Richard Dailey
U.S. Department of Energy
EH-43

Kevin Kytola
Project Performance Corporation

The U.S. Department of Energy (DOE) is undertaking an effort to initiate the use of generic approaches to waste site remediation. Generic approaches are remedial strategies which use the knowledge gained from previous waste site remediation experience to serve as the basis and justification for subsequent responses at similar sites. Generic approaches include using the Environmental Protection Agency's (EPA) presumptive remedies per EPA guidance, developing a bridge to an EPA presumptive remedy, and developing plug-in approaches and contingent removal actions.

Many waste sites requiring remediation have similar characteristics due to common disposal practices (e.g., liquid waste disposal trenches, solid waste burial grounds), and common media, contaminants, and site characteristics (e.g., geologic settings). Additionally, many waste sites at federal facilities, such as those operated by DOE, have characteristics similar to waste sites regularly addressed by EPA outside the DOE complex (e.g., municipal landfills). It is also recognized that a limited suite of technologies are available to remediate waste sites and that early identification of preferred remedies results in time and resource savings throughout the Comprehensive Environmental Response, Cleanup, and Liability Act (CERCLA) Response and Resource Conservation and Recovery Act (RCRA) Corrective Action processes.

Although the technical basis and documentation used to implement generic approaches may vary to meet the specific nature of the site problem(s) being addressed, the underlying premise is that similarities between sites can be used to better focus data collection, risk evaluations, and alternative analyses while reducing repetitive documentation and enhancing decision making consistency. This concept of utilizing similarities between sites to streamline response planning and implementation is embodied in EPA's presumptive remedy policy (see OSWER Fact Sheet 9355.0-47FS, September 1993, EPA-540-F-93-047) and serves as the basis for implementing generic approaches to site remediation.

Many Federal Facility waste sites present similar problems warranting action due to common waste management practices (e.g., liquid waste disposal trenches, solid waste burial grounds), and common media, contaminants, and site characteristics (e.g., geologic settings). These commonalties offer opportunities to cut costs and schedules by utilizing these similarities to focus the response selection process. This concept of utilizing similarities between sites to streamline remedial planning and implementation is embodied in EPA's presumptive remedy policy (OSWER Fact Sheet 9355.0-47FS, September, 1993, EPA 540-F-93-047) and serves as the basis for implementing generic approaches.

Generic approaches are remedial strategies which use the knowledge gained from previous experience at a waste site(s) to serve as the basis and justification for subsequent responses at similar sites. Although the technical basis and documentation used to implement generic approaches may vary to meet the specific nature of the site problem(s) being addressed, the underlying premise is that similarities between sites can be used to better focus data collection, risk evaluations, and the analysis of remedial alternatives. As such, each of the various approaches discussed below is intended to focus and accelerate remediation projects, but may differ in their implementation to reflect the specific site conditions to which they are applied.

Additionally, a key component of any accelerated approach is the necessity to establish and maintain an effective decision making core team. This core team includes those parties which must share responsibility for making key project decisions (e.g., DOE, USEPA, and State agency project managers), and reviewing and approving work in progress. Since generic approaches require some degree of "pre-approval" of a response action for agreed to site problems, it is imperative that the core team be established early and maintained throughout the development and implementation of any of these approaches.

In situations where there are multiple sites with similar characteristics, the traditional remedial decision-making process would likely result in redundant technical (e.g., alternative evaluations) and administrative (e.g., decision documentation) efforts, and culminate in a similar decision on the appropriate response action to be implemented at each waste site. Consistent with EPA's presumptive remedy policy (EPA, 1993), which focuses on maximizing the administrative efficiency of CERCLA by utilizing similarities between operable units (OUs) to streamline remedial planning and implementation, DOE has adopted the use of plug-in approaches where recurrent site problems a warrant similar response. This approach identifies a preferred remedial action and then defines a process that will be used to determine where that remedial action is applied. Plug-in approaches have been used by the EPA, DOE, and the United States Air Force to accelerate remedial actions. Accordingly, a plug-in approach includes the following components:

For the plug-in approach to be beneficial, there must be the potential for similar site problems to be encountered recurrently. As site problems are identified and defined, the core team should evaluate existing information to determine the potential for recurring site problems to exist. Recurring site problems may be identified based on process history, contaminant type, media type, and type of waste unit (e.g., solid waste burial grounds).

The plug-in approach relies on up front agreement of a preferred response action for a recurring site problem. This preferred response is generally selected by evaluating a "lead site". A lead site may be a site: 1) previously addressed at the facility, or 2) not yet evaluated but considered most representative of expected and recurring site conditions.

Once the likely response action is identified to address the recurring site problem, the core team defines the "remedy profile" by identifying the range of conditions that a technology is effective at addressing. Essentially, the core team is identifying those conditions which must or must not be present for the technology to be effective. This profile may be composed of technical factors (e.g., technology can only address certain constituents), as well as administrative considerations (e.g., land use requirements) which have the potential to impact the effectiveness or implementability of a response action. Potential remedy profile parameters include: soil characteristics, concentration limits, cost considerations, site logistics, land use requirements, and hydrological parameters.

In situations where there is the potential for site characteristics to vary, the core team will need to carefully evaluate whether technical enhancements to the remedy can be used to expand the range of conditions over which the technology is considered effective.

Because the plug-in will be employed for a number of site-specific decisions in the future, it is necessary to establish the methodology for evaluating individual sites. A decision making framework is developed to provide a basis for determining if subsequent sites plug-in to the preferred remedy. This decision framework represents those key site conditions which must be present in order for: 1) action to be initiated; and 2) for the preferred technology to be applied. Once the core team defines and concurs on the decision framework, it must be formally communicated to the public in a decision document (e.g., Record of Decision).

Once the plug-in decision framework is established in a decision document, the core team evaluates existing information on the various physical and contaminant parameters at subsequent waste sites to determine whether the site problem is amenable to the plug-in response. This decision is based on evaluating site- specific conditions against the key parameters of the plug-in decision framework (i.e., triggers for action and remedy profile parameters).

As waste sites are evaluated against the remedy profile to determine whether the necessary conditions are met for the site to be "plugged in", several potential outcomes are possible:

1. the waste site's characteristics indicate a problem similar to the lead site AND those characteristics fall within the bounds of the remedy profile;
2. the waste site's characteristics fall outside the remedy profile but with considered enhancements, the site can be addressed within the plug-in technology; or
3. the waste site's characteristics indicate the problem is sufficiently different from the lead site and the plug-in cannot be used, even with considered enhancements.

The contingent removal action approach (see DOE/EPA's Expediting Cleanup Through Contingent Removal Actions, DOE/EH/(CERCLA)-003, February 1997) is designed to address anticipated recurrent site problems more efficiently and consistently by establishing a standardized, pre-approved response strategy (e.g., excavate and dispose off-site in a permitted cell) for a defined site condition (e.g., Thorium hot spots above x pCi/g in the top y inches of soil). Additional benefits include reduced approval and documentation delays, and accelerated cleanup. To effectively utilize this approach, the core team must reach consensus on: appropriate site problems for contingent removals; appropriate criteria to trigger removals; removal implementation procedures (e.g., generic design and response procedures); and a strategy for integrating contingent removals into the overall site remediation strategy (e.g., incorporating into an existing Federal Facility Agreement). The steps of developing a contingent removal action approach are described below:

The core team should consider a type of problem as a candidate for a contingent removal action approach if it is anticipated to reoccur, and can be addressed within available site resources. The more frequently a problem type occurs, the greater the savings resulting from use of the contingent removal action approach (i.e., economies of scale increase each time a problem is more efficiently addressed through a contingent removal). Important resources to consider when determine whether a problem type can be addressed using a contingent removal action approach include: 1) fiscal considerations (e.g., problem type can be addressed within the fiscal year); 2) health and safety (H&S) needs (e.g., necessary H&S personnel are available and an adequate H&S plan is currently in place to address the problem); and 3) technology and waste management capability and availability (i.e., necessary equipment, waste management facilities, and regulatory approvals are available).

Once the core team agrees that a type of site problem will be addressed using a contingent removal action approach, facility specific criteria must be established to clearly identify the need for action and delineate the boundaries of the response. Setting concentrations or dose levels where there is a clear potential for risk ensures that resources are being utilized on substantive cleanup.

The core team must also define the specific implementation procedures for executing the contingent removal action. This includes defining: 1) responsibilities and authorities (e.g., the organizations to conduct the action); 2) contracting mechanisms, if necessary; 3) a monitoring strategy for terminating a removal (i.e., plan for indicating when an action may stop or scope limits have been reached); and 4) generic design and technical procedures. Once the trigger criteria are met, field activities can being immediately as all necessary direction for completing the contingent removal action has been pre-defined and agreed upon by the core team.

Once a contingent removal action approach has been developed by the core team and the public has had an opportunity to comment, it needs to be integrated into the overall site remediation strategy (e.g., incorporated into the existing Federal Facility Agreement). Each time a situation is encountered which meets the trigger criteria, a response can be implemented immediately. Each time a contingent removal action is initiated, the core team should prepare an information brief to communicate to the public what remediation has been (or is being) conducted to keep them informed of the progress being made.

Contingent removal actions have not been employed to date, however, the concept is sufficiently developed and DOE Headquarters is actively searching for candidates across the complex.

When site-specific conditions are amendable, an established EPA presumptive remedy should be used. In certain circumstances, site conditions may be similar, but also include an additional aspect, i.e., a physical condition or presence of a contaminant not specifically considered when the presumptive remedy was developed. In such situations, it may be possible to create a "bridge" to the presumptive remedy, i.e., to present sufficient information/analysis to adequately justify use of the presumptive remedy and to demonstrate what, if any, modifications to the presumptive remedy are necessary to ensure adequate protection of human health and the environment is achieved. The following is the general approach for establishing a bridge to an EPA presumptive remedy.

• Identifying the applicable presumptive remedy (e.g., capping of CERCLA municipal landfill sites);
• Defining the site conditions which correspond with the conditions addressed in the presumptive remedy (e.g., waste site contains large volumes of heterogeneous material which makes treatment impracticable);
• Evaluating the site conditions which differ from the presumptive remedy (e.g., waste contains low-level radioactive material);
• Recommending modifications necessary to use the presumptive remedy (e.g., cap will be constructed using special liner designed to inhibit radon emissions).

Bridging is a concept which has been considered by both DOE and DOD. In support of the generic approach initiative DOE-HQ is seeking opportunities to apply the bridging concept to a specific remediation project.

Many waste sites requiring remediation have similar characteristics due to common disposal practices, and common media, contaminants, and site characteristics. Generic approaches use knowledge gained from previous waste site remediation experience to serve as the basis and justification for subsequent responses at similar sites. Thus, generic approaches capitalize on similarities between waste sites to better focus data collection, risk evaluations, and alternative analyses, while reducing repetitive documentation and enhancing decision making consistency.

DOE Headquarters is supporting development and implementation of these approaches such that acceleration and savings can be realized across the complex. DOE Headquarters will provide technical assistance in educating site staff on the generic approach concepts, identifying candidate sites, developing approaches, and implementing the approaches to ensure success. Any site personnel interested in additional information regarding development and implementation of generic approaches should contact Richard Dailey on (202)586-7117.