Remediation Process Optimization: Identifying Opportunities for Enhanced and More Efficient Site Remediation

Technical/Regulatory Guideline Remediation Process Optimization: Identifying Opportunities for Enhanced and More Efficient Site Remediation September 2004 Prepared by The Interstate Technology & Regulatory Council Remediation Process Optimization Team ABOUT ITRC Established in 1995, the Interstate Technology & Regulatory Council (ITRC) is a state-led, national coalition of personnel from the environmental regulatory agencies of some 40 states and the District of Columbia; three federal agencies; tribes; and public and industry stakeholders. The organization is devoted to reducing barriers to, and speeding interstate deployment of, better, more cost-effective, innovative environmental techniques. ITRC operates as a committee of the Environmental Research Institute of the States (ERIS), a Section 501(c)(3) public charity that supports the Environmental Council of the States (ECOS) through its educational and research activities aimed at improving the environment in the United States and providing a forum for state environmental policy makers. More information about ITRC and its available products and services can be found on the Internet at www.itrcweb.org. DISCLAIMER This document is designed to help regulators and others develop a consistent approach to their evaluation, regulatory approval, and deployment of specific technologies at specific sites. Although the information in this document is believed to be reliable and accurate, this document and all material set forth herein are provided without warranties of any kind, either express or implied, including but not limited to warranties of the accuracy or completeness of information contained in the document. The technical implications of any information or guidance contained in this document may vary widely based on the specific facts involved and should not be used as a substitute for consultation with professional and competent advisors. Although this document attempts to address what the authors believe to be all relevant points, it is not intended to be an exhaustive treatise on the subject. Interested readers should do their own research, and a list of references may be provided as a starting point. This document does not necessarily address all applicable heath and safety risks and precautions with respect to particular materials, conditions, or procedures in specific applications of any technology. Consequently, ITRC recommends also consulting applicable standards, laws, regulations, suppliers of materials, and material safety data sheets for information concerning safety and health risks and precautions and compliance with then-applicable laws and regulations. The use of this document and the materials set forth herein is at the user’s own risk. ECOS, ERIS, and ITRC shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages arising out of the use of any information, apparatus, method, or process discussed in this document. This document may be revised or withdrawn at any time without prior notice. ECOS, ERIS, and ITRC do not endorse the use of, nor do they attempt to determine the merits of, any specific technology or technology provider through publication of this guidance document or any other ITRC document. The type of work described in this document should be performed by trained professionals, and federal, state, and municipal laws should be consulted. ECOS, ERIS, and ITRC shall not be liable in the event of any conflict between this guidance document and such laws, regulations, and/or ordinances. Mention of trade names or commercial products does not constitute endorsement or recommendation of use by ECOS, ERIS, or ITRC. Remediation Process Optimization: Identifying Opportunities for Enhanced and More Efficient Site Remediation September 2004 Prepared by The Interstate Technology & Regulatory Council Remediation Process Optimization Team Copyright 2004 Interstate Technology & Regulatory Council Permission is granted to refer to or quote from this publication with the customary acknowledgment of the source. The suggested citation for this document is as follows: ITRC (Interstate Technology & Regulatory Council). 2004. Remediation Process Optimization: Identifying Opportunities for Enhanced and More Efficient Site Remediation. RPO-1. Washington, D.C.: Interstate Technology & Regulatory Council, Remediation Process Optimization Team. Available on the Internet at http://www.itrcweb.org. ACKNOWLEDGMENTS The members of the Interstate Technology & Regulatory Council (ITRC) Remediation Process Optimization (RPO) Team wish to acknowledge the individuals, organizations, and agencies that contributed to this guidance document. As part of the broader ITRC effort, the RPO Team is funded primarily by the U.S. Department of Energy. Additional funding and support is provided by the U.S. Department of Defense and the U.S. Environmental Protection Agency. ITRC operates as a committee of the Environmental Research Institute of the States, a Section 501(c)(3) public charity that supports the Environmental Council of the States through its educational and research activities aimed at improving the environment in the United States and providing a forum for state environmental policy makers. The RPO Team would particularly like to thank the Air Force Real Property Administration (AFRPA) for its support in funding the team’s program advisors: Jon Horin and Patty Reyes of Mitretek Systems. They kept the project focused and well supported and fostered the development of RPO as a valid and viable concept within the states in more ways than they can imagine. The team recognizes the following states’ support of team leadership and guidance preparation: • New Jersey Department of Environmental Protection—Tom O’Neill, Team Leader • California Department of Toxic Substances Control—Ning-Wu Chang, current member; Mark Malinowski and Laszlo Saska, former members • Florida Department of Environmental Protection—Bheem Kothur • Georgia Department of Natural Resources—Christopher Hurst, current member; Madeleine Kellam, former member • Maine Department of Environmental Protection—Robert Syptikowski • Oregon Department of Environmental Quality—Jill Kiernan • South Carolina Department of Health and Environmental Control—Sriram Madabhushi The team would also like to recognize the excellent participation from various federal agencies and other public institutions: • Los Alamos National Laboratory—Diana Hollis • U. S. Air Force—Don Gronstal, Rod Whitten, Javier Santillan, current members; Jeff Cornell, former member • U. S. Army Corps of Engineers—Dave Becker, Judith Leithner • U. S. Department of Energy—Jaffer Mohiuddin, Beth Moore, current members; Rich Daily, former member • U. S. Environmental Protection Agency, Office of Superfund Remediation and Technology Innovation—Kathy Yager • U. S. Navy—Tanwir Chaudhry, Karla Jenkins, Laura Yeh, current members; Amy Walker, former member i We would also like to recognize the efforts and varied perspectives provided by the members, former members, and interested parties representing industry: • Robert Bacher, U. S. Filter Operating Services, Inc. • James Cashwell, MACTEC Engineering and Consulting, Inc. • Bud Johnson, Remedial Operation Group, Inc. • Mark Kluger, Dajak, LLC • Peter Rich, GeoTrans, Inc. • Tess Rottero, AMEC Earth & Environment, Inc. • Russell Sirabian, Battelle Corporation • Charles “Chuck” Whisman, Groundwater & Environment Services, Inc. All parties who contributed to this document—whether named or unnamed, be they team member, interested party, independent reviewer, or ITRC staff—are thanked by the RPO Team for their efforts. Some made major contributions to the project; others were able to make only minor ones. All are appreciated for their time and effort. ii EXECUTIVE SUMMARY For the foreseeable future, federal, state, and private-sector organizations will continue to spend billions of dollars on the characterization and assessment of contaminated environmental media and on the selection, construction, operation, maintenance, and monitoring of environmental remediation systems. As the various environmental cleanup statutes and their implementing regulations evolved, the initial assumption was that these programs could follow a basic “study, design, build” linear paradigm. However, years of experience has led to the realization that the significant uncertainty inherent in environmental cleanup requires more flexible, iterative approaches that manage uncertainty. Uncertainty, as demonstrated by frequently missed target dates, has forced the development of mechanisms that allow for both the systematic reevaluation of initial objectives and the continuous improvement and optimization of remediation technologies and techniques. These mechanisms and reevaluations are known collectively, or generally, as “remediation process optimization” (RPO). The Interstate Technology & Regulatory Council RPO Team developed this guide to respond to that realization. With schedules for projects in the operating and maintenance or long-term remedial action phase frequently being measured not merely in years, but in decades, RPO is not an just option, but a necessity. In the initial stages of a remediation action, much of the effort is on characterization and source remediation; limited effort is spent on monitoring. As the project matures, most of the resources are spent for monitoring and operations and maintenance (O&M). Figure ES-1 depicts effort and cost vs. time for a typical conventional remediation action

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