Fundamentals of Environmental Site Assessment and Remediation

Yue Rong, Yue Rong

• Éditeur: CRC Press
• Année: 2018
• ISBN:
  9781351590426
• Édition: 1
• Sujet: Technology & Engineering
• Sous-sujet: Environmental Management

Fundamentals of Environmental Site Assessment and Remediation examines all aspects of environmental site assessment and remediation and outlines the interdisciplinary skills needed to work in the field. It provides a comprehensive overview for students, environmental professionals, and real estate developers, and includes the latest environmental regulations, environmental site assessment and remediation practices, and industry standards. It examines pollution sources and the related impacts on drinking water supplies, the associated health risks, and how to protect water resources. The monitoring of surface water, groundwater, and soil is explained, as well as vapor intrusion. It will include several practical case studies throughout.

Features

• Includes the latest and best practices for environmental site assessment and remediation procedures.
  
  

• Presents a multidisciplinary approach, including environmental forensics, nanotechnology, microbiology (DNA technology) and isotopes, etc.
  
  

• Examines various pollutants and their related impacts on drinking water supplies, the associated health risks, and how to protect water resources.
  
  

• Presents the best practices for the monitoring of surface water, groundwater, and soil.
  
  

• Covers the latest environmental regulations and industry standards.
  
  

1	Site Remediation–Related Laws and Regulations

Ning-Wu Chang , Jian Peng , Jason J. Wen , and Yue Rong

CONTENTS

1.1 Introduction

1.2 Resources Conservation and Recovery Act

1.2.1 Disposal of Site Remediation Waste

1.2.2 Imminent Hazards and Corrective Actions

1.2.3 Underground Storage Tanks

1.3 Comprehensive Environmental Response Compensation and Liability Act

1.3.1 National Contingency Plan

1.3.2 Hazardous Substances and Petroleum Exclusion

1.3.3 Responsible Party

1.3.4 Brownfields Program

1.4 Clean Water Act

1.4.1 Water Quality Criteria

1.4.2 NTR and CTR

1.4.3 Sediment Quality Objectives

1.4.4 Total Maximum Daily Loads (TMDLs)

1.4.5 National Pollutant Discharge Elimination System (NPDES)

1.4.6 State Implementation Plan (SIP)

1.4.7 A Case Study in Clean Water Act Implementation

1.5 Safe Drinking Water Act

1.5.1 Safe Drinking Water Act and Drinking Water Regulation

1.5.2 Drinking Water Source Protection

1.5.3 Drinking Water Standards and Remediation Goals

1.6 California Low-Threat Underground Storage Tank Case Closure Policy

Practice and Exercises

References

Further Reading

1.1 Introduction

This chapter provides an overview of legislations and regulations related to site remediation. Besides the overarching objectives of site remediation to protect human health and the environment, the implementation of site remediation relies on regulatory framework and guidelines. There are two primary laws that govern site remediation: the Resource Conservative and Recovery Act (RCRA) and the Comprehensive Environmental Response Compensation and Liability Act (CERCLA), as will be discussed further in this chapter.

The US RCRA of 1976 is the primary legislation regulating hazardous waste management. RCRA originated as a set of amendments to the Solid Waste Act of 1965. RCRA was then signed into law in 1980 and 1984 with additional amendments. The 1984 RCRA amendment is often referred to as the Hazardous and Solid Waste Amendment (HSWA). Basically, RCRA contains the “cradle to grave” concept in the control of hazardous material and the handling of hazardous waste. The other primary legislation is the CERCLA, also known as the Superfund, which addresses hazardous waste release from past activities and emergency responses. The CERCLA was first passed in 1980 and was amended in 1986 with the Superfund Amendments and Reauthorization Act (SARA) to add new requirements and new focus to the Superfund program.

The other related environmental legislations, such as the Clean Air Act (CAA), the Clean Water Act (CWA), the Safe Drinking Water Act (SDWA), the Toxic Substances Control Act (TSCA), and the National Environmental Policy Act (NEPA), are also applicable regulations governing the implementation of site remediation.

1.2 Resources Conservation and Recovery Act

RCRA covers hazardous waste management from a preventive perspective. It addresses the hazardous waste management responsibilities of all involved entities, including generators, transporters, and treatment, storage, and disposal facilities (TSDF). RCRA is a federal law and provides the minimum requirements. However, under RCRA, states can develop their own hazardous waste programs. The state programs must meet or exceed the requirements in the federal program, and the states must be authorized by the United States Environmental Protection Agency (EPA) to implement the state programs.

There are areas in RCRA that are relevant to site remediation: the disposal of site remediation wastes, imminent hazards, and corrective actions for RCRA-regulated facilities. They are briefly discussed in the following sections.

1.2.1 Disposal of Site Remediation Waste

For the most part, hazardous waste from site remediation must be managed in accordance with applicable RCRA requirements. First, the waste generated from the site remediation must be profiled properly to determine whether the waste from site remediation is a hazardous waste. The criteria for the classification of hazardous waste have been codified in Part 40 of the Code of Federal Regulation (40 CFR), specifically in 40 CFR 261. In general, a hazardous waste can be a characteristic waste or a listed waste under this regulation. However, under this regulation, some wastes are exempted and excluded from full RCRA regulations. The list of excluded wastes can be found in 40 CFR 261.4, and universal waste as an exempted waste can be found in 40 CFR 261.9. However, since the state program may be more stringent than RCRA, certain excluded wastes under RCRA may still be considered as hazardous wastes under the state program. In addition, the state program may name and/or identify additional wastes as hazardous wastes.

Certain special wastes are not regulated under RCRA. For example, polychlorinated biphenyls (PCBs) are regulated under TSCA, specifically under 40 CFR 761; therefore, they are not regulated under RCRA unless the toxicity limits are exceeded. Similarly, since asbestos is already regulated under CAA, CWA, and TSCA, it is not regulated as hazardous waste under RCRA.

Under RCRA, the entity (the responsible party in the case of site remediation) will be responsible for properly identifying the hazardous waste being generated. Once identified as hazardous waste, the waste must be handled in accordance with RCRA’s generator, transporter, on-site or off-site TSDF regulations.

1.2.2 Imminent Hazards and Corrective Actions

Under RCRA, the responsible persons of an RCRA-regulated entity are required to take the necessary cleanup actions when situations pose imminent hazards from hazardous waste releases. RCRA’s authority is usually used to strengthen the government’s action through issuing orders, decrees, and agreements.

The corrective actions under RCRA are synonymous with site remediation in general. Releases of hazardous waste from an RCRA-regulated facility will require the corrective actions necessary to protect human health and the environment. Even though RCRA usually regulates the hazardous waste management within the facility boundary, such as fence-to-fence coverage, corrective actions can extend beyond the facility boundaries as needed. An RCRA-regulated facility, through permit or administrative order, is required to conduct facility investigations, corrective measure studies, and corrective actions: a similar process to CERCLA site remediation.

1.2.3 Underground Storage Tanks

In 1984 RCRA amendments, the underground storage tank program was added as Section 601. The purpose of this program is to regulate underground tanks that store regulated substances to prevent and manage releases. The regulated substances include hazardous chemical products and petroleum products. Hazardous waste storage tanks are already regulated under RCRA Subtitle C, which details performance standards under the RCRA facility permit requirement.

This RCRA amendment specifies schedules for system installation and notification, for leak and release detection, for release response and corrective action, and for standard setting for new tanks. The technical standards and corrective action requirements for the owners and operators of underground storage tanks are further codified in 40 CFR 280.

The underground storage tank program expands the regulated communities to small quantity entities such as neighborhood gasoline fueling stations. Any releases from the underground storage tank will be subject to similar RCRA corrective action requirements, and the corrective action will usually go beyond the property boundary of a gasoline station.

1.3 Comprehensive Environmental Response Compensation and Liability Act

To respond to circumstances where there is an imminent hazard from past releases, CERCLA, also known as the Superfund Program, was enacted in 1980. The CERCLA program also addresses immediate response to emergencies due to hazardous releases and establishes reporting quantities for all hazardous substances. CERCLA provides broad federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment. CERCLA provides a framework for site remediation and requires more extensive public participation in the site remediation process (USEPA, 1992). There are several areas that require further discussion.

1.3.1 National Contingency Plan

The CERCLA implementing regulations have been codified in 40 CFR 300, the National Oil and Hazardous Substances Pollution Contingency Plan (also known as the National Contingency Plan [NCP]). The NCP provides the guidelines and procedures needed to respond to releases and threatened releases of hazardous substances, pollutants, or contaminants. These guidelines and procedures are generally followed when conducting site remediation.

The NCP spells out the typical sequence of a site remediation project, which involves the following steps: preliminary assessment (PA), site investigation (SI), listing of priority list (National Priority List [NPL] under federal program), remedial investigation (RI), feasibility study (FS), record of decision (ROD), remedial design (RD), remedial action (RA), long-term operation and maintenance, and final site close-out. During the FS, the remedial alternatives will be evaluated using the following nine criteria:

• Threshold criteria

• Overall protection of human health and the environment

• Compliance with applicable or relevant and appropriate requirements (ARARs)

• Balancing criteria

• Long-term effectiveness and p...