Use of a Net Environmental Benefit Analysis (NEBA) Framework in Site Remediation

1. 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

2. Convergence of Thinking A Coordinated Approach to Assessment, Remediation and Restoration Cleanup NRI Parallel Track Remedial Investigation Health/Eco Risk Assessment EE/CA, FS (NEBA) ROD Remedial Action O&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)

3. Background • Natural Resource Damage Assessment (NRDA) regulatory process: OPA/CERCLA • Natural resource restoration-based compensation process • Process to compensate for injuries to natural resources • Needed to understand/quantify injury and restoration value • Natural resources identified as providing a variety of services

4. Nesting Area for Birds Breeding Area for Fish Sediment Stabilization Water Quality Enhancement Many Others Ecological Direct Human Uses (e.g., Recreational, Commercial) Bird watching Fishing Swimming Hunting Commercial Fishing Passive Use Existence value Aesthetic value Preservation of diversity T&E species Services “The functions a natural resource provide for other resources and for humans”. Habitat

5. Area B - Services Gained(Credit) B A Area A - Services Lost (Debit) Quantifying Natural Resource Changes: % of Services Natural Resources Are Like Assets That Pay In Service Units Instead of Dollars Contaminant Release Years

6. Comparing Environmental Values(Cost Benefit Analysis of Project Alternatives) % Services Baseline Services Years

7. Comparing Environmental Values(Cost Benefit Analysis of Project Alternatives) B1 % Services Baseline Services Years

8. Comparing Environmental Values(Cost Benefit Analysis of Project Alternatives) B1 B2 % Services Baseline Services Years

9. Comparing Environmental Values(Cost Benefit Analysis of Project Alternatives) Areas B1, B2 & B3 - Service Values Associated With Project Alternatives Net Environmental Benefit Analysis (NEBA) B1 B2 B3 % Services Baseline Services • Develop $/credit • Fiscal merit • Conservation/natural resource benefits Years

10. Table 1. Overall Framework for Evaluation of NEBA Project Alternatives (allows for comparison of project alternatives).A NEBA Example

11. 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)

12. 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

13. 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

14. 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

15. Criterion Level HQ=1 (using less conservative assumptions) Larger Reduction in Risk High Risk Areas Smaller Reduction in Risk Marginal Risks/ Uncertainty HQ=1 Lower % Higher % Cleanup to Criterion (Cost/Benefit) Concentration/Risk Effort/Cost ($) Risk Management Decisions Allows For Offsetting Restoration

16. 16 Conceptual NEBA Results: Comparison of remedial costs for each remedial alternative evaluated. 40 30 20 10 0 Remedial Cost ($ millions) No Action Surface Sweep Surface Clearance Clearance 2 Feet Clearance 4 Feet ALTERNATIVE N o Action Hot Spot Removal Soil Cover Complete Removal Other

17. 17 Conceptual NEBA Results: Comparison of remedial costs and risk profile changes for each remedial alternative evaluated. 40 30 20 10 0 Remedial Cost ($ millions) Concentration/Risk No Action Surface Sweep Surface Clearance Clearance 2 Feet Clearance 4 Feet ALTERNATIVE N o Action Hot Spot Removal Soil Cover Complete Removal Other

18. 18 Conceptual NEBA Results: Comparison of remedial costs to risk profile, and ecological service changes for each remedial alternative evaluated. 0 5,000 10,000 15,000 20,000 40 30 20 10 0 Remedial Cost ($ millions) Concentration/Risk No Action Surface Sweep Surface Clearance Clearance 2 Feet Clearance 4 Feet ALTERNATIVE N o Action Hot Spot Removal Soil Cover Complete Removal Other Net Ecological Service Loss (dSAYs)

19. 19 Conceptual NEBA Results: Comparison of remedial costs to risk profile, ecological service and human use value changes for each remedial alternative evaluated. 0 5,000 10,000 15,000 20,000 40 30 20 10 0 0 10 20 30 40 Remedial Cost ($ millions) Concentration/Risk No Action Surface Sweep Surface Clearance Clearance 2 Feet Clearance 4 Feet ALTERNATIVE MNA Hot Spot Removal Soil Cover Complete Removal Other Net Human Use Value Loss ($ millions) Net Ecological Service Loss (dSAYs) 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. Efroymson Oak Ridge National Laboratory Joseph P. Nicolette CH2M HILL Glenn W. Suter II USEPA 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 1980 1989 1996 2005 CERCLA Exxon Valdez NRDA Regs Today $ $ Evolution of Thinking Application