IMPROVING SITE CHARACTERIZATION Rhode Island’s Perspective IMPROVING SITE CHARACTERIZATION Rhode Island’s Perspective Overview by Leo Hellested, P.E. Chief RI DEM Office of Waste Management

I.Goals/Objectives Programmatic Goal: To minimize or eliminate the impacts and risks to human health and the environment which result from releases of oil, chemicals or wastes.Programmatic Goal: To minimize or eliminate the impacts and risks to human health and the environment which result from releases of oil, chemicals or wastes. Site Characterization Objective: To accurately assess the nature and extent of contamination, including its mobility, toxicity and volume, such that the actual or potential impacts of the release may be evaluated and addressed.Site Characterization Objective: To accurately assess the nature and extent of contamination, including its mobility, toxicity and volume, such that the actual or potential impacts of the release may be evaluated and addressed.

II.Program Background and Perspective R.I.’s program is not privatized (e.g. no LSP process).R.I.’s program is not privatized (e.g. no LSP process). Site Investigation Reports (SIR’s) require RI DEM approval.Site Investigation Reports (SIR’s) require RI DEM approval. A scope of work (SOW) for the SIR does not require approval (optional in VCP). A scope of work (SOW) for the SIR does not require approval (optional in VCP).

II.Program Background and Perspective (cont.) There are no regulatory hurdles inhibiting use of innovative investigation (or remedial) technologies.There are no regulatory hurdles inhibiting use of innovative investigation (or remedial) technologies.

III.RIDEM Issues: Technical and Administrative Waste Site Remediation Permit Streamlining Task Force –Waste Site Remediation Permit Streamlining Task Force – Spring thru fall Stakeholder Process Purpose: To identify issues and recommendations for improving the review/approval process for clean up projects - Administrative, regulatory and technical areas.Purpose: To identify issues and recommendations for improving the review/approval process for clean up projects - Administrative, regulatory and technical areas.

III.RIDEM Issues: Technical and Administrative (continued) Incomplete SIR submissions necessary for final decision making.Incomplete SIR submissions necessary for final decision making. Insufficient data or data gaps.Insufficient data or data gaps. Unclear text (explanations) in SIR of methodologies and/or rationales used – Reports need to be clear and concise.Unclear text (explanations) in SIR of methodologies and/or rationales used – Reports need to be clear and concise. Lack of guidance materials – unclear RIDEM expectations.Lack of guidance materials – unclear RIDEM expectations.

III.RIDEM Issues: Technical and Administrative (continued) Additional training – for both consultants and RIDEM staff.Additional training – for both consultants and RIDEM staff. RIDEM review process not commensurate with site risks.RIDEM review process not commensurate with site risks.

IV.Administrative Recommendations and Outcomes IV.Administrative Recommendations and Outcomes Developed a submission checklist to standardizing both submissions and reviewsDeveloped a submission checklist to standardizing both submissions and reviews Developed a “Marginal Risk Site” policy to expedited review of low/marginal risk sites.Developed a “Marginal Risk Site” policy to expedited review of low/marginal risk sites. Developed joint training opportunities between RIDEM and RISEP (Rhode Island Society of Environmental Professionals).Developed joint training opportunities between RIDEM and RISEP (Rhode Island Society of Environmental Professionals). Committed to more “pre-application” meetings between staff and owners/consultantsCommitted to more “pre-application” meetings between staff and owners/consultants Developed a FAQ’s guide on “How to Hire an Environmental Professional”.Developed a FAQ’s guide on “How to Hire an Environmental Professional”.

V.Ongoing Efforts on Technical Issues: RIDEM recognizes the benefits of gathering larger data sets, even with less QA for individual data points, to better characterize site contamination. RIDEM recognizes the benefits of gathering larger data sets, even with less QA for individual data points, to better characterize site contamination. Greater use of direct push technologies and micro- wells (geoprobes).Greater use of direct push technologies and micro- wells (geoprobes). Regular use of field screening techniques including on-site GC labs.Regular use of field screening techniques including on-site GC labs.

V.Ongoing Efforts on Technical Issues (cont.): Immunoassays – Currently being used by State TAC contractor on pre-remedial sites and on other federal clean up projects for PCB’s and dioxin (Centerdale Manor Superfund site, and other DoD and pre-remedial sites).Immunoassays – Currently being used by State TAC contractor on pre-remedial sites and on other federal clean up projects for PCB’s and dioxin (Centerdale Manor Superfund site, and other DoD and pre-remedial sites). XRF technology currently being used and advocated on DoD sites (Newport Navy sites). OWM also is trying to secure funding to purchase its own XRF unit.XRF technology currently being used and advocated on DoD sites (Newport Navy sites). OWM also is trying to secure funding to purchase its own XRF unit. Passive diffusion samplers used at Centerdale Manor to assess river impacts. Use on other pre- remedial sites being advocated.Passive diffusion samplers used at Centerdale Manor to assess river impacts. Use on other pre- remedial sites being advocated.

VI. Remaining Issues Lab analysis still required for confirmation sampling (typically 10% or more).Lab analysis still required for confirmation sampling (typically 10% or more). Dynamic work planning not always consistent with public participation requirements.Dynamic work planning not always consistent with public participation requirements. Issues with identifying environmental receptors and evaluating eco-risk (in particular on state sites and/or urban settings - criteria). Issues with identifying environmental receptors and evaluating eco-risk (in particular on state sites and/or urban 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.