The document summarizes a presentation on the history and evolution of risk-based corrective action (RBCA) for environmental remediation. It discusses how RBCA developed from early cleanup standards using total petroleum hydrocarbons to more sophisticated site-specific risk assessment approaches. It also overviewed the global environmental remediation market, noting the US and Europe as leaders and emerging opportunities in Asia and developing countries.

1. Presentation to Environmental Consultants in TokyoMonday August 15, 2011Risk-Based Corrective Action (RBCA):History, Evolution, Realities and Risk+ASTM 101+Environmental Business in the Global MarketJoseph E. Odencrantz, Ph.D., P.E. Principal, Tri-S Environmental-CaliforniaVisiting Professor, Kyoto University (2007-on going)

2. BeginningsTotal Petroleum Hydrocarbons by EPA 418.1>

3. Enforced by Local Fire Departments. Prone to false positives. C8-C70 Range. Infrared Detector. Does not discriminate compounds.

4. Used 1980`s and Early 1990`s

5. Cleanup Level 100 ppm in soil at many jurisdictionsCalifornia LUFTStands for Leaking Underground Fuel Tank Field Manual

6. California LUFT ManualBegan in 1989 Dispersion, Mass Flux and Biodegradation.

7. Considered Precipitation, Depth to Groundwater and Source Thickness

8. Tables and Decision Matrices to Simplify Risk Analyses: Scoring System

9. Remediation Required?

10. Soil Cleanup Levels for B, T, E, X and TPH .LUFT Cleanup LevelsBenzene 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.

11. Cleanup Levels Based on ModelsBase 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.

12. 1991 Mobil Exploration and Production ResearchExpanded variables to include Effective Solubility, Biodegradation Rate Ranges and Organic Carbon Content with Sensitivity Analysis.Emphasized necessity for site specific parametersOdencrantz, Farr and Robinson (1992) Journal Article.

13. Beginning of RBCADevelopment 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.

14. 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.

15. Tier 1A 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.

16. Tier 2Alternate, more realistic exposure points and scenarios. Some sites should screen out with a Tier 2 evaluation. Site-Specific Target Levels are implemented.

17. Tier 3The 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.

18. Many States Set Their Own StandardsAfter 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.

19. API Decision-Support SoftwareDeveloped 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.

20. Example Application

21. Low-Risk SitesIn 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.

22. Mandated Risk-Based Target LevelsIn 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.

23. Move to Risk-Based Decision Making-1999RBDM Performance AssessmentStudy was an ongoing research effortdesigned to assist state and territorialenvironmental regulatory agencies withthe evaluation of their individualRBDM corrective action programperformance for Leaking UndergroundStorage Tanks (LUST).

24. RBDM ContinuedThe evaluation helped to determinewhether RBDMprograms areachievingtheirstate agency management goals.

25. DefinedRBDM is a science-based processthat offers a clearly defined andconsistent basis for site evaluationand remediation. As a result, implementationof RBDM correctiveaction programs is expected toresult in increased program efficiencyand improved risk reduction.

26. Three-Part Program1. Risk-Based Site Prioritization: Prioritizesites based on the timingor magnitude of potential impactsto human health and theenvironment.

27. Part 2Site-Specific, Risk-Based RemediationGoals: Determine risk-basedconcentration limits for affectedenvironmental media designedto prevent impacts on humanhealth and the environment.Tier 1 remediation goals representgeneric concentration limits,based on conservative defaultassumptions. Tier 2 and Tier 3provide site-specific medialimits based on additionalsite data and more sophisticateddata analysis.

28. Part 3Remedy Selection: Selectremediationalternatives, such as removalor exposure control, toaddress site-specific risk drivers.

29. ExampleCalculate 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.

30. California-2005The 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.

31. ASTM 101Closing statements.Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

32. CHHSL`sThe CHHSLs presented in thelookup tables are NOTregulatorycleanupstandards. Use of theCHHSLs 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.

33. ExampleBenzene-AIR PHASEIndoor air-8.40 E-02: Residential1.41 E-01: CommericalShallow Soil Gas3.62 E+01:Residential1.22 E+02: Commercialunits- ug/m3

34. ASTM 101Closing statements.Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

35. Vapor TestingCan use TO-15 or TO-17.TO-15: Summa canisters at 1L or 6 L sizeTO-17: Air pump with sorbents (Two carbon black and molecular sieve)

36. ASTM 101ASTM 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 15358contain the word water. www.astm.org

37. ASTM 101Closing statements.Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

38. ASTM 101Closing statements.Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

39. ASTM 101Closing statements.Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

40. ASTM 101Closing statements.Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

41. ASTM 101Closing statements.Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

42. ASTM 101Closing statements.Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

43. Environmental Business in the Global MarketMaterial Obtained fromRemediation and Nature and Landscape Protection Services: An Examination of U.S. and Foreign MarketsUnited States International Trade Commission Publication 3727

44. Environmental Business in the Global MarketRemediation services: Global marketTotal 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.

45. Environmental Business in the Global MarketIndustry 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.

46. Environmental Business in the Global MarketEUROPEDemand 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.