[CPEO-MEF] Adaptive Site Management (new National Research Council report)

[Lenny Siegel <lsiegel@cpeo.org>]

On January 13, 2003, The  Water Science and Technology Board of the
National Research Council (NRC), the research arm of the National
Academies of Sciences, released "Environmental Cleanup at Navy
Facilities: Adaptive Site Management." The 259-page document can be
read, free, page-by-page at http://www.nap.edu/catalog/10599.html.
Hardcopy publication by the National Academies Press is forthcoming.

The Navy-sponsored report includes a valuable detailed evaluation of a
range of technologies suitable for environmental response at Navy and
similar cleanup sites, but the heart of the report is its suggestion
that the Navy and other federal agencies adopt "adaptive site
management" (ASM), a term coined by the NRC committee that prepared the
report, as a cleanup strategy. As a member of that Committee, I believe
that ASM is an important new approach that will help responsible
parties, regulators, and the public deal with evolving conditions
through the life cycle of cleanup at each facility, from its current
state through long-term stewardship or closure. It is consistent with
existing hazardous waste laws, and it builds on optimization initiatives
already underway at the Navy and other federal agencies.

According to the report summary, "this report proposes a comprehensive
and flexible approach, referred to as 'adaptive site management,' for
dealing with difficult-to-remediate hazardous waste sites over the long
term. Although adaptive site management is entirely consistent with the
current cleanup paradigm used at federal facilities (as principally
defined by Superfund), it has additional features that stress knowledge
generation and transmittal and that complement more traditional cleanup
objectives in order for progress to be made at sites where recalcitrant
contamination prevents site closure and subsequent unrestricted land use.

"Adaptive site management is responsive to the concern of large
responsible parties that current technologies have proved to be
ineffective in reaching cleanup goals for many types of contamination.
Many studies and reports have documented that there are still no proven
technologies for addressing hydrogeologically complex sites contaminated
with dense nonaqueous phase liquids (DNAPLs) and metals, which are the
contaminants of concern at many federal facilities. A variety of
technical factors - such as geological and flow heterogeneity as well as
slow mass transfer from solid phases and free phase contamination -
limit remediation effectiveness and lead to the 'asymptote' effect where
further operation of the remediation system does not significantly
reduce contaminant levels. At the present time, there is very limited
regulatory or policy guidance on what to do when the asymptote is
reached before cleanup goals have been met as long as the remedy remains
protective of human health and the environment. The goals of adaptive
site management are to facilitate decision making when the effectiveness
of the remedy reaches an asymptote prior to reaching the cleanup goal
and, if necessary, to facilitate implementation of long-term stewardship
(long-term management in DoD [Department of Defense] terminology). This
approach can accommodate different cleanup objectives, it provides
guidance at key decision-making points, and it is a mechanism for
dealing with the uncertainty inherent in many remedial strategies - both
engineered technologies and institutional controls."

Lenny Siegel

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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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