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[co-author: Jeff Bolin - Vice President of Abstruse Operations The Dragun Corporation]
This commodity was ahead appear in the Michigan Defense Quarterly (Vol. 31 No. 2, October 2014), a advertisement of the Michigan Defense Trial Admonition (MDTC). It is reprinted actuality with permission.
Executive SummaryWhen adverse the abeyant of spending ample sums of money on remediation, authoritative enforcement, or action due to a actinic absolution to the environment, you charge be able to booty the calm advice and abstracts and acquaint a abstruse adventure that is clear, concise, persuasive, and memorable. One way to do that is by developing a Conceptual Armpit Archetypal that generates a acute adventure from abstracts and advice aggregate from and about the site. This commodity outlines the action of creating aloof such a model.
“After a presentation, 63 percent of attendees bethink stories. Alone 5 percent bethink statistics.” (Source, Best Selling authors, Dent and Dan Heath). A account is account a thousand words, and, back you get bottomward to it, what is action or authoritative acceding for your client? ... Dare we say it’s a presentation of a story? And, it bigger be an accurate, and alike a compelling, story.
When your applicant is adverse the abeyant of spending ample sums of money on remediation, authoritative enforcement, or action due to a actinic absolution to the environment, you charge be able to booty the calm advice and abstracts and acquaint a story. Not aloof a story, but a ablaze and acceptable story. In fact, this adventure needs to be authentic and defensible, and it needs to be authentic by all that abstracts and minutia of advice that, if presented improperly, will acceptable be forgotten. The accuracy is, the best advice and abstracts may abutment you, but it will abatement on deafened aeriform if you abort to acquaint a acute story.
So how do we acquaint a abstruse adventure that is clear, concise, actuating ... and memorable? By developing a Conceptual Armpit Archetypal (CSM). A CSM is like a paint-by-numbers game, but the numbers that accomplish the account appear from abstracts and advice aggregate from and about the site. Decisions apropos remediation, risk, litigation, etc., are not fabricated based on a abounding compassionate of the complete subsurface conditions; decisions are fabricated based on the CSM; that is, it is based on the assuming of that bound advice into a fuller account of what is in the subsurface.
What Is a CSM?
A Conceptual Armpit Archetypal is an affiliation of aggregate we apperceive about a armpit including (1) armpit history, (2) hydrogeologic information, (3) actinic absolution antecedent and timing, (4) concrete and actinic backdrop of the release, (5) contaminant fate and transport, (6) administration of chemicals, and (7) risks, acknowledgment pathways, and receptors. It is ultimately a multi-dimensional account that tells the adventure about the site. “Just gather” all of this advice and ... Presto! It sounds easy, but ... .
There are abundant advice abstracts that altercate alertness of CSMs, including ASTM, Interstate Technology Authoritative Council (ITRC), U.S. Ecology Protection Bureau (USEPA), U.S. Army Corps of Engineers (USACE), and abounding accompaniment authoritative agencies. However, alive the basal accomplish from the advice abstracts alone gets you the pieces to the CSM and the story. It does not acquaint the story. Alone back the pieces are integrated, prioritized, and corroborated does the adventure booty shape. The botheration is that we never accept complete information, and, frequently, there has been no integration, or there has been poor integration, of the accessible information. Complicating it added is that appliance of the advice abstracts to a armpit are generally accountable to acknowledged interpretations based aloft authoritative programs and case law.
Building an authentic CSM is a authentic action of amalgam abstracts and abstruse and acknowledged advice about a site. It has a cardinal of accomplish that can be burst bottomward into (1) the Basic CSM, (2) the Revised CSM, and (3) the Able-bodied CSM. The development of the CSM through this action will actuate aloof how able-bodied your adventure is told. That is, are there “multiple curve of evidence” that acrylic a constant account and acquaint the complete and authentic story?
The Basic CSM
The complete aboriginal footfall to the Basic CSM is developing a armpit history. The Basic CSM is the antecedent affiliation of accessible advice about the site. It may, or may not, accommodate any (or minimal) site-specific abstracts apropos the subsurface conditions. The Basic CSM is about comprised of advice such as advertence literature, accessible records, air photos, and interviews with bodies accustomed with the site.
Why is compassionate your armpit history so critical? It is analytical because you appetite to apperceive if it’s your adventure to tell. Companies accept paid bags to millions of dollars to apple-pie up addition else’s ecology contagion because of an inaccurate adventure based on a ailing – constructed, Basic CSM.
You charge to body an authentic armpit history adventure about your acreage and the backdrop surrounding your property. This needs to be based on, and embodied by, available, relevant, absolute abstracts gleaned from all accessible sources.
What blazon of advice should you gather? Aloof about aggregate and annihilation that you can analytic get your easily on and that can be substantiated. This footfall can be compared to administering a “quasi” Phase I Ecology Armpit Assessment (ESA) as if you were purchasing property. You appetite to accept the “who, what, when, where, and how” of the acreage about to actinic use, administration and disposal.
Typical advice sources accommodate actual adventure reports, discharge reports, ecology assay reports, above-mentioned administration history and action apropos the site, discharge acknowledgment plans, purchasing annal (chemicals used), aeriform photographs, burghal directories, blaze allowance maps, interviews with abiding advisers or retirees, above owners or operators, database searches (e.g., EDR), a armpit assay of the armpit and abutting backdrop (with owner’s permission), and Freedom of Advice Act (FOIA) requests to the USEPA, accompaniment authoritative office, and borough offices. And in today’s world, consistently “Google that.”
The basic CSM builds the framework of the site. At this stage, you can usually activate to accept (1) what chemicals were acclimated on your property, area they were acclimated on your property, and their use and accumulator on adjoining properties; (2) back these chemicals were used; (3) what ability appear to chemicals that are appear at the armpit or adjoining property; and (4) how they ability drift in the environment. But you charge to be alert not to abject too abundant alone on this framework. As with any acceptable story, the artifice may accept abounding twists and turns. Relying on a CSM too bound after acknowledging the adventure with added advice can be a pitfall back it comes to remediation, negotiations with authoritative agencies, or litigation. It can advance to a “bad experience” in court, spending money absurdly on a poorly-designed antidote or on a poorly-crafted authoritative adjustment or agreement.
This leads to the abutting footfall in the process; the Revised CSM. It should be acclaimed that there is no abracadabra ablaze band that defines the Basic CSM from a Revised CSM. It all depends aloft the bulk of advice in duke and how able-bodied that advice tells the story. That is, do the abstracts from altered sources abide to body and acquaint the aforementioned adventure like capacity in a book?
Revised Conceptual Armpit Model
The basic CSM has provided a framework and a ashen outline of the account and a glimpse of the artifice of the story. To “fill in” the framework, you charge to attending for acceptance evidence. With armpit history in hand, the questions become added focused and refined. The questions become added specific about the site. For our story, these questions are answered by establishing the (1) geologic framework, (2) groundwater flow, (3) adobe and groundwater chemistry, and (4) contaminant carriage processes.
Developing a account of the geologic framework is a analytical basic to compassionate the abeyant movement and clearing of a actinic release. You charge to actuate what the apparent and subsurface altitude of the armpit are and how those altitude admission actinic migration. Are the apparent and subsurface altitude natural, man-made, or both?
The apparent appearance of a armpit will absolute and authorize a alleyway for a actinic release. You appetite to actuate items such as apparent topography, the attendance of paved surfaces and their condition, the attendance of ditches, swales, storm baptize bolt basins, barter wells, and assimilation ponds. Additionally, the attendance of adjacent apparent baptize bodies (lakes, streams, rivers, wetlands, etc.) will accommodate acumen as to apparent baptize flow, groundwater flow, and receptors.
With account to subsurface conditions, you charge to actuate if the cartography is acceptable sand, silt, clay, or bedrock, as actinic movement is afflicted abnormally by each. Underground utilities and corridors (sewers, catchbasin curve and fields, electrical lines, baptize lines, and wells, etc.) at a armpit can accept a cogent appulse on the clearing of a actinic release.
Information apropos apparent and subsurface altitude can be acquired through abundant sources, such as online geological database information, USGS topographic maps, geological maps, geological assay reports, USDA adobe surveys, geotechnical letters from architecture construction, and account maps from municipalities. Accomplished authoritative information, administration actions, or action apropos the acreage can be cogent as well.
As you admission this information, you abide to body the CSM by accumulation the accustomed and manmade appearance and creating a geological database. Note that, at this point, the CSM is based alone on abstracts and advice acquired from absolute sources. We accept not yet avant-garde a adobe arid or installed a ecology well. That is not to say that some subsurface advice from adobe borings or ecology wells does not abide from antecedent armpit investigations.
As we body the CSM and accommodate the abstracts that may accept been generated for the site, we charge be analytical of the data. For example, are there any accessible mistakes in the antecedent interpretations of the data? Are there added areas that charge to be investigated? Is there advice missing (non-continuous logging of soil, no grain-size analysis, borings not abysmal enough, etc.)? The answers to these questions advice us analyze abstracts gaps and advance a assignment plan.
Using the CSM to analyze the abstracts gaps, you can clothier a assignment plan to admission the “missing” abstracts and advice through focused assay (the focused assay additionally is afflicted by acknowledgment pathways that charge to be addressed/evaluated – see below). This can accommodate both advancing and non-intrusive methods of investigation. Non-intrusive methods accommodate geophysics, such as ground-penetrating alarm (GPR), magnetometer surveys, electromagnetic (EM) surveys, etc.
Intrusive methods accommodate conduct and sampling the subsurface adobe and groundwater. At this point, the areas of assay and adjustment of adobe borings should be adequately defined. Accordingly, the assay should be focused to accumulate abstracts to actualize a added able-bodied CSM.
Drilling at a armpit is actual abased aloft the characteristics of the site. The Revised CSM should be a adviser to chief the best conduct techniques back you should accept an compassionate of cartography (i.e., sand, silt, clay, bedrock), abyss to groundwater (e.g., adviser able-bodied awning placement), types of chemicals of absorption (e.g., soluble, LNAPLs, DNAPLs), abyss of conduct appropriate (e.g., circumscribed layers, bedrock, etc.), and armpit admission constraints (e.g., utilities, central a building). Anniversary of these armpit characteristics may crave a altered conduct abode which can accommodate direct-push technology (e.g., GeoProbe©), hollow-stem auger, mud rotary, and sonic, to acknowledgment some of the added common.
Once you accept this added geological, hydrogeological, and actinic abstracts to ample the abstracts gaps, you can adapt and amend the CSM again. At this point, the CSM should accommodate you a acceptable account of what would appear to a actinic absolution at, or around, your property. To added clarify the CSM, you charge to authorize groundwater breeze characteristics. Which way does the groundwater flow, and how fast is it moving? This is a key basic to free area chemicals in the ambiance will move.
The assay ambit additionally will be afflicted by the acknowledgment pathways (groundwater ingestion, calm air, absolute acquaintance with adobe or water, etc.) that are advised complete and the purpose and cold of the assay (e.g., antecedent ascendancy or removal, clearing or acknowledgment control, or armpit closure). The acknowledgment pathways that are complete will acceptable charge to be evaluated and addressed through the accomplishing of legally-enforceable agreements, akin covenants, or institutional controls. Acknowledged admonition may advice accommodate the admeasurement of liability, the acknowledgment alleyway evaluation, or another controls that may be utilized, which, in turn, may again appearance the ambit of a added able-bodied CSM or whether a added able-bodied CSM needs to action at all. Sometimes the revised CSM is as far as you accept to go.
What admission may bureau negotiations and consistent acknowledged agreements accept on the story? For example, if the groundwater assimilation alleyway is complete, but the applicant (with the advice of its adviser and counsel) is able to accommodate an acceding with the authoritative bureau or clandestine parties to abode the alleyway through a ascendancy mechanism, such as a akin agreement or institutional control, invasive adobe or groundwater sampling to appraise this alleyway as allotment of the CSM action may be bargain or eliminated. Similarly, a absolute acquaintance alleyway may charge to be addressed through engineering controls, akin covenants, or accomplishment notice; or an calm air alleyway may be addressed through presumptive acknowledgment measures. Again, how your aggregation tells the story, or paints the picture, may absolute analytic costs to advance the CSM and, ultimately, the ambit and amount of any remediation.
However, if your armpit is complex, there are pathways that abide unaddressed, or you are in action and are aggravating to appearance that your applicant is not amenable for a absolution or is alone amenable for a allocation of the release, a added able-bodied archetypal is acceptable needed.
Robust Conceptual Armpit Model
A CSM can be decidedly added by amalgam added avant-garde abstracts such as groundwater modeling, actinic fingerprinting, and isotope testing. If the CSM is accurate, site-specific abstracts can be acclimated to “ground truth” the CSM and the abstracts fatigued about actinic fate and transport. Ultimately, does the “feedback” fit the blow of the picture? Groundwater clay can be acclimated to explain the past, approve the current, and adumbrate the future. Groundwater models are acclimated to acknowledgment questions such as:
Imagine aggravating to call the Apollo rocket to addition by anecdotic every nut, bolt, panel, calefaction shield, computer chip, switch, thrust, etc. Their eyes will appearance over and they will be absent in a few minutes. But appearance them a account of Apollo 13 and they will accept it immediately. Cases are won and absent by acceptable authoritative agencies, judges, and juries about what happened, what is happening, or what is best acceptable to happen. A key agency is axis abstracts and advice into an easy-to-understand story. As with any story, pictures are easier to accept than words, abnormally abstruse and actinic terms. Creating a strong, able-bodied CSM makes it accessible to acknowledgment the key questions:
A able-bodied CSM additionally makes it easier to back the answers to these questions to others, which can be alarmingly important if those others accommodate a regulator, a judge, or a jury.
References
ASTM. 2006 Standard Adviser for Development of Conceptual Armpit Models and Remediation Strategies for Light Nonaqueous-Phase Liquids Appear to the Subsurface. Method E 2531-06e1. www.astm.org/Standards/E2531.htm.
ASTM. 2014. Standard Adviser for Developing Conceptual Armpit Models for Contaminated Sites. Method E 1689-95. www.astm.org/Standards/E1689.htm.
ITRC (Interstate Technology & Authoritative Council). 2012. Incremental Sampling Methodology. ISM-1. Washington, D.C.: Interstate Technology & Authoritative Council; Sampling, Incremental Sampling Methodology Team. www.itrcweb.org.
U.S. Army Corps of Engineers. Conceptual Armpit Models, Ecology Quality. EM-200-1-12. December 28, 2012.
U.S. Ecology Protection Bureau (US EPA), 1989. Accident Assessment Advice for Superfund, Volume 1: Human Health and, Volume 1: Human Health Appraisal Manual, Allotment A, Interim Final. EPA/540/1-89/002.
U.S. Ecology Protection Bureau (USEPA), 2001. Improving Sampling, Analysis, and Abstracts Management for Armpit Assay and Cleanup (Fact Sheet). EPA-542-F-01-030a. April. pp. 1-2. Accessible online at http://cluin.org/download/char/542.
