Navys Portfolio Optimization: In Situ Remediation Sites Presented - PowerPoint PPT Presentation

Navy’s Portfolio Optimization: In Situ Remediation Sites Presented By Mike Singletary P E Mike Singletary, P.E. Naval Facilities Engineering Command (NAVFAC) Southeast Federal Remediation Technology Roundtable (FRTR) Meeting, Reston, VA, May 9, 2018

Objectives • Discuss challenges complex sites pose to the g p p ER,N Program • Describe technical and non-technical attributes of complex sites complex sites • Discuss commons themes from Portfolio Optimization that relate to complex sites • Describe Adaptive Site Management as means of S f managing site uncertainty and complexity • Case study example site – NWIRP McGregor, TX y p g , DON Environmental Restoration Training – March 6-8, 2018 2

ER,N Cost to Complete (EOY FY17) IRP Total Marine Corps Sites: 1,104 (25%) (17%) $0.43 168 Sites (18%) $0.67 B (15%) Marine Corps Marine Corps $2 09 $2.09 (83%) (83%) 216 Sites (18%) 754 Sites (82%) $B Marine Corps Marine Corps $3.81 B (85%) MRP Navy Navy 950 Sites (82%) $0.24 (12%) 48 Si 48 Sites (20%) (20%) Total Navy Sites: 3,394 (75%) (88%) $1.72 196 Sites (80%) $ $B Projects Only 3

EOY FY17 Snapshot of ER,N Program IRP EOY FY2017 (# SITES) ($CTC) 816 $342M 21 $8M 2,690 18 $7M 847 RC 847 RC $370M ACTIVE CLEANUP 232 $698M RAO 323 232 RAO 3 $698M 2,838 SC $1,480M RC Doc Pending RC Doc Pending $0.5M $0 5M RC 560 31 $3,419M $28M SC 237 $1,939M 148 4,498 Sites ( EOY16: 4,435 Sites ) 4 498 Sites ( EOY16: 4 435 Sites ) RC: 3,685 (81.9%) MRP $4,495M CTC = $2,528M (IRP) + $1,967M (MRP) Projects Only 4

Navy Optimization Policy and Guidance • DON Policy for Optimizing Remedial and Removal Actions at all DON Restoration Sites (April 2012) • NAVFAC Guidance for NAVFAC G id f Optimizing Remedial Action Operation (October 2012) • DON Guidance for Planning and Optimizing Monitoring Strategies (N (November 2010) b 2010) • DON Guidance for Optimizing Remedy Evaluation Selection and Evaluation, Selection, and Design (March 2010) DON Environmental Restoration Training – March 6-8, 2018 5

2013 NRC Report on Complex Sites • National Research Council report on managing the p g g nation’s complex sites • Team of experts from industry, academia, and government t • Estimated roughly 10% of sites are “complex” and will not meet cleanup will not meet cleanup objectives in reasonable timeframe • Estimated cost to remediate ~$127 billion DON Environmental Restoration Training – March 6-8, 2018 6

NRC 2013 on Achieving Site Closure “… at complex sites “…the Committee has characterized by multiple concluded that regardless of contaminant sources, large the remedial technologies past releases of chemicals, or applied at complex sites, highly complex geologic removal of sufficient mass to environments, meeting the i ti th reduce contaminant d i DoD’s ambitious programmatic concentrations in goals for remedy in groundwater to levels that place/response complete place/response complete allow for unlimited use and allow for unlimited use and seems unlikely and site closure unrestricted exposure is almost an impossibility .” unlikely for many decades .” DON Environmental Restoration Training – March 6-8, 2018 7

NRC 2013 on Breakthrough Technologies Technologies “ Furthermore, no “Rather, the nation’s cleanup transformational remedial transformational remedial programs are transitioning programs are transitioning technology or combination of from remedy selection into technologies appears capable remedy operation and long- of overcoming the inherent term management (LTM), technical challenges to potentially over long timeframes .” restoration at these complex sites.” DON Environmental Restoration Training – March 6-8, 2018 8

2014-17 ITRC Complex Sites Team • 2017 ITRC Complex Site Definition Definition – “Remediation Remediation progress is uncertain and remediation may not achieve closure or even long term closure or even long term management within a reasonable time frame” • “Reasonable time frame” for restoring groundwater reso rce to beneficial se is resource to beneficial use is subject to interpretation and Source: ITRC Remediation Management of Complex Sites depends on site circumstances i t DON Environmental Restoration Training – March 6-8, 2018 9

Site Challenges/Complexities Technical Examples Non-Technical Examples Challenges Challenges Geologic Fractured bedrock, Site objectives Deviations from conditions karst geology, low­ promulgated screening values or closure criteria permeability sediments (e.g. MCLs) Hydrogeologic Groundwater table Managing changes Phased remediation, that may occur over multiple PRPs, loss of Conditions fluctuations, groundwater­surface long time frames institutional knowledge water interactions G Geochemical h i l L Low/high pH, /hi h H Overlapping O l i F d l/ Federal/state cooperation, t t ti Conditions alkalinity, elevated regulatory numerous stakeholders electron acceptors responsibilities Contaminant- LNAPL/DNAPL, Institutional controls Tracking and managing related emerging g g ICs, enforcement , Conditions contaminants, back diffusion Large-scale site Size and depth of Changes in land use Site access, plume, number and redevelopment, variety of receptors i t f t l land/water use change d/ t h Funding Uncertain funding, politics DON Environmental Restoration Training – March 6-8, 2018 Source: Modified from ITRC 2017 10

Back Diffusion Example OU2, Former NTC Orlando • TCE and daughter products stored in low permeability silt layer • Bio-barrier injection wells screened Bi b i i j i ll d only in overlying sand unit • Back diffusion likely contributing to long-term plume persistence long term plume persistence Source: ESTCP 201581-PR DON Environmental Restoration Training – March 6-8, 2018 11

Adaptive Site Management • Refine CSM • Set or re-visit site S t i it it objectives • Develop interim objectives objectives • Adaptive remedial strategy • Develop long-term Develop long term management plan • Transition Assessments Source: ITRC Remediation Management of Complex Sites DON Environmental Restoration Training – March 6-8, 2018 12

2003 NRC Adaptive Site Management • NRC study on latter stages of site cleanup at Navy installations • NRC committee proposed comprehensive and comprehensive and flexible approach – “Adaptive Site Management” • Express recognition that system responses will be monitored, interpreted, and used to adjust and used to adjust approach in iterative manner over time Source: NRC 2003 DON Environmental Restoration Training – March 6-8, 2018 13

Types of Cleanup Endpoints Traditional Traditional Alternative Alternative Established by ARAR waivers ARAR waivers regulation State designations and ARARs ARARs programs Groundwater Risk-based objectives object reclassification Alternate concentration Other Alternative Endpoints MNA MNA over extended timeframes d d ti f limits (ACLs) Adaptive Site Management Source: Navy 2016 DON Environmental Restoration Training – March 6-8, 2018 14

States Regulatory Programs • State Programs/Policy – Typically follow Risk-Based Corrective Action Typically follow Risk Based Corrective Action (RBCA) – Low-Threat Closure (California) – Texas Risk Reduction Program (TRRP) – Florida Risk Management Options (RMO I, II, III) • State Designations – Containment Zone – Plume Management Zone (PMZ) • Texas (NWIRP Dallas, NWIRP McGregor) – Conditional points of compliance • Washington, Florida Source: Navy 2016 DON Environmental Restoration Training – March 6-8, 2018 15

Navy Portfolio Optimization (P-OPT) Phase I Review of Complex Sites (2015-17) p ( )  Primary objectives were to identify opportunities to reduce remediation timeframe (accelerate RC), improve remedy effectiveness, and achieve cost avoidance  In­house Navy subject matter experts (SMEs) developed preliminary findings and recommendations  External SMEs, each with more than 20 or 30 years experience in the industry, were used to further vet the findings  Portfolio­wide themes were developed by y analy yzing g common findings from all sites  Findings and recommendations discussed with RPMs and FECs – and adjusted based on additional insights from end users j g  Navy SMEs continuing to work with RPMs and FEC Managers to implement the Phase I recommendations 16

Complex Sites with In Situ Treatment Trains 17

Summary of Site Findings • Restoration timeframes estimated at >30 years for most sites (actual timeframe typically greater) • Source reduction technology (e.g. bioremediation, ISCO) typically implemented with natural attenuation and other passive technologies to treat/control downgradient plume • Few opportunities to accelerate remediation timeframes R Inherent technical difficulties prevented site closure, meeting MCLs (e.g. DNAPL, complex geology, contaminant back diffusion) • Long-term monitoring/management requirements drive costs • Long-term management appropriate goal for most complex sites in Phase I • Guidance needed for RPMs to determine when to transition sites from active treatment to passive management DON Environmental Restoration Training – March 6-8, 2018 18