Principles Matter

• Nov 01, 2001

Managers of environmental cleanup projects at federal facilities have been struggling for years with investigation techniques and cleanup of hazardous and radioactive waste contamination. Hundreds of pages of technical guidance on how to collect samples, evaluate risk and applicable technologies have produced thousands of pages of site-specific reports, maps, charts and more often than not, have resulted in costly and inefficient progress in cleaning up the sites.

In 1995, a small team of U.S. Department of Energy (DOE) staff engineers, environmental managers, former U.S. Environmental Protection Agency (EPA) employees and contractors, all of whom were previously involved with hazardous and radioactive contamination cleanup activities, formed a committee to reassess cleanup procedures and the methodology being used at these sites. They carefully examined trends and commonalties in projects that stalled as well as those that excelled. From these deliberations came a consensus approach to field support and procedures, focused on improving the efficiency and cost effectiveness of site cleanup. The tenets of this consensus approach have generally become known as the techniques or "Principles" of environmental restoration.

DOE, Department of Defense (DOD) and EPA embrace these Principles as the preferred approach to streamlining processes, improving decision making and reporting for environmental cleanup projects under Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or Superfund) or Resource Conservation and Recover Act (RCRA) corrective action programs. Through joint guidance, and indoctrination training on these Principles delivered by the DOE's National Environmental Training Office (NETO), these federal agencies (and many state partners) are increasingly applying the Principles.Their implementation and subsequent success has been demonstrated at sites where some of the most difficult environmental cleanup problems exist and where the involved parties have reached impasse on how to resolve technical issues or working relationships.

Too often, the site characterization portion of cleanup projects becomes an ongoing endeavor seeking ever greater reporting detail and accuracy, rather than a tool to identify the actual problems.

The Principles

The four Principles of Environmental Restoration are

Early identification of site problems -- Too often, the site characterization (e.g., the sampling and field or laboratory analysis of the site) portion of cleanup projects becomes an ongoing endeavor seeking ever greater reporting detail and accuracy, rather than a tool to identify the actual problems, the degree of acceptability and remedies. The past site characterization process sought to define the complete nature and extent of acceptable components as well as contaminants down to and sometimes below background concentrations. This Principle refocuses decision makers on problem identification, not comprehensive characterization, sometimes involving detailed sampling, but more often using existing data to define those conditions that are known to be unacceptable (e.g., a contaminant is found above an allowed cleanup level). This eliminates duplicate effort, costly sampling rounds or unnecessary precision and shifts the focus towards answers rather than elaborating on already known problems.

Early identification of appropriate technologies -- The restoration technology evaluation process commonly follows completion of characterization, rather than proceeding as a concurrent activity. Many environmental problems have well-established and proven technical solutions. For example, EPA, DOD and DOE have presumptive remedies for many types of soil contaminants and more than 20 years of collective lessons learned and implementation experience. Early identification of appropriate technologies has two positive affects - any sampling being conducted to investigate site conditions can also collect data to confirm or reject a "preferred" technical approach, and second, lengthy engineering studies can be avoided when only one or two workable technologies are likely to be the best solutions.

Uncertainty management -- All environmental cleanup projects face uncertainties such as the presence of certain site characteristics, applicability of regulations, the likely future use of the land and the effectiveness of a given restoration technology. This Principle advocates early identification of significant uncertainties and development of effective approaches to manage them in the form of contingency plans, monitoring strategies, or focused sampling efforts. The lack of an uncertainty management strategy could result in less confidence in the cleanup approach and a subsequent inability to dictate safe use and/or the limitations of characterizing technology.

The most important principle is building a core team with a decision making structure that brings parties face-to-face on a regular basis to make consensus decisions.

Develop and rely on a core team concept -- Perhaps the most important principle is building a core team with a decision making structure that brings parties face-to-face on a regular basis to make consensus decisions rather than reading and editing technical reports, and responding to hundreds of comments from separate entities. Typically, a core team includes the EPA state and local regulators and a project manager from the appropriate owning agency. No aspect of the principles is more important than teaching project teams to embrace this concept. As one DOD project manager says, "the key for us was sitting down with the regulators in a Principles training workshop and working through each element setting the consensus parameters necessary to achieve project success as expeditiously as possible." DOE, DOD and EPA now establish proactively synergistic relationships for each site, sharing lessons learned and allowing field decisions to be made, which save time, money and provide a safer environment.

How Does Incorporating the Principles Work?

Typically, the Principles process is first taught through a two-day formal training program attended by all of the parties involved in any way in a cleanup project. The training addresses each of the Principles separately and requires all participants to work through case studies as a core team. Attempting to reach consensus solutions, as a group, is the primary focus rather than articulating differences. DOE's NETO has administered these Principles training classes across the nation as either open-enrollment offerings or as exclusive events for the host with numerous testimonies of success.

Following the training (or in many cases, during the training as staff from different agencies begin to focus on the same goals), the technical implementation portion of the Principles process begins. Technical facilitators lead the core team through a joint project phase in which a conceptual site model is developed based on existing data. Using this conceptual site model, discussion of the effects of various restoration techniques, applicable technologies and existing uncertainties are considered, after which a determination is made whether additional data collection or engineering study is needed. These technical sessions often take two or three days consisting of several iterations per day resulting in joint implementation in a single document, executed by all core team members.

Often many rounds of sampling are avoided once the core team realizes the data will not add new information to what they already know to be the problem. In other cases, a technical solution emerges early in the process as the preferred approach (rather than waiting for a long engineering study to determine which technology is best). Finally, disagreements about whether more data are needed to solve a problem can often be addressed through an uncertainty management approach by defining specific circumstances when new data might be appropriate (contingency plan) if certain monitoring conditions are observed in the future. Equally as important, many iterations of edits and changes to workplans and technical reports are avoided because the core team has worked out a consensus approach.

Attempting to reach consensus solutions, as a group, is the primary focus rather than articulating differences.

Do the Principles Work?

Testaments from staff managing projects at DOE sites, DOD bases and from the participating regulatory organization proves the Principles do work. Reviews of the training courses on the Principles process, and subsequent results from their application to actual projects, show that substantial inefficiency, cost and frustration can be eliminated.

For example, published reports on the use of the Principles at DOE sites show savings of millions of dollars and avoidance of months or years of effort at sites in Nevada, Ohio, Kentucky and South Carolina. At a site in South Carolina, ongoing challenges with implementing a cleanup program led to the regulators calling a "time out" in enforcing compliance agreement milestones and a rethinking of how all parties could approach planning and implementing environmental cleanup. A series of Principles courses and technical planning sessions resulted in all parties adopting the process.

In addition to the savings associated with more efficient document review/revision processes, the new approach results in additional savings because objectives (i.e., scope) are clearly understood early in the project life cycle, which ensures an appropriate level of effort is defined for technical analyses (i.e., risk assessments). Further, the new approach identifies opportunities to select a preferred response early in the process based on institutional knowledge. Consequently, there is opportunity to not only focus on project scope, but also to accelerate cleanup by minimizing the need for unnecessary technical analysis.

At U.S. Army sites, successes of the Principles include an Army Depot in New York where the project manager anticipates "a reduction in schedule of 24 months and savings of as much as $1 million" because the process led the project team to forgo detailed site characterization and move immediately to an active cleanup measure once they realized that the additional characterization would provide little new information that the decision makers needed.

At another Army site in California, early identification of likely response actions for cleaning up a series of underground storage tanks and a small localized plume resulted in schedule savings of nearly a year and cost savings of $100,000. This was accomplished by avoiding a long feasibility study to evaluate engineering alternatives because existing data already suggested a remediation approach that was feasible and effective.

The inter-agency collaboration on the development of this new approach to Remedial Investigation/Feasibility Study decision-making has resulted in an approach that has been readily implemented and immediately beneficial. Staff from all organizations and at all levels have a renewed focus on the fundamentals of environmental restoration - identifying threats to human health and the environment and responding to them as expeditiously as possible. As a result of these successes, similar efforts are being encouraged at other federal facilities.

Principles Training Courses

The DOE National Environmental Training Office offers a series of training courses on application of these "Principles" through the life cycle of a cleanup project:

1. Principles for Accelerating Environmental Restoration (NETO183)
2. Principles for Accelerating Remedial Design and Implementation (NETO360)
3. Facility Disposition: Principles of Integrated Safety and Project Management (NETO192)
4. Site Closure: Integrating Regulatory and Administrative Activities (NETO429)

More course information is available at www.em.doe.gov/neto/.

More Information on the Principles Process

DOE publications on application of the "Principles" process include

1. Preparing Effective Decision Documents: Facilitating the Transition into Response Design and Implementation (DOE/EH-413-0012)
2. Facility Disposition: Principles for Accelerated Project Management (DOE/EH-413-0002)
3. Environmental Response Design and Implementation Guidance (DOE/EH-413-9915)
4. A Monograph: Facility Disposition Lessons Learned from the Mound Site (DOE/EH-413-9909)
5. Expediting Cleanup through Early Identification of Likely Response Actions (DOE/EH-413-9902)
6. Expediting Cleanup through Problem Identification and Definition (DOE/EH-413-9904)
7. Uncertainty Management: Expediting Cleanup Through Contingency Planning (DOE/EH/(CERCLA)-002)
8. Streamlined Approach for Environmental Restoration (SAFER) Pilot Project, Final Report

All of these reports are available on the Web at tis.eh.doe.gov/oepa/, then click on "Policy & Guidance," then select CERCLA.

This article appeared in the November 2001 issue of Environmental Protection, Vol. 12, No. 11, on page 37.

This article originally appeared in the 11/01/2001 issue of Environmental Protection.