Trends In Regulatory Acceptance Of Risk-Based Cleanup Goals And Natural Attenuation For Site Closure

Since 1994, there has been a significant regulatory shift toward risk-based cleanup standards based on the site-specific risk of the more toxic and mobile compounds; namely, benzene, ethyl benzene, toluene, and xylene (BTEX). This regulatory shift has been accompanied by a growing acceptance of natural attenuation as an important component of petroleum site remediation. This article briefly reviews regulatory progress toward risk-based remediation and describes the successful application of risk-based corrective actions (RBCAs) at two fuel contaminated sites on Air Force installations. By developing site-specific cleanup goals, and combining natural attenuation, source reduction, and land use controls, innovative risk-based closure plans have been implemented on these sites.     

Using community relations to reduce costs during remediation projects

Almost everyone who has been involved in a site remediation project has seen schedules slip and costs escalate due to political pressure from the public or the press. While focusing on remediation technologies and containment techniques to control costs, many organizations have neglected a major cost driver—public opinion. This article examines community relations from the perspective of an organization trying to control costs during a site remediation project. It details the strong correlation between the cost of a site cleanup and the level of public dissatisfaction and provides an organization with specific strategies on how to use proven communications techniques to lower costs. Examination of several case studies is provided, including a study involving a site in which community representatives actively worked to reduce project costs. It is clear that any responsible cleanup must be protective of public health and the environment. But it is becoming increasingly apparent that wise allocation of available resources has a profound effect on the program's ability to ensure public and environmental safety. In many cases, it has been proven that some costly cleanups—for example, involving excavation—sometimes actually increase risk by creating an exposure pathway where none existed before. In turn, such cleanups waste resources that are needed elsewhere. The challenge in dealing with this complicated issue is to help stakeholders understand the true ramifications of the choices that are faced at each site. If these stakeholders feel uninformed, powerless, or excluded from the process, it is likely that they will be unable to enter a productive discussion. The community relations programs outlined in documents such as a Superfund guidance can be helpful in familiarizing the community with site-related issues and with gathering public input. These activities act as a baseline for the programs discussed in this article. However, existing programs are not focused on providing a strategic advantage in reaching cleanup solutions and balancing health and environmental considerations with economic considerations.     

Systematic planning for Triad projects

This article examines specific systematic planning steps that can be used for designing and controlling Triad projects. Triad work strategies act to limit decision uncertainty, expedite schedules to meet project milestones, and reduce costs associated with cleanup activities. As a result, the Triad approach is rapidly increasing in popularity. Good project planning has always been seen as the cornerstone of successful Triad projects. However, the specific steps in the systematic planning process have not been extensively published. Demands of Triad projects, which attempt to make maximum use of innovative technologies and sequencing of activities in a learn‐ as‐you‐go framework, put new demands on regulators and project managers alike. Specific activities and relationships are identified to assist project managers with dynamic work strategies and real‐time measurements to support improved decision making. These include: assembly of stakeholders, a core technical team, and key decisions; development and refinement of a site model; use of demonstrations of methods applicability; development of dynamic work strategies and project sequencing; real‐time data management assessment and presentation; and unitized procurement of technologies and services. © 2004 Wiley Periodicals, Inc.     

Developing Life‐Cycle Environmental Response Costs for Leaking Underground Storage Systems at Service Station Sites

Leaking underground storage tank systems at service stations have resulted in tens of thousands of petroleum releases and associated groundwater chemical plumes often extending hundreds of feet off‐site. Technical and engineering approaches to assess and clean up releases from underground tanks, product lines, and dispensers using technologies such as soil vapor extraction, air sparging, biostimulation, and monitored natural attenuation are well understood and widely published throughout the literature. This article summarizes life‐cycle environmental response costs typically encountered using site‐specific cost estimation or metric‐based cost categories considering the overall complexity of site conditions: (1) simple sites where response actions require smaller scale assessments and/or remediation and have limited or no off‐site impacts; (2) average sites where response actions require larger scale assessments and/or remediation typical of petroleum releases; (3) complex sites where response actions require greater on‐site and/or off‐site remediation efforts; and (4) mega sites where petroleum plumes have impacted public or private water supplies or where petroleum vapors have migrated into occupied buildings. Associated cleanup cost estimates rely upon appropriate combinations of individual work elements and the duration of operation, maintenance, and monitoring activities. These cost estimates can be offset by state reimbursement funds, coverage in purchase agreements, and insurance policies. A case study involving a large service station site portfolio illustrates the range of site complexity and life‐cycle environmental response costs. © 2014 Wiley Periodicals, Inc.     

Full‐scale in‐situ biobarrier demonstration for containment and treatment of MTBE

The Naval Facilities Engineering Service Center (NFESC), Arizona State University, and Equilon Enterprises LLC are partners in an innovative Environmental Security Technology Certification Program cleanup technology demonstration designed to contain dissolved MTBE groundwater plumes. This full‐scale demonstration is being performed to test the use of an oxygenated biobarrier at Naval Base Ventura County, in Port Hueneme, California. Surprisingly, few cost‐effective in‐situ remedies are known for the cleanup of MTBE‐impacted aquifers, and remediation by engineered in‐situ biodegradation was thought to be an unlikely candidate just a few years ago. This project demonstrates that MTBE‐impacted groundwater can be remediated in‐situ through engineered aerobic biodegradation under natural‐flow conditions. With respect to economics, the installation and operation costs associated with this innovative biobarrier system are at least 50 percent lower than those of a conventional pump and treat system. Furthermore, although it has been suggested that aerobic MTBE biodegradation will not occur in mixed MTBE‐BTEX dissolved plumes, this project demonstrates otherwise. The biobarrier system discussed in this article is the largest of its kind ever implemented, spanning a dissolved MTBE plume that is over 500 feet wide. This biobarrier system has achieved an in‐situ treatment efficiency of greater than 99.9 percent for dissolved MTBE and BTEX concentrations. Perhaps of greater importance is the fact that extensive performance data has been collected, which is being used to generate best‐practice design and cost information for this biobarrier technology. © 2001 John Wiley & Sons, Inc.     

Development of a site‐specific cleanup goal for PAHs in soil based on anthropogenic background levels

During removal of an industrial landfill in Folsom, California, fill material was excavated and processed through a mechanical screening plant to segregate soil from construction and demolition debris. The segregated soil was stockpiled and analyzed for a wide range of chemical groups to determine if the soil could be backfilled on‐site. The analytical results indicated many of the stockpiles had concentrations of polycyclic aromatic hydrocarbons (PAHs) that exceeded US EPA Regional Screening Levels, and a large quantity of soil was initially classified as requiring off‐site disposal at considerable cost. Because PAHs are ubiquitous in urban settings and the landfill did not contain a significant source of PAHs, development of a site‐specific PAH cleanup goal was proposed to regulators. Cal/EPA guidance for using on‐site data to develop a background threshold for metals was applied to the development of the PAH cleanup goal. The Cal/EPA approach involves demonstrating whether the data belong to a single population or multiple populations based on data distribution tests and probability plots. This article explains the statistical and graphical methods that were used to demonstrate that the Cal/EPA approach was valid for PAHs and that the calculated cleanup level was consistent with published anthropogenic background levels of PAHs in California and across the United States. The site‐specific PAH cleanup goal enabled most of the soil to be backfilled on‐site, saving about $227,000 in transportation and disposal costs, and regulators subsequently approved unrestricted future use of the property. © 2010 Wiley Periodicals, Inc.     

Let biodegradation promote in-situ soil venting

Although vapor extraction systems (VES) certainly help remediate volatile hydrocarbons (e.g., gasoline in unsaturated soils), recent studies have found that much of the related hydrocarbon removal is due to aerobic biodegradation, not simple volatilization. In many cases, more than 50 percent of the hydrocarbon removal by these systems is due to biodegradation. By emphasizing biodegradation and minimizing volatilization, the costs of system operation can be reduced, especially for off-gas treatment. Maximizing biodegradation also supports more efficient site remediation because not only are the volatile hydrocarbons cleaned up, but the less volatile contaminants are also cleaned up—by biodegradation. More complete site cleanups are possible through bioventing, especially when cleanup criteria are related to total petroleum hydrocarbons. This article explores the major environmental conditions that influence biodegradation, analyzes several bioventing case histories, and calculates biodegradation's remedial costs.     

Triad case study: Rattlesnake Creek

The U.S. Army Corps of Engineers (US ACE) is responsible for conducting the cleanup of radiological contaminated properties as part of the Formerly Utilized Sites Remedial Action Program. One property is the Rattlesnake Creek (RSC) portion of the Ashland sites. The RSC stream sediments are contaminated with thorium‐230, radium‐226, and uranium. The US ACE is closing RSC using protocols contained within the Multi‐Agency Radiation Survey and Site Investigation Manual (MARSSIM). At RSC, the US ACE developed site‐specific derived concentration guideline level (DCGL) cleanup requirements consistent with the MARSSIM guidance. Because of uncertainty about the distribution of contamination within the creek, the US ACE used the Triad approach to collect data and design remedial actions. Systematic planning helped target the areas of concern, develop a conceptual site model, and identify data gaps to be addressed before remediation plans were finalized. Preremediation sampling and analysis plans were designed to be explicitly consistent with final status survey requirements, allowing data sets to support both excavation planning needs and closure requirements in areas where contamination was not encountered above DCGL standards. Judicious use of real‐ time technologies such as X‐ray fluorescence and gamma walkover surveys minimized expensive off‐ site alpha spectrometry analyses, and at the same time provided the ability to respond to unexpected field conditions. © 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.     

Environmental impacts associated with manufacturing of solar and wind power alternative energy systems

The Air Force Center for Engineering and the Environment (AFCEE) is performing Environmental Restoration Program Optimization (E‐RPO) at various United States Air Force (USAF) installations to evaluate existing remediation strategies and recommend actions to advance issues impacting the remediation program. As sustainability practices (including green and sustainable remediation [GSR]) increase at Air Force facilities and throughout the environmental industry, the use of alternative energy‐collection sources (i.e., solar photovoltaics [PV] and wind turbines) is likely to increase dramatically. Although PV and wind power systems exhibit a low environmental footprint during their use, there are potential human health and environmental impacts from the manufacturing and recycling processes. This article presents a summary of available information regarding the environmental impacts associated with life‐cycle assessments that include raw material extraction and refinement, product manufacturing, use, and postuse disposal for PV and wind turbines (i.e., cradle‐to‐grave impacts). © 2010 Wiley Periodicals, Inc.     

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.     

Sustainable soil remediation by refrigerated condensation at sites with “high‐concentration” recalcitrant compounds and NAPL: Two case studies

Remediation of recalcitrant compounds at sites with high concentrations of volatile organic compounds (VOCs) or nonaqueous‐phase liquids (NAPLs) can present significant technical and financial (long‐term) risk for stakeholders. Until recently, however, sustainability has not been included as a significant factor to be considered in the feasibility and risk evaluation for remediation technologies. The authors present a framework for which sustainability can be incorporated into the remediation selection criteria focusing specifically on off‐gas treatment selection for soil vapor extraction (SVE) remediation technology. SVE is generally considered an old and standard approach to in situ remediation of soils at a contaminated site. The focus on off‐gas treatment technology selection in this article allows for more in‐depth analysis of the feasibility evaluation process and how sustainable practices might influence the process. SVE is more commonly employed for recovery of VOCs from soils than other technologies and generally employs granular activated carbon (GAC), catalytic, or thermal oxidation, or an emerging alternative technology known as cryogenic‐compression and condensation combined with regenerative adsorption (C3–Technology). Of particular challenge to the off‐gas treatment selection process is the potential variety of chemical constituents and concentrations changing over time. Guidance is available regarding selection of off‐gas treatment technology (Air Force Center for Environmental Excellence, 1996; U.S. Environmental Protection Agency, 2006). However, there are common shortcomings of off‐gas treatment technology guidance and applications; practitioners have rarely considered sustainability and environmental impact of off‐gas treatment technology selection. This evaluation includes consideration of environmental sustainability in the selection of off‐gas treatment technologies and a region‐specific (Los Angeles, California) cost per pound and time of remediation comparisons between GAC, thermal oxidation, and C3–Technology. © 2008 Wiley Periodicals, Inc.     

Remediation,land use,and risk at Rocky Flats,and a comparison with Hanford

US Department of Energy (US DOE) responsibilities for its former national atomic weapons complex include remediation of the Rocky Flats facility near Denver, Colorado. In 1993, the site's primary mission shifted from “production'' of plutonium components for atomic weapons to cleanup of extensive radioactive and chemical contamination representing the legacy of production activities. Remediation was governed by the agreements between the US DOE as the responsible party and the US Environmental Protection Agency and the state of Colorado as joint regulators. In 1995, the Rocky Flats Future Use Working Group issued its final report, recommending among other features that long‐term cleanup reduce contamination levels to background. This article describes the circumstances that led the US DOE to complete the Rocky Flats cleanup more quickly and makes comparisons to the situation at the US DOE's Hanford site. © 2011 Wiley Periodicals, Inc.     

Challenges of soil mixing using catalyzed hydrogen peroxide with rotating dual axis blending technology

Although known to be one of the most effective oxidants for treatment of organic contaminants, catalyzed hydrogen peroxide (CHP) is typically not used for soil mixing applications because of health and safety concerns related to vapor generation and very rapid rates of reaction in open excavations. In likely the first large‐scale in situ CHP soil mixing application, an enhanced CHP, modified Fenton's reagent (MFR), was applied during soil mixing at the Kearsarge Metallurgical Superfund Site in New Hampshire. An innovative rotating dual‐axis blender (DAB) technology was used to safely mix the MFR into low‐plasticity silt and clay soils to remediate residual 1,1,1‐trichloroethane (111TCA); 1,1‐dichloroethene (11DCE); and 1,4‐dioxane (14D). It was expected that the aggressive treatment approach using relatively “greener” hydrogen peroxide (HP) chemistry would effectively treat Site contaminants without significant byproduct impacts to groundwater or the adjacent pond. The remediation program was designed to treat approximately 3,000 cubic yards of residual source area soil in situ by aggressively mixing MFR into the soils. The subsurface interval treated was from 7 to 15 feet below ground surface. To accurately track the soil mixing process and MFR addition, the Site was divided into 109 10‐foot square treatment cells that were precisely located, dosed, and mixed using the DAB equipped with an on‐board GPS system. The use of stabilizing agents along with careful calculation of the peroxide dose helped to ensure vapor‐free conditions in the vicinity of the soil mixing operation. Real‐time sampling and monitoring were critical in identifying any posttreatment exceedences of the cleanup goals. This allowed retreatment and supplemental testing to occur without impacting the soil mixing/in situ chemical oxidation (ISCO) schedule. Posttreatment 24‐hr soil samples were collected from 56 random locations after ensuring that the HP had been completely consumed. The posttreatment test results showed that 111TCA and 11DCE concentrations were reduced to nondetect (ND) or below the cleanup goals of 150 μg/kg for 111TCA and 60 μg/kg for 11DCE. Supplemental posttreatment soil samples, collected six months after treatment, showed 100 percent compliance with the soil treatment goals. Groundwater samples collected one year after the MFR soil mixing treatment program showed either ND or low concentrations for 111TCA, 11DCE, and 14D. Successful stabilization and site restoration was performed after overcoming considerable challenges associated with loss of soil structure, high liquid content, and reduced bearing capacity of the blended soils.     

When the Going Gets Tough,Communities Believe It's Time to Optimize and Adapt

The people who live in the communities where complex groundwater sites are located are as diverse as the country itself, but those who fight for the cleanup of our groundwater recognize that total cleanup may be difficult, if not impossible, in our lifetimes. Still, as explained in a December 2013 joint letter to US EPA, we want those who are responsible for environmental protection, be they polluters, developers, or regulatory agencies, to try harder before admitting defeat. In Mountain View, California, community activists have developed criteria for the adaptive cleanup of the Moffett‐MEW Regional Plume of TCE groundwater contamination that emphasizes areas with high contaminant mass, source areas, locations that reduce the need for long‐term vapor intrusion mitigation, properties where the detectable plume encroaches on residential areas, schools, and other sensitive uses, and areas planned for reuse. In many other communities, trust is the key to developing community support for remedial strategies. Communities that are listened to tend to feel more empowered. Empowered communities tend to offer more constructive advice. Decision makers tend to listen to communities that offer constructive advice. In summary, when the cleanup going gets tough, empowered communities believe that it is time to optimize and adapt, not to give up. © 2014 Wiley Periodicals, Inc.     

Risk assessment and accepted regulatory cleanup levels

The determination of cleanup levels at a CERCLA or RCRA site is often the single most important decision made by risk managers. This decision can have a major impact on the costs and time required for remediation, as well as on the selection of remedial technologies. The object of this article is to provide a critical review of the methods used by regulatory agencies and the regulated community to calculate chemical-specific cleanup goals for inactive hazardous waste sites, focusing on those cleanup goals that are designed to protect human health from the effects of chemicals. In addition to this analysis of historical methods that have been used, this article discusses some innovative solutions to the problem of calculating cleanup levels and presents an analysis of controversial topics related to cleanup levels currently under debate by regulatory agencies, industry, environmentalists, and legislative bodies.     

Methodology and model for performance and cost comparison of innovative treatment technologies at wood preserving sites

Wood preserving facilities have used a variety of compounds, including pentachlorophenol (PCP), creosote, and certain metals, to extend the useful life of wood products. Past operations and waste management practices resulted in soil and water contamination at a portion of the more than 700 wood preserving sites in the United States (EPA, 1997). Many of these sites are currently being addressed under federal, state, or voluntary cleanup programs. The U.S. Environmental Protection Agency (EPA) National Risk Management Research Laboratory (NRMRL) has responded to the need for information aimed at facilitating remediation of wood preserving sites by conducting treatability studies, issuing guidance, and preparing reports. This article presents a practical methodology and computer model for screening the performances and comparing the costs of seven innovative technologies that could be used for the treatment of contaminated soils at user‐specified wood preserving sites. The model incorporates a technology screening function and a cost‐estimating function developed from literature searches and vendor information solicited for this study. This article also provides background information on the derivation of various assumptions and default values used in the model, common contaminants at wood preserving sites, and recent trends in the cleanup of such sites. © 2001 John Wiley & Sons, Inc.     

Net impact of remediation

Following years of progress in designing and executing cleanups of contaminants at waste sites, the U.S. Air Force, state regulatory groups, and others are crafting methods to evaluate broader considerations of risk in remedial decisions. Integrating worker and climate risks into remediation efforts may confer significant benefits, but challenges exist to identifying, assessing, and accounting for them in the remedial process. For sites where future risk posed by contamination far exceeds the risk posed to workers who may be exposed to the contaminants during the remedial process, limiting the range of decision inputs to those presented by the site conditions made sense and provided a net benefit to human health and the environment. There are other sites, however, where future risk posed by the in situ contamination are at levels comparable to the real risks posed to workers, ecology, and even emerging concerns about climate change. For these sites, a net risk reduction cannot be assumed to be a result of remedial action, challenging the remedial community to develop new approaches to ensure positive results. © 2009 Wiley Periodicals, Inc.     

Stable Isotope Probing to Confirm Field‐Scale Co‐Metabolic Biodegradation of 1,4‐Dioxane

1,4‐Dioxane, a common co‐contaminant with chlorinated solvents, is present in groundwater at Site 24 at Vandenberg Air Force Base in California. Historical use of chlorinated solvents resulted in concentrations of 1,4‐dioxane in groundwater up to approximately 2,000 μg/L. Starting in 2013, an in situ propane biosparge system operation demonstrated reductions in 1,4‐dioxane concentrations in groundwater. The work detailed herein extends the efforts of the first field demonstration to a second phase and confirms the biodegradation mechanism via use of stable isotope probing (SIP). After two months of operation, 1,4‐dioxane concentrations decreased approximately 45 to 83 percent at monitoring locations in the test area. The results of the SIP confirmed ¹³C‐enriched 1,4‐dioxane was transformed into dissolved inorganic carbon (suggesting mineralization to carbon dioxide) and incorporated into microbial biomass (likely attributed to metabolic uptake of biotransformation intermediates or of carbon dioxide).  ©2016 Wiley Periodicals, Inc.