At this point we are ready to kick off the session. Today's first speaker
is going to be Dave Becker.
Dave is a geologist at the U.S. Army Corps of Engineersm,
environmental and in addition to center of expertise. He has a
total of 35 years of experience in environmental restoration field.
His focus areas include institute remediation technologies
and remedy optimization. He has the primary architect of the remediation
center evaluation optimization process.
He has participated in well over 60 optimization of
studies for Army, Air Force, EPA, DOE and NASA over the past 20 years.
I would like to handed over to Dave. You may
start your presentation.
>> Thank you very much, Cindy, I hope
everyone can hear me okay. It is certainly my pleasure to speak with
you all today. This topic is near and dear to my heart. That is a
remedy optimization. I'm going to talk about the history and evolution
of remedy optimization
of some of the federal agencies, and spend most of my time talking
about some of the lessons learned in observations that I have had
over doing these kind of optimization sites for 20 years.
Then I will put on my visionary hat and look into the
future, and identify issues and trends that I think will
be important for remedy optimization going forward.
Cindy, my computer is lagging. I hit the
forward button and it is spinning.
I am presuming that you can see my slide on the presentation
overview.
Was that Kirby?
>> Yes, I am seeing it.
>> Reporter: Okay thanks, Kirby.
I will start with the definition of optimization
and talk about the history and
evolution of federal optimization protocols,
and approaches.
I will spend most of my time talking about some of
those lessons learned in observations.
I have categorized them by six categories as you can see on the slide. I will
finish with those future trends and prognostications that I would
like to have.
Hopefully your advancing when I press the arrow key.
Always a good place to start is with the definition of optimization.
I have shown here one definition that I particularly
like. It is marginally taken from the EPA definition of optimization.
It is really anything that we do to identify and make
happen efforts to improve the effectiveness
and cost efficiency of the remedy that we are responsible for, including
trying to speed containment of closure or
the endpoint.
You notice that it really doesn't say we are trying to find the optimal
remedy, but we are trying to improve the remedy. We are really
trying to get to the good. Maybe not necessarily
the optimal. That is okay, because in a lot of cases the optimal solution
for anything is right on the verge of failure. Maybe the good is actually
a little bore -- more robust than optimal. The take-home point is
that you talk about remedy optimization, I am talking
about a process that tries to improve what we are doing. It is not a one
time shot, it is a multiple time shot.
I just want to talk about the history
for remediation optimization among the federal agencies. We have a
long history of cooperation, and collaboration among the agencies.
EPA, the DOD services, the DOE. It has
been very productive, I think.
Early on when we started talking with each other we realized we were
working toward the same goal. We actually,
this is a late 90s and early 2000's, we invited
representatives from some of the other agencies or services to participate
in some of the cities that we were actually doing. It led to some long-term
friendships among the people involved.
I still consider a lot of friends from that effort.
That give us the opportunity to cross pollinate and
share good ideas, and identify tools that were really
useful for optimization.
It culminated early on with a couple of optimization conferences.
One was in 1999 and another in 2004 that was a follow-up.
It brought together not only the federal
agencies, but also people from the state agencies, the private sector,
consulting world, everybody talking about things that were
related to improving our remedial approaches. Those were very good
conferences. I should point out that I have provided some links
to the proceedings for those conferences, as well as for a number of other
references and guidance documents I talk about in the presentation.
I will go on now to slide 5.
Beyond the earliest part of the 2000s we started to evolve
with our optimization.
One of the first critical things was the development of the interstate
technology and relative -- -- regulatory counsel of the mediation
process optimization team or ITRC, back in 2003. A number of
disciplines and optimization were part of the team, as well as some
very talented people from the states, particularly New Jersey, Georgia,
California, and a whole bunch of talented people from the private
sector and academia that they got involved. We prepared some
guidance on conducting remediation process type optimization. As part
of that, the clear consensus came out,
some commonalities included the need for an independent expert
team to do the optimization. A fresh set
of expert eyes, basically. Another key point was that the optimization
should look at all aspects of the remediation. Everything
from the technical details, dosages of chemicals, operation
of pumps analytical usage, to the reporting for the monitoring and
analytical, to the project management, to the contracting
approach even. A very holistic look at different ways we can improve
things. The review should be balanced.
It shouldn't all be about cost.
It should be just about saving money.
It should be a matter of improving the effectiveness, as well as reducing
cost. There is a balance there.
That was very important that everybody recognized. That was a
great effort.
I have a link available for that guidance. Beyond that,
there were additional collaborations with the federal agencies, the EPA
and the core of engineers collaborative on preparing
some guidance on long-term monitoring optimization back in the mid-2000s.
EPA, the Navy and the Corps of Engineers collaborated on some DOD
funded demonstration projects for monitoring optimization, as
well as transport modeling optimization tools that were
very successful. Again, the collaboration
proceeded and evolved over time.
Going onto slide 6.
There was continued evolution of the optimization approaches
in the late 2000s and into the current decade. It certainly became
obvious to folks that optimization extended beyond the
post construction operating remedy kind of focus that had been
there. That was the focus early on.
Things like the triad approach for optimizing your site characterization
effort was really part of the optimization family. There was
recognition that there should be an exit or closure strategy for
these sites, the roadmap on how to
get to where you want the endpoint to be for your particular site.
There is a fact sheet repaired by the ITRC
optimization team on making exit strategy documents. That is
a good reference. Another recognition was that there should be
an evaluation of the conceptual site model. This
validates the need for independent team to look at the
stuff. A fresh set of eyes can often come in him a look at the data,
develop a conceptual site model that doesn't necessarily take for
granted some of the things that may -- maybe the product that --
project team was looking at or swimming.
Maybe change the way we view the site.
That often makes a big difference in the performance of the remedy,
and the cost of the remedy. And also the success of the remedy.
Looking at the conceptual site model became a fundamental part
of the EPA and Air Force in particular, there optimization
approaches.
There was this evolution to look at optimization throughout
the lifecycle of the remediation project, from
characterization to remedy selection, to design, to construction and
on into remedy operation further down the road. EPA has certainly
taken that to a very high level and you will
hear more about that from Kirby Biggs.
One thing that came up since the middle of the 2000s,
particularly in the Department of Defense, was this real emphasis
on conducting, or contracting with, what is called
performance-based contracts. Rather than telling a contractor what and
how to do stuff, you would tell the contractor what you wanted to
end up with, what your goals are within the timeframe of the contract.
Leave it to the contractor to use their own
innovation, their own innovative thought to come up with an optimized
approach to achieve those endpoints.
There would be some metrics to monitor their performance.
That really changed the way optimization was looked
at, because now rather than having an independent team coming in from
the client side, you really were putting the emphasis of optimization
on the contractor. We will talk more about how that played out in
a little bit. If we can go to slide 7.
I want to shift gears and focus on these lessons learned
and observations. The first thing I want to start
with is the good news. That is that the optimization efforts,
both at the federal level and I'm sure the state level, and even for
private clients with our consultants, we are having an impact.
What we have found over the recent years is that the project teams
that we interact with our very well aware
of some of the new technologies, some
of the optimization approaches and even some of the optimization tools.
Our tech transfer efforts with webinars like this and others at EPA and
the ITRC sponsor are really
having an impact. That is good news.
Another thing I run across with the project teams is that many of
them have internal processes to conduct optimization at the grassroots
level. They periodically do brainstorming sessions
and look at maybe bringing in fresh people from within their organization,
or others within the consulting firm, to actually do the brainstorming
to think about ways to improve it.
I am all for that. The solution shouldn't be a top-down kind of
thing. That is a good news item, too.
I would say that the most common type of optimization
conducted in my experience, by the project teams, has been monitoring
optimization. The word has really gotten out
on that in terms of looking at the monitoring frequency, location,
network, analytical methods, sampling methods, all of those kind of things.
People have picked up on that and that is good.
Another good news story, and this is true going back to the early
days of optimization. In my experience, the operators and others responsible
for operating optimization are
generally very well qualified and very diligent in doing what they
need to do. Most of the sites that we visited
have been well maintained. I can tell
you some entertaining stories about a few exceptions to that, but by
and large I have been impressed with the people who are responsible
for operating the remediation's.
Lastly and probably the most important good news is that, many of the recommendations
from optimization studies that have been done, that I have been
involved with, many of those recommendations have been implemented. Real cost
savings and real improvement and effectiveness and
protectiveness have been recognized.
That is the bottom line. Kind of an interesting sideline, just
yesterday I was looking back at two optimization studies at a
site that I had done previously. I was looking at the recommendations,
and doing another optimization at the same site 8 years after the
last one, to see what they have done. And a lot of the recommendations
have been implemented. I think that was very
gratifying to me. We will go on now to slide 8. I'm going to
get into some of the other lessons learned topics. In the first category
I want to tackle technological issues.
One of the big things I have noticed
is that, for the larger remediation systems that have long-term active
remediation, pump and treat, SP, a lot of the systems have been out
there for 10. 20. 30 years and some of the equipment is approaching
their design lifespan. We are
dealing with aging infrastructure. The
nature of our optimization is now starting to look at what makes
sense to replace, in terms of the equipment, or
is it a good point in time to think about doing something completely
different? The economics are different, and that is something that needs
to be considered.
Another technological change over the last 15 years is this a dramatic
shift from active to traditional remedies like pump and treat to
in Situ remediation technologies.
A lot of the size that we do optimization studies have had some kind of in
Situ remediation applied. The problem is that our intimate -- imitation
of some of these injection technologies with different amendments
have been less than perfect.
We have some successes we have had some failures. We have some
ways to go with improving our understandings and these
in-situ technologies, particularly develop -- delivery systems.
We are not providing enough amendment, or just other
kinds of mechanical failure issues.
I'm happy to note that interstate technology and regulatory
counsel has a new team this year.
It has been very active at developing guidance on optimizing injection
type technologies for mediation. Hopefully
that will help address that need.
There's been an evolving recognition
that, at many sites it is going to take a long time
to attain some type of aggressive cleanup goal,
some very low levels. The recognition now is that it may take a treatment
train, a temporarily available or evolving application of
different technologies and sequence in order to most economically
bring the site closer to closure.
Usually we end up with some phase of monitored natural
attenuation. This typically involves some kinds of aggressive resource
treatment or some other mechanism to greatly diminish the mass discharge
or mass flows from the source area that
makes other technologies, including monitored natural
attenuation more economically feasible and viable. The real word nowadays
is to have multiple
technologies applied at the sites.
We recognize it is going to take time.
One other issue I would like to bring up that is kind of a pet one
of mine is, some of, I hate to call it a flaw a kind
of is, with our feasibility study approach. Usually in looking at
a lot of feasibility studies, the authors
present the different technologies as having an equal likelihood of
attaining whatever goals you have.
In reality, different technologies give you
different degrees of certainty of attaining those goals. There are
some that have a higher likelihood of attainment
than others. Unfortunately, usually,
those that have a higher likelihood also cost more.
By basically saying that all the technologies have an equal chance
of attaining the endpoint, the decision-makers end up making the decision strictly
on cost. When in reality, there is a trade-off between cost and
certainty. Maybe for a modest increase
in cost weakened by a significant increase in certainty of attainment.
Particularly where poverty transfer considerations
come into play. That may be important to the decision maker. That is something
I think we can do in it better job on. Going to slide 9. The next category
or characterization -- I am a geologist
so this is important to me.
We have found that a lot of times the conceptual site model has not
really been updated, and it doesn't, in some cases, take into account
some data gaps on the actual extent of contamination. It doesn't consider
perhaps some other exposure pathways that may exist, most notably vapor
intrusion.
I think there is, again, some complacency
that may be some project teams have, and they don't take the opportunity
to integrate new information to update the conceptual site model.
That is for optimization can really help. This certainly is a validation
for the need of the expert team to take a look
at this.
The net result of not having a good conceptual site model and not
have a complete characterization is you often pay a penalty in cost
and performance. By addressing these kind of things we hopefully can
improve both cost and performance.
In particular, the teams need to be encouraged to
look at what operational data tells you about your system, and
update your conceptual model accordingly, and adapt. One of the
things that helps us now that is available, and I say increasingly
used, is high -- -- direct push technologies, membrane
interface probes, laser-induced fluorescent probes, those kind of
tools in the last 20 years have really helped us do a better job
characterizing, particularly the vertical distribution,
of contaminants and the lower cost helps us have a better network to
address the distribution laterally as well. That has helped us make
better decisions and optimize some of these remedies after the fact.
That should hopefully cut time off the duration of these projects.
One last thing, in terms of characterization, is I still see sites where the project
teams have not considered some of the emerging contaminants. I still
see sites where try correctly is present, and they haven't looked
for one 4-dioxane. There is fire training
or something where the fluorinated compounds have not
been evaluated. That is an area where maybe we still need to do
some technology transfer.
If we go to slide 10 now. I want to talk about what
I call people issues. One of the things that is important with optimization
is that the optimization team needs
to approach the study with great respect and packed towards
the project team. There is a natural sort of
apprehension on the part of the team. They kinda
view it as an audit and maybe there's going to be negative consequences
for them. But really, we have to be very positive,
forward-looking. It doesn't matter how they got there, let's work together
to try and move it forward. That should be the attitude with that.
We should reassure the project team that it is normal to have to modify,
or remedy.
Things are going to change and we have to adapt to that. As a matter
of fact, the real buzzword now a days is
adaptive management. That is really what we want them to do.
Changing stuff is not an admission of failure, it is just a natural
consequence of our progress towards closure.
Another people issue has to do with how to motivate them to implement
the recommendations that the optimization study may make.
What we have found, at least from a programmatic
level, is that having some means of following up with the project
team usually involving people from higher management, or higher headquarters,
is good motivation for them to take the recommendations seriously.
Usually maybe a year or two after the optimization study, just to
follow up and see what they have done. That goes a long way. These
recommendations also have to be backed up with the commitment of
providing funding to implement them by management or the clients.
There is a responsibility on the part of the optimization team
to provide realistic estimates for implementing the remedy.
If they are way off, the project team could make bad decisions
if it was cost-efficient to make the remedy.
One last people issue, maybe it is because
I am getting old, but I see that a lot of the folks that I know that
have been very involved in the optimization field are nearing retirement age.
I have not seen as many young people coming in behind, or
being meant toward to take our place.
I am a little worried that some of the
experts we have now are going to retire, and we may not have a pool
of people that can comprise those independent
teams. Let's go to slide 11 now.
One other is you category is
with contracting. I mentioned the performance-based contract before.
Again, this is where we have moved the optimization
responsibility onto the contractor.
There has been difficulties at some of the sites I have looked
at, where the contractor has implemented the technology
that is not performing as well, and they are getting to the end
of the period of performance of the contract. The customer,
the Department of Defense is going to end up with something that
is not what we really want it to end up with at the end.
Inheriting additional liability at the end of the contract that
we didn't anticipate is disappointing, to say the least.
There has been maybe a poor job at writing our
objectives and metrics on the part of some of the federal agencies.
We are still learning how to do that. I think we still have a way
to go, in my experience with that.
In a lot of cases, again, the decision about the contractor to do the work
has been made a lot of
times only on costs, without really looking at the technical risk or
uncertainty that I made --
mentioned before. The independent optimization
still has a role where performance contracting is done.
The independent team can comment and evaluate the likelihood of the
contractor that is going to meet the performance goals at the
end of the contract. They can also identify options that may
cede ideas by the contractors to make better proposals on the next
contracting round. There is still a role I think for independent
optimization to be done.
There are other incentives to
optimize, besides performance-based contract.
Cost sharing, savings, those kind of -- sharing
might be a way to do some of the same kinds of things. If we go now
to slide 12.
The last category is related to exit strategy.
I mentioned how that is important to have, but there aren't many good
examples to share out there. I mentioned the ITRC fact sheet on exit strategies.
There aren't a lot of examples to share.
I will point out that there is a couple of documents that the Department
of Energy specifically, specific Northwest national labs, have prepared
one on -- the other on property. These are transmission
and closure guided through the basically layout some decision luggage to
take the active remediation from where it is to where you wanted
to be. That would really support some exit strategy development.
There are links to those documents provided with this training course.
Certainly, our decision documents, or records of decision,
or permits, need to account for this adaptive
management, the sequential application of differential technology, or even
an application of contingency technology if something doesn't work. We need
to have the flexibility to do that, to avoid some of the costs
associated with the administrative changes that would be necessary
in the case of a non-flexible decision document.
We also would like to see I think more
flexibility in setting but our
ultimate end goals are, recognizes -- recognizing
site conditions. That is somewhat controversial topic
and it is something that would probably have to be worked
out site by site. One last thing, in terms of the exit strategy, is
that the management, whoever is responsible
for paying for the stuff, really needs to make it clear what their
overall problematic strategies. I can always
say you can have a cleanup that is fast, you could have one that
is cheap, but you can't have it both ways. Usually it is either
fast or cheap. Some management may want to delay expenses, push more
cost out into the future to minimize their
outflow cash now.
Others may want to get it off the books as quickly as possible for
property transfer, or for closing out environmental info -- liabilities
on their balance sheet or whatever.
That has to be made clear to the project team. It has to be made
clear to the optimization team.
That needs to be may be clarified in a lot of cases. Again, there
is a trade-off in costs and benefits with these
kind of things.
One thing that I will point out that I struggle with on a lot of
sites, is that there is a trade-off.
The effort that is applied
to more aggressively trying to remediate
the site, and the duration of the remedy, so you
are spending money now to save money somewhere far in the future. Trying
to quantify the change in duration of the remediation, therefore
at the change of preps cost, is very difficult. It usually involves
modeling. It often has big error bars. That makes the decision even
more difficult. Let's go to slide 13. I
want to look forward with a few observations.
As I mentioned before, I think one of the
things we are going to deal with more and
more with optimization, and our remedies in general going forward,
is just dealing with the aging infrastructure I mentioned before.
Sometimes replacement of equipment may be a good opportunity to maybe
change your overall approach to the site. It might be a good time
to do that. In other cases we may have sites that are quite mature,
and where the concentrations we are observing have plateaued
above our cleanup goals. It is a good reason to start thinking
about something else that may take us to the next step, or to have
some alternative management strategies for those plateaued concentrations.
I think we need to do a better job, and I think we will
see more of this looking at other natural attenuation processes.
Other than anaerobic degradation of petroleum
hydrocarbons or anaerobic degradation pathway for chlorinated solvents,
looking at natural processes that are abiotic,
reactive mineral things,. Or say co-metabolic,
those things should be kept in --
I've made a lot of observations about those
very things. We need to get the word out. I think we will get the
word out and that is going to become more prevalent going forward. We
need to start thinking for these long-term remedies, these large
sites with high concentrations that have centuries of duration to them.
We need to think about what climate change may me to our in permitted
remedies. I know of at least one site where modeling
had evaluated the impact of the projected changes
in precipitation in that area on a long-term groundwater pump
and treat system.
I think we may see more of that consideration, going forward. I
think we are in an exciting time for the availability of
conversational power. We are going to see an increase in the use of
more numerical, formal optimization tools and techniques. The availability
of high-performance computing and massively paralleled cloud-based
computing puts into the hands of our project teams some tools
that can do some really serious numbercrunching to give us an optimal
solution, or approach, for a particular
site. I think we will see more of that. As
a matter of fact there has been a number of demonstration projects
that have been looking at these things. I point out one research
effort under the STD see project by Jack Parker, where some optimization
models have been done in order to optimize the transition
and that adaptive management approach, switching between different technologies.
When is the best time to do that?
The tools are out there and our computational tools are
available. I think we'll see more of that. We can go now to slide
14.
I wanted to point out that some of the things that are older
are kind of new again. Things like pump and treat
kind of thrown on the waist heap a while back. There's been some
interesting things done by Arcata's for example, looking at
aggressive pump and treat extraction and injection, particularly
forcing flow perpendicular to geologic fabric or flow directions, that
can really enhance and speed the remediation of the
sol face plumes. I am seeing a lot more consideration of permeability
enhancement to aid in the delivery of amendments at institute technologies.
Both type size. Making it possible to inject
more amendment over a broader area. I
think we are going to see that going forward. As I
mentioned, it is going to be important that we really
develop our next generation of optimization experts. I really am
pushing for people to find talented young professionals that can be
mentored to follow in our footsteps.
And that our organizations, whether it is
a government agency or a consulting firm, or a private firm with a
portfolio site that they manage, there should be some value
placed on technical expertise. That should be developed.
The more sites our young people see, the better they will be at
that. The more you see, the better you are.
In the second part of this FRTR
presents series you will hear another presentation about this,
but I think for agencies and companies that have large portfolios and fights,
doing optimization studies at individual sites, doing them in
detail at a modest expense will take a while to look at a lot of
sites. Looking for ways to apply optimization
concepts to more sites, more rapidly and at lower cost, is something
I think we are going to see more of. I have been pushing that within
the Army. I think we will see more of that. It is something to take
note of. Moving to the last slide, I just want
to summarize.
Federal agencies have had 20 years of cooperation, collaboration,
process pollination, to come up with some
good optimization ideas and tools that have been shared with the
private sector. I think the industry as a whole has
really benefited.
I think that our optimization efforts, certainly at the federal level and
I think it other levels, too, have really had an impact. I think that
is a good take-home message.
I think that optimization has changed as our technologies have developed,
and our industry has changed. It really has a good role in improving
and -- on
what we do out there. I think agencies and companies need to look forward
to making sure that we have the human resources
that we need to do these kind of optimization studies in the future.
And to apply them may be more rapidly at more sites in their portfolios.
With that I would like to take questions.
>> We had just enough time for a couple of questions. I want to
remind you to type your questions in the Q&A pod in the lower right-hand
side of your screen. Thank you, Dave. The first question I have
for you, they would like to know if you
could comment on if you have seen code generated contaminants that
influence transport properties, such as VOCs affecting
nuclear transfer within your optimization studies.
>> I have done some work at
DOE sites we had some mixed waste.
I'm not sure that I saw any influence on their transport properties.
I am kind of interested, as a
side note to this question, interested in the interaction of the radioactive
decay products with the contaminants, the other contaminants.
There is some indication that there may be some very slow but measurable
impacts there. I have seen
code disposed contaminants having affect
more where you have petroleum hydrocarbons disposed of with, chlorinated solvents.
The chlorinated's are actually in oily Hydro
carbon and Apple was kind of a variable density that
is -- has affected their transport. That
is mates for some difficult cleanups.
One site I am working on now is definitely an issue there.
I am not sure if I'm getting at the
heart of the question, though. Maybe they can ask a follow-up.
>> Or take it off-line.
>> Or, take it off-line. Good point, could be.
>> Cindy, were there any
other questions?.
>> Yes I have one more question for you. Can you discuss if
you did as part of your optimization studies, did you have
a survey to decide on closure and future use question mark if you
did, what are the aspects for the monitoring program. What are special
aspects for the monitoring program for the final survey?
>> I am trying to figure that one out. Can you repeat that question
by the first part again? The survey?
>> Would you do a type of survey on an optimization project
for a site to determine what the closure
and future use will be of that site?
And what kind of asked asked you look after
that?
>> We certainly ask the questions of the project team and the project
manager, or the person responsible. What is the ultimate and use for
that property? We take that into consideration in terms
of our recommendations. That certainly affects timeframe and exposure routes,
and those kind of things.
It is a line of questioning often and formal at a site we often get
those kinds of things.
When we are looking at the monitoring program that is currently in place
there, we consider those kind of things.
Certainly future land use can impact monitoring networks,
buildings over the top of monitoring points have happened.
Making sure you have the right monitoring to address any potential
future exposure, because of site land use changes
or nearby developments, or pumping, those kinds of things, they have
to be flexible. Hopefully I'm getting at the gist of that question.
>> I think that is it.
That is all of the questions we have time
for right now.
Again, I want to remind people that if you have
more questions, go ahead and submit those. Will provided to the speakers
and they can follow up with you later on. Thank you again, Dave,
for the presentation. With that we are going to move on to Kirby
Biggs. There's not enough time to go through all of Kirby's
work history [ Laughter ] he has been with EPA
for quite a while. He is currently with the technology innovation
and field service division of Superfund officer is the national optimization
program manager. He is leading the national optimization team of headquarters
and regional staff, working on multiple site-specific
optimization projects, involving EPA headquarters, regions, states,
and public centers entities, conducting Superfund article
project throughout the Superfund pipeline using targeted investigation
radical support, and it been a designer view, remedial systems, evaluations,
and long-term monitoring and optimization studies. Kirby also sponsors development
of optimization Internet seminars and develops, or delivers webinars
and classroom optimization courses. He identifies and develops
new techniques, methods, procedures and practices to facilitate the
closeout of sites and return them to productive use. Kirby, go ahead,
please, and start your presentation.
>> I am not sure I can live up to my bio [ Laughter ] hello everybody.
Welcome to the webinar.
I think you'll see in my presentation a reflection of what Dave just
gave us. And validation verification of that
that is true. Many of the things he mentioned are actually observable.
In terms of the team, I am a member of the team. Ed Gilbert is
our team leader.
We just formed and optimization team this past year. It consisted
-- consisted of me, Gilbert, Carlos
and -- was not part of this particular presentation. They are a valuable
and important member of our team.
I just want to let you know that we have in fact organized headquarters
into a teeming concept. One of the objectives is to
manifest what Dave mentioned a few minutes ago, which
is bringing other professionals in. I have been doing this for a
long time. I have been with the program since 2005. I have
been either a coleader or a leader in the past 5 years or so.
As Cindy mentioned, I am reaching my 40th year at EPA
so I will be leaving at some point. Today I
will talk to you first about key elements of the Superfund optimization
program. We will look at how those have developed the administrative
component. We will look at the nature of Superfund remedies.
This is from the remedy selection report, it is the 15th one that
has been done. We have had a lot of time to get that. You will see
some very interesting slides and graphics from that.
They also verify what Dave was saying, that is the
remedy transition. These are from statistics. This is not just an
anecdotal remark. It is a statistical remark.
The findings from the 2017 Superfund optimization report, we did that
last year. You will be hearing about 61 sites for various recommendations.
We did a very formal follow-up with a report that is now available online
at the clue in optimization website. We
will talk about some conclusions.
Let me reflect on what Dave just said, which is, this is
EPA's current working definition of optimization. This is the short
version. A systematic site review by a team of, and this is key,
independent technical experts, at any phase of a cleanup process.
We will see a slight on that and just a second.
To identify opportunities to improve remedy protectiveness, effectiveness,
cost efficiency and to facilitate progress toward site
completion.
That is very similar to what Dave put out there. We have been using
this particular definition for a long time. There are some adds to
it in the national strategy, which was put in place September 2012
-- 2012.
Let's move on to the key optimization
components. Optimization, the early efforts were
back into the process. We will look at a slide that suggests
why that is the case.
When the strategy was put into play in September
2012. the strategy had a submerging upstream,
that is moving the lessons we learned in the backend of the process an
hour early efforts towards the front end of the process, with the objective
of probably working ourselves out of a job, because we can't always
completely work ourselves out of and optimization.
Things still require it later on.
In terms of intense efforts we have been putting in perhaps what is
bringing to the front end of the process will help meet the need
for some of the backend work. You will also see the quadrant chart
on the right. It is the hexagon.
That shows the conceptual site model at the heart of optimization.
That being the key question. If you don't know what is going
on with your site, you might be able to clean it up, but it will
be an accident. You have to know enough about it. We also look at
the exit strategy. The remedy components of the site,
whether they are operating holistically together,
or they are doing their job. We look at the monitoring that is being
done. Is that adequate to understand the site? Does it eliminate the
plumes and so forth. We look at the data management. There has been
a big deal throughout much of our optimization time.
Sometimes you go to an RPM process office and they still have
a big log in the corner of paperwork that they had
to have digitized. We have done a lot of
data management work on that in these optimizations. We used Triad
and many of them. Systematic planning, going into field strategy, measurements,
and then green reading -- remediation, which is of course
foot print reduction and climate resiliency. We will see those again
in just a minute.
We have an actual optimization process. We have a standard operating
procedure. It is 19 or so pages that we follow. This particular
chart shows the process leading from the beginning
of the request for optimization on the left-hand side, the top.
Following through the scoping call, going further to
a kickoff call.
Then moving into the site visit.
After the site visit we have a specific period
of time because this is something I can control, not something that
I have a little control over, which is like when I get comments back.
We follow the process of the kickoff call, the site visit, we
then do a draft report. We do a draft, we take comments on that.
We will do a draft final report.
We have the review of the final report,
final comments, then the report gets finalized. And then those into
a tracking mode.
It goes into the optimization report inventory tracking tool for follow-up.
That is what we will be talking about a few minutes. This standardized
process, you notice it is 2015 that we finish
the start. We have been using this process for a long time. It works
very well.
What do optimization reviews resulting? We look at six specific
things in our optimization reviews.
We look at remedy effectiveness and protectiveness, cost reductions,
opportunities at cost reductions including moving
to alternative technologies is that is a meaningful way of doing that.
Tentacle improvements to the remedy, that might mean and operating system
we might suggest "Well, your green sand is not doing
anything. You might take that off-line.
The key part of this is site closure.
How does this site graduate from the NPO question mark not
just go to the state, but graduate completely to become whatever it
may be after it's finished. That is a redevelopment potential you
see. Green remediation. We are calling that climate resiliency
these days because, should the worst
incidents happen, we are going to need to have our sights hardened.
So we are talking about resiliency on the sites. Three
prevalent concepts that are going along in a third-party optimization.
That is the adaptive site management. Are there things we
can do, are there pathways that we can follow that will speed
the remedy and contribute to the overall remedy,
but that are possibly no-brainers that you could do the beginning
of the process? Also, adaptive site management means to us moving in
the treatment train notion if you're a subtopic on your
primary treatment train them and that you need to move to something
else. Sometimes that means an ESD or conception forests and
-- we look at CSM development. We
look at this as a living document.
It is not just a sharpie on a transparency, then you put
that away, and that is all you do.
As a site moves from stage to stage in its lifecycle process,
the CSM also needs to follow that. That changes.
The use of alternative technologies and approaches. Those are very important
to us now. As Dave mentioned, we have been moving from
exit 22 Institute using injections and doing a variety of new
technologies. I wouldn't -- I call them new innocence that
we are using the new. Many have been using other feels they
are adopting and adapting.
Let us look at the accomplishments.
We have done a lot of work. You will notice
that in the 1997-2010., The 15 years, we did 94 of those
optimization sites.
We are doing 6-8 per year. When the strategy in
2010 was decided we would make a national strategy out of it, and
sort of work with. One of the key components was to pump the volume
up of the optimization. In the 2011-2017 time period we have done 155
of those.
2018 to date is 12. You will notice
that was May 9. that is the date of the presentation.
We are up to about 285 sites now.
I have done 100 of them myself.
We have lots of information about those. Let's take a
look at Emma what have we done to actually
institutionalize this waste programs practice. We applied standardized
processes to the conflict of interest check, the site engagement form,
that is my ticket to ride. People fill that out. That is what you
want, who was involved, what do we need to do?
The scoping and kickoff calls are designed to really put a boundary
on the scope and optimizations that we do.
We do on-site visits. We have an interview guide for on-site visits
that we send out to people beforehand, so that we know what we are going
to be asking about. The report itself has a standardized format. We have
Artie seen most of that with the six parts. It
has developed its reviews to cede this process. We have the
optimization report inventory, a tracking tool, and
the optimization project log. The optimization project log of the
normal day-to-day tracking system that records the scoping call, the
kickoff call, the metric parameters that we track to make
our completion status for the sites. The optimization
report inventory is our follow-up tracking tool that records the recommendations,
the findings, the costs, and follows them up
after sometimes, depending on the extent
of the optimization. Six months, a year, then maybe another
year and a half down the road, to make sure that
the optimization recommendations were meaningful, they were useful,
they worked for the people.
Our cost estimates were, in fact, correct.
Also to ask, is there anything else that optimization needs to
help you with? We have identified process improvements to reduce
cost and time. We standardized in streamlined the report template.
He used to be very long. We have it is no more than 30 pages, usually
15-20. It is not uncommon.
It is much more cut to the chase.
The portfolio, Dave mentioned doing multiple sites at one blow.
We have been doing multiple portfolios down in region 6
and region 10. We haven't been doing the kinds of portfolios you will
see Mike Singletary talk about in the following
presentation, where they did a very large batch of sites. We have been
doing maybe six anytime. We do the more intensive optimization studies.
But we have conducted portfolios earlier on of 30. 35 sites, back
in the early 2000.
We have involved regional management in optimization. That is
really helping because now management knows that we
are there, we are coming in and looking at the site. All of them
are very, very aware of who we are and what our purpose and methods
are. They are very much in favor of that.
Usually we ask our project managers, they are the
ones that come to us, and say we need some help. Sometimes management
will say well, we would like help on this particular site.
The other thing is the staffing realities
that we have. I think most of you know that the site of the
-- has diminished and the availability
of staff has been further constrained from that. The availability
of the contract research is to afford the optimization
pogrom to support -- has turned out to be
a very important recent development.
Other programs are adapting. Our house program,
we have several tribal sites using our optimization resources.
They are using some on their own.
We are currently working with the RFI process,
rapid first, the investigative process.
Helping to learn from them what they are learning about
the first process, which by the way, reduced
their number of steps in their process and investigation by I think 52
to 19 or 17. A significant reduction.
We are looking at the backend of the process and seeing what we can
do to help them. Regions and optimization.
I have a number of regions leading optimization with intent
particularly, region 6. region one, my optimization liaisons, which
I have one for each region. That is my regional contact person.
They are doing their own with my resources.
Providing a broad network of optimization support. We have probably six or
maybe contract resources that we can resource one,
to avoid COI.
The other one can take it up.
Remedial action contractors, we have been using
them.
Support from USACE.
I have a cooperative interagency agreement and
I use Dave regularly to do optimizations for us. Particularly we have been
branching out into some federal facilities recently. Let us look
at the Superfund task force. As most of
you are probably familiar, this task force was put into play as
soon as the administration came in. This is another version
of every administration wants to put their mark on Superfund.
There have been integrative cleanup initiatives.
The one EPA initiative, there have been Superfund reforms. There have
been many things. Now there are the Superfund workgroup and Superfund
task force recommendations. Luckily, adaptive management
is recommendation 3.
Recommendation 7 is a third-party independent optimization reviews.
That is us here in the optimization program. We
feel very fortunate that the value of
the work that we have been doing over the past 20 years has been
called out here, specifically by the task force, and a recommendation
has been made to pump up the volume on that. We
have declared three optimization recommendations. Number seven,
that being, we have done 18 sites under that. We are in the process
of precluding those sites. We brought the lessons learned to those.
We developed a strategic method for picking them out that focuses
on worst sites first. Sites of great complexity, sites
with human exposure not under control, sites with groundwater, migration
not under control. Sites which have large redevelopment potential.
We develop a set of metrics to ascertain
more valuable sites for optimization. You see
the 2017 optimization evaluation, this is a typical year carryover
projects from the previous year.
We start a set of new projects. In this case it is
35. We completed 25 so we had some carryover.
The totally active projects in 2017 were 71.
That is with optimization and technical support. We do larger and smaller
pieces of work. Let us look at remedy selection as a
drive for optimization. The information in this section comes from the
2017 remedy selection report. That is the 15th one we have done.
We are going to look at the number of COC's, remedy
selection review, the pump and treat versus other remedies. This falls
on Dave's information. We are going to look at the transitions.
COC's, very interesting here. It
is about 100%, we are talking about a lot of sites.
1100 that have metals, 1100 that have VOCs.
Almost the same number with S VOCs and there are small amount
of numbers. Interestingly, in this 25% here, these are individuals.
Metals, 149. VOCs are about the same number.
SVE, about a third.
-- Again, very similar numbers, SVOC's, and metals,
VOCs, SVOC's and metals very much the
same. Not much difference. Ones with
all of them is about 52%, or 737 of the sites. There is a very, very
small fragment which are other. Usually
there are mixed contaminants. That usually means mixed technologies
that you have to use.
Let's look quickly at a number of sites here. This is
1540 sites, very large population. We are looking at
1982-2014. For nontreatment there is an a or
NFA, that is 344 sites, or 22%. There were 78 with treatment.
Let us look at treatment.
18% was first control, groundwater and source, 42. Groundwater alone, 18.
The biggest chunk of them, 70%.
There is a scattering of others here.
And a, NFA, and there are groundwater containment
with multiple activities.
The next smaller source is the source container
disposed of is 12%.
Let us look further now at P&T selection. We thought P&T was
a magic bullet.
You can see that, in the very early parts of the process, 85
-90 and all the way into 90 or 91. there
were a huge number of pump and treat systems
selected. That is because we thought they would all be working. We found
that they didn't exactly work as much as we were thinking.
We were hoping that would work better. The question we had to ask
was why. Why would they not be working better? That is where
optimization started to come into this process, looking at that. You
can see with the -- that the pump and treat systems are dropping.
We will look at another chart that shows the inclusive
technology. What I wanted to point out is that we still select a lot
of these. Even though by 95 the numbers dropped, let us
look at 92 -- 82 through 2014. a longer period
of time for groundwater.
The two segments will be looking at our pump and treat with source
control. That would be 61% of our pump can treat
with source control and on-site containment. 10% only with
pump and force treatment, although that number is increasing as Dave
mentioned. Pump and treat resource -- with source contaminant
or disposal, containment at 15.
Looking further along in the smaller segments, you
see a mixture.
P&T and M and a and SVE five Institute treatment
and M and a Mac only. Only 9% of those that
are not mixed remedy.
You can see why there is a need to have optimization, and
why it started at the back end of the process.
Let us look at the trends. This is going to be the spaghetti chart
so get ready. This is in-situ treatment. You'll see that
there is a clear trend upwards through 2014. which is when the stops. There
is a drop-off between 13 and 14.
Next let's look at pump and treat.
I said it was going down. Well, it is going down and it did go down.
It popped back up and it is being used more sparingly. It is
being used in combination with more high resolution
characterization activities that make it more available to selectively
pull contaminants out of the ground.
This is ICs. Institutional
controls pretty can see a big bump in the late 80s, I'm sorry,
the 90s, late 80s and early 90s.
That was when the management assistant group institution controlled
the magic group went out and did a lot of work. It has
only been going up since then. I think a very huge chunk
of the cleanups these days have institution control as their
signature. We've done a good job with that. Let us look
now at SVE. That was
not looked at very favorably in the process. As we have
found that the course of the years, it is useful. It has fallen out
of popularity.
You can see the 2002 timeframe up and down. I am not
sure why these swings are happening.
I think it is partly due to like I said, it's popularity.
It is the view as to whether it is actually a way to
do it. I think we do not believe that is the case, so we will probably
continue to see it bounce around like this. Last two things are alternative
water supplies and vertically engineered barriers. That is the
bottom redline as the vertical engineered barriers. You
can see that that has been bouncing around up and down. We still continue
to use these as a regular feature.
The provision of alternative water supplies has decreased, and then
have plateaued. A very interesting set of trends for
optimization, and a way to see that optimization has been
following, sort of this trajectory.
Oftentimes we will recommend a bioengineered barrier or other
alternative technologies.
Let us turn out to the optimization strategy update. This is the
national optimization progress report. This is our report card.
We had a very good report card I am very happy to say.
We did expand the program.
Now we have about 50 ongoing optimization events per year. We have 20-25 completed
per year.
I mentioned we were moving from the
backend of the process to the front end of the process. Only 14% are
in ON them. Some of them are state Owen M's were
they come in to help the state for a site that is still lingering.
In the remedial action we are still at 50% of that. Removed -- we moved
back up to pre-remedial 235.
64% of the recommendations of the 61 sites, 745
recommendations and you will see that statistic
in a moment. They were either implemented or progress or plan. Another 50%
are under consideration. That is about 80% or so that are
either done, planned, underway, or
anticipated. Only 16% of them are declined. We will look at those
numbers more closely in a moment.
Only 60% showed improvements in the CSM.
Is everyone still there?
Hello?
>> I can hear you.
>> Oh okay, good. I thought I may have lost people. Sorry about that.
Thank you.
39% had improved system engineering.
36% change in remedial approach.
We did technical support we did both optimization and technical
support for a number of events. There is a different
take on these. These are the 600 45 recommendations for the sites.
Effectiveness, 273.
Cost reduction 152. Again, these are the standard
optimization reports areas,
the metrics. Technical improvement, site closures, you can read the
numbers yourself. Green remediation was 32. It is a total of 722 recommendations.
Some recommendations are in more than one group.
Here is another way of looking at this. This is looking
at the tools and techniques that we are permitted. When we look at
the 61 sites, we looked at, what were the things that we found that
we looked at, just a historical perspective.
That would be the CSM requirements.
We looked at -- we had CSM recommendations
for 60% of the sites had streamlined or improved monitoring. That is
something we almost always find as the data gaps and monitoring
improvements that can be made. That would really be more a lot about
the site.
We are talking about 39% with improved system engineering. Another 36%
changes to remedial action approach.
That would sometimes generate -- deviation. Or
lot amendments, moving from one technology to another.
The use of strategic sampling is increasing all the time.
Improved data management, as I mentioned, that is one of
our focus areas. A full jump of those got improved
data management. And the use of combined remedies, where we would
recommend yet another remedy or modification to remedy.
That is a percent of those cases.
Let's take a quick look.
I will go quickly through this.
Implemented, 293. in progress, 76%, planned, 7%.
That means they are going to be doing it. They are thinking about
it and another 15%. Then we deferred to the
state, if the state was in the operation maintenance business, the recommendations
would be to forward to them.
Declined. You might say well, why would they do that? Often
times in optimization reports you will describe
two paths forward, a path a and the path be. Passé has recommendations,
path B has emendations. If you take path A, you don't do the path be
recommendations. Even in some of these declined recommendations a
number fallen to those calendar -- category not relevant.
Then there is a small and a different fraction. Let me continue to push
on through.
This is just looking at another piece of this. It
is the same numbers, 14% and Owen M, remedial action 37. The
key thing here is the prelim Arial -- pre-remedial
we are up to 20% now. 21 and 14% or RF system design respectively.
Okay let me quickly talk about a new development
going on here. I know I am running low on time.
We have the remedial action framework.
This is our new contract mechanism that we will be going through national
contracts. The three design and engineering services,
remediation environmental services contract, that is the remediation.
The RA contract and the environment
all services and operations.
And each of these contracts, there are similar language point that
is requiring optimization that the contractors will consider
and to the extent EPA apply optimization activities
for all contract activities. We haven't figured out exactly how
this is going to work yet. We
believe that is going to generate self optimization
to a larger extent. We are hoping for that.
Again, the similar requirements for the third-party optimization
activities, third-party optimization on projects they have
requested.
Just to reflect back on Dave's comments, this is an old chart
and probably not up-to-date. There is optimization policy.
Except for DOE, although they have a lot of
optimization work going on.
Each of us in the services has our own optimization approach,
which is very similar. I wanted to just show that
we are all working collectively on our optimization. Let me conclude
by just saying that optimization is a very mature effort. We
have done, my boss and I, have done work with public administrators.
We have done a lot of work to standardize the process to make
it underpinned with the actual infrastructure
that one needs to operate a government program. We are moving
that program, disseminating it from headquarters, distributing
it down into our regional offices, and seeking to improve
the contractors abilities to produce optimizations,
independent self optimizations.
We are acting on our findings.
Dave was saying how he goes out and he hears how
people did the work, and he is really heavy. We are, too. We can
prove it because we have a report.
We have done the statistical analysis of this. Again, we are seeing remedy
effectiveness, increases, very significant benefits on that. Cost reductions,
I can confidently say that I have saved hundreds of millions of dollars
through the optimization program for EPA.
On one side I saved $19 million.
On another site I saved nine. My program has cost about $11 million
since 1997. when it started.
And that one site I paid for my entire program. I am pretty happy
about that.
We have made significant technical improvements. We have closed sites.
We have made some significant advances on some
sites in really moving them along.
I don't want to forget about what
we call green room remediation or footprint
-- footprint reduction, because that will be important later in
our lifetimes. We are not expecting optimization to do anything but
have continued support, greater integration, growing. That is our
intention. I just want to point out that the task force did recognize
many of the great works that all of us,
Dave, Mike -- Mike Singletary, the EPA people
have been doing over the years in developing our
new and very spiffy techniques.
With that, let me just say that there are plenty of
resources. You can go to the website, we have progress reports
on limitation. That is the report, the annual report I
was talking about.
The Superfund remedy report, that is actually on another
page in the cluin.org
website.
If you want to talk to me, you can call me at this number. Or you
can write me at this address.
Let me just go ahead and say, again, there's the
epa.gov/superfund. You
can also reference the cluin.org page.
I will open up the floor for questions.
Thank you for listening.
>> Thank you, Carly. If we have more time for questions at the end,
we will take those. You guys can go ahead and type them
into the Q&A pot. We now need to move on to our next speaker. Our
next speaker, thank you, Kirby.
>> Thank you, Cindy.
>> Our next speaker is Michael Singletary.
Mr. Singletary is a registered professional engineer with 20 years of federal
and private sector experience in soil and groundwater remediation
and environmental engineering.
He supervises, design, and implement site characterization and restoration
programs, addressing the requirements of a variety of regulatory programs,
including -- he collaborates with the scientific
and engineering community to conduct applied research on
innovative soil and groundwater remediation technologies, and to
develop and promote technologies for site restoration.
Mike specializes in contaminated groundwater and transport
processes, environmental risk management, some service -- fuel hydrocarbons,
mediation technologies and molecular biological tools.
Mike, I will let you start your presentation, thanks.
>> Thank you, Cindy. Thanks for inviting me to give this presentation
on the Navy's portfolio optimization work
that we have been doing over the past 3 years. I want to acknowledge
-- -- and the subject matter experts within
the Navy that has been working on this program for the last years.
We will be doing additional rounds of these portfolio reviews. I will
focus on the first round that we have done. As Dave and Kirby alluded
to in the overview, the focus of these portfolio reviews
is to shift the focus from the individual site
and look at groupings of sites, or multiple sites, and hopefully
from that we can draw on certain common findings and themes that
we can use to drive future optimization efforts, and
also policy and guidance and training for our RPMs. That is we have attempted
to do in this first round. Today's presentation is really in the context
of complex sites. The sites that we looked at were really targeting
the complicated sites, large chlorinated solvent
five, large and one Apple site that
we base the selections on cost to complete, or the total lifecycle
cost. As well as the remediation timeframe. Those that are being
pretty good proxies for picking out this subset of complex
sites. I will talk about the sites in the -- and the challenging they
pose to the Navy's cleanup program.
Finally I will touch on adaptive site management. You have turned
that term mentioned in the previous speakers.
I will give an example of a site we have done some
of that, the site management concept, even though we weren't necessarily
starting out under that framework. We adapted and optimized
the site over a long period of time.
I think able give some examples of some of these concepts for adaptive
site management.
The site I'm going to talk about is in Texas.
Dave did a good job of outlining the optimization the history that
went into the federal facilities and other government agencies
in the late 90s and early 2000's.
The Navy developed guidance documents starting about that time.
We have three different guidance documents, one for optimizing remedy
selection, optimizing remedial action and
-- we also have an overall policy for optimizing remedial
actions and Navy sites. The policy first
came out in 2004 and we have updated it over the years
to incorporate new concepts, such as green remediation, and now with
this new portfolio round of reviews that we are doing as well.
This slide gives you a snapshot of our cost to complete,
or CTC. This is basically the lifecycle cost for the Navy's environmental,
entire environmental restoration
program. The large pie chart on the left represents the total cost
breakdown. Our program is about a $4.5 billion program.
The smaller pie charts
on the right are broken down by installation restoration program.
That is traditional soil and groundwater type contamination, which
is what I'm going to focus on today.
It also includes the munitions response program. The
breakout of cost for those two
programs is product approximately $2.5 million
for the IRP and about 2 billion for the MRP. For a
total of $4.5 million. In terms of the total number of sites,
again, the chart on the left shows the sites for the overall program,
including the ammunition sites.
If you look at the pie chart on the top right, that shows just
the IRP sites. What is interesting is that
the blue and the green represents sites we have already achieved site
closeout, which is cleanup and points to unrestricted
use, or to response complete, which typically involves closure with
some form of institutional control on the property. If you total
those up, that is about 86% of all of the
sites. What we are left with at this point is this subset of sites
that are in active cleanup or long-term monitoring or remedial action operation.
That is about 13.5%.
We have made a lot of progress in getting to closure, but these
last sites, these last 13.5%, it is about 550 sites.
It represents a couple of different baskets of sites.
One of the complex sites that we know we will be doing long-term
management on. There are also newer sites coming into the program that
are lower risk in the way we sequence the initial work in the
program. We addressed the high risk sites first. There are some
lower risk sites that are accounted for and that 13.5%, but most of
the funding in most of the sites are what I would consider
to be more complex sites. We have heard a lot in hearing more about
"complex" sites and what it really that means and how you define those.
Folks have different interpretations.
I think the bottom line is that, at least
for the Navy's program, most of our straightforward sites have been
addressed largely. We have been able to close those out either
in an unrestricted land-use scenario, or if we need
to put institutional controls, we have that ability as well.
We are devoting our funding and resources now are really on these
larger complex sites.
We are going to have to manage them over a longer period of time. A
lot of what we found in our own program mirrors
what we have reported in 2013 as part of the national research Council
report on the state of the nation's cleanup program. The estimate roughly
10% of the sites are "complex".
That definition of complex really means that they are not going to
meet cleanup objectives in a reasonable timeframe. The cost to remediate
all of those sites across the nation they estimate to be around $127
billion. I think the bottom line is that
for these complex sites we need to be thinking about alternative
ways to manage those over the long-term.
Things like adaptive site management appear to be a reasonable approach
to take for the sites.
A couple of quotes from a document that I think
definitely apply to the Navy's cleanup program,
in terms of achieving site closure is that document states that
meeting the DND's ambitious polymeric goals remedy in place in response
complete. They appear to be unlikely and
site closure may even be an impossibility of some of the sites.
Also, the nation's cleanup program appears to be transitioning from
remedy selection into remedy operation and long-term management. Potentially
over long time frames. This is decades of long-term management that we
will have to implement for these types of sites.
What makes these sites so challenging? This chart is actually
pulled from an ITRC online document a team was
formed was manage to -- most
of these are familiar with the technical challenges. Things like the presence
of -- the ability of these contaminants
to defuse and store in the low permeability of
media and how that impacts the ability to achieve groundwater cleanup goals
over time. I think also these non-technical challenges play a
big role, too. When you have multiple regulators
and stakeholders involved, and you are all trying to reach an agreement
on a remedy for a site, that is a challenge. Also within
DOD and other institution, property changes hands. You can either sell
property to the private sector, we can transfer land to
over to local municipalities. The ability
to manage that risk, ensure we have the right kind of institutional
controls, is another set of challenges.
I believe that chart for you to study at your convenience. We have
heard a lot about adaptive site management. As can be mentioned,
the EPA Superfund task force has a pilot program
they are in permitting this year, where they are looking for example
sites across the EPA regions.
They will be using sites and using this adaptive site management
process to help in decision-making.
It will be interesting to see what comes out of that, what kind of
good case study examples they can share with the
rest of us, so that we can see what adaptive site management looks like,
but on paper in terms of guidance, but also in good field examples.
I just want to point out with this
lie that this concept is nothing new. I think we have all done some
adaptive site management on our projects, particularly those
that last for long periods of time.
We are always optimizing, updating our conceptual site model. Those
are really some of the key components to adaptive management. In fact,
in 2003. another NRC report ratified this process
is a good way for the Navy to manage their own sites. I think in some
ways we have been doing this, but it will be nice to get more
definitive guidance out so that we can all be on the same page.
This process for us started back in 2015 when we
looked at approximately, I think there
were 32 or 33 sites in total that we looked at. About two thirds of
those were sites where in-situ remedies have been implemented.
They were used on chlorinated solvent sites. We also had some larger
M Apple site. The other one third of the sites were pump and treat
systems. We had about a dozen pump and treat systems where we were
looking at optimizing those sites as well.
We did this or a combination of Navy subject matter
experts, and we also teamed up with some outside private consultants
who had experience with other government agencies, as well as the private
sector. That was a good feedback mechanism for us, to make
sure that some of our recommendations were grounded with the state of
the practice outside of the Navy.
That was a valuable component to our team as well.
We develop both site-specific, detailed site-specific funding for
each individual site, and we share those with the RPMs and the regional
management. We also assisted RPMs in and promoting those recommendations
with their project teams. We were also trying to develop some
larger portfolio wide things that we could use
to focus future optimization efforts and provide training and guidance
for RPMs on specific issues.
We've identified several of those over the last 3 years and through
our own Ritz training seminars, as well as some
policy and guidance. We have been able to communicate that to our
RPMs.
These are the sites. This is just a listing
and a chart showing some of the sites that we
looked at. These are the Institute sites. 20 one of these
are in total. The blue bars represent the cost to complete.
This would be the cost to complete the entire
lifecycle for the project. Most of these sites that ranged from
up to $5 million. We did have some sites that were in the 10-20
million dollar range as well.
The red dots represent the remediation timeframe. For most
of the sites that was resting -- recommended a greater than 30 years
and were detailed modeling had been done, that could have been 50 or
even 100 years in some cases. These were sites that all had very
long time frames associated with them. A summary of our findings.
These are all sites with very long time frames. Typically these sites,
as can be talked about earlier, we typically saw these implemented
as treatment train. There will be a source reduction
technology implemented to try to reduce the source area concentration
by remediation. That was typically coupled with something to manage
the down gradient plan.
It may have been a hotspot treatment for another
portion of the plume, or even a barrier to try to cut or intercept
a part of a plume from leaving a property or further expanding. With
all of these sites, there was an M&A component that would be relied
on for being the component that would be used to attain the
final cleanup goal which, for the sites, were typically the
NCL or Ritz based standard. One of our initial goals was to try
to identify sites that we could accelerate the cleanup timeframe.
One of our metrics within the Navy is to try to achieve 95% response
complete at our sites by 2021.
One of our goals was to try to identify some site that we could bring into
that timeframe. Unfortunately, we did not find any that we felt like,
through additional aggressive treatment, we could meet those NCL type objectives.
What we did find on several sites, were areas where we could do
additional aggressive treatment and make meaningful
impact on actual risk reduction.
A couple of examples are sites where vapor intrusion was
identified as a potential receptor. We were
able to do aggressive treatment to try to manage or mitigate that
exposure pathway. Likewise, we had some sites where
plumes were discharging into service water and we can take immediate
actions to address that. We could still make meaningful risk reduction
for additional action, but not necessarily shorten the overall remediation
timeframe. That is a distinction, did we don't want to lose the fact
that there, we still had some successes in terms of shifting our resources
in different areas. We found that long-term management and monitoring
were really what were driving these costs. Even a small
amount of money, if you add that up over 30-50 plus years, that
adds up, particularly for the DOD.
We are unable to discount those out your
cost. So those costs are going to stay the same without optimization.
Those will stay constant over time.
Those costs add up. Finally, and I think an important area of
future worth is this idea of these transition
assessments. We found a number of sites where project teams were
uncertain went to go from aggressive treatment to something more passive,
like M&A or some other type of technology. The transition
assessment is an important thing that I think is lacking in
a lot of the tools out there. Some of the
key site management questions we use as part of this process to guide
us in making these decisions and focusing our resources on certain
sites are listed here.
If you look at these questions, they are kind of a very simplified
decision framework almost. The first question we asked was,
is there an ongoing actual impact to receptors? I
use the vapor intrusion example before. That is a good one.
If those receptors were identified, then
we need to take a more immediate action to try to control that risk,
or to control that pathway. If those immediate impacts did not exist,
then the next question was, what about the plan? Is it stable, is
it leaving our property? And if it was then that was another
area where we felt like we needed to step in and do things like install
a treatment barrier, or worst case, a pump and treats his men, or something
to try to control the expansion of the plan. If the plume was stable
another set of questions were, what is controlling the stability
of the plan? It is it a natural process? If so, we need to understand
those processes and ensure their sustainability over a long
time frame. In other words, if there is a reductive D chlorination reaction
going on, are we going to be able to rely on the process to occur
for decades. On the flipside, if an engineering system was being
used to control the plume stability, we need to make sure that we have
the right kind of lifecycle and design operation and maintenance
that can handle this kind of process over the long-term. These are some
of the key site management that we identified as went through the
sites.
I'm going to go through these key messages. This
is a review that I'm going to get into the site example to wrap up
the presentation. Some of these key messages,
there are these subsites of these out there. Complex sites,
ones that will really drive resource allocation in the coming
decades for this type of work.
We definitely identified a subset of those and we are putting policy
and guidance in place on how to manage those types of sites again,
adaptive site management appears to be at this point the most suitable
approach to try to manage these types of sites
and really to try to manage that uncertainty. By using this iterative
process that relies on multiple you know feedback, loops and mechanisms
we can continuously update that conceptual site model,
and that will give us the ability to guide our decision-making.
Again, for the site, long-term passive management
appears to be inappropriate long-term goal or endpoint for these
sites. Obviously want to focus our initial efforts on sites where
there is uncontrolled risk. But those long-term goals of the
NCL being attained, that is to "Going to happen through natural
attenuation. And that may take a fairly long, decades, to achieve.
In the we need to have a robust set of institutional
controls and we can prevent exposure on the sites. Obviously
we are continuously doing optimization and updating conceptual site model
throughout the process.
To go along with that long time frame,
interim goals are very important.
This is one of the recommendations out of the
ITRC document. If you have a decades long site that you are
managing, it is perfectly reasonable for regulators and other stakeholders
to want to see interim goals as they can monitor and track the
progress of the site. We developed some goals, and there are different
ways of thinking about and looking at these interim transition goals.
They may be concentration based, they may be flux based, and it may
be just as simple as ensuring that there
is no uncontrolled exposure pathways at the site.
That is a huge interim goal that needs to
be met. Those need to be incorporated into decision documents and agreed
upon with the teams. Finally, I mentioned the transition assessments.
I think these are important. I know --
trying to develop terms and these transition
assessments fit into that mold as well. Hopefully will get more
of these tools that are available for RPMs so that they can do these
assessments and make sure we are doing things in and effective and
efficient way. I'm going to wrap up with
an example of a site that I have been working on for a while.
We have done a lot of optimization over a long time. Here. I think
we have incorporated some of these adaptive management
concepts. This is a site in McGregor, Texas. It is a Naval
weapons industrial reserve plant.
These are government owned and contractor operated, facilities.
This one operated until 1995 it was used
to manufacture rocket motors and bombs. Through that process,
released a lot of perchlorate to the environment.
As well as chlorinated solvents, but perchlorate was the real
risk driver here. This is a huge facility, almost 10.000 acres in
a rural area outside of Waco, Texas.
The current use of the property, there are several
different industrial and agricultural companies that have moved in and
are doing work in this area including
SpaceX. They have a launch facility at the site. The Navy does maintain
all of the cleanup and -- we
have lease agreements that we go in and do work as part of our Navy
cleanup program.
This is a map showing the size of the area. I'm going to be
focusing in on the
southwestern part of the area, the area shaded in gray. It
is called area M.
I mentioned we are doing a lot of lifecycle optimization.
We started in the early 2000's,
looking at optimizing a
-- bed reactor. We had a pump and treat system activated
here. We try to add some promoting in the early 2000. We have been
doing long-term monitoring optimization over time. Our efforts lately have
shifted toward trying to think of exit strategies and closure strategies
for the site. We developed a conceptual model
of the natural attenuation capacity groundwater and surface water system
at the side to address the low-level perchlorate that is found at the
site. Think of tends to low hundreds per billions.
There is ability for this to -- also a slide that goes over that
in a minute. We have been able to work with the Texas commission on
environmental quality to change the or reclassify the groundwater
system, which gives a not as stringent cleanup
goal for the site. That was done in 2016.
We also did some risk assessments, looking at ecological receptors
and their exposure to perchlorate and surface water.
Finally, we are working with transitioning the groundwater and pump and
treat system with the bed reactor from an above ground
pump and treat system to a series of passive in-situ
bio barriers. That is where we are in this process.
This is an aerial view of the site.
We are down in this part here. These blue
lines represent trenches that were cut into the
ground, anywhere from 30-40 below grade. They are used to collect
groundwater. They are cut both parallel and perpendicular
to the groundwater inflow velocity.
We intentionally did this to try to collect the water before it left
the property boundary, which is the maroon line along the bottom.
And also before it discharged into this receding tributary, located
here.
Again, that system has been running since the early 2000's, I think
2001 and 2002 timeframe.
It is a challenge from the operation and maintenance
standpoint, in terms of what it takes to keep the system running.
I mentioned the groundwater surface water interactions with the site.
This is a relatively dry part of the state but there are
a lot of precipitation occurs in the spring, and it creates this
dynamic effect where we get ephemeral territories and streams that form
during the wet season. Those dry out over time.
You can think of this dynamic movement of the water table up and down that
creates this mixing process that can occur. We've been able to demonstrate
that it does attenuate the perchlorate them concentration over time, particularly
downgrading as you get more into the downgrading watershed.
That is an important aspect of his conceptual site model.
These are photos of the aboveground treatment system. You can see the
lagoons. This is a fairly large area. These lagoons
are to store water during wet portions of the season.
That water has been prompted
to do so it is a bed reactor where it is used to treat the perchlorate
as a reaction they wait discharge the water into the tributary that
I showed earlier. This plot shows the perchlorate concentrations
going into the pump and treat system. This is before treatment.
What is meant to show is the roughly order of magnitude reduction
in perchlorate overtime.
You can see through a combination of source reduction,
we did a lot of excavation and removal of contaminated soil. But also,
this natural flushing process. We have seen a significant reduction
in what is heading into the fluidized bed reactor.
We are at a point now where we are thinking of transitioning the pump
and treat system into something more passive that we can manage
over a longer period of time. With a little more ease, in terms of
operation and maintenance, and also at a lower cost. Our goal is to
shut the system down, and transition it over to a series of bio barriers.
We are working with the TC Q to do this.
We had done a pilot study. You can see this plot
shows the change in concentration in perchlorate in 2001 compared
to 2018. You can see through our remedial efforts we have made
a significant impact on the plume.
This area is about 10 ppb. That
has been reduced in size to the smaller area here. This is where
were going to focus that bio barrier portion of the remedy moving
forward. We have done some pilot testing. It appears this will
be an effective way to treat the contamination
in-situ. You can see the plight on the right isn't upgrading well
we have perchlorate greater than 10.000 parts
per billion and it stays relatively
constant. In our down gradient well, after we injected the emulsified
oil into the bio barrier, or the bio wealth, we saw a significant
reduction, almost three orders of magnitude
in perchlorate, as well as some nitrate that is present on here.
Again, this appears to be a viable technique moving forward.
This is something we are going to be working with our regulars and
other stakeholders, as we transition moving forward. One last thing I
want to bring up is that we were able to work with
TC Q to reclassify this groundwater system. This is a key aspect because
Texas allows, this is done under a regrowth post closure order.
They allowed groundwater standards for both residential use of groundwater,
as well as commercial and industrial.
By reclassifying this groundwater to class III we were able to increase
that number up to around 5000 ppb.
That basically, for the downgrading or off-site portions
of our property, we already meet that. The portion of the site
that is above 5000 is really now more on the former
Navy property. That helps in managing this, going forward.
To wrap up, we are almost out of time. Again, just
to reiterate some of the components of this site management process
that we have gone through, again, great
-- reclassifying the groundwater over
time. Updating our conceptual site model to include some of these other
types of natural attenuation mechanisms.
During a transition assessment, going from pump and treat to
an in-situ system to treat the remaining
-- remaining perchlorate. We also did an ecological
risk assessment we were able to demonstrate that there were no adverse
impacts to sensitive receptors from exposure to perchlorate in the down
gradient service water. That was another key aspect, in terms of
risk, and making sure that ecological pathway was not of a concern.
Through this process we feel like this adaptive site management approach
will result in significant cost avoidance, but also maintain
protection of human health and the environment, and just improve
the effectiveness and efficiency of the system. It is aging. It is
15+ years old so it makes sense to transition this on to something
that we can get more useful life out of. With that, I will and. I
will leave my contact information, email address, and we may have a
minute or two for questions but I will turn it back over to Cindy
to do that.
>> Thank you, Mike. I'm afraid we are out of time today. If
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>> Bye-bye