Using risk assessment to achieve cost-effective property transfers and site closures for former UST sites

Risk assessment has been increasingly applied as a tool in making risk management decisions that affect cleanup of contaminated sites, property transactions, and liability issues. As a site-specific evaluation, risk assessment takes into account the unique characteristics and intended future uses for site property in evaluating chemical concentrations which may remain in place without risk to public health and the environment. The results of a risk assessment can be used to determine reuse options for a property, facilitate site closure, and reduce liabilities (Copeland and Robles, 1994; Copeland et al., 1993a). This article describes the risk assessment process, the role of risk assessment in determining the need for remedial action and identifying site-specific cleanup goals, and the cost effectiveness of applying risk assessment in remedial decisions. Because of the prevalence of former UST sites throughout the United States, this article focuses on risk assessment and remediation of UST sites. However, the process can be applied at sites where other chemicals have been released. Three case studies are presented to illustrate the application of risk assessment in achieving cost-effective site closure at sites containing leaking underground storage tanks.     

Radiological risks and cleanup costs: A remediation case study

Potential health risks and cleanup costs are primary factors for measuring the effectiveness of a remediation project concerning a site contaminated with residual radioactive materials. Demanding cleanup of a contaminated site to its original condition, while eliminating any health risks after cleanup, can require prohibitive costs. However, by setting practical remediation objectives and by performing realistic but conservative risk assessments, health risks can be acceptable and cleanup costs can be reasonable. This article uses the South-Middle and Southeast Vaults Decontamination and Demolition Project at Argonne National Laboratory to demonstrate how negligible health risks can result after cleanup with minimal cleanup costs. Substantial cost savings of approximately $2 million was realized by implementing in-place decontamination and demolition (D&D) on the basis of acceptable risk, instead of requiring cleanup of the site to its original condition. By using the RESRAD computer program as a modeling tool, we show the maximum projected radiation dose (0.1 mrem per year) and the potential lifetime cancer risk (on the order of 10⁶) to an individual from exposure to the residual radioactivities are negligibly small. In addition to aiding in the selection of a preferred remediation alternative, results of the RESRAD modeling were also used to guide the implementation of the selected alternative to reduce exposures from the dominant pathway and to ensure that exposures from all pathways would be as low as reasonably achievable.     

Improving decision quality: Making the case for adopting next‐generation site characterization practices

Better site characterization is critical for cheaper, faster, and more effective cleanup. This fact is especially true as cleanup decisions increasingly include site redevelopment and reuse considerations. However, established attitudes about what constitutes “data quality” create many barriers to exciting new tools capable of achieving better characterization, slowing their dissemination into the mainstream. Traditional approaches to environmental “data quality” rest on simplifying assumptions that are rarely acknowledged by the environmental community. Data quality assessments focus on the quality of the analysis, while seldom asking what impact matrix heterogeneity has had on analytical results. Assessments of data quality typically assume that chemical contaminants are distributed nearly homogeneously throughout environmental matrices and that contaminant‐matrix interactions are well behaved during analysis. Yet, these assumptions seldom hold true for real‐world matrices and contaminants at scales relevant to accurate risk assessment and efficient remedial design. For the site cleanup industry to continue technical advancement, over‐simplified paradigms must give way to next‐generation models that are built on current scientific understanding. If reuse programs such as Brownfields are to thrive, the scientific defensibility of individual projects must be maintained at the same time as characterization and cleanup costs are lowered. The U.S. Environmental Protection Agency (EPA) offers the Triad Approach as an alternative paradigm to foster highly defensible, yet extremely cost‐effective reuse decisions. © 2003 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.     

Integrating Natural Resource Damage Assessment and Environmental Cleanup Activities at CERCLA and RCRA Sites

Although the release or threatened release of hazardous substances into the environment often creates liability for both cleanup costs and natural resource damages liability, the process of planning and conducting cleanup and the process of assessing natural resource damages are most often conducted separately. However, the substantial similarities between the two processes often present opportunities to integrate significant steps in each. Such integration has the potential to reduce both the cost of measuring and, often, resolving the full range of environmental claims at a given cleanup site and the time it takes to do so. It can also lead to faster restoration of injured natural resources and the services they provide to the public and the environment. One key reason for the lack of integration is the fact that cleanup managers generally know little if anything about the natural resource damage assessment process, while the public officials authorized to assess damages to natural resources know little about the cleanup process. This article identifies the similarities between the cleanup and natural resource damage assessment processes and provides guidance on when and how to integrate the two. © 2013 Wiley Periodicals, Inc.     

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.     

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.     

The trade-off between assessment and cleanup phases of remediation projects

Based on actual project experiences over the past decade, execution strategies for remediation projects have varied significantly. For example, the overlap between the assessment and cleanup phases can range from none (for projects that complete assessment activities before starting the cleanup) to almost half of the assessment duration (for projects that may be under pressure to show progress at the site). This article quantifies the relationship between remediation project execution strategies, project definition components, and remediation project cost and schedule performance. By relating project outcomes to indicators that can be monitored early in the project cycle, project teams may be able to correct problems before they affect the ultimate performance of the remediation project.     

How chemically stable is stabilized hazardous waste?

Bioassays can provide meaningful information about the relative toxicity of remediated soil samples, revealing the unwelcome toxic side effects produced by some cleanup projects. Section 121 of CERCLA's 1986 amendments calls for hazardous waste site remediations to permanently and significantly reduce the volume, toxicity, and mobility of hazardous substances, pollutants, and contaminants. Traditional engineering technology has focused on reducing volume and mobility, assuming that such reduction would lead to reductions in toxicity. Environmental scientists have argued, however, that such reductions are not always the result, but lack of consensus on how hazardous waste mixtures should be measured toxicologically has slowed development of integrated assessments. The aquatic and terrestrial bioassays discussed in this article are evaluated for various chemicals, mixtures of chemicals, and actual waste site chemical mixtures at a Superfund mobility reduction project in Kent, Washington. Results suggest that although remediation accomplished the primary objective of reducing mobility, it also introduced toxic effects. These tradeoffs must be viewed holistically when the ultimate performance of cleanup measures is judged.     

Risk assessment: A site-specific approach to establishing acceptable soil cleanup levels

In 1980 the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was passed to instigate the cleanup of uncontrolled hazardous waste sites. CERCLA necessitated the development of a set of criteria for estimating the severity of the contamination at these sites, the potential impact on human health and the environment, and establishing appropriate cleanup levels for the contaminated media. The risk assessment (RA) format was developed to meet these challenges. Though RAs vary dramatically in their scope, emphasis, and regulatory application, there are two primary objectives common to all RAs: (1) to evaluate potential risks to human health and the environment posed by the release of hazardous substances and (2) to evaluate and establish safe cleanup levels based primarily on the number and type of potential receptors, the toxicity and mobility of the contaminants, and the types of exposure pathways present. Achieving these objectives may be a relatively simple task or an extremely complex and difficult one depending on the type of material released and our understanding of its behavior in the environment, the site conditions, and the governing regulations. This article presents an approach for establishing acceptable cleanup levels for subsurface soils and illustrates the application of this approach to three different regulated sites.     

Assessing cleanup levels for industrial sites under state risk reduction programs

Many states are promoting the cleanup and reuse of industrial sites. The reasons stem from the need to implement cost-effective risk reduction programs that show reasonable progress in the cleanup of contaminated sites and from the need to make effective use of industrial sites instead of abandoning them and making use of greenfield sites for new industrial facilities. The industrial land-use cleanup criteria developed by states are primarily risk-based. Several EPA regional offices also have developed similar risk-based cleanup criteria. This article addresses methodologies employed for assessing and evaluating the level of cleanup at several industrial sites in Texas, Michigan, and Ohio. This includes defining the regulatory framework, estimating the level and extent of contamination of soil and groundwater, assessing migration pathways, performing health risk assessments, and estimating cleanup requirements and associated costs. The implications associated with the various types of risk reduction options available for these states also are addressed.     

Alternatives to incineration in remediation of soil and sediments assessed

Contamination of soil and sediment by pollutants represents a major environmental challenge. Remediation of soil during the original Superfund years consisted primarily of dig and haul, capping, or containment. The 1986 amendments to CERCLA—SARA—provided the incentive for treatment and permanent remedies during site remediation. Thermal treatment, which routinely achieves the low cleanup criteria required by RCRA land-ban regulations, became one of the major technologies used for cleanup under the concept of ARAR. As the remediation industry matured and recognized specific market niches in soil remediation, a number of new technologies emerged. Thermal desorption, bioremediation, soil vapor extraction, soil washing, and soil extraction are being used on sites at which the technology offers advantages over incineration. In addition, a continuing stream of emerging technologies is being presented that requires careful evaluation relative to existing cleanup methods. Each of these technologies offers a range of options for achieving appropriate cleanup criteria, application to different soil matrices, cost, time of remediation, and public acceptability. Balancing cleanup criteria defined by regulation or risk assessment with technology cost and capability affords the opportunity to solve these problems with appropriate balance of cost and protection of human health and the environment.     

Cleanup levels for dioxin-contaminated soils

EPA's use of a 1 part per billion (ppb) level for dioxin contamination in residential soils is shown to be too high and not protective of public health. It was derived in a 1984 cancer risk assessment by another federal agency, but it is inconsistent with risk-based levels of 2 to 4 parts per trillion (ppt) obtained by using EPA's standard risk assessment methods. EPA has called the 1 ppb level a policy-based level, which correctly distinguishes it from a risk or health-based cleanup standard. The 1984 assessment is shown in this article to have considerable shortcomings. For over a decade, dioxins have been left in soils at levels posing health risks and sometimes at levels that EPA is legally required to address. Moreover, noncancer effects have been ignored, but recent work has shown them to support action at low ppt levels. To protect public health, be consistent with current scientific knowledge and other EPA policies, reduce confusion in the environmental management community, and be responsive to public demands for stringent dioxin cleanups, new EPA policy guidance for dioxin soil cleanups is needed, and key elements are presented in this article. In an ad hoc fashion, EPA Region 4 has recently used a 200 ppt dioxin cleanup level for residential soil, acknowledged to correspond to a one-in-ten-thousand cancer risk, at two Superfund sites, which environmental professionals should be aware of. This suggests a shift in EPA policy.     

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.     

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.     

A framework for analysis of contamination on human and ecological receptors at DOE hazardous waste site buffer lands

This article discusses a framework and tools for evaluating ecological resources and the effects of cleanup on hazardous waste sites, particularly those with ecological buffer lands. Environmental professionals are faced with assessing the risks of contamination to humans and ecological receptors (organisms and ecosystems) at hazardous waste sites. While exposure assessment has focused largely on human receptors, environmental managers have recently taken a broader view, recognizing the intrinsic value and aesthetic importance of ecological resources and services, and of including a range of stakeholders in remediation decisions. The assessment process involves understanding exposure pathways from source to receptor, and determining how best to interdict these pathways. Environmental characterization and exposure assessment, indicator and biomarker identification, and biomonitoring and surveillance are the major components of ecological assessments. Using the Department of Energy as a case study, this article offers a framework for ecological exposure assessment, recognizing that humans are important components of ecosystems and, like other biota, are exposed to contaminants that move through environmental media. © 2007 Wiley Periodicals, Inc.     

Contributions of common sources of polycyclic aromatic hydrocarbons to soil contamination

Asphalt products, particularly sealants, are prepared using petroleum products that contain a com‐plex mixture of aliphatic and aromatic hydrocarbons, including polycyclic aromatic hydrocarbons (PAHs). Clearly, these products are ubiquitous in urban environments, which raises an issue regard‐ing the potential for PAHs to be transported from parking lots to underlying or adjacent soil, surface‐water bodies, or groundwater. Based on a literature review, there are limited studies focus‐ing on this issue; however, the studies that have been published have fascinating conclusions. The literature shows, as expected, that asphalt‐based products contain PAHs. The highest PAH concen‐trations are present in asphalt sealants, particularly those manufactured using coal tar. Furthermore, due to the low solubility and high partition coefficients of PAHs, the potential for PAHs to leach from asphalt surfaces is negligible, which has been confirmed by leachability studies. Thus, there is little risk that PAHs will be present in stormwater runoff or leach into groundwater from asphalt‐paved areas in a dissolved form. However, asphalt pavement and sealants produce particulate matter that can contain concentrations of PAHs in the sub‐percent range (100s to 1,000s mg/kg total PAHs) that is transported in stormwater runoff. Some studies show that this can cause soil and sediment con‐tamination with total PAH concentrations in the range of 1 to 10 mg/kg. From a remediation per‐spective, many site cleanups are conducted to remediate the presence of PAHs to cleanup goals below 1 mg/kg or, in some cases, 0.1 mg/kg or lower. From a total risk perspective, remediating sites to low PAH cleanup goals may be unwarranted in light of the risk of transportable PAHs produced from paved parking surfaces. In other words, is it reasonable to conduct a cleanup to remediate low PAH concentrations and then redevelop the area with asphalt pavement and sealant, which may pose a greater PAH‐related risk? © 2006 Wiley Periodicals, Inc.     

Impact: A Model for calculation of soil cleanup levels

The establishment of soil cleanup levels is a primary concern in site remediation projects. Soil cleanup levels provide targets that drive the remediation process from technology selection through closure. Several state regulatory agencies are currently in the process of developing scientifically based soil cleanup standards. The underlying premise in the derivation of such standards is to ensure that the site will not pose a threat to human health and the environment after remediation has been completed. To accomplish this, remediation project managers must consider several contaminant transport pathways. This article presents the salient features of a model named IMPACT, which was developed to assist in the derivation of soil cleanup levels. IMPACT considers the soil-to-groundwater pathway and predicts the cleanup levels in a contaminated soil layer in the vadose zone such that groundwater quality standards are met at any point in the aquifer.