[CPEO-MEF] DOE Groundwater Optimization Guidance

[Lenny Siegel <lsiegel@cpeo.org>]

In May, 2002, the Department of Energy's Office of Environmental
Management issued its  "Guidance for Optimizing Ground Water Response
Actions at Department of Energy Sites." The Guidance provides a clear
description, for people familiar with remediation terminology, of the
standard approach to groundwater remedy selection, but it does more,
addressing key long-term issues.

It starts by describing EPA's hierarchy of "programmatic expectations":

1. Restore ground water to highest beneficial use
2. Stop plume growth and migration of contaminants
3. Reduce the toxicity, mobility or volume of contaminants

The Guidance covers the three typical phases of groundwater response:

1. source control
2. mass removal/containment
3. monitoring

Most important, the Guidance contains an innovative section on
"Transition and Exit Strategies," with supporting examples. It states,
"Regardless of whether ground water restoration is ultimately determined
to be practicable, an essential requirement of an optimal ground water
response strategy is knowing when and how to transition from one phase
of response to another.  To ensure transitions between the phases
proceed at the appropriate time, a transition or exit strategy must be
developed and documented for each technology application/phase of the
response.  A transition or exit strategy may be viewed simply as the set
of information that will be used to demonstrate the desired performance
has been achieved and the technology-specific objective met, such that
it is appropriate to move to the next phase of the response, or
terminate all activities if the desired end-state has been attained"

The guidance continues, "The four essential elements of an effective
transition/exit strategy include:

1. A description of the objective of the activity, i.e., the objective
associated with a technology application or phase of a response; 

2. A performance ?model? that describes the expected course of the
remediation process, i.e., how conditions are expected to change over
time from the current state until the response objective is attained;

3. A set of the performance metrics, decision criteria, and endpoints
that will be used to assess how the response is progressing, demonstrate
when the objective has been reached or an unacceptable
condition/deviation occurs; and

4. A contingency plan that will be implemented if data indicate an
objective(s) will not be met."

It explains contingency plans: "The contingency plan should not only
define the criteria to signify a deviation has occurred, but also the
course of action to be taken.  For example, contingencies may include:
1) the collection of additional data to better assess performance; 2)
re-evaluation of performance data to determine whether expectations need
to be redefined; 3) implementation of an alternative remediation
strategy, or, 4) re-analysis of response objectives to determine whether
they are indeed attainable."

This discussion of revising or terminating remedies is significant in
two ways: First, it recognizes that remedial decisions are not completed
with the signing of an original Record of Decision or other decision
document. Second, it encourages consideration of such long-term
management issue early in the cleanup process.

Lenny

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Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope 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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