1. Improving The Quality of Site Characerization Jennifer Griffith Northeast Waste Management Officials’ Association

2. Northeast Waste Management Officials’ Association (NEWMOA) Non-profit, non-partisan interstate organization established in 1986 New England, New Jersey, & New York Governed by the Hazardous Waste, Solid Waste, Waste Site Cleanup, & Pollution Prevention Program Directors Facilitates communication & cooperation Develops unified positions on waste & P2 issues Organizes training & conducts research

3. Outline Redevelopment Phases Why is Site Characterization So Important? State Site Characterization Concerns Recommendations for Improvement Relevant Components of NEWMOA Project

4. Redevelopment Phases Preliminary Assessment – Site History – Develop thoughts on contamination – what/where Site Characterization – Define Nature and Extent of Contamination – Collect/analyze samples – test contamination theory – Also evaluate human health and environmental impacts Remedial Investigation – Samples/tests to determine feasibility of cleanup option(s) Remediation

5. Why is Site Characterization Important It is the foundation upon which all decisions about the future of the site are made! Provides the Information to Determine: – Appropriate future use(s) – Whether the site requires remediation or not – Extent of material that requires remediation – Remediation options that might be appropriate – Cost estimate for redeveloping site

6. More Reasons… Get it wrong and it could COST you! – Extra work = dollars and schedule delays – Lost opportunities If you think there is more contamination than there is… – Liability If you miss something and it’s found later – it’s still your problem (even if you’ve sold the property)…

7. State Site Characterization Concerns Insufficient Data to Adequately Determine: – nature and extent of contamination – potential exposures Documentation/Report Quality Problems – significant resources spent writing lengthy comment letters and other correspondence – resources could be used more efficiently to move other projects Many Projects Take Too Long – years spent going back and forth – wastes resources!

8. NEWMOA Projects Innovative Technology – Advisory Opinions and Research Brief Improving Quality of Site Characterization – Top Priority of Waste Site Cleanup Program Directors – Consultant Outreach Conferences & Survey Results – Outreach to Responsible Parties Documents Presentations – Consultant Workshops on Conceptual Site Model Approach Stakeholder Input!

9. Stakeholder Advisory Group Representatives from: Environmental bankers (1) Environmental insurance (1) Environmental lawyers (2) City Neighborhood Redevelopment (1) Industry (3) Consultants (3) Excellent Roundtable Discussions Similar Concerns as States – Report Quality!

10. Recommendations Upfront Strategic Planning – Conceptual Site Model (CSM) Collect More Data – More data of lower quality from more locations is better than a few locations with “perfect” quality data – Innovative methods should play a role Write Better Reports – Present Information Clearly! Explain WHY!

11. Strategic Planning - Upfront Define clear project end goals – Identify decisions that must be made Develop Conceptual Site Model – Organizes and presents known information (graphics key - diagrams/maps/tables) – Identify areas of uncertainty – Identify information needed – Note: CSM is CONTINUOUSLY reevaluated and update with every piece of new information

12. More Data- Improving Decision Quality Traditional – A few fixed locations - borings/wells with drill rig – Samples with analysis off-site at laboratory – Evaluate data - revisit site to collect more data to fill gaps Improved – Rapid sampling methods and on-site analytics – Real-time data – can focus/follow problem areas – Better target (& limit) samples for analysis at lab – Save time – usually one sampling event – More data from more locations – better decisions

13. “Innovative” Technologies Sampling Methods – Direct Push – Microwells – Low-flow groundwater sampling – Soil gas survey Field Analytical Methods – X-Ray Fluorescence (XRF) – Immunoassay test kits – Portable Gas Chromatograph/Mass Spectrometry (GC/MS) Geophysical Methods

14. Report Problems Data doesn’t support conclusions Significant data gaps Only some data used (and some ignored) Lots of data – but: – it is not analyzed – what does it mean? – not presented clearly – need tables, maps and graphs

15. More Report Problems Report doesn’t explain WHY things were (and were not) done – leaves the regulator with too many questions Off-site conditions not addressed – need to discuss receptors! Difficult to determine how/where consultant and regulator disagree Report does not address all the requirements in the state regulations

16. Conceptual Site Model Benefits Data gaps managed Data is analyzed and presented well Reasoning is explained – a key to better reports! – many potential questions are answered – makes correspondence more efficient Receptor evaluation is integral Conclusions are based on the data Overall stakeholder confidence enhanced Less skepticism about quality of work

17. FYI - Advisory Opinions Technology Review Committee – Staff members from each state Immunoassay – Advisory issued May 1999 X-ray Fluorescence – September 1999 Portable GC/MS – November 2000 Passive Diffusion Bag Samplers – Feb. 2002 Available at: www.newmoa.org/cleanup Co-sponsored hands-on training on each

18. FYI - Research Brief - Regulatory Barriers to Innovative Technology (1/2002) Examined state statutes, regulations, guidance documents, and policies Findings: – Generally no true barriers, but language often suggests traditional approach expected – “burden of proof” on user (extra work = barrier) – regulatory issues in CT, NJ, and NY – greatest use when lots of gov’t involvement Available at: www.newmoa.org/cleanup

19. Contact Information Jennifer Griffith NEWMOA 129 Portland Street, 6th Floor Boston, MA 02114 (617) 367-8558, ext. 303 (617) 367-0449 (fax) jgriffith@newmoa.org www.newmoa.org