P.E.

Environmental Exam Review: Environmental Assessment and Remediation

Mark P. Saliga, P.E. Email: mark_saliga@shieldmw.com

Presentation Outline
1. Environmental Assessments i. Regulatory Overview ii. Site Assessments (Phase I and Phase II) iii. Risk Assessments 2. Environmental Remediation i. Cleanup Standards ii. Site Specific Conditions iii. Treatment Perspectives and Alternatives iv. Treatment Evaluation, Screening, Selection and Implementation v. Site Closure Management Options
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Regulatory Overview for Environmental Assessments & Remediation

National Environmental Policy Act (NEPA) of 1969
Requires federal government to consider environmental effects of many actions that are federally funded

Clean Air Act (CAA) of 1970

New Performance Standards Emission standards for Hazardous Air Pollutants (HAPs) Requires proper use and disposal of chemicals

Federal Insecticide, Fungicide and Rodenticide Act of 1972

Regulatory Overview for Environmental Assessments & Remediation Federal Water Pollution Control Act of 1972
Established National Pollution Discharge Elimination System (NPDES) Section 208 established area wide waste treatment planning programs Created dredge and fill permit requirements

Safe Water Drinking Act (SWDA) of 1974

Sets standards for purity by public water systems

Toxic Substances Control Act (TSCA) of 1976

Established toxic release inventory requirements

Regulatory Overview for Environmental Assessments & Remediation

Resource Conservation and Recovery Act (RCRA) of 1976
Created cradle to grave (i.e., disposal) tracking requirements for hazardous waste materials The 1986 amendment of RCRA focused on management of Underground Storage Tanks (USTs) Established effluent standards on an industry by industry basis The 1987 reauthorization of the CWA focused on toxic substances

Federal Clean Water Act (CWA) of 1977

Regulatory Overview for Environmental Assessments & Remediation

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980
Created the Superfund Program to cleanup abandoned hazardous waste sites

Superfund Amendments and Reauthorization Act (SARA) of 1986

Reauthorized CERCLA

Emergency Planning and Community Right to Know Act (EPCRA) of 1986

Authorized by SARA Outlines industry reporting and public notice reporting requirements
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Regulatory Overview for Environmental Assessments & Remediation Small Business Liability Relief and Revitalization Act of 2002
the Brownfields Law signed by President Bush on January 11, 2002 The term Brownfield means, with certain legal exclusions and additions, real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutants, or contaminants Amends CERCLA Provides funds to assess and cleanup brownfield sites

Site Assessments
Questions What is a Phase 1 Environmental Site Assessment? What is a Phase 2 Environmental Site Assessment?

Site Assessments Phase 1 Environmental Site Assessment (PESA)

The following of Relevant Federal and ASTM Standards, through All Appropriate Inquiry (AAI) to identify Recognized Environmental Conditions (RECs)

Phase 2 Environmental Site Assessment

Site Characterization using waste, soil and groundwater sampling and analyses to determine if RECs actually exist at an unacceptable risk level to human health and the environment

Site Assessments Phase 1 Environmental Site Assessment (PESA)

Relevant Federal and ASTM (American Society for Testing and Materials) Standards
ASTM E1527-00 (from 2000) Standard Practice for Environmental Site Assessments: Phase 1 Environmental Site Assessment Process Contains requirements for a PESA for a commercial real estate property transaction related to possible environmental contamination Scope, Referenced Documents, Terminology, Significance and Use, Users Responsibilities, Phase 1 Environmental Site Assessment, Records Review, Site Reconnaissance, Interviews with Owners and Occupants, Interviews with Local Government Officials, Evaluation and Report Preparation, Non-Scope Considerations Updated and replaced by ASTM E1527-05 (in 2005)
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Site Assessments Phase 1 Environmental Site Assessment (PESA) Relevant Federal and ASTM Standards
ASTM E1528-00 (from 2000) Standard Practice for Environmental Site Assessments: Transaction Screen Process Replaced ASTM Standard E1528-93 (from 1993) Contains requirements for a Transaction Screen for a commercial real estate property transaction related to possible environmental contamination Scope, References, Terminology, Significance and Use, Questionnaire, Owner / Occupant Inquiry, Site Visit, Records Review, Non-Scope Considerations Determined in 2005 to no longer meet the requirements of All Appropriate Inquiry (AAI)
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Site Assessments Phase 1 Environmental Site Assessment (PESA)

Relevant Federal and ASTM Standards

USEPA Final Rule 40 CFR Part 312 (from 2005)

Federal Register Vol. 70, No. 210, dated 11-1-05 Final Rule to become effective 11-1-06 Contains requirements for All Appropriate Inquiry (AAI) for a commercial real estate property transaction related to possible Recognized Environmental Conditions (RECs)

Purpose, applicability, scope and disclosure obligations Definitions References All appropriate inquiries Results of inquiry by an environmental professional (PE or PG + 3 yrs experience or be licensed to perform AAIs or Baccalaureate in Eng. Or Science + 5 yrs experience or have 10 yrs experience) Additional Inquiries Interviews with past and present owners, operators, and occupants (including neighbors) Reviews of historical sources of information Searches for recorded environmental cleanup liens Reviews of Federal, State, Tribal, and local governmental records Visuals inspections of the facility and of adjoining properties Specialized knowledge or experience on the part of the buyer Relationship of the purchase price to the value of the property, if the property was not contaminated Commonly known or reasonably ascertainable information about the property The degree of obviousness of the presence or likely presence of contamination at the property, and the ability to detect the contamination by appropriate investigation 12

Site Assessments Phase 1 Environmental Site Assessment (PESA) Relevant Federal and ASTM Standards

ASTM E1527-05 (from 2005) Standard Practice for Environmental Site Assessments: Phase 1 Environmental Site Assessment Process
Replaced ASTM Standard E1527-00 (from 2000) ASTM E1527-05 issued 11-1-05 Contains requirements for All Appropriate Inquiry (AAI) for a commercial real estate property transaction related to possible Recognized Environmental Conditions (RECs) Scope Referenced Documents Terminology Significance and Use Significance of Activity and Use Limitations Users Responsibilities Phase 1 Environmental Site Assessment Records Review Site Reconnaissance Interviews with Past and Present Owners and Occupants Interviews with State and/or Local Government Officials Evaluation and Report Preparation Non-Scope Considerations

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Site Assessments Phase 1 Environmental Site Assessment (PESA) Questions What is All Appropriate Inquiry (AAI)? What are Recognized Environmental Conditions (RECs)?

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Site Assessments Phase 1 Environmental Site Assessment (PESA) All Appropriate Inquiry (AAI)
The requirement for assessing the environmental conditions of a property prior to its acquisition Required by innocent landowners, bona fide prospective purchasers, and contiguous property owners Significant changes to PESA requirements include;
Inquiry by an environmental professional (PE or PG + 3 yrs experience or be licensed to perform AAIs or Baccalaureate in Eng. or Science + 5 yrs experience or have 10 yrs experience) Interviews with past and present owners, operators, and occupants (including neighbors) Searches for recorded environmental cleanup liens Visuals inspections of the facility and of adjoining properties Evaluating specialized knowledge or experience on the part of the buyer Relationship of the purchase price to the value of the property, if the property was not contaminated Commonly known or reasonably ascertainable information about the property Non-Scope Considerations
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Site Assessments Phase 1 Environmental Site Assessment (PESA) Recognized Environmental Conditions (RECs)
REC means the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, ground water, or surface water of the property. RECs do not include de minimus conditions that generally do not present a threat to human health and the environment.

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Site Assessments Phase 2 Environmental Site Assessment Site Characterization

Invasive Study to include drilling and sampling of possibly waste material, soil and/or groundwater Overall goal is to determine the nature and extent of constituents of concern (COCs) related to the RECs identified during the Phase 1 Environmental Site Assessment including All Appropriate Inquiry The term nature means what COCs are present in the waste, soil or groundwater The term extent means what is the horizontal and vertical extent of the COCs encountered above regulatory cleanup standards Site Characterizations are typically performed in phases with subsequent phases being informed by the results of previous phases.
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Site Assessments Phase 2 Environmental Site Assessment Characterization of Waste Material

Waste Study to include
Sample and analyze identified waste material to determine if constituents of concern (COCs) are present Samples may be collected from tanks, drums, vats, pipelines, piles, or anywhere that the existence of waste material is identified Detections of COCs in waste material makes further study work related to soil and/or groundwater obviously necessary

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Site Assessments Phase 2 Environmental Site Assessment Characterization of Site Soils

Soil Study to include Advance number and depth of soil borings as needed based on estimated contaminant migration habits Field screen soil samples collected with a Photo Ionization Detector (PID), Flame Ionization Detector (FID), or a Organic Vapor Analyzer (OVA) Analyze selected soil samples with highest field screening results for COCs Remember that contamination in soil can migrate along numerous pathways (utilities, backfill, foundations, etc.) Properly abandon, by grouting, all borings after sample collection

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Site Assessments Phase 2 Environmental Site Assessment

Characterization of Site Groundwater
Groundwater Study to include Install number of groundwater monitoring wells (MWs) as needed, usually 3 to 10 (source area, down gradient, up gradient, off-site, etc.) Select type of MW to install (Type I, II or III) Set appropriate MW screen depths (floaters versus sinkers) Use appropriate MW materials (teflon, stainless steel, pvc) Survey well casings and gauge water levels in MWs to determine groundwater flow direction Sample and analyze groundwater from MWs to determine if constituents of concern (COCs) are present. Be sure MWs are properly developed and purged prior to sampling. Sample and analyze water from on site drinking water wells to determine if COCs are present If identified RECs threaten to effect surface water then ditch, stream and/or pond water and sediment may need to be sampled and analyzed

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Site Assessments Phase 2 Environmental Site Assessment

Sampling and Analyses for Waste Material, Soil, or Groundwater

Constituents of Concern (COCs) may include the following depending on RECs identified or selection approach used
Volatile Organic Compounds (VOCs) Semivolatile Organic Compounds (SVOCs) including Polynuclear Aromatic Hydrocarbons (PAHs) Heavy Metals (total and/or dissolved) Polychlorinated Biphenyl (PCBs) Herbicides Pesticides

Analytical parameter selections

Shotgun all of the COCs above Known Waste Stream focused and limited Chemical Class focused and limited Cost Effective limit COCs based on earlier data received High Liability guessing to save money

Compare analytical results to regulatory cleanup objectives

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Risk Assessments
Risk Assessments, conducted after Phase 1 and Phase 2 ESAs, may Include

Contaminant characteristic and partitioning analysis Exposure scenarios evaluation Exposure pathways evaluation Contaminant migration analysis (fate and transport)
soil, groundwater, vapor, pipelines, backfill, etc.

Inherent toxicity of chemicals identified Conceptual Modeling

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Risk Assessments
Questions What is Environmental Risk? What is an Environmental Risk Assessment?

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Risk Assessments
Environmental Risk
USEPA considers risk to be the chance of harmful effects to human health, or to ecological systems, resulting from exposure to an environmental stressor. A stressor is any physical, chemical, or biological entity that can induce an adverse response. Stressors may adversely affect humans, specific natural resources or entire ecosystems, including plants and animals, as well as the environment with which they interact.

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Risk Assessments Environmental Risk Assessment Risk Assessment is used to characterize the nature and magnitude of health risks to humans (e.g., residents, workers, recreational visitors, etc.) and ecological receptors (e.g., birds, fish, wildlife, etc.) from chemical contaminants and other stressors, that may have been identified to be present in the environment during Phase 1 and 2 ESAs.

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Risk Assessments
Risk assessment is, to the highest extent possible, a scientific process. In general terms, risk depends on the following factors: How much of a chemical is present in an environmental medium (e.g., soil, water, air), How much contact (exposure) a person or ecological receptor has with the contaminated environmental medium, and The inherent toxicity of the chemical. Based on this, the Risk Assessor evaluates the frequency and magnitude of human and ecological exposures that may occur as a consequence of contact with the contaminated medium, both now and in the future. Based on this, conceptual modeling may be produced to outline and present the findings to project Stakeholders

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Cleanup Standards for Environmental Remediation

Question What effects project specific environmental remediation cleanup standards?

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Cleanup Standards for Environmental Remediation

Project Specific Environmental Remediation Cleanup Standards may be effected by:

Federal regulations and guidance documents
Federal Superfund sites Federal government owned properties Army, Navy, Air Force facilities Trans State properties Depending on site location (USEPA Region 9 Preliminary Remediation Goals ?) Example: Illinois regulation Tiered Approach to Corrective Action (TACO) is an approach for developing remediation objectives that includes three tiers for selecting applicable remediation objectives. Example: Mississippi regulation is ??????????
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State regulations and guidance documents

Cleanup Standards for Environmental Remediation

Local requirements City government and/or Environmental Department Local Sewer District City Engineering Department Air Pollution Control Board Regulatory agency jurisdiction and participation Federal, State, Tribal, and/or Local Soil, Water, and/or Air Intended land use Residential, Industrial, or Commercial

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Cleanup Standards for Environmental Remediation

Risk Based Corrective Action (RBCA) RBCA is not a substitute for corrective action, but a tool for determining the amount and urgency of action necessary. RBCA helps you to categorize sites according to risk and allocate resources for maximum protection of human health and the environment. You can use RBCA to: Identify exposure pathways and receptors at a site Determine the level and urgency of response required at a site Determine the level of oversight appropriate for a site Incorporate risk analysis into all phases of the corrective action process Select appropriate and cost-effective corrective action measures
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Possible Remedial Alternatives for Environmental Remediation

All Possible Remedial Alternatives have the following issues that need to be considered
Applicability to site conditions and COCs targeted Limitations to effectiveness Data needs required for evaluation and design Performance data requirements during operation Costs

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Possible Remedial Alternatives for Environmental Remediation Possible Evaluations for Remedial Alternative and Technology Selection
1. 2. 3. 4. 5. 6. Site Specific Cleanup Standards (as discussed above) Site Specific Conditions Possible Treatment Perspectives Possible Treatment Technology Alternatives Specific Treatment Evaluations, Screening and Selection Selected Treatment Implementation and Post Implementation Requirements

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Site Specific Conditions effecting Environmental Remediation

Question What site specific conditions may effect environmental remediation?

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Site Specific Conditions effecting Environmental Remediation

Effects may Include:
The nature of contaminants
What COCs are present in the waste, soil or groundwater? What COCs are present (VOCs, SVOCs, PAHs, Metals, PCBs, Herbicides, Pesticides)? What is the horizontal and vertical extent of the COCs encountered? Waste, soil, groundwater, surface water, and / or vapors? Porosity Groundwater gradients and velocity Hydraulic conductivity Transmissivity Salt water encroachment Aquifer tests may be required Detailed extraction well design may be required

The extent of contaminants

Location of contaminants

Site Hydrogeology

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Site Specific Conditions effecting Environmental Remediation

Types and conditions of soils Gravel, Sand, Silt, and/or Clay Organic and/or Peat material Physical obstructions Under buildings or structures? Is area capped? Are underground utilities or structures present? Off site property access required? Sensitive Environmental Features Surface waters (rivers, lakes, ponds, etc.)
Wetland areas

Drinking water use (wells, cisterns, reservoirs, etc.)

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Treatment Perspectives for Environmental Remediation

Remedial Action Alternatives for Waste Material
1. 2. 3. 4. Off site disposal Off site treatment Off site recycling Ex-Situ On-site Treatment (i.e., out of the ground treatment)

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Treatment Perspectives for Environmental Remediation

Remedial Action Alternatives for Subsurface Soils
In-Situ Treatment (i.e., in the ground treatment) Biological, Physical, or Chemical Ex-Situ Treatment (i.e., out of the ground treatment) Biological, Physical, Chemical, or Thermal Air Emissions / Off-gas Treatment Usually for VOCs Biological, Physical, Thermal, or Chemical Other Methods Excavation and off-site disposal Containment

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Treatment Perspectives for Environmental Remediation

Remedial Action Alternatives for Groundwater
In-Situ Treatment (i.e., in the ground treatment) Biological, Physical, or Chemical Ex-Situ Treatment (i.e., out of the ground treatment) Biological, Physical, or Chemical Air Emissions / Off-gas Treatment Usually for VOCs Biological, Physical, Thermal, or Chemical Other Methods Natural Attenuation

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Question

Possible Treatment Technology Alternatives for Environmental Remediation

What overall groups of treatment technology processes are available to be used for environmental remediation?

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Possible Treatment Technology Alternatives for Environmental Remediation

Biological Treatment Physical Treatment Chemical Treatment Thermal Treatment Air Emissions / Off-gas Treatment

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Possible Treatment Technology Alternatives for Environmental Remediation

Biological Treatment
Bioventing (in-situ for soils)
Supplies existing bacteria with oxygen as an electron acceptor. Only useful when all other bacterial requirements already exist. Applicable to petroleum hydrocarbons, non chlorinated solvents, some pesticides, wood preservatives, and various organic COCs. Not applicable to inorganics. Limitations include groundwater interference, COC vapor formation, and temperature dependency

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Possible Treatment Technology Alternatives for Environmental Remediation (bio) Enhanced Bioremediation or Biodegradation (insitu for soils and groundwater)
Use of indigenous bacteria, fungus or other microbes. Aerobic processes, using oxygen (O2) as an electron acceptor, will convert organic COCs to intermediate products, CO2, H2O and microbial cell mass. Anaerobic processes, using something other than oxygen (ex, NO3, MnIV, FeIII, SO4) as an electron acceptor, will convert organic COCs to intermediate products, methane, limited CO2, and trace hydrogen gas. Need to evaluate environmental factors including; available microbial groups, microbial metabolism, biodegradation kinetics and rates of COCs, available electron acceptors, and available nutrients. Also evaluate physical and chemical factors including; temperature, pH, moisture content, and Oxidation-Reduction (Redox) Potential. Typically involves the percolation or injection of uncontaminated water mixed with nutrients, saturated with an electron acceptor, and mixed with a co-metabolite

Applicable to petroleum hydrocarbons, solvents, pesticides, wood preservatives, and various organic COCs. Not applicable to inorganics. Limitations include limited porosity soils, non-existence of insitu bacteria and temperature dependency 42

Possible Treatment Technology Alternatives for Environmental Remediation (bio) Phytoremediation using plants (in-situ for soil and groundwater)
Facilitates, with aesthetic benefits, direct uptake mechanism by plants and/or trees (i.e., extraction of organic compounds) or degradation in Rizosphere (i.e., root zone). Can also be referred to as phytostabilization , phytoextraction, or phytofiltration using aquatic plants or algae. Applicable to organic and inorganic COCs including heavy metals, nutrients, (i.e., nitrogen), PAHs, pesticides, Limitations include limited to shallow reach depth, plant toxicity from highly contaminated soils, and requirements for long term maintenance.
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Possible Treatment Technology Alternatives for Environmental Remediation (bio)

Biopiles [composting, controlled solid phase treatment, land farming] (ex-situ for soils, sediments and sludges)
Process by which organic COCs are converted by microorganisms to innocuous and stabilized byproducts through addition of amendments. Applicable to petroleum hydrocarbons (with lower molecular weight), soils, sediments, sludges, containing biodegradable organic compounds, explosives, non chlorinated compounds, and to a limited extent; some pesticides and heavier VOCs or SVOCs. Not applicable to inorganics. Limitations include large areas are needed for implementation, ex-situ process, may include liner requirements and leachate collection and treatment.
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Possible Treatment Technology Alternatives for Environmental Remediation (bio) Slurry Phase Treatment (ex-situ for soils and sludges)
Excavated soil is mixed with water, nutrients, and air in a tank to facilitate treatment. Slurry in tank (ca. 10 to 40% solids) is then continuously mixed during treatment. Applicable to explosives, and organics including petroleum hydrocarbons, petrochemicals, solvents, pesticides, and wood preservatives. Not applicable to inorganics. Limitations include need to treat water effluent, longer treatment times, ex-situ process, and high costs.
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Possible Treatment Technology Alternatives for Environmental Remediation (bio) Natural Attenuation (in-situ for groundwater)
Reduce levels of organic COCs through dilution, volatilization, biodegradation, adsorption, and chemical reactions. Not the same as no action. Applicable to VOCs, SVOCs, and petroleum hydrocarbons Limitations include requirements for extensive site characterization, possible production of more toxic intermediate degradation products, removal of source area may be required, highly skilled modeling is required.
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Possible Treatment Technology Alternatives for Environmental Remediation Physical Treatment Over-excavation and off-site treatment or disposal (ex-situ for soils)
Contaminated material is removed and transported to permitted off-site treatment and/or disposal facilities. Applicable to a complete range of COCs. Limitations include possible land disposal restrictions (LDRs) of COCs, fugitive emissions, extensive depth of excavation required, and possible relocation, not treatment, of contaminants.
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Possible Treatment Technology Alternatives for Environmental Remediation (physical) Capping and/or Containment (in-situ for soils and groundwater)
The process of eliminating potential receptor exposure by cutting off access to existing contaminated soil or groundwater. Soil access is typically cut off by construction of an impermeable cap above the area of concern that cannot be modified (i.e., concrete, asphalt, building, etc.). Groundwater access is typically cut off by containing the contaminated groundwater, via pumping wells or underground slurry cut-off walls, and restricting water pumping and use in the area. These technologies only restrict access but do not treat contaminants. Applicable to a complete range of COCs. Limitations include widespread areas of impacts and contamination that has migrated to adjoining properties.
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Possible Treatment Technology Alternatives for Environmental Remediation (physical) Solidification / Stabilization / Vitrification (insitu for soils)
Process to immobilize or destroy contaminants through either physical and chemical means. Auger/caisson or injection head systems are used to apply solidification or stabilization agents to in-situ soils. Vitrification uses electrodes to melt soils and create vitrified glass or crystalline mass. Applicable to inorganics, SVOCs (limited), and pesticides (limited) for S/S. For Vit, applicable to inorganics, VOCs, SVOCs, dioxins, PCBs, metals, and radionuclides. May not be applicable at depths below 20 feet. Limitations include soil vapor creation, changes in soil characteristics, extreme depths of COCs, limited future land use, soil expansion, or possible COC migration.
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Possible Treatment Technology Alternatives for Environmental Remediation (physical) Soil Flushing (in-situ for soils)
The process of applying water or other suitable aqueous solutions (ex, surfactants) to a soil area effected by COCs. Water may be extracted from the underlying aquifer, treated with additives, and then injected or infiltrated into the in-situ soils. Applicable to inorganics, radioactive contaminants, VOCs, SVOCs, fuels, pesticides, and metals. Limitations include non effective use in low permeability soils, reduction of soil porosity, sorption of COCs to soils, and possible spreading of contaminants.
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Possible Treatment Technology Alternatives for Environmental Remediation (physical)

Soil Washing (ex-situ for soils)
A water based process for scrubbing soils to remove contaminants. The scrubbing process also removes coarser particles from the soil that do not require treatment. The wash solution is later treated by conventional wastewater treatment methods. Applicable to soils which contain clay, silt, and organics that bind the COCs including heavy metals, radionuclides, selected VOCs, selected pesticides, SVOCs, and fuels. Limitations include fine soil particles, complex waste mixtures, high humic content, and treatment requirements of the wash solution.
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Possible Treatment Technology Alternatives for Environmental Remediation (physical)

Soil Vapor Extraction (SVE) or Dual Phase Extraction (DPE) (in-situ for soils and groundwater)
SVE uses an applied vacuum to induce a control flow of air to remove COCs from the subsurface soil. DPE uses the applied vacuum to remove both soil vapor and groundwater from the subsurface. The removed vapor and/or groundwater is then separated and treated aboveground, per local or state regulatory requirements, prior to discharge. SVE or DPE technology may also be enhanced by in-situ thermally heating the subsurface to increase the mobility of the COCs. Applicable to VOCs, lighter fuels, along with some SVOCs and pesticides with thermal enhancement. Limitations include ineffectiveness on heavy oils, metals, PCBs, dioxins, tight clays, high moisture content (SVE), and highly adsorbed COCs.
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Possible Treatment Technology Alternatives for Environmental Remediation (physical) Air Sparging (AS) (in-situ for groundwater)
AS is an in-situ technology in which air is bubbled through a contaminated aquifer creating an underground stripper that removes COCs via volatilization. These air bubbles, and the COCs, are typically collected by an SVE system if vapor intrusion into a building is of concern. Applicable to VOCs and lighter fuels. Limitations include extreme thickness of contaminated aquifer, and heterogeanous soils.

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Possible Treatment Technology Alternatives for Environmental Remediation (physical) Pumping and treating (ex-situ for groundwater)
A technology by which contaminated groundwater is removed from the subsurface, treated aboveground, and then discharged to a surface water body, or public sewage plant, or re-injected as clean water. Aboveground treatment of the collected water is generally a well established procedure, however collection of all the contaminated water via pumping can be problematic. Applicable to a wide range of COCs, however the particular COCs being treated will factor in the selection of the treatment technology (ex, carbon absorption, bioreactors, air stripping, UV oxidation, constructed wetlands treatment, filtration, chemical oxidation, precipitation, chemical reduction/oxidation, free product separation, etc.). Limitations include typically long time frames for treatment success, extensive pumping rates, ineffectiveness in final treatment polishing, and possibly long term operation and maintenance.

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Possible Treatment Technology Alternatives for Environmental Remediation (physical) Hydraulic or Pneumatic Fracturing (in-situ for soils and groundwater)
Hydraulic and/or pneumatic fracturing is an enhancement technology used to increase the injection or extraction efficiency of other in-situ remediation (ex, SVE, bioremediation, pump and treat). Water or air is injected to develop cracks in low permeability and over-consolidated sediments or soils. Applicable to the complete range of COCs where in-situ technology is planned. The technology is used primarily to fracture silts, clays, shale, and bedrock. Limitations include underground utilities, possible spreading of contaminants, possible short lasting fractures, and non applicability in highly seismic areas.
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Possible Treatment Technology Alternatives for Environmental Remediation

Chemical Treatment
Reactive Zones or Walls (in-situ for groundwater)
Utilizes a passive in-situ permeable reaction zone or wall installed underground across the flow path of contaminated groundwater to treat the COCs prior to further migration. Treatment is typically achieved by chelators, sorbents, microbes, ion exchange, etc.). Applicable to VOCs, SVOCs, and inorganics. Limitations include limited reactive capacity of treatment material, fluctuating pH levels, and possible extensive depth and width of zone or wall.
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Possible Treatment Technology Alternatives for Environmental Remediation (chem) Chemical Oxidation (in-situ for soil or groundwater)
Utilizes treatment chemicals that are injected into the subsurface within contaminated soils, or across the flow path of contaminated groundwater, to treat the COCs in place or prior to further migration. Some chemicals used for treatment are hypochloride, hydrogen peroxide, potassium permanganate, or sodium permanganate. Applicable to VOCs, SVOCs, chlorinated solvents, and some inorganics. Limitations include limited reactive capacity of treatment chemical, limited injection zone of influence, and possible extensive depth and width of injection.

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Possible Treatment Technology Alternatives for Environmental Remediation Thermal Treatment

High Temperature Thermal Desorption (ex-situ for soils) A technology in which contaminated soils, post excavation, are heated to > 600 F to volatilize water and organic COCs. COCs are not treated by the high temperature but air emissions are then treated prior to discharge. Applicable to VOCs, fuels, SVOCs, PAHs, PCBs, some metals, and pesticides. Limitations include larger soil particle size, possibly long residence times, high moisture content, clay, silt, and high humic content.

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Possible Treatment Technology Alternatives for Environmental Remediation (therm) Low Temperature Thermal Destruction (ex-situ for soils)
A technology in which contaminated soils, post excavation, are heated to < 600 F to volatilize water and organic COCs. Typical designs include rotary dryer and thermal screw. COCs are not treated by the applied temperature but air emissions are then treated prior to discharge. Applicable to nonhalogenated VOCs, fuels, and some SVOCs Limitations include larger soil particle size, possibly long residence times, high moisture content, and heavy metal content.
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Possible Treatment Technology Alternatives for Environmental Remediation (therm)

Incineration (ex-situ for soils)
A technology (typically a rotary kiln) in which contaminated soils or wastes, post excavation, are heated to > 1,400 F to volatilize and combust COCs. All COCs that are not combusted are not treated by the high temperature but air emissions are then further treated prior to discharge. Applicable explosives, chlorinated hydrocarbons, PCBs, dioxins and listed/characteristic hazardous wastes. Limitations include limited permitted treatment systems for PCBs and dioxins, larger soil particle size, heavy metal content, and ash residue management requirements.
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Possible Treatment Technology Alternatives for Environmental Remediation

Air Emissions / Off-gas Treatment

As stated above, certain technologies for environmental remediation also require air emission or off-gas treatment for the technology to be permitted and/or successful. Some of these include soil washing, SVE, air strippers, and thermal treatment. Typically, although dependent on the COCs being treated, the following air emission / off-gas treatment technologies are utilized: Biofiltration includes passing contaminated air through a packed media (i.e., biofilter) in which it is sorbed and degraded by microorganisms prior to discharge. High Energy Corona Destruction includes passing contaminated air through a packed bed in which high-voltage electricity is used to destroy the COCs prior to discharge.

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Possible Treatment Technology Alternatives for Environmental Remediation (air)

Membrane Separation includes passing contaminated air through a nonporous gas separation membrane in which COCs are condensed and collected for disposal. Oxidation (thermal or catalytic) includes passing contaminated air through oxidation equipment in which the COCs are oxidized and thus treated by burning (thermal) or reaction (catalytic facilitated) prior to discharge. Vapor-Phase Carbon Adsorption includes passing contaminated air through granular activated carbon (GAC) in which it is adsorbed and collected by the GAC prior to discharge. When full of COCs, the GAC is then removed from the system for off site disposal or regeneration. 62

Treatment Evaluations, Screening and Selection for Environmental Remediation

Question What evaluations should be performed to screen and select appropriate technologies for environmental remediation?

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Treatment Evaluations, Screening and Selection for Environmental Remediation

Question: What evaluations should be performed to screen and select appropriate technologies for environmental remediation? Answers:
Technical Environmental Human Health Institutional Cost
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Treatment Evaluations, Screening and Selection for Environmental Remediation

Technical Evaluation
Performance Estimated Time to Achieve Cleanup Objectives Reliability Ease of Implementation Safety

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Treatment Evaluations, Screening and Selection for Environmental Remediation

Environmental Evaluation
Facility Conditions and Constraints Nature and Extent of Contamination in Soil and/or Groundwater Soil Types Pathways of Contamination Chemical and Physical Characteristics of COCs Short and Long Term Benefits and Adverse Effects Environmentally Sensitive Areas

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Treatment Evaluations, Screening and Selection for Environmental Remediation

Human Health Evaluation

Mitigation of Short and Long Term Potential Exposure to Residual Contamination Protection of Human Health and the Environment During and After Implementation

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Treatment Evaluations, Screening and Selection for Environmental Remediation

Institutional Evaluation
Public Health Standards Governmental Regulations
Cleanup Standards

Guidance Documents Local Building Codes Short and Long Term Land Use Planning Community Relations

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Treatment Evaluations, Screening and Selection for Environmental Remediation

Cost Considerations
Consider Initial and Long Term Costs Direct Capital Costs (construction, equipment, building, services, relocation, disposal) Indirect Capital Costs (engineering, permitting, startup, contingency) Operation and Maintenance Costs (operating labor, maintenance material, energy, insurance, progress review monitoring and reporting) Consider Cost Effectiveness

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Implementation Requirements for Environmental Remediation

Design Options for System or Equipment

Full 100% For Bid design Performance Based design Design / Build

Construction Quality Assurance Quality Control (QA/QC)

Written QA/QC Programs, Policies and Procedures
Management Responsibility Documentation of Field Activities Construction Quality Control Requirements Health and Safety Requirements

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Implementation Requirements for Environmental Remediation

Construction Reliability
Inspection Requirements Schedule Preparation and Adherence Operational Maintenance Requirements and Performance
System Monitoring (equipment and chemicals) System Repair

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Implementation Requirements for Environmental Remediation

Post Construction Performance Evaluations

System Effluent (water and/or air) Monitoring Periodic Soil and/or Groundwater Monitoring Periodic Monitoring and Performance Evaluation Reporting
Future activity suggestions Eventual request for Site Closure or No Further Action status

Final System Abandonment and Removal

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Site Closure Management Options After Environmental Remediation

Question When evaluating, screening, and selecting environmental remediation alternatives and technologies, what are the possible end games for project completion to be considered?

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Site Closure Management Options After Environmental Remediation

When evaluating, screening, and selecting environmental remediation alternatives and technologies, the end game for project completion must be considered. Typically, a particular project is considered complete, through either clean closure or managed closure, when no further unknown action is required by the governmental regulator.

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Site Closure Management Options After Environmental Remediation

Clean Closure
No Further Action (NFA) through clean closure is typically requested by the responsible party and granted by the regulatory agency after site specific environmental remediation is completed. Alternatives or perspectives may include an evaluation that no action was necessary, management of contamination in place, site restoration through active treatment, or a combination of these.

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Site Closure Management Options After Environmental Remediation

Managed Closure
No Further Action (NFA) through managed closure is typically requested by the responsible party and granted by the regulatory agency after site specific environmental remediation has not been successful or has been deemed impracticable. Alternatives or perspectives may include an evaluation that no action was necessary, an evaluation that active corrective action was impracticable, management of contamination in place, or a combination of these.

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Site Closure Management Options After Environmental Remediation

Managed closure most likely may also require the following site controls be implemented. Engineering Barrier (EBs) is a physical feature that eliminates exposure routes and/or controls migration of COCs at the site. A barrier may be natural or human-made, but its effectiveness must be verified by engineering practices. Institutional Controls (ICs) are legal and/or administrative tools used to maintain protection of human health and the environmental at contaminated sites. ICs do not involve construction or physical changes to the site. The four general types of ICs are Governmental Controls, Proprietary Controls, Enforcement Tools, and Informational Devices. Site Management Plans (SMPs) are written documents that are attached to the property deed to help institute the identified engineering barriers and/or institutional controls. The SMP is to be implemented during future site operations including during and after any future redevelopment of the subject property site.
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?????? Any Questions ??????

Mark P. Saliga, P.E. Shield Environmental Associates, Inc. 11700 Commonwealth Drive, Suite 200 Louisville, KY 40299 Phone: (502) 493-0305 Email: mark_saliga@shieldmw.com
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References
American Society for Testing and Materials (ASTM), Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process E1527-00, 2000. American Society for Testing and Materials (ASTM), Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process E1527-05, 2005. Michigan Department of Environmental Quality, Introduction to Risk-Based Corrective Action, www.michigan.gov. Professional Publication s, Inc., Environmental Engineering Reference Manual, Belmont, CA. Sperber, Marc N., RCRA Corrective Action Manual, Thompson Publishing Group, New York, 1995. Suthersan, Suthan S., Remediation Engineering Design Concepts, CRC Lewis Publishers, New York, 1997.

United States Federal Remediation Technologies Roundtable (FRTR), Treatment Technologies Screening Matrix, www.frtr.gov.
USDOD, Remediation Technologies Screening Matrix and Reference Guide, 1994. USEPA, 40 CFR Part 312 Innocent Landowners, Standards for Conducting All Appropriate Inquires, Federal Register of 11/1/05. USEPA, Risk Assessment Portal, www.epa.gov/risk. WASTECH, Monograph Series (Phase II) on Innovative Site Remediation Technology: Design and Application, Annapolis, MD,.

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