Managing Risk
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Remediation/Cleanup
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Contaminated areas identified through site assessments may require remediation prior to revitalization. The fact that a site requires some environmental cleanup or corrective action in order to render it suitable for its proposed end use does not represent the barrier that it had in the past. Even sites once thought unmarketable due to requirements for long-term cleanup are now strong candidates for successful revitalization as a result of being incorporated into an innovative revitalization plan. Stakeholders now consider environmental cleanup costs to be a potential line item to be addressed in the project budget.
Prospective revitalization sites often have existing corrective actions associated with previous environmental activities. As such, revitalization teams should consider costs associated with operation and maintenance activities required for existing systems. These costs may include potential system optimization or replacement costs, permitting and monitoring costs, and reporting costs that may be associated with activities at the site.
Revitalization of environmentally contaminated properties requires the development of detailed cost estimates that include the entire range of activities that will be necessary. Successful teams will consider the following factors:
- Costs associated with removal or interim activities
- Design and construction costs
- Installation, testing, and startup costs
- Operation and maintenance costs, costs associated with environmental security measures, and institutional and engineering control costs
- Cost recovery by state or federal environmental agencies that may require reimbursement of oversight costs during investigation and cleanup
- Disposal, monitoring, and reporting costs
Financial issues associated with environmental cleanup activities and the mechanisms available for funding them are presented in Public Financing section of
Sources of Money.
An additional resource, the Environmental Knowledge and Assessment Tool (EKAT) is a Web-based tool used to identify, research, and evaluate environment and safety-related issues for products and systems. Used by both environmental and non-environmental professionals, EKAT was designed for Department of Defense environmental professionals, material acquisition specialists. Civilians and military alike can use EKAT to:
- Screen for environmental issues
- Educate employees and customers about environmental regulations
- Find valuable information about remediation of environmental contamination
- Understand hazardous waste handling requirements
EKAT is an easy to use, intuitive software package that offers assistance to people with little or no environmental background as well as environmental professionals.
The Remediation/Cleanup exhibit presents additional resources:
Exhibit: Remediation/Cleanup
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Program
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Summary
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A state-led coalition working together with industry and stakeholders to achieve regulatory acceptance of environmental technologies. ITRC consists of 49 states, the District of Columbia, multiple federal partners, industry participants, and other stakeholders, cooperating to break down barriers and reduce compliance costs. ITRC develops guidance documents and training courses to meet the needs of both regulators and environmental consultants.
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Gateway to state environmental and energy agencies. Includes links to some local government environmental offices.
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Provides an overview of the Superfund program, Superfund cleanup process, guides users to enforcement information, lists EPA's Superfund offices and partnership organizations, and provides answers to frequently asked questions.
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EPA's cleanup enforcement program protects human health and the environment by getting those responsible for a hazardous waste site to either clean up or reimburse EPA for its cleanup.
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Collaborative efforts among agencies for technology development, demonstration partnerships with private developers, consistent and unified federal approach to technology evaluation and regulatory acceptance, and technology transfer tools and other information resources.
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Contamination Removal
Feedback
Excavation and disposal, colloquially known as “dig and haul,” removes contaminated material (soil, solid wastes) from its current location and transports it to a permitted off-site treatment and/or disposal facility. The soil is excavated using construction equipment, like backhoes or bulldozers. Excavation is the initial component in all ex situ treatments. Excavation and off-site disposal is a well proven and readily implementable technology. However, additional factors that may limit the applicability and effectiveness of the “dig and haul approach' include:
- Prohibitive cost
- Generation of waste (not a sustainable practice)
- Generation of fugitive emissions (may be a problem during operations)
- The distance from the contaminated site to the nearest disposal facility with the required permits will affect cost
- Transportation of the soil through populated areas may affect community acceptability
- Disposal options for certain waste (for example mixed waste or transuranic waste) may be limited
The rate of excavation depends on a number of factors, including the number of loaders and trucks operating. For example, the excavation of 18,200 metric tons (20,000 tons) of contaminated soil would typically require about 2 months. Disposal of contaminated media is dependent upon the availability of adequate containers to transport the hazardous waste to a permitted facility. In addition, some pretreatment of the contaminated media is usually required to comply with land disposal restrictions. At some sites, the area to be excavated is not predetermined: as soil is removed the area surrounding it is sampled until all soil around the excavated site tests cleaner than the remedial objectives. The total time it takes to excavate soil depends on several factors:
- Types and amounts of harmful chemicals present
- Size and depth of the polluted area
- Type of soil
- Amount of moisture in the polluted soil (wet soil slows the process)
The type of contaminant and its concentration will impact off-site disposal requirements. Soil characterization as dictated by land disposal restriction (LDRs) are required. Most hazardous wastes must be treated to meet either RCRA or non-RCRA treatment standards prior to land disposal. Determining the feasibility of off-site disposal requires knowledge of land disposal restrictions an other regulations. The disposal of hazardous wastes is governed by RCRA (40 CFR Parts 261 – 265), and the U.S. Department of Transportation (DOT) regulates the transport of hazardous materials (49 CFR Parts 172 – 179, 49 CFR Part 1387, and DOT-E 8876).
The Contamination Removal exhibit presents additional resources:
Exhibit: Contamination Removal
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Program
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Summary
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Innovative web site provides quick access to compliance assistance tools, contacts, and planned activities from US EPA, its partners, and other compliance assistance providers.
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Gateway to state environmental and energy agencies. Includes links to some local government environmental offices.
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Provides suggestions and perspectives on how to demonstrate compliance with the alternative treatment standards for certain contaminated soils that will be land disposed.
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Presents RCRA history, regulations, guidance, policy, and resources.
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Provides an overview of the Superfund program, Superfund cleanup process, guides users to enforcement information, lists EPA's Superfund offices and partnership organizations, and provides answers to frequently asked questions.
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EPA's cleanup enforcement program protects human health and the environment by getting those responsible for a hazardous waste site to either clean up or reimburse EPA for its cleanup.
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Innovative Approaches
Feedback
Revitalization stakeholders open to innovative ideas and technologies to solve environmental issues often focus on finding ways to reach assessment and cleanup requirements more efficiently. Environmental research completed in support of Superfund indicated a clear shift toward faster, less expensive, more effective approaches to limiting costs associated with Superfund corrective action. The results of the years of research completed in support of these efforts are applicable to the expedited project schedules and stringent financial requirements associated with the revitalization of potentially contaminated sites. Faster, less expensive, and more effective cleanup technologies are also useful in the redevelopment environment where economic considerations drive successful revitalization.
There is a variety of excellent resources available regarding innovative processes and technologies that may be applicable in the expedited assessment and cleanup of potentially contaminated sites destined for reuse. The EPA Innovative Technology Resources Exhibit presents EPA resources as a starting point in stakeholder research.
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Program
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The SITE Program has compiled data regarding innovative environmental technology cost and performance since 1987.
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The mission of TIP is the promotion of innovative technologies as they enter and progress through the marketplace.
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The CLU-IN web site provides information about characterization and treatment technologies for the hazardous waste remediation community. It offers technology selection tools and describes programs, organizations, publications for federal and state personnel, consulting engineers, technology developers and vendors, remediation contractors, researchers, community groups, and individual citizens.
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EPA created the REACH IT System to compile and share information on treatment and characterization technologies for a range of contaminant types and media. Over time, this system was populated with information on over 500 remediation technologies and 260 characterization technologies. With the evolution of on-line search services and engines and the development of a range of other resources on technologies and vendors coupled with resource limitations, EPA discontinued the on-line REACH IT System in 2006. Upon discontinuation of the EPA REACH IT System, a fully searchable database is no longer available. However, limited technology vendor information is preserved in the form of two vendor summary lists.
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A cooperative effort to provide technical support to federal, state, and local officials on items related to use of technology for site investigation and cleanup. Can help decision makers evaluate strategies to streamline the site investigation and cleanup process, identify and review information about complex technology options, evaluate contractor capabilities and recommendations, explain complex technologies to communities, and plan technology demonstrations.
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Includes resources to assist in the identification and selection of innovative site characterization and cleanup technologies for site revitalization. The Road Map provides a generally applicable outline of the steps involved in the cleanup of a site slated for revitalization and introduces revitalization stakeholders to the range of innovative technology options and resources available to them.
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A state-led coalition working together with industry and stakeholders to achieve regulatory acceptance of environmental technologies. ITRC consists of 49 states, the District of Columbia, multiple federal partners, industry participants, and other stakeholders, cooperating to break down barriers and reduce compliance costs. ITRC develops guidance documents and training courses to meet the needs of both regulators and environmental consultants.
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The Hazardous Substances Technical Liaison Program (HSTLP) was created to:
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The ETV Program provides links to information regarding various site sampling, monitoring and characterization technologies, along with contact information for verified vendors that provide them.
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Superfund Accelerated Cleanup Model
Feedback
Several factors that have increased costs at CERCLA sites include extended site assessments with duplicative sampling efforts, litigation with potentially responsible parties (PRPs), and lengthy remedy selection analyses. In April 1992, EPA introduced the Superfund Accelerated Cleanup Model (SACM) to address some of these issues.
SACM streamlines the traditional Superfund response process, established by Congress in CERCLA and amended by the Superfund Amendment and Reauthorization Act of 1986 (SARA), by reorganizing and restructuring various components of the process. The main goals of SACM are:
- Non-duplicative site assessment
- Prompt risk reduction
- Cross-program coordination of response planning
- Early initiation of enforcement activities
- Early public notification and participation
One important tool within SACM is the presumptive remedy approach. Since Superfund’s inception in 1980, remedial and removal programs have found that certain categories of sites have similar characteristics, such as types of contaminants present, types of disposal practices, or environmental media affected. On the basis of information acquired from evaluating and cleaning up these sites, EPA is developing presumptive remedies to accelerate future cleanups. The objective of the presumptive remedies initiative is to use the past experience of the program to streamline site investigations, speed up selection of cleanup actions, ensure consistency in remedy selection, and reduce the cost and time required to clean up similar types of sites.



