Contributors Mohamed S. Abdel-Rahman University of Medicine & Dentistry of New Jersey, New Jersey Medical School, Newark, New Jersey Yalcin B. Acar Elecirokinetics Inc., Baton Rouge, Louisiana L. Bruce Allen OHM Remediation Services Corp., Trenton, New Jersey Bruce M. Applegate Center for Environmental Biotechnology at the University of Tennes- see, Knoxville, Tennessee Subrata Bandyopadhyay Tulane University, New Orleans, Louisiana Richard Bartha Rutgers University, New Brunswick, New Jersey Larry L. Barton The University of New Mexico, Albuquerque, New Mexico Sanjoy K. Bhattacharya Tulane University, New Orleans, Louisiana Robert C. Blake Il Meharry Medical School, Nashville, Tennessee Friedrich Boelsing University of Hannover, Hannover, Germany Judith Bower Carberry University of Delaware, Newark, Delaware Ronald M. Dennis Lafayette College, Easton, Pennsylvania Louls J. DeFilippi AlliedSignal Research and Technology, Des Plaines, Illinoisx Contributors Merrit P. Drucker Army Management Staff College. Fort Belvoir. Virginia Daniel Dworkin Roy F. Weston, Inc., West Chester, Pennsylvania Chi-Yuan Fan U.S. Environmental Protection Agency, Edison, New Jersey James T. Fleming Center for Environmental Biotechnology at the University of Tennessee, Knoxville, Tennessee Ronald D. Fletcher University of Pittsburgh, Pittsburgh, Pennsylvania Robert J. Gale = Electrokinetics Inc., Baton Rouge, Louisiana Abbas Ghassemi New Mexico State University, Las Cruces, New Mexico Duane A. Graves JT Corporation, Knoxville, Tennessee Satish K. Gupta /T Corporation, Knoxville, Tennessee Oliver J. Hao University of Maryland, College Park, Maryland Alan R. Harker Oklahoma State University, Stillwater, Oklahoma Robert H. Harris ENVIRON Corporation, Princeton, New Jersey Douglas A. Heely Groundwater Technology, Inc., Norwood. Massachusetts Armin Heitzer Center for Environmental Biotechnology at the University of Tennessee, Knowville, Tennessee Jeremiah D. Jackson = Kleinfelder, Inc., Sacramento, California Aaron A. Jennings Case Western Reserve University, Cleveland, Ohio Douglas E. Jerger OHM Remediation Services Corp., Findlay, Ohio Tim L. Jones New Mexico State University, Las Cruces, New Mexico Carl Keller Eastman Cherrington Environmental, Santa Fe, New Mexico William B. Kerfoot K-V Associates, Inc., Falmouth, Massachusetts Youngjun Kim Oklahoma State University, Stillwater, Oklahoma Sarah L. Kimball Oklahoma State University, Stillwater, Oklahoma P. S. Kodukula = Woodward-Clyde Consultants, Overland Park, Kansas Richard G. Kowalski Groundwater Technology, Inc., Norwood, MassachusettsContributors xi S. Krishnan GeoSyntec Consultants, Huntington Beach, California Peter M. Kroopnick Groundwater Technology, Inc., Concord, California Curtis A. Lajoie Center for Environmental Biotechnology at the University of Tennessee. Knoxville, Tennessee Maureen E. Leavitt /7 Corporation, Knoxville, Tennessee William C. Lindemann = New Mexico State University, Las Cruces, New Mexico Richard G. Luthy Carnegie-Mellon, Pittsburgh, Pennsylvania Priyodarshi Majumdar = Tulane University, New Orleans, Louisiana Ajay Manocha The University of Toledo, Toledo, Ohio Robert E. Marks Electrokinetics Inc., Baton Rouge, Louisiana Udayakumar Matrubutham Oklahoma State University, Stillwater, Oklahoma H. E. Nuttall The University of New Mexico, Albuquerque, New Mexico Peter J. Pace Vitro Corporation, Silver Spring, Maryland Sibel Pamukcu = Lehigh University, Bethlehem, Pennsylvania Kotu K. Phull U.S. Army Environmental Hygiene Activity-North, Fort Meade, Maryland William G. Rixey University of Houston, Houston, Texas Kevin G. Robinson University of Tennessee, Knoxville, Tennessee John Sanseverino = /T Corporation, Knoxville, Tennessee Photeinos Santas ikoTechnics, Athens, Greece Regas Santas 9 OikoTechnics, Athens, Greece Kevin M. Savage University of Cincinnati, Cincinnati, Ohio Gary S. Sayler Center for Environmental Biotechnology at the University of Tennessee, Knowille, Tennessee Gloria A. Skowronski University of Medicine & Demtistry of New Jersey, New Jersey Medical School, Newark, New Jersey Peter F. Strom Rutgers University, New Brunswick, New Jersey Anthony N. Tafuri U.S. Environmental Protection Agency, Edison, New Jersey Marleen A. Troy OHM Remediation Services Corp., Trenton, New JerseyContributors Rita M. Turkall University of Medicine & Dentistry of New Jersey, New Jersey Medical School and School of Health Related Professions, Newark, New Jersey Stephen A. Turner ABB Environmental Services, Inc., Portland, Maine Daniel M. Twomey, Jr. ABB Environmental Services, Inc., Portland, Maine C. Vipulanandan University of Houston, Houston, Texas $. Wang University of Houston, Houston, Texas Xlaoping Wang Rutgers University, New Brunswick, New Jersey Jill Warnasch =ENVIRON Corporation, Princeton, New Jersey Stephen T. Washburn ENVIRON Corporation, Princeton, New Jersey Elliot S. Werk Groundwater Technology, Inc., Norwood, Massachusetts J. Kenneth Wittle = Electro-Petroleum, Inc., Wayne, Pennsylvania Kent Zenobia Kleinfelder, Inc., Sacramento, California Alan J. Zupko Roy F. Weston, Inc., West Chester, PennsylvaniaPart I ENGINEERING ISSUES IN WASTE REMEDIATION1 Ethical Responsibilities of Environmental Engineers Merrit P. Drucker Army Management Staff College Fort Belvoir, Virginia 1. INTRODUCTION Environmental engineers have the fate of the Earth in their minds and hands. As the global ecosystem continues to decline, the combined efforts of all of humanity will be required if we are to halt the precipitous destruction of the biosphere. All professions will need to become extensively involved in the effort to heal the Earth; environmental engineering is no exception. Environmental engineers have been and will continue to be in the forefront of any effort to protect the environment. This is an immense responsibility, and in the final analysis, a moral responsibility. Every engineer ought to keep in mind that the engineering profession does not exist for itself; rather, it exists to serve humanity and the environment. Now humanity finds itself at a crossroads. We can radically transform all of our human systems, making them harmonize with and respectful of the Earth, or we can continue our present global system, which will guarantee the degradation of the Earth and the eventual demise of any form of human civilization worth living in The seriousness of the present state of environmental degradation cannot be overstated. While considerable local progress has been made in some areas of the world, the combined effects of overpopulation, pollution of all types, global deforestation, soil erosion, depletion of the ozone layer, warfare,” industrial preparation for war, the greenhouse effect. and loss of species diversity will be disastrous not only for humans, but also for all other living organisms on Earth. The ecosystem does not belong to any nation or state, despite the political boundaries established to mark the living places of different peoples. Rather, the environment is the shared gift to and responsibility of all persons, no matter where they live. Environmental engineers “I describe environmental damage caused by warfare in my essay “The military commander's responsibility for the environment,” which appeared in Environmental Ethics. Volume 11. Summer 1989. Military engineers as well as engineers employed by the armed forces may find this essay of help in preventing war-caused environmental damage.2 Drucker should always strive to think in global or cosmopolitan terms. Few environmental problems lend themselves to strictly local solutions, and there is no possibility of simply sending problems away, Away is always someone else’s living area, or a problem for future generations. Awareness of these problems, as well as a strong demand on the part of individuals, groups, and some governments around the world to see these problems resolved, is increasing very rapidly. For the foreseeable future, environmental issues will continue to become more prominent in the daily lives of all the planet's inhabitants. We are in the very beginning stages of a massive, global paradigm shift, which will change every aspect of human culture. The political economy, systems of government, warfare. technology, educational systems, religion, philosophy, legal thinking, the arts and sciences, and theories of morality will change as we reevaluate our relationship to the Earth. We are entering a period of change that will be more pervasive, extensive, and massive than any other period in history, and that will dwarf any other great human cultural change. This period of change will be accelerated and made much more complicated by an unprecedented, and out of control, rate of change in technology. Despite much conflict and disagreement, the environment, or concerns about the environment, will soon become the central organizing principle of mankind, whether we consciously accept it or not. Global environmental degradation is so severe, and accelerating so rapidly, that we will soon be forced to accept protection of the environment as our first priority as a matter of sheer survival. New definitions of national security, national defense, and the rights of nations are rapidly emerging, and the need for a healthy environment will be part of all of them I. THE ETHICAL POINT OF VIEW Any notion of ethical responsibility depends upon the ethical point of view. This means that the practice of ethical conduct depends upon an acceptance of morality and moral thinking as a precondition for any discussion or consideration of ethical principles. What is the ethical point of view? It is an acceptance of the necessity and importance of morality and moral thinking and reflection in human situations. The ethical point of view requires consideration of matters of rightness and wrongness in all important human enterprises and endeavors. Perhaps most significantly, the ethical point of view requires that we consider morality to be universal, or applicable to all, without exception, and contains a strong presumption against individual exemptions. Some have argued that science, and engineering as a scientific and technological system, are amoral activities, or activities to which morality does not apply. This is simply not the case Science, logic, and mathematics are human systems fraught with moral and ethical assumptions, values, and preconditions. Science, scientific research, and the development of technology are not sterile, neutral, objective processes. They are heavily politicized activities grounded in ideological beliefs. Claiming that one is merely doing one's job, or only contributing technical information or input to a project does not exclude engineering from the moral realm. Engineers must examine the basic value assumptions underlying the supposedly objective science and technology that govern their activities. Putting technology before morality has lead to numerous human and ecological disasters. There are various ethical theories that have been developed over time to create systems to explain how we should act, or to define a consistent, rational ethical theory. Studying these theories can be of great value for those wanting to develop a refined ethical point of view. All *Sce Earth in the Balance by Senator Al Gore (Houghton Mifflin Company. New York, 1992) for a description of global environmental problems. their causes and likely consequences, as well as possible solutionsEthical Responsibilities 3 engineers are well advised to complete course work or to undertake a program of study to become knowledgeable about ethical theories; further, thinking and reflection on matters of ethics should be a lifetime pursuit for the engineer. 7 Engineering is a profession that is, in the final analysis, a moral undertaking. Engineers and their works touch all of us; their profession determines and shapes the physical infrastructure of our civilization. In turn, the physical form of our surroundings tends to influence and determine the shape and direction of our lives for the long term. No engineer can escape the need to adopt a moral perspective. Every significant environmental engineering decision is a moral decision, since this type of engineering has both direct and indirect effects on human healthy, the environment, and nonhuman species, as well as on future generations. ‘As persons with significant moral responsibilities, engineers ought to ask themselves a series of questions to better understand the ethical point of view. Why, for example, do engineers, design a waste water treatment system? The answer is to facilitate a clean, safe, health environment for humans and other species. But why do we want a clean, normal environment? We want it so life on Earth is easier, better, or more fulfilling and rewarding. But why do we want human life to be better? It is because we want to strive after the good in life, which is happiness or satisfaction, not only for people, but for all inhabitants of the planet. At its most basic, primary, most important level or foundation, engineering is, or ought to be, an enterprise whose aim is to increase the net amount of goodness, benefit, or happiness in the world, not only for humans, but for all other species as well. This is a simple concept, but one that will entail much complexity when put into action. Environmental engineers must consistently ask themselves, their peers, and their clients, at all stages of the engineering process, if the particular project or system will contribute to the overall long-term good or happiness of the world and all of its inhabitants. In the American legal and planning system, the National Environmental Policy Act (NEPA) is the Federal law that requires that the “why” question be asked about all large projects that affect the human or natural environment. The requirement to ask how a specific project contributes to humanity and the planet is not merely a formal or legalistic one. The necessity to constantly and consistently question the moral, legal, financial, and ecological wisdom of a particular project or process is a primary, basic, essential responsibility, which engineers, particularly environ- mental engineers, cannot avoid. Abdication or denial of this responsibility degrades the profession and causes the engineer to lose his or her status as a professional Environmental engineers ought not to assume that the ethical point of view is universally accepted. They should carry it with them into their professional lives with business, industry, government, or nonprofit organizations. There is an onus of moral responsibility on the environmental engineer to be a partisan for both moral thinking and the global environment. Ill. ENGINEERING AS A PROFESSION Engineering is an immensely powerful profession, pervasive in influence and enormous in potential. Engineers should be proud to be members of an ancient profession that has literally created the human-made world we live in. The very power of the engineering profession immediately and absolutely makes it a profession with a moral purpose, and as with all powerful forces, it must be guided by morality, often expressed in ethical systems, if itis to be a beneficial profession. Engineers are not technicians, drafts persons, or project managers, Rather, they are “I found Applying Moral Theories by C. E. Harris, Jr. (Wadsworth Publishing Company, Belmont, California, 1986) to be an excellent, concise discussion of four major ethical theories: self-interest, natural law. utilitarianism, and respect for persons. I recommend it for those interested in obtaining a working knowledge of moral theories.4 Drucker men and women with a moral purpose who express their moral thinking in the field of engineering. Engineering falls under the classic descriptions of a profession. Generally, the professions are set apart by clearly defined parameters. First, the hallmark of a profession is that it exists to serve the larger community, or the society. The professions, which have traditionally included law, medicine, the clergy, the military officer corps, and engineering, all exist, at least within the context of a democratic society, to serve the larger goals of the society. The professions serve others; they do not exist as self-serving or selfish entities. This altruistic motivation is what sets the professions apart from other occupations or forms of employment. To meet the needs of the client, or the larger society, the professions have developed a system to ensure that the standards and objectives of the profession are met. Generally, membership in the profession is open to all on a competitive basis. That is, the only criterion for entrance into the profession is the ability to perform in the profession. Matters of equal opportunity, equity, and social justice are extremely important, and all professions must ensure that fairness in s to the profession is maintained. The professions have established a general set of standards or norms for the regulation or maintenance of the profession. First, while entrance into the profession is open to all, there is generally some program of formal education required. This educational program is usually long and extensive; further, additional education and training is required throughout the professional's life. Second, there is normally some type of examination and licensing procedure required before admission into the profession. Third, the professions are self-regulating or autonomous They control their system of education, admission, discipline, and professional standards, often essentially free from government or societal oversight. Fourth, the professions generally have an internal disciplinary system that can censure or even expel members from the profession. Fifth, the professions have a special skill, knowledge, competence, or expertise not generally shared by the larger society. Finally, the professions engage in research and have a developmental aspect, or a research component, which is most clearly expressed in the professional journals and literature With the special characteristics of the professions come special responsibilities. Because the professions have a unique skill or knowledge, which cannot be effectively evaluated or supervised by the general public, professionals must always act to perform their duties in accordance with established professional norms. Other professionals who evaluate the work of their colleagues must be extremely rigorous and objective, and they must bear in mind that their primary responsibility is to the public, not the profession. Society must be able to trust the professions to act in the best interest of the society. Being a professional entails far more than being competent, having a license, or adhering to the formal and informal norms, values, and traditions of the profession. The professional mantle rests only upon those who have assumed both the responsibility to be competent in the profession and morally alert and inquisitive. Competence and right moral thinking are inseparable for the true professional in any field. Unfortunately, many professionals, while professionally competent, are often morally retarded Our educational system and professional associations have not done an adequate job in preparing people for professional moral responsibility, and they have been woefully inadequate in stimulating and sustaining moral debate within and among the professions. One has only to look at our decaying and inadequate infrastructure, our degraded and dying ecosystems, and our wasteful and irrational transportation, energy, production, and housing policies to see the result of our society’s general failure to adopt an inquisitive, imaginative, questioning, and reflective moral attitudeEthical Responsibilities 5 Engineers must become both moral philosophers and futurists if they are to transform their profession into one that will both serve humanity and preserve our shared planet. We are now at a critical, perhaps final, phase of human history. We must either transform human civilization into a culture in which all people can live together in harmony with the natural world, or we will perish, slowly in a dying planet, or quickly in a nuclear suicide. Engineering is at a crossroads. Engineers must decide if they are going to preserve the status quo, which is a prescription for disaster, or if they are going to radically transform engineering into a powerful force for human good and environmental health. Only through the carefully thought out decisions of individual engineers will this transformation take place. A carefully thought out decision is one that has fully and carefully answered the moral questions posed by the decision. IV. MORAL THINKING AND ORGANIZATIONS Engineers rarely work independently, totally free of external constraints. Rather, the environ- mental engineer will find him or herself employed by a for-profit organization or a government entity. Engineers, however, cannot transfer their moral responsibility to an external agency. At all times, they retain individual moral responsibility for their actions. This inherent, individual moral responsibility cannot be minimized or diluted through an organizational or bureaucratic structure. Each engineer must assume full responsibility for his or her actions. Engineers are in a unique position to do much moral good. Above all professions, their actions determine what is actually done to the Earth. Engineers must use this great power to protect and preserve the environment for all mankind. At times, bureaucratic organizations foster a climate of moral irresponsibility and stupidity They enable normally moral people to engage in activities that are clearly wrong. For example, many of the massive and destructive water projects implemented by the Bureau of Reclamation could only have been built by a large bureaucracy that stifled individual moral responsibility. Since decisions are “made” by the organization, no individual is responsible. Organizations often allow persons to evade responsibility for their actions.” Environmental engineers must be the guardians of their organization’s virtue. They must be alert to the legal and moral implications of what their organizations are doing, and they must be prepared to confront and stop environmentally immoral behavior. Confronting immoral (or merely stupid) action in one’s organization is not a supererogatory action, or an action above and beyond the call of duty. Correcting moral mistakes on the job is a normal responsibility of any morally developed person. The presence of “whistleblowing” in our organizations is evidence that moral thinking and responsibility have eroded so badly that when someone makes the simple assertion that a particular course of action is wrong or immoral, we have a special name for them. What whistleblowers do as an exception should be a normal activity for all. Everyone should make problems known and seek their correction, not when they become major problems, but every day, and in a proactive fashion. A well-managed, healthy organization will not need whistleblowers; it will prevent the situations that lead to whistleblowing Managers in engineering organizations (who may not necessarily be engineers) bear a special responsibility to create an ethically sound organizational culture. They must encourage both high standards and moral virtue, and they must ensure that those who disagree are heard and that divergent points of view are not shut out. Moral leadership is the single most important *Mare Reisner, in Cadillac Desert (Penguin Books, New York, 1987), presents a fascinating picture of two large bureaucracies: the Bureau of Reclamation and the Corps of Engineers. This work is instructive for its presentation of the interaction between engineering, politics, ecology. and morality6 Drucker contribution a manager can make to his or her organization, and managers must strive to create a situation in which people are allowed to act morally. They must avoid putting subordinates into situations of moral conflict or doubt. Vv. NONHUMAN SPECIES Much recent philosophical thinking has gone into the moral status of nonhuman species, their value and our relationship to them. One can consider other species valuable because they are useful to man, or valuable in and of themselves. This is a basic question of value that may never be fully resolved. There is an emerging consensus, however, that other species have a right to exist, and that the preservation of all species is important not only because they are beneficial to us, but because each species is a part of the integrated, global ecosystem. Species extinction will no longer be tolerated as the cost of progress. We are more likely to see projects being delayed, modified, or canceled entirely to protect one or more species, despite considerable political controversy. Thinking and engineering affecting the natural world must never neglect the impact of human activity on nonhuman species. Wildlife ecology, biological diversity, and species preservation must be vital concerns for every environmental engineer; every project and process must be conceived, designed, and implemented in a way that improves and enhances natural habitats and wildlife populations. We are not the only inhabitants of the planet; other living organisms have a right to exist. The other living species contribute to the richness, diversity, health, wholeness, and integrity of the environment, and they make our own lives better and more fulfilling by providing us examples of the forms and shapes life can take. We have a spiritual and economic need for large, healthy wildlife populations. Environmental engineers can be of great value to wildlife preservation, and they should actively seek to become educated on wildlife matters. Every engineering project should make the planet more hospitable for wildlife. This means that environmental engineers must question the assumptions and the information underlying all engineering projects that affect wildlife. ‘Toward that end, environmental engineers should educate themselves in the field of wildlife ecology, and they should regularly consult with wildlife specialists during all phases of the engineering process. Often, simple changes or modifications in the project can have enormously beneficial effects for wildlife. Considering wildlife throughout the project causes the project to be examined from another perspective; this examination of the situation from another perspective can be an important stimulus to both reflective moral thinking and higher quality engineering Vi. SUGGESTIONS FOR ENVIRONMENTAL ENGINEERS Morality requires action. This is a list of actions environmental engineers can take to put beliefs into practice: 1. Learn the moral principles and basic moral problems of the profession 2. Read the professional literature and know the thinking on moral issues confronting engineering. 3. Set a good example on the job, and encourage others to act morally. 4. Practice doing what you know to be right—develop moral courage. 5. Become involved in resolving environmental problems in your community. 6. Donate your professional expertise to nonprofit groups attempting to resolve environmental problems. 7. Adhere to high professional standards, and encourage others to do so.Ethical Responsibilities iy 8. Incorporate pollution control, waste minimization, and recycling into both engineering plans and daily operations. 9. Stay aware of environmental problems and solutions. 10. Take time to reflect upon the moral implications of your work. 11. Write professional articles that examine ethical problems in engineering. 12. Maintain contact with those outside the engineering profession to obtain different, perhaps adversarial, views about the engineering profession. ACKNOWLEDGMENT I would like to thank my friend, Eileen Sharon Rose Lynch. for her help in reviewing this chapter.2 Risk Assessment in the Remediation of Hazardous Waste Sites Stephen T. Washburn, Jill Warnasch, and Robert H. Harris ENVIRON Corporation Princeton, New Jersey 1. INTRODUCTION—AN OVERVIEW OF THE SITE REMEDIATION PROCESS The hazardous site remediation process generally consists of four steps: The preliminary assessment, which involves identification of any conditions at a site that pose an imminent threat to human health or the environment. This assessment is typically based on visual observations and limited sampling and analysis of site materials Selection and implementation of appropriate interim remedial measures, to address any imminent hazards that may exist at a site. In many cases, interim remedial measures may not be necessary, or may involve only restricting site access. Site investigation and remedial technology feasibility study, during which the nature and extent of contamination at the site are more accurately defined, and potential final remedies are identified and evaluated. Selection of a final remedy, based on the results of the site investigation and remedial technology feasibility study. The selection process takes into account a number of factors, including the effectiveness of different remedies in reducing risks at the site, and the cost associated with these remedies. The National Oil and Hazardous Substances Pollution Contingency Plan, also known as the NCP, explicitly requires that this process be followed for cleanups at Superfund sites." Similar requirements exist for remediation performed under the Resource Conservation and Recovery Act (RCRA), and many state statutes. The first two steps in the remediation process, the preliminary assessment and the selection of appropriate interim remedial measures (if necessary), are usually based on a review of available data and information and direct observations at the site. These initial steps are meant to be quick, relatively immediate measures to protect human health and the environment from imminent site-related hazards, and thus they should not involve extended, detailed studies 910 Washburn et al regarding the nature and extent of contamination or remediation options, Common examples of removal actions (or interim remedial measures) include the removal of leaking or otherwise dangerous drums from on site, the excavation of “hot-spot” surface soils, and the provision of an alternate water supply for surrounding residents affected by contaminated ground water. Once the imminent site hazards have been addressed through appropriate interim remedial measures, the nature and extent of contamination is usually more accurately defined through additional site characterization activities. In Superfund cleanups, this step is known as the remedial investigation (RI). The RI is intended to be a detailed study of the site hazards, including an assessment of the types and concentrations of chemicals present in the various environmental media (¢.g., soil, ground water, surface water, and air). After this information has been compiled, remedial options for addressing the site hazards are identified and evaluated Under Superfund, this process is known as a feasibility study (FS). After the FS is completed, a final remedy is selected on the basis of specific criteria set forth in the NCP. These criteria include long-term protection of human health and the environment after the remedy is completed, short-term protection of worker and community risk during remedy implementation, achieving applicable or relevant and appropriate requirements (ARARs). and cost effectiveness. “No action” must be evaluated as one of the options at all Superfund sites. Risk assessment is an integral part of the remedy selection process at hazardous waste sites. Using risk assessment, it is possible to perform a quantitative, objective evaluation of the need for cleanup activities, and develop a clear basis for comparing both the short-term and long-term risks associated with proposed remediation alternatives. This chapter provides an overview of risk assessment methodologies, and it examines the importance of risk assessment in the hazardous waste site remediation process—from the identification of which sites require cleanup through the selection of a final remedy. A case study based on an actual RCRA-site cleanup is presented to illustrate the application of risk assessment to the remedy selection process. This ase study assessed the risk posed to the off-site community in the event of a hypothetical, worst-case instantaneous release of contaminants from drums in a landfill. il, RISK ASSESSMENT METHODOLOGIES Both the National Academy of Sciences? and the U.S. Environmental Protection Agency* have established guidelines for performing risk assessments. According to these guidelines, a quantitative risk assessment typically includes the following three steps: Hazard evaluation Exposure assessment Risk characterization These steps are discussed in what follows. A. Hazard Evaluation The sampling and analysis of soil, ground water. surface water, air, and other environmental media at contaminated sites often reveal the presence of a variety of potentially hazardous chemical substances. At complex waste disposal sites, literally hundreds of individual chemicals may be detected in several different media After the validity of the data has been established, the chemicals of primary concern at a site can be identified. One common method for screening substances detected at a site is through a comparison with background levels in soil or ground water in that region. Such a screening permits elimination of ubiquitous compounds that do not reflect site activities. It may also beRisk Assessment in Remediation of Waste Sites M1 useful to consider possible releases from nearby off-site operations that may have affected the site under consideration, and on-site contamination that predates the present use of the site. For example, soil contamination at and around many industrial sites has been attributed to fill material brought to the area prior to site development or operation, and thus may represent the true local background conditions in an area. Once a list of chemicals possibly related to site activities has been obtained, additional screening methods can be applied to further reduce the number of chemicals to be considered in the risk assessment, if necessary. The USEPA’ describes several methods for selecting indicator chemicals, including grouping chemicals by class, evaluating frequency of detection, and applying a concentration-toxicity screen to select the contaminants most likely to present the greatest concern. In many cases, however, developing a defensible set of indicator chemicals may require more time and effort than simply including in the risk assessment all contaminants detected above background. Once the chemicals of concern at a site have been identified, available toxicity data are collected and evaluated to ascertain the nature of health effects associated with exposure to these chemicals. Data from actual human exposures are obviously the most relevant for assessing potential human health risk; however, such data are often unavailable, and information must instead be derived from studies involving laboratory animals as test subjects. For the purposes of a risk assessment, the toxicity studies of human or laboratory animal exposure must be evaluated to determine the quantitative dose-response relationship between the magnitude of exposure and the extent and severity of the adverse effect. Different methodologies are used to characterize dose-response relationships, depending on whether or not a chemical has been identified as a carcinogen according to classification schemes such as those used by the National Toxicology Program of the U.S. Department of Health and Human Services, the USEPA Carcinogen Assessment Group, and the International Agency for Research on Cancer (IARC). Carcinogens (chemicals believed to have the potential to cause cancer) are often assumed to pose some finite risk at any exposure level, with risk becoming zero only at zero exposure. This no-threshold assumption is based on theories regarding the mechanism of the carcinogenic process, and it has been generally adopted by the USEPA for all chemical carcinogens as a conservative practice to protect public health. For some carcinogens, such as arsenic and 2,3,7,8-tetrachlorodibenzo-p-dioxin (better known simply as dioxin), there is evidence suggesting that a minimum threshold dose must be exceeded before a carcinogenic response might be expected, although the USEPA has not adopted this position. ** Scientists have developed several mathematical models to extrapolate low-dose carcino- genic risks to humans based on effects observed at the high doses typically used in experimental animal studies. These models provide estimates of the upper limit on lifetime cancer risk per unit of dose (carcinogenic slope factor, or CSF). The mathematical model used by the USEPA to generate CSF values is the linearized multistage model. There are several alternative models that generally predict lower risks in the low-dose region, sometimes by several orders of magnitude. The regulatory agencies have used the linearized multistage model as a protective public health measure, however, because it generally provides a conservative estimate of risk at low doses (i.e., the model is likely to overestimate the actual CSF for a carcinogen, and thus overestimate potential cancer risk). It should be noted, however, that the multistage model may be less conservative than some other models for certain types of carcinogens. Noncarcinogenic effects are generally believed to occur only when exposures exceed a threshold dose. The threshold dose for a particular noncarcinogenic effect is identified by determining the no-observed-adverse-effect level (NOAEL)—or, if a NOAEL is not available, the lowest-observed-adverse-effect level (LOAEL)—from observations of exposed humans or experimental animals. For some chemicals, such as lead, it has been extremely difficult to12 Washburn et al establish an absolute NOAEL; itis possible that these substances may act through a no-threshold mechanism in producing noncancer health effects. NOAELs and LOAELs are divided by safety (or uncertainty) factors to obtain an acceptable daily intake (ADD for the chemical. An ADI represents a dose expected to present no health risk over a specified period of exposure (e.g. a lifetime). Safety factors adjust for limitations and uncertainties in the toxicity data, and for differences between the conditions under which the toxicity data were collected and the conditions of actual human exposure. They also adjust for variability in susceptibility in the human population, and for imprecision in extrapolating from laboratory animals to humans. The size of the safety factor applied depends on the nature of the toxicological information available. A 10-fold safety factor is typically used when extrapolating from studies involving long-term human exposures, to account for the possible presence of sensitive individuals in the general population. A 100-fold safety factor is applied when extrapolating from long-term animal experiments; this represents an additional 10-fold factor for extrapolating data from test animals to the “average” human. The application of generic safety factors is clearly a very simplistic way of addressing the many complex, chemical-specific issues associated with the extrapolation of toxicity data. Based on available information, these safety factors appear to be generally conservative, i.e., to provide an extra measure of protection for most chemicals. It is important to emphasize that, due to the uncertainties inherent in the development of ADIs, these values should not be viewed as strict demarcations between “safe” and “unsafe” exposure levels (although. in practice, that is often how they are used). Rather, ADIs should be viewed as conservative estimates of levels below which adverse affects would not be expected; exposures at doses greater than the ADI are associated with an increased probability (but not certainty) of adverse effects.® Thus, human exposures that exceed the ADI would not necessarily be expected to produce adverse health effects ADIs developed and verified by the USEPA are referred to as reference doses (R{Ds) and are expressed in mg/kg/day: the USEPA also publishes reference concentrations (RfCs) in mg/m* air. RfDs and RECs appear either in the USEPA Integrated Risk Information System data base (IRIS)’ or in the USEPA’s quarterly Health Effects Assessment Summary Tables (HEAST). When RfDs or RECs are not available. it is often possible to calculate ADIs by reviewing available data to determine a NOAEL or LOAEL, and applying the appropriate safety factors. Acute effects caused by short-term exposures are evaluated through comparison with levels that are known or believed to cause certain types of health effects. For example, for workers, comparisons to short-term exposure limits (STELs) developed by the American Conference of Governmental Industrial Hygienists (ACGIH) often can be used to analyze the potential for adverse effects; comparisons with Immediately Dangerous to Life or Health (IDLH) levels developed by the National Institute for Occupational Safety and Health (NIOSH) can be used to examine the possibility of more serious health effects. These criteria are not usually considered appropriate for the general population without the application of safety factors to account for sensitive individuals; furthermore, regulatory agencies often require more stringent standards in protecting public health than in assuring worker safety. In fact, standards established by the Occupational Safety and Health Administration (OSHA) are not based solely on health effect levels but may reflect detection limits or considerations of economic impact B. Exposure Assessment 1, Identification of Major Exposure Pathways The second step in the risk assessment process involves identification of populations at risk of exposure to the chemicals of concern, and the major potential pathways for exposure. TheRisk Assessment in Remediation of Waste Sites 13 pathways that are relevant at a site are dependent upon a number of factors, including which on-site environmental media are contaminated, the potential for chemicals in these media to migrate off site, and land use in the vicinity of the site. Common on-site pathways of exposure include direct contact with soil, incidental ingestion of soil, and inhalation of volatile chemicals or contaminated dust. Migration of chemicals off site can occur via a variety of mechanisms, including Wind-blown dust and vapor emissions from soil Leaching of chemicals to ground water with subsequent movement off site Runoff of surface water Once off site, chemicals can accumulate in other media, including crops, meat, milk, and fish. For each potential exposure pathway, individual routes of exposure (e.g., inhalation, ingestion, dermal contact) are identified, and chemical doses received by each route are calculated. In order to calculate the dose received, the following factors must be known or estimated: (1) the concentration of the chemical in the environmental medium at the point of contact; (2) the magnitude and frequency of exposure, which depends upon the frequency of contact with the environmental media and the amount of medium contacted (e.g., amount of soil deposited on skin, amount of water ingested), as well as physiological parameters such as breathing rate and body weight; and (3) the degree of absorption of the chemical into the body 2. Exposure Concentrations The results of site sampling and analysis are usually preferred for determining chemical concentrations in environmental media at the point of exposure. The use of site data in a risk assessment is not always straightforward, however. For example, if data on chemical concentrations in soil from many different site locations and depths are available, it must be decided whether to use the arithmetic average of all sample concentrations, some other statistical measure of the central tendency of the data (e.g., the geometric mean), the maximum measured concentration at any location and depth, or the average/maximum of some subset of the data (for example, excluding data obtained below a specified depth). Since sampling data often form the foundation of a risk assessment, it is important that site investigation activities be designed and implemented with the needs of the risk assessment in mind. For example, if direct exposures to surface soils are likely to be of primary concern, sampling can be directed toward the top layer of soil, rather than subsurface soils. Estimating exposure point concentrations is even more complicated when sampling data are not available for all media of concern, and it is necessary to predict chemical concentrations using mathematical models. For example, air dispersion models, such as the USEPA Industrial Source Complex (ISC) model, can be used to predict concentrations of airborne dust and chemical vapors at given distances downwind of a contaminated source area.* Other models can be used to predict the amount of chemical deposition from the atmosphere onto soil and water, and the subsequent uptake of chemicals in fish, plants, animals, and the food chain Although these models are often based on actual field data, their application can introduce considerable uncertainty into the resulting estimate of chemical concentrations. 3. Exposure Scenarios The actual dose that an individual receptor will receive from exposure to a given chemical concentration is a function of the frequency and magnitude of the exposure. This in turn is influenced by behavioral factors (e.g., the number of times a person is likely to visit a4 Washburn et al contaminated area and the nature of the activities performed in the area) as well as physiological factors such as breathing rate, body weight, and skin surface area The USEPA? has published “standard” parameters for many of the physiological factors, and it also provides some values for particular activity patterns, such as length of time an average individual resides at one location. In some cases, however, it may be possible to incorporate site-specific information (e.g., creel census data to determine the number and type of fish consumed by local fishermen) to refine the exposure scenarios. When site-specific data are unavailable, it is often necessary to rely on professional judgment in establishing appropriate exposure factors Initially, regulatory agencies? placed emphasis on providing conservative estimates of worst-case exposure assumptions (e.g., assuming a full 70-year lifetime at the point of maximum chemical concentrations). It is now recognized by regulators that the simultaneous use of many different, individual worst-case assumptions to derive an estimate of dose will result in a dose estimate so extreme that, in all probability, it would never occur. More recently, the USEPA? is emphasizing that exposure assessments should strive to provide an overall dose estimate that represents a “reasonable maximum exposure (RME),” defined as “the highest exposure that is reasonably expected to occur at a site.” [t is less clear which combination of “average” and worst-case individual exposure assumptions should be used to arrive at this result. One way to address this problem is through the use of computerized Monte Carlo simulations, which can provide probability distributions for dose and risk estimates by incorporating ranges for individual exposure assumptions. According to the USEPA,'? “The best approach for deriving a 90th percentile (or other percentile judged to represent reasonable worst-case) exposure level is by using Monte Carlo techniques.” Using Monte Carlo approaches avoids the problem of presenting a single point estimate of dose (or risk), which is easily misinterpreted as a “true” dose estimate, and instead presents a range of doses, along with indications as to the statistical probability of each dose estimate. Monte Carlo methods, as previously described, provide a probabilistic distribution of both exposure and risk. In a Monte Carlo simulation, each assumption within the risk assessment is assigned a probability distribution. Random input values for each assumption are chosen based on each input's probability distribution, and the resulting exposures are calculated; this process is repeated, often for over 1000 iterations, resulting in many separate estimates of exposure with corresponding probabilities. The results of the iterations may then be analyzed to determine the probabilistic distribution of exposure. The Monte Carlo process is illustrated in Fig. 1 for the soil ingestion pathway, with ingestion rate (IR), exposure frequency (EF), and exposure duration (ED) as input variables. Finally, reasonable maximum exposure estimates corresponding to 90th or 95th percentile exposures can be taken directly from the Monte Carlo probability distribution results. Experience has shown that such 90th-9Sth percentile estimates are generally much lower than those obtained by merely combining individual worst-case exposure assumptions. Monte Carlo techniques are increasingly being used to assess human health risks and to develop cleanup targets at hazardous waste sites.'"-! C. Risk Characterization 1. Risk Calculation After evaluating the hazard of the chemical(s) at the site and estimating the magnitude of potential exposures, it is possible to characterize the level of potential health risks. In general, risks associated with chronic exposures to carcinogens, chronic exposures to noncarcinogens, and acute exposures are evaluated separately to reflect the different conditions of exposure and the different mechanisms of toxicity.Risk Assessment in Remediation of Waste Sites 1s X=IR FOGYZ) Dose y Figure 1 Monte Carlo exposure assessment methodology For chronic exposures to noncarcinogens, risks are characterized by comparing the predicted or actual magnitude of exposure with an exposure level below which no adverse health effects are expected to occur (the ADI). The usual measure of chronic noncancer risk is the hazard index (HI), which is equal to the dose received divided by the ADI. In cases where exposures to more than one chemical are under evaluation, the noncancer HI values for individual chemicals are aggregated to provide an overall HI value. (Technically, an HI is defined as the sum of two or more hazard quotients, or HQs, which are chemical- and exposure route-specific ratios of received dose to the R{D.) In more refined assessments, the method of aggregation may take into account the different mechanisms of toxicity and toxicological endpoints for the chemicals being evaluated. If the overall HI value is less than one, the public health risk is considered to be very low. If the overall HI value is equal to or greater than one, the exposure is considered to be potentially significant and may produce adverse human health effects. While the potential severity of these effects increases as the HI value increases above one, it should be emphasized that, due to uncertainties inherent in the ADI, an HI greater than one does not automatically mean that adverse effects will occur. For chronic exposures to carcinogens, risks are typically represented by the lifetime probability of increased incidence of cancer (lifetime cancer risk, or LCR). This probability is calculated by multiplying the level of exposure by the CSF value of a chemical. If exposures to multiple carcinogens are being evaluated, the risks of individual chemicals usually are added together to calculate the total cancer risk. Since USEPA policy states that any finite exposure to a carcinogen is assumed to pose some level of risk, a judgment must be made as to what constitutes a sufficiently “low” carcinogenic risk. Although such judgment is necessarily subjective, regulatory agencies generally have acted to reduce individual lifetime cancer risks in those cases where they exceed | in 10,000 (107).'? Recent guidance from the USEPA, in fact, states that remediation of Superfund sites is generally unwarranted if cancer risks are less than | x 10°, unless the HI exceeds 1.0 or applicable regulations are violated.'* It must be recognized, however, that a range of risks deemed acceptable appears to exist; for example, the USEPA has indicated a risk range of 10° to 10~ as a “target” risk level for remedial alternatives at Superfund sites.'"!5 Acute risks, due to on-site upsets and accidents or off-site transportation accidents, are16 Washburn et al. characterized by both the consequences and the frequency of the predicted exposure. The consequences of an acute event may be determined by comparison of the expected exposure with exposures having the potential to produce a given adverse effect. The nature of the adverse effect may range from minor irritation to serious irreversible injuries or even fatality. The frequency may sometimes be predicted by statistical analysis of the information from similar facilities: often, however, only qualitative or semiquantitative estimates can be developed. Criteria for judging the significance of potential accidental releases are not usually well defined. For example, an accidental spill scenario with the potential to cause a single fatality may not be considered significant if it has only a 1 in 10 million (107) probability of occurring over the life of the facility. On the other hand, releases that cause minor irritation may be judged unacceptable if they occur frequently. 2. Analysis of Uncertainty Significant limitations and uncertainties can exist throughout the risk assessment process Common sources of uncertainty include Limitations in data regarding the nature and magnitude of emissions into the environment Reliance on animal studies to determine the toxicities of the chemicals in humans Lack of a consideration of pharmacokinetics, or insufficient pharmacokinetic information Extrapolation of chemical toxicity data from observed high-dose conditions to predicted low-dose conditions Lack of knowledge regarding the combined biological effects of multiple toxic chemicals Reliance on mathematical models to calculate chemical concentrations in the environment Uncertainties in contaminant fate and transport, leading to uncertainties in predicting human exposures Both qualitative and quantitative methods have been developed to analyze the uncertainty associated with risk assessment." Qualitative analyses typically involve a discussion of the types of uncertainties, the general effects of each uncertainty, and the impacts of the uncertainties on the conclusions of the risk assessment. A quantitative analysis may be conducted using either (1) a sensitivity analysis or (2) a probability analysis (e.g., a Monte Carlo simulation). A sensitivity analysis tests the effects of variations in each of the assumptions on the results of the risk assessment. The input variables that most affect the results are further analyzed to develop a more complete understanding of the upper-bound (and, less commonly, lower-bound) risks associated with a given chemical exposure Il, RISK ASSESSMENT APPLIED TO HAZARDOUS WASTE SITE REMEDIATION A. Identification of Sites Requiring Cleanup Although any contaminated site can pose some level of risk to human health and the environment, not all sites with contamination require remediation. The need for remediation and the extent of remediation required depend on the chemicals present and their concentrations in the various environmental media, including soil, ground water, surface water, and air. Risk assessment techniques are commonly used to identify those sites that may pose unacceptably high risks to human health and the environment. Typically, the first step in the site remediation process is an initial assessment of potential risks to determine whether or not any portion of the site may require cleanup. Under Superfund and RCRA, this initial assessment is typically referred to as a baseline risk assessment. TheRisk Assessment in Remediation of Waste Sites 7 baseline risk assessment examines the current and future risks posed by a site in the absence of remediation, taking into account expected land use in the area, and usually using assumptions and inputs that are believed to be conservative (i.e., more likely to overestimate rather than underestimate potential human health and environmental risks). The results of a baseline risk assessment are often used as the basis for determining whether remediation should be considered to reduce the risks posed by contamination at a site For carcinogens an excess lifetime cancer risk greater than 1 in | million (10) has traditionally been used as a benchmark for determining whether a site poses potentially significant risks to human populations. The recently revised 1990 NCP! requires that a 10° level be used as a “point of departure” in determining the need for remediation. If risks are below 1 x 10°, a cleanup is rarely, if ever, required. In fact, according to recent guidance from the USEPA, remediation at Superfund sites is generally not warranted unless excess cancer risks exceed 1 in 10 thousand (1 x 10™).'* In evaluating noncancer health effects, the point of departure is usually taken to be a “no-adverse-effect” level, taking into account an appropriate safety factor. If conditions at a site are such that exposures would be expected to produce adverse noncancer effects, i.e., the HI is greater than 1.0, remediation is typically required B. PI ization of Site Areas Requiring Cleanup ‘Complex industrial facility sites often have multiple areas requiring remediation, and each area or aspect requiring remediation presents a different level of hazard to human health and the environment. While some soil contamination may not require immediate attention because it presents no imminent hazard to human health and the environment, leaking drums and contaminated ground water may require immediate interim remedial measures. Drum removal and the provision of an alternate water supply to affected residents are common examples of interim remedial actions. Major factors in determining which areas of a site should receive top priority include current and future potential risks to workers, the off-site community, and the environment, as well as compliance with current and future local, state, and federal regulations. In some cases, issues of special public or regulatory concern may also exist. For example, there may be regulatory or public concerns regarding the possibility of buried drums in a particular area, or areas of contamination that produce off-site odors. The need to address expressed public concerns can also be an important factor in prioritizing site areas for cleanup. Quantitative area-specific risk assessments are generally the preferred method in ranking individual site areas according to potential risk to workers, the off-site community, and the environment. Such assessments, however, typically require large amounts of data or numerous conservative assumptions, and they can be costly to perform. Instead, generic risk-based criteria, or screening criteria, can be compared with available analytical results in the areas of potential concern to establish priority rankings. The soil cleanup levels included in the proposed RCRA Subpart S rule are an example of such screening criteria. '* ‘As an example of this methodology, individual areas of concern might be ranked according to potential current and future risk using the following steps: Any area for which no chemicals are detected above the screening criteria in any media would be assigned a low priority for remediation. A hazard score would be calculated for any area with at least one chemical exceeding the screening criteria for at least one medium by accounting for the number and magnitude of chemical exceedances. Areas would be prioritized according to the overall hazard score The hazard score ranking could be modified to reflect differences between areas in terms of18 Washburn et al. potential for exposure. For example, areas where minimal contact with soil (even at relatively high chemical concentrations) is likely could be moved down in the rankings, while relatively low chemical concentrations in ground water that is a source of drinking water for residents could be more up in the rankings The comparison of site contaminant levels to generic risk-based criteria can be used as a screening methodology to help identify priority areas of concern. For the highest priority areas, it might then be appropriate to perform area-specific risk assessments as a first step in developing specific remedial approaches. Another important consideration in the prioritization of site areas for remediation might be an evaluation of relationships between the areas. For example, some important relationships between site areas might involve physical proximity, the nature and extent of contamination, current and future use, the potential for recontamination, and the potential for use of similar remedial technologies. An identification of common elements among site areas is useful in aggregating areas to simplify the overall site remediation process, and this can possibly reduce total remediation cos C. Development of Target Cleanup Levels ‘The first step in remediating an area of a site usually consists of specifying target cleanup levels that represent an “acceptable” level of residual concentrations in the affected environmental media. Cleanup levels may be established by Relying on environmental quality standards from applicable or relevant statutes, such as maximum contaminant levels (MCLs) in drinking water Setting levels equal to local background concentrations or analytical detection limits Using risk assessment methods to determine concentrations that are protective of human health and the environment Risk-based cleanup levels are usually developed using the basic methodologies and assumptions applied in the baseline risk assessment, Often, cleanup levels are “back-calculated” to correspond to an overall risk goal for a site. This is achieved by setting chemical-specific cleanup levels equal to chemical concentrations believed to have no adverse effect on human health or the environment, and which pose an “acceptable” or “insignificant” cancer risk. There are several advantages to a risk-based approach for establishing cleanup target levels. First, risk assessment provides a scientifically defensible and increasingly standardized method for establishing cleanup levels that are protective of human health and the environment. In contrast, the use of standards from relevant statutes may yield cleanup levels that are either not sufficiently protective, or are overly stringent and wasteful of limited resources. While the uncertainties of the risk assessment process can be considerable, it provides a rational basis for setting consistent cleanup goals. Furthermore, the risk assessment approach permits the establishment of target cleanup levels appropriate to the actual current or anticipated future use of a site. A site that is expected to remain in industrial use and is located in a heavily industrial area need not be cleaned to the stringent levels appropriate for a residential area. Such distinctions allow for available resources to focus on conditions posing the greatest public health risk. In developing risk-based cleanup levels, appropriate concepts of areal and temporal averaging can often be incorporated. As exposure to soils over a period of time would be expected to occur over an area rather than at one particular point location, it would be appropriate to expect cleanup levels to be met over an exposure area, rather than at every point in the area. Similarly for ground water, because exposure would occur through a well and a well drawsRisk Assessment in Remediation of Waste Sites 19 ground water from an area rather than a single point in an aquifer, it would be appropriate to meet ground water cleanup levels over the well’s recharge area rather than at each point in the aquifer. ‘A metals refinery and manufacturing facility located in a heavily industrial area of Newark, New Jersey, serves as a case example. At this site, risk assessment approaches were applied to derive health-based soil cleanup levels as alternatives to the informal cleanup guidelines established under the New Jersey Environmental Cleanup Responsibility Act (ECRA). Strict adherence to the ECRA guidelines would have required an extensive remediation, resulting in major cleanup costs as well as problems with disposal of a large volume of soil. The cleanup criteria ultimately developed using risk assessment methods resulted in a more than $10 million reduction in cleanup costs, as compared with those associated with the direct application of ECRA cleanup guidelines. D. Evaluation of Remedial Alternatives The process of remedy selection offers further applications of risk assessment techniques. In this section, decision tree analysis and the importance of a full consideration of the risks associated with remedy implementation are discussed. Decision tree analysis provides a formal structure for decision making that accounts for inherent uncertainty and risk, Remedy implementation risks often receive little attention in the evaluation of remedies by the USEPA, but in some cases they may outweigh the traditionally emphasized risks. The use of decision trees and a full consideration of potential risks aid in the evaluation of remedial alternatives and the selection of a cost-effective remedy that is fully protective of human health and the environment. 1. Decision Tree Analysis The appropriate remedy for a particular site can range from “no action required” to complete removal of contaminated materials with off-site treatment and disposal. Selecting the most appropriate remedy involves the consideration and balancing of a number of important factors, including long-term effectiveness, short-term effectiveness, implementability, cost, and reduc- tion of toxicity, mobility, or volume through treatment. Usually, however, uncertainty exists about some or all of these factors. For example, there may be considerable uncertainty over which technologies will be effective, their levels of effectiveness, and their costs. Further, the level of cleanup that will be required by the appropriate regulatory agency is often unknown when evaluating remedial alternatives. Decision tree analysis provides a formal structure that enables a consideration of all factors and uncertainties. A decision tree graphically represents the decisions that must be made, alternative events that may occur, the probabilities of their occurrence, and the costs associated with various steps in the remedial process. Through formulating the remedy selection process as a decision tree, the decision maker is able to outline all possible options and all possible outcomes of each option, and to develop the necessary data to estimate probabilities and calculate payoffs. Consider a case in which both incineration and bioremediation are being evaluated as remedial alternatives for contaminated soils. A proven technology such as incineration has been shown to reduce the toxicity and volume of contaminated soil, whereas innovative technologies such as bioremediation are more experimental and pose a greater risk of failure. The costs of incineration, however, are potentially much greater than for bioremediation, and incineration remedies are often opposed by the local community. Decision tree analysis is especially helpful in this situation, where potential cost savings must be weighed against the possibility of failure20 Washburn et al. and the lower likelihood of agency acceptance of innovative technologies. Using. decision analysis, these risks can be explicitly and quantitatively evaluated as part of the decision-making process 2. Remedy Implementation Risks The risks potentially posed by the implementation of alternative remedies for a site should be evaluated when considering the short-term effectiveness criterion. The risks created by remedy implementation at a site may include exposures to toxic chemicals, accidents associated with use of heavy equipment, heat stress caused by impermeable protective coveralls and use of respirators, and accidents or spills during off-site transportation of hazardous materials. The populations potentially at risk during implementation include on-site workers during site investigation and cleanup; off-site residents and workers in nearby areas; and crops, livestock, and wildlife in the vicinity of the site. In some cases. implementation risks may exceed the long-term risks associated with a no-action remedy. Recent revisions to the NCP and the proposed RCRA Subpart S regulations both require a consideration of implementation risks in remedy selection at hazardous waste sites. USEPA guidance explicitly states that “alternatives should be evaluated with respect to their effects on human health and the environment during implementation of the remedial action.” The evaluation should include “any risk that results from implementation of the proposed remedial action such as dust from excavation . . . that may affect human health . . . [and] threats that may be posed to workers.” !!7 Failure to adequately evaluate implementation risks during the remedy selection process can result in unanticipated chemical exposures for workers and nearby residents during cleanup. or in costly delays or abandonment of an incomplete remedy. For example. at a Superfund site in Baton Rouge, Louisiana, excavation of soil containing a variety of volatile organic compounds (VOCS) was abandoned because the associated release of vapors was deemed unacceptable. At a Superfund site in Denver, Colorado, poor air quality during cleanup forced workers to evacuate the site at least once. Nearby residents complained frequently of astringent fumes Despite the clear intent of the NCP and the potential importance of remedy implementation risks, many assessments address the risks created by site cleanups only qualitatively, if at all. Implementation risk assessments are beginning to figure more prominently in remedy selection, however. At the Tyson's Lagoon Superfund site in Pennsylvania, the USEPA reevaluated its initial Record of Decision (ROD), which specified excavation of contaminated materials. Due in part to the public health risks created by excavation, the USEPA issued a revised ROD, which selected a nonintrusive remedy, in situ vacuum extraction. "6 At the Hardage Superfund site in Oklahoma, an evaluation of potential on-site worker and off-site community health risks during remediation weighed heavily in a judge's decision to overturn a USEPA ROD based on excavation in favor of a more nonintrusive containment remedy.” Implementation risks were also cited as a critical factor by the USEPA in selecting a nonintrusive remedy at the MeColl Superfund site in California.” E. Conclusion Risk assessment is playing an increasingly important role in the remediation of hazardous waste sites and complex industrial facilities. Figure 2 schematically summarizes the use of risk assessment in the remedial process, from the baseline risk assessment utilized in site characterization to the evaluation during the FS of remedy implementation and postremediation risks, Both federal and state regulations call for the use of risk assessment techniques to help in identifying and prioritizing sites requiring remediation, developing remedial objectives and