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Use of a Net Environmental Benefit Analysis (NEBA) Framework in Site Remediation. Joseph Nicolette Vice President, CH2MHILL Practice Director For Natural Resource Liability and Asset Management June 30, 2005. - PowerPoint PPT Presentation
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1
Use of a Net Environmental Benefit Analysis (NEBA) Framework in
Site Remediation
Joseph NicoletteVice President, CH2MHILL
Practice Director For Natural Resource Liability and Asset Management June 30, 2005
2
Convergence of Thinking A Coordinated Approach to Assessment,
Remediation and Restoration
Remedial InvestigationHealth/Eco Risk Assessment
EE/CA, FS (NEBA)ROD
Remedial ActionO&M
Natural Resource Injury
Overall Goals•Minimize NRI through remedial strategy
•Manage short and long-term risks •Reduce time to resolution (transaction costs)
•Reduce study costs, improve design (e.g., eco-risk)
Parallel TrackCleanup NRI
3
Background Natural Resource Damage Assessment
(NRDA) regulatory process: OPA/CERCLA Natural resource restoration-based
compensation process Process to compensate for injuries to natural
resourcesNeeded to understand/quantify injury and restoration
value Natural resources identified as providing a
variety of services
4
Habitat
Services“The functions a natural resource provide for other resources and for humans”.
Direct Human Uses (e.g., Recreational, Commercial)
Bird watchingFishingSwimmingHuntingCommercial Fishing
Existence valueAesthetic valuePreservation of diversityT&E species
Passive Use
Ecological
Nesting Area for BirdsBreeding Area for FishSediment StabilizationWater Quality EnhancementMany Others
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% o
f S
ervi
ces
Years
Area B - Services Gained (Credit)
B
Quantifying Natural Resource Changes:
Natural Resources Are Like Assets That Pay In Service Units Instead of Dollars
Area A - Services Lost (Debit)
A
Contaminant Release
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Comparing Environmental Values(Cost Benefit Analysis of Project Alternatives)
% S
erv
ice
s
Years
Baseline Services
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Comparing Environmental Values(Cost Benefit Analysis of Project Alternatives)
% S
erv
ice
s
Years
Baseline Services
B1
8
Comparing Environmental Values(Cost Benefit Analysis of Project Alternatives)
% S
erv
ice
s
Years
Baseline Services
B2B1
9
Comparing Environmental Values(Cost Benefit Analysis of Project Alternatives)
% S
erv
ice
s
Years
Baseline Services
B3B2
B1
Areas B1, B2 & B3 - Service Values Associated With Project Alternatives
• Develop $/credit• Fiscal merit• Conservation/natural resource benefits
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Table 1. Overall Framework for Evaluation of NEBA Project Alternatives (allows for comparison of project alternatives).
A NEBA Example
Project Alternatives
Ecological Services (dSAYs)
Human Use Value (User-Days
and $)Cost ($)
Cost/Eco dSAY
Cost/Human Use $
Project A 20,000 $4,000,000 $1,000,000 $50 $0.25
Project B 10,000 $3,000,000 $1,000,000 $100 $0.33
Project C 20,000 $25,000,000 $1,000,000 $50 $0.04
Project D 2,000 $1,000,000 $1,000,000 $500 $1.00
Scenario #1
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Alternative Comparisons Using NEBA
Remedial Actions NEPA Alternatives Land Management Actions Land Re-Use Designs (e.g., Brownfield,
greenspace designs) Restoration, Recreational Area Designs (e.g., eco-
tourism) Any actions that affect natural resource service
values (ecological and human use)
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NEBA In The Context of Site Remediation
Analytical framework to compare natural resource benefits of various remedial actions versus natural resource costs
Using formally quantified values Assist with risk management decisions
Goals: assist in remedy selection to: avoid creating natural resource injury (NRI) and; encourage the selection of remedial options that offer the
greatest benefit to the environment and public.
Considers both cleanup and natural resource issues
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NEBA Consistent With “EPA’s Ecological Benefits Assessment Strategic Plan”
Draft September 30, 2003 EPA document Goals:
advance EPA's ability to identify, measure, value and communicate the ecological benefits of its actions in order to improve the integrity of decision-making.
Consider net ecological benefits of an EPA action including any negative, as well as positive changes in ecological services
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Risk and Injury Issues Driver of clean-up is typically concentration
driven: Injury and/or benefits to natural resource service value
associated with remedies are rarely formally quantified
Risk assessments can be overly conservative Uncertainty NEBA provides collaborative framework to
address these issues
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Marginal Risks/Uncertainty
Cleanup to Criterion (Cost/Benefit)
Effort/Cost ($)
Co
nce
ntr
atio
n/R
isk
Criterion Level
HQ=1
High Risk Areas
Risk Management DecisionsAllows For Offsetting Restoration
HQ=1(using less conservative assumptions)
Lower % Higher %
Larger Reduction in Risk
Smaller Reduction in Risk
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No Action Surface Sweep Surface Clearance Clearance 2 Feet Clearance 4 Feet
40
30
20
10
0
Rem
edial C
ost($ m
illions)
ALTERNATIVE
Conceptual NEBA Results: Comparison of remedial costs for each remedial alternative evaluated.
N o Action Hot Spot Removal Soil Cover Complete Removal Other
16
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No Action Surface Sweep Surface Clearance Clearance 2 Feet Clearance 4 Feet
40
30
20
10
0
Rem
edial C
ost($ m
illions)
Con
cen
trat
ion
/Ris
k
ALTERNATIVE
Conceptual NEBA Results: Comparison of remedial costs and risk profile changes for each remedial alternative evaluated.
N o Action Hot Spot Removal Soil Cover Complete Removal Other
17
18
No Action Surface Sweep Surface Clearance Clearance 2 Feet Clearance 4 Feet
0
5,000
10,000
15,000
20,000
40
30
20
10
0
Net
Eco
logi
cal S
ervi
ce L
oss
(d
SA
Ys)
Rem
edial C
ost($ m
illions)
Con
cen
trat
ion
/Ris
k
ALTERNATIVE
Conceptual NEBA Results: Comparison of remedial costs to risk profile, and ecological service changes for each remedial
alternative evaluated.
N o Action Hot Spot Removal Soil Cover Complete Removal Other
18
19
No Action Surface Sweep Surface Clearance Clearance 2 Feet Clearance 4 Feet
0
5,000
10,000
15,000
20,000
40
30
20
10
00
10
20
30
40Net
Eco
logi
cal S
ervi
ce L
oss
(d
SA
Ys)
Rem
edial C
ost($ m
illions)
Con
cen
trat
ion
/Ris
k
Net H
um
an U
se Valu
e Loss
($ million
s)
ALTERNATIVE
Conceptual NEBA Results: Comparison of remedial costs to risk profile, ecological service and human use value changes for each
remedial alternative evaluated.
MNA Hot Spot Removal Soil Cover Complete Removal Other
19
Is There a Break-Point?
20
NEBA Consistent With Risk Management Objectives
EPA Superfund ERA Guidance (Step 8) “The risk manager must balance (1) residual risks posed by site
contaminants before and after implementation of the selected remedy with (2) the potential impacts of the selected remedy on the environment independent of contaminant effects.”
“In instances where substantial ecological impact will result from the remedy (e.g., dredging a wetland), the risk manager will need to consider ways to mitigate the impact of the remedy and compare mitigated impacts to the threats posed by the site contamination.”
NEBA provides potential framework to help comply with this guidance
21
Why and When NEBA? Balance of risks and benefits of remediation is
ambiguous site retains significant ecological value remediation causes environmental damage
Example: Prince William Sound ecological risks are small, uncertain, or limited remediation or restoration may fail or not truly change
risk scenario costs appear disproportionate to changes in the risk
scenario
No unacceptable human health risks
22
Value of the NEBA Approach Provides information for management decisions
using technical, scientific, and credible tools Uses quantifiable metrics providing a basis for decisions
e.g., layer of protection from third party-suits
Shows benefits to the public and demonstrates environmental sustainability/stewardship
Framework may result in : better environmental management and greater
environmental improvement at lower costs
Methodologies are consistent with policy and direction of natural resource agencies
23
“A Framework for Net Environmental Benefit Analysis For Remediation or Restoration of Contaminated Sites”
Rebecca A. EfroymsonOak Ridge National Laboratory
Joseph P. NicoletteCH2M HILL
Glenn W. Suter IIUSEPA National Center for Environmental Assessment
Published, Environmental Management, August 2004
24
Prior EPA Region 4 Presentation Provided overview to Jimmy Palmer (Regional
Administrator, Region IV) and Staff (October 2004, Feb 2005).
Comments The benefits of the NEBA approach appear consistent
with the policy and direction of the agency Is useful and most beneficial when done in a collaborative
and cooperative process Overall, this is a useful tool in remedial decision-making
process A new approach for the region, which may set a precedent
and may have far reaching implications
25
EPA HQ Meetings
Office of Solid Waste and Emergency Response (OSWER)/Policy Analysis and Regulatory Management
EPA is looking at NEBA as a possible method to demonstrate the value of Superfund Program
Currently discussing regional pilot studies with HQ EPA
26
Collaboration
Co-Chairing Panels/Sessions with EPA re NEBA and resource metrics at:
Wildlife Habitat Council Conference on Brownfields (EPA Region 6): May 2005
National Brownfields Conference: Denver, Nov 2005
SETAC, Baltimore, Nov 2005
27
Current DoD NEBA Projects
Army BRAC HQ: Fort McClellan, AL; Fort Ord, CA; Camp Bonneville, WA; Savanna Army Depot, IL
Edwards AFB, CA. OU Specific NEBA’s in proposed collaborative process.
Tyndall AFB. Integrating NEBA in collaboration with agencies
Navy, New Gosport
28
A Shift in Thinking: Natural Resource Service Values
CERCLA Exxon Valdez NRDA Regs Today
$$
1980 1989 1996 2005
Evolution of Thinking Application