Please excuse the redundant postings.
On Wednesday, December 12, 2012, at 1:00 pm EST, the National Research Council (NRC) will host a free Webinar explaining its new report, "Alternatives for Managing the Nation's Complex Contaminated Groundwater Sites." Michael Kavanaugh, chair of the report-authoring committee will present the report’s findings and, along with other committee members (including myself), answer questions from the public. Please register in advance for the webinar at: https://nasevents.webex.com/nasevents/onstage/g.php?t=a&d=665634292. You may need to copy and paste the link.
News coverage about the report has emphasized its conclusion that "The complete removal of contaminants from groundwater at possibly thousands of complex sites in the U.S. is unlikely." That's nothing new. The NRC has concluded that several times before.
Some people, who appear not to have read the entire report, seem to see it as justification for the wholesale shutdown of cleanup activity at complex groundwater sites. It isn't.
Instead the NRC Committee has established a framework to help make decisions about when it is appropriate to transition to passive long-term management, and what that management entails.
The heart of the report, in my opinion, is its final chapter, Chapter 7. Here are its conclusions and recommendations.
Lenny Siegel
CONCLUSIONS AND RECOMMENDATIONS
At many complex sites, contaminant concentrations in the plume remain stalled at levels above cleanup goals despite continued operation of remedial systems. At such sites, which may number in the tens of thousands, there is no clear path forward to a final end state, such that money continues to be spent with no concomitant reduction in the risks posed by the sites. If the effectiveness of site remediation reaches a point of diminishing returns prior to reaching cleanup goals and optimization has been exhausted, the transition to MNA or some other active or passive management should be considered using a formal evaluation. This transition assessment, which is akin to a focused feasibility study, would determine whether a new remedy is warranted at the site or whether long-term management is appropriate (see Figure 7-2). This analysis, particularly the graphical demonstration that contaminant concentrations at a site have reached an asymptote, is likely to enhance public involvement in long-term decision- making and thus strengthen public confidence in the decisions made.
As part of the transition assessment, the costs of remedial options should be updated, ideally using probabilistic methods, to reflect the current present value of costs in order to more effectively compare the costs of various future alternatives. To the extent possible, the marginal cost of remediation through time should be quantified. Also as part of the transition assessment, formal post-remedy risk assessment should be conducted to compare alternatives, including long-term active or passive management. This risk analysis should explicitly consider uncertainty and take into account both individual and population risks, where appropriate, such that the relative risk reduction of the alternatives can be determined.
Five-year reviews are an extremely valuable source of field data for evaluating the performance of remedial strategies that have been implemented at CERCLA facilities and could be improved. To increase transparency and allow EPA, the public, and other researchers to assess lessons learned, more should be done, on a national basis, to analyze the results of five- year reviews in order to evaluate the current performance of implemented technologies. EPA’s technical guidance for five-year reviews should be updated to provide a uniform protocol for analyzing the data collected during the reviews, reporting their results, and improving their quality.
Informed public involvement characterized by two-way communications and that builds trust is a key element of good remedial decision-making, particularly at complex sites. Federal agencies generally go beyond the minimum level of public involvement by forming or recognizing advisory groups and providing technical assistance, such that members of affected communities have the opportunity to influence remedial decision-making. Nonetheless, public involvement tends to diminish once remedies at a site or facility are in place. No agency has a clear policy for sustaining public involvement during long-term management.
Regulators and federal responsible parties should work with members of existing advisory groups and technical assistance recipients to devise models for ongoing public oversight once remedies are in place. Such mechanisms may include annual meetings, Internet communications, or the shifting of the locus of public involvement to permanent local institutions such as public health departments. Such involvement is critical to the success of the processes found in Figure 7-2.
The cost of new remedial actions may decrease at complex sites if more of them undergo a transition to passive long-term management. However, long-term management at complex sites will still demand substantial long-term funding obligations. Failure to fund adequately the long-term management of complex sites may result in unacceptable risks to the public due to unintended exposure to site contaminants.