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.     

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.     

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.     

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.     

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.     

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.     

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.     

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.     

Modeling remediation time using natural attenuation at a dry‐cleaner site

Contaminants from dry‐cleaning sites, primarily tetrachloroethene (PCE), trichloroethene (TCE), cis‐dichloroethene (cis‐DCE), and vinyl chloride (VC), have become a major concern because of the limited funds and regulatory programs to address them. Thus, natural attenuation and its effectiveness for these sites needs to be evaluated as it might provide a less costly alternative to other remediation methods. In this research, data from a site in Texas were analyzed and modeled using the Biochlor analytical model to evaluate remediation times using natural attenuation. It was determined that while biodegradation and source decay were occurring at the site, the resulting attenuation rates were not adequate to achieve cleanup in a reasonable time frame without additional source remediation or control strategies. Cleanup times exceeded 100 years for all constituents at the site boundary and 800 years at the source for PCE, assuming cleanup levels of 0.005 mg/L for PCE and TCE and 0.07 mg/L and 0.002 mg/L for cis‐DCE and VC, respectively. © 2005 Wiley Periodicals, Inc.     

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.     

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.     

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.     

Proven methods for managing public perception of cleanups

Negative public perceptions can dramatically increase site remediation costs or even bring projects to a grinding halt. Public opposition and ensuing political pressure are two damaging, but often ignored, obstacles that confront remediation managers. This article discusses these and other public management issues, recommending tactics proven for maintaining positive working relationships with a site's human neighbors, the media (electronic and print), government officials, regulatory agencies, and other concerned groups to allow site cleanup to proceed without intervention, opposition, or unnecessary delay. It illustrates its warnings about public and political hostility with case histories from Superfund, RCRA, and other cleanup sites, recounting how corporate management won the public's confidence and kept their projects on time and within budget.     

National monument locations and remediation of World War II battle sites

In December 2008, George W. Bush established the World War II Valor in the Pacific National Monument, including eight locations connected with World War II fighting. The executive proclamation designating the monument briefly described the individual sites, mentioning remaining battlefield debris. World War II battle locations in Hawaii and Alaska are currently designated for remediation under different programs of the U.S. Environmental Protection Agency or Department of Defense (DOD). The Pearl Harbor Naval Complex is a “Superfund” National Priority List site. Former military locations in the Aleutian Islands, involved in Japanese occupation and the U.S. offensive to regain control, are included in DOD's Formerly Used Defense Sites (FUDS) remediation program. These monument sites, the regulatory frameworks of the applicable programs, and the current cleanup status are described. © 2009 Wiley Periodicals, 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.     

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.     

Influences on RCRA corrective action costs for nonfederal facilities

Thousands of known hazardous waste sites across the country require remediation, with thousands more yet to be discovered, at estimated cleanup costs of billions of dollars over the next few decades. With this enormous financial burden placed on all members of society through increased prices, taxes, and lost investment opportunities, policy makers face the difficult prospect of defining cleanup standards that meet the goals of protecting human health and the environment and achieving remediation in the most cost-effective manner. Using a statistical methodology to investigate factors influencing the cost of RCRA corrective action, this article examines site characteristics that significantly affect cleanup costs and explains differences in costs among EPA's four proposed Subpart S corrective action options.     

The maturing of the Triad approach: Avoiding misconceptions

Misunderstandings and misconceptions have arisen as the Triad approach has gained wider application. The Triad initiative's ability to catalyze second‐generation cleanup practices will be hampered if inaccurate or incomplete assumptions create persistent confusion about what Triad is or how it works. This article has been prepared by the multi‐agency workgroup responsible for articulating the Triad approach and coordinating national Triad efforts. It serves to address some misunderstandings about key Triad concepts. As an aid to those wishing to learn more, a new Web site (the Triad Resource Center, http://www.triadcentral.org) and a new Triad reference document from the Interstate Technology and Regulatory Council (ITRC) are introduced as sources of explanatory information supporting the Triad approach. © 2004 Wiley Periodicals, Inc.     

New perspectives on horizontal to vertical well ratios for site cleanup

Directional drilling has been used for a variety of purposes, including utilities, dewatering, and remedial activities. Using this method for site cleanup versus traditional vertical extraction wells needs to be considered based upon today's remedial challenges. Traditionally, it has been stated that a single horizontal well can substitute for up to 11 vertical wells. This “rule” is arbitrary, since length and depth of the plume, surface access, and hydrogeological conditions must be considered. A better way to evaluate the cost‐benefit of a horizontal versus vertical well system is a predicted zone of influence using a mathematical and hydrogeological approach, as described herein.