An Evaluation of the Role of Risk-Based Decision-Making in a Former Manufactured Gas Plant Site Remediation

Abstract

Environmental remediation decisions are driven by the need to minimize human health and ecological risks posed by environmental releases. The Risk Assessment Guidance for Superfund Sites enunciates the principles of exposure and risk assessment that are to be used for reaching remediation decisions for sites under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Experience with remediation management under CERCLA has led to recognition of some crucial infirmities in the processes for managing remediation: cleanup management policies are ad hoc in character, mandates and practices are strongly conservative, and contaminant risk management occurs in an artificially narrow context. The purpose of this case study is to show how a policy of risk-based decision-making was used to avoid customary pitfalls in site remediation. This case study describes the risk-based decision-making process in a remedial action program at a former manufactured gas plant site that successfully achieved timely and effective cleanup. The remediation process operated outside the confines of the CERCLA process under an administrative consent order between the utility and the New Jersey Department of Environmental Protection. A residential use end state was negotiated as part of this agreement. The attendant uncertainties, complications, and unexpected contingencies were overcome by using the likely exposures associated with the desired end state to structure all of the remediation management decisions and by collecting site-specific information from the very outset to obtain a detailed and realistic characterization of human health risks that needed to be mitigated. The lessons from this case study are generalizable to more complicated remediation cases, when supported by correspondingly sophisticated technical approaches.