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AUGUST 25, 2016 REMEDY OPTIMIZATION & SITE EXIT STRATEGIES

REMEDY OPTIMIZATION OVERVIEW GEORGIA ENVIRONMENTAL CONFERENCE AUGUST 25, 2016


THE CHALLENGE

Given an often complex set of site conditions, environmental media and contaminant composition, we are challenged to select remedies that •  Are protective of human health and the

environment •  Remain protective over time while

enabling site reuse •  Limit future liabilities and/or increase

land value •  Are cost effective

•  Achieve closure


THE CHALLENGE

Given an often complex set of site conditions, environmental media and contaminant composition, we are challenged to select remedies that •  Are protective of human health and the

environment •  Remain protective over time while

enabling site reuse •  Limit future liabilities and/or increase

land value •  Are cost effective

•  Achieve closure

>>> SITE EXIT?


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INTRODUCTION

•  Optimization = Quicker and Cheaper (with Equivalent or Improved Protectiveness)

•  Preparing for site closeout and optimization begins at SI

•  Optimization should be a consideration throughout a project life

•  Successful Optimization Requires

•  Realistic characterization of site risks

•  Clearly defined objectives – performance targets and final cleanup goals; total cost versus cash flow

•  Understanding of typical remediation system performance

•  Planning for change

Definition of optimization: an act, process, or methodology of making something (as a design, system, or decision) as fully perfect, functional, or effective as possible

Merriam‑Webster


5

INTRODUCTION

•  Optimization = Quicker and Cheaper (with Equivalent or Improved Protectiveness)

•  Preparing for site closeout and optimization begins at SI

•  Optimization should be a consideration throughout a project life

•  Successful Optimization Requires

•  Realistic characterization of site risks

•  Clearly defined objectives – performance targets and final cleanup goals; total cost versus cash flow

•  Understanding of typical remediation system performance

•  Planning for change

Definition of purgatory: a place or state of suffering

Merriam‑Webster


REMEDY OPTIMIZATION OVERVIEW


REMEDY OPTIMIZATION OVERVIEW OPTIMIZATION THROUGHOUT REMEDY PROGRAM

Optimizing SI, Remedy Evaluation, Selection, and Design

Optimizing Remedial Action Operation

Optimizing Groundwater Monitoring

Conceptual Site Model Reassess CSM and RAOs Review of CSM, RAOs and goals of the monitoring program

Risk Assessment Evaluate Remediation Effectiveness Review/refine monitor locations

Remedial Action Objectives Evaluate Cost Efficiency Review/refine monitoring frequency

Target Treatment Zones Identify Remediation Alternatives Review/refine contaminants to monitor

Treatment Train Develop & Prioritize Optimization Strategies Review sampling methods

Performance Objectives Implement Optimization Strategy Data evaluation

Optimization & Exit Strategy Ensure Regulatory Acceptance


Remedy & post-remedy risk assessment

INTEGRATING RISK ASSESSMENT SUPPORTING EFFECTIVE DECISION MAKING

•  Streamline site characterization •  Determine need for remedy •  Develop cleanup goals and treatment levels

•  Select appropriate remedy •  Modify previously selected remedy •  Provide basis for risk management decisions

Enough data?

Remedy needed?

Remedy type?

Remedy complete?

RI Phase 2, PA/SI FS

Site Closeout

RD/RA-C/O


INTEGRATING RISK ASSESSMENT APPLYING RISK ASSESSMENT FOR RISK MANAGEMENT

Remedy Decisions (CERCLA and RCRA) How clean is clean enough?

Does cleanup mean contaminant treatment/removal?

No further action

10-4 10-2 10-6

Low-Level Threat Principal Threat Acceptable Risk

1 0.01 100 Noncancer hazard index →

Cumulative cancer risk →

Remediation necessary Containment Preferred Treatment Preferred

Reference: OSWER Directive 9355.0-30 and USEPA (1997) Rules of Thumb for Superfund Remedy Selection [540-R-97-013]


EXAMPLE – RISK MANAGEMENT & OPTIMIZING LAND USE

•  Apply appropriate USEPA risk management policy Ø  Resulted in savings of over $5 million

•  Define minimum remediation for continued industrial use

Ø  Resulted in savings of over $6 million •  Tailor site-specific risk assessment to allow alternate

site reuse 1.  Assess mixed land use options to optimize land use

for future redevelopment 2.  Account for realistic assumptions regarding exposure

Ø  Identified savings of over $3 million


Effort/Cost ($)

Con

cent

ratio

n/Ris

k

Low-end Criterion

High Risk Areas

Larger Reduction in Risk

Lower % Higher %

Marginal Risks/ Uncertainty

Risk Range Smaller Reduction in Risk

Why Consider Tradeoffs?

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INTEGRATING RISK ASSESSMENT BALANCING RISK / BENEFIT


1.00E-07

1.00E-06

1.00E-05

1.00E-04

1.00E-03

1.00E-02

1.00E-01

0

2

4

6

8

10

12

14

16

18

20

1 2 3 4 5 6

Res

idua

l Can

cer R

isk

C

ost I

ncre

ase

Fact

or R

elat

ive

to A

ltern

ativ

e 1

Remedial Alternative

Figure 1.

Cost Increase Factor Relative to Alternative 1

Hypothetical Post-Remedy Cancer Risk

Hypothetical Post-Remedy Cancer Risk - Inhalation Only

EXAMPLE – BALANCING RISK REDUCTION AND COST


INTEGRATING RISK ASSESSMENT USE OF NET ENVIRONMENTAL BENEFIT ANALYSIS

Goal: Identify remedies that are ecologically protective, serves the public interest, meets stakeholder goals , help conserve resources that provide human and ecological value, and are generally more cost effective

•  Shifts focus from a chemical-centric view of the environment to environmental services, productivity, and health

•  Quantitative assessment of total impacts related to the remedial alternatives being considered; for example

•  direct and indirect sources of GHGs and relative scale of the GHGs,

•  material reused on site or disposed,

•  travel required to maintain the remedy.

•  Differentiate between remedies that offer equivalent public health and environmental protection using relevant and readily calculable metrics


0

0.1

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0.3

0.4

0.5

0.6

0.7

0.8

0.9

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Baseline Alt 1 Alt 2 Alt 3 Alt 4

Offsite Migra;on Risk Total Energy (MMBTU) Total SOx (tons) Total NOx (tons) CO2e (tons) Fatality Risk Injury Risk Forest Habitat Lost (dSAYs) Cost $ millions

Preferred Alternative?

$2.8 $3.3 $3.6 $4.0

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EXAMPLE – NET ENVIRONMENTAL BENEFIT


SETTING REMEDY OBJECTIVES

Alternative Goals & Objectives •  Reduction of overall contaminant

concentrations compared to baseline levels (e.g., >90% reduction)

•  Mass removal to asymptotic levels (following appropriate optimization of the system)

•  Operate only as long as cost-effective •  Rapid site exit •  Minimize cash flow

2900

3000

3100

3200

3300

3400

3500

3600

2000 2005 2010 2015 2020 2025 2030 2035

Cum

ulat

ive

Cos

t (in

thou

sand

s)

Year

Alternative 1

Alternative 2

Alternative 3

Monitoring may or may not be required during this period depending on concentrations detected in previous sampling events.

Typical Remedy Selection Criteria •  Protective •  Effective •  Implementable •  Minimizing cost •  Regulatory acceptance •  Community acceptance


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UNDERSTANDING TYPICAL REMEDIATION PERFORMANCE

Time (t)

Mass

Rem

oval

Rate

(m/t)

Exit Point

Characteristic Curve

Conventional Design Level

Life-Cycle Design Level

Extended Maximum Efficiency


EXAMPLE – PUMP & TREAT OPTIMIZATION

$0.00

$5.00

$10.00

$15.00

$20.00

$25.00

100 166 270 325 400 600

Cost

($M

M)

Flow Rate (gpm)

Pump-and-Treat System Costs

O&M -- 30yrTotal Cap Costs

NEW JERSEY SUPERFUND SITE •  CVOC plume in stratified aquifer •  EPA ROD required extraction of 3 pore

volumes in 30 years •  3 mile discharge pipeline required

OPTIMIZATION OBJECTIVES •  Maximize mass removal •  Minimize cross-boundary capture •  Reduce treatment capacity •  Achieve EPA’s 3 pore volume requirement

Light blue fact box

97.0

97.5

98.0

98.5

99.0

99.5

100.0

170 184 190 201 214 225 230 268 276 505

Perc

entag

e fo T

otal

Mass

Rem

oved

in 30

year

s

Pumping Rate (gpm)

Estimated % of Total Mass Removed in 30 Years (Assumes No Biodegradation)

Outcome:

•  Approved design

•  Eliminated major construction elements

•  Est. savings >$10M over 30 yrs


EXAMPLE – TREATMENT TRAIN APPROACH

Free Product Recovery

Vacuum-Enhanced Product Recovery

Air Sparging/Soil Vapor Extraction Pilot Test

Ozone Sparging/SVE Phase II

Ozone Sparging/SVE Phase I

Monitored Natural Attenuation


SUMMARY

Optimization of a remedy should be continuous throughout remedy evaluation, implementation and post-remedy monitoring

•  Risk analysis throughout project will lead to more efficient investigation and remedy selection Ø  The costs of remedies selected need to be warranted by the benefits derived -- Higher cost does

not always mean overall lower risk

•  Projects can be expedited by making decisions in the field (as much as possible) using real-time data. Ø  New technologies are available for improved access to environmental media for sample

collection, as well as analysis of in situ conditions (i.e. contaminant concentrations, lithologic conditions, etc.)

•  Recognize current technological limitations in remedy selection decisions, while being open to innovative technologies where appropriate Ø  Multiple remediation technologies “Treatment Trains” should be used concurrently or

sequentially (depending on site-specific conditions) to achieve remedial objectives


THANK YOU!

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Mark Nielsen [email protected] 1-215-523-5602

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