Steve Cook provided insight to a standing room of attendees at the PA Brownfield Conference on the issues that are important for EPA to tackle. Adaptive management, groundwater restoration and risk communication were center stage on that agenda. While the issues are not unique to brownfields remediation and reuse, they certainly impact them directly.
Adaptive Management is a formal and systematic project management approach centered on rigorous site planning and a firm understanding of site conditions and uncertainties. This technique encourages continuous reevaluation and management prioritization of activities to account for new information and changing site conditions. In action, adaptive management could result in EPA’s increased use of removal actions to significantly reduce existing exposures at a site, interim remedial actions and phased action based on operable units.
EPA acknowledged that the state regulations on how clean is clean when addressing groundwater, varies greatly in each state. Greater coordination with the states is necessary in establishing the appropriate groundwater cleanup standards for sites. This will only get more complex as states advance their work in risk exposure for emerging contaminants.
And lastly, everyone is familiar with at least one site in which an Institutional Control (IC) was used as part of an approved remedy. As the years pass, work is needed to ensure that the existence of an IC at a site continues to be recognized and complied with by subsequent owners/operators of a site. This is great insight into a future problem that we all hope never comes to fruition.