In Part 1 of this series, I advanced the idea that the environmental consulting business model is poised for major disruption from the developing interconnectivity offered by the internet and smart devices. Emerging sensor technology, low cost embedded systems, and automated analytical platforms are starting to become a compelling option for the collection and dissemination of measurable environmental data. Automation offers advantages like precision, repeatability, rapid spatial interpolation, and real-time delivery of information. Streamlined delivery of environmental conclusions are clearly important to decision-makers such as stockholders, regulators, and insurance company risk managers. The US EPA now recognizes the value of modernizing the compliance process and has forwarded new programs that incorporate automated electronic reporting and advanced monitoring technologies.
The environmental compliance industry has only marginally tapped the potential benefits realized from combining spatial data with temporally-relevant data. For the spatial aspect, traditional spatial renderings generated from quarterly groundwater sampling data reveal a valuable visual approximation of the contaminant plume, however, these outputs represent only a snapshot in time. Decades ago, the industry settled on the quarterly monitoring schedule since the associated costs (for labor and lab) were often deemed cost-prohibitive for more frequent monitoring events. It has been further argued that the water quality variability within an aquifer is too gradual to justify the additional sampling and testing expense. However, as companies begin to embrace continuous monitoring methods, they are learning that environmental conditions in the air, soil, or groundwater are much more dynamic than first thought. Technologies can now take high density data-sets and automatically generate plume contour maps for each time-step and deliver those maps to a practitioner though the web within seconds. This capability can be likened to viewing a movie versus viewing a few still shots. With a higher resolution of information, practitioners can better predict trends, identify influences, and evaluate and optimize remediation efforts.
Some argue that regulatory policy is too restrictive to support market adoption of these tools. For the most part, the environmental compliance business model tends to follow a linear process that is temporally dependent upon permits and approvals. For example, for sites with subsurface impacts, Phase I studies proceed to Phase 2 studies and remediation cannot proceed until regulatory decision makers are satisfied with the approach. For groundwater sites, remediation is further followed by Monitored Natural Attenuation (MNA), a process that can take many years. Using modern technologies and alternative compliance programs, the entire process can be streamlined to gain efficiencies, save costs, promote transparency, and free up land for beneficial use. The US EPA already recognizes the need to modernize the regulatory compliance process. In 2014, they launched the “Next Generation Compliance Strategic Plan1” with the stated goal of implementing:
- More effective regulations and permits with “next generation compliance principals and tools”;
- Advanced monitoring capabilities by encouraging the use of modern and emerging pollution detection and monitoring technologies;
- Enhanced communication by incorporating electronic reporting for accurate and timely reporting;
- Expanded transparency offered by making electronic reporting available to the public;
- Innovative enforcement principals to strengthen enforcement.
Some of these advancements are already taking root in the areas of air emissions compliance and process discharge monitoring, however, such initiatives are only slowly being adopted in support of subsurface pollution compliance. The current “phased compliance model” is an outdated policy designed around an enforcement model driven by regulatory orders that often put responsible parties on the defensive. However, in the current business climate, corporations are recognizing the return on investment offered by proactive environmental stewardship. With the public being only mouse clicks away from global information, Responsible Parties (RPs) can no longer hide behind their cleanup obligations without attracting scrutiny. To align their company performance with environmental compliance, RPs can follow the lead of the EPA’s strategic plan and demand self-policing approaches that incorporate advanced automation and reporting.
To accommodate these changes, regulatory agencies would need to adapt their review policies and user interfaces to accommodate vastly larger datasets and near real-time compliance deliverables. The self-monitoring approach could allow for bridging of the phased compliance process but likely with a caveat that transparency measures are in the mix. The Conceptual Site Model (CSM) has always been considered an “improving” product and as such can eventually (for some sites) convert to a truly “dynamic CSM”. A model that is perhaps, continuously calibrated and updated by automation (and professional input). Furthermore, the remediation process and MNA can also be considered dynamic processes with room for technology upgrades and improvements like the incorporation of biosensors.
The application of continuous monitoring and remote data automation to environmental assessment and characterization is still in its early development yet practitioners are making innovative discoveries at a rapid pace. Armed with high-frequency, spatial and temporally resolved environmental data, earth scientists are beginning to challenge or at least modify well entrenched theories describing the interaction of the states of matter. These discoveries are fueling a new generation of scientific papers in the environmental community and new approaches to optimizing remediation results. High density temporally relevant data is revealing surrogate parameters that show direct correlation with changes in chemical of concern concentrations. Such insights allow use of low cost, standard-state sensors to fill in data gaps, track trends, and minimize analytical costs until such time reliable analyte-specific sensors are developed.
Based on my experiences and associations with many innovative groups in California, I can attest to many benefits offered by adoption of these technologies. A few of these include:
Workflow automation allows for consistent, high density data collection, processing, and archival. The data is ordered, digital, and easily accessed. If interpretation is needed, the consultant has a vastly greater dataset with temporal relevance to aid his or her insights. Automated digital reporting allows for fast communication with all stakeholders and the time-stamped (tagged) data archives promise to improve regulatory compliance and legal documentation.
- Data Gaps, Trends and Temporal Insights
Automated collection of time-ordered data eliminates data gaps and serves to link measurable events to specific patterns such as range, order, recurrence, behavior, etc. which can improve prediction and analysis. Temporal data patterns presented by time-series plots can show trends and seasonal cycles but can also show data clusters, threshold exceedances, and outliers. This information can be used to automatically trigger alert notifications for leaks, exposures, or other measurable incidents of concern. It can also be used to automatically engage actuators for mitigation systems, recovery pumps, and emergency shutdown systems. Access to massive temporal data may also support the development of First & Second Order Decision-Response Models that are backed up by measurable trends.
- Second Order Insights
Some of the most valuable benefits from continuous monitoring are the unintended or collateral temporal insights that can be revealed. At groundwater sites with petroleum impacts, continuous monitoring of bioremediation activity is yielding fresh new insights into the dynamic behavior of indigenous bacteria within a petroleum plume. For example, an in-situ biosensor is available that measures and reports electrical signals emitted by microbes actively biodegrading organic compounds under reducing conditions. Continuous tracking of microbial activity and redox conditions can reveal new insights into Natural Source Zone Depletion (NSZD) trends including dynamic relationships with changing dissolved oxygen and carbon dioxide levels. Such systems can be used to support low risk conclusions, direct amendment activities, and document remedial effectiveness.
In the field of VI management, high frequency monitoring has been used to isolate source areas and pin-point intrusion pathways using “cause and effect” exercises in real time. More importantly, high frequency monitoring has demonstrated temporal correlations between indoor VOC concentrations, barometric pressure, and pressure differential. In fact, repeatable episodic trends have been observed that suggest that VI conditions can be highly variable over a 24-hour period in response to diurnal pressure dynamics (particularly in coastal regions)1. Such insights have important implications for the many risk-based site closures that relied upon discrete time-integrated sampling methods (passive diffusion and summa canisters) that offer little spatial-temporal resolution. Conclusions about exposure risk that ignore the entire range of exposure concentrations may be misrepresenting the true temporal window of inhalation exposure resulting in false negative and/or false positive conclusions. Best available monitoring technologies with spatial temporal resolution are tools that can raise the level of certainty for VI risk decisions.
- Cost Savings
Manufacturing industries have long demonstrated cost efficiencies afforded by automation. With respect to environmental monitoring applications, it appears that the cost for deploying remote data automation is approaching the price-point where return on investment appears compelling. Services are now available that can mobilize telemetry-enabled platforms for 24-hour monitoring by the day, week, or month. These service models are similar to that of a driller, HRSC testing provider, or mobile laboratory. Although costs are comparable to traditional quarterly monitoring investments, continuous monitoring options offer a much greater value if evaluation is made on a cost-per-data-point basis. Furthermore, substantial cost savings can be realized from optimizing remediation efforts using spatial and temporally relevant data.
Collecting a lot of spatial and temporal data is not a solution in of itself. A skilled professional is still required to recognize meaningful and actionable data. There is a valid concern for the possibility of “drowning in data” and for that reason, consultants will need to become adept at discerning data that is of value or relevant to their client. Algorithms can be used to filter, screen, or send an alert upon exceedance thresholds but human interaction is needed for recognizing trends, patterns, and insights pertinent to stakeholder concerns. Though a smart data network may be hyper-efficient at collecting and reporting data, it will likely not offer hunches or experiences from which to draw (ignoring developments in artificial intelligence).
Excellent deterministic models are available to assist consultants in predicting chemical exposure risk based on fate and transport mechanisms driven largely by physical and chemical properties. However, such models are only as accurate as the input parameters used. Additionally, models often assume that subsurface conditions are homogeneous, steady-state conditions and non-preferential flow. Continuous monitoring approaches can provide many of the site-specific parameters required to support models and can often identify preferential flow paths.
More than likely, these emerging technologies will serve to supplement and improve professional decision-making by providing much more information with nearly on-demand timing. Technology advancements are progressing at a pace that warrants attention by the environmental professional community given their potential to disrupt, and these advancements are not limited to the measurement of physical and chemical properties. Interestingly, Planet Labs Inc. has begun deploying tiny shoebox-sized imaging satellites that will enable consultants to rapidly retrieve high-resolution earth images on a daily basis. Such services will likely offer an immediate benefit to environmental resource and due diligence professionals and potentially reward those offering leading-edge capabilities.
In future articles, I will profile specific emerging technologies and touch on some of the innovative applications for optimizing environmental site assessment and remediation.
Brian M. Kahl, PG
1 US EPA Office of Enforcement and Compliance Assurance, Next Generation Compliance: Strategic Plan 2014-2017 https://www.epa.gov/sites/production/files/2014-09/documents/next-gen-compliance-strategic-plan-2014-2017.pdf