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Ground Water & Soil Cleanup: Improving Management of Persistent Contaminants 6 Findings and Recommendations The Department of Energy (DOE) will be unable to meet all of the applicable federal and state regulations for cleanup of contaminated groundwater and soil at its facilities with existing technologies. The most intractable problems involve dense nonaqueous-phase liquids (DNAPLs), metals, and radionuclides. The Subsurface Contaminants Focus Area (SCFA) within DOE's Office of Science and Technology (OST) is charged with developing innovative, cost-effective technologies to address these intransigent problems. As described in this report, SCFA has achieved a number of successes, but its progress has been limited by budget and programmatic problems, both in SCFA and in the DOE environmental restoration program as a whole. The Committee on Technologies for Cleanup of Subsurface Contaminants in the DOE Weapons Complex, at the request of DOE and in the course of preparing this report, developed a series of findings and recommendations for improving SCFA's technology development program. The major findings and recommendations are presented in this chapter and are based on the analyses provided in Chapters 2 through 5. They are organized into four categories: (1) technology development priorities, (2) overall program direction, (3) barriers to deployment, and (4) budget limitations. SETTING TECHNOLOGY DEVELOPMENT PRIORITIES Finding. Because many metal, radionuclide, and DNAPL remediation technologies are in their early stages of development, relatively rapid
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Ground Water & Soil Cleanup: Improving Management of Persistent Contaminants progress should be expected with continuing work by consulting firms, private industries, and academic and government laboratories involved in remediation technology development, as well as by SCFA. • Recommendation: SCFA should develop and maintain a system for updating technology evaluations for remediation of metals, radionuclides, and DNAPLs. In order to avoid duplicating the work of others, SCFA needs to keep apprised of and selectively use results from remediation technology development projects by outside organizations. Finding. Fewer than one-third of SCFA technologies address the need for in situ remediation of contaminants in groundwater and soil. Development of in situ remediation technologies appears not to be receiving appropriate priority. • Recommendation: In situ remediation technologies should receive a higher priority in SCFA because of their potential to reduce exposure risks and costs. Finding. Promising technologies for remediation of metals and radionuclides include ion exchange systems and electrokinetic technologies. Ion exchange methods are simple and potentially effective for use in in situ barriers for metals and radionuclides, particularly if more selective ion exchange media can be developed. Electrokinetic technologies appear promising for extraction of metal and radionuclide contaminants from fine-grained media, but additional field demonstrations are necessary to establish performance under field conditions encountered at DOE sites. • Recommendation: SCFA should consider funding work on the development of selective ion exchange media for use in reactive barriers. SCFA also should fund additional field demonstrations of electrokinetic systems, building on private-sector and overseas tests and focusing on metals and radionuclides unique to the weapons complex. Finding. Although it is unlikely that any remediation technology will restore every portion of an aquifer contaminated with DNAPLs to baseline standards, some emerging technologies have demonstrated applicability for removing significant amounts of contaminant mass from DNAPL source zones. These technologies include systems using surfactants, cosolvents, steam and other forms of heat, soil vapor
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Ground Water & Soil Cleanup: Improving Management of Persistent Contaminants extraction (including thermal enhancements), air sparging, and in situ oxidation. In addition, several technologies have potential applicability primarily for aqueous-phase contamination dissolved from DNAPLs. These technologies include various bioremediation and reactive barrier wall systems, in addition to conventional pump-and-treat systems. • Recommendation: Although the potential of the DNAPL remediation technologies listed above has been demonstrated, SCFA should fund additional, carefully controlled tests in conjunction with external technology developers (where appropriate) to provide cost and performance data to facilitate application of these technologies. There is much uncertainty in technology evaluations due to the limited amount of high-quality data, and SCFA can play a key role in generating the needed data. Finding. Technologies for treating contaminant mixtures are in short supply, and the efficacy of many technologies for treating mixtures has not been established. The permeable reactive barrier is the most promising method for preventing the migration of mixtures of dissolved metals, radionuclides, and DNAPL components under appropriate conditions, but the longevity of barrier materials needs to be established. • Recommendation: SCFA should fund tests designed to develop and determine performance limits for technologies capable of treating the types of contaminant mixtures that occur at DOE sites. In particular, SCFA should continue to fund studies of the longevity of reactive barriers in terms of reactivity, permeability, and integrity. Finding. Removing all sources of groundwater contamination, particularly DNAPLs, will be technically impracticable at a number of DOE sites, and long-term containment systems will be necessary for these sites. Methods will be needed to monitor the performance of containment barriers, because the longevity of barrier materials is uncertain. Electrical resistance tomography methods have received a significant amount of SCFA funding for studies of the integrity of subsurface barriers (including reactive barriers and conventional containment systems), but these methods have considerable limitations for this application.
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Ground Water & Soil Cleanup: Improving Management of Persistent Contaminants • Recommendation: SCFA should focus a portion of the program's work on development of remedial alternatives (including containment systems) that prevent migration of contaminants at sites where contaminant source areas cannot be treated. Methods for monitoring long-term performance of these systems should be included in this work. In making its funding decisions, SCFA should distinguish between characterization technologies that can evaluate subsurface barrier performance and those that can delineate site features that are important in remedy selection and design. Finding. Use of monitored natural attenuation in place of active cleanup remedies is increasing at contaminated sites nationwide, but implementing natural attenuation at DOE sites to help control plume migration may require additional research to develop methods for predicting the fate of certain classes of contaminants in natural environmental media. • Recommendation: SCFA should determine what additional research will be needed for DOE to consider use of monitored natural attenuation at some of its sites, while still meeting applicable regulatory requirements, and should develop a corresponding research strategy. Finding. Representative successful SCFA achievements in developing technologies for remediation of metals and radionuclides include in situ redox manipulation for chromium immobilization at Hanford, bottom barriers for waste containment at the Idaho National Engineering and Environmental Laboratory, the site characterization and analysis penetrometer system for characterization of sub-surface environments in a wide range of settings, and the dig-face system for real-time guidance of excavations. Representative successful SCFA projects for developing DNAPL remediation technologies include dynamic underground stripping and thermally enhanced vapor extraction. Unfortunately, in the past SCFA has had to discontinue funding for some promising projects before technology development work was completed. • Recommendation: SCFA should emphasize moving these and other technologies with demonstrated performance records to wider use. For its most promising projects, SCFA should ensure funding consistent with needs, including time for completion and long-term monitoring of field tests.
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Ground Water & Soil Cleanup: Improving Management of Persistent Contaminants Improving Overall Program Direction Finding. The overall goals of SCFA's technology development program have to be better defined in order to evaluate success. SCFA has struggled to provide Congress and others with concrete measures of program performance. To date, SCFA has focused on demonstrating the extent to which its technologies have been deployed in the field, but the available deployment data are inadequate (see Chapter 5). Further, the total number of SCFA technology deployments is not a sufficient metric for evaluating the SCFA program. • Recommendation 1: SCFA should continue its efforts to work more closely with end users of remediation technologies (the DOE field personnel responsible for selecting these technologies) in setting its overall program direction. Working with end users, SCFA should identify key technical gaps and prepare a national plan for developing technologies to fill these gaps. This plan should be updated periodically as regulatory requirements and technology needs change. The extent to which the technology gaps have been filled should serve as the key measure of SCFA's success. SCFA's recent work with the site technology coordination groups to develop lists of technology needs (see Chapter 5) represents an important step in this direction, but implementation of the process has been hampered by budget limitations. Although SCFA developed a prioritized list of problem areas (known as work packages) for funding in fiscal year 1998, it was unable to use this list to guide its program because the entire SCFA budget went to supporting multiyear projects that began before SCFA was formed. • Recommendation 2: SCFA should significantly increase use of peer review for (1) determining technology needs and (2) evaluating projects proposed for funding (see NRC, 1998, for guidelines on peer review). Peer reviews should carry sufficient weight to affect program funding. • Recommendation 3: SCFA should improve the accuracy of its reporting of technology deployments. SCFA should use a consistent definition of deployment and should work with the Office of Environmental Restoration to verify the accuracy of its deployment report. Finding. SCFA technology development projects have been most successful when they have been based on specific needs identified by
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Ground Water & Soil Cleanup: Improving Management of Persistent Contaminants DOE installations and have involved DOE end users in planning the demonstrations. Other factors important in successful projects include (1) availability of sufficient financial support for timely demonstrations of the technology; (2) conduct of exploratory and pilot-scale assessments to enhance the technology prior to full-scale demonstrations; (3) adequacy of system design and operation; (4) availability of data showing cost savings; (5) multiplicity of potential applications; and (6) use of independent peer review in planning and evaluating demonstrations. • Recommendation 1: SCFA should strive to increase the involvement of technology end users in planning the technology demonstrations it funds. End users should be involved in planning every demonstration that SCFA funds, as in the Accelerated Site Technology Deployment Program. • Recommendation 2: SCFA should continue efforts to improve its success metrics for individual technology development projects. The metrics should be based on a careful analysis of factors that have led to the success or failure of past projects and could include the factors listed in the finding above. • Recommendation 3: SCFA should identify successful technology demonstration projects to serve as models for future demonstrations. Finding. Regulatory policies concerning cleanup requirements for groundwater and soil are evolving rapidly toward more flexible approaches. These policies will affect the range of cleanup goals that are acceptable at DOE installations and, correspondingly, the suite of possible remediation technologies for achieving these goals. • Recommendation: SCFA should work with DOE field personnel to develop a process for continuously tracking cleanup requirements (and corresponding technology needs) at the sites. SCFA should keep track of policy changes, as discussed in Chapter 2 of this report, that may affect cleanup requirements. OVERCOMING BARRIERS TO DEPLOYMENT Finding. Contractors at DOE installations are reluctant to try innovative technologies developed by SCFA and others in part because of uncertainties about technology performance and the risk that the innovative technology will fail to perform as predicted.
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Ground Water & Soil Cleanup: Improving Management of Persistent Contaminants • Recommendation 1: SCFA should sponsor more field demonstrations, such as those funded under the Accelerated Site Technology Deployment Program, to obtain credible performance and cost data. SCFA should consider whether sponsorship could include partial reimbursement for failed demonstrations, if an alternate remediation system has to be constructed to replace the failed one. • Recommendation 2: SCFA should ensure that the project reports it provides contain enough technical information to evaluate potential technology performance and effectiveness relative to other technologies. The project descriptions contained in SCFA's periodic technology summary reports are not sufficiently detailed to serve this purpose. Project reports should include well-documented performance data, detailed cost estimates, design information useful to practitioners, and lessons learned. They should follow the guidelines in the Federal Remediation Technologies Roundtable's Guide to Documenting and Managing Cost and Performance Information for Remediation Projects (EPA, 1998). • Recommendation 3: A key future role for the SCFA should be the development of design manuals for technologies that could be widely used across the weapons complex. SCFA could use the Air Force Center for Environmental Excellence (AFCEE) design manual for bioventing as a model (Leeson and Hinchee, 1996). The AFCEE approach is to test a technology at a number of well-characterized sites and develop design manuals from the results. Other possible models include the WASTECH® monograph series published by the American Academy of Environmental Engineers (AAEE)1 and the surfactant-cosolvent manual (Lowe et al., 1999) published by the Advanced Applied Technology Demonstration Facility (AATDF, sponsored by the Department of Defense and based at Rice University). • Recommendation 4: Appropriately qualified SCFA staff members (with in-depth knowledge of remediation technologies) should be available to serve as consultants on innovative technologies for DOE's environmental restoration program. These staff members also should develop periodic advisories for project managers on new, widely applicable technologies. SCFA needs to ensure that DOE technology end users are provided with 1 Information about these monographs is available from the AAEE in Annapolis, Maryland.
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Ground Water & Soil Cleanup: Improving Management of Persistent Contaminants the technical assistance (from within and as necessary from outside DOE) required to deploy new technologies at full scale. Finding. Fewer than one-third of SCFA technologies have been deployed at more than one facility, and fewer than 20 percent have been deployed at more than two facilities. This lack of multisite deployments is primarily a result of the lack of demand for SCFA technologies, but lack of organized data on the types and locations of different contamination problems in the weapons complex also hinders multisite deployments. Without a well-organized data base on the prevalence of different types of subsurface contamination problems in the weapons complex, planning for multisite deployments is difficult. • Recommendation: SCFA should use the potential for multisite application of new technologies as an important criterion in selecting projects for funding, although single applications are appropriate for unique, high-risk situations. DOE could strengthen its efforts to organize site characterization data so they can be easily accessed and used in planning SCFA's program. Addressing Budget Limitations Finding. SCFA's progress has been limited in part by large budget swings. In fiscal year 1998, SCFA's budget was reduced to a level that was insufficient to support significant progress on the development of innovative remediation technologies. The budget was cut from a 1994 level of $82 million to a 1998 level of $15 million, which included a $5 million congressional earmark, leaving an effective budget of $10 million. This budget was inadequate to fund the types of large-scale demonstrations needed to transition innovative remediation technologies from the research and development phase to full-scale application. It also was too small to allow open bidding for project funding. The fiscal year 1999 budget of $25 million, while representing a significant increase, will allow for funding of only a limited number of projects. • Recommendation 1: DOE managers should reassess the priority of subsurface cleanup relative to other problems and, if the risk is sufficiently high, should increase remediation technology development funding accordingly. • Recommendation 2: SCFA should pursue a variety of strategies to leverage its funding. First, it should develop an im-
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Ground Water & Soil Cleanup: Improving Management of Persistent Contaminants proved strategy for collaborating with external technology developers to adapt technologies for DOE use that have been developed in the private sector or by other government agencies. SCFA should work closely with the original technology developers to avoid duplicating their work, and new technology development efforts should focus on problems for which no cost-effective technical solutions exist. Second, SCFA should create stronger ties with the Environmental Management Science Program (EMSP). SCFA should assess the relevance of EMSP research for application to the SCFA program. Third, SCFA should continue its participation with working groups of the Remediation Technologies Development Forum (RTDF), a public-private partnership organization involved in remediation technology development. SCFA is involved in several RTDF working groups, including the Lasagna Partnership and the Permeable Reactive Barriers Action Team, and this involvement should continue. In summary, DOE faces the challenge of cleaning up large quantities of contaminated groundwater and soil with a suite of baseline technologies that are not adequate for the job. Political pressure to meet federal and state groundwater and soil remediation requirements at DOE installations continues and recently has created problems for DOE at facilities such as Hanford, where politicians have pressured the department for better efforts to clean up contamination in the vadose zone (the soil above the water table). Although the implementation of site remediation laws is becoming somewhat more flexible, addressing groundwater and soil contamination problems at DOE installations cannot be avoided. DOE will have to continue to invest in accessing and developing remediation technologies for these media. A number of new remediation technologies are currently in the pipeline that, with adequate DOE investment to complete development work, could make significant contributions to the cleanup effort. SCFA has overseen some successful technology development projects in the past. Although its operations need continued improvements as discussed in this report, nonetheless SCFA is the key entity within DOE for ensuring that the department will be adequately equipped to solve its groundwater and soil contamination problems. DOE managers as a whole need to reassess the priority assigned to subsurface remediation technology development and whether SCFA is adequately supported and organized to accomplish its mission.
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Ground Water & Soil Cleanup: Improving Management of Persistent Contaminants REFERENCES EPA (Environmental Protection Agency). 1998. Guide to Documenting and Managing Cost and Performance Information for Remediation Projects. EPA 542-B-98-007. Washington, D.C.: EPA. Leeson, A., and R. E. Hinchee. 1996. Principles and Practices of Bioventing. Brooks Air Force Base, Tex.: U.S. Air Force Center for Environmental Excellence. Lowe, D. F., C. L. Oubre, and C. H. Ward, Eds. 1999. Surfactants and Cosolvents for NAPL Remediation: A Technology Practices Manual. Boca Raton, Fla.: Lewis Publishers. NRC (National Research Council). 1998. Peer Review in Environmental Technology Development Programs. The Department of Energy's Office of Science and Technology . Washington, D.C.: National Academy Press.
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