Improving Environmental Site Remediation Through Performance-Based Environmental Management (RPO-7)

As noted in the Interstate Technology & Regulatory Council (ITRC) Remediation Process Optimization (RPO) Team’s first technical regulatory guidance document, Remediation Process Optimization: Identifying Opportunities for Enhanced and More Efficient Site Remediation (ITRC 2004), federal, state, and private-sector organizations will continue—for the foreseeable future—to spend billions of dollars on the characterization and assessment of contaminated environmental media and on the selection, construction, operation, maintenance, and monitoring of environmental remediation systems. As numerous environmental cleanup statutes and their implementing regulations evolved, it was initially assumed that these programs could follow a basic “study, design, build” linear paradigm. However, years of experience have led to the realization that the significant uncertainty inherent in environmental cleanup requires more flexible, iterative approaches that manage uncertainty. Uncertainty, as demonstrated by frequently missed target dates, has forced the development of mechanisms that allow for both the systematic reevaluation of initial objectives and the continuous improvement and optimization of remediation technologies and techniques. These mechanisms and reevaluations are known collectively, or generally, as RPO. The team has identified a related concept—performancebased environmental management (PBEM), a method of project management that relies on establishing, and working towards, performance objectives rather that managing only the process. The ITRC RPO team developed this guide to respond to that realization. Schedules for projects in the operating and maintenance or long-term remedial action phase are frequently measured not in years but in decades. In such instances, RPO and PBEM are not just desirable; they are essential.