Not every remedial approach will work on every site. Certainly not every remedial approach is ideally suited for every site. AEL takes a careful approach to evaluating and selecting remedial strategies that are matched to the client’s specific goals for the site.
When a Phase II ESA finds impacts above the allowable limit on a property, the process of evaluating option for remediating this contamination begins. This is called a Phase III ESA and happens prior to filing a Record of Site Condition (RSC) for the site.
To evaluate remedial options for their suitability for a specific project, the team begins by identifying the problem on the site and reviewing characterization that has been done so far. This includes Phase I and II ESAs that have been completed for the site and any other documentation that they have access to.
The team then will examine non-technical drivers that are influencing the project. What are the client’s goals for the site? Who is liable and what does their liability look like? Other non-technical factors are considered and evaluated.
Next, remedial technology selection criteria are identified and ranked by importance. The team may develop a force-ranking system or points system at this point to aid in weighing the importance of each factor. These may include:
- Compliance with achieving remediation targets, or effectiveness;
- Ease of implementation;
- Schedule to implement;
- Social acceptability;
- Cost (considered AFTER technical considerations are assessed)
All potential remedial approaches are listed (regardless of their perceived appropriateness) and are placed in a simple matrix with the selection criteria identified above. These may include no action, monitoring only, containment/control/isolation strategies, off-site disposal, on-site in-situ treatment, on-site ex-situ, or combinations of those.
This matrix is evaluated by the team with force-rankings applied. The initial screening of all potential remediation approaches is iterative – gradually moving down to a subset of 5-6 realistic approaches. When the team has identified and agreed upon these 5-6 approaches, a more careful evaluation is completed. This time, it includes cost (or cost-benefit, as appropriate) as well.
The team provides a final reality check to ensure all issues have been considered with respect to the top 2-3 selected approaches. Cost projections are developed.
The team proceeds to recommend the most appropriate remedial alternative (which may be a combination of risk assessment and physical remediation) including:
- Implementation cost;
- Schedule; and
- Post monitoring/verification.
With all these factors considered in the selection process, the team can be confident that they’ve given a thoughtful evaluation of strategies for the site. The owner is able to see the process and understand the factors behind the team’s recommendation. AEL believes that this logical and straightforward process leads to clear decision-making and effective management of environmental risk.