A risk-based approach to how clean is clean

Clearly defined remedial action objectives are a key factor in successful remediation programs. Chemical-specific cleanup criteria are critical components of remedial action objectives. A common risk-based approach can be applied for developing cleanup criteria for remediations under CERCLA, RCRA, and TSCA. This approach involves four steps: identify regulatory requirements; identify chemical-specific cleanup guidelines from previous cleanups; evaluate site-specific risk considering mitigating factors for a given site; select the final cleanup criteria based on information from the first three steps. To describe this approach, this paper presents a case study on a PCB cleanup conducted under TSCA. An objective risk-based approach was used to capitalize on the flexibility built into EPA's PCB cleanup guidelines. EPA granted an exemption to the stated policy on the basis of competing risk factors using a comparative risk-assessment approach. Similarly, risk assessment can be used to take advantage of regulatory flexibility in the selection of applicable or appropriate and relevant requirements (ARARs) under CERCLA, or in the selection of media protection standards under RCRA.     

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.     

NYSDEC's DER‐31/Green Remediation Policy Influences Tool Development and Global Program

The New York State Department of Environmental Conservation (NYSDEC) Division of Environmental Remediation (DER) issued a program policy focused on the overall sustainability of hazardous waste site cleanups on August 11, 2010. This DER‐31/Green Remediation program policy (DER‐31) was issued in accordance with 6 New York Codes, Rules and Regulations (NYCRR) Part 375 Environmental Remediation Programs. DER‐31 represents one of the first government‐issued green and sustainable remediation (GSR) policies in the United States. Consistent with other DER policies, DER‐31's provisions are broadly considered to be an expectation/requirement. GSR experts from within AECOM's Remediation Services (RS) Practice Area developed and implemented a GSR program designed to comply with DER‐31 provisions and have now broadly incorporated GSR into our New York remediation projects. Lessons learned from this experience in New York have influenced AECOM's global GSR program and implementation procedures and prompted the development of a new GSR tool (GSRx^TM) for identifying and assessing GSR best management practices (BMPs), which has also been employed globally. © 2013 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.     

Improved direct push technologies: Quicker and cheaper on-site methods for sampling and monitoring

Cost-effective remedial action is dependent on clear identification of site conditions and accurate delineation of contamination. Many site cleanups have been hampered by complex subsurface conditions. Standard drilling and monitoring well installations have proven to be costly and time-consuming. Improved direct push technologies, however, are being developed to perform quicker and less expensive on-site sampling and testing. This article describes the benefits of improved direct push technologies.     

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.     

Lessons learned from classroom training on natural attenuation of chlorinated solvents

Technology and information transfer are critical functions within the remediation industry. Researchers in the private sector, academia, and government all struggle to have their findings accepted and put to good use by the remediation industry at large but must work even harder to have their findings accepted and put into practice by state and federal regulators in the environmental agencies overseeing cleanups. Unfortunately, many technology and information transfer efforts fail to reach state and federal regulators, and even fewer achieve regulatory acceptance. A two‐year‐long campaign to deliver a training class on the natural attenuation of chlorinated solvents in groundwater is one prominent example of very effective technology and information transfer. Several of the elements and aspects of that successful training class are presented and discussed in order to provide others with a proven and workable template. © 2010 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.     

Travis Air Force Base: A greener cleanups case study

Travis Air Force Base, California, has accelerated the pace of remediation while reducing long‐term costs and cutting greenhouse gas production. This has been achieved through optimizing existing systems and processes, adopting greener cleanups best management practices, and testing and implementing innovative “green” technologies. By optimizing and replacing existing systems that used energy‐intensive infrastructure, and by promoting the use of innovative in situ technologies, the US Air Force (Air Force) led team comprised of the Air Force Civil Engineer Center, the US Army Corps of Engineers, the performance‐based contractor CH2M, and the regulatory agencies consisting of the US Environmental Protection Agency, the California Water Board, and the California Department of Toxic Substances Control, has reduced annual system operation and maintenance costs by over $200,000 per year, while reducing annual carbon dioxide production by approximately 930 tons per year. As a result of these actions, chlorinated solvent source areas have been reduced by over 99 percent in some cases, and the predicted cleanup time frame for multiple sites has been reduced by several decades. This article provides a case study for implementation of cost‐effective greener cleanup actions, and summarizes the approach taken by the Air Force led team to complete the greener cleanups self‐declaration process consistent with the ASTM International's E‐2893 Standard Guide for Greener Cleanups.     

Sustainable remediation: Quo vadis?

Sustainable remediation is at a crossroads. In a few short years it has become a mainstream topic while simultaneously maintaining its chimeral status. Sustainable remediation is a term claimed by many yet a concept apparently understood by few. Its characterization has necessitated the development of a plethora of metrics and tools yet its essence readily emerges. U.S.‐led initiatives have been adopted around the globe. Relative sustainability appraisal is easy to carry out and potentially sufficient for most site circumstances. The need to adequately protect human health and the environment has been recognized. Now the industry needs to focus our attention on protection and restoration that itself has a reasonably maximized net benefit. © 2011 Wiley Periodicals, 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.     

Insufficient source area remediation results in the rebound of TCE breakdown products in groundwater

In the early 1990s, a soil removal action was completed at a former disposal pit site located in southern Michigan. This action removed waste oil, cutting oil, and chlorinated solvents from the unsaturated zone. To contain groundwater contaminant migration at the site, a groundwater pump‐and‐treat system comprised of two extraction wells operating at a combined flow of 50 gallons per minute, carbon treatment, and a permitted effluent discharge was designed, installed, and operated for over 10 years. Groundwater monitoring for natural attenuation parameters and contaminant attenuation modeling demonstrated natural attenuation of the contaminant plume was adequate to attain site closure. As a result of incomplete contaminant source removal, a rebound of contaminants above the levels established in the remedial action plan (RAP) has occurred in the years following system shutdown and site closure. Groundwater concentrations have raised concerns regarding potential indoor air quality at adjacent residential properties constructed in the past 9 to 10 years. The only remedial option available in the original RAP is to resume groundwater pump‐and‐treat. To remediate the source area, an alternate remediation strategy using an ozone sparge system was developed. The ozone sparge remediation strategy addresses the residual saturated zone contaminants beneath the former disposal pit and reestablishes site closure requirements without resumption of the pump‐and‐treat system. A pilot study was completed successfully; and the final system design was subsequently approved by the Michigan Department of Environmental Quality. The system was installed and began operations in July 2010. As of the January 2011 monitoring event, the system has shown dramatic improvement in site contaminant concentrations. The system will continue to operate until monitoring results indicate that complete treatment has been obtained. The site will have achieved the RAP objectives when the system has been shut down and meets groundwater residential criteria for four consecutive quarters. © 2011 Wiley Periodicals, 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.     

Operating windows to assess whether monitored natural attenuation is a technically feasible remediation option for BTEX‐contaminated groundwater

When used in combination with source management strategies, monitored natural attenuation (MNA) is likely to be a technically feasible remediation option if the contaminant persistence time along the flow path is less than (a) the transport time to the compliance point and (b) the time available for groundwater remediation objectives to be achieved. Biodegradation is often the most significant natural attenuation process for benzene, toluene, ethylbenzene, and xylenes (BTEX) in groundwater. While BTEX transport rates increase with groundwater velocity, examination of data obtained from the published literature for seven sites undergoing MNA revealed significant positive correlations between groundwater velocity and first‐order biodegradation rates for toluene (r = 0.83, P < 0.05), ethylbenzene (r = 0.93, P < 0.01), m‐ and p‐xylene (r = 0.96, P < 0.01), and o‐xylene (r = 0.78, P < 0.05). This is attributed to increased dispersion at higher velocities leading to more mixing of electron acceptors with the contaminant plume. There was no positive correlation between groundwater velocity and first‐order biodegradation rates for benzene due to noise in the relationship caused by variations in (a) the concentrations of electron acceptors in the uncontaminated groundwater and (b) the proportions of benzene in the total BTEX concentration in the source area. A regression model of the relationship between groundwater velocity and the first‐order biodegradation rate can be used to delineate operating windows for groundwater velocity within which the contaminant persistence time is less than the transport and remediation times for a given source concentration, target concentration, distance to compliance point, retardation factor, and remediation time. The operating windows can provide decision makers with a rapid indication of whether MNA is likely to be a technically feasible remediation option at a given site. © 2005 Wiley Periodicals, Inc.     

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.     

Cover design for radioactive and AMD-producing mine waste in the Ronneburg area, eastern Thuringia

At the former uranium mining site of Ronneburg, large scale underground and open pit mining for nearly 40 years resulted in a production of about 113,000 tonnes of uranium and about 200 million cubic metres of mine waste. In their present state, these materials cause risks to human health and strong environmental impacts and therefore demand remedial action. The remediation options available are relocation of mine spoil into the open pit and on site remediation by landscaping/contouring, placement of a cover and revegetation. A suitable vegetated cover system combined with a surface water drainage system provides long-term stability against erosion and reduces acid generation thereby meeting the main remediation objectives which are long-term reduction of radiological exposure and contaminant emissions and recultivation. The design of the cover system includes the evaluation of geotechnical, radiological, hydrological, geochemical and ecological criteria and models. The optimized overall model for the cover system has to comply with general conditions as, e.g. economic efficiency, public acceptance and sustainability. Most critical elements for the long-term performance of the cover system designed for the Beerwalde dump are the barrier system and its long-term integrity and a largely self-sustainable vegetation.     

Best management practices for environmental restoration programs

Based on a review of hundreds of environmental restoration program optimization reviews, this article describes management tools found in successful and efficient remediation programs. Projects that consistently struggled to achieve their objectives were observed to be missing certain, or to have inadequately used, these tools. The tools are articulated as best practices because when they are present and actively used, project shortcomings were minimal. Priority objectives for site owners and project managers include improving efficiency and effectiveness through performance management, reducing resource usage and energy consumption, ensuring protectiveness, and reducing uncertainty in management decision making. Restoring environmental resources damaged by historic waste management practices began in earnest in the late 1960s and early 1970s with the broad recognition of the problems caused by environmental discharges and spills when wastes are not managed appropriately. Under new regulations, soil and groundwater remediation projects could be, and were, conducted within a defined framework. The number and variety of restoration projects that were launched resulted in a slew of projects progressing through the stages of characterization, decision, and cleanup, and more were added to the cleanup process each year. In the 1990s, the Department of Defense noted that many cleanup efforts were projected to incur substantial operational, maintenance, and monitoring costs for decades into the future. This was correctly perceived as an opportunity to optimize those systems and programs, minimize costs, and reduce health and environmental risks. The best practices outlined in this article address management tools that were identified in optimization efforts that led to effective and efficient environmental remediation projects. © 2010 Wiley Periodicals, Inc.     

Directionally drilled horizontal wells offer cost savings and technical advantages over alternative soil and groundwater remediation systems

Directionally drilled horizontal wells offer the opportunity for significant cost savings and technical advantages over alternative trenched well and vertical well soil and groundwater remediation systems in many cases. The magnitude of the cost savings is a function of the remediation technology deployed and the values placed on the reduction of site impacts, dramatic reduction in the time required to achieve site remediation goals and requirements, the ability of horizontal well remediation to easily treat normally recalcitrant contaminants such as MTBE, and the ability to drill under paved areas, operating plants, residential areas, landfills, lagoons, waterways, ponds, basins, and other areas that are normally difficult or impossible to access with conventional drilling or trenching methods. In addition to improvements in site access capabilities, horizontal wells have been found capable of addressing contaminants that vertical wells do not readily treat, even with the same remediation technology deployed, especially if air‐based remediation technologies are deployed. With biosparging, for example, greater treatment capabilities of horizontal wells over vertical wells are attributed to greater oxygen flux over a broader area, a larger treatment zone, and extremely prolonged residence of groundwater contaminants in the aerobic treatment area, typically months or years. This article describes the use of directionally drilled horizontal wells for application of a variety of treatment technologies and includes costs of various options with a detailed comparison of biosparging options. © 2002 Wiley Periodicals, Inc.