characterization and treatment. It is highly mobile and has not been shown to readily biodegrade in the environment. In December 2006, the U.S. Environmental Protection Agency's Office of Superfund Remediation and Technology Innovation (OSRTI) prepared a report titled “Treatment Technologies for 1,4‐Dioxane: Fundamentals and Field Applications.” The report provides information about the chemistry of dioxane, cleanup goals, analytical methods, available treatment technologies, and site‐specific treatment performance data. The information may be useful to project managers, technology providers, consulting engineers, and members of academia faced with addressing dioxane at cleanup sites or in drinking water supplies. This article provides a synopsis of the US EPA report, which is available at http://cluin.org/542R06009 . © 2007 Wiley Periodicals, Inc.     

Issues in monitoring hazardous chemicals in stormwater runoff/discharges from superfund and other hazardous chemical sites

Deficiencies in design and execution render stormwater‐runoff monitoring programs for many hazardous chemical sites inadequate for assessing the potential environmental quality and public health impacts of chemicals in the runoff. Two pervasive problems are the use of analytical methods that are inadequate for measuring certain hazardous chemicals at potentially hazardous concentrations, and the application of “criteria/standards” that are inappropriate for evaluating the environmental/public health impacts of chemicals. These concerns are most notable for carcinogens and chemicals that bioaccumulate in edible aquatic organisms, including arsenic, chromium, beryllium, mercury, dioxins, organochlorine pesticides (such as DDT), and polychlorinated biphenyls; unrecognized pollutants; and nanomaterials. In order to appropriately evaluate whether the runoff/discharge from a hazardous chemical site is a threat to human health, the analytical methods must be sufficiently sensitive in critical concentration ranges; sampling regimens need to be sufficiently rigorous to provide reliable characterization of the content of the runoff, receiving water, and, for bioaccumulatable chemicals, levels in edible organisms in receiving water. Proper sampling and analysis will then provide data to enable the appropriate criteria/standards to be applied. © 2010 Wiley Periodicals, Inc.     

Financing remediation by delisting and selling clean portions of affected property

It is an established fact that property owners can face significant liabilities as a result of an on-site environmental contamination problem. This paper outlines a successful, innovative remedial strategy that, in conjunction with agency negotiation, afforded a property owner minimal financial expenditure and, at the same time, facilitated property cleanup and reuse. The strategy includes the delisting and sale of “clean” portions of the property to obtain the finances necessary to remediate the remaining “impacted” portion of the property. Previous investigations performed by EPA indicate the affected area to be a five to seven acre area located in the northeast portion of the property. Since a portion of the property was affected, significant restrictions for long-term use were placed on the entire property. A summary of environmental data generated for the property was prepared and submitted to the agency. This data summary communicated a strategy which was developed to delist and sell the “clean” portion of the property and to use the proceeds to clean up the affected property. To accomplish this, several tasks were outlined, including work-plan preparation and submittal, data collection, and interim remedial activities. In addition, a risk assessment is planned to identify potential threats to receptors downgradient of the impacted areas. This strategy allows the owner of an environmentally distressed property to use financial assets of the property to facilitate an acceptable solution with both regulatory agencies and the surrounding community.     

Triad case study: Marine Corps Base Camp Pendleton

The U.S. Navy Public Works Center (PWC) Environmental Department, San Diego, California, is home to the Navy West Coast Site Characterization and Analysis Penetrometer System (SCAPS). SCAPS has been extensively used at several Navy sites since 1995 to provide real‐time, high‐density data sets. The U.S. Environmental Protection Agency's Triad approach provided an ideal framework for optimizing the use of the Navy SCAPS during a volatile organic compound (VOC) source investigation at Installation Restoration Site 1114 at Marine Corps Base Camp Pendleton. All three elements of Triad—systematic planning, dynamic work strategy, and use of real‐time measurement tools—were implemented to manage decision uncertainty and expedite the site management process. The investigation was conducted using the Navy SCAPS, outfitted with a cone penetrometer, membrane interface probe, and a direct sampling ion trap mass spectrometry detector, which allowed for real‐ time collection of over 690 feet of continuous lithologic information and VOC concentration data. These data were used collaboratively with 24‐hour turnaround US EPA 8260B VOC groundwater results from temporary direct‐ push wells to support the conclusion of a limited source area. Implementation of the Triad approach for this investigation provided an expedited high‐density data set and a refined conceptual site model (CSM) in real time that resulted in cost savings estimated at $2.5M and reduction of the site characterization and cleanup schedule by approximately three years. This project demonstrates how the US EPA's Triad approach can be applied to streamline the site characterization and cleanup process while appropriately managing decision uncertainty in support of defensible site decisions. © 2004 Wiley Periodicals, Inc.     

Transuranic waste remediation in Idaho: Pit 9, failed contracts,and lawsuits

The U.S. Department of Energy (US DOE) remediation responsibilities include its Idaho National Laboratory. In 1989, the U.S. Environmental Protection Agency placed the Idaho site on its National Priority List for environmental cleanup. The site's contamination legacy from operations included inactive reactors and other structures, spent nuclear fuel, high‐level liquid radioactive wastes, calcined radioactive wastes, and transuranic wastes. Documents governing cleanup include a 1995 Settlement Agreement between the US DOE and the US Navy as responsible parties, and the State of Idaho. The Subsurface Disposal Area contains buried transuranic wastes, lies above the East Snake River Plain Aquifer, and could be the “site's most nettlesome cleanup issue,” according to an outside observer. This article describes the technical and legal difficulties that have been encountered in remediating this area. © 2010 Wiley Periodicals, Inc.     

Perils of categorical thinking: “Oxic/anoxic” conceptual model in environmental remediation

Given ambient atmospheric oxygen concentrations of about 21 percent (by volume), the lower limit for reliable quantitation of dissolved oxygen concentrations in groundwater samples is in the range of 0.1–0.5 mg/L. Frameworks for assessing in situ redox condition are often applied using a simple two‐category (oxic/anoxic) model of oxygen condition. The “oxic” category defines the environmental range in which dissolved oxygen concentrations are clearly expected to impact contaminant biodegradation, either by supporting aerobic biodegradation of electron‐donor contaminants like petroleum hydrocarbons or by inhibiting anaerobic biodegradation of electron‐acceptor contaminants like chloroethenes. The tendency to label the second category “anoxic” leads to an invalid assumption that oxygen is insignificant when, in fact, the dissolved oxygen concentration is less than detection but otherwise unknown. Expressing dissolved oxygen concentrations as numbers of molecules per volume, dissolved oxygen concentrations that fall below the 0.1 mg/L field detection limit range from 1 to 10¹⁷ molecules/L. In light of recent demonstrations of substantial oxygen‐linked biodegradation of chloroethene contaminants at dissolved oxygen concentrations well below the 0.1–0.5 mg/L field detection limit, characterizing “less than detection” oxygen concentrations as “insignificant” is invalid. © 2012 Wiley Periodicals, Inc.     

A data integration framework to support Triad projects

Cost‐effective and efficient site remediation and scientifically defensible decisions require site characterizations that are representative of site conditions. The Triad conceptual site model (CSM) is at the center of a continually improving site characterization process that begins during systematic planning and ends after the last data are developed. To gain the full benefit and greatest cost‐effectiveness, the process of CSM refinement should be performed in real time. Thus, the use of collaborative data is critical for evolving and maturing the CSM. In the field, through the use of all available data that are of known quality, a skilled and experienced field team can collect sufficient site information to mature the CSM in a timely manner. To facilitate the planning and execution of such a process, an easily understandable framework is needed to structure data quality that supports scientifically defensible decisions and efficient projects. This article explores such a framework. © 2004 Wiley Periodicals, Inc.     

You Know Your Environmental Contractor Is Out of Control When…

Far too often private industry is caught in situations where they become responsible for environmental characterization and remediation projects. The processes involved in successfully completing such tasks may be foreign to the responsible industry. In such cases, an environmental contractor is hired to perform the necessary work. While many environmental contractors claim a high level of ethics and customer orientation, the very essence of their jobs should make the responsible industrial client wary. Far too often, environmental characterizations and remediations become too drawn out and costly. Far too often, environmental contractors need “just a little more data” to complete otherwise simple tasks. To guard against the phenomenon of “never-ending environmental work,” responsible industrial clients that do not have environmental expertise on their staff would do well to retain a senior level independent environmental contractor to watch out for the best interests of the responsible industry. While the hiring of a contractor to watch a contractor may seem redundant and cost inefficient, the truth of the matter is the exact opposite. By bringing in an expert in environmental characterization and remediation, the responsible industrial client essentially hires another technical employee. It is best to hire this person as a member of the company to avoid additional overhead costs. If such an “environmental guardian” cannot be hired or found, then the responsible industrial client must learn to recognize the warning signs of an environmental characterization or remediation project that is out of control and should be stopped and regrouped. These warning signs become more apparent as time goes on (and money is spent). Having an experienced independent environmental contractor “look over the shoulder” of another contractor is just good business sense. One could say that it is the “potentially responsible party's” (PRP's) right to a second opinion.     

Cost estimating of the closure/post-closure phase

The U.S. Department of Energy (DOE) is beginning major environmental restoration projects of both active and inactive sites throughout the United States. The problems at the sites include contaminated soils, groundwater and surface waters, structures, and old waste disposal areas. IT Corporation, under the direction of the Office of Independent Cost Estimating (OICE) for DOE, developed a list of environmental problems at the sites and probable cleanup technologies and techniques that could be used. Estimated unit costs were then developed for these cleanup technologies, using available data and references. Some procedures developed were common to many or all cleanup projects. These included site characterization, remedial investigation (RI), feasibility studies (FS), and the closure/post-closure phase. The article will focus on cost estimating of the closure/post-closure phase of a cleanup project. The cost data provided are for budget level or check estimates. Site-specific conditions as well as items peculiar to the environmental industry, such as governmental regulations and community relations, can influence both the cost and duration of a cleanup project.     

Advanced site diagnostic tool 3D‐CSIA for in situ remediation

In situ remediation is inherently considered “green remediation.” The mechanisms of destruction by in situ technologies, however, are often unseen and not well understood. Further, physical effects of amendment application affect concentration data in an identical manner as the desired reactive mechanism. These uncertainties have led to the weight‐of‐evidence approach when proving viability: multiple rounds of data collection, bench studies, pilot studies, and so on. Skipping these steps has resulted in many failed in situ applications. Traditional assessment data are often tangential to the desired information (e.g., “Is contaminant being destroyed or just being pushed around and diluted?” and “What is the mechanism of the destruction and can it be monitored directly?”). An advanced site diagnostic tool, “Three‐Dimensional Compound Specific Stable Isotope Analysis” (3D‐CSIA), can assess the viability of in situ technologies by providing definitive data on contaminant destruction that are not concentration‐related. The 3D‐CSIA tool can also locate source zones and apportion remediation cost by identifying plumes of different isotope signatures and fractionation trends. Further, use of the 3D‐CSIA tool allows remediation professionals to evaluate effectiveness of treatment and make better decisions to expedite site closure and minimize costs. This article outlines the fundamentals of advanced site diagnostic tool 3D‐CSIA in detail, and its benefit is highlighted through a series of case studies at chlorinated solvent–contaminated sites. © 2010 Wiley Periodicals, Inc.