Pilot Project to Optimize Superfund-financed Pump
and Treat Systems: Summary Report and Lessons
Learned
DISCHARGE PIPE
EXTRACTION WELLS
TREATMENT
BUILDING
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Pilot Project to Optimize Superfund-financed Pump
and Treat Systems: Summary Report and Lessons
Learned
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NOTICE
Work described herein was performed by GeoTrans, Inc. (GeoTrans) and the United States Army Corps
of Engineers (USAGE) for the U.S. Environmental Protection Agency (U.S. EPA). Work conducted by
GeoTrans, including preparation of this report, was performed under Dynamac Contract No. 68-C-99-
256, Subcontract No. 91517, Task AD02-105. Mention of trade names or commercial products does not
constitute endorsement or recommendation for use.
This document (EPA 542-R-02-008a) may be downloaded from EPA's Technology Innovation Office
website at www.epa.gov/tio or www.cluin.org/rse. A limited number of hard copies are also available
free of charge from the National Service Center for Environmental Publications (NSCEP) at the following
address:
U.S. EPA National Service Center for Environmental Publications
P.O. Box 42419
Cincinnati, OH 45242-2419
Phone: (800) 490-9198 or (513) 489-8190
Fax:(513)489-8695
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PREFACE
This report summarizes Phase II (site optimization) of the Nationwide Fund-lead Pump and Treat
Optimization Project. This phase included conducting Remediation System Evaluations (RSEs) at each of
the 20 sites selected in Phase I with the purpose of providing recommendations to improve remedy
effectiveness, reduce remedy costs, improve technical operations, and gain site closeout. RSEs at four of
the 20 P&T systems (two in Region 4 and two in Region 5) were previously conducted as part of a
demonstration project completed in 2000.
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ACKNOWLEDGMENTS
The project team is grateful for the help provided by the EPA Remedial Project Managers (RPMs) for
each evaluated site and the EPA Project Liaisons from each Region. They were vital in transferring site
documents to the RSE team, scheduling the site visits, providing information during site visits, and
reviewing the RSE reports. The authors also extend sincere thanks to the principal investigators from the
U.S. EPA Technology Innovation Office (TIO) and U.S. EPA Office of Emergency and Remedial
Response (OERR).
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IV
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EXECUTIVE SUMMARY
As part of the Superfund program, the U.S. Environmental Protection Agency (EPA) provides funding for
groundwater remedies at Superfund-fmanced (i.e., "Fund-lead") sites. A large percentage of these
remedies are pump and treat (P&T) systems designed to restore groundwater and/or contain contaminants.
On July 7, 2000, the EPA Office of Solid Waste and Emergency Response (OSWER) issued Directive
No. 9200.0-33, Transmittal of Final FYOO - FY01 Superfund Reforms Strategy, which outlined a
commitment to optimize Fund-lead P&T systems. To assist EPA Regions in fulfilling this commitment,
the EPA Technology Innovation Office (TIO) and Office of Emergency and Remedial Response (OERR)
implemented a nationwide optimization project for Fund-lead P&T systems, consisting of the following
three phases:
• Phase I (complete) involved identifying the Fund-lead P&T systems and selecting
specific systems to receive optimization evaluations. The work performed during Phase I
is summarized in Groundwater Pump and Treat Systems: Summary of Selected Cost and
Performance Information at Superfund-financed Sites (EPA 542-R-01-021a).
Phase II (complete), the subject of this report, involved conducting an optimization
evaluation at each of the sites selected in Phase I. The optimization evaluations were
accomplished using the Remediation System Evaluation (RSE) process, which was
developed by the U.S. Army Corps of Engineers as a tool for remedy optimization.
• Phase III (ongoing) involves following up with site managers of the evaluated sites
primarily to track the progress toward implementing the recommendations generated
from the RSEs.
This report summarizes the results from RSEs performed at 20 Fund-lead sites with P&T systems. These
20 optimization evaluations have resulted in an improved understanding of the operating Fund-lead P&T
systems and have identified a number of opportunities for improvements in efficiency and effectiveness
relatively early in the operation of these systems. Throughout this project, effectiveness has been defined
as the ability of a remedy to meet its stated objectives of protecting human health and the environment by
containing ground water plumes and eliminating exposure pathways to site-related contamination. These
opportunities have been conveyed to the site managers through RSE reports that highlight
recommendations in the following four categories:
recommendations to improve remedy effectiveness with respect to preventing plume
migration and monitoring other exposure pathways
recommendations to reduce life-cycle operation and maintenance (O&M) costs
• recommendations for technical improvement
recommendations regarding site closeout
Each of the 20 RSEs resulted in recommendations related to one or more of the above-listed categories.
In general, recommendations to improve effectiveness pertained to subsurface issues such as improving
delineation of contaminant plumes and/or better evaluating the capture of those plumes. The
recommendations to reduce costs generally pertained to the above-ground treatment system and included
recommendations such as eliminating treatment components that are no longer necessary and reducing
labor costs (often possible because actual influent concentrations are much lower than design influent
concentrations). Technical improvement recommendations covered a wide range of items such as
repairing or replacing faulty equipment and rehabilitating fouled extraction wells. Site closeout
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recommendations generally involved developing a clearly stated site exit strategy or considering more
aggressive source removal options. The RSE team estimated that the capital cost for implementing all
recommendations is approximately $5.9 million but would result in a reduction in annual O&M costs of
approximately $4.8 million per year. Ground water remedies at Fund-lead sites are typically expected to
operate for more than 30 years.
In addition to summarizing the findings from this project, this report also presents specific lessons learned
and other considerations, listed below:
EPA Remedial Project Managers (RPMs) require additional technical assistance and
guidance (e.g., capture zone analysis, exit strategy, recognizing and correcting treatment
plant over-design, contracting, methods of life-cycle cost comparisons, etc.).
The remedial process is dynamic, and system evaluations must be routinely performed in
order to account for variations that occur in site conditions throughout the process.
• Many sites have continuing sources of NAPL contamination in the subsurface and are
unlikely to reach target clean-up levels through the entire plume with existing remedial
actions.
• Many ROD goals are not associated with specific metrics for evaluating progress, which
makes it impossible to determine the success or failure of the remedy.
RPMs are responsible for managing remedies that are protective of human health and the
environment and, as a result, may not adequately consider the remedy cost-effectiveness.
This may result in remedies with unnecessarily high costs.
Independent technical evaluations provide more opportunities for improving systems than
evaluations performed by site managers or O&M contractors.
• Oversight costs by EPA contractors are inconsistent and in some cases appear to be
higher than necessary.
Many recommendations require further engineering analysis to prove feasibility and may
involve additional capital expenditure and time for design and construction.
In addition, the following recommendations are suggested to maximize the benefits of the RSE process
and to develop the full-scale implementation of the project to all Fund-lead sites:
Follow up on each of the sites evaluated to date, to ensure progress is being made toward
implementing the recommendations, and to track associated costs and savings.
• Develop an ongoing program to track progress and costs/savings associated with
implementation of RSE recommendations in the future, including an approach to resolve
disputes if site managers do not implement RSE recommendations.
• Periodically update the database of Fund-lead P&T systems determined in Phase 1.
• Develop a strategy for selecting sites to receive future RSEs.
VI
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• Perform additional RSEs in the future utilizing RSE teams that are independent from the
site managers and their contractors.
Consider performing independent reviews of high-cost remedies during the design phase.
Consider establishing a strategy to identify and address sites with continuing sources of
ground water contamination (e.g., non-aqueous phase liquids) before transfer to the
states.
Develop guidance and training opportunities on technical deficiencies discovered during
RSEs conducted to date (e.g., effective overall management of pump and treat systems,
capture zone analysis, etc.).
Follow up is underway in Phase III of this project. Preliminary results from follow up of the 20 sites
suggest that the EPA Regions plan to implement 210 of the 230 RSE recommendations.
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Vlll
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TABLE OF CONTENTS
NOTICE i
PREFACE ii
ACKNOWLEDGMENTS iii
EXECUTIVE SUMMARY v
TABLE OF CONTENTS ix
1.0 INTRODUCTION 1
1.1 PROJECT BACKGROUND 1
1.2 THE RSE PROCESS 1
1.3 EVALUATED SITES AND SCHEDULE 2
2.0 SUMMARY OF RSE FINDINGS AND RECOMMENDATIONS 5
2.1 COMMON THEMES REGARDING EFFECTIVENESS 5
2.2 COMMON THEMES REGARDING COST REDUCTION 6
2.3 COMMON THEMES REGARDING TECHNICAL IMPROVEMENT 8
2.4 COMMON THEMES REGARDING SITE CLOSEOUT 8
3.0 CONCLUSIONS, LESSONS LEARNED, & RECOMMENDATIONS 11
3.1 LESSONS LEARNED 12
3.2 RECOMMENDATIONS To MAXIMIZE THE BENEFITS OF THE RSE PROCESS FOR FUND-LEAD P&T
SYSTEMS 13
4.0 PRELIMINARY FINDINGS FROM PHASE III 15
APPENDIX: 17
List of Tables
Table 1-1: Sites where RSEs were conducted as part of the nationwide Fund-lead pump and treat optimization
project
Table 3 -1: Number of RSE Recommendations by Category
Table 3-2: Summary of Cost and Cost Savings Estimates by Recommendation Category
Table 4-1: Summary of Progress Made Toward Implementing RSE Recommendations
List of Appendices
Appendix: Remediation System Evaluation (RSE) Reports for 20 Fund-lead Sites with Pump and Treat
Systems
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1.0 INTRODUCTION
1.1 PROJECT BACKGROUND
As part of the Superfund program, the U.S. Environmental Protection Agency (EPA) provides funding for
groundwater remedies at Superfund-fmanced (i.e., "Fund-lead") sites. A large percentage of these
remedies are pump and treat (P&T) systems designed to restore groundwater and/or contain contaminants.
On July 7, 2000, the EPA Office of Solid Waste and Emergency Response (OSWER) issued Directive
No. 9200.0-33, Transmittal of Final FYOO - FY01 Superfund Reforms Strategy, which outlined a
commitment to optimize Fund-lead P&T systems. To assist EPA Regions in fulfilling this commitment,
the EPA Technology Innovation Office (TIO) and Office of Emergency and Remedial Response (OERR)
implemented a nationwide optimization project for Fund-lead P&T systems, consisting of the following
three phases:
Phase I (complete) involved identifying the Fund-lead P&T systems and selecting
specific systems to receive optimization evaluations. A total of 88 Fund-lead P&T
systems were identified and 20 of them were selected for Remedial System Evaluations
(RSEs). The work performed during Phase I is summarized in Groundwater Pump and
Treat Systems: Summary of Selected Cost and Performance Information at Superfund-
fmanced Sites (EPA 542-R-01-021a).
• Phase II (complete), the subject of this report, involved conducting an optimization
evaluation at each of the sites selected in Phase I. The optimization evaluations were
accomplished using the Remediation System Evaluation (RSE) process, which was
developed by the U.S. Army Corps of Engineers as a tool for remedy optimization.
Phase III (ongoing) involves following up with site managers of the evaluated sites
primarily to track the progress toward implementing the recommendations generated
from the RSEs.
1.2 THE RSE PROCESS
The RSE process is a comprehensive, independent expert evaluation of an operating remediation system.
For a P&T system, the RSE team includes one or more senior process engineers and one or more senior
hydrogeologists working with EPA and state RPMs and site contractors. This team evaluates the
following items:
• system goals
site conceptual model
• extraction well network
above-ground treatment system
• groundwater and treatment process monitoring
system effectiveness with respect to protection of human health and the environment
• data management
costs
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The RSE process includes scheduling a site visit, reviewing site data, visiting the site for one to two days,
submitting a draft report for review by the site managers, and finalizing that report considering the
comments from the review. The RSE site visit generally needs to be scheduled a month in advance to
allow for transfer of key site documents to the RSE team for their review prior to the site visit. Once the
site visit is conducted, the draft RSE report is generally submitted in approximately 45 days. The time
frame for finalizing the RSE report depends heavily on the time taken for the site managers to review the
draft report and send comments to the RSE team. The typical cost for an RSE is about $25,000.
During the site visit the RSE team tours the facility and surrounding area and interviews the site
managers, contractors, and key regulators (EPA and State). The RSE report documents the findings and
presents recommendations to improve the remedy. The recommendations typically fall into the following
categories:
• recommendations to improve system effectiveness
• recommendations to reduce life-cycle operation and maintenance (O&M) costs
• recommendations for technical improvement
• recommendations to improve the likelihood of site close out
As a clarification, throughout this project, effectiveness has been defined as the ability of a remedy to
meet its stated objectives of protecting human health and the environment by containing ground water
plumes and eliminating exposure pathways to site-related contamination. The recommendations
obviously have the benefit of the operational data unavailable to the original designers; therefore, a RSE
is viewed as a team effort between the site managers and the RSE team rather than a site audit.
1.3 EVALUATED SITES AND SCHEDULE
This report summarizes the results from RSEs performed at 20 Fund-lead sites with P&T systems. Four
of these RSEs were conducted in Regions 4 and 5 as part of a demonstration project, and 16 RSEs were
subsequently conducted nationwide. Table 1-1 lists the 20 sites where the RSEs were conducted and
provides the dates the RSE visits occurred, the dates the draft RSE reports were submitted, and the dates
the finalized RSE reports were submitted. At the time of the evaluations, some of the evaluated sites were
in a startup mode and others had been operating for approximately 10 years. On average, as of January
2002 the sites had been operating for approximately 4.5 years.
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Table 1-1: Sites where RSEs were conducted as part of the nationwide Fund-lead
pump and treat optimization project
Site Name
Oconomowoc Electroplating
MacGillis and Gibbs
Elmore Waste Disposal
PCX Statesville
Bayou Bonfouca
Midland Products
Savage Municipal Water Supply
Mattiace Petrochemical
Baird and McGuire
Cleburn Street Well
Hellertown Manufacturing
Raymark
Claremont Polychemical
Modesto Groundwater Contam.
Silresim Chemical Corp.
Comm. Bay/S. Tac. Chan., Well 12A
McCormick and Baxter
Ott/Story/Cordova
Brewster Wellfield
Selma Pressure Treating
EPA
Region
5
5
4
4
6
6
1
2
1
7
o
5
o
5
2
9
1
10
10
5
2
9
Date of RSE Site
Visit
3/14/00 - 3/15/00
6/13/00 - 6/14/00
9/19/00 - 9/20/00
9/20/00 - 9/22/00
2/21/01-2/22/01
2/27/01
3/22/01-3/23/01
3/29/01-3/30/01
4/18/01-4/19/01
4/24/01-4/25/01
6/5/01
6/7/01-6/8/01
6/26/01-6/27/01
7/19/01-7/20/01
8/15/01-8/16/01
8/21/01-8/22/01
8/23/01 -8/24/01
9/27/01-9/28/01
10/30/01
11/7/01-11/8/01
Date Draft
RSE Report
was Submitted
5/25/00
9/12/00
12/22/00
12/1/00
3/28/01
4/11/01
4/23/01
5/15/01
6/13/01
6/13/01
7/18/01
7/30/01
8/28/01
9/11/01
10/8/01
10/9/01
10/19/01
11/19/01
12/17/01
12/18/01
Date Final RSE
Report was
Submitted
8/11/00
2/26/01
4/17/01
3/6/02
7/9/01
6/4/01
9/17/01
7/27/01
1/18/02
7/30/01
11/14/01
12/19/01
2/15/01
12/10/01
12/20/01
12/11/01
2/8/02
3/12/02
4/8/02
1/31/02
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2.0 SUMMARY OF RSE FINDINGS AND RECOMMENDATIONS
The detailed RSE report for each site contains the following sections:
an introduction that details the purpose of the visit, the RSE team, the documents
reviewed, persons contacted, site location, history, hydrogeology, etc.
• a description of the remediation system including the extraction and treatment systems
• system objectives, plus performance and closure criteria
• findings and observations from the RSE site visit including system and component
performance, recurring problems, capture zone evaluation, and contaminant delineation
evaluation of the system effectiveness with respect to protection of human health and the
environment for ground water, surface water, air, and soils
• recommendations intended to
• • enhance remedy effectiveness with respect to preventing plume
migration and monitoring other exposure pathways
• • reduce life-cycle O&M costs
• • improve technical operations
• • gain site closeout
• a table summarizing the recommendations, including estimated capital costs and
estimated annual cost increases or decreases associated with each recommendation
The cost estimates provided in the RSE reports have levels of certainty comparable to those done for
CERCLA Feasibility Studies (-307+50%). The observations and recommendations presented in the RSE
reports are not intended to imply a deficiency in the work of either the designers, operators, or site
managers. They are offered as constructive suggestions that have the benefit of an independent review of
operational data that was unavailable to the original designers. In general, system improvements are
merited because site conditions and available technologies have changed since design and installation of
the P&T systems.
Information on how to obtain the report from each of the 20 RSEs are included in the Appendix.
2.1 COMMON THEMES REGARDING EFFECTIVENESS
The RSE team generally found the Fund-lead P&T systems to be operating, regularly meeting treatment
plant discharge levels, and removing contaminant mass from the subsurface. The RSE team did,
however, identify at 17 of the 20 sites recommendations to improve remedy effectiveness (i.e., improve
the ability of a remedy to meet its stated objectives of protecting human health and the environment by
containing ground water plumes and eliminating exposure pathways to site-related contamination). The
recommendations to improve effectiveness predominantly suggested more rigorous evaluation of the
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subsurface portion of the remedy rather than the above-ground treatment portion. In total, the RSE team
estimates that the capital costs for implementing all of these recommendations would be approximately
$1.25 million and the increase in annual O&M costs would be approximately $270,000 per year. The
majority of effectiveness recommendations made by the RSE team fall into three categories, summarized
below.
Improve capture zone analysis and/or plume delineation
The RSE team found that plume containment (or "capture") is not being evaluated sufficiently at 16 of the
20 RSE sites. In addition, a "target capture zone" was typically not specified, further complicating the
evaluation of plume containment. In many cases updated plume maps were not being generated, even
though groundwater monitoring data were routinely collected. At 10 of 20 sites it appeared that the
extent of the plume was not fully delineated and that plume migration toward potential receptors was not
being actively evaluated. A total of 17 sites had issues with either containment or plume delineation.
Conduct additional sampling
At 7 of the 20 sites, the RSE team recommended additional sampling, including air sampling in buildings
for volatile organic compounds (4 of 20 sites), water sampling of drinking wells (2 of 20 sites), and
surface water or sediment sampling (5 of 20 sites). These recommendations were warranted by potential
impacts from site contaminants, in the opinion of the RSE team. In some cases, this sampling may
already be collected by other parties but is not regularly reviewed by site managers.
Improve data collection, interpretation, and/or reporting
At some of the 20 sites the RSE team found that routine O&M reports did not contain sufficient
information or analysis to adequately assess the effectiveness of the system. In some cases key data were
not included in the report (such as water levels), and in other cases the reports were not being produced
and/or reviewed in a timely manner.
2.2 COMMON THEMES REGARDING COST REDUCTION
The RSE team found that the evaluated sites had annual O&M costs ranging from under $100,000 per
year to approximately $3.4 million per year. The total annual O&M cost for these systems is
approximately $13.3 million per year. The RSE team identified cost savings opportunities at 17 of the 20
sites, with the greatest potential cost savings associated with higher cost systems. The estimated capital
cost for implementing all of these recommendations would be approximately $3.5 million; however, the
estimated potential annual cost savings from implementation would be approximately $5.1 million, which
would represent an approximate 38% decrease in annual O&M costs (excluding the costs for
implementing the effectiveness, technical improvement, or site closeout recommendations). The
following six categories represent the most common types of recommendations for cost reduction.
Reduce groundwater or process treatment monitoring
Reducing or eliminating groundwater or process monitoring that is no longer necessary was the most
common recommendation for reducing costs. The RSE team recommended reductions in groundwater or
treatment process monitoring at 9 of the 20 sites. Achieving these reductions would require estimated
capital costs of approximately $30,000 (for piping modifications at one site); however, the combined
annual cost savings from the reductions at the 9 sites would be approximately $800,000 per year.
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Approximately three quarters of this potential annual cost savings stems from a recommendation to
reduce process monitoring at one site.
Replace existing treatment components with more efficient units or technologies
Due to highly conservative estimates of influent concentrations during design or due to changing site
conditions, some treatment components were inefficient given current site conditions. For example, at
one site a thermal oxidizer was installed to destroy contaminants removed from the subsurface. Because
contaminant loading was lower than expected, the thermal oxidizer required excess natural gas to operate
and was inefficient compared to using granular activated carbon with onsite regeneration.
Recommendations to replace existing treatment components with more efficient units or technologies
were made at 7 of the 20 sites. The estimated capital cost for implementing these recommendations is
approximately $1.8 million with estimated potential cost savings of approximately $800,000 per year.
Simplify existing system and/or remove unnecessary treatment components
At 5 of the 20 sites, the RSE team found a treatment plant that was over-designed or had treatment
components that are no longer necessary due to changing site conditions. By simplifying the systems and
removing the components, reductions in material usage, utilities, and labor can potentially result. The
estimated capital cost for implementing these recommendations is approximately $ 1 million; however, the
estimated potential annual costs savings from implementing them is approximately $1.3 million per year.
Consider alternate discharge options for treated groundwater
The RSE team recommended reviewing the discharge criteria or considering alternate discharge options
for the treated water at 5 of the 20 sites. The estimated capital cost for implementing these
recommendations is approximately $54,000, and the estimated potential annual savings is approximately
$175,000 per year.
Reduce labor costs
The RSE team identified 3 of the 20 sites where operator or onsite labor could be reduced without
sacrificing the effectiveness of the remedy. At one of the sites automation is required to achieve this
reduction in labor. The estimated capital cost for implementing these recommendations are
approximately $103,000; however, the estimated potential annual cost savings from implementing these
recommendations would be approximately $1.6 million per year. In addition, many recommendations
that fall into other categories (e.g. removing treatment components that are no longer needed) also result
in reductions in labor and commensurate reductions in cost.
Reduce oversight or project management costs
At 4 of the 20 sites, the RSE team recommended that oversight and/or project management costs be
reduced. However, the potential cost savings for only 2 of those sites were estimated. Reductions in
project management and oversight at these two sites could potentially save approximately $175,000 per
year.
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2.3 COMMON THEMES REGARDING TECHNICAL IMPROVEMENT
In general, the RSE team found most Fund-lead P&T sites well maintained. Recommendations in this
category include repairing or replacing faulty equipment, changing data evaluation protocols,
rehabilitating fouled extraction or injection wells, reformatting reports, modifying sampling protocols,
and other site-specific recommendations to improve overall operations. A total of 63 recommendations
for technical improvement were made at 16 of the 20 evaluated sites received. The RSE team estimates
that implementing these recommendations would require approximately $360,000 in capital costs and an
additional $25,000 in annual O&M costs.
2.4 COMMON THEMES REGARDING SITE CLOSEOUT
The RSE team found it unlikely that any of the evaluated sites would reach closeout or system shutdown
prior to the transfer of the site to the State (which for Fund-lead sites with restoration as a goal occurs 10
years after the system is Operational and Functional). A primary reason is that continuing sources of
dissolved phase groundwater contamination will continue to persist at many sites, most often due to the
presence of non-aqueous phase liquids (NAPLs). Of the 20 evaluated sites, 16 have either direct
evidence, anecdotal evidence, or groundwater concentrations indicating the presence of NAPL. The
science of NAPLs has evolved over time, and the potential presence of NAPL at many of these sites may
not have been adequately recognized during remedy selection and design.
To assist EPA and the States in eventually closing sites, the RSE team identified recommendations
regarding site closeout at 16 of the 20 evaluated sites. At one site, excavation of a remaining source area
is recommended for an estimated capital cost of $500,000. Including this recommendation, the total
capital cost for implementing the recommendations for site closeout at all of the sites is approximately
$775,000 and the estimated increase in annual O&M costs is approximately $35,000 per year. The RSE
team also offered recommendations for consideration of alternative technologies that could replace or
augment the existing P&T system, especially with respect to more aggressive source removal. The costs
and potential life-cycle savings of implementing these technologies were sometimes estimated when
practicable but are not included in the estimated costs provided above. The majority of recommendations
made by the RSE team with regard to site closeout fall into the following two categories.
Develop an exit strategy
An exit strategy consists of outlining the specific requirements for achieving closeout of the remedy or
various components of the remedy. Developing an exit strategy involves establishing realistic cleanup
goals, and it also involves determining the specific data and criteria to be used to evaluate if goals are met
such that some or all of the system can be shut down. An exit strategy involves setting milestones for the
remedy and determining intermediate goals and metrics to measure progress. If the intermediate goals
and milestones are not met, site managers should then consider alternatives to the current system. At 10
of the 20 sites visited, the RSE team made a recommendation that pertains to development of an exit
strategy. The RSE team specifically recommended development of an exit strategy at 4 sites,
establishment or reconsideration of specific cleanup goals at 5 sites, and determining data needs
specifically related to exit strategy at 1 site.
Consider more aggressive source removal or alternate technologies
At 13 of the 20 sites evaluated, the RSE team recommended consideration alternate technologies to
replace pump and treat or to supplement it with more aggressive source removal. Such recommendations
are site specific and range from increased pumping in "hot spot" areas to the potential use of chemical
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oxidation, air sparging, or in-situ thermal remediation. The selection of a particular technology may
depend on commercial or industrial activities at the surface, the geology, the nature and extent of
contamination, the proximity to receptors, and other factors. Because aggressive source removal does not
necessarily improve site conditions to the point of shutting down the operating P&T system (there is some
debate regarding the ability of these technologies to achieve concentrations that allow P&T to be
discontinued), the RSE team encourages the site managers to consider the life-cycle costs of an optimized
P&T system versus the life-cycle costs of the P&T plus the more aggressive source removal alternatives.
Prior to proceeding with a pilot test for an innovative technology, the RSE team encourages the site
managers to consider the scaled-up costs for using the technology site wide (or over the entire source
area). If the cost for implementing the technology at the full scale is impracticable, then the RSE team
generally suggests considering other technologies rather than moving forward with the pilot test.
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3.0 CONCLUSIONS, LESSONS LEARNED, & RECOMMENDATIONS
These optimization evaluations have resulted in an improved understanding of the operating Fund-lead
P&T systems and have identified a number of opportunities for improvements in efficiency and
effectiveness relatively early in the operation of these systems. These opportunities have been conveyed
to the EPA Remedial Project Managers (RPMs) through recommendations highlighted in RSE reports.
The following table provides the predominant RSE recommendation categories and the number of sites
where such recommendations were made.
Table 3-1: Number of RSE Recommendations in each Recommendation Category
Recommendation Category
Improvement in effectiveness
Cost reduction
Technical improvement
Site closeout
Number of Sites where Recommendations
Category were Made
in each
17 of 20 sites
17 of 20 sites
16 of 20 sites
16 of 20 sites
In general, recommendations to improve effectiveness pertained to subsurface issues such as improving
delineation of contaminant plumes and/or better evaluating the capture of those plumes. The
recommendations to reduce costs generally pertained to the above-ground treatment system and included
recommendations such as eliminating treatment components that are no longer necessary and reducing
labor costs. Technical improvement recommendations covered a wide range of items such as repairing or
replacing faulty equipment and rehabilitating fouled extraction wells. Site closeout recommendations
generally involved developing a clearly stated site exit strategy or considering more aggressive source
removal options.
To assist site managers in considering and implementing the recommendations, the RSE team provided
cost estimates where feasible. The following table reports the four recommendation categories and the
total cost estimates for the recommendations in each category.
Table 3-2: Summary of Cost and Cost Savings Estimates by Recommendation Category
Recommendation Category
Improvement in effectiveness
Cost reduction
Technical improvement
Site closeout
Total
Estimated
Capital Cost*
($)
$1.25 million
$3.5 million
$360,000
$775,000
$5.9 million
Estimated Change in Annual
O&M Costs*
($/yr)
$270,000
($5.1 million)
$25,000
$35,000
($4.8 million)
*Cost estimates have levels of certainty comparable to those done for CERCLA Feasibility Studies (-30/+50%)
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Given that the annual O&M costs for these 20 sites is approximately $13.3 million per year,
implementing all of the recommendations would require an estimated 44% increase in spending for one
year but could potentially result in a savings of approximately 36% in annual O&M costs. Therefore, life-
cycle savings would likely be realized within approximately two years of implementing the
recommendations, if all recommendations are implemented. Savings would then accrue by millions of
dollars per year in subsequent years as ground water remedies at Fund-lead sites are typically expected to
operate for more than 30 years.
3.1 LESSONS LEARNED
Some of the lessons learned from this project are listed below:
• EPA Remedial Project Managers (RPMs) generally require additional technical
assistance and guidance (e.g., capture zone analysis, exit strategy, recognizing and
correcting treatment plant over-design, contracting, methods of life-cycle cost
comparisons, etc.)."
The remedial process is dynamic, and system evaluations should be routinely performed
in order to account for variations that occur in site conditions through the process. The
RSE team frequently found that plume delineation and capture zone analyses were last
conducted during system design and had not been updated or evaluated once the system
was operating. In addition, changing influent concentrations to the treatment plant over
time and the development of new technologies for treatment provide opportunities for
future cost savings.
Many sites have continuing sources of NAPL contamination in the subsurface and are
unlikely to reach target clean-up levels over the entire plume with existing remedial
actions. The potential presence of NAPL at many of these sites may not have been
adequately recognized during remedy selection and design; as a result, the cleanup time
estimates stated in the ROD are unrealistically low at some sites.
Many ROD goals are not associated with specific metrics for evaluating progress, which
makes it impossible to determine the success or failure of the remedy.
• RPMs are responsible for managing remedies that are protective of human health and the
environment and, as a result, may not adequately consider the remedy cost-effectiveness.
This may result in remedies with unnecessarily high costs.
• Independent technical evaluations provide more opportunities for improving systems than
evaluations performed by site managers or O&M contractors. Despite efforts by site
managers to evaluate their own performance and optimize their own systems, the RSE
team was able to identify a number of additional opportunities for system improvement.
The outside perspective and combined technical expertise of the RSE team yielded
increased opportunity for developing recommendations to improve operating P&T
systems.
• Oversight costs by EPA contractors are inconsistent and in some cases appear to be
higher than necessary.
• Many recommendations require further engineering analysis to prove feasibility and may
involve additional capital expenditure and time for design and construction.
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3.2 RECOMMENDATIONS To MAXIMIZE THE BENEFITS OF THE RSE
PROCESS FOR FUND-LEAD P&T SYSTEMS
The following recommendations are suggested to maximize the benefits of the RSE process and
potentially scale up the project to all Fund-lead P&T systems:
Follow up on each of the sites evaluated to date, to ensure progress is being made toward
implementing the recommendations, and to track associated costs and savings.
• Develop an ongoing program to track progress and cost/savings associated with
implementation of RSE recommendations in the future, including an approach to resolve
disputes if site managers do not implement RSE recommendations. This should also
include reviewing the actual costs of implementing RSE recommendations versus the
implementation costs estimated in the RSE reports.
• Periodically update the database of Fund-lead P&T systems determined in Phase 1.
• Develop a strategy for selecting sites to receive future RSEs.
• Perform additional RSEs in the future utilizing RSE teams that are independent from the
site managers and their contractors.
Consider performing independent reviews of high-cost remedies during the design phase.
Consider establishing a strategy to identify and address sites with continuing sources of
ground-water contamination (e.g., non-aqueous phase liquids) before transfer to the
states.
Develop guidance and training opportunities on technical deficiencies discovered during
RSEs conducted to date (e.g., effective overall management of pump and treat systems,
capture zone analysis, etc.).
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4.0 PRELIMINARY FINDINGS FROM PHASE III
In Phase III of the Nationwide Fund-lead P&T Optimization Project, EPA OERR and the RSE team
followup with the site managers on the RSE reports that were generated during Phase II and have been
summarized in this report. OERR has the following primary objectives for Phase III:
• note the progress made toward implementing RSE recommendations
• communicate with RPMs to determine and assess ongoing challenges at the sites
• provide further technical assistance or clarification to the RPMs with respect to RSE
recommendations
provide further regulatory assistance or clarification to the RPMs with respect to
Superfund policy and Headquarter's current areas of focus
• determine the effectiveness of the RSE process from the perspective of the RPMs
• for each site, determine an appropriate time for the next follow up call
Phase III of the Nationwide Fund-lead P&T Optimization project has begun with promising results.
Initial follow up conference calls have been conducted for all 20 of the sites, and progress on
approximately 230 recommendations has been discussed. Of those recommendations, approximately 20
will not be further pursued by the Regions for various technical reasons. Table 4-1 summarizes the
progress made toward implementing the remaining approximate 210 recommendations in four categories.
Table 4-1 Summary of Progress Made Toward Implementing RSE Recommendations that will be
Pursued by the Regions
Recommendation Category
Effectiveness/Protectiveness
Cost Reduction
Technical Improvement
Site Closeout
Approximate number
of recommendations
that will be pursued by
the Regions
65
63
56
24
Percentage of
recommendations
where implementation
is in progress
40%
29%
13%
33%
Percentage of
recommendations
where implementation
is complete
20%
13%
52%
0%
Based on these followup calls, EPA Regions are currently implementing recommendations that will lead
to enhanced effectiveness and annual O&M cost savings of over $2 million per year. Additional
information regarding the anticipated time frames for implementation and resulting changes in O&M
costs will be discussed in a summary report for Phase III of this project.
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APPENDIX:
REMEDIATION SYSTEM EVALUATION (RSE) REPORTS FOR 20
FUND-LEAD SITES WITH PUMP AND TREAT SYSTEMS
Reports from each of the 20 RSEs are available on-line at www.epa.gov/tio and www.cluin.org/rse.
Report titles and document numbers are listed below.
RSE Report Name
Remediation System Evaluation, Oconomowoc Electroplating Superfund Site
Remediation System Evaluation, MacGillis and Gibbs Superfund Site
Remediation System Evaluation, Elmore Waste Disposal Superfund Site
Remediation System Evaluation, PCX Statesville Superfund Site
Remediation System Evaluation , Bayou Bonfouca Superfund Site
Remediation System Evaluation, Midland Products Superfund Site
Remediation System Evaluation, Savage Municipal Water Supply Superfund Site
Remediation System Evaluation, Mattiace Petrochemical Superfund Site
Remediation System Evaluation, Baird and McGuire Superfund Site
Remediation System Evaluation, Cleburn Street Well Superfund Site
Remediation System Evaluation, Hellertown Manufacturing Superfund Site
Remediation System Evaluation, Raymark Superfund Site
Remediation System Evaluation, Claremont Polychemical Superfund Site
Remediation System Evaluation, Modesto Groundwater Contamination Superfund
Site
Remediation System Evaluation, Silresim Chemical Corp. Superfund Site
Remediation System Evaluation, Comm. Bay/South Tacoma Channel, Well 12A
Superfund Site
Remediation System Evaluation, McCormick and Baxter Superfund Site
Remediation System Evaluation, Ott/Story /Cordova Superfund Site
Remediation System Evaluation, Brewster Wellfield Superfund Site
Remediation System Evaluation, Selma Pressure Treating Superfund Site
EPA Document Number
EPA 542-R-02-008b
EPA 542-R-02-008C
EPA 542-R-02-008d
EPA 542-R-02-008e
EPA 542-R-02-008f
EPA 542-R-02-008g
EPA 542-R-02-008h
EPA 542-R-02-008i
EPA 542-R-02-008J
EPA 542-R-02-008k
EPA 542-R-02-0081
EPA 542-R-02-008m
EPA 542-R-02-008n
EPA 542-R-02-008o
EPA 542-R-02-008p
EPA 542-R-02-008q
EPA 542-R-02-008r
EPA 542-R-02-008s
EPA 542-R-02-008t
EPA 542-R-02-008u
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