PILOT PROJECT TO OPTIMIZE GROUND WATER REMEDIATION
SYSTEMS AT RCRA CORRECTIVE ACTION FACILITIES:
SUMMARY REPORT AND LESSONS LEARNED
REPORT
SUBMITTED:
DECEMBER 22,2005
-------
This page is intentionally left blank.
-------
Office of Solid Waste EPA 542-R-06-001
and Emergency Response January 2006
(5102G) www.epa.gov/tio
clu-in.org/optimization
Pilot Project to Optimize Ground Water Remediation
Systems at RCRA Corrective Action Facilities:
Summary Report and Lessons Learned
-------
This page is intentionally left blank.
-------
NOTICE
This document is not a U.S. EPA policy, guidance or regulation. It does not create or impose
any legally binding requirements or establish U.S. EPA policy or guidance. The information is
not intended, nor can it be relied upon, to create any rights enforceable by any party in litigation
with the United States or any other party. The information provided may be revised periodically
without public notice. Use or mention of trade names does not constitute endorsement or
recommendation for use. Standards of Ethical Conduct do not permit EPA to endorse any
private sector product or service.
The U.S. Environmental Protection Agency funded the preparation of this document by
GeoTrans, Inc. under EPA Contract No. 68-C-00-181 Task Order #40 to Tetra Tech EM, Inc,
Chicago, Illinois.
For further information about this report, please contact the EPA's Office of Solid Waste, Mike
Fitzpatrick, (703) 308-8411, fitzpatrick.mike@epa.gov or the EPA's Office of Superfund
Remediation and Technology Innovation, Ellen Rubin, (703) 603-0141, mbin.ellm(a)Lep_a.gov.
-------
PREFACE
This report was prepared as part of a pilot project conducted by the United States Environmental
Protection Agency (U.S. EPA) Office of Superfund Remediation and Technology Innovation
(OSRTI) and the Office of Solid Waste (OSW). The objective of this project is to conduct
Streamlined Remediation System Evaluations (RSE-Lites) of pump and treat systems under the
Resource Conservation and Recovery Act Corrective Action Program. The following
organizations are implementing this project:
Organization
Key Contact
Contact Information
U.S. EPA Office of Solid Waste
(U.S. OSW)
Mike Fitzpatrick
5303W
USEPA Headquarters
1200 Pennsylvania Avenue, N. W.
Washington, DC 20460
Phone:703-308-8411
fitzpatrick.mike@epamail.epa.gov
U.S. EPA Office of Superfund
Remediation and Technology
Innovation
(U.S. EPA OSRTI)
Ellen Rubin
5102G
USEPA Headquarters
1200 Pennsylvania Avenue, N. W.
Washington, DC 20460
Phone: 703-603-0141
rubin.ellen@epa.gov
Tetra Tech EM, Inc.
(Contractor to U.S. EPA)
Stanley Lynn
Tetra Tech EM Inc.
250 W. Court Street, Suite 200W
Cincinnati, OH 45202
Phone:513-564-8349
Fax:513-241-0354
Stanlev.Lvnn@ttemi.com
GeoTrans, Inc.
(Contractor to Tetra Tech EMI)
Doug Sutton
GeoTrans, Inc.
2 Paragon Way
Freehold, NI 07728
Phone: 732-409-0344
Fax: 732-409-3020
dsutton@geotransinc.com
-------
ACKNOWLEDGEMENTS
The project team is grateful for the cooperation and participation of all site stakeholders,
including EPA and/or State Project Managers, facility representatives, and site contractors. They
were vital in transferring site documents to the RSE team, scheduling the conference calls and
site visit, providing information during conference calls and site visit, and reviewing the RSE-
Lite/RSE reports. The authors also extend sincere thanks to the principal investigators from the
U.S. EPA Office of Superfund Remediation and Technology Innovation (OSRTI) and the U.S.
EPA Office of Solid Waste (OSW).
in
-------
This page is intentionally left blank.
IV
-------
EXECUTIVE SUMMARY
Following the success with conducting independent optimization evaluations at Superfund-
fmanced pump and treat (P&T) sites, the U.S. EPA Office of Solid Waste (OSW) and the U.S.
EPA Office of Superfund Remediation and Technology Innovation (OSRTI) sponsored
independent optimization evaluations in 2003 and 2004 at five facilities with pump and treat
(P&T) systems regulated under the Resource Conservation and Recovery Act (RCRA). The
Remediation System Evaluation (RSE) process developed by the U.S. Army Corps of Engineers
was used. For each of the five RCRA sites, the RSE process involved an independent team of
experts reviewing site documents, interviewing site stakeholders, and providing
recommendations for improving remedy effectiveness, reducing costs, and gaining site closure.
Based on the positive results of these RSEs and the consideration that many sites would receive a
similar benefit from a streamlined RSE with a lower cost, OSRTI and OSW commissioned a new
pilot study to develop and pilot a streamlined RSE process (or "RSE-lite") that reduces the
evaluation cost relative to a full-scale RSE.
Both the RSE-lite and RSE processes involve a team of expert hydrogeologists and engineers,
independent of the site, conducting a third-party evaluation of a remedy. It is a broad evaluation
that considers the goals of the remedy, site conceptual model, above-ground and subsurface
performance, and site exit strategy. The evaluation includes reviewing site documents,
communicating with the site team, and compiling a report that includes recommendations to
improve the efficiency and effectiveness of the remedy. A full-scale RSE includes a site visit
and in-person interviews between the evaluation team and site team. An RSE-lite uses a
conference call in place of the site visit and in-person interviews. Recommendations are
provided in the following four categories:
• Improvements in remedy effectiveness
• Reductions in operation and maintenance costs
• Technical improvements
Gaining site closeout
Four sites were selected by the EPA OSRTI and OSW to receive RSE-lites based on nominations
provided by EPA project managers. Upon completion of the draft RSE-lite reports, one of the
four sites was selected to receive a site visit and additional analysis to convert the RSE-lite into a
full-scale RSE.
All four of the evaluated sites are impacted with volatile organic compounds. Three of the sites
have unconsolidated geology and one has fractured bedrock. Light non-aqueous phase liquid
(LNAPL) is present at one site and dense non-aqueous phase liquid (DNAPL) is present at one
of the other sites. The annual costs for operating the systems ranged from $50,250 to $945,000
per year.
Recommendations for improving system effectiveness and for reducing costs were provided at
all four sites. Recommendations for technical improvement were provided at two of the four
sites. Recommendations for gaining site closeout were provided at all four sites.
v
-------
Recommendations for improving system effectiveness pertained to improving evaluation of
plume capture and/or control and evaluating the degree of monitored natural attenuation,
sampling residential wells, and evaluating the potential for vapor intrusion. Recommendations
for reducing cost included modifications to the ground water sampling programs for two sites,
simplifying operations and maintenance activities at one site, and simplifying the treatment train
at another site. Recommendations for technical improvement were primarily associated with
progress reporting. The recommendations for site closure included considerations for continuing
with a plume control remedy, developing an alternative exit strategy, and evaluating an interim
action as a potential final action.
VI
-------
TABLE OF CONTENTS
NOTICE i
PREFACE ii
ACKNOWLEDGEMENTS iii
EXECUTIVE SUMMARY v
TABLE OF CONTENTS vii
1.0 INTRODUCTION 1
1.1 PROJECT BACKGROUND 1
1.2 RSE AND RSE-LiTE PROCESSES 1
1.3 SITE SELECTION PROCESS FOR THE RSE-LiTES 3
1.4 SCHEDULE OF RSE-LiTES 4
1.5 SITE-SELECTION AND SCHEDULING FOR THE FULL-SCALE RSE 5
1.6 BRIEF SITE DESCRIPTIONS 5
2.0 SUMMARY OF RSE FINDINGS AND RECOMMENDATIONS 8
2.1 COMPARISON OF SITE/SYSTEM CHARACTERISTICS 8
2.2 COMMON THEMES REGARDING RECOMMENDATIONS FOR IMPROVING EFFECTIVENESS .. 8
2.3 COMMON THEMES REGARDING RECOMMENDATIONS FOR COST REDUCTION 9
2.4 COMMON THEMES REGARDING RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT .... 9
2.5 COMMON THEMES REGARDING RECOMMENDATIONS FOR SITE CLOSURE 10
3.0 PRELIMINARY FEEDBACK FROM SITE STAKEHOLDERS 11
3.1 PRELIMINARY FEEDBACK FOR THE CHEMKO SITE 11
3.2 PRELIMINARY FEEDBACK FOR THE EATON SITE 11
3.3 PRELIMINARY FEEDBACK FOR THE ENGELHARD SITE 12
3.4 PRELIMINARY FEEDBACK FOR THE BP CARSON REFINERY SITE 12
4.0 LESSONS LEARNED AND POTENTIAL NEXT STEPS 13
4.1 LESSONS LEARNED 13
4.2 POTENTIAL NEXT STEPS 14
vii
-------
1.0 INTRODUCTION
1.1 PROJECT BACKGROUND
In 2003 and 2004, the EPA Office of Solid Waste (OSW) and the EPA Office of Superfund
Remediation and Technology Innovation (OSRTI) sponsored independent optimization
evaluations called Remediation System Evaluations (RSEs) at five RCRA sites with pump and
treat (P&T) systems. These RSEs involved an independent team of experts reviewing site
documents, interviewing site stakeholders, and providing recommendations for improving
remedy effectiveness, reducing costs, and gaining site closure.
Based on the positive results of these RSEs, OSRTI and OSW commissioned a new pilot study
to develop and pilot a streamlined RSE process that reduces the evaluation cost relative to a full-
scale RSE. It is thought that the streamlined RSE will provide much of the same benefit as a
full-scale RSE for many sites but at a lower cost.
For this new pilot study, four facilities regulated under the RCRA Corrective Action Program
that have operating P&T systems were selected to receive streamlined RSEs or "RSE-lites".
Upon completion of the draft RSE-lites for these sites, one of the sites was selected to receive
additional evaluation, including a site visit to enhance the RSE-lite into a full-scale RSE.
This report summarizes the following:
The RSE and RSE-lite processes
The site-selection process for this project
• Brief descriptions of participating sites
Typical recommendations generated from the optimization evaluations at these sites
• Lessons learned from conducting this pilot project
1.2 RSE AND RSE-LITE PROCESSES
RSEs and RSE-lites
The RSE process was developed by the U.S. Army Corps of Engineers (USAGE). It involves a
team of expert hydrogeologists and engineers, independent of the site, conducting a third-party
evaluation of a remedy. It is a broad evaluation that considers the goals of the remedy, site
conceptual model, above-ground and subsurface performance, monitoring, data management,
costs, and site exit strategy. The evaluation includes reviewing site documents, visiting the site
for 1 to 1.5 days, and compiling a report that includes recommendations to improve the system.
Recommendations are provided in the following four categories:
• Improvements in remedy effectiveness
• Reductions in operation and maintenance costs
1
-------
• Technical improvements
• Gaining site closeout
The RSE-lite process is similar to the RSE, but instead of conducting a site visit, the evaluation
team conducts a two hour conference call with the site team. This reduces contractor labor
associated with visiting a site and eliminates other travel costs. Conceptually, however, the
evaluation team obtains enough information to provide valuable recommendations similar to
those that would be generated from a full-scale RSE.
The documents reviewed by the evaluation team typically include information pertaining to site
investigations, remedy design, and remedy operations and maintenance (O&M). Upon reviewing
this information, the evaluation team conducts either the site visit (RSE) or conference call
(RSE-lite) with the remedy project manager to address questions that may have arisen as part of
the document review or to address other information gaps.
RSE and RSE-lite Reports
Based on the site documents and the information from the site visit (RSE) or conference call
(RSE-lite), the evaluation team prepares a report documenting recommendations for improving
efficiency and effectiveness. The reports for RSEs and RSE-lites for this project are similar.
The reports include the following:
• An introduction that details the evaluation process (RSE or RSE-lite), the evaluation
team, and the documents that were reviewed
• A brief summary of site history, site conceptual model, ground water remedial system,
remedy goals, and costs
• Findings from the document review and conference call (RSE-lite) or site visit (RSE)
pertaining to remedy effectiveness, cost-effectiveness, and remedy progress with respect
to site closure
• Recommendations intended to
o Enhance remedy effectiveness and efficiency with respect to preventing plume
migration and monitoring other exposure pathways
o Reduce life-cycle O&M costs
o Improve technical operations
o Gain site closeout
• A table summarizing the recommendations, including estimated capital costs and
estimated annual cost increases or decreases associated with each recommendation
• Figures, developed by the evaluation team or by the site contractor, to provide
perspective and a visual reference for the reader
-------
The observations and recommendations presented in the RSE or RSE-lite reports are not
intended to imply a deficiency in the work of the designers, operators, or site managers. They
are offered as constructive suggestions that have the benefit of an independent review of
operational data that were unavailable to the original designers. The recommendations are also
not requirements for the site team to implement. They are provided for the consideration of the
site team.
1.3 SITE SELECTION PROCESS FOR THE RSE-LITES
EPA OSW and OSRTI requested that EPA project managers in each of the 10 EPA Regions
nominate sites to participate in this pilot project. The nomination form provided by EPA OSW
and OSRTI to the Regions requested information on the following types of facilities:
1. Facilities that are on the EPA Corrective Action GPRA baseline (either 2005 or
2008).
2. Facilities with significant uncertainly with respect to whether the existing ground
water remedy is sufficient to meet the Migration of Contaminated Groundwater
Under Control environmental indicator (i.e., whether existing plumes of contaminated
ground water are getting larger or adversely affecting surface water bodies).
3. Facilities with uncertainty with respect to whether the existing ground water remedy
is sufficient to meet the Current Human Exposures Under Control environmental
indicator (i.e., whether there is a significant potential for existing unacceptable
exposures to contaminants in or from ground water).
4. Facilities located on highly valued ground water resources (e.g., sole source aquifers,
nearby public or private uses of ground water as drinking water).
5. Facilities where a ground water remedy has been operating for at least one year.
6. Facilities that are not making expected progress toward cleanup goals.
7. Facilities where EPA project managers (PMs) would agree to provide copies of
RSE/RSE-lite reports (i.e., findings and recommendations) to all interested parties
(e.g., facility owners/operators, state representatives, and EPA management). [Note
that PMs are not required to implement all recommendations included in RSE/RSE-
lite reports; however, PMs are asked to thoroughly consider all recommendations and
document progress toward evaluating and implementing RSE recommendations
within one year of RSE/RSE-lite completion].
8. Facilities where EPA project managers require technical assistance in reviewing a
technical proposal put forth by the owners/operators of RCRA facilities to modify an
existing ground water remedy. [Note: In conducting the RSE/RSE-lite (an
independent evaluation), the RSE/RSE-lite team would assess the proposal and
include associated findings and recommendations in the RSE/RSE-lite report.]
-------
9. To maintain the independent aspect of the RSE/RSE-lite process, facilities will not be
considered if there is a conflict of interest for the evaluation team. The evaluation
team includes representatives from GeoTrans, Inc., an environmental consulting firm
that is a wholly-owned subsidiary of Tetra Tech, Inc., which has contracts with many
of the EPA Regions. The following two scenarios represent a definite conflict of
interest for GeoTrans:
a) The owner/operator of the RCRA facility is a client of GeoTrans.
b) The owner/operator is a client of another Tetra Tech company.
The third scenario represents a potential conflict of interest for GeoTrans that would
need to be resolved on a case by case basis.
c) A Tetra Tech company is the oversight contractor for that site. (Note: This is
not necessarily a conflict of interest in the opinion of GeoTrans, but may appear
as a conflict of interest to Tetra Tech, EPA, or the facility.)
10. The facility and the overseeing regulator Agency have a history of relatively good
communication, the facility is willing to provide access to the RSE/RSE-lite team,
and the facility and/or the overseeing regulator is willing to provide copies of relevant
reports and data.
EPA Regions 1, 2, 4, 7, and 9 provided nominations. A total of seven nominations were
received. Of those seven sites, there were conflicts of interest (see item 9 of the nomination
questions) for three of them. The remaining four were deemed appropriate to benefit from the
RSE or RSE-lite process, so EPA OSW and OSRTI did not make additional requests for
nominations from the Regions.
1.4 SCHEDULE OF RSE-LiTES
The four sites that participated in the pilot project are listed in the following table along with the
dates of various project milestones. As is evident in the table, the BP Carson Refinery site was
the one site selected to receive the full-scale RSE after completing the RSE-lite process.
Site Name and Location
Chemko Technical Services, Inc.
Minis, FL
Engelhard Corporation Facility
Plainville, MA
BP Carson Refinery
Carson, CA
Eaton Corporation Facility
Kearney, NE
EPA
Region
4
1
9
7
Date of
Conference Call
3/17/2005
3/22/2005
4/7/2005
5/4/2005
Date Draft RSE-Lite
Report Submitted
4/20/2005
5/27/2005
RSE-Lite: 6/10/2005
6/21/2005
Date Final RSE-Lite
Report Submitted
8/8/2005
8/3/2005
N/A*
12/9/2005
* A full-scale RSE was conducted at BP Carson Refinery site, and a final RSE report was produced instead of a final
RSE-lite report.
-------
1.5 SITE-SELECTION AND SCHEDULING FOR THE FULL-SCALE RSE
Upon completion of the four RSE-lites and receipt of comments from the site teams at each of
the sites, the RSE team selected the BP Carson Refinery site to receive the full-scale RSE for the
following reasons:
• Of the four sites in the pilot project, the BP Carson Refinery site is one of the more
complex sites from a hydrogeological perspective.
Of the four sites, the BP site is the most costly site to operate (largely due to the
complexity of the site relative to the three other sites)
• Of the four sites, the BP site would benefit most from an RSE site visit because the
infrastructure and activities of an operating refinery greatly influence the remediation
activities and the RSE team can provide more relevant recommendations after seeing the
site first hand.
The BP site team (i.e., EPA Region 9 and BP) provided comments on the draft RSE-lite
report that merited additional time and data analysis to address.
• There was information that became available after the preparation of the draft RSE-lite
report that the evaluation team could consider during the RSE.
The RSE site visit was conducted on August 18, 2005. The draft RSE report was distributed to
the site team on November 4, 2005, and a finalized RSE report was distributed to the site team
on December 9, 2005.
1.6 BRIEF SITE DESCRIPTIONS
The following are brief descriptions of the four sites in the pilot test. Common themes from the
RSE-lite and RSE reports are discussed in Section 2.0 of this report.
Chemko Technical Services, Inc. Facility-Mims, Florida
The Chemko Technical Services, Inc. Facility ("Chemko") is located at 5325 North U.S.
Highway 1 in Mims, Florida. Chemko purchased the property in 1972. Prior to Chemko's
purchase, the facility had been used for fiberglass fabrication as well as heavy equipment repairs.
Operations at the Chemko site historically, and currently, consist of metal fabrication and
cleaning.
A series of site assessment activities were conducted beginning in 2001, which included
delineation of contamination from a drain system, a soil vapor study, geologic borings,
monitoring well design and installation, ground water sampling, and surface water sampling.
Identification of the Chemko facility as a RCRA Corrective Action site is relatively recent and
-------
initial site assessment was completed in FY 2003. The ground water contaminant plume
consisting of tetrachloroethene (PCE) and its breakdown products has migrated beyond the
property boundary and has impacted a domestic drinking water well. An interim measure P&T
system was installed for source control on the Chemko property in 2004. Monitored natural
attenuation (MNA) has been selected as the interim remedy for the downgradient plume, and a
point of entry treatment system has been installed at the residence with the impacted well.
Engelhard Corporation Facility - Plainville, Massachusetts
The Engelhard Corporation Facility ("Engelhard") is located at 30 Taunton Street in Plainville,
Massachusetts. The facility, which was constructed in the late 1950's, was primarily involved in
the manufacturing/processing of various precious metal products. Environmental investigation
and remedial activities have been conducted at the site since the mid 1980's.
The ground water contaminant plume consisting of tetrachloroethene (PCE) and 1,1,1-
trichloroethane (TCA) have migrated beyond the property boundary. EPA and Engelhard signed
a 3008(h) Corrective Action consent order in 1993. As a result, a ground water stabilization
measure (GSM) P&T system consisting of six deep bedrock extraction wells and a vertical high-
density polyethylene (HDPE) barrier membrane was installed and began operating in 1998. The
objective of GSM is to contain the plume along the HDPE barrier membrane and establish a
gradient reversal to capture contamination that may be present immediately downgradient of the
GSM.
BP Carson Refinery - Carson, California
The BP Carson Refinery ("BP") is located at 1801 East Sepulveda Boulevard in Carson,
California. Petroleum refining operations have been conducted at the site since 1923. From
1937 through 1945, other parcels of land were purchased and added to the refinery, and refining
operations were expanded. The refinery is divided into various geographic areas with total area
of approximately 702 acres. Ground water remediation has been ongoing at the refinery since
1977. Recovery of light non-aqueous phase liquid (LNAPL) was the focus of early remediation
activities at the refinery. Between 1983 and 1996, approximately 17,000,000 gallons of LNAPL
were recovered. A perimeter recovery system was constructed along the refinery's western
boundary between 1994 and 1997 to control potential off-site LNAPL migration, and LNAPL
recovery efforts continue to be part of site remedial activities. In the mid-1990s, oxygenates
emerged as constituents of concern for drinking water in the Carson area.
The current approach to remediation at the site consists of three parts: a collaborative regional
approach to address the regional commingled plume(s), on-site LNAPL management, and on-site
remedial measures to control dissolved oxygenate migration from the Northern Tank Farm
(NTF), which is part of the main refinery. The collaborative regional approach involves working
with the Carson Region Groundwater Group (CRGG) to develop a regional numerical model to
determine if the plumes underlying the CRGG properties (including but not limited to the BP
Carson Refinery) are "in control" in accordance with the Ground Water Environmental Indicator
requirements of the RCRA Corrective Action Program. The onsite approach involves source
elimination, source-area characterization and remediation, and ground water recovery for control
of the oxygenate plume. The current remediation practices reflect a shift in focus from LNAPL
-------
recovery to also include management of the dissolved phase plume. At the request of the site
team, the RSE-lite and RSE focused on the performance of the ground water and LNAPL
recovery system to control the migration of the dissolved oxygenate plume.
Eaton Corporation Facility - Kearney, Nebraska
The Eaton Corporation Facility ("Eaton") is located on East Highway 30 in Kearney, Nebraska.
The facility covers an area of 365,000 square feet and began operations in 1969 with engine
valve manufacturing. Onsite remediation began in 1986 after trichloroethene (TCE) was found
in production wells. On April 20, 1993, Eaton Corporation entered into an agreement with the
EPA Region 7 to delineate and remediate TCE contamination downgradient of the facility. An
interim system began operation in 1996, was reconfigured in 1998 to improve plume capture,
and reconfigured again in 2003 to adapt to a change in the direction of plume migration.
The current approach to remediation includes an onsite P&T system to contain the onsite TCE
contamination and an offsite P&T system to intercept the downgradient plume. The RSE-lite
applies primarily to the offsite P&T system.
-------
2.0 SUMMARY OF RSE FINDINGS AND RECOMMENDATIONS
2.1 COMPARISON OF SITE/SYSTEM CHARACTERISTICS
The four evaluated systems had the following characteristics:
• The primary contaminants of concern at all four sites are VOCs, such as TCE, PCE, and
MTBE
One of the four sites (Engelhard) has dense non-aqueous phase liquid (DNAPL) and one
of the four sites has LNAPL (BP)
• Only one of the four sites involves contamination that is present in fractured rock
(Engelhard)
• POET systems have been installed at residences for two of the sites (Chemko and Eaton)
• Annual O&M costs for the systems in increasing order are
o $50,250 for Chemko
o $85,690 for Eaton
o $141,000 for Engelhard
o $945,000 for BP
2.2 COMMON THEMES REGARDING RECOMMENDATIONS FOR IMPROVING EFFECTIVENESS
Each of the four evaluated sites had recommendations for improving system effectiveness. The
recommendations at the four sites pertained to plume capture and further evaluating potential
receptors.
Evaluations pertaining to plume capture or plume control were recommended at all four
of the sites. At two of these sites (Chemko and Eaton), the evaluation team believed the
current capture might be sufficient but further evaluation of concentration trends and
potentiometric surface maps were recommended. At the other two sites (Engelhard and
BP), the evaluation team did not see conclusive evidence of plume capture based on data
provided, and recommendations were geared toward improving plume delineation and/or
considering additional lines of evidence for evaluating plume capture and/or control.
Further evaluation of potential receptors was recommended at two of the sites. At one
site (Chemko), the recommendation was to track results of potable well sampling
conducted by the local Department of Public Health. At the other site (Eaton), the
recommendation was to remove POETS from two residential wells but to begin routine
sampling at two other residential wells.
-------
Other recommendations for improving effectiveness pertained to evaluating MNA at two of the
sites (Chemko and BP), evaluating the potential for vapor intrusion (Chemko), sampling at
residential wells (Eaton), improving of documentation for the site conceptual model (Engelhard),
and increasing the extraction rate (Engelhard).
2.3 COMMON THEMES REGARDING RECOMMENDATIONS FOR COST REDUCTION
Recommendations to reduce costs were provided at all four of the sites. Recommendations in
this category generally pertained to modifying ground water monitoring programs and modifying
treatment technologies.
The RSE-lite team recommended modifying the monitoring program at all four sites. The
suggested modifications included the following:
• Reducing the number of water quality sampling locations was recommended at two sites
(Chemko and Engelhard).
• Reducing the sampling frequency was recommended at two sites (Chemko and Eaton).
• Reducing the number of sampling parameters was recommended at one site (BP).
• Requesting a revision in the low-flow sampling procedure to expedite sampling without
sacrificing sample quality was recommended at one site (BP).
The RSE-lite team estimated that implementing these recommendations at all four sites could
save over $75,000 per year through reduced monitoring costs, with little or no capital
investment.
At the BP site the RSE/RSE-lite team made a recommendation to reduce recovery system O&M
labor and another recommendation to reduce labor associated with data evaluation and reporting
costs once the system is optimized. The estimated potential savings associated with these
recommendations was approximately $270,000 per year. At the Engelhard site, the RSE-lite
team recommended considering the elimination of the metals removal equipment and removal of
the liquid phase GAC units, with potential savings of up to $62,000 per year from reduce
material, disposal, and labor costs.
In total, the RSE-lite team provided nine cost-reduction recommendations that, if implemented,
could potentially result in cost savings of over $400,000 per year with little or no capital
investment.
2.4 COMMON THEMES REGARDING RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT
Recommendations for technical improvement were provided at two sites (BP and Eaton). At the
Eaton site, the RSE-lite team recommended revising the frequency and format of the progress
report. At the BP site, the RSE-lite team recommended instituting a specific annual report for
-------
the area of concern and also recommended reconsidering pumping from one of the recovery
wells
2.5 COMMON THEMES REGARDING RECOMMENDATIONS FOR SITE CLOSURE
Recommendations for site closure were provided at all four sites but do not necessarily share a
common theme.
• At the Chemko site, the RSE-lite team suggested that the current interim remedial action
be evaluated for a three-year period to determine if it would be an effective final remedial
action.
• At the Eaton site, considering a potential alternative exit strategy was recommended,
including the potential for discontinuing pumping if plume stability in the absence of
pumping can be demonstrated.
• At the Engelhard site, the RSE-lite team recommended revisiting MNA criteria for the
downgradient plume and continuing with a source control remedy. Due to the presence
of DNAPL, the RSE-lite team suggested the site team focus on source
control/containment, and potentially avoiding costly DNAPL remediation in the bedrock.
• With regard to the BP site, the evaluation team believes the wide-spread presence of
LNAPL, the relatively impermeable nature of the water table aquifer, and the potential
for future releases suggests that a remedy focused on plume control (through a
combination of ground water extraction and MNA) would be more appropriate than a
remedy focused on aquifer restoration.
10
-------
3.0 PRELIMINARY FEEDBACK FROM SITE STAKEHOLDERS
Optimization evaluation recommendations can take several months to evaluate and implement.
As a result, given the time constraints of the project, following-up with the site stakeholders to
determine which recommendations would be implemented was not part of the pilot project scope
of work. It is therefore difficult to determine the impact the evaluations have had at the sites and
to evaluate the points of view of the various stakeholders from each site. The following
comments, however, were provided to the evaluation team shortly after submitting the evaluation
reports. There are more comments from EPA and/or the State than there are from the facility
representatives. This should not be construed as a lack of willingness to comment since a formal
request for feedback by the project team was not requested.
3.1 PRELIMINARY FEEDBACK FOR THE CHEMKO SITE
The Florida Depart of Environmental Protection (FDEP) communicated the following to the
Chemko facility after reviewing the RSE-lite report:
The facility may choose to continue the current interim measure corrective action system as the long-term
corrective action system.... A revised groundwater/corrective action monitoring plan should incorporate the
recommendations in the EPA RSE-lite Report as well as the Department's monitoring recommendations.
This comment suggests that the monitoring program recommended in the RSE-lite, which
involved cost savings for the facility, was considered by FDEP in its direction for the site. In
addition, FDEP staff stated to the RSE-lite team, "Thanks for your work on the site. The report
was well done and was quite beneficial at this site where the owner had limited resources
available for CA [Corrective Action]." This comment indicates that the RSE-lite process may be
particularly helpful at sites where evaluation is needed but limited resources are available from
the regulatory agency and facility to conduct the evaluation. The facility did not provide
feedback to the evaluation team.
3.2 PRELIMINARY FEEDBACK FOR THE EATON SITE
The EPA project manager for the Eaton site stated the following to the RSE-lite team regarding
the RSE-lite process:
Thanks for your efforts at revising and finalizing the RSE-lite report for the Eaton facility in Kearney, NE.
The document and response to comments have now been forwarded to the facility. The facility appears
receptive to the recommendations contained in the report and I hope to work with their representatives over
the next few months to implement most if not all of those recommendations.
In addition, the facility, in responding to the draft report, indicated concurrence with one
recommendation to reduce costs and suggested modifications to two of the recommendations
pertaining to improving remedy effectiveness. Ultimately, the RSE-lite team agreed with one of
the two modifications and incorporated this modification into the final RSE-lite report.
11
-------
These comments indicate that the RSE-lite recommendations will likely contribute to both a
more protective and cost-effective remedy that is agreeable to both the regulatory agencies and
the facility representatives.
3.3 PRELIMINARY FEEDBACK FOR THE ENGELHARD SITE
No specific feedback was received for the Engelhard site from the regulatory agency or from the
facility.
3.4 PRELIMINARY FEEDBACK FOR THE BP CARSON REFINERY SITE
The EPA project manager for the BP Carson Refinery Site provided the following feedback to
the evaluation team:
I want to commend Geotrans for the concise analysis contained in the RSE and thank OSRTI and OSW for
supporting this effort. I believe the process of evaluating this particular remedial system has been helpful
not only for this site, but will have applications for cleanup systems at other refineries and terminals in the
LA West Coast Basin.
This statement suggests the value of the RSE-lite and RSE processes to EPA. In providing its
comments on the draft RSE report, the BP representative stated, "ARC [BP] believes that the
RSE-lite and RSE processes have provided ARC recommendations that will be helpful in
ongoing evaluations at the BP Carson Refinery."
12
-------
4.0 LESSONS LEARNED AND POTENTIAL NEXT STEPS
4.1 LESSONS LEARNED
The primary lessons learned are as follows:
• RSE-lites can effectively be conducted at RCRA sites with involvement of both the
regulatory and facility stakeholders. Prior to this RSE-lite pilot project, full-scale RSEs
had been conducted at RCRA and Fund-lead sites. In this RSE-lite pilot project, RSE-
lites provided a similar level of beneficial results for two sites as would be expected from
full-scale RSEs, but at lower cost (approximately $10,000 per RSE-lite instead of
$25,000 per RSE).
• However, the RSE-lite process was not as effective as a full-scale RSE at the Eaton and
BP sites for two different reasons. At the Eaton site, the conference call format did not
allow sufficient time and face to face communication for the evaluation team and the site
team to interact. As a result, several follow-up communications were necessary for the
evaluation team to fully understand the perspectives of the various site stakeholders. At
the BP site, the refinery infrastructure and variety of ongoing site activities could not
easily be communicated through a conference call. For this reason, and others, the BP
site was selected for a full-scale RSE, allowing the evaluation team to tour the site and
observe site remedial activities.
• In addition to identifying opportunities to improve remedy effectiveness, the evaluations
from this pilot program yielded cost-reduction recommendations with potentially
substantial annuals savings.
The site-selection process involved EPA project managers nominating sites, and the
primary reason for a site nomination was a third party review of remedy effectiveness.
By involving only EPA staff in the site-selection process, sites that might benefit from a
third-party review for another reason (e.g., cost-reduction or remedy efficiency) may not
have been considered for the pilot project.
The majority of feedback received from the site teams regarding the RSE-lite and RSE
processes was provided by EPA or its State counterpart. This might be a result of the
EPA project managers nominating the sites for EPA-sponsored reviews. That is, the EPA
project manager might be more comfortable than the facility in commenting on the
process given that EPA is the regulator and the facility is the regulated party. The facility
representatives might participate differently in a process if the review was sponsored by a
third-party or co-sponsored by both EPA and the facility.
13
-------
4.2 POTENTIAL NEXT STEPS
The following items are potential next steps that could be taken as a follow-up to this pilot
project based on the above-mentioned lessons learned.
• Approximately six months after the end of the pilot project, the progress at each of these
sites (and sites in the previous RCRA RSE pilot project) could be evaluated to determine
how many of the RSE recommendations were implemented and how implementation of
those recommendations has affected the sites. This information could help better judge
the long-term value of the third-party reviews at these sites. Feedback from EPA, the
State counterpart (if applicable), and the facility representatives would be helpful to in
determining the value of the third-party review from these differing perspectives.
• Based on the feedback collected to date, third-party reviews such as RSE-lites and RSEs
could continue to provide a benefit to sites in the RCRA Corrective Action Program. The
process itself does not require further piloting; therefore, consideration might be given to
how third-party reviews could be provided as part of a program. If there is no third-party
source of funding for the reviews, funding might be equally provided by all parties
involved in the process. That is, the RSE-lites or RSEs could be jointly funded by the
EPA, the State (if applicable), and the facility. The topic of joint funding could be raised
by EPA to a group of facility representatives suggesting the potential application of RSE-
lites or RSEs at the following types of sites:
o Sites where a remedy has stagnated or has not performed to expectations and
additional measures are required
o Sites where there is disagreement between the regulator and the facility with
regard to a remedial approach
o Sites where the facility is proposing a new or modified remedial approach and
both the regulator and the facility see benefit in an independent analysis
o Sites where a third party could help determine an appropriate level of financial
assurance
o Sites that will be transferred to a State or another party due to bankruptcy
settlements
o Sites where efficiencies and performance could be enhanced with respect to
optimizing monitoring, extraction, treatment, etc.
o Sites where the facility is interested in cost savings and other benefits by applying
optimization while maintaining remedy effectiveness
• Although the RSE and RSE-lite process have both been piloted, only one form of site
selection has been performed because this project used the same site-selection process as
the original RCRA RSE project in 2003. Therefore, it is difficult to determine how RSE-
14
-------
Lites or RSEs would be received, and what value they would have at sites that were
selected through a different process (e.g., nominations from facility representatives).
15
------- |