In a recent memorandum,[i] the EPA approved the use of several advanced monitoring technologies and approaches to support long-term stewardship (LTS) of contaminated properties.
These advanced monitoring technologies support institutional controls (ICs) and engineering controls (ECs) which aim to monitor the progression, safety, and efficiency of government sites in the cleanup process and are intended to supplement existing IC and EC monitoring and review requirements.
ICs are administrative rules and guidelines (e.g. zoning restrictions) created to prevent exposure or contamination from a contaminated site.[ii] ECs provide a physical means to prevent exposure or contamination, such as barriers, fences, and landfill soil caps.[iii] LTS refers to the overall maintenance of “physical and legal controls, implementation entities, authorities, accountability mechanisms, information and data management,” and other site protections. The EPA points out the importance of ICs and ECs as they ensure that toxic waste or contamination will be contained, kept away from the public or causing only minimal exposure, and/or correctly remediated.
Aside from geographic information system (GIS) mapping tools, many of the advanced monitoring technologies mentioned in the EPA memo were created by third party companies focused on monitoring technologies. The EPA defines advanced monitoring in the LTS context as “a broad range of analytic systems, techniques, technologies, and approaches for better detecting potential land uses or activities that are inconsistent with the cleanup, that conflict with an IC, and/or that may impede the effectiveness of an EC.” These advanced monitoring approaches aim to improve and assist ICs and ECs, as well as provide transparency to the public, potential future owners, or affiliates of a property. Specifically, some of the advanced technologies mentioned in the EPA’s memorandum are:
- Land activity monitoring: Monitors data and information about IC and EC monitored properties against property-specific regulations
- One-call excavation monitoring: Monitors excavation activities and compares them against the site’s ICs, ECs, and LTS regulations
- Land use and building permit monitoring: Works in conjunction with state, local, or tribal government, uses mapping technology to monitor activities, and compares them against the site’s ICs, ECs, and LTS regulations
- Geographic information system (GIS) mapping and database approaches: Uses satellite imaging to monitor site activity and is information readily available to the public
- Vapor intrusion system remote monitoring: Automated monitoring of vapor intrusion mitigation systems to ensure continuous functionality
- Change detection monitoring: Aerial satellite monitoring of sites to monitor property changes such as additional buildings or construction
The EPA’s formal support of these advanced monitoring technologies is intended to keep the public safe, promote proper and efficient site cleanup, and work towards a faster rehabilitation of contaminated sites.
SOURCES
[i] https://www.epa.gov/sites/production/files/2018-07/documents/adv-mon-lts-mem-final-2018.pdf
[ii] https://www.epa.gov/superfund/superfund-institutional-controls
[iii] https://www.epa.gov/sites/production/files/2015-09/documents/ec_information_guide.pdf
