When it comes to in-situ injection remedies there is no one-size fits all solution. A good conceptual site model enables injection remedy designers to get it right the first time; well, almost right the first time. That is correct, ‘almost right‑the‑first‑time’ because even the best investigation tools and conceptual site models are unable to fully predict behavior, performance, and implementation issues of injection remedies. Today’s changing paradigm for injection remedies recognizes need to embrace adaptive optimization along the way.
For example, the Interstate Technology & Regulatory Counsel (ITRC) released a 2020 Guidance Document1 entitled Optimizing Injection Strategies and In Situ Remediation Performance details how ineffectiveness can be avoided through effective up-front characterization and design, attentive monitoring and performance interpretation, and follow-on in-progress enhancements (aka adaptations and optimization initiatives) as informed by performance monitoring results. Driven by firsthand knowledge and experiences, this guidance document provides valuable insight for environmental consultants, responsible parties, federal and state regulators, and community and tribal stakeholders.
From EHS Support’s perspective, agencies have largely embraced the use of adaptive management and adaptive optimization for injection-based remedies. Yet regulators remain conflicted as some of their (aged) statutes, rules, and guidance are written in a linear fashion (assess, design, construct, implement, monitor, close when cleanup objectives are met) – offering little or no path for refining the remedy along the way.
EHS Support is skilled at navigating the nuances of the rigid and linear-thinking legacy regulations. Through this experience, we have found that incorporating a more-modern path to cost-effectiveness garners optimum performance leading to a more-timely and more-cost effective remedy completion.
If you would like to discuss in more detail, EHS Support’s team of subject matter experts are here to help:
Will Harms, In-Situ Remediation Services Practitioner
John Bartos, Senior Remediation Hydrogeological Engineer
Rich Landis, Senior Innovative Technologies Practitioner
Laurel Seus, Remediation Microbiologist
Sources
1 ITRC. 2020. Optimizing Injection Strategies and In situ Remediation Performance. OIS-ISRP-1. Washington, D.C. OIS-ISRP Team. 2020 Guidance Document: https://ois-isrp-1.itrcweb.org/
