Environmental Cleanup at Navy Facilities Risk-Based Methods (1999) / Chapter Skim
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Executive Summary
Executive Summary
Pages 1-14
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From page 1... ...
This report presents the results of the first phase of the NRC study, which focused on the use of risk-based methodologies for increasing the speed and cost-effectiveness of the Navy's environmental remediation projects. Approximately 66 percent of the Navy' s hazardous waste sites are subject to regulation under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
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From page 2... ...
A second ASTM RBCA standard guide, for contaminants other than petroleum hydrocarbons, has also been developed ("chemical RBCA"~. Encouraged by RBCA's growing role in cleanup programs, the Navy asked the NRC to evaluate ASTM's standard guides and suggest whether those methodologies, or a similar but simpler approach, could be used to rapidly close out Navy sites.
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From page 3... ...
The final stages of the CERCLA process include maintaining engineering and institutional controls and conducting long-term monitoring. ASTM RBCA Standard Guides Like the EPA's Soil Screening Guidance, both of ASTM's RBCA standard guides (for petroleum release sites and for sites containing other chemical contaminants)
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From page 4... ...
Tier evaluations are followed by remedial actions, which eventually lead to closure of the site. Under the ASTM RBCA methodology, the remedy may include a combination of removal actions, treatment technologies, engineering controls, and institutional controls.
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From page 5... ...
One procedural difference is that with the ASTM methodology remedial options are available earlier in the process, and the tiered approach is used for all types of contaminated media. There is a general perception that ASTM RBCA is faster, less costly, and more user friendly than CERCLA.
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From page 6... ...
Petroleum RBCA does not promote public involvement at an early stage in the cleanup process, although this is somewhat corrected in chemical RBCA. Finally, like other ASTM voluntary standard guides, both ASTM RBCA standard guides were designed and approved by a limited group of stakeholders.
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From page 7... ...
CERCLA has a long history of use in environmental remediation at federal facilities and is familiar to Navy remedial project managers. Public involvement occurs at explicit stages of the CERCLA process, which is important for ensuring acceptance of the remedial option.
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From page 8... ...
Because Navy facilities include both simple low risk sites and complex high risk sites, the Navy's risk-based methodology must include a systematic approach for conducting site investigations of differing complexity. In facilitating the evaluation of sites ranging from simple to highly complex, both conservative, generic cleanup goals and less conservative but more site-specific cleanup goals should be allowed.
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From page 9... ...
The Navy's risk-based methodology should allow for the explicit consideration of these uncertainties and suggest options for reducing them, using both long-term monitoring and formal uncertainty analyses. Uncertainty analyses within the methodology should use stochastic modeling approaches, such as Monte Carlo analysis, to represent the degree of uncertainty associated with the risk estimates.
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From page 10... ...
Ranking of sites takes place during the initial site assessment and leads to site classifications of immediate threat, short-term threat, long-term threat, or no demonstrable threat. The tiered approach of RBCA provides a mechanism for addressing all site types and for replacing conservative cleanup goals with sitespecific cleanup goals, and thus this process meets the second criterion.
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From page 11... ...
Public involvement is not discussed in the petroleum RBCA standard guide. Chemical RBCA mentions public involvement during the collection of site assessment information, following site classification, and during remedy selection, but public involvement does not appear at explicit points in the RBCA flowchart.
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From page 12... ...
Use of the ASTM RBCA Standard Guides The committee does not recommend the adoption of either the ASTM petroleum or chemical RBCA standard guides at Navy facilities unless they are modified to satisfy the 11 criteria outlined above. As currently formulated, the ASTM RBCA methodology does not satisfy all of the 11 criteria listed above as characteristics of an effective risk-based methodology.
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From page 13... ...
As currently envisioned by the committee, this tool would be based on the paradigm of optimizing risk reduction per dollar spent for a suite of available remedial options. Another important aspect of a risk-based approach is its ability to assess risk over the long term.
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From page 14... ...
However, recognizing that a consideration of risk during environmental remediation can help to better allocate limited resources, the committee suggests 11 criteria that the Navy should incorporate into a risk-based methodology for use at its facilities. These criteria overcome many of the weaknesses of risk-based methodologies in general and afford a level of scientific credibility and protectiveness of human health and the environment appropriate for the Navy' s Environmental Restoration Program.
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