Strategic Planning for Contaminated Sediment Projects: Setting the Course for Proper Project Execution Howard L. Cumberland Geosyntec Consultants October 24, 2012

Talk Overview  Regulatory Considerations  Conceptual Site Model  Client Understanding and Developing the Desired End-Game Strategy  Agency Negotiations  Project Completion

Regulatory Considerations  Investigation/Disposal  Clean Water Act  404, 401, 303d, NPDES  CERCLA, RCRA,  Promulgated State Programs  Rivers and Harbors Act  Marine Protection Resources and Sanctuary Act  Restoration  Oil Pollution Act (OPA) – NRDA  ESA, Wetlands  Tribes/Public

Conceptual Site Model

Strategy Development  Complexities require a strategy that is based on total project goals:  Business objectives  Regulatory and Stakeholder objectives  Short- and long-term goals  Continually re-assessed and forward looking  Continually discussed with Management and Regulators

Client Strategy  What is the Business Strategy?  Operating property or Legacy Site  Is there Insurance?  Many clients and regulators do not have sediment-specific technical expertise  Previous Owners  Adjacent properties (PRPs) and are you aligned?  What is timing?  Can investigations be combined with new- or re-development?  Is property for Sell?

Study Design – Strategic Planning  What are the Questions Being Asked by the Agencies?  How Do We Answer the Questions?  How to Define and Agree on Objectives?  How Sophisticated are the Data Needs?  What Are the Sources/Pathways?  How many do you assess at once?  What Are the Ranges of Successful Outcomes?

Data Needs  Multiple Pathways and contaminant sources (site and non-site related)  Source identification  Nature and extent of contamination – horizontal and vertical  Contaminant fate and transport  Hydrodynamics and hydrology  Exposure pathways and biological receptors  FS data needs  Remedial Options  CONTINUALLY ADD DATA AND RE-EVALUATE CSM

Formulate the Study Questions  What level of contamination is a concern, and over what area?  What are the Sources? What are the unknowns?  What do you need to know in order to make decisions about how to clean up or manage the site?  What are the perceptions of the agencies?  What are the receptors?  Are there Published/Accepted sediment risk criteria?  What might be the end game?

 Define the primary contaminants  Determine which are yours  Identify Your and other sources Historical operations Current Operations Stormwater other inputs Identify and Evaluate COPCs

Components of Sediment Investigation Physical Biological Chemical Water Use Bathymetry Bearing Strength Mixing Layer Depth Particle Size / Distribution Groundwater Interaction Hydrodynamics Toxicity Human Fish Consumption Susceptible Species Assessment Indicator Species Analysis Habitat Stressor Analysis Emergent / Submergent Plants Bioavailability Radiometric Dating Biota Concentrations Pore Water Analysis Surface/Vertical Contaminant Concentrations Contaminant Speciation Geochemistry

Multiple PRPs

Restrict Depth of Excavation

Joint Defense Agreement - Privileged and Confidential 2012

1934

 Complex Sediment Sites Require:  A Comprehensive and Integrated Project Strategy  Experienced Multi-disciplinary Team  Focus on Business and Regulatory goals to maintain positive momentum and direction Conclusions