Alternatives for Managing the Nation’s Complex Contaminated Groundwater Sites Alternatives for Managing the Nation's Complex Contaminated Groundwater Sites Alternatives for Managing the Nation’s Complex Contaminated Groundwater Sites Committee on Future Options for Management in the Nation’s Subsurface Remediation Effort Water Science and Technology Board Division on Earth and Life Studies THE NATIONAL ACADEMIES PRESS Washington, D.C. www.nap.edu Copyright © National Academy of Sciences. All rights reserved. Alternatives for Managing the Nation's Complex Contaminated Groundwater Sites THE NATIONAL ACADEMIES PRESS 500 Fifth Street, N.W. Washington, DC 20001 NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the panel responsible for the report were chosen for their special competences and with regard for appropriate balance. This study was supported by Contract Number W911SR-09-1-0004 between the National Academy of Sciences and the U.S. Department of the Army. Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the author(s) and do not necessarily reflect the views of the organizations or agencies that provided support for the project. Library of Congress Cataloging-in-Publication Data or International Standard Book Number 978-0-309-27874-4 Additional copies of this report are available for sale from the National Academies Press, 500 Fifth Street, NW, Keck 360, Washington, DC 20001; (800) 624-6242 or (202) 334-3313; http://www.nap.edu. Copyright 2012 by the National Academy of Sciences. All rights reserved. Printed in the United States of America. PREPUBLICATION COPY Copyright © National Academy of Sciences. All rights reserved. Alternatives for Managing the Nation's Complex Contaminated Groundwater Sites The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Ralph J. Cicerone is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. 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The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy’s purposes of furthering knowledge and advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Ralph J. Cicerone and Dr. Charles M. Vest are chair and vice chair, respectively, of the National Research Council. www.nationalacademies.org PREPUBLICATION COPY Copyright © National Academy of Sciences. All rights reserved. Alternatives for Managing the Nation's Complex Contaminated Groundwater Sites Copyright © National Academy of Sciences. All rights reserved. Alternatives for Managing the Nation's Complex Contaminated Groundwater Sites COMMITTEE ON FUTURE OPTIONS FOR MANAGEMENT IN THE NATION’S SUBSURFACE REMEDIATION EFFORT* MICHAEL C. KAVANAUGH, Chair, Geosyntec, Oakland, California WILLIAM A. ARNOLD, University of Minnesota, Minneapolis BARBARA D. BECK, Gradient, Cambridge, Massachusetts YU-PING CHIN, The Ohio State University, Columbus ZAID CHOWDHURY, Malcolm Pirnie, Phoenix, Arizona DAVID E. ELLIS, DuPont Engineering, Newark, Delaware TISSA H. ILLANGASEKARE, Colorado School of Mines, Golden PAUL C. JOHNSON, Arizona State University, Tempe MOHSEN MEHRAN, Rubicon Engineering, Irvine, California JAMES W. MERCER, Tetra Tech GEO, Sterling, Virginia KURT D. PENNELL, Tufts University, Medford, Massachusetts ALAN J. RABIDEAU, State University of New York, Buffalo ALLEN M. SHAPIRO, U.S. Geological Survey, Reston, Virginia LEONARD M. SIEGEL, Center for Public Environmental Oversight, Mountain View, California WILLIAM J. WALSH, Pepper Hamilton LLP, Washington, DC NRC Staff LAURA J. EHLERS, Study Director STEPHANIE E. JOHNSON, Senior Staff Officer KERI SCHAFFER, Research Associate JEANNE AQUILINO, Senior Administrative Associate ELLEN DEGUZMAN, Research Associate, through June 2011 ANITA HALL, Senior Program Associate *Kevin J. Boyle, Virginia Polytechnic Institute and State University, Blacksburg, was a member of the Committee from February 2010 to June 2012. v PREPUBLICATION COPY Copyright © National Academy of Sciences. All rights reserved. Alternatives for Managing the Nation's Complex Contaminated Groundwater Sites WATER SCIENCE AND TECHNOLOGY BOARD DONALD I. SIEGEL, Chair, Syracuse University, Syracuse, New York LISA ALVAREZ-COHEN, University of California, Berkeley EDWARD J. BOUWER, Johns Hopkins University YU-PING CHIN, The Ohio State University, Columbus M. SIOBHAN FENNESSY, Kenyon College, Gambier, Ohio BEN GRUMBLES, Clean Water America Alliance, Washington, DC GEORGE R. HALLBERG, The Cadmus Group, Inc., Watertown, Massachusetts KENNETH R. HERD, Southwest Florida Water Management District, Brooksville GEORGE M. HORNBERGER, Vanderbilt University, Nashville, Tennessee CATHERINE L. KLING, Iowa State University, Ames DEBRA S. KNOPMAN, The Rand Corporation, Washington, DC LARRY LARSON, Association of State Floodplain Managers, Madison, Wisconsin RITA P. MAGUIRE, Maguire & Pearce PLLC, Phoenix, Arizona DAVID H. MOREAU, University of North Carolina, Chapel Hill ROBERT SIMONDS, The Robert Simonds Company, Culver City, California FRANK H. STILLINGER, Princeton University, Princeton, New Jersey MARYLYNN V. YATES, University of California, Riverside JAMES W. ZIGLAR, SR., Van Ness Feldman, Washington, DC NRC Staff JEFFREY JACOBS, Director LAURA J. EHLERS, Senior Staff Officer LAURA J. HELSABECK, Senior Staff Officer STEPHANIE JOHNSON, Senior Staff Officer JEANNE AQUILINO, Financial and Administrative Associate ANITA HALL, Senior Program Associate MICHAEL STOEVER, Research Associate SARAH BRENNAN, Senior Program Assistant vi PREPUBLICATION COPY Copyright © National Academy of Sciences. All rights reserved. Alternatives for Managing the Nation's Complex Contaminated Groundwater Sites Preface Despite nearly 40 years of intensive efforts in the United States as well as in other industrialized countries worldwide, restoration of groundwater contaminated by releases of anthropogenic chemicals to a condition allowing for unrestricted use and unlimited exposure (UU/UE) remains a significant technical and institutional challenge. Recent (2004) estimates by EPA indicate that expenditures for soil and groundwater cleanup at over 300,000 sites through 2033 may exceed $200 billion (not adjusted for inflation), and many of these sites have experienced groundwater impacts. One dominant attribute of the nation’s efforts on subsurface remediation efforts has been lengthy delays between discovery of the problem and its resolution. Reasons for these extended timeframes are now well known: ineffective subsurface investigations, difficulties in characterizing the nature and extent of the problem in highly heterogeneous subsurface environments, remedial technologies that have not been capable of achieving restoration in many of these geologic settings, continued improvements in analytical detection limits leading to discovery of additional chemicals of concern, evolution of more stringent drinking water standards, and the realization that other exposure pathways, such as vapor intrusion, pose unacceptable health risks. A variety of administrative and policy factors also result in extensive delays, including, but not limited to, high regulatory personnel turnover, the difficulty in determining cost-effective remedies to meet cleanup goals, and allocation of responsibility at multiparty sites. Over the past decade, however, remedial technologies have shown increased effectiveness in removing contaminants from groundwater, and the use of more precise characterization tools and other diagnostic technologies have improved our ability to achieve site-specific remedial action objectives within a reasonable time frame at an increasing number of sites. For example, of the over 1,700 National Priority List sites, the U.S Environmental Protection Agency (EPA) has deleted over 360 sites (as of March, 2012), including some that have reported achieving restoration goals for groundwater, usually defined as drinking water standards. Other regulatory programs at both the federal and state level report closures of many sites with contaminated groundwater, although “closure” is often defined by site-specific conditions, such as the need for long-term institutional controls. Such trends and financial pressures have prompted the DoD to set very aggressive goals for significantly reducing the expenditures for the Installation Restoration Program within the next few years. There is general agreement among practicing remediation professionals, however, that there is a substantial population of sites, where, due to inherent geologic complexities, restoration within the next 50-100 years is likely not achievable. Reaching agreement on which sites should be included in this category, and what should be done with such sites, however, has proven to be difficult. EPA recently summarized the agency’s recommended decision guidance vii PREPUBLICATION COPY Copyright © National Academy of Sciences. All rights reserved. Alternatives for Managing the Nation's Complex Contaminated Groundwater Sites viii Preface (July, 2011) for these more complex sites, presenting a Road Map for groundwater restoration that targets both Superfund and RCRA Corrective Action sites. A key decision in that Road Map is determining whether or not restoration of groundwater is “likely.” If not, alternative strategies must be evaluated to achieve the remedial action objectives, including possible modification of these objectives or the points of compliance. The National Research Council (NRC) has also addressed the issue of complex and difficult sites. Since 1987, there have been at least six NRC studies to evaluate barriers to achieving the goal of groundwater restoration. These reports addressed both technical and institutional barriers to restoration, but in general, the reports have concluded that some fraction of sites will require containment and long-term management and the number of such sites could be in the thousands. Other organizations have also undertaken in- depth assessments of barriers to restoration at more complex sites including the Interstate Technology Regulatory Commission (ITRC). In this context, the U.S. Army Environmental Command (AEC) agreed to support a NRC study to address the technical and management issues arising from barriers to restoration of contaminated groundwater at these complex sites. In particular, the AEC was concerned that delays in decision making on the final remedies at many of their more complex sites could diminish their ability to achieve DoD goals for the IRP. For the Army, one significant goal is achieving the RIP or RC milestones for 100 percent of their IRP sites at active installations by 2014. This study was established under the Water Science and Technology Board (WSTB) of the NRC with the title “Future Options for Management in the Nation’s Subsurface Remediation Effort.” The Committee included fifteen individuals representing expertise in all areas relevant to the SOT, including various scientific and technical disciplines, resource economics, environmental policy, risk assessment and public stakeholder issues. Seven meetings were held over the past two years, with presentations from a wide range of interested parties. I would like to thank the following individuals for giving presentations to the committee during one or more of its meetings: Laurie Haines-Eklund, Army Environmental Command; Jim Cummings, EPA Superfund Office; Adam Klinger, EPA Underground Storage Tank Office; Jeff Marquesee and Andrea Leeson, SERDP; Brian Looney, DOE Environmental Management; John Gillespie, Air Force Center for Environmental Excellence; Anna Willett, Interstate Technology and Regulatory Council; Alan Robeson, American Water Works Association; Jill Van Dyke, National Groundwater Association; Ira May, May Geoenvironmental Services; Roy Herndon, Orange County Water District; Milad Taghavi, LADWP; Carol Williams, San Gabriel Supply; Gil Borboa, City of Santa Monica; David Lazerwitz, Farella Braun + Martel, LLP; James Giannopoulos, California State Water Quality Control Board; Herb Levine, EPA Region 9; Alec Naugle, CA Region 2 Water Board; David Sweeney, New Jersey Department of Environmental Protection; Rula Deeb, Malcolm Pirnie; Amy Edwards, Holland & Knight LLP; Brian Lynch, Marsh Environmental Practice; Richard Davies, Chartis; Henry Schuver and Helen Dawson, EPA; Tushar Talele, Arcadis; Anura Jayasumana, Colorado School of Mines; Deborah Morefield, Office of the Deputy Undersecretary of Defense; Alana Lee, EPA Region 9; Betsy Southerland and Matt Charsky, EPA; Mike Truex, Pacific National Lab; and Jim Gillie, Versar/Joint Base Lewis McChord. I wish to acknowledge the herculean efforts of Laura Ehlers and her colleagues at the WSTB for organizing our meetings, managing multiple tasks, and finally completing the editing of contributions from committee members, a task that requires both editing and substantial technical expertise and diplomacy in helping a diverse committee reach consensus. I am indebted to Laura for her efforts on completing this report. I also want to send special thanks to PREPUBLICATION COPY Copyright © National Academy of Sciences. All rights reserved. Alternatives for Managing the Nation's Complex Contaminated Groundwater Sites Preface ix all the Committee members who so diligently participated in long sessions at our meetings, produced comprehensive summaries of the state of the science in subsurface remediation, and who wrestled with the complexities of addressing the challenges of better decision making. The contributions of those who worked on the final chapter are especially appreciated, and particularly those individuals who joined the committee later in deliberations to fill in for vacancies caused by unanticipated changes in the committee roster. This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise, in accordance with procedures approved by the National Research Council’s Report Review Committee. The purpose of this independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We wish to thank the following individuals for their review of this report: Lisa Alvarez-Cohen, University of California, Berkeley; Linda Lee, Purdue University; Jacqueline MacDonald Gibson, University of North Carolina, Chapel Hill; David Nakles, Carnegie Mellon University; Stavros Papadopulos, S.S. Papadopulos & Associates, Inc.; Tom Sale, Colorado State University; Rosalind Schoof, Environ International Corporation; Hans Stroo, HydroGeoLogic, Inc.; and Marcia E. Williams, Gnarus Advisors, LLC. Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations nor did they see the final draft of the report before its release. The review of this report was overseen by Susan L. Brantley, Pennsylvania State University; and Mitchell Small, Carnegie Mellon University. Appointed by the National Research Council, they were responsible for making certain that an independent examination of this report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final content of this report rests entirely with the authoring committee and the institution. Michael C. Kavanaugh, Chair Committee on Future Options for Management in the Nation’s Subsurface Remediation Efforts PREPUBLICATION COPY Copyright © National Academy of Sciences. All rights reserved.