What Is An Exit Strategy

Transcription

1 What Is An Exit Strategy How A Well Defined Exit Strategy Closes Sites Joann Socash Dave Hofmann May 10, 2011

2 Overview Definition of an Exit Strategy Purpose of an Exit Strategy Elements of an Exit Strategy Examples of a Well Defined Exit Strategy Exit Strategies and Decision Documents Summary 2

3 Definition of an Exit Strategy An executable plan to effectively and efficiently complete all environmental actions necessary to achieve site closure with regulator approval The plan must include specific contingency actions to address unexpected circumstances 3

4 Purpose of an Exit Strategy To implement a clearly-defined and achievable plan to ultimately obtain site closure Efficient Effective To help reduce and effectively manage environmental response liabilities 4

5 Elements of an Exit Strategy A conceptual site model (CSM) of sufficient accuracy and detail to allow effective decision making Risk or problem statement summarizing the technical, remedial, legal and regulatory basis for the cleanup goals and actions Decision logic and associated timeframe to achieve and document site closure Poor little guy didn t think it through! 5

6 Elements of an Exit Strategy (Concluded) Remedial action objectives and cleanup goals Milestones on the way to response complete, no further action or site closure Contingency plan associated with the decision logic 6

7 Conceptual Site Model (CSM) CSM represents best current understanding of contaminants and site conditions Sources and pathways of contaminants Fate and effect of contaminants Potential receptors 7

8 CSM (concluded) CSM is the foundation for technical, regulatory and public understanding of remedial alternatives and cleanup goals 8

9 A brief description of risk and/or problem using the CSM for support Example : Risk or Problem Statement The concentration of arsenic in soil at Site 17 does not meet human health federal regulatory guidelines and there is a need to prevent exposure. Chlorinated solvents in a groundwater plume exceed drinking water standards and drinking water wells located downgradient are at risk. 9

10 Decision Logic Describe the decision points at which management actions are required to maintain protection of human health and the environment and achieve ultimate goal of no further action, response complete or site closure Decision logic should include use of appropriate elements of the exit strategy such as the CSM and contingency plan 10

11 Remedial Action Objectives (RAOs) and Cleanup Goals RAOs are brief statements of desired conditions not yet achieved based on the CSM Cleanup goals should: Protect human health and the environment Be practical, timely, and cost effective Measureable and lasting Drive remedy selection 11

12 Milestones Milestones should define reasonable and achievable events that will be used to document progress toward the ultimate goal of site closure Example: Achieve mean concentrations of <200 µg/l with air sparging, install fence and signage around Parcel 3 and confirm consistently protective mean concentrations with one year quarterly sampling, finally close site with regulatory concurrence. 12

13 Contingency Plan Identify alternative actions to protect human health and the environment in the event remedial performance objectives are not met Include key decision criteria to trigger contingency Contingencies can be developed for many portions of the exit strategy to ensure the exit strategy is dynamic and can meet unforeseen circumstances 13

14 Exit Strategy Template 14

15 Example of Well Defined Exit Strategy 15

16 Exit Strategies and Decision Documents Exit strategies are useful as part of any decision document such as a record of decision, statement of basis or memorandum of agreement Incorporating exit strategies into decision documents strengthens and clarifies the strategy for all stakeholders 16

17 Summary Exit Strategies: Executable plan to ultimately achieve environmental site closure Help reduce and manage environmental response liabilities Elements of an Exit Strategy include: CSM, risk problem statement, decision logic, RAO and cleanup goals, milestones and contingency plans 17

18 Comments and Questions 18