&EBV
United States
Environmental Protection
Agency
Office of Solid Waste and
Emergency Response
OSWER9355.0-107
EPA-540-R-04-010
September 2004
Updating Remedy Decisions
at Select Superfund Sites
Summary Report
FY 2002 and FY 2003
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SUMMARY REPORT FY02 AND FY03
Executive Summary (FY02-FY03)
Since FY96, Updating Remedy Decisions has been characterized as one of EPA's most successful
Superfund reforms. In FY02 and FY03, EPA updated more than 100 remedies, reducing estimated future
cleanup costs by almost $150 million. Other key successes and findings include the following:
• Most remedy updates completed during FY02 and FY03 were the result of additional technical
information gathered as part of the remedy design process. A small number of remedy updates were
the result of non-technical changes in the applicable or relevant and appropriate requirements (ARARs),
land use, or required cleanup levels. Another small number of remedy updates were the result of State
input or community preference which focused on either technical or non-technical modifications to the
remedy.
• EPA tracked all remedy updates during FY02 and FY03, most of which were reform-related. In FY02,
the total estimated cost savings for remedy updates were in excess of $57 million, 92 percent of which
was based on scientific and technological advancements. For remedy updates completed in FY03, the
total estimated cost savings were in excess of $87 million, all of which was based on scientific and
technological advancements. There were 14 remedy updates in FY02 that resulted in cost increases
totaling an estimated $175.6 million, and there were 14 remedy updates in FY03 that resulted in cost
increases totaling an estimated $81.1 million. The majority of the cost increase totals were attributable
to the remedy updates for a small number of sites.
• Estimated cost savings for 102 individual remedy updates during FY02 and FY03 ranged from a
negligible amount to over $32 million, with most remedy updates generating savings under $10 million.
Of the 28 remedy updates that resulted in estimated cost increases, of over $250 million, there was a
median cost increase of $2 million.
• Remedy updates generally occurred in the remedial design phase of the cleanup process and were
more likely to be documented with Explanations of Significant Differences (ESDs) than Record of
Decision (ROD) Amendments. Over the two-year period, there were 74 ESDs and 28 ROD
Amendments representing remedy updates with both cost savings and increases.
• Most remedy updates during FY02 and FY03 were initiated by parties outside of EPA (e.g., potentially
responsible parties (PRPs), States, communities, Federal facilities). Over the two-year period, parties
outside of EPA initiated 48 updates and EPA initiated 40 updates (these numbers do not include 14
updates initiated by more than one party).
• Over the two-year period, the most commonly addressed medium was ground water (59 updates)
followed by soil (43 updates). Eight other media types were addressed by remedy updates during FY02
and FY03.
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
Cumulative Summary (FY96-FY03)
Since its inception, Updating Remedy Decisions has continued to significantly impact Superfund sites
across the country. From FY96-FY01, there were 418 remedy updates reducing future cleanup costs by
more than $1.7 billion while at the same time increasing estimated future cleanup costs by $228.8 million.
By including the FY02 and FY03 data, the cumulative totals for FY96-FY03 are 520 remedy updates
reducing future cleanup costs by more than $1.8 billion, while at the same time increasing estimated future
cleanup costs by $486.2 million.
Over the initial eight years of implementing the remedy update reform, EPA has shown overwhelming
success regarding large savings of money, time, and resources. The data gathered in FY02 and FY03,
however, shows less estimated cost savings and more estimated cost increases than in previous years.
Specifically, this is the first two year summary of the reform where estimated cost increases have
exceeded estimated cost savings. EPA believes that this is due to reform maturation. Most Regions have
already reviewed the remedies in their available pool of sites, so the likelihood of finding new large savings
is not as great as it was in the past. Conversely, there have been an increasing number of sites that
initially selected a lower cost remedy, but because that remedy was found to not work as designed, EPA
needed to select another remedy, which was more expensive than the original remedy. The data from
FY02 and FY03 confirms that initially large estimated cost savings have been replaced with smaller
estimated cost savings and initially fewer estimated cost increases have been replaced with more
numerous, large estimated cost increases.
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SUMMARY REPORT FY02 AND FY03
Table of Contents
Executive Summary i
Cumulative Summary ii
1.0 Introduction 1
2.0 FY02 and FY03 Results 2
Exhibit 2.1: Estimated Remedy Update Savings by Region for FY02 and FY03 2
Exhibit 2.2: Estimated Savings Per Remedy Update for FY02 and FY03 3
Exhibit 2.3: Remedy Updates by Medium for FY02 and FY03 3
Exhibit 2.4: Number and Type of Remedy Updates for FY02 and FY03 3
3.0 Remedy Update Process 4
Exhibit 2.5: Remedy Update Initiators in FY02and FY03 4
3.1 Determination of Remedy Update Type 5
Exhibit 2.6: ESDsvs. ROD Amendments in FY02and FY03 6
3.2 State/Tribal and Community Roles 7
3.3 Remedy Review Duration 7
Exhibit 2.7: Approximate Review Time for Remedy Updates in FY02 and FY03 8
4.0 Lessons Learned 8
4.1 Benefits 8
4.2 Site Examples 9
5.0 Conclusion 10
Acknowledgments 10
Appendix A: Summary of Updated Remedy Decisions for FY02 and FY03
Appendix A. 1: Summary of Updated Remedy Decisions Without Cost Increases for FY02 and FY03
Appendix A.2: Summary of Updated Remedy Decisions With Cost Increases for FY02 and FY03
MI
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
1.0 Introduction
Updating Remedy Decisions, announced in the third
round of Superfund Reforms in October 1995, is one of
a broad range of administrative reforms undertaken to
improve the efficiency, speed, and fairness of the
Superfund program. Specifically, the Reform
encourages the Regions to revisit selected remedy
decisions at sites where significant new scientific
information, technological advancements, or other
considerations will protect human health and the
environment while enhancing overall remedy cost
effectiveness.
This report contains an evaluation of remedy updates
completed during FY02 and FY03. Information
regarding the progress of the reform, during the
previous six years, is available in four multi-year
summary reports.
• For remedy updates completed in FY96 and FY97,
see the document, "Updating Remedy Decisions at
Select Superfund Sites, Summary Report, FY1996
and FY1997" July 1998, OSWER Directive 540-R-
98-017 on EPA's website at: http://www.epa.gov/
superfund/programs/reforms/docs/urd96-97.pdf.
The Summary Report for FY96 and FY97 contains
the background information of the Reform, a
description of the Reform, the process for
implementing the Reform, and Regional
implementation plans from each of the ten EPA
Regions.
• For remedy updates completed in FY98 and FY99,
see the document "Updating Remedy Decisions at
Select Superfund Sites, Summary Report, FY1998
andFY 1999," March 2001, OSWER Directive 540-R-
01 -00 on EPA's web site at: http://www.epa.gov/
superfund/programs/reforms/docs/urd98-99.pdf.
• To find a cumulative four-year summary of this
reform as well as trends during fiscal years 1996
through 1999, see the document, "Updating Remedy
Decisions at Select Superfund Sites Cumulative
Summary Report FY 1996 Through FY 1999," March
2001, OSWER Directive 9355.0-77 on EPA's web site
at: http://www.epa.gov/superfund/programs/
reforms/docs/urd96-99.pdf.
• Finally, for remedy updates completed in FYOO and
FY01, see the document, "Updating Remedy
Decisions at Select Superfund Sites, Summary
Report, FY2000andFY2001" February 2003,
OSWER Directive 9355.0-94 on EPA's web site at:
http://www.epa.gov/superfund/programs/reforms/
docs/rem_report.pdf.
This report:
• Provides a summary of Superfund sites where
remedies have been updated during FY02 and FY03;
• Highlights estimated future cost reductions (cost
savings) or cost increases expected to result from
updated remedies; and
• Presents stakeholders with information on the role of
remedy updates in improving Superfund
implementation.
Originally, EPA encouraged remedy updates to
incorporate new technical information into existing site
cleanups. Today, EPA continues to promote remedy
updates that incorporate the latest science and
technology into selecting and implementing Superfund
remedial decisions. As a whole, these reforms were
selected to make Superfund faster, fairer, and more
efficient. In particular, the remedy update reform has
achieved each of these goals.
It is important to emphasize that this initiative does not
signal any variations in the Agency's current policies
regarding site cleanup, including policies regarding
remedy selection, treatment of principal threats,
preference of permanent remedies, establishment of
cleanup levels, or the degree to which remedies must
protect human health and the environment. EPA
remains committed to the protection of public health,
welfare, and the environment.
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SUMMARY REPORT FY02 AND FY03
2.0 FY02 and FY03 Results
EPA completed approximately 102 remedy updates
in FY02 and FY03, saving over $146 million in
estimated site cleanup costs, while at the same time
creating increases in estimated site cleanup costs of
about $257.4 million.
Updates during FY02 resulted in a total estimated cost
savings of over $185.0 million, most of which resulted
from updates of the kind identified in the Reform
Guidance. Updates during FY03 resulted in a total
estimated cost savings of over $84.0 million, all of
which resulted from updates of the kind identified in the
Reform Guidance.
(Seethe Reform Guidance, "Superfund Reforms:
Updating Remedy Decisions," OSWER Directive 9200.2-
22, dated September 27,1996, at EPA's website: http://
www.epa.gov/superfund/programs/reforms/remedy/
index.htm.)
The estimated cost savings per update ranged from a
negligible amount to $32.0 million, with the majority of
EPA Regions reporting savings in each year reviewed.
Exhibit 2.1 shows the amount of estimated savings by
fiscal year. (Note: Exhibit 2.1 may not include all
remedy updates from FY02 and FY03 because of
limitations on EPA Regional accessibility to remedy
update information.)
Most of the remedy updates generated savings of less
than $10.0 million per update, as shown in Exhibit 2.2.
(Note: Cost estimates for several remedy updates are
either unavailable to EPA or incomplete at the time of
this writing. These are labeled NA/TBD (Not available/
To be determined) in Appendices A, A.1 and A.2.)
EPA Regions also reported on updated remedies that
generated cost increases during FY02 and FY03. The
FY02 cost increases for 14 remedy updates totaled
$176.3 million. The FY03 cost increases for 14 remedy
updates totaled $81.1 million. Of these remedy
updates generating estimated cost increases during
FY02 and FY03, most were less than $5.0 million per
update. This trend may reflect the maturation of the
reform because many remedies with lower cost
increases were updated before this two-year period.
The remedy update cost increase for FY02 and FY03
occur in 8 EPA Regions and only 2 of those EPA
Region had more than 4 increases over the two-year
period.
Recent advances in the area of soil and ground water
science and remediation made these types of decisions
good candidates for remedy updates. Exhibit 2.3
shows that during FY02 and FY03, updates of ground
water remedies were the most common (59 updates),
Exhibit 2.1 : Estimated Remedy Update Savings by Region in FY02 and FY03
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Based on 102 updates
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
Exhibit 2.2: Estimated Savings Per
Remedy Update in FY02 and FY03
<=$1M
18%
• No Sal-ings •<=$1M
D >$1M-$5M • >$5M-$10M
D >$10M-$35M D NA/TBD
• Increases
Exhibit 2.3: Remedy Updates by Medium
for FY02 and FY03
Medium
Ground Water
Soil
Sediment
Waste
Surface Water
Air
Debris
Sludge
Wetlands
Other
FY02
24
16
5
4
0
1
1
0
0
1
FY03
35
27
6
3
3
2
1
2
1
0
Total
59
43
11
7
3
3
2
2
1
1
followed by soil remedies (43 updates). The remaining
updates pertained to eight other media, as depicted in
Exhibit 2.3. These media are consistent with media
typically found at contaminated Superfund sites.
More detailed information regarding remedy updates can
also be found in Appendices A, A.1 and A.2. Specific
remedy updates are listed by Region and site, and
include the following information:
• Type and date of remedy update;
• Update initiator;
• Media involved;
• State and community involvement;
• Estimated resource demands;
• Estimated cost savings or cost increases; and
• Summary of remedy change and factual basis.
Exhibit 2.4 depicts the number and kind of remedy
updates that were completed in FY02 and FY03. It
shows that not all remedy updates generated cost
savings or cost increases. In some cases, the remedy
updates generated neither cost savings nor cost
increases; in other cases, the numbers are yet to be
determined or were unavailable at the time of this
report. The data do not differ significantly from FY02 to
FY03, but they confirmed that the summary totals in
this report are conservative values for estimated cost
Exhibit 2.4: Number and Type of Remedy
Updates for FY02 Through FY03
Total # of Remedy Updates
# Updates With
Estimated Savings
# Updates With
Estimated Increases
# Updates With No Savings
# Updates NAorTBD
FY02
42
21
14
5
2
FY03
60
25
14
13
8
Total
102
46
28
18
10
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SUMMARY REPORT FY02 AND FY03
3.0 Remedy Update Process
After a remedy decision has been completed at a site
(i.e., a ROD is signed), new information may be
received or generated that could affect how the remedy
selected in the ROD should be implemented. This
information may be supplied by a PRP, a Federal
agency conducting the cleanup, the support agency
(e.g., another Federal agency or State/Tribe), or the
public or other interested parties. Data for FY02 and
FY03 indicate that 48 remedy updates were initiated by
parties outside of EPA (e.g., PRPs, States, Federal
facilities) compared to 40 updates initiated by EPA (see
Exhibit2.5). In addition, 14 remedy updates have joint
initiators because information arrived simultaneously
from several different parties. Exhibit 2.5 shows that
the relative percentage of remedy update initiators were
not significantly different from FY02 to FY03.
Although the types of new information that could affect
remedy decision-making vary widely, the Reform
Guidance recommends that EPA pay particular
attention to information which shows that:
• Updating the remedy may result in a more cost-
effective cleanup;
• Physical limitations imposed by the site or the
contaminants may warrant changes in the cleanup
goals; or
• Site conditions may warrant reducing the scope of
the site monitoring after cleanup.
As outlined in the Reform Guidance, the basic process
that Regions should use to consider proposed remedy
updates consists of three steps: identification and
prioritization, technical review, and implementation.
Exhibit 2.5: Remedy Update Initiator in FY02
Based on 42 updates
Remedy Update Initiator in FY03
Based on 60 updates
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
Identification and Prioritization involves assessing
the update request to determine the type of change
(e.g., remedial method, cleanup standards, cleanup
area), the resources required to fully evaluate it, and
any potential increase or decrease in protectiveness
or cost. To ensure that the Region's rationale for
prioritizing update reviews is clear and equitable,
Regions are encouraged to carefully track all
requests for remedy updates. Review and
consideration of potential remedy updates should not
result in any delays in the completion of work
products or other remediation activities required by
the existing ROD and enforcement instruments (e.g.,
unilateral administrative orders (UAOs) or consent
decrees (CDs)).
Technical Review evaluates the site-specific
information supporting both the current remedy and
the update request to determine whether or not the
remedy update was warranted. This information is
typically collected by the site's lead entity (e.g., the
Federal Agency, Federal facility, PRP, State, or
Tribe).
Implementation involves preparing and filing the
necessary documentation (a note or memorandum to
the Administrative Record file, an BSD, or a ROD
Amendment) to support the update, consulting with
the State and community, and physically conducting
the updates at the site.
3.1 Determination of Remedy
Update Type
In order to categorize the update, remedy update teams
consider the following factors:
• Scope - Does the update alter the scope of the
remedy (e.g., the physical area of the response,
remediation goals to be achieved, or type and
volume of wastes to be addressed)?
• Performance - Would the update alter the
performance (e.g., treatment levels to be attained,
methodology used to achieve cleanup goals, and
new technology not considered in the original ROD)
and, therefore, raise concerns about the
protectiveness or long-term effectiveness of the
remedy?
• Cost - Does the update alter remedial costs and are
the changes in costs of such a nature that they could
not have been anticipated based on: (1) the
estimates in the ROD; and (2) the recognized
uncertainties associated with the selected remedial
alternative?
Based on this evaluation, and depending on the extent
or scope of the modification being considered, the lead
agency must determine the type of update involved
(e.g., nonsignificant or minor, significant, or fundamental
change to the scope, performance, or cost of the
original remedy). An aggregation of nonsignificant or
significant changes could result in a fundamental
change overall. Post-ROD updates fit into one of these
categories:
• A nonsignificant or minor change usually arises
during design or construction when modifications are
made to the functional specifications of the remedy
to optimize performance and minimize cost. Such
changes may affect the type or cost of materials,
equipment, facilities, services, and supplies used to
implement the remedy. Minor changes might include
a slight increase in the volume of treated soil, a
change in disposal location, or a modification in
ground water monitoring specifications.
• A significant change generally involves incremental
change to a component of a remedy that does not
fundamentally alter the overall remedial approach. A
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SUMMARY REPORT FY02 AND FY03
significant change might involve an increase of over
50 percent in the volume of soil to be remediated, a
change in reasonably anticipated land use following
the remedy, or a change in an ARAR that has
impacts on cleanup levels and other parameters.
• A fundamental change involves an appreciable
change or changes in the scope, performance, and/or
cost of a remedy or may involve a number of
significant changes that together have the effect of a
fundamental change. Fundamental changes result in
a reconsideration of the waste management
approach (e.g., change in the primary remedy for the
wastes, residual risk, cleanup technology) selected
in the original ROD and must include a formal public
comment period. A fundamental change might
involve selecting a different primary treatment
technology because of community preference,
discovery of additional contaminants, or the
determination that less treatment than originally
expected is needed.
For more information on remedy update type, see "A
Guide to Proposing Superfund Proposed Plans,
Records of Decision, and Other Remedy Selection
Decision Documents,"OSWER Directive No. 9200.1 -
23P (July 1999). Enforcement decision documents may
also need to be modified, depending on the type of
remedy update and the language in the order or consent
decree, if there is an order or consent decree.
The type of change will determine which of the following
documents EPA uses to update the remedy: a
memorandum or note to the Administrative Record for a
nonsignificant or minor change; an ESD for a significant
change; or a ROD Amendment for a fundamental
change. As shown in Exhibit 2.6, there were 74 ESDs
and 28 ROD Amendments completed during FY02 and
FY03.
In general, more remedy updates occur during remedy
design and represent a significant but not fundamental
change to the remedy. Consequently, more remedy
updates correspond to at least one of the following
situations: the scope of the remedy has changed (e.g.,
Exhibit 2.6: ESD vs. ROD Amendments
in FY02 and FY03
ESDs
ROD Amendments
FY02 FY03 Total
30 (41%) 44 (59%) 74
11 (39%) 17 (61%) 28
volume increase or decrease); the performance of the
remedy can be modified or optimized (e.g., change in
disposal or discharge point); or there is a more cost
effective way to implement the remedy.
In some situations, additional contamination is
identified or the original remedy does not meet the
required cleanup levels specified in the ROD. In those
cases, the determination for an updated remedy may
result in estimated cost increases.
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
3.2 State/Tribal and
Community Roles
State/Tribal Roles
States play an important role in the modification of
remedy decisions. Section 300.515 of the NCR and the
Model CERCLA RD/RA Consent Decree (which forms
the basis for most consent decrees) provide an
opportunity for States to review and comment on
specified steps in the remedy selection. Agreements
between EPA and States, including contracts, may
require modification following an update to a remedy.
Furthermore, the Model Consent Decree states that
EPA will provide the State with a reasonable opportunity
to review and comment on any proposed modifications.
Additional information regarding the role of States and
supporting agencies in the remedy modification process
can be found in "A Guide to Preparing Superfund
Proposed Plans, Records of Decision and Other
Remedy Selection Decision Documents,"OSWER
Directive 9200.1-23P (July 1999).
Native American Tribes are afforded substantially the
same treatment as States with respect to certain
provisions of CERCLA (see CERCLA Section 126; NCP
Section 300.505). A Federally-recognized tribal
government, with responsibilities including
governmental functions such as environmental
protection and jurisdiction over a Superfund site, can be
treated essentially the same as a State, (see NCP
Section 300.515).
Community Roles
Several remedy updates in FY02 and FY03 involved
significant State participation and/or community
involvement. Although the initiation of a formal public
comment period is required only in the case of a
fundamental update (i.e., ROD Amendment), most
remedy updates, regardless of their significance, have
a substantial community involvement component (see
NCP Section 300.435(c)(2)(i) and (ii)). For example,
documents pertaining to the site, including any
information on remedy updates, are placed in the
Administrative Record or at the site repository located
near the site (e.g., local library). Other activities,
including a public availability session, public meetings,
issuance of fact sheets about the site, and the release
of an amended proposed plan, may allow the
surrounding community and other interested parties an
opportunity to learn more about the site and present
their opinions on remedial activities. Refer to the
individual site summaries in Appendices A.1 and A.2
for specific activities related to State participation and
community involvement that were part of the remedy
update process for each update completed during FY02
and FY03.
3.3 Remedy Review Duration
Reviewing site-specific material and completing the
ESD or ROD Amendment took less than a year for a
majority of the remedy updates completed during FY02
and FY03 (see Exhibit2.7). Of note, there is a slight
increase in the number of remedy updates with
extended review periods. An examination of sites with
longer review periods suggests that the review
durations were influenced by:
• A lengthy, but important public involvement phase;
• An extensive verification/pilot test period following
the discovery of new performance, technical, or
toxicological data;
• The discovery of unexpected contamination late in
the remedy design phase; or
• A redefinition of land use.
Section 4.2 provides specific examples of remedy
changes whose reviews lasted more than one year.
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SUMMARY REPORT FY02 AND FY03
Exhibit 2.7: Approximate Review Time for Remedy Updates in FY02
Based on 42
updates
year >l-2 >2-3 >3-4 >4-5 >6-7
years years years years years
Approximate Review Time for Remedy Updates in FY03
Based on
60 updates
/\
4.0 Lessons Learned
During the last two years of reform implementation,
EPA has continued to gain insight into ways of
successfully updating site remedies. The following
sections detail information collected regarding reform
benefits, site examples, and comments from
stakeholders.
4.1 Benefits
This Reform has been very successful in bringing past
decisions in line with current science and technology.
By doing so, these updates improve the cost
effectiveness of site remediation while ensuring reliable
short- and long-term protection of human health and the
environment. The quantifiable results of this Reform
have been previously announced in EPA's testimony
before Congress, described in private industry
evaluations of Superfund reforms, and included in a
report by the U.S. General Accounting Office. Of
additional note is EPA's overwhelmingly positive record
of responding to remedy update requests made by
outside parties.
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
4.2 Site Examples
In many cases, remedies were updated as a result of a
decrease or increase in contaminant volume or an
inability to achieve desired results in a test of the ROD-
selected treatment or contaminant technology during
the remedial design phase of the cleanup. Although all
updates described in Appendix A represent site-specific
situations, it is possible to use some as examples of
typical remedy update situations that occurred during
FY02 and FY03.
Updates Based on New Technology
Some updates were the result of new technology that
was not considered at the time of the original remedy.
At Hunterstown Road in Pennsylvania, the potentially
responsible party (PRP) replaced the original remedy of
air stripping using a catalytic off-gas treatment system
with an updated remedy consisting of air stripping using
a vapor phase carbon adsorption system. This design
improvement resulted because the vapor phase carbon
adsorption system was determined to be more cost
effective than the catalytic off-gas treatment system.
Estimated savings of $1.4 million resulted from the
remedy update.
The PRP at the Saegertown Industries Area in
Pennsylvania demonstrated that molasses-based
carbon could enhance biodegradation of volatile organic
compounds (VOCs) in ground water to promote natural
attenuation. The original remedy included the extraction
and treatment of ground water and air sparging/vacuum
extraction. The updated remedy will also involve
ongoing operation and monitoring as well as institutional
controls, at an estimated cost savings of $7.2 million.
Updates Based on New Performance Data
New performance data can also provide the needed
basis for updating remedies. For instance, at Roebling
Steel in New Jersey, the changes documented in the
ROD Amendment were based on new information
received subsequent to the issuance of the ROD. EPA
determined that the test used to identify contamination
"hot spots" was not a good indicator. Instead, the
analytical results from ground water, surface water, and
sediment investigations were found to be more relevant.
The remedy update removed the treatment component
of the original remedy, with resultant estimated savings
of $32 million.
Coordinating the Update
Some remedy updates involve coordination among
EPA, other Federal agencies, and State and local
government agencies. For example, at the Portsmouth
Naval Shipyard in Maine, the original remedy entailed
installation of a landfill cover, institutional controls,
shoreline erosion controls, and monitoring. Following
the Navy's re-evaluation of the feasibility of
consolidating waste at the site, a remedy update was
initiated to evaluate the soil/waste, consolidate it with
another landfill, and construct wetlands.
Representatives from the Navy, EPA, state, and
community met regularly about the remedy update that
resulted in $5.8 million in estimated cost increases.
State Input in the Update
States can be either the lead or support agency for a
remedy update. The remedy update was State-lead at
Evor Phillips Leasing in New Jersey. This change
occurred after the state declared an immediate
environmental concern because it was thought that
ground water leaving the Evor site could impact
downgradient sites. The ESD changed the method of
discharge from on-site reinjection of treated ground
water to discharge to the county utilities authority and
resulted in estimated savings of $1 million.
Community Preference
Community preference can have a significant impact in
addressing site contamination. For example, there was
very high community involvement at New Bedford
Harbor in Massachusetts. Initially, a confined disposal
facility was scheduled to be built. EPA gained
additional site information and refined its approach for
addressing the upper and lower harbor areas. .The
remedy update entails sending dredged sediments to an
off-suite landfill, with estimated savings of $8 million.
Cost Increases
While the Reform Guidance is aimed at controlling all
site costs, there are remedy updates that result in cost
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SUMMARY REPORT FY02 AND FY03
increases. At the Coleman Evans Wood Preserving
Company in Florida, the original remedy involved
excavating and treating 45,000 cubic yards of
contaminated soil with high temperature
thermodesorption. During implementation of the
removal action, additional contaminated soil was
identified so the remedy was changed to include the
excavation and thermal treatment of 135,000 cubic
yards of soil. As a result, the estimated cost increases
were $43 million.
Similarly, at the Bunker Hill Mining and Metallurgical
Complex in Idaho, a remedy update became
necessary when data revealed that the original remedy
was inadequate in meeting treatment levels and the
existing treatment plant could not consistently meet the
current water quality standards. Following treatability
studies, a remedy update was initiated to provide
source control; collect, store, and treat Acid Mine
Drainage; dispose of sludge; and monitor untreated
mine water. An estimated cost increase of $53 million
resulted.
Timeframe for Completing Remedy
Updates
The time needed to complete an update varies with
each site. In some instances, exploring other remedies
takes years of review and completion. At the Marshall
Landfill in Colorado, the review for the remedy update
took nearly a decade. Originally, the remedy consisted
of a ground water pump and treatment system.
Following a determination that the original ARARs were
not protective, a remedy update was initiated to
address new ground water standards for VOCs and
state surface water quality standards. There were no
resultant estimated savings or costs.
In contrast, a review for the remedy update at
Continental Steel in Indiana took approximately one
monthjo complete. The original remedy involved the
removal of lead-contaminated soil. The results of
supplemental sampling, during the design phase, lead
to an enhanced remedy that incorporated more stringent
remedial action goals and a Maximum Contaminant
Level for arsenic in ground water in order to be
protective under a recreation use scenario. There were
no resultant estimated savings or costs.
5.0 Conclusion
ERA and outside parties continued to consider Updating
Remedy Decisions a successful Reform in both FY02
and FY03. The number of remedies updated by each
Region during FY02 and FY03 clearly shows that all ten
EPA Regions are implementing this Reform, with half of
the Regions reporting estimated cost savings above
$10 million for the two fiscal years combined. All ten
EPA Regions continue to evaluate requests to review
old Fund-lead remedies, as well as consider updates to
more recent remedies that may not be up-to-date with
current science or technology. Regions also continue to
encourage outside parties to submit remedy update
requests to EPA when new technical information exists
to support them. Typically, EPA and outside parties
share the benefits of both cost and time savings as a
consequence of implementing the updated remedy.
Interested parties should review the existing Reform
Guidance (OSWER Directive 9200.2-22) for basic
information concerning the Reform. Additional guidance
on remedy updates is included in the updated Record of
Decision Guidance (see "A Guide to Preparing
Superfund Proposed Plans, Records of Decision, and
Other Remedy Selection Decision Documents," OSWER
Directive 9200.1-23P, July 1999). Specific questions on
implementation of the Reform may be directed to Matt
Charsky of the Office of the Office of Superfund
Remediation and Technology Innovation by telephone at
(703) 603-8777, e-mail at charsky.matthew@epa.gov,
or FAX at (703) 603-9133. Each Region also has a
remedy update contact who can be reached by
contacting the Superfund Program office in any of
ERA's ten Regional offices.
Acknowledgments
This report was made possible by the dedicated efforts
of numerous EPA Superfund staff. Regional remedial
project managers (RPMs) responsible for considering
and implementing remedy updates at Superfund sites
are to be commended for making these changes to
select the best technologies available at Superfund
sites nationwide.
This report was prepared for EPA under contract #68-W-
01-58.
10
-------
UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
Appendix A:
Summary of Remedy Update Decisions for FY02 and FY03
Note: The information and data presented in Appendix A have been supplied to EPA headquarters by Regional
offices. The data is subject to occasional updates as new information is received, thus the data in Appendix
A data should be used for informational purposes only.
-------
SUMMARY OF UPDATED REMEDY DECISIONS FOR FY02
Region
1
2
3
4
5
6
7
8
9
10
TOTAL
#With
No Sav.
1
2
0
0
1
0
0
0
0
1
5
#of
TBD
0
1
0
0
1
0
0
0
0
0
2
# With Est.
Sav.
2
4
4
2
4
1
0
0
2
2
21
# With Est.
Incr.
1
2
2
1
1
0
0
0
2
5
14
Estimated
Savings
$9.1M
$4.7M
$17.9M
$7.0M
$11.4M
$5.0M
$0
$0
$0.6M
$3.0M
S58.7M
Estimated
Increases
$0.4M
$5.5M
$0.5M
$7.0M
$7.7M
$0
$0
$0
$21.4M
$133. 8M
S176.3M
Change Initiator
PRP
0
0
4
1
1
0
0
0
0
0
6
EPA
3
4
1
0
4
0
0
0
2
3
17
State
0
1
0
0
1
0
0
0
0
0
2
Fed.
Fac.
0
3
0
2
1
0
0
0
0
2
8
Public
0
0
0
0
0
0
0
0
0
0
0
Joint
1
1
1
0
0
1
0
0
2
3
9
Type of Change
ESD
3
9
4
1
4
1
0
0
3
6
31
ROD-A
1
0
2
2
3
0
0
0
1
2
11
21
14
42 sites
6 PRP 17 EPA 8 FED FAC
9 JOINT 2 STATE
42 sites
31ESD
11 ROD-A
42 sites
Appendix A
-------
SUMMARY OF UPDATED REMEDY DECISIONS FOR FY03
Region
1
2
3
4
5
6
7
8
9
10
Total
# With No
Sav.
3
1
1
1
2
0
0
2
0
3
13
#ofTBD
0
4
0
2
0
0
0
0
1
0
7
# With Est.
Sav.
2
2
5
2
9
1
1
0
1
3
26
# With Est.
Incr.
2
4
0
3
i
i
0
0
0
3
14
Estimated
Savings
$3.2M
$32.3M
$5.0M
$2.4M
$27.5M
$9.9M
$0
$0
$2.5M
$4.8M
S87.6M
Estimated
Increases
$5.8M
$2.2M
$0
$50.5M
$0.5M
$1.7M
$0
$0
$0
$20.4M
S81.1M
Change Initiator
PRP
1
0
3
3
3
1
1
0
0
1
13
EPA
4
4
3
1
5
1
0
1
2
2
23
State
0
0
0
0
1
0
0
1
0
1
3
Fed.
Fac.
1
6
0
4
3
0
0
0
0
2
16
Public
0
0
0
0
0
0
0
0
0
0
0
Joint
1
1
0
0
0
0
0
0
0
3
5
Type of Change
ESD
7
9
3
9
8
0
1
1
0
8
43
ROD-A
0
2
3
3
4
2
0
1
2
1
17
13
7
26 14
60 sites
13 PRP 23 EPA 3 JOINT
16 FED FAC 5 STATE
60 sites
43 ESD
17 ROD-A
60 sites
Appendix A
-------
UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
Appendix A.1:
Summary of Remedy Update Information for FY02 and FY03
for Sites Without Cost Increases
Note: The information and data presented in Appendix A.1 represent only a portion of the information available in
the decision document. If more information is needed, please refer to the site's ESD, ROD-Amendment,
memo-to-file, or letter.
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Region 1 - FY 02
Region 1
New Bedford Harbor, MA
Region 1
Ottati & Goss/Kingston
Steel Drum, OU4, NH
9/25/98
9/27/01 BSD
8/16/02 BSD
2/02
8/02
EPA
Sediments
Very high community
involvement.
Fed = 1000 hrs.
Contr. = 40 hrs.
Est'd Savings = $8M
Type of Change: From - Build confined disposal facility; To - Send dredged sediments to an off-site landfill.
Factual Basis: EPA gained additional site information and refined its approach for the upper and lower harbor area.
1/11/87
9/28/99 BSD
2/7/02 BSD
9/01
1/02
EPA
Soil
State concurrence,
public comment period
Fed = 120 hrs.
Contr. = $5K
Est'd Savings = $1.1M
Type of Change: From - Destruction of PCBs using incineration; To - Change in off-site disposal of PCB and VOC residue collected
through thermal desorption.
Factual Basis: The change resulted from a determination that it would be more cost effective to landfill than incinerate.
Appendix A.I
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 1
Sylvester, NH
Date of
Original ROD
Date of Change
(ESD/ROD-A)
7/29/82
1983 Supp ROD
9/23/02 BSD
Date Review
Commenced
Date Review
Completed
6/02
9/02
Change
Initiator
EPA
Media
Groundwater
State/Community
Involvement
State concurred, local
notification
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 160 hrs.
Contr. = None
Est'd Savings = None
Type of Change: From - Groundwater interception and recirculation system, extract and treat groundwater; To - Adjustment to
alternate concentration limits (ACLs) for groundwater contaminants at the site, DCA and TCA.
Factual Basis: Measurable, protective limits for DCA and TCA were established
Region 1 - FY 03
Region 1
Baird & McGuire, OU1,
MA
9/20/86
8/21/03 BSD
6/03
8/03
EPA
Groundwater,
Soil
State concurred, local
notification
Fed = 120 hrs.
Contr. = None
Est'd Savings = None
Type of Change: Groundwater: From - Extract and treat groundwater, alternate water supply; To - Increase drinking water capacity.
Soil: From - Incineration; To - Excavate silt, peat, sand, and gravel.
Factual Basis: The groundwater remedy was updated due to the discovery of a discharge of LNAPL and the need to supplement the
local drinking water supply.
Appendix A.I
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 1
Baird & McGuire, OU4,
MA
Region 1
Kearsarge Metallurgical
Corp., NH
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/27/90
8/21/03 BSD
Date Review
Commenced
Date Review
Completed
6/03
8/03
Change
Initiator
EPA
Media
Groundwater
State/Community
Involvement
State concurred, local
notification
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 320 hrs.
Contr. = None
Est'd Savings = None
Type of Change: From - Alternate water supply through reopening of Donna Road Wellfield; To - No further action.
Factual Basis: The water treatment plant was no longer necessary. An expansion of the public water supply, under OU1, was
constructed instead.
9/28/90
9/29/03 BSD
10/99
6/03
EPA
Groundwater,
Soil
State wrote first draft of
BSD, signed
concurrence letter prior
to EPA issuance of
BSD. Community was
briefed, legal notice and
Admin Record
prepared.
Fed = 120 hrs.
NHDES= 40 hrs.
Contr. = 198 hrs., $19,468
Est'd Savings = $2.7M*
Type of Change: Groundwater: From - Pump and treat, cleanup goal based on ARARs or risk- based calculations; To - Extraction
trench and revised cleanup goal for 1,1, DCA.
Soil: From - Soil removal of shallow suits; To - Soil removal of deeper soils, offsite disposal.
Factual Basis: New information was gathered through the completion of several actions.
* The estimated capital cost to implement the BSD was $1. 1M. The BSD provides for additional source reduction below the
groundwater table.
Appendix A.I
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 1
Silresim Chemical Corp.,
MA
Region 1
Tinkham Garage Site, NH
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/19/91
9/30/03 BSD
Date Review
Commenced
Date Review
Completed
6/03
9/03
Change
Initiator
EPA
Media
Groundwater,
Soil
State/Community
Involvement
State provided
comments, BSD had
public notice.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 40 hrs.
Contr. = 100 hrs.
Est'd Savings = None
Type of Change: Soil: From - In-situ soil vapor extraction (SVE), residual oils will be excavated, stabilized and capped onsite.
Groundwater: From - extract and treat, metal removal , air stripping, vapor treatment and discharge to city sewage system; To - revised
risk-based cleanup goals based on change in groundwater clarification and inability to meet ROD cleanup levels.
Factual Basis: The remedy was updated based on results of SVE, results of SVE pilot test and re-evaluation of ROD cleanup goals.
9/30/86
3/3 1/03 BSD
1997
3/03
PRP
Groundwater
State signed a
concurrence letter.
Community fact sheet,
legal notice and Admin
Record prepared.
Fed = 80 hrs.
Contr. = None
Est'd Savings = $0.5M
(3 year period)
Type of Change: From - Groundwater pump and treat; To - Monitored Natural Attenuation (MNA).
Factual Basis: The remedy was updated based on ongoing data.
A 1
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Region 2 - FY 02
Region 2
Evor Phillips Leasing, NJ
Region 2
Little Valley, NY
9/29/92
5/22/02 BSD
9/99
5/02
State
Groundwater
No public comments.
Fed = 150 hrs.
Contr. = None
Est'd Savings = $1.0M
Type of Change: From - The 1992 ROD called for the extraction of contaminated groundwater underlying the site with on-site
treatment and recharge; To -The BSD changed the method of discharge from reinjection to discharge to the Middlesex County Utilities
Authority (MCUA).
Factual Basis: This change was initiated because in 1993, the NJDEP declared an Immediate Environmental Concern and it was
thought that groundwater leaving the Evor site could be impacting downgradient sites. The discharge to the MCUA is an acceptable
and economical alternative to reinjection.
9/30/06
4/4/02 BSD
10/00
4/02
EPA
Groundwater
Full State involvement;
community expressed
no opinion.
Fed = 300 hrs.
Contr. = None
Est'd Savings = $1.0M*
Type of Change: From - The ROD called for the installation of air stripper treatment units to protect the public from volatile organic
contamination which was detected in private water supply wells; To - The selected remedy also called for an evaluation within five
years of implementation of the remedy to determine whether a permanent alternate water supply system would be required. EPA
determined that is more appropriate to evaluate whether a permanent alternative water supply will be necessary during the selection of
a final remedy for the site, which is intended to address the source areas and groundwater.
A 1
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 2
Rowe Industries
Groundwater
Contamination, NY
Region 2
Sealand Restoration Inc.,
NY
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Factual Basis: This determination was based upon the fact that the source area and groundwater investigation is ongoing and must be
completed before the water supply can be fully evaluated. Air stripper treatment units were installed on 90 private wells in 1997.
* The original cost to install the air stripper/activated carbon treatment units and five years of operation and maintenance and annual
private well sampling and analysis was approximately $1.6 million (consisting of the actual purchase and installation costs and the
actual purchase and installation costs and the actual operation, maintenance, and monitoring costs for 4 years, and the estimated annual
costs for the fifth year.) The estimated cost related to using two activated carbon treatment units in series and five years of operation
and maintenance and annual private well sampling and analysis is $621,000.
9/30/02
12/20/01 BSD
5/01
12/01
EPA
Groundwater
Full State involvement.
Remedy modified by
BSD because of public's
concerns.
Fed = 500 hrs.
Contr. = None
Est'd Savings = None
Type of Change: From - The ROD called for the extraction and treatment of contaminated groundwater and discharge of the treated
groundwater to Ligonee Creek/Inner Sag Harbor Cove; To - Instead, all treated groundwater will be discharged into a recharge basin
that will be constructed on a Town of Southampton-owned property located adjacent to Sag Harbor Industries..
Factual Basis: In response to public concern regarding a freshwater discharge into saltwater environment, EPA decided not to
discharge any treated groundwater to Ligonee Creek and Sag Harbor Cove.
9/29/95
10/19/01 BSD
6/01
10/01
EPA
Groundwater
Full State involvement;
community expressed
no opinion.
Fed = 100 hrs.
Contr. = None
Est'd Savings =$1.1M
A 1
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Type of Change: From - The ROD for groundwater called for the extraction and onsite treatment of the high levels of acetone and the
performance of a study to determine if natural attenuation1 could reduce the VOC plume to groundwater standards within a reasonable
time frame. The remedy also included the construction of a groundwater extraction and treatment system if it was determined that
natural attenuation had little potential to reduce the VOC concentrations to groundwater standards; To - In-place treatment combined
with natural attenuation.
Factual Basis: Data collected during pre-Remedial Design sampling groundwater investigations revealed the presence of several
localized areas of groundwater contamination characterized by high levels of acetone and a VOC plume downgradient of these areas.
Natural attenuation is the use of natural processes, such as degradation, dispersion, and dilution, to reduce contaminant
concentrations to levels that are protective of human health and the environment.
A 1
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 2
Volney Municipal
Landfill, NY
Date of
Original ROD
Date of Change
(ESD/ROD-A)
7/31/87
9/29/89 FDD
8/97 BSD
10/19/01 BSD
Date Review
Commenced
Date Review
Completed
9/01
10/01
Change
Initiator
EPA, PRPs
Media
Groundwater
State/Community
Involvement
Full State involvement;
community expressed
no opinion.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 400 hrs.
Contr. = None
Est'd Savings = None
Type of Change: From- The 1987 ROD, as modified by the 1989 Post-Decision Document (FDD) and 1997 BSD, called for
groundwater extraction and treatment, on an as needed-basis, to address the intermittent groundwater contamination located
downgradient from the landfill. The ROD also called for long-term monitoring and a supplemental investigation to evaluate the
potential for the migration of contaminants in the groundwater and to the surface water and sediments of the adjacent Bell Creek and
wetlands surrounding the site; To - Extraction and treatment, in combination with natural attenuation, would adequately address the
site-related groundwater contamination and a supplemental groundwater remedy does not need to be implemented.
Factual Basis: Based upon the results of that investigation, it was determined that intermittent groundwater extraction and treatment in
combination with natural attenuation would adequately address the site-related groundwater contamination.
Region 2 - FY 03
Region 2
D'Imperio Property, NJ
3/27/85
7/3/03 ROD-A
4/98
7/03
EPA, PRPs
Soil
Full State and
community
involvement.
Fed = 250 hrs.
Contr. = None
Est'd Savings = $0.3M
Type of Change: From - The ROD called for excavation of contaminated soils, the construction of a RCRA cap after the excavation of
soils, and the installation of a groundwater treatment system. It was determined after the excavation phase to proceed with the
groundwater treatment system because the data at the time revealed that the groundwater plume had migrating even further downstream
than expected. Following the completion of the groundwater treatment system in 1997, a soil study was initiated; To - From the results
of that study, EPA decided to delineate the remaining soils by ordering the responsible parties to initiate a soil investigation. An
evaluation report was prepared which compared several other alternatives to the final component (RCRA cap) of the selected remedy.
Factual Basis: A soil study was initiated to determine the quality and quantity of the remaining contaminated soils.
A 1
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 2
Griffiss Air Force Base,
Bldg. 214, NY
Region 2
Griffiss Air Force Base,
Bldg. 2 19, NY
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/30/99
9/26/03 BSD
Date Review
Commenced
Date Review
Completed
6/03
9/03
Change
Initiator
Air Force
Media
Groundwater
State/Community
Involvement
Full State involvement.
Community expressed
no major interest.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = Limited
Contr. = None
Est'd Savings = No
Change
Type of Change: From - Evaluate groundwater further; To - Groundwater ARARs have been met and no further action for
groundwater.
Factual Basis: Recent groundwater data.
9/30/99
9/26/03 BSD
6/03
9/03
Air Force
Groundwater
Full State involvement.
Community expressed
no major interest.
Fed = Limited
Contr. = None
Est'd Savings = No
Change
Type of Change: From - Evaluate groundwater further; To - Groundwater ARARs have been met and no further action for
groundwater.
Factual Basis: Recent groundwater data.
A 1
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 2
Griffiss Air Force Base,
Bldg. 222, NY
Region 2
Griffiss Air Force Base,
Bldg. 255, NY
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/27/01
9/26/03 BSD
Date Review
Commenced
Date Review
Completed
6/03
9/03
Change
Initiator
Air Force
Media
Groundwater
State/Community
Involvement
Full State involvement.
Community expressed
no major interest.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = Limited
Contr. = None
Est'd Savings = No
Change
Type of Change: From - Original ROD was for soils only and required the GW to be further evaluated under the On-Base, GW-AOC
Operable Unit. This On-Base, GW-AOC ROD will include not only the Bldg. 222 area, but all GW areas on base. However, this ROD
will not be issued for 1-2 years. Recent GW data pertaining to Bldg. 222 indicates that ARARs for GW have been met.; To - an BSD
was performed on the Bldg. 222 soils only ROD to include GW. The BSD indicates that GW ARARs have been met and No Further
Action for GW is required.
Factual Basis: Recent GW data pertaining to Bldg. 222 indicates that ARARs for GW have been met and No Further action for GW
required for Bldg. 222.
9/27/01
9/26/03 BSD
6/03
9/03
Air Force
Groundwater
Full State involvement.
Community expressed
no major interest.
Fed = Limited
Contr. = None
Est'd Savings = No
Change
Type of Change: From - Original ROD was for soils only and required the GW to be further evaluated under the On-Base, GW-AOC
Operable Unit. This On-Base, GW-AOC ROD will include not only the Bldg. 255 area, but all GW areas on base. However, this ROD
will not be issued for 1-2 years. Recent GW data pertaining to Bldg. 255 indicates that ARARs for GW have been met.; To - an BSD
was performed on the Bldg. 255 soils only ROD to include GW. The BSD indicates that GW ARARs have been met and No Further
Action for GW is required.
Factual Basis: Recent GW data pertaining to Bldg. 255 indicates that ARARs for GW have been met. Therefore, an BSD was
performed on the Bldg. 255 soils only ROD to include GW.
A 1
in
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 2
Higgins Disposal, NJ
Region 2
Roebling Steel, NJ
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/30/97
12/9/02 BSD
Date Review
Commenced
Date Review
Completed
6/99
12/02
Change
Initiator
EPA, PRPs
Media
Groundwater
State/Community
Involvement
Full State and
community involvement
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 120 hrs.
Contr. = None
Est'd Savings = $1.6M
Type of Change: From - The ROD called for the installation of extraction wells, construction of a one and a half mile pipeline for
pumping groundwater contaminated with volatile organics (plus some semi-volatile organics) to the treatment and disposal via surface
discharge. The selected remedy also called for the extension of the water supply line to 13 residents including the Higgins property on
Laurel Avenue. The water supply line extension was completed in 1998; To - Extract groundwater, on-site treatment, and reinjection
of treated water into the aquifer system.
Factual Basis: The remedy update resulted from new data collected during the pre-design investigation and a focused feasibility study.
9/26/91
9/30/03 ROD-A
8/97
9/03
EPA
Soil
Full State and
community involvement
Fed = Unknown
Contr. = Unknown
Est'd Savings = $32.0M
Type of Change: From - The ROD for the Slag Area called for treating hot spots through stabilization (defined by TCLP testing),
covering the 34-acre Slag Area with a soil cap and vegetation, installing a stormwater management system and shoreline protection,
and using institutional controls; To - The ROD amendment removes only the treatment component.
Factual Basis: EPA determined that the TCLP test used as a basis for defining hot spots, was not a good indicator of the leaching
behavior in the Slag Area. Instead, the analytical results from the hot spot delineation, groundwater, surface water and sediment
investigations would be more relevant.
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11
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 2
Stanton Cleaners Area
Groundwater
Contamination Site, NY
Date of
Original ROD
Date of Change
(ESD/ROD-A)
3/31/99
9/25/03 BSD
Date Review
Commenced
Date Review
Completed
9/02
9/03
Change
Initiator
EPA
Media
Groundwater
State/Community
Involvement
State and the
community concurred.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = None
Contr. = None
Est'd Savings = None
Type of Change: From - Extract and treat groundwater, long-term monitoring and groundwater use restrictions; To - No further
response for off-site sources of groundwater.
Factual Basis: The results of Investigation Summary Report generated the remedy update
Region 3 - FY 02
Region 3
Abex Corp., VA
9/29/92
8/15/94 ROD-A
10/15/95 BSD
8/27/02 BSD
4/00
8/02
PRP
Soil
State and City of
Portsmouth and
Portsmouth Regional
Housing Authority
involvement.
Fed = 75 hrs.
Contr. = None
Est'd Savings = $2.0M
Type of Change: From - Residential cleanup standards for the Washington Park Housing Complex soils and debris; To -
Commercial/Industrial cleanup standards for the Washington Park Housing Complex soils and debris.
Factual Basis: The Washington Park Housing Complex was demolished and the residents were relocated permanently. The City of
Portsmouth and the Portsmouth Redevelopment and Housing Authority requested that residential cleanup standards be changed to
commercial/industrial standards to facilitate the site's development.
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19
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 3
Palmerton Zinc Pile, PA
Region 3
Saegertown Industries
Area, PA
Region 3
Whitomoyer Laboratories
OU3, PA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/29/88
8/27/02 BSD
Date Review
Commenced
Date Review
Completed
1995
8/02
Change
Initiator
PRP
Media
Soil
State/Community
Involvement
State concurrence
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 75 hrs.
Contr. = None
Est'd Savings = $7.5M
Type of Change: From - A Cinder Bank cap of soils and clay or soil/bentonite mixture; To - A Cinder Bank cap consisting of
Ecoloam.
Factual Basis: The original ROD required a more sophisticated cap to extinguish fires within the Cinder Bank. Subsequent Air Quality
studies revealed that fires were not causing a significant impact on Air Quality so the Ecoloam cap was deemed sufficient to maintain
Cinder Bank stabilization. Burning portions will be monitored to determine need for further controls.
1/29/93
9/30/02 ROD-A
1998
9/02
PRP
Groundwater
State concurrence and
public meeting.
Fed= 150 hrs.
Contr. = None
Est'd Savings = $7.2M
Type of Change: From - Extraction and treatment of groundwater and air sparging/vacuum extraction; To - Enhanced bio-
remediation of VOCs in GW using a molasses-based carbon source and monitoring; on going operation and monitoring of domestic
well treatment system; and institutional controls (safety and health management planning and groundwater use restrictions).
Factual Basis: The PRP demonstrated that the molasses-based carbon source could enhance biodegradation of VOCs in groundwater to
promote natural attenuation. Some well treatment and groundwater use restrictions are still required.
12/31/90
4/16/02 ROD-A
2/01
2/02
PRP
Soil
State approval and
public meeting prior to
ROD-A.
Fed = 150 hrs.
Contr. = None
Est'd Savings = $1.2M
Type of Change: From - Excavation of contaminated, unsaturated soils; To - Use of an asphalt cover to stabilize and maintain
contaminated, unsaturated soils. New roadway will be inspected regularly to ensure the integrity of the cover. Deed restrictions will be
used where contaminated soils remain.
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Factual Basis: Excavation of the contaminated soils would have required the closing of an access roadway to local residents and the
possibility of contact with utility (electric, gas and water) lines. An asphalt cover, continuously maintained with concurrent deed
restrictions, is the preferred alternative.
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14
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Region 3 - FY 03
Region 3
Berks Sand Pit, PA
Region 3
Brown's Battery Breaking
Site, OU2, PA
9/24/88
2/2/94 BSD
9/14/01 BSD
1/6/03 BSD
2/01
2/02
EPA
Groundwater,
Air
State involvement.
Fed = 75 hrs.
Contr. = None
Est'd Savings = $8.0K
Type of Change: From - Air stripping using a vapor phase granulated activated carbon unit (VPGAC); To - Air stripping without
VPGAC.
Factual Basis: Contamination levels have decreased to the extent that the VPGAC is not considered to be necessary for the continued
successful operation of the remedy. EPA's calculated weight of contaminants and the modeled risks from the emission levels are below
Federal and State levels.
7/2/92
7/30/03 ROD-A
6/96
6/03
PRP
Groundwater
State and Tilden
Township, PA
involvement.
Fed = 150 hrs.
Contr. = None
Est'd Savings = $2.4M
Type of Change: From - Install a vertical limestone barrier in the alluvial aquifer; Pump and treat onsite the contaminated groundwater
from the bedrock aquifer. Allow for infiltration of clean water to the alluvial zone to increase groundwater velocity; To - Injection of
in-situ treatment agents directly into the alluvial and bedrock units. Eliminate vertical limestone barrier and pump and treat of
contaminated groundwater. Eliminate need for infiltration of clean water to the alluvial zone increase groundwater velocity.
Factual Basis: This remedy update was initiated due to the results of monitoring in predesign investigation, results of hydraulic testing,
and bench-scale testing.
A 1
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 3
Brown's Battery Breaking
Site OU2, PA
Region 3
Delaware Sand & Gravel,
DE
Region 3
Hunterstown Road, PA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
7/2/92
9/25/03 BSD
Date Review
Commenced
Date Review
Completed
2002
2003
Change
Initiator
EPA
Media
Soil
State/Community
Involvement
State and Tilden
Township, PA
involvement.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 75 hrs.
Contr. = None
Est'd Savings = None
Type of Change: From - Excavation of all soil exceeding lOOmg/kg of lead; To - During the removal action, EPA determined that
excavation of the soil in the vicinity of a railroad track could determine rail right-of-way. Instead of further excavation, the BSD calls
for: 1) Add a 2 foot soil cover on the contaminated portion of the railroad embankment; 2) Implement institutional controls (site use
restrictions); and 3) Extend site use restrictions to the rail embankment.
Factual Basis: Confirmation sampling and a successful pilot-test resulted in the remedy update.
4/22/88
9/30/92 ROD-A
7/8/03 ROD-A
2003
2003
EPA
Building
Materials, Soil
State and New Castle,
DE involvement.
Fed = 75 hrs.
Contr. = None
Est'd Savings = $500
Type of Change: From - Deed restrictions on use of the drum area and any future use of the drinking water wells at the site; To - EPA
wants to change "Deed Restrictions" to "Institutional Controls" as a replacement in the ROD Amendment. Change is of terminology
only. Same restricted areas apply.
Factual Basis: The original ROD omitted a requirement to establish institutional controls at the disposal area.
8/2/93
8/25/98 BSD
3/22/01 BSD
8/1 1/03 BSD
12/17/02
8/5/03
PRP
Groundwater,
Air
State involvement.
Fed = 75 hrs.
Contr. = None
Est'd Savings = $1.4M
Type of Change: From - Air stripping utilizing a catalytic off-gas treatment system; To - Air stripping utilizing a vapor phase carbon
adsorption system for treating off gases.
Factual Basis: The design phase improvement resulted because the vapor phase carbon absorption system is less costly than the
catalytic off-gas treatment system.
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IfS
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 3
Welsh Road Landfill
OU1, PA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/30/90
7/2/03 ROD-A
Date Review
Commenced
Date Review
Completed
6/99
10/02
Change
Initiator
PRP
Media
Soil,
Groundwater
State/Community
Involvement
State and Honeybrook,
PA involvement.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 75 hrs.
Contr. = None
Est'd Savings = $1.2M
Type of Change: From - Multi-media Cap; razor or barbed wire on perimeter fencing; To - Install Evaporation/Transpiration Cap;
long- term groundwater monitoring; surface water management controls; demolition of structures and debris removal; remove razor of
barbed wire fencing.
Factual Basis: Change during Remedial Design negotiations.
Region 4 - FY 02
Region 4
Rochester Property, SC
9/28/99
1/29/02 ROD-A
5/00
1/02
DOE
Groundwater,
Soil
State concurred on
Proposed Plan. Public
comment period.
Fed = 40 hrs.
Contr. = None
Est'd Savings = $1.4M
Type of Change: From - In-situ groundwater treatment and on-site biotreatment of contaminated soils; To - Monitored natural
attenuation of groundwater and off-site disposal of contaminated soils.
Factual Basis: After the contaminated soils were excavated and placed in the biotreatment area, ground water monitoring indicated
that natural attenuation was occurring. During biotreatment operation and maintenance, it was determined that treatment costs were
going to be significantly higher than planned. Off-site disposal was found to be more cost effective.
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17
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 4
Savannah River Site/CMP
Pits, OU24, SC
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/28/99
1/29/02 ROD-A
Date Review
Commenced
Date Review
Completed
5/00
1/02
Change
Initiator
DOE
Media
Groundwater,
Soil
State/Community
Involvement
State concurred on
Proposed Plan. Public
comment period
conducted.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 40 hrs.
Contr. = lOhrs.
Est'd Savings = $5.6M
Type of Change: (1) From - Soil excavation with off-site disposal; To - Limited soil excavation/off-site disposal and evaluation of on-
site treatment options.
(2) From - Treatment of vadose zone soils with soil vapor extraction (SVE) and an asphalt cover; To - Soil vapor
extraction without the asphalt cover.
(3) From - Groundwater hot spot treatment with air sparging and SVE; To - Defer treatment to final groundwater
remedy.
Factual Basis: (1) The discovery of Silvex (F-025) in contaminated soils limited off-site disposal options.
(2) New data indicated the presence of DNAPL that requires further characterization.
(3) the water table dropped below a low permeability clay zone that renders air sparging ineffective.
Region 4 - FY03
Region 4
Aberdeen Pesticide
Dumps, NC
10/7/93
9/30/03 ROD-A
1/01
9/03
PRP
Groundwater
State concurred. Public
notice in local paper,
30- day public comment
period and public
meeting.
Fed = 200 hrs.
Contr. = None
Est'd Savings = $2.0M
Type of Change: From - Pump and treat; To - Monitored Natural Attenuation.
Factual Basis: A noted reduction in groundwater concentrations, over five year period, and results of groundwater modeling initiated
this remedy update.
A 1
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 4
Koppers Company, Inc.
(Charleston Plant), SC
Region 4
Leonard Chemical
Company, Inc., SC
Date of
Original ROD
Date of Change
(ESD/ROD-A)
4/29/98
4/24/03 BSD
Date Review
Commenced
Date Review
Completed
1/02
4/03
Change
Initiator
PRP
Media
Groundwater,
Sediments
State/Community
Involvement
State concurred. Fact
sheet mailed and public
notice in local paper.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 100 hrs.
Contr. = None
Est'd Savings =$0.4M
Type of Change: From - Pump and treat of NAPL and capping of sediments To - In situ solidification/stabilization of NAPL
containing soils and monitored natural siltation covering of contaminated sediments.
Factual Basis: Additional site data collected during the development of the Remedial Design.
8/20/01
2/13/03 BSD
1/02
2/03
PRP
Groundwater
State concurred. Public
notice in local paper.
Fed = 80 hrs.
Contr. = None
Est'd Savings = None
Type of Change: From - Groundwater cleanup level developed by risk calculations. To - Cleanup level based on results from site
specific leaching test data.
Factual Basis: The remedy update was initiated due to site-specific soil leaching test data.
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1Q
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 4
Savannah River Site
(CRSB, OU60), SC
Region 4
Savannah River Site
(LRSB, OU65), SC
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/28/99
10/23/02 ROD-A
Date Review
Commenced
Date Review
Completed
4/02
10/02
Change
Initiator
DOE
Media
Soil
State/Community
Involvement
State concurred. Public
notice in local paper,
30- day public comment
period and public
meeting.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 80 hrs.
Contr. = 40 hrs.
Est'd Savings = Unknown
Type of Change: From - In situ soil stabilization To - Soil capping.
Factual Basis: Radioactive decay of contaminants in soil was determined to occur at a faster rate.
9/28/99
10/23/02 ROD-A
4/02
10/02
DOE
Soil
State concurred. Public
notice in local paper,
30- day public comment
period and public
meeting.
Fed = 80 hrs.
Contr. = 40 hrs.
Est'd Savings = Unknown
Type of Change: From - In situ soil stabilization; To - Soil capping.
Factual Basis: Radioactive decay of contaminants in soil was determined to occur at a faster rate.
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Region 5 - FY 02
Region 5
Byron Salvage Yard, IL
Region 5
Feed Materials Production
Center (USDOE), OH
9/24/98
9/20/02 BSD
2002
9/02
EPA
Soil
State concurred with
BSD
Fed = 100 hrs.
Contr. = Unknown
Est'd Savings =Unknown
Type of Change: From -Five areas of the site designated for capping in the 1998 ROD. Based on pre-design sampling; To - Excavate
and remove metal contaminated soil from north disposal area of the Dirks Farm Property (DFP). Therefore capping and long-term
maintenance of the cap is not required for the former DFP north disposal area.
Factual Basis: There is no need to cap metal-contaminated soils on the salvage yard portion of the site. Based on the pre-design
sampling, the PRPs, with USEPA concurrence, also found it more cost effective and equally protective.
1/31/96
11/29/01 BSD
12/00
11/01
DOE
Groundwater
State concurred. Citizen
involvement.
Fed = 100 hrs.
Contr. = Unknown
Est'd Savings = $3. 5M
Type of Change: To - The BSD signed on 1 1/29/01 was a change in the final remedial level for uranium in the aquifer from 20
micrograms per liter to 30 micrograms per liter.
Factual Basis: This remedy update resulted because the proposed Maximum Contaminant Level (MCL) under the Safe Drinking Water
Act went final on 12/7/00 and the MCL went from 20 to 30. This change resulted in no significant increased risk and will reduce the
groundwater cleanup time by approximately 5 years, saving $3.5 million.
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91
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Industrial Excess Landfill,
OH
Region 5
Michigan Disposal
Service, MI
Date of
Original ROD
Date of Change
(ESD/ROD-A)
7/17/89
3/1/00 ROD-A
9/27/02 ROD-A
Date Review
Commenced
Date Review
Completed
3/00
9/02
Change
Initiator
EPA
Media
Soil,
Groundwater
State/Community
Involvement
State concurred
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 200 hrs.
Contr. = Unknown
Est'd Savings = $6.5M
Type of change: From - The March 2000 ROD Amendment was initiated as a result of new groundwater data obtained during the
remedial design. New RD groundwater data revealed that the contamination was no longer outside the boundaries of the landfill. The
March 2000 ROD Amendment ceased operation of the pump & treat system, added monitored natural attenuation and simplified the
engineering cap.
In June 2000, a local community group received a redevelopment grant from EPA and therefore, redevelopment initiatives for the site
began to increase. The PRPs petitioned EPA to change the conventional engineering cap and enhanced vegetative cover to further
encourage site redevelopment ; To - Augment existing vegetation cover natural attenuation (NA) for groundwater monitor.
Groundwater and landfill gas, deed restrictions on site use, maintain alternate water supply.
Factual Basis: Results of groundwater surveys and limited radiation testing of groundwater.
9/30/91
9/25/02 ROD-A
2002
9/02
EPA
Groundwater
State concurred
Fed = 200 hrs.
Contr. = Unknown
Est'd Savings = $1.2M
Type of Change: From - Pump and treat groundwater and discharge; To publicly -owned wastewater treatment facility.
Factual Basis: Pre-design studies to update the vertical and horizontal extent of the contaminated groundwater showed that the quality
of groundwater discharging from the site was no longer causing and environmental risk to Davis Creek. The groundwater study
provided data to support the MDEQ's Mixing Zone Determination (MZD) evaluation and approval. The information collected in the
pre-design studies, in conjunction with supplemental groundwater quality and stream flow data analysis, provided data to support
changes in the cleanup action for groundwater at the site.
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99
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Onalaska Municipal
Landfill, IL
Region 5
Thermo-Chem, Inc., MI
Date of
Original ROD
Date of Change
(ESD/ROD-A)
8/14/90
11/13/01 BSD
Date Review
Commenced
Date Review
Completed
9/00
11/00
Change
Initiator
State
Media
Groundwater,
Landfill waste
State/Community
Involvement
State and community
involvement.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 100 hrs.
Contr. = Unknown
Est'd Savings = $0.2M
Type of Change: From - Groundwater extract and treat and bioremediation system (with air stripping); To - The BSD allows for the
temporary shut down of the pump and treat system to study monitored natural attenuation as a long-term remedy for the site.
Factual Change: Groundwater data collection in 2000 indicated that only iron and select metals were still above the state standards.
9/30/91
9/17/02 BSD
1995/1996
9/02
EPA
Groundwater
State concurred
Fed = 100 hrs.
Contr. = Unknown
Est'd Savings = None
Type of Change: From - In the 1991 ROD, OU1 focused on contaminated soil, sludge and groundwater at the site up to the Black
Creek. OU2 addressed contamination in Black Creek, i.e., surface water sediment, plants, living organisms and groundwater of Black
Creek; To - U.S. EPA combined OU1 and OU2 with an BSD based on the following findings: the Groundwater Extraction and
treatment System (GWETS) in the ROD stops the flow of contaminated groundwater to the Black Creek flood plain and the
groundwater contaminant levels beneath the flood plain will continue to decline due to natural dilution and dispersion of contaminants;
naturally occurring biological and/or chemical processes.
Factual Basis: The groundwater cleanup standards in the ROD were based on Type B standards pursuant to Michigan Environmental
Response Act, PA 307 of 1982, as amended (Michigan Act 307). In 1994, Michigan Act 307 became Part 201, Act 451. Part 201 was
amended in 1995 which lead to a change in the groundwater cleanup standards for many compounds.
A 1
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Region 5 - FY 03
Region 5
Buckeye Reclamation, OH
Region 5
Continental Steel, IN
1991
8/15/03 BSD
9/02
11/03
EPA
Groundwater,
Surface water
State involvement
Fed = 100 hrs.
Contr. = Unknown
Est'd Savings = $8.5M
Type of Change: From - The ROD provided for the installation of a leachate and groundwater collection system to intercept acid mine
drainage (AMD), leachate and surface water from the landfill areas and channel it to the treatment system; To - The BSD stated that no
additional groundwater/leachate collection/treatment mechanisms are required.
Factual Basis: The settling defendants completed four quarterly monitoring events for surface water and leachate flow and quality, to
determine the need for additional or modified groundwater/leachate collection mechanisms and/or groundwater/leachate treatment.
The results of this study indicated that no treatment of these streams is currently required.
9/30/98
9/26/03 ROD-A
3/03
4/03
State
Soil,
Groundwater,
Sediments
State involvement
Fed = 200 hrs.
Contr. = Unknown
Est'd Savings = None
Type of Change: From -Remove lead contaminated soil; To - The ROD Amendment will: 1) Incorporated remedial action goals
initially developed and presented in the baseline human health risk assessment, 2) Incorporate a more stringent remedial action goal for
PCBs in the creeks, 3) An MCL for arsenic as a groundwater cleanup goal, 4) Formalize reorganization of the project management
strategy from former geographic approach (OUs) to a task-based approach based on similar activities, and 5) More stringent remedial
action goals for OUS (Main Plant) that will be protective under a recreational use scenario.
Factual Basis: Additional sampling results during design resulted in the remedy update.
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94
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Feed Materials Production
Center (USDOE),OU1,
OH
Region 5
Feed Materials Production
Center (USDOE),OU4,
OH
Date of
Original ROD
Date of Change
(ESD/ROD-A)
3/1/95
11/7/02 BSD
Date Review
Commenced
Date Review
Completed
11/01
11/02
Change
Initiator
DOE
Media
Waste
State/Community
Involvement
State concurred. Citizen
involvement.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 100 hrs.
Contr. = Unknown
Est'd Savings = $2.0M
Type of Change: From - Off-site treatment and truck shipment for disposal; To - The BSD signed in 2002 integrated the processing of
various waste streams on-site through the Operable Unit 1 infrastructure of thermally drying the waste and shipping the materials off-
site via rail to Envirocare of Utah.
Factual Basis: The processing of the materials through the existing treatment, shipping and disposal infrastructure as opposed to off-
site treatment and truck shipment for disposal, will save $2 million.
12/7/94
9/24/03 ROD-A
8/02
9/03
DOE
Waste
State concurred. Citizen
involvement
Fed = 200 hrs.
Contr. = Unknown
Est'd Savings = $13.0M
Type of Change: From - Cement stabilization; To - The ROD-A was a result of off-site disposal facilities (Nevada Test Site) changing
its waste acceptance criteria to not require treatment for TCLP; and Envirocare being able to receive untreated Silo 3 waste material in
its disposal cell. This resulted in the need for only minimal treatment, as opposed to cement stabilization to meet TCLP. Further this
minimal treatment resulted in the ability to ship the waste to Envirocare.
Factual Basis: A change in acceptance criteria by the disposal facility resulted in the remedy update.
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 5
H.O.D. Landfill, IL
Region 5
Joliet Army Ammunition
Plant, IL
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/28/98
8/28/03 BSD
Date Review
Commenced
Date Review
Completed
8/02
8/03
Change
Initiator
EPA
Media
Soil
State/Community
Involvement
State concurred
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 100 hrs.
Contr. = Unknown
Est'd Savings =
$20,000/10 year period
Type of Change: From - Contaminant through leachate and gas extractions, waste cap improvements and ground water- monitored
natural attenuation; To - BSD only changed the fencing and access requirements. BSD allowed for removal offence from 120 acre
property (that includes 51 -acre landfill) and replacement around the operation and maintenance facility (flare and building, leachate
tank and pump out area). BSD also required that flust-mounted methane/leachate collection vaults to be secured (locked). Monitored
natural attenuation.
Factual Basis: Post-construction risk assessment quantified specific risks associated with recreational reuse as acceptable.
11/4/98
6/25/03 BSD
6/02
4/03
Army
Groundwater
State concurred
Fed = 100 hrs.
Contr. = Unknown
Est'd Savings = None
Type of Change: From - The selected remedy for groundwater at site MI Limited Action, which included natural attenuation,
establishment of a Groundwater Management Zone (GMZ), deed restrictions, and monitoring. The ROD specified the GMZ to
encompass the known extent and suspected migration of contaminated groundwater. The GMZ boundaries serve as the point of
compliance for meeting the Remedial Goals (RGs) established in the ROD for contaminants in groundwater; To - The BSD addresses
contaminated groundwater at Site Ml, the Southern Ash Pile.
Factual Basis: Sulfate was found after the ROD was signed, at concentrations exceeding the RG at the GMZ boundary. The BSD
expanded the GMZ boundaries to include 49 additional acres in order to prevent potential groundwater withdrawals.
A 1
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Organic Chemical, MI
Date of
Original ROD
Date of Change
(ESD/ROD-A)
2/5/97
9/29/03 BSD
Date Review
Commenced
Date Review
Completed
1998
2/01
Change
Initiator
EPA
Media
Soil,
Groundwater
State/Community
Involvement
Unknown
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 100 hrs.
Contr. = Unknown
Est'd Savings = $0.3M
Type of Change: From - The ROD estimated that approximately 6,000 cubic yards of soils would exceed the cleanup the cleanup
levels and need to undergo solidification/stabilization prior to on-site disposal. The ROD also allowed for a small part of this volume
of soils which needed to be removed from the site to meet the established cleanup levels was determined to be removed from the site to
meet the established cleanup levels was determined to be approximately 2,500 cubic yards; To - This BSD also allows for a
modification concerning the requirement for treatment of contaminated soils by solidification/stabilization prior to on-site disposal.
Factual Basis: Sampling and excavation of soils at the site revealed that a significant volume (1,000 cubic yards) of soils may either
contain higher levels of contamination or contain enough waste material that solidification/stabilization would be difficult or
impossible to implement. During design, the PRPs compared the costs of off-site disposal of all soils to the costs of
solidification/stabilization and on-site disposal and identified significant savings for off-site disposal.
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97
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Sauget Area 2, ILL
(Sauget & County
Landfill, Site Q), OU2, IL
Region 5
Seymour Recycling Site,
IN
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/30/02
7/30/03 BSD
Date Review
Commenced
Date Review
Completed
4/03
7/03
Change
Initiator
EPA
Media
Groundwater
State/Community
Involvement
State concurred
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 100 hrs.
Contr. = Unknown
Est'd Savings = $1.4M
Type of Change: From - EPA issued its Interim ROD and a Unilateral Order with a selected interim remedy for OU2. The Interim
ROD and order called for the installation of a 3,500 foot long, 140 foot deep "U"- shaped jet grout physical barrier between the down
gradient boundary of site R and the Mississippi River. This limited -scope action is intended only address the release of contaminated
groundwater into the Mississippi River in the vicinity of site R. A final response action to address fully any additional threats posed by
conditions at the Site will be evaluated upon completion of the Area 2 Site RI/FS.
The use of a slurry wall as a physical barrier was screened out in the original FS based on the uncertainty identified with the use of this
technology (the ability to construct the wall to a depth of 140 feet below surface, to key the wall into the bedrock, and the use of the
excavated soil as a backfill in the slurry trench); To - On April 24, 2003, PRP submitted to U.S. EPA a Technical Memorandum
regarding the implementation of conventional soil-bentonite slurry wall instead of jet grout wall. The PRP demonstrated that the
integrity of the finished product as jet grouting. The slurry wall is estimated to be between 15 to 20% less expensive then the jet grout
wall.
Factual Basis: The remedy update was initiated following the release of a PRP technical memorandum.
9/30/87
12/24/02 BSD
1/02
12/02
PRP
Groundwater
State involvement
Fed = 200 hrs.
Contr. = Unknown
Est'd Savings = $1.5M
Type of Change: From -The groundwater pump & treat system operated for 12 years, and was no longer the most efficient method to
remediate the groundwater; To - As a result, it was shut down and the plume was allowed to naturally degrade and attenuate. The
remedy change added sampling requirements, as well as a contingency to restart the groundwater treatment system if necessary.
Factual Basis: collection of data for 5 year review inspection.
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Verona Well Field, MI
Region 5
Wheeler Pit, WI
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/28/91
9/28/03 BSD
Date Review
Commenced
Date Review
Completed
3/94
6/03
Change
Initiator
PRP
Media
Soil,
Groundwater
State/Community
Involvement
State and City of Battle
Creek involvement.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 100 hrs.
Contr. = Unknown
Est'd Savings = $0.5M
Type of Change: From - The blocking wells and two source area cleanups are being conducted by PRPs under Unilateral
Administrative Orders; To - EPA and the PRPs are working on a Consent Decree to address all final issues. Because the State has
made oversight of this site a priority, EPA is using State technical staff instead of contractors for technical support for oversight. The
State oversight costs are being reimbursed under a separate agreement between the state and the PRPs if the consent Decree is
approved. One of the source area pump-and-treat systems is continuing to operate using State funds, as the 10 year period for a long-
term response action was completed.
Factual Basis: New groundwater cleanup standards became effective through Michigan's new Part 201 law. Also updated toxicity
data and additional groundwater and soil sampling data demonstrated decreased VOC concentrations in the downgradient plume
through natural attenuation processes. In addition, MDEQ determined that RCRA was applicable to the contaminated groundwater
transport in the pipeline.
9/30/90
6/16/03 BSD
11/00
6/03
PRP
Groundwater
State concurred
Fed = 100 hrs.
Contr. = Unknown
Est'd Savings = $70K
Type of Change: From - The groundwater remedy selected in the ROD was natural attenuation. Groundwater cleanup goals for all
groundwater contaminants have been achieved, with the exception of manganese; To -The BSD determined that for number of reasons,
manganese could be eliminated as a site contaminant of concern and thus, groundwater cleanup is now complete.
Factual Basis: Results of a five-year review indicated that a remedy update was needed.
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9Q
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Region 6 - FY 02
Region 6
Koppers Company Inc.,
Texarkana Plant, OU3,
TX
9/23/88
3/4/92 ROD-A
8/20/02 BSD
7/02
8/20/02
PRP, City of
Texarkana
Groundwater
Community Advisory
Group (CAG)
Representative
contacted
Fed = Unknown
Contr. = Unknown
Est'd Savings = $5.0M
Type of Change: From - Use of surfactant to mobilize DNAPLs surface treatment of collected groundwater/NAPL emulsion; To -
Remove use of surfactant and surface treatment use subsurface groundwater separator, reinfiltration back into aquifer to enhance NAPL
mobility.
Factual Basis: Additional data was collected during design.
Region 6 - FY 03
Region 6
Sheridan Disposal
Services Site, OU1, TX
12/29/88
12/4/02 ROD-A
4/97
12/02
PRP
Sludges, Soil
State concurred with
amended remedy on
9/19/02. No adverse
public comments
Fed = Unknown
Contr. = Unknown
Est'd Savings = $9.9M
Type of change: From - Biotreatment, solidification/stabilization and capping of waste; To - In-situ solidification/stabilization and
capping of waste. With the exception of eliminating the biotreatment step, all portions of the 1998 ROD remedy are included in the
amended remedy.
Factual Basis: The decision to eliminate the biotreatment of site waste is based on new information submitted by the responsible
parties and included the following considerations: 1) the biotreatment portion of the remedial action was never initiated, 2) the original
remedy included a stabilization and capping component, 3) bioremediation would not remove poly chlorinated biphenyls, and 4)
advances in remedial technologies provide an alternate remedy (without the use of bioremediation) that is of at least equal protection to
human health and the environment. In addition, EPA Region 6 successfully implemented the use of solidification/stabilization at two
similar Superfund sites.
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Region 7 - FY 03
Region 7
Conservation Chemical
Co., MO
9/30/87
1/28/03 BSD
1990
1/03
PRP
Groundwater
MDNR reviewed the
BSD and provided
concurrence
Fed = Unknown
Contr. = Unknown
Est'd Savings = Less than
1 percent
Type of change: From - Groundwater source utilizing hydraulic contaminant and specific treatment unit treatment requirements for
metals; To - Set plant effluent limits and eliminate sulfide system.
Factual Basis: The original remedy was operational for 12 years so some metal levels decreased substantially. Additionally, the results
of a pilot program to investigate metal effluent concentrations resulted in the remedy update.
Region 8 - FY03
Region 8
Central City, Clear Creek,
OU3, CO
9/30/91
6/5/03 ROD-A
1999
6/03
State
Surface water
Public and other
government entities
reviewed and
commented on ROD-A.
Fed = None
Contr. = None
Est'd Savings = None
Type of change: From - Passive treatment of Burleigh Tunnel and monitoring; To - No action with annual high-flow and low flow
water monitoring. State responsible for monitoring as part of long-term O and M.
Factual Basis: The remedy update operation and data collection from pilot scale wetland system. Zinc concentrations were observed
below Clear Creek aquatic stream standards.
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 8
Marshall Landfill, CO
Date of
Original ROD
Date of Change
(ESD/ROD-A)
1986
1992 BSD
9/03 BSD
Date Review
Commenced
Date Review
Completed
1993
9/03
Change
Initiator
EPA
Media
Groundwater;
Surface water
State/Community
Involvement
State reviewed and
concurred with BSD
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = None
Contr. = None
Est'd Savings = None
Type of Change: From - Groundwater collect and treat; To - New groundwater standards for VOCs and to comply with updated state
surface water quality standards. Pump and treat continues.
Factual Basis: The remedy update documents new or changed ARARs. The original ARARs were no longer protective.
Region 9 - FY02
Region 9
Jasco Chemical Corp., CA
9/30/92
9/13/02 BSD
1998
9/02
EPA, PRP
Groundwater,
Soil
An BSD notice was
published in the local
newspaper. The State
concurred with the
remedy change.
Fed = Unknown
Contr. = $10K
Est'd Savings = $0.3M
Type of Change: From - Groundwater extract and treat via liquid phase carbon adsorption treatment unit soil extract and treat by
Enhanced Biological treatment and off-site disposal; To - Utilize on air stripper and vapor phase carbon adsorption treatment unit for
groundwater ; soil biotreatment.
Factual Basis: The remedy update meets NPDES requirements for groundwater and addressed the infeasibility of original soil remedy.
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 9
Waste Disposal Inc., OU1
and OU2, CA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
12/27/93
6/2 1/02 ROD-A
Date Review
Commenced
Date Review
Completed
5/01
6/02
Change
Initiator
EPA
Media
Groundwater,
Soil, Waste,
Air
State/Community
Involvement
State concurred. Public
comments were
addressed.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = Unknown
Contr. = Unknown
Est'd Savings = $0.8M
Type of Change: From - Excavation, reconsolidation and contaminant of waste using a RCRA equivalent capping system over the
reservoir with soil gas control and monitor; - To - Contain, collect, and treat gases; collect and remove site liquids; and institutional
controls.
Factual Basis: The remedy update was initiated due to new Feasibility Study information gathered after the ROD, expanded lateral
extent and volume, nature and increased extent of soil gas, and presence of liquids inside the buried concrete-lined reservoir.
Region 9 - FY03
Region 9
Selma Treating Co., CA
9/24/88
10/26/93 BSD
9/30/03 ROD-A
1999
9/03
EPA
Soil
State prefers the
amended remedy EPA
addressed public
comments.
Fed = $0.5M
Contr. = 120 hours
Est'd Savings = $2.5M
Type of Change: From - Soil would be executed, fixed, and consolidated on-site under a RCRA cap; To - Soil excavation down to five
feet; place in on-site impoundment, without fixation; covering with a RCRA cap; and backfill and cap excavated areas, and institutional
controls.
Factual Basis: Additional soil contamination was found to be present through focused Feasibility Study.
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 9
Valley Wood Preserving,
Inc., CA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/27/91
9/29/03 ROD-A
Date Review
Commenced
Date Review
Completed
4/00
9/03
Change
Initiator
EPA
Media
Soil
State/Community
Involvement
State concurred with
final cleanup standard
for soil. Public
comments included in
Administrative Record
file.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = $0.3M
Contr. = None
Est'd Savings = $2.5M
Type of Change: From - Excavate soil, fix with cement compound, backfill the fixated soil, and maintain mixture with an asphalt cap
and institutional controls ; To - Excavate and off-site disposal and backfill excavated areas with clean soil; new cleanup level for
arsenic in soil of 25mg/kg; eliminate soluble leachate soil cleanup numbers based on Designated Level Methodology (DLM); and new
institutional control to prohibit residential use.
Factual Basis: The land use was changed from residential to commercial/industrial. Additionally, cleanup levels for arsenic were
adjusted because of the results of the risk assessment.
Region 10 - FY02
Region 10
INEEL, OU Unit 8-08,
Naval Reactors Facility-
21 A, ID
9/29/98
7/1 1/02 BSD
12/01
7/02
Federal
Facility
Soil, Debris
State concurred
Fed = 150 hrs.
Contr. = None
Est'd Savings = $2. 1M
Type of Change: From - limited excavation, disposal, and contaminant of soil and debris; To - Present excavation will be secured and
filled, and an engineered cover will be constructed over basin.
Factual Basis: New information during 2000 and 2001 excavations revealed more contamination than originally thought.
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 10
McCormick and Baxter
(Portland Plant), OU3, OR
Region 10
Umatilla Chemical
Depot. Oregon.
Ammunition Demolition
Area (ADA) Sitel9E/F.
Date of
Original ROD
Date of Change
(ESD/ROD-A)
3/29/96
3/17/98 ROD-A
8/13/02 BSD
Date Review
Commenced
Date Review
Completed
2000
8/02
Change
Initiator
State, EPA
Media
Groundwater
State/Community
Involvement
State and tribe
commented on BSD and
their comments were
addressed in the new
design
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 450 hrs.
Contr. = $300K
Est'd Savings = None
Type of Change: From - NAPL extraction with a contingent impermeable barrier wall; To - Implementing the contingent barrier wall,
as well as monitoring, continued NAPL recovery, reevaluation of surface water goals and evaluation of alternative cap designs.
Factual Basis: The NAPL was not being contained through the recovery system so the contingency was triggered.
4/10/94
7/30/02 BSD
8/01
5/02
Army, EPA
Soil
30 day comment period
on the BSD. State
concurred with the
changes.
Fed = 80 hrs.
Contr. = None
Est'd Savings = $0.9M
Type of Change: From - For one part of the OU, onsite treatment and disposal, with risk-based cleanup levels based on a troop training
future land use scenario; To - For one part of the OU, offsite treatment and disposal, with risk-based cleanup levels based on a future
residential land use scenario.
Factual Basis: This BSD addresses one of five sites within the OU. During the initial remedial actions in 1996 & 1997, more
contamination was found than expected and the excavation and treatment of the area was not completed due to funding limitations. In
the intervening years, the anticipated future use for the area has changed from troop training to residential because of the facility's
BRAC status and new risk-based cleanup levels were developed. In addition, the on-base landfill has closed, making offsite treatment
and disposal necessary. A combination of new cleanup levels and better delineation of the nature and extent of soil contamination
through additional sampling in 2000, resulted in lower volume estimates to complete the remedial action than was projected in the
ROD. Once offsite treatment and disposal costs were accounted for, this resulted in an overall savings of approximately $900K.
A 1
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Region 10 - FY03
Region 10
Adak Naval Air Station,
AK
QUA
Region 10
Arctic Surplus, Alaska
4/13/00
9/17/03 ROD-A
2/03
8/03
Community of
Adak for Fish
Signs.
EPA to move
POL sites to
Two Party
Agreement.
Soil,
Groundwater
30 day comment period
on the proposed plan
and a public meeting.
Community input on
fish consumption fact
sheets. State concurred
with the changes and
provided input on fish
consumption fact sheets.
Fed = 60 hrs.
Contr. = None
Est'd Savings = None
Reduced oversight costs
for EPA with POL sites
under Two Party
agreement.
Type of Change: From - Subsistence fish advisory signs; cleanup of petroleum contaminated sites under both CERCLA and the State-
Navy Two Party Agreement. To - Fish consumption advisory fact sheets directed at Adak residents; cleanup of petroleum contaminated
sites under state cleanup program only.
Factual Basis: Change in format of fish advisory information provides more useful information to the people most likely to be affected
by any remaining contamination; change in regulatory status of petroleum contaminated sites reduces government's administrative
costs without affecting the protectiveness of the remedy.
9/28/95
6/17/03 BSD
1/03
6/03
PRP
Soil
The state concurred
with the change. A fact
sheet was distributed to
the site mailing list and
a notice was published
in a local newspaper.
Fed = 125 hours
Contr. = None
Est'd Saving = $0.3M
Type of Change: From - On-site treatment of lead and PCB contaminated soil, with a cap with a silt liner over the lesser contaminated
soils and treated soils; To - Off-site disposal of highly contaminated soil, stabilization of all remaining contaminated soils, stabilized
soils capped using a geosynthetic clay liner
Factual Basis: A more thorough site characterization study demonstrated that the many site removals were more effective than
thought at the time of the ROD in removing the soils with the highest levels of contamination, greatly reducing the cost-effectiveness of
on-site treatment. Also, new views on potential site re-use and recent engineering studies on alternative cover systems allowed the
selection of a different cap design.
A 1
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 10
Hanford 100-NR-l and
100-NR-2, WA
Region 10
Harbor Island
Lockheed Shipyard,
WA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
12/99
1/00
5/21/03 BSD
Date Review
Commenced
Date Review
Completed
12/02
5/03
Change
Initiator
DOE, EPA
Media
Soil
State/Community
Involvement
State concurred in the
remedy change. 30 day
public comment period,
plus a 25 day extension.
Proposed change also
discussed with Hanford
Advisory Board
Committee.
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 20 hrs.
Contr. = None
Est'd Savings = None
Type of Change : From - Excavate all contaminated soil up to 80 feet below the surface; To - Excavate 15 feet of soil and add
institutional controls at one waste site.
Factual Basis: Additional sampling post-ROD indicated that some soil contamination continues to the water table. The ROD
specified balancing factors that may be used to limit excavation of soil to top 15 feet. These factors were applied here through the
BSD.
11/27/96
2/02 BSD
3/31/03 BSD
1/03
3/03
EPA
Sediments
State participated in the
review of the remedy
change. Public notice
of the BSD.
Fed = 120 hours
Contr. = None
Est'd Savings = None
Type of Change: From: General description of sediments to be dredged or capped; To - Better definition of waste that needs to be
remediated and long-term O&M and monitoring requirements and to select disposal option.
Factual Basis: Pre-remedial design studies resulted in remedy update.
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Summary of Remedy Update Information for FY02 and FY03 for Sites Without Cost Increases
Region
Site Name, State
Region 10
Idaho National
Engineering Lab
(USDOE), ID
OU 1-10
Test Area North
Region 10
Idaho National
Engineering Lab
(USDOE), ID
WAG 4-13
CFA Comprehensive
Date of
Original ROD
Date of Change
(ESD/ROD-A)
11/22/99
6/30/03 BSD
Date Review
Commenced
Date Review
Completed
11/02
3/03
Change
Initiator
DOE
Media
Soil
State/Community
Involvement
State supported the
change in the remedy.
A notice of the BSD
was published in seven
Idaho newspapers. A
fact sheet was issued
summarizing all the
remedy changes being
considered
Est'd Resource Demands
Fed/Contr.
Est'd Cost Increase
Fed = 150 hrs.
Contr. = None
Est'd Savings: $4.4 M
Type of Change: Many areas addressed. TSF-09 and TSF-18 V-Tanks: From - Established area of contamination; To - Additional
sampling to determine the area of contamination. WRRTF Burn pits and fuel leak areas: From - Capping and/or soil removal; To -
No action needed. TSF-03 Burn Pit From - Native soil cover; To - Contingent remedy of removal and disposal.
Factual Basis: Additional site characterization performed post-ROD resulted in cost-effective changes to the remedies.
7/14/00
3/26/03 BSD
7/02
3/03
DOE
Soil
State supported the
change in the remedy.
A notice of the BSD
was published in seven
Idaho newspapers.
Fed = 150 hrs.
Contr. = None
Est'd Savings: $0.1M
Type of Change: From - Excavation and disposal of all soil in the CFA-04 mercury pond containing more than 0.5 mg/kg mercury
(approximately 8,290 cubic yards); To - Excavation and disposal of all soil in the CFA-04 mercury pond containing more than 8.4
mg/kg mercury (approximately 10,597 cubic yards.) and elimination of the requirement to backfill the pond to grade.
Factual Basis: New information during remedial design sampling revealed larger area of contamination however new information on
the toxicity and fate and transport information on the form of mercury found at this site allowed for the reconsideration of the human
health and ecological receptor risk-based cleanup value.
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SUMMARY REPORT FYOO AND FY01
Appendix A.2:
Summary of Remedy Update Information for FY02 and FY03
for Sites With Cost Increases
Note: The information and data presented in Appendix A.2 represent only a portion of the information available in
the decision document. If more information is needed, please refer to the site's ESD, ROD-Amendment,
memo-to-file, or letter.
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 1 - FY 02
Region 1
O'Connor Company,
OU2, ME
9/27/89
9/26/02 ROD-A
2/01
8/02
EPA, State,
PRP
Groundwater
State involved; limited
community involvement
Fed = 800 hrs.
Contr. = None
Est'd Increase = $0.4M*
Type of Change: From - Groundwater extract and treat system; To - Institutional controls (ICs) plus TI waiver for a limited portion of
the site, active recovery of separate phase PCB oil, long-term monitoring and 5 year reviews.
Factual Basis: Reassessment, in accordance with EPA guidance, on PCBs and the technical practicability of restoring groundwater
resulted in this remedy update.
*Note: This is a PRP-lead site. No increase in oversight is anticipated.
Region 1 - FY 03
Region 1
Portsmouth Naval
Shipyard, OU3, ME
8/29/01
9/17/03 BSD
3/03
9/03
Navy
Contaminated
soil/waste,
Wetlands
Navy, EPA, State,
community (SAPL) meet
regularly. BSD was
provided to all
stakeholders for
comment.
Fed = 100 hrs.
Contr. = None
Est'd Increase = $5.8M
Type of Change: From - Landfill cover, ICs, shoreline erosion controls and monitoring; To - Evaluate soil/waste, consolidate with
another landfill, construct wetlands.
Appendix A.2
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Region 1
Sullivan's Ledge OU1,
MA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Factual Basis: This change was initiated following re-evaluation of the feasibility of consolidating waste.
6/29/89
9/29/03 BSD
3/03
9/30/03
EPA/PRP
Soil
State concurrence letter
Fed = 40 hrs.
Contr. = None
Est'd Increase = Slight
increase
Type of Change: From - Excavation, solidification, and disposal of contaminated soils. Construction of an impermeable cap with
passive gas collection system; To - Installation of soil gas collection system; adding pertinent ARARs.
Factual Basis: Based on the discovery of methane in gas monitoring wells, after placement of cap, the remedy update was initiated.
Extraction and venting is required by the BSD.
Region 2 - FY 02
Region 2
Imperial Oil Co.
Inc./Champion Chemicals,
NJ
9/26/90
9/30/97 BSD
7/10/02 BSD
2/99
7/02
EPA/State
Soil, Sediments
Full state involvement
and state concurrence
with BSD #2. EPA did
not conduct a public
meeting or provide
comment period.
Fed = Unknown
Contr. = Unknown
Est'd Increase = $4.7M
Type of Change: From - The ROD called for the excavation of approximately 3,700 cubic yards of contaminated soil from off-site
area 1 and 2. Pre-designed sampling indicated that site related contamination was also present on four residential properties adjacent
the Imperial facility. Therefore, BSD #1 was issued in order to provide for remediation of these residential properties; To - EPA
issued BSD #2 in order to provide for the remediation of contaminated Brook sediment and contaminated soil on these two residential
properties.
Appendix A.2
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Region 2
Naval Air Engineering
Station, Areas A/B, NJ
Region 2
Naval Air Engineering
Station, Areas C, H, NJ
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Factual Basis: Further pre-design sampling indicated that Birch Swamp Brook sediment and soil on two residential properties,
adjacent to the brook, also contained site related contaminants.
7/7/97(A/B)
3/6/02 (A/B)
5/24/02 BSD
9/89
2/96 (A/B)
5/02 (A/B)
Navy
Groundwater
State oversight
Fed = Unknown
Contr. = Unknown
Est'd Increase = $20K-
$50K per site
Type of Change: From - Pump and treat facilities are located at Areas A/B, C & H to remove VOCs through air stripping & carbon
adsorption units & reinjection of the treated water, will continue; To - Injection of Oxygen Release Compound (ORC) into
groundwater at Areas A/B (Site 13), Area C (Sites 16 &17) and Area H (Site 32), as a secondary treatment technology to reduce
higher levels of contamination and expedite achievement of overall cleanup goals.
Factual Basis: Expedite GW remediation in each area.
2/4/9 1(C,H)
2/20/96 (C, H)
5/24/02 BSD
5/01
5/02
Navy
Groundwater
State oversight
Fed = Unknown
Contr. = Unknown
Est'd Increase = $20K-
$50K per site
Type of Change: From - Pump and treat facilities are located at Areas A/B, C & H to remove VOCs through air stripping & carbon
adsorption units & reinjection of the treated water, will continue; To - Injection of Oxygen Release Compound (ORC) into
groundwater at Areas A/B (Site 13), Area C (Sites 16 &17) and Area H (Site 32), as a secondary treatment technology to reduce
higher levels of contamination and expedite achievement of overall cleanup goals.
Factual Basis: Expedite GW remediation in each area.
Appendix A.2
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 2 - FY 03
Region 2
Claremont Polychemical
Corp., OU2, NY
9/28/90
4/14/03 BSD
9/01
4/03
EPA
Soil, Debris
Full state involvement;
community expressed no
opinion.
Fed = 80 hrs.
Contr. = None
Est'd Increase = $1.6M
Type of Change: From - Excavate and treat soil by low heat, dispose of treated soil in excavated areas; To - Treat soils under former
process building by SVE and maintain integrity of floor to prevent exposure to cadmium contaminated soil. Remove of industrial
commercial demolition plus ICs and construction debris and decommissioning of five concrete-lined pits.
Factual Basis: Newly identified soil contaminated with VOCs and cadmium was discovered during implementation of the remedy
selected in the 1990 ROD. EPA's evaluation indicated that vapors from VOCs in the soil beneath the former Process Building were
highly likely to migrate from the shallow subsurface to indoor air and the potential cancer risks from direct exposure to these indoor
air vapors were likely to significantly exceed EPA's levels of risk.
Appendix A.2
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Region 2
Grand St. Mercury Site,
NJ
Region 2
Naval Air Engineering
Station, OU21-Site 13, NJ
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/30/97
4/17/03 BSD
Date Review
Commenced
Date Review
Completed
5/02
4/03
Change
Initiator
EPA
Media
Soil
State/Community
Involvement
State concurred on this
remedy. The local
community, meaning the
people having their yards
remedied, fully supported
the change to the ROD.
The remaining
community were
unaffected and expressed
no opinion.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = 80 hrs.
Contr. = None
Est'd Increase = $0.4M
Type of Change: From - Removal of all site soils that had an average concentration of 23 ppm Hg; To - EPA decided that, due to the
relatively small area of the yards, and in order to be conservatively protective, all soils at adjacent properties with levels at or above
23 ppm should be removed, even if the average concentrations of the yard's soil below 23ppm. The BSD also modified the ROD to
call for soil removal at the adjacent property (the ROD only required soil sampling at those properties).
Factual Basis: When private properties (backyards of homes) adjacent to the Grand Street property were sampled, as required by the
ROD, it was discovered that several had discrete hits above the 23 ppm cleanup goal, but average concentrations below that level.
7/7/97
9/30/03 BSD
10/02
9/03
Navy
Groundwater
State oversight
Fed = Unknown
Contr. = Unknown
Est'd Increase = $2 IK
Type of Change: ROD: From - Pump and treat to remove VOCs through air stripping and carbon adsorption units and reinjection of
the treated water at the site, will continue;
BSD: To - Installation of an air sparging system, a secondary treatment technology, will be implemented to reduce
higher concentrations of groundwater contamination.
Factual Basis: Higher levels of groundwater contamination were discovered.
Appendix A.2
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Region 2
Naval Air Engineering
Station, OU26, Areas I/J,
NJ
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/27/99
9/30/03 BSD
Date Review
Commenced
Date Review
Completed
11/02
9/03
Change
Initiator
Navy
Media
Groundwater
State/Community
Involvement
State oversight
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = Unknown
Contr. = Unknown
Est'd Increase = $200K
Type of Change: ROD: From -Natural attenuation with long-term groundwater monitoring to address the groundwater contamination
and downgradient of Area I/J and co-metabolism to treat the higher area of groundwater contamination;
BSD: To - injection of nanoscale particles, a secondary treatment technology, will be implemented in lieu of co-
metabolism, to reduce higher levels of contamination.
Factual Basis: More expansive groundwater contamination was discovered. Co-metabolism was determined not to be effective and
has been abandoned.
Region 3 - FY 02
Region 3
Dublin TCE, PA
12/30/91
7/15/02 BSD
1/98
7/02
EPA
Groundwater
State
Fed =75 hrs.
Contr. = None
Est'd Increase = $0.5M
Type of Change: From - All remedies in the original ROD; To - Extend the public water line to include additional residences.
Factual Basis: The pursuit of secure, safe drinking water for additional residences whose drinking water was either at risk or
potentially at risk from contaminated groundwater, resulted in this remedy update.
Appendix A.2
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Region 3
U.S. Titanium Site, VA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
11/21/89
9/26/90 BSD
2/3/95 BSD
9/25/02 BSD
Date Review
Commenced
Date Review
Completed
3/00
9/02
Change
Initiator
PRP and
Public
Media
Soil
State/Community
Involvement
State and citizens of
Nelson and Amherst
Counties were involved.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = 75 hrs.
Contr. = None
Est'd Increase = $25K
Type of Change: From -All the remedies in the ROD and 2 prior ESDs. To - In addition, neutralize newly identified contaminated,
acidic soils. Apply institutional controls to prevent further installation of drinking water wells. Use fencing and other barriers to
prevent access of contaminated soils to nearby public trails.
Factual Basis: Additional measures were needed to make the initial ROD and subsequent ESDs protective. Fencing and natural
barriers will allow the use of the nearby property for public recreation.
Region 4 - FY 02
Region 4
Battery Tech (Duracell-
Lexington), NC
9/30/99
9/30/02 BSD
5/02
9/02
PRP
Soil, Sediments
State concurred on BSD.
Notice in local paper.
Fed = 40 hrs.
Contr. = None
Est'd Increase = $7.0M
Type of Change: From - In-situ soil treatment/solidification; To - soil excavation and treatment/solidification.
Factual Basis: During remedy design, additional field study determined that in-situ soil treatment/solidification was not feasible due
to site condition.
Appendix A.2
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 4 - FY03
Region 4
Coleman Evans Wood
Preserving Company, FL
Region 4
Savannah River Site
(TNX, OU29), SC
9/25/86
8/14/03 BSD
5/03
8/03
EPA
Soil
State concurred on BSD
Notice in local paper and
community meeting.
Fed = 55 hrs.
Contr. = 10 hrs.
Est'd Increase = $43. OM
Type of Change: From - Excavating and treating 45,000 cubic yards of contaminated soil by high temperature thermodesorption. To
- Excavating and thermo treating 135,000 cubic yards.
Factual Basis: Additional contaminated soils needing cleanup were identified during the implementation of the Removal Action.
11/9/94
6/18/03 BSD
2/03
6/03
DOE
Groundwater
State concurred on BSD.
Public notice in local
paper and community
meeting May 2003.
Fed = 40 hrs.
Contr. = 20 hrs.
Est'd Increase = $1.0M
Type of Change: From - Pump and treat; To - Soil vapor extraction with increased reporting requirements.
Factual Basis: Determination that SVE will reduce VOC mass quicker that traditional pump and treat.
Appendix A.2
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Region 4
Savannah River Site
(PRSB, OU66), SC
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/28/99
9/24/03 BSD
Date Review
Commenced
Date Review
Completed
5/03
9/03
Change
Initiator
DOE
Media
Sediments
State/Community
Involvement
State concurred, public
notice in local paper, 30-
day public comment
period and public
meeting.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = 80 hrs.
Contr. = 40 hrs.
Est'd Increase = $6.5M
Type of Change: From - The 1999" Plug-In" ROD established a presumptive remedy consisting of in situ stabilization with a low
permeability soil cover system for high-risk radioactively contaminated waste units. These units have similarities in history of use,
contaminants, and location. The 1999 ROD identified OU66 as a candidate for the Plu-In Remedy; To - OU66 was evaluated and in
the 2003 BSD it was determined that the unit meets the plug-in criteria established in the 1999 ROD.
Factual Basis: Results of 2002 Technical Evaluation Report.
Region 5 - FY 02
Region 5
South Macomb Disposal
Authority, LF 9 & 9A, MI
8/31/91
6/26/02 ROD-A
11/00
6/02
PRP
Groundwater
State Enforcement Lead
Fed = 200 hrs.
Contr. = Unknown
Est'd Increase = $7.7M
Type of Change: From - Slurry wall, leachate collection system and groundwater purging and treatment; To - Remedy change
implemented by the State agency without seeking EPA input/concurrence.
Factual Basis: Investigations indicate that the LF OU needed to be addressed. Removal Action Plan (State ROD Amendment) added
landfill OU --cap improvements, gas venting/monitoring, O&M and changed groundwater action to eliminate the slurry wall, add
leachate collection, and modify groundwater treatment.
Appendix A.2
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 5 - FY 03
Region 5
West KL Avenue Landfill,
MI
9/28/90
2/27/03 ROD-A
1998
2/03
EPA
Groundwater
Community is actively
involved in getting
municipal water. State
concurred on ROD-A
Fed = 200 hrs.
Contr. = Unknown
Est'd Increase = $0.5M
Type of Change: From - Monitor old deed restrictions on the use of shallow aquifer as a drinking water source, groundwater
extraction and treatment; To - The PRPs have petitioned EPA to allow natural attenuation of the groundwater and landfill contents,
however additional studies were necessary to support a decision on natural attenuation. The change ensures that all groundwater users
in the immediate vicinity of the plume remain protected while any additional studies are performed. While the users in question are
not currently being exposed to unacceptable levels of contaminants in the groundwater, this action creates a buffer zone of restricted
groundwater use around the KL Avenue Landfill plume. If the plume were to be migrating to the west this buffer zone would allow
EPA the time necessary to evaluate and implement the appropriate actions without putting those groundwater users at risk.
Factual Basis: The groundwater plume had migrated approximately one mile downgradient, forcing many homes onto alternate water
supplies.
Appendix A.2
10
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 6 - FY 03
Region 6
Mallard Bay Landing
Bulk Plant, LA
3/12/03
7/10/03 ROD-A
2003
7/03
EPA
Sludges, Soil
State comments
incorporated into
amendment. No public
comments.
Fed = 100 hrs.
Contr. = $125K
Est'd Increase: $1.7M
Type of Change: From - Excavate/extract and treat aboveground tank sludges and hot spot guild wing stabilization with off-site
disposal of treated material; To - Excavate/extract sludge wastes and off-site energy recovery /thermal destruction.
Factual Basis: During course of Remedial Design, it was determined that the original remedy would not comply with RCRA
Universal Treatment Standards. The ROD Amendment ($1.8M) addressed alternative method for sludge disposal. During Removal
Action implementation, additional field problems were encountered with the waste that required additional funding.
Region 9 - FY 02
Region 9
Phoenix-Goodyear Airport
Area, OU1, AZ
9/26/89
5/93 BSD
9/19/02 BSD
6/02
9/02
EPA
Soil
State reviewed and
commented on BSD.
City and community
concerns regarding
dioxin emissions from
thermox unit were
addressed.
Fed = 100 hrs.
Contr. = $125K
Est'd Increase: $0.2M
Type of Change: From - Soil vapor extraction system with thermox; To - Reestablishment of air emission central mechanism for soil,
gas remedy to granular activated carbon.
Factual Basis: Results of soil gas samples resulted in this remedy.
Appendix A.2
11
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Region 9
San Gabriel Valley, Area
1, El Monte OU, CA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/23/99
8/22/02 BSD
Date Review
Commenced
Date Review
Completed
2000/2001
8/02
Change
Initiator
EPA, PRP
Media
Groundwater
State/Community
Involvement
State and Regional Water
Quality Central Board
support the change.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = 100 hrs.
Contr. = $125K
Est'd Increase: $21.2M
Type of Change: From - Air stripping and carbon adsorption of VOC-contaminated groundwater; To - Additional technologies
decided in design.
Factual Basis: The discovery of additional contaminants, e.g., perchlorale, hexavalent chromium, and 1, 4-dioxane in selected
shallow groundwater monitoring wells, initiated this remedy update.
Region 10 - FY02
Region 10
Bunker Hill Mining and
Metallurgical Complex,
OU2, ID
Non-populated area
9/22/92
12/10/01 ROD-A
12/99
12/01
EPA
Acid Mine
Drainage
(AMD)
State concurred with the
remedy change.
Comment period on
proposed plan was
extended and a public
meeting was held.
Fed. = 700 hrs.
Contr. = $30,000
Est'd Increase = $53. OM
Type of Change: From -treatment in existing treatment plant and new wetlands system, To - Source control; collect, store and treat
AMD, dispose sludge on top of Central Impoundment Area; and monitor untreated mine water.
Factual Basis: Through treatability studies, the original remedy was found inadequate to meet treatment levels, and the existing
treatment plant could not consistently meet current water quality standards.
Appendix A.2
12
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Region 10
Commencement Bay -
Near Shore/Tide Flats,
WA
Middle Waterway
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/30/89
2/24/02 BSD*
Date Review
Commenced
Date Review
Completed
3/01
2/02
Change
Initiator
EPA
Media
Sediments
State/Community
Involvement
A fact sheet was mailed
to 1300 people and a
public comment period
was held. 80 comment
letters were received.
The state and the
Puyallup Tribe were
supportive of the
amended remedy, except
for one area at the head
of the waterway.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = 1,000 hrs.
Contr. = $5K
Est'd Increase = $4.8M
Type of Change: From - Site use restrictions, source control, natural recovery, sediment remedial action (i.e., confinement and
habitat restoration), and monitoring; To - More specific remedial actions consistent with the results of the post-ROD investigations of
Middle Waterway.
*Note: A second BSD for the Middle Waterway was signed on 3/20/03.
Factual Basis: Pre-remedial design studies at the Middle Waterway has better defined the area and volume exceeding the cleanup
levels which lead to the identification of specific areas where natural recovery would be appropriate and specific areas to be dredged
or capped. Estimated volume of material that needs to be dredged increased from approximately 57,000 cubic yards in the ROD to
approximately 90,000 cubic yards.
Appendix A.2
13
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Region 10
Fort Wainwright, OU3,
AK
Region 10
Hanford 200 Area
(USDOE), WA
ERDF
Date of
Original ROD
Date of Change
(ESD/ROD-A)
3/26/96
9/27/02 BSD
Date Review
Commenced
Date Review
Completed
9/01
9/02
Change
Initiator
Federal
Facility
Media
Soil,
Groundwater
State/Community
Involvement
State is a support agency
and concurred in the
remedy change.
Notice of the BSD was
published in a local
newspaper.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed. = 380 hrs.
Contr. = $15K
Est'd Increase = $17.0M
Type of Change: From - In-situ soil vapor extraction, air sparging and natural attenuation; To - Addressing larger extent of soil and
groundwater contamination; added ex-situ soil treatment and on-base disposal
Factual Basis: The remedy update was initiated following implementation of post-ROD studies that indicated more total volume and
lateral extent of contamination than previous documented.
1/20/95
1/3 1/02 ROD A
10/01
1/02
DOE,EPA
Hazardous
waste, Mixed
waste
30-day public comment
period. State supported
remedy changes.
Fed. = 20 hrs.
Contr .= None
Est'd Increase = $40.0M
Type of Change: From - Four disposal cells at the Environmental Restoration Disposal Facility (ERDF) and waste staging at OU
prior to treatment and disposal; To - Four additional disposal cells at ERDF and staging of remediation waste at ERDF prior to
treatment.
Factual Basis: The remedy update was needed to support ongoing remediation by providing additional waste disposal capacity.
Appendix A.2
14
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Region 10
Harbor Island
Lockheed Shipyard
WA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
11/27/96
2/22/02 BSD
Date Review
Commenced
Date Review
Completed
8/01
2/02
Change
Initiator
EPA
Media
Sediments
State/Community
Involvement
State participated in the
review of the remedy
change. 30 day public
comment period with 9
comment letters
received.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = 1,500 hrs.
Contr. = $150K
Est'd Increase = $19. OM
Type of Change: From - General description of sediments to be dredged or capped; To - Better definition of the nature and extent of
contaminated sediments that need to be remediated.
Factual Basis: Pre-remedial design studies resulted in remedy update.
Region 10 - FY03
Commencement Bay -
Near Shore/Tide Flats,
WA
Middle Waterway
9/30/89
2/24/02 BSD
3/20/03 BSD
1/03
3/03
State
Sediments
State and Puyallup Tribe
concurred with the
change. BSD went out
for public comment
simultaneously with
consent decree
Fed = 40 hrs.
Contr. = $0
Est'd Increase = $1.6M
Type of Change: From - Leave in place and monitor an area of subsurface sediment contamination at the head of the waterway; To -
removal with offsite upland disposal for the area at the head of the waterway.
Factual Basis: State desired enhancement of the remedy in this section of the waterway and agreed to pay for the additional work.
Appendix A.2
15
-------
Summary of Remedy Update Information for FY02 and FY03 for Sites With Cost Increases
Region
Site Name, State
Region 10
Hartford 100-HR-3, WA
Region 10
Harbor Island
Todd Shipyard
WA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
1996
10/99 ROD-A
3/3 1/03 BSD
Date Review
Commenced
Date Review
Completed
12/02
3/03
Change
Initiator
DOE, State
Media
Groundwater
State/Community
Involvement
State concurred with the
remedy change. Public
notice of the BSD.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = 80 hrs.
Contr. = None
Est'd Increase = $4.8M
Type of Change: From - Cost and schedule based on conceptual design; To - Higher costs and longer construction period based on
better site knowledge.
Factual Basis: Additional time and cost to implement the in situ treatment remedy based on actual costs and experience during
installation of the remedy.
11/27/96
12/99 BSD
3/31/03 BSD
10/00
3/03
EPA
Sediments
State participated in the
review of the remedy
change. Public notice of
the BSD.
Fed = 1,700 hrs.
Contractor = $0.2M
Est'd Increase = $14.0M
Type of Change: From - General description of sediments to be dredged or capped; To - Better definition of the nature and extent
of contaminated sediments that need to be remediated and to select sediment disposal option
Factual Basis: Pre-remedial design studies resulted in remedy update.
Appendix A.2
16
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Office of Solid Waste and Emergency Response
Washington, D.C. 20460
OSWER 9355.0-107
EPA-540-R-04-010
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