for
EPA III
-------
Solid Waste and EPA542-R-07-011
Emergency Response August 2007
(5203P) www.epa.gov
for
EPA III
-------
NOTICE
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. Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
-------
TABLE OF CONTENTS
NOTICE i
TABLE OF CONTENTS iii
1.0 INTRODUCTION 1
1.1 PROJECT BACKGROUND 1
1.2 SELECTED SITES 1
1.3 SCHEDULE OF PROJECT ACTIVITIES 2
2.0 OPTIMIZATION EVALUATIONS 4
2.1 OPTIMIZATION EVALUATION PROCESS 4
2.2 SUMMARY OF RECOMMENDATIONS 5
2.3 SUMMARY OF POTENTIAL COSTS AND COST SAVINGS 6
2.4 SUMMARIES BY SITE 6
3.0 FOLLOW-UP AND TRACKING 11
3.1 FOLLOW-UP PROCESS 11
3.2 SUMMARY OF OPTIMIZATION PROGRESS 12
3.3 SUMMARY OF COSTS AND COST SAVINGS 12
3.4 SUMMARY OF FOLLOW-UP BY SITE 13
4.0 TECHNICAL ASSISTANCE 19
4.1 SITES WITH TECHNICAL ASSISTANCE 19
4.2 BRIEF SUMMARY OF TECHNICAL ASSISTANCE 19
5.0 MILESTONES 21
5.1 PURPOSE OF DEVELOPING MILESTONES 21
5.2 FIRST ATTEMPT TO DEVELOP MILESTONES 21
6.0 LESSONS LEARNED AND CONCLUSION 24
Attachments
Attachment A Kickoff Meeting Sign-in Sheet and Agenda
Attachment B Baseline Forms for Gathering Site Information
Attachment C Typical Agenda for an Optimization Evaluation Meeting
Attachment D Optimization Follow-up Site Trackers for the 12 Fund-lead Sites
[provided as individual reports]
in
-------
1.0 INTRODUCTION
1.1 PROJECT BACKGROUND
During fiscal years 2000, 2001, and 2002, the EPA Office of Superfund Remediation and
Technology Innovation (OSRTI) conducted optimization evaluations called Remediation System
Evaluations (RSEs) at 24 Fund-lead pump and treat (P&T) sites (i.e., those sites with P&T
systems funded and managed by Superfund and the States). In 2003 and 2004, OSRTI
conducted RSEs at additional Fund-lead sites, and piloted the RSE process at RCRA P&T sites
and LUST P&T sites. Also during 2003 and 2004, EPA Region III funded optimization
evaluations at two more of its Fund-lead P&T sites, marking the first time an EPA Region had
sponsored its own effort to optimize Fund-lead sites using an evaluation process like an RSE.
Based on the positive results of these optimization evaluations and a realization that Regional
resources are likely need to augment the nationwide optimization effort by OSRTI, EPA OSRTI
and Region III initiated a pilot study for a Region-based optimization program of the Region III
Fund-lead sites with P&T systems. The pilot program consists of the following components:
Conducting streamlined optimization evaluations
Implementing a formal follow-up/tracking program
Documenting the proj ect results
Providing technical assistance based on requests of the Remedial Project Managers
(RPMs) and findings during follow-up
Each of these components is implemented by a Regional Optimization Evaluation Team (ROET)
that is comprised of Regional management, Regional technical staff, technical experts
unassociated with the sites, and a representative from OSRTI. This is a modification of the
process utilized in the nationwide OSRTI program in that with this Regional program, Regional
management and technical staff are more directly involved with the optimization evaluations and
follow-up.
In addition to these optimization components, the ROET was tasked with developing site-
specific milestones to help track the progress of each P&T system in meeting its remedial
objectives.
1.2 SELECTED SITES
Region III identified 13 Fund-lead sites within the Region where P&T was either implemented
or planned as a site remedy. One of these sites, North Penn Area 6, was determined to not be
appropriate for the optimization pilot program because of an ongoing dynamic management
program conducted by a third party (i.e., the U.S. Geological Survey) to continually optimize the
pumping strategy. The other 12 sites were included in this Regional optimization pilot program.
Four of the 12 sites received full-scale optimization evaluations between 2001 and 2004 (prior to
entering this pilot program) so they entered the pilot program at the follow-up/tracking phase.
1
-------
The other eights entered the program at the streamlined optimization evaluation phase. The
following table indicates the 12 sites that were included in the program, distinguishing the four
"old" sites from the eight "new" sites.
Site Name
Location
Site Status
Date of O&F
"Old" Sites that Received Full-Scale Evaluations Prior to Entering the Pilot Program
Greenwood Chemical Co.
("Greenwood")
Havertown PCP ("Havertown")
Hellertown Manufacturing Co.
("Hellertown")
Raymark
Newtown,
Virginia
Havertown,
Pennsylvania
Hellertown,
Pennsylvania
Hatboro,
Pennylvania
Interim Remedy
Interim Remedy
LTRA
LTRA
3/2002
N/A
9/1997
6/1995
"New" Sites that Had Not Received Optimization Evaluations Prior to the Program
AIW Frank/Mid-County Mustang
Site ("AIW Frank")
Butz Landfill ("Butz")
Crossley Farm ("Crossley")
Croydon TCE ("Croydon")
Cryochem Inc. ("Cryochem")
North Perm - Area 1
("North Pennl")
Saunders Supply Co. ("Saunders")
Standard Chlorine of Delaware
("SCO")
Exton,
Pennsylvania
Tannersville,
Pennsylvania
Berks County,
Pennsylvania
Croydon,
Pennsylvania
Worman,
Pennsylvania
Souderon,
Pennsylvania
Chuckatuck,
Virginia
Delaware City,
Delaware
LTRA
LTRA
Pre-Design for Interim
Remedy
LTRA
LTRA
LTRA
LTRA
Design
3/2001
7/2001
N/A
11/1995
5/1998
9/1998
6/1999
N/A
1.3 SCHEDULE OF PROJECT ACTIVITIES
The project began with a kickoff meeting on November 3, 2004. The kickoff meeting included
the following participants:
All Regional staff that would participate in the pilot program, including management,
technical staff, coordination staff, and site RPMs
EPA OSRTI representatives that would participate in or observe the pilot program
EPA optimization contractors that would facilitate the program and be a technical lead
The kickoff meeting was designed to introduce Regional staff to the pilot program objectives and
procedures and introduce Regional staff to the EPA OSRTI representatives and optimization
contractor. The sign-in sheet and agenda for this kickoff meeting are provided as Attachment A
to this report.
-------
Optimization evaluations and follow-up/tracking meetings began shortly after the kickoff
meeting. The schedules for all the optimization evaluations and follow-up meetings for each of
the 12 sites are listed in the following table.
Site
Optimization
Evaluation
Meeting
Date of Draft
Opt. Eval.
Report
1st Follow-Up
Meeting
Final Opt.
Eval. Report &
Draft Site
Tracker
2nd Follow-Up
Meeting
"Old" Sites that Received Full-Scale Evaluations Prior to Entering the Pilot Program
Greenwood
Havertown
Hellertown
Raymark
8/7/2003
8/5/2003
6/5/2001
6/8/2001
4/2/2004 *
3/4/2004 *
11/14/2001 *
12/19/2001 *
12/16/2004
12/16/2004
12/16/2004
12/16/2004
3/7/2005 **
3/14/2005 **
1/24/2005 **
3/7/2005 **
10/18/2005
10/18/2005
10/18/2005
10/18/2005
"New" Sites that Had Not Received Optimization Evaluations Prior to the Program
AIW Frank
Butz
Crossley
Croydon
Cryochem
North Perm 1
Saunders
SCO
12/15/2004
12/15/2004
2/8/2005
12/1/2004
12/1/2004
2/8/2005
2/10/2005
2/10/2005
1/14/2005
1/14/2005
3/21/2005
1/14/2005
2/14/2005
3/21/2005
5/20/2005
4/15/2005
7/20/2005
7/20/2005
11/7/2005
7/20/2005
7/13/2005
7/20/2005
7/13/2005
7/13/2005
7/29/2005
7/29/2005
10/26/2005
8/5/2005
8/5/2005
8/5/2005
7/29/2005
8/5/2005
11/7/2005
10/19/2005
***
10/19/2005
10/19/2005
11/7/2005
11/7/2005
10/19/2005
Note:
* Full-scale evaluations were conducted at Greenwood, Havertown, Hellertown, and Raymark for the previous
pilot studies. The dates indicate the completion of the final evaluation reports.
** The dates indicate the draft site tracker only.
*** Two follow-up meetings were scheduled for this site, but the first scheduled follow-up meeting was used to
discuss the draft optimization report and arrange a site visit for both the site team andROET. Therefore, the
second scheduled follow-up meeting is the first true follow-up for this site.
-------
2.0 OPTIMIZATION EVALUATIONS
2.1 OPTIMIZATION EVALUATION PROCESS
The Hellertown and Raymark sites (e.g., two of the "old" sites) were evaluated using the RSE
process developed by the U.S. Army Corps of Engineers (USAGE), and the Havertown and
Greenwood sites (e.g., the other two "old" sites) were evaluated using an identical process to the
RSE. The eight "new" sites were evaluated using a streamlined version of the RSE process. All
three of these evaluation processes are designed to provide a third-party perspective of site
operations with the goal of providing recommendations to improve remedy effectiveness, reduce
cost, improve general operations, and gain site closure. The evaluations are not intended to be
an audit or to criticize previous efforts. The activities and various roles and responsibilities
associated with the streamlined evaluation process are discussed below.
Preparation
The preparation stage began at the kickoff meeting on November 3, 2004. The streamlined
optimization evaluations were scheduled for the eight new sites and the first round of follow-up
meetings was scheduled for the four old sites. In addition, the ROET distributed baseline
information forms to the site RPMs so that the RPMs could provide baseline information
regarding annual costs, remedy status, and other fundamental remedy information. The baseline
form, designed for use with operating systems, is provided as Attachment B to this report. A
slightly modified version of the form was developed later in the project to use for systems in the
design or planning stage. This modified version is also included in Attachment B. The RPMs
for each of the 12 sites completed the form and returned it to the ROET prior to the optimization
evaluation meeting (for the new sites) or the first round of tracking/follow-up (for the old sites).
Regional coordination staff also gathered relevant site documents and transferred them to the
ROET for review. The coordination staff identified relevant documents by referring to a list of
useful documents provided in the kickoff agenda (see Attachment A), reviewing the
administrative record, and coordinating with the RPM and ROET.
Evaluation
The ROET began the evaluation phase for the eight new sites by reviewing the baseline site
information and the site documents to become familiar with the site and to generate questions to
be answered during the optimization evaluation meeting. This review began approximately one
month prior to the scheduled optimization evaluation meeting. The ROET then met with the site
team on the scheduled day for 1.5 hours to discuss the site and answer questions that stemmed
from a review of the baseline information and site documents. The meeting was geared toward
information gathering so that the ROET could later analyze the data, update the site information
form, develop recommendations, and draft a report. The meetings were constructed so that
optimization evaluations for up to four sites were conducted in one day. This reduced the
optimization contractor travel costs associated with meeting attendance. A typical agenda for an
optimization meeting that was distributed to Regional staff during the kickoff meeting for
introductory purposes is provided as Attachment C to this report.
-------
Report
For the eight new sites, after the optimization evaluation meeting the optimization contractor
took the lead on developing recommendations and drafting a report. The optimization contractor
worked in concert with the other members of the ROET to develop appropriate
recommendations. A draft report that included findings and recommendations was generally
submitted to the site team within 45 days of the optimization evaluation meeting. The report
also included an updated site information form. The reports were streamlined compared to those
associated with a full-scale evaluation. These streamlined reports focused mostly on findings
and recommendations and did not provide a comprehensive summary of the site.
The streamlined report and updated site information form for each site were finalized after
feedback was received from and discussed with the site RPM. These documents then served as a
baseline for subsequent follow-up activities.
2.2 SUMMARY OF RECOMMENDATIONS
The following table lists the number of recommendations provided for each of four categories,
based on the finalized optimization evaluation report:
Site
System
Effectiveness
Cost Reduction
Technical
Improvement
Site Closure
Total
"Old" Sites that Received Full-Scale Evaluations Prior to Entering the Pilot Program
Greenwood
Havertown
Hellertown
Raymark
Old-Site Subtotal
4
4
4
7
19
5
2
2
0
9
2
2
1
0
5
2
2
1
o
J
8
13
10
8
10
41
"New" Sites that Had Not Received Optimization Evaluations Prior to the Program
AIW Frank
Butz
Crossley *
Croydon
Cryochem
North Perm 1
Saunders
SCO
New-Site Subtotal
Total
1
2
2
2
3
3
3
1
17
36
1
3
0
1
4
0
1
3
13
22
2
2
1
0
1
2
1
0
9
14
1
1
0
1
2
1
1
0
7
15
5
8
3
4
10
6
6
4
46
87
* Recommendations were not finalized at the time of this summary report. The indicated recommendations
for Crossley were based on the draft optimization report.
-------
2.3 SUMMARY OF POTENTIAL COSTS AND COST SAVINGS
The following table summarizes the potential costs and cost savings associated with
implementing recommendations in each of the recommendation categories. There were several
recommendations where estimates for costs and/or savings were "not quantified" in the
optimization evaluation reports to the open-endedness of the recommendation. This table does
not reference any "unquantified" estimates of costs or cost savings.
Recommendation Category
Estimated Capital Costs
to Implement
Estimated Change in
Annual Costs after
Implementation
"Old" Sites that Received Full-Scale Evaluations Prior to Entering the Pilot Program
Protectiveness
Cost Reduction
Technical Improvement
Site Closeout*
Old-Site Subtotal
$851,000
$125,000
$80,000
($1,500,000)
($444,000)
$26,000
($295,000)
$35,000
($30,000)
($264,000)
"New" Sites that Had Not Received Optimization Evaluations Prior to the Program
Protectiveness
Cost Reduction
Technical Improvement
Site Closeout
New-Site Subtotal
Total
$322,000
$0
$10,000
$320,000
$652,000
$208,000
$2,000
($161,000)
$29,200
($80,000)
($209,800)
($473,800)
Costs in parentheses indicate cost savings.
* Costs associated -with site closeout recommendations for old sites include costs for a recommendation to remove
contaminated surface soil or use a permeable soil cover instead of constructing an impermeable RCRA cap. The
optimization evaluation suggested anticipated savings of $1,500,000 for using these alternatives in place of the
impermeable cap (e.g., the difference between $2 million for a RCRA cap and $500,000 for the alternative).
2.4 SUMMARIES BY SITE
The optimization evaluation reports for all 12 sites (full-scale reports for the four old sites and
streamlined reports for the eight new sites) are included as part of the optimization follow-up site
trackers, which are provided within Attachment D to this report. Summaries of the optimization
evaluation results for each of the 12 sites are provided below for convenience.
AIWFrank
This site with karst geology has a relatively small source area (less than one acre) but a dilute
plume that is approximately 2,000 feet long. The primary contaminant of concern is TCE and its
breakdown products, but 1,1,1-TCA is present at concentrations below the MCL and 1,4-
Dioxane is present at concentrations up to 250 ug/L. At the time of the meeting, there were no
established cleanup or discharge limits for 1,4-Dioxane, which was present in the system
-------
influent. The optimization evaluation included one recommendation to improve protectiveness,
which was to verify the appropriate 1,4-Dioxane limits. The one recommendation to reduce cost
was to streamline the VOC removal process by either discontinuing air stripping or bypassing
the GAC polishing step. The evaluation team also recommended the use of chemical oxidation
with Fenton's reagent in the source area to address both the TCE and the 1,4-Dioxane.
Recommendations were also made with regard to progress reporting.
Butz
The P&T system at this site operates cost-effectively to address a TCE plume in fractured
bedrock. Prior to operation of the P&T system EPA had extended a water line for all but few
residents in the area. The recommendations for improving protectiveness included implementing
institutional controls to prevent future use of impacted ground water, and attempting to sample
potable wells at two residences that are not hooked up to the waterline. The recommendations to
reduce cost included reductions in the ground water sampling frequency, reductions in the
process monitoring sampling, and elimination of the sampling for MNA parameters. Other
recommendations pertained to improving progress reporting and reducing system downtime.
The evaluation team also suggested that the site team continue with a P&T remedy rather than
pursuing alternative remedial approaches.
Crossley
The interim remedy for this site with fractured bedrock and TCE concentrations over 100,000
ug/L included the installation of point-of-entry treatment systems for residential wells and a P&T
system in the source area that was in the pre-design stage at the time of the optimization
evaluation. The planned interim P&T system was to contain the TCE concentration at the
100,000 ug/L contour, but funding for design and construction had been delayed. At the time of
the optimization evaluation, the site team was piloting the use of in-situ chemical oxidation in
the source area using permanganate. The optimization evaluation for this site involved an
original meeting associated with a streamlined evaluation and a follow-up visit to the site. The
evaluation team recommended the installation of a P&T system at a location further
downgradient than previously planned to contain more of the plume, a vapor intrusion analysis
for residences located over the plume, and further consideration of aggressive source
remediation technologies.
Croydon
At the time of the streamlined optimization evaluation for this site, the remedy was reaching the
end of the LTRA period and the site team was preparing to transfer the remedy to the State. The
site had low level TCE concentrations (e.g., approximately 10 ug/L). The recommendations for
improving protectiveness were to implement institutional controls and to extend access to a local
property to allow continued operation of the remedy. The one recommendation to reduce cost
was to reduce the process monitoring. The evaluation also suggested consideration of an exit
strategy, but recognizes that this is best left to the State given the upcoming transfer.
-------
Cryochem
The P&T system for this remedy was designed to capture the contaminant plume upgradient of a
residential area with potable wells, but the demonstration of capture was unclear in site reports.
The recommendations to improve protectiveness were to perform a detailed capture zone
analysis, continue monitoring for MTBE and 1,4-Dioxane to detect if concentrations increase
above discharge standards, and work with local government to implement institutional controls.
The recommendations to reduce cost included reducing the both ground water and process water
sampling and the associated data validation. A recommendation was also made to produce
timelier ground water monitoring reports. The evaluation provided further recommendations
supporting a continuation of a P&T remedy and avoiding source removal activities given the
difficulty and expense of fully characterizing the source area contamination.
Greenwood
This site received a full-scale optimization evaluation in 2003/2004 that included a site visit by
an optimization team. The optimization team found the site operating in a manner consistent
with its ROD for an interim ground water remedy. The P&T system was extracting
contamination and reducing the potential for contaminant migration; however, the plume had not
been fully delineated and plume capture offered by the P&T system had not been fully evaluated.
The optimization evaluation included the following recommendations for improving
protectiveness: resample nearby residential wells, improve plume delineation (specific
monitoring locations were suggested), establish a target capture zone, and check condition of
vapor phase GAC used to treat vapors from process tanks. The recommendations to reduce cost
were as follows: reduce operator labor, address lagoon sediments to reduce solids loading to the
treatment plant, consider bypassing the UV/Oxidation system, streamline the ground water
monitoring program, and review project management and technical support costs.
Recommendations for site closure included recommended alternatives to a RCRA cap that was
planned to address surface soil contamination.
Havertown
This site received a full-scale optimization evaluation in 2003/2004 that included a site visit by
an optimization team. The ROET found the site operating in a manner consistent with its ROD
for an interim ground water remedy. The P&T system was extracting contamination and
reducing the potential for contaminant migration; however, the plume was not fully delineated
and plume capture offered by the P&T system had not been fully evaluated. The optimization
evaluation included the following recommendations for improving protectiveness: continue
efforts to investigate and seal the abandoned sewer line to eliminate this preferential path for
contaminant migration, delineate the plume (specific monitoring locations were suggested),
establish a target capture zone, and modify the treatment plan to reduce downtime. The
recommendations to reduce cost were as follows: bypass two or more of the UV/Oxidation units
to rely on GAC for contaminant removal and consider reductions in labor (particularly project
management and sampling labor) once system reaches steady-state operation.
-------
Hellertown
This site received a full-scale optimization evaluation in 2001 that included a site visit by an
optimization team. The optimization team observed a site with relatively low-level
concentrations of TCE (maximum concentration of approximately 200 ug/L) and a P&T system
that was operating cost-effectively. The degree of plume capture offered by the P&T system was
unclear. The optimization evaluation included the following recommendations for improving
protectiveness: install an additional monitoring well downgradient of the extraction well to
monitor concentration trends and evaluate plume capture, evaluate the cause of recent reductions
in well capacity, continue pursuit of appropriate institutional controls for the site, and investigate
a potential source area that may remain near the former lagoons. The recommendations to
reduce cost were as follows: consider replacing the air stripper with GAC to treat extracted
ground water and reduce the building heat from approximately 65 degrees to approximately 40
degrees to save energy costs.
North Perm 1
This site with PCE contamination in fractured bedrock consists of one extraction well that pumps
approximately 2 gpm. At the time of the streamlined optimization evaluation, the extracted
water generally had a concentration of approximately 10 ug/L, but a monitoring well
downgradient of this well had PCE concentrations over 2 mg/L. The streamlined optimization
evaluation recommended updating the site conceptual, conducting a pump test (instead of the
planned packer test) in the well with the elevated PCE to determine the effect of pumping on the
concentration, and determining the need for further characterization based on the pump test
results. The evaluation also recommended improving the reporting, revising the current pumping
strategy, and considering in-situ remedial options (such as in-situ chemical oxidation) for the
impacted well.
Raymark
A full-scale Remediation System Evaluation was conducted at this site in June 2001,
approximately six years after it had become operational and functional. During that first six
years, the site had been transferred to several RPMs, and a number of protectiveness issues had
developed that the current RPM was addressing. The RSE provided seven recommendations for
improving protectiveness, including surveying and evaluating well-construction data for all site
monitoring wells, creating a potentiometric surface map, delineating plume contamination,
evaluating capture, and evaluating vapor intrusion. No recommendations were made in the cost
reduction category. Recommendations were also made to organize the site data, complete an
O&M manual, and label all site wells.
Saunders
The P&T system at this former wood treating site overlying unconsolidated media has four
extraction wells that pump a total of a approximately 1 gallon per minute. The highest
contamination detected on-site was located at depth downgradient from the original source area,
with no overlying contamination. The streamlined optimization evaluation recommendations to
-------
improve protectiveness included documenting a site conceptual model, conducting a preliminary
capture zone analysis, and potentially installing additional monitoring points. Other
recommendations included reducing the ground water monitoring frequency, improving O&M
reports, and considering other remedial alternatives if continued P&T is not the most appropriate
remedy given a revised conceptual site model.
SCD
At the time of the streamlined optimization evaluation, the remedy for this site was in the design
phase. The remedy would include a barrier wall encircling a large source area and a P&T system
extracting water to maintain an inward and upward gradient. The one streamlined optimization
evaluation recommendation to improve protectiveness included further investigation of the
presence of contamination in the deeper aquifer. The recommendations to reduce cost included
conducting a cost comparison of additional P&T downgradient of the barrier wall with the
proposed in-situ chemical oxidation that was planned for the area, reevaluating the costs of
including a cap for the site, and considering the potential use for on-site regeneration of GAC
rather than the planned off-site regeneration.
10
-------
3.0 FOLLOW-UP AND TRACKING
3.1 FOLLOW-UP PROCESS
The optimization program was designed to include a follow-up process that would continue a
dialogue between the ROET and the site team after the optimization evaluation was conducted.
The follow-up process included two in-person meetings for each site. For the eight new sites,
these follow-up meetings were intended to occur within one year of conducting the original
optimization evaluation. It is expected that the optimization program will continue after this
initial pilot year and that additional follow-up meetings will occur, with the frequency dependent
on the complexity of the site and the site activities that are either planned or being implemented.
Each of the two follow-up meetings was 1.5 hours in length per site and consisted of both the
ROET and the site team. For the eight new sites, the first meeting was generally conducted
within 6 months of submitting the draft optimization evaluation report, and the objectives of the
first meeting were as follows:
Discuss recommendations and finalize the draft optimization report accordingly
Determine progress toward implementing any recommendations
Discuss issues facing the site that were either not discussed during the optimization
evaluation or are new to the site since the optimization evaluation
Identify areas where the site team would benefit from technical assistance provided by
the outside contractor
Discuss potential milestones for tracking site progress toward meeting its remedial
objectives
The second follow-up meeting was generally conducted approximately 3 months after the first
follow-up meeting, and had similar objectives to the first follow-up meeting with the exception
that the optimization evaluation report was considered final prior to the second follow-up
meeting.
The follow-up process was facilitated by the use of a site tracker that is updated with each
follow-up meeting. The site tracker provides the following information:
Updated site information sheet to summarize site costs and other information
Site team and ROET participants
Progress in implementing recommendations that have not yet been fully implemented
11
-------
Additional recommendations that were identified during the most recent follow-up
meeting
Archive of recommendations that have been implemented, including the purpose of each
recommendation, how it was implemented, when it was implemented, and estimated
costs or cost savings associated with implementation
Technical assistance archive in reverse chronological order, including both current and
historical technical assistance provided by the ROET and/or outside contractor (attached
as an appendix)
Original optimization evaluation report (attached as an appendix)
The site trackers for the 12 sites in this project are provided as Attachment D of this report.
3.2 SUMMARY OF OPTIMIZATION PROGRESS
The following table summarizes the progress the Region has made in considering and
implementing the recommendations from the pilot program by the end of the latest follow-up
meeting.
Recommendation
Category
Implemented
In progress
Planned/
Delayed*
Will not be
implemented
Total
Status for Four Old Sites
Effectiveness
Cost Reduction
Technical Improvement
Site Closure
Subtotal for New Sites
13
3
7
3
26
3
o
J
1
1
8
1
2
0
1
4
2
1
0
0
3
19
9
8
5
41
Status for Eight New Sites
Effectiveness
Cost Reduction
Technical Improvement
Site Closure
Subtotal for New Sites
Total
1
11
4
5
21
47
8
1
4
1
14
22
6
0
0
2
8
12
2
1
0
0
3
6
17
13
8
8
46
87
* Also includes those recommendations that are "under consideration " or "deferred to the State ".
3.3 SUMMARY OF COSTS AND COST SAVINGS
The following table summarizes "actual" costs and cost savings associated with implementing
recommendations in each of the recommendation categories. "Actual" costs and cost savings
refers to those values that have been provided by the site team representing costs or savings that
have either been incurred or are expected to be incurred. The table only provides those values
that have been provided by the site teams. Values for several recommendations were not
available at the time this report was prepared. This includes values associated with some
recommendations that have been implemented but costs and/or savings were not broken out as of
the date of this report. Therefore, the table reflects only a snapshot of the costs and savings that
will eventually be incurred/realized.
12
-------
Recommendation Category
Capital Costs for
Implementation*
Change in Annual Costs
after Implementation*
"Old" Sites that Received Full-Scale Evaluations Prior to Entering the Pilot Program
Protectiveness1
Cost Reduction
Technical Improvement
Site Closeout2
Old-Site Subtotal
$630,000
$0
$0
($2,000,000)
($1,370,000)
$0
($54,000)
$0
$0
($54,000)
"New" Sites that Had Not Received Optimization Evaluations Prior to the Program
Protectiveness1
Cost Reduction
Technical Improvement
Site Closeout3
New-Site Subtotal
Total
$175,000
($10,000)
$0
$90,000
$255,000
($1,115,000)
$0
($130,000)
$0
$0
($130,000)
($184,000)
Costs in parentheses indicate cost savings.
* Noted capital costs and changes in annual costs are either actual costs/savings from implementing
recommendations or are reasonable estimates of costs/savings that have not yet been quantified by the site team.
Estimates -were calculated by the ROET but -were considered reasonable by the site team.
1 Several of the high cost protectiveness recommendations -were implemented as part of system modifications
associated -with transitioning remedies from interim remedies to final remedies.
2 A recommendation for removing contaminated surface soil or using an impermeable soil cover as an alternative
to an impermeable RCRA cap at one site -was effectively implemented as EPA -went through the process selecting
and implementing a final remedy. The actual costs of the alternative -were similar to those estimated in the
optimization evaluation for a RCRA cap ($2 million) but -were substantially lower than the EPA final cost estimate
for the RCRA cap (~$4 million) in the Proposed Plan. Therefore, instead of realizing savings of $1.5 million (i.e.,
the difference between $2 million and $500,000) indicated in the table in Section 2.3, the site team realized
savings of $2 million (i.e., the difference between $4 million and $2 million). The savings of $2 million is
reflected in the above table.
3 Capital cost of $100,000 reflects the cost-effective implementation of a recommendation that the ROET estimated
would cost approximately $300,000.
3.4 SUMMARY OF FOLLOW-UP BY SITE
AIWFrank
The streamlined optimization evaluation provided five recommendations to the AIW Frank site
(one for effectiveness, one for cost reduction, two for technical improvement, and one for site
closeout). Between the original evaluation meeting in December 2004 and the end of the pilot
project in Decemeber 2005, the AIW Frank site team had implemented four of the five
recommendations and made progress on implementing the fifth. Highlights of the site team's
effort during the optimization pilot project include the following:
Implementing the cost reduction recommendation involved piloting the use of GAC only
(e.g., discontinuing air stripping) for VOC treatment, interpreting the pilot results, and
13
-------
ultimately bypassing the treatment plant air stripper. The site team estimates that up to
$18,000 will be saved annually from reduced electrical costs. The site team also
indicates that additional savings will likely be realized because GAC changeouts will be
easier, because hardening of the GAC has decreased in the absence of air stripping.
Implementing the site closeout recommendation involved all aspects of applying in-situ
chemical oxidation in the source area, including work plan development and actual
implementation planned for November 2005.
The recommendation to improve protectiveness was to determine an appropriate
discharge and cleanup standard for 1,4-Dioxane. EPA is continuing to work with the
State to determine this standard.
The only additional considerations/recommendations suggested by the ROET during the
tracking/follow-up process were suggestions regarding monitoring and evaluating the results of
the in-situ chemical oxidation, the majority of which would likely occur after the optimization
pilot program comes to an end.
Butz
In the 11-month period between the streamlined optimization evaluation and the last follow-up
meeting for the site, the site team had implemented five recommendations, made significant
progress on two recommendations, and decided against implementing one recommendation. The
implemented recommendations included reducing the ground water monitoring frequency,
eliminating analysis for MNA parameters, receiving timelier ground water monitoring reports,
and continuing with P&T instead of pursuing alternative remedies. A savings of approximately
$10,000 per year will likely be realized. As of the end of the follow-up process, the site team
was abandoning pilot tests of other technologies and appropriately focusing on P&T by
estimating the costs for another extraction well. Approximately $50,000 of funding is
appropriately being reallocated to the installation of a source area extraction well. The
significant progress toward reducing system downtime included a search for a local person to
regularly check and restart the system, if necessary. The significant progress toward
implementing institutional controls included reviewing efforts made by previous RPMs
Crossley
The streamlined optimization evaluation provided three recommendations to this site that is in
the pre-design phase (two for protectiveness and one for site closeout). Between the original
evaluation meeting in February 2005 and the end of the pilot project in December 2005, the site
team and ROET worked together on this complex site (including a site visit) to identify the most
appropriate next steps for the site. Highlights of the site team's effort during the optimization
pilot project include the following:
The site team worked with the ROET during the optimization evaluation meeting, first
follow-up meeting, and a site visit to determine the most appropriate location for an
extraction system and treatment plant.
14
-------
In response to recommendation to evaluate vapor intrusion, the site team tasked the
support team from Fort Meade to develop a work plan for evaluating vapor intrusion at
approximately 20 residences located over the Crossley Farm TCE plume.
The RPM decided to prepare a ROD Amendment documenting the revised location for
the extraction system and treatment plant. The new location would involve installing the
extraction system downgradient from the source area location indicated in the ROD. The
new location will better contain the plume and provide a better opportunity for the area
downgradient of the extraction system to eventually reach cleanup standards.
Because the RPM is planning on including the potential for source area pumping in the ROD
Amendment (in addition to pumping from the downgradient location), the ROET has provided
additional considerations for conducting pump tests to help determine the most appropriate way
of implementing the source area pumping given that an extraction system and treatment system
will be present at a downgradient location. Also during follow-up, the ROET provided
considerations for the vapor intrusion evaluation that will be conducted by the Fort Meade
group.
Croydon
In the 11-month period between the streamlined optimization evaluation and the last follow-up
meeting for this site, the site was preparing for transfer to the State. EPA had discussed the
recommendations with the State but was not able to have them implemented prior to transfer.
The recommendations, such as establishing institutional controls, maintaining site access, and
considering an exit strategy, will be addressed by the State.
Cryochem
In the 11-month period between the streamlined optimization evaluation and the last follow-up
meeting for this site, the site team had implemented (or implemented an alternative to) seven of
the recommendations and was making significant progress on the remaining three
recommendations, including the capture zone analysis, which was a subject of further technical
assistance from the evaluation team, and working toward implementing appropriate institutional
controls. Recommendations that were implemented included reducing the ground water
monitoring frequency and eliminating analysis for metals from the extraction well sampling
program. Savings of approximately $100,000 per year is expected to be realized due to reduced
sampling labor.
Greenwood
The full-scale optimization evaluation conducted prior to the optimization pilot project provided
13 recommendations for this site that currently has an interim remedy (four for protectiveness,
five for cost reduction, two for technical improvement, and two for site closeout). Between the
original evaluation site visit in August 2003 and the second follow-up meeting conducted as part
of the pilot project, the site team had implemented nine of the recommendations, made
significant progress on three of them, and made significant strides toward reaching construction
15
-------
completion for a final remedy. The three recommendations in progress were to continually aim
to eliminate metals removal and the UV/Oxidation units while maintaining protectiveness,
optimizing the ground water monitoring program, and evaluating project management for costs.
As of October 2005, the site team was conducting a pilot test to bypass the UV/Oxidation unit
and was obtaining favorable results for eliminating that process. Savings of approximately
$17,000 will likely be realized. The other two recommendations will be more effectively
implemented once the modifications to the P&T system for the final remedy are completed and
operation is stable. A recommendation for removing contaminated surface soil or using an
impermeable soil cover as an alternative to a RCRA impermeable cap was effectively
implemented as EPA went through the process selecting and implementing a final remedy for
OU-4. The actual costs of the alternative were similar to those estimated by the optimization
evaluation for a RCRA cap ($2 million) but were substantially lower than the costs estimated by
EPA for the RCRA cap (~$4 million), according to the Proposed Plan for the site. Therefore, a
savings of approximately $2 million (e.g., the difference between $4 million and $2 million) was
realized.
Havertown
The full-scale optimization evaluation conducted prior to the optimization pilot project provided
ten recommendations for this site that currently has an interim remedy (four for protectiveness,
two for cost reduction, two for technical improvement, and two for site closeout). Between the
original evaluation site visit conducted in August 2003 and the first round of follow-up
conducted as part of the pilot project, the site team made significant progress on four
recommendations and implemented three others. Highlights of the site team's effort during that
period include the following:
The site team had plugged an abandoned sewer that was acting as a conduit for
contamination to migrate downgradient. They had also investigated the impacts and were
awaiting results from field samples.
The site team had attempted to delineate the plume by following the optimization
evaluation recommendation and installed six new monitoring wells. Sampling of the new
wells indicated additional monitoring wells would need to be installed.
The site team had developed a numerical model to evaluate capture. It was later
determined by the ROET that this model was incorrectly calibrated and that additional
work would be needed for the model to be useful for the site.
The site team had piloted operation of the treatment system with only one UV/oxidation
unit instead of three. The pilot confirmed that the treatment plant would be effective in
this mode, and the treatment plant is now running with one unit, result in savings of
approximately $35,000 per year.
The site team has made several modifications to the treatment plant to improve reliability
and reduce down time.
16
-------
During the second round of follow-up for this site, the site team informed the ROET of results
from recent ground water sampling and implications for the final remedy. As a result of the
sampling, the site team was planning on using a new well location as an extraction point for the
final remedy. The ROET subsequently provided considerations for further evaluating this well
location, including conducting a pump test from the well, re-calibrating the numerical model,
and using the calibrated model to simulate the effects of extracting from the new well.
Hellertown
Of the eight recommendations made at this site in the full-scale RSE conducted in June 2001, the
site team had implemented four of them by the second follow-up meeting, which was conducted
in October 2005. One of these recommendations included lowering the thermostat for the
building temperature to saving heating costs. The site team estimates savings of approximately
$2,000 per year from implementing this recommendation. The site team determined that another
recommendation (replacing the air stripper with GAC) would not be implemented until the air
stripper required replacement or extensive maintenance. By deferring implementation of this
recommendation, the projected savings of $33,000 per year associated with this recommendation
will not be realized, but the capital cost of $125,000 to implement the recommendation will not
be incurred. Two of the remaining recommendations required cooperation from other entities,
including accessing a parcel of land to install monitoring wells for a capture zone evaluation and
working with the property owner to implement institutional controls. The final recommendation
(to establish cleanup levels for the site) is scheduled for completion in 2006 when an ESD will
document MCLs as the site cleanup levels.
North Perm 1
Of the six recommendations made at this site, one has been implemented, three are in progress,
and two are delayed based on the results of implementing other recommendations. The one
recommendation that was implemented was to discontinue pumping at the one extraction well
where low concentrations were observed. The intent is to perform further investigation,
including a pump test, at a nearby well where much higher concentrations are observed. The
results of that investigation, which has not yet been performed, will determine subsequent
actions. Other recommendations include more clearly stating the site conceptual model and
improving semi-annual monitoring reports.
Raymark
Of the 10 recommendations made at this site in the full-scale RSE conducted in June 2001, the
site team had implemented six of them prior to transferring the site to the State in June 2005.
Two of the recommendations will not be implemented. The first was to evaluate the TCE
impacts on the surface water body that receives the treated water, and the Region opted against
this recommendation due to the presence of other non-site-related TCE sources in the area. The
second was to abandon selected wells, which will not be implemented due to a lack of funding
for the site and a priority for other site-related activities prior to site transfer to the State. EPA
will continue with a soil gas survey and installation of an extraction after the site transfer and
will attempt to evaluate the potential vapor intrusion as part of that evaluation. A total capital
cost of $270,000 was reserved for conducting these activities.
17
-------
Saunders
The streamlined optimization evaluation provided six recommendations to the Saunders site
(three for effectiveness, one for cost reduction, one for technical improvement, and one for site
closeout). During the first follow-up meeting, the ROET identified potential problems with the
sampling technique that has been used at the site. The use of bailers have likely resulted in
increased turbidity that may have led to metals and PCP concentrations that were not
representative of ground water and that ground water concentrations may be significantly lower
than previously suggested by the old sampling method. The ROET recommended resampling
with low-flow sampling with an in-line filter. Between the original evaluation meeting in
February 2005 and the end of the pilot project in December 2005, the Saunders site team had
conducted two rounds of sampling with the revised sampling technique. The other
recommendations, which primarily focus on updating the site conceptual model and conducting a
capture zone analysis, have been delayed until the results of the sampling have been reviewed.
The sampling appears to indicate that ground water concentrations are sufficiently high to merit
additional remediation, so the site team is moving forward with the recommendations. The site
team will also move forward with the recommendation to reduce the ground water monitoring
frequency from quarterly to semi-annually. The reduction will likely save approximately
$12,000 per year in labor costs.
SCD
Three of the four recommendations provided were ideas for consideration during design, and the
fourth was a recommendation to investigate the deeper aquifer. In the seven-month period
between the streamlined optimization evaluation meeting and the second follow-up meeting,
which was held in October 2005, the site team made significant progress toward the deeper
aquifer investigation and fully considered the three other ideas. The investigation was being
conducted by the USGS as part of a larger hydrogeological investigation for a cost of $150,000.
During the follow-up process, the evaluation team also provided additional items for
consideration beyond those communicated in the evaluation report.
To simplify the construction process and reduce cost, the evaluation team suggested
constructing the P&T system prior to constructing the full-encircling barrier wall so that
pumping could be initiated before the source area was enclosed. The evaluation team
also provided considerations for contracting the construction teams for the barrier wall.
The evaluation team pointed out that mass removal through P&T alone will provide
substantially more mass removal than what previous DNAPL collection efforts have
demonstrated. Therefore, the evaluation team recommended for cost-effectiveness that
the site team not include DNAPL collection as a focus of the remedy.
The evaluation team also raised a question about the in-situ oxidation planned for the
impacted wetlands. Although the contamination is adversely impacting the wetlands, the
proposed remedy would likely result in more severe impact to the wetlands and would
cost approximately $10 million. Therefore, the evaluation team suggested other potential
alternatives to addressing the wetland contamination and encouraged the site team to
discuss these alternatives with Regional ecologists and toxicologists.
18
-------
4.0 TECHNICAL ASSISTANCE
4.1 SITES WITH TECHNICAL ASSISTANCE
As part of the scope of this project, technical assistance either has been provided at the following
five sites:
Havertown
Hellertown
SCO
Cryochem
Crossley
AIW Frank
4.2 BRIEF SUMMARY OF TECHNICAL ASSISTANCE
Havertown
A technical review was provided on the "Groundwater Model Report" prepared by Val F.
Britton, revision dated July 29, 2004. The report was reviewed by the ROET contractor. The
details are included in the Havertown site tracker (Attachment D of this report).
Hellertown
Technical assistance was provided on the following issues:
Capture zone width and stagnation point calculations
Replacement pump information
Development of an exit strategy
The details are included in the Hellertown site tracker (Attachment D of this report).
SCD
Technical assistance was provided regarding considerations for the following:
Sequencing the construction of the barrier wall and P&T system
DNAPL recovery
Addressing the wetlands contamination
Contracting considerations for construction of the barrier wall
The details are included in the SCD site tracker (Attachment D of this report).
19
-------
Cryochem
A conference call was conducted between RPM, RSE-lite team, and site contractor regarding the
capture zone analysis for the site and the related modeling effort performed by the site
contractor. Subsequently, a written technical review with a suggested approach for a revised
model calibration has been prepared. The details are included in the Cryochem site tracker
(Attachment D of this report).
Crossley
At Crossley, a site visit by the ROET and site team was conducted on September 14, 2005. The
site visit was arranged so that the site team and ROET could walk the site and determine the
most appropriate location for an extraction system and treatment plant. The site team had been
preparing for an extraction system in the source area while the ROET was recommending an
extraction system further downgradient to contain a larger portion of the plume. A consensus
was reached during the site visit. The optimization evaluation report was then finalized to
document recommendations (including extraction system location) that were determined based
on the site visit.
AIWFrank
At AIW Frank, the site conducted in-situ chemical oxidation in response to a recommendation
from the optimization evaluation. This effort was conducted near the end of the optimization
project. For technical assistance, the ROET provided an example decision tree that the site team
could consider for evaluating the results of the in-situ chemical oxidation application.
20
-------
5.0 MILESTONES
5.1 PURPOSE OF DEVELOPING MILESTONES
One pilot project objective was to developed site-specific milestones and a standardized
milestone program to help track the progress of a long-term ground water remedy from the time
it becomes operational and functional until the time cleanup standards are reached. If
successfully implemented at the Regional scale, the milestone program could be launched
nationwide to help all EPA Regions, EPA OSRTI, and the States to track the progress of
approximately 90 Fund-lead P&T systems. The task of developing milestones and a milestone
program was thought to be uniquely suited to the ROET because it included Regional
management, Regional technical staff, EPA OSRTI representatives, and an outside optimization
contractor. By not including a site RPM, the ROET avoids the potential conflict for a site RPM
to develop its own milestones.
5.2 FIRST ATTEMPT TO DEVELOP MILESTONES
The optimization contractor provided a first, preliminary attempt at developing site specific
milestones for each site to serve as a discussion point with the rest of the ROET. This
preliminary attempt helped identify a number of issues that complicates the development of such
milestones. The preliminary attempt at developing milestones had the following components:
Ten site-specific milestones were developed for each site. The first milestone was O&F
and the tenth milestone was site closure.
Although many of the milestones were intended to be met in sequential order, progress to
remediation would be determined by how many of the 10 milestones had been met,
regardless of the order. This would provide more flexibility in how site conditions might
change as progress to site closure is reached.
The ten milestones were designed to be relatively equally spaced between O&F and site
closure so that reaching each milestone was an indicator that significant progress had
been made. This would theoretically reduce the potential for achieving 9 of 10
milestones but still being far from reaching site closure.
Each of the milestones was given a target date for achievement. If a target date was not
achieved, it would be a possible indication that the appropriateness of the remedy should
be reviewed.
A sample set of milestones for one site is provided in the following table to illustrate the concept
behind this preliminary approach to developing milestones.
21
-------
#
1
2
3
4
5
6
7
8
9
10
Milestone
Remedial System Operational and Functional
Remove 50 pounds of TCE; 1,1,1-TCA; and PCE combined
(e.g., estimated mass removal of source area wells after one
to two years of operation)
Observe a 50% decrease in TCE concentrations in MW-
112AandMW-112B (determined as average of four most
recent samples compared to an average of the four first
samples from each well) . . .these are first set of
downgradient performance monitoring wells relative to
presumed capture zone
Observe a 50% decrease in TCE concentrations in MW-
MW-1 13 A and MW-1 13B (determined as average of four
most recent samples compared to an average of the four
first samples from each well) . . . these are second set of
downgradient performance monitoring wells relative to
presumed capture zone
Observe a 50% decrease in TCE concentrations in OB-1I,
MW- 1 08 A, and MW- 111 (determined as average of four
most recent samples compared to an average of the four
first samples collected between October 2000 and April
200 1) . . . source area wells
Observe a 90% decrease in TCE concentrations in OB-1I
and MW-108A (determined as average of four most recent
samples compared to an average of the four first samples
collected between October 2000 and April 200 1) ... source
area wells
Discontinue pump and treat in favor of monitoring only, TI,
or another remedial approach based on appropriate criteria
Maximum concentration of each contaminant of concern
within one order of magnitude of that contaminant's
cleanup standard.
Maximum concentration of each contaminant of concern
within a factor of five of that contaminant's cleanup
standard.
Site closure - Contaminants of concern are below standards
for a specified number of sampling events that is consistent
with EPA Region 3 policy, or based on TI waiver
Status
(Yes/No/In Progress)
Yes
Yes
No
No
No
No
No
No
No
No
Actual/Target
Date
3/29/2001
7/2004
3/2006
3/2011
3/2006
3/2011
3/2016
3/2016
3/2026
Some of the identified issues of using such milestones are as follows:
The assigned dates to most milestones (particularly the later ones) are somewhat arbitrary
unless they are based on simulations with well-calibrated ground water flow and
contaminant transport modeling, and such modeling is not necessary for remediation
purposes at many sites. Therefore, the milestones should not include target dates.
Setting a milestone by comparing a maximum contaminant concentration to some
multiple of the cleanup level (e.g., "Maximum concentration of each contaminant of
concern within a factor of five of that contaminant's cleanup standard") does not
22
-------
necessarily reflect an equivalent milestone for reduction of risk, which is the basis for
Superfund remedial actions.
The use of 10 milestones for each site will lead to some sites with more milestones than
are appropriate.
Despite best efforts, milestones at some sites will be achieved at a faster rate than at
others due to site conditions, and through no fault of a site team, RPM, or Region
milestones may not be reached, suggesting failure or non-performance of EPA staff and
contractors.
Changing conditions may merit the addition of new milestones and/or eliminating certain
milestones, complicating the intended use of the milestones.
The milestones have relatively little relevance to the management of the site at the site or
Regional level. The number of Fund-lead sites in each Region is sufficiently small for
Regional management to track in a more meaningful and comprehensive manner. In
addition, EPA's role in site management changes after LTRA, which is typically 10 years
after O&F. Therefore, life-cycle milestones have relatively little relevance during the
LTRA period and places additional reporting and tracking pressures on the States and
EPA after LTRA.
Several suggestions were made to develop an alternative to the milestones, including developing
criteria to help the EPA RPM track remedy performance during LTRA and/or developing criteria
to help the EPA RPM provide regulatory oversight after LTRA. Because these suggestions were
inconsistent with the original objective of measuring or tracking progress toward site closure,
these were not implemented.
23
-------
6.0 LESSONS LEARNED AND CONCLUSION
This optimization pilot program differed from other optimization efforts that EPA has
implemented to date. Some of those differences and associated lessons learned are discussed
below.
Establishment of a Region Optimization Evaluation Team (ROET)
The establishment of a ROET greatly facilitated the optimization process because it involves
Regional management and Regional technical staff beyond those directly associated with the
site. Although involving this many people complicates scheduling of optimization-related
meetings, the participation of these individuals, in addition to the optimization contractor and
OSRTI representative, means that these individuals are involved in forming optimization
recommendations. The following benefits result:
The RPM knows that management and technical staff support the recommendations, and
the RPM can therefore move forward with implementation immediately.
The recommendations fully consider/incorporate EPA and Regional policy rather than
just the technical considerations provided by an optimization contractor.
Policy or funding obstacles to implementing recommendations can be resolved quickly.
A consistent group of Regional staff become involved with multiple sites and can assist
in transferring knowledge and lessons learned from one site to another.
A presence from the original optimization evaluation remains within the Region after the
contract with the optimization contractor ends.
Recommendations are provided by Regional colleagues (with the assistance of
optimization contractors and a headquarters representative) as part of a team rather than
by an optimization contractor directed by headquarters. As a result, the ROET is seen
more as a resource for improvement rather than as an auditor.
Streamlined Optimization Process Applied to a Portfolio of Sites
The streamlined optimization process involved face to face meetings that were conducted in the
office for multiple sites in one day. In addition, the optimization evaluation reports were shorter,
focusing on key findings and recommendations. This reduced the initial level of effort for
reviewing each site, and if a site visit, further evaluation, technical assistance, or elaboration on
existing recommendations was needed, it could be addressed during the follow-up period and/or
through a generic technical assistance task. As a result, resources could be dedicated to those
sites that needed the most assistance from the ROET rather than devoting equal time to each site
regardless of site complexity. For example, more resources were dedicated to the Havertown
and SCD sites than to the Croydon and Butz sites due to the difference in site complexity and
potential for optimization.
24
-------
Implementation of a Dynamic Optimization Process
Each site received two in-person follow-up meetings after the original optimization evaluation.
This format of multiple in-person meetings provided an improved forum for discussion of the
draft report, follow-up on implementation status for recommendations, and addressing new or
recurring site issues. As a result, technical assistance was requested for 6 of the 12 sites
involved in the program, and new issues/recommendations were identified during follow-up at 6
of the 12 sites.
By the end of the project (a one year time frame), 21 of 46 total recommendations for the new
sites were implemented, and 14 of 46 recommendations were in progress. Therefore, over 75%
of the recommendations for new sites were either implemented or in progress within one year of
making the recommendation. The Region also chose to pursue 81 of 87 recommendations that
were made at all 12 sites. Recommendations that were not implemented were generally either
determined to be impractical after further consideration or were not allowed by the State. These
statistics are comparable or represent a possible improvement over what has been documented
for the nationwide optimization conducted by EPA between 2000 and 2001 as documented in the
Pilot Project to Optimize Superfund-financed Pump and Treat Systems: Summary Report and
Lessons Learned (EPA 542-R-02-008a, October 2002).
Use of Optimization on Interim Sites and Sites in the Design Phase
Of the 12 sites involved in the project, two were interim remedies, one was in the design phase,
and one was in the pre-design phase. Although optimization evaluations in the nationwide effort
had previously focused on operating final remedies, the optimization evaluation process proved
beneficial at these four sites. For one of the interim sites (Havertown), the ROET provided
suggestions for greatly improving the calibration for a model that would be used to design the
final extraction system. For the site in the design phase (SCD), the ROET provided suggestions
for sequencing the construction of the barrier wall and P&T system as well as suggestions for
determining an appropriate remedy for impacted wetlands. For the site in the pre-design phase
(Crossley), the ROET and the site team worked together to determine a more appropriate
location for an extraction system and treatment plant than the one originally identified in the
interim ROD. Therefore, the optimization evaluation process helped identify issues that would
improve effectiveness and ultimately save time and resources before the systems became
operational.
Implementation of Continued Follow-up
This pilot project included two rounds of follow-up for each of the 12 sites. For the original four
sites, these follow-up meetings allowed for tracking of optimization progress, for the ROET to
provide additional recommendations or considerations, and for the opportunity for the site team
to use the ROET as a technical resource. For the eight new sites, the follow-up meetings were
generally helpful for developing a final optimization report and adapting ROET and site team
feedback as new information was collected. Most of the sites benefited from the continued
follow-up and would continue to benefit from future follow-up. However, three of the sites
25
-------
(Croydon, Butz, and Raymark) are either very stable in terms of site activities or have been
transferred to the State and the benefits of additional follow-up meetings with the ROET beyond
these first two meetings would not necessarily outweigh the costs. Future follow-up for most of
the sites would likely be appropriate on an annual basis, but given the complexity and the
number of decisions being made at the Havertown, Greenwood, Crossley, and SCD sites, semi-
annual follow-up might be more appropriate.
Pilot Program Costs and Benefits
This pilot optimization program had a total optimization contractor cost of approximately
$240,000 for project kickoff, optimization evaluations for the eight new sites, two rounds of
follow-up, and a final summary report. As indicated in Section 3.3 of this report,
implementation of recommendations from the pilot program has resulted in a net savings of over
$1 million in capital costs and a net savings of approximately $184,000 per year in annual
operations costs, with the potential for additional savings as more recommendations are
implemented.
It should be noted, however, that approximately $2 million in capital cost savings resulted from
one recommendation that was provided in the pre-design stage for a soil remedy at the
Greenwood site. During the original optimization evaluation conducted in 2003 for this "old"
site, EPA indicated the intent to proceed with an impermeable RCRA cap. The optimization
evaluation provided an alternative to this remedy and several reasons (both pertaining to cost and
remedy effectiveness) to avoid an impermeable cap. Ultimately, EPA went through the formal
remedy selection process, and selected a remedy consistent with the optimization evaluation
recommendation. With or without this single recommendation that has such a large influence on
the cost savings for the Region, the annual savings from the implementation of other
recommendations will more than pay for the cost of the pilot program in one or two years.
During the follow-up process, the ROET also identified the potential to avoid a costly remedy
(approximately $10 million) for impacted wetlands at the SCD site and to opt for a more
appropriate, but lower cost remedy. The ROET input on a downgradient location for the P&T
system at the Crossley site may also result in substantial savings. These potential savings have
not yet been quantified, but the location selected during the optimization process may save the
capital and operating costs for a second P&T system. These examples of cost savings during the
pre-design or design phase at the SCD and Crossley sites, along with the example from the
Greenwood site, demonstrates the value of conducting optimization evaluations prior to system
construction and operation. Furthermore, the example for the Greenwood site demonstrates that
the optimization evaluation process is valuable for remedies other than P&T.
The benefits from this optimization process are not limited to cost savings. Several
recommendations were provided and are either implemented or are being implemented to
improve the remedy protectiveness. For example, recommendations for improving the capture
zone analyses at Hellertown and Cryochem were provided and are now being implemented. The
plumes at Havertown and Greenwood are better delineated and, as a result, will likely be
appropriately addressed by final remedies. A larger portion of the plume at Crossley will be
contained and the residences overlying the plume will be evaluated for potential vapor intrusion.
The remedy at AIW Frank will operate more efficiently due to a streamlined treatment plant, and
26
-------
site closure may be reached faster as the result of aggressive source remediation with in-situ
chemical oxidation.
Application to Other Regions
The pilot conducted in this Region is easily transferable to other Regions. In other Regions, a
similar program could apply to more remedies than just operating P&T systems because of the
benefits noted in this pilot project for P&T remedies in the design (or pre-design) stage and non-
P&T remedies. The following aspects of the project would likely be replicated if applied in
another Region:
Creation of a ROET that involves Regional management, Regional technical staff,
OSRTI representative, and a technical contractor
Inclusion of all (or most) Fund-lead sites in the Region
Streamlined optimization evaluations and two follow-up meetings as implemented here
A generic technical assistance allocation
A final report for presentation to both the Region and OSRTI
General Comments and Feedback from Regional Staff
Feedback on the pilot project from Region III staff was solicited by Regional management. A
total of 11 RPMs participated in the project (one RPM managed two of the 12 sites), and eight of
those RPMs provided feedback. A total of four Regional hydrogeologists participated in the
project, and one of the site hydrogeologists provided feedback. The feedback is summarized
below.
Among the comments received from the nine responders, the following benefits of the
project were cited:
o Discussions were multi-sided. They included the RPM rather dictating
instruction to the RPM.
o A second or fresh set of eyes provided detailed input and implementable
recommendati ons.
o The project provided a focused, comprehensive review of a site's remedy and
progress.
o Management was involved in and supportive of the site reviews and optimization.
o Expert site-specific input was not biased by previous site experience.
o Optimization contractor provided independent engineering expertise not normally
available to Regional staff.
o Cost and potential for cost reduction was reviewed.
Among the comments received from the nine responders, the following drawbacks of the
project were cited:
27
-------
o If the project ended at the pilot, it would be too short.
o The review team should have been brought in earlier.
o Two of the responders noted that having the follow-up meetings conducted by an
optimization contractor seemed to place that contractor in a position of authority
(potentially intimidating to the RPM and/or Regional hydrogeologist).
o One responder noted that sometimes the whole site needs to be reviewed rather
than just the P&T system.
o One responder noted that the review team appeared "annoyed" if progress was not
made after several reviews.
o One responder noted that stronger expertise in bedrock remediation and sufficient
time for the optimization contractor to analyze geology would have been helpful.
Eight of the nine responders recommended that the optimization process continue in
Region III beyond this pilot project. The ninth responder did not provide direct feedback
on this topic. Of those eight responders, six suggested continued involvement of the
outside contractor, and two suggested review continue only with internal Regional
personnel. One of the responders cited the need for strong upper-level management
participation.
All nine of the responders recommended that a similar process be implemented in the
other EPA Regions, but one of these nine responders noted that each Region would need
to be committed to following through.
28
-------
ATTACHMENT A:
KICKOFF MEETING SIGN-IN SHEET AND AGENDA
-------
Region III Pilot Optimization Program Kickoff Meeting
November 3, 2004
Meeting Attendees
Name
Email
Region 3 Staff and Management
Alexis Alexander (Hanlon)
Norm Kulujian
Mindi Snoparsky
Kathy Davies
Walter Graham
Charlie Root
Romuald Roman
Jim Feeney
Bruce Rundell
Anthony Dappolone
Peter Schaul
Jill Lowe
Haiilon.alexisfflicpagov
Kuluiiaiuiorm:'fljcpa.gov
Snoparskv.mindiฎ.cpa.aov
Davies.kalhvฎepa.aov
Graharn.waltcr,ฎ,cpjy>ov
Root.charlic(S.cpa.fiov
Roman.romiialdijSicoa.gov
Fccncv.iimfolcpa.aov
Rundcll.braccffllcpa.aov
Dappolonc.antlionvt&cpa.gpv
Schaul.pctcrฎ.cpa.aov
Lowc.iill@fioa.gov
EPA OSRTI Staff
Kathleen Yager
Steven Chang
Yagcr.kalMccn@coa.gov
Chang. stcvcn@.coa. aov
Optimization Contractor Staff
Rob Greenwald rerccnwaldฎecotransinc.com
Peter Rich ptick'fligcolransinc.com
Doug Sutton dsultonฎ.aeotransinc.com
-------
Proposed Kickoff Agenda and Related Preparation
Region-Based Optimization Program for Region 3
Revised October 7, 2004
Purpose of this Document
A pilot project for a Region Based Optimization Program for Region 3, described below, is
expected to begin within several weeks. An early milestone in this project will be a project
kickoff meeting. The purpose of this document is to propose an agenda for the kickoff meeting,
and identify items that should be addressed to prepare for the meeting. A preliminary schedule
for the entire pilot project is also provided.
Overview of the Pilot Program
EPA OSRTI and EPA Region 3 intend to pilot a Region-based optimization program of the
Superfund-fmanced pump and treat (P&T) sites in Region 3. The pilot program will consist of
the following components:
Conducting streamlined optimization evaluations (reduced in cost and scope
relative to a full optimization evaluations) at Fund-lead sites in Region 3
Developing a formal follow-up/tracking program, and implementing the follow-up
at the sites receiving streamlined evaluations, plus four sites that previously
received full evaluations (2 follow-ups per site)
Providing technical assistance based on requests of the RPMs and findings during
follow-up
Demonstrating a systematic approach to capture zone analysis at two sites
The project will be implemented by GeoTrans, who will also participate as a member of the
"Regional Optimization Evaluation (ROE) team" that will include members of Regional
management, Regional technical staff, and a representative from Headquarters.
Anticipated Tasks and Proposed Project Schedule
A preliminary project schedule is provided below. It will be discussed in detail at the Kickoff
Meeting, and may be modified at that time. The purpose of presenting this preliminary schedule
in this document is to identify a general project time-line.
Proposed Kickoff Agenda and Related Preparation
Revised October 7, 2004
-------
Preliminary Schedule
Pre-Meeting Preparation Items
(the party responsible for each task is provided in parentheses)
Pre-meeting tasks
- gather information on sites to be evaluated (Region/HQ)
- preliminarily establish members of ROE team (Region)
- outline of streamlined evaluation report (GeoTrans)
- preliminary evaluation/follow-up/tracking program (GeoTrans)
- develop list of candidate sites of capture zone assistance (Region/HQ)
- establish available dates thru Dec '04 for ROE (All)
Kickoff Meeting
Optimization Evaluations
Follow-up Round #1 - Previously evaluated sites
Draft Status Report #1
Initiate Capture Zone Assistance (2 sites)
Site Specific Technical Assistance
Follow-up Round #2 - Previously and newly evaluated sites
Draft Status Report #2
Follow-up Round #3 - Newly evaluated sites
HQ Briefing (Washington DC)
Draft Final report
Finalized Report
Proposed
Completion Date
up thru 1 1/3/04
1 1/3/04
before 1/15/05
before 1/15/05
before 1/31/05
before 12/31/04
as requested
before 4/1 5/05
before 3/3 1/05
before 8/3 1/05
before 6/30/05
before 9/1 5/05
before 10/15/05
Kickoff Meeting: Proposed Agenda
A proposed agenda for the project kickoff meeting is presented as Exhibit 1.
Proposed Kickoff Agenda and Related Preparation
Revised October 7, 2004
-------
Exhibit 1: Proposed Meeting Agenda
Region-Based Optimization Program for Region 3
Proposed Agenda for Project Kickoff Meeting
Date: November 3, 2004
EPA Region 3, Philadelphia, PA
9:00 AM to 12:00 PM
open plans for lunch after the meeting
9:00-9:15 Introductions
9:15- 9:30 Project description and objectives (Region 3/OSRTI)
9:30 - 9:45 Discuss composition and responsibilities of ROE Team (open discussion)
9:45 -10:00 Discussion of Fund-lead sites to be included in project (Region 3)
10:00 - 10:20 Open discussion
BREAK
10:30 - 10:45 Outline of Streamlined Optimization Evaluation Report (GeoTrans)
10:45 - 11:00 Plan for Tracking and Follow-up (GeoTrans)
11:00- 11:15 Finalize remaining logistics regarding first three streamlined evaluations
11:15- 11:30 Review/Update Preliminary Project Schedule (open discussion)
11:30-12:00 Open Discussion
12:00- Open plans for lunch
Note: The capture zone demonstration aspect of the project will be discussed if time allows or a
conference call will be scheduled for the capture-zone related discussions on a later date.
Proposed Kickoff Agenda and Related Preparation
Revised October 7, 2004
-------
Suggested Items to prepare for Kickoff Meeting
A substantial amount of preparation will be appropriate to make the Kickoff Meeting an efficient
use of time. Some of this preparation will be performed by personnel in the Region, and some
will be performed by GeoTrans. Recommended items associated with this preparation are
indicated in the above project schedule and are discussed below.
Gather Information on Sites to be Evaluated (Region)
An information gathering form previously developed for OSRTI accompanies this document.
The information on this form should be completed for each of the Fund-lead P&T sites in Region
3 that will be part of this project.
In addition, although the optimization evaluations will take place after the kickoff meeting, the
scheduling and logistics for these optimization evaluations can begin prior to the meeting to
expedite the project schedule. The site teams (i.e., the RPM, the site hydrogeologist, and the site
contractor) should identify potential dates and/or conflicts for holding the optimization
evaluations. The optimization evaluations would require a half-day meeting at the Region 3
office in Philadelphia. Comprehensive site information for these sites should also be gathered
and provided to GeoTrans. This comprehensive site information typically includes the
following:
Remedial Investigation Report
Feasibility Study Report
Record of Decision (ROD)
ROD Amendments and Explanation of Significant Differences (ESDs), if any
Design documents and O&M manual
Recent O&M reports (weekly, monthly, etc.)
Recent semi-annual and annual reports
Previous 5-year reviews
Any other reports or documents the site managers feel are pertinent to the site
The transfer of these site documents to GeoTrans can be coordinated with Doug Sutton from GeoTrans
(732-409-0344, dsutton@geotransinc.com). Original documents can be sent to GeoTrans. GeoTrans will
copy what is needed and return the originals to Region 3 in a timely manner.
Preliminarily Establish Members of ROE Team (Region)
The Region should preliminarily determine who will represent the Region on the ROE team.
This should be done prior to the kickoff meeting, so scheduling can be performed to allow all of
these individuals to be present for the kickoff meeting. The participants on the ROE Team will
be finalized at the Kickoff meeting.
Proposed Kickoff Agenda and Related Preparation
Revised October 7, 2004
-------
Outline of Streamlined Evaluation Report (GeoTrans)
GeoTrans will develop an outline for the streamlined evaluation reports, which will be presented,
discussed, and finalized at the kickoff meeting.
Preliminary Evaluation/Follow-up/tracking Program (GeoTrans)
GeoTrans will develop an approach for following up on the evaluations at each site and tracking
progress. This will be presented, discussed, and finalized at the kickoff meeting.
Develop List of Candidate Sites of Capture Zone Assistance (Region)
The Region should determine if there are already good candidate sites for the demonstration of
capture zone analysis (i.e., where improved capture zone analysis is a high priority). If so, a brief
presentation should be prepared for each such site. There may be time to discuss these candidate
sites during the meeting. If there is no time during the meeting, a conference call will be
scheduled in November for this purpose.
Establish Available Dates thru December '04 for ROE (All)
To the extent possible, dates requiring ROE Team participation (such as optimization
evaluations) should be finalized at the kickoff meeting. Therefore, all ROE Team members
(including GeoTrans) should determine open dates through December 15, 2004 and be prepared
to commit to scheduled meeting days through December 15, while at the kickoff meeting.
Proposed Kickoff Agenda and Related Preparation
Revised October 7, 2004
-------
ATTACHMENT B:
BASELINE FORMS FOR GATHERING SITE INFORMATION
-------
Date:
Filled Out By:
A. Site Location, Contact Information, and Site Status
1. Site name
2. Site Location (city and State)
3. EPA Region
4a. EPA RPM
5a. State Contact
4b. EPA RPM Phone Number
5b. State Contact Phone Number
4c. EPA RPM Email Address
5c. State Contact Email Address
5. Is the groundwater remedy an interim remedy or a final remedy? Interim Final
6. Is the site EPA lead or State-lead with Fund money?
EPA
State
B. General Site Information
1 a. Date of Original ROD for Ground Water Remedy
Ib. Dates of Other Ground Water Decision Documents (e.g., ESD, ROD Amendment)
2a. DateofO&F
2b. Date for transfer to State
3. What is the primary goal of the P&T system
4. Check those classes of contaminants that are
contaminants of concern at the site.
Contaminant plume containment
Aquifer restoration
Containment and restoration
Well-head treatment
VOCs (e.g., TCE, benzene, etc.)
SVOCs (e.g., PAHs, PCP, etc.)
metals (e.g., arsenic, chromium, etc.)
other
5. Has NAPL or evidence of NAPL been observed at the site? Yes
No
6. What is the approximate total pumping rate?
7. How many active extraction wells
(or trenches) are there?
8. How many monitoring wells are regularly
9. How many samples are collected
from monitoring wells or piezometers
each year? (e.g., 40 if 10 wells are
sampled quarterly)
10. How many process monitoring samples
(e.g., extraction wells, influent, effluent, etc.)
are collected and analyzed each year? (e.g., 24
if influent and effluent are sampled monthly)
11. What above-ground treatment processes are used (check all that apply)?
Air stripping
Carbon adsorption
Filtration
Off-gas treatment
Ion exchange
Metals precipitation
Biological treatment
UV/Oxidation
Reverse osmosis
Other
12. What is the approximate percentage of system downtime per year? 10% 10 to 20% >20%
-------
C. Site Costs
1. Annual O&M costs
O&M Category Actual Annual Costs
for FY03
Labor: project management, reporting,
technical support
Labor: system operation
Labor: groundwater sampling
Utilities: electricity
Utilities: other
Consumables (GAC, chemicals, etc.)
Discharge or disposal costs
Analytical costs
Other (parts, routine maintenance, etc.)
O&M Total
Actual Annual Costs Projected Annual
forFY04 Costs for FY05
The O&M total should be equal to the total O&M costs for the specified fiscal years, including oversight from
USAGE or another contractor. For costs that do not fit in one of the above cost categories, include them in the
"Other" category. If it is not possible to break out the costs into the above categories, use the categories as best
as possible and provide notes in the following box.
2. Non-routine or other costs
Additional costs beyond routine O&M for the specified fiscal years should be included in the above spaces. Such
costs might be associated with additional investigations, non-routine maintenance, additional extraction wells, or
other operable units. The total costs billed to the site for the specified fiscal years should be equal to the O&M
total plus the costs entered in item 2.
Notes on costs:
-------
D. Five-Year Review
1. Date of the Most Recent Five-Year Review
2. Protectiveness Statement from the Most Recent Five-Year Review
Protective Not Protective
Protective in the short-term Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below
E. Other Information
If there is other information about the site that should be provided please indicate that information in the space
below. Please consider enforcement activity, community perception, technical problems to be addressed, and/or
areas where a third-party perspective may be valuable.
-------
Date:
Filled Out By:
A. Site Location, Contact Information, and Site Status
1 . Site name 2. Site Location (city and State)
4a. EPA RPM 5a. State Contact
3. EPA Region
4b. EPA RPM Phone Number 5b. State Contact Phone Number
4c. EPA RPM Email Address 5c. State Contact Email Address
5. Is the groundwater remedy an interim remedy or a final remedy? Interim | | Final I I
6. Is the site EPA lead or State-lead with Fund money? EPA | | State I I
B. General Site Information
1 a. Date of Original ROD for Ground Water Remedy
2a. Date of Projected O&F
3 . What is the primary goal of the designed P&T
system (select one)?
1 1 Contaminant plume containment
1 1 Aquifer restoration
1 1 Containment and restoration
1 1 Well-head treatment
lb. Dates of Other Ground Water Decision Documents (e.g., ESD, ROD Amendment)
2b. Date for Projected Transfer to State
4. Check those classes of contaminants that are
contaminants of concern at the site.
CD VOCs (e.g., TCE, benzene, etc.)
n SVOCs (e.g., PAHs, PCP, etc.)
1 1 metals (e.g., arsenic, chromium, etc.)
1 1 other
5. Has NAPL or evidence of NAPL been observed at the site? Yes I I No I I
6. What is the designed total pumping rate?
7. How many extraction wells
(or trenches) are there based on
design?
9. How many samples are proposed to
be collected from monitoring wells or
piezometers each year? (e.g., 40 if 10
wells are sampled quarterly)
1 1 . What above-ground treatment processes are prop
1 I Air stripping
1 1 Carbon adsorption (liquid phase only)
1 I Filtration
1 1 Off-gas treatment
1 I Ion exchange
8. How many monitoring wells are
proposed to be regularly sampled?
10. How many process monitoring samples
(e.g., extraction wells, influent, effluent, etc.)
are proposed to be collected and analyzed
each year? (e.g., 24 if influent and effluent
are sampled monthly)
>osed (check all that apply)?
1 I Metals precipitation
1 1 Biological treatment
O UV/Oxidation
1 1 Reverse osmosis
O Other
12. What is the anticipated percentage of system downtime per year? 10% O 10-20%[
m >2o% o
-------
C. Site Costs
1. Projected Annual O&M costs
O&M Category
Labor: project management, reporting,
technical support
Labor: system operation
Labor: groundwater sampling
Utilities: electricity
Utilities: other
Consumables (GAC, chemicals, etc.)
Discharge or disposal costs
Analytical costs
Other (parts, routine maintenance, etc.)
O&M Total
Projected Annual Costs for
System Start-up (e.g., year 1)
Projected Annual Costs for
Steady-State Operation
(e.g., after year 1)
The O&M total should be equal to the total O&M costs for the specified fiscal years, including oversight from
USAGE or another contractor. For costs that do not fit in one of the above cost categories, include them in the
"Other" category. If it is not possible to break out the costs into the above categories, use the categories as best
as possible and provide notes in the following box.
2. Non-routine or other costs
Additional costs beyond routine O&M for the specified fiscal years should be included in the above spaces. Such
costs might be associated with additional investigations, non-routine maintenance, additional extraction wells, or
other operable units. The total costs billed to the site for the specified fiscal years should be equal to the O&M
total plus the costs entered in item 2.
3. Estimated costs for system design
and/or construction
Notes on costs:
-------
D. Five-Year Review
1. Date of the Most Recent Five-Year Review
2. Protectiveness Statement from the Most Recent Five-Year Review
I | Protective I I Not Protective
Protective in the short-term Determination of Protectiveness Deferred
3. Please summarize the primary recommendations in the space below
E. Other Information
If there is other information about the site that should be provided please indicate that information in the space
below. Please consider enforcement activity, community perception, technical problems to be addressed, and/or
areas where a third-party perspective may be valuable.
-------
ATTACHMENT C:
TYPICAL AGENDA FOR AN OPTIMIZATION EVALUATION MEETING
-------
AGENDA FOR STREAMLINED OPTIMIZATION EVALUATION MEETINGS
AT
FUND-LEAD SITES WITH OPERATING PUMP AND TREAT SYSTEMS
Region 3 Pilot
The streamlined optimization evaluation, unlike a full-scale Optimization Support Evaluation (OSE)
or Remediation System Evaluation (RSE), does not include a full-day site visit with the site
stakeholders. Rather, the evaluation team gathers pertinent information through a review of site
documents and a two-hour meeting with the site stakeholders at Region 3 in Philadelphia.
Immediately after the meeting with site stakeholders, the evaluation team then spends one hour alone,
summarizing the information from the meeting in a template format. Using this approach, two
meetings can be conducted in one day.
It is assumed that, prior to the meeting, all participants are familiar with the site through either their
daily work at the site or through reviewing site documents.
The following agenda has been developed to facilitate the evaluation meeting. The listed times are
approximate based on a two-hour (120-minute) meeting and will vary by site. Much of the discussion
will result from specific questions that the evaluation team has for the site stakeholders based on a
review of site documents.
Minute
Discussion Topic
0-5
Introductions - The evaluation team leader introduces the team and the concept
behind the evaluation. Each call participant will be asked to introduce themselves
by stating their name, affiliation, and role at the site.
Each participant will be asked to provide their name, affiliation, title, role at the
site, and contact information on a sign-in sheet.
6- 10
The evaluation team indicates any site-specific issues that they want to discuss
during the meeting, based on their preliminary review of the documents.
11-15
Site conceptual model - The evaluation team leader will ask someone
knowledgeable about the site (typically the RPM or site contractor) to provide a
brief description of the site conceptual model, including the following:
Contaminant sources
Contaminant fate and transport
Previous and current remedies
Remedy goals
Streamlined Optimization Evaluation Meeting Agenda
-------
Minute
Discussion Topic
16-45
Protectiveness - The following items are discussed:
Receptors and exposure pathways
Receptor sampling
Plume capture
Performance monitoring
Institutional controls
Site fencing, health and safety, etc.
46-60
Extraction/Injection Systems - The following items are discussed:
Confirmation of extraction system components and specifications
Performance relative to design specifications
Associated sampling and analysis
Maintenance, fouling, etc.
61-80
Treatment System - The following items are discussed:
Confirmation of treatment system components and specifications
Performance relative to design specifications
Downtime
Operator responsibilities and level of effort
Chemicals and material usage
Utilities
Process monitoring
Water discharge and waste disposal
Exceedances, accidental releases, etc.
Recurring technical problems
Opportunities for system simplification
81-100
Costs - The following items are discussed:
Confirmation and clarification of provided cost information
Estimated life-cycle costs
Actual costs vs. original cost estimates
Primary cost drivers
Opportunities for reducing cost
Challenges or obstacles to implementing cost reduction opportunities
101-115
Site closure - The following items are discussed:
Potential alternative remedies
Remaining source removal or source control needs
Exit strategy for system
Exit strategy for various system components
Appropriate site-specific milestones towards site closure
116-120
Debriefing and Action Items - The evaluation team provides a time frame for
submitting a report. The evaluation team may also ask for additional information
to be forwarded. The evaluation team provides a schedule for follow-up.
Streamlined Optimization Evaluation Meeting Agenda
-------
ATTACHMENT D:
OPTIMIZATION FOLLOW-UP SITE TRACKERS FOR THE 12 FUND-LEAD SITES
[PROVIDED AS INDIVIDUAL REPORTS]
------- |