Strategic Planning for Contaminated Sediment Projects:

Setting the Course for Proper Project Execution

Howard L. CumberlandGeosyntec 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

PhysicalBiological

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