NATIONAL MEETING
OF
REMEDIAL PROJECT MANAGERS
March 15-18, 1993
Seattle, Washington
MEETING SUMMARY
ational Association of Remedial Project Managers
• * inual Conference in Seattle, Washington, March 1993
SPONSORED BY THE NATIONAL ASSOCIATION
OF
REMEDIAL PROJECT MANAGERS (NARPM)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
i REGION 6
? 1445 ROSS AVENUE, SUITE 1200
. DALLAS TX 75202-2733
November 19, 1993
MEMORANDUM
SUBJECT: 1993 National Association of Remedial Project Managers
(NARPM) Conference Report
FROM: Cathy D. Gilmore, Region
Steve Sandler, Region 4
I /yv/Brad Bradley, Region 5
Fran Costanzi, Region 3
l\ Rosemarie Caraway, Region 9
M 1993-1994 NARPM National Officers
TO: Regional NARPM Representatives
Attached, finally, is the 1993 NARPM Conference Report. I am
including, initially, two copies per region. While compiling the
report, I was very surprised at the number of people we had
attending the conference and the scope of the conference. We had
our largest conference ever - more than 170 people attending - and
about 130 of those were RPMs.
In the conference report, you will find summaries of most of the
panels, another compilation of the abstracts of the presentations
and exhibits, and the agenda. Looking back on the conference,
with a clearer head now that it is behind us, the conference was
quite an achievement. The officers would again like to thank all
who assisted with the 1993 conference.
Attachment
NOV 3 0
EPA REGION HI
05L AND TITLE III
C/^6 Printed on Recycled Paper
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£PA IoH /P- *7 5 ^0(0
DISCLAIMER
The development of this document was funded by the United States Environmental
Protection Agency. It has not been subject to the Agency's peer review, and it has not yet
been approved for publication as an EPA document.
The policies and procedures established in this document are intended solely for the
guidance of government personnel. They are not intended and cannot be relied upon to
create any rights, substantive or procedural, enforceable by any party in litigation with the
United States. The Agency reserves the right to act at variance with these policies and
procedures and to change then at any time without public notice.
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1993 NARPM NATIONAL MEETING
MEETING SUMMARY
The fourth annual National Association of Remedial Project Managers
(NARPM) National Meeting for 1993 was held in Seattle, Washington,
from March 15-18, 1993. It was a very productive conference and
covered many topics of concern to its members, the Remedial Project
Managers from the ten EPA regional offices. Over 170 people
attended the conference, making the 1993 conference the largest one
to date. Approximately 140 Remedial Project Managers attended with
all ten regions represented. Others attending the conference were
from EPA Headquarters, the various EPA laboratories, the
Environmental Response Team, the U.S. Army Corps of Engineers, and
the Bureau of Reclamation. This was the largest NARPM conference
yet and with the widest participation!
One of the early highlights of the meeting was the tour of the
Manchester Lab. This lab is a regional laboratory and for many of
the participants in the tour, it was the first time through a
regional EPA lab. Since the trip to the lab required a one-hour
ferry ride, a speaker was secured so that the time on the ferry was
interesting and productive. Ken Moser, the Puget Sound Keeper,
gave us a very interesting overview of the Puget Sound and his
efforts to assist in solving the problems along the Sound.
The formal conference began on March 16 with welcoming addresses
from Randy Smith and Barbara McAllister of Region 10 and Ika Joiner
of the Superfund Revitalization Office. Richard Guimond, the
Acting Assistant Administrator for Solid Waste and Emergency
Response, presented the Keynote Address.
A new feature at the conference was an all-conference panel
discussion entitled, RPM Professional Development in the 90's. The
panel was made up of RPMs from 5 regions, Rich Guimond (Acting
Assistant Administrator of the Office of Solid Waste and Emergency
Response), Meg Kelly (Acting Director of the Technology Innovation
Office), and Randy Smith (Director of the Hazardous Waste Division
in Region 10). The panel presentations and discussions proved to
be quite lively at times and many questions and concerns were
voiced from the RPMs present.
There were numerous panel discussions and a record number of papers
presented. In all, over sixty abstracts were submitted during the
call for abstracts and more than fifty papers were presented at the
conference. There were panel discussions and papers presented on
the following topics: environmental and human health risk
assessment, settlement issues, federal facilities, ground water
remedial investigations and feasibility studies, remedial design
and remedial action, remedy selection, ground water remedial design
and remedial action, community relations, the Superfund Accelerated
Cleanup Model, RCRA/CERCLA Integration, the Superfund
Revitalization Office, the Compendium of Good Ideas, the NARPM
newsletter, remedial investigation and feasibility studies,
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contract management, site completion, and remedial design and
remedial action. Specific paper topics and abstracts for those
papers are included in the program agenda which is included in this
document. Summaries of the majority of the panel discussions are
also included in this document.
The officers of NARPM would like to thank all of those people who
took the time to prepare and present a paper, those who moderated
panels, and all of the people of Region 10 who worked so hard to
make the conference a success. Without each of these people, the
conference would not have happened. We would also like to thank
Headquarters for the assistance with the hotel rooms and the
management in each of the ten regions for allowing travel funds for
the NARPM National Meeting. We know in these times of very tight
budgets that it takes a very special commitment from the management
in the ten regions and Headquarters to allow the funds to make this
conference a reality and a success.
Steve Sandler and Cathy Gilmore would also like to thank the
retiring co-chairs and alternate, Dion Novak from Region 5, Lee
Otis from Region 10, and Laura Williams from Region 8, for all of
their work and assistance in planning the conference and with
NARPM. Dion should also be recognized as the first co-chair ever
to fully serve the two year term as a NARPM officer. In turn, we
would also like to welcome the two new officers and alternate, Brad
Bradley from Region 5, Fran Costanzi from Region 3, and Rosemarie
Caraway from Region 9. WelcomeI
With the Seattle conference finished, the officers of NARPM are
well into the planning of the Fifth Annual Meeting in Kansas City,
Missouri, in May 1994. Hope to see you there!!
1992-1993 officers
Steve Sandler, Region 4
Dion Novak, Region 5
Cathy Gilmore, Region 6
Laura Williams, Region 8
Lee Otis, Region 10
1993-1994 Officers
Fran Costanzi, Region 3
Steve Sandler, Region 4
Brad Bradley, Region 5
Cathy Gilmore, Region 6
Rosemarie Caraway, Region 9
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PANEL SUMMARIES
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PANEL SUMMARY
1993 NARPM CONFERENCE
Seattle, Washington
Date: March 17, 1993
Topic of Panel: Remedy Selection
Panel Moderator: Monica Chapa Smith
Panel Members: Nick Ceto
Region VI
Region X
Region IX
Region IX
HSCD
Kevin Mayer
Jeff Dhont
Shahid Mahmud
The Remedy Selection Panel was a new addition to the NARPM
conference this year. There were three presentations as follows:
The Plug-In ROD: An Accelerated Approach for Multi-Source
Sites; Jeff Dhont, RPM Region 9
Contingencies and Deferred Decisions at Large Ground Water
Contamination Sites Involving Local Water Supply Agencies,
Kevin Mayer, RPM, and Colette Kostelec, RPM, Region 9
Institutional Controls, Buncker Hill, Kellogg, Idaho, Nick
Ceto,RPM, Region 10
The Panel was moderated by Monica Chapa Smith (Region VI) and
included the above mentioned presenters and Shahid Mahmud of HSCD.
Issues: The main topic of discussion during the panel session was
Presumptive Remedies.
- using the presumptive remedy fact sheets in scoping RI/FS
- using presumptive remedy fact sheets in preparing the
Proposed Plan and ROD
- RPMs to provide HQ with rationale if presumptive remedy is
not selected for site
Discussion:
Mr. Mahmud presented to the attendees the status of the presumptive
remedy discussions in Headquarters (HQ). Mr. Mahmud stated that HQ
was generating Presumptive Remedy Fact sheets which would be
distributed to the Regions. These fact sheets are to be used in
the RI/FS scoping and Remedy selection phases. Mr. Mahmud stated
that if, for example, the ROD for a wood treatment facility was not
the presumptive remedy, the Region would have to supply HQ with the
rationale as to why the presumptive remedy was not selected. This
discussion led to much input from the RPMs in attendance. Some of
the comments were as follows:
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* Last year, presumptive remedies were discussed and at that
time, RPMs stated their objections. Why are we hearing about
them again? Are our comments not taken into consideration?
* HQ should not try to force the presumptive remedy idea down
our throats. They should present the presumptive remedy fact
sheets as a tool and not a requirement.
* During the evaluation of the alternatives for a ROD,
remedies that have been proven to work at other sites are
considered and evaluated.
The RPMs in attendance were concerned that HQ had not involved RPMs
in the process of developing the Fact Sheets. Mr. Mahmud informed
the RPMs that in fact RPMs were involved and that prior to a fact
sheet being finalized, the Regions were given the opportunity to
comment.
Recommendations: The following recommendations were discussed
during the panel and presented to the NARPM conference attendees.
1. Headquarters should present the presumptive remedy fact
sheets as a "TOOL" and not another "REQUIREMENT".
2. Headquarters should try to get NARPM concurrence on the
presumptive remedy approach.
3. Headquarters should encourage greater participation from
RPMs in developing the fact sheets since it is the RPMs
who will be using them.
4. Each region should have an RPM contact in order to ensure
that the fact sheets are properly disseminated.
5.
Include this panel in the future NARPM Conferences.
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1993 NARPM Conference
SACM Session Summary Moderator - Jim Feenev
RPM. Rea. 3
Introduction;
Six presentations focussed on the successes, and failures, of
SACM and SACM-like expedited pilot projects in the regions.
Presentations also highlighted and addressed the expansion of
individual roles to merge the responsibilities of the RPM, OSC and
SAM in site investigations and response. The panel discussion
focussed on the cost of expediting the pilots and the obstacles to
implementing SACM.
Discussion:
The presentations included case studies showing the
integration of Remedial and Removal-type response actions in
expediting investigation and/or clean-up, and the development of
innovative approaches for handling sites with special
characteristics. As presented (see abstracts), it was demonstrated
that Superfund Sites can be driven rapidly to clean up if they are
given priority, handled using a team approach, and tightly managed
throughout the project.
The "cloned" removal orders used for PCB remediation at
natural gas pipelines in Region 7 showed that once a team and a
system of operations were developed and a certain amount of trust
among the participants was established, additional sites could be
handled at a virtual lightning-like pace (at least relative to
government time). The innovative "Plug-in" ROD of Region 9, which
was mentioned in the panel discussion, showed similar potential for
facilitating handling and eliminating unnecessary redundancy.
The Big River Mining Site in Region 7 and the "Lightning" RODs
of Region 6 demonstrated how site progress can be expedited
utilizing existing programmatic procedures, when involvement and
commitment to the site are intensified.
Also included in the presentations was a description of the
NCP authorities shared by OSCs and RPMs - there are only two
references that specify OSC and not OSC/RPM - and a description of
how the role of the OSC can be expanded to support Site Assessment
and the Hazard Ranking System (OSC acting as a SAM). The
overlapping authorities have always been in place. It seems that
the separation and entrenchment of the current roles and
responsibilities was caused only by the independent evolution of
the various regional programs.
One presentation, concerning the Solvents Recovery Service in
Region 1, demonstrated how SACM-type expedited response can run
aground on the entrenched perceptions of established programs.
This Site showed the necessity of clear roles and definitions, and
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understanding of the different characteristics/requirements of
handling expedited actions. In essence, a removal action is to be
handled as a removal action, not subject to the restrictions and
requirements typical to remedial, even when it appears in a
remedial context. As presented, the biggest obstacle to speed at
this site appeared to be ORC's request to handle the Site in a more
remedial fashion. Efficiency was lost making the action memo
appear more ROD-like. It was suggested that increased
communication and education for the players early on would do much
to avoid this type of problem at other sites. Specifically, risks
taken at SACM projects (deviations from normal operations) should
be written up and distributed to show how risks taken led to
success and progress.
Similarly, the risk assessment was perceived as the most
difficult and time-consuming portion of an EE/CA conducted for one
of the Region 6 "lightning" sites because it was perceived to need
the exacting quality of a remedial study. It was strongly advised
that in-house, quick and dirty risk assessments be used when
appropriate to determine if a situation falls within the risk
range. It was also suggested that standardized risk assessments
should be developed. Kids eating dirt are the same, no matter the
site, and it should not be difficult to develop a plug-in risk
assessment database.
Also mentioned as an impediment to efficiency and speed are
the lengthy turnarounds for CLP analyses. Discussion suggested
that ARCS and CLP not be used in SACM.
The moderator initiated the Panel Discussion with the
question, "What is the cost of SACM?" In response, the discussion
seemed to focus on the up-front investment of resources dedicated
to the SACM project. One RPM indicated that, when his Site went
SACM, involvement increased from 10 to 40% of his time dedicated to
that Site. The experience of the other presenters was similar.
Consistent teamwork from the beginning and continuity through the
projects also played key roles in facilitating quick response,
especially when using innovative, untested, approaches. The down
side of this is obvious: with a limit on available resources, an
increase in one area necessarily means a decrease in another.
The discussion moved toward perceived obstacles to SACM
implementation. It was noted that some of the innovative
approaches were low on beans. The Plug-in ROD had only one ROD for
multiple operable units. The approach saved years of time and
effort and advanced those operable units rapidly to ultimate
cleanup but produced only one countable accomplishment. The Plug-
in approach also wreaks havoc with CERCLIS/SCAP. With RIs
continuing after the ROD, what pot should expenditures come from?
To address this problem in the light of SACM, it was suggested
that EPA develop different colored beans; start counting what we do
as accomplishments, rather than relying on the definitions
developed years ago. It was generally agreed that CERCLIS is a
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system that is, and always has been, more an impediment than a
planning and support tool.
The presentation comparing the authorities of OSC and RPM
pointed out certain limitations to handling remedial sites or
break-out units as removals. Specifically, RPMs have no warrant
authority. RPMs are currently not trained for and cannot utilize
the ERCS contracts. Many of the regions are at or near their
ceilings for ERCS capacity and therefore must limit their current
use to classic removal actions. The panel discussion identified
other difficulties, such as: there are still perceptions of
animosity and lack of cooperation between OSCs and RPMs in some
regions, and reluctance in some regions for RPMs (already
overburdened) to learn and implement the additional array of
responsibilities necessary to expand into OSC-type work.
Interestingly though, some regions, notably 7, are currently
organized and staffed such that RPMs routinely handle removals as
standard operating procedure.
During the Panel discussion, a brief explanation of the new
contracting strategy was presented by a representative of SRO.
This information indicated that some of the described contracting
limitations are being addressed at Headquarters and may ease the
implementation of SACM. The new Superfund contracting mechanisms
promise to be more flexible, with all contracts directly accessible
to RPMs. It was also mentioned that HQ is working on many of the
areas that were identified as problems in the SRO regional visits;
however, there is a problem in communicating this progress to the
regional staff.
Conclusion:
In summary, SACM presents the potential for speed and
efficiency in Superfund cleanups, but at a cost. There are
obstacles, both real and perceived, and a certain amount of
resistance to overcome. Further, it was brought up that the
Regions have recently expressed willingness to handle only five
"SACM" sites per year, contending that there are too many sites
currently in the pipeline tying up available resources. This
position and language indicates that there is no real support for
SACM and fosters the perception that SACM is just a management
flavor of the month, and the month is almost over. The promise of
fundamental change for Superfund goes unfulfilled. As a poignant
example of this perception, very few RPMs attended this panel
discussion and the general feeling was that those in attendance
were interested only because they were directly involved in the
regional SACM projects.
To conclude on a positive note, the discussions demonstrated
that, although newly packaged as SACM, most of the concepts that
drive current SACM pilots and procedures were developed in the
regions prior to the "New Paradigm of Superfund" and will remain as
viable tools for future site clean-up even if "SACM" does not.
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Recommendations
For SACM projects to be successful, intensified communication and
education for the team members must be initiated early.
Risks taken at SACM projects should be written up and distributed
to show how risks taken led to success and progress.
In-house, quick and dirty risk assessments should be used when
appropriate to determine if a site falls within the risk range.
Standardized risk assessments should be developed (e.g. a plug-in
risk assessment database).
If possible, ARCS and CLP should not be used in SACM.
Revamp the bean counting to reflect clean-up progress and recognize
innovation. Revamp CERCLIS.
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PANEL SUMMARY
1993 NARPM CONFERENCE
Date: Thursday,
Topic of Panel:
Panel Moderator:
Panel Members:
March 18, 1993
Remedial Design/Remedial Action
Bill Haubold
Larry Granite
Region
II
Rocco Grasse
Region
II
Rich Heinz
ACOE
Fran Costanzi
Region
III
Kathleen Warren
Region
V
Michelle Lau
Region
IX
Mary Tierney
Region
V
Armando Saenz
Region
VIII
Miguel Cintron
ACOE
Tom Simmons
ACOE
ISSUES:
Since there were no papers presented during this panel, the
format of the discussion was an open roundtable style. Issues were
developed by the panel members before the discussion, and these
issues were then discussed amongst the panel members and audience.
The following issues were mentioned.
• Performance-based designs do not provide details to track
contractor performance. Also the procurement process takes
longer in order to work out details.
• Descriptive designs are too cumbersome and result in work
order and design amendments during the actual design process.
• The objective of sampling requirements during Remedial Design
differs from the RI/FS objectives.
• Lengthy Remedial Designs because of:
- Excessive State requirements.
- Work assignment requirements too specific;
- Inadequate Responsible Party design submittals;
- Lab data scrutiny is too extreme for RD objectives.
• Cost plus contracts do not provide incentive for the
contractor to do a correct job the first time.
• Procurement process under the Remedial Action cannot begin
until the design is complete.
• Remedial Design start does not account for enforcement
negotiations which can slow down appearance of RD start.
• Land use after completion of construction is not defined nor
planned after O&M.
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Inadequate cooperation between US Army Corps of Engineers
(USACOE) main office and the USACOE district construction
offices.
DISCUSSION:
The open forum discussion provided interaction between panel
members and the audience. There were two objectives with this
format. The first was to highlight issues, and the second was to
present discussion and provide recommendations for issues
highlighted. Since several issues were raised, not all of them
were addressed during the discussion.
The panel discussion opened with Fran Costanzi explaining the
Remedial Design/Remedial Action Guidance Work Group function of
preparing new RD/RA guidance. RPMs are a part of this work group
and are currently drafting the guidance. A handout explaining the
function of the Work Group and a list of the members was provided
to the audience.
The discussion then revolved around soliciting new issues not
previously presented by the panel members. These issues have
already been summarized under the previous section. Since several
issues were presented, there was not enough time to provide
recommendations to all of the issues. However, some suggestions
and experiences from RPMs were presented.
RECOMMENDATIONS:
Specific recommendations are as follows:
• RI/FS guidance should specifically outline the difference in
sampling objectives between the RI and the remedial design.
• The RD/RA guidance currently being written should include a
section on RD sampling objectives. In addition, the guidance
should also provide input on how the RI information should be
incorporated into the RD.
• Training should be given on the objectives of RD sampling.
• One suggestion to alleviate lengthy designs was to provide
off-the-shelf designs for certain remedies that did not
require innovative designs or site specific technology. A
section on these type of designs should be included in the
RD/RA guidance.
• One recommendation was for the implementation of an on-board
review of the remedial design for specific projects.
• One recommendation for the issue of future land use is to
provide input into guidance that is being prepared on future
land use.
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• A suggestion was made to have NARPM formally support
performance-based designs as an organization.
• A recommendation for the problem of waiting for the design to
be completed before a design can be bid is to include the
bidding process as one of the design tasks. This was
recommended by Armando Saenz of Region 8. The results of this
recommendation would allow the contractors performing the work
to be on-line when the remedial design is complete.
RESOURCES NEEDED TO IMPLEMENT RECOMMENDATIONS:
The current work group will be the most valuable resource to
implement or explore the recommendations presented by the panel and
audience. This work group should be provided with NARPM's support
to complete the guidance. This support should be in the form of
written advocation for the need of this guidance. NARPM should
contact the Headquarters' chairperson for the work group, Jo Ann
Griffith, and communicate the importance of this guidance.
Second, NARPM members should specifically bring issues regarding
RD/RA to their regional work group members or the Headquarters'
contact person, Jo Ann Griffith. The resources necessary to
execute this recommendation would be any individual's time to
contact the appropriate person.
Third, if the work group does not have the resources necessary to
complete the guidance in a timely manner, then NARPM should support
this group by providing individuals willing to become a part of
this group. Specific recommendations for completion of the
guidance would be developed in coordination with the work group.
IN SUMMARY:
This summarizes the events for the RD/RA panel discussion and
subsequent follow-up. If you should have any questions, please
call me at (312) 353-6261. Attached is a copy of the handout
distributed at the panel discussion.
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UP-DATE ON RD/RA WORKGROUP
March 12, 1993
RD/RA Handbook
A regional workgroup, consisting of staff from Headquarters and
seven of the Regions, is working on updating the Remedial
Design/Remedial Action Guidance which was last revised in 1986.
The revised guidance handbook will be separated into Federal-lead,
Enforcement-lead, and State-lead sections and will focus on RPM
project management principles. The targeted dates for submittal of
draft chapters are as follows:
Draft Federal-lead chapter (for regional review) May 1993
Draft Enforcement-lead chapter (for workgroup review) July 1993
Draft State-lead chapter (for workgroup review) August 1993
Draft RD/RA Handbook (for regional review) 09/30/93
Guidance on Remedial Design Scoping Chapter
Guidance is also being drafted that will provide information on the
steps taken to get a remedial design underway. This chapter is
being released prior to the other chapters of the handbook. The
scoping guidance will cover: 1) project planning (including the
selection of RD/RA contract types; 2) collecting pre-design
technical information; and 3) preparation of the RD independent
government cost estimates (IGCEs), schedules, and statements of
work. A fact sheet explaining the guidance has been drafted and a
second fact sheet describing the use of ARCS "standard tasks" in
preparing RD/RA work assignments will also be prepared. Design and
Construction Management Branch (DCMB) staff will be visiting
regions to present the guidance. Presentations on the guidance are
tentatively scheduled for May 15 for Region III, May 30 for Region
IV, and June 15 for Region VII. Visits to the other regions have
not yet been scheduled. The contact person at Headquarters for the
scoping chapter is Ken Skahn at (703) 603-8801.
RD/RA Workgroup
A list of the staff on the RD/RA workgroup is attached.
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RD/RA WORKGROUP
March 12, 1993
Name
Jo Ann Griffith
Luis R. Lopez
Lori Frigerio
Fran Costanzi
Gene Wingert
Randy Sturgeon
Bill Bolen
Ed Hanlon
Earl Hendrick
Steve Auchterlonie
Mike McCeney
Ken Erickson
Jo Ann Cola
Region Phone Number
HQ (703) 603-8774
2 (212) 264-9005
2 (212) 264-7022
3 (215) 597-3923
3 (215) 597-1727
3 (215) 597-0978
5 (312) 353-6316
5 (312) 353-9228
6 (214) 655-8519
7 (913) 551-7778
8 (303) 294-7169
9 (415) 744-2324
9 (415) 744-2238
Bob Curnyn, USACE, Missouri River Division (402)
Wren Wilson, USACE, Huntington District, VA (304)
221-7388
576-9901
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PANEL SUMMARY
1993 NARPM CONFERENCE
Seattle, Washington
Date: March 17, 1993
Topic of Panel: Groundwater RI/FS
Panel Moderator: Jeff Gore
Panel Members: Rene Fuentes, Keith Rose, Eva Hoffman, Sharon
Jaffess, Jeff Gore, John Kuhns, Ralph Howard, Tony
Able, Turpin Ballard and Kathy Setian
Issues: (l) Defining groundwater plumes
(2) GIS (Geographical Information Service) applications
(3) Low-velocity sampling for metals
(4) Providing data on disk or in a format rather than
hard copies
Discussion:
(1) Concern over additional RI work — When is it justified?
— How much is duplication of effort?
(2) It's applicable for data input — would rather look at a
map than a bunch of data. One person had problem of
entering data on proper components.
(3) Different Regions have different procedures for using
filtered samples, bailers and pumps. Policy differs in
Regions.
(4) EPA doesn't have a standard for providing data on disk.
Recommendations:
(1) Each situation is site specific and should be researched
individually, but duplication of effort should be
avoided.
(2) Need a Regional expert or contact person.
(3) Know Regional policy on sampling procedures and
variability of them.
(4) Need to have approved software package for EPA or
contractors.
Resources Needed to Implement Recommendations:
FCD: March 4, 1993: (2) HQ has a strategy for working with GIS.
Don't currently have contact; (3) Need up-to-date QAS material or
guidance; (4) Need to have contract to provide service. Also, the
Agency needs better information management.
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PANEL SUMMARY
1993 NARPM CONFERENCE
Seattle, Washington
Date:
Topic of Panel:
Panel Moderator:
Panel Members:
March 18, 1993
Site Completion
Jamie VanBuskirk
Donna Vizian
Jim DiLorenzo
Randall Chaffins
Sven Kaiser
Region 6
Region 2
Region 1
HQ
HQ, SRO
The Site Completion Panel Discussion was preceded by three Paper
presentations:
• Five Year Review Reports at Superfund Sites, presented by
Thomas Bloom, Region 5.
• Five Year Review and Close-Out of Pre-SARA Sites,
presented by Jennifer Wendel, Region 5.
• Remedial Action Construction Completion at the Defense
Distribution Depot, presented by Sandra Bourgeois, Region
8, and Muhammad Slam. Utah DEQ.
Each presentation discussed various aspects of the Site Completion
process. The subsequent Panel discussion included brief
presentations by HQ concerning the Site Completion process and the
importance of "Construction Completions" as well as topics raised
during the Paper presentations.
issues:
Quite clearly, the main issue raised throughout the Panel
discussion revolved around the timing and definitions of the
various Site Completion activities. Much confusion was expressed
concerning when to write a Preliminary Close Out Report, Final
Close Out Report, RA Completion Report, 5-Year Review, etc. In
addition, in attempting to answer these questions, several
different views on definitions for RA Start, RA Completion,
Construction Completion, Site Completion, O&F, O&M, etc., were
expressed which clearly showed the confusion that exists
The definitions and timing of these activities were further
confused when the factor or SCAP commitment definitions were
discussed and their relevance to the Site Completion definitions.
It is not clear that the definitions are the same in both areas.
Confusion reigned supreme when these discussions attempted to bring
in how the definitions were effected by a site with several
Operable Units. All of this confusion is most disturbing
considering the high importance that Site Completions has in the
Superfund Program. In addition, little time was devoted to
discussing the actual contents and preparation of the reports
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because a common understanding of the definition and timing of
post-RA completion reports is lacking.
RECOMMENDATIONS:
It became clear to the moderators that several factors have
contributed to the confusion that surrounds the area of Site
Completions. These factors include:
1) RPM ignorance. The RPMs have not been exposed to these
activities because site completions have not been as important
in the past (as compared to RODs, for instance) and not many
sites have made it to this stage of the remedial process.
2) HQ is continuously revising or increasing the number of post-
RA site completion activity definitions. Although HQ has
prepared a Superfund Completion Care Package for the purpose
of reducing confusion by centralizing completion guidance, it
is not up-to-date (it is already being revised), it has only
been issued to RPMs that are scheduled for Construction
Completion in the near future (thus sustaining other RPM's
ignorance), and it is difficult to know if this Care Package
is consistent with other Superfund Program entities (such as
SCAP).
It is recommended that the revised Care Package include an all-
encompassing discussion of the definitions and timing of the
numerous post-RA Site Completion activities. It is important that
all RPMs become exposed to these definitions regardless of a
pressing need. A good understanding of site completion issues is
important even at the remedy selection stage because RODs and
Consent Decrees need to discuss the post-RA requirements in detail.
It is also recommended that HQ continue to press the importance of
Site Completions. It appears that some RPMs are not hearing the
message, perhaps thinking that this is the latest "buzz word" issue
which will soon be replaced by another. HQ, by developing the Care
Package and holding monthly Division Director conference calls and
quarterly staff level conference calls, is doing their part in the
effort to provide Site Completion guidance. It is time that the
RPMs get involved, regardless of their immediate need to develop a
post-RA report or not. Each Region should form a Regional Site
Completion Peer Review Panel headed by a senior RPM. This panel
can act as both the collector and disseminator of Site Completion
guidance and policy as well as promote consistency and quality.
The Panel would also be responsible for providing training and make
sure that all RPMs grasp the importance of Site Completions.
RESOURCES NEEDED TO IMPLEMENT RECOMMENDATIONS:
No significant amount of resources should be necessary to implement
these recommendations.
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RPM PROFESSIONAL DEVELOPMENT IN THE 90'S
Summary Report
Panel Moderator: Laura Williams, RPM; Region VIII
Panel Members: Randy Smith, Director
Hazardous Waste Division; Region X
Richard J. Guimond, Acting Assistant Administrator
OSWER; HQ
Tim Brincefield, RPM; Region X
Steve Sandler, RPM; Region IV
Damian Duda, RPM; Region II
Fran Costanzi, RPM; Region III
Meg Kelly, Acting Office Director for TIO; HQ
MaryAnn Abrahamson, RPM; Region VI
Peter Ismert, RPM; Region VIII
The RPM Professional Development Panel was a new addition to
the NARPM conference this year though not because of a lack of
interest. The term "Professional Development" is a very broad
umbrella and can encompass almost as many scenarios as there are
RPMs. The panel focused on the existing OSC/RPM Support program
initiatives and accomplishments as a starting point for soliciting
input from panel members, particularly management, and the
audience. It was recognized that one of the most visible results
of the Support Program is HQ's partial payment of hotel rooms for
RPMs attending the NARPM conference and the attendance of Rich
Guimond as the conference keynote speaker.
MaryAnn Abrahamson provided a brief synopsis of the
circumstances and events which resulted in the OSC/RPM Support
Program. A 1989 study determined that Superfund management jobs
are among the most difficult and diverse of professions (see
attached "bubble chart"). In addition, turnover among key
Superfund field personnel was greater than 20 percent. The study
concluded that Superfund managers were an "elite force" requiring
superior technical, administrative, managerial and communications
skills. Therefore, the OSC/RPM Support Program was created. The
Program included:
The Superfund Academy,
SUTI training,
The STEP program,
Regional/National Awards, and
GS-13 career positions, and Possible GS-14 promotion
potential.
Tim Brincefield followed with an overview of the status of
RPMs since implementation of the Support Program. The attrition
rate of RPMs is down even though the job is as difficult as ever.
We have a new President and Administrator. The Superfund program
has set and met ambitious goals for the last two years while
simultaneously emphasizing new initiatives and ways of doing
business - SACM. Despite our accomplishments, the program
continues to take criticism and resources are flat or declining.
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It was stated that investment in Professional Development should
not be discontinued or decrease.
A forward approach to Professional Development was to assess
how the Superfund program is changing and what RPMs need to do to
prepare themselves to meet the goals of the program. Also, what
support can/should NARPM, the Regions, and HQ provide? These
thoughts are presented below.
Damian Duda presented some initial recommendations (attached)
developed by a Region II focus group to enhance the career
opportunities of RPMs and improve RPM job satisfaction. The
recommendations are composed of two basic interrelated categories.
The first category supports the development of RPM experts and the
second envisions the creation of a Technical Advancement Ladder.
The Ladder would also encourage the development of RPM experts.
Randy Smith presented his view of "What would I do if I were
you?" It was felt that broadening the types of sites which you
work on by working on different sites/programs could help to avoid
"burn-out." This would include looking for rotations that broaden
the RPM experience. He urged RPMs to not spend the whole time as
captives of their projects.
Rich Guimond felt that RPM was a misnomer and that an RPM must
be a leader. Therefore, helping RPMs to improve as leaders would
contribute to their professional development. Rich also urged RPMs
to not only find a mentor but also to be a mentor.
Meg Kelly provided some updates on the OSC/RPM Support
Program; the Superfund Academy has become the CERCLA Education
Center (CEC) and only criteria for the "master level" is still
tracked for the STEP program. Finally, the support program has
endured because it was developed properly.
An open panel discussion led into the audience question and
answer period. Because the panel discussion was held to a strict
time frame, additional issues which were not brought up during the
actual panel are also presented below as "Other Issues/Concerns."
The majority of comments presented by the audience or panel members
were in the form of comments with recommendations. These
recommendations are summarized below without modification. No
opinions or commitments by management, either regional or HQ,
should be assumed unless specifically indicated. The RPM panel
members urge NARPM to formally present the comments/recommendations
to HQ management.
Comment: It is difficult to get GS-14 positions because RPMs lack
"management" experience.
Recommendation: Recognition of RPMs' management and contract
administration skills by HQ and management. Incorporation of
these skills into a generic RPM position description (general
RPM position descriptions are already developed in some
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regions).
C: HQ rotations (usually 3 months) to SRO often lead to RPMs
doing site-specific work rather than providing input on
guidance, regulations, etc.
R: Plan a one-week schedule for a topic to be discussed. Then
bring in a panel of RPMs (10-20) to meet with the appropriate
HQ personnel or regional coordinators. This will provide a
much wider perspective on any one issue and will not be any
more costly than a 3-month rotation for one person. Also,
more RPMs will gain exposure to HQ.
C/R: Provide needed and appropriate training:
- Current project focus is on RD/RA
- Managerial Training
- Contractor training (Meg stated that an enhanced
contract training program should be pilot-tested in
July '93)
C: SUTI training is available but there are no dollars for
travel.
R: Provide dollars dedicated for SUTI training only.
C: The advisory group has been a vital mechanism for RPM input
into their own professional development but appears to have
been discontinued sometime during the past year.
R: Continue the Advisory group and provide for continued RPM
input.
Q: How will RPMs be able to go on rotations/details if the
regions can't backfill their positions (hiring freeze) and it
is also being proposed that OSC/RPM FTE be decreased by 11
positions to achieve the Agency's 2.5% reduction?
A: (Rich Guimond) If anything, Rich felt there would be more
positions in Superfund.
Other Issues/Concerns
C: Within many regions, RPMs are evaluated according to a higher
standard than other EPA employees. This affects an RPM's
ability to apply for positions in other areas of the Agency,
particularly supervisory positions. QSIs or other monetary
awards are, therefore, also more difficult to attain or less
in value than comparable work in other areas of the Agency.
R: Require a standard type of performance evaluation throughout
the Agency with equal amounts of cash awards and QSIs for all
employees receiving the same evaluation (i.e., award money is
not distributed by Division/Branch). Perhaps this is
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idealistic, but it is still worth striving for and is more
fair to all employees.
C: There is concern that management (both regional and national)
appears to be apologetic about the Support Group benefits for
RPMs, especially the capability to attain GS-13s and receive
regional/national awards (also referred to as the "the
deification" of RPMs). This affects general RPM morale on a
subtle, though no less devastating, level such as the Browner
quotes about mismanagement.
R: Revitalize management's psychological support for RPMs. This
costs nothing and can vastly improve RPMs as well as support
staff morale.
C/R: Continue to support attendance at NARPM conferences through
payment of hotel rooms by HQ. HQ should encourage and support
sending 25 percent of RPMs from each region to NARPM.
C/R: Evaluate/implement remaining Support Program recommendations
including 1) award bonuses to staff who stay with EPA, 2)
early retirement options, 3) sabbaticals, and 4) specialized
training outside the government in exchange for additional
government service.
C/R: Direct funding from HQ for a set amount of training/travel $
per RPM for the RPM to use at his/her discretion for
Professional Development opportunities (regional funds have
too many competing priorities).
C/R: Provide a NARPM bulletin board such as the OSCs already have
so that RPMs can better communicate between regions about
particular site concerns/issues.
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REGION II
3/12/93
DRAFT PROPOSAL FOR IMPROVING
THE REMEDIAL PROJECT MANAGER WORK FORCE
Abstract
This proposal outlines several recommendations for enhancing the
career opportunities of RPMs and improving RPM job satisfaction.
The recommendations were developed by a focus group of Region II
RPMs over a three-month period.
The recommendations fall into two basic interrelated categories.
The first category of recommendations support the development of
RPM experts - RPMs who, in conjunction with their project
management duties, develop expertise in a particular area having to
do with Superfund site remediation. Several of the group's
recommendations are aimed at supporting the development of RPM
experts. To assist in this effort, it is recommended that the FRRD
Training Coordinator position be revamped in order to serve as the
focal point for and as an active supporter of developmental and
training opportunities for RPMs.
Equally as important, the second category supports the development
of a Technical Advancement Ladder for RPMs. The existence of such
a ladder should encourage the development of RPM experts. The
details of the technical advancement ladder are supplied below.
Several other supplementary recommendations are also presented.
The group will be presenting its findings to ERRD management in the
coming month.
Background
The RPM Career Issues Focus Group is composed of Damian Duda,
Sharon Jaffess, Christos Tsiamis, Lisa Carson, Gary Adamkiewicz,
Alison Barry, and Laura Lombardo. The group met over a three-month
period and were charged with developing recommendations to improve
career opportunities and job satisfaction for RPMs. The group was
formed in response to concerns raised to ERRD management by an RPM,
Christos Tsiamis.
The group met several times over a period of three months to
brainstorm and discuss potential improvements to RPM career
opportunities. Many of the potential recommendations were
solicited from RPMs during a regional NARPM meeting. The
recommendations were compiled and will be presented to ERRD
management.
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General Recommendations
The group determined that RPM job satisfaction and morale would
best be addressed through improving RPM career opportunities and,
thus, developed several specific recommendations for expanding RPM
career options. These recommendations include 1) the development
of an individual career plan for each RPM; 2) the identification
and equitable distribution of training and developmental
opportunities; and, 3) development of a technical advancement
ladder for RPMs.
It is important to note that the by-product of the career plan,
training, and rotational assignments is the development expertise.
Once an "expert", that RPM may be eligible for technical
advancement.
Specific Recommendations
Creation of a Technical Advancement Ladder
- It is recommended that a Technical Management Ladder be
created to augment the existing administrative management ladder
and to allow highly skilled, experienced, and expert RPMs to
provide technical leadership to the less experienced ones. At
present, RPMs with 10-20 years private industry experience and/or
expertise in specific remedial areas and RPMs who are recent
college graduates are given identical responsibilities in managing
multi-million Superfund projects where they 1) make decisions
concerning the extent of the required work, 2) negotiate with
contractor teams (organized in a hierarchical order with the more
experienced engineer spearheading the contractor's effort), 3) make
technical judgments on the value of comments and recommendations
provided from within the agency, from other agencies, and from the
public.
- It is recommended that two team leader positions per section
be created. The team leader position will be a Grade 13, Step 5
position. Accordingly, approximately 20 new technical management
positions will be created within the Division. However, if the
person selected for the position is already at 13/5 level or
higher, the advancement to the position will amount to a quality
step increase.
- Alternately, technical management positions could be created
in the form of Assistant Section Chief-Technical Management. These
would be Grade 14 positions. Approximately 10 new technical
management positions would be created within the Division.
- It is recommended that a council of Project Management
Technical Advisors (experts) be created, functioning as Assistants
to the Director. These individuals would advise the
Director/Deputy Directors on issues involving technology, project
economics, regulatory issues, project contract management, among
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others. It is envisioned that the council would consist of 3-5
experts and would be a Grade 15 position.
The qualifications and precise duties of the aforementioned
recommended positions would be developed by RPMs and approved by
management. However, advancement would be directly related to the
development of expertise in the areas of Superfund remediation.
All positions would be filled on a competitive basis.
A reorganization of the RPM work force along the lines recommended
above would improve Superfund's efficiency and its effectiveness in
controlling costs and accelerating cleanups. The close supervision
of the less-experienced RPMs by those more experienced within the
recommended technical hierarchy would reduce the allocation of
resources to administrative support programs designed to counteract
deficiencies at the RPM level.
Revamping the ERRD Training Coordinator Position
- Create a full-time position within the Emergency & Remedial
Response Division, Program Support Branch, Planning & Information
Management Section or utilize a current staff position (add job
responsibilities to the performance standards and allot at least
50% dedication to this position).
Responsibilities:
® Serve as the focal point for the dissemination of the
training, education, rotational assignments to ERRD
employees. Duties will include: expanding rotational
assignment opportunities, i.e., shadow (acting as special
assistant) an OSC, the ERRD Division Director, a Division
Director in another Division, a Deputy Director/Branch
chief, a RCRA permit writer/inspector for 6 months;
having a two-week assignment on the Water Management
Division's boat(s); switch positions with an RPM in
another branch for 6 months, with an RPM in another
Region for 6 months; secure a HQ's detail; assist a
university professor in an environmental course. Job
switching is viable where you know the job and shadowing
is required when there isn't the time to become
proficient at the job. Perhaps, a job switching can be
enacted after a shadow assignment with another staff
person has been completed.
• Initiate and organize a library dedicated to education,
training, and federal career information. The library
must include both "paper" information and information
available from the myriad of computer bulletin boards.
• Create a database to serve as the index for the
aforementioned library. Update and maintain this
database.
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• Assess training/education opportunities within the tri-
state (local) area and maintain contact with training
institutions/universities.
• Assess rotational opportunities within EPA (nationally or
regionally), other Federal agencies, State agencies, and
non-profit organizations.
• Create, maintain and update a database to track the
training, education, and rotational assignments of ERRD
employees, registering proof of employee completion of
training/education/assignment.
• Serve as an advisor to ERRD employees seeking federal
career guidance.
• Coordinate with the OSC/RPM Support Program and any other
applicable HQ's programs and serve as EPA Region II
liaison with such programs.
• Assess training needs of ERRD staff and develop in-house
training programs (technical and administrative) to meet
these needs. Appropriate Divisional and Regional staff
may serve as instructors. An in-house training program
will be used to supplement extramural training, limited
by budgetary constraints, as well as, to provide training
that is specific to the staff's needs. Informational
seminars on environmental topics, such as those conducted
by ORC, may also be developed utilizing non-EPA speakers.
Assign Sites and Projects based on Individual Interests and
Background
- Maintain a list of individual RPMs' education, interests and
background, including previous employment history, professional
decrees or certifications, stated preferences for site assignments,
participation in workgroups or special projects, etc. This list
would be used to assist management in assigning sites and overall
workload. Upper management could use the list to assign special
projects.
Other Recommendations
Conduct an RPM retreat (run through the regional NARPM group).
At the retreat, RPMs will brainstorm to come up with a group
definition of job satisfaction. This definition will then be
used to derive ways of meeting that goal.
Encourage the establishment of individual career plans for
each RPM which would be used as a guide for an RPM's training
requirements/development into an "expert"/rotational
assignments'site assignments. The plans should not be
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mandatory, since every RPM may not have a "career plan"; or,
if they do, they may not want to publicize it. The plans
should not have an associated deadline, since this may not
increase morale but instead create two group of RPMs: those
who are "career-oriented" and those who are not.
If every RPM had a career plan, the limited travel and
training budget could be optimized and not wasted by sending
staff to training courses that are not within their required
training needs. There are certainly training courses every
RPM needs to fulfill his/her role as a general project
manager. However, specialized courses (e.g., fracture flow
course) should be reserved for those becoming hydrogeologic
experts, whereas a general groundwater course should be a
requirement for every RPM.
Even an RPM with no particular desire to be an RPM expert
needs to be satisfied with his/her job. Therefore, a general
career plan can be developed that would be structured around
general project management skills.
Consider ways to make the distribution of travel and training
more equitable, including the possibility of dividing the
travel budget based on needs rather than on program
constraints.
Staff should be encouraged to pursue graduate work at area
universities with the financial support of the Division. The
option of enrolling in full-time study through extended leave-
with-pay should be explored for some individuals, in exchange
for their commitment to future work within the Division.
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COMMUNITY RELATIONS ISSUES
SUMMARY REPORT
Panel Moderator: Laura Williams, Region VIII
Panel Members: Brad Bradley, Region V - presentation
David Rosoff, Region II - presentation
Fred Schauffler, Region IX - presentation
Dave Kluesner, Region IV - presentation
Kevin Mayer, Region IX - presentation
Marc Herman, Region VIII
Ken Lucas, Region IV
Diana Hammer, OSWER: HQ
Bob Lance, Region V
Introduction: The Community Relations (CR) panel consisted of six
presentations followed by a directed panel discussion. The
majority of the presentations dealt with unexpected issues
which did not arise prior to the site Record of Decision.
Panel members felt that previous Community Relations issues
identified in the 1992 NARPM conference were still valid.
1. Site communities have a negative perception of "the
Government" particularly technical expertise and
Government control of their lives (1992) . No further
discussion of this issue occurred.
2. The State, environmental groups, and/or PRPs often have
secret agendas and goals which conflict with each other
or EPA (1992) . No further discussion of this issue
occurred.
3. The Site community becomes more interested after the ROD
is signed (1992). This topic generated a great deal of
discussion since most of the presenters and audience are
now in the RD/RA phases. An important subissue was
obtaining access (by EPA or PRPs) for off-site
requirements of RD/RA such as well installation or road
access/transportation. Many felt that there was a
definite profit motive on the part of property owners
adjacent to Superfund sites, particularly in more
economically disadvantaged areas. With similar motives,
a community which could not be affected (because they are
upgradient) by a nearby Superfund site has continuously
impeded access because they feel that active construction
activities will decrease their property values.
A second reason for post-ROD community involvement is
that many poorer communities can easily be misread by EPA
such as occurred at NL Industries/Taracorp lead smelter
site. Because some members of the community couldn't
read, they weren't reading the public notices being
mailed. Because of their economic situation, they also
couldn't attend public meetings which were several miles
out of town. But once real activities began to occur,
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the community became very aware that something was going
on.
4. CR causes additional work which requires time, resources,
and funding (1992) . This will more than likely become a
larger issue as resource and funding cuts begin to be
felt.
New Issues
Environmental Equity was an issue at the Prewitt Refinery
which is mostly owned by the Navajo Nation. Contaminated ground
water affects off-site, non-Navajo families who are downgradient to
the site, though remedy selection considerations included potential
residential use of the site property by the Navajo nation. Prior
to remedy selection, both EPA and the Navajo Nation were in
agreement with the residential cleanup requirements included in the
proposed plan. However, at the same time that the ROD was being
signed, the Navajo Nation and PRPs signed a land exchange agreement
which conveyed all site property to the PRPs. While the off-site
families continue to be impacted via the contaminated ground water,
the Navajo Nation no longer concurs with the selected remedy which
brings up potential reverse environmental equity issues.
A success story outlining the use of a non-EPA Technical
Advisory Committee (TAC) for a large ground water contamaination
site was presented by Kevin Mayer. The TAC was started at the same
time as the Remedial Investigation and includes regulators, local
water supply agencies, and a group of professors from a local
university to achieve a credible and positive relationship with
local communities and the various entities involved.
SACM, particularly presumptive remedies, is expected to have
a big impact on CR. Diana Hammer stated that guidance on the CR
issues is expected sometime in the fall of 1993 (or shortly
thereafter).
In the spirit of SACM, it is important to acknowledge progress
at Superfund sites. Laura Williams briefly discussed a video
produced for the North Dakota Arsenic Trioxide Site. The 11-minute
video documents completion of the Superfund site in a realistic
manner (i.e., community was generally distrustful of "the
Government" and saw no real reason for the project). While a
completion video does not directly benefit the individual site, it
does promote positive aspects of the Superfund program on a
regional and national level. Copies can be obtained from Laura.
The remaining discussion was general in nature including the
observation, "I hate the public meeting." This sentiment was
echoed by the majority of the panel members and audience. Diana
Hammer felt that RPMs could (should) rely on their Community
Relations Coordinators (CRCs) for more support, especially as
resource/funding becomes limited. The general consensus was that
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RPMs get relatively little assistance from the CRCs now and do not
expect to get more help later. Overall, RPMs have no control in
determining the sites which CRCs will work on. CRCs are assigned
to the "important", high-profile sites while the remaining RPMs
must direct the CRCs in doing the low-profile CR site work, or RPMs
just do the work themselves. Diana suggested that some control
could be regained if CRCs were in the same Branch/Section as the
RPMs with the same supervisor.
Recommendations! Recommendations resulting from the discussion
outlined above were directed at communicating more effectively and
humanly ("What if this were your home [at/near the site]?") with
site communities.
Get to know your community! Even if the community has
been contacted and identified before, communities and
feelings can change - especially after the ROD.
Subscribe to the local paper so you can keep up with
issues.
- During construction activities, make sure there is a 1-
800 number publicized for community members to call you.
Issue frequent fact sheets and hold press
briefings/availability sessions to meet the public and
provide factual information. This helps avoid rumors and
misinformation.
One business (a well-known restaurant) avoided the stigma
of "Superfund cleanup in progress" by putting up a
"REMODELING" sign.
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Summary of RD/RA Paper Presentations
Note: This session only included paper presentations related to
RD/RA (i.e. not panel discussions) and therefore the recommended
format was not used. The RD/RA Panel will be summarized by Bill
Haubold.
The first two papers in this session were on soil washing. The
first paper by Erna Acheson (Region 8) and Patrick Augustin (ORD-
Edison) discussed a treatability study performed in October 1992 to
assist with the Remedial Design on a site near Denver, Colorado.
The second paper by Gary Adamkiewicz (Region 2) took the soil
washing process further to the Remedial Action at an acid
processing site located in New Jersey. After an initial bench-
scale study of the New Jersey soil, the contaminated soil from the
Site was shipped to Holland for the treatability study. The
differences between the projects related to the phase of cleanup
and the rate of treatment (the ORD mobile unit can process 150
lbs/hour and the large unit in Holland can process approximately 25
tons/hour). Both papers supported soil washing as a feasible
alternative for cleaning up a variety of contamination. The New
Jersey site, a PRP site, plans to be in full-scale operation in
June 1993.
Gayle Garman (Region 1) provided an impressive "new RPM war story"
on the New Bedford Harbor Site in Massachusetts. Not only did she
face very high PCP contamination (2000 ppm), she also had strong
public opposition to the remedy selected in the ROD (incineration).
Misinformation raged in the community of 400 residents and with
elected officials. Gayle contacted EPA's Risk Reduction Lab for
help. The lab provided great support including tables detailing
the performance standards for incineration. She was then able to
respond to community concerns by comparing this technology to
others the community was recommending.
Linda Nachowicz (Region 5) provided a different type of "war story"
associated with an innovative technology - In-situ vitrification
(ISV). It was applied at a Michigan agriculture manufacturing
facility. The ISV volatized DDT, dieldrin and chlordane and
immobilized the metals, but it also had limitations. The major
ones were site set-up and high moisture content. These limitations
added to the cost. She does not consider ISV a true in-situ
technology. Anyone considering using this technology should call
her.
James Hahnenberg (Region 5) opened his talk by referring to this
experience on a Michigan 0.5-acre lagoon site. Although originally
estimated at one month, it took the PRPs 1.5 years to clean up the
lagoon. James faced state ARAR issues and requests to have off-
site disposal or treatment of soils. Also, he had legal problems
in modifying the Consent Decree. The PRPs were paying $4,000/day
for stand-by operations. So being in a bind, he worked to bridge
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the communication gap and the soils were eventually taken off-site.
It is now a clean site; however, the PRPs paid a hefty price. The
State and EPA have communicated better since the incident.
John Banks (Region 3) began his presentation by giving some
information on the Brodhead Creek Site, a former coal gasification
plant. He then mentioned that EPA entered into a CD with the PRPs
in September 1992 for implementation of the CROW (Contained
Recovery of Oily Waste) process which involved the injection of hot
water to displace and mobilize the coal tar accumulation with
subsequent recovery in production wells. The CROW process is
planned to be implemented by the EPA SITE Program concurrently with
the PRP RD/RA. Incentives provided to the PRPs include lower costs
since they will be permitted to use SITE information and selected
sampling data. The CD also provides a clause that, in the event
that EPA issues a new or amended ROD for the operable unit, the
PRPs would not be obligated to perform any aspects of the selected
remedy that are different from the remedy in the CD. Benefits
derived by EPA include site cleanup and progress toward evaluating
and applying innovative technologies. Consequently, a cooperative
relationship has developed between EPA and the PRPs.
Lawrence Granite (Region 2) talked to us about the Helen Kramer
Landfill which encompasses a 66-acre refuse area. Construction of
the RA has been completed. It included the following:
multi-layer cap;
remediation of on-site lagoons;
slurry wall;
roller-compacted concrete retaining wall;
groundwater/leachate collection trench;
pretreatment of leachate;
active gas collection and treatment system;
surface water controls;
security fence;
monitoring program;
0 & M.
He provided a brief history of the site and a review of the
construction activities focussing on access to GCUA (Gloucester
County Utilities Authority) and the transfer of site
responsibilities from EPA to the State of New Jersey for 0 & M.
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PANEL SUMMARY
1993 NARPM CONFERENCE
Seattle, Washington
Date; March 19, 1993
Settlement Issues
Moderator: Ruth Rzepski
During the Bankruptcy during RI/FS presentation, it was
pointed out that the bankruptcy laws and recent decisions are
confusing when they run up against environmental cleanup law. Can
we order a bankrupt PRP to clean up? If EPA can put a cash value
on the cleanup or has the option of conducting the clean-up and
then cost recovery (and don't we always have that option"), it may
be ruled to be just another claim that will be considered in the
settlement like all other claims. If, however, the PRP owns the
property, an injunction to clean up the property may be considered
an administrative expense and be directly implementable by the PRP
because it would be "maintaining the estate". However, if EPA can
put a cash value, it may again be ruled a claim. In essence, see
your attorney for the latest, and prepare to generate a complete,
but qualified, proof of claim.
It was also shown, by two examples, that the PRP may change
from their opening position, as they become better versed in
bankruptcy proceedings. A verbal, written, or even publicly
announced commitment to continue site work may later be determined
to have been an "unfortunate statement". The recommendation of the
presenter is to be proactive. As soon as work stops, confront the
PRP and demand, by a reasonable date, that the PRP generate and
propose the exact petition (not just a promise) to the bankruptcy
court for continuing work. In this way, the uncertainty of the
pre-petition period is minimized and the ruling of the bankruptcy
court is expedited, so that, if the petition is disallowed, the RPM
can move forward on the project. If the agreed-upon petition date
is exceeded, good faith has not been satisfied and the project can
proceed as a funded takeover.
The focus of the New Cost Recovery Rule presentation was to
get RPMs to realize that the new rule will definitely affect the
way RPMs do business with DOJ when it comes to Cost Recovery cases.
The new rule requires that more detailed documentation of costs be
provided. The problem for most Regions is that much of this work
performed documentation for past cost is stored at EPA
headquarters. Although the rule is only proposed, DOJ is
requesting the documentation of the proposed rule for current
cases. The problem is getting the resources to seek, find and
generate this work performed documentation. Each Region needs to
address this issue and come up with a method for providing the
required documentation for past costs as well as address the
provision of future costs.
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Another presentation was on the use of Alternative Dispute
Resolution (ADR) as a settlement tool. ADR involves the use of a
third-party to aid in resolving disputes with PRPs through the use
of mediation, arbitration, fact-finding and mini-trials. Dave
Batson (202) 260-8173 is the headquarters contact who arranges for
the facilitator. There should be a contact in each regional office
as well. There is no cost to the Regions when using ADR. The
costs for the facilitator are paid for by headquarters and the
PRPs. The presenter indicated that more application from the
program of the ADR process should be considered. The ADR process
has the potential to settle enforcement disputes at lower costs and
lower use of resources than the "alternative which is going to
court.
In the Missouri Electric Works presentation, it was pointed
out that proactive community relations not only can increase the
communities' acceptance of the remedial alternative chosen by EPA,
but also aids in the settlement process when you have complex cases
with a large, diverse group of PRPs.
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PANEL SUMMARY
199 3 NARPM CONFERENCE
Seattle, Washington
Date: Wednesday, 3/17/93
Topic of Panel: Ground Water RD/RA
Panel Moderator: Howard Orlean - Region 10
Panel Members: Margaret Guerriero - Region 5
Beth Reiner - Region 5
Carl R. Froede Jr. - Region 4
Peter Feldman - HQ - OERR - HSCD
Jeff Gore - Region 5
Tom Barounis - Region 5
Wayne Praskins - Region 9
Issues:
Innovative technologies for remediation of ground water (ground
water sparging, biodegradation)
Disposition of extracted ground water
Determination of technical impracticability of ground water
remediation.
Discussion:
Most of the discussion centered around the determination of
technical impracticability for ground water remedies that may not
be achieving desired cleanup goals. As HQ guidance and
recommendations are developed re: technical impracticability, RPMs
will be kept informed and will be involved in the review process.
Recommendations:
Due to the large interest of the audience with respect to all the
papers presented, there was no time for panel or audience
recommendations to be made. Every paper presented generated huge
interest, and therefore it is important that a compendium of
abstracts be produced as a result of the conference.
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PANEL SUMMARY
1993 NARPM CONFERENCE
Seattle, Washington
Panel Moderator:
Panel Members:
Date:
Topic of Panel:
March 18, 1993
RCRA/CERCLA Integration & Managing Active
Facilities
Sharon Jaffess, Region 2, RPM
Dave Fagan, HQ/OSW, Chief, Corrective Action
Branch
Mary Pat Tyson, Region 5, Chief,
Michigan/Wisconsin Section
Dion Novak, Region 5, RPM
Jon Peterson, Region 5, RPM
Edwin Smith, Region 5, RPM
Jamie VanBuskirk, Region 6, RPM
Howard Orlean, Region 10, RPM
Issues & Discussion
The major topics of discussion are summarized as follows:
1) RPMs, whether working on sites that are both on the NPL and are
currently operating RCRA facilities, must be familiar with the RCRA
regulations. Since the majority of sites have some type of ground
water contamination, the RCRA MCLs are usually identified as ARARs.
However, RCRA contains detailed requirements for various aspects of
hazardous waste management, including, but not limited to, closure
of facilities (landfills, surface impoundments, waste piles, etc),
monitoring, and corrective action. One problem identified is that
the MCLs are usually identified in a timely manner, but other
potential RCRA ARARs are not. In order to rectify this problem,
the causes must be identified; potential causes include the fact
that RODs contain conceptual remedy designs which make it difficult
to predict the actual regulatory requirements which will need to be
met during remedy implementation and difficulties in communication
between the RCRA and CERCLA programs.
2) In addition to the existing abundance of RCRA regulations that
may be ARARs for NPL site remedial action are the newly-promulgated
(58 FR 29, 2/16/93) provisions for corrective action management
units (CAMUs) and temporary units under Subpart S of 40 CFR 2 64.
These rules became effective on April 19, 1993. It is of utmost
importance that these rules are applied only to the on-site
treatment of remediation waste in order to promote more reliable,
protective and cost effective remedies, not applied for the purpose
of avoiding the land disposal restrictions (LDR). Attached are the
promulgated rules, which RPMs were briefed on during the panel
discussion. Note that Subpart S rules will be ARARs for CERCLA.
However, the procedures in the rules will not have to be adhered
to, only the substance of the rules (the basis for the performance
of the procedures).
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3) OSW/OERR has established a workgroup to develop standards or
guidelines for contaminated soils. This issue is related to the
need for consistency between RCRA and CERCLA in the area of
exposure and risk assessment (and issues in evaluating the exposure
scenario from the soil to ground water pathway). The
aforementioned workgroup is working with the Exposure Assessment
Group to determine the pathways which need to be addressed.
4) RPMs can take an active role in EPA's pollution prevention
program. For example, RPMs can negotiate Consent Decrees with
provisions for reducing the use of paper (e.g., draft deliverables
can be submitted via disk), eliminating 30/60/90 design stages
where the design is not complex, and utilizing early actions and
presumptive remedies.
5) The high costs to comply satisfactorily with the RCRA/HSWA
regulations contributed to the closure of small ("Mom & Pop")
businesses within the hazardous waste realm. Companies, originally
expected to be managed under RCRA, are now under the jurisdiction
of CERCLA. As such, many RPMs must manage sites without viable
PRPs (PRPs which are bankrupt as well as PRPs without the technical
expertise to implement studies, design, and remedies).
6) In addition to being knowledgeable on RCRA rules for the
purpose of ensuring compliance with ARARs during remedy
implementation, RPMs must understand the highly complex definition
of hazardous waste under RCRA as well as the differences between
RCRA hazardous waste and CERCLA hazardous substances. It is
important to understand the differences in the regulations for
hazardous waste and hazardous substances. Many examples of
industry (PRPs and owners/operators) and regulatory (EPA/State RCRA
Inspectors and RPMs) confusion exist with regard to the application
of the hazardous waste/hazardous substance rules. RPMs must be
alert to arguments from PRPs and owners/operators arguments that
site "waste" is exempt. The "waste" may be exempt from RCRA;
however, it is not exempt from CERCLA when hazardous substances are
confirmed.
Recommendations
Although the RCRA program has highly-experienced staff which could
provide technical/administrative/regulatory support to CERCLA RPMs,
support to the CERCLA program is not a priority of the RCRA program
(nor should it be expected to be a priority) . Therefore, the
CERCLA program must incorporate RCRA expertise into its own
program. Although support programs do exist (e.g., Region 2's
CERCLA program has funded some RCRA FTEs for the purpose of
ensuring that CERCLA remedial actions are consistent with
applicable or relevant and appropriate RCRA regulations), the
consensus of RPMs present at the meeting perceived that there is
minimal RCRA support and that there is a need to improve this
situation. In addition, RCRA's corrective action rules (proposed
and promulgated) have been devised to be consistent with CERCLA.
Therefore, in addition to a RCRA supporting role to CERCLA, RCRA
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and CERCLA programs require integration (defined as information
dissemination between the programs to ensure technical and
administrative/regulatory consistency) . Note that this integration
has been necessary in the past, since there are RCRA active
facilities on the NPL, but as in the support function, the
consensus was that integration has not been successful.
Therefore, NARPM recommends a Quality Action Team (QAT)/National
Workgroup to devise a program within Headquarters (and then
recommend implementation within the Regions) to facilitate
RCRA/CERCLA integration and the support each program can supply to
the other. It is recommended that such a QAT begin by answering
this question: How have HQ and each Regional RCRA and CERCLA
program office managed integration thus far, and what aspects have
been effective/successful, and what aspects need improvement? The
QAT can then propose solutions. This QAT can also serve to examine
consistency within the programs to evaluate both the technical
components that should be consistent and the technical components
that do not require consistency. Various aspects of the programs
to evaluate for consistency include: sampling methodologies, QA/QC
procedures, investigatory time-frames, remediation methods, costs,
cleanup standards, community relations, and enforcement.
It must be noted that one of NARPM's recommendations to support
RCRA/CERCLA integration has already been implemented: the
formation of the RCRA/CERCLA Integration Panel at the NARPM annual
conference. It is proposed that this panel serve as the basis for
the aforementioned QAT/National Workgroup.
Another recommendation is the use of some of the panel discussion
time at the conference to train RPMs via a seminar format. This
year's RCRA/CERCLA integration panel included a seminar on the RCRA
Subpart S CAMU rule and the use of the RCRA/CERCLA soil cleanup
levels/trigger levels. This seminar was given by Dave Fagan, the
principal author of the Subpart S regulations, and Mary Pat Tyson,
currently serving on the SRO and a HQ contact for soil cleanup
levels. Mr. Fagan and Ms. Tyson successfully targeted the
discussion to the critical issues RPMs need to understand.
Resources Needed to Implement Recommendations
The QAT will require RPMs (from a minimum of four different
regions) and HQ representation from OSW and OERR. Regional RCRA
Permit Writers would also be encouraged to become part of this
National Workgroup/QAT. Meetings at least once per month (in
Washington, D.C.) are recommended and, as such, would require a
travel budget.
NARPM Conference trainings/seminars require at least one volunteer
from the RCRA or CERCLA program to prepare a short course geared to
RPMs to be given at the NARPM Conference. This requires travel
funding once per year.
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PANEL SUMMARY
Date: 3-18-93
Topic of Panel:
Panel Moderator:
Panel Members:
Issues;
1. RI/FS Guidance Amendment - upcoming
2. Need a statement of minimum RI/FS requirements - CNSL concerns
often want everything included whether helpful or useful or
not.
3. Data needs can never be completely satisfied - At what point
can be quit gathering data and attempt cleaning up the site?
4. Observational approach has great potential and may go a long
way towards resolving a lot of RI/FS issues.
Discussion:
The above four items were discussed at length. The general
theme was, "How much information is sufficient for decision-making
since we can never actually gather all (or enough) data to make an
absolute judgement?"
Recommendations:
Item 1 should contain a specific statement of Minimum Elements
of RI/FS and no specific statement or other items that could be
included, as they will be included if necessary but won't if not.
Item 2 — The other items are self-explanatory and should also
be in the new guidance. Get plenty of feedback from RPMs PRIOR to
publication.
1993 NARPM CONFERENCE
Seattle, Washington
RI/FS
Steven Kinser
All in attendance
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Newsletter
Date:
Topic of Panel:
Panel Moderator:
Panel Members:
Issues:
1.
2.
3.
4.
5.
6.
Panel Summary
1993 NARPM Conference
Seattle, Washington
March 18, 1993
NARPM Newsletter
Rosemarie Caraway, Region 9
Cathy Gilmore, Region 6
Monica Chapa Smith, Region 6
Fred Schauffler, Region 9
Naming the newsletter
Continue with the newsletter
Format
Types of articles and repeated features
Rotation of editor
Regional newsletter editors/representatives
Discussion:
The newsletter was named "Adventures in Wasteland" by vote of
those present in the session. Those present in the session decided
that we should continue the newsletter in much the same format as
it exists. The wording of the disclaimer was discussed as well as
the types of articles and features to include in the newsletter.
The regions should focus on more technical articles if we are to
use the newsletter to disseminate technical information. Repeated
features should include Federal Facilities. Also, perhaps a
feature should be to spotlight the work of one or more RPMs,
especially those receiving the OSC/RPM Support Program regional
awards.
Rosemarie agreed to serve as editor for one more year. Each
region is to give the name of one RPM who will serve as the
regional newsletter contact. In the future, we cannot continue to
depend on Region 9 to write the total newsletter.
Recommendations:
Spend more time on the newsletter or discontinue it.
Resources Needed to Implement Recommendation: RPMs will need to
take time from their schedules to prepare articles regularly.
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ABSTRACTS
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1993 NARPM CONFERENCE
ABSTRACTS
AUTHOR REGION
1. Tony Able, Ralph Howard 4
2. Erna Acheson 8
3. Gary Adamkiewicz 2
4. Indira Balkissoon 1
5. Wm. Turpin Ballard 5
6. John Banks 3
7. Tom Barounis 5
8. Thomas Bloom 5
9. Mark A. Bogina, Robert Koke 7
TITLE
Free for the Taking: Springs as
Ground Water Sampling Locations
at Superfund Sites
Will Soil Washing Work for the
Sand Creek Superfund Site?
Soil Washing at the King of Prussia
Site: An International Approach
Ground Water Issues: Alternate
Concentration Limits,
Assumptions, Realities, and
Uncertainties
Ground Water Samples for Metals
Analysis: A Reasonable Approach
to the Filtration Controversy
Brodhead Creek Superfund Site:
A Cooperative Effort Between
EPA Region III, EPA Site
Program, and Potentially
Responsible Parties
The Distribution of Treated Water
From a Long-Term Ground Water
Pump- and Treat-System: A
Cooperative Effort
Five-Year Review and Interim
Close-Out Reports at Superfund
Sites
Remedial/Removal Program
Integration in Development of
Early Action at the Big River
Mining Site near Desloge, Missouri
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10. Sandra A. Bourgeois
11. Brad Bradley
12. Shelley Brodie
13. Nick Ceto
14. Jeff Dhont
15. James J. Feeney
16. Peter Feldman
17. Pauletta France-Isetts
18. Carl R. Froede, Jr.
19. Gayle Garman
20. Jeff Gore
21. Lawrence Granite
Remedial Action Construction
Completion at the Defense
Distribution Depot, Ogden, Utah
Communicating with a Community
Where 1600 Residences are Part of
the Superfund Site
PCB Remediation at Natural Gas
Pipelines
Institutional Controls, Bunker Hill,
Kellogg, Idaho
The Plug-in ROD: An Accelerated
Approach for Multi-Source Sites
Dealing with a Responsible Party
Suddenly Declaring Bankruptcy
During Site Operations at an NPL
Site
Determination of the Technical
Impracticability of Ground Water
Remediation
Missouri Electric Works - Case
Study
Moving an Interim Pump and
Treat Remedial Action to Final at
Kennedy Space Center, Florida
Incineration or Innovative
Technology? An Evaluation of
Treatment Technologies, New
Bedford Harbor Hot Spot
Sediments
Using Biodegradation to Enhance
a Ground Water Pump and
Treatment System
Remedial Action at the Helen
Kramer Landfill Superfund Site
8
5
7
10
9
3
HQ
7
4
1
5
2
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22. Margaret Guerriero 5
23. James J. Hahnenberg 5
24. Richard Hammond 4
25. Nancy Harney 10
26. C. Kaleri, M. Abrahamson 6
27. Dave Kluesner 4
28. Tony Koller 3
29. John Kuhns 5
30. Robert J. Leger 1
31. Kathleen Lohry 6
32. Shawn Luetchens 4
33. Kevin Mayer, Colette Kostelec 9
Case Study: Enhancement of Soil
Vacuum Extraction Via Ground
Water Sparging at the Verona Well
Field Superfund Site
Keeping a Remedial Action
Moving Around, Over and Under
Seemingly-Insurmountable
Obstacles
Use of the Observational Approach
in the Design of a Soil Sampling
Plan
"No Action/No ARARS" or How
to Pick a Fight with a State
New Cost Recovery Rule and
Potential Impacts
Successful Administration of a
Technical Assistance Grant at the
Maxey Flats Nuclear Disposal Site,
Kentucky
Remedial Action, Palmerton Zinc,
Blue Mountain Revegetation
Case Study on Site
Characterization at a TCE Plume:
St. Joseph, Michigan, NPL Site
Developing Cleanup Levels for
PAHs in Sediments
The Use of Aerial Photography to
Streamline Delineation of Area of
Contamination: Case Studies and
Procedures
Environmental Horizon
Contingencies and Deferred
Decisions at Large Ground Water
Contamination Sites Involving
Local Water Supply Agencies
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34. Kevin Mayer 9
35. Kelly S. McCarty 9
36. Bret Moxley 9
37. Bret Moxley 9
38. Linda M. Nachowicz 5
39. Michael Nalipinski 1
40. Mike Negrelli, Donna Vizian 2
41. Arturo Palomares 8
42. Jon Peterson 5
43. Brian Pinkowski 8
44. Wayne Praskins 9
45. Beth Reiner 5
46. David Rosoff 2
A Successful Non-EPA Technical
Advisory Committee for a Large
Ground Water Contamination Site
in San Bernardino, California
SACM: A Unique Perspective
from an Ex-OSC Turned RPM
Vinyl Chloride in Landfill Soil
Gas Shown to Migrate Beyond the
End of the Methane Plume
In-Home Air Sampling for Vinyl
Chloride in Residences Near a
Landfill
Future Considerations for the
Application ofln-Situ Vitrification
at Superfund Sites
Solvents Recovery Service of New
England
Remedial Pipeline Project
Management Module (RP2M)
Quality Assurance Project Plans
Chromium Electroplaters = F001,
F006, F007, and F008
The Role of Community Interests
and Medical Information in Risk
Management
Mega-Site Remediation in the Arid
West: What to Do with 30,000
gpm of Extracted Ground Water?
Innovative Technology for
Remediation of Organics in
Ground Water
Access Issues at the Ewan Property
- A Road to Nowhere? Ewan
Property Superfund Site, Shamong
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Township, New Jersey
47. Donna Santiago 3
48. Fred Schauffler 9
49. Kathy Setian 9
50. Edwin R. Smith 5
51. Monica Chapa Smith 6
52. Jamie VanBuskirk 6
53. D. Weeks, etc. 6
54. Jennifer Wendel 5
55. Tom Williams 5
56. Craig Zeller 4
Expanding the Objectives of
Emergency Response Activities
Access, Easements and Angry
Neighbors - Whatever Happened
to Site Cleanup?
GIS Made Painless: How RPMs
Can Access GIS Data at Multi-
Source Ground Water Sites
Pollution Prevention in Superfund
Environmental Equity? Reverse
Environmental Equity? Prewitt
Abandoned Refinery, Prewitt, New
Mexico
Superfund's Rose in Regulating the
Oil and Gas E&P Waste
Lightning RODs (a.k.a. Region 6
SACM Experiences)
Five-Year Review and Close-Out
of Pre-SARA Sites
Cone Penetrometer Application at
the Organic Chemical Site to
Characterize Oil Contamination
Innovative RI/FS Approach to a
Complex PCB Site
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Free For The Taking:
Springs As Ground Water Sampling Locations
At Superfund Sites
Tony Able and Ralph Howard
Region 4
Recent experience at several Superfund sites in Region IV indicates that springs are an
underutilized source of ground water quality data which otherwise can only be obtained
through the installation and sampling of monitoring wells. In contrast, springs are very
common and have no installation costs. Springs occur in most geologic settings and are
found at, or near, most hazardous waste sites. Springs may be used to gather rapid site
assessment data upon site discovery, and/or later as part of an established sampling or
monitoring program. In light of EPA's recent emphasis on speeding up the Superfund
process, such as the Superfund Accelerated Cleanup Model (SACM), the use of springs as
ground water sampling points can provide fast, low-cost information and should be
employed to the greatest degree possible.
Springs have been useful for identifying aquifer contamination when wells were found
ineffective. They have been used to identify reaches of streams in which plumes of
contaminated ground water are discharging, and they have been used as remediation sites
for aquifer and stream corrective actions. This paper will present case studies of sites in
several geologic settings where springs have been useful in accelerating activities in the
characterization and remediation process.
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Will Soil Washing Work for the Sand Creek Superfund Site?
Erna Acheson, Region 8
Patrick Augustin, Edison NJ ORD
The 1987 Sand Creek Operable Unit 5 (OU5) Record of Decision (ROD) identified soil
washing as the selected remedy to remediate soils contaminated with high levels of
organochlorine pesticides, 2,4-D herbicides and metals. The following are the major
problems encountered when starting the Remedial Design (RD) for the Sand Creek
Superfund Site:
1) The action levels in the ROD are very low.
2) The volume of contamination reported in the ROD is based on only 17
samples analyzed for pesticides and metals.
3) Costs provided in the ROD were not accurate due to the uncertainty of the
actual volume of soil and the limited knowledge of soil washing clean-up cost
at the time the ROD was being prepared. Also, no State Contract was in
place for the ten percent cost share, and the State of Colorado requested that
the cost of cleanup be close to what was submitted in the ROD.
To assist in solving these problems, the EPA Office of Research and Development (ORD)
brought their mobil Volume Reduction Unit (VRU) to the Site from September 21, 1992
through October 2, 1992. The VRU was used to wash on-site soils. During the soil washing
process, fines that are residues of soil washing are separated from the coarse soil (>200
mesh) and clean coarse soil was backfilled on-site. Fines (< 200 mesh) was sent off for
incineration.
Twenty-three experimental test runs were performed using the VRU at the site. Three
different surfactants, four different surfactant combinations, two different soil-to-water
ratios, two different temperatures, two different pHs and three different soil types were
evaluated by the test runs. The conclusion made from the results of the VRU test runs are
the following:
Soil washing is cost effective in cleaning up the soils at the site to levels that
are acceptable for an industrial location (Note: Sand Creek is located in an
industrial area).
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Soil Washing at the King of Prussia Site:
An International Approach
King of Prussia Site, Winslow Township, NJ
Gary Adamkiewicz
Region 2
Soil washing will be utilized at the King of Prussia (KOP) site to address the cleanup of
25,000 cubic yards of metals-contaminated soils and sludges. This technology has had
limited full-scale success in the United States, while it has been applied successfully for
several years in The Netherlands and Germany. During the past year, the site's PRPs have
been conducting lab- and bench-scale treatability studies using a soil washing process
developed in The Netherlands. These studies culminated in July 1992 with a "demonstration
run" at a full-scale soil washing facility in the city of Moerdijk, The Netherlands. This run
successfully treated 200 tons of soils and sludges that had been shipped from the site. This
presentation will focus on site specifics, the technology of soil washing, the complications
of international shipment and the use of a demonstration run to expedite remedial action
by over one year.
The site was used by the King of Prussia Technical Corporation to process industrial waste
(mainly spent acids) in on-site lagoons during the early 1970s. One component of the
selected remedy addressed in the Record of Decision dated September 1990 calls for the
excavation of 25,000cubic yards of lagoon sludges, contaminated soils and sediments, to be
followed by treatment utilizing a multi-phase soil-washing process. Cleaned materials will
then be redeposited in approximately their original location, followed by re-vegetation. The
primary contaminants of concern at the site are chromium, copper and nickel.
In accordance with a 1991 Unilateral Administrative Order, the PRPs performed lab- and
bench-scale treatability studies for the treatment of site soils. Following the completion of
these studies in July 1992, a "demonstration run" was conducted at a bull-scale soil washing
facility in the city of Moerdijk that treats contaminated soil from several Dutch provinces.
Activities associated with this run included the following: Approximately 165 tons of
contaminated soils and sludges were shipped from the site to Heidemij's facility. This
volume supplied enough material to perform an 8-9 hour (full day) run, simulating the
operation of the unit which will be constructed on site. This demonstration run successfully
treated the KOP soils and sludges to meet the cleanup levels specified in the ROD. Based
on the success of this run, the design schedule has been expedited by over one year,
allowing for remediation to begin in the summer of 1993.
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Ground Water Issues
Alternate Concentration Limits
Assumptions, Realities and Uncertainties
Indira Balkissoon
Region 1
Alternate Concentration Limits (ACLs) are attractive to potentially responsible parties
(PRPs) and are proposed as part of ground water remedies because of their intent to be less
stringent than maximum concentration limits. However, the establishment of ACLs is very
difficult and costly.
This paper describes assumptions, realities and uncertainties of developing ACLs at the
Winthrop Landfill Superfund Site in Winthrop, Maine. After 11 years of collecting ground
water data and a PRJP expenditure of 11 million dollars, the ACLs were developed using
maximum concentration limits (MCLs), and other risk based criteria.
In concept ACL assumptions appear straightforward, but they are a black box idea which
is difficult to use considering the realities and uncertainties of nature. There are numerous
assumptions which make the development of ACLs difficult and perhaps inappropriate. The
most difficult concept to reconcile is the development of attenuation factors. How is
attenuation determined? Is there a difference in the attenuation factor if it is developed
in a system which is not in equilibrium? How does an antecedent plume affect the
development of attenuation factors? In addition, how does the chemical loading of the
ground water flow system affect attenuation, will chemicals eventually begin to desorb?
Attenuation factor development as outlined in the Winthrop Landfill consent decree, states
that an attenuation factor should be developed using a ratio of the concentration of a
representative chemical in an upgradient well, at the facility boundary, divided by that same
chemical's concentration in a downgradient well. Dimethylformamide (DMF), the
compound most conservative chemically at the Winthrop Landfill, was chosen to be the
representative chemical and was used to determine the attenuation factor. The problem
with this methodology is that the attenuation factor developed indicates that there is no
attenuation, the attenuation factor is very close to one. Based on the large data set
gathered at Winthrop, there is an indication used to develop attenuation factors because it
does not attenuate.
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Ground Water Samples for Metals Analysis:
A Reasonable Approach to the Filtration Controversy
Wm. Turpin Ballard
Region 5
Any ground water monitoring wells should be constructed and sampled with the goal of
minimizing turbidity, and consequent analytical interferences. Clear, unfiltered monitoring
well samples should be the goal of any sampling program whose objective is risk assessment
and risk management. However, despite the most careful installation, development, and
sampling practices, excess turbidity may occur which can bias analytical results for metals
high, and affect both the risk assessment and subsequent risk management decisions. A
standard industry approach has been to filter ground water samples for metals analysis with
a 0.45 micron filter. However, recent EPA research suggests that 0.45 microns is an
inappropriate filter size for metals filtration. In addition, filtering conflicts with U.S. EPA's
Risk Assessment Guidance for Superfund (RAGS). RAGS has a stated preference for
applying unfiltered metals data to a drinking water ingestion scenario, under the assumption
that residential consumption from a private water well will be unfiltered and all mobile
metals will be available for ingestion. Useability of the metals data from consistently turbid
samples for risk assessment is questionable, and an alternate approach is needed. Presence
of excess turbidity in a well dictates a hierarchical approach to sampling methodology.
Considerations include general turbidity levels for all wells in the study, along with
development, purge, and sampling rates, and appropriate sampling equipment. This
hierarchy ultimately culminates in a decision either to disapprove use of a problem well, or
to field filter metals samples prior to acidification and shipment for analysis. Should
filtration be deemed appropriate, use of a filter in the 2.0 to 5.0 micron range will prevent
high biased results while still providing for a reasonable estimation of the maximum
concentrations of mobile metals. The decision to filter or not to filter must be made by the
project manager consistent with the Data Quality Objectives, and in consultation with risk
assessment support staff so that all data users understand the logic and rationale behind the
decision.
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Brodhead Creek Superfund Site
A Cooperative Effort Between EPA Region 13, EPA SITE Program,
and Potentially Responsible Parties
John Banks
Region 3
OBJECTIVE
The objective of this paper is to outline a case study for furthering the use of innovative
treatment technologies at PRP sites and blending RD/RA with the EPA SITE
Demonstration Program.
INTRODUCTION
The Brodhead Creek Site occupies approximately 12 acres in the Borough of Stroudsburg
in Monroe County, Pennsylvania along the western bank of Brodhead Creek. The Site is
the former location of a coal gasification plant which operated from approximately 1888 to
1944. Coal tar was disposed of in an open pit on the site until the mid-1940's when the
plant was abandoned. Based on the RI, an estimated volume of approximately 9000 gallons
of free coal tar is believed to be in a stratigraphic depression onsite. Coal tar at residual
saturation levels is more extensive but limited to a stream gravel unit.
RECORD OF DECISION
An interim action ROD was issued for this Site on March 29, 1991 for OU-1 to address free
coal tar contamination. The ROD-selected remedy is an innovative technology called the
Contained Recovery of Oily Waste (CROW) process involving the injection of hot water
to displace and mobilize the coal tar accumulation with subsequent recovery in production
wells.
REMEDIAL DESIGN/REMEDIAL ACTION
EPA entered into a Consent Decree (CD) with the PRPs in September 1992 for
implementation of the CROW Process. The EPA SITE Program is also interested in
performing a field demonstration of this technology concurrently with the PRP RD/RA.
A cooperative relationship has developed between EPA and the PRPs in implementing this
remedy. Incentives provided to the PRPs include lower costs since they will be permitted
to use SITE program information and selected sampling data. In addition, since the PRPs
will be implementing an innovative technology, the Consent Decree provides that in the
event EPA issues a new or amended ROD for this operable unit, the PRPs would not be
obligated by the CD to perform any aspects of the remedy selected in the new or amended
ROD that are different from or in addition to the work required under the CD. Benefits
derived by EPA include site cleanup and progress toward evaluating and applying innovative
technologies.
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The Distribution of Treated Water From A Long-Term Ground Water
Pump- And Treat- System: A Cooperative Effort
Tom Barounis
Region 5
One of the issues that must be dealt with as part of any remedial action involving ground
water pumping and treatment is how to deal with the treated ground water that results from
these systems. One common solution is to discharge the treated water to a publicly-owned
treatment works (POTW). Another is to release it back to the ground surface or a nearby
surface water body, provided the discharge meets the appropriate surface discharge criteria.
Ideally, ground water that has been pumped and treated to high water quality standards,
often at considerable expense, should be put to its highest and best use. In many cases, this
use would be as a potable water supply.
To distribute treated ground water as a potable water supply, several hurdles must be
overcome. The treated ground water must be of sufficient quality to meet drinking water
standards. It must be reliably available over a long period of time and it must meet the
distribution requirements of a public water supply system. Finally, it is necessary to
overcome the public resistance that the use of treated ground water may meet from the
local community for which such an option is being considered. These constraints have been
addressed at the New Brighton/Arden Hills Superfund Site in Ramsey County, Minnesota,
where a large plume of volatile organic chemical (VOC) contamination has impacted the
ground water supplies of several local communities.
The primary PRP at the Site is a U.S. Army federal facility, the Twin Cities Army
Ammunition Plant (TCAAP). Working together, the City of New Brighton and the U.S.
Army have forged an agreement whereby the City will be accepting treated ground water
at the rate of 1000 gpm, into its municipal water supply. The ground water, which will be
treated by granular activated carbon (GAC), will meet MCLs and the system will be
designed to accommodate the distribution requirements of the City.
The agreement forged by the PRP and the City, and guided by the U.S. EPA and the
Minnesota Pollution Control Agency (MPCA) can serve as a model for ground water
restoration actions which minimize wastage and conserve ground water as a natural
resource. Although it may not be appropriate for all ground water remedies, it can provide
a promising approach to a significant number of future ground water remedies.
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Five-Year Review and Interim Close-out Reports
at Superfund Sites
Thomas Bloom
Region 5
Recently, I have completed an Interim Close-out Report (ICR) and a Five-Year Review
Report on the FMC Corporation Site. In the process of completing these reports, I gained
valuable knowledge about both Interim Close-out and Five-Year Review Reports from EPA
Headquarters, ORC, State personnel, and from my experienced co-workers, that I would
be willing to share with fellow NARPM members at the next NARPM conference in March
1993. I plan to communicate information in the form of a presentation or by serving as a
panel member. I plan to interview the folks that assisted me with my reports in EPA HQ,
ORC, and the State, to obtain their major concerns when reviewing ICRs and Five-Year
review reports. I also plan to present recent information contained in the Superfund
Completion CARE Package dated July 17, 1992.
Remedial actions at the FMC Corp. site consist of a source removal activity with, on-site
placement in a RCRA containment facility, and a ground water pump out system to
hydraulically contain and reduce TCE concentrations in the ground water plume. The
source removal activity was conducted under an Administrative Order and Interim Response
Order by Consent between EPA, the State, and FMC. This Order required FMC Corp. to
conduct an RI/FS to investigate ground water contamination. In 1986, the State signed an
Enforcement Decision Document (EDD) which is their version of a ROD. Subsequently,
in 1987, EPA signed a ROD selecting the same remedy (pump out with discharge to a
POTW).
The FMC Corporation Site is an unusual site in which the Five-Year Review may present
an innovative approach to post Five-Year review work. As stated in the Introduction
section of the report, the remedial action at FMC continues to be protective of human
health and the environment. Hydraulic containment of the TCE plume is still adequate and
institutional controls regarding site related contamination on land outside of the site are still
in place. However, data gaps in the initial investigation leave some questions unanswered
which relate to the efficiency of the pump out system, i.e. residual source contamination
loading the ground water plume. In addition, another possible source of contamination was
noted during a recent areal photo review.
A problem exists because the Agreement to implement the remedial action is between the
State and FMC Corp. Back in 1987, after signing the ROD, EPA never sought an
agreement with FMC Corp. because FMC Corp. signed an Agreement by Consent with the
State to implement the State's ROD. Since FMC Corp. was correctly implementing the
remedy under the State Agreement, EPA did not pursue an agreement. The problem is,
how does EPA get FMC Corp. to do additional investigatory work recommended in the
Five-Year Review Report. A couple of answers will be discussed in March.
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Remedial/Removal Program Integration
in Development of Early Action at the Big River
Mining Site near Desloge, Missouri
Mark A. Bogina and Robert Koke
Region 7
The Big River Mine Tailings site is a 400-acre tailings pile located within a horseshoe bend of
the Big River near Desloge in southeastern Missouri. The St. Joe Mineral Corporation
conducted mining operations at the site from 1929 to 1958. Fine-grained, lead-bearing tailings
(slimes) were milled on-site and deposited behind a tailings dam above Big River. In 1977, a
drainage structure within the tailings dam failed during a rainstorm, resulting in a release of
50,000 y3 of mine waste into the Big River. Subsequent studies conducted by the Fish and
Wildlife Service (FWS) to assess the effects of the tailings on the river reported that the release
had caused adverse impacts on aquatic biota in the Big River.
EPA performed a Listing Site Inspection (LSI) and proposed the site to the National Priorities
List (NPL) in 1991. Upon final listing to the NPL in February 1992, a field conference was
conducted by EPA, ERT, ATSDR, FWS, the Missouri Department of Natural Resources
(MDNR), the Missouri Department of Health (MDOH), and the Missouri Department of
Conservation (MDOC) to explore response options for early action at the site. The removal
program tasked a Technical Assistance Team (TAT) contractor to develop an Engineering
Evaluation/Cost Analysis (EE/CA) for a non-time critical response action to stabilize the tailings
impoundment and contain the slime ponds.
The remedial program organized a Biological Technical Assistance Group (BTAG) and worked
to develop consensus among the interested parties on the preferred alternative. Following public
comment on the draft EE/CA, the removal program will issue the Action Memorandum. The
remedial program along with regional counsel will then be negotiated with the potentially
responsible parties (PRPs) for implementation of the EE/CA, and conduct of a Remedial
Investigation/Feasibility Study (RI/FS) for the ground water and surface water pathways not
addressed by the removal action. If an agreement cannot be reached with the PRPs, the removal
program will implement the removal action, while the remedial program conducts the RI/FS.
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Remedial Action Construction Completion At The
Defense Distribution Depot, Ogden, Utah
Sandra A. Bourgeois - Region 8
Muhammad A. Slam - Utah Dept. of Environmental Quality
The Defense Distribution Depot, Ogden, Utah (DDOU) is an NPL site consisting of four
operable units. Pump and treat and offsite soil incineration were selected as remedial
actions in the ROD for operable unit 2. The ground water remedial action construction was
completed in September 1992, DDOU is the first NPL site in the Department of Defense
(DOD) which has reached this major milestone.
The audience will gain an understanding of the technical and contractual issues involved in
the process of completing the remedial action construction at this operable unit, including
plume delineation, effective communication and schedule implementation. An overview of
remedial action construction will also be presented.
TCE was a contaminant of concern in the ground water. Chlordane and Bromacil were
contaminants of concern in the soil. U.S. Army Corps of Engineers (USACE) is the
contracting agency for DDOU. However, USACE did not take into account the 15 months
statutory deadline for continuous onsite remedial action construction into their contracting
process. The possibility of missing the timely remedial action start-up was avoided by
selecting a single remedial design and remedial action contractor. Sixty percent remedial
design report was omitted from the list of deliverables to accommodate an additional round
of sampling for better plume delineation. Thirty, ninety-five and hundred percent design
submittals were required. EPA Region 8 and the State of Utah project managers jointly
reviewed the outstanding issues n a weekly basis. The issues were communicated to DDOU
and their contractors, in a timely manner, through conference calls, meetings or letters as
deemed appropriate. To further enhance communication among parties, a project manager'
conference for all four Utah federal facilities was held in August 1992 to discuss issues
presented by the federal facilities. The conference was a big success and resulted in
improved communication. The close coordination, effective communication and innovative
approaches led to an on-time and successful completion of remedial action construction at
DDOU.
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Communicating With A Community Where 1600 Residences
Are Part of the Superfund Site
Brad Bradley
Region 5
The presentation will outline successes, failures, and lessons learned in communicating with
the communities of Granite City, Madison, and Venice, Illinois, which are all affected by
the NL Industries/Taracorp lead smelter site. Topics covered will include:
reading the community (e.g. what newspaper(s) do they read, where is the
best place to hold meetings/availability sessions);
dealing with technical challenges from and litigation with the local
government (i.e. finding out the true sentiments of and communicating with
the citizens themselves);
procuring access for soil sampling at 1600 residences;
effectiveness of community relations tools during the ROD process; and
how to put the community in perspective with site activities, deadlines, etc.
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PCB Remediation At Natural Gas Pipelines
Shelley Brodie
Region 7
PCB contamination in the nation's pipelines is being investigated and remediated through
a combined effort by EPA and the industry. Compressor stations that propel the gas have
contamination in soil, sediment, drainlines, sumps and internal air compressor systems.
Innovative approaches were needed to investigate the extent of contamination and to
conduct cleanups at these unique sites. The facilities needed to remain in operation during
the investigation and removal activities. Safety considerations included accessing buried
drainlines, working in close proximity to high pressure gas lines, cleaning inaccessible areas
and excavating without affecting the structural integrity of the buildings. Other obstacles
included limited site information and a restricted work schedule. Using a combination of
remediation techniques including removal, flushing, solvent washing and grouting, both
accessible and inaccessible areas have been successfully decontaminated. Using a team
approach with the industry , mobile labs, an innovative negotiation approach and new
decontamination procedures, all cleanups were conducted on an expedited schedule which
resulted in 13 cleanups in less than 3 years.
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Institutional Controls
Bunker Hill, Kellogg, Idaho
Nick Ceto
Region 10
Kellogg, Idaho and the surrounding communities have been heavily contaminated by lead
and other metals as a result of over 100 years of mineral mining and processing in northern
Idaho. The Record of Decision for the Bunker Hill Superfund Site requires extensive use
of containment remedies (i.e. capping) as well as removal and disposal actions to minimize
the health risks to local communities posed by metals contamination of surficial soils. In
many instances soil removal and replacement remedial actions will mitigate future risk by
removing all contamination. However, low level contamination across large areas of the
Bunker Hill Superfund Site also requires extensive utilization of remedial actions relying
upon partial removals coupled with replacement of the top one foot of soil. Such actions
are designed to create a protective barrier which prevents direct contact with contaminants,
prevents fugitive dust migration, and minimizes surface runoff of contaminants. Institutional
Controls will be required to maintain the protective barrier specified in the ROD.
Local communities understand the need for Institutional Controls to protect barriers and
provide guidance for future development in the community. This presentation will discuss
Institutional Controls proposed for the Site, community response, and mechanisms for
implementation.
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The Plug-in ROD
An Accelerated Approach for Multi-Source Sites
Jeff Dhont
Region 9
A new remedial selection approach is being implemented at an area-wide multi-source NPL
site in Arizona. The Approach is called the "Plug-in ROD." This "mega"-site contains
within it a large number of distinct subsites with similar soil contamination and physical
properties. The same remedy is likely to apply at each subsite, but the timing of RD/RA
at each subsite will be staggered due both to differences in the amount of RI work needed
and limitations in EPA's resources for concurrent enforcement actions. In this situation,
the Plug-in ROD provides an alternative to 1) performing tens of operable units that all
arrive at the same remedy, or 2) performing a single giant action in which all subsites must
wait for one final ROD before entering RD/RA.
Under the Plug-in ROD approach, a standard subsite profile is developed and a remedy is
selected to address that profile. The RI is decoupled from the FS; RI work simply
continues at each subsite until characterization is complete. The FS and ROD select a
standardized remedy that will apply to 90%+ of subsites. The ROD does address ARARs
and risk, however a special approach to risk assessment is required. AT the time the ROD
is signed, the remedy does not yet apply directly to any particular subsite. Subsites later
"plug-in" to the ROD as their RI work is completed. The Plug-in ROD goes further than
a typical ROD in that, in addition to selecting a remedial technology; it also establishes a
process (by decision-tree) for determining under what conditions a subsite must plug-in to
the ROD. If special conditions not envisioned by the standard ROD are discovered at a
subsite, EPA can make specific adjustments before plugging it into the ROD, or decide not
to plug it in at all. Thus, complete flexibility is preserved until the point of plug-in. As
each subsite plugs in, it drops directly in RD; there is no separate FS and OU ROD for
each subsite. This time and associated resources are saved. RI work and RD work can
occur concurrently; thus remedial action begins at the site and is not held up by slower
subsites. The ROD provides a sense of forward motion and focus to the public and PRPs
and guides the collection of additional RI data.
Certain prerequisite conditions should exist before a Plug-in approach is used. The
approach also presents certain challenges for providing due process and for meeting the
statute of limitations for cost recovery. None of these challenges appears insurmountable,
however. Because the ultimate decision for a subsite is not made until plug-in, the
approach when properly used is compatible with the NCP.
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Dealing With A Responsible Party Suddenly Declaring Bankruptcy
During Site Operations At An NPL Site
James J. Feeney
Region 3
Presentation includes brief histories of two Pennsylvania Superfund Sites, North Penn-Area
12 and Salford Quarry, at which the Responsible Parties conducting the Remedial
Investigations declared bankruptcy; the subsequent disruption of Site activities and the final
disposition of Site responsibilities include the delays involved and duplication of effort.
Summaries of recent, relevant district court decisions are also discussed as to their effect
on EPA authority and the divergent rights and responsibilities of the parties. Finally,
Region 3's suggested approach for dealing with bankruptcy is presented.
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Determination of the Technical Impracticability of
Ground Water Remediation
Peter Feldman
OERR Hazardous Site Control Division
This paper/presentation will discuss guidance OERR is developing regarding evaluation of
the technical impracticability (TI) of achieving ground-water cleanup ARARs at hazardous
waste sites. TTie presentation will briefly touch on the background and regulatory
framework of the issue, and then discuss in more detail the decision criteria and site data
which should be used to make TI determinations.
TI waivers have been used in twelve RODs and two ROD amendments to date, and in nine
cases, TI contingency language has been used. The use of TI waivers in RODs, and
negotiations over TI language in RA consent decrees, is on the rise. This guidance's
implications to the use of TI waivers and to ground water remediation in general will be
discussed.
The NCP allows ARARs to be waived where attainment is technically impracticable from
an engineering perspective. OSWER has also recognized this issue in recent guidance and
policy directives; however, criteria for making these determinations have yet to be clarified
and standardized. Attainment of ground water ARARs may be limited by hydrogeologic,
contaminant, and system design factors; TI evaluations should attempt to distinguish
between system flaws and true technical limitations.
Decision criteria should include the following:
- Adequacy of the site conceptual model,
- Hydrogeologic and contaminant-related constraints,
- Degree and effectiveness of source control,
- Appraisal of remedy performance to date,
- Trends in contaminant concentrations,
- Rate of mass removal,
- Role of dilution and natural attenuation,
- Predicted restoration time frame,
- Cost,
and other factors. No single factor should generally be considered sufficient to make this
determination (e.g. asymptotic, concentration "plateaus"); rather, the site conceptual model
should be evaluated to determine the restoration potential of the contaminated ground
water.
Where an ARAR is waived, an alternate remedial strategy must be chosen as part of the
decision document. This strategy must ensure protectiveness, and should satisfy ARARs
and other remedy selection criteria to the extent practicable. Examples of alternate
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strategies include containment of the aqueous plume, establishing alternate cleanup
concentration levels, and natural attenuation with institutional controls.
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Missouri Electric Works - Case Study
Pauletta R. France-Isetts
Region 7
The objectives of this paper are to share the lessons learned during complex consent decree
negotiations and providing proactive community relations. These objectives will be
addressed by providing the audience with a brief history of the Missouri Electric Works site;
the community relations program provided to the citizens of Cape Girardeau and their
reaction; and an overview of the consent decree negotiations and their outcome.
Missouri Electric Works (MEW) operated at the site location from 1954 until 1992. During
that time, MEW repaired thousands of transformers and purchased numerous used
transformers. The records kept by MEW were extensive. After reviewing the MEW
records, the Environmental Protection Agency (EPA) issued over 700 information
request/general notice letters to former customers. In an effort to be equitable, Region VII
staff reviewed information provided by Potentially Responsible Parties (PRPs) which, in
their opinion, refuted their liability. As a result of this review, about 300 PRPs were
released from further liability and hundreds of others had their amount of liability reduced.
Based on the information contained in the MEW records, the information letter responses
and the EPA liability determinations, a non-binding allocation of responsibility was
proposed by the MEW steering committee for use in the consent decree settlement.
The negotiations for settlement used many of the tools specified in Section 121 of CERCLA
and as a result were very time consuming. The consent decree settlement contains
provisions for two classes of de minimis settlors, cashout provisions for other federal agency
PRPs, and mixed funding provisions because several of the PRPs with larger allocations
were either nonexistent or did not have the ability to pay for their portion of responsibility.
Community relations for the site were complicated by the fact that adjacent property was
owned by one of the local newspaper editors. After a short period of reactive community
relations, it was decided that EPA would take a proactive approach. This included
designating an EPA ombudsman for site-related meetings, conducting several availability
sessions during which interested citizens could tale one-on-one with EPA staff, public
meetings, the RPM and attorney being guests on local radio talk-shows and frequent fact
sheets. When the proposed plan, which indicated that the selected remedial action for the
contaminated soils was on-site incineration, was made available to the citizens of Cape
Girardeau, no adverse comments were received. It is the opinion of Region VII that the
proactive community relations were responsible for the lack of public comment and outcry
against the selected remedial alternative.
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Moving An Interim Pump and Treat Remedial Action
to Final at Kennedy Space Center, Florida
Carl R. Froede Jr., PG
Region 4
OBJECTIVE: To show that interim remedial design/action is a dynamic exercise which, if
performed properly, can ease the transition to final remedy selection.
The National Aeronautics and Space Administration's Kennedy Space Center (KSC),
Florida, has been assembling and launching spacecraft since the early 1960's. The
generation, treatment and disposal of hazardous waste products associated with the space
program has been performed, for the most part, in a responsible manner. However, there
are several sites in which poor hazardous waste handling has occurred. One of these sites
is Wilson Corners.
Carbon strippers (i.e., degreasers) and solvents were used at the Wilson Corners Site to
clean rockets and their associated parts. The main solvent used was Trichloroethene (TCE),
a dense non-aqueous phase liquid (DNAPL). This solvent was used at this site from 1963
to 1974 and occurs in high concentrations in the subsurface. The Wilson Corners Site was
originally identified as requiring additional characterization in November 1977. In
December 1983 a decision was made that the site would require remedial action. Kennedy
Space Center determined that a pump and treat system was necessary in the first quarter
of calendar year 1987. The pump and treat system went into operation as an interim
remedial action on May 15, 1989. Comparison of initial influent and effluent samples
showed a 99% efficiency for the removal of TCE and vinyl chloride.
As part of KSC's effort to finalize this pump and treat system for the Wilson Corners site,
KSC provided EPA and the State of Florida with a Feasibility Study supported by a Risk
Assessment and Draft Proposed Plan on June 5, 1992. The Draft Proposed Plan
recommends additional recovery wells and adjusted flow rates in finalizing this remedial
action. The State of Florida agrees with KSC's decision to finalize the remedial action;
however, the State will require KSC to perform additional vertical plume delineation before
their approval is given. Coordination between EPA, the State and KSC in resolving these
issues will likely result in the acceptance of this remedial action as final. Once finalized,
this remedial action will undergo refinements based on additional ground-water sampling,
until the site is remediated.
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Incineration or Innovative Technology?
An Evaluation of Treatment Technologies
New Bedford Harbor Hot Spot Sediments
Gayle Garman
Region 1
In 1990 EPA Region 1 adopted a Record of Decision specifying treatment by onsite
incineration for the sediments in the New Bedford Harbor Hot Spot. The Hot Spot is a 5-
acre area contaminated with 4000 ppm to 200,000+ ppm or PCBs. Local opposition to the
incineration developed in late 1991. In response, Region 1 evaluated four innovative
treatment technologies: gas-phase reductive dechlorination, APEG-plus dechlorination, low-
oxygen thermal desorption, and base-catalyzed dechlorination. This presentation will
describe the evaluation process utilized, and the basis for confirming the decision to treat
the Hot Spot sediments by incineration.
Information on the innovative technologies was collected from vendor brochures, EPA
reports, RPMs at other Superfund sites, and from technical experts at the Risk Reduction
Engineering Laboratory in Cincinnati, Ohio. This information was compared to the physical
and chemical characteristics of the Hot Spot sediment, the results of previous treatability
tests of New Bedford Harbor sediment, and performance information from TSCA licensed
incinerators. Among the generally applicable considerations:
Q New technologies often have difficulties with mechanical and/or material
handling mechanisms. Physical characteristics of the waste were as significant
as chemical characteristics to finding a successful treatment method.
Q Despite claims that a process is without metal emissions, comparison of
process operating temperatures may indicate a potential for metal emissions,
similar to incineration.
Q Results from treatment of one organic material should not be extrapolated to
another organic material, without considering differences in chemistry,
reactions, and end products.
Q In addition to uncertainties about treatment effectiveness, there are
uncertainties about availability and cost of innovative technologies.
By definition, there is a limited amount of performance data available for an innovative
technology. However, it should not be assumed that a technology which has treated one
contaminant will necessarily be as successful treating that same contaminant at much greater
concentrations or in a different matrix. These considerations demonstrate the need for a
broad variety of treatment technologies, and for evaluation of their applicability on a site
specific basis.
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Using Biodegradation To Enhance
A Ground Water Pump and Treatment System
Jeff Gore
Region 5
The purpose of this paper is to outline how biodegradation enhanced the effectiveness of
the ground water pump and treatment system at the Seymour, In. Superfund Site. Proper
placement of ground water extraction wells reduced the volume of contaminants entering
the ground water treatment plant, thus reducing air stripper emissions and potential
activated carbon filter absorption.
The two operating extraction wells at the Seymour Site are located approximately 30 feet
and 100 feet respectively from the soil source area. As the ground water plume travels from
the source area to the extraction wells, there is a significant reduction in certain
contaminant levels such as chloroethane, benzene and vinyl chloride.
If ground water extraction wells were placed t the boundary of the soil source area and not
in their current position further downgradient along the plume, these contaminant
reductions would not be allowed to take place, therefore increasing the volume of
contaminant chemicals traveling through the ground water treatment plant.
This presentation will outline the Seymour ground water pump and treatment system, and
the sampling data at the Seymour Site. It will then analyze the reduction in certain ground
water contaminant levels between the soil source area and the ground water extraction
wells. After this information is presented, an analysis will be presented which explains the
most probable reasons for the contaminant mobility and potential biodegradation in the
ground water aquifer.
In conclusion, it is important to consider potential biodegradation of ground water
contaminants when designing and constructing pump and treatment systems for a Superfund
Site. If site conditions favor biodegradation, proper placement of extraction wells can
significantly reduce the volume of site contaminants treated, and therefore reduce air
stripper emissions and activated carbon absorption.
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Remedial Action at the Helen Kramer Landfill Superfund Site
Lawrence A. Granite
Region 2
The Helen Kramer Landfill encompasses a 66-acre refuse area. An 11-acre stressed area
between the eastern limit of the refuse and Edwards Run, a surface water tributary to
Mantua Creek and the Delaware River, was also present. The landfill was originally a sand
and gravel excavation operation; however, in the early 1960's, landfilling occurred
simultaneously with sand excavation. During the 1970's, the landfill is estimated to have
received several million gallons of chemical wastes, including waste solvents and paints. In
addition, approximately two million cubic yards of solid waste are estimated to have been
disposed of at the landfill. The waste is believed to be more than 50 feet thick in most
areas. The deposited materials include septic, municipal, hospital and industrial wastes.
The landfill ceased operation in 1981 through court-ordered closure.
The major components of the remedial action include: construction of a multi-layer cap
over the site; remediation of on-site lagoons; construction of a slurry wall to surround the
entire site; construction of a roller-compacted concrete retaining wall along the east side of
the landfill; construction of a ground water/leachate collection trench to prevent leachate
from entering Edwards Run; pretreatment of leachate from the collection trench prior to
discharge to the Gloucester County Utilities Authority (GCUA); construction of an active
gas collection and treatment system; implementation of surface water controls; construction
of a security fence surrounding the site and work areas; implementation of a monitoring
program to assess the effectiveness and reliability of the remedial action; and operation and
maintenance (O&M) as required to ensure the continued effectiveness of the remedy.
Construction of the remedial action at the site has been completed. This presentation will
provide a brief history of the site, and a review of the construction of the remedial action
and future activities. It will also focus on two items of special interest: the obtainment of
access to GCUA and the resulting discharge requirements; and the transfer of site
responsibilities, from the Federal government to the New Jersey Department of
Environmental Protection and Energy, for the long-term O&M.
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Case Study: Enhancement of Soil Vacuum Extraction
Via Ground Water Sparging
At The Verona Well Field Superfund Site
Margaret Guerriero
Region 5
Ground water extraction (GWE) and Soil Vacuum Extraction (SVE) were implemented at
the Thomas Solvent Raymond Road Source Area of the Verona Well Field in 1987 and
1988 (respectively) to remedial ground water and soils containing very high levels of volatile
organic contaminants (VOCs). By early 1992, the SVE system had removed more than
45,000 pounds of VOCs from the soils and it appears the soils now meet the clean-up
criteria identified in the ROD. However, by the end of 1990, monitoring data from the
GWE system indicated that VOC concentrations in the ground water had reached a plateau
and there has been little decrease in VOC concentrations since that time. The presence of
NAPLs in the saturated soils at the water table interface is considered largely responsible
for this condition.
In researching this problem and its long-term effects on site clean-up levels, EPA directed
its contractor, CH2M Hill, to design a small number of pilot tests utilizing different
technologies to determine if enhancements to the SVE or GWE systems could reduce the
concentrations of VOCs in the ground water. The results showed sparging to be the only
technology with any promise of remediating saturated soils. Based on these results, a
second, 5-month, ground water sparging pilot test was implemented.
My presentation will focus on implementation of sparging at the site and the results of the
extended ground water sparging pilot test. In addition, I will discuss potential applications
of ground water sparging for remediation of VOCs in ground water and soils at superfund
sites.
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Keeping a Remedial Action Moving
Around, Over & Under Seemingly-Insurmountable Obstacles
James J. Hahnenberg
Region 5
The Anderson Development Company Site, located in Adrian, Michigan, is a site where the
Remedial Action has been successfully implemented. This paper will describe how the
remediation was achieved despite obstacles and complications. This was accomplished
thanks to a supportive (and clever) Regional Counsel, a helpful State Project Manager, a
cooperative PRP, and strong technical support by EPA's oversight contractor and the SITE
program.
First, a little history (I'll keep it brief, I promise). A ROD was signed September 1990; the
remedy (In-Situ Vitrification for contaminated sludges) was not popular with the PRP or
the community. Being the responsive agency we are, a ROD Amendment was issued
September 1991, changing the remedy to low temperature thermal description. This time
we had a hit with the PRP and the community! An incredibly ambitious schedule planned
to have all contaminated site materials treated by the end of 1991.
This goal was not achieved. Delays have been primarily due to the following:
Q Volume of contaminated material increasing approximately three times from
the original estimate;
Q Analytical difficulties; and
Q Operational problems.
A major additional complication was a late ARAR raised by the State for manganese; this
was especially interesting (?!) since manganese would not be treated by low temperature
thermal desorption. The State recommended off-site disposal after treatment of
contaminated materials. Since treatment was continuing, limited site storage space required
an early decision, or treatment of contaminated materials would have to be stopped. EPA
conducted a focused Risk Assessment to evaluate human health risks from manganese at
the site, and the PRP informally evaluated alternatives for disposing or treating manganese-
contaminated materials.
After these evaluations were concluded, the PRP agreed to off-site disposal, and an
Explanation of Significant Differences (ESD) was issued. The major modification was off-
site disposal of materials (because of manganese contamination), after on-site treatment;
originally, treated materials were to be placed back in the on-site lagoon.
These materials are currently being treated and removed for off-site disposal; treatment and
removal of all contaminated materials is expected by spring 1993. Lessons learned: stay
goal oriented, don't get bogged down; and a supportive and cooperative team is essential
and can even include the PRP.
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DATA COMPLETENESS VERSUS DATA SUFFICIENCY
Use of the Observational Approach in the
Design of a Soil Sampling Plan
Richard Hammond
Region 4
Throughout the history of Superfund remediations, there has been a tendency to design
remedial investigation (RI) sampling plans with the objective of collecting enough data to
completely define the entire nature and extent of a contaminant plume. This objective can
be termed "data completeness." However, the National Contingency Plan (NCP) requires
only that sufficient data be collected ..."toassess site conditions and evaluate alternatives
to the extent necessary to select a remedy" (NCP 330.430 (a)(2). This objective can be
termed "data sufficiency."
An immediate problem related to data sufficiency is that the term data sufficiency is
subjective, requiring a decision to answer the question, "What is sufficient?" One technique
for achieving data sufficiency is known as the "observational approach." Recently, Oak
Ridge National Lab (ORNL), located in east central Tennessee and operated by the
Department of Energy (DOE), has incorporated the observational approach to design RI
sampling plans. The case study of the development of the RI sampling plan for Waste Area
Grouping (WAG) 5 within ORNL provides a unique opportunity to compare the data
complete method versus the data sufficient method, because the RI sampling plan was
developed prior to implementation of the observational approach, but redesigned using the
observational approach.
This paper is divided into two sections. Section One provides a synopsis of the
observational approach and provides some of the generic conclusions regarding sampling
plan design that may be reached using the observational approach. One of the generic
conclusions reached in Section One provides for much greater use of Data Quality Level
1 and Level 2 during the RI. Another conclusion is that statistical analysis techniques such
as confidence intervals are not applicable to soil sampling programs unless a "distribution
profile" for contaminants is established. Section Two uses the WAG 5 case study to
illustrate practical application of the observational approach when designing RI sampling
plans.
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"NO ACTION/NO ARARS" or How To Pick A Fight With a State
Nancy Harney
Region 10
What has become known as "The Don Clay Memo" (officially cited as "Role of the Baseline
Risk Assessment in Superfund Remedy Selection Decisions, OSWER Directive 9355.0-30")
serves as the guideline for making risk management decisions in Superfund. In defining the
"acceptable risk range," Clay's memo asserts that if EPA determines that the risks posed by
a site are within the acceptable range of 1 x 10"* to 1 x 10"6, no further action needs to be
taken. In EPA's view of the world, if no action is taken, then ARARs are not triggered.
EPA's position presents problems for states, particularly those states that have adopted
stringent regulatory cleanup levels. EPA may make the determination that no further action
is necessary based on the risk assessment; however, if state cleanup standards are exceeded,
the state may not be satisfied with EPA's decision and may insist on the need for remedial
action to comply with state requirements. In Region 10, the state of Washington has been
particularly adamant in their opposition to EPA's "no action/no ARARs" policy. At sites
where there are low levels of contamination, these two seemingly polarized positions by the
regulatory agencies have led to numerous delays in site cleanups as well as strained
relationships between EPA and the state.
The argument cannot be won by either side because there are states rights issues that are
beyond the capabilities of RPMs and even regional administrators to resolve; in all
likelihood, there will be lengthy litigation and ultimately it will be the courts that decide.
In the meantime, rather than becoming bogged down in bureaucratic wrangling, we want
to keep sites moving towards cleanup.
The Region 10 Federal Facility Superfund program has tried to finesse the "no action/no
ARARs" issue. Through a panel discussion, we would like to explore this issue. We plan
to share our experiences and the type of "stop gap" solutions we have employed and then
open up the discussion to other regions' experiences. We are looking not only for
innovative solutions but also a discussion of the validity of EPA's position and where the
agency is headed in the future.
The panel will consist of RPMs from throughout the Superfund program as well as
representatives of ORC and perhaps EPA headquarters.
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New Cost Recovery Rule and Potential Impacts
Cynthia Kaleri & MaryAnn Abrahamson
Region 6
Don Clay issued a memo dated November 3, 1992 entitled "Cost Recovery Case Support"
which called for each region to establish a plan for dealing with the new Cost Recovery
Rule's compilation of work performed documentation. The Department of Justice has
blessed the method currently in use by Region 3 and would like all regions to copy suit.
However, each region is set up a bit differently and cannot merely implement Region 3's
procedures.
In November, representatives from Regions 5 and 6 met with Region 3 to discuss the pros
and cons of their current system and exchange ideas on cost documentation for work
performed. Areas of concern can be split into two subcategories: past documentation
available under the system currently in place (each region) and future documentation efforts
under a revised system (region specific). Future efforts depend mainly on support efforts
of management, but should be much easier than compilation of past documentation for
older sites. The impact of the new rule on how RPMs interact with DOJ for cost recovery
cases (in view of work performed documentation) is the focus of this presentation.
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Abstract On The Successful Administration Of A
Technical Assistance Grant At The
Maxey Flats Nuclear Disposal Site, Kentucky
Dave Kluesner
Region 4
The Maxey Flats Nuclear Disposal Site (MFNDS) is an inactive low-level radioactive waste
disposal site encompassing approximately 280 acres. The MFNDS is located in rural eastern
Kentucky, wherein an estimated 663 people live within 2.5 miles of the site, 25 of them
within a half mile of the site. The site operated from 1963 to 1977, accepting approximately
5 million cubic feet of radioactive waste which was generated by more than 800 Potentially
Responsible Parties (PRPs), including universities, hospitals, utilities, research organizations
and federal agencies. The Commonwealth of Kentucky (Commonwealth) has owned the
site since 1963, licensing it to a private contractor for the disposal of low-level radioactive
waste until studies indicated the movement of radioactive leachate into the environment.
EPA included the MFNDS on the NPL in 1986 at the request of the Commonwealth and
signed an Administrative Order on Consent with 82 PRPs to perform the Remedial
Investigation/Feasibility Study (RI/FS). EPA approved the RI/FS in June 1991 and signed
a Record of Decision on the MFNDS on September 30, 1991. EPA is currently in the
process of negotiating a Consent Decree for Remedial Design/Remedial Action. The
estimated cost of the remedy is $57 million and is expected to require approximately 100
years before remedial action is completed.
Community interest in the MFNDS has been high since the opening of the site to the
disposal of commercial waste in 1963. Organized community groups have been in existence
since the mid 1970'swhen studies indicated the migration of radionuclides from the disposal
area. Since that time, the community's efforts have either culminated or assisted in, closure
of the site in 1977, placement of the MFNDS before the State legislature every year since
1976, formation of two Governor-appointed commissions to study the site and evaluate
remedial alternatives for site closure, and acquisition of a $50,000 Technical Assistance
Grant from EPA in January 1989. The Maxey Flats Concerned Citizens Group (MFCC)
was very active throughout the RI/FS, sponsoring site rallies and forums at local schools and
universities, attending EPA-sponsored public meetings and site tours, reviewing draft RI and
FS Reports for technical input, and serving as moderator of EPA's proposed Plan public
meeting. The MFCC and their Technical Advisor provided input into the remedial
alternative screening process, leading to EPA selection of a remedy which is favored by the
MFCC and the Maxey Flats community. This issues-paper will describe how the existence
of a Technical Assistance Grant for the MFNDS has resulted in: reduced fear due to a
heightened community awareness of the risks posed by the site, a better understanding of
the remedy to be implemented, and a greater trust of EPA actions resulting in a more
constructive working relationship between EPA and the community.
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Remedial Action
Palmerton Zinc Site
Blue Mountain Revegetation
Tony Roller
Region 3
Background - Short discussion on the causes of the defoliation of approximately 2000 acres
on Blue Mountain by a zinc smelter
Problem - Identification of unique limitations on remedial alternatives and design
RI - Results of investigation into types of growth capable for Blue Mountain
Remedial Action - Discussion of construction techniques for the application of a
sludge/flyash mixture on Blue Mountain
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Case Study On Site Characterization At A TCE Plume:
St. Joseph, Michigan, NPL Site
John Kuhns - Region 5
and
Peter Kitanidis - Stanford University
A plume of TCE in a sandy water table aquifer originates from an industrial facility in St.
Joseph, Michigan. The origin of the plume is on a ground-water divide. The plume
bifurcates; part drains to the east and part to the west. Based on concentrations of
compounds in conventional monitoring wells, bioremediation through co-oxidation by
methane-oxidizing bacteria was proposed as the remedy for the west plume. To calibrate
a design model for bioremediation, it was necessary to estimate the average concentration
of TCE and its dechlorination products in the ground water, and the flux of TCE and
dechlorination products along the plume.
GROUND-WATER SAMPLING
Estimates of contaminant concentrations were obtained from two transects extending across
the plume roughly perpendicular to the flow of ground water. To sample ground water, an
auger slotted over the first 5 ft. of its length was drilled into the earth. Starting at the water
table about 40 ft. below land surface, the auger was advanced 5 ft., water was pumped until
conductivity and redox stabilized, and samples were taken for chemical analysis; then the
auger was advanced another 5 ft. to take the next sample. This depth-discrete sampling was
continued to the bottom of the aquifer 80 ft. below the land surface. Borings were spaced
along the transects at intervals of 20 ft. to 40 ft. Both transects extended all the way across
the plume.
ESTIMATES OF CONTAMINANT FLUX
Concentrations in the plume were estimated by averaging the individual depth-discrete
samples. More than 50 such samples were included in each transect. The hydraulic
gradient was multiplied by the hydraulic conductivity to determine the flow of water in the
plume. The flow was multiplied by the concentrations of contaminants to estimate the flux.
The flux of TCE off the industrial facility was 60 kg/year. The flux of cis DCE and vinyl
chloride was 71 and 11 kg/year, respectively.
IMPLICATIONS FOR BIOREMEDIATION
The design model strongly indicated that bioremediation could not reach acceptable
concentrations for TCE or cis DCE when methane was used as the primary feedstock for
aerobic biotransformation. As a result, plans for a pilot-scale evaluation of bioremediation
were abandoned. This case study illustrates the importance of site characterization for
proper implementation of bioremediation. If data from the conventional monitoring wells
had been used to design the remedy, it would not have performed as expected.
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Developing Cleanup Levels For PAH's In Sediments
Robert J. Leger
Region 1
Objective - To describe three (3) separate methodologies that were developed to determine
a total polycyclic aromatic hydrocarbon ("PAH") concentration that would be protective of
aquatic life.
There are no data on toxicity of PAHs in sediments to freshwater organisms that
conclusively support any particular number for cleanup levels of total PAHs in freshwater
sediments. Three (3) separate methodologies are developed to determine a total PAH
concentration that would be protective of the aquatic life at the Hocomonco Pond
Superfund Site in Westborough, Massachusetts.
The Equilibrium Partitioning ("EP") method and Toxicity Quotient Approach are used to
develop cleanup levels to protect the aquatic benthic life. The evaluation of contaminants
using the EP method allows derivation of site-specific sediment quality criteria ("SQC") from
which toxicity in sediments can be evaluated. The EP method uses the SQC to develop a
Total Toxicity Quotient for each contaminant at a particular sampling station. The Toxicity
Quotient Approach involves dividing an exposure concentration for each individual PAH
at a particular sampling station by the contaminant-specific SQC. Resultant quotients for
each individual PAH are totaled for each station. The total PAH concentration measured
at a location is divided by the Total Toxicity Quotient to obtain a concentration at which
a Total Toxicity Quotient of "1" would be obtained for total PAHs.
The second methodology involved calculating the mean percentage of each individual PAH
constituent for all the samples stations. The mean percentage is divided by the
contaminant-specific SQC and the resultant quotients are totaled for all constituent PAHs.
The summed quotients of all constituent PAHs is then divided into a Total Toxicity
Quotient of 1 to obtain a total PAH concentration.
The third methodology involved using the interim sediment quality criteria for
phenanthrene, which is the lowest (i.e., most toxic) of the six compounds for which criteria
have been developed. A SQC for phenanthrene is subsequently developed. This SQC was
equilibrated with the percentage that phenanthrene represented of the total PAHs present.
The equivalent PAH concentration obtained using this methodology is determined. As has
been done at other superfund sites, not only would the total equivalent PAH concentration
have to be met as an endpoint for remediation, but the SQC for phenanthrene would have
to be met as well.
Because of the varying results generated by the assumptions in the three approaches, EPA
decided not to rely on one simple approach, but has considered all three methodologies in
setting its cleanup levels. EPA decided that a cleanup level for phenanthrene, as well as
a cleanup level for total PAHs which averages the results of these three methodologies, is
reasonable. A discussion of the assumptions involved with each methodology is also given.
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The Use of Aerial Photography to Streamline Delineation of Area
of Contamination: Case Studies and Procedures
Kathleen Lohrv
Region 6
The use of aerial photographs during the early investigatory stages of site development can
save time and money. Historical aerial photos discovered ruing the RI process at several
Region 6 sites showed that sample locations were not in the optimum locations and that the
extent of contamination was not defined accurately. The aerial photos also aided in the
PRP search and enforcement activities since they gave clear evidence of site usage.
After delineation of site contamination by borings at the Cleve Reber site, an abandoned
landfill in Louisiana, aerial photos produced by the PRPs showed that the boundaries of the
landfill were not those assumed by EPA from sample results. The photos also pinpointed
locations of buried drums much more precisely than the borings that had been done.
Dating of the trees in the landfill confirmed the PRP aerial photo information.
At the West Memphis landfill in Arkansas, areas of disturbance were found in the aerials
that led EPA to determine that the extent of contamination was much greater than
originally anticipated.
At two adjacent oilfield-related sites in Louisiana, several areas used for previous disposal
were discovered after review of the historical aerials. Additional sampling proved the
existence of buried waste pits. Again, the use of aerials better delineated waste areas and
volume and allowed for a more accurate site characterization.
In the previous examples, a thorough historic aerial photo search would have greatly
facilitated site characterization and expedited the choosing of the location of samples during
the RI. Areas of past disposal would have been known and criticism by the public and the
PRPs would have been avoided. At the Cleve Reber site, the discovery of aerial photos
significantly reduced the costs and changed the technical approach to remedial design.
The presentation will illustrate why aerial photograph use during the preliminary stages of
site investigation can greatly speed the investigation, provide a more accurate delineation
of site contamination than samples alone, aid in enforcement and potentially save money
by narrowing the areas that must be sampled while confirming sample results. The three
case studies will be presented showing instances where aerial photographic analysis at
various stages of the RI changed the methodology of the investigation, in two cases yielding
different boundaries for site contamination than the results of the original EPA sampling
program. Subsequent changes in the costs of the remedies based on the aerial data will be
noted. In addition, the presentation will discuss sources and procedures for the acquisition
of aerial photos that are available to the RPM.
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Contingencies and Deferred Decisions At Large Ground Water
Contamination Sites Involving Local Water Supply Agencies
Kevin Mayer and Colette Kostelec
Region 9
Many decisions at Superfund sites are deferred routinely to the Remedial Design (RD)
phase of the project (e.g., the details of extraction well, pipeline and treatment facility
locations). The complexity of large pump-and-treat systems and the uncertainties in dealing
with public water supply agencies at several sites in Southern California have necessitated
proposals to postpone selection of major project features to post-Record of Decision (ROD)
phases. We have also discovered many benefits of ROD flexibility for elements of the
remedy that are critical to implementability, but really secondary to the project objectives.
The preferred options for various Operable Units in the San Bernardino (Newmark Site)
and San Fernando Valleys involve extracting contaminated ground water at rates ranging
from 2,000 to 14,000 gpm (3 to 20 MGD), treating and conveying the valuable water to
public water supply agencies. The local agencies cannot be relied upon prior to the ROD
to agree contractually to accept this water year-round, so contingencies for reinjection of
the treated water must be incorporated into the RODs.
Treatment technologies for removing TCE, PCE, and other volatile solvent contaminants
for a public water supply become critical. The conventional technologies, liquid-phase
carbon filtration and air-stripping (with emissions treatment in this region of poor air
quality), were determined to be equivalent in effectiveness and cost. The final decision
between these two are deferred until further design details become available (post-ROD).
Additionally, innovative treatment technologies which have not been demonstrated at such
high flow rates could be considered if acceptable results become available early in the RD
phase.
Monitoring well system design has also been deferred, due to the expense of drilling wells
which could be deeper than 1000 ft. in urban areas.
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A Successful Non-EPA Technical Advisory Committee For A Large
Ground Water Contamination Site in San Bernardino, California
Kevin Mayer
Region 9
A Technical Advisory Committee (TAC) was established by the RPM in 1990 at the start
of the Remedial Investigation of the Newmark Ground water Contamination Site in San
Bernardino. This team has required relatively little effort — meetings have been held twice
each year — and the benefits have been significant.
The site consists of a plume of PCE- and TCE-contaminated ground water extending for
over 5 miles through a deep (300 to over 1000 feet of saturated thickness) and highly
productive aquifer on which over 500,000 people rely. Many local and state agencies had
been involved prior to the listing of this site on the NPL. The importance of the aquifer
and multiple objectives had generated interagency disagreements (which continue to plague
a nearby Federal facility which preferred a closed process).
The involvement of regulators (Office of Drinking Water, Toxic Substances Control, and
Regional Water Quality Control Board from the state, plus the County Health Department)
helps information flow and the development of a common objective for the project. Four
local water supply agencies (Cities of San Bernardino and Riverside, San Bernardino Valley
Water District and a valley-wide purveyors' group) provide invaluable information on actual
hydrogeologic and operational conditions, cooperation during field studies and a positive
relationship with the local communities. A group of professors from University of
California at Riverside, along with a research hydrogeologist from USGS, improve the rigor
of the project analysis, ensure that our technical approach is consistent with the state-of-the-
art research, and offer the credibility of an objective observer and critic.
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SACM: A Unique Perspective From An Ex-OSC Turned RPM
Kelly S. McCarty
Region 9
The objective of the presentation is to discuss how SACM can work: how we can blend the
best of both the removal and remedial programs to develop the most efficient and effective
cleanup at each site.
I will discuss:
Q "OSC" authorities: what they are, and who has them;
Q what is the distinction between emergency, time-critical, non-time critical, and early
actions;
Q when each type of action is appropriate;
Q how to use the distinction to the best advantage;
Q contract mechanisms for each type of action;
Q pros and cons of each contract mechanism, and how to fix some of the cons.
Having worked on both sides of the fence, and in two regions (including Region 4 during
the "removals"), my perspective is somewhat unique. I will share that perspective and my
experience in discussing how we can "speed up" the remedial process.
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Vinyl Chloride In Landfill Soil Gas Shown To Migrate
Beyond The End Of The Methane Plume
Bret Moxley
Region 9
Soil gas contaminant plumes emanating from landfills are typically thought to be defined
by the leading edge of the methane plume. Soil gas sampling recently completed at the
Fresno Sanitary Landfill Superfund site has shown this presumption to be incorrect. At this
site, methane migrated 200 feet from the trash prism. Vinyl chloride and tetrachloroethane
were detected at up to 700 feet from the trash prism. The detection limit for vinyl chloride
in soil gas was 0.2 parts per billion by volume (ppbv). This sampling was conducted to
determine if there was a possible soil gas exposure pathway for vinyl chloride in homes near
the landfill.
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In-home Air Sampling For Vinyl Chloride
In Residences Near A Landfill
Bret Moxley
Region 9
An in-home air sampling program is presently being conducted to determine the exposure
of residents near the Operating Industries Inc. landfill to vinyl chloride. The route of
migration is through soil gas into the living space. This program will eventually include over
200 homes. Preliminary results have shown approximate risks of 3E-3 for small children.
This discussion will include indoor air action levels and risk levels for vinyl chloride,
children as a sensitive subpopulation for vinyl chloride exposure, community relations issues
and mitigation measures.
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Future Considerations For The Application Of In-Situ
Vitrification At Superfund Sites
Linda M. Nachowicz
Region 5
In-situ vitrification (ISV) as applied to soils requires the insertion of electrodes into the soil
in a square array on the average of 20 square feet, 15 ft. deep. Dissipation of electrical
power through the starter material creates temperatures high enough (up to 2000° C) to
melt a layer of soil. This molten zone continues to grow downward encompassing
contaminated soils. Non-volatile hazardous elements (heavy metals) are incorporated into
the matrix while organic compounds are destroyed by pyrolysis. A hood is placed over the
area being vitrified directing the gaseous effluents to an off-gas treatment system. After
application, the area will cool to form a obsidian monolith. The process operation is based
on extensive joule heated melter work performed at Battelle Pacific Northwest Laboratory
for various nuclear waste immobilization projects.
ISV was the selected technology for a non-time critical removal at the Parson's Chemical
Site in Grand Ledge Michigan. The ISV process was chosen because it will result in a
twenty to thirty percent reduction in volume, it will decrease the toxicity to virtually zero,
and it will permanently immobilize all of the hazardous substance on the site. The
alternative, which is incineration and land disposal, would reduce toxicity to a lesser degree
but may not permanently immobilize them. In addition, the ISV process will destroy the
dioxin contaminated soils, whereas, at the time of technology selection, no incinerator
and/or landfill is permitted for acceptance of this waste type.
In testing prior to mobilization at the site, an incident occurred that revealed several
important factors that need to be considered for future applications of this technology which
are as follows: a) the capability of water vapor to pass to the surface as well as other
moisture generating sources will need to be analyzed. Sites will have to be characterized
for the presence of water and other vapor generation materials for purposes of estimating
worst case vapor generation rates; 2) all future large-scale application will either be
performed with moving electrodes, or will be pre-analyzed for acceptability of fixed
electrode use; 3) sites containing sealed containers or pooled liquids will not be processed.
However, proper site preparation can eliminate these conditions on a limited scale; 4) a
metal off-gas collection hood design will be used in order to withstand the inadvertent
spattering of molten glass as may be expected through normal operations.
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Solvents Recovery Service of New England (SRS)
Michael Nalipinski
Region 1
I. Description of SRS
Q Location, size, and key features of study area
Q Nature and extent of contamination
Q Current status of RI/FS
II. Genesis/Evolution of Non-Time Critical Removal Action
Q Concern over high levels of VOCs in subsurface soils contaminating ground
water which is migrating away from the source (despite the presence of an
onsite interceptor well system). These soils are too "hot" to excavate without
causing an air release that would pose an unacceptable threat to workers and
nearby residents.
Q Preliminary early action goals: 1) Initiate reduction of VOCs to reduce the
source of ground water contamination, to permit consideration of final soil
remedies involving excavation, and to accelerate completion of the final
remedial action; 2) Minimize migration of ground water contamination.
Q Contemplation of plume containment measures by owner
Q Exploration of soil vapor extraction field test with ORD
Q SVE study would delay planned ROD. Removal actions would be counted
as beans equal in weight to RODs in FY'93
Q Discussions with ESD leading to time-critical removal action (ESD hesitant
to get involved in ground water pump and treat)
Q Discussions with CT DEP leading to new treatment system for existing ground
water interceptor system
HI. Process Overview
Q Obtained $200,000 for RI/FS ARCS contractor. EE/CA from $50 million
remedial action set-aside for early actions
Q Initiated EE/CA, three drafts planned
Q Belatedly prepared EE/CA Approval Memo which triggers the administrative
record
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Q Will hold public meeting and 45-day public comment period
Q Regional Administrator to sign the Action Memo?
Q Action likely to require a consistency exemption from the statutory limits on
removals $2 million, one year)
Q ORC, ESD, and CT DEP will review the draft EE/CA Approval Memo, the
draft EE/CA, and the draft Action Memorandum
Q ARCS contractor will subcontract and oversee the implementation of the
selected non-time-critical removal action if Fund-Financed (no design step
necessary)
IV. Likely Components of Non-Time-Critical Removal Action
Q Soils: Soil vapor extraction (SVE), thermally enhanced SVE, or SVE with air
sparging. Will operate until removal cleanup levels met or commencement
of remedial action, whichever comes earlier.
Q Ground water Containment and Treatment
Q Vapor Treatment
Q Dewatering (Except for air sparging alternative)
Q Cost range of alternatives: $10-23 million
V. Lessons Learned
Q Integrated site management planning which accounts for all technical and
enforcement components of the case and funding needs is important to
understand links between different aspects of the project, and for workload
planning and scheduling
Q Conduct of the EE/CA resulting in higher quality, more focused FS since
we're learning more earlier and that knowledge is being built up in a single
contractor with responsibility for both components
Q Forecasting the final remedial action to a certain extent is critical to ensuring
consistency between removal and remedial actions while avoiding pre-
selection
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Remedial Pipeline Project Management Module (RP2M)
Mike Negrelli and Donna Vizian
Region 2
The Remedial Pipeline Project Management Module (RP2M) is a project tracking tool
designed by RPMs to assist in planning and managing projects. As a project planning tool,
RP2M allows RPMs to schedule predefined and user-defined remedial pipeline
Event/Activity, Subevent-Milestone project dates, evaluate site-specific data, and track
progress at multiple levels of detail. RP2M also has the ability to generate a number of
varied tracking reports, including a Gantt Chart, Monthly Calendar, NPL Status Report, and
Summary Listing Report. The module's interaction with WasteLAN allows program
planning and project planning to be automatically entered, preventing the need for duplicate
data entry. Information entered by RPMs is updated in WasteLAN through a Management
Review session, enacted by section or branch chiefs. RP2M uses three concepts —
templates, branching, and cascading — to integrate project information and update it in a
useful manner.
RP2M is essentially used in the same manner as WasteLAN, but is significantly more user-
friendly and multifaceted. Once an RPM selects a site, RP2M automatically selects the
Remedial template, a predetermined list of Events/Activities and Subevents/Milestones,
defined by the Regions and maintained by the WasteLAN System Administrator. RPMs
can modify templates by adding or deleting user-defined Subevents/Milestones. RP2M data
are relating using a "branching" technique. Branching uses WasteLAN LINKS data to
connect related Events/Activities into a comprehensive site schedule. Because changing a
Subevent/Milestone date may affect subsequent planned dates, RP2M provides an optional
ability to automatically change subsequent planned completion dates by the same intervals
through cascading. On-line Help and Hotkeys are additional conventions that make RP2M
a user-friendly tracking tool.
Background Information: RP2M is a still-evolving software tool, designed primarily through
the efforts of a Workgroup consisting of representatives from Regions 2, 3, 4, and 5,
Headquarters, and the design contractor, the Marasco Newton Group. After an
approximate 6-month pilot program, RP2M is now in use program-wide in Region 2.
Version 2.2 is currently scheduled for release in late February, which will include a
Financial Module. Outstanding comments collected to fine-tune the program are
continually being prioritized and addressed by the Workgroup in a timely manner.
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Quality Assurance Project Plans
Arturo Palomares
Region 8
Section 300.430(ii) of the NCP requires that Quality Assurance Project Plans (QAPPs) be
prepared for Superfund investigations. The development, review, approval, and
implementation of the QAPP is mandatory for all organizations performing work for EPA.
The QAPP is an important tool for project managers to document the type and quality of
data needed to make environmental decisions.
Information needed to prepare QAPPs will be discussed.
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Chromium Electroplaters = F001, F006, F007, and F008
Jon Peterson
Region 5
Chromium Electroplaters commonly generate at least four RCRA listed wastes:
F002 - Degreasers
F006 - Sludge from pretreatment of plating waste waters
F007 - The spent plating bath solution
F008 - The residue at the bottom of the plating baths
These wastes tend to be spilled on the concrete floor of the plating shop and are directed
to pretreatment facilities and/or sanitary sewer discharge points by troughs in the concrete
floor. The acidic plating bath solutions react with the concrete and the integrity of the
concrete is destroyed. Ventilation systems are used in the plating shop which exhaust the
fumes from these wastes to the outdoor air. The soils under the ventilation discharge will
eventually become contaminated as well. In locations where there are no permitted
hazardous waste treatment facilities and Subtitle C landfills, the potential for improper
disposal of these wastes increases due to the expense of complying with the law.
When the electroplating companies go out of business, they may or may not have arranged
for proper disposal of their hazardous wastes in the plant, but they rarely arrange for the
remediation of the contaminated soils and buildings they have left behind. The wastes
which have leaked through the concrete and been exhausted or pumped outside the building
constitute RCRA listed wastes which then are contained in the soil, ground water, and
surface water.
A Superfund Remediation of the site would have to incur significantly more expense if the
contaminated soils are handled in accordance with RCRA. If the soils were only deemed
to be hazardous by virtue of exceeding the TCLP criteria for chromium cadmium, cyanide,
etc., the material must be treated to meet the standards in 40 CFR 268 Subpart D.
If the treated material then meets the TCLP criteria, it may be disposed of in a Subtitle D
landfill. However, the soils under electroplating sites are usually contaminated with listed
wastes. This means that even if the material is treated to achieve the treatment standards,
it remains a listed waste and is required to be placed in a Subtitle C landfill.
This presents the RPM with a quandary - does he or she manifest the material as listed
wastes and incur the significantly greater expense of Subtitle C disposal of the treated soil
containing the waste or manifest the material as characteristic waste, and have the treated
residual placed in a Subtitle D landfill with a resulting cost savings to the government?
It makes sense to handle this material as if it were not listed since the treatment standards
are exactly the same, but it requires one to ignore or circumvent the true letter of the law
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by not acknowledging that the material is at least similar to the RCRA listed wastes
discussed above.
A Regional or National policy, which directs that soils containing waste from electroplating
companies should be treated as if they were characteristic, would save the government
money and would be equally protective as the current loophole in the regulations.
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The Role of Community Interests and Medical Information
In Risk Management
Brian Pinkowski
Region 8
Communities across the nation are becoming involved in risk management decisions that
were once made independently by governmental bodies such as the Environmental
Protection Agency. This is in part due to the community's interest in determining what goes
on within its borders and preventing outside agents without a personal stake in the
community from making decisions which impact the community. As a result of this sort of
community involvement in local risk management, nonuniformity in risk management will
result. Since each community may have a different threshold for determining what is an
"acceptable risk". Great ethical difficulty will result when communities determine that
medical information which shows an impact on the children in the community should be the
threshold for environmental cleanup that reduces risks. The community in Aspen, Colorado
has made such a decision with respect to the soil lead contamination left behind from the
town's silvermining history. The technical information describing Aspen's situation, the
community dynamic, and the ethical considerations in EPA's risk management decisions for
the area will be discussed in this paper.
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Mega-Site Remediation In The Arid West:
What To Do with 30,000 gpm Of Extracted Ground Water?
Wayne Praskins
Region 9
The San Gabriel Valley Superfund Sites in Southern California share several characteristics
with Superfund sites throughout the country: contamination of ground water; the present
of PCE, TCE and other organic solvents; and the user of "pump and treat" for ground water
cleanup.
In several ways, however, the Sites are unique. The area of contamination is large (many
square miles and hundreds of feet deep); the aquifer is highly permeable (ground water
velocities up to 1000 feet per year); and the aquifer provides drinking water to more than
a million people.
The proposed remedy is to pump and treat up to 29,000 gallons per minute of ground
water. The size of the remedy and the site's location in the arid western United States have
several consequences:
Q The amount of water is too large and valuable to use for any purpose other
than as a drinking water supply.
Q The remedy will be costly: capital costs are estimated at $50 - 100 million;
O&M costs are estimated at $5 - 10 million/year.
Q Implementing the remedy will be institutionally complex: requiring the
participation of public water supplies that will serve treated water to retail
customers; the court-appointed "Watermaster" responsible for administering
an existing court decision adjudicating water rights; and other agencies which
manage, transport, or distribute water in California.
Q The remedy will require significant energy consumption to lift ground water
200' from the water table to ground surface, transport the water to end users,
and pressurize it for delivery to public water supplies. The evaluation of
remedial alternatives considers the cost of electricity in the estimate of O&M
costs and the "secondary environmental effects" resulting from the generation
of electricity.
Q The remedy is likely to include air stripping for VOC removal. Air emissions
from the air strippers will be large enough (50-100 lbs/day) to require offgas
controls, require the acquisition of "emission offsets," and raise concerns
about risk via the air pathway.
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Innovative Technology for Remediation Of Organics
In Ground Water
Beth Reiner
Region 5
Conventional ground water pump and treat has come under increasing criticism for being
an inefficient and expensive means for remediating ground water contamination.
Development of less costly and more efficient technologies are in progress. Some of these
technologies are air sparging, bioventing, enhanced biological attenuation, and in-situ
treatment walls. At the Electro-Voice (EV) Superfund site in Buchanan, Michigan, a
combination air sparging/bioremediation system is being demonstrated on soils and ground
water contaminated with volatile and semi-volatile organic compounds. The system is called
the Subsurface Volatilization and Ventilation System (SVVS) and was developed by Billings
& Assoc., Inc. in Albuquerque, New Mexico. The demonstration is being conducted in
conjunction with U.S. EPA's Superfund Innovative Technology Evaluation (SITE) Program.
The SVVS system at the EV site consists of a series of air injection and vacuum/extraction
wells designed to circulate air below the ground to: 1) volatilize and remove volatile organic
contaminants from the soil and ground water, and 2) increase the flow of oxygen in the soil
to enhance the rate of organics destruction by soil microbes. The system consists of three
rows of injection and vapor extraction wells called reactor lines. Each reactor line is
connected to a single central vapor control unit which is used to house air injection and
vacuum pumps and gauging, as well as emissions control equipment.
The injection wells are drilled below the ground water table and are used to inject air into
the ground water. The injected air then percolates up through the water, circulates in the
soil, and is removed via extraction wells under vacuum. The developer claims that the
circulation of the air removes volatile organic contaminants from the soil, and that the
increased circulation of air in the soil, specifically oxygen, increases the rate of
biodegradation by soil microbes. At the EV site, eight sand chimneys will be installed in
the area of demonstration to aid the circulation process. These are sand-packed borings
which provide passive airflow through the soils.
The system has been tested in New Mexico on fuel spills where contaminants of concern
were BTEXs. The developer claims degradation rates are on the order of 10% to 20% per
month and cost savings of 60% to 80% over traditional techniques such as pump and treat.
The developer claims the average rate of remediation based on field data is five years. This
is a significantly shorter time than projected clean-up timeframes for pump and treat, which
is normally more on the order of 30+ years.
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Access Issues At The Ewan Property Site — A Road to Nowhere?
Ewan Property Superfund Site, Shamong Township, New Jersey
David RosofT
Region 2
This paper will present a case study depicting the pitfalls surrounding site access and
associated community relations issues that can occur at Superfund sites. The paper will
focus on the history and development of site access issues at the Ewan Property Superfund
site located in Shamong Township, Burlington County, New Jersey.
The Ewan Property site is situated in a forested wetland in the central Pine Barrens of New
Jersey approximately one quarter mile south and one mile north of residential
developments. The site consists of 500 to 8000 buried drums of organic and metals
contaminants and a contaminated ground water plume flowing south at a rate of 75 to 120
feet per year. The cleanup of the site has been divided into two operable units. The first
operable unit addresses the excavation and off-site treatment and disposal of the source
materials (drums and heavily contaminated soil). The second Operable Unit consists of the
remediation of the ground water and residually contaminated soils. RODs for these
Operable Units were signed in 1988 and 1989, respectively.
Because there is no direct access to the site by public roadways, the construction of an
access route was necessary to implement the work called for in the ROD. EPA began the
pursuit of permanent access to the site in August 1990. The construction of this permanent
site access route has been delayed by more than two years by a combination of continued
community resistance to the location of the selected route, congressional inquiry, private
property access negotiations and the resultant acquisition and condemnation process, and
state/New Jersey Pinelands regulatory issues. At each step of the way toward access route
construction, EPA has been presented with unique and difficult issues that have had little
or nothing to do with the relatively simple task of building a road. As a result, the access
road is not yet built and the ground water contaminant plume continues to migrate towards
the residences to the south. It is clear that the focus at the Ewan Property site is no longer
on the contamination or the impending health threat, but on the location of an access route
and the ramifications therein.
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Expanding the Objectives of Emergency Response Activities
Donna Santiago
Region 3
The objective of this paper is to discuss how the evaluation of a site can be streamlined
from the emergency response actions to listing on the National Priorities List (NPL).
Discussion will include steps that the on-scene coordinator (OSC) can take to obtain
information needed for site assessment or information needed to evaluate the site with the
Hazard Ranking System (HRS). The paper will outline ways in which the OSC can obtain
this data during emergency response action. Such steps will include: (a) learning the HRS;
(2) becoming familiar with the targets identified in the HRS; (3) becoming familiar with
characteristics of sites that score above a 28.5 when evaluated with the HRS and
mechanisms that make the sites score; (4) implementing what they know above the HRS to
obtain information needed to evaluate the site with the HRS during the emergency response
actions. The paper will illustrate through examples how information obtained by the OSC
can be used to determine whether or not a site will score above a 28.5 (the cutoff score for
listing on the NPL).
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Access, Easements and Angry Neighbors -
Whatever Happened To Site Cleanup?
Fred Schauffler
Region 9
The Koppers Company, Inc. Superfund site in Oroville, California, is an operating wood-
treating facility located just south of the city limits. Since 1955, Koppers has used a variety
of chemical preservatives in its wood-treating processes. Utility poles, railroad ties, and
dimensional lumber have been pressure-treated using chemical formulations that include
pentachlorophenol (PC), creosote, and chromated copper arsenate (CCA). Ground water,
surface water, soil and sediment contamination have resulted from both wood treatment
operations, related waste disposal practices, and two major fires that occurred at the plant.
On- and off-plant ground water contamination will be addressed by the installation of two
separate treatment systems. Each system will include extraction wells, a carbon adsorption
system and recharge wells that return the treated water to the aquifer. As a temporary
measure during the initial period of operation, the treated off-plant ground water will be
discharged to a nearby stream in compliance with a State-issued permit.
The off-property ground water system will be located in a rural residential area located near
the tow of the plume. The treatment plant and two of the three extraction wells will be
located on property which the PRP has purchased. Construction of the pipelines and the
extraction, reinjection and monitoring wells will require long-term easements from nearby
property owners. In addition, temporary access is needed to drill test borings at the
proposed well locations.
Obtaining easements and access has been hampered by the residents' dislike for the PRP
and by their own mistrust of one another. This presentation will elaborate on the issues
that created this situation and on the actions taken to minimize schedule delays in
construction of this treatment system.
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GIS Made Painless:
How RPMs Can Access GIS Data
At Multi-Source Ground Water Sites
Kathy Setian
Region 9
OBJECTIVE: To show how RPMs can display and query GIS data for themselves
without needing to become (or work through) a computer wizard.
During the Remedial Investigation of ground water sites with multiple sources or very large
areas of contamination, computer-based Geographic Information Systems (GIS) are often
used to store and manage large quantities of water quality data, as well as hydrogeologic
and geographic data and PRP information. The added advantage of a GIS over a standard
database management system is the ability to relate data spatially. EPA and other
government agencies have standardized on powerful GIS software, ARC/INFO.
Unfortunately for RPMs, since ARC/INFO is difficult to learn and cumbersome to use, we
are often forced to rely on either in-house or contracted technical support to access the data
in the GIS on our behalf.
In order to give an RPM direct access to the GIS, an easier-to-use Graphical User Interface
(GUI) is required. One such interface is ARCView, which became available in 1992. This
paper will discuss how I as an RPM for the San Gabriel Valley Superfund site was able to
use ARCView to create views of our GIS that can be accessed by other RPMs with
comparatively little training. It will also discuss the current shortcomings, anticipated
enhancements, and potential pitfalls of the system.
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Pollution Prevention In Superfund
Edwin R. Smith
Region 5
The idea of minimizing the amount of hazardous waste generated is not new in regulatory
history. In 1986, with the Hazardous and Solid Waste Amendments (HSWA) to the
Resource Conservation and Recovery Act (RCRA), the Congress declared that "...wherever
feasible, the generation of hazardous waste is to be reduced or eliminated as expeditiously
as possible." The Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) of 1980 as amended by the Superfund Amendments and Reauthorization
Act (SARA) of 1986 mandates the selection of remedial actions that utilize resource recovery
technologies or permanent solutions to the maximum extent practicable. The Pollution
Prevention Act codifies the evolution in this Nation's thinking about the best way to address
the problems of pollution.
Over the past several months, people from the Region 5 Office of Superfund with a shared
interest in preventing pollution have met to discuss pollution prevention options in
Superfund. The first issue that needed to be addressed was whether or not pollution
prevention even applied to the Superfund program. Although the Pollution Prevention Act
embodies a management hierarchy, EPA's strict definition of pollution prevention is source
reduction only. Certainly, one could argue that since Superfund deals with waste that has
already been generated, there is no opportunity for the pollution to be "prevented or
reduced at the source." If, however, one thinks of the Superfund program itself as a
generator of hazardous waste, opportunities do present themselves. Actions can be taken
during the course of the investigation and cleanup, be it Superfund or RCRA corrective
action, that result in the generation of less waste. Fifty-five gallon drums could be cleaned
and reconditioned, instead of going to a landfill. Solvents could be recycled instead of being
incinerated. Treatment trains could be employed to reduce the volume of waste requiring
final deposition. Whether it's called "pollution prevention" or "waste minimization" the goal
of this workgroup is to promote and encourage a mind set that results in less waste being
generated during the investigation and cleanup process.
Guidelines are being developed to help project managers identify, assess and implement
opportunities for limiting waste during the remedial process of the Superfund program. It
may not be apparent at first where opportunities exist outside of selecting remedies that use
resource recovery technologies, but waste reduction approaches can be applied to all waste
generating activities. Although these guidelines are geared towards Superfund, similar
situations exist during RCRA corrective action.
I propose to discuss these guidelines and present an example of P2 in RD/RA at the
Arrowhead Refinery site: Utilizing a BIF unit (a wet process cement rotary kiln) in place
of on site incineration for the thermal destruction of waste oil sludge.
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Environmental Equity? Reverse Environmental Equity?
Prewitt Abandoned Refinery
Prewitt, New Mexico
Monica Chapa Smith
Region 6
The Prewitt Refinery is an abandoned crude oil refinery on approximately 70 acres located
near the town of Prewitt in McKinley County, New Mexico. The Site is located
approximately 20 miles northwest of Grants, New Mexico. The Site is bounded on the
south by Interstate Highway 40, and on the north by the Atcheson, Topeka and Santa Fe
Railroad. Old U.S. Highway 66 divides the Site into two tracts. In the northern part of the
Site, north of the railroad track, lies an area which received waste. This area is known as
the North Pit. Much of the Site property on which the Site is located in currently owned
by the Navajo Nation. The area in which the Site is located is rural, with a cluster of six
homes about one thousand feet northeast of the Site and two homes occupied by Navajo
families located east-southeast of the site. The six northeast homes are occupied or owned;
yet abandoned by anglo families. Due to ground water flowing in a northeast direction,
EPA ordered the PRPs to install carbon treatment units on five of these homes. The
treatment units have been monitored for the past three years. There have not been any
detection of contamination in these wells.
In the July 1992 proposed plan of action, EPA's preferred remedy required that 1) the
ground water which is contaminated with lead, benzene, toluene, xylene, and ethylbenzene
be treated through a pump and treat alternative; 2) the Non-Aqueous Phase Liquids be
treated through soil-vapor extraction; 3) the West Pits area which contains sludges and the
hydrocarbon contaminated soils be landfarmed; 4) the separator and its contents be
removed and treated and disposed off-site; 5) the lead contaminated soils and the asbestos
containing materials be excavated, treated as necessary and disposed off-site. The selected
remedy contained in the Record of Decision signed on September 30, 1992 was the same
as had been proposed.
In September 1992, the Navajo Nation and the Responsible Parties signed a land exchange
agreement which conveys all property on which the site exists and which EPA deems as
needing to be remediated to the Responsible Parties. As a result of this land exchange, the
issue arose regarding the level and extent of cleanup since the Navajo Nation was no longer
impacted. The only risk posed to the Navajo Nation would have suffered was that of direct
contact to contaminated soils and sludges if the land were used for residential purposes in
the future. Regardless of ownership of the property, the anglo families continued to be
impacted via the contaminated ground water. Thus, a decision based on ownership, that
there was no longer a need to remediate the ground water would have resulted in a reverse
environmental equity situation.
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Superfund's Role In Regulating Oil And Gas E&P Waste
Jamie VanBuskirk
Region 6
Much confusion exists both within the Agency and the regulated community regarding the
scope of CERCLA's authority in dealing with the so-called "Special Study Wastes" (or Bevill
wastes). Much of the confusion arises from a lack of knowledge regarding the relationship
between RCRA and CERCLA and misinterpretations of exclusionary provisions they
contain. More specifically, both statutes contain exclusions for petroleum and petroleum
products and RCRA excludes oil and gas exploration and production (E&P) wastes from
regulation under Subtitle C (these wastes are, however, regulated by the states under
Subtitle D). CERCLA also contains language that has been interpreted as totally excluding
E&P waste from remedial and liability authorities. In addition, several recent and ongoing
legal battles over the scope and interpretation of these exclusions has led to an inconsistent
approach to remedial and enforcement response by the Agency for Superfund sites
containing these wastes.
This paper will discuss the Bevill Amendment exclusions contained in CERCLA and the
common misunderstanding surrounding their scope. Specific examples will be discussed
concerning three Superfund sites where Region 6 is aggressively pursuing enforcement
actions (PAB Oil, Gulf Coast Vacuum, and D.L. Mud) that dealt almost exclusively with
oil and gas E&P wastes. In addition, an update on the latest legal interpretation of the
scope of the exclusion will be discussed.
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Lightning RODs
(a.k.a. Region 6 SACM Experiences)
David Weeks, Bert Griswold & Paul Sieminski
Region 6
In November, 1991, Region 6 Environmental Protection Agency initiated three pilot projects
to demonstrate ways to improve the quality and speed of remediating Superfund sites.
Dubbed "Lightning RODs", the objectives of these pilots was to shorten the time spent in
pre-construction study and design by three to four years and improve remedial decision
making. These pilot projects were conceived before the Superfund Accelerated Clean-up
Model (SACM) was established by EPA as a new approach to managing site activities.
While some of the SACM these, such as integration of work efforts, were utilized in these
pilots, the Lightning RODs also had unique features, such as performing the Remedial
Design (RD) concurrently with the Remedial Investigation and Feasibility Study (RI/FS).
The process changes which EPA Region 6 planned to pilot at each of the three sites
included:
1. Complete detailed planning and budgeting for the RI/FS/RD before the sites
are proposed to the National Priorities List;
2. Consciously recognize both previous experience and pre-remedial/removal
data and use this information to focus the field studies and develop realistic
remedial alternatives;
3. Perform the RI/FS and RD concurrently if previous experience shows that a
limited universe of potential alternatives is available and that each of the
alternatives in this universe shares a commonality of several design elements;
4. Standardize design elements by preparing "off-the-shelf specifications for
common activities and technologies such as site preparation, excavation,
stabilization/solidification and incineration;
5. Demand higher quality and accountability from the ARCS contractors by
requiring complete RI/FS work plans to be submitted within 30 days of the
contractor's receipt of the work assignment, reformatting the RI/FS work plan
to minimize duplication of effort and excess verbiage, and rely upon Standard
Operating Procedures to describe sampling activities.
6. Use innovative techniques during the remedial investigation which facilitate
rapid collection of data and a greater understanding of site characteristics
than is typical with a boring program.
7. Use of innovative evaluation techniques such as a sensitivity analysis to
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evaluate how uncertainties may affect the remedy selection process.
All of these process changes were implemented except for the standardization of design
elements. Additional unexpected improvements in the Superfund process were also
realized. These additional improvements include: (1) development of innovative
enforcement techniques which resulted in time savings in the fund/enforcement transition
process, (2) implementation of the Quick Turnaround Method (QTM) Contract Laboratory
Program (CLP), (3) community involvement in the early planning of investigation and
remedy selection activities.
This paper describes how these process changes were implemented by EPA Region 6 and
provides several general conclusions concerning how the changes improved the quality and
speed of the remedy selection process. In addition, the paper includes a general discussion
of how much it cost EPA Region 6 to implement the process changes.
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Five-Year Review And Close-Out
Of Pre-SARA Sites
Jennifer Wendel
Region 5
The 3M Oakdale Dump site, and the Nutting Truck and Caster site are both Pre-SARA
Consent Order, NPL, sites in Minnesota. Both sites were scheduled for close-out (LTRA)
during the fourth quarter of 1992, and five-year review completion set for second quarter,
1993. Because they are pre-SARA sites, the five-year review at both sites will be a "Policy
Review" as described in OSWER Directive 9320.2-3B ("Update to the Procedure for
Completion and Deletion of National Priority List Sites-Guidance Document Regarding the
Performance of Five-Year Reviews").
Both sites have State "Response Orders on Consent" in place, and have been to this date,
State enforcement lead sites. Following review of the site file, and correspondence from
the State to 3M, EPA Region 5, in coordination with Headquarters, determined that the
ground water pump-out system in place at the Oakdale site required significant
modification. The scheduled Close-Out was postponed, pending the results of an expanded
five-year review, to determine if the remedy remained protective, and the need for
additional construction or modification. This site is unique, in that the five-year review may
not conclude that the remedy is protective, and introduce the need for additional work.
Sampling for possible additional source removal and treatment technologies has been
proposed by 3M, and is being reviewed by the State and EPA. This site is a very good
example of the intent of the five-year review process.
Because State Consent Orders are in place at both sites, I have coordinated the five-year
review effort for both sites with the State, and have helped to familiarize the project
managers with the five-year review process. I have conducted site visits, as required by
OSWER Directive 9355.7-02 ("Structure and Components of Five-Year Reviews"), and have
met with the Responsible Parties for both sites, informing them of the process and
requirements of a five-year review. A letter was sent to each of the RPs explaining the five-
year review process, prior to conducting the site visits. Both RPs were cooperative, and 3M
provided a presentation encompassing all phases of work previously conducted at the
Oakdale site, prior to the site visit. I have also started a five-year review work group in
Region 5's Ohio/Minnesota branch, to address specific issues that have arisen as a result of
conducting five-year reviews at sites in Ohio and Minnesota.
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Cone Penetrometer Application at the Organic Chemical Site
To Characterize Oil Contamination
Tom Williams
Region 5
The Organic Chemical Inc. (OCI) site has been previously used for petroleum refining from
1941 to 1945, and transport and storage operations from 1945 to 1966. Between 1968 and
1980, OCI discharged its process waste and cooling water into the onsite seepage lagoon
which included F001-F005 hazardous wastes. In June, 1980 OCI ceased discharge of
wastewater to the seepage lagoon. The past operation of the seepage pit, along with past
oil-related activities had resulted in significant contamination at the site. These
contaminants include high levels of chlorinated solvents, benzene, ethylbenzene, toluene,
xylene, and oils. Lower concentrations of other volatile and semi-volatile organic
compounds were also detected.
Due to the high levels of oil observed at various depths in the shallow aquifer, it was
decided to use an innovative technology developed by the U.S. Army Corps of Engineers,
Waterways Experiment Station. The technology includes a cone penetrometer for
hydraulically pushing a small diameter probe into the earth, equipped with a laser and fiber
optic device, and sensor for soil classification. As a result of this investigation, a graphic
color coded three-dimensional plume was developed, clearly showing the extensive oil
contamination at the site. The use of this technology has significantly reduced the cost and
time of locating monitoring wells to monitor the oil contamination at the site and has
dramatically impacted the major oil company associated with the site.
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Innovative RI/FS Approach To A Complex PCB Site
Craig Zeller
Region 4
The Sangamo Weston, Inc./Twelve Mile Creek/Lake Hartwell PCB Superfund Site
(Sangamo) is located on the upper reaches of Lake Hartwell near Pickens, in Pickens
County, South Carolina. Sangamo Weston, Inc. owned and operated a capacitor
manufacturing plant near the headwaters of Lake Hartwell from 1955 to 1987. These
capacitors utilized several kinds of dielectric fluids which contained PCBs. Waste disposal
practices from Sangamo's manufacturing processes included land burial of off-specification
capacitors and waste water treatment sludges and discharge of wastewater effluent into
Town Creek.
Town Creek is one of approximately eighty tributaries that flow into Twelve Mile Creek.
Twelve Mile Creek, a major tributary to Lake Hartwell, flows over a distance of
approximately 24 miles before reaching the Hartwell Reservoir. Lake Hartwell is a man-
made reservoir that was constructed by the U.S. Army Corps of Engineers between 1955
and 1963. The lake covers nearly 56,000 acres and has a shoreline of 962 miles. Portions
of Twelve Mile Creek's original streambed which indicated the presence of PCB
contamination is now inundated by Lake Hartwell.
The RI/FS of Operable Unit Two focused on the downstream impact past waste disposal
activities have had on the sediments and aquatic biology of this extensive watershed. The
atypical nature of this Superfund Site coupled with its extensive size required the
development of an innovative investigation approach. The objective of this Abstract is to
delineate these innovative procedures which resulted in significant time and cost savings
while ensuring a comprehensive Fund-Lead RI/FS.
A field screening technique, the Modified Spittler Method, was employed for the analysis
of sediment core and grab samples. The Modified Spittler Method provides a field
screening technique for detecting PCBs at concentrations greater than 1 ppm in soil and
sediment samples. While this procedure results in data of DQO Level III quality (vs. DQO
Level IV data from the CLP analysis procedure), it is very rapid and cost-effective. Using
commonly available laboratory equipment, one analyst can easily extract and analyze 20
samples per day (vs. a 30-day turnaround time for CLP). The cost of analysis using this
screening method is between $50 and $100, compared to $300 for the equivalent CLP
analysis. The implementation of the Modified Spittler Method allowed for the collection
and analysis of over 1,000 sediment core and grab samples over two phases of the RI/FS.
Traditional surveying methods were not appropriate to determine sediment core and grab
sample stations with the desired degree of accuracy. Therefore, sample locations were
established by using a Global Positioning System (GPS). The GPS is a satellite navigation
network consisting of an 18-satellite array. By utilizing two hand-held Magellan GPS units,
sample positions were established by latitude and longitude coordinates with an accuracy
of +1-5 meters.
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The implementation of these two innovative field techniques allowed for contaminated
sediment mapping in the upper reaches of Lake Hartwell using Geostatistical Analysis. This
valuable technical support and analysis was provided by EPA's EMSL in Las Vegas and
enabled Region 4 to fully determine the nature and extent of PCB- contaminated sediment
in Lake Hartwell.
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POSTER/DEMONSTRATION SESSIONS
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U.S. Bureau of Reclamation
Bob Peterson
Chief, Hazardous Waste Technical Assistance Office
U.S. Bureau of Reclamation
Mail Code D-3800
P.O. Box 25007
Denver Federal Center
Denver, Colorado 80225-0007
(303) 236-8646
(303) 236-0017 FAX
Bureau of Reclamation Hazardous Waste Site Activities
The display's purpose is to acquaint the Remedial Project Managers
(RPMs) with the U.S. Bureau of Reclamation (Reclamation) and the
capabilities Reclamation has in regards to hazardous waste cleanup.
Reclamation was established in 1902 to develop water resources in
the western United States. It is an agency within the Department
of Interior and has a staff of approximately 7500. Some of
Reclamation's larger projects have been Hoover Dam, Glen Canyon
Dam, and Grand Coulee Dam.
In the fall of 1987, Reclamation and the Environmental Protection
Agency (EPA) signed a Memorandum of Understanding (MOU) for
Reclamation to assist the EPA in implementing the Superfund
program. The MOU allows Reclamation to support the EPA anywhere
within the United States. Since the signing of the MOU,
Reclamation has assisted the EPA and other Government agencies on
a number of hazardous waste sites.
From its work in water resources and now in hazardous waste
cleanup, Reclamation has considerable experience in Total Project
Management which includes the areas of: project planning,
engineering designs, research, construction management and
oversight, and project operation and maintenance. Reclamation can
be used as a flexible source of assistance in technical and
management aspects of: Preliminary Assessments/Site
Investigations, Remedial Investigations/Feasibility Studies,
Remedial Designs, and Remedial Actions. Support can be provided in
areas such as: environmental engineering, chemistry, groundwater,
water treatment, geology, geotechnical engineering, subsurface
investigations including drilling and well programs, biology,
hydrology, industrial hygiene, water distribution systems, land
acquisition, and hazardous waste regulations.
Several video tapes of Reclamation site remediation assistance
activities will be featured.
Exhibitor:
Point:
of Contact
-------
Exhibitor: Robert S. Kerr Environmental Research Laboratory
Point:
of
Contact
David S. Burden
U.S. EPA
Robert S. Kerr Environmental Research Lab
P.O. Box 1198
Ada, Oklahoma 74820
(405) 436-8606
(405) 436-8614 FAX
Scientific and Regulatory Application of Ground-Water
& Vadose Zone Mathematical Models
Mathematical models are valuable tools in understanding the effect
of physical and chemical processes on the ultimate fate of
contaminants in the subsurface. Several models (computer codes)
are currently available that describe scenarios under which
different processes are significant. A scenario was designed based
on know field situations to illustrate the use of computer models
in hazardous waste management as well as to illustrate how model
scenarios can be utilized to assist environmental managers in
decision making. This demonstration will present the application
of two such models, RITZ and BIOPLUME II, to hazardous waste
management. The RITZ model simulates the land treatment application
of oily pollutants. BIOPLUME II is useful in the design and
operation of bioremediation schemes for hydrocarbon contaminated
aquifers. The advantages and the limitations of the model
applications will also be discussed. Using mathematical models
hazardous materials managers can improve storage and handling
practices to minimize the economic losses due to a release and can
improve emergency response actions in the event of a release.
In addition to the models RITZ and BIOPLUME II, the ground-water
flow model, MODFLOW will be demonstrated. MODFLOW is a modular,
block-centered finite difference model for the simulation of two-
dimensional and quasi- or fully three-dimensional transient ground-
water flow in anisotripic, heterogenous, layered aquifer systems.
The model includes modules for flow towards wells, through
riverbeds, and into drains. Other modules handle
evapotranspiration and recharge. In a recent report published by
EPA's Office of Solid Waste and Emergency Response (OSWER), titled
Ground-Water Modeling Compendium. MODFLOW was identified as one of
four models generally well known and often used in EPA programs.
To assist the Agency in the instruction of the proper use of
ground-water modeling, several documented problems, complete with
problem statements and input data sets will be presented to provide
hands-on experience with the practical application of the ground-
water flow model MODFLOW.
-------
Exhibitor:
U.S. EPA Environmental Monitoring Systems Laboratory
Ken Brown
U.S.EPA, EMSL-LV
P.O. Box 93478
Las Vegas, NV 89193-3478
(702) 789-2270
Clare Gerlach
Lockheed, Environmental Programs
1050 E. Flamingo Road
Las Vegas, NV 89119
(702) 734-3321
(702) 796-1084 FAX
Reaching the Regions
This video (about 20 minutes long) is a collection of slides
showing various technologies available to Remedial Project Managers
through the EMSL-LV Technology Center. A descriptive text
describing the slides adds to the information provided by the
presentation. Slides represent sampling events at Superfund sites,
scientists "on location", and in the Laboratory. This provides
the viewer with an encapsulated panorama of the specialties of the
Las Vegas Facility.
The Technology Support Center at the EMSL-LV has been serving the
Regions since 1987 and has a remarkably successful and diverse
record. Technical support teams have provided Regional clients
with assistance ranging from soil-gas measurements of VOCs to
geostatistical data analysis, from experimental design to
immunochemistry. The Laboratory continues to research areas of
promising applied technologies which will form the technical
support toolbox of the future.
In addition to the video, EMSL-LV will provide attendees with
informational material that identifies and discusses in further
detail, the technologies available through this growing Technology
Support Center.
Point(s):
of
Contact
-------
Exhibitor:
Risk Reduction Engineering Laboratory (RREL)
EPA-Cincinnati
Terry Lyons
U.S. EPA
START Team Leader
Cincinnati, Ohio
(513) 569-7589
Kevin Savage
Center for GeoEnvironmental Science and Technology
University of Cincinnati
USEPA Center Hill Solid & Hazardous Waste Research
Facility
5995 Center Hill Road
Cincinnati, Ohio 45224
(513) 569-7865
(513) 569-7445 FAX
ICASE Data Visualization Software
Site characterization data plays an essential role in determining
the feasibility, design, and operation of remediation systems.
These data represent a series of point measurements taken from
monitoring wells, soil borings, and test pits of a highly
heterogeneous three-dimensional subsurface environment. The site
engineer is faced with the task of interpreting these point
measurements from a variety of perspectives. Site characterization
data should be displayed in a meaningful way so that it can be
properly interpreted and used correctly when making remedial action
decisions. The goal of this project is to develop a powerful, yet
easy to use, data visualization tool for site engineers and
managers.
The NARPM Conference display is data visualization software, called
ICASE (Integrated Computer Assisted Site Evaluation), that takes
measurements made at irregularly-spaced locations at a site, and
uses a stratified interpolation process to estimate values within
a uniform three-dimensional grid beneath the site. This procedure
is carried out for any parameters of interest, which can include
both soil properties and chemical species. It is then possible to
display the geographical distribution of single parameters on a map
of the site. Formats for displaying the data include:
* shaded contour diagrams on a plan view of the site within any
depth layer
* 2-D cross-sectional views across the site, displayed as single
slices, fence diagrams, or and animated sequence of slices,
and
* 3-D shaded volume views within the subsurface ("block
diagrams"), with the ability to slice open the volume along
any plane to get a cross-sectional view.
Point(s):
of
Contact
-------
The first year of the project has focused on developing map display
and data visualization features. Base map display, data queries,
contouring, and 2-D cross-sectioning have all been completed. The
3-D visualization methods are currently being enhanced. The second
year will focus on completion of map display and visualization
feature, incorporation of a bioremediation knowledge base, and
testing of the completed system on a suite of site remediation case
studies.
-------
Exhibitor:
U.S. Army Corp of Engineers
Eric D. (Ric) Hines, P.E.
US Army Corp of Engineers
Hazardous, Toxic & Radioactive Waste
Mandatory Center of Expertise (CEMRD-ED-HP)
12565 West Center Road
Omaha, Nebraska 68144
(402) 221-7398
(402) 221-7561 FAX
Site Characterization and Analysis Penetrometer System (SCAPS)
As a result of a tri-service Research and Development effort, led
by the U.S. Army Toxic and Hazardous Materials Agency, a state-of-
the-art Site Characterization and Analysis Penetrometer System
(SCAPS) has been developed by the U.S. Army Engineer Wasteways
Experiment Station for use in mapping areas of soil and groundwater
contamination.
As the program name implies, SCAPS is organized around a cone
shaped penetrometer. The system is mounted in a uniquely
engineered 20-ton, all-wheel-drive truck designed with protected
work spaces to allow safe access to toxic and hazardous waste sites
while minimizing exposure of the work crew.
The SCAPS includes a suite of geophysical equipment, survey and
mapping equipment, special penetrometers with sensors for
contamination detection, and soil and groundwater samplers. The
basic acreening detector is a soil resistivity unit which can sense
contaminants that alter the resistivity of the soil. The SCAPS
incorporates numerous features that are not available in standard
cone penetrometer (CPT) equipment. All cone sensors output real-
time, and a computer-based data collection and analysis system
permits a display and immediate on-site interpretation of data.
Development of efforts are being aimed toward the production of
sensors capable of detecting solvents and hydrocarbon products (at
low levels), explosive wastes, and toxic and hazardous metal
wastes. The goal is to produce sensor systems that respond rapidly
and reversely to the presence of specific contaminants at low
levels in soil.
The SCAPS system has potential application in a variety of problem
areas including:
* Early warning of contaminant spreading, as from leaks in
storage tanks.
* Detecting variations in contaminant concentration level as a
result of seasonal changes in the groundwater regime.
* Verification of the efficacy of in-situ remediation work
* Installation of monitoring sensors or groundwater sampling
points.
Point:
of
Contact
-------
Exhibitor: EPA Technology Innovation Office (USEPA/OSWER)
Point(s):
of
Contact
John Quander, TIO
OS-llOW
USEPA/OSWER/TIO
401 M. Street S.W.
Washington, D.C. 20460
(703) 308-8845
(703) 308-8528 FAX
Richard Doughtery
PRC/EMI
1505 Planning Research Blvd.
McLean, VA 22102
(703) 883-8517
(703) 556-2852 FAX
VISITT Database
The Technology Innovation Office will display our new table-top
exhibit at the NARPM Conference. Included as part of this display
will be several current publication/technical information on the
development and use of innovative treatment technologies. These
will be fact sheets, project summaries, recent newsletters and
order forms on this subject.
As part of the Conference display, there will be a hands-on
demonstration of the Vendor Directory Computer Data Base (VISITT).
This data base developed by TIO has pertinent information on
specific technology vendors that project manager would find
helpful.
-------
Exhibitor: EPA Risk Reduction Engineering Laboratory (RREL)
Edison, NJ
Point(s):
of
Contact
Joyce M. Perdek
ATTIC Project Manager
U.S. EPA, RREL (MS-106)
2890 Woodbridge Avenue
Edison, NJ 08837-3679
(908) 321-4380
(908) 906-6990 FAX
ATTIC System Operator
Scientific Consulting Group, Inc.
Suite 210
4 Research Place
Rockville, MD 20850
(301) 670-6294
Alternative Treatment Technology Information Center Database (ATTIC)
The Alternative Treatment Technology Information Center (ATTIC) is
a comprehensive information retrieval system containing data on
alternative treatment technologies for hazardous waste. The ATTIC)
system is a collection of hazardous waste databases that are
accessed through a bulletin board. The bulletin board includes
features such as news items, bulletins, and special interest
conferences-such as the Bioremediation Special Interest Group. It
also features a message board that enables users to "chat" and
request advice from other users, as well as pose questions to the
ATTIC System Operator. ATTIC users can access any of four
databases: (1) the ATTIC Database, which contains over 2200 records
dealing with alternative and innovative technologies for hazardous
waste treatment; (2) the RREL Treatability Database, which provides
data on characteristics and treatablity of a wide variety of
contaminants in aqueous and solid media; (3) a Technical Assistance
Directory, which identifies EPA contacts experts on a given
technology or type of contaminant; and (4) a Calendar of upcoming
relevant conferences and events.
ATTIC is accessible free of charge to all members of the federal,
state and private sectors involved in site remediation. ATTIC can
be directly accessed by users with a personal computer and a modem.
In addition, users can request an ATTIC search by phoning the ATTIC
System Operator. The ATTIC phone numbers are:
ATTIC System Operator (Voice Line): (301) 670-6294
Online ATTIC Computer Access (2400 baud): (301) 670-3808
Online ATTIC Computer Access (9600 baud): (301) 670-3813
New users can register themselves and assign their own password the
first time they call into ATTIC. For best success, the user should
set up their communication software with the following parameters
prior to dialing:
-------
Baud Rate:
Data Bits:
Stop Bits:
2400/1200 (9600 if applicable)
8
1
Parity:
Duplex
None
Full
Management of the ATTIC System was transferred to EPA Risk
Reduction Engineering Laboratory (RREL) from ORD Headquarters in
November 1991. RREL's mission is to improve ATTIC'S content and
user friendliness. Efforts in 1992 were focused on obtaining and
analyzing user needs in order to achieve the goal of improving
ATTIC'S content and user friendliness. Responses to questionnaires
distributed to select ATTIC users to solicit this input were
received from EPA and State environmental personnel, remediation
contractors and the Hazardous Waste Action Coalition. Based on
analysis of the responses, plans for (1) redesigning the ATTIC
system to improve its user friendliness and (2) systematically
acquiring information to assure that ATTIC contains current
information on alternative treatment technologies were developed
for implementation in 1993.
Interim measures for improving the system were implemented during
1992. Improvements to bulletin board and ATTIC Database commands
were made for clarification purposes. All site program documents
and RREL Superfund Technical Support Program documents, such as the
Engineering Bulletins, are downloadable from the system. Copies of
complete reports are provided on request.
-------
Exhibitor: EPA Risk Reduction Engineering Laboratory(RREL)
Cincinnati, Ohio
Point:
of
Contact
Joan Mattox
Technical Support Branch
Superfund Technology Demonstration Division
EPA Risk Reduction Engineering Laboratory
Cincinnati, Ohio 45268
(513) 569-7624
(513) 569-7676 FAX
Screening Level laboratory & Technical Support Branch Activities
RREL in Cincinnati has developed a number of protocols to screen
technologies for remediation of contaminated sites. The unique
nature of these protocols is that they are independent of specific
site situations, can be used on a routine basis, have a quick
turnaround time and are funded by OSWER and ORD. The protocols are
Biotreatability, Alkaline Polyethylene Glycol (APEG), Soil Vapor
Extraction, Solidification/Stabilization, Solvent Extraction,
Thermal Desorption, Soil Washing, Soil Flushing, and Incineration.
These protocols are part of the "Remedy Screening Program" and
provide information as to the advisability of performing Remedy
selection level treatability tests for a particular technology.
A Screening Level Lab video (12-15 minutes) showing the aspects and
effectiveness of screening technologies for remediation through
this program.
A Technical Support Branch display will list the services available
to the RPM in site remediation assistance. Assistance activities
highlighted include:
a) Site Specific Activities:
START - Superfund Technical Assistance Response Team
for long term site specific assistance
ETSC - Engineering Technical Support Center
for short term site specific assistance
b) Technical Transfer:
Engineering Bulletins
Treatability Guides
Techincal Resource Documents
c) Treatability Assistance - Data Bases
RREL Data Base
Solidification/Stabilization Data Base
Computer Assisted Systems Evaluation (CASE)
-------
AGENDA
-------
AGENDA
NATIONAL ASSOCIATION OF REMEDIAL PROJECT MANAGERS
1993 NATIONAL MEETING
MONDAY, MARCH 15,1993
8:00 a.m. Depart Westin Hotel (very tight schedule, no extra time - if you
are late you will literally "miss the boat")
9:00 a.m. Seattle to Bremerton Ferry Leaves (precisely at 9:00 a.m.)
Ferry Ride lasts approximately one hour.
Speaker: Ken Moser (invited)
Puget Sound Keeper
10:30 a.m. Manchester Laboratory Tour
1:00 p.m. Lunch in Manchester
3:00 p.m. Depart via Ferry to Westin Hotel in Seattle (one hour ferry
ride)
4:30 p.m. Arrive Hotel
TUESDAY, MARCH 16,1993
7:30 a.m. Registration Foyer
Sign-in
Pick up Meeting/Abstract Packet
8:00 a.m. Introductions Fifth Avenue Room
Regional Updates
Overview of Meeting
NARPM Co-Chairs and Regional Representatives
1
-------
8:45 a.m.
Welcoming Remarks
Fifth Avenue Room
Randy Smith, Director
Hazardous Waste Division
EPA Region 10
Barbara McAllister, Deputy Director
Hazardous Waste Division
EPA Region 10
Ika Joiner
Superfund Revitalization Office
9:00 a.m. Keynote Address Fifth Avenue Room
Questions and Answers
Richard J. Guimond
Acting Assistant Administrator for Solid Waste and Emergency
Response
U.S. EPA
9:45 a.m. Break
10:00 a.m. Panel Discussion Fifth Avenue Room
RPM Professional Development in the 90's
Moderator: Laura Williams, RPM, Region 8
Panel Members: Fran Costanzi, RPM, Region 3
Steve Sandler, RPM, Region 4
Mary Ann Abrahamson, RPM, Region 6
Peter Ismert, RPM, Region 8
Tim Brincefield, RPM, Region 10
Linda Meyer, RPM, Region 10
Richard J. Guimond, Acting Assistant
Administrator, OSWER, HQ
Meg Kelly, Acting Director, TIO, HQ
Randy Smith, Director, Hazardous Waste
Division, Region 10
12:00 NOON Lunch
2
-------
1:30 p.m. Paper Presentations and Panel Discussions
Session 1 - Olympic Room - Environmental and Human
Health Risk Assessment
(Panel and 5 Papers)
1:30 p.m. Introduction
Moderator: Dr. Jon Rauscher,
Toxicologist, Region 6
1:40 p.m. Developing Cleanup Levels for PAHs in
Sediments, Robert J. Leger, RPM, Region
1
2:00 p.m. "No Action/No ARARs" or How to Pick a
Fight with the State, Nancy Harney, RPM,
Region 10
2:20 p.m. Ground Water Issues - Alternate
Concentration Limits: Assumptions,
Realities, and Uncertainties, Indira
Balkissoon, RPM, Region 1
2:40 p.m. The Role of Community Interests and
Medical Information in Risk Management,
Brian Pinkowski, RPM, Region 8
3:00 p.m. In-Home Air Sampling for Vinyl Chloride
in Residences Near a Landfill, RPM, Bret
Moxley, Region 9
3:20 p.m. Break
3:40 p.m. Panel Discussion
Panel Members:
Dr. David Charters, ERT
Mary Beth Novy, RPM, Region 5
Keith Rose, RPM, Region 10
Alyce Fritz, NOAA
Elaine Suriano, OWPE, HQ
Dr. Bruce Duncan, Ecologist, Region 10
3
-------
5:00 p.m. Adjourn
Session 2 - Adams Room - Settlement Issues (Panel
and 3 Papers)
1:30 p.m. Introduction
Moderator: Ruth Rzepski, RPM,
Region 3
1:40 p.m. Dealing with a Responsible Party
Suddenly Declaring Bankruptcy During
Site Operations at an NPL Site, James H.
Feeney, RPM, Region 3
2:00 p.m. New Cost Recovery Rule and Potential
Impacts, Cynthia Kaleri, RPM, and
Mary Ann Abrahamson, RPM, Region 6
2:20 p.m. Missouri Electric Works - Case Study,
Pauletta R. France-Isetts, RPM, Region 7
2:40 p.m. Break
3:00 p.m. Panel Discussion
Panel Members:
Jim Berkley, RPM, Region 8
Rachel Blumenfeld, Attorney, Region 6
Dion Novak, RPM, Region 5
Bill Haubold, RPM, Region 5
Leslie Jones, OWPE, HQ
5:00 p.m. Adjourn
Session 3 - Baker Room - Federal Facilities Panel
Discussion
1:30 p.m. Introduction
Moderator: Brian Swarthout, RPM,
Region 9
4
-------
1:40 p.m.
Panel Discussion
5:00 p.m.
3:00 p.m.
3:20 p.m.
5:00 p.m.
Adjourn
Panel Members:
Larry Diede, RPM, Region 8
Mary Logan, RPM, Region 2
Jennifer Wendel, RPM, Region 5
Tom Bloom, RPM, Region 5
Carl Froede, RPM, Region 4
Break
Panel Discussion Continued
Adjourn
WEDNESDAY, MARCH 17,1993
8:30 a.m. Paper Presentations and Panel Discussions
Session 1 - Olympic Room -
8:30 a.m.
8:40 a.m.
9:00 a.m.
9:20 a.m.
Ground WaterRI/FS (Panel
and 4 Papers)
Introduction
Moderator: Jeff Gore, RPM, Region 5
Free for the Taking: Springs as Ground
Water Sampling Locations at Superfund
Sites, Tony Able, RPM, and Ralph
Howard, RPM, Region 4
Ground Water Samples for Metals
Analysis: A Reasonable Approach to the
Filtration Controversy, Wm, Turpin
Ballard, RPM, Region 5
Case Study on Site Characterization at a
TCE Plume: St. Joseph, Michigan, NPL
Site, John Kuhns, RPM, Region 5, and
Peter Kitanidis, Stanford University
5
-------
9:40 a.m. GIS Made Painless: How RPMs Can
Access GIS Data at Multi-Source Ground
Water Sites, Kathy Setian, RPM, Region
9
10:00 a.m. Break
10:20 a.m. Panel Discussion
Panel Members:
Eva Hoffman, RPM, Region 8
Rene Fuentes, Ground Water Forum,
Region 10
Sharon Jaffess, RPM, Region 2
Keith Rose, RPM, Region 10
Steve Padovani, RPM, Region 5
Julie DalSoglio, RPM, Region 8
12:00 NOON Adjourn
Session 2 - Baker Room - RD/RA Presentation of 8
Papers
8:30 a.m. Introduction
Moderator: Armando Saenz, RPM,
Region 8
8:40 a.m. Will Soil Washing Work for the Sand
Creek Superfund Site?, Erna Acheson,
RPM, Region 8 and Patrick Augustin,
ORD-Edison
9:00 a.m. Soil Washing at the King of Prussia Site:
An International Approach, Gary
Adamkiesicz, RPM, Region 2
9:20 a.m. Incineration or Innovative Technology?
An Evaluation of Treatment Technologies,
New Bedford Harbor Hot Spot Sediments,
Gayle Garman, RPM, Region 1
6
-------
9:40 a.m. Future Considerations for the Application
of In-Situ Vitrification at Superfund Sites,
Linda M. Nachosicz, RPM, Region 5
10:00 a.m. Keeping a Remedial Action Moving
Around, Over, and Under Seemingly-
Insurmountable Obstacles, James J.
Hahnenberg, RPM, Region 5
10:20 a.m. Break
10:40 a.m. Brodhead Creek Superfund Site: A
Cooperative Effort Between EPA Region
3, EPA SITE Program, and the Potentially
Responsible Parties, John Banks, RPM,
Region 3
11:00 a.m. Remedial Action - Palmerton Zinc Site,
Blue Mountain Revegetation, Tony Roller,
RPM, Region 3
11:20 a.m. Remedial Action at the Helen Kramer
Landfill Superfund Site, Lawrence A.
Granite, RPM, Region 2
11:40 a.m. Adjourn
Session 3 - Adams Room - Remedy Selection (Panel
and 3 Papers)
8:30 a.m. Introduction
Moderator: Monica Chapa Smith, RPM,
Region 6
8:40 a.m. The Plug-In ROD: An Accelerated
Approach for Multi-Source Sites, Jeff
Dhont, RPM, Region 9
9:00 a.m. Contingencies and Deferred Decisions at
Large Ground Water Contamination Sites
Involving Local Water Supply Agencies,
Kevin Mayer, RPM, and Colette Kostelec,
RPM, Region 9
7
-------
9:20 a.m.
Institutional Controls, Bunker Hill,
Kellogg, Idaho, Nick Ceto, RPM, Region
10
9:40 a.m. Break
10:00 a.m. Panel Discussion
Panel Members:
Rachel Blumenfeld, Attorney, Region 6
Shahid Mahmud, HSCD, HQ
Jeff Gore, RPM, Region 5
12:00 NOON Adjourn
12:00 NOON Lunch
1:30 p.m. Paper Presentations and Panel Discussions
Session 1 - Olympic Room - Ground Water RD/RA
(Panel and 7 Papers)
1:30 p.m. Introduction
Moderator: . Howard . Orlean, RPM,
Region 10
1:40 p.m. Case Study: Enhancement of Soil
Vacuum Extraction Via Ground Water
Sparging at the Verona Well Field
Superfund Site, Margaret Guerriero,
RPM, Region 5
2:00 p.m. Innovative Technology for Remediation of
Organics in Ground Water, Beth Reiner,
RPM, Region 5
2:20 p.m. Using Biodegradation to Enhance a
Ground Water Pump and Treatment
System, Jeff Gore, RPM, Region 5
8
-------
2:40 p.m. Moving an Interim Pump and Treat
Remedial Action to Final at the Kennedy
Space Center, Florida, Carl R. Froede, Jr.,
RPM, Region 4
3:00 p.m. Break
3:20 p.m. Determination of the Technical
Impracticability of Ground Water
Remediation, Peter Feldman, OERR
Hazardous Site Control Division
3:40p.m. The Distribution of Treated Water from a
Long-Term Ground Water Pump-and-
Treat System: A Cooperative Effort, Tom
Barounis, RPM, Region 5
4:00 p.m. Mega-Site Remediation in the Arid West:
What To Do With 30,000 gpm of
Extracted Ground Water?, Wayne
Praskins, RPM, Region 9
4:20 p.m. Panel Discussion
Panel Members:
Rene Fuentes, Ground Water Forum,
Region 10
John Banks, RPM, Region 3
Mike Montgomery, RPM, Region 9
5:00 p.m. Adjourn
Session 2 - Baker Room - Community Relations
(Panel and 6 Papers)
1:30 p.m. Introduction
Moderator: Laura Williams, RPM,
Region 8
9
-------
1:40 p.m. Communicating with a Community Where
1600 Residences are Part of the
Superfund Site, Brad Bradley, RPM,
Region 5
2:00p.m. Access Issues at the Ewan Property Site -
A Road to Nowhere?, David Rosoff,
RPM, Region 2
2:20 p.m. Access, Easements, and Angry Neighbors -
What Ever Happened to Site Cleanup?,
Fred Schauffler, RPM, Region 9
2:40 p.m. Successful Administration of a Technical
Assistance Grant at the Maxey Flats
Nuclear Disposal Site, Kentucky, Dave
Kluesner, RPM, Region 4
3:00 p.m. Break
3:20 p.m. A Successful Non-EPA Technical
Advisory Committee for a Large Ground
Water Contamination Site in San
Bernardino, California, Kevin Mayer,
RPM, Region 9
3:40 p.m. Environmental Equity? Reverse
Environmental Equity?, Prewitt Refinery,
New Mexico, Monica Chapa Smith, RPM,
Region 6
4:00 p.m. Panel Discussion
Panel Members:
Marc Herman, RPM, Region 8
Ken Lucas, RPM, Region 4
Bob Lance, RPM, Region 5
Diana Hammer, OSWER, HQ
Tony Koller, RPM, Region 3
Shawn Luetchens, RPM, Region 4
5:00 p.m. Adjourn
10
-------
Session 3 - Adams Room -
SACM (Panel and 6
Papers)
1:30 p.m. Introduction
Moderator: Jim Feeney, RPM, Region 3
1:40 p.m. Remedial/Removal Program Integration in
Development of Early Action at the Big
River Mining Site near Desloge, Missouri,
Mark A Bogina, RPM, and Robert Koke,
RPM, Region 7
2:00 p.m. SACM: A Unique Perspective from an
Ex-OSC Turned RPM, Kelly S. McCarty,
RPM, Region 9
2:20 p.m. Solvents Recovery Service, Michael
Nalipinski, RPM, Region 1
2:40p.m. Lightening RODs (a.k.a.,Region 6SACM
Experiences), David Weeks, RPM, Bert
Griswold, RPM, and Paul Sieminski,
RPM, Region 6
3:00 p.m. PCB -Remediation at Natural Gas
Pipelines, Shelley Brodie, RPM, Region 7
3:20 p.m. Expanding the Objectives of Emergency
Response Activities, Donna Santiago,
Region 3
3:40 p.m. Break
4:00 p.m. Panel Discussion
Panel Members:
Eva Hoffman, RPM, Region 8
Rachel Blumenfeld, Attorney, Region 6
Ika Joiner, SRO, HQ
Jeff Dhont, RPM, Region 9
5:00 p.m. Adjourn
11
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5:00 p.m. Adjourn
THURSDAY, MARCH 18,1993
8:30 a.m. Paper Presentations and Panel Discussions
Session 1 - Olympic Room - RCRA/CERCLAIntegration
and Managing Active
Facilities (Panel and 3
Papers)
Introduction
Moderator: Sharon Jaffess, RPM,
Region 2
Pollution Prevention in Superfund, Edwin
R. Smith, RPM, Region 5
Superfund's Role in Regulating Oil and
Gas E&P Waste, Jamie VanBuskirk,
RPM, Region 6
Chromium Electroplaters = F001, F006,
F007, and F008, Jon Peterson, RPM,
Region 5
Break
Panel Discussion
Panel Members:
Mary Pat Tyson, SRO, HQ
Kathleen Lohry, RPM, Region 6
Dion Novak, RPM, Region 5
Howard Orlean, RPM, Region 10
12:00 NOON Adjourn
8:30 a.m.
8:40 a.m.
9:00 a.m.
9:20 a.m.
9:40 a.m.
10:00 a.m.
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Session 2a- Baker Room -
8:30 a.m.
Presenters:
9:00 a.m. Adjourn
Session 2b- Baker Room -
9:00 a.m.
Moderator:
9:10 a.m.
10:00 a.m.
10:15 a.m.
11:00 a.m. Adjourn
Session 2c- Baker Room -
11:00 a.m.
Presenter:
11:30 a.m. Adjourn
What is SRO and What is
the "Compendium of Good
Ideas"?
Mary Pat Tyson, SRO, HQ
Sven Kaiser, SRO, HQ
NARPM Newsletter Panel
Cathy Gilmore, RPM,
Region 6
Blowing Up YourSuperfund
Site - The ASARCO Stack
Demolition Video
Kevin Rochlin, RPM,
Region 10
Introduction
Introduction
Panel Discussion
Panel Members:
Monica Chapa Smith, RPM, Region 6
Fred Schauffler, RPM, Region 9
Break
Panel Discussion Continued
Introduction and Video
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Session 2d- Baker Room - Remedial Pipeline Project
Management Module
(RP2M)
11:30 a.m. Demonstration
Presenters: Mike Negrelli, RPM,
Region 2, and Donna
Vizian, IMC, Region 2
12:00 NOON Adjourn
Session 3 - Adams Room - RI/FS (Panel and 6 Papers)
8:30 a.m. Introduction
Moderator: Steve Kinser, RPM, Region
7
8:40 a.m. Innovative RI/FS Approach to a Complex
PCB Site, Craig Zeller, RPM, Region 4
9:00 a.m. Cone Penetrometer Application at the
Organic Chemical Site to Characterize Oil
Contamination, Tom Williams, RPM,
Region 5
9:20 a.m. Data Completeness versus Data
Sufficiency: Use of the Observational
Approach in the Design of a Soil
Sampling Plan, Richard Hammond, RPM,
Region 4
9:40 a.m. The Use of Aerial Photography to
Streamline Delineation of Area of
Contamination: Case Studies and
Procedures, Kathleen Lohry, RPM,
Region 6
10:00 a.m. Break
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10:20 a.m. Vinyl Chloride in Landfill Soil Gas Shown
to Migrate Beyond the End of the
Methane Plume, Bret Moxley, RPM,
Region 9
10:40 a.m. Quality Assurance Project Plans, Arturo
Palomares, RPM, Region 8
11:00 a.m. Panel Discussion
Panel Members:
12:00 NOON
12:00 NOON Lunch
Shahid Mahmud, HSCD, HQ
Rhonda McBride, RPM, Region 5
Adjourn
1:30 p.m. Paper Presentations and Panel Discussions
Session 1 - Olympic Room - Contract Management
Panel Discussion
1:30 p. m. Introduction
Moderator: Mary Jane Near man, RPM,
Region 10
1:40 p.m. Panel Discussion
Panel Members:
Jim Berkley, RPM, Region 8
Ika Joiner, SRO, HQ
Michelle McNeill, RPM, Region 10
Mike Gifford, RPM, Region 5
Kelly McCarty, RPM, Region 9
Steve Calder, RPM, Region 1
Pat Evangelista, RPM, Region 2
3:30 p.m. Break
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Session 2 - Baker Room -
1:30 p. m. Introduction
Moderator:
1:40 p.m.
2:00 p.m..
2:20 p.m.
2:40 p.m.
3:30 p.m. Break
Session 3 - Adams Room -
1:30p.m. Introduction
Moderator:
1:40 p.m.
Site Completion (Panel and
3 Papers)
Jamie Van Buskirk, RPM,
Region 6
RD/RA Panel Discussion
Bill Haubold, RPM, Region
5
Panel Discussion
Five Year Review Reports at Superfund
Sites, Thomas Bloom, RPM, Region 5
Five Year Review and Close-Out of Pre-
SARA Sites, Jennifer Wendel, RPM,
Region 5
Remedial Action Construction
Completion at the Defense Distribution
Depot, Ogden, Utah, Sandra A.
Bourgeois, RPM, Region 8 and
Muhammad A. Slam, Utah Department of
Environmental Quality
Panel Discussion
Panel Members:
Donna Vizian, IMC, Region 2
Jim DiLorenzo, RPM, Region 1
Randall Chaffins, OERR, HQ
Sven Kaiser, SRO, HQ
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Panel Members:
Mary Tierney, RPM, Region 5
Kathleen Warren, RPM, Region 5
Miguel Cintron, Omaha District,
USACOE
Rick Hines, Center of Expertise,
USACOE
Michelle Lau, RPM, Region 9
Rocco Grassi, RPM, Region 2
Larry Granite, RPM, Region 2
Fran Costanzi, RPM, Region 3
Armando Saenz, RPM, Region 8
3:30 p.m.
Break
3:30 p.m. Break (All Sessions)
3:45 p.m. Panel Summaries
Fifth Avenue Room
4:45 p.m. Wrap-Up
Fifth Avenue Room
5:00 p.m. Adjourn
DATE DUE
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