Fast-track remediation for redevelopment of a former integrated steel mill site

Remedial action was initiated and completed on an approximately 500-acre brownfield site in southern California within a period of five months during the summer of 1995. Remedial actions included design and construction of an approximately 14-acre cap, including a synthetic membrane; design, construction, and testing of an in-situ soil vapor extraction system; excavation, on-site treatment, and off-site disposal of approximately 7,000 cubic yards of residual waste and affected soil; and verification sampling, analysis, and health risk screening in 20 units of a former integrated steel mill. Completion of remedial action on this portion of the mill site within this time frame was required due to site redevelopment plans which included construction of an auto raceway with scheduled races in early 1997. Rapid remedial action was possible only through simultaneous completion of multiple remediation tasks. This could be done only with continuous communication and close coordination among the site owner, lead regulatory agency, and contractors.     

Expect Déjà vu all over again

It is difficult to define “property damage,” but one knows it when one sees it. Groundwater and soil impacts are readily discernible. However, owners of property that has been adversely affected by environmental conditions caused by others have recently sought recovery for the stigma which may attach to property which has in the past been affected by hazardous substances, even after remediation. These cases are particularly interesting in light of the traditional causes of action for negligence, trespass, and nuisance, and the statutes of limitations which may affect both rights to sue and damages. This article addresses “stigma” as an emerging area and an element of damages in environmental cases.     

Enhanced attenuation: Its place in the remediation of chlorinated solvents

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

On-site analytical support: A cost-effective alternative to fixed laboratory services

Two recent projects involving soils remediation at Superfund sites in southern New Jersey and northeastern Pennsylvania exemplify the power of “real time” field analytical support in reducing time and expense during a project's remedial phase. The remediation efforts at both of these CERCLA sites were supported by ERM-FAST on-site analytical facilities which, in a “real-time” scenario, achieved all data quality objectives (DQOs), met all regulatory agency requirements, and satisfied the client's needs. Both of these sites offer illustrations of the effectiveness of field analysis for vastly differing site contaminants. The client benefited from substantial savings on analytical cost as well as the savings realized through efficient and effective process and schedule management.     

Institutional controls for future land use at active installation restoration program (IRP) sites

One of the strategies now in vogue in hazardous waste cleanup is basing remedial strategies on future land use. The initial thrust of CERCLA for permanent and complete remedies has given way, pushed by concepts like “brownfields” and base closure and reuse, to strategies often based on “institutional controls” that attempt to stabilize future land uses at a site based on residual risk. The heart of this concept is that instead of removing all wastes from a site, some wastes can safely remain so long as in the future the site is not used in such a way that the residual contamination poses an unacceptable risk to human health and the environment. “Institutional controls” is a term for land use management strategies that do not rely on engineering approaches to reduce risk, but rather seek to ensure that the site is not used in an inappropriate way in the future. This article cautions that such a strategy has inherent residual risks that must be understood by those involved in implementing hazardous waste cleanups and those responsible for future uses of contaminated property. Simply put, institutional controls are only as good as the processes that are in place to ensure they are respected in the future. This presents particular problems for active duty installations because most of the protections commonly available to private sector sites are not useful at active installations. This article discusses an initiative by the Air Combat Command to develop a handbook on instituting and maintaining land restrictions. It will also discuss that effort in light of the April 21 EPA Region IV guidance on assuring Land Use Controls at Federal Facilities. This article is based on a paper and presentations given at the 1998 ACC Environmental Training Symposium.     

Optimizing data usability in the remedial process

Large quantities of data are collected and evaluated throughout every stage of the remedial process. The usability of these data is often a function of the perceived “quality” of the data, with good data considered usable and bad data considered unusable. The assessment of data quality and usability has traditionally focused on analytical and other direct measurement errors and uncertainty. However, problems with the data that are measurement-related are usually a relatively minor portion of the total error and uncertainty. Error and uncertainty are introduced throughout every aspect of any remedial process, including planning errors, measurement errors, and interpretation errors. Although each error component is important, the errors and uncertainty associated with the design, collection, and interpretation of data are often much greater than measurement-related errors. Nevertheless, there is typically a disproportionate level of effort expended addressing the minor types of measurement errors when compared to other more important error components in the remedial process. However, the key to obtaining optimum data use requires the general redirection of Data Quality Assurance (DQA) activities from measurement-related errors/uncertainty to other important planning and interpretation elements. The elements considered essential for developing an effective approach for maximizing data usability include: focused project planning activities stressing a rigorous data quality objective process and a geostatistical approach to the design of the data collection program; the development of sensible and appropriate data validation/review objectives; and the development of realistic error and uncertainty limits for measurement/analytical activities.     

A Case Study of the Beneficial Reuse of Treated Groundwater

The future disposal of treated groundwater at the former Nebraska Ordnance Plant (NOP) Superfund site has been a topic of interest to the local property owners, the U.S. Army Corps of Engineers, and the local regulatory agencies. The Record of Decision for the site includes the extraction, treatment, and disposal of almost 3,000 gpm of groundwater with an estimated restoration time period exceeding 100 years. Interest from property owners and the Nebraska agency charged with regulating groundwater supply prompted the Corps of Engineers to consider several strategies for beneficially reusing the treated water. Alternatives included the establishment of a rural water district or local distribution system; delivery of the water to the municipal supply system of Lincoln, Nebraska, andsol;or other nearby municipalities; and consideration of innovative remedial technologies to reduce the quantity of treated water requiring disposal. The selected disposal plan consists of providing treated groundwater to interested parties for agricultural use with excess treated groundwater discharged to two streams. Multiple feasibility studies were generated, public input was solicited, and interagency agreements were executed during the course of the project. The remediation project is currently being constructed, and at least one property owner has constructed a new center‐pivot irrigation system to use the treated groundwater. © 2001 John Wiley & Sons.     

Monitoring parameters and statistics: A land treatment unit monitoring case study

Statistical evaluation procedures for monitoring data at facilities permitted under the Resource Conservation and Recovery Act (RCRA) are frequently established before monitoring begins. Selecting the statistical method before background data have been collected often leads to the use of statistical procedures that are inappropriate for the actual monitoring data. Such was the case for unsaturated zone monitoring at a permitted land treatment unit in the Gulf Coast area of Texas. Due to the large number of “not detected” results in the background database for lysimeters, statistical evaluation procedures specified in the original RCRA permit yielded an artificially low standard deviation, resulting in background values that were strongly biased on the low side. An alternate statistical procedure based on probability plots was developed and was accepted by the state environmental regulatory agency. This technique, which has wide applicability for many types of environmental monitoring data, significantly reduced the chasing of false positives, thus saving potentially expensive investigations and remediations.     

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.     

Managing Excessive Methanogenesis During ERD/ISCR Remedial Action

Excessive production of methane has been observed at some remediation sites following the addition of organic hydrogen donors such as (emulsified) oils/lecithin, sugars, and conventional carbon + zero‐valent iron (ZVI) amendments. This is due to the fact that methanogens are commonly the most ubiquitous indigenous microbes in anoxic aquifer settings, and, under enriched environmental conditions, methanogens replicate every one to two hours (whereas Dehalococcoides spp., e.g., double in 24–48 hr). Hence, methanogens often bloom and dominate the microbial ecosystem following the addition of remedial amendments, thereby liberating large amounts of methane gas. There are at least three important consequences of this response:

1. By utilizing hydrogen, the methanogens compete with dechlorinating microbes, thus making inefficient use of the remedial amendment (just 20 ppm methane in groundwater represents an approximate 30 percent “waste” of added fermentable substrate (i.e., hydrogen donor)—this is a common and tangible detriment);
2. Methanogens can methylate heavy metals and their rapid growth consumes alkalinity, while generating acidity, thereby facilitating multiple potential mechanisms for creating secondary contaminant issues (i.e., arsenic plumes); and
3. Elevated methane concentrations can exceed current and pending regulations of <10 to <28 ppm methane in groundwater and/or 0.5 percent by volume methane in soil gas (e.g., 10 percent of the lower explosive limit) and/or indoor air (methane is flammable between 5 percent and 15 percent by volume) and this will induce migration of contaminant vapors potentially causing indoor air issues.

Considering the recent guidelines for indoor air published by the US Environmental Protection Agency, it is increasingly important to prevent excessive methanogenesis associated with remedial actions. From a regulatory perspective, public safety issues are paramount; from a property re‐use or real estate (brownfield) developers’ perspective, project delays are costly and can jeopardize an entire program. The use of antimethanogenic compounds as inhibitors of protein biosynthesis and the activity of enzyme systems unique to Archaea (i.e., methanogens) during in situ remedial action can improve contaminant removal while offering safer, more efficacious treatment, simply by impeding the methanogenic bacteria's ability to proliferate and out compete desired bacterial communities (e.g., Dehalococcoides spp.). ©2016 Wiley Periodicals, Inc.     

Expert software that matches remediation site and strategy

Expert software-based decision support is speeding the process of defining environmental hazards and identifying remedial responses for the U.S. Department of Energy's (DOE) hazardous waste cleanup projects throughout the United States. Pacific Northwest Laboratories' (PNL) Remedial Action Assessment System (RAAS), and associated Technology Information System (TIS), written for Macintosh computers (soon for PC-compatible computers), sort through an encyclopedic data base to help environmental engineers prepare the most appropriate remedial strategy. The system has been available to DOE and other U.S. government engineers since last year and will soon be commercially available.     

Advantages of finite‐structured environmental insurance policies

Over the last five years, insurance products have been expanded to assist companies better manage environmental liabilities. The most progressive of these products is a finite‐structured program whereby the convergence of insurance and financial markets expand the meaning of “alternative risk transfer.” Finite programs blend financial markets and banking concepts with risk transfer concepts to more effectively and efficiently allow the insured to manage the financial implications of its environmental liabilities. This article presents the advantages of using finite‐structured environmental insurance policies and discusses how potential insureds can protect against several types of remediation project risks, including cleanup costs, inflation uncertainty, and variability in investment returns. © 2001 John Wiley & Sons, Inc.     

Use of mixed technologies to remediate chlorinated DNAPL at a Brownfields site

A former chlorofluorocarbon manufacturing facility in northern New Jersey was purchased for redevelopment as a warehousing/distribution center as part of the New Jersey Department of Environmental Protection's Brownfields redevelopment initiative. Soil and groundwater at the site were impacted with dense nonaqueous‐phase liquids (chlorinated organic compounds) and light nonaqueous‐phase liquids (petroleum hydrocarbons). The initial remedial strategy (excavation and offsite disposal) developed by prior site owners would have been cost‐prohibitive to the new site owners and made redevelopment infeasible. Mixed remedial technologies were employed to reduce the cost of remediation while meeting regulatory contaminant levels that are protective of human health and the environment. The most heavily impacted soils (containing greater than 95 percent of the contaminant mass) were excavated and treated onsite by the addition of calcium oxide and lime kiln dust coupled with physical mixing. Treated soils were reused onsite as part of the redevelopment. Residual soil and groundwater contamination was treated via in situ injections of emulsified oil to enhance anaerobic biodegradation, and emulsified oil/zero‐valent iron to chemically reduce residual contaminants. Engineering (cap) and administrative (deed restriction) controls were used as part of the final remedy. The remedial strategy presented in this article resulted in a cost reduction of 50 percent of the initial remedial cost estimate. © 2008 Wiley Periodicals, Inc.     

The treatment of contaminated water at remedial wood preserving sites

Contaminated groundwater and surface water have posed a great challenge in restoring wood preserving sites to beneficial use. Often contaminated groundwater plumes extend far beyond the legal property limits, adversely impacting drinking water supplies and crop lands. To contain, treat, and/or remediate these valuable resources is an important part of restoring these impacted sites. Various options are available for remediating the groundwater and other affected media at these sites. Frequently, pump and treat technologies have been used that can provide well‐head treatment at installed extraction wells. This approach has shown to be costly and excessively time consuming. Some of the technologies used for pump and treat are granular activated carbon (GAC), biotreatment, and chemical oxidation. Other approaches use in‐situ treatment applications that include enhanced bioremediation, monitored natural attenuation (biotic and abiotic), and chemical reduction/fixation. Ultimately, it may only be feasible, economically or practicably, to use hydraulic containment systems. Depending upon site‐specific conditions, these treatment approaches can be used in various combinations to offer the best remedial action. A comparison of water treatment system costs extrapolated from the treatability studies performed on contaminated groundwater from the McCormick/Baxter Superfund site in Stockton, California, yielded operation and maintenance costs of $1.19/1,000 gal. for carbon treatment and $7.53/1,000 gal. for ultraviolet (UV) peroxidation, respectively.     

Off‐gas treatment carbon footprint calculator: Form and function

The quantification of greenhouse gas (GHG) emissions can be a powerful sustainability measurement indicator for assessing environmental impacts of various operations, which can include remediation of chemically impacted media or construction projects. A carbon footprint calculator was developed and is presented in this article as one tool for applying sustainable practices to environmental remediation—specifically to assess the GHG footprint for remediation projects. The calculator is constructed from a compilation of published metrics and “standards.” © 2008 Wiley Periodicals, Inc.     

California's Low‐Threat LUFT Site Closure Policy: Looking Forward

California's regulatory agencies have historically been at the forefront of national efforts to address environmental concerns. In 2012, California's agency for addressing leaking underground fuel tanks (LUFTs) adopted a policy that identifies low‐threat conditions warranting closure of an LUFT case. That development clearly fulfills the role of risk management in the risk assessment–risk management paradigm inherent in environmental remediation. It also encourages identification of additional categories of sites and other circumstances that are “low threat” to develop similar guidance on closure to apply to those sites. ©2015 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.     

You Know Your Environmental Contractor Is Out of Control When…

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

Facilitating brownfields transactions using Triad and environmental insurance

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