[CPEO-MEF] Navy Optimization Report

[Lenny Siegel <lsiegel@cpeo.org>]

The Navy has prepared an innovative report, "Guidance for Optimizing
Remedial Action Operation (RAO)," designed to help project managers
evaluate and improve ongoing cleanup remedies. Though called a
"Guidance," it's really a series of well thought out observations and
recommendations, not a requirement from above. Still, it appears that
Navy cleanup teams are starting to implement its approach. I suggest
that others responsible for managing the cleanup of groundwater and soil
would benefit from its strategies as well.

Now that the Navy, like many other responsible parties, has remedies in
place at a large share of its contaminated sites, it faces the
continuing responsibility and mounting costs of remedial action
operations. Many standard remedies, however, lose their effectiveness
over time. Measures of performance, such as contaminant mass removal,
tend to reach an asymptote, often before remedial objectives are
reached. The Navy report provides a roadmap for analyzing such results,
ANNUALLY, using life-cycle design principles.

The purpose of such evaluation is to optimize or even change remedies,
with the following benefits in mind:

"* Ensuring that the remedial action (RA) remains protective of human
health and the environment.
"* Enhancing the effectiveness of RAs toward achieving remedial objectives
"* Reducing operation and maintenance (O&M) costs
"* Accelerating the site closeout schedule."

It shouldn't be surprising, given the political pressures from above on
the Navy program, that the examples in the report are biased toward
saving money, rather than protecting public health and the environment.
Solutions often include monitored natural attenuation and/or use
restrictions. But the methodology can just as easily be used to find
ways to accomplish more complete cleanup, as well.

The report defines a seven-step Remedial Action Optimization Process:

1. Review and Evaluate Remedial Action Objectives

2. Evaluate Remediation Effectiveness

3. Evaluate Cost Efficiency.

4. Identify Remediation Alternatives

5. Develop and Prioritize Optimization Strategies

6. Prepare Optimization Report

7. Implement Optimization Strategy

The report contains an appendix detailing 15 common remediation
technologies, describing difficulties often encountered in implementing
them, and suggestion optimization strategies. It also summarizes several
optimization case studies from Navy and Marine Corps facilities.

The report is clearly written. Its explanations of remediation
technologies are simple but accurate. It uses both notional and actual
graphs to illustrate well the changing performance of remedies over time.

"Guidance for Optimizing Remedial Action Operation (RAO," Naval
Facilities Engineering Command Special Report SR-2101-ENV, Interim
Final, April 2001, was prepared by Radian International for the Navy
Working Group for Optimizing Remedial Action Operations and Long-term
Monitoring. The 150-page document may be downloaded as a 2 megabyte PDF
file from
http://enviro.nfesc.navy.mil/erb/erb_a/support/wrk_grp/raoltm/rao_interim_final2.pdf


Lenny




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Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
lsiegel@cpeo.org
http://www.cpeo.org

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