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Presentation to Environmental Consultants in Tokyo
Monday August 15, 2011
Risk-Based Corrective Action (RBCA):
History, Evolution, Realities and Risk
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ASTM 101
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Environmental Business
in the Global Market
Joseph E. Odencrantz, Ph.D., P.E.
Principal, Tri-S Environmental-CaliforniaVisiting Professor, Kyoto University (2007-on going)
Beginnings
Total Petroleum Hydrocarbons by EPA 418.1>
Enforced by Local Fire Departments. Prone to false positives. C8-C70 Range. Infrared Detector. Does not discriminate compounds.
Used 1980`s and Early 1990`s Cleanup Level 100 ppm in soil at
many jurisdictions
California LUFT
Stands for Leaking Underground Fuel Tank Field Manual
California LUFT Manual
Began in 1989 Dispersion, Mass Flux and Biodegradation.
Considered Precipitation, Depth to Groundwater and Source Thickness
Tables and Decision Matrices to Simplify Risk Analyses: Scoring System
Remediation Required? Soil Cleanup Levels for B, T, E,
X and TPH .
LUFT Cleanup Levels
Benzene in Soil from 1 ppm for deep groundwater and low rainfall. THP-1,000.
Benzene in Soil from 0.3 ppm for intermediate groundwater depth and rainfall. TPH-100.
No Benzene in Soil Specified for shallow groundwater and large rainfall. TPH-10.
Cleanup Levels Based on Models
Base Case> with set of parameters including Organic Carbon, Solubility, Biodegradation and other variables.
Used SESOIL for one-dimensional soil transport and AT123D for groundwater transport.
1991 Mobil Exploration and Production Research
Expanded variables to include Effective Solubility, Biodegradation Rate Ranges and Organic Carbon Content with Sensitivity Analysis.
Emphasized necessity for site specific parameters
Odencrantz, Farr and Robinson (1992) Journal Article.
Beginning of RBCA
Development of site-specific cleanup levels was the basis for the development of risk-based corrective action, RBCA.
Regulatory Agency Cooperation and Education Began in California with site-specific parameters and cleanup levels.
First Draft 1994 timeframe.
What is RBCA?
For managing petroleum & chemical release sites through the integration of site assessment, risk assessment, risk management, and remedial action into a streamlined and technically defensible framework for environmental decision making.
Tier 1
A site is assessed by comparing concentrations at the point of contamination with risk-based concentrations established by the administering regulatory agency. Many sites (10% estimated) can be screened out at this point so that no further action is necessary.
Tier 2
Alternate, more realistic exposure points and scenarios. Some sites should screen out with a Tier 2 evaluation. Site-Specific Target Levels are implemented.
Tier 3
The most refined analysis and can involve detailed modeling and assessment of contamination reduction factors with contaminant fate and transport. Sites that do not pass a Tier 3 evaluation have substantial risk/hazard and should be remediated.
Many States Set Their Own Standards
After RBCA came out in a formal standard, ASTM E1739 - 95(2010), the push was to get the method accepted and implemented into all 50 states.
The process was long and difficult with some states refusing participation in the initiative.
API Decision-Support Software
Developed in ~1995, Soil and Groundwater transport models combined with risk calculation models (Carcenogic-Risks and Non-Cargenogenic-Hazard Quotients).
Deterministic and Monte Carlo on both transport and risk calculations.
Example Application
Low-Risk Sites
In about 1997, State of California issued a directive to close all low risk sites, Most sites were predominantly clayey. Called the Petite letter.
In California, the Governor was very conservative, but was not Arnold Schwartzenaeger.
Mandated Risk-Based Target Levels
In Orange County, California, the Agency set 400 ppb (ug/L) in groundwater for the target “low risk” level for benzene.
This short-lived basis did not last very long.
Move to Risk-Based Decision Making-1999
RBDM Performance Assessment
Study was an ongoing research effort
designed to assist state and territorial
environmental regulatory agencies with
the evaluation of their individual
RBDM corrective action program
performance for Leaking Underground
Storage Tanks (LUST).
RBDM Continued
The evaluation helped to determine whether RBDM programs are achieving their state agency management goals.
Defined
RBDM is a science-based process that offers a clearly defined and consistent basis for site evaluation and remediation. As a result, implementation of RBDM corrective action programs is expected to result in increased program efficiency and improved risk reduction.
Three-Part Program
1. Risk-Based Site Prioritization: Prioritize sites based on the timing or magnitude of potential impacts to human health and the environment.
Part 2
Site-Specific, Risk-Based Remediation Goals: Determine risk-based concentration limits for affected environmental media designed to prevent impacts on human health and the environment. Tier 1 remediation goals represent generic concentration limits, based on conservative default assumptions. Tier 2 and Tier 3 provide site-specific media limits based on additional site data and more sophisticated data analysis.
Part 3
Remedy Selection: Select remediation alternatives, such as removal or exposure control, to address site-specific risk drivers.
Example
Calculate CRF-Composite Reduction Factors Profiles. Defined as maximum site concentration / site cleanup goal.
Break case load into no action, simple action, remediation plan required and estimated time of closure.
Oversight cost assessment.
California-2005
The California Human Health Screening Levels (CHHSLs or “Chisels”) are concentrations of 54 hazardous chemicals in soil or soil gas that the California Environmental Protection Agency (Cal/EPA) considers to be below The thresholds of concern used to develop the CHHSLs are an excess lifetime cancer risk of one-in-a-million (10-6) and a hazard quotient of 1.0 for noncancer health effects. The CHHSLs were developed using standard exposure assumptions and chemical toxicity values published by the U.S. Environmental Protection Agency (USEPA) and Cal/EPA.
ASTM 101
Closing statements. Beacon Environmental
(BESURE) vapor intrusion and indoor air sampling kits.
CHHSL`s
The CHHSLs presented in the lookup tables are NOT regulatory cleanup standards. Use of the CHHSLs is voluntary on the part of those who choose to use them. At sites where cleanup of contaminated soils to levels at or below the CHHSLs would be costly, the time and effort to develop more site-specific cleanup may be desired.
Example
Benzene-AIR PHASE Indoor air- 8.40 E-02: Residential 1.41 E-01: Commerical Shallow Soil Gas 3.62 E+01:Residential 1.22 E+02: Commercial units- ug/m3
ASTM 101
Closing statements. Beacon Environmental
(BESURE) vapor intrusion and indoor air sampling kits.
Vapor Testing
Can use TO-15 or TO-17. TO-15: Summa canisters at 1L
or 6 L size TO-17: Air pump with sorbents
(Two carbon black and molecular sieve)
ASTM 101 ASTM International, formerly known as the
American Society for Testing and Materials (ASTM), is a globally recognized leader in the development and delivery of international voluntary consensus standards. Today, some 12,000 ASTM standards are used around the world to improve product quality, enhance safety, facilitate market access and trade, and build consumer.
4257 standards contain the word
environment and 15358 contain the word
water. www.astm.org
ASTM 101
Closing statements. Beacon Environmental
(BESURE) vapor intrusion and indoor air sampling kits.
ASTM 101
Closing statements. Beacon Environmental
(BESURE) vapor intrusion and indoor air sampling kits.
ASTM 101
Closing statements. Beacon Environmental
(BESURE) vapor intrusion and indoor air sampling kits.
ASTM 101
Closing statements. Beacon Environmental
(BESURE) vapor intrusion and indoor air sampling kits.
ASTM 101
Closing statements. Beacon Environmental
(BESURE) vapor intrusion and indoor air sampling kits.
ASTM 101
Closing statements. Beacon Environmental
(BESURE) vapor intrusion and indoor air sampling kits.
Environmental Business in the Global Market
Material Obtained from
Remediation and Nature and Landscape Protection Services: An Examination of U.S. and Foreign Markets
United States International Trade Commission Publication 3727
Environmental Business in the Global Market
Remediation services:
Global market
Total revenue approximately US $30 Billion annually. Remediation services accounted for 10. percent of the $300 billion worldwide environmental services market (solid and hazardous waste management services, nature and landscape protection, and remediation services.
Environmental Business in the Global Market
Industry observers expect the environmental consulting segment of the remediation industry to be the principal beneficiary of increased trade in the future. Most agree that it is not cost-effective to export actual remediation services to most other countries because work requires specialized equipment that is difficult to transport across borders, and most technology is widely available. However, industry representatives believe that the skills of U.S. firms in areas such as site assessment and overall project planning are highly competitive in foreign markets, and over the coming years these are likely to represent growth opportunities for U.S. companies in the field.
Environmental Business in the Global Market
EUROPE
Demand for remediation services varies considerably across European markets. While certain large markets are mature, other markets are exhibiting significant growth. In particular, Central and Eastern European (CEE) countries are potentially large markets for such services due to Communist-era environmental damage and environmental obligations stemming from the recent accession of many of these countries to the European Union. However, CEE markets are relatively small at present, as other environmental issues such as air and water pollution take precedence over remediation services.
Environmental Business in the Global Market
More on EUROPE-Market
In 2000, Europe as a whole accounted for $8.6 billion,3 or 30 percent, of the global market for remediation services, making it the world’s second-largest market for such services behind the United States. Remediation service revenues grew at an average annual rate of 15.1 percent during 1994-2000. According to data provided by Environmental Business International (EBI), Western Europe accounted for $7.9 billion, or 92 percent, of revenues generated in the European remediation services market in 2000. In comparison, the research and consulting firm ECOTEC (now http://www.ecorys.com/ ) values expenditures on remediation and cleanup in the European Union at $4.1 billion in 1999. Note: Ecorys is a leading European research and consultancy company.
Environmental Business in the Global Market
More on EUROPE-Technology Remediation methods vary from country to
country with respect to efficiency, cost, and site requirements. Many Western European countries use physical or chemical remediation techniques to treat contaminated soil. These methods account for one-half of the European market for such services. In general, ex-situ technologies dominate the West European market because results are faster, firms have more experience using these technologies, and the results are more easily controlled. Results from use of in-situ technologies are typically not as fast as those from ex-situ technologies, and concerns about the comprehensiveness of the results have constrained demand for onsite remediation. However, in-situ technologies are often used in areas where extraction is impractical, such as underneath existing structures, in large contaminated areas, or in areas that contain both contaminated soil and water.
Environmental Business in the Global Market
Asian-Markets While a handful of countries have substantial market
activity in this sector, most are still in the process of defining standards and regulations. Japan accounted for the largest share of the Asia-Pacific market for remediation, although remediation services account for a greater share of overall environmental expenditures in Australia. The Australian market for remediation services is considered mature due to stringent regulations and increasing urban expansion that is raising the value of land and creating incentive for the transformation of former industrial sites into residential areas. Conversely, the Japanese remediation sector is poised for significant growth, with the country having passed its first national binding soil remediation law.
Hong Kong, China, and Thailand have either established or drafted standards for remediation, though enforcement mechanisms are not in place. In Malaysia and the Philippines, awareness of contamination issues has emerged, but other economic and environmental issues continue to take precedence over remediation and NLP issues
Environmental Business in the Global Market
Emerging Markets-Latin America, Africa, Middle East and Asia (Not including Japan, Australia or New Zealand)
The market for remediation services in developing countries represents only a small fraction of the global market for such services. Industry data indicate that Latin America, Africa, Asia, and the Middle East together accounted for $3.3 billion, or approximately 11 percent, of the nearly $29 billion global market for remediation services in 2000
Contact
Joe Odencrantz
o Email: [email protected] Web: www.tri-s.com
o California: USA 949 644 8602
o Japan Ketai: 09030562852o Japan Ketai email: