Environmental Cleanup at Navy Facilities Risk-Based Methods (1999) / Chapter Skim
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5 Conclusions and Recommendations
5 Conclusions and Recommendations
Pages 111-132
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From page 111... ...
As a result, the Navy's budget for performing cleanup of hazardous waste sites is limited. The combined Defense Environmental Restoration Account and BRAC funding for FY97 was $549 million, and the Navy is under pressure from Congress to reduce that figure in future years.
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From page 112... ...
The CERCLA process, which the Navy uses for 66 percent of its hazardous waste sites, is complicated and lengthy, and is perceived by some in the Navy as being too expensive. The Navy is seeking alternative strategies that will save money in cleaning up both petroleum and non-petroleum sites.
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From page 113... ...
Most Navy facilities are large and contain multiple types of hazardous waste sites. In individual sites there may be a variety of toxic
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From page 114... ...
The committee recognizes the attraction of a new risk-based approach to the Navy Environmental Restoration Program, but remains cautious in recommending its use at Navy facilities. This is because risk-based approaches are more likely than source removal or technology-based approaches to result in remedies that leave contamination in place.
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From page 115... ...
If a risk-based approach to environmental remediation is to be used at naval facilities, it must overcome the weaknesses that characterize solutions in which contamination is left in place. Based on its review of federal, state, and other risk-based methodologies, interviews with and presentations from Navy personnel, previous NRC reports, and the expertise of its members, the committee has identified 11 important criteria for a risk-based methodology that addresses hazardous waste sites at Navy facilities.
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From page 116... ...
A satisfactory risk-based methodology will provide guidance for setting data collection methods and data quality objectives. It will suggest ways to conduct an initial site assessment that will aid in prioritization of sites, as well as methods of site characterization that can be used to generate site-specific cleanup goals.
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From page 117... ...
Currently, the selection of remedial options is qualitative, and relies on the limited guidance embodied by the nine criteria in the NCP (or other similar criteria, as found in the ASTM RBCA standard guides)
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From page 118... ...
The affected public and regulatory agencies may be more willing to accept short-term decisions that appear to leave sources in place if they believe responsible parties are willing to take additional future action. Therefore, the Navy would be best served by a flexible risk-based method
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From page 119... ...
This criterion for revisiting sites over the long term applies to both active and BRAC facilities. It should be noted that in some circumstances, current DOD policy relieves the Navy of responsibility for performing additional cleanup activities on BRAC facilities that have been transferred to the private sector.
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From page 120... ...
Implementation of any risk-based methodology adopted by the Navy should take place in a public forum. The assumptions and relevant science used during the risk assessment process and the proposed remedies, along with all relevant value judgments, must be presented to and understood by interested
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From page 121... ...
It does not imply that the RBCA approach could not be modified to take some of these criteria into account. Most states have modified the ASTM petroleum RBCA standard guide to some extent prior to implementation for cleanup of USTs.
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From page 122... ...
Users would greatly benefit from more information on data quality objectives, monitoring methods, appropriate sample size, and performance criteria for data collection methods. Integrated Risk Assessment The petroleum RBCA standard guide makes no mention of either cumulative risk assessment or integrated risk assessment.
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From page 123... ...
The ASTM documents do suggest using Monte Carlo techniques as part of a tier 3 analysis. Evidence from state programs implementing the petroleum RBCA standard guide indicates that most contaminated sites never reach tier 3 because of the costs associated with conducting extensive site characterization, so this suggestion is rarely realized.
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From page 124... ...
In addition, the RBCA standard guides specifically discuss the use of institutional controls as remedial options. While similar guidance for the other types of remedial options would be beneficial, what is needed most is a quantitative method for analyzing various remedial options during each tier evaluation.
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From page 125... ...
If interpreted in this way, this figure negates many of the improvements of this document over the petroleum RBCA standard guide.
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From page 126... ...
External Scientific Peer Review and Public Review Both ASTM standard guides were designed and approved by a limited group of stakeholders. Petroleum RBCA was the product of negotiations between the oil industry, state regulatory programs, members of ASTM, and the EPA.
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From page 127... ...
To its credit, the chemical RBCA standard guide, unlike the petroleum RBCA standard guide, repeatedly stresses that it is a voluntary methodology meant to complement state and federal regulatory programs rather than replace them. It suggests strongly that the appropriate regulatory authorities should be contacted to assist users with a myriad of technical policy decisions that would have to precede its use at the state level.
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From page 128... ...
Despite these improvements, however, the committee does not recommend the adoption of either the petroleum or chemical RBCA standard guides at Navy facilities unless they are modified to satisfy the 11 criteria outlined above. As currently written, the ASTM RBCA methodology does not satisfy all 11 criteria listed above as characteristics of an effective risk-based methodology.
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From page 129... ...
Although not necessarily the intention of its authors, it is clear that the ASTM RBCA approach is attractive because it is perceived by responsible parties to be a short cut to cleanup that will lead to faster site closure. This perception is partially due to examples in both ASTM standard guides in which site closure is obtained relatively quickly and with minimal cleanup efforts.
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From page 130... ...
If the ASTM RBCA methodology is used as a guide, care should be taken to avoid the weaknesses currently found in the ASTM standard guides. The framework must be flexible enough to work with existing state and federal environmental statutes.
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From page 131... ...
enforcing a wide variety of institutional controls. Success Metrics The committee has observed that on-site project managers in the Environmental Restoration Program often strive to meet vague or inconsistent goals regarding the level of cleanup required to close a site.
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From page 132... ...
1997. Risk-Based Cleanup Index for the Closure of Underground Storage Tanks at Naval Air Station, North Island, San Diego County, California.
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