The document summarizes a presentation on the history and evolution of risk-based corrective action (RBCA) for environmental remediation. It discusses how RBCA developed from early cleanup standards using total petroleum hydrocarbons to more sophisticated site-specific risk assessment approaches. It also overviewed the global environmental remediation market, noting the US and Europe as leaders and emerging opportunities in Asia and developing countries.

1. Presentation to Environmental Consultants in Tokyo Monday August 15, 2011 Risk-Based Corrective Action (RBCA): History, Evolution, Realities and Risk + ASTM 101 + Environmental Business in the Global Market Joseph E. Odencrantz, Ph.D., P.E. Principal, Tri-S Environmental-California Visiting Professor, Kyoto University (2007-on going)

3. Enforced by Local Fire Departments. Prone to false positives. C8-C70 Range. Infrared Detector. Does not discriminate compounds.

4. Used 1980`s and Early 1990`s

7. Considered Precipitation, Depth to Groundwater and Source Thickness

8. Tables and Decision Matrices to Simplify Risk Analyses: Scoring System

9. Remediation Required?

11. Cleanup Levels Based on Models Base Case> with set of parameters including Organic Carbon, Solubility, Biodegradation and other variables. Used SESOIL for one-dimensional soil transport and AT123D for groundwater transport.

12. 1991 Mobil Exploration and Production Research Expanded variables to include Effective Solubility, Biodegradation Rate Ranges and Organic Carbon Content with Sensitivity Analysis. Emphasized necessity for site specific parameters Odencrantz, Farr and Robinson (1992) Journal Article.

13. Beginning of RBCA Development of site-specific cleanup levels was the basis for the development of risk-based corrective action, RBCA. Regulatory Agency Cooperation and Education Began in California with site-specific parameters and cleanup levels. First Draft 1994 timeframe.

14. What is RBCA? For managing petroleum & chemical release sites through the integration of site assessment, risk assessment, risk management, and remedial action into a streamlined and technically defensible framework for environmental decision making.

15. Tier 1 A site is assessed by comparing concentrations at the point of contamination with risk-based concentrations established by the administering regulatory agency. Many sites (10% estimated) can be screened out at this point so that no further action is necessary.

16. Tier 2 Alternate, more realistic exposure points and scenarios. Some sites should screen out with a Tier 2 evaluation. Site-Specific Target Levels are implemented.

17. Tier 3 The most refined analysis and can involve detailed modeling and assessment of contamination reduction factors with contaminant fate and transport. Sites that do not pass a Tier 3 evaluation have substantial risk/hazard and should be remediated.

18. Many States Set Their Own Standards After RBCA came out in a formal standard, ASTM E1739 - 95(2010), the push was to get the method accepted and implemented into all 50 states. The process was long and difficult with some states refusing participation in the initiative.

19. API Decision-Support Software Developed in ~1995, Soil and Groundwater transport models combined with risk calculation models (Carcenogic-Risks and Non-Cargenogenic-Hazard Quotients). Deterministic and Monte Carlo on both transport and risk calculations.

20. Example Application

21. Low-Risk Sites In about 1997, State of California issued a directive to close all low risk sites, Most sites were predominantly clayey. Called the Petite letter. In California, the Governor was very conservative, but was not Arnold Schwartzenaeger.

22. Mandated Risk-Based Target Levels In Orange County, California, the Agency set 400 ppb (ug/L) in groundwater for the target “low risk” level for benzene. This short-lived basis did not last very long.

23. Move to Risk-Based Decision Making-1999 RBDM Performance Assessment Study was an ongoing research effort designed to assist state and territorial environmental regulatory agencies with the evaluation of their individual RBDM corrective action program performance for Leaking Underground Storage Tanks (LUST).

24. RBDM Continued The evaluation helped to determinewhether RBDMprograms areachievingtheirstate agency management goals.

25. Defined RBDM is a science-based processthat offers a clearly defined andconsistent basis for site evaluationand remediation. As a result, implementationof RBDM correctiveaction programs is expected toresult in increased program efficiencyand improved risk reduction.

26. Three-Part Program 1. Risk-Based Site Prioritization: Prioritizesites based on the timingor magnitude of potential impactsto human health and theenvironment.

27. Part 2 Site-Specific, Risk-Based RemediationGoals: Determine risk-basedconcentration limits for affectedenvironmental media designedto prevent impacts on humanhealth and the environment.Tier 1 remediation goals representgeneric concentration limits,based on conservative defaultassumptions. Tier 2 and Tier 3provide site-specific medialimits based on additionalsite data and more sophisticateddata analysis.

28. Part 3 Remedy Selection: Selectremediationalternatives, such as removalor exposure control, toaddress site-specific risk drivers.

29. Example Calculate CRF-Composite Reduction Factors Profiles. Defined as maximum site concentration / site cleanup goal. Break case load into no action, simple action, remediation plan required and estimated time of closure. Oversight cost assessment.

30. California-2005 The California Human Health Screening Levels (CHHSLs or “Chisels”) are concentrations of 54 hazardous chemicals in soil or soil gas that the California Environmental Protection Agency (Cal/EPA) considers to be below The thresholds of concern used to develop the CHHSLs are an excess lifetime cancer risk of one-in-a-million (10-6) and a hazard quotient of 1.0 for noncancer health effects. The CHHSLs were developed using standard exposure assumptions and chemical toxicity values published by the U.S. Environmental Protection Agency (USEPA) and Cal/EPA.

31. ASTM 101 Closing statements. Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

32. CHHSL`s The CHHSLs presented in thelookup tables are NOTregulatorycleanupstandards. Use of theCHHSLs is voluntary on the part of those who choose to use them. At sites where cleanup of contaminated soils to levels at or below the CHHSLs would be costly, the time and effort to develop more site-specific cleanup may be desired.

33. Example Benzene-AIR PHASE Indoor air- 8.40 E-02: Residential 1.41 E-01: Commerical Shallow Soil Gas 3.62 E+01:Residential 1.22 E+02: Commercial units- ug/m3

34. ASTM 101 Closing statements. Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

35. Vapor Testing Can use TO-15 or TO-17. TO-15: Summa canisters at 1L or 6 L size TO-17: Air pump with sorbents (Two carbon black and molecular sieve)

36. ASTM 101 ASTM International, formerly known as the American Society for Testing and Materials (ASTM), is a globally recognized leader in the development and delivery of international voluntary consensus standards. Today, some 12,000 ASTM standards are used around the world to improve product quality, enhance safety, facilitate market access and trade, and build consumer. 4257 standards contain the word environment and 15358contain the word water. www.astm.org

37. ASTM 101 Closing statements. Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

38. ASTM 101 Closing statements. Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

39. ASTM 101 Closing statements. Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

40. ASTM 101 Closing statements. Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

41. ASTM 101 Closing statements. Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

42. ASTM 101 Closing statements. Beacon Environmental (BESURE) vapor intrusion and indoor air sampling kits.

43. Environmental Business in the Global Market Material Obtained from Remediation and Nature and Landscape Protection Services: An Examination of U.S. and Foreign Markets United States International Trade Commission Publication 3727

44. Environmental Business in the Global Market Remediation services: Global market Total revenue approximately US $30 Billion annually. Remediation services accounted for 10. percent of the $300 billion worldwide environmental services market (solid and hazardous waste management services, nature and landscape protection, and remediation services.

45. Environmental Business in the Global Market Industry observers expect the environmental consulting segment of the remediation industry to be the principal beneficiary of increased trade in the future. Most agree that it is not cost-effective to export actual remediation services to most other countries because work requires specialized equipment that is difficult to transport across borders, and most technology is widely available. However, industry representatives believe that the skills of U.S. firms in areas such as site assessment and overall project planning are highly competitive in foreign markets, and over the coming years these are likely to represent growth opportunities for U.S. companies in the field.

46. Environmental Business in the Global Market EUROPE Demand for remediation services varies considerably across European markets. While certain large markets are mature, other markets are exhibiting significant growth. In particular, Central and Eastern European (CEE) countries are potentially large markets for such services due to Communist-era environmental damage and environmental obligations stemming from the recent accession of many of these countries to the European Union. However, CEE markets are relatively small at present, as other environmental issues such as air and water pollution take precedence over remediation services.

47. Environmental Business in the Global Market More on EUROPE-Market In 2000, Europe as a whole accounted for $8.6 billion,3 or 30 percent, of the global market for remediation services, making it the world’s second-largest market for such services behind the United States. Remediation service revenues grew at an average annual rate of 15.1 percent during 1994-2000. According to data provided by Environmental Business International (EBI), Western Europe accounted for $7.9 billion, or 92 percent, of revenues generated in the European remediation services market in 2000. In comparison, the research and consulting firm ECOTEC (now http://www.ecorys.com/ ) values expenditures on remediation and cleanup in the European Union at $4.1 billion in 1999. Note: Ecorys is a leading European research and consultancy company.

48. Environmental Business in the Global Market More on EUROPE-Technology Remediation methods vary from country to country with respect to efficiency, cost, and site requirements. Many Western European countries use physical or chemical remediation techniques to treat contaminated soil. These methods account for one-half of the European market for such services. In general, ex-situ technologies dominate the West European market because results are faster, firms have more experience using these technologies, and the results are more easily controlled. Results from use of in-situ technologies are typically not as fast as those from ex-situ technologies, and concerns about the comprehensiveness of the results have constrained demand for onsite remediation. However, in-situ technologies are often used in areas where extraction is impractical, such as underneath existing structures, in large contaminated areas, or in areas that contain both contaminated soil and water.

49. Environmental Business in the Global Market Asian-Markets While a handful of countries have substantial market activity in this sector, most are still in the process of defining standards and regulations. Japan accounted for the largest share of the Asia-Pacific market for remediation, although remediation services account for a greater share of overall environmental expenditures in Australia. The Australian market for remediation services is considered mature due to stringent regulations and increasing urban expansion that is raising the value of land and creating incentive for the transformation of former industrial sites into residential areas. Conversely, the Japanese remediation sector is poised for significant growth, with the country having passed its first national binding soil remediation law. HongKong, China, and Thailandhave either established or drafted standards for remediation, though enforcement mechanisms are not in place. In Malaysia and the Philippines, awareness of contamination issues has emerged, but other economic and environmental issues continue to take precedence over remediation and NLP issues

50. Environmental Business in the Global Market Emerging Markets-Latin America, Africa, Middle East and Asia (Not including Japan, Australia or New Zealand) The market for remediation services in developing countries represents only a small fraction of the global market for such services. Industry data indicate that Latin America, Africa, Asia, and the Middle East together accounted for $3.3 billion, or approximately 11 percent, of the nearly $29 billion global market for remediation services in 2000

52. Email: jodencrantz@tri-s.com

53. Web: www.tri-s.com

54. California: USA 949 644 8602

55. Japan Ketai: 09030562852

56. Japan Ketai email: jodencrantz@docomo.ne.jp