Optimization Strategies for Long-Term
Ground Water Remedies
(with Particular Emphasis on Pump and Treat Systems)
REMEDY
OPTIMIZATION
US Army Corps %
of Engineers . t
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Office of Solid Waste EPA 542-R-07-007
and Emergency Response (5203P) May 2007
www.cluin.org
www.epa.gov/superfund
Optimization Strategies for Long-Term
Ground Water Remedies
(with Particular Emphasis on Pump and Treat Systems)
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DISCLAIMER
This document provides references to models and processes in use by outside parties and other Federal
Agencies. Mention of these models and processes does not imply endorsement for specific purposes.
This fact sheet is not intended to be a detailed instruction manual. In addition, this fact sheet is not a
regulation; therefore, it does not impose legally binding requirements on EPA, States, or the regulated
community, and may not apply to a particular situation based upon the circumstances. The document
offers technical information to EPA, states and others who manage or regulate long-term ground water
remedies as part of any cleanup program. EPA and State personnel may use other approaches, activities
and considerations, either on their own or at the suggestion of interested parties. Interested parties are
free to raise questions and objections regarding this document and the appropriateness of using these
recommendations in a particular situation, and EPA will consider whether or not the recommendations are
appropriate in that situation. This fact sheet may be revised periodically without public notice. EPA
welcomes public comments on this document at any time and will consider those comments in any future
revision of this document.
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PREFACE
This fact sheet discusses the principles and techniques for optimizing long-term ground water remedies,
with particular emphasis on optimizing pump and treat (P&T) systems. It is part of a series of fact sheets
that the EPA Office of Superfund Remediation and Technology Innovation (OSRTI) is preparing to assist
the ground water remediation community to effectively and efficiently design and operate long-term
ground water remedies. This series is available at www.cliiin.org/optimization and consists of the
following fact sheets, plus others that will be available in the future.
• Elements for Effective Management of Operating Pump and Treat Systems
OSWER 9355*4-27FS-A, EPA 542-R-02-009, December 2002
• Cost-Effective Design of Pump and Treat Systems
OSWER 9283.1-20FS, EPA 542-R-05-008', April 2005
• Effective Contracting Approaches for Operating Pump and Treat Systems
OSWER 9283.1-21FS, EPA 542-R-05-009, April 2005
• O&M Report Template for Ground Water Remedies (with Emphasis on Pump and
Treat Systems)
OSWER 9283.1-22FS, EPA 542-R-05-010, April 2005
• A Cost Comparison Framework for Use in Optimizing Ground
Water Pump and Treat Systems, EPA 542-R-07-005, May 2007
• Options for Discharging Treated Water from Pump and Treat
Systems, EPA 542-R-07-006, May 2007
The ideas contained in this series of fact sheets are based on professional experience in designing and
operating long-term ground water remedies and on lessons learned from conducting optimization
evaluations called Remediation System Evaluations (RSEs) at sites with P&T systems. RSEs have been
conducted at Superfund-financed sites. Resource Conservation and Recovery Act (RCRA) sites, and
leaking underground storage tanks sites. Reports from RSEs conducted by EPA are available at
www.cluin.org/optimization.
The content of these fact sheets is relevant to almost any long-term ground water remedy, particularly
those that involve P&T. Therefore, these documents may serve as resources for managers, contractors, or
regulators of any P&T system, regardless of the regulatory program.
Access to a wider range of EPA documents is available at vvvvw.cluin.org.
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TABLE OF CONTENTS
A. INTRODUCTION
B. BENEFITS OF OPTIMIZATION....
C. COMPONENTS OF A TYPICAL
OPTIMIZATION EVALUATION.
D. OPTIMIZATION APPROACHES
DEVELOPED AND USED BY THE
FEDERAL AGENCIES
E. COMPONENTS OF AN OPTIMIZATION
PROGRAM
F. TOOLS TO SUPPORT OPTIMIZATION.
G. SUMMARY
H. REFERENCES
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12
14
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APPENDIX A: EXAMPLE DOCUMENT
"AN INTRODUCTION TO RSES AND RSE-
LITES"
APPENDIX B: EXAMPLE DOCUMENT
"FORM TO SUBMIT INFORMATION FOR
OPTIMIZATION"
A. INTRODUCTION
Federal agencies have conducted optimization
evaluations at approximately 100 operating pump
and treat (P&T) systems since 2000 and have
successfully identified hundreds of opportunities for
improving effectiveness in protecting human health,
reducing remedy life-cycle cost, and speeding
progress toward site closure. The widespread use of
optimization at operating ground water remedies by
Federal agencies and the identification of these
opportunities suggests value in communicating
optimization to a broader environmental community.
This fact sheet has been prepared to assist
environmental case managers from Federal and State
agencies, environmental program managers from
private organizations, and environmental contractors
with optimization of operating long-term ground
water remedies, particularly those that involve pump
and treat. It discusses the benefits of optimization,
components of atypical optimization evaluation, and
components of an optimization program that utilizes
such evaluations. Specific optimization evaluation
processes that have been implemented by various
Federal agencies are highlighted.
For the purpose of this document, "optimization"
refers to efforts associated with improving a
remedy's effectiveness in protecting human health
and the environment, improving efficiency (i.e.,
improving cost-effectiveness while maintaining the
same or higher level of effectiveness), and speeding
progress toward site closure. Similarly, an
"optimization evaluation" refers to an evaluation
conducted by an independent party (i.e., a party not
associated with historical site activities and current
operation) on a remedy with the purpose of
identifying opportunities for improving remedy
effectiveness, improving efficiency, and speeding
progress toward site closure. Although independent
reviews of other phases of work such as remedial
investigations and remedial designs also provide for
greatly improved remedies, this fact sheet focuses
specifically on optimization of operating remedies.
A reference section is included at the end of this
document to direct readers to additional sources of
information on optimization and the concepts
discussed in this document.
B. BENEFITS OF OPTIMIZATION
The 2004 Edition of EPA's Cleaning up the
Nation 's Waste Sites: Markets and Technology
Trends (U.S. EPA, 2004b) indicates that P&T has
been selected as a remedy at 67% of the sites on the
National Priorities List (NPL) with ground water
contamination. This translates to over 700 NPL sites
with P&T systems, of which approximately 90 are
owned and operated by EPA (U.S. EPA, 2001,
2002a). P&T is also used as a ground water remedy
at sites in other cleanup programs. For example, the
same document reports that a study of a subset of
186 RCRA sites indicated that 133 of those sites
involved treatment of ground water contamination
and 116 of those 133 (87%) used P&T. With
approximately 2,000 RCRA sites with ground water
contamination, the number of RCRA sites with P&T
is likely several times higher than 116. Given the
potential receptors near many of these sites, the
relatively high recurring costs associated with
operating these remedies, and the many additional
sites with P&T that are part of other State and
Federal cleanup programs, identifying opportunities
to improve effectiveness, efficiency, and progress
toward site closure is of paramount importance.
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Potential opportunities for improvement identified in
optimization evaluations do not imply a deficiency
in the work of the system designers, system
operators, or site managers. Rather, they generally
result from analysis of operational data unavailable
to the original designers, from site conditions that
have changed overtime, and/or from improved
knowledge of ground water and remediation
technology. The following are examples of potential
opportunities for improvement that illustrate the
various benefits of optimization.
Example of Potential Opportunities to Improve
Effectiveness in Protecting Human Health and the
Environment
A site impacted with chlorinated volatile organic
compounds had an operating P&T system that was
designed to provide hydraulic containment of the
contaminant plume and prevent the migration of
contaminants to downgradient receptors. Although
the system design included a detailed capture zone
analysis using a ground water flow model, the
validity of this model and the design had not been
verified by analyzing data during operation of the
P&T system. The optimization evaluation team
discussed the target capture zone with the site team
and identified existing data that could be used to
interpret actual capture. As part of the evaluation, a
preliminary capture zone analysis was conducted,
illustrating that the degree of capture was uncertain
and likely less than indicated in the design, primarily
due to lower than expected recovery from the
extraction wells. The optimization team suggested a
well rehabilitation program to improve the well
yields and a reevaluation of capture after the yields
improve. In the event that sufficient improvement in
the well yields is not evident, the optimization
evaluation team suggested locations for additional
extraction wells that would likely provide adequate
capture without exceeding the capacity of the
treatment system.
Example of a Potential Opportunity to Improve
Efficiency
A former wood treating facility had both a pilot and
full-scale P&T system operating to contain a
contaminant plume and remove non-aqueous phase
liquid. The two systems had identical treatment
components, but the full-scale system had 50 times
the treatment capacity. The optimization evaluation
suggested discontinuing operation of the pilot
system, piping all extracted water to the full-scale
system, and simplifying the full-scale system. By
implementing the recommendation, the site team
was able to eliminate the extra costs associated with
operating a parallel treatment system. In addition,
because the bioreactor in the treatment train reliably-
met discharge standards, the site team was able to
discontinue treatment of the bioreactor effluent with
granular activated carbon (GAC) and eliminate the
costs associated with frequent GAC replacements.
The full-scale system without the granular activated
carbon has effectively treated all extracted water and
has continued to meet discharge requirements,
indicating that this cost-reducing measure has
maintained an equal level of effectiveness. Savings
of over $100,000 per year likely will be realized.
Example of a Potential Opportunity to Speed
Progress toward Site Closure
A P&T system had been operating at a site for
approximately 10 years. It had been effectively
containing site-related contamination and reducing
contaminant concentrations. Concentrations in all
site monitoring wells had decreased below cleanup
standards, but concentrations had consistently
remained approximately one order of magnitude
above standards in the extraction well located near
the historic source area. An optimization evaluation
suggested a limited investigation of the historic
source, an air sparging pilot test, and establishing
criteria that, if achieved, would allow active
remediation to be discontinued. The investigation
indicated limited soil contamination in the saturated
and unsaturated soil, and the designed pilot air
sparging system will likely fully address the
remaining contamination. Addressing this source
area may now allow discontinuation of all site-
related active remediation in less than six months;
whereas continued P&T was forecasted to continue
for up to 10 more years.
C. COMPONENTS OF A TYPICAL
OPTIMIZATION EVALUATION
A number of approaches have been developed
within the Federal government and private sector to
implement optimization evaluations that are
consistent with the definition provided in the
introduction of this fact sheet. Some of these
approaches are described in Section D, and although
each approach implements an optimization
evaluation in a different manner, these approaches
generally share common components, including the
following:
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evaluation team development
• scheduling and logistics
• document review
• site visit and interviews
• data analysis and draft report preparation
site team review
report finalization
This section describes these various common
components of optimization evaluations employed
by EPA and other Federal agencies.
Evaluation Team Development
An optimization evaluation team is comprised of
experts in various fields who are independent of
current site activities. This independence allows the
team members to bring a fresh perspective to the site
and to analyze data and provide recommendations
without bias. The evaluation team therefore will not
benefit from recommendations that result in more
work for the site team or will not lose work or
revenue from recommendations that result in a lower
level of effort. The evaluation team is generally-
comprised of experts, or has immediate access to
experts, in the following fields:
• environmental policy and regulations
hydrogeology
• environmental engineering
• risk assessment
contracting
• chemistry (including geochemistry)
• health and safety
cost estimating
• biology
In some cases, a single team member may have
expertise in multiple categories. The size of the
team depends on the optimization evaluation
approach that is being used. A team may consist of
as few as two individuals with different areas of
expertise and immediate access to other individuals
that have expertise in the remaining areas.
The team members often are directly responsible for
conducting the site interviews and preparing the
optimization evaluation report. Therefore, these
individuals often have strong communication and
critical thinking skills that allow them to
communicate their questions effectively during site
interviews and to communicate their findings and
recommendations effectively in the report.
Scheduling and Logistics
An optimization evaluation generally takes several
months from initial contact to a final optimization
evaluation report. A time frame for typical
evaluation is presented in Exhibit 1. The process
begins with initial contact between a representative
of the evaluation team and the project manager for
the site to be evaluated. During this initial contact
the evaluation team representative provides
background on the evaluation process, and often
provides a short document with the following
information:
Exhibit 1
Time Frame for a Typical Optimization Evaluation
Weekl
Weeks 1-3
Week3
Weeks 3-4
WeekS
Weeks 5-10
Weeks 10-13
Weeks 13-16
Initial contact and scheduling
Site team gathers documents for evaluation team
Evaluation team receives documents from site team
Evaluation team reviews documents
Evaluation team visits site and/or conducts interviews of site team
Evaluation team analyzes site information and generates draft
report
Site team reviews draft report and provides feedback
Evaluation team finalizes report based on comments from site
team
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background on the evaluation process
Document Review
• a typical site visit agenda (Exhibit 2)
the types of documents that the evaluation team
typically reviews (Exhibit 3)
• expected format of the final optimization
evaluation report
An example of such an introductory document is
provided as Appendix A.
An information sheet to be completed by the project
manager can also be provided during this initial
contact. The project manager can use this sheet to
provide general background about the site, describe
particular issues that may be a focus for the
evaluation team, indicate recent upgrades or
modifications that may not be described in the site
documents, and provide a breakdown of operations
and maintenance (O&M) costs. An example of a
site information sheet is provided as Appendix B.
Together, the site project manager and the evaluation
team leader determine the site documents that will
be transferred to the evaluation team for review,
which site stakeholders will participate in the
evaluation process, and the date and time for the site
visit and interviews. Exhibit 4 indicates the site
stakeholders that typically attend optimization
evaluations. The site project manager generally
takes the responsibility for coordinating the
schedules of the other site stakeholders, informing
them of the evaluation, and often providing the
introductory document to each of mem.
Once the evaluation team acquires the relevant site
documents, they review the documents to become
familiar with the site and generate questions to be
answered during a site visit and/or site interviews.
Exhibit 5 provides a list of topics that the evaluation
team might consider during the document review.
Site Visit and Interviews
Most optimization evaluations include a site visit
where the evaluation team tours the operating
remedy. The duration of the visit depends on the
size and complexity of the site and the specific
remedy that is being evaluated. It also depends on
the optimization evaluation process. In general, the
length of a site visit will increase with the number of
participants and the detail of the evaluation. For
most sites, a site visit of one to two days in length is
often sufficient.
Generally, the site stakeholders indicated in Exhibit
4 are present and are interviewed by the evaluation
team during the site visit. The interviews generally
take the form of a large discussion group led by the
evaluation team, and during the tour of the remedy,
the evaluation team often has the opportunity to
interview individual site stakeholders directly. For
some sites, the optimization evaluation may include
a conference call rather than a site visit. The
determination as to whether an evaluation should
include a site visit is often made at the programmatic
level and is discussed further in Section D.
Exhibit 2
Typical Agenda for a One-Day* Site Visit for an Optimization Evaluation of a P&T System
Morning Discussioa Typically, an evaluation site visit begins at the site in the morning with a discussion of the site
history, remedy objectives, site conceptual model, contractor's scope of work, significant milestones reached at the site, and
significant changes in approach or strategy taken at the site. During this time participants refer to site documents, site maps,
and monitoring results.
Afternoon Discussion. Upon returning from lunch, the site project manager, contractor, and plant operator leads a tour of
the site and the ground water treatment plant where the evaluation team asks detailed questions regarding specific elements
of the remedy and their performance. After the site tour, discussions are held to determine a rough breakdown of site-
related costs. Potential options for either augmenting or replacing the current remedy are also discussed.
Debriefing. The discussion on costs typically ends in the late afternoon and a general debriefing session follows before the
group disbands for the day.
* Site visit duration can he extended, if necessary.
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Exhibit 3
Types of Documents Typically Reviewed by the
Optimization Evaluation Team
Remedial Investigation Report (in some cases)
Decision documents
- Superfund Record of Decision (ROD)
Superfund Explanation of Significant
Differences (BSD)
- RCRA Permit
- Consent or unilateral order
Design documents and O&M manual
Recent O&M reports (weekly, monthly, etc.)
Recent semi-annual and annual reports with current
and historical sampling data
Previous evaluations or reviews (including previous
optimization reviews or Five-Year Reviews)
Any other reports or documents the site managers
feel are pertinent to the site
Breakdown of annual O&M costs
The site interviews (whether part of a site visit or a
conference call) involve many questions, and it is
important that the questions are not posed in a
manner that suggests criticism. The site interviews
are meant as an information-gathering tool for
evaluation and not to pass judgment on previous or
current activities. At the onset of the site visit and/or
interviews, the evaluation team may provide an
introduction to prepare the site team for questions.
For larger, more complicated sites, the evaluation
team may ask questions that are related to the entire
site rather than just the remedy that has been
selected for evaluation. For example, although a
P&T system at a site might be designed to address
ground water contamination, the evaluation team
might ask questions relating to current or past soil
remediation measures. Although the focus of the
evaluation may be the P&T system, impacted soil
could affect the performance of a P&T system. The
flexibility to look beyond the evaluated remedy to
other components of the site generally allows the
evaluation team to provide recommendations that are
more appropriate both for the evaluated remedy and
for the site as a whole.
During the site visit and/or site interviews, it is
common for the evaluation team to identify
additional information or site documents mat would
be helpful in developing recommendations. An
evaluation team representative and the project
manager may communicate after the visit to
coordinate the transfer of this additional information
to the evaluation team.
The site visit and/or interviews will generally
conclude with coordinating the transfer of this
additional information and a debriefing from the
evaluation team. Often, the evaluation team will
provide preliminary thoughts on its findings and
likely recommendations. However, it is emphasized
that the thoughts are preliminary and, upon further
evaluation, may change.
Exhibit 4
Site Stakeholders that Typically Participate in an
Optimization Evaluation
• Facility project manager (if any)
• Federal regulatory case manager and technical
support staff (if any)
• State or local regulatory case manager and technical
support staff (if any)
Organization's optimization liaison (if any)
Site contractor project manager
Site contractor technical lead
One or more representatives of organization's
management
• Remedy operator (particularly for complex systems)
Data Analysis and Draft Report Preparation
Following the site visit and/or interviews, the
evaluation team performs various technical analyses
to evaluate performance and alternatives to the
current site operations, equipment, or remediation
technology. These analyses generally begin with a
detailed look at the site conceptual model to verify
its validity and determine if there are any data gaps
that should be addressed. Other analyses are site-
specific and might include (but are not limited to)
the following:
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evaluation of vertical and horizontal plume
delineation
preliminary evaluation of plume capture,
including identification of a target capture zone
and interpreting capture using a simple water
budget, potentiometric surface maps, water level
pairs, concentration trends in downgradient
wells, or previously conducted ground water
modeling results
• review of historical monitoring data, the current
monitoring program, and the potential for
changing sample locations, frequency, sampling
technique, or target parameters
• comparison of design influent concentrations
and flow rate to actual influent concentrations
and flow rate
• comparison of actual treatment effectiveness and
cost relative to design estimates
• comparison of actual treatment effectiveness and
cost relative to that of other potential remedial
technologies
• evaluation of O&M costs and level of effort for
the subject site compared to O&M costs and
level of effort for similar sites
• evaluation of remedy performance against
remedy objectives and expectations
consideration of an "exit strategy" for the
remedy and potential transition remedies that
may occur between discontinuation of the
current remedy and eventual site closure
The draft report is compiled within a set time frame
and can vary in length and detail depending on the
parameters of the organization's optimization
program. Exhibit 6 provides a common format for a
detailed optimization report (perhaps 30 to 40 pages)
and indicates how a more streamlined optimization
report (perhaps 5 to 7 pages) would differ. As is
evident from Exhibit 6, the recommendations are
often categorized into the following groups:
recommendations to enhance effectiveness in
protecting human health and the environment
recommendations to reduce life-cycle costs
while maintaining or improving remedy
effectiveness
Exhibit 5
Topics Typically Considered by the Evaluation
Team During Document Review and Site
Interviews
Site conceptual model
• Contaminant sources, fate, and transport
• Hydrogeologic framework
• Adequacy of existing site characterization
Previous and current remedies
Remedy goals
Protectiveness
• Receptors and exposure pathways
• Receptor sampling
• Plume capture
• Performance monitoring
• Institutional controls
• Site fencing, health and safety, etc.
Extraction/Injection Systems
• Confirmation of components and specifications
• Performance relative to design specifications
• Associated sampling and analysis
• Maintenance, fouling, etc.
Treatment System
Confirmation of components and specifications
Performance relative to design specifications
Downtime
Operator responsibilities and level of effort
Chemicals and material usage
• Utilities
• Process monitoring
• Water discharge and waste disposal
• Exceedances and accidental releases
• Recurring technical problems
• Opportunities for system simplification
Costs
Confirmation and clarification of O&M costs
Estimation of life-cycle costs
Actual costs vs. original cost estimates
• Primary cost drivers
• Opportunities for reducing cost, and challenges in
implementing those opportunities
Site closure
Potential alternative remedies
Remaining source removal/control needs
Exit strategy for system and system components
• Site-specific milestones towards site closure
• Legal and programmatic considerations
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• recommendations for technical improvement
• recommendations to speed site closure
Estimates of capital costs and changes to annual
costs are provided for each recommendation. The
evaluation team generally prepares the draft report
within 30 to 45 days of the site visit unless
preparation was delayed by the transfer of additional
material to the evaluation team after the site visit.
Site Team Revie\v
The review of the draft report is generally
coordinated through the site project manager, and
the evaluation team encourages the project manager
to share the report with those who participated in the
evaluation process (including the site contractor) and
Exhibit 6
Common Formats for Full-Scale and
Streamlined Optimization Evaluation
Reports
Introduction. Details the purpose of the visit, the
evaluation team members, other participants, documents
reviewed, site location, history, major features,
hydrogeology, plume extent, etc.
Description of the Remediation System. Describes the
major components of the remedy, such as the extraction
and treatment systems
System Objectives, Performance and Closure Criteria.
Includes a summary of the remedial action objectives for
site and associated cleanup and discharge standards
Findings and Observations. Includes system and
component performance, recurring problems, capture
zone evaluation, contaminant delineation, and
concentration trends
Evaluation of the System Effectiveness. Evaluates
treatment of ground water, surface water, air, and soils
Recommendations. Includes recommendations to
improve remedy effectiveness, reduce life-cycle costs,
improve technical operations, and speed progress toward
site closure (includes a summary of the estimated costs
and cost savings associated with each recommendation)
A streamlined evaluation report typically includes a
brief introduction and then focuses on findings and
recommendations. A streamlined report generally relies
on other existing site documents to provide background
information.
perhaps others. Each reviewer generally provides
their comments in writing, and the project manager
compiles these comments into one comprehensive
set for the evaluation team, ideally within 30 days of
receiving the draft report. It is expected that if there
are any questions or concerns regarding the
recommendations made in the draft report that they
are clearly documented in the reviewer's comments
so that the evaluation team can reconsider the
recommendation. Exhibit 7 provides a list of items
to consider when reviewing a draft optimization
evaluation report before it is finalized.
Final Report Preparation
Upon receiving one comprehensive set of comments,
the evaluation team finalizes the report and provides
a response to comments. During this process, the
evaluation team addresses the concerns of the
reviewers. However, because it is an independent
evaluation, the evaluation team does not
compromise its professional integrity to meet the
concerns of the reviewers. If any of the reviewers'
comments are not implemented, a response-to-
comments document is used to document the
reasons. Generally, if the optimization evaluation
report is written clearly and professionally, and the
site team is committed to optimizing the remedy,
then there are few concerns that are not addressed in
the final report. However, in the rare instances
where concerns are not easily addressed, a solution
can often be provided by an organization's
management, especially if a representative of
management has been participating in the
optimization process.
D. OPTIMIZATION APPROACHES
DEVELOPED AND USED BY THE FEDERAL
AGENCIES
Remediation System Evaluations (RSEs)
The U.S. Army Corps of Engineers Hazardous,
Toxic, and Radioactive Waste Center of Expertise
(HTRW CX) developed the RSE process for
evaluating remedies that are owned and operated by
the Army. As part of this development, a series of
checklists were prepared to assist RSE teams. The
checklists are available electronically (USAGE,
2005).
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The U.S. EPA has adopted the process for use in its
nationwide program for optimization of Superfund-
financed long-term remedies. An RSE team
typically includes three or four experts and a one to
two day site visit. An RSE report is typically 30 to
40 pages in length and provides site background,
findings from the RSE process, and optimization
Exhibit 7
Items to Consider when Reviewing a Draft
Optimization Evaluation Report Prior to
Finalizing the Report
Is the background information provided in the report
factual/accurate? Does the document provide
adequate background for the reader (full-scale report)
or does it adequately reference existing documents
for background (streamlined report)?
Are all of the evaluation participants mentioned?
Does the report indicate the documents that were
reviewed? Were the appropriate documents provided
to the evaluation team?
Does the report demonstrate that the optimization
evaluation team gained a superior understanding of
the remedy and site/facility conditions that directly
affect the remedy? Are the recommendations
appropriate for the remedy?
Do you agree with the recommendations? If not, do
you disagree with the spirit of the recommendations
or specific details?
Are the recommendations clearly written and
understandable? Would additional clarification be
helpful?
Do you generally agree with the approximate cost
estimates provided with the recommendation? Are
there site-specific costs or considerations that have
not been included?
Is there wording that may be misinterpreted by the
general public or those unfamiliar with the site that
should be changed?
Did you share this draft report with relevant site
stakeholders for their review? Do you agree with
their feedback?
Does the report clearly state that the findings and
recommendations are the opinion of the evaluation
team and are not legally binding requirements?
recommendations. A typical RSE report is consistent
with the description in Exhibit 6. In 2007, the cost
for an RSE was $25,000 to $30,000, excluding the
costs for the site project manager and contractor to
provide information and attend the site visit.
EPA has also piloted the RSE process at leaking
underground storage tank sites and Resource
Conservation and Recovery Act (RCRA) Corrective
Action sites. For more information on EPA's
application of the RSE process, visit the following
website: http://v. ww.cluin.org/optimization.
Streamlined Remediation System Evaluations
(SRSEs or "RSE-lites")
To streamline the optimization process and reduce
the cost for optimization evaluations at some sites,
EPA developed the RSE-lite process. This process
is similar to the RSE process but uses a conference
call for site interviews rather man a site visit.
Typically, two experts, rather than three, form the
optimization evaluation team, and either a full RSE
report or a streamlined report can be prepared. The
streamlined RSE report does not include the
background sections. Rather, it is approximately
five to seven pages in length and focuses on findings
and recommendations from the evaluation. The cost
for an RSE-lite depends on the complexity of the site
and reporting. It can range from $10,000 to $15,000
(2007 dollars), excluding the costs for the site
project manager and contractor to provide
information and attend the site visit. An RSE-lite
can be converted into a full-scale RSE if further
analysis is needed and funding is provided. EPA has
piloted the use of the RSE-lite at Superfund-
financed, leaking underground storage tank, and
RCRA Corrective Action sites.
Remedial Process Optimization (RPO) Evaluations
The Air Force Center for Environmental Excellence
developed the Remedial Process Optimization
(RPO) approach as a systematic way to assure that
remedial actions are focused on the appropriate
goals and are periodically evaluated for performance
and cost. The RPO process advocates annual limited
Phase I RPO reviews of performance and cost data
by the site manager (with oversight from a
supervisor) as a means of screening sites for
optimization evaluations. If needed based on Phase
I results, more intense Phase II evaluations are
conducted by an independent team of experts. The
Phase II process includes the identification of
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alternatives to improve performance and possible
proposal of alternative remedial goals. The RPO
team typically involves approximately 10 experts
visiting a site for more than a week and authoring
the report while on the site. Substantial data
analysis is conducted and the resulting report can be
hundreds of pages in length, including appendices.
An RPO Phase II typically addresses several
operating units (e.g., remedies) on a particular site,
and the cost may exceed $100,000 (2007 costs,
excluding the costs of the site team). For more
information, refer to the Air Force RPO Handbook
(AFCEE/ERT and DLA, 2001).
Navy Guidance for Optimizing Remedial Action
Operation (RAO)
The Navy has prepared guidance on the periodic
optimization of remedial actions. The optimization
evaluation is scheduled considering the need for
submitting funding requests and for meeting
requirements under CERCLA or RCRA. The
guidance suggests annual reviews of the systems and
the involvement of the regulatory agencies. A
particular team composition and schedule are not
provided; rather, a seven-step process that ranges
from reviewing remedial objectives to preparing a
report and implementing an optimization strategy is
described. More information can be obtained from
the Guidance for Optimizing Remedial Action
Operation (NFESC, 2001).
Other Initiatives
A number of private sector organizations have
developed optimization evaluation processes to
evaluate their own remedies or as a service to others.
However, it is beyond the scope of this document to
describe these private sector initiatives.
E. COMPONENTS OF AN OPTIMIZATION
PROGRAM
Optimization evaluations are generally implemented
as part of an organization's overall optimization
program. To be effective, an optimization program
generally considers the following:
• program documentation and communication
updated database of cost and technical
information for each site within the organization
site selection for optimization evaluations
• selection of an optimization team and/or
contractor
timing and integration of optimization
evaluations with respect to other organization
practices
• defined optimization evaluation process
• follow-up of optimization evaluations and
tracking of progress toward considering and
implementing recommendations
• involvement of management
• funding for implementation of recommendations
This section describes each of these considerations.
For an example of an optimization program, the
reader is directed to the U.S. EPA Action Plan for
Ground Water Remedy Optimization, OSWER
9283.1-25 (U.S. EPA, 2004a), which describes how
the U.S. EPA is implementing its own optimization
program.
Program Documentation and Communication
Effective optimization programs are well-
documented and have been communicated to all
relevant staff within the organization as well as any
interested stakeholders (as applicable). There is
generally a memorandum or report that outlines the
components and expectations of the program. This
memorandum is generally distributed and a central
repository (perhaps a webpage) is established where
the memorandum and supporting documents are
readily accessible. In addition, a central point of
contact for the program is established and there are
liaisons or intermediate points of contact for each of
the various divisions within the organization that
might be participating. The central point of contact
and the liaisons are instrumental in selecting sites to
receive evaluations, scheduling and overseeing
evaluations, assisting with policy issues, and
tracking optimization progress for the program.
Updated Database of Cost and Technical
Information for Each Site within the Organization
To implement the optimization program, it is helpful
to have a database of site information that allows
optimization program directors to determine the
universe of sites within the organization.
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Establishing a baseline of information for each of the
sites helps program directors allocate optimization
resources to high priority sites, and updating it
routinely helps with tracking results from the
optimization program. The information sheet in
Appendix B includes much of the information that
might be included in the database.
Site Selection for Optimization Evaluations
For organizations with a large number of sites,
resources (both time and funding) may be limited to
address all sites in a timely manner. As a result, it is
helpful to prioritize the sites in terms of potential
benefit from optimization. Often, high priority sites
include those that have high life-cycle costs and
those that have concerns with respect to protecting
human health and the environment. The
presumption is that the cost savings or performance
improvements justify the investment in the
optimization evaluation. If there are concerns
regarding protecting human health and the
environment, the cost of the remedy is generally a
secondary consideration.
The following types of sites are often good
candidates for optimization evaluation, and
consideration of these site types may help an
organization determine which sites are the highest
priorities for evaluation:
• sites where there are known or suspected
shortcomings with respect to protection of
human health and the environment
sites where annual O&M costs exceed the cost
of the evaluation by an order of magnitude
• sites where a remedy has stagnated or has not
performed to expectations and additional
measures are required
• sites where there is disagreement between the
regulator and the facility with regard to a
remedial approach
• sites where a new or modified remedial
approach is being considered
• sites that will likely be divested or transferred to
another party and either party would like an
independent perspective of the site
sites where further analysis is preferable before
determining a budget for future expenses or
financial assurance
Some organizations may choose to implement two
types of optimization evaluations: a full-scale,
detailed evaluation for the more complex sites (with
respect to either cost or effectiveness) and a
streamlined, lower-cost evaluation for the more
straightforward sites. The determination of whether
or not a site receives a full-scale or a streamlined
optimization evaluation is site-specific but generally
involves two considerations:
Are the annual O&M costs and/or life-cycle
costs prohibitively low for investing in a full-
scale evaluation?
Are there unique aspects of the site or
complexities that are pertinent to the evaluation
and can only be fully appreciated when viewed
in person? These unique aspects or complexities
may include the following:
- an old, but complex treatment system that
does not have an O&M manual
- access issues that may affect the placement
of new extraction or monitoring wells
- potential nearby receptors that are not well
described in site documents
- upcoming decisions regarding the remedy
that include relocating remedy components
- on-site documents that are not permitted to
leave the site
- site complexities that would be difficult to
discuss without directing attention to
figures, maps, etc.
Assuming a remedy will operate for a number of
years (e.g., a P&T system), an organization may-
choose to conduct a full-scale evaluation if the
annual cost of the remedy exceeds the entire cost of
the evaluation (both site team and evaluation team
expenses) by an order of magnitude. If the annual
costs are less than an order of magnitude of the
evaluation cost, the organization may opt for a
streamlined evaluation.
Selection of an Optimization Team/Contractor
Each organization can choose who will conduct the
independent optimization evaluations of the ground
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water remedies. In some cases, organizations may
choose members of their own staff (who are
independent of direct site activities). In other cases,
organizations may choose to select an optimization
contractor. In either case, the quality of the
evaluation will generally depend on the quality and
expertise of the evaluation team. Important factors
to consider when selecting a team are discussed in
Section C of this document. The U.S. Army Corps
of Engineers has developed a sample scope of work
to assist in hiring an optimization evaluation
contractor. This sample language is available on the
U.S. Army Corps of Engineers website:
http://www.environmental.usace.annv.mil/libraiv/gu
ide/rsechk/rsechk .html
Timing and Integration of Optimization
Evaluations with Respect to Other Organization
Practices
It is generally beneficial to schedule optimization
evaluations when there is enough information to
review regarding remedy performance but early-
enough for implementation of recommendations to
improve performance or reduce costs. For P&T
systems, optimization evaluations may be
appropriate after one or two years of system
operation. During these first two years of operation,
data are collected that will help evaluate remedy
performance and cost-effectiveness. After
recommendations are implemented, the system can
operate at a presumably higher level of effectiveness
relatively early in the remedy life-cycle.
Organizations may also want to conduct
optimization evaluations in conjunction with other
reviews or prior to planning or revising a long-term
O&M budget. For example, for Superfund sites, the
optimization evaluations can be conducted in
conjunction with the Five-Year Review process.
Because remediation technologies, site conditions,
and regulatory climates change, it is often beneficial
to conduct optimization evaluations of P&T systems
and other long-term remedies on a routine basis,
perhaps every two to five years, depending on the
changes associated with the site.
Follow-up of Optimization Evaluations and
Tracking Progress toward Considering and
Implementing Recommendations
Because optimization programs have a cost
associated with them and because optimization does
not actually occur without implementing changes,
the optimization program should have a follow-up
component to track the progress each site is making
with respect to implementing the recommendations
from an optimization evaluation. The follow-up
generally involves the site project manager, the
evaluation team, organizational management, and
optimization program director. This broad
involvement often provides site managers with the
opportunity to receive assistance in overcoming
obstacles to implementing recommendations,
whether that assistance involves direction from
management or clarification on a recommendation
from the evaluation team.
The follow-up and tracking generally involves
noting the following:
concerns regarding protection of human health
and the environment
• recommendations that will be implemented
recommendations that will not be implemented
and the reason why
• cost of implementing the recommendations and
comparing the cost to the estimates provided
during the optimization evaluation
• significant changes in the remedy performance,
site conditions, community involvement, and
regulatory climate
changes in annual O&M costs and how they
compare to the baseline costs collected prior to
optimization
funding requests for implementing optimization
evaluation recommendations
Involvement of Management
Organizations that are committed to optimization
generally involve management in the optimization
process. This involvement of management indicates
to the site project manager that management
supports optimization and expects results. By
participating, management can also help with
decisions that may be out of the control of the site
project manager, such as requests for additional
funding or making changes to the system that may
be dependent on recent or upcoming changes to
organizational policy. It is particularly important to
include management if the optimization program is
11
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being administered by one division of the
organization and the sites and site managers belong
in a different (perhaps parallel) division.
Funding for Implementation of Recommendations
A number of the recommendations that result from
optimization evaluations require capital expenditures
to implement. In some cases, these capital
expenditures will fund modifications that are
necessary to provide adequate protection to human
health and the environment. In other cases, these
capital expenditures will fund modifications that will
reduce annual and life-cycle costs. For both types of
recommendations, optimization will not occur
without implementation, so it is important that
organizations provide the funding to implement
recommendations, particularly those with the highest
priority.
F. TOOLS TO SUPPORT OPTIMIZATION
This section provides a list of existing support tools
for optimization. Some of these tools can help site
managers pro-actively manage their site, others are
meant to assist optimization evaluation teams, and
others are intended to provide further detailed
analysis beyond the scope of a traditional
optimization evaluation.
General Optimization Information
Factsheets and Handbooks
• Remedial Process Optimization Handbook
(AFCEE/ERT and DLA, 2001)
• Guidance for Optimizing Remedial Action
Operation (RAO), (NFESC, 2001)
• Elements for Effective Management of
Operating Pump and Treat Systems (U.S.
EPA, 2002b)
• Remediation Process Optimization:
Identifying Opportunities for Enhanced, and
More Efficient Site Remediation (ITRC,
2004) "
• Cost-Effective Design of Pump and Treat
Systems (U.S. EPA, 2005a)
Effective Contacting Approaches for
Operating Pump and Treat Systems (U.S.
EPA, 2005b)
O&M Report Template for Ground Water
Remedies (with Emphasis on Pump and
Treat Systems) (U.S. EPA, 2005c)
A Cost Comparison Framework for Use in
Optimizing Ground Water Pump and Treat
Systems (U.S. EPA, 2007a)
Options for Discharging Treated Water
from Pump and Treat Systems (U.S. EPA,
2007b)
Checklists
• USACE Remediation System Evaluation
(RSE) Checklists (USACE, 2005)
Websites
www.frtr.gov/optimization
The Federal Remediation Technologies
Roundtable (FRTR) promotes Federal
interagency cooperation to advance
remediation technologies. The optimization
website provides a repository of information
on remedial process optimization
approaches and case studies as well as
information on other more specific forms of
optimization including monitoring and
simulation optimization.
www.cliiin.org/optimization
This website is sponsored by the U.S. EPA
Office of Superfund Remediation and
Technology Innovation. The webpage
provides information on EPA's optimization
efforts, including over 25 RSE reports from
EPA and non-EPA sites, as well as other
optimization information.
www.epa.gov/superfuiid/action/postconstruction
/optimize.htm
EPA refers to the time period following
remedy construction as "post-construction
completion". This website provides EPA
Remedial Project Managers (RPMs) with
fundamental information on guiding sites
12
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through the post-construction completion
process, including O&M and remedy
optimization. The website includes fact
sheets, guidance, and EPA memorandums
that pertain to the post-construction
completion period.
Ground Water Modeling Optimization
Ground water modeling optimization is one of many
specific technical activities that may be appropriate
as either a stand-alone action or as a follow-up
action to optimization of an entire P&T system.
Modeling optimization attempts to minimize cost or
time needed to achieve a remedial objective using
computer models of subsurface processes. These
models may simulate only the movement of ground
water (hydraulic or flow models) or may simulate
both the movement of ground water and the
transport of contaminants (transport models). The
modeling is typically done by a professional that
runs one combination of well locations and flow
rates at a time. The model is repeatedly run in a
"trial and error" fashion until the modeler determines
that a certain combination most effectively achieves
the goals. However, this process is usually very
labor intensive, and algorithms have been developed
that work in conjunction with existing ground water
models to try many more combinations of well
locations and flow rates than a single modeler could
perform in the same time (perhaps hundreds to
thousands more combinations). In the process, the
algorithms quantify the optimal solutions to specific
problems subject to specific constraints. Such
algorithms yield a much higher probability of
locating a truly "optimal" answer. These tools can
be applied to systems in design or to existing
systems that are being optimized.
There are two primary modeling optimization
approaches for P&T systems: ground water flow
(hydraulic) modeling optimization and contaminant
transport modeling optimization. Hydraulic
optimization has been more widely available and
applied for a longer time than transport optimization.
After a flow model is developed, it typically costs
under $20,000 (2007 costs) and is generally
applicable to optimization problems pertaining to
plume containment. Transport optimization is
complex and few personnel currently perform this,
though many efforts are underway to transfer this
technology to the environmental consulting
community. The cost for such work is several times
the cost of flow optimization, and use of this
optimization approach generally applies to
optimization problems that include aquifer
restoration. For more information on modeling
optimization, including descriptions of
demonstration projects and the codes described
above, visit the following website:
http://www.frtr.gov/optimizatioiVsimiilation.htm
Monitoring Program Optimization
Monitoring costs often represent a substantial
fraction of the cost of O&M at remediation sites. As
with other aspects of the system, the efforts for
monitoring of both the subsurface and above-ground
systems can be optimized for adequacy and cost-
effectiveness. Although monitoring programs are
generally evaluated as part of an optimization
evaluation, more thorough monitoring optimization
is sometimes beneficial.
The Livermore National Laboratory developed the
"Cost Effective Sampling" process to address
objectively the issue of adequate sampling
frequency. This approach weighs the considerations
described above in recommending sampling
frequencies. The recommendations can be modified
based on non-technical factors (Ridley and
MacOueen, 2001). The MAROS software (AFCEE,
2005) developed for the Air Force also has the
capability to assess sampling frequencies.
Monitoring wells installed during the site
characterization phase are often part of the
monitoring network, and are often not optimal for
monitoring the performance of ground water
extraction. The analysis of the adequacy of the
monitoring network is often done by professional
judgment, though quantitative analysis using a
statistical approach (e.g., geostatistics) can be very
useful if a large network (e.g., >20 wells) is present.
The MAROS software (AFCEE, 2005) has
capabilities to quantitatively assess the network, and
other software using the kriging method can quantify
the value added by sampling only selected wells.
Additional information on the use of kriging and
other techniques for monitoring network
optimization is available at the following website:
http://www.frtr.gov7optimization/monitoring.htm
Monitoring at some sites has been conducted over
many years and the methods used may have been
adequate at the time the program was initiated, but
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new methods may be available that would provide
data that meet quality needs at a reduced cost. For
example, high-speed pumping based on well volume
criteria or use of bailers may be replaced with low-
flow sampling or passive diffusion bag samplers
(PDBs), resulting in substantial labor and water-
disposal cost savings if site conditions are
appropriate. In some cases, the current sampling
methods do not provide data of adequate quality.
For additional information on alternatives to current
sampling procedures, refer to the Field Analytical
Technologies Encyclopedia (FRTR. 2005) and
"Ground-Water Sampling Guidelines for Superfund
and RCRA Project Managers" (Yeskis and Zavala,
2002). Information on application of PDBs is
available from the Interstate Technologies
Regulatory Council (ITRC, 2004), and information
on low-flow sampling is available from the U.S.
EPA Office of Research and Development (Puls and
Barcelona, 1996).
A number of documents have also been developed to
support monitoring optimization, including Me thods
for Monitoring Pump-and-Treat Performance (U. S.
EPA, 1994), Road Map to Long-Term Monitoring
Optimization (U.S. EPA, 2005d), and others
accessible electronically from the following website:
http: /Avvvw. frtr. go v/o ptim izati on/moni tori ng .htm
G. SUMMARY
H. REFERENCES
This document provides an overview of optimization
for operating long-term ground water remedies. It
discusses the benefits of optimization, details the
components of atypical optimization evaluation, and
discusses the key aspects of an optimization program
that incorporates optimization evaluations.
"Optimization" as defined in this document refers to
efforts used to improve a remedy's effectiveness in
protecting human health and the environment,
reducing life-cycle remedy costs, and speeding
progress toward site closure. The optimization
processes discussed are based on independent
evaluations that are conducted by a team of experts.
This document is geared toward the general
environmental community and highlights
optimization tools that may be helpful to that
community.
Air Force Center for Environmental Excellence
Technology Transfer Division (AFCEE/ERT) and
Defense Logistics Agency (DLA) Environmental
and Safety Office (DSS-E), Remedial Process
Optimization Handbook, San Antonio, TX and Fort
Belvoir,VA, 2001
Air Force Center for Environmental Excellence
(AFCEE), February 17, 2005, Monitoring and
Remediation Optimization System (MAROS) v 2.2,
Federal Remedial Technologies Roundtable,
February 17, 2005, Field Analytical Technologies
Encyclopedia.
Interstate Technology & Regulatory Council (ITRC)
Diffusion Sampler Team, Technical and Regulatory
Guidance for Using Polyethylene Diffusion Bag
Samplers to Monitor Volatile Organic Compounds
in Groundwater, 2004
interstate Technology & Regulatory Council (ITRC)
Remedial Process Optimization Team, Remediation
Process Optimization: Identifying Opportunities for
Enhanced and More Efficient Site Remediation,
September 2004
Naval Facilities Engineering Service Center
(NFESC), Guidance for Optimizing Remedial Action
Operation (RAO), Special Report SR-2101-ENV,
Interim-Final, April 2001
Puls, Robert W. And Michael J. Barcelona, "Low-
flow (Minimal Drawdown) Ground-water Sampling
Procedures", EPA/540/S-95/504, U.S. EPA Office
of Research and Development, 1996
Ridley, Maureen and Don MacQueen. "Cost-
effective Sampling of Groundwater Monitoring
Wells: A Data Review & Well Frequency
Evaluation", Lawrence Livermore National
Laboratory, UCRL- JC-118909, 2001
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U.S. Army Corps of Engineers (USAGE), February
17, 2005, USAGE Remediation System Evaluation
(RSE) Checklists
U.S. EPA, Methods for Monitoring Pump-and-Treat
Performance, EPA/600/R-94/123, 1994
U.S. EPA, Groundwater Pump and Treat Systems:
Summary of Selected Cost and Performance
Information at Superfund-Financed Sites, EPA 542-
R-01-021b, 2001
U.S. EPA., Pilot Project to Optimize Superfund-
Financed Pump and Treat Systems: Summary
Report and Lessons Learned, EPA 542-R-02-008a,
2002a
U.S. EPA, Elements for Effective Management of
Operating Pump and Treat Systems, OSWER
9355.4-27FS-A, EPA 542-R-02-009, 2002b
U.S. EPA, Action Plan for Ground Water Remedy
Optimization, OSWER 9283.1-25, 2004a
U.S. EPA, Cleaning up the Nation "s Waste Sites:
Markets and Technology Trends, EPA 542-R-04-
015,2004b
U.S. EPA, Cost-Effective Design of Pump and Treat
Systems, OSWER 9283.1-20FS, EPA 542-R-05-008,
2005a
U.S. EPA, Effective Contracting Approaches for
Operating Pump and Treat Systems, OSWER
9283.1-21FS, EPA 542-R-05'-009, 2005b
U.S. EPA, O&M Report Template for Ground Water
Remedies (with Emphasis on Pump and Treat
Systems), OSWER 9283.1-22FS, EPA 542-R-05-
010, 2005c
U.S. EPA, Roadmap to Long-Term Monitoring
Optimization, EPA 542-R-05-003, May 2005d
U.S. EPA, A Cost Comparison Framework for Use
in Optimizing Ground Water Pump and Treat
Systems, EPA 542-R-07-005, May 2007a
U.S. EPA, Options for Discharging Treated Water
from Pump and Treat Systems. EPA 542-R-07-006,
May 2007b
Yeskis, Douglas and Bernard Zavala. ''Ground-
Water Sampling Guidelines for Superfund and
RCRA Project Managers", Ground Water Forum
Issue Paper, EPA 542-S-02-001, U.S. EPA Office of
Solid Waste and Emergency Response, May 2002
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APPENDIX A:
Appendix A is an example of a brief document used to introduce optimization evaluation participants to the
optimization process. This example is used by the U.S. EPA as part of its nationwide program to optimize
operating Superfund-financed long-term ground water remedies.
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An Introduction to Remediation System Evaluations (RSEs) and "RSE-lites"
Background
As part of a nationwide effort between 2000 and 2003, the EPA Office of Solid Waste and Emergency Response
commissioned a total of 27 optimization evaluations called Remediation System Evaluations (RSEs) to be
conducted at Fund-lead pump and treat (P&T) systems in each of the ten EPA Regions. In addition, one RSE was
conducted at a Responsible Party Superfund site. This nationwide optimization effort enabled EPA Headquarters
to assist the EPA Regions and individual site managers with management and operation of their Fund-lead P&T
systems.
To include optimization in part of a larger post construction-complete strategy for the Fund-lead P&T systems,
the EPA Office of Superfund Remediation and Technology Innovation (OSRTI) has commissioned additional
optimization evaluations. Both RSEs and a streamlined form of RSEs called "RSE-lites" will be used.
What are the Differences between RSEs and RSE-lites?
An RSE involves an independent team of experts (i.e., individuals that are not associated with the evaluated site)
reviewing site documents, visiting the site for a full day, and compiling a draft report (typically 30-40 pages) that
includes recommendations to improve the system. The draft report is generally available for review within 45
days of the site visit. Upon review by the site manager and other stakeholders that report is finalized. The
observations made and the recommendations given are not intended to imply a deficiency in the work of the
designers, operators, or site managers but are offered as constructive suggestions. The recommendations
obviously have the benefit of the operational data unavailable to the original designers.
An RSE-lite is a very similar process but differs from an RSE in two primary ways.
An RSE-lite does not include a site visit. Rather, the evaluation team conducts interviews with the site
team in a conference call. The conference call allows the site team and evaluation teams to communicate
but reduces the cost of the evaluation and facilitates scheduling.
• An RSE-lite report is streamlined relative to an RSE report. Site and remedy background, general
findings, and recommendations are provided, but the report is not as detailed as a full scale RSE report.
If during an RSE-lite, it is determined that a site visit and more detailed evaluation is required, they can be
arranged through technical assistance or by extending the RSE-Lite into a full-scale RSE.
What Documents does the Evaluation Team Typically Review?
For either process, the evaluation team typically reviews the following site documents/information:
• Remedial Investigation Report
• Feasibility Study Report
• Record of Decision (ROD)
• ROD Amendments and Explanation of Significant Differences (ESDs), if any
• Design documents and O&M manual
Recent O&M reports (weekly, monthly, etc.)
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• Recent semi-annual and annual reports
• Previous 5-year reviews
A summary of system changes or modifications that are not described in site documents
• Any other reports or documents the site managers feel are pertinent to the site
What is Typically Included in an RSE or RSE-lite Report?
A typical RSE or RSE-lite report includes the following sections:
General site background
Description of the pump and treat system and any other operating remedies at the site
• A summary of the site objectives
• Findings from the visit including performance of individual components of the remedy
• A review of the site's effectiveness in protecting human health and the environment
• Recommendations to
improve effectiveness
- reduce costs
- improve technical operation
gain site closure
• Suggested approach to implementing recommendations
The primary difference between RSE and RSE-lite reports is the level of detail.
What are some Typical Questions that are Asked During an RSE or RSE-lite?
The following questions are examples of questions asked during an RSE. This list of questions is by no means a
complete list of all questions that will be asked. In many cases, these questions are used to generate discussion
and to lead the RSE team toward more direct and detailed questions.
1. Please provide a history of the site that brings us to the present time. Please try to include any significant
changes in the approach or strategy taken at the site including ROD Amendments and ESDs (if any). Please
note that many aspects of this site history will provide discussion points.
2. What is the conceptual model for the site? For example, what are/were the sources of contamination? Where
are/were they located? What processes/mechanisms were involved in arriving at the currently observed
conditions? Consider horizontal and vertical transport, contaminant degradation, recharge, ground water
extraction, etc.
3. What are the site objectives as specified in the ROD? Is the remedy achieving those objectives? If so, what
monitoring is being done to confirm this? If not, what steps, if any, have been taken to modify the remedy or
the ROD?
4. What are the discharge limits for the treatment plant? Which contaminants provide the most difficulty in
meeting these limits? Are the discharge limits consistently exceeded?
5. What is the current exit strategy for the site? How has this strategy changed over time? What elements of the
remedy have led to these changes?
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6. What is the current work plan for analysis of aquifer and process monitoring data? Does this work plan
involve analysis of plume capture, changes in the plume area or extent, or other indicators of effectiveness?
Does this plan include criteria for reducing monitoring locations or frequency over time?
7. What is the current schedule for turning the site over to the State? What are the concerns, if any, of the State?
8. What is the total annual O&M cost for the site? Without divulging the contractor's proprietary information,
please provide approximate estimates as to how this total cost is distributed among the following categories:
• Oversight, project management, technical support, and reporting
Operator labor
• Sampling and analysis
• Utilities
Materials/consumables
• Disposal costs
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APPENDIX B:
Appendix B is an example of a site information form that can be used to collect baseline information on operating
pump and treat systems. This example is used by the U.S. EPA as part of its nationwide program to optimize
operating Superfund-financed long-term ground water remedies.
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Date:
Filled Out By:
A. Site Location, Contact Information, and Site Status
1 . Site name 2. Site Location (City and State)
4a. EPA RPM 5a. State Contact
3. EPA Reg ion
4b. EPA RPM Phone Number 5b. State Contact Phone Number
4c. EPA RPM Email Address 5c. State Contact Email Address
5. Is the ground water remedy an interim remedy or a final remedy? Interim | | Final I I
6. Is the site EPA-lead or State-lead with Fund money? EPA EH State EH
B. General Site Information
1 a. Date of Original ROD for Ground Water Remedy
2a. Date Remedy is Operational and Functional (O&F)
3 . What is the primary goal of the P&T system
(select one)?
I | Contaminant plume containment
1 I Aquifer restoration
I | Containment and restoration
1 I Well-head treatment
1 b. Dates of Other Ground Water Decision Documents (e.g., ESD, ROD Amendment)
2b. Date for Transfer to State
4. Check those classes of contaminants that are
contaminants of concern at the site.
O VOCs (e.g., TCE, benzene, etc.)
D SVOCs (e.g., PAHs, PCP, etc.)
I | metals (e.g., arsenic, chromium, etc.)
1 I other
5. Has NAPL or evidence of NAPL been observed at the site? Yes | | No | |
6. What is the approximate total pumping rate?
7. How many active extraction wells
(or trenches) are there?
9. How many samples are collected
from monitoring wells or piezometers
each year? (e.g., 40 if 10 wells are
sampled quarterly)
11. What above-ground treatment processes are usec
1 1 Air stripping
1 I Carbon adsorption (liquid phase)
1 1 Filtration
1 I Off-gas treatment
1 1 Ion exchange
8. How many monitoring wells are
regularly sampled?
10. How many process monitoring samples
(e.g., extraction wells, influent, effluent, etc.)
are collected and analyzed each year? (e.g., 24
if influent and effluent are sampled monthly)
(check all that apply)?
1 1 Metals precipitation
1 I Biological treatment
O UV/Oxidation
1 I Reverse osmosis
O Other
12. What is the approximate percentage of system downtime per year? <10% I I 10 - 20% I I >20% I I
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C. Site Costs
1. Annual O&M costs
O&M Category
Actual Annual Costs
for FY03
Actual Annual Costs
forFY04
Projected Annual
Costs for FY05
Labor: project management, reporting,
technical support
Labor: system operation
Labor: ground water sampling
Utilities: electricity
Utilities: other
Consumables (GAC, chemicals, etc.)
Discharge or disposal costs
Analytical costs
Other (parts, routine maintenance, etc.)
O&M Total
The O&M total should be equal to the total O&M costs for the specified fiscal years, including oversight from
U.S. Army Corps of Engineers or another contractor. For costs that do not/it in one of the above cost categories,
include them in the "Other" category. If it is not possible to break out the costs into the above categories, use
the categories as best as possible and provide notes in the following box.
2. Non-routine or other costs
Additional costs beyond routine O&h-Ifor the specified fiscal years should be included in the above spaces. Such
costs might be associated with additional investigations, non-routine maintenance, additional extraction wells, or
other operable units. The total costs billed to the site for the specified fiscal years should be equal to the O&M
total plus the costs entered in item 2.
Notes on costs:
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D. Five-Year Review
1. Date of the Most Recent Five-Year Review
2. Protectiveness Statement from the Most Recent Five-Year Review
I | Protective I I Not Protective
Protective in the short-term Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below.
E. Other Information
If there is other information about the site that should be provided, please indicate that information in the space
below. Please consider enforcement activity, community perception, technical problems to be addressed, and/or
areas where a third-party perspective may be valuable.
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NOTICE:
This document may be downloaded from EPA?s Clean Up Information (CLUTN) System at http://www.cluin. org.
Hard copy versions are available free of charge from the National Service Center for Environmental Publications
(NSCEP) at the following address:
U.S. EPANSCEP
P.O. Box 42419
Cincinnati, OH 45242-2419
Phone: (800) 490-9198
Fax: (301) 604-3408
nscep@bps-lmit.com
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^eo «!•«.
~ United States EPA 542-R-07-007
I "". * ; ;, Office of Solid Waste and May 2007
•; Environments Protection ._ _ . .
? . Emergency Response www.clum.org
^enc^ www.epa.gov/superfund
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