&EPA
United States
Environmental Protection
Agency
Off ice of
Solid Waste and
Emergency Response
Publication. 9200.5-2151
April 1991
Superfund Design and
Construction Update
Office of Emergency and Remedial Response
Hazardous Site Control Division OS - 220W
Intermittent Bulletin
Volume 5 Number 1
REMEDIAL DESIGN/REMEDIAL ACTION GUIDANCE TO
BE REVISED •"•^^"•^^"^^^••••^^^^^~
Thecurrenteditionofthe "Remedial
Design/Remedial Action Guidance"
was published in June 1986, and
much of its emphasis was on con-
ducting RD/RA through the U. S.
Army Corps of Engineers (USAGE).
The involvement of States, Poten-
tially Responsible Parties, and EPA
contractors in conducting RD/RA
has expanded EPA's procedures
significantly. While other guidance
documents address certain aspects
of RD/RA, an updated overall guid-
ance is definitely needed. The Haz-
ardousSite Control Di vision (HSCD)
has identified the development of
updated guidance as a priority for
fiscal year 1991.
A work group has been established
to revise the guidance; its represen-
tation includes the Regions, Head-
quarters (Office of Emergency and
Remedial Response and the Office
of Waste Program Enforcement), the
Superfund Engineering Forum, and
the U. S. Army Corps of Engineers.
Other interested parties, such as the
States and the contracting commu-
nity, will provide input to the guid-
ance through review and comment
on draft documents.
The kick-off meeting for the work
group was held on January 10 and
11,1991, at EPA Headquarters. At
the meeting, the work group was
briefed on the general RD/RA proc-
ess and the Headquarters perspec-
tive on the guidance. The group
then used Total Quality Manage-
ment (TQM) techniques to establish
the RD/RA guidance needs and ob-
jectives. These priorities are being
used by Headquarters to plan the
drafting of the guidance.
The work group consensus was to
developaconciseprimarydocument
that describes the RD and RA proc-
esses without regard to lead or con-
tract vehicle. This "core" will be
supplemented by other sections and
appendices that include, for example,
roles and responsibilities, checklists
for reviewing deliverables, model
statements of work, procedures for
State and PRP lead sites, and quality
assurance/quality control.
The current plan is to publish the
revised Remedial Design/Remedial
Action Guidance in the summer of
1992. Another work group meeting
is planned for April 30, 1991, in
conjunction with the "Design and
Construction Issues at Hazardous
Waste Sites" conference in Dallas,
May 1-3, 1991. If you have any
questions about the RD/RA Guid-
ance revision process, please call
Tracy Loy, HSCD, at (703) 308-8349
or FTS 398-8349.
COST ESCALATION OF LOW TEMPERATURE VOLATIZATION
SYSTEMS
The Kansas City District of the U.S.
Army Corps of Engineers (USAGE)
conducted a study on the use of low
temperature volatization systems
(LTVS) at several Superfund sites in
New Jersey. A paper was developed
and presented by Alan Tool at the
EPA/USACE Senior Management
Review Meetingin August 1990. The
study was undertaken when the
designs for the sites were showing
major cost escalation from the esti-
mates provided in the Record of
Decisions.
The four sites, Lipari Landfill,
Waldick Aerospace, Metaltec, and
Caldwell Trucking are undergoing
design by the Kansas City District.
The study was undertaken at the
request of USAGE and EPA Senior
Management, so that whatever
caused the cost escalation could be
corrected. Thecost escalation num-
ber has resulted in ROD amend-
ments and in the case of Lipari, a
change in the remedy.
The following information is ex-
cerpted from USAGE'S position
continued on page 2.
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continued from page 1.
COST ESCALATION
paper on Low Temperature Volati-
zation Systems.
“Prior to proceeding with issues dis-
cussion, it is appropriate to discuss
the function of an LTVS. LTVS are
basically thermal methods of remov-
ing volatile and semi-volatile con-
taminates from a soil matrix. This is
accomplished by heating the matrix
that has been placed in a thermal
unit to temperatures adequate to
volatize the contaminants. Other
terms used for this process are low
temperature thermal treatment and
low temperature thermaldesorption.
‘There are several different thermal
units which can serve as the heart of
the system. They are:
- Rotary Kiln Dryer
- Thermal Screw
- Infrared Furnace
The four designs underway at Kan-
sas City District (KCD) are being
done using a total systems approach.
When doing this, several key design
issues surface. The remainder of
this paper is devoted to discussing
these issues and theirimpacton proj-
ect construction and operation costs.
“ Soil Characterization
It is important to know the in-situ
characteristics and the disturbed
characteristics to design for delivery
to the feed system of the LTVS. In
order to provide the needed infor-
mation, soil characterization should
include:
a. size distribution/gradation
b. heat capacity of the material
c. material density (in-situ and
disturbed)
d. organic contaminants
e. moisture content
f. Atterberg limits/liquid and plas-
tic limits
“ Materials Handling
The initial handling of the material,
from excavation to feed must ac-
commodate the LTVS thermal unit
limitations. A major issue associ-
ated with material handling is the
water content of the feed. Some
LTVS units requireinitial feed mois-
ture contents to be 25% or less. Other
more flexible units may be able to
treat higher water contents but the
energy costs and the residence times
will increase dramatically. Also
largerand more complex vapor treat-
ment systems are required with an
increase in water content.
“ Cleanup/Disposal Criteria
The establishment of cleanup/dis-
posal criteria impacts directly on
project cost for LTVS. Although
cleanup/disposal criteria may not
be required in the Record of Deci-
sion, they do need to be established
for the Remedial Design. Stricter
cleanup standards may require
longer residence times and higher
energy requirements.
“ Treatability Studies
The resul ts of treatabiity studies will
directly impact design decisions and
may also play a part in establishing
cleanup criteria. For these reasons,
treatability studies should generally
be a part of each LTVS project. Pilot
testing is not always necessary since
it would have to be done on several
different types of units to allow equal
competition. Vendors know the
transfer coefficients and other spe-
cific parameters for their units. Each
vendor can determine its own sys-
tern’s residence times and heat re-
quirements based on the treatability
study data.
Off Gas Treatement
Few, if any, options exist besides
incineration, activated carbon, or
condensation and liquid recovery.
Air Ouality Requirements
Air quality requirements are of con-
cern primarily during two phases of
the operation of a LTVS. This con-
cern exists during the excavation and
handling of the untreated soil and
during the thermal treatment of the
soil. While air quality control asso-
ciated with the treatment itself is
closely controlled, the air quality
during the handling is more difficult
to control.
Side Stream Handling. Treatment,
and Disposal
Side streams are a major part of the
design of a LTVS. A major side
stream to be considered is the liquid
removed from wet material prior to
processing in the thermal unit. Be-
cause of the contaminated nature of
this side stream, attention must be
given to treatment and disposal.
End Product Disposal
The end product disposal require-
ments vary from project to project;
the disposal of these products will
require careful planning and cost
consideration.
Cost Comparison Data
Cost escalation between the feasa-
bility study and current design esti-
mates for several projects are listed
in the table below:
Cost Estimate ($/cu.yd)
Project Name FS Current ____
Lipari Off Site $38.06 $164.24
Caidwell $17.86 $505.67 2831%
Metaltec — $356.66
Waldick $332.13 $499.02 150%
The KCD position is that earlier cost
estimates were low. More detailed
information has been examined and
current cost estimates are more rep-
resentative of site specific factors.
Future estimates should improve as
experience is gained in the field and
bid data becomes available. The cur-
rent design estimates reflect costs
for only the portion of the LTVS
process from the point of feeding the
material into the thermal unit
through the production of the treated
side streams from the thermal unit.
The cost estimates do not include
i nntmu d on nape 3
Percent
h_rease
432%
2
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continued from page 2.
COST ESCALATION
handling costs, dewatenng, or dis-
posal of treated soils and other side
stream products.
‘Given the three-fold difference be-
tween current design cost estimates,
it is appropriate to discuss the source
of the differences between projects.
First and foremost is the uniqueness
of each site. Second, there is some
economy of scale that may account
for the lower cost per cubic yard at
the Lipari site. Third, the uncertain-
ties of estimating costs for full scale
application of a technology that has
not yet received full scale use, can
result in a wider range of estimates.It
is difficult, if not impossible, to es-
tablish a confidence interval for the
estimates given the limited availa-
bility of full scale cost data.
Conclusions
a. A primary factor in the cost of
LTVS pro jectsisthe character of each
specific site. The characteristics of
each site must be carefully consid-
ered; the costs to remediate a site
can vary substantially.
b. Treatability study data will be
helpful in enhancing the quality of
design cost estimates.
c. Although off-gas treatment is a
costly issue, there is no way to deter-
mine if costs for off-gas treatment
were included in earlier FSestimates.
d. The overall conclusion is that the
current cost estimates are more reli-
able than those presented in the FS.
They are based on a more thorough
knowledge of each site.
For additional information, contact
Mr. Alan Tool, Kansas City District
at (816) 426-7135, or your Regional
RD/RA Coordinator at EPA Head-
quarters.
THE SARA 200 UPDATE
As a reminder, the Office of Emer-
gency and Remedial Response
(OERR) is tracking the progress
towards meeting the SARA man-
dated 200 first remedial action (RA)
startswith theOctober 17,1991 dead-
line rapidly approaching.
The data obtained from a recent
CERCLIS pull (02/09/91) shows that
contracts have been awarded at only
14 sites since October 17, 1989. De-
signs have been completed at an
additional 27 sites. This leaves a re-
maining total of 102 sites that are
being followed closely for a design
completion with possible contract
award. RAfundswillbedistributed
on a first come, first serve basis until
June 1991. All projects, where de-
signs are scheduled to be completed
pnor to the October deadline, have
been included on the “Candidate
List.” This list was discussed with
each of the Regions and then final-
ized. Copies were sent to the Re-
gions in December 1990.
One of the factors in determining
whether a site meets the criteria for
a “200 RA Start” is whether an RA
contract has been awarded. This
activity is a sub-event in CERCLIS
beneath the event “RA Start”. To
help clarify the difference between
RA start” and “award of the RA
contract’, the following definitions
are provided from the Superfund
Program Management Manual
(OSWER Directive 9200 .3-OlD):
RA Start
Fund-financed (F or S events) - The
date a contract, lAG, or CA is
awarded and funds are obligated.
PRP-financed (RP, MR, or PS events)
- Credit for an RA start is given when
one of the following occurs:
• When work is performed under a
CD or AO, the start is the date EPA
approves the PRP remedial design
(RD) package.
• If the work is performed under a
state order or CD, and EPA ap-
proved the ROD, the RA start is the
date EPA approves the PRP RD
package.
• Where the Fund performed the
RD, and the PRPs are doing the RA
under the terms of a CD, UAO, or
judgement, the RA start is the date
on which the PRPs provide notice of
intent to comply with the UAO or
the date the CD is referred to HQ or
DOJ.
The Remedial Design/Remedial
Action Regional Coordinators will
be in contact with each of the Re-
gions during the month of March to
follow up on the “200” sites. Much
of the information to be gathered
will assist OERR in the development
of the report to Congress to be pre-
pared later in the fall.
If you have any questions, please
contact Ms. Jo Ann Griffith, Design
and Construction Management
Branch at FTS 398-8353 or (703) 308-
8353.
RA Contract Award
Fund-financed (F or S events) - The
date the EPA, State, USACE, BUREC
award a contract to initiate a Fund-
financed RA.
PRP-financed (RI’, MR, or PS lead
events) - The date the PRPs have
begun substantial and continuous
physical action, which is equivalent
to an EPA contract award, or where
the PR? has taken equivalent action
with its own work force.
ABOUT THE UPDATE
For comments, ideas, submissions, or questions about the Update, please contact Jo Ann Griffith. Design and Construction Management
Branch, at FFS 398-8353 or commercially at (703) 308-8353. For copies, contact EPA’s Public Information Center at FTS 382-2080 or
(202) 382-2080. or write to EPA Public Information Center, U.S. Environmental Protection Agency, 401 M St. S.W.. Washington, D.C.
20460.
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continued from page 3.
THE PREDESIGN TECHNICAL SUMMARY
The Pre-Design Technical Summary
(PDTS) is a compilation of available
site information that is to be pre-
pared by the remedial project man-
ager (RPM) to provide the designer
with a clear understanding of the
technical objectives of the remedial
action. Guidance is being devel-
oped by the Design and Construc-
tion Branch on preparation of the
PDTS.
The objective of developing a PDTh
is to provide a smooth transition
from the Record of Decision (ROD)
into the design process. The prepa-
ration and use of the PDTS should
ensure that the designer will under-
stand the technical objectives of the
design as well as provide the de-
signer with an up-to-date inventory
of all available information that may
be pertinent to the design. The PDTS
will serve the RPM as the initial
buildingblock fordevelopingacom-
prehensive statement of work for
the remedial design.
The intent of the PDTS is to accom-
plish the following:
• define initial site conditions;
• describe the selected remedy;
• identify applicable regulatory
requirements;
• summarize available data
(and identify possible additional
data needs); and
• state all known unresolved issues.
The Remedial Investigation/Feasi-
bility Study (Rl/FS) and ROD will
be the sources for much of the infor-
mation to be summarized or refer-
enced in the PDTS. However, the
guidance will identify a great deal of
additional site-specific information
that may be known to the RPM and
is not included in the RI/FS or ROD.
The guidance is now being revised
to incorporate comments from re-
gional offices. The guidance will be
part a larger document on “scoping
remedial design” that will also in-
clude such topics as remedial man-
agement strategy development,
model statements of work for reme-
dial design, and design schedule
development/costestimating. If you
would like a copy of the draft PDTS
guidance or have any questions,
please contact Ken Skahn at FTS 398-
8355 or (703) 308-8355.
INTRODUCTION TO REMEDIAL DESIGN SCHEDULE
MANAGMENT SEMINARS
EPA has developed remedy-specific
generic schedules to help CERCLA
employees complete site-specific
schedules. The seminars will show
employees how to use these generic
schedules to develop and/or assess
site-specific plans and schedules.
Using the Remedy-Specific Generic
Remedial Design Schedules asa base
will help establish a common lan-
guage and set of assumptions, as
well as facilitate communication
between all of the parties involved
in a remedial design. Also, methods
for optimizing remedial design
schedules will be presented, which
will contribute to more effective and
efficient management of remedial
design activities.
After completing a seminar, atten-
dees will be familiar with:
• Generic remedial design tasks
• Eleven remedy-specific
applications of the generic tasks
• Basics of scheduling, including
the Critical Path Method
• Strategies for expediting and
optimizing remedial designs
• Techniques for scheduling main-
tenance, control, and problem solv-
ing
The seminars will lead to increased
ability in preparing and reviewing
design service agreements. Ulti-
mately, attendees will be better pre-
pared to manage remedial design
activities and promote successful
outcomes.
Schedule of Course Deliveries
Philladelphia, January 29 through 31, 1991 (Completed)
Atlanta, February 26 through February 28, 1991 (Completed)
San Francisco, March 26 through March 28, 1991 (Completed)
Denver, April 16 through April 18, 1991
Chicago, May 7 through May 9, 1991
For more information on the Remedial Design Schedule Management Seminars, please contact your re-
gional training coordinators:
Region 8
Charles Brinkman
(303) 293-1489
FAX
(303) 293-1488
Region 5
Denise Reape
(312) 353-8987
FAX
(313) 353-6775
Region 3-
Region 4-
Region 9-
Region 8-
Region 5-
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