Table Of ContentAlternatives 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
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Alternatives for Managing the Nation's Complex Contaminated Groundwater Sites
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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
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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
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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
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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
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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
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