IMPROVING IMPROVING SITE CHARACTERIZATIONSITE CHARACTERIZATION

  Rhode Island’s PerspectiveRhode Island’s Perspective  

Overview byOverview by

Leo Hellested, P.E. ChiefLeo Hellested, P.E. Chief

RI DEM Office of Waste ManagementRI DEM Office of Waste Management

6-6-026-6-02

I.I. Goals/ObjectivesGoals/Objectives

• Programmatic GoalProgrammatic Goal: To minimize or eliminate : To minimize or eliminate the impacts and risks to human health and the the impacts and risks to human health and the environment which result from releases of oil, environment which result from releases of oil, chemicals or wastes.chemicals or wastes.

• Site Characterization ObjectiveSite Characterization Objective: To : To accurately assess the nature and extent of accurately assess the nature and extent of contamination, including its mobility, toxicity contamination, including its mobility, toxicity and volume, such that the actual or potential and volume, such that the actual or potential impacts of the release may be evaluated and impacts of the release may be evaluated and addressed.addressed.

II.II. Program Background and Program Background and PerspectivePerspective

• R.I.’s program is not privatized (e.g. no R.I.’s program is not privatized (e.g. no LSP process).LSP process).

• Site Investigation Reports (SIR’s) require Site Investigation Reports (SIR’s) require RI DEM approval.RI DEM approval.

• A scope of work (SOW) for the SIR does A scope of work (SOW) for the SIR does not require approval (optional in VCP).not require approval (optional in VCP).

II.II. Program Background and Program Background and PerspectivePerspective (cont.) (cont.)

• There are no regulatory hurdles There are no regulatory hurdles inhibiting use of innovative investigation inhibiting use of innovative investigation (or remedial) technologies.(or remedial) technologies.

III.III. RIDEM Issues: Technical and RIDEM Issues: Technical and AdministrativeAdministrative

• Waste Site Remediation Permit Streamlining Waste Site Remediation Permit Streamlining Task Force – Task Force –

Spring thru fall 2001 - Stakeholder ProcessSpring thru fall 2001 - Stakeholder Process

  • Purpose: To identify issues and Purpose: To identify issues and

recommendations for improving the recommendations for improving the review/approval process for clean up projects - review/approval process for clean up projects - Administrative, regulatory and technical areas.Administrative, regulatory and technical areas.

  

III.III. RIDEM Issues: Technical and RIDEM Issues: Technical and Administrative (continued)Administrative (continued)

• Incomplete SIR submissions necessary for final Incomplete SIR submissions necessary for final decision making.decision making.

• Insufficient data or data gaps.Insufficient data or data gaps.

• Unclear text (explanations) in SIR of methodologies Unclear text (explanations) in SIR of methodologies and/or rationales used – Reports need to be clear and/or rationales used – Reports need to be clear and concise.and concise.

• Lack of guidance materials – unclear RIDEM Lack of guidance materials – unclear RIDEM expectations.expectations.

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III.III. RIDEM Issues: Technical and RIDEM Issues: Technical and Administrative (continued)Administrative (continued)

• Additional training – for both consultants and Additional training – for both consultants and RIDEM staff.RIDEM staff.

• RIDEM review process not commensurate with RIDEM review process not commensurate with site risks. site risks.

  IV.IV. Administrative Administrative Recommendations Recommendations and Outcomesand Outcomes

• Developed a submission checklist to Developed a submission checklist to standardizing both submissions and reviewsstandardizing both submissions and reviews

• Developed a “Marginal Risk Site” policy to Developed a “Marginal Risk Site” policy to expedited review of low/marginal risk sites.expedited review of low/marginal risk sites.

• Developed joint training opportunities between Developed joint training opportunities between RIDEM and RISEP (Rhode Island Society of RIDEM and RISEP (Rhode Island Society of Environmental Professionals).Environmental Professionals).

• Committed to more “pre-application” meetings Committed to more “pre-application” meetings between staff and owners/consultantsbetween staff and owners/consultants

• Developed a FAQ’s guide on “How to Hire an Developed a FAQ’s guide on “How to Hire an Environmental Professional”.Environmental Professional”.

V.V. Ongoing Efforts on Technical Ongoing Efforts on Technical Issues:Issues:

RIDEM recognizes the benefits of RIDEM recognizes the benefits of gathering larger data sets, even with less gathering larger data sets, even with less QA for individual data points, to better QA for individual data points, to better characterize site contamination.characterize site contamination.

• Greater use of direct push technologies and micro-wells Greater use of direct push technologies and micro-wells (geoprobes).(geoprobes).

• Regular use of field screening techniques including on-Regular use of field screening techniques including on-site GC labs. site GC labs.

V.V. Ongoing Efforts on Technical Ongoing Efforts on Technical Issues (cont.):Issues (cont.):

• Immunoassays – Currently being used by State TAC Immunoassays – Currently being used by State TAC contractor on pre-remedial sites and on other federal contractor on pre-remedial sites and on other federal clean up projects for PCB’s and dioxin (Centerdale Manor clean up projects for PCB’s and dioxin (Centerdale Manor Superfund site, and other DoD and pre-remedial sites).Superfund site, and other DoD and pre-remedial sites).

• XRF technology currently being used and advocated on XRF technology currently being used and advocated on DoD sites (Newport Navy sites). OWM also is trying to DoD sites (Newport Navy sites). OWM also is trying to secure funding to purchase its own XRF unit.secure funding to purchase its own XRF unit.

• Passive diffusion samplers used at Centerdale Manor to Passive diffusion samplers used at Centerdale Manor to assess river impacts. Use on other pre-remedial sites assess river impacts. Use on other pre-remedial sites being advocated.being advocated.

  

VI.VI.                            Remaining IssuesRemaining Issues

• Lab analysis still required for confirmation sampling (typically Lab analysis still required for confirmation sampling (typically 10% or more).10% or more).

• Dynamic work planning not always consistent with public Dynamic work planning not always consistent with public participation requirements.participation requirements.

• Issues with identifying environmental receptors and Issues with identifying environmental receptors and evaluating eco-risk (in particular on state sites and/or urban evaluating eco-risk (in particular on state sites and/or urban settings - criteria).settings - criteria).

• Indoor air quality – ongoing issues with VOC’s. Indoor air quality – ongoing issues with VOC’s.

• Sediments – lack of standards. Sediments – lack of standards. •