risk-based zoning strategy for soil remediation at an industrial site

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Risk-Based Zoning Strategy for Soil Remediation at anIndustrial SiteA. Basel Al-Yousfi a , Peter G. Hannak a , James F. Strunk a , Wyn V. Davies a & Sunil I. Shah aa Union Carbide Corporation, P.O. Box 8361, South Charleston, WV 2530Published online: 24 Jun 2010.

To cite this article: A. Basel Al-Yousfi , Peter G. Hannak , James F. Strunk , Wyn V. Davies & Sunil I. Shah (2000) Risk-BasedZoning Strategy for Soil Remediation at an Industrial Site, Journal of Soil Contamination, 9:1, 1-12

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1

Journal of Soil Contamination, 9(1):1–12 (2000)

Risk-Based Zoning Strategy forSoil Remediation at an Industrial Site

A. Basel Al-Yousfi,* Peter G.Hannak, James F. Strunk, Jr., WynV. Davies, and Sunil I. Shah

*Union Carbide Corporation, P.O. Box 8361,South Charleston, WV 25303([email protected])

After determining at an early stage of theproject that the future land use of this NewJersey chemical manufacturing site remainindustrial in nature, the site was zoned ac-cording to risk. The chemicals of concern(COCs) at the site included relatively lowlevels of mono- and polynuclear aromatichydrocarbons, chlorinated aliphatics, as wellas other volatile and semivolatile compounds.Direct human exposure scenarios were thekey to the mitigation of risks related to soilsbecause the groundwater migration pathwaywas already interrupted using groundwaterrecovery. A focused remedial strategy wasdeveloped to ensure that the exposure path-ways (inhalation, ingestion, and dermal con-tact) are alleviated and the remedial mea-sures are protective to the workers operatingand/or maintaining the site. The risk evalua-tion process included a preliminary risk as-sessment (Tier 1) based on a comparisonwith pertinent soil cleanup criteria, aprioritization analysis to rank zones, chemi-cals and pathways of concern, and an appli-cation of the Risk Based Corrective Action(RBCA) approach (Tier 2) for construction

worker exposure scenario. The risk assess-ment identified selected areas that wouldbenefit from remedial actions. PrioritizationAnalysis classified the site into five high-pri-ority (comprising 97% of the total health-based risk), three medium-priority (contribut-ing to remaining 2 to 3% of the risk), andadequately protected areas. The boundariesand volumes of affected areas were delin-eated based on confirmatory soil samplingand statistical analyses. The remedial tech-nologies selected for the site have achievedappropriate reduction in risk to comply withall State regulations and include (in additionto the institutional controls):

• Capping the site where only immobilesemivolatile contaminants are present

• Excavation and on-site treatment of thesoils impacted by volatile organic com-pounds through ex situ low temperaturedesorption, or alternative “biopile” treat-ment and natural attenuation, and

• Excavation and off-site disposal of lim-ited volumes of soils

This risk-based, integral approach helpedidentify the real significance of contamina-tion present at the site and facilitated thedevelopment of suitable and adequate rem-edies. Had not it been for this approach, themere comparison with soil cleanup criteriawould have unnecessarily resulted in denot-ing all areas as nuisance contributors, andthus requiring some actions. New JerseyDepartment of Environmental Protection(NJDEP) has approved this approach andcontributed to its accomplishment.

KEY WORDS: risk-based zoning, soil remediation, industrial site, chemical manufacturing.

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INTRODUCTION

ORE and more public and regulatory attention is focused on site cleanupactivities. The objective of this article is to describe activities and assess-

ments leading to the successful remedial process. Specific attention is given to thedemonstration of the risk assessment and forensic approach to set examples usefulat other sites to control costs and achieve sound cleanup in compliance withpertinent regulatory requirements.

This chemical manufacturing facility has been continuously operating since the1930s. The site is located in an urban area, in the State of New Jersey, known forhigh levels of past (and present) industrial activities. Various comprehensive soiland groundwater sampling and analyses assessments had been conducted at thesite, and results indicated that several areas required remedial actions to reduce oreliminate the potential threat to human health and the environment.

Some important observations from the site investigation included:

• All known and/or potential soil sources of contamination have been miti-gated, and the site is free from any continuous release(s).

• Chemical contaminants were present at several distinct areas related toroutine/systematic process leaks or spills or where solid waste had beenmanaged historically.

• Type and concentrations of chemicals varied significantly from one area toanother, as well as spatially within the same area.

• The soil sampling investigation identified all zones of the site requiringfurther risk-based evaluation and ranking.

• It was possible to identify discrete areas that were likely to require specialattention (e.g., remediation), designated as Areas of Concern (AOCs).

• The ongoing isolation, containment, and recovery of groundwater contami-nants had concomitantly enhanced soil mitigation and cleanup by interrupt-ing the pathway of exposure. This implies that even if contaminants migratefrom soil to groundwater the extraction system in place will prevent themfrom reaching a receptor. Therefore, the existing groundwater pump andtreat system was considered an integral part of the overall remedial effortneeded for some finite period of time. Although the length of operation hasnot been defined, the monitoring will continue to observe the cleanup trendand bring groundwater handling to a satisfactory closure at a later date.

In order to focus efforts and resources needed to clean the site, a prioritizationhierarchy was established by accounting for the toxicity of the COCs and rankingthe risk imposed to human health and the environment. This task was designatedas risk-based prioritization. It is important to recognize that the risk was evaluated

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by using a ranking matrix and relating the output to existing soils standards. Theapproach is somewhat bound because it is based on the full acceptance of theinherent risk assumptions built in the regulatory value.

METHODOLOGY

Although most of the applied method components are known in the remediationfield, the combination of risk assessment and forensic site assessment led to aunique but holistic evaluation approach. Initial risk evaluation and prioritizationprocedures were developed, primarily by comparing the measured chemical con-centrations in soil with soil cleanup standards. The soil standards were compiledas “look up” tables, which included the EPA Soil Screening Levels (SSL)1,2 and theNew Jersey Department of Environmental Protection (NJDEP) Soil Cleanup Cri-teria (SCC).3 A straight comparison between chemical to regulatory standardsshowed that such a comparison would not be helpful in determining where the realhazard to human health potentially existed. Such a simple comparison would haveemphasized local exceedances ‘hot spots”, but would have been inadequate todescribe spatial distribution and significance of contamination. In fact, the variabil-ity in the data was high enough to cause exceedences throughout most of the site.

A risk-based scoring and ranking system was constructed, which is in essencea numerical means of determining what contaminant(s), media, pathway(s), and/orarea present the highest contribution of risk to a potential receptor at the site. Fora given area of concern (AOC), the maximum scores resulting from all chemicalspresent in soil were summed, incorporating all identified pathways of exposure toobtain the total score of risk for this particular area. Initial delineation of AOCs wasbased on historical plant operation and available soil characterization data. AOCsboundaries were conservatively extended to include all potentially impacted soils.However, all initial assumptions were verified during the remedy implementationprocess. Risk scores of various chemicals were also summed for one specificexposure pathway to determine the full impact of exposure through the specificpathway. The relative contribution of risk due to a COC within an AOC wasdetermined by dividing the maximum risk score of this contaminant by the totalestimated risk score of the area. This relative contribution value provided the riskrank of the subject chemical among all other chemicals of concern (COCs) in thearea. Such calculations were carried out by employing the following mathematicalexpressions:

RSCCS

= ⋅⋅⋅ (1)

RSEP RSCi

n

i= ( ) ⋅⋅⋅=

∑1

(2)

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RSA Max RSEP i

i

n

= ( ) ⋅⋅⋅=

∑1

(3)

TRS RSAj

m

j= ⋅⋅⋅=

∑1

( ) (4)

RCPRSA

TRSjj( ) =

( )⋅⋅⋅ (5)

(6)

where C = spatial average (arithmetic) concentration of a chemical of concern(COC), S = NJDEP SCC, EPA SSL for the pathway of interest, RSC = Risk scoreof a COC (computed for groundwater and soil exposure pathways, respectively),RSEP = Risk Score of an Exposure Pathway due to all COCs, RSA = Risk Scoreof an Area, TRS = Total Risk Score at the entire site, RCP = Specific Areacontribution to the total site risk, RR = Risk Rank, i to n = indicates COCs, j to m =indicates number of AOC

Note: Most AOCs were sampled several times in previous attempts do describethe extent of the contamination. These sampling events were designed and imple-mented over a several-year time period individually without the foresight of futuredata use. Because the risk ranking was the first step to approximate the riskcharacter of the site the existing data were accepted as appropriate for site assess-ment. The data sets typically covered laterally and vertically the entire AOC. Thedata were deemed quite conservative because systematically more samples wereobtained from the very source of contamination, resulting in a biased site average.

The final risk scores for the various areas of concern were then ranked into:high-, medium-, and low-priority “no-action” areas.

The results of this analysis revealed that 97% of the health-based risk at the sitewas due to five AOCs (of the total of 12 AOCs). Indeed, one AOC alone (a formertank farm containing chlorinated/nonchlorinated aliphatics and aromatic hydrocar-bons) comprised about 80% of the site’s risk. These five areas were identified as“high-priority” areas. Active remediation technologies were searched and identi-fied for these five areas to achieve maximum risk reduction. Three AOCs weredesignated as “medium-priority” areas and contribute about 2 to 3% of the overallrisk at the site. Engineering controls (e.g., isolation and containment), and limitedsoil removal measures were planned for these areas. The remainders were classi-fied as low priority or adequately protected areas, because thorough evaluationresults indicated minimal or no impact on human health or the environment. Notethat high-priority classification was used to identify an AOC of RCP > 2%,medium priority for RCP = 0.1 to 2%, and low priority for RCP < 0.1%, respec-tively.

The risk score computations and ranking are provided in Table 1.

RR Max RSA Min RSA= ( ) ( )... ...→

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RISK-BASED REMEDIAL ASSESSMENT

In this phase of the project a statistical site screening approach was adapted. Thisincluded a reevaluation of the individual AOC to ascertain that the remedial actionselected is applicable, is practical, and will ensure the minimization of criticalpathways and contaminant release.

Soil data sets were evaluated, and the assessment was developed as a three-step(compilation, averaging, and comparison) process. All soil concentration data weresorted and rescreened, excluding the below detection limit results. Subsequently,the individual and data averages were compared with the applicable regulatorycriteria, and exceedences were determined. For assurance, the results of this secondphase evaluation were examined against those from the first phase risk ranking andprioritization. Both methods reached the same conclusions in terms of identifyingthe same AOCs for cleanup action.

Three types of soil measurement averages were computed in each AOC:

• First, average concentrations for all samples in a given vertical interval(stratum)

• Second, an average of stratified sample concentrations

• Third, an average of all individual sample concentrations

It should be emphasized that none of these averages include the below-detectionlimit data, thus they conservatively and artificially increased the values of averagesusing detected and confirmed data exclusively. (Note that Average 2 is a weightedaverage that gives more weight to a stratum with more analytical data points.) Thedata sets (and thus averages) are conservatively biased because systematicallymore samples were taken from highly contaminated areas.

The remedy selection for an individual area was finalized looking at the siteconditions and representative spatial (lateral and vertical) sampling, in terms oflocation, distribution, and concentration of all samples taken at the site. The dataevaluation, including screening and analyzing on an area by area basis, is repre-sented by Figure 1.

The extent and magnitude of contamination were determined via comparisonwith NJDEP soil cleanup criteria for groundwater and contact protection, eventhough the groundwater risk at the site has been mitigated by the ongoing pump-and-treat operation. The predicted maximum extent of soil to be treated, disposed,and/or capped is summarized in Table 2. The soil volumes were conservativelyestimated to encompass (and indeed maximize) all areas of contamination asdetermined by the existing sampling data. These soil volumes were field verifiedagain prior to the implementation of the remedial work, using horizontal delinea-tion sampling and piezometric field confirmation studies.

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REMEDIAL TECHNOLOGY SELECTION

The required remedial actions at an AOC was determined on the basis of site-specific conditions, and representative spatial (lateral and vertical) sampling loca-tion, distribution, and concentrations. The remedial objectives included:

• Eliminate those exposure pathways that pose potential hazards to humanhealth and the environment.

• Provide methods to prevent or control contaminant migration.

• Select technologies appropriate to the hazard posed by the area.

• Allow maximum future reuse of the site for industrial activities.

Collectively, the proposed remediation technologies at the site are summarized as:

• Capping the areas where only less mobile semivolatile contaminants arepresent

• Excavation and on-site, ex situ treatment of the contiguous and isolated soilvolumes impacted by VOCs using thermal or biopile desorption technolo-gies (depending on treatment economics),

• Excavation and off-site disposal of smaller volumes of soils contaminatedby relatively high concentrations of semivolatile chemicals of concern (orex situ treatment as appropriate)

• No corrective measures (other than institutional measures) at any of the“low or adequately protected” areas.

TREATMENT ENDPOINTS

The mitigation of risks at the site was driven by the human health soil exposurescenarios (i.e., inhalation, ingestion, and dermal contact) because the groundwatermigration pathway is already interrupted by the pump-and-treatment operation atthe site. Additionally, risk assessment analyses for construction worker exposurewas conducted to stimulate the field condition during remedial works and/or futureindustrial activities. ASTM methodology (PS 104-98) was used, applying Tier 2Risk-Based Corrective Action (RBCA) software.4,5 The potential risk was found tobe minimal even prior to any remedial action at the site.

The proposed soil treatment technologies and their target endpoints were estab-lished to guard against groundwater impacts, to protect workers during futureconstruction and site maintenance activities, and to guarantee maximum industrialusage of the areas of concern in the future. As an added caution to ensure reliableand conservative excavation compliance, all designated areas were further evalu-ated to comply with the New Jersey’s Impact to Groundwater Criteria (IGWC). A

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review of all areas of concern indicated that no additional excavation volumes areneeded, except in one area. In fact, the data showed that in order to meet IGWCcriteria in this particular area, additional excavation of 885 yd3 (~1000 tons) of soilwould be required to remove a total of 2 extra pounds of contaminants (i.e.,Methylene Chloride (MeCl) and Tetrachloroethylene (PCE)). Such extensive ex-cavation and treatment of soil was deemed unnecessary considering the trivialamount of contamination that may remain behind the site above IGWC.

Moreover, these compounds are highly water soluble, and the soil remediationwill be better achieved through groundwater treatment in addition to naturalattenuation. The extra layer of protection provided by the operating groundwaterpump-and-treat system has also contributed to the level of comfort in making thisdecision. Table 3 identified six compounds of concern and their treatment end-points (IGWC) criteria.

The entire site regardless of the residual risk remaining after the remedy is to bedeed-restricted, designated for industrial use, and its accessibility to the publiccontrolled by common institutional measures.

EXCAVATION CONTROL

Excavation control refers to controlling the volume of soil excavated and treatedin the Low-Temperature Thermal Desorption or the biopile unit. Excavation wasproposed to start from the center of contamination (the core of impacted soil) andreach radially toward the outer perimeters. Delineation sampling of soil has deter-mined the horizontal extent of excavation, and piezometric groundwater measure-ments decided the depth to the water table or local bedrock, and therefore thevertical extent of excavation. Removal of soil in or below the groundwater tablewas deemed unnecessary because of the continued operation of the groundwater

TABLE 3COCs Determining Excavatipn

Control and Remediation Endpoints

NJDEPNJDEP impact to

contact protection groundwatercriteria (CPGC) criteria (IGWC)

Compound CAS number (mg/kg) (mg/kg)

Methylene chloride 73-09-2 210 1Trichloroethene 79-01-6 54 1Ethylbenzene 100-41-4 1000 100Styrene 100-42-5 97 100Toluene 108-88-3 1000 500Tetrachloroethene 127-18-4 6 1

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interceptor and treatment system. It was noted that the contaminant soil concentra-tions measured in the early 1990s and used in the preceding calculations werelikely to have declined over the years via various natural removal mechanisms(natural attenuation). This has been concluded from the preconstruction confirma-tion sampling event that was conducted in 1997, showing considerable decrease incontaminant concentrations.

The risk-based approach by zones presented herein to identify and clean upcontaminated soils at this industrial site was proven to be technically sound andpractical and resulted in the excavation and treatment of only those soils that couldhave adverse health impacts. Verification sampling conducted during field imple-mentation confirmed the delineation, excavation cut lines, and predicted soilvolumes within ±5% accuracy. Furthermore, the approach provided adequatecurrent and future protection against any potential exposure due to soil or ground-water contamination.

SUMMARY AND CONCLUSIONS

The risk-based strategy employed to remediate contaminated soils at this chemicalmanufacturing site is outlined as follows:

FIGURE 2

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As opposed to simple comparison with soil cleanup standards, this strategy hasfacilitated the tasks of sorting out information and directing attention to zones ofsignificant nuisance contribution. Technical focus and monetary allocations wereconcentrated on such areas that actually drive the potential risk to human healthand the environment. Remedial actions were chosen based on the nature and extentof contamination and to eliminate (or reduce to deminimus levels) exposure topotential receptors. Soil cleanup and groundwater extraction actions were fullyintegrated in selecting the best treatment scenario, which will restore the site andpreserve its future industrial use. This approach has resulted in effective, reason-able, and protective cleanup of the site, which both met the regulatory requirementsand reserved valuable resources for the economic and social viability of thecommunity. This approach may be applied successfully at various soil remediationsites with due considerations to site-specific conditions and unique regulatoryrequirements.

REFERENCES

1. Soil Screening Guidance, USEPA, Office of Emergency and Remedisl Response, HazardousSite Control Division, EPA/540/R-94/101, December 1994.

2. Development of Risk-Based Concentrations, EPA, Risk-Based Concentration Table, Back-ground Information, Roy L. Smith, February 1995.

3. Guidance Document for the Remediation of Contaminated Soils, New Jersey Department ofEnvironmental Protection, Site Remediation Program, Bureau of Planning and Systems: 609-292-9418, June 1994.

4. Risk-Based Corrective Action (RBCA) Software Package and Guidance Document, AmericanSociety of Testing and Material (ASTM), 1995.

5. Designation: PS 104-98, Standard Provisonal Guide for Risk-Based Corrective Action, Ameri-can Society for Testing and Materials (ASTM), July 1998.

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nive

rsity

] at

03:

40 1

1 N

ovem

ber

2014

risk-based zoning strategy for soil remediation at an industrial site

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