use of a net environmental benefit analysis (neba) framework in site remediation

1

Use of a Net Environmental Benefit Analysis (NEBA) Framework in

Site Remediation

Joseph NicoletteVice President, CH2MHILL

Practice Director For Natural Resource Liability and Asset Management June 30, 2005

2

Convergence of Thinking A Coordinated Approach to Assessment,

Remediation and Restoration

Remedial InvestigationHealth/Eco Risk Assessment

EE/CA, FS (NEBA)ROD

Remedial ActionO&M

Natural Resource Injury

Overall Goals•Minimize NRI through remedial strategy

•Manage short and long-term risks •Reduce time to resolution (transaction costs)

•Reduce study costs, improve design (e.g., eco-risk)

Parallel TrackCleanup NRI

3

Background Natural Resource Damage Assessment

(NRDA) regulatory process: OPA/CERCLA Natural resource restoration-based

compensation process Process to compensate for injuries to natural

resourcesNeeded to understand/quantify injury and restoration

value Natural resources identified as providing a

variety of services

4

Habitat

Services“The functions a natural resource provide for other resources and for humans”.

Direct Human Uses (e.g., Recreational, Commercial)

Bird watchingFishingSwimmingHuntingCommercial Fishing

Existence valueAesthetic valuePreservation of diversityT&E species

Passive Use

Ecological

Nesting Area for BirdsBreeding Area for FishSediment StabilizationWater Quality EnhancementMany Others

5

% o

f S

ervi

ces

Years

Area B - Services Gained (Credit)

B

Quantifying Natural Resource Changes:

Natural Resources Are Like Assets That Pay In Service Units Instead of Dollars

Area A - Services Lost (Debit)

A

Contaminant Release

6

Comparing Environmental Values(Cost Benefit Analysis of Project Alternatives)

% S

erv

ice

s

Years

Baseline Services

7

Comparing Environmental Values(Cost Benefit Analysis of Project Alternatives)

% S

erv

ice

s

Years

Baseline Services

B1

8

Comparing Environmental Values(Cost Benefit Analysis of Project Alternatives)

% S

erv

ice

s

Years

Baseline Services

B2B1

9

Comparing Environmental Values(Cost Benefit Analysis of Project Alternatives)

% S

erv

ice

s

Years

Baseline Services

B3B2

B1

Areas B1, B2 & B3 - Service Values Associated With Project Alternatives

• Develop $/credit• Fiscal merit• Conservation/natural resource benefits

10

Table 1. Overall Framework for Evaluation of NEBA Project Alternatives (allows for comparison of project alternatives).

A NEBA Example

Project Alternatives

Ecological Services (dSAYs)

Human Use Value (User-Days

and $)Cost ($)

Cost/Eco dSAY

Cost/Human Use $

Project A 20,000 $4,000,000 $1,000,000 $50 $0.25

Project B 10,000 $3,000,000 $1,000,000 $100 $0.33

Project C 20,000 $25,000,000 $1,000,000 $50 $0.04

Project D 2,000 $1,000,000 $1,000,000 $500 $1.00

Scenario #1

11

Alternative Comparisons Using NEBA

Remedial Actions NEPA Alternatives Land Management Actions Land Re-Use Designs (e.g., Brownfield,

greenspace designs) Restoration, Recreational Area Designs (e.g., eco-

tourism) Any actions that affect natural resource service

values (ecological and human use)

12

NEBA In The Context of Site Remediation

Analytical framework to compare natural resource benefits of various remedial actions versus natural resource costs

Using formally quantified values Assist with risk management decisions

Goals: assist in remedy selection to: avoid creating natural resource injury (NRI) and; encourage the selection of remedial options that offer the

greatest benefit to the environment and public.

Considers both cleanup and natural resource issues

13

NEBA Consistent With “EPA’s Ecological Benefits Assessment Strategic Plan”

Draft September 30, 2003 EPA document Goals:

advance EPA's ability to identify, measure, value and communicate the ecological benefits of its actions in order to improve the integrity of decision-making.

Consider net ecological benefits of an EPA action including any negative, as well as positive changes in ecological services

14

Risk and Injury Issues Driver of clean-up is typically concentration

driven: Injury and/or benefits to natural resource service value

associated with remedies are rarely formally quantified

Risk assessments can be overly conservative Uncertainty NEBA provides collaborative framework to

address these issues

15

Marginal Risks/Uncertainty

Cleanup to Criterion (Cost/Benefit)

Effort/Cost ($)

Co

nce

ntr

atio

n/R

isk

Criterion Level

HQ=1

High Risk Areas

Risk Management DecisionsAllows For Offsetting Restoration

HQ=1(using less conservative assumptions)

Lower % Higher %

Larger Reduction in Risk

Smaller Reduction in Risk

16

No Action Surface Sweep Surface Clearance Clearance 2 Feet Clearance 4 Feet

40

30

20

10

0

Rem

edial C

ost($ m

illions)

ALTERNATIVE

Conceptual NEBA Results: Comparison of remedial costs for each remedial alternative evaluated.

N o Action Hot Spot Removal Soil Cover Complete Removal Other

16

17

No Action Surface Sweep Surface Clearance Clearance 2 Feet Clearance 4 Feet

40

30

20

10

0

Rem

edial C

ost($ m

illions)

Con

cen

trat

ion

/Ris

k

ALTERNATIVE

Conceptual NEBA Results: Comparison of remedial costs and risk profile changes for each remedial alternative evaluated.

N o Action Hot Spot Removal Soil Cover Complete Removal Other

17

18

No Action Surface Sweep Surface Clearance Clearance 2 Feet Clearance 4 Feet

0

5,000

10,000

15,000

20,000

40

30

20

10

0

Net

Eco

logi

cal S

ervi

ce L

oss

(d

SA

Ys)

Rem

edial C

ost($ m

illions)

Con

cen

trat

ion

/Ris

k

ALTERNATIVE

Conceptual NEBA Results: Comparison of remedial costs to risk profile, and ecological service changes for each remedial

alternative evaluated.

N o Action Hot Spot Removal Soil Cover Complete Removal Other

18

19

No Action Surface Sweep Surface Clearance Clearance 2 Feet Clearance 4 Feet

0

5,000

10,000

15,000

20,000

40

30

20

10

00

10

20

30

40Net

Eco

logi

cal S

ervi

ce L

oss

(d

SA

Ys)

Rem

edial C

ost($ m

illions)

Con

cen

trat

ion

/Ris

k

Net H

um

an U

se Valu

e Loss

($ million

s)

ALTERNATIVE

Conceptual NEBA Results: Comparison of remedial costs to risk profile, ecological service and human use value changes for each

remedial alternative evaluated.

MNA Hot Spot Removal Soil Cover Complete Removal Other

19

Is There a Break-Point?

20

NEBA Consistent With Risk Management Objectives

EPA Superfund ERA Guidance (Step 8) “The risk manager must balance (1) residual risks posed by site

contaminants before and after implementation of the selected remedy with (2) the potential impacts of the selected remedy on the environment independent of contaminant effects.”

“In instances where substantial ecological impact will result from the remedy (e.g., dredging a wetland), the risk manager will need to consider ways to mitigate the impact of the remedy and compare mitigated impacts to the threats posed by the site contamination.”

NEBA provides potential framework to help comply with this guidance

21

Why and When NEBA? Balance of risks and benefits of remediation is

ambiguous site retains significant ecological value remediation causes environmental damage

Example: Prince William Sound ecological risks are small, uncertain, or limited remediation or restoration may fail or not truly change

risk scenario costs appear disproportionate to changes in the risk

scenario

No unacceptable human health risks

22

Value of the NEBA Approach Provides information for management decisions

using technical, scientific, and credible tools Uses quantifiable metrics providing a basis for decisions

e.g., layer of protection from third party-suits

Shows benefits to the public and demonstrates environmental sustainability/stewardship

Framework may result in : better environmental management and greater

environmental improvement at lower costs

Methodologies are consistent with policy and direction of natural resource agencies

23

“A Framework for Net Environmental Benefit Analysis For Remediation or Restoration of Contaminated Sites”

Rebecca A. EfroymsonOak Ridge National Laboratory

Joseph P. NicoletteCH2M HILL

Glenn W. Suter IIUSEPA National Center for Environmental Assessment

Published, Environmental Management, August 2004

24

Prior EPA Region 4 Presentation Provided overview to Jimmy Palmer (Regional

Administrator, Region IV) and Staff (October 2004, Feb 2005).

Comments The benefits of the NEBA approach appear consistent

with the policy and direction of the agency Is useful and most beneficial when done in a collaborative

and cooperative process Overall, this is a useful tool in remedial decision-making

process A new approach for the region, which may set a precedent

and may have far reaching implications

25

EPA HQ Meetings

Office of Solid Waste and Emergency Response (OSWER)/Policy Analysis and Regulatory Management

EPA is looking at NEBA as a possible method to demonstrate the value of Superfund Program

Currently discussing regional pilot studies with HQ EPA

26

Collaboration

Co-Chairing Panels/Sessions with EPA re NEBA and resource metrics at:

Wildlife Habitat Council Conference on Brownfields (EPA Region 6): May 2005

National Brownfields Conference: Denver, Nov 2005

SETAC, Baltimore, Nov 2005

27

Current DoD NEBA Projects

Army BRAC HQ: Fort McClellan, AL; Fort Ord, CA; Camp Bonneville, WA; Savanna Army Depot, IL

Edwards AFB, CA. OU Specific NEBA’s in proposed collaborative process.

Tyndall AFB. Integrating NEBA in collaboration with agencies

Navy, New Gosport

28

A Shift in Thinking: Natural Resource Service Values

CERCLA Exxon Valdez NRDA Regs Today

$$

1980 1989 1996 2005

Evolution of Thinking Application