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.     

Accounting for Science and Uncertainty in Cleanup Levels: The Use of 1 μg/kg as the Cleanup Criterion for Dioxin in Soil

At hazardous waste sites, a 1 μg/kg (ppb) cleanup level has commonly been used for dioxin in residential soil. This article outlines reasons for the continued use of this value in site remediation. Dioxin, one of the most toxic compounds known, has been a focus of scientific study for many years. However, controversy continues to surround its regulation, with some scientists arguing that new scientific results support decreasing risk estimates for dioxin and others taking the opposite view. Part of this controversy appears to involve a decreasing emphasis on cancer and an increased concern about non-cancer and ecological impacts of dioxin. The 1 ppb soil cleanup level represents a reasonable generic value for dioxin, with higher or lower values required on a case-by-case basis to protect specific populations.     

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.     

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.     

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.     

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.     

Look at groundwater quality to set VOC cleanup levels

In 1981, the Arizona Department of Health Services (ADHS) discovered groundwater contamination by solvents and chromium at the Phoenix Goodyear Airport (PGA), just outside the city of Phoenix. ADHS and the U.S. EPA sampled the site for the next two years, finding that eighteen of their wells were contaminated with trichloroethene (TCE), six exceeding ADHS's action level of five micrograms per liter (μg/l). In 1983, the PGA site was added to the National Priorities List, and, in 1984, EPA began a $3 million remedial investigation, focusing on soils and groundwater. This article discusses how that investigation inspired the authors to develop a stream-lined evaluation method for PGA's volatile organic compounds (VOCs), the process for establishing VOC cleanup levels, and the $26 million of remediation work needed to be done at the site. The heart of this effort is a computer program called VLEACH, loosely standing for VOC-LEACHing, which anticipates the influence of VOCs on PGA's groundwater, even as remediation proceeds.     

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.     

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.     

Risk Assessment in Remediation: Accurately Accounting for Uncertainty

Cleanup levels at hazardous waste sites are typically developed based at least in pan on either generic or site-specific risk assessments. Risk assessment in its purest form should be a measure of the potential for a site to cause adverse effects and therefore should be used as the basis for cleanup. However, the process of risk assessment continues to be subject to problems, primarily related to inherent uncertainties in the exposure parameters and toxicity criteria that are the building blocks of the risk assessment. Criticism of risk assessments and risk-based decisions range from comments that the process inadequately protects human health to comments that the process is overly protective, and examples of both ends of the spectrum are readily available. Site remediation professionals should be aware of the issues related to uncertainty and understand the potential problems in order to ensure appropriate and effective site cleanup. © 1999 John Wiley & Sons, 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.     

Effects of cosolvency in the fate and transport of PCBs in soil

Under the purview of EPA's Remedial Engineering Management (REM III) Superfund contract, a CERCLA RI/FS was performed at the Pinettes Salvage Yard site located in Washburn, Maine (EPA Region I). The purpose of the RI/FS was to fully characterize the nature, extent, and fate and transport of PCB contamination resulting from an alleged surface spill of transformer dielectric fluid containing Arochlor 1260 (a polychlorinated biphenyl) and various volatile and semivolatile organic constituents. The RI/FS was performed subsequent to both an immediate removal action (IRA) and a deletion remedial investigation (DRI) performed by EPA contractors. Results of both efforts indicated that the site was unsuitable for deletion from the National Priorities List (NPL) because the site soils contained elevated levels of PCBs. This article presents a case history of the extensive field investigations performed to characterize the contaminant source and evaluate the fate and transport of PCBs in site soils. These investigations included on-site mobile laboratory gas chromatograph (GC) analytical techniques for PCBs and targeted volatile and semivolatile organic compounds; confirmatory Contact Laboratory Program (CLP) laboratory analyses of soils, sediments, surface water, and groundwater samples; statistical analyses and correlation of field mobile laboratory GC data with CLP laboratory analytical results; and an evaluation of the potential effects of cosolvency in the fate and transport of PCBs in subsurface soils.     

Remediation and future land use: Incorporating reuse considerations into Superfund activities

The U.S. Environmental Protection Agency (US EPA) is placing increased emphasis on the selection and implementation of remedies that accommodate the reasonably anticipated future use of contaminated land. These remedies result in the long‐term protection of human health and the environment. Postconstruction reuse of the land can significantly benefit communities in other ways as well. The launching of the Superfund Redevelopment Initiative in 1999 and the Return to Use Initiative in 2004 reflects an evolution in the US EPA's understanding of what actions can be taken to support the reuse of Superfund sites from discovery through long‐term stewardship. Through these initiatives, the US EPA has increased its understanding of site reuse and continues to explore and implement reuse assessment, reuse planning, and other tools effective in integrating reuse considerations with response activities throughout the remedial process. © 2005 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.     

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.     

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.     

Forum

The State of Washington's Model Toxics Control Act cleanup standards, argues the author, provide the best available strategy for setting and achieving cleanup goals. Besides Protecting human health and the natural environnment, Washington's guidelines, which took effect March 1, 1991, incorporate enough flexibility to handle site-specific, finaical, and tehnological considerations. This column outlines the law's three approaches for defining cleanup levels for groundwater, surface water, air, industrial soils, and nonindustrial soils, comparing these methods with related methods in California, New Jersey, and New York.     

A dynamic methodology for estimating cleanup efforts for mercury in soil at gas utility gate stations

This article provides an overview of a dynamic methodology leading to the estimation of the level of mercury concentration in soil and soil cleanup volumes associated with a large number of gate stations suspected of having mercury in their soil. The methodology uses a unique screening approach that has been developed for relating measurements of volatile mercury near the surface to mercury concentration in the upper soil subsurface (about twelve inches deep). The screening approach was used in an effort to reduce the number of sites that are subject to extensive multimedia environmental sampling and analysis. The approach helps to focus on a small number of sites that are suspected of having the highest mercury concentration in soil, perform multimedia environmental sampling at these sites, use the field data to perform risk assessment, and determine the cleanup action levels and the volume of hot spots soil to be cleaned at these sites. The information obtained for the most contaminated sites is used to determine, if required, the level of cleanup for less contaminated sites.