Environmental Cleanup at Navy Facilities

Risk-Based Methods

Committee on Environmental Remediation at Naval Facilities

Water Science and Technology Board

Commission on Geosciences, Environment, and Resources

National Research Council

Washington, D.C.

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--> Environmental Cleanup at Navy Facilities Risk-Based Methods Committee on Environmental Remediation at Naval Facilities Water Science and Technology Board Commission on Geosciences, Environment, and Resources National Research Council NATIONAL ACADEMY PRESS Washington, D.C. 1999

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--> NATIONAL ACADEMY PRESS 2101 Constitution Ave., N.W. Washington, DC 20418 NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance. Support for this project was provided by the U.S. Navy under Contract No. N47408-97-C-0234. International Standard Book Number 0-309-06343-4 Published book will be available from National Academy Press 2101 Constitution Avenue, N.W. Washington, DC 20418 (1-800-624-6242; http://www.nap.edu) Copyright 1999 by the National Academy of Sciences. All rights reserved. Printed in the United States of America

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--> Committee on Environmental Remediation at Naval Facilities EDWARD J. BOUWER, Chair, Johns Hopkins University, Baltimore, Maryland GENE F. PARKIN, Vice-Chair, University of Iowa, Iowa City MICHAEL J. BARCELONA, University of Michigan, Ann Arbor LAWRENCE W. BARNTHOUSE, LWB Environmental Services, Inc., Oak Ridge, Tennessee JOHN C. CHAMBERS, Arent, Fox, Kintner, Plotkin & Kahn, Washington, D.C. FRANCIS H. CHAPELLE, U.S. Geological Survey, Columbia, South Carolina NEIL R. GARRETT, Oklahoma Corporation Commission, Oklahoma City FRANKLIN W. SCHWARTZ, Ohio State University, Columbus LENNY M. SIEGEL, Center for Public Environmental Oversight, San Francisco State University, California ALICE D. STARK, New York State Department of Health, Albany SAMUEL J. TRAINA, Ohio State University, Columbus ALBERT J. VALOCCHI, University of Illinois, Urbana-Champaign BRIAN J. WAGNER, U.S. Geological Survey, Menlo Park, California CLAIRE WELTY, Drexel University, Philadelphia, Pennsylvania JEFFREY J. WONG, California Environmental Protection Agency, Sacramento Staff LAURA J. EHLERS, Study Director KIMBERLY A. SWARTZ, Project Assistant

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--> Water Science and Technology Board HENRY J. VAUX, JR., Chair, University of California, Riverside CAROL A. JOHNSTON, Vice-Chair, University of Minnesota, Duluth RICHELLE ALLEN-KING, Washington State University, Pullman JOHN S. BOYER, University of Delaware, Lewes JOHN BRISCOE, The World Bank, Washington, D.C. DENISE FORT, University of New Mexico, Albuquerque EVILLE GORHAM, University of Minnesota, St. Paul CHARLES D. D. HOWARD, Charles Howard & Associates, Victoria, British Columbia, Canada WILLIAM A. JURY, University of California, Riverside WILLIAM M. LEWIS, JR., University of Colorado, Boulder GARY S. LOGSDON, Black & Veatch, Cincinatti, Ohio RICHARD G. LUTHY, Carnegie Mellon University, Pittsburgh, Pennsylvania JOHN W. MORRIS, J. W. Morris, Ltd., Arlington, Virginia CHARLES R. O'MELIA, Johns Hopkins University, Baltimore, Maryland PHILIP A. PALMER, DuPont Engineering, Wilmington, Delaware REBECCA T. PARKIN, The George Washington University, Washington, D.C. JOAN B. ROSE, University of South Florida, St. Petersburg ERIC F. WOOD, Princeton University, New Jersey Staff STEPHEN D. PARKER, Director JACQUELINE A. MACDONALD, Associate Director CHRIS ELFRING, Senior Staff Officer LAURA J. EHLERS, Staff Officer JEFFREY W. JACOBS, Staff Officer MARK GIBSON, Research Associate JEANNE AQUILINO, Administrative Associate ANITA A. HALL, Administrative Assistant ELLEN DE GUZMAN, Senior Project Assistant KIMBERLY A. SWARTZ, Project Assistant

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--> Commission on Geosciences, Environment, and Resources GEORGE M. HORNBERGER, Chair, University of Virginia, Charlottesville PATRICK R. ATKINS, Aluminum Company of America, Pittsburgh, Pennsylvania JERRY F. FRANKLIN, University of Washington, Seattle B. JOHN GARRICK, PLG, Inc., Newport Beach, California THOMAS E. GRAEDEL, Yale University, New Haven, Connecticut DEBRA KNOPMAN, Progressive Foundation, Washington, D.C. KAI N. LEE, Williams College, Williamstown, Massachusetts JUDITH E. MCDOWELL, Woods Hole Oceanographic Institution, Massachusetts RICHARD A. MESERVE, Covington & Burling, Washington, D.C. HUGH C. MORRIS, Canadian Global Change Program, Delta, British Columbia RAYMOND A. PRICE, Queen's University at Kingston, Ontario, Canada H. RONALD PULLIAM, University of Georgia, Athens THOMAS C. SCHELLING, University of Maryland, College Park VICTORIA J. TSCHINKEL, Landers and Parsons, Tallahassee, Florida E-AN ZEN, University of Maryland, College Park MARY LOU ZOBACK, U. S. Geological Survey, Menlo Park, California Staff ROBERT M. HAMILTON, Executive Director GREGORY H. SYMMES, Assistant Executive Director JEANETTE SPOON, Administrative & Financial Officer SANDI FITZPATRICK, Administrative Associate MARQUITA SMITH, Administrative Assistant/Technology Analyst

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--> Preface "I have yet to see any problem, however complicated, which, when you looked at it in the right way, did not become still more complicated." Poul Anderson, New Scientist (London, Sept. 25, 1969) Under the auspices of the Water Science and Technology Board (WSTB), the National Research Council (NRC) established the Committee on Environmental Remediation at Naval Facilities in 1997. The NRC chose 15 experts to serve on the committee for the purpose of studying issues associated with the remediation of contaminated soil, sediment, and ground water at Navy facilities. The committee was initially established to provide guidance on the following three main areas pertinent to characterization and remediation of Navy facilities: Risk-Based Methodologies. What are the strengths and weaknesses of risk-based methodologies for cleaning up contaminated sites, including (but not limited to) the Risk-Based Corrective Action standard (RBCA) devised by the American Society for Testing and Materials? How should such a methodology be implemented at Navy facilities? Innovative Technologies. What innovative technologies are appropriate to assist the cleanup efforts at Navy facilities? Long-Term Monitoring. For Navy facilities that will not be able to meet regulatory standards for cleanup in the near future, what guidance can be given for establishing and maintaining long-term monitoring at such sites? The project was supported by the U.S. Navy with the stipulation that the three study topics listed above would be funded incrementally. This report reflects the outcome of the first year of committee deliberations that addressed risk-based methodologies (Task 1 above). The committee saw as its goals to provide a review of existing risk-based methodologies, a description of their strengths and weaknesses, and a set of recommendations on how the Navy should proceed.

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--> The Navy did not ask the committee to review methods they are currently using to comply with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The committee was also not asked to review the Relative Risk Site Evaluation Framework, which is a risk-based framework for requesting and distributing cleanup funds in the military. Consequently, the committee did not view as its role the task of suggesting improvements to the approach the Navy is currently using and did not deliberate on how to improve the CERCLA process. The committee discussions focused on risk-based methods not currently being used by the Navy that may offer cost and time savings. Navy personnel indicated that they were interested in a methodology that could encompass all of their sites, from petroleum underground storage tanks to more recalcitrant types of contamination. The committee undertook a thorough evaluation of the use of risk-based methodologies for managing current soil and ground water cleanup efforts. During four meetings held over nine months, the committee gathered information from expert presentations to the committee, field trips to three Navy facilities, and dialogue with Navy personnel. The committee also relied on the in-depth experience and expertise of the committee members, who are recognized leaders in environmental engineering, hydrogeology, soil science, geochemistry, ground water modeling, statistical sampling of ground water, toxicology, risk assessment, law, public health, and public participation/stakeholder involvement. Although the committee members represented a diversity of opinions and backgrounds, we were able to reach a consensus on almost all issues. The quote from Poul Anderson above is an accurate reflection of the experiences of this committee. The Navy, like most if not all responsible parties, would like to see a simpler solution to its cleanup problems. However, the committee agreed that site cleanup and maintaining an acceptable risk at a site are both complex and difficult issues. The uncertainties associated with leaving contamination in place and the uncertainties in source, pathway, and receptor characterization led the committee to develop eleven criteria that a risk-based approach must fully satisfy to address Naval hazardous waste sites. The document that follows is the culmination of our initial efforts to help the Navy solve problems in its Environmental Restoration Program. Although the committee discussed the additional time and costs that would be necessary to implement its recommendations, these issues were not quantitatively evaluated. This report has been reviewed, in accordance with NRC procedures, by individuals chosen for their expertise and broad perspectives on the issues addressed herein. These independent reviews provided candid and critical comments that assisted the authors and the NRC in making the published report as sound as possible, and they ensured that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The content of the review comments and the draft manuscript remain confidential to protect the integrity of the deliberative process. The committee wishes to thank the following individu-

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--> als for their participation in the review of this report and their many instructive comments: Patrick Atkins, Aluminum Company of America; Anthony Grey, New York State Department of Health; Theodore Henry, Community Health Assessment & Public Participation Center; Michael Kavanaugh, Malcolm Pirnie, Inc.; Paul Kostecki, University of Massachusetts at Amherst; Philip LaMoreaux, P. E. LaMoreaux and Associates, Inc.; Joel Massmann, University of Washington; and William Walsh, Pepper Hamilton LLP. While the individuals listed above have provided many constructive comments and suggestions, responsibility for the final content of this report rests solely with the authoring committee and the NRC. Special thanks must go to several individuals who contributed to the committee's overall effort in so many ways. First, a great share of appreciation must go to Laura Ehlers, the NRC Staff Officer for this project. Laura put forth a great deal of effort in coordinating the committee meetings, gathering information, preparing copious minutes of the meetings, and reminding the committee members of their duties and responsibilities. Laura actively participated in the committee discussions, offered insightful comments and input, and demonstrated considerable editing skills in preparing and extensively rewriting significant sections of the report. We owe much of the credit for the success of this report to Laura. Second, much appreciation also goes to Jackie MacDonald. Jackie is the associate director of the WSTB and assisted the committee with this project by actively participating in the meetings, providing background details on the evolution of the study, and writing sections of the report. Jackie's positive feedback of the committee's progress during these past nine months is appreciated. Third, the committee extends its appreciation to Kim Swartz who, as project assistant, provided the essential administrative support associated with the committee effort. Fourth, the committee thanks Steve Eikenberry, director of the Environmental Restoration Division of the Naval Facilities Engineering Service Center, for his role as the Navy liaison. The committee benefited from Steve's insight into the problems and needs of the Navy with respect to environmental remediation. Fifth, I thank Gene Parkin who assisted me as vice-chair. Gene's attention to details, timeliness, and positive spirit are much appreciated. Finally, I would like to thank the committee members, who devoted many long hours to this project. I have enjoyed immensely the opportunity to work with such a talented and articulate group of professionals. They provided a stimulating environment for addressing the study issues. I especially appreciate their willingness to spend time researching, writing, and revising their contributions. I believe the results of their efforts will provide useful guidance for some of the environmental restoration challenges of the Navy, which should also be relevant to a broader universe of sites and facilities. EDWARD J. BOUWER, CHAIR COMMITTEE ON ENVIRONMENTAL REMEDIATION OF NAVAL FACILITIES

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--> Contents     Executive Summary   1 1   Introduction   15     The Emergence of Risk-Based Approaches   19     Current Regulatory Framework   22     Characteristics of Naval Hazardous Waste Sites   25     Pressing Cleanup Challenges   28     References   34 2   Review of Risk-Based Methodologies   35     Introduction   35     Universe of Risk-Based Methodologies   38     References   66 3   Strengths and Weaknesses of Risk-Based Methodologies   68     Strengths and Weaknesses of a Generic Risk-Based Approach   68     Comparing ASTM RBCA and CERCLA(RAGS/SSG)   71     Strengths and Weaknesses of ASTM RBCA   74     Strengths and Weaknesses of CERCLA   79     Conclusions   81     References   81

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--> 4   Uncertainty in Risk-Based Methodologies   83     Uncertainty in Risk Assessment   83     Uncertainty in Risk Management   95     References   106 5   Conclusions and Recommendations   111     The Navy's Environmental Challenges   111     Eleven Criteria for a Risk-Based Methodology   114     Comparing ASTM RBCA to the Eleven Criteria   121     Recommendations   127     References   132     Appendixes     A   Survey of State Risk-Based Decision Making   133 B   Acronyms   137 C   Biographical Sketches of Committee Members and Staff   139