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recommendations rse optimization implementation oswer progress updated site osrti sites remedy operating effectiveness system cost technical ground rpms report team
^ OSWER 9283.1-31
S EPA-540-R-08-004
jr July 2008
Ground Water Remedy Optimization
Progress Report: 2006 - 2007
Office of Superfund Remediation and Technology Innovation
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1.0. Introduction
1.1 Purpose
The purpose of this report is to provide a summary and analysis of progress toward
implementation of optimization recommendations at Superfund-financed ground water pump and
treat (P&T) sites. The report summarizes successful implementation strategies, opportunities for
improvement, barriers to implementation, and changes in project costs as a result of
optimization. The report also identifies sites requiring no further follow-up and discusses related
initiatives underway at Headquarters and in the Regional offices.
The main body of the report is accompanied by an appendix containing a summary of
optimization recommendations by Region and site name. Regions are encouraged to review the
appendix to assess progress in their respective programs. This summary report generally
represents progress on optimization recommendations that were implemented during calendar
years 2006 and 2007 at 29 sites. The report contains updated information for 20 sites where
implementation has continued since the last summary report, as well as nine sites subject to more
recent reviews which are being reported for the first time. The name, location and review date
for these sites are listed in Exhibit 1.
1.2 Project Background
The Office of Solid Waste and Emergency Response (OSWER) developed the pilot
Fund-lead P&T optimization initiative as part of the FY2000-FY2001 Super/and Reforms
Strategy (OSWER 9200.0-33; July 7, 2000). Optimization is intended to facilitate systematic
review and modification of existing P&T systems to promote continuous improvement, and to
enhance overall remedy and cost effectiveness. In the Superfund program, optimization
evaluations should be accomplished using the Remediation System Evaluation (RSE) process, a
tool developed by the U.S. Army Corps of Engineers.
The pilot phase of the optimization initiative demonstrated that this effort offers
measurable benefits in the form of cost savings and improved remediation systems. In August
2004, the Office of Superfund Remediation and Technology Innovation (OSRTI) developed the
Action Plan for Ground Water Remedy Optimization ("2004 Action Plan") (OSWER 9283.1- 25;
August 25, 2004) to further implement important lessons learned from the pilot phase and fully
integrate optimization into the Superfund cleanup process where appropriate. Among other
things, the Action Plan envisions the development of routine progress reports concerning the
implementation of recommended system changes.
1.3 Sites Subject to Optimization Reviews
There are fewer than 75 Superfund-financed P&T systems operating nationwide. To
date, the Superfund program has conducted an optimization evaluation at 52 sites, nearly all from
this universe of Fund-financed P&T systems.
July 2008
OSWER 9283.1-31
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The approach for selecting sites to receive an optimization review typically includes a
review of annual operating costs, the age of the system, and concerns for remedy effectiveness or
system efficiency. Ground water remedies with the highest annual operating costs likely offer
the greatest opportunities for cost savings and increased efficiency. RSEs may also be
appropriate for systems that have been operating for two to four years, in order to maximize
early opportunities for improvements and cost savings.
Regardless of annual operating costs or the age of the system, an optimization review
may be valuable at sites where there are concerns about the effectiveness of the remedy or the
efficiency of the P&T system. An RSE may also help address recommendations in Five-Year
Reviews that identify similar concerns.
1.4 Monitoring Implementation Progress
Each site that receives an optimization review is subject to follow-up, typically in the
form of annual conference calls between OSRTI and the Region, for at least two years after the
RSE report is finalized. These follow-up discussions highlight the status of recommended
changes and obstacles to implementation that require additional attention. Continuous oversight
of progress at RSE sites helps maximize the benefits of optimization, identify lessons learned,
and provide technical assistance.
RSEs generate a number of suggestions, ideas, and recommendations which should be
discussed and evaluated. Regions should weigh many factors including, but not limited to,
technical feasibility, short-term implementation issues, long-term benefits, public and State
acceptance, contractual requirements, effectiveness and availability of funding, when
determining whether to implement optimization recommendations. Disagreements regarding the
implementation of a particular recommendation are possible, and may be elevated to
management for resolution.
If RPMs have questions regarding implementation of complex RSE recommendations,
technical assistance is available from many sources, including Regional technical support staff,
OSRTI staff and the RSE team, the EPA laboratories through the Technical Support Project, and
the U.S. Army Corps of Engineers.
July 2008
OSWER 9283.1-31
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Exhibit 1. Sites subject to implementation monitoring in 2006 and/or 2007
EPA
Region
1
2
3
4
5
6
7
8
9
10
State
NH
MA
NY
NY
NJ
NJ
NY
NJ
NY
PA
VA
NC
sc
NC
FL
WI
MI
IN
IN
MI
WI
—
NE
KS
KS
CO
CA
WA
WA
OR
Site Name
Savage Municipal Water Supply
Groveland Wells
Claremont Polychemical
Brewster Well Field
Bog Creek Farm
Higgins Farm
Circuitron Corp.
Ellis Property
GCL Tie & Treating
Havertown PCP
Greenwood Chemical Co.
FCX, Inc. (Statesville Plant)
Elmore Waste Disposal
Cape Fear Wood Preserving
American Creosote Works, Inc. (Pensacola)
Oconomowoc Electroplating
Ott/Story/Cordova Chemical Co.
Douglas Road/Uniroyal, Inc., Landfill
Reilly Tar & Chemical Corp. (Indianapolis)
Peerless Plating Co. Inc.
Penta Wood Products
No sites for this reporting period
Cleburn Street Well
57th & North Broadway
Ace Services
Central City, Clear Creek
Modesto Ground Water Contamination
Boomsnub/Airco
Wyckoff Co. /Eagle Harbor
Northwest Pipe & Casing
Fiscal Year
of Review (a)
2001
2002
2001
2002
2002
2003
2004
2006
2006
2003
2003
2000
2000
2004
2006
2000
2001
2004
2004
2005
2006
—
2001
2006
2007
2007
2001
2002
2004
2007
Reporting
Status (b)
updated
updated
updated
updated
updated
updated
updated
new
new
updated
updated
updated
updated
updated
new
updated
updated
updated
updated
new
new
—
updated
new
new
new
updated
updated
updated
new
(a) Date refers to date of review; RSE reports may be finalized months later, following multiple-party review. All
RSE reports may be accessed online via http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm.
(b) Updated sites were included in previous progress reports; progress at new sites is being reported for the first
time.
July 2008
OSWER 9283.1-31
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2.0 Summary of Implementation Progress
2.1 Overview
Each RSE results in an improved understanding of the operating P&T system and
identified a number of opportunities for improvements in efficiency and effectiveness. The RSE
reports specifically highlight recommendations in the following four categories:
• recommendations to improve remedy effectiveness,
• recommendations to reduce operating costs,
• recommendations for technical improvement, and
• recommendations to expedite site closure.
The annual follow-up discussions between OSRTI and the Remedial Project Manager
(RPM) assess progress with the implementation of each recommendation contained in the RSE
reports. Exhibit 2 summarizes progress in each of the four categories of recommendations. The
subsequent sections provide an analysis of implementation progress and highlights of site-
specific progress. The data included in this report represents only the sites that are still subject to
the follow-up process described above (all sites in Exhibit 1). Sites that completed the follow-up
process, as documented in previous progress reports, are no longer included in the calculations.
Exhibit 2. Status of optimization recommendations
Types oi
Recommendations
Remedy
Effectiveness
(92 total)
Cost Reduction
(112 total)
Technical
Improvement
(89 total)
Site Closure
(33 total)
Overall Progress
(326 total)
Implementation Status
Implemented
73%
(67)
65%
(73)
65%
(58)
45%
(15)
65%
(213)
In
progress
12%
(11)
8%
(9)
10%
(9)
18%
(6)
11%
(35)
Planned
5%
(5)
3.5%
(4)
3%
(3)
9%
(3)
4.5%
(15)
Declined
4%
(4)
19%
(21)
16%
(14)
9%
(3)
13%
(42)
Deferred
to
PRP/State
1%
(l)
<1%
(1)
2%
(2)
6%
(2)
2%
(6)
Under
Consideration
4%
(4)
3.5%
(4)
3%
(3)
12%
(4)
4.5%
(15)
Note: Numbers in parentheses represent actual number of recommendations, used to calculate rounded percentages.
July 2008
OSWER 9283.1-31
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RPMs have made positive efforts to address approximately 95% of all recommendations
made to date; fewer than 5% of the RSE recommendations remain to be addressed. While the
proportion of recommendations either Declined or Deferred to other parties has remained
relatively consistent over time, there has been steady improvement in the percentage of
recommendations moving from Under consideration to the Implemented or In progress
categories.
2.2 Implementation of Remedy Effectiveness Recommendations
A thorough review of remedy effectiveness is a principal element of OSRTI's
optimization initiative. Recommendations to improve effectiveness predominantly suggest more
rigorous evaluation of the extraction and subsurface portions of the remedy rather than the
above-ground treatment portion. The most common recommendations in this category generally
relate to plume delineation, additional source area characterization, and improved data collection
and/or reporting. More recent evaluations have increasingly identified issues related to
institutional controls and vapor intrusion.
Nearly three-quarters (73%) of remedy effectiveness recommendations have been
implemented and another 17% are in progress or planned for the near-term. The implementation
of remedy effectiveness recommendations continues to be a high priority for RPMs; this
category has consistently had the greatest proportion of recommendations implemented since
national reporting began.
Highlight: Success with Remedy Effectiveness Recommendations
Ace Services Site (Colby. KS): The RSE recommended that the site team modify the
method of evaluating the capture zone of the P&T system. Since the RSE, the site team
has improved potentiometric surface maps by eliminating measurements from operating
extraction wells, monitored concentration trends at downgradient locations, and
conducted a flow budget analysis. All lines of evidence suggest complete capture of the
contaminated plume.
57th and North Broadway Site (Wichita. KS): The RSE recommended that the site team
pursue characterization of an additional source area utilizing direct push sampling
techniques. The site team conducted three sampling events and successfully identified a
new PCE source area. As a result, EPA is working with a newly identified PRP to
implement a combined soil vapor extraction (SVE)/air sparging removal action within the
next year. The site team was able to conduct the characterization work for less than
half the estimated cost provided in the RSE report.
2.3 Implementation of Cost Reduction Recommendations
RSE recommendations pertaining to cost reduction may cover many aspects of system
operation, including the selection of treatment technologies, operator and laboratory labor, and
project management. A common recommendation for cost reduction typically calls for site
managers to streamline ground water or process monitoring once a system is operating at steady-
state.
5 July 2008
OSWER 9283.1-31
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RSEs continue to identify opportunities to reduce onsite labor without sacrificing remedy
effectiveness. Such reductions may be expected following system shakedown or automation,
when a remedy is operating at steady-state. Furthermore, some treatment components become
inefficient or unnecessary as a result of changing site conditions, or due to conservative estimates
during the design phase. Simplifying a treatment system under such conditions has resulted in
cost savings associated with reduced material usage, utilities, and labor. More recent evaluations
have increasingly recommended modifications to the extraction well network, such as reducing
pumping rates or terminating pumping in select wells.
Approximately 65% of cost reduction recommendations were implemented during this
reporting period. This demonstrates a significant improvement over the previous reporting
period (53.5% implemented in 2005). Of the four categories of recommendations, the cost
reduction category is characterized by the greatest percentage of recommendations declined; one
common rationale for not pursuing a potential cost savings opportunity is State or local
resistance to altering the method or location of discharging plant effluent.
While OSRTI and the States continue to report reduced operating costs and improved
efficiencies, documenting precise cost savings and expenditures as a direct result of RSE
implementation continues to pose a challenge. To maximize cost savings for EPA, it may be
beneficial to implement recommendations that offer the greatest potential reduction in annual
operating costs as early as possible during the LTRA phase.
Highlight: Success with Cost Reduction Recommendations
Boomsnub/Airco Site (Hazel Dell. WA): The RSE team recommended that the site team
and responsible party consider at least partial reinjection of treated ground water at the
site, to improve system effectiveness and reduce operating costs.
The site team first confirmed that reinjection would not spread the contaminated plume
or otherwise degrade ground water quality. The site team then began to work with the
responsible party to design and construct an infiltration gallery to accept treated water.
The infiltration gallery will eliminate the fees associated with discharging to the local
POTW. Operating costs have been reduced by $350,000 per year (50%); over the life of
the remedy, the new discharge scheme is expected to save $3.5 million.
2.4 Implementation of Technical Improvement Recommendations
Technical improvement recommendations cover a wide range of items to improve overall
site operations. As Exhibit 2 demonstrates, nearly two-thirds (65%) of these recommendations
have been fully implemented. RPMs continue to implement the majority of these
recommendations shortly after the RSE site visit highlights the opportunity for improvement.
These recommendations are generally easy to implement, require little up front funding, and are
not typically contingent on other recommendations.
July 2008
OSWER 9283.1-31
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Examples of technical improvement recommendations include the following:
• Reconfigure components of the treatment train,
• Clean, repair or replace faulty equipment,
• Rehabilitate fouled extraction or injection wells,
• Improve or streamline data evaluation protocols, and
• Reformat O&M reports.
2.5 Implementation of Site Closure Recommendations
RSEs continue to identify opportunities to accelerate progress toward achieving final
cleanup goals and eventual site closure. These recommendations most commonly involve
developing a clear and comprehensive exit strategy and/or evaluating alternate remedial
approaches. Developing an exit strategy typically involves confirming that clear and appropriate
cleanup goals were established in the Record of Decision, then determining the specific data and
criteria to be used to evaluate if goals are met such that some or all of the system can be shut
down. If the intermediate goals and milestones are not met, RPMs should then consider
alternatives to the current system. This may include alternate technologies to replace P&T, or to
supplement it with more aggressive source removal.
Nearly half (45%) of recommendations associated with site closure have been
implemented, which is a substantial improvement over the last progress report (at which time
only 26% percent of these recommendations were complete). As demonstrated in previous
progress reports, exit strategy recommendations are often considered after effectiveness and cost
reduction recommendations are implemented. The use of a supplemental or alternative remedial
approach may require funding that was not previously budgeted, revised contracts, and updated
decision documents (e.g., an amended Record of Decision). For these reasons, the data continue
to show a lower percentage of these recommendations implemented, and a larger percentage still
under consideration.
Highlight: Success with Recommendations to Expedite Site Closure
Circuitron Site (East Farmingdale. NY): The RSE team recommended that a previously
unidentified source area be identified and remediated in order to accelerate progress
toward site closure. The RSE team suggested that air sparging and SVE would be more
cost effective than other approaches that would require pilot testing (such as nutrient
injection or chemical oxidation).
EPA's Environmental Response Team (ERT) provided support at the site, successfully
identifying two storm drains that served as ongoing sources near the monitoring well with
the highest contaminant concentrations. An in-well vapor stripping unit began operation
in early 2008 and is expected to operate for approximately one year in order to reach
cleanup goals. The ground water P&T system has been shutdown in the interim, to avoid
interference with the source remedy.
July 2008
OSWER 9283.1-31
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2.6 Sites Requiring No Further Follow-Up
As shown in Exhibit 2, RPMs continue to demonstrate a commitment to the
implementation of RSE recommendations. In fact, the optimization process is complete at a
number of sites as a result of the successful implementation or thorough consideration of all RSE
recommendations. OSRTI is no longer conducting annual follow-up discussions at these
particular sites, though assistance is still available to site managers in the event that any
optimization-related issues arise.
OSRTI has also completed the follow-up process for a number of sites where EPA is no
longer responsible for operating or optimizing the P&T system. This includes sites where the
State now has responsibility for operation and maintenance of the remedy, or where the P&T
system is no longer operating. Exhibit 3 highlights the 11 sites that completed the follow-up
process in 2006 or 2007.
Exhibit 3. Sites requiring no further follow-up
Rationale
Successful implementation and/or thorough consideration of
all RSE recommendations
Fund-lead Long-Term Response Action (LTRA) is complete
P&T system is no longer operational
Site Name
Bog Creek Farm
Circuitron Corp.
Claremont Polychemical
Cleburn Street Well
Elmore Waste Disposal
Greenwood Chemical Co.
Groveland Wells
Penta Wood Products
Brewster Well Field
FCX, Inc. (Statesville Plant)
Oconomowoc Electroplating
3.0 Related Initiatives
.1
Long Term Monitoring Optimization
OSRTI continues to provide technical support and training on the topic of long-term
monitoring optimization (LTMO) for ground water. Site-specific technical support has been
provided to five regions and training on the theory and application of LTMO has occurred in
nine Regions. Typically the scope of technical assistance involves compiling historical
groundwater monitoring data and performing statistical and geostatistical analyses, using a
variety of methods to determine if samples are being collected in the optimal locations (spatial
analysis) and at the optimal frequencies (temporal analysis).
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OSWER 9283.1-31
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At most of the sites evaluated, increases and decreases in temporal and spatial sampling
are recommended based on changing site conditions, changes in the plume dimensions,
discovery of new source terms or high uncertainty areas, and changes to the regulatory
requirements. Generally, RPMs have found the analyses very helpful in providing a thorough
evaluation of the monitoring network in support of Five Year Reviews, negotiations with
responsible parties, or to justify changes to the monitoring program. Additional technical
support and completion of trainings in all ten Regions are anticipated through calendar year
2008.
3.2 Training
OSRTI developed a training course for site managers related to the optimization process
and its many fiscal and environmental benefits. The training also provides an overview of the
roles and responsibilities of RPMs, technical support staff and State project managers in all
phases of optimization, from site selection to implementation of recommended system
improvements. In 2006 and 2007, this training was delivered in five Regional offices, at each of
the annual National Association of Remedial Project Managers (NARPM) training conferences,
and at the 2006 Association of State and Territorial Solid Waste Management Officials
(ASTSWMO) conference.
4.0 Future Plans
OSRTI expects to continue to fund independent, technical experts to conduct additional
RSEs and streamlined RSE-Lites each year. OSRTI will continue to select sites for future
reviews based on annual operating costs, the age of the system, and concerns for remedy
effectiveness and system efficiency. Regions should contact OSRTI to recommend any sites that
may benefit from an optimization review.
OSRTI will continue to utilize the existing process for follow-up discussions in order to
monitor progress with the implementation of RSE recommendations. Follow-up will continue at
all sites, with the exception of those identified in Section 2.6 of this report. RPMs may request
technical assistance to aid in the implementation of system changes.
5.0 References
5.1 Internet Resources
OSRTI, Post-Construction Program Area
• Guidance for post-construction completion activities, with optimization project updates
• http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm
OSRTI, Hazardous Waste Clean-Up Information (CLU-IN) web site
• Site-specific RSE reports and recommendations
• http://www.clu-in.org/optimization
July 2008
OSWER 9283.1-31
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U.S. Army Corps of Engineers, Hazardous, Toxic and Radioactive Waste Center of Expertise
• RSE checklists and scope of work, provided by developers of the RSE tool
• http://www.environmental.usace.army.mi1//l tm_rse.htm
Federal Remediation Technologies Roundtable
• Case studies, conference materials and more, compiled by an inter-agency workgroup
• http://www.frtr.gov/optimization.htm
5.2 Guidance and Fact Sheets
A Systematic Approach for Evaluation of Capture Zones at Pump and Treat Systems
(EPA 600-R-08-003; January 2008)
A Cost Comparison Framework for Use in Optimizing Ground Water Pump and Treat Systems
(EPA 542-R-07-005; May 2007)
Optimization Strategies for Long-Term Ground Water Remedies (with Particular Emphasis on
Pump and Treat Systems) (EPA 542-R-07-007; May 2007)
Options for Discharging Treated Water from Pump and Treat Systems (EPA 542-R-07-006;
May 2007)
Effective Contracting Approaches for Operating Pump and Treat Systems (OSWER 9283.1-
21FS / EPA 542-R-05-009; April 2005)
O&M Report Template for Ground Water Remedies (With Emphasis on Pump and Treat
Systems) (OSWER 9283.1-22FS / EPA 542-R-05-010; April 2005)
Cost-Effective Design of Pump and Treat Systems (OSWER 9283.1-20FS / EPA 542-R-05-008;
April 2005)
Action Plan for Ground Water Remedy Optimization (OSWER 9283.1-25; August 25, 2004)
Pilot Project to Optimize Superfund-financed Pump and Treat Systems: Summary Report and
Lessons Learned (OSWER 9283.1-18; November 2002)
Elements for Effective Management of Operating Pump and Treat Systems (OSWER 9355.4-
27FS-A; November 2002)
Implementation of RSE Recommendations: Technical Assistance Resources Available to RPMs
(January 2002)
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OSWER 9283.1-31
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5.3 General Project Documentation
2005 Annual Progress Report for Ground Water Remedy Optimization (OSWER 9283.1-28;
December 2006)
2004 Annual Progress Report for Ground Water Remedy Optimization (OSWER 9283.1 -27;
August 2005)
Groundwater Pump and Treat Systems: Summary of Selected Cost and Performance
Information at Superfund-financed Sites (EPA 542-R-01-021a; December 2001)
Super fund Reform Strategy, Implementation Memorandum: Optimization of Fund-lead Ground
Water Pump and Treat (P&T) Systems (OSWER 9283.1-13; October 31, 2000)
11 July 2008
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