Considerations for Adaptive Management at Superfund Sites

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

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Adaptive management is a formal and systematic site or project management approach
centered on rigorous site planning and a firm understanding of site conditions and
uncertainties. This technique, rooted in the sound use of science and technology,
encourages continuous re-evaluation and management prioritization of site activities to
account for new information and changing site conditions. A structured and continuous
planning, implementation and assessment process allows EPA, states, other federal
agencies (OFAs), or responsible parties (PRPs) to target management and resource
decisions with the goal of incrementally reducing site uncertainties while supporting
continued site progress.

The workgroup determined that, for the Superfund remedial program, AM could be applied at
the site or the project level. At the site level, AM is focused on achieving broad site objectives,
making it generally better suited for complex sites in the earlier stages of the Superfund process.
At the project level, AM can target specific project uncertainties in the remedial
investigation/feasibility study (RI/FS) or remedial design/remedial action (RD/RA) phases. It
may also be applicable to projects where remedial progress may appear stalled in the long-term
operations and maintenance (O&M) phase.

PH OT IMPLEMENTATION

The AM workgroup focused on six site- and project-level pilots. The three site-level pilots were
Bonita Peak Mining District in unincorporated Colorado; the Baytown Township Groundwater
Plume in Washington County, Minnesota; and the 10th Street Superfund Site in Columbus,
Nebraska. The project-level pilots were the Bunker Hill Lower Basin in Smelterville, Idaho; and
two Federal Facilities, Operable Unit 1 at the Naval Base Kitsap Keyport in Keyport,
Washington; and Site 1, Dudley Road Landfill, Operable Unit 33 at the Naval Weapons Station
Yorktown in Yorktown, Virginia. Each pilot provided unique application, perspective and
lessons learned for AM's potential future role in the Superfund remedial program.

WESSONS l l' AUM I) AND RECOMMEND A TTONS

Building a Team and Designating Roles

• Include primary partners and stakeholders, as applicable (including but not limited to,
state counterparts, tribes and responsible parties), relevant to the selected site or project in
the AM process. This inclusion can create mutual understanding of short- and long-term
goals for the site or project.

• The lead agency for the remedial cleanup should typically be responsible for initiation of
the AM process. Federal Facility sites were piloted during this project, led by the EPA
AM workgroup and its extramural contractors. In the future, the lead agency should
generally be the one to lead the AM process.

• An independent facilitator is beneficial to guide the process and balance differing
perspectives in a neutral way; however, team members should expect that such an
individual is unlikely to have site-specific knowledge and experience.

• Include team members early in the AM process, including technical support, legal and
management. Include these members in the initial planning exercise to develop the main

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AM project or site plan, if possible (although it bears noting that such inclusion takes
considerable time and effort if involving the full team). This inclusion will ensure that
expectations of site goals and timelines are reasonable from the technical, legal and
program perspectives.

Application of Adaptive Management

• AM can provide meaningful structure to particularly complex sites in the earlier stages of
the Superfund process or to sites lagging on the path to completion. Sites may be
considered complex due to size and scope, technical difficulty, and/or community
involvement.

o For complex sites, site-level AM may consist of early actions followed by a final
action, whereby an AM plan guides achievement of remedial action objectives
and remediation goals. AM can also be used at the project level where specific
project uncertainties are targeted in discrete phases, such as RI/FS, RD/RA or
O&M.

o The application of AM may not be necessary or useful for every site due to the
large upfront time and resource investment and nature of the cleanup action, such
as final remedies, interim remedies or early actions.

• AM can result in possible "scope creep" and overambitious timelines; therefore, site
teams should develop an AM plan within the site's current remedy, scope and budget.

• AM may help to establish a mutual understanding across regulatory stakeholders
regarding whether conditions warrant a remedy modification, but it does not replace the
existing requirements or processes for documenting post-record of decision changes.

• AM requires a greater time and resource investment upfront but can result in overall
project efficiency and alignment of expectations across stakeholders.

• Most pilot teams recommended updating AM plans approximately once per year to sync
them with other annual site planning activity updates.

Future Considerations and Implementation

• There is some redundancy between an AM plan and a Site Strategy. The Site Strategy
team may recommend AM as a follow-up tool where particularly complex projects or
sites could benefit from more detailed and adaptive planning practices.

• It could be beneficial for remedial project managers to have access to extramural AM
contractor support as a technical resource for development of site- and project- specific
documents, meeting facilitation, etc.

ADDITIONAL RESOURCES
Sediment Sites

AM is one option for planning remediation at Superfund sediment sites with long remediation
times and high levels of uncertainty regarding the remedial actions necessary to achieve final,
protective remediation goals. The new Sediment Assessment and Monitoring Sheet (OLEM
9200.1-166, June 2022) describes how site-level AM can be applied to large, complex
contaminated sediment sites in a manner consistent with the Comprehensive Environmental
Response, Compensation, and Liability Act and the National Oil and Hazardous Substances
Pollution Contingency Plan.

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Technical Assistance

The Office of Superfund Remediation and Technology Innovation (OSRTI) is well positioned to
provide a variety of technical and policy support in line with AM concepts. Site teams should
contact the appropriate OSRTI regional coordinator to discuss support needs (the Site
Assessment and Remedy Decisions Branch for RI/FS and remedy selection; the Construction and
Post Construction Management Branch for post-remedy selection). Similarly, for Federal Facility
sites, regions should contact their regional coordinator in the Federal Facilities Restoration and
Reuse Office (FFRRO) to discuss AM at Federal Facility sites. Contact information for all
regional coordinators (including FFRRO) is kept current on the OSRTI SharePoint site.

Employing headquarters regional coordinators in site-specific AM efforts creates a foundation to
expand the Superfund program's knowledge and appropriate use of AM. Headquarters will use
regional technical assistance requests to inform efforts to assess additional AM training and
assistance, which may be necessary to support regional needs and to apply AM effectively at
Superfund sites.

CONCLUSION

By providing a framework for structured and continuous planning, implementation and
assessment, AM application in the Superfund process may help reduce site uncertainties while
supporting continued site progress. A given site or project's suitability for AM will vary;
therefore, regional site teams should work with the appropriate headquarters office to help ensure
its application is appropriate and successful.

cc: Barry Breen, OLEM

Carlton Waterhouse, OLEM
Dana Stalcup, OLEM/OSRTI
Brigid Lowery, OLEM/OSRTI
Pam Barr, OLEM/OSRTI
Barbara McDonough, OLEM/OSRTI
Kathleen Salyer, OLEM/OEM
Greg Gervais, OLEM/FFRRO
Cyndy Mackey, OECA/OSRE
Sally Dalzell, OECA/FFEO
Remedial Branch Chiefs, Regions 1-10
NARPM Co-Chairs

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