Environmental Cleanup at Navy Facilities Adaptive Site Management (2003) / Chapter Skim
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Summary
Summary
Pages 1-17
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The Navy's Environmental Restoration Program encompasses a wide array of contaminants reflecting the military's multiple purposes over the past 100 years as well as a diversity of locations, including coastal environments and inland waterways. Because efforts to remediate hazardous waste sites began as much as 20 years ago, a large percentage of identified hazardous waste sites have reached the latter stages of cleanup (i.e., beyond remedy selection)
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The following specific tasks were given: define a decision-making framework that is embodied within a "systems engineering approach" to site cleanup, review innovative technologies for cleanup of groundwater, sediment, and soils, focusing on the top technologies that should be considered for the three or four greatest Navy problems, · consider how remedies can be altered over time to introduce innovative technologies where the chosen remedy is no longer optimal because of changing site conditions, limited efficacy of technologies, or the discovery of new contamination and/or exposure pathways, and define logical endpoints and milestones for site closure. In response, this report proposes a comprehensive and flexible approach, referred to as "adaptive site management," for dealing with difficult-toremediate hazardous waste sites over the long term.
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to refer to the application of the adaptive management concept to hazardous waste cleanup. Within the environmental arena, adaptive management concepts are timely, given the observed limitations in remediation effectiveness and the increased use of remedies like containment and institutional controls that will leave residual contamination in place for long periods.
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The main tenets of ASM are that it: is applicable at various stages of site restoration, is applicable to a wide variety of sites regardless of the contaminants being addressed or remedies envisioned, provides a mechanism for the optimization of existing remedies changing ineffective remedies, and refining the site conceptual model, · formalizes the routine examination of monitoring data and how to act upon the data, · incorporates public participation, · recognizes uncertainty and suggests approaches to dealing with it, especially when institutional controls are used, stimulates the search for new, innovative technologies to replace older or inefficient approaches, stresses the need for pilot programs to test both new technologies as well as modifications of existing technologies that might enhance their effectiveness, and recognizes the increasing role of long-term stewardship. ASM encompasses the initial steps of site management, including the site conceptual model and risk assessment.
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. Later management decision periods give remedial project managers an opportunity to use information gained during evaluation and experimentation and routine monitoring to optimize the existing remedy, change the remedy, or even change the remedial goal.
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~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: ............................................................................................................................ FIGURE S-1 Latter stages of adaptive site management: post-remedy selection.
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MONITORING AND DATA ANALYSTS DURING ADAPTIVE SITE MANAGEMENT Management decision periods 2 through 4 require information in the form of quantitative data from a monitoring program and subsequent data analysis. For example, MDP2 involves the following key questions: (1)
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but the concentration remains above the site-specific remedial action goal. Such plots can also make it clear when continued operation of the existing remedy may incur substantial per unit costs with relatively little improvement in mass removal.
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EVALUATION AND EXPERIMENTATION An essential feature of ASM is that it allows for a change in remedy where the chosen approach is falling short of cleanup goals that takes into account information about other potentially more effective remedies collected during evaluation and experimentation. Information from laboratory studies, on- or off-site pilot-scale activities, expert panel evaluations, literature reviews, or experience from other federal or private sector sites should be assessed on a regular basis to determine if a more effective remedy applicable to the site of concern exists.
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Evaluation and experimentation are integral to adaptive site management and should occur concurrently with remedy implementation. Improved understanding of a site through evaluation and experimentation can reduce the amount of uncertainty associated with the risk estimate, suggest ways to enhance the performance of the existing remedy, and help guide the selection of an alternative in case the remedy is ineffective in meeting cleanup goals.
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INNOVATIVE TECHNOLOGIES (:hapter 5 reviews a variety of innovative technologies the Navy might consider during initial remedy selection, as replacements for existing remedies that have proved to be unsuccessful, or as additions to current remedies to better achieve cleanup goals or reduce cleanup time. Because the Navy identified its most pressing current problems as solvents and metals in soil and groundwater and sediment contamination, the focus is on these types of contamination and applicable remedial technologies, including in situ chemical oxidation, thermal treatment, permeable reactive barriers, enhanced bioremediation, technologies for
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Site-specific analyses of the effectiveness of source removal technologies, including in situ chemical oxidation, thermal treatment, and enhanced bioremediation, are needed to better guide and justify remedy selection. Controlled field demonstrations are needed to evaluate the benefits (e.g., to groundwater quality)
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This approach must be implemented with caution as certain source removal technologies can disrupt microbial metabolism via redox changes, removal of primary substrates, and creation of inhibitory conditions. LONG-TERM STEWARDSHIP Because many remedies today utilize containment and institutional controls rather than treatment of the contaminant source, residual contamination is expected to remain at these sites such that unrestricted use of soil, groundwater, and surface water will not be permitted.
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This includes considering whether there are newly available technologies that could expeditiously lead to site closeout; if there were a more effective remedy available, the user would cycle back through the previous parts of ASM (see Figure S-1~. Other improvements in the five-year review process are also suggested, particularly with regard to the lack of adequate public involvement in long-term stewardship, the performance and capability of the stewards, and the adequacy of funding for long-term stewardship.
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Despite these similarities, to the committee's knowledge adaptive management has never been formally used for hazardous waste cleanup. There is strong support for adaptive approaches already present in recent federal guidance on monitoring and remediation.
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Although many individual guidance documents mention public involvement, there is no coherent public involvement process described in existing guidance or practiced in the field after remedy selection. As part of the Restoration Advisory Board rule development process, DoD should work with regulators, public representatives, and other stakeholders to develop a menu of options for involving the public in the long-term oversight of cleanup programs at facilities where remedies or long-term stewardship activities are continuing.
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Summary 17 widespread adoption, the Navy should consider pilot testing ASM at a limited number of high-risk, complex sites to allow Navy managers to better understand any transactional costs and delays that may accompany ASM implementation.
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