Derivation of Alternative Remedial Goals

Derivation of Risk-Based Remedial Groundwater Concentrations. Groundwater containing Methyl tertiary Butyl Ether (MtBE) and benzene migrated from its release point, a service station, beneath a residential neighborhood into a storm water pipe whose outfall entered a 300-foot long swale discharging to a small stream. Dr. Smith derived risk-based concentrations of MtBE and benzene allowable in groundwater underneath the residential neighborhood based on their potential to infiltrate indoor air. Dr. Smith also derived a risk-based surface water concentration in the swale considering contaminant volatilization to air and adsorption to sediment. Dr. Smith evaluated receptor exposure through the inhalation of outdoor air, dermal contact with surface water and sediments, and ingestion of surface water and sediments by nearby residential receptors.

The client used these risk-based allowable media concentrations to back calculate allowable groundwater concentrations at a point of onsite compliance. Dr. Smith presented the findings of his analysis in a report and during court ordered arbitration that resulted in Pennsylvania Department of Environmental Protection (PADEP) agreement that the current release to surface water and current onsite and offsite groundwater MtBE and benzene concentrations do not pose significant health risk to residential receptors.

Derivation of Alternative Remedial Goal for Mercury Using the State default remedial goal for mercury in soil, a confidential client faced removal and treatment of more than 200,000 cubic yards of soil at a former pesticide manufacturing and battery disposal facility .  Dr. Smith managed the development and application of an innovative technique for estimating the bioavailability of inorganic mercury from soil using soil speciation and anin vitro bioaccessibility test.  Dr. Smith used this information to derive an alternate risk-based soil cleanup level for inorganic mercury that was more than 12-fold greater than the State default cleanup goal.  This resulted in a significant reduction in the amount of soil requiring removal and treatment, a projected remedial cost savings of $20–$30 million.

Negotiated Increased Remedial Goals for Selenium, Chromium, and Arsenic Concentrations of selenium, arsenic, and chromium in soil at a former forge site in Endicott, New York exceeded acceptable state action levels.  Remedial efforts to reduce the concentration of these metals in soils would have required the removal and/or treatment of approximately 16,000 cubic yards of soil.  Negotiation with the New York State Departments of Environmental Conservation (NYDEC) and Health (NYDOH) resulted in significant increases in the concentration of these metals allowed in site soils without restriction, resulting in an 80 percent reduction in the volume of soil requiring removal and/or treatment, a substantial savings in remedial costs.

Derivation of Alternative Remedial Goal for Mercury Dr. Smith assisted a competitor in the development of an alternative cleanup level for inorganic mercury in soils at a former thermometer and barometer manufacturing facility in Rochester, New York. Dr. Smith managed derivation of an alternative industrial site risk-based cleanup level for inorganic mercury in soil using site-specific bioaccessibility data. The alternative cleanup goal is estimated to save $5 million dollars in remedial costs.

Derivation of Alternative Remedial Goals for Boron and Lithium A confidential client had purchased a Superfund site for its stockpile of relatively pure Lithium.  Soils and ground water at the former mineral mining operation were determined to contain significant concentrations of boron and lithium.  The Pennsylvania Department of Environmental Protection (PADEP) assumed site soils were contributing to ground water contamination.  Dr. Smith was engaged to critically review information on boron and lithium mobility and toxicology to develop an argument for the derivation of alternative risk-based remedial goals for these metals in site soils.  Chemical-specific properties and site soil characteristics were used to develop an argument that soil boron and lithium were not mobile in site soils and therefore, were not a continuing source of contamination to ground water.  The result was a several fold increase in the allowable levels of lithium and boron which could remain in soil.

Derivation of an Alternative Remedial Goal for ArsenicState regulators in Minnesota required remediation of arsenic in site soils to a specified level at a former arsenic pesticide manufacturing facility.  Dr. Smith negotiated a higher remedial objective for arsenic in soil using information on soil arsenic bioavailability, planned future land use, and site- and receptor-specific exposure parameters.  Regulators agreed that an appropriate remedial goal for arsenic in site soils is twofold higher than initially proposed, resulting in significant cost savings in site remediation. 

Derivation of Groundwater Remedial Objectives.. Potable ground water beneath a former electronics manufacturing facility in Rhode Island contained several chlorinated volatile organic compounds (cVOC).  An engineering consulting firm hired to remediate the property was planning to remove and treat contaminated soils and ground water beneath the building slab.  Dr. Smith developed alternative groundwater remedial objectives based on estimates of human health risk posed by cVOC infiltrating indoor air, eliminating the need to remediate site soils underneath the building slab.

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