A sustained optimization effort is an important element of the remediation approach to ensure efficiency and effectiveness at each site. The Department of the Navy (DON) optimization efforts span the entire environmental restoration (ER) process from investigation through remedy implementation and long-term monitoring. In accordance with DON policy, green and sustainable remediation (GSR) is incorporated into the optimization process to emphasize and promote sustainability practices within the ER program. Detailed procedures for implementing optimization practices are provided in NAVFAC guidance as noted below.
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The goal of optimization is to maximize the effectiveness of cleanup actions, while minimizing costs and negative environmental and societal impacts. This must also be accomplished without sacrificing data quality and the ability to make environmentally protective decisions. The DON Optimization Policy addresses the requirement for optimization efforts to be conducted throughout the ER process.
According to the policy, optimization efforts are to be considered during site characterization, remedy evaluation and selection, design and construction, remedy operation, and long-term management. In addition, the policy addresses implementing green and sustainable remediation (GSR), requirements for new pump and treat systems, and documentation of response complete/site closeout milestones. Consideration of optimization and sustainability concepts throughout the ER process improves performance of the remedial action and reduces the remedy footprint.
For sites where final remedies are not yet selected or implemented, remedy selection optimization efforts utilize scientific advances to select a more effective remediation strategy, develop a flexible Record of Decision (ROD), and use life cycle design concepts. For sites that have operating remedies, optimization offers opportunities for improving the existing remediation system performance, revising the remediation strategy, and streamlining the monitoring program. Remedy optimization efforts ensure that remedial action objectives (RAOs) are met and site closeout or long-term management is achieved in a timely and cost-effective manner.
By applying key optimization concepts, ER managers can ensure that remedial action selection, design, implementation and site closeout are completed efficiently and cost-effectively at each Environmental Restoration Program (ERP) site.
To further enhance optimization opportunities, the DON Installation Restoration Program (IRP) implements its optimization efforts with the reviews noted below:
- Remedial Alternatives Analysis (RAA): The RAA provides for early review of the key elements of the conceptual site model (CSM), remedial action objectives, and the proposed remedial approach
- Quality Document Review (QDR) Directive: The QDR Directive was established to improve resource utilization in support of the continued optimization efforts throughout remediation lifecycle of IRP sites. The QDR process applies to Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Resource Conservation and Recovery Act (RCRA), or State equivalent documents that directly or indirectly evaluate, select, or modify a remedy or path forward at DON IRP sites. The QDR process emphasizes collaborative efforts and provides feedback mechanisms among the Remedial Project Managers (RPMs), Contractors, Subject Matter Experts (SMEs), First-level Supervisors, and ER Managers..
- Ad-Hoc Portfolio Sites Review: This review process is a NAVFAC HQ initiative that brings together a team of both internal NAVFAC and external industry SMEs to provide optimization reviews on IRP sites. In many cases these sites are pre-ROD and complex and have not met the response complete (RC) goal. In other cases, they are post-ROD sites with long-tail operations and maintenance (O&M) and monitoring. NAVFAC headquarters (HQ), along with the ER Managers, selects the sites to be included in this portfolio review.
For more information, Chapters 6 to 11 of the DON Environmental Restoration Program Manual describe how the Navy incorporates optimization throughout the CERCLA process.