United States
Environmental Protection
Agency
Office of Emergency and
Remedial
Response
EPA540-R-98-017
OSWER 9355.0-70
PB98-963304
July 1998
«£PA Updating Remedy Decisions
at Select Superfund Sites
Summary Report
FY 1996 and FY 1997
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9355.0-70
PB98-963304
EPA540-R-98-017
July 1998
Updating Remedy Decisions
at Select Superfund Sites
Summary Report
FY 1996 and FY 1997
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, DC 20460
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Summary Report FY96 and FY97
Overview
Updating Remedy Decisions initiative has been characterized as one of EPA's most successful Superfund
reforms. During FY96 and FY97, EPA updated remedies at over 140 sites, reducing estimated future cleanup
costs by more than $745 million. Other key successes and findings include the following:
Most remedy updates completed during FY96 and FY97 were the result of additional technical
information gathered as part of the remedy design process. A small number of remedy updates were
the result of non-technical changes in applicable, relevant and appropriate requirements (ARARs),
land use, or required cleanup levels. Another small number of remedy updates were the result of
State input or community preference which focused on either technical or non-technical modifica-
tions to the remedy.
The total estimated future cost reductions (cost savings) for remedy updates in FY96 exceeded $350
million, of which over $325 million was based on advances in science and technology. For remedy
updates completed in FY97, the total estimated cost savings exceeded $390 million, of which over $270
million was based on science and technology advancements. There were no remedy updates that
resulted in estimated cost increases during FY96, and there were five remedy updates in FY97 with cost
increases totaling an estimated $13.5 million.
During FY96 and FY97, most of the individual remedy updates generated estimated cost savings.
These savings ranged from $5,000 to $82,000,000, with a majority generating estimated savings under
$10,000,000. A few remedy updates, however, generated estimated cost increases. The five remedy
updates in FY97 that resulted in estimated cost increases ranged from $300,000 to $12,000,000.
Remedy updates generally occurred in the remedial design phase of the cleanup process and were
more likely to be documented with Explanations of Significant Differences (ESDs) than Record of
Decision (ROD) Amendments. Over the 2-year period, there were 101 ESDs and 40 ROD Amend-
ments representing remedy updates with both cost savings and increases.
Most remedy updates in FY96 and FY97 were initiated by parties outside of EPA (e.g., potentially
responsible parties (PRPs), States, communities, Federal facilities). Over the 2-year period, parties
outside EPA initiated 90 updates and EPA initiated 34 updates (these numbers do not include 24
updates initiated by more than one party). These numbers are consistent with the percentage of EPA
vs. non-EPA parties who conduct the actual cleanup work (e.g., since the inception of Superfund, the
party lead for remedial design is approximately 70 percent non-EPA and 30 percent EPA).
Over the 2-year period, ground water (77 updates) and soil (73 updates) were the most commonly
addressed media. Another nine different media types were addressed by remedy updates during FY96
and FY97.
Most of the remedy updates involved some kind of State participation and/or community involvement.
Common forms of communication between the parties included the following: public notices, public
meetings, public or State comments on the proposed plan, fact sheets, and public availability sessions.
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Summary Report FY96 and FY97
Table of Contents
Overview i
1.0 Introduction 1
2.0 Background 1
3.0 Reform Description 1
4.0 FY96and FY97 Results 2
Exhibit 1: Estimated Remedy Update Savings by Region for FY96 and FY97 2
5.0 Remedy Update Process 2
Exhibit 2: Estimated Savings Per Remedy Update for FY96 and FY97 3
Exhibits: Updates by Medium in FY96 and FY97 3
Exhibit 4: Remedy Update Initiators in FY96 and FY97 4
5.1 Determination of Remedy Update Type 4
Exhibit 5: ESDs vs. ROD Amendments in FY96 and FY97 5
5.2 Cost as a Remedy Update Driver 5
5.3 State/Tribal and Community Roles 7
Exhibit 6: Community Involvement at Sites with Remedy Updates 7
5.4 Remedy Review Duration 8
Exhibit 7: Approximate Review Time for Remedy Updates in FY96 and FY97 8
6.0 Lessons Learned 8
6.1 Benefits 8
6.2 Site Examples 8
6.3 Update Requests Can Be Denied 10
Stakeholder Comments 10
7.0 Conclusion 11
Acknowledgements 11
Appendix A: Summary of Remedy Update Decisions for FY96 and FY97
AppendixA.1: Summary of Remedy Update Information for FY96 and FY97for
Sites Without Cost I ncreases
Appendix A.2: Summary of Remedy Update Information for FY96 and FY97
for Sites With Cost I ncreases
Appendix B: Summary of Regional Implementation Plans for FY98
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Summary Report FY96 and FY97
1.0 Introduction
Updating Remedy Decisions,
announced in the third round of
Superfund reforms in October
1995, is one of a broad range of
administrative reforms undertaken
to improve the efficiency, speed, and
fairness of cleanups in the
Superfund program. Specifically,
this Reform encourages the Regions
to revisit selected remedy decisions
at sites where significant new
scientific information, technological
advancements, or other consider-
ations will protect human health and
the environment while enhancing
overall remedy cost effectiveness.
This report discusses remedy
updates made during both FY96
and FY97, and:
• Describes the rationale and
implementation of the Reform;
• Provides a summary of
Superfund sites where remedies
have been updated;
• Highlights estimated future cost
reductions (cost savings) or cost
increases expected to result from
updated remedies;
• Summarizes Regional plans for
implementing the reform for
Fund-, PRP-, Federal facility-, and
State-lead sites in FY98; and
• Presents stakeholders with
information on the role of
remedy updates in improving
Superfund implementation.
This report should be of interest to
the following parties who are
typically involved in the Superfund
program: EPA Regional staff, State
environmental agencies, other
Federal agencies, communities and
community-interest groups repre-
senting residents living near
Superfund sites, and regulated
parties that may be responsible for
implementing the selected remedy.
2.0 Background
In 1980, when the Superfund
program was established, there was
little knowledge and even less
experience in cleaning up hazardous
waste sites. Original estimates of
the number and prevalence of
contaminated sites were low, and
initial models of contaminant
movement and behavior, particu-
larly in ground water, were found to
be too simple to explain actual site
conditions. The accumulated
technical and engineering experience
of the 1980s and early 1990s
produced major advances in the
science of contaminant fate and
transport modeling and
remediation, illuminating initial
inefficiencies in the remediation
process at some sites.
EPA sought to encourage remedy
updates that would incorporate such
new information into existing site
cleanups. Thus, in October 1995,
EPA announced the Updating
Remedy Decisions Reform as part
of its third round of Superfund
reforms. As a whole, these reforms
were implemented to make
Superfund cleanups faster, fairer,
and more efficient.
3.0 Reform Description
The purpose of the Updating
Remedy Decisions Reform is to
encourage the Regions to revisit
remedy decisions at certain sites
where significant new scientific
information, technological advance-
ments, or other considerations will
protect human health and the
environment while enhancing overall
remedy and cost effectiveness.
Typically, these updates are made to
reflect new technical information
about the characteristics or volumes
of contamination present or new
expectations regarding the perfor-
mance of selected technologies
under site-specific conditions.
Further, these updates consider the
implications of these factors on
original decision criteria such as
short- and long- term effectiveness
and permanence, implementability,
cost, and community acceptance.
Often, updates are also made to
reflect changes in applicable,
relevant, and appropriate require-
ments (ARARs) or other non-
technical information gathered after
the original decision.
While recognizing that other types
of updates may be appropriate,
EPAs Reform Guidance imple-
menting the reform (Superfund
Reforms: Updating Remedy
Decisions, OSWER Directive
9200.2-22, dated September 27,
1996) targets updates where:
• Updating the remedy technology
or strategy would generally result
in a more cost-effective cleanup;
• Physical limitations are imposed
by the site or where the contami-
nants warrant changes in the
cleanup goals; and
• Site conditions warrant reducing
the scope of site monitoring after
cleanup (monitoring may include
sampling rates, extent of analysis,
or extent of reporting required).
This initiative does not signal any
variations in the Agency's current
policies regarding site cleanup,
including policies regarding remedy
selection, treatment of principal
threats, preference for permanence,
establishment of cleanup levels, or
the degree to which remedies must
protect human health and the
environment. EPA remains commit-
ted to protecting public health,
welfare, and the environment.
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Summary Report FY96 and FY97
4.0 FY96and FY97
Results
More than 140 remedy updates
were completed in FY96 and FY97,
saving over $745 million in esti-
mated site cleanup costs. Updates
during FY96 resulted in a total
estimated cost savings of over $350
million of which over $325 resulted
from updates of the kind identified in
the Reform Guidance. Updates
during FY97 resulted in a total
estimated cost savings of over $390
million of which over $270 million
resulted from updates of the kind
identified in the Reform Guidance.
The difference in the estimated cost
savings between all remedy updates
completed during FY96 and FY97
and remedy updates identified in the
Reform Guidance is that some up-
dates were not based on new science
or technology and therefore can't be
counted as reform-related updates.
The estimated cost savings per update
ranged from $5,000 to $82,000,000,
with all EPA Regions reporting
savings in each year reviewed. Exhibit
1 shows the amount of estimated
savings by Region and by fiscal year.
(Note: Exhibit 1 does not include a
remedy update from the DOE
Hanford site which addressed part of
the overall remedy through value
engineering1 for an estimated cost
savings of $297 million.)
In addition, most of the remedy
updates generated savings of less than
$10 million, as shown in Exhibit 2 (see
page 3). Note: Cost estimates for
several remedy updates are either
unavailable to EPA or incomplete at
the time of this writing. These are
labeled NA/TBD (Not available/To
be determined) and can be found in
Appendices A.1 and A.2.
Exhibit 1:
Estimated Remedy Update Savings
by Region for FY96 and FY97
140-.
120-
100-
«T 80-
.o
I 60-
40-
20-
0
1 2
Based on 143 sites.
s
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3 B
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^
1
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|
456
Region
10
OFY96
OFY97
Remedy updates generated few
cost increases. Only three Regions
reported updated remedies which
generated cost increases during FY97.
The FY97 cost increases were for five
remedy updates, which ranged from
$300,000 to $12,000,000 each, and
totaled $13,500,000. No cost
increases were reported for FY96.
Recent advances in the area of
ground water science and remediation
made these types of decisions good
candidates for remedy updates.
Exhibit 3 shows that during FY96 and
FY97, updates of ground water
remedies were the most common
updates, followed closely by soil
remedy updates (see page 3).
More detailed information regarding
remedy updates can also be found in
Appendices A, A.1 and A.2. Specific
remedy updates are listed by Region
and by site, and include the following
information:
• Type and date of remedy update;
• Update initiator;
• Media involved;
• Summary of remedy change and
factual basis;
• State and community involvement;
and
• Estimated cost savings or cost
increase.
5.0 Remedy Update
Process
After a remedy decision has been
completed at a site (i.e., a ROD is
signed), new information may be
received or generated that could
1 Value Engineering is a highly beneficial technique used in Superfund Federal lead remedial design (RD) and remedial action (RA) projects
managed by the U.S. Army Corps of Engineers (USAGE) to reduce unnecessary cost in engineering projects. This is required by the Office of
Management and Budget (OMB Circular No. A-131, issued January 28, 1988) to be implemented by Federal departments and agencies, when
appropriate. For further information, see EPA memorandum titled, "Implementation of Value Engineering for Corps of Engineer Managed
Superfund Remedial Design and Remedial Action Projects," dated June 27, 1990 and the attached fact sheet titled, "Value Engineering," OSWER
Publication 9355.5-03FS, dated May 1990.
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Summary Report FY96 and FY97
Exhibit 2:
Estimated Savings Per Remedy Update
for FY96 and FY97
increases (3%)
NA/TBD (12%)
>$20M (6%)
>$10M-20M (10%)
no savings (10%)
<$1M (28%)
>$1M-$10M (31%)
Based on 148 sites.
no savings (15)
<$1M (41)
>$1M-$10M (46)
>$10M-$20M (15)
>$20M (9)
NA/TBD (17)
increases (5)
affect how the remedy should be
implemented. This information may
be supplied by a potentially respon-
sible party (PRP), the Federal agency
conducting the cleanup, the support
agency (e.g., other Federal agency or
State/Tribe), or the public and other
interested parties. Data for FY96
and FY97 indicate that more remedy
updates were initiated by parties
outside EPA (e.g., PRPs, States,
communities, Federal facilities) than
by EPA (see Exhibit 4, page 4).
These numbers are consistent with
the percentage of EPA vs. non-EPA
parties who conduct the actual
cleanup work (e.g., since the incep-
tion of Superfund, the party lead for
remedial design is approximately 70
percent non-EPA and 30 percent
EPA). In some cases, remedy updates
have joint initiators because informa-
tion arrived simultaneously from
several parties. In addition, the
exhibit shows that the relative
percent of remedy update initiators
in FY96 and FY97 were not signifi-
cantly different.
Although this new information varies
widely, the Reform Guidance
recommends that EPA pay particular
attention to information which shows
that:
• Updating the remedy may result in
a more cost-effective cleanup;
• Physical limitations imposed by the
site or the contaminants may
warrant changes in the cleanup
goals; or
• Site conditions may warrant
reducing the scope of the site
monitoring after cleanup.
Once new information has been
collected, update requests are usually
sent to the Regional Superfund
manager assigned to the site. Each
Region has developed protocols for
considering update requests, making
it easier for stakeholders to prepare
and request remedy updates.
Currently, no Region reports a
backlog in reviewing requests made
by PRPs or other parties. Appendix
B presents more detail on each
Region's strategy for considering
remedy updates in FY98.
As outlined in the Reform Guidance,
the basic process that Regions should
use to consider proposed remedy
updates consists of three steps:
identification and prioritization,
technical review, and implementation.
• Identification and
Prioritization involves assessing
the update request to determine
the type of change (e.g., remedial
method, cleanup standards,
cleanup area), the resources
required to fully evaluate it, and
any potential increase or decrease
in protectiveness or cost. To
ensure that the Region's rationale
for prioritizing update reviews is
clear and equitable, Regions are
encouraged to carefully track all
requests for remedy updates. In
addition, the review and consider-
ation of potential remedy updates
should not result in any delays in
the completion of work products
or other remediation activities
required by the existing ROD and
enforcement instruments (unilat-
eral administrative orders (UAOs)
or consent decrees (CDs)).
• Technical Review evaluates the
site-specific information support-
ing both the current remedy and
Exhibits:
Updates by Medium
in FY96 and FY97
Medium FY96 FY97 Total
Ground Water 31 46 77
Soil 38 36 74
Surface Water 549
Debris 6 6 12
Sediment 2 10 12
Sludge 437
Leachate 538
Air 213
Solid Waste 538
Gas 101
Liquid Waste 1 0 1
Residuals 1 0 1
Based on 148 sites.
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Summary Report FY96 and FY97
the update request. This review is
conducted by the site's lead entity
(e.g, the Federal agency, Federal
facility, PRR State, or Tribe).
• Implementation involves
preparing and filing the necessary
documentation (a note or memo-
randum to the Administrative
Record file, an BSD, or a ROD
Amendment) to support the
update, consulting with the State
and community, and physically
conducting the updates at the site.
5.1 Determination of
Remedy Update Type
Determining the type of remedy
update and its documentation is a
three-step process. First, EPA or
another lead agency must categorize
the update by asking questions about
the extent to which it changes the
scope, performance, or cost of the
remedy selected in the ROD. This
categorization then allows the lead
agency to determine if the update is a
nonsignificant or minor change, a
significant change, or a fundamental
change to the scope, performance, or
cost of the original remedy. Finally,
the type of change will determine
which document EPA uses to update
the remedy: a memorandum or letter
to the Administrative Record file, an
ESD, or a ROD Amendment (see
NCP §300.435)
Step 1
In order to categorize the update,
remedy update teams ask the
following questions:
• Scope - Does the update alter the
scope of the remedy (e.g., the
physical area of the response,
remediation goals to be achieved,
and type and volume of wastes to
be addressed)?
• Performance - Would the update
alter the performance (e.g.,
treatment levels to be attained,
methodology used to achieve
cleanup goals, and new technology
not considered in the original
ROD) and thus raise concerns
about the protectiveness or long-
term effectiveness of the remedy
that could not have been antici-
pated?
• Cost - Does the update alter
remedial costs and are the changes
in costs of such a nature that they
could not have been anticipated
based on: (1) the estimates in the
ROD; and (2) the recognized
uncertainties associated with the
hazardous waste engineering
process selected?
Step 2
Based on this evaluation, and
depending on the extent or scope of
the modification being considered,
the lead agency must determine the
type of update involved (i.e.,
nonsignificant or minor, significant,
or fundamental change to the scope,
performance, or cost of the original
remedy). An aggregate of nonsig-
nificant or significant changes could
result in a fundamental change
overall. Post-ROD updates fit into
one of these categories:
• A nonsignificant or minor
change usually arises during
design or construction when
modifications are made to the
functional specifications of the
remedy to optimize performance
and minimize cost. Such changes
may affect the type or cost of
materials, equipment, facilities,
services, and supplies used to
implement the remedy. The
changes will not have a major
impact on the scope, performance
or cost of the remedy and will not
require a modification of an
enforcement decision document
(e.g., consent order or decree).
Exhibit 4:
Remedy Update Initiators for FY96
State (8%) City (2%)
Fed. Fac. (3%)
Joint
(17%)
EPA (22%)
Based on 64 sites.
Remedy Update Initiators for FY97
Comm. (2%)
PRP (45%)
Fed. Fac. (12%)
State (2%)
Joint
(15%)
EPA (24%)
Based on 84 sites.
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Summary Report FY96 and FY97
Minor changes might include a
slight increase in the volume of
treated soil, a change in disposal
location, or a modification in
ground water monitoring
specifications.
A significant change generally
involves incremental change to a
component of a remedy that does
not fundamentally alter the overall
remedial approach. Significant
changes to a component of a
remedy may result from an
enforcement action or be part of a
settlement or consent decree
concluded after EPA signs the
ROD. Depending on the signifi-
cance of the change, a formal
public comment period may be
conducted and an enforcement
decision document may need to be
modified. EPA will generally
consult with the Department of
Justice as soon as the Region
believes the remedy update will
require modification of any
related consent order or decree.
A significant change might involve
an increase of over 50 percent in
the volume of soil to be reme-
diated, a change in reasonably
anticipated land use following the
remedy, or a change in an ARAR
that affects cleanup levels and
other parameters.
A fundamental change involves
an appreciable change or changes
in the scope, performance, and/
or cost of a remedy or may
involve a number of significant
changes that together have the
effect of a fundamental change.
Fundamental changes result in a
reconsideration of the waste
management approach (e.g.,
change in the primary remedy for
the wastes, residual risk, cleanup
technology) selected in the
original ROD and must include a
formal public comment period.
Generally, a fundamental change
will lead to modification of the
settlement document, obligating
Exhibits: ESDs vs. ROD Amendments
FY96
FY97
Based on 148 sites.
the settling parties to implement
the response work in question.
EPA routinely consults with the
Department of Justice regarding
any changes it believes are needed
in a settlement document. A
fundamental change might involve
selecting a different primary
treatment technology because of
community preference, discovery
of additional contaminants, or the
determination that less treatment
is needed than originally expected.
Step 3
The type of change will determine
which document EPA uses to update
the remedy: a memorandum or note to
the Administrative Record for a
nonsignificant or minor change; an
ESD for a significant change; or a
ROD Amendment for a fundamental
change. Exhibits indicates the
number of ESDs, ROD Amendments,
and other documents used for
remedy updates in FY96 and FY97.
Two years of reform data show
that, in general, remedy updates
tend to occur during remedy design
and represent a significant but not
fundamental change to the remedy.
Consequently, most remedy
updates correspond to at least one
of the following situations: the
scope of the remedy has changed
(e.g., volume reduction); the
performance of the remedy can be
modified or optimized (e.g., change
in disposal or discharge point); or
there is a more cost-effective way
to implement the remedy.
In rare situations, the original
remedy does not meet the required
cleanup levels specified in the ROD,
thus the determination for an
updated remedy may result in
estimated cost increases.
5.2 Cost as a Remedy
Update Driver
Cost plays a significant role through-
out the entire remedy selection
process and is one of three factors
generally considered when deter-
mining the type of remedy update
(as mentioned in Section 5.1). For
more information on the use of cost
in the selection of remedial actions,
see EPAs fact sheet, "The Role of
Cost on the Superfund Remedy
Selection Process" (OSWER
9200.3-23FS, dated September
1996). This section describes in
more detail the procedures for
estimating cleanup cost from
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Summary Report FY96 and FY97
remedy selection through the
remedy update.
Procedures for Estimating
Original Remedy Cost
At the beginning stages of the
remedy selection process, cleanup
options are often broadly described
in a qualitative manner and the
project scope and schedule are not
well defined. This occurs because it
is extremely difficult to develop a
cost estimate for a project when
there's uncertainty about materials
and labor that will be required or
specific activities that will take place
during the remedial action.
As the site progresses through the
Superfund pipeline and the remedy
is designed, initial remedy cost
estimates are refined and their
accuracy with respect to the actual
project cost increases. As a general
matter, the initial cost estimates used
as a basis for the remedy updates
described in this report are devel-
oped early during the Superfund
process when estimates are expected
to vary.
In the Superfund program, initial
cost estimates are developed during
the remedial investigation/feasibility
study (RI/FS). During the FS, a
cost estimate is developed for each
cleanup alternative to be considered
during the remedy selection process.
The ROD presents the selected
remedy and decisionmaking
rationale, including the cost estimate
for the selected cleanup activity.
Due to the challenges associated
with accurately characterizing sites
before the remedial design/remedial
action (RD/RA) phase, the cost of
remedial actions at the FS stage is
based on engineering assumptions
and data that need to be verified and
more accurately defined during RD.
Recognizing this fundamental
limitation, EPA established an
accuracy expectation for cleanup
cost estimates that are developed
during the FS as part of the remedy
selection process. The estimate
should be accurate within a range of
plus 50 to minus 30 percent. This
means that a study with an estimate
of $100,000 could ultimately cost
between $70,000 and $150,000.
Feasibility cost estimates are
calculated using:
• Direct capital costs, which include
costs of construction, equipment,
buildings, and relocation;
• Indirect capital costs, which
include engineering and design as
well as contingency allowances
[see below]; and
• Operation and maintenance
(O&M) costs, which include the
cost of operating and maintaining
the remedy during a projected
time period.
Contingencies are also factored
into the remedy cost estimate.
Contingencies are specific provi-
sions for unforseen circumstances
which may result in additional costs
(e.g., adverse weather conditions,
inadequate site characterization).
The contingency is used to reduce
the risk of cost overruns and
should be factored into capital and
O&M cost estimates developed
during the FS.
Procedures for Estimating
Updated Remedy Cost
The cost effects of a potential
remedy update generally are first
assessed by the Region during the
prioritization phase of the remedy
update process once the sites have
been prioritized based on the
potential effects on the human health
protection provided for in the
original remedy and the update's
effect on the schedule of the selected
remedy. The Region decides if the
remedy is appropriate for review by
determining the significance of the
potential update's impact on cost. In
addition, the Region considers the
potential remedy update's propor-
tion of the total remedy cost, the
implementation cost of the update,
and the resources required to review
and update the remedy. The latter
expenditures may include, according
to the OSWER Directive "Superfund
Reforms: Updating Remedy
Decisions at Select Sites," "the
administrative costs of modifying a
remedy, which may include prepara-
tion of an ESD or ROD Amend-
ment, responding to the concerns of
parties affected by the remedy
change, and modifying or renegotiat-
ing unilateral administrative orders
(UAOs) or consent decrees."
Remedy updates have similar
uncertainties about material and
labor as the original remedy cost
estimates, and thus have some
variables built into the updated cost
estimates (plus 50 to minus 30
percent).
When Regional remedy update
teams compare costs, they compare
the updated remedy costs to original
remedy costs, both of which
account for some uncertainty during
the remedial process. For this
reason, it is necessary to emphasize
that the estimated savings for each
remedy update represent just that,
an estimate, and is not meant to be
an exact figure. Only as the remedy
progresses towards construction
completion will the actual savings or
cost increases be known. In
addition, because cost savings
estimates compare original remedy
costs to updated remedy costs, any
work completed as part of the
original remedy is not included in
the savings estimates. However, the
effect of these expenditures is
negligable since most updates occur
early in remedy design.
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Summary Report FY96 and FY97
Exhibit 6: Community Involvement at Sites with Remedy Updates
This chart summarizes data
from a random representative sample of 79 ESDs, ROD Amendments,
and Letters to File from both FY96 and FY97 (39 from FY96 and 40 from FY97).
Tvoe of
Community
Involvement
Administrative Record
Public Notice
Public Availability
-
Public Comment Period
Public Meeting
Fact Sheet
E.
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Percentage of Sites Reporting Use Of Community Involvement Activity
5.3 State/Tribal and
Community Roles
State/Tribal
States play an important role in the
modification of remedy decisions.
Both the NCR §300.515 and the
Model CERCLA RD/RA Consent
Decree (which forms the basis for
most consent decrees) provide an
opportunity for States to review
and comment on specified steps in
remedy selection. Agreements
between EPA and States, including
contracts, may require modification
following a remedy update.
Furthermore, the Model Consent
Decree states that the EPA will
provide the State with a reasonable
opportunity to review and com-
ment on any proposed modifica-
tions. Further information
regarding the role of States and
supporting agencies in the remedy
modification process can be found
in the "Interim Final Guidance on
Preparing Superfund Decision
Documents," OSWER Directive
9335.3-02 (October 1989).
Native American Tribes are
afforded substantially the same
treatment as States with respect to
certain provisions of CERCLA
(see CERCLA §126; NCP
§300.505). A Tribe that is Federally
recognized, has a governing body
that is currently performing
governmental functions regarding
environmental protection, and has
jurisdiction over a Superfund site
can be treated essentially the same
as a State (see NCP §300.515).
Community
Although the initiation of a formal
public comment period is required
only in the case of a fundamental
update (i.e., ROD Amendment),
most remedy updates, regardless of
their significance, have a substantial
community involvement component
(see NCP §300.435(c)(2)(i) and (ii)).
For example, documents pertaining
to the site, including any information
on remedy updates, are placed in the
Administrative Record or at the site
repository located in the area of the
site (e.g., local library). Other
activities, including a public availabil-
ity session, public meetings, issuance
of fact sheets about the site, and the
release of an amended proposed
plan, may allow the surrounding
community and other interested
parties an opportunity to learn more
about the site and present their
opinions on remedial activities.
Most remedy updates in FY96 and
FY97 involved State participation
and/or community involvement.
Common forms of communication
between the parties are shown in
Exhibits.
-------
Summary Report FY96 and FY97
5.4 Remedy Review
Duration
Time taken to review site-specific
material and complete the memo-
randum, BSD, or ROD Amend-
ment, was generally less than a year
for most remedy updates completed
during FY96 and FY97. As
demonstrated in Exhibit 7, most of
the ESDs and ROD Amendments
issued took less than one year to
complete. A brief survey of sites
with longer remedy review times
shows that these durations can be
influenced by:
• A lengthy, but important, public
involvement phase;
• A protracted verification/pilot test
period following the discovery of
new performance, technical, or
toxicological data;
• The discovery of unexpected
contamination late in the remedy
design phase; or
• A redefinition of land use.
Specific examples of remedy changes
whose reviews lasted more than one
year may be found in Section 6.2.
6.0 Lessons Learned
Through two years of reform
implementation, EPA has gained
insight into ways of successfully
updating site remedies. The
following section details informa-
tion collected regarding reform
benefits, site examples, and com-
ments from stakeholders.
6.1 Benefits
This reform has been very successful
in bringing past decisions in line with
current science and technology. By
doing so, these updates improve the
cost-effectiveness of site remediation
while ensuring reliable short- and
long-term protection of human health
and the environment. The quantifi-
Exhibit 7:
Approximate Review Time for
Remedy Updates in FY96
<1YEAR >1- 2 YEARS >2-3 YEARS
Approximate Review Time for
Remedy Updates in FY97
Based on 64 sites.
Based on 84 sites.
able results of this reform have been
announced in EPAs testimony
before Congress, private industry
evaluations of Superfund reforms,
and a report of the U.S. General
Accounting Office. Of additional
note is EPAs overwhelmingly
positive record of responding to
remedy update requests made by
outside parties.
6.2 Site Examples
In many cases, remedies were
updated because of a decrease or
increase in contaminant volume or
because of the inability to achieve
desired results in a test of the ROD-
selected treatment or containment
technology during the remedial
design phase of the cleanup. Al-
8
-------
Summary Report FY96 and FY97
though all updates described in
Appendices A and B represent site-
specific situations, it is possible to use
some as site examples of several
trends. The following represent
examples of some remedy update
situations that occurred during FY96
and FY97.
Updates Based on New
Technology
Some updates were the result of new
technology that wasn't considered in
the original remedy. At the Davis
Liquid Waste site in Rhode Island,
United Technologies proposed an
update based on performance data.
This data indicated the increased
effectiveness and reduced implemen-
tation costs of using thermal
desorption instead of incineration,
resulting in a savings of $5 million.
In some cases, the selection of a new
technology will substantially reduce
the cleanup time, such as at Avco
Lycoming in Pennsylvania. Here
Avco/Textron Lycoming proposed
a remedy update based on successful
pilot tests of molasses injection for
metals treatment and air sparging/
soil vapor extraction for organics
treatment. This update reduces the
cleanup time by 33 percent and saves
an estimated $5.3 million.
Updates Based on New
Performance Data
New performance data can provide
the needed information for updating
remedies. The update at Auburn
Road Landfill in Massachusetts
reflects an approach to ground water
contamination that relied on
modeling and two years of perfor-
mance data. The remedy was
updated from pump and treat to
monitored natural attenuation once it
was proven that volatile organic
compound (VOC) levels had
dropped below cleanup levels in
most areas, saving $12 million. At
the Coakley Landfill site in New
Hampshire, Coakley Landfill
Group gathered new data during the
pre-design phase of the remedy. This
data indicated lower gas production
volumes so that a passive gas
collection and venting system could
be substituted for the costlier active
collection and incineration option.
This remedy modification resulted
in $0.7 million estimated savings.
Coordinating the Update
Some remedy updates involve
coordination among EPA, other
Federal agencies, and State and local
government agencies. One remedy
update was tied to county redevelop-
ment (Rentokil, Virginia), while
two other updates involved discus-
sions with several parties as part of a
technical impracticability (Tl) waiver
determination. For example, at the
Crystal Chemical site in Texas,
Southern Pacific Transportation
substituted a slurry wall containment
remedy for a pump and treat remedy
after proving that restoration of
ground water at some parts of the
site was deemed technically impracti-
cable, resulting in estimated savings
of $2.8 million. At the South
Municipal Water Supply Well site
in New Hampshire, EPA granted a
Tl waiver due to the discovery of
dense non-aqueous phase liquids
(DNAPLs) during pre-design
sampling. This saved an estimated
$3.5 million.
State Input in the Update
States can be either the lead or the
support agency for a remedy
update. For example, at the
Kummer Sanitary Landfill in
Minnesota, the State initiated the
remedy update, conducted public
involvement activities, and wrote a
ROD Amendment to change a
remedy based on the availability of
additional site data to save an
estimated $5.6 million.
Community Preference
Community involvement can be the
basis for the remedy update and, in
some cases, may conflict with the
best technology available to address
the contamination. During one
update at the Brown's Battery
Breaking site in Pennsylvania, the
community preferred a different
location for the treatment facility,
while during another remedy update
(at the Tucson International
Airport in Arizona), the commu-
nity preferred a method for ground
water discharge that differed from
the original remedy which dis-
charged treated ground water to the
local water distribution system.
Cost Increases
Although the Reform Guidance is
aimed at controlling site costs, there
are remedy updates that result in
cost increases, especially when data
discovered during remedial design
demonstrates that a selected
technology does not function under
current conditions at the site. For
example, at the Robintech site in
New York, Buffton Corporation
gathered additional information
during the design phase which
indicated that the geology of the
shallow aquifer was unsuitable to
implement the previously selected
ground water extraction systems.
For this reason, the treatment was
changed to excavation and treat-
ment using low temperature thermal
desportion for soils, monitored
natural attenuation for shallow
aquifer ground water, and pump and
treat of water from the bedrock
aquifer, increasing the cost of the
remedy by an estimated $0.7
million. At the Imperial Oil/
Champion Chemical site in New
Jersey, sampling conducted during
the design phase revealed a higher
level of soil contamination than
previously thought. This discovery
resulted in additional excavation and
-------
Summary Report FY96 and FY97
off-site disposal at a cost yet to be
determined.
Timeframe for Complet-
ing Remedy Updates
The time needed to complete an
update varies with each site. For
example, the ground water remedy
at Savannah River, South Caro-
lina, was updated in as little as 11
days. Department of Energy
testing during the remedial action
(RA) phase demonstrated that a
recirculation well was not effective.
EPA decided to remove the well
from the treatment plan, saving an
estimated $0.1 million. The soil/
sediment remedy at the Cleveland
Mill site in New Mexico was
updated in only one month. The
Mining Remedial Recovery
Company proposed updating the
remedy to onsite containment when
a large volume of acid mine runoff
caused the need for an immediate
response. Additionally, a soil/
sludge remedy was proposed by
GATX Corporation and updated in
one month at the Saegertown
Industrial Area in Pennsylvania.
At this site, off-site thermal
treatment facilities were expanded
to include a different type of boiler,
resulting in a savings of $4.6
million.
Other updates do not occur so
quickly, as at the Preferred Plating
site in New York. At this site, the
ground water remedy update took
over three years to complete but
saved an estimated $9.3 million.
The remedy was updated from
active extraction and treatment to
monitored natural attenuation
because sampling identified space
restrictions and a "natural" decline
in contaminant concentrations over
time. The review for a soil remedy
update at the Koppers (Oroville)
site in California site took over
two years to complete. Unfavor-
able treatability testing results, the
Stakeholder Comments
In the Chemical Manufacturers Association's Report, "A
Chemical Industry Perspective on EPA's Superfund Administra-
tive Reforms," April 1997, the following quotes were made:
"Of the five reforms covered in this report, the updating
of previous RODs reform generated the most positive
comments, both from PRPs and from EPA (pg. 15);"
"In sum, this reform has produced the greatest tangible
benefits of any of EPA's Superfund administrative reforms
(pg. 18);"
"PRPs confirm that some remedies are being updated
and that additional petitions to update remedies are pending
(pg. 15);" and
"Of all of the EPA reforms announced in October, 1995,
this is the one that has produced the most tangible results
(pg. 17)."
In their December 1996 report, "EPA's Superfund Reforms: A
Report on the First Year of Implementation," the Superfund
Settlements Project said:
"In another key reform aimed at making 'smarter
cleanup choices,' EPA will now entertain requests to
updates earlier remedy decisions when significant new
scientific information or technological advances will achieve
the same level of protectiveness at lower cost" (pg.8); and
"Significantly, although the EPA Headquarter guidance
focused primarily on DNAPLs in ground water, both Regions
[I and III] have applied EPA's guidance to remedies outside
the DNAPL context. In fact, several sites involved updating
old remedies calling for on-site incineration and adopting
thermal desorption (e.g., Davis Liquid Waste) or off-site
incineration (e.g., Saunders Supply Co.) (pg.20).
discovery of more extensive mixed
contamination, and a change in land
use scenario resulted in a remedy
update that may save an estimated
$15 million.
6.3 Update Requests
Can Be Denied
Not all remedy update requests are
approved by EPA. Some have
proposed remedy updates that are
not as protective or reliable as the
original remedy. At the Sharkey
Landfill site in New Jersey, the
proposal to modify the capping
70
-------
Summary Report FY96 and FY97
remedy was denied because it was
not protective of the environment.
At the Chem-Solv Site in Dela-
ware, the request to update the
remedy by eliminating ground water
protection was denied because
sampling of the local ground water
supply down gradient of the site
demonstrated the continuing threat
posed by the site. Even though an
update request has been denied, new
information may be gathered and
another update may be submitted at
a later time.
Guidance currently under develop-
ment by EPA. Specific questions on
implementation of this reform may
be directed to Matt Charsky of the
Office of Emergency and Remedial
Response by telephone at (703) 603-
8777 or e-mail at
charsky.matthew@epamail.epa.gov
or FAX at (703) 603-9133. Each
Region also has a remedy update
contact who can be accessed by
contacting the Superfund Program
area in any of EPAs 10 Regional
offices.
Acknowledgements
This report is a reality because of the
dedicated efforts of numerous EPA
Superfund staff. Regional remedial
project managers (RPMs) responsible
for considering and implementing
remedy updates at Superfund sites are
to be commended for making these
changes so that the best technologies
available are in place at all sites
nationwide.
This report was prepared for EPA
under contract #68-W6-0038.
7.0 Conclusion
Generally EPA and outside parties
consider the Updating Remedy Decisions
reform a success during both FY96 and
FY97. The number of remedies
updated by each Region during both
FY96 and FY97 clearly shows that all
10 Regions are implementing this
reform, with most Regions reporting
estimated cost savings above $50
million for the 2 fiscal years combined.
The Regional implementation plans for
FY98 do not signal any change to the
current remedy updating process. All
10 Regions continue to evaluate
requests to review old Fund-lead
remedies as well as consider updates to
more recent remedies that may not be
up-to-date with current science or
technology. Regions continue to
encourage outside parties to submit
remedy update requests to EPA when
new technical information exists to
support them. For the most part, EPA
and outside parties share the benefits
of both cost and time savings as part
of implementing the update in
remedy.
Interested parties should review the
existing Reform Guidance (OSWER
Directive 9200.2-22) for basic
information concerning the reform.2
Additional guidance on remedy
updates will also be included in the
updated Record of Decision
2 The Reform Guidance can be accessed through the Internet at http://www.epa.gov/superfund/oerr/remedy.htm.
77
-------
Appendix A:
Summary of Updated Remedy Decisions
for FY96 and FY97
NOTE: The information and data presented in Appendix A have been supplied to EPA
Headquarters by Regional offices. The data is subject to occasional updates as new information
is received, thus Appendix A data should be used for informational purposes only.
-------
Appendix A:
SUMMARY OF UPDATED REMEDY DECISIONS FOR FY96
Reg.
1
2
3
4
5
6
7
8
9
10
#With
No Sav.
1
0
0
4
0
1
1
0
1
0
#of
TBD
0
0
1
0
0
0
2
1
3
0
#With
Est. Sav.
5
1
13
6
7
3
5
3
3
3
#With
Est. Incr.
0
0
0
0
0
0
0
0
0
0
Est.
Savings
$56.3M
$9.6M
$46.3M
$24.4M
$73. 1M
$5.2M
$4.4M
$2.0M
$41.2M
$90.2M
Est.
Increase
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Change Initiator
2 PRP 2 EPA 1 STATE
1 JOINT
1PRP
10 PRP 1EPA 3 JOINT
3 PRP 4 EPA 2 JOINT
1 STATE
3 PRP 1 EPA 1 STATE
2 JOINT
2 PRP 2 EPA
3 PRP 2 EPA 2 STATE
1 CITY
2 PRP 1 EPA 1 JOINT
3 PRP 2 FED FAC
2 JOINT
2 PRP 1 EPA
Type of Change
4 ESD 1 ROD-A 1 Memo
1ESD
1 1 ESD 3 ROD-A
7 ESD 3 ROD-A
3 ESD 4 ROD-A
3 ESD 1 ROD-A
5 ESD 1 ROD-A 2 Letters
4 ESD
5 ESD 2 ROD-A
1 ESD 2 ROD-A
Totals
49
S352.7M $0
31 PRP
5 STATE
1CITY
14 EPA 11 JOINT
2 FED FAC
64 sites
64 sites
44 ESD 17 ROD-A 3 Other
64 sites
Appendix A
-------
Appendix A:
SUMMARY OF UPDATED REMEDY DECISIONS FOR FY97
Reg.
1
2
3
4
5
6
7
8
9
10
#With
No Sav.
0
1
2
1
0
1
1
2
3
0
#of
TBD
0
2
2
2
2
0
0
0
1
0
#With
Est. Sav.
6
6
7
8
14
5
2
2
4
5
#With
Est. Incr.
0
1
(+1TBD)
0
2
0
0
0
0
1
0
Est.
Savings
$20.3M
$43. 6M
$9.1M
$36.8M
$138. 3M
$36.3M
$6.2M
$2.0M
$73. 2M
$29. 1M*
Est.
Increase
$0
$0.7M
$0
$12.3M
$0
$0
$0
$0
$0.5M
$0
Change Initiator
2 PRP 3 EPA 1 STATE
1 PRP 6 EPA 4 JOINT
6 PRP 2 EPA 1 FED FAC
1 JOINT 1 COMM
6 PRP 3 EPA 3 FED FAC
1 JOINT
10 PRP 2 EPA 4 JOINT
4 PRP 1 JOINT 1 COMM
2 PRP 1 FED FAC
2 EPA 1 FED FAC
1 JOINT
3 PRP 2 EPA 4 FED FAC
3 PRP 1 STATE
1 JOINT
Type of Change
5 ESD 1 ROD-A
7 ESD 4 ROD-A
9 ESD 2 ROD-A
8 ESD 5 ROD-A
1 1 ESD 5 ROD-A
2 ESD 3 ROD-A 1 Other
1 ESD 2 Letters
3 ESD 1 Other
9 ESD
3 ESD 2 ROD-A
Totals
11
59 4+1TBD S394.9M S13.5M 37 PRP 20 EPA 13 JOINT 58 ESD
10 FED FAC 2 STATE
2 COMM
22 ROD-A 4 Other
84 sites
* Not included is the DOE Hanford site which has an estimated cost savings of $297 million.
84 sites
84 sites
Appendix A
-------
Appendix A.I:
Summary of Remedy Update Information for FY96 and
FY97 for Sites Without Cost Increases
NOTE: The information and data presented in Appendix A. 1 represents only a portion of the
information available in the decision document. If more information is needed, please refer to
the site's ESD, ROD-Amendment, memo-to-file, or letter.
-------
Appendix A.I:
Summary of Remedy Update Information for FY96 and FY97 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 1 - FY97
Region 1
Auburn Road Landfill,
NH
Region 1
Groveland Wells, MA
Region 1
PSC Resources, MA
9/29/89
12/19/96
[ROD-A]
1993
7/1/96
EPA
Groundwater
State helped compile ROD; public
notified; public comment period;
public meeting held. State
concurred.
Fed = 250 hrs;
Contr. = $0
Est'd Savings =
$12 million
Type of Change: From - pump and treat of groundwater; To - monitored natural attenuation and long-term monitoring.
Factual Basis: Groundwater modeling and two years of performance data show VOC contamination fell below cleanup
levels; no pump and treat facility to be built.
9/30/91
11/15/96
[BSD]
1/30/96
11/15/96
EPA
Groundwater
State concurred; public notice and
fact sheet issued; public comment
period; public meeting held.
Fed = 500 hrs;
Contr. = $0
Est'd Savings =
$1.6 million
Type of Change: From - Treatment system to treat entire plume; To - reduced size of treatment system, and From - active
treatment in less concentrated portion of plume; To - monitored natural attenuation.
Factual Basis: New field data obtained by EPA during remedy design; reduced volume of groundwater to be pumped and
treated.
9/15/92
1 1/26/96
[BSD]
3/96
11/96
PRP
Sediment,
Soil
Comment on ESD; public notice;
public meeting.
Fed = 400 hrs;
Contr. = $0
Est'd Savings =
$1 million
Type of Change: From - in-situ stabilization; To - ex-situ stabilization, and From - permeable cap; To - impermeable cap.
Factual Basis: Needed improved means of stabilizing soils and sediments, physical obstacles impeded in-situ mixing.
Appendix A.1
-------
Region
Site Name, State
Region 1
Salem Acres, MA
Region 1
Savage Municipal Water
Supply Well, NH
Region 1
South Municipal Water
Supply Well, NH
Date of
Original ROD
Date of Change
[ESD/ROD-A]
3/25/93
4/11/97
[BSD]
Date Review
Commenced
Date Review
Completed
3/1/97
4/11/97
Change
Initiator
PRP
Media
Sediment,
Soil
State/
Community
Involvement
State concurred; public notified.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 200 hrs;
Contr. = $0
Est'd Savings =
$0.7 million
Type of Change: From - original ROD cleanup levels; To - reduced soil cleanup levels.
Factual Basis: BSD established cleanup levels for carcinogenic PAHs for which there previously were no levels.
9/27/91
12/9/96
[BSD]
6/1/95
12/9/96
State
Groundwater
State proposed changes; public
meeting held by State.
Fed = 390 hrs;
Contr. = $10,000
Est'd Savings =
$1.5 million
Type of Change: From - extract and treat using ultraviolet oxidation; To - air stripping with carbon adsorption; add slurry wall,
extraction wells, and soil vapor extraction system.
Factual Basis: Design studies revealed presence of DNAPLs.
9/27/89
2/3/97
[BSD]
5/15/96
1/29/97
EPA
Groundwater,
Soil
State concurred; public notified;
public comment period; no
community comments.
Fed = 300 hrs;
Contr. = $5,000
Est'd Savings =
$3.5 million
Type of Change: From - groundwater treatment and soil vacuum extraction; To - hydraulic containment.
Factual Basis: DNAPLs found in pre-design data; technical impracticability waiver was granted.
Appendix A.1
-------
Region
Site Name, State
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 1 - FY96
Region 1
Coakley Landfill, NH
Region 1
Davis Liquid Waste, RI
Region 1
Gilson Road, NH
6/28/90
5/17/96
[BSD]
3/8/96
4/11/96
PRP
Landfill gas
State concurred; public comment
period; no community comments.
Fed. = 80 hrs;
Contr. = $1,000
Est'd Savings =
$0.7 million
Type of Change: From - active landfill gas collection and incineration; To - passive collection and venting.
Factual Basis: New data in pre-design indicated lower gas production volumes.
9/29/87
7/19/96
[BSD]
4/21/94
3/25/96
PRP
Soil
State concurred; no comments from
community except 2 non-settling
PRPs.
Fed= 150 hrs;
Contr. = $0
Est'd Savings =
$5 million
Type of Change: From - on-site incineration; To - on-site low temperature thermal desorption.
Factual Basis: Performance data indicated increased effectiveness and reduced implementation costs using new technology.
9/22/83
12/29/95
[Other: memo]
9/30/94
12/29/95
State
Groundwater
State responsible for change; public
notified.
Fed = 120 hrs;
Contr. = $0
Est'd Savings =
$3.6 million
Type of Change: From - groundwater pump and treat; To - monitoring only.
Factual Basis: Remedy attained ROD remediation goals and met alternate concentration limits for groundwater.
Appendix A.1
-------
Region
Site Name, State
Region 1
Landfill & Resource
Recovery, RI
Region 1
Norwood PCB, MA
Region 1
Pinettes Salvage Yard, ME
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/29/88
9/16/96
[BSD]
Date Review
Commenced
Date Review
Completed
6/96
9/16/96
Change
Initiator
EPA,
PRP
Media
Landfill debris
(that could
migrate to
groundwater)
State/
Community
Involvement
State reviewed draft ESD and
deferred concurrence until
resolution of an existing State
consent order; ESD will be made
part of Administrative Record;
community not involved.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 60 hrs;
Contr. = $0
Est'd Savings =
no analysis of cost
savings
Type of Change: From - groundwater cleanup not directly required in ROD; To - clarification of groundwater performance
standards, for example, maximum contaminant levels (MCLs) to be used to evaluate performance of landfill closure.
Factual Basis: Clarify that MCLs were included in the original ROD to monitor the integrity of the landfill closure and provide
maximum protection to groundwater.
9/29/89
5/17/96
[ROD-A]
5/95
5/17/96
EPA
Sediment,
Soil,
Building
Material
Revised remedy sent to
State/community for review during
public comment period. State
concurred.
Fed = 500 hrs;
Contr. = $0
Est'd Savings =
$45 million
Type of Change: From - on-site solvent extraction; To - on-site consolidation under impermeable asphalt cap and From -
building remediation; To - building demolition.
Factual Basis: ROD treatment impracticable due to space constraints and safety issues; new cleanup goals based on future land
use and changes in risk assessment methodologies; new remedy more cost-effective.
5/30/89
6/20/96
[BSD]
3/25/95
6/20/96
EPA
Groundwater
Town consulted; State involved in
review; announcement made to
community.
Fed = 580 hrs.;
Contr. = $0
Est'd Savings =
$2 million
Type of Change: From - pump and treat; To - monitored natural attenuation and institutional controls.
Factual Basis: New data from monitoring revealed VOCs below ROD action levels.
Appendix A.1
-------
Region
Site Name, State
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 2 - FY97
Region 2
American Thermostat, NY
* Initial cost increase,
overall cost decrease.
Region 2
DeRewal Chemical
Company, NJ
Region 2
Haviland, NY
6/29/90
7/97
[BSD]
3/95
5/95
EPA
Groundwater,
Soil
Full State involvement; community
expressed little interest.
Fed= lOOhrs;
Contr. = $0
Est'd Savings =
not available*
Type of Change: From - excavation and thermal treatment of unsaturated soils and groundwater; To - removal and treatment
of soils in several "hot spot" areas.
Factual Basis: Pre-design sampling revealed additional soil contamination; removal of soil (source of groundwater
contamination) will shorten length of groundwater treatment process.
9/29/89
6/12/97
[BSD]
1/96
7/96
EPA
Soil
Full State involvement; State
concurred; public notice given;
community expressed interest and
was supportive.
Fed= lOOhrs;
Contr. = $0
Est'd Savings = TBD
Type of Change: From - on-site solidification/stabilization of inorganic-contaminated soil and backfill of treated soil; To - no
on-site treatment of inorganics and off-site disposal.
Factual Basis: Treatability study results in design showed original remedy would leach inorganics if left in place.
9/87
8/97
[ROD-A]
12/95
8/96
EPA
Groundwater
Full State and community
involvement; local officials
objected to change in water supply
portion of remedy.
Fed = 500 hrs;
Contr. = $0
Est'd Savings =
$4.2 million
Type of Change: From - groundwater pump and treat and alternate water supply; To - monitored natural attenuation and
monitoring and maintenance of existing home systems.
Factual Basis: Recent data showed decrease in levels of contamination.
Appendix A.1
-------
Region
Site Name, State
Region 2
Love Canal, NY
Region 2
Pepe Field, NJ
* Initial cost increase,
overall cost decrease.
Region 2
Preferred Plating, NY
Date of
Original ROD
Date of Change
[ESD/ROD-A]
10/87
11/96
[2nd BSD]
Date Review
Commenced
Date Review
Completed
3/96
11/96
Change
Initiator
EPA,
PRP
Media
Sediments
State/
Community
Involvement
State was fully involved; public
somewhat interested.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 200 hrs;
Contr. = $0
Est'd Savings =
$10 million
Type of Change: From - off-site incineration of creek and sewer sediments at PRP facility; To - off-site incineration or
disposal of creek and sewer sediments at commercial facility.
Factual Basis: Dioxin disposal classification of 1 ppb as the action level that would require treatment of remedial wastes prior
to land disposal; no loss in protection.
9/29/89
7/25/97
[BSD]
10/96
6/97
EPA
Soils
Of significant interest to local
community. Public notice of final
action.
Fed = 30 hrs;
Contr. = $0.1 million
Est'd Savings =
$0*
Type of Change: From - landfill containment remedy; To - stabilization, excavation, and off-site disposal of landfill waste
material.
Factual Basis: In design, cost of containment remedy greatly increased.
9/89
9/97
[ROD-A]
7/94
7/97
EPA
Groundwater
Full State involvement; public
notice given; public meeting held;
community expressed little interest.
Fed= 1,000 hrs;
Contr. = $0
Est'd Savings =
$9.3 million
Type of Change: From - active extraction and treatment; To - monitored natural attenuation.
Factual Basis: Subsequent sampling identified space restrictions and decline in contaminant concentrations.
Appendix A.1
-------
Region
Site Name, State
Region 2
Rowe Industries, NY
Region 2
Vineland Chemical, NJ
Region 2
Volney Landfill, NY
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/30/92
7/97
[ROD-A]
Date Review
Commenced
Date Review
Completed
12/11/95
5/16/97
Change
Initiator
PRP
Media
Groundwater,
Soil
State/
Community
Involvement
Significant State and public
interest; public notice; public
comment period; community
provided comment.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed= lOOhrs;
Contr. = $0
Est'd Savings =
$0.1 million
Type of Change: From - excavation and off-site disposal of soil; To - excavation, in-situ soil vapor extraction of unsaturated
soil, and in-situ air sparging of saturated soil.
Factual Basis: Extent of soil contamination greater than originally presumed; new remedy more efficient and cost-effective.
9/29/89
6/30/97
[BSD]
5/95
6/97
EPA,
State
Buildings,
Groundwater
State concern over cost of remedy.
Fed = 300 hrs;
Contr. = $0.1 million
Est'd Savings =
$5 million
Type of Change: (Groundwater) From - groundwater treatment system; To - downsize treatment system. (Buildings) demolish
and dispose of off-site.
Factual Basis: Request by State during design to downsize system.
7/87
8/97
[BSD]
6/97
8/97
EPA,
PRP
Groundwater
State and public interest.
Fed= 100 hrs;
Contr. = $0
Est'd Savings =
$15 million
Type of Change: From - install slurry wall and expand leachate collection system; To - no slurry wall; intermittent extract and
treat in combination with existing leachate collection system.
Factual Basis: Results of pre-design studies conclude that expansion of the leachate collection system is not appropriate, a
slurry wall is not cost-effective, and the off-site treatment and disposal of leachate is more cost-effective than on-site treatment
and disposal.
Appendix A.1
-------
Region
Site Name, State
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 2 - FY96
Region 2
A.O. Polymer, NJ
6/28/91
9/17/96
[BSD]
3/9/95
9/17/96
PRP
Groundwater
State involved in PRP negotiations
and meetings; public notified;
community concerns were
identified and considered; State
concurred with remedy change.
Fed = 400 hrs;
Contr. = $0
Est'd Savings =
$9.6 million
Type of Change: From - powdered activated carbon treatment (PACT) system; To - air stripping, and From - discharge of
treated groundwater to recharge basins; To - discharge to Wallkill River.
Factual Basis: PACT failed treatability study testing; additional modeling reduced capture zone; change reduces chance of
flooding neighboring areas.
Region 3 - FY97
Region 3
Avco Lycoming, PA
6/28/91
12/30/96
[ROD-A]
5/15/95
6/15/96
PRP
Groundwater
State was involved in review and
concurred; public notified, public
meeting held; community was
receptive to change.
Fed= 1000 hrs;
Contr. = $4.2
million1
Est'd Savings =
$5.3 million
Type of Change: From - groundwater pump and treat; To - in-situ groundwater treatment using molasses injection for metals
treatment and air sparging/soil vapor extraction for organics treatment.
Factual Basis: Pilot tests were successful, cleanup time would be reduced by thirty-three percent.
1 Extensive Federal hours and contractor dollars needed to review and analyze remedy performance.
Appendix A.1 8
-------
Region
Site Name, State
Region 3
Brodhead Creek
OU1, PA
Region 3
Browns Battery, PA
Region 3
Croydon TCE, PA
Date of
Original ROD
Date of Change
[ESD/ROD-A]
3/29/91
7/19/94
[BSD]
9/30/97
[BSD]
Date Review
Commenced
Date Review
Completed
6/7/96
7/25/96
9/28/97
Change
Initiator
PRP
Media
Soil,
Groundwater
State/
Community
Involvement
State concurred; public notified.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 75 hrs;
Contr. = $0
Est'd Savings =
$87,000
Type of Change: (Soil) From - interim remedy for OU1; To - final remedy for OU1. (Groundwater) From - Contained
Recovery of Oil Waste (CROW) process; To - intermittent pumping for CROW in subsurface when pockets of contamination
exist.
Factual Basis: Revised estimate of total surface area of coal tar accumulation, and determination that interim actions addressed
site risks.
7/92
1/27/97
[BSD]
6/96
1/27/97
Comm.
Soil
State concurred; public
notification; public comment
period; community opposition to
original treatment location.
Fed = 50 hrs;
Contr. = $0
Est'd Savings =
no net savings
Type of Change: From - remove PRP's home facility as only thermal treatment location; To - any permitted hazardous waste
toxic substance disposal facility.
Factual Basis: Community opposed original treatment location.
6/29/90
12/31/96
[BSD]
3/93
12/31/96
EPA
Groundwater
State concurred; public notice
given; posted in Federal Register.
Fed= 1000 hrs2;
Contr. = $0
Est'd Savings =
$1 million
Type of Change: From - treating two plumes; To - treat one plume.
Factual Basis: PRP was found for one of the plumes and it will be addressed under RCRA.
2 Multiple meetings with PRPs on the proposal; extensive data review - hydrogeological and historical.
Appendix A.1 9
-------
Region
Site Name, State
Region 3
Industrial Lane, PA
Region 3
Mill Creek Dump, PA
Region 3
Paoli Rail Yard, PA
* Initial cost increase,
overall cost decrease.
Date of
Original ROD
Date of Change
[ESD/ROD-A]
3/29/91
12/5/96
[BSD]
Date Review
Commenced
Date Review
Completed
11/15/95
1 1/26/96
Change
Initiator
PRP
Media
Debris
State/
Community
Involvement
State concurred.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 120 hrs;
Contr. = $0
Est'd Savings =
$2.4 million
Type of Change: From - soil cap and groundwater pump and treat; To - change cap design and change groundwater discharge
and From - background-based; To - MCL/health-based standards for groundwater.
Factual Basis: Change in Applicable or Relevant and Appropriate Requirements (ARARs) (PA eliminated requirement for
cleaning up groundwater to background levels).
5/7/86
4/30/97
[BSD]
11/96
4/30/97
PRP
Surface soils
State involved in review; public
comment period.
Fed = 26 hrs;
Contr. = $0
Est'd Savings =
no net savings
Type of Change: From - land use identified in ROD; To - build driving range for land reuse.
Factual Basis: Other than reform; changed intended land use.
9/30/92
3/30/97
[BSD]
7/97
9/97
PRP
Residuals,
Sludge,
Surface water,
Structures
State and community concurred.
Fed = 68 hrs;
Contr. = $0
Est'd Savings =
savings over time;
not estimated*
Type of Change: From - decontamination of on-site buildings; To - decontamination and demolition of on-site buildings.
Factual Basis: Community requested demolition of building, savings overtime regarding operation and maintenance.
Appendix A.1
10
-------
Region
Site Name, State
Region 3
Recticon/Allied Steel, PA
Region 3
Revere Chemical, PA
Region 3
Tonolli Corp., PA
Date of
Original ROD
Date of Change
[ESD/ROD-A]
6/93
8/29/97
[ROD-A]
Date Review
Commenced
Date Review
Completed
12/95
8/29/97
Change
Initiator
PRP,
State
Media
Soil,
Groundwater
State/
Community
Involvement
State concurred; public notified;
public comment period; public
meeting. Comments addressed in
Responsiveness Summary.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 140 hrs;
Cont. = $0
Est'd Savings =
$40,000
Type of Change: (Soil) From - excavate and off-site disposal of soils; To - no disposal needed, but institutional controls to
limit future use. (Groundwater) From - extract and treat and dispose to surface water; To - performance standard will be MCLs.
Factual Basis: PA background requirements were used for original ROD (ARAR change).
12/27/93
3/25/97
[BSD]
12/11/95
3/25/97
PRP
Soil
State concurred; several residents
attended public availability
sessions.
Fed = 265 hrs;
Contr. = $0
Est'd Savings =
$0.2 million
Type of Change: From - in-situ vacuum extraction for soil cleaning; To - ex-situ vacuum extraction, and From - slurry wall to
prevent spread of contaminants; To - no slurry wall, and From - size of cap determined by Drinking Water Method Detection
Limits; To - size of cap determined by MCLs.
Factual Basis: Poor performance pilot test of ROD remedy and decrease in volume of VOC-contaminated soil.
9/30/92
1/7/97
[BSD]
10/17/96
1/17/97
EPA
Closure of On-
Site hazardous
waste landfill
State did not concur on BSD.
Fed = 46 hrs;
Contr. = $0
Est'd Savings =
$50,000
Type of Change: From - evaluation of artificial groundwater dewatering system; To - no evaluation.
Factual Basis: Results of hydrogeological study; granted waiver of State ARARs due to equivalent standard of performance
already being met.
Appendix A.1
11
-------
Region
Site Name, State
Region 3
West Virginia Ordnance
Works, WV
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/30/88
2/27/97
[BSD]
Date Review
Commenced
Date Review
Completed
2/17/94
4/3/94
Change
Initiator
Fed. Fac.
Media
Groundwater,
Surface water
State/
Community
Involvement
Mason County involved in BSD.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = not available
Contr. = not
available
Est'd Savings =
not available
Type of Change: From - discharge of pump and treat system into Ohio River; To - adjacent creek.
Factual Basis: Time savings - discharge to creek could begin immediately.
Region 3 - FY96
Region 3
Abex Corp., VA
Region 3
Bendix, PA
9/29/92
10/5/95
[BSD]
10/30/92
3/28/94
PRP
Soil
Received State review and
comment; public availability
sessions.
Fed = 300 hrs;
Contr. = $0
Est'd Savings =
$1 million
Type of Change: From - excavation of all soil in two-block area; To - excavation of only uncovered soil.
Factual Basis: City rezoned some of residential area for commercial/industrial use.
9/30/88
1 1/22/95
[BSD]
6/1/95
1 1/22/95
EPA,
PRP
Soil
State concurred; notice of BSD
published; BSD placed in
Administrative Record; no
comment from community.
Fed = 48 hrs;
Contr. = $5,000
Est'd Savings =
$0.1 million
Type of Change: From - soil vapor extraction; To - mechanical aeration of soils.
Factual Basis: Tight soil density made soil vapor extraction impractical; restricting utilities removed; treatability study results.
Appendix A.1
12
-------
Region
Site Name, State
Region 3
Defense General Supply
Center, VA
Region 3
Defense General Supply
Center, VA
Region 3
Delta Quarries/Stotler
Landfill, PA
Date of
Original ROD
Date of Change
[ESD/ROD-A]
3/25/92
3/8/96
[BSD]
Date Review
Commenced
Date Review
Completed
3/15/93
9/3/95
Change
Initiator
EPA,
State,
Fed. Fac.
Media
Air,
Groundwater,
Soil
State/
Community
Involvement
Public notice; no negative
comments received; State involved
in entire process.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = not available;
Contr = not available
Est'd Savings =
$1.5 million
Type of Change: From - groundwater extraction/treatment system; To - capping.
Factual Basis: Sampling in design indicated groundwater no longer posed a risk.
9/29/93
3/8/96
[BSD]
12/5/93
9/15/95
EPA,
State,
Fed. Fac.
Groundwater
Public comment requested, no
comments received; State was
partner in all decisions.
Fed = not available;
Contr = not available
Est'd Savings =
$2,000
Type of Change: From - ground water treatment ; To - different discharge location of treated groundwater.
Factual Basis: Field testing in design.
3/29/91
12/6/95
[BSD]
9/95
12/95
PRP
Groundwater
State concurred; public
notification; public meeting.
Fed = 26 hrs;
Contr. = $0
Est'd Savings =
$0.3 million
Type of Change: From - on-site treatment using air stripping; To - more reliable off-site treatment.
Factual Basis: PRP investigation during design determined that change from onsite to offsite treatment of groundwater was
protective of human health and the environment.
Appendix A.1
13
-------
Region
Site Name, State
Region 3
Fike/Artel, WV
Region 3
NCR,DE
Region 3
Old City of York Landfill,
PA
Date of
Original ROD
Date of Change
[ESD/ROD-A]
3/31/92
1/30/96
[BSD]
Date Review
Commenced
Date Review
Completed
4/94
1/30/96
Change
Initiator
PRP
Media
Air,
Surface water
State/
Community
Involvement
Periodic meetings; press releases;
and newspaper ads.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed= 1742hrs3;
Contr. = $0
Est'd Savings =
$4.8 million
Type of Change: From - dome-enclosed excavation; To - open air excavation, and From - on-site treatment of surface water
in deteriorating plant; To - treatment in newly built plant.
Factual Basis: Improved safety, increased cost savings.
8/12/91
3/27/96
[BSD]
10/17/94
3/27/96
PRP
Groundwater
Initial and follow-up fact sheets
provided to community; State
concurred with revised remedy.
Fed = 811hrs;
Contr. = $0
Est'd Savings =
$2.5 million
Type of Change: From - pump and treat groundwater through air stripper; To - air sparging/soil vapor extraction.
Factual Basis: Reduced remediation time by using in-situ treatment.
9/30/91
9/27/96
[BSD]
7/25/96
9/27/96
PRP
Groundwater,
Sediment
State concurred. BSD placed in
Administrative Record for public
review.
Fed = 40 hrs;
Contr. = $0
Est'd Savings =
not available
Type of Change: From - stabilization and off-site disposal of sediments; To - capping, and From - background performance
standards; To - achieving MCLs.
Factual Basis: Analytical testing showed on-site placement was appropriate; change in State ARARs.
3 Extensive data review, especially for design and cost of new treatment plant; multiple document reviews needed; and
multiple meetings with interested parties.
Appendix A.1 14
-------
Region
Site Name, State
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 3
Rentokil, Inc., VA
6/22/93
8/27/96
[ROD-A]
8/30/95
11/13/95
PRP
Soil
State concurred; proposed plan
released to public; public notice
published; public meeting held;
comments addressed; county
interested in site redevelopment.
Fed = 320 hrs;
Contr. = $0
Est'd Savings :
$10 million
Type of Change: From - low temperature thermal desorption of "hot spot" soil; To - delete "hot spot" treatment; add cap and
slurrv wall.
Factual Basis: Modeling indicated that "hot spot" treatment had no impact on groundwater contamination.
Region 3
Saegertown Industrial
Area, PA
1/29/93
3/1/96
[BSD]
2/1/96
3/1/96
PRP
Sludge,
Soil
State and community were
informed of proposal.
Fed= 160 hrs;
Contr. = $0
Est'd Savings :
$4.6 million
$4.6 million
Type of Change: From - off-site thermal treatment; To - expanded off-site thermal treatment facilities to include large
coal-fired cyclone power generating boilers.
Factual Basis: EPA approval of alternate thermal treatment.
Region 3
Saunders Supply
Company, VA
9/30/91
9/27/96
[ROD-A]
12/8/95
3/21/96
EPA
Soil
State concurred; proposed plan
made available; public meeting
held and comments addressed.
Fed = 224 hrs;
Contr. = $0
Est'd Savings :
$0.7 million
Type of Change: From - on-site thermal desorption; To - off-site incineration.
Factual Basis: New VDEQ (Virginia) regulations on backfilling - more cost-effective and improved short-term effects.
Appendix A.1
15
-------
Region
Site Name, State
Region 3
Tyson's Dump, PA
Region 3
Whitmoyer Labs, PA
Region 3
William Dick Lagoons,
PA
Date of
Original ROD
Date of Change
[ESD/ROD-A]
3/31/88
7/26/96
[ROD-A]
Date Review
Commenced
Date Review
Completed
11/15/94
7/26/96
Change
Initiator
PRP
Media
Soil
State/
Community
Involvement
State concurred; involved during
remedial design/remedial action;
public comment period held by
EPA; community is content with
change.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed= lOOOhrs;
Contr. = $300,0004
Est'd Savings =
$8 million
Type of Change: From - soil vacuum extraction; To - covering lagoons with wet soil cover.
Factual Basis: Original remedy could not achieve cleanup levels set forth in ROD.
12/17/90
1 1/7/95
[BSD]
6/7/95
1 1/7/95
PRP
Debris,
Solid Waste
State concurred with BSD; public
notified; public meeting held;
public strongly supported
modification.
Fed= lOOhrs;
Contr. = $0
Est'd Savings =
$7 million
Type of Change: From - on-site incineration and fixation; To - off-site incineration and fixation.
Factual Basis: Technology remained the same - only the location was modified; community preference.
3/31/93
12/8/95
[BSD]
5/18/93
7/6/95
PRP
Soil
Public notice; BSD placed in
Administrative Record; State
concurred.
Fed= 170hrs;
Contr. = $0
Est'd Savings =
$5. 8 million
Type of Change: From - excavation and on-site thermal desorption for all soil; To - soil vapor extraction/bioremediation
treatment for soil under lagoon.
Factual Basis: Found the use of in-situ treatment cost-effective based on pilot study results without changing the cleanup
standards.
4 Multiple reviews of the ROD and supporting data; multiple meetings with interested parties; and additional enforcement time
needed.
Appendix A.1
16
-------
Region
Site Name, State
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 4 - FY97
Region 4
Aberdeen Pesticide Dump
Site - Farm Chemicals
Twin Sites, and Fairway
Six Areas - (OU3), NC
Region 4
Arlington Blending, TN
Region 4
ByPass601,NC
(OU2)
10/7/93
9/15/97
[BSD]
5/97
7/3/97
PRP
Groundwater
State and community received
proposed fact sheet and attended
public meeting.
Fed= 180hrs;
Contr. = $2,000
Est'd Savings =
TBD
Type of Change: From - thermal destruction in air stripper; To - carbon filtration and phytoremediation.
Factual Basis: Additional data in RA changes groundwater approach.
6/91
7/24/97
[ROD-A]
8/96
7/24/97
EPA,
PRP
Groundwater
State concurred; EPA convened
public meeting and received no
written comments.
Fed = 240 hrs;
Contr. = $0
Est'd Savings =
$5.5 million
Type of Change: From - groundwater pump and treat; To - monitored natural attenuation.
Factual Basis: Sampling indicated drinking water aquifer not contaminated as originally presumed.
4/20/93
4/18/97
[ROD-A]
1/15/96
4/18/97
PRP
Groundwater,
Soil
State and community concurred;
State is major PRP.
Fed = 400 hrs;
Contr. = $0
Est'd Savings =
$28 million
Type of Change: From - stabilization/solidification of all soil; groundwater pump and treat; To - stabilization/solidification of
reduced volume of soil and groundwater monitoring.
Factual Basis: Reduced volume of soil contamination and the use of alternate concentration levels for ground water.
Appendix A.1
17
-------
Region
Site Name, State
Region 4
Diamond Shamrock
Landfill/Cedartown, GA
Region 4
Homestead Air Force
Base, FL (OU 6)
Region 4
Marzone Inc./Chevron
Chemical Co., GA
Region 4
Munisport Landfill, FL
Date of
Original ROD
Date of Change
[ESD/ROD-A]
5/12/94
9/15/97
[BSD]
Date Review
Commenced
Date Review
Completed
8/15/96
8/15/97
Change
Initiator
PRP
Media
Groundwater
State/
Community
Involvement
State involved and approved of
change. Public was notified by fact
sheet.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 220 hrs;
Contr. = $0
Est'd Savings =
unknown
Type of Change: Change in performance goals for manganese from 200 mg/1 to 850 mg/1.
Factual Basis: Change in reference dose for manganese.
6/27/95
10/22/97
[BSD]
9/17/97
10/22/97
Fed. Fac.
Groundwater,
Soil
Input from Restoration Advisory
Board; conducted public meetings
and public agrees with change;
published in local newspaper.
Fed= 10 hrs;
Contr. = $0
Est'd Savings =
$0.1 million
Type of Change: From - thermal treatment on-site of soil; To - off-site disposal of soil; groundwater system recovered less
LNAPL than previously anticipated.
Factual Basis: Data in design showed reduced volume of soil.
9/30/94
6/18/97
[ROD-A]
3/15/97
6/18/97
EPA
Soil
EPA addressed community and
ATSDR concerns. Proposed plan
fact sheet issued to public and
State. State concurred.
Fed = 80 hrs;
Contr. = $0
Est'd Savings =
$2.8 million
Type of Change: From - low temperature thermal desorption; To - off-site landfill disposal.
Factual Basis: Community opposed to thermal treatment and discovery of dioxin during remedial design.
7/17/90
9/5/97
[ROD-A]
9/4/95
9/5/97
EPA
Groundwater,
Surface water
State and county briefed and
concurred with change; proposed
plan fact sheet issued and there
were three public meetings;
community activists oppose
change.
Fed = 2,000 hrs;
Contr. = $0.2 million
Est'd Savings =
$0.1 million
Type of Change: From - tidal restoration of wetland and groundwater pump and treat for containment; To - groundwater pump
and treat not needed to create hydraulic barrier.
Appendix A.1
18
-------
Region
Site Name, State
Region 4
NASPensacola(OU12),
FL
Region 4
National Starch, NC
Region 4
Reeves Southeastern, FL
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Factual Basis: Response actions to date have met objectives in original ROD.
7/31/95
9/2/97
[BSD]
10/96
9/2/97
Fed. Fac.
Groundwater
Public was notified about the
change.
Fed = 8 hrs;
Contr. = $0
Est'd Savings =
$5,000
Type of Change: From - remedy included 5-yr. review requirement; To - remove 5-yr. requirement.
Factual Basis: Re-evaluated risk assessment and found the detected arsenic levels were below the Federal and State drinking
water standards.
10/93
6/10/97
[BSD]
3/97
6/10/97
PRP
Soil
State review and concurrence;
public was notified.
Fed= 15 hrs;
Contr. = $0
Est'd Savings =
negligible
Type of Change: From - off-site disposal of well drilling cuttings; To - on-site treatment by thermal desorber and on-site
disposal.
Factual Basis: Elevated levels of contaminants in soil cuttings required treatment prior to disposal.
10/13/92
4/17/97
[BSD]
2/27/97
4/17/97
PRP
Soil
Public comment period; no
significant issues raised by
public/State.
Fed = 50 hrs;
Contr. = $5,000
Est'd Savings =
$0.2 million
Type of Change: From - on-site solidification/stabilization and containment; To - off-site containment.
Factual Basis: Original remedy could not meet performance standards.
Appendix A.1
19
-------
Region
Site Name, State
Region 4
Savannah River Plant,
(OU21,29), SC
Date of
Original ROD
Date of Change
[ESD/ROD-A]
1/9/94
5/14/97
[BSD]
Date Review
Commenced
Date Review
Completed
5/16/97
5/27/97
Change
Initiator
Fed. Fac.
Media
Groundwater
State/
Community
Involvement
State approved BSD. Public notice
of BSD to be placed in
Administrative Record.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 6 hrs;
Contr. =- $0
Est'd Savings =
$0.1 million
Type of Change: From - groundwater treatment with recirculation well of part of treatment plan; To - remove recirculation
well from treatment plan.
Factual Basis: Testing in RA demonstrated that the recirculation well was not effective.
Region 4 - FY96
Region 4
Aberdeen Pesticide
Dumps Site, NC
Region 4
Cape Fear Wood
Preserving, NC
9/30/91
3/96
[BSD]
8/19/94
2/13/95
PRP
Soil
The State was involved in the
decision. The BSD notice was
published in the local newspaper,
however, a public meeting was not
held.
Fed = 120 hrs
Contr. =
Est'd Savings =
None
Type of Change: From - arsenic performance standard of 1 ppm; To - arsenic performance standard of 30 ppm.
Factual Basis: Revisions to the arsenic cancer slope factor and changes in the bioavailability factor.
8/95
9/96
[BSD]
4/96
6/96
EPA
Soil
State review and concurrence;
public notified; BSD placed in
Administrative Record.
Fed = 20 hrs;
Contr. = $0
Est'd Savings =
None
Type of Change: From - soil washing, biotreatment, and solidification; To -low temp, thermal desorption and solidification.
Factual Basis: Cleanup goals could be reached without bioremediation step. Also, soil washing did not achieve cleanup goals.
Appendix A.1
20
-------
Region
Site Name, State
Region 4
Cedartown Municipal
Landfill, GA
Region 4
Harris Corp., FL
Region 4
Hipps Road Landfill, FL
Region 4
ILCO (Interstate Lead
Company) Leads, AL
Date of
Original ROD
Date of Change
[ESD/ROD-A]
1 1/2/93
6/3/96
[BSD]
Date Review
Commenced
Date Review
Completed
5/22/96
6/3/96
Change
Initiator
EPA
Media
Leachate
State/
Community
Involvement
Reviewed draft ESD.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed= lOhrs
Contr. = $0
Est'd Savings =
None
Type of Change: Changed groundwater performance standard for manganese based on reviewed reference dose.
Factual Basis: Revised reference dose for manganese.
2/15/95
12/8/95
[BSD]
4/95
12/95
PRP,
State
Groundwater
State involved throughout review;
public notified; community
provided with fact sheets; no
comments received.
Fed = 320 hrs;
Contr. = $1,500
Est'd Savings =
$0.1 million
Type of Change: From - treatment of manganese; To - only monitoring of manganese; also deleted 2 contaminants of concern.
Factual Basis: Sampling data in design showed contaminants to be below cleanup levels.
9/30/86
6/1/96
[BSD]
1/1/96
4/1/96
EPA
Groundwater
State and community not involved
in change.
Fed = 60 hrs;
Contr. = $0
Est'd Savings =min.
Type of Change: From - discharge to holding pond; To - alternate discharge to POTW when holding pond reaches capacity.
Factual Basis: Successful discussion with publically-owned treatment works (POTW) allows for alternate discharge location.
10/13/94
8/27/96
[ROD-A]
2/96
8/27/96
EPA
Solid waste
State and community preference for
off-site disposal led to change.
Fed = 450 hrs;
Contr. = $0
Est'd Savings =
$15 million
Type of Change: From - acid leaching with a contingency for on-site disposal; To - off-site disposal without acid leaching.
Factual Basis: Treatability study results show acid leaching was not effective on all site soils.
Appendix A.1
21
-------
Region
Site Name, State
Region 4
JFD Electronics/Channel
Master, NC
Region 4
Marzone Inc./Chevron
Chemical Co., GA
Region 4
Mathis Brothers/South
Marble Top Road
Landfill, GA
Region 4
Potter's Septic Tank, NC
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/10/92
1/24/96
[BSD]
Date Review
Commenced
Date Review
Completed
4/95
1/24/96
Change
Initiator
PRP
Media
Groundwater
State/
Community
Involvement
State concurred with BSD; public
was notified.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 120 hrs;
Contr. = $0
Est'd Savings =
$3 million
Type of Change: From - treatment and disposal; To - air stripping.
Factual Basis: Remedial design information indicated air stripping was sufficient.
9/30/94
9/12/96
[BSD]
8/12/96
9/12/96
EPA,
PRP
Soil
State reviewed draft BSD. No
comments received. Fact sheet
issued to public, but no comments
received on temperature change.
Fed= 10 hrs;
Contr. = $0
Est'd Savings =
$0.5 million
Type of Change: Changed operating temperature of thermal desorber unit.
Factual Basis: Lower temperature more efficient at treating soils.
3/24/93
9/27/96
[ROD-A]
7/12/95
8/15/96
PRP
Debris,
Liquid waste,
Soil,
Groundwater
Proposed plan fact sheet issued.
State and community concurred.
Fed = 400 hrs;
Contr. = $50,000
Est'd Savings =
$5 million
Type of Change: From - on-site treatment; To - off-site treatment.
Factual Basis: Studies in design indicated volume smaller than in original ROD.
8/5/92
2/6/96
[ROD-A]
11/95
2/6/96
State
Soil
Community provided with fact
sheets; newspaper notices; State
concurred.
Fed = 120 hrs;
Contr. = $0
Est'd Savings =
$0.8 million
Type of Change: From - lead soil excavation target of 25 ppm; To - lead soil excavation target of 400 ppm.
Factual Basis: Revised leachate model for lead cleanup goal in soil for protection of groundwater based on new modeling of
effect on groundwater.
Appendix A.1
22
-------
Region
Site Name, State
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 5 - FY97
Region 5
Allied Chemical/Ironton
Coke, OH
Region 5
Arcanum Iron and Metal,
OH
Region 5
Buckeye Reclamation
Landfill, OH
12/28/90
9/4/97
[ROD-A #2]
8/23/96
2/26/97
PRP
Soil
State concurred; public notified;
public comment period; no
comments received.
Fed = 80 hrs;
Contr. = $0
Est'd Savings =
$2.2 million
Type of Change: From - pad bioremediation; To - off-site disposal in subtitle D landfill.
Factual Basis: Additional sampling in design determined lower levels of contaminants than originally thought, classifying soils
as non-hazardous.
9/6/86
6/18/97
[ROD-A]
9/15/89
2/28/97
EPA
Soil,
Solid Waste,
Groundwater
Public notice; public meeting held;
comments summarized in
Responsiveness Summary; State
concurred with change.
Fed = 500 hrs;
Contr. = $100,000
Est'd Savings =
$14 million
Type of Change: From - off-site disposal of waste with lead (Pb) concentrations >500 ppm; To - off-site disposal of waste with
lead (Pb) concentrations >1500 ppm.
Factual Basis: Revision of lead cleanup standards and redefining of land use from residential to industrial.
8/19/91
7/17/97
[BSD]
3/7/95
5/97
PRP
Groundwater,
Solid Waste,
Leachate
Fact sheets sent to community;
State involvement throughout.
State concurred.
Fed = 3000 hrs5;
Contr. = $20,000
Est'd Savings =
$25 .2 million
Type of Change: From - solid waste containment; To - "less, but still appropriate, containment," and From -
groundwater/leachate treatment; To - monitoring for possible future treatment.
Factual Basis: Historical review of area resulted in change of standard to 1976 Ohio solid waste capping requirements.
5 Intensive review effort that took over two years; additional field work was conducted; extended negotiation period occurred;
and multiple documents reviewed.
Appendix A.1 23
-------
Region
Site Name, State
Region 5
City Disposal Corp.
Landfill, WI
Region 5
Clare Water Supply, MI
Region 5
Enviro-Chem, IN
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/28/92
6/11/97
[BSD]
Date Review
Commenced
Date Review
Completed
9/12/96
6/11/97
Change
Initiator
EPA,
PRP,
State
Media
Groundwater
State/
Community
Involvement
State concurred; public notified;
fact sheets issued; public meetings
held for community.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed= 160hrs;
Contr. = $6,000
Est'd Savings =
not available
Type of Change: From - on-site groundwater extract and treat; To - allow removal and off-site treatment while monitoring
content to develop long-term remediation effort.
Factual Basis: Based on treatability study results.
9/16/92
5/15/97
[ROD-A]
4/26/96
7/1/96
PRP
Soil
Public notice given; public
comment period; public meeting
held; State and community
support.
Fed = 90 hrs;
Contr. = $0
Est'd Savings =
$2 million
Type of Change: From - in-situ vapor extraction; To - containment and capping.
Factual Basis: In-situ vapor extraction ineffective due to soil impermeability to air.
9/25/87
7/14/97
[BSD]
1/93
3/11/96
PRP
Groundwater,
Soil
State concurrence; public notified;
public comment period; no
comments received.
Fed = 400 hrs;
Contr. = $30,000
Est'd Savings =
not available
Type of Change: From - soil vapor extraction; To - soil excavation and addition of three new compounds, installation of cap,
extension of remediation boundary.
Factual Basis: Additional technical and toxicological information, including identification of nine additional organic
compounds, discovery of higher water tables, and change to organic carbon content modeling.
Appendix A.1
24
-------
Region
Site Name, State
Region 5
Fields Brook Superfund
Site, OH
Region 5
Fisher-Calo, IN
Region 5
Janesville Ash Beds and
Janesville Old Landfill,
WI
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/30/86
8/15/97
[BSD]
Date Review
Commenced
Date Review
Completed
9/96
4/20/97
Change
Initiator
PRP
Media
Sediment
State/
Community
Involvement
State commented; State did not
concur with the change. Public
notified; public meeting.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 250 hrs;
Contr. = $0
Est'd Savings =
$20 million
Type of Change: From - solidification and on-site thermal treatment; To - on-site landfill and off-site thermal treatment.
Factual Basis: Additional data in design refines cleanup goal, showed reduced volumes of sediment contamination, and
documents waiver of TSCA landfill requirement.
8/7/90
9/26/97
[ROD-A]
8/15/96
9/23/97
EPA,
PRP
Soil
State concurred with change;
community involved in public
meeting and comment period.
Fed = 300 hrs;
Contr. = $20,000
Est'd Savings =
$6 million
Type of Change: From - incineration of soils; To - air sparging bioremediation for SVOC-soils and off-site disposal of PCB-
soils.
Factual Basis: Sampling results in design showed reduced volumes of contamination.
12/29/89
9/17/97
[BSD]
1/30/95
7/30/97
PRP
Groundwater
State reviewed and concurred with
change. Public comment period;
no comments from community,
only PRP and State commented.
Fed= 100 hrs;
Contr. = $0
Est'd Savings =
$1.4 million
Type of Change: From - groundwater extract and treat; To - monitored natural attenuation.
Factual Basis: Groundwater monitoring data shows decrease in VOC concentrations.
Appendix A.1
25
-------
Region
Site Name, State
Region 5
Moss-American, WI
Region 5
Ormet, OH
Region 5
Peerless Plating, MI
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/27/90
4/29/97
[BSD]
Date Review
Commenced
Date Review
Completed
9/4/96
4/29/97
Change
Initiator
PRP
Media
Groundwater
State/
Community
Involvement
Fact sheet distributed to
community.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed= 160hrs;
Contr. = $4,000
Est'd Savings =
$70,000
Type of Change: From - extract and treat system; To - in-situ groundwater treatment using a runnel and gate type system.
Factual Basis: Data gathered in design indicating relatively fine grained soils at the site which gave opportunity for funnel and
gate type system; more cost-effective approach.
9/12/94
4/1/97
[BSD]
8/27/96
3/31/97
PRP
Sediment,
Soil
Public notice in newspaper; State
did not concur with changes or
ROD.
Fed = 140 hrs;
Contr. = N/A
Est'd Savings =
$1 million
Type of Change: From: soil removal and off-site disposal; To - on-site disposal in a Toxic Substance Control Act (TSCA)
compliant cell.
Factual Basis: Pre-design studies and same type of disposal cell to be constructed on-site.
9/21/92
8/4/97
[BSD]
12/30/96
3/30/97
EPA
Soil
State concurred; public notice in
local paper.
Fed = 75 hrs;
Contr. = $3,000
Est'd Savings =
$1.9 million
Type of Change: From - extraction and off-site disposal; To - decreased soil remediation levels and volume to be extracted.
Factual Basis: New pre-design phase data, new MDEQs (Michigan) standards.
Appendix A.1
26
-------
Region
Site Name, State
Region 5
Powell Road Landfill, OH
Region 5
Powell Road Landfill, OH
Region 5
Reilly Tar & Chemical,
MN
Region 5
United Scrap Lead, OH
Date of
Original ROD
Date of Change
[ESD/ROD-A]
10/30/93
1/97
[BSD]
Date Review
Commenced
Date Review
Completed
5/14/96
1/97
Change
Initiator
PRP
Media
Groundwater
State/
Community
Involvement
Fact sheet issued; public meeting;
and public comment period held;
State concurred with ESD.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 200 hrs;
Contr. = $8,000
Est'd Savings =
$8.4 million
Type of Change: From - groundwater extract and treat with source control measures (cap and leachate collection); To -
postponing of groundwater pump and treat system until all other remedial actions are set up.
Factual Basis: Pending study, cap, landfill leachate, and gas collection may have significant effect on groundwater.
10/30/93
8/13/97
[BSD]
11/96
5/97
PRP
Leachate
State concurred with change; fact
sheet and public notice in local
newspaper for change.
Fed= 100 hrs;
Contr. = $2,000
Est'd Savings =
$1.6 million
Type of Change: From - on-site leachate treatment facility; To - discharge to municipal POTW for treatment.
Factual Basis: In design, PRPs investigated this possibility; no loss in protection.
6/30/95
3/26/97
[BSD]
7/15/96
10/15/96
EPA,
State,
PRP
Groundwater
Public notice.
Fed = 80 hrs;
Contr. = $0
Est'd Savings =
$0.5 million
Type of Change: From - use of newly constructed extraction well for containment; To - use of existing well for containment.
Factual Basis: New well can't capture plume, subsequently old well more effective treatment.
9/16/88
6/27/97
[ROD-A]
6/30/92
12/15/96
EPA,
PRP
Soil,
Solid Waste,
Groundwater
Public notice; public meeting held;
State concurred with change.
Fed = 500 hrs;
Contr. = $100,000
Est'd Savings =
$54 million
Type of Change: From - soil/solid waste treatment; To - off-site disposal of soils with lead concentrations above 1,550 ppm
and containment of soil below 1,550 ppm.
Factual Basis: Revision of lead cleanup standards and redefining of land use from residential to industrial.
Appendix A.1
27
-------
Region
Site Name, State
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 5 - FY96
Region 5
Cannelton Industries, MI
Region 5
Electrovoice, MI
Region 5
Kummer Sanitary
Landfill, MN
9/30/92
9/27/96
[ROD-A]
1/15/95
1/15/96
PRP
Sediment,
Soil
State concurred with change;
proposed plan made available to
public; public meeting held;
community supportive of change.
Fed = 240 hrs;
Contr. = $100,000
Est'd Savings =
$15 million
Type of Change: From - on-site containment; To - off-site disposal.
Factual Basis: New data from pre-design investigations showing little groundwater contamination and confirmed minimal
leaching and movement of contaminants; community preference; change in State ARARs for land use.
6/23/92
5/23/96
[BSD]
7/31/95
(phone) or
8/4/95
(written)
8/11/96
PRP
Groundwater,
Sludge,
Soil
State concurred; fact sheet
distributed to community.
Fed= 160 hrs;
Contr. = $25,000
Est'd Savings =
$0.5 million
Type of change: From - perform subsurface volatilization and ventilation system study; To - no need to expand subsurface
system due to revised cleanup standards.
Factual Basis: Treatability study results and change in Michigan environmental law.
9/29/90
11/21/95
[ROD-A]
5/24/95
9/14/95
State
Groundwater,
Leachate,
Soil
State initiated remedy update and
wrote ROD-A; proposed plan made
available to public; public notified;
public comment period included;
public meeting held.
Fed = 120 hrs;
Contr. = $3,480
Est'd Savings =
$5. 6 million
Type of Change: From - advanced oxidation process (AOP); To - bioremediation and groundwater monitoring.
Factual Basis: Additional site data shows change of receptors, decrease of contaminants, and technical and feasibility
complication of AOP; more cost-effective and reduces waste volume.
Appendix A.1
28
-------
Region
Site Name, State
Region 5
Metamora, MI
Region 5
Pristine, Inc., OH
Region 5
Sturgis Municipal Field,
MI
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/30/86
8/28/96
[ROD-A]
Date Review
Commenced
Date Review
Completed
4/12/95
4/23/96
Change
Initiator
PRP,
EPA
Media
Residuals,
Soil
State/
Community
Involvement
State and community involved in
ROD amendment; Congressional
interest in site - EPA responded to
several controlled correspondence
letters from residents that did not
support the change.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 300 hrs;
Contr. = $200,0006
Est'd Savings =
$29 million
Type of change: From - incineration; To - relocation of waste and inclusion (containment) under a landfill cap.
Factual Basis: Improved understanding of the nature of the soils threat and more cost-effective.
12/31/87
4/24/96
[BSD]
7/11/95
4/9/96
EPA
Groundwater,
Surface water
State agreed with waiver of
antidegradation requirements.
Public notified through newspaper
notice; fact sheet distributed.
Fed = 300 hrs;
Contr. = $10,000
Est'd Savings =
$15 million
Type of Change: From - compliance with Ohio effluent limitations; To - waived State anti-degradation requirements.
Factual Basis: Waiver due to information indicating the technical impracticability of chosen technology to meet State
requirements.
9/30/91
9/10/96
[ROD-A]
3/22/96
9/10/96
PRP
Groundwater,
Soil
Public comment period; no
indication of community interest;
State involvement (site became
State enforcement lead).
Fed = 30 hrs;
Contr. = N/A
Est'd Savings =
$1.8 million
Type of Change: From - attain groundwater cleanup levels; To - State Federal MCL's, and From - off-site disposal of
polyaromatic hydrocarbons (PAH)-contaminated soil; To - eliminate need to address PAH-contaminated soil.
Factual Basis: New data in pre-design investigation indicated reduced soil contamination levels.
6 Performed intensive oversight of PRPs; conducted and reviewed additional sampling; and coordinated extensively with
interested parties.
Appendix A.1 29
-------
Region
Site Name, State
Region 5
Wash King Laundry, MI
Date of
Original ROD
Date of Change
[ESD/ROD-A]
3/31/93
7/1/96
[BSD]
Date Review
Commenced
Date Review
Completed
11/1/95
1/1/96
Change
Initiator
EPA,
State
Media
Groundwater,
Sediment,
Soil
State/
Community
Involvement
Public comment period; fact sheet
distributed to community.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 120 hrs;
Contr. = $0
Est'd Savings =
$6.2 million
Type of Change: From - removal of trace metallics in groundwater resulting in surface water discharge; To - reinjection of
treated groundwater.
Factual Basis: Post-ROD sediment content and groundwater modeling results.
Region 6 - FY97
Region 6
Bailey Waste Disposal,
TX
Region 6
Brio Refining, TX
6/28/88
12/16/96
[ROD-A]
7/95
12/16/96
PRP
Soil
Public meeting; no public concern
expressed; State provided letter of
support for change.
Fed = 400 hrs;
Contr. = $0
Est'd Savings =
$ 5.4 million
Type of Change: From - stabilization and capping; To - capping only.
Factual Basis: Failure of stabilization in field testing.
3/31/88
7/2/97
[ROD-A]
9/1/94
7/2/97
Comm.
Soil
State concurred; extensive
community involvement;
Community Advisory Group
formed by EPA. Public notified;
public meeting held; State provided
letter of support for change.
Fed= 1000 hrs7;
Contr. = $25,000
Est'd Savings =
$20 million
Type of Change: From - on -site incineration of VOCs; To - containment system for VOCs including cap/slurry wall.
Factual Basis: Focused feasibility study information showed high escape of fugitive emissions for incineration remedy and
costly engineering controls, leading to community preference for containment.
7 Intensive resource effort in responding to Community Advisory Group concerns during remedy development process.
Appendix A.1 30
-------
Region
Site Name, State
Region 6
Cleveland Mill, NM
Region 6
Crystal Chemical, TX
Region 6
PAB Oil and Chemical
Services, LA
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/22/93
7/11/97
[Other: Action
Memorandum]
Date Review
Commenced
Date Review
Completed
5/15/97
6/12/97
Change
Initiator
EPA,
PRP,
State
Media
Sediment,
Soil
State/
Community
Involvement
EPA held open house and
discussed changes with members of
community.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 300 hrs;
Contr. = $0
Est'd Savings =
no net savings
Type of Change: From - off-site reprocessing and reclamation, disposal of residuals; To - on-site lime neutralization and
disposal in limestone cell with multilayer cap.
Factual Basis: Poor site conditions (recent heavy rainfall) and lack of reprocessing facility to accept waste.
9/27/90
3/19/97
[BSD]
2/96
3/19/97
PRP
Groundwater
State concurred. Public notified;
public comment period - few
comments received; public
meeting, public open house.
Fed= 1000 hrs8;
Contr. = $0
Est'd Savings =
$2.8 million
Type of Change: From - pump and treat; To - containment with a slurry wall.
Factual Basis: Design investigation and evaluation study data and approval of a technical impracticability waiver.
9/22/93
3/12/97
[BSD]
12/96
3/12/97
PRP
Sludge,
Soil
EPA held open house; no
opposition from community; State
provided letter of support for
change.
Fed = 500 hrs;
Contr. = $0
Est'd Savings =
$3 million
Type of Change: From - biological treatment and solidification/stabilization; To - solidification/stabilization only.
Factual Basis: Revised precision and detection limits of analytical test procedures.
8 Intensive technical review and development of technical impracticability package.
Appendix A.1 31
-------
Region
Site Name, State
Region 6
South Cavalcade Street,
TX
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/26/88
6/27/97
[ROD-A]
Date Review
Commenced
Date Review
Completed
9/27/95
6/27/97
Change
Initiator
PRP
Media
Soil,
Groundwater
State/
Community
Involvement
State concurred; public notified;
public comment period; public
meeting; very little community
interest.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 80 hrs;
Contr. = $0
Est'd Savings =
$5.1 million
Type of Change: From - soil washing and treatment; To - concrete cap and containment.
Factual Basis: Soil washing failed pilot test.
Region 6 - FY96
Region 6
Bailey Waste Disposal,
TX
Region 6
Bailey Waste Disposal
(Pit-B), TX
Region 6
Oklahoma Refining
Company, OK
6/28/88
2/28/96
[BSD]
7/95
2/28/96
PRP
Soil
Fact sheets provided by EPA to
community; State provided letter of
support for change.
Fed = 300 hrs;
Contr. = $0
Est'd Savings =
$.9 million
Type of Change: From - relocation, solidification/stabilization, and capping; To - off-site disposal in industrial waste landfill.
Factual Basis: Improved timeliness of remedy and increased waste stabilization.
6/28/88
5/1/96
[BSD]
7/95
5/1/96
PRP
Soil
Fact sheets provided by EPA to
community; State provided letter of
support for change.
Fed = 200 hrs;
Contr. = $0
Est'd Savings =
no net savings
Type of Change: From - relocation, solidification/stabilization, and capping; To - off-site disposal in industrial waste landfill.
Factual Basis: Improved timeliness of remedy, technical difficulties in implementing original remedy, and increased waste
stabilization.
6/9/92
3/27/96
[BSD]
9/95
3/27/96
EPA
Soil
Public notified; ESD placed in
Administrative Record; community
concurred. State part of request for
remedy change.
Fed = 200 hrs;
Contr. = $0
Est'd Savings =
$1.3 million
Type of Change: From - recycling or landfilling of asphaltic material; To - stabilize material and cap.
Factual Basis: New information during value engineering study.
Appendix A.1
32
-------
Region
Site Name, State
Region 6
Vertac, Inc., AR
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/27/90
9/17/96
[ROD-A]
Date Review
Commenced
Date Review
Completed
10/95
9/17/96
Change
Initiator
EPA
Media
Soil
State/
Community
Involvement
Numerous public meetings; State
provided letter of support for
change.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 80 hrs;
Contr. = $0
Est'd Savings =
$3 million*
Type of Change: From - on-site incineration of soils with >260 ppb TCDD; To - landfilling all soils contaminated >5 ppb.
Factual Basis: Community preference. *Cost Savings: From - Proposed Plan; to - ROD-A.
Region 7 - FY97
Region 7
Cornhusker Army
Ammunition Plant, NE
Region 7
McGraw Edison, IA
Region 7
Peoples FMGP, IA
9/24/94
2/7/97
[BSD]
9/96
2/97
U.S.
Army
Groundwater,
Surface Water
Public comment period; public
meetings.
Fed = 50 hrs;
Contr. = $0
Est'd Savings =
$6 million
Type of Change: From - discharge point to Platte River; To - discharge point to on-site drainage ditch.
Factual Basis: Public concerns regarding impact to groundwater and migration of contaminants offsite.
9/93
9/97
[Letter]
4/25/97
9/17/97
PRP
Groundwater
State review and verbal
concurrence.
Fed = 25 hrs;
Contr. = $0
Est'd Savings =
$0.2 million
Type of Change: From - groundwater extract and treat system with activated carbon; To - pretreatment via air stripping.
Factual Basis: Cost-effectiveness of treatment train.
9/91
8/97
[Letter]
6/5/97
8/19/97
PRP
Soil,
Sludges
State review and concurrence.
Fed = 38 hrs;
Contr. = $0
Est'd Savings =
minimal
Type of Change: From - incineration of wastes at PRP -owned boiler; To - incineration at another boiler utility.
Factual Basis: Technical review of the alternative for high capacity boiler will save time (about 12 months).
Appendix A.1
33
-------
Region
Site Name, State
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 7 - FY96
Region 7
Chemplex, IA
Region 7
Doepke - Holliday, KS
Region 7
Hastings Well #3 OU #13,
NE
9/27/89
1/26/96
[Other: letter to
file]
12/4/95
1/26/96
PRP
Groundwater
State concurred; public availability
of change.
Fed = 50 hrs;
Contr. = $0
Est'd Savings =
$0.2 M
Type of Change: State regulation standard for tetrachloroethylene (PCE) amended: From - .7 ug/1 standard; To - 5.0 ug/1.
Factual Basis: Previous standard impractical based on new data.
9/21/89
2/6/96
[BSD]
2/16/95
2/6/96
PRP
Groundwater,
Leachate,
Surface Water
State concurred. Public notified;
BSD placed in Administrative
Record; no comments received.
Fed = 240 hrs;
Contr. = $11,200
Est'd Savings =
$1 million
Type of Change: From - collection and treatment; To - monitoring after installation of multi-layer cap.
Factual Basis: Groundwater seepage is occasional and continues to be monitored.
6/30/93
7/23/96
[BSD]
11/95
7/23/96
City
Groundwater
State and EPA concurred. City
involved.
Fed= 100 hrs;
Contr. = $10,000
Est'd Savings =
no estimate
calculated
Type of Change: From - reinjection; To - potential reuse of extracted groundwater.
Factual Basis: Groundwater to be used for spray irrigation.
Appendix A.1
34
-------
Region
Site Name, State
Region 7
John Deere Dubuque
Works, IA
Region 7
McGraw Edison, IA
Region 7
Mid- America Tanning, IA
Region 7
Red Oak Landfill, IA
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/28/88
1 1/28/95
[Other: letter to
file]
Date Review
Commenced
Date Review
Completed
10/27/95
1 1/28/95
Change
Initiator
State
Media
Groundwater
State/
Community
Involvement
State concurred; public availability
of change.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 30 hrs;
Contr. = $0
Est'd Savings =
not available
Type of Change: From - State MCLs deferral; To - Federal MCLs.
Factual Basis: Attainment of goal was impractical; no loss in protection.
9/93
6/96
[BSD]
4/8/94
6/96
PRP
Soil
State concurred with change;
public was notified.
Fed = 60 hrs;
Contr. = $10,000
Est'd Savings =
$0.4 million
Type of Change: From - cleanup level of 200 ppb; To - cleanup level of 750 ppb for TCE.
Factual Basis: Supplemental source soil/groundwater modeling.
9/24/91
7/29/96
[ROD-A]
3/14/95
10/25/95
EPA
Sludge,
Soil,
Solid Waste,
Surface Water
State concurred; no public
comments. EPA offered to hold
public meeting.
Fed = 200 hrs;
Contr. = $5,000
Est'd Savings =
$2 million
Type of Change: From - in-situ stabilization and capping; To - in-situ stabilization for only more highly contaminated sludges
and more impenetrable cap barrier.
Factual Basis: New information showing presence of H2S gas.
1/31/93
1/30/96
[BSD]
7/95
1/30/96
EPA
Groundwater,
Soil
State concurred; public availability
of change; public was notified.
Fed= 150 hrs;
Contr. = $0
Est'd Savings =
$0.8 million
Type of Change: From - thorough slope stability analysis; To - reshaping and revegetation of slope.
Factual Basis: Slope stability analysis following 1993 floods.
Appendix A.1
35
-------
Region
Site Name, State
Region 7
Weldon Spring, MO
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/27/93
1/18/96
[BSD]
Date Review
Commenced
Date Review
Completed
11/95
1/18/96
Change
Initiator
State
Media
Debris,
Soil,
Solid Waste
State/
Community
Involvement
Public notice in local paper; public
meeting; DOE contacted citizen's
group; State involved throughout
change process.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 53 hrs;
Contr. = $0
Est'd Savings =
$0
Type of Change: From - use of separate landfills; To - combination of landfills.
Factual Basis: Similar waste on adjacent DOE property; value engineering study.
Region 8 - FY97
Region 8
Libby Groundwater, MT
Region 8
Ogden Depot (OU2), UT
12/30/88
1/22/97
[BSD]
1/24/95
5/30/96
EPA
Groundwater,
Soil
State reviewed and provided
comments on ESD; public notice
and fact sheet.
Fed= 160 hrs;
Contr. = $12,000
(incl. 5-yr review)
Est'd Savings =
probably no savings
Type of Change: From - excavation and biotreatment of soils within on-site land treatment unit, in-situ biotreatment of
groundwater, and pump and treat/bioreactor system; To - new MCLs for certain groundwater contaminants and revised
remediation levels.
Factual Basis: Revised toxicology assessments and change in promulgated MCL for primary contaminant.
9/7/90
10/15/96
[BSD]
3/1/96
10/15/96
Fed. Fac.
Groundwater
State reviewed and concurred with
this proposal.
Fed = 20 hrs.
Contr. = $640
Est'd Savings =
None
Type of Change: From - Treat groundwater until cleanup level is below MCLs; To - Treat groundwater until cleanup level is at
or below MCLs.
Factual Basis: Original objective was too stringent by law.
Appendix A.1
36
-------
Region
Site Name, State
Region 8
Summitville Mine, CO
Region 8
Summitville Mine, CO
Date of
Original ROD
Date of Change
[ESD/ROD-A]
12/15/95
5/16/97
[Memo to files]
Date Review
Commenced
Date Review
Completed
1/15/96
5/30/96
Change
Initiator
EPA
Media
Surface Water
State/
Community
Involvement
Colorado Department of Public
Health and Environment.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = hrs.
Contr. = not included
~ in part of standard
design
Est'd Savings =
$350,000
Type of Change: From - Acid mine drainage discharged to treatment plant; To - Acid mine drainage discharged to surface
impoundment and then treatment prior to release.
Factual Basis: Modifications were made in the Water Treatment Interim ROD to optimize the performance and minimize costs
of the selected remedy during remedy design.
12/15/95
6/4/97
[BSD]
9/1/95
4/1/96
EPA,
State
Leachate
State concurred.
Fed = 0 hrs;
Contr. = $0
Est'd Savings =
$1.7 million
Type of Change: From - in-situ biotreatment of cyanide and cap; To - rinsing with clean water and treatment of leachate.
Factual Basis: Cyanide levels in leachate were reduced without biological treatment.
Region 8 - FY96
Region 8
Chemical Sales, CO
6/27/91
12/11/95
[BSD]
3/93
11/1/95
EPA
Soil,
Groundwater
State concurred with ESD and
changes to selected remedy. ESD
placed in Administrative Record.
Fed= 180 hrs;
Contr. = $10,000
Est'd Savings =
$1.5 million
Type of Change: From - recirculation of treated exhaust gases into soil, and air stripping of groundwater; To - eliminate
recirculation of soil, and air sparging for groundwater, and From - catalytic oxidation of soil vapors; To - resin absorption.
Factual Basis: New hydrogeologic information obtained during design and more effective remedy.
Appendix A.1
37
-------
Region
Site Name, State
Region 8
Idaho Pole, MT
Region 8
Old Minot Landfill, ND
Region 8
Wasatch Chemical, UT
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/28/92
5/21/96
[BSD]
Date Review
Commenced
Date Review
Completed
6/95
12/95
Change
Initiator
PRP,
EPA
Media
Groundwater,
Soil
State/
Community
Involvement
State reviewed and provided
comments on BSD; public meeting
and fact sheets.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed= 160hrs;
Contr. = $10,000
Est'd Savings =
not available
Type of Change: From - water flushing of soils and biological treatment of groundwater; To - ambient temperature water
flushing of soils and carbon adsorption of groundwater.
Factual Basis: Additional information in design replaced design problem in original ROD remedy.
6/21/93
5/2/96
[BSD]
1 1/7/95
5/2/96
PRP
Leachate,
Landfill gas
City involved in cleanup; limited
community interest.
Fed= lOOhrs;
Contr. = $0
Est'd Savings =
$0.3 million
Type of Change: From - active methane gas extraction and leachate collection system; To - passive collection system and
cap design changes, and From - proposed active leachate extraction system, To - passive gravity drain system and limits of
buried waste extended.
Factual Basis: New information regarding limits of buried waste and equivalent protection at less cost.
3/29/91
11/30/95
[BSD]
5/17/93
6/9/95
PRP
Groundwater,
Soil,
Surface water,
Site boundary
State concurred Fact sheets
provided to community and State.
Fed = 80 hrs;
Contr. = $4,000
Est'd Savings =
$244,000
Type of Change: From - asphalt cover for soils; To - eliminate cover to prevent stormwater control problems and change site
boundaries.
Factual Basis: Additional data from investigations during design, including reduction of stormwater discharge and differences
in site boundaries.
Appendix A.1
38
-------
Region
Site Name, State
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 9 - FY97
Region 9
Apache Powder, AZ
Region 9
Fort Ord, CA
(OU2)
Region 9
Lawrence Livermore
National Laboratory
(Main Site), CA
9/30/94
4/16/97
[BSD]
11/96
2/97
EPA
Groundwater
Public meeting, State comments.
Fed = 600 hrs;
Contr. = $3,000
Est'd Savings =
$13M
Type of Change: From - Extraction from 7 wells in perched ground water with treatment by brine concentrator; extraction
from 4 wells in shallow aquifer with treatment by constructed wetlands; To -Extraction from 4 total wells in shallow aquifer
with treatment in 2 constructed wetland systems in different locations.
Factual Basis: Reduced nitrate and water levels in perched ground water enabling dewatering of this zone by pumping from
shallow aquifer and elimination of brine concentrator. Wetland location change enabled simpler construction, including
elimination of pond liners.
8/94
1/17/97
[BSD]
1/97
Fed. Fac.
Soil
State concurred; public meeting;
60-day public comment period.
Fed = hrs;
Contr. = $0
Est'd Savings =
$ 1 1 million
Type of Change: From- Landfill cap; To- Consolidation of wastes into the existing landfill from other Fort Ord wastes and
subsequent capping.
Factual Basis: Cost and groundwater modeling. Savings resulted from avoiding cost of offsite disposal of soil from other sites.
7/15/92
4/16/97
[BSD]
1/97
4/97
DOE/
LLNL
Groundwater
Cal/EPA(Both DTSC and
RWGCB) involved.
Public notified during public
meetings; no public comments
received.
Fed = hrs;
Contr. =
Est'd Savings =
$220,000/year
Type of Change: From - Use of ultraviolet/hydrogen peroxide (UV/H202) and air stripping groundwater treatment technologies
at treatment facilities A and B (TFA and TFB); To - Air stripping only groundwater treatment systems at TFA and TFB.
Factual Basis: Sampling results show VOC levels decreasing; no UV/H202 system needed; air stripping alone OK.
Appendix A.1
39
-------
Region
Site Name, State
Region 9
Lawrence Livermore
National Laboratory
(Main Site), CA
Region 9
San Fernando Valley Area
1, Burbank OU, CA
Region 9
Selma Pressure Treating,
Selma, CA
Region 9
Tucson International
Airport, AZ
Date of
Original ROD
Date of Change
[ESD/ROD-A]
7/15/92
4/15/97
[BSD]
Date Review
Commenced
Date Review
Completed
1/97
4/97
Change
Initiator
DOE/
LLNL
Media
Groundwater
State/
Community
Involvement
Cal/EPA involved.
Public notified during public
meetings; no public comments
received.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = hrs;
Contr. =
Est'd Savings =
None
Type of Change: From - Fixed metals discharge limits; To - Seasonal (wet/dry season) metals discharge limits.
Factual Basis: Changes made after original discharge permit expired. Seasonal limits are more protective.
6/89
2/97
[BSD]
3/95
2/97
PRP
Groundwater
No objections from State or
community.
Fed = 600 hrs;
Contr. = $5,000
Est'd Savings =
$49 million
Type of Change: From - extract and treat groundwater using air or steam stripping and vapor phase granular activated carbon;
To - extracted volume reduced by 25%.
Factual Basis: New information from design review process and reduced volume levels.
9/88
4/18/97
[BSD]
3/97
4/97
EPA
Groundwater
DTSC reviewed and commented;
fact sheets were sent to people on a
community distribution list; public
comment period provided.
Fed = hrs;
Contr. = $
Est'd Savings = TBD
Type of Change: From - Return of effluent via reinjection wells; To - Return of effluent via percolation ponds.
Factual Basis: Reconsideration of certain technical information during design and additional data gathered pursuant to ROD.
8/88
2/27/97
[BSD]
11/94
2/97
Fed. Fac.
Air,
Groundwater
State and community support the
change.
Fed = 200 hrs;
Contr. = $0
Est'd Savings =
no net savings
Type of Change: From - air stripping and municipal end use; To - air stripping with emission control and reinjection end use.
Factual Basis: Community and city objected to delivery of treated ground water into drinking water distribution system.
Appendix A.1
40
-------
Region
Site Name, State
Region 9
United Heckathorn Co.,
CA
Date of
Original ROD
Date of Change
[ESD/ROD-A]
10/26/94
11/96
[BSD]
Date Review
Commenced
Date Review
Completed
7/95
11/96
Change
Initiator
PRP
Media
Sediment
State/
Community
Involvement
State and community generally
supportive.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 700 hrs;
Contr. = $0
Est'd Savings =
no net savings
Type of Change: From - dredged material disposed at one landfill; To - different landfill.
Factual Basis: More rapid disposal.
Region 9 - FY96
Region 9
Fort Ord, CA
(OU2)
Region 9
Koppers (Oroville), CA
8/94
8/13/96
[BSD]
8/13/96
Fed. Fac.
Groundwater
State concurred.
Fed = hrs;
Contr. = $0
Est'd Savings =
None
Type of Change: From- Unestablished lower aquifer cleanup levels; To- Establish lower 180 ft. aquifer cleanup levels.
Factual Basis: Set ground water cleanup levels at MCLs.
9/89
8/29/96
[ROD-A]
3/94
8/96
PRP
Soil
High level of State and community
involvement and support. Public
comment period; public meeting;
fact sheet issued; City and State
concurred.
Fed= 1600 hrs9;
Contr. = $15,000
Est'd Savings =
$15 million
Type of Change: From - innovative treatment of soils to residential levels; To - Excavate and dispose in an on-site landfill to
industrial land use levels.
Factual Basis: Treatability testing results were unfavorable to original technology, discovery of more extensive mixed
contamination, and change in land use scenario.
9 Long-term project with extensive community involvement; severe differences in design compared to actual contamination;
EPA made many changes to ROD.
Appendix A.1
41
-------
Region
Site Name, State
Region 9
Middlefield - Ellis -
Whisman (MEW) Study
Area, CA
Region 9
Nineteenth Ave. Landfill,
AZ
Region 9
Phoenix-Goodyear, AZ
Date of
Original ROD
Date of Change
[ESD/ROD-A]
6/89
4/6/96
[BSD]
Date Review
Commenced
Date Review
Completed
10/95
4/96
Change
Initiator
PRP
Media
Groundwater
State/
Community
Involvement
None.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 500 hrs;
Contr. =
Est'd Savings =
$150,000
Type of Change: From - Air stripping with vapor phase granular activated carbon (GAC) treatment; To - Air stripping with
liquid GAC treatment.
Factual Basis: Numerical standards characterized as "goals" in the original ROD are now the final cleanup "standards" per the
BSD.
9/29/89
11/95
[BSD]
11/94
11/95
PRP,
State,
Comm.
Groundwater,
Leachate,
Solid waste
State-lead project; State and
community Technical Advisory
Group requested change.
Fed = 40 hrs;
Contr. = $0
Est'd Savings =
not available (higher
capital cost, lower
maintenance cost)
Type of Change: From - old liner system; To - different type of impermeable liner.
Factual Basis: To reduce maintenance problems and improve reliability.
9/26/89
12/22/95
[BSD]
10/94 (oral),
9/95 (written)
12/95
EPA,
PRP
Groundwater
No State or community opposition.
Public notified; public comment
period; BSD and other documents
placed in Administrative Record.
Fed = 80 hrs;
Contr. = $0
Est'd Savings =
not available
Type of Change: From - pump and treat using air stripping followed by liquid phase granular activated carbon; To - air
sparging and inclusion of a metal adsorption treatment system.
Factual Basis: More effective and accelerated removal of VOCs; treatability study indicating more effective removal of
chromium from groundwater; cost-effective response.
Appendix A.1
42
-------
Region
Site Name, State
Region 9
Purity Oil, CA
Region 9
Williams AFB, OU2, AZ
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/92
7/3/96
[BSD]
Date Review
Commenced
Date Review
Completed
8/95
7/96
Change
Initiator
PRP
Media
Soil
State/
Community
Involvement
State support; no community
objections.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed= 1000 hrs10;
Contr. = $0
Est'd Savings =
$26 million
Type of Change: From - slurry wall and extensive soil vapor extraction system; To - no slurry wall and change in design of
soil vapor extraction.
Factual Basis: New information on soil and waste characterization in pre-design.
12/30/92
8/16/96
[ROD-A]
5/96
8/96
Fed. Fac.
Soil
Groundwater
The public was invited to comment
through public comment periods
advertised in local newspapers and
public meeting. The RAB was
briefed in the proposed change in
remedy.
Fed = hrs;
Contr. = $
Est'd Savings =
TBD
Type of Change: From - Separated deep soil (>25 ft.) into OU3; To - returned deep soils into OU2 and propose SVE to treat
deep soils.
Factual Basis: Results of treatability studies performed at OU2 and OU3.
10 Intensive in-house technical and enforcement review over 2-year period; multiple meetings of the EPA team and PRPs.
Appendix A.1 43
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Region
Site Name, State
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 10 - FY97
Region 10
Commencement Bay
Nearshore/
Tideflats, WA
Region 10
Gould, OR
9/30/89
7/28/97
[BSD]
6/95
7/28/97
PRP
Sediment
Fact sheets/public notices and
meetings held; responded to >50
comments (verbal/written). State
concurred but Puyallup Tribe did
not concur.
Fed = 2,000 hrs11;
Contr. = $7,000
Est'd Savings =
$13 million
Type of Change: From - PCB sediment cleanup levels after 10 years; To - Slightly higher levels of PCBs in
sediment immediately after cleanup and after 10 years.
Factual Basis: New modeling (toxicity and exposure assumptions) and cost estimates justified new response levels.
3/31/88
6/3/97
[ROD-A]
5/94
6/3/97
PRP
Debris,
Sediment,
Soil
State reviewed and concurred; fact
sheet distributed to community;
other interested parties and PRPs;
no comments from community.
Fed = 800 hrs;
Contr. = $0
Est'd Savings =
$15 million
Type of Change: From - treatment and recycling of lead contaminated materials; To - treatment and containment (stabilize
waste and consolidate in a lined and capped on-site containment facility).
Factual Basis: Additional investigation showed volume of waste is smaller than originally presumed and new remedy is more
efficient and cost-effective. Cleanup activities coordinated with adjacent facility.
11 The process took over one year - involved numerous reviews and responses to comments; coordinated with trustees and the
public; and reviewed technical decisions.
Appendix A.1
44
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Region
Site Name, State
Region 10
Hanford 100 Area, WA
Region 10
Teledyne Wah Chang, OR
Region 10
Toftdahl Drums, WA
Date of
Original ROD
Date of Change
[ESD/ROD-A]
9/28/95
4/4/97
[ROD-A]
Date Review
Commenced
Date Review
Completed
4/96
4/4/97
Change
Initiator
EPA,
State,
Fed. Fac.
Media
Debris,
Soil,
Solid waste
State/
Community
Involvement
Public notices - received comment
supporting change; fact sheets
issued; Fed. Fac. Sponsored
Advisory Committee meeting; State
concurred.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
EPA: 4 mos., DOE:
12 mos. + 3 FTE for
contractors, State: 8
mos.
Est'd Savings =
$297 million
Type of Change: From - excavation, treatment and on-site disposal to clean up 37 sites; To - Streamlining of the original 37
sites plus excavation and on-site disposal of 34 more sites with similar wastes.
Factual Basis: No technology change; value engineering and inter-organizational coordination regarding improved soil volume
estimates and reduction in sampling and analysis costs.
6/10/94
10/8/96
[BSD]
3/96
9/19/96
PRP
Groundwater,
Sediment,
Soil
Public notice; public comment
period; no comments received;
State was part of negotiations
leading to change and concurred
with BSD.
Fed = 800 hrs;
Contr. = $0
Est'd Savings =
$1.1 million
Type of Change: Modifications to ground water remedy: From - groundwater extraction at and outside the plant boundaries;
To - on-site hot-spot ground water remediation and monitored natural attenuation.
Factual Basis: Monitoring of groundwater during design indicated significant decreases of concentrations.
9/30/86
6/17/97
[BSD]
2/97
6/17/97
State
Groundwater
State discussed proposed changes
with nearby residential property
owners; State and EPA issued
public notice (no comments).
Fed = 6 hrs;
Contr. = $0
Est'd Savings =
$5,000
Type of Change: From - 15 years of ground water monitoring; To - cease ground water monitoring after 10 years.
Factual Basis: Monitoring determined that no threat posed to public health and safety.
Appendix A.1
45
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Region
Site Name, State
Date of
Original ROD
Date of Change
[ESD/ROD-A]
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/
Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 10 - FY96
Region 10
Bunker Hill Mining and
Metallurgical Complex,
ID
Region 10
Harbor Island (Soil and
Ground Water Operable
Unit), WA
Region 10
Western Processing, WA
9/22/92
9/9/96
[ROD-A]
1/96
9/9/96
EPA
Soil
Notices and public meetings;
only one comment letter received
from Coeur d'Alene Tribe; State
concurred with change.
Fed = 200 hrs;
Contr. = $3,500
Est'd Savings =
$6.2 million
Type of Change: From - stabilization/cap in a closure cell; To - waste encapsulation and cap.
Factual Basis: Post-ROD leachability study inconclusive for previous remedy; new remedy provides cost-effectiveness for
equivalent protection.
9/30/93
1/25/96
[ROD-A]
4/11/95
1/25/96
PRP
Soil
Public notice - few comments
received; State concurred with
change.
Fed = 200 hrs;
Contr. = $0
Est'd Savings =
$2 million
Type of Change: From - thermal desorption of petroleum- contaminated soil; To - off-site disposal of petroleum -contaminated
soil that is not a hazardous nor dangerous waste.
Factual Basis: Re-evaluation of site conditions and options provided more cost-effective and timely but still protective clean
up.
9/25/85
12/11/95
[BSD]
9/12/95
12/11/95
PRP
Groundwater,
Soil
Fact sheet issued; local government
and State support; low level of
community interest.
Fed = 700 hrs;
Contr. = $30,000
Est'd Savings =
$82 million
Type of Change: From - slurry wall and pump and treat for contaminant mass removal and protect surface waters; To -
source contaminant with inward gradient within slurry wall, plume containment outside slurry wall, bioremediation, and other
treatment of hot spots.
Factual Basis: Updated information after 5+ years of pumping and more cost-effective response.
Appendix A.1
46
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Appendix A.2:
Summary of Remedy Update Information for FY96 and
FY97 for Sites With Cost Increases
NOTE: The information and data presented in Appendix A. 2 represents only a portion of the
information available in the decision document. If more information is needed, please refer to
the site's ESD, ROD-Amendment, memo-to-file, or letter.
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Appendix A.2: Summary of Remedy Update Information for FY96 and FY97 for
Sites with Cost Increases
Region
Site Name, State
Region 2
Robintech, NY
legion 2
mperial Oil/Champion
Chemical, NJ
Region 4
Coleman-Evans Wood
Preserving, FL
Date of
Original ROD
Date of Change
[ESD/ROD-A]
3/92
7/97
[ROD-A]
Date Review
Commenced
Date Review
Completed
1/97
9/97
Change
Initiator
EPA, PRP
Media
Soil,
Groundwater
State/
Community
Involvement
Some State and public interest.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 200 hrs;
Contr. = $
Est'd Increase =
$700,000
Type of Change: From - Extraction and air stripping of bedrock and overburden groundwater; To - Excavate and treat using
low temperature thermal desorption for soils, natural attenuation for overburden groundwater and treatment of bedrock aquifer.
Factual Basis: Additional information gathered in design made it apparent that the geology of the overburden was unsuitable
for the implementation of a groundwater extraction system.
9/90
9/97
[BSD]
7/96
7/96
EPA
Soil
State concurrence, full State and
community support.
Fed= 10 hrs;
Contr. =$
Est'd Increase =
TBD
Type of Change: From - Excavation and offsite disposal of soil within wetlands; To - Additional excavation and off-site
disposal for soil in off-site area 2.
Factual Basis: Comprehensive sampling data in design showed a greater value of soil contamination present.
9/25/86
9/25/97
[2nd ROD-A]
6/30/92
4/30/95
EPA
Debris,
Groundwater,
Soil, Sediment
State supported EPA throughout
the process. Fact sheet issued to
public, no comments received.
Fed=10001hrs;
Contr. = $250,000
Est'd Increase =
$12M
Type of Change: From - Soil washing, bioremediation, and solidification/stabilization; To - Thermal desorption with a
contingency of capping.
Factual Basis: Due to the discovery of dioxin at the site and the inability of bioremediation to treat dioxin, the remedy was
amended.
Evaluated treatability study results; prepared supplemental feasibility study; extensive characterization of dioxin, both onsite and offsite; conducted
public meeting and community interviews; and negotiated with the State.
Appendix A.2
1
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Region
Site Name, State
Region 4
National Electric
Coil/Cooper Industries,
KY
Region 9
Westinghouse, CA
Date of
Original ROD
Date of Change
[ESD/ROD-A]
4/96
7/97
[BSD]
Date Review
Commenced
Date Review
Completed
1 1/5/96
7/97
Change
Initiator
PRP
Media
Groundwater
State/
Community
Involvement
State concurred with BSD.
Public was notified by fact
sheet.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 200 hrs;
Contr. = $
Est'd Increase =
$300,000
Type of Change: From - Extraction wells; To - interceptor trench for "shallow" groundwater recovery method.
Factual Basis: Shallow aquifer was determined to be poor water formation during dry periods; trench is a more passive means
to recover contaminated water.
10/16/91
3/14/97
[BSD]
1/94
2/97
PRP
Soil
Notified community via fact
sheet and community meeting
held 2/20/97.
Fed = hrs;
Contr. = $
Est'd Increase =
$500,000
Type of Change: From - Incineration of PCB soils with concentrations greater than 25 ppm; To - Landfilling PCB soils with
concentrations between 25-500 ppm and incinerating soils with concentrations greater than 500 ppm.
Factual Basis: The BSD only applies to newly discovered contaminated soil found in the North parking Lot. PRP requested
change which is applicable for TSCA. Change requested because company wanted to sell half of parking lot acreage to a
corporate neighbor who will use the lot to build a warehouse.
Appendix A.2
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Appendix B:
Summary of Regional Implementation Plans
NOTE: EPA requested that Regions provide their strategy for implementing the Updating
Remedy Decisions reform. The following implementation plans should be viewed as "living "
documents, and subject to possible future revisions.
-------
Appendix B:
Summary of Regional Implementation Plans
Region
Date
Submitted
Strategy for Fund-lead Sites
Strategy for Other-lead
Sites
General Comments
1
11/25/97
Region 1 has developed draft criteria to
review sites and remedies. These have
been forwarded to EPA Headquarters.
Region 1 continuously
reviews remedies with States
and PRPs to identify any new
technologies or policy
changes that could expedite
the cleanup.
Region 1 is receptive to PRP
requests for modifying a
remedy.
There is no backlog of PRP
requests in the Region.
Region 1 anticipates
completing remedy updates at
six sites during FY98.
Appendix B
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Region
Date
Submitted
Strategy for Fund-lead Sites
Strategy for Other-lead
Sites
General Comments
1/18/98
The Region 2 remedy review team will
meet for four hours per week to review
RODs, design documents, Five Year
Reviews, or other technical
documentation of the remedy and for
team discussion with the Remedial
Proj ect Manager (RPM). The team' s
goal will be to provide assistance to
RPMs in determining if a remedy
update could benefit site cleanup
activities.
The focus of the reviews will be on
older remedies. The team will
generally not consider sites that are
currently targeted for construction
completion by the end of year 2000.
The team will also review any site that
the RPM requests. The group will
provide a monthly status report to the
Director which will indicate the
number of remedies reviewed and the
status of the work group
recommendations. In five months, all
Fund-lead operable units where
construction has not begun will have
been reviewed.
Region 2 continues to review
every proposed remedy
change requested by
responsible parties (RPs).
The site project manager and
the appropriate technical staff
and management will conduct
all reviews of PRP-proposed
changes.
Region 2 will continue to track
every request to review a
remedy and will report on the
number of ESDs or ROD
Amendments issued.
Region 2 will track the
estimated cost savings if
appropriate.
The entire review is expected
to last approximately five
months.
Appendix B
-------
Region
Date
Submitted
Strategy for Fund-lead Sites
Strategy for Other-lead Sites
General Comments
12/13/97
All remedies at Fund-lead sites
should be evaluated for
possible changes during the
Five Year Review. Reviews
will be conducted by the site's
RPM, the ORC attorney, the
Remedial Section Chief and a
member of Regional technical
support group. Region 3 may
also involve the Office of
Research and Development
and the Remedy Review
Board.
Any potential remedy change
can be considered up until the
Remedial Design (RD) phase
is 30 percent complete.
New technologies and more
cost effective strategies will be
periodically reviewed as part
of the monthly Regional RPM
meetings.
All remedies at PRP-lead sites
should be evaluated for
possible changes during the
Five Year Review.
Changing the remedy is
always open to discussion.
RPMs create a climate of open
discussion with RPs and are
open to review requests at any
time.
New technologies and more
cost effective strategies will be
periodically reviewed as part
of the monthly Regional RPM
meetings.
RPMs will also maintain the
resources to implement the
original remedy, should the
remedy change not be feasible.
Appendix B
-------
Region
Date
Submitted
Strategy for Fund and Other-lead Sites
General Comments
12/22/97
Remedy review considerations occur continuously at all
Regional remedial sites throughout the RD phase (and to some
degree during the early stages of Remedial Action (RA)).
Requests from EPA, the PRP, the State, or Federal facilities can
trigger a remedy review.
All remedies will be evaluated as part of the Five Year Review
process, which will occur at least once on all sites and will occur
every 5 years for all long-term response actions.
Supplemental alternatives that demonstrate a likelihood of
significantly decreasing the duration of a long-term remedial
action or attaining a much better end-point at potential technical
impracticability (TI) sites will be considered in the routine
review process of evaluating remedy implementation.
The primary criteria Region 4 will
use to determine whether to revise
a remedy are: 1) Is it equally or
more protective of human health
and the environment? 2) Is it more
cost and/or technically effective?
3) What effect will the remedy
change have on the speed and
timeliness of cleanup?
For FY 98, Region 4 will continue
to identify and track sites that are
evaluating alternative approaches
to the remedy selected in the
ROD.
Appendix B
-------
Region
Date
Submitted
Strategy for Fund and Other-lead Sites
General Comments
12/16/97
The Region will continue to respond to requests for remedy
changes from stakeholders (PRPs, States, communities).
Requests can be made verbally or in writing and should initially
be directed to the site RPM.
The Region will use a portfolio management concept for updates
which includes:
- A uniform set of critical project milestones for each phase of
the remedial pipeline; and
A set of questions for use during the RI/FS/Remedy
Selection phase to enhance the dialogue between RPMs and
first-line managers on areas of national programmatic focus
(e.g., lead, groundwater, National Remedy Review Board
(NRRB) criteria).
In FY98, first-line supervisors will expand the dialogue with
each RPM to include a discussion on potential for updating the
site remedy.
Region 5 is committed to exploring the development of
Operations and Maintenance (O&M) experts during FY98.
O&M experts will review projects in long-term Response
Action for possible changes.
During FY96, remedy updates
were completed at six sites, for an
estimated $58.1 million in cost
savings. During FY97, remedy
updates were completed at 16
sites, for an estimated $137.1
million in cost savings.
For both years, the majority of
remedy changes were initiated by
PRP requests.
Appendix B
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Region
Date
Submitted
Strategy for Fund-lead Sites
Strategy for Other-lead Sites
General Comments
12/16/97
Any site where a remedy has been selected may be reviewed.
Requests for a remedy update are evaluated by the Regional
office.
A review may be triggered by:
A request from a PRP, a State or local environmental or
health agency, or a community group; or
Information generated by the Regional office, either as
part of a remedial design or a site Five Year Review.
Region 6 considers all remedy review requests.
Proposed changes to remedies
must be at least as protective and
cost effective as the remedy
already selected.
Some remedies will not be
changed if the proposed
alternative provides less overall
protection of human health and
the environment, or does not
comply with applicable
regulations.
Appendix B
-------
Region
Date
Submitted
Strategy for Fund and Other-lead Sites
General Comments
11/25/97
All Superfund remedial sites are eligible for remedy review.
Sites will be identified by stakeholders, such as: PRPs; State
environmental and health agencies; local city and county
government; local formal and informal community groups; EPA
technical staff; and the EPA Regional Superfund Ombudsman.
Where appropriate, sites subject to Five Year Review will be
considered as possible update remedy candidates depending on
the protectiveness and effectiveness of each site remedy. In
addition to revisions based on advances in remediation, science
and technology, Region 7 will consider remedy improvements
indicated by additional post-ROD sampling and analytical data,
remedy performance data gathered from a post-ROD period of
operation, and other factors.
Generally, the criteria for updating
a remedy will be whether the
proposed change to the remedy is
equally or more protective of
human health and the
environment, and equally or more
cost and technically effective.
Region 7 has compiled a list of
FY98 candidate remedy update
sites. The list will be updated at
least quarterly and will track
completed reviews and resulting
decisions.
Appendix B
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Region
Date
Submitted
Strategy for Fund-lead Sites
Strategy for Other-lead Sites
General Comments
12/31/97
EPA RPMs and State staff are
expected to identify
opportunities for remedy
changes. Some of these
become evident as designs are
completed; as the remedy is
being implemented; and
during the O&M phase or at
the Five Year Review.
A determination must be made
on the significance of the
change to determine whether
the change should be a ROD
Amendment, BSD, or minor
change that should be
documented in the record.
Region 8 plans to track these
three types of changes in
CERCLIS.
Any stakeholder may request a
review (i.e., PRPs, Federal
facilities, State, community, or
local government). Region 8
expects that Five Year
Reviews may result in remedy
updates at many sites. All
requests must be documented
in writing and placed in the
Superfund Record Center.
Region 8 will evaluate all
requested updates to RODs in
a two-phased process. The
request will first be screened
to determine if there is
adequate supporting rationale
for the request (e.g., new data
not considered in the ROD,
new technology not evaluated
in the ROD, new risk
information, new cost
estimates, or a change in land-
use nearby). If sufficient
rationale exists, a more
detailed analysis will be done
to determine whether an
update is warranted based on
the nine criteria, and what
form it should take.
Project staff will be expected to
follow the two-step process and
keep appropriate records on how
the requests were handled.
A Superfund Reforms seminar,
which will include a discussion of
key reforms and an explanation of
expectations for site teams in
evaluating review requests, will
be held during the second quarter
of 1998 for all Regional
Superfund staff.
Appendix B
-------
Region
Date
Submitted
Strategy for Fund-lead Sites
Strategy for Other-lead Sites
General Comments
1/6/98
Region 9 will consider all
requests for remedy changes.
All sites are considered to be
equally eligible for changes.
Decisions on remedy changes
will be made at the Branch
Chief level. The procedure for
review and response will be
determined on a case-by-case
basis.
Managers of projects in the
design phase are being
encouraged by their
supervisors to actively seek
opportunities to refine
remedies to reduce cost and/or
improve effectiveness.
Where new information
indicates that a remedy is not
meeting objectives, Region 9
will consider modification of
the remedy and, where
appropriate, a technical
impracticability waiver.
Region 9 will address the
potential for remedy update in
all Five Year Reviews.
All sites are considered to be
equally eligible for changes.
Federal facility remedy update
activities will generally be
consistent with the Fund-lead
sites, although the fact that the
Federal agencies have lead
responsibilities requires that
these sites be managed in
different ways.
As part of Region 9's FY98
planning process, each section
chief in the Superfund Site
Cleanup Branch prepared a
Section Operating Plan which
included site-specific plans for the
upcoming fiscal year. These plans
discussed how Superfund
Reforms would be implemented
on a site-specific basis, including
the potential for updating
remedies at each site during
FY98. Region 9 identified 12
sites as potential candidates for
remedy updates in FY98.
Region 9 recommends that a
national analysis of past remedy
updates be conducted to
determine what has been
accomplished to date and where
the best opportunities may lie for
other projects.
Appendix B
-------
Region
Date
Submitted
Strategy for Fund-lead Sites
Strategy for Other-lead Sites
General Comments
10
12/4/97
All sites are considered to be
equally eligible for changes.
Generally, these sites are
identified by the people who
are most familiar with the
sites: the EPA RPMs working
together with the State,
Federal facility, and PRP site
managers.
All sites undergoing Five Year
Reviews will also be
considered as possible update
remedy candidates.
All sites are considered to be
equally eligible for changes.
Requests received from other
parties, including the PRPs
and the public, would receive
equal consideration and
priority with those updates
identified by the site
managers.
All sites undergoing Five Year
Reviews will also be
considered as possible update
remedy candidates.
Five sites are under review for
potential remedy updates (3
Federal facilities; 1 State-lead; 1
Federal-lead fund-financed).
Region 10 has no backlog of sites
where a remedy update has been
requested but where the Region
has not started the review.
Post-ROD sampling and remedy
performance information are
among the many possible sources
of information for remedy
updates.
Region 10 has not had any
requests for updates based on new
State ARARs, but anticipates
them in the future.
Appendix B
10
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