United States
Environmental
Protection Agency
Office of Emergency
and Remedial
Response (OERR)
EPA 540-R-01-00
OSWER 9355.0-76
March 2001
Updating Remedy
Decisions
at Select Superfund Sites
Biannual Summary
Report
FY 1998 And FY 1999
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SUMMARY REPORT FY98 AND FY99
Executive Summary (FY98 and FY99)
During the last two years of implementation, Updating Remedy Decisions has been characterized by the U.S.
General Accounting Office (GAO) as one of EPA's most successful Superfund reforms. In FY98 and FY99,
EPA updated approximately 160 remedies, reducing estimated future cleanup costs by more than $710 million.
Other key successes and findings include the following:
< Most remedy updates completed during FY98 and FY99 were the result of additional technical information
gathered as part of the remedy design process. A small number of remedy updates were the result of
non-technical changes in applicable, relevant and appropriate requirements (ARARs), land use, or required
cleanup levels. Another small number of remedy updates were the result of State input or community
preference which focused on either technical or non-technical modifications to the remedy.
< EPA tracked all remedy updates during FY98and FY99; most of these updates were reform-related, while
others were not. In FY98, the total estimated cost savings were in excess of $280 million, of which over
$245 million was based on scientific and technological advancements. For remedy updates completed in
FY99, the total estimated cost savings was in excess of $430 million, of which over $420 million was
based on scientific and technological advancements. There were 10 remedy updates in FY98 that resulted
in cost increases totaling an estimated $57.2 million, and there were 14 remedy updates in FY99 that
resulted in cost increases totaling an estimated $58.0 million.
< Estimated cost savings for 98 individual remedy updates during FY98 and FY99 ranged from a negligible
amount to over $87 million, with most remedy updates generating savings under $10 million. There were
also 24 remedy updates that resulted in estimated cost increases of over $120 million, with a majority
under $2 million.
< Remedy updates generally occurred in the remedial design phase of the cleanup process and were more
likely to be documented with Explanations of Significant Differences (ESDs) than Record of Decision
(ROD) Amendments. Over the two-year period, there were 105 ESDs and 54 ROD Amendments repre-
senting remedy updates with both cost savings and increases.
< Most remedy updates during FY98 and FY99 were initiated by parties outside of EPA (e.g., potentially
responsible parties (PRPs), States, communities, Federal facilities). Over the two-year period, parties
outside of EPA initiated 66 updates and EPA initiated 55 updates (these numbers do not include 38
updates initiated by more than one party).
< Over the two-year period, the most commonly addressed medium was soil (99 updates) followed by ground
water (58 updates). Nine other media types were addressed by remedy updates during FY98 and FY99.
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SUMMARY REPORT FY98 AND FY99
Table of Contents
Executive Summary i
1.0 Introduction 1
2.0 FY98 and FY99 Results 1
Exhibit 2.1: Estimated Remedy Update Savings by Region for FY98 and FY99 2
Exhibit 2.2: Estimated Savings Per Remedy Update for FY98 and FY99 2
Exhibit 2.3: Updates by Medium for FY98 Through FY99 3
Table 2A: Number and Kind of Remedy Updates for FY98 and FY99 3
3.0 Remedy Update Process 3
Exhibit 2.4: Remedy Update Initiators in FY98 and FY99 3
3.1 Determination of Remedy Update Type 4
Table 2B: ESDsvs. ROD Amendments in FY98 and FY99 5
3.2 State/Tribal and Community Roles 6
3.3 Remedy Review Duration 6
Exhibit 2.5: Approximate Review Time for Remedy Updates in FY98and FY99 7
4.0 Lessons Learned 7
4.1 Benefits 7
4.2 Site Examples 7
5.0 Conclusion 10
Acknowledgments
Appendix A: Summary of Updated Remedy Decisions for FY98 and FY99
Appendix A.1: Summary of Updated Remedy Decisions for FY98
Appendix A.2: Summary of Updated Remedy Decisions for FY99
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SUMMARY REPORT FY98 AND FY99
1.0 Introduction (FY98-FY99)
Updating Remedy Decisions, announced in the third round of Superfund Reforms in October 1995, is one of a
broad range of administrative reforms undertaken to improve efficiency, speed, and fairness of the Superfund
program. Specifically, the Reform encourages the Regions to revisit selected remedy decisions at sites where
significant new scientific information, technological advancements, or other considerations will protect human
health and the environment while enhancing overall remedy cost effectiveness.
This report contains an evaluation of remedy updates completed during FY98 and FY99. For remedy updates
completed in FY96 and FY97, see the document, "Updating Remedy Decisions at Select Superfund Sites,
Summary Report, FY1996 and FY1997," July 1998, OSWER Directive 540-R-98-017 at EPA'swebsite: http://
www.epa.gov/oerrpage/superfund/programs/reforms/docs/urd96-97.pdf. The Summary Report for FY96
and FY97 contains the background information of the Reform, a description of the Reform, the process for
implementing the Reform, and Regional implementation plans from each of the ten EPA Regions.
This report:
• Provides a summary of Superfund sites where remedies have been updated during FY98 and FY99;
• Highlights estimated future cost reductions (cost savings) or cost increases expected to result from
updated remedies; and
• Presents stakeholders with information on the role of remedy updates in improving Superfund implementa-
tion.
EPA sought to encourage remedy updates that would incorporate such new information into existing site
cleanups. As a whole, these reforms were implemented to make Superfund faster, fairer, and more efficient.
It is important to emphasize that this initiative does not signal any variations in the Agency's current policies
regarding site cleanup, including policies regarding remedy selection, treatment of principal threats, preference
of permanent remedies, establishment of cleanup levels, or the degree to which remedies must protect human
health and the environment. EPA remains committed to the protection of public health, welfare, and the environ-
ment.
2.0 FY98 and FY99 Results
EPA completed approximately 159 remedy updates in FY98 and FY99, saving over $710 million in
estimated site cleanup costs, while at the same time creating increases in estimated site cleanup costs
of about $115 million.
Updates during FY98 resulted in a total estimated cost savings of over $280 million, of which over $245 million
resulted from updates of the kind identified in the Reform Guidance. Updates during FY99 resulted in a total
estimated cost savings of over $430 million, of which over $420 million resulted from updates of the kind
identified in the Reform Guidance.
(See the Reform Guidance, "Superfund Reforms: Updating Remedy Decisions," OSWER Directive 9200.2-22,
dated September 27,1996, at EPA'swebsite: http://www.epa.gov/oerrpage/superfund/programs/reforms/
remedy/index.htm.)
The estimated cost savings per update ranged from a negligible amount to $87 million, with all EPA Regions
reporting savings in each year reviewed. Exhibit 2.2 shows the amount of estimated savings by fiscal year.
(Note: Exhibit 2.2 may not include all remedy updates from FY98 and FY99 because of limitations on EPA
Regional accessibility to remedy update information.)
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SUMMARY REPORT FY98 AND FY99
Most of the remedy updates generated savings
of less than $10 million per update, as shown
in Exhibit 2.2. (Note: Cost estimates for
several remedy updates are either unavailable
to EPA or incomplete at the time of this writing.
These are labeled NA/TBD (Not available/To be
determined) in Appendices A, A.1, and A.2.)
EPA Regions also reported updated remedies
which generated cost increases during FY98
and FY99. The FY98 cost increases for 10
remedy updates totaled $57.2 million. The
FY99 cost increases for 14 remedy updates
totaled $58.0 million. Most of these remedy
updates generating estimated cost increases
during FY98 and FY99 are less than $2 million
per update. The remedy update cost increase
for FY98 and FY99 occur in 7 different EPA
Regions and no EPA Region has more than 5
increases over the two-year period.
Exhibi
Saving
140
120
100
"tn"
o 80
! -
40
20
0
t2.1: Estimated Remedy Update
s by Region for FY98 and FY99
%
li
?
I
SI
1
ft
•
i „- I L
i . m i r-m i 1 1 I [_i
1 2345 6789 10
Region
DFY98
• FY99
Based on 159 sites.
Exhibit 2.2: Estimated Savings Per
Remedy Update for FY98 and FY99
no savings (14%)
increases (15%)
>$10M-$20M
>$1M-$10M(29%)
<=$1M(21%)
NAfTBD (9%)
Recent advances in the area of soil and
ground water science and remediation made
these types of decisions good candidates for
remedy updates. Exhibit 2.3 shows that
during FY98 and FY99, updates of soil
remedies were the most common (99
updates), followed by ground water remedies
(58 updates. The remaining updates per-
tained to nine other media, as depicted in
Exhibit 2.3. These media are consistent with
media typically found at contaminated
Superfund sites.
More detailed information regarding remedy
updates can also be found in Appendices A,
A.1, and A.2. Specific remedy updates are
listed by Region and by site, and include the
following information:
• Type and date of remedy update;
• Update initiator;
• Media involved;
• State and community involvement;
• Estimated resource demands;
• Estimated cost savings or cost increases; and
• Summary of remedy change and factual basis.
Table 2A depicts the number and kind of remedy updates that were completed in FY98 and FY99. It shows that
not all remedy updates generated cost savings or cost increases. In some cases, the remedy updates gener-
ated neither cost savings or cost increases; in other cases, the numbers are yet to be determined or are
unavailable at the time of compiling this report. The data do not differ significantly from FY98 to FY99.
D no savings (23)
D <=$1M(33)
D >$1M-$10M(46)
I increases (24)
>$20M (9)
NA/TBD (14)
>$10M-$20M (10)
Based on 159 sites.
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SUMMARY REPORT FY98 AND FY99
Exhibit 2.3: Updates by Medium for FY98 and FY99
Medium
Soil
Ground Water
Sediment
Debris
Other
Sludge
Surface Water
Leachate
Air
Gas
Solid Waste
FY98
5O
31
6
9
4
3
2
1
1
1
O
FY99
49
27
1 1
3
3
3
1
2
2
2
0
Total
99
58
17
12
7
6
3
3
3
3
O
The information in Exhibit 2.3 is
based upon 159 sites. However,
since remedy updates often
involve more than one medium at a
site, the total number of updates
by medium is more than 159.
Table 2A: Number and Kind of Remedy Updates for FY98 and FY99
Total # of Remedy Updates
# Updates With Estimated Savings
# Updates With No Savings
# Updates With Estimated Increases
# Updates NAorTBD
FY98
76
48
12
10
6
FY99
83
50
11
14
8
Total
159
98
23
24
14
3.0 Remedy Update Process
After a remedy decision has been
completed at a site (i.e., a ROD is
signed), new information may be
received or generated that could
affect how the remedy selected in
the ROD should be implemented.
This information may be supplied
by a PRP, a Federal agency
conducting the cleanup, the
support agency (e.g., another
Federal agency or State/Tribe), or
the public or other interested
parties. Data for FY98 and FY99
(see Exhibit 2.4) indicate that 66
remedy updates were initiated by
parties outside of EPA (e.g.,
PRPs, States, communities,
Exhibit 2.4: Remedy Update Initiators for FY98
State (4%) City/Public (1 %)
Fed. Fac. (3%) RRp (27«,/o)
Joint (33%)
EPA (32%)
Remedy Update Initiators for FY99
Fed. Fac. (5%) State (5%) City/Public (1%)
Based on 76 sites
Joint (16%)
PRP (36%)
EPA (37%)
Based on 83 sites
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SUMMARY REPORT FY98 AND FY99
Federal facilities) compared to 55 updates initiated by EPA. In addition, 38 remedy updates have joint initiators
because information arrived simultaneously from several different parties. Exhibit 2.4 shows that the relative
percentage of remedy update initiators were not significantly different from FY98 to FY99.
Although the types of new information that could affect remedy decision-making vary widely, the Reform
Guidance recommends that EPA pay particular attention to information which shows that:
• Updating the remedy may result in a more cost-effective cleanup;
• Physical limitations imposed by the site or the contaminants may warrant changes in the cleanup goals; or
• Site conditions may warrant reducing the scope of the site monitoring after cleanup.
As outlined in the Reform Guidance, the basic process that Regions should use to consider proposed remedy
updates consists of three steps: identification and prioritization, technical review, and implementation.
• Identification and Prioritization involves assessing the update request to determine the type of change
(e.g., remedial method, cleanup standards, cleanup area), the resources required to fully evaluate it, and
any potential increase or decrease in protectiveness or cost. To ensure that the Region's rationale for
prioritizing update reviews is clear and equitable, Regions are encouraged to carefully track all requests for
remedy updates. Review and consideration of potential remedy updates should not result in any delays in
the completion of work products or other remediation activities required by the existing ROD and enforce-
ment instruments (e.g., unilateral administrative orders (UAOs) or consent decrees (CDs)).
• Technical Review evaluates the site-specific information supporting both the current remedy and the
update request to determine whether or not the remedy update was warranted. This information is typically
collected by the site's lead entity (e.g., the Federal agency, Federal facility, PRP, State, or Tribe).
• Implementation involves preparing and filing the necessary documentation (a note or memorandum to the
Administrative Record file, an ESD, or a ROD Amendment) to support the update, consulting with the
State and community, and physically conducting the updates at the site.
3.1 Determination of Remedy Update Type
In order to categorize the update, remedy update teams ask the following questions:
• Scope- Does the update alter the scope of the remedy (e.g., the physical area of the response,
remediation goals to be achieved, or type and volume of wastes to be addressed)?
• Performance-Would the update alter the performance (e.g., treatment levels to be attained, methodology
used to achieve cleanup goals, and new technology not considered in the original ROD) and thus raise
concerns about the protectiveness or long-term effectiveness of the remedy?
• Cost - Does the update alter remedial costs and are the changes in costs of such a nature that they could
not have been anticipated based on: (1) the estimates in the ROD; and (2) the recognized uncertainties
associated with the selected remedial alternative?
Based on this evaluation, and depending on the extent or scope of the modification being considered, the lead
agency must determine the type of update involved (e.g., nonsignificant or minor, significant, or fundamental
change to the scope, performance, or cost of the original remedy). An aggregation of nonsignificant or signifi-
cant changes could result in a fundamental change overall. Post-ROD updates fit into one of these categories:
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SUMMARY REPORT FY98 AND FY99
• A nonsignificant or minor change usually arises during design or construction when modifications are
made to the functional specifications of the remedy to optimize performance and minimize cost. Such
changes may affect the type or cost of materials, equipment, facilities, services, and supplies used to
implement the remedy. Minor changes might include a slight increase in the volume of treated soil, a
change in disposal location, or a modification in ground water monitoring specifications.
• A significant change generally involves incremental change to a component of a remedy that does not
fundamentally alter the overall remedial approach. A significant change might involve an increase of over
50 percent in the volume of soil to be remediated, a change in reasonably anticipated land use following
the remedy, or a change in an ARAR that has impacts on cleanup levels and other parameters.
• A fundamental change involves an appreciable change or changes in the scope performance, and/or cost
of a remedy or may involve a number of significant changes that together have the effect of a fundamental
change. Fundamental changes result in a reconsideration of the waste management approach (e.g.,
change in the primary remedy for the wastes, residual risk, cleanup technology) selected in the original
ROD and must include a formal public comment period. A fundamental change might involve selecting a
different primary treatment technology because of community preference, discovery of additional contami-
nants, or the determination that less treatment is needed than originally expected.
For more information on remedy update type, see "A Guide to Proposing Superfund Proposed Plans, Records of
Decision, and Other Remedy Selection Decision Documents, "OSWER Directive No. 9200.1-23P (July 1999).
Enforcement decision documents may also need to be modified, depending on the type of remedy update and
the language in the order or consent decree, if there is an order or consent decree.
The type of change will determine which document EPA uses to update the remedy: a memorandum or note to
the Administrative Record for a nonsignificant or minor change; an ESD for a significant change; or a ROD
Amendment for a fundamental change. Table 28 indicates that there were 105 ESDs and 54 ROD Amendments
completed during FY98 and FY99.
Table 2B: Types and Percentages of Remedy Updates for FY98 and FY99
ESDs
ROD Amendments
FY98
53 (70%)
23 (62%)
FY99
52 (30%)
31 (38%)
Total
105
54
In general, remedy updates tend to occur during remedy design and represent a significant but not fundamental
change to the remedy. Consequently, most remedy updates correspond to at least one of the following situa-
tions: the scope of the remedy has changed (e.g., volume increase or decrease); the performance of the remedy
can be modified or optimized (e.g., change in disposal or discharge point); or there is a more cost effective way
to implement the remedy.
In some situations, additional contamination is identified or the original remedy does not meet the required
cleanup levels specified in the ROD. In those cases, the determination for an updated remedy may result in
estimated cost increases.
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SUMMARY REPORT FY98 AND FY99 ••••••••••••••••••••
3.2 State/Tribal and Community Roles
State/Tribal Roles
States play an important role in the modification of remedy decisions. Both the NCR Section 300.515 and the
Model CERCLA RD/RA Consent Decree (which forms the basis for most consent decrees) provide an opportu-
nity for States to review and comment on specified steps in the remedy selection. Agreements between EPA
and States, including contracts, may require modification following an update to a remedy. Furthermore, the
Model Consent Decree states that EPA will provide the State with a reasonable opportunity to review and
comment on any proposed modifications. Additional information regarding the role of States and supporting
agencies in the remedy modification process can be found in "A Guide to Preparing Superfund Proposed Plans,
Records of Decision and Other Remedy Selection Decision Documents,"OSWER Directive 9200.1-23P (July
1999).
Native American Tribes are afforded substantially the same treatment as States with respect to certain provi-
sions of CERCLA (see CERCLA Section 126; NCP Section 300.505). A Federally-recognized tribal government,
with responsibilities including governmental functions such as environmental protection and jurisdiction over a
Superfund site, can be treated essentially the same as a State, (see NCP Section 300.515).
Community Roles
Most remedy updates in FY98 and FY99 involved State participation and/or community involvement. Although
the initiation of a formal public comment period is required only in the case of a fundamental update (i.e., ROD
Amendment), most remedy updates, regardless of their significance, have a substantial community involve-
ment component (see NCP Section 300.435(c)(2)(i) and (ii)). For example, documents pertaining to the site,
including any information on remedy updates, are placed in the Administrative Record or at the site repository
located within the area of the site (e.g., local library). Other activities, including a public availability session,
public meetings, issuance of fact sheets about the site, and the release of an amended proposed plan, may
allow the surrounding community and other interested parties an opportunity to learn more about the site and
present their opinions on remedial activities. Refer to the individual site summaries in Appendices A.1 and A.2
for specific activities related to State participation and community involvement that were part of the remedy
update process for each update completed during FY98 and FY99.
3.3 Remedy Review Duration
Reviewing site-specific material and completing the ESD or ROD Amendment, as demonstrated in Exhibit 2.5,
took less than a year for an overwhelming majority of the remedy updates completed during FY98 and FY99.
Of note, is a slight increase in the number of remedy updates with extended review periods. An examination of
sites with longer review periods suggests that the review durations were influenced by:
• A lengthy, but important public involvement phase;
• An extensive verification/pilot test period following the discovery of new performance, technical, or toxico-
logical data;
• The discovery of unexpected contamination late in the remedy design phase; or
• A redefinition of land use.
Specific examples of remedy changes whose reviews lasted more than one year, that are summarized in
Exhibit 2.5, may be found in Section 4.2 of this document.
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SUMMARY REPORT FY98 AND FY99
Exhibit 2.5
Approximate Review Time for Remedy
Updates in FY98
0 L^"—LJ-^B—LL^m—u^—u Based on 76 sites.
<1 YEAR >1-2 >2-3 >3-4 >4
YEARS YEARS YEARS YEARS
Approximate Review Time for Remedy
Updates in FY99
Based on 83 sites.
1 YEAR >1-2 >2-3 >3-4 >4
YEARS YEARS YEARS YEARS
4.0 Lessons Learned
During the last two years of reform implementation, EPA has gained insight into ways of successfully updating
site remedies. The following sections detail information collected regarding reform benefits, site examples, and
comments from stakeholders.
4.1 Benefits
This Reform has been very successful in bringing past decisions in line with current science and technology.
By doing so, these updates improve the cost effectiveness of site remediation while ensuring reliable short- and
long-term protection of human health and the environment. The quantifiable results of this Reform have been
announced in EPA's testimony before Congress, described in private industry evaluations of Superfund reforms,
and included in a report by the U.S. General Accounting Office. Of additional note is EPA's overwhelmingly
positive record of responding to remedy update requests made by outside parties.
4.2 Site Examples
In many cases, remedies were updated because of a decrease or increase in contaminant volume or because
of an inability to achieve desired results in a test of the ROD-selected treatment or contaminant technology
during the remedial design phase of the cleanup. Although all updates described in Appendix A represent site-
specific situations, it is possible to use some as site examples of the remedy update situations that occurred
during FY98 and FY99.
Updates Based on New Technology
Some updates were the result of new technology that was not considered in the original remedy. For instance,
the results of an air sparging pilot test lead to a change in the remedy at the Hastings Ground Water Contami-
nation site in Nebraska. Conventional soil vapor extraction and a ground water pump and treat system were
replaced with air sparging near the source area and areas of the ground water plume with high concentrations
contamination, which increased the rate of volatile organic removal from ground water via soil vapor extraction.
Now, the ground water cleanup may be completed sooner than it would have under the original pump and treat
remedy with a result of $1.0 million in estimated savings.
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SUMMARY REPORT FY98 AND FY99
In some cases, the performance of a remedy is discovered to be less effective than originally expected. For
example, after two years of vacuum extraction, the original remedy performance declined attheTibbetts Road
site in New Hampshire. At the conclusion of extraction and treatment, a remedy update resulted because it
was found that residual concentrations were above cleanup levels. These residual concentrations were found to
be amenable to treatment with phytoremediation and bioremediation. Site cleanup levels remain unchanged and
the remedy update may result in $140,000 in estimated cost savings.
Updates Based on New Performance Data
New performance data can provide the needed information for updating remedies. At Bofors Nobel, Inc. in
Michigan, the changes documented in the ESD were based on new information received subsequent to the
issuance of the ROD, which required cleanup to soil performance standards and ground water treatment and
discharge to a publicly-owned treatment works (POTW). A new calculation of performance standards was
based on an error correction, revised risk factors, and revised guidance that resulted in undisclosed cost
savings.
Another example of a remedy update based on new performance data occurred at the Woodlands site in New
Jersey, where traditional ground water pump and treat was replaced with air sparging/soil vapor extraction and
natural attenuation. The remedy update resulted from a BTAG memo which indicated that the ground water
pump and treat system would dewater nearby wetlands. During remedial design, the PRP successfully identi-
fied alternatives that would meet ROD objectives at a much lower cost and the resultant estimated savings
exceeded $87.0 million.
Coordinating the Update
Some remedy updates involve coordination among EPA, other Federal agencies, and State and local govern-
ment agencies. For example, at MCAS Cherry Point in North Carolina, EPA coordinated the remedy update
with the State and the Federal facility. The ROD specified the number of extraction wells in the original remedy,
but this changed during implementation of the remedial design and remedial action. The expanded extraction
system in the remedy update can treat all areas within a particular operable unit above a certain threshold level
of volatile organic compound concentration. Moreover, the treatment plant was consolidated with the currently
operating Industrial Waste Treatment Plant with resultant savings of approximately $1.0 million.
One update at the Coakley Landfill in New Hampshire involved coordination between EPA, the PRP, and the
State. The original remedy included collection and treatment of landfill leachate, however contaminant concen-
trations decreased after a landfill cap was installed. Since most cleanup levels had already been met, without
leachate collection and treatment, the remedy update saved an estimated $14.0 million.
EPA and the PRPs jointly initiated the change at the Springfield Township Dump in Michigan, along with
significant community involvement. The original remedy involved the on-site incineration of PCB-contaminated
soil and was updated to include excavation and treatment via soil washing, a limitation on the potential future
exposure and treatment of ground water. The remedy was altered to reflect current State standards and saved
an estimated $26.0 million.
State Input in the Update
States can be either the lead or support agency for a remedy update. The remedy update was State-lead at the
MacGillis & Gibbs/Bell Lumber & Pole site in Minnesota, although the change initiators at the site also
included EPA and the City of New Brighton. The high cost of incineration and soil washing which totaled $26.0
million, as well as the unreliability of soil washing, prompted reevaluation of the remedies at the site. In addi-
tion, EPA's Presumptive Remedy Guidance was issued subsequent to the relevant RODs and had identified
biological treatment as the Agency's primary presumptive remedy for wood treater sites which further prompted
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SUMMARY REPORT FY98 AND FY99
the reevaluation of the existing remedies. The original remedies involved soil washing involved soil washing and
on-site incineration of debris and some soils. The remedy update involved RCRA capping of an operable unit,
off-site disposal, and biological/chemical oxidation-reduction treatment of some soils with off-site landfilling of
the treated soils. The resultant savings were estimated to be $16.0 million.
At the Charles George Landfill in Massachusetts, EPA and the State worked closely on proposed remedy
changes at the site. EPA and the State held frequent informal meetings to keep the community updated on all
on-going activities, including changes to the remedy. The selected remedy for ground water included an on-site
pump and treat system. The municipal sewer was extended near the site by others and discharge to the local
POTW became a viable alternative remedy. The POTW issued the site a discharge permit for ground water and
leachate collected on-site and EPA extended the sewer to the site. Based on a gas characterization study
performed during the design phase, the landfill gas remedy was changed from an on-site incinerator to an
enclosed flare system which can destroy the landfill gas contaminants at a lower temperature and costs
significantly less. Off-site contaminated sediments in a nearby brook were to be excavated and placed under
the cap. However, resampling of the sediments and a reevaluation of risk showed that the sediments did not
pose an unacceptable risk and were therefore not removed. These changes in the remedies provided estimated
cost savings of approximately $10.0 million.
Community Preference
Community involvement can be the basis for remedy updates and, in some cases, may mean using alterna-
tives to the best available technology to address site contamination. For example, at the Texarkana Wood
Preserving Site in Texas, the community was not in favor of the original remedial action (incineration). A
consensus was reached with the community advisory group to use a cap for contaminated soils, which was an
equally protective remedy. This remedy update lead to $3.5 million in estimated cost savings.
Another example of the effect of community preference on remedy updates, occurred at the United Creosoting
site in Texas where EPA and the State held several community meetings, including one formal public hearing.
The public was very vocal in opposition to the continuation of the innovative technology because it failed to
meet the remediation rate. The costs due to time extension of the original remedy would have greatly exceeded
the costs of off-site disposal. The resultant savings of the remedy update were estimated to be $21.0 million,
which includes the cost of overruns with the original remedy.
Cost Increases
Although the Reform Guidance is aimed at controlling all site costs, there are remedy updates that result in cost
increases, especially when data generated during remedial design demonstrates that a selected technology
does not function under current conditions or additional contamination is discovered at the site. For example, at
the Silver Bow Creek/Butte Area in Montana, in the course of preparing the design, the State and EPA
reevaluated certain elements of the remedy as described in the ROD in light of new site information developed
in the design process. Although this remedy update resulted in an estimated cost increase of over $50 million,
an $81.0 million cash-out settlement with the PRP covered the cost increase reflected in this ESD.
Similarly, at the Baldwin Park Operable Unit of the San Gabriel Valley Area 2 site in California, the reme-
dial design called for cleanup of contamination caused by volatile organic chemicals only. However, in 1997, it
was discovered that in addition to volatile organic chemicals, ground water in Baldwin Park was also contami-
nated with other chemicals. A remedy update was necessary to address the other contaminants not identified
in the original ROD. The remedy update resulted in an estimated cost increase of $38.0 million plus $6.0 million
in operation and maintenance costs.
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SUMMARY REPORT FY98 AND FY99
Timeframe for Completing Remedy Updates
The time needed to complete an update varies with each site. In some instances, exploring other remedies
takes years of review and completion. At the MW Manufacturing site in Pennsylvania, on-site incineration of
fluff and soil, stabilization of ash, and off-site disposal were substituted with temporary sedimentation and
erosion control; treatment of fluff, sediment, and soils by ex situ stabilization; and treatment of non-aqueous
phase liquid in soil by low temperature thermal desorption. Consequently, this remedy update required several
years to complete and resulted in $26.0 million in estimated cost savings.
In contrast, the review for the remedy update at Strother Field in Kansas took less than one year to complete.
The results of a study lead to substitution of the original remedy, a conventional pump and treat system, with a
reduced pump and treat system accompanied by MNA of water. Additionally, a contingency plan for a soil
excavation/capping component was implemented at the site. The update resulted in $4.0 million in estimated
savings.
5.0 Conclusion
EPA and outside parties continued to consider the Updating Remedy Decisions Reform a success in both FY98
and FY99. The number of remedies updated by each Region during FY98 and FY99 clearly shows that all ten
EPA Regions are implementing this Reform, with half of the Regions reporting estimated cost savings above
$50 million for the two fiscal years combined. All ten EPA Regions continue to evaluate requests to review old
Fund-lead remedies, as well as consider updates to more recent remedies that may not be up-to-date with
current science or technology. Regions also continue to encourage outside parties to submit remedy update
requests to EPA when new technical information exists to support them. Typically, EPA and outside parties
share the benefits of both cost and time savings as part of implementing the updated remedy.
Interested parties should review the existing Reform Guidance (OSWER Directive 9200.2-22) for basic informa-
tion concerning the Reform. Additional guidance on remedy updates is included in the updated Record of
Decision Guidance (see "A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other
Remedy Selection Decision Documents," OSWER Directive 9200.1-23P, July 1999). Specific questions on
implementation of the Reform may be directed to Matt Charsky of the Office of Emergency and Remedial
Response by telephone at (703) 603-8777, e-mail at charsky.matthew@epa.gov, or FAX at (703) 603-9133.
Each Region also has a remedy update contact who can be accessed by contacting the Superfund Program
area in any of EPA's ten Regional offices.
Acknowledgments
This report was made possible by the dedicated efforts of numerous EPA Superfund staff. Regional remedial
project managers (RPMs) responsible for considering and implementing remedy updates at Superfund sites are
to be commended for making these changes to select the best technologies available at Superfund sites
nationwide.
This report was prepared for EPA under contract #68-W6-0038.
10
-------
Appendix A:
SUMMARY OF UPDATED REMEDY DECISIONS FOR FY98
Region
1
2
3
4
5
6
7
8
9*
10
Total
# With
No Sav.
0
0
4
2
1
0
1
1
0
O
12
#of
TBD
1
1
0
0
1
0
0
1
0
2
6
#With
Est.
Sav.
4
3
9
8
12
4
1
1
4
2
48
#With
Est.
Incr.
0
1
1
2
1
0
0
2
1
2
10
Est.
Savings
$1.7M
$11. 8M
$40.5 M
$22.0 M
$99.9 M
$29.8 M
$1.0M
$3.0 M
$51.9M
$20.5 M
$282.1 M
Est.
Increases
$0
$2.0 M
$0.03 M
$0.03 M
$3.1M
$0
$0
$51. 3 M
$0.1 M
$0.3 M
$57.0 M
Change Initiator
PRP
1
2
5
2
3
1
2
2
2
1
21
EPA
1
3
4
6
5
2
0
2
1
0
24
State
0
0
0
0
1
0
0
1
0
1
3
Fed Fac.
1
0
0
0
0
0
0
0
0
1
2
Public
0
0
0
0
0
1
0
0
0
0
1
Joint
2
0
5
4
6
0
0
0
2
6
25
Type of Change
ESD
4
4
10
9
9
1
1
5
4
6
53
ROD-A
1
1
4
3
6
3
1
0
1
3
23
12
48
10
76 sites
25 JOINT
3 STATE
24 EPA
2 FED FAC
21 PRP
1 PUBLIC
76 sites
53 ESD
23 ROD-A
76 sites
* The Selma Pressure Treating update is not counted in FY98 as it was counted in FY97. However, the estimated savings were not reported in FY97 and are being
counted in FY98.
-------
Appendix A:
SUMMARY OF UPDATED REMEDY DECISIONS FOR FY99
Region
1
2*
3
4
5**
6
7f
8
9
10
Total
#With
No Sav.
1
0
1
6
0
0
0
2
1
0
11
#of
TBD
2
0
0
0
4
1
0
0
0
1
8
#With
Est.
Sav.
4
7
8
9
9
1
4
4
2
2
50
#With
Est.
Incr.
0
2
5
3
3
0
0
0
1
0
14
Est.
Savings
$33.6 M
$103. 8 M
$92.9 M
$11.2M
$135. 5 M
$21.0 M
$9.8 M
$3.8M
$18.3 M
$1.0M
S430.9M
Est.
Increases
$0
$5.4 M
$5.4 M
$0.2 M
$3.0 M
$0
$0
$0
$44.0 M
$0
S58.0M
Change Initiator
PRP
1
5
5
8
4
0
3
1
1
2
30
EPA
3
O
7
6
5
2
0
O
2
0
31
State
0
0
0
1
2
0
1
0
0
0
4
Fed
Fac.
0
0
0
1
0
0
0
2
0
1
4
Public
1
0
0
0
0
0
0
0
0
0
1
Joint
2
1
2
2
5
0
0
0
1
0
13
Type of
Change
ESD
6
5
9
12
9
0
1
5
3
2
52
ROD-A
1
4
5
6
7
2
3
1
1
1
31
11
8
50
14
83 sites
31 EPA 30 PRP 13 JOINT
4 FED FAC 4 STATE 1 PUBLIC
83 sites
52 ESD
31 ROD-A
83 sites
*: Universal Oil Products (UOP), NJ had a ROD Amendment and ESD during FY99.
**: Butterworth #2, MI had two ESDs during FY99, but only one remedy update is counted because the costs cannot be split. In addition, the ESD for Fields
Brook, OH was for two OUs, but is counted as one because the costs cannot be split.
f: Des Moines TCE Site, IA is not counted under any category because the update is strictly cost-related.
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 1 - FY98
Region 1
Beacon Heights Landfill,
CT
Region 1
Boston & Maine
Wastewater Lagoons
Iron Horse Park, MA
OU1
9/23/85 (PROD)
9/28/90 (2nd ROD)
9/9/98 (ESD)
1/98
9/98
EPA
Leachate, Soil,
Air
State supports leachate
transport and
compensatory wetland
aspects, but has not
concurred with the
constructed cap.
Fed = 120 hours
Contr. = Unknown
Est'd Savings =
$700 K
Type of Change: From - leachate treatment occurring at the Naugatuck Facility, RCRA cap with low permeability soil, and
location of compensatory wetlands on the 82 acres that comprise the site; To - leachate treatment occurring at the Beacon
Falls publicly-owned treatment works (POTW), an alternate capping system with geosynthetic clay liner (GCL), and location
of compensatory wetlands on the Swan property.
Factual Basis: The pipeline to POTW is shorter, has a lower propensity for O&M problems, and disturbs the community
less. The GCL is less expensive to install, eliminates high-volume truck traffic, and accelerates cleanup schedule. The Swan
property is more suitable for wetlands creation.
9/15/88
10/1/97 (ESD)
2/97
10/97
PRP
Soil, Ground
water, Surface
Water, Sludge,
Debris
State concurred; EPA
published notice and
public comment period;
and EPA conducted
public meeting.
Fed = 240 hours
Contr. = $0
Est'd Savings =
Unknown
Type of Change: From - bioremediation, returning treated material to the lagoon area, covering it with clean soil and
establishing a vegetative cover, and decontamination and disposal of piping and pumps associated with the lagoons; To -
excavation, asphalt batching, and reuse.
Factual Basis: The results of Supplemental Feasibility Study prompted this remedy update.
Appendix A. 1
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 1
Loring Air Force Base
Landfill 3, ME
OU2
Region 1
Naval Construction
Battalion Center, RI
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/94
9/30/98 (ESD)
Date Review
Commenced
Date Review
Completed
8/98
9/98
Change
Initiator
EPA,
Fed. Fac.
Media
Soil, Sediment
State/Community
Involvement
The community has
been notified. EPA
and State concurred on
the remedy update.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 40 hours
Contr. = $0
Est'd Savings =
$800 K
Type of Change: From - incorporate excavated contaminated soils and sediments from OU8 and OU13 as subgrade fill
beneath the Landfill 3 cover system; To - construction of two cells within subgrade fill in order to use excavated
contaminated soils and sediments from OU8 and OU13, while meeting the technical requirements for their disposal.
Factual Basis: The cells allow for the use of a greater volume of soils/sediments from the site as subgrade fill while
providing a cost-effective disposal method for soils/sediments contaminated with polychlorinated bi-phenyl concentrations
greater than 50 ppm.
9/23/93
9/29/98 (ESD)
8/98
9/98
Fed. Fac.
Soil, Debris
EPA and State
concurred; community
notified; fact sheet
distributed.
Fed = 40 hours
Contr. = $0
Est'd Savings =
$15 K
Type of Change: From - removal of contaminated soil and asphalt/concrete, and restricted future use of the area, as well as
a five-year review to reassess the protectiveness of the remedy; To - removal of contaminated soil and asphalt/concrete plus
no five-year review or institutional controls.
Factual Basis: Due to the amount of polychlorinated bi-phenyl removal that has been completed at Sites 12 and 14, soil and
concrete at the sites do not pose unacceptable risks for residential reuse; thus, restriction of the area is unnecessary. The
recent post-removal data indicated that the concentration levels are so low that future monitoring is also unnecessary.
Appendix A. 1
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 1
Tibbetts Road, NH
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/29/92
9/28/98 (ROD-A)
Date Review
Commenced
Date Review
Completed
12/96
5/8/98
Change
Initiator
EPA, State
Media
Ground water
State/Community
Involvement
State concurred; public
notified and also
concurred.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 320 hours
Contr. = $0
Est'd Savings =
$140 K
Type of Change: From - extraction and treatment using vacuum extraction; To - bioremediation and phytoremediation.
Factual Basis: After two years of vacuum extraction, performance declined. Conclusion of extraction and treatment found
residual concentrations above cleanup levels which are amenable to treatment with phytoremediation and bioremediation.
Cleanup levels are unchanged.
Region 1 - FY99
Charles George
Landfill, MA
9/29/88
9/30/99 (ESD)
4/1/95
9/30/99
EPA
Ground water,
Landfill gas,
Sediment
State and community
involved in all
decisions; regular town
meetings to discuss site
and changes to original
remedy.
Fed = 240 hours
Contr. = not available
Est'd Savings =
$ 10.8 M
Type of Change: From - build on-site ground water pump and treatment system, landfill gas incinerator, monitor residential
drinking water wells and remove approximately 500 cubic yards of sediment from a nearby brook and placed under the cap;
To - extend municipal sewer and discharge to local POTW, modify gas collection system to an enclosed flare system, and
decision not to remove sediments.
Factual Basis: 1. Discharge to sewer option become available due to extension of municipal sewer close to site and site
meeting pretreatment standards of POTW. 2. Based on gas characterization, an enclosed flare gas destruction system proved
to be effective treatment on it rather than more expensive incinerator option. 3. A resampling and calculation of risks
associated with sediments showed that there were no unacceptable risks.
Appendix A. 1
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 1
Coakley Landfill, NH
Region 1
Hoccomoco Pond, MA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/28/90
9/30/99 (ESD)
Date Review
Commenced
Date Review
Completed
7/15/99
9/30/99
Change
Initiator
EPA, PRP
Media
Leachate,
Ground water
State/Community
Involvement
State concurred; public
notification, but no
comments received.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed =120 hours
Contr. = $0
Est'd Savings =
$ 14.0 M
(over 10 years)
Type of Change: From - collection and treatment of landfill leachate; To - elimination of collection and treatment of landfill
leachate.
Factual Basis: Contaminant concentrations have decreased after the landfill cap was installed. Most cleanup levels have
already been met without leachate collection and treatment.
9/85
9/21/99 (ESD)
6/99
9/21/99
PRP
Ground water
State involved in
decision- making;
community notified;
fact sheet distributed.
Fed = 400 hours
Contr. = not available
Est'd Savings =
$7.5M
(over 30 years)
Type of Change: From - ground water pump and treat system; To - TI waiver and monitored natural attenuation.
Factual Basis: DNAPL was first identified during the RI/FS, and a bioassessment of the pond showed that concentration
levels were decreasing due to natural processes.
Appendix A. 1
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 1
Kellogg-Deering
Wellfield, CT
Region 1
Naval Construction
Battalion Center, RI
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/86 (1st ROD)
9/89 (2nd ROD)
3/3 1/97 (ESD)*
Date Review
Commenced
Date Review
Completed
1/97
3/31/97
Change
Initiator
EPA
Media
Soil, Ground
water
State/Community
Involvement
Community notification;
State concurrence.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 40 hours
Contr. = $0
Est'd Savings =
not available
Type of Change: From - 1989 ROD included institutional controls to restrict use of contaminated soil and ground water.
Institutional controls were established to restrict use of contaminated soil; To - EPA has determined that implementing further
institutional controls to restrict use of groundwater is unnecessary.
Factual Basis: EPA has determined that existing state and local laws and permitting requirements related to the use of
ground water are adequate and institutional tools to restrict use of ground water are unnecessary.
* The remedy update was completed in FY97 but was reported in FY99.
9/29/97
7/21/99 (ESD)
5/98
8/99
Fed. Fac.,
EPA
Soil, Sediment
State concurred;
community notified;
fact sheet distributed.
Fed =160 hours
Contr. = $ 5 K
Est'd Savings = None
Type of Change: From - landfill cap; To - excavation and off-site disposal of PCB-contaminated soil and sediment near cap
and expansion of landfill cap; plus one acre of wetland mitigation.
Factual Basis: PCB contamination in soil and sediment discovered above the Toxic Substances Control Act (TSCA) risk
criterion outside limits of original cap.
Appendix A. 1
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 1
New Bedford Harbor,
MA
OU2
Region 1
Ottati and Goss/
Kingston Steel Drum,
NH
Date of
Original ROD
Date of Change
(ESD/ROD-A)
4/6/90
4/27/99 (ROD-A)
Date Review
Commenced
Date Review
Completed
12/93
4/27/99
Change
Initiator
Public
Media
Sediment
State/Community
Involvement
State and community
involvement including
biweekly meetings.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = not available
Contr. = not available
Est'd Savings =
not available
Type of Change: From - on-site incineration of dredged Hot Spot sediments; To - transportation and disposal of dredged Hot
Spot sediments to an off-site TSCA permitted chemical waste landfill.
Factual Basis: In April 1990, EPA issued the 1990 Hot Spot ROD for the Hot Spot Operable Unit of the site. Based on a
vehement and Congressionally-supported reversal in community acceptance of the 1990 Hot Spot ROD's on-site incineration
component of the remedy, EPA suspended plans to incinerate the Hot Spot sediments in New Bedford. Working with the
local community, EPA agreed to study other options for treating the Hot Spot sediments and to amend the April 1990 Hot
Spot ROD with a consensus based cleanup plan. Off-site landfilling is the consensus based cleanup plan.
1/16/87
9/28/99 (ESD)
6/97
9/28/99
EPA
Soil, Sediment
State concurrence and
support of changes in
future use; public
meeting held.
Fed = 400 hours
Contr. = not available
Est'd Savings =
$ 1.3 M
Type of Change: From - incineration; residential clean up scenario; To - low temperature thermal desorption; industrial clean
up scenario.
Factual Basis: The change in future use is appropriate considering the site's location on a major State highway, near existing
development, and the past use of the site that was commercial/industrial. Thermal desorption is less expensive than
incineration.
Appendix A. 1
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 2 - FY98
Region 2
Carroll & Dubies
Sewage Disposal, NY
OU1
Region 2
Cosden Chemical
Coatings Corporation,
NJ
3/31/95
8/24/98 (ESD)
5/97
8/24/98
EPA
Soil, Sludge
Public comment period;
official documents
available for public
viewing.
Fed =105 hours
Contr. = 145 hours
Est'd Savings =
$1.4 M
Type of Change: From - on-site bioslurry treatment of lagoon wastes and containment; To - excavation, additional off-site
waste treatment and disposal at a licensed hazardous waste facility.
Factual Basis: Supplemental sampling activities found that the industrial organic waste bonded together and separated from
surrounding waste. Therefore the waste treatment in the ROD was not deemed practical.
9/92
9/24/98 (ESD)
6/97
9/98
EPA
Soil
State concurred; public
announcement.
Fed = 480 hours
Contr. = 320 hours
Est'd Savings =
$1.2 M
Type of Change: From - in-situ soil treatment using 500 ppm cleanup goal for lead; To - off-site treatment and/or disposal of
the soil using 400 ppm cleanup goal for lead, excavation and treatment of VOC contaminated soil, and addition of soil vapor
extraction system.
Factual Basis: Sampling performed during remedial design indicated that significantly less soil is contaminated and
distributed more sporadically than previously estimated. In-situ treatment process would be more complicated and costly than
anticipated and off-site treatment and/or disposal, supported by the community, is preferable.
Appendix A. 1
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 2
Ramapo Landfill, NY
Region 2
Reynolds Metals
Company Study Area,
NY
Date of
Original ROD
Date of Change
(ESD/ROD-A)
3/31/92
1 1/26/97 (ESD)
Date Review
Commenced
Date Review
Completed
Not
Applicable
11/26/97
Change
Initiator
PRP
Media
Sludge, Debris,
Liquid Waste
State/Community
Involvement
Public comments
invited; State supported
ESD.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 80 hours
Contr. = Unknown
Est'd Savings =
Unknown
Type of Change: From - landfill cap with impermeable barrier only on top (flat) portion; To - landfill cover with an
impermeable barrier on top and side slopes.
Factual Basis: As a result of studies called for in the ROD, it was determined that an impermeable barrier on the side slopes
would be more cost-effective and protective than the original cap design.
9/27/93
9/30/98 (ROD-A)
1995
9/98
PRP
Sediments
Public meeting with
community and
Mohawk Tribe.
Community supports
landfill remedy, but
Tribe only supports a
temporary landfill.
State concurred on
proposed plan.
Fed = 200 hours
Contr. = 40 hours
Est'd Savings =
$9.2 M
Type of Change: From - dredging and dewatering of sediments with polychlorinated biphenyl (PCB) levels exceeding 1
ppm, polycyclic aromatic hydrocarbon (PAH) levels exceeding 10 ppm, and total dibenzofuran (TDBF) levels exceeding 1
ppb together with on-site treatment of sediments by thermal desorption for PCBs at levels above 25 ppm and on-site landfill
of PCBs at levels less than 25 ppm; To - eliminate on-site thermal desorption treatment and dispose of sediment with PCBs at
levels between 50 and 500 ppm; off-site treatment of sediments with PCBs at levels greater than 500 ppm, and on-site landfill
and cap of sediments with PCBs at levels less than 50 ppm.
Factual Basis: New information in design on lower cost of off-site disposal and the presence of a substantially larger volume
of contaminated sediments.
Appendix A. 1
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 2 - FY99
Region 2
Batavia Landfill
Region 2
Forest Glen Mobile
Home Subdivision, NY
Region 2
General Electric (GE)
Wiring Devices, PR
6/6/95
9/20/99 (ESD)
7/15/99
9/20/99
PRP
Soil
Public notice.
Fed = 40 hours
Contr. = $0
Est'd Savings =
$ 770.5 K
Type of Change: From - hot spot consolidation and cap; To - large area consolidation and cap.
Factual Basis: Change in conditions discovered in RD.
3/31/98
9/30/99 (ROD-A)
4/16/99
9/30/99
City, PRP
Soil
Public meeting held.
Fed = 40 hours
Contr. = $0
Est'd Savings =
$3.9M
Type of Change: From - consolidate and cap; To - cap in place.
Factual Basis: Land use changed from residential to commercial/ industrial.
9/30/88
4/26/99 (ESD)
5/98
4/26/99
EPA
Soil
Full Territory
involvement;
community supportive
Fed = 40 hours
Contr. = $50 K
Est'd Savings =
$5.4 M
Type of Change: From - on-site hydro-metallurgical treatment; To - off-site disposal.
Factual Basis: PRP proposed cost-saving alternative that afforded same level of environmental protection.
Appendix A. 1
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 2
General Motors (GM),
NY
Date of
Original ROD
Date of Change
(ESD/ROD-A)
12/17/90
3/23/99 (ROD-A)
Date Review
Commenced
Date Review
Completed
6/98
3/23/99
Change
Initiator
EPA
Media
Soil, Sediment
State/Community
Involvement
Extensive Tribal, State,
and community
involvement.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 300 hours*
Contr. =50 hours
Est'd Savings =
$3.8M
(Reduction in cleanup
costs)
Type of Change: From - on-site treatment for sediments and soils from the Raquette and St. Lawrence River and GM site
soils excavated during the installation of ground water controls; To - off-site disposal.
Factual Basis: ROD amendment on only a portion of the site was developed primarily to gain community acceptance and
further the cleanup, which had been halted due to Tribal community opposition.
* Received many conflicting public comments and needed to develop an extensive responsiveness summary.
Appendix A. 1
10
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 2
Universal Oil Products
(UOP), NJ
Region 2
Woodlands, NJ
Route 72
Route 532
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/30/93
12/8/98 (ROD-A)
4/29/99 (ESD)
Date Review
Commenced
Date Review
Completed
1997
12/98
4/99
Change
Initiator
PRP
Media
Soil
State/Community
Involvement
State and community
supported changes to
the remedy.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
ROD-A
Fed = 120 hours
Contr. = $0
Est'd Savings =
$ 1.2 M
ESD
Fed = 40 hours
Contr. = $0
Est'd Savings =
$ 1.1 M
Type of Change: ROD-A : From - Low Temperature Thermal Desorption (LTTD) of PCB/PAH contaminated soils; To -
off-site disposal.
ESD : From - LTTD of VOC contaminated soils; To- on-site thermally enhanced vapor extraction.
Factual Basis: In both the amendment and ESD, the on-site treatment using LTTD was halted in 1997 after operational
problems and odor complaints from neighbors. Remedy changes were necessary to complete the remedy aside from bringing
LTTD back on site.
5/16/90
7/1/99 (ROD-A)
12/93
7/1/99
PRP
Ground water
State supported the
change. The site is
located in a rural area
and the local population
supports the remedy
change.
Fed =150 hours
Contr. = $0
Est'd Savings =
S87.6M
Type of Change: From - ground water pump and treat; To - air sparging/soil vapor extraction and natural attenuation.
Factual Basis: BTAG memo indicated that the ground water pump and treat system would dewater the nearby wetlands. In
addition, during remedial design, the PRP successfully identified alternatives that would meet ROD objectives at much lower
cost.
Appendix A. 1
11
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 3 - FY98
Region 3
Arrowhead Plating, VA
Region 3
Brown's Battery
Breaking, PA
OU2
9/30/91
9/15/98 (ESD)
12/97
9/98
PRP
Ground water
State supported the
remedy modification.
Fed = 250 hrs.
Contr. = $0
Est'd Savings =
$650 K
Type of Change: From - ground water pump and treat using air stripping and carbon adsorption; To - Permeable Reactive
Subsurface Barriers (PRSBs).
Factual Basis: Treatability study results and advances in the development of PRSBs and in-situ ground water treatment
technology indicate that PRSBs are a more appropriate means of treating ground water at the site.
7/2/92
12/19/97 (ESD)
8/97
12/97
EPA, State
Ground water,
Soil
State concurred with
the ESD; public
comment period was
held.
Fed = 252 hrs.
Contr. = $0
Est'd Savings = $0
Type of Change: From - cleanup of ground water contamination in shallow and deep aquifers to background levels; To -
cleanup to State standards.
Factual Basis: EPA accepts State's new cleanup standard for lead in ground water issued in State-wide, health-based
remediation standards.
Appendix A. 1
12
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 3
CryoChem, Inc., PA
OU3
Region 3
Dover Gas Light Co.,
DE
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/30/91
9/22/98 (ESD)
Date Review
Commenced
Date Review
Completed
5/96
9/98
Change
Initiator
EPA
Media
Soil
State/Community
Involvement
State concurred.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 235 hrs.
Contr. = $0
Est'd Savings =
$100 K
Type of Change: From - utilization of soil vapor extraction to remove the contamination from the soil; To - no further action.
Factual Basis: Soil sampling in 1992 and 1995 revealed that contaminant levels were significantly below the operating norm
for a vapor extraction system, thus no longer posing a threat to human health, welfare, and the environment.
8/16/94
12/16/97 (ROD-A)
7/95
12/97
PRP
Soil, Ground
water
Several public meetings
were held; public had
comments on amended
FS and proposed plan;
State concurred on
proposed plan.
Fed = 90 hours
Contr. = $0
Est'd Savings =
$9.0 M
Type of Change: From - excavating soils at former gas plant for off-site incineration; To - excavation and off-site thermal
destruction of soil inside the buried bottoms of former gas holders; soil vapor extraction outside gas holders; pave other areas
and limit development.
Factual Basis: The soil cleanup was modified to take into account restricted future land use.
Appendix A. 1
13
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 3
Hunterstown Road, PA
Region 3
MW Manufacturing
Site, PA
OU5 (formerly OU2)
Date of
Original ROD
Date of Change
(ESD/ROD-A)
8/2/93
8/25/98 (ESD)
Date Review
Commenced
Date Review
Completed
7/98
8/25/98
Change
Initiator
EPA,
State
Media
Ground water
State/Community
Involvement
State concurred;
Administrative Record
is available for public
review.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 40 hrs.
Contr. = $0
Est'd Savings = $0
Type of Change: Procedural change: From - determination of "engineering feasibility" of remedial goals after remedial
action; To - determination of "engineering feasibility" of remediation goals prior to remedial action.
Factual Basis: EPA found that it may be possible to determine a remediation goal based on hydrogeologic investigation
conducted during the pre-design phase of ground water pump and treat remedial design.
6/90
12/22/97 (ROD-A)
12/92
12/97
PRP
Soil,
Fluff,
Sediments,
Lagoons, Debris
State and community
concurred on
amendment;
community concerns
were answered in
responsiveness
summary.
Fed =150 hours
Contr. = $0
Est'd Savings =
$26.0 M
Type of Change: From - on-site incineration of fluff with off-site disposal; incineration of soil, stabilization of ash and off-site
disposal; To - temporary sedimentation and erosion control; treatment of fluff, sediment and soils by ex situ stabilization;
treatment of non-aqueous phase liquid in soil by low temperature thermal desorption.
Factual Basis: New Information was obtained from supplemental site characterization, a focused feasibility study, and
treatability study results.
Appendix A. 1
14
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 3
NCR Corporation, DE
Region 3
North Penn Area 1, PA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
8/12/91
3/96 (1st ESD)
9/29/98 (2nd ESD)
Date Review
Commenced
Date Review
Completed
4/98
9/98
Change
Initiator
PRP
Media
Ground water
State/Community
Involvement
State supports the
remedy change.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 245 hrs.
Contr. = $0
Est'd Savings =
$2.5 M
Type of Change: From - ground water pump and treat (P&T) system; To - enhanced P&T with air sparging/soil vapor
extraction system.
Factual Basis: The use of air sparging/soil vapor extraction for the down gradient portion of the aquifer has been successful
in reducing the concentration of TCE. Augmentation of the existing pump and treat system with an air sparging/soil vapor
extraction system lowers the cost of the remedy and speeds the process of cleanup.
9/30/94
10/29/97 (ESD)
11/95
10/97
EPA, State
Ground water
State concurred.
Fed = 250 hrs.
Contr. = $0
Est'd Savings =
$125 K
Type of Change: From - ground water treatment with air stripper, cleanup to background levels, and pump and treat entire
S-9 well; To - ground water discharge to publicly-owned treatment works (POTW), cleanup to maximum contaminant levels,
and no pumping of S-9 well.
Factual Basis: Sampling results from remedial design activities revealed low levels of contamination which can be handled
by the POTW. Pennsylvania's remediation standards have also recently changed.
Appendix A. 1
15
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 3
North Penn Area 1, PA
Region 3
Osborne Landfill
(ROD 1), PA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/30/94
9/24/98 (ESD)
Date Review
Commenced
Date Review
Completed
1/98
9/98
Change
Initiator
EPA
Media
Ground water
State/Community
Involvement
State verbally
concurred with the
ESD.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 250 hrs
Contr. = $0
Est'd Savings =
$125 K
Type of Change: From - interim remedy of discharge to publicly-owned treatment works selected for OU2 ground water;
To - final remedy for contaminated ground water.
Factual Basis: Monitoring of newly installed wells revealed that the levels of contamination were low with no evidence of
the presence of dense non-aqueous phase liquids. Source of ground water contamination was removed and levels of
contaminated soil are not expected to increase.
9/28/90
8/24/98 (ESD)
3/98
8/24/98
EPA, State
Ground water
State concurred;
Administrative Record
is available for public
review.
Fed = 250 hrs.
Contr. = $0
Est'd Savings = $0
Type of Change: From - institutional controls to help reduce site exposure; To - removal of institutional controls.
Factual Basis: EPA no longer considers the institutional control on any new wells within one-half mile of the site to be
necessary. The plume is almost completely limited to lot 203, which contains the landfill. Homes near the plume have access
to public water supply. Leachate treatment system in operation since 1996.
Appendix A. 1
16
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 3
Osborne Landfill
(ROD 2), PA
Region 3
Westinghouse Elevator
Co. Plant, PA
OU1
Date of
Original ROD
Date of Change
(ESD/ROD-A)
12/30/97
8/24/98 (ESD)
Date Review
Commenced
Date Review
Completed
1/98
8/24/98
Change
Initiator
EPA
Media
Ground water
State/Community
Involvement
State concurred;
Administrative Record
is available for public
review.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 250 hrs.
Contr. = $0
Est'd. Savings = $0
Type of Change: From - well monitoring (natural attenuation with monitoring); To - removal of two wells from the
monitoring network.
Factual Basis: Two wells were abandoned due to interference with construction of slurry wall and clay cap. Performance
wells are close to these abandoned wells; therefore, the removal of the wells does not significantly reduce the scope of the
monitoring program.
6/30/92
8/3/98 (ESD)
10/95
8/3/98
EPA, PRP
Ground water,
Air
State concurred;
Administrative Record
is available for public
review.
Fed = 250 hrs.
Contr. = $0
Est'd. Savings =
$500 K
Type of Change: From - construction of off-site ground water extraction system connected to an on-site air stripper; To -
continued use of the off-Plant treatment system.
Factual Basis: During design, EPA believed it would be simpler and cheaper to pump the ground water extracted off-Plant
to an air stripper located on the Plant property.
Appendix A. 1
17
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 3
Whitmoyer Laboratories
Site, PA
OU2
Date of
Original ROD
Date of Change
(ESD/ROD-A)
12/17/90
5/12/98 (ROD-A)
Date Review
Commenced
Date Review
Completed
11/94
5/98
Change
Initiator
PRP
Media
Soils,
Lagoons,
Debris
State/Community
Involvement
State concurred with
amendment;
community had
concerns with on-site
incineration.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 537 hours
Contr. = $0
Est'd Savings =
$1.5 M
Type of Change: From - on-site incineration and off-site disposal; To - off-site stabilization of arsenic-contaminated soil and
disposal to Subtitle C landfill.
Factual Basis: Community opposition to on-site incineration and full scale pilot test of stabilization exceeds treatment level of
90 percent efficiency, which is required for a treatability variance.
Region 3 - FY99
Region 3
Butz Landfill, PA
6/30/92
8/27/99 (ESD)
3/31/99
8/27/99
EPA
Ground water
State concurrence;
ESD available for
public review.
Fed =150 hours
Contr. = not available
Est'd Savings =
$9.5 M
Type of Change: From - ground water extraction wells at the perimeter of the area of contamination; To - elimination of the
ground water extraction wells; use of maximum contaminant levels (MCLs) or new applicable state standards for cleanup of
contaminants; and natural attenuation of contaminants at the down-gradient perimeter of contaminated ground water.
Factual Basis: Changes to the remedy occurred as a result of a change in Pennsylvania law; new information relating to the
natural attenuation of contaminants; and additional site-specific information gained as a result of the remedial design activities
at the site.
Appendix A. 1
18
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 3
Chem-Solv, Inc., DE
Region 3
Douglassville Disposal,
PA
OU2
Date of
Original ROD
Date of Change
(ESD/ROD-A)
3/29/92
6/18/99 (ESD)
Date Review
Commenced
Date Review
Completed
12/98
6/18/99
Change
Initiator
EPA
Media
Ground water
State/Community
Involvement
State concurrence;
administrative record
available for public
review.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 50 hours
Contr. = not available
Est'd Savings = None
Type of Change: From - establishment of State Ground Water Management Zone (GWMZ) and placement of notice in
property records of all properties located within the GWMZ; and removal of existing recovery wells onsite. To - no notice
necessary to alert prospective purchasers of property within the GWMZ; it was also deemed unnecessary to record notices in
property records.
Factual Basis: Notices in property records are often impractical to record and such notices would remain permanently in the
property records, potentially stigmatizing the property.
6/89
8/31/99 (ROD-A)
9/97
8/31/99
PRP
Soil
Community Relations
Plan was developed for
the site; Administrative
Record available for
public review; public
meeting was held.
Fed = 3,000 hours*
Contr. = $0
Est'd Savings =
S36.0M
Type of Change: From - on-site thermal treatment (incineration) of oily diatomaceous earth filter cake wastes and oily
sediments in the drainageway; To - remediation of filter cake wastes and oily sediments using a lime-based stabilization
process.
Factual Basis: Stabilization was not chosen in the original ROD primarily because the processes available at the time were
not deemed to be suitable for materials that contained greater than 10% organics. EPA believes that certain forms of waste
stabilization are, today, protective and cost-effective for the type of waste under consideration at the site. The stabilization
alternative would immobilize the major portion of the hazardous constituents of waste.
* Although review began in FY97 and ended in FY99, the concerned parties were looking at a possible remedy change for at
least three years, perhaps as many as six. Much time was spent gathering and processing the site information to defend the
remedy change. Numerous meetings were held to discuss the most recent site information.
Appendix A. 1
19
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 3
H&H Burn Pit, VA
Region 3
Ordnance Works, WV
OU1
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/30/95
9/28/99 (ESD)
Date Review
Commenced
Date Review
Completed
2/28/99
9/28/99
Change
Initiator
PRP
Media
Ground water
State/Community
Involvement
Administrative Record
available for public
review.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 80 hours
Contr. =30 hours
Est'd Savings =
$2.2M
Type of Change: From - pump and treat system using precipitation, sedimentation, and ultra-violet oxidation; To -
construction of a soil vapor extraction system.
Factual Basis: The modification of the ground water remedy will achieve the ground water remedial objectives more quickly
and cost-effectively than the ground water pump and treat system outlined in the original ROD.
3/88 (1st ROD)
9/29/89 (2nd ROD)
9/30/99 (re-ROD)
6/7/99
9/30/99
PRP
Soil, Sediments,
Lagoon Wastes,
Air
Administrative Record
available for public
review.
Fed = 300 hours
Contr. = not available
Est'd Savings =
$ 1.6M
Type of Change: From - excavation and treatment of inorganic hot spots from the lagoon and scraped areas; disposal of
treated inorganic contaminants at the former landfill area; capping the former landfill area; and excavation and treatment of
organics-contaminated soils and sediments using bioremediation; To - off-site treatment of visibly stained stream, lagoon, and
scraped area soil/sediments; consolidation of contaminated media into existing landfill; capping of existing landfill; long-term
monitoring and institutional controls. The new ROD supercedes the 2nd ROD of 9/29/89 at OU1.
Factual Basis: New information provided in the focused feasibility study changed the scope of the original remedy.
Appendix A. 1
20
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 3
Whitmoyer Labs, PA
OU3
Region 3
Whitmoyer Labs, PA
OU2
OU3
Date of
Original ROD
Date of Change
(ESD/ROD-A)
10/31/90
9/30/99 (ROD-A)
Date Review
Commenced
Date Review
Completed
12/98
9/30/99
Change
Initiator
PRP
Media
Soil, Ground
water
State/Community
Involvement
State concurrence;
community concerns
addressed at public
meeting; public
comment period;
negotiations between
property members and
PRPs currently on-
going.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed =150 hours
Contr. = 0 hours
Est'd Savings =
$ 17.5 M
Type of Change: From - treatment of organically contaminated soils via on-site bioremediation; To - off-site treatment of
organically contaminated soils by low-temperature thermal desorption.
Factual Basis: The thickness of the saturated zone makes it very difficult to maintain structural stability in the excavation
areas due to the presence of water; the large volumes of soil to be excavated would be difficult to manage and place on-site.
12/17/90 (OU 2)
11/1 6/98 (ESD)
12/3 1/90 (OU 3)
11/1 6/98 (ESD)
2/10/98(OU
2)
11/16/98
2/10/98(OU
3)
11/16/98
PRP
Soils, Lagoon
wastes
State and community
concurred.
Fed =132 hours
Contr. = 0 hours
Est'd Savings =
$4.2 M
Type of Change: From - on-site treatment and off-site disposal; To - off-site treatment and off-site disposal.
Factual Basis: Detailed delineation of the lagoons and soils resulted in reduced volumes requiring treatment; completion of
treatability tests demonstrated that the lagoon wastes and highly contaminated soils could be successfully treated off-site; and
passage of the Phase IV Land Disposal Restrictions which provide for an alternate treatment criterion for soils.
Appendix A. 1
21
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 3
William Dick Lagoons,
PA
Region 3
Woodlawn Landfill, MD
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/28/91 (1st ROD)
3/31/93 (2nd ROD)
2/3/99 (ESD)
Date Review
Commenced
Date Review
Completed
7/97
2/3/99
Change
Initiator
EPA
Media
Soil, Ground
water
State/Community
Involvement
Administrative Record
available for public
review.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 400 hours
Contr. = not available
Est'd Savings =
$4.3M
Type of Change: From - (original ROD) extension of the existing water supply to homes impacted by the Site; and hydro-
geological study and an interim ground water pump and treat system; and deference of soil remediation until completion of
treatability study and focused feasibility study; (ROD II) additional soil sampling; excavation and treatment (thermal
desorption unit) of contaminated soil; treatment of air emissions from thermal desorption unit; management/ off-site disposal
of treatment residuals and wastewater; backfilling treated soils and either vegetative or multi -layer cap over such areas (and
O&M of cap); deed restrictions; and five year remedy review; To - include a CAMU to facilitate the remedy outlined in
ROD II (not requiring the construction of an on-site hazardous waste landfill).
Factual Basis: The remedy proposed in ROD II anticipated a RCRA delisting be processed to allow treated material to be
placed back into the excavated areas if all cleanup standards are not met.
9/28/93
9/30/99 (ROD-A)
3/24/99
9/30/99
EPA
Ground water
Public meeting;
notification; and
comment period.
Fed =150 hours
Contr. = $0
Est'd Savings =
$ 17.6 M
Type of Change: From - capping of landfill with low permeability cap; excavation and disposal of mercury contaminated
surface soil; and extraction and on-site treatment of contaminated ground water with discharge of treated ground water to the
on-site stream; To - vegetative soil cover placed over landfilled wastes; monitored natural attenuation of ground water.
Factual Basis: It was determined through ground water monitoring that the concentrations of the organic contaminants were
decreasing more rapidly than expected. It was determined that naturally occurring processes are effectively degrading the
organic compounds.
Appendix A. 1
22
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 4 - FY98
Region 4
Cedartown Municipal
Landfill Site, GA
Region 4
GE/Shepard Farm, NC
11/2/93
5/1 1/98 (ROD-A)
12/8/97
2/28/98
EPA
Leachate,
Ground water
State concurred on and
community supports
ROD amendment.
Fed = 35 hours
Contr.= $0
Est'd Savings =
$8.6M
Type of Change: From - pump and treat ground water; To - deletion of ground water pump and treat remedy.
Factual Basis: Analysis of 2.5 years of ground water data during remedial design indicated that contamination was not
migrating off-site and that some constituents may be from natural sources.
9/29/95
9/30/98 (ESD)
12/97
9/98
EPA, PRP,
State
Soil
State involved; no
community involvement
Fed = 40 hours
Contr. = $0
Est'd Savings = $0
Type of Change: From - on-site capping of two landfills and a dry sludge impediment (DSF); To - excavate landfill and
place a much larger DSF and then cap.
Factual Basis: PRP will maintain one cap instead of three.
Appendix A. 1
23
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 4
Geiger (C&M Oil), SC
Region 4
Hercules 009 Landfill,
GA
Region 4
Marzone Inc./Chevron
Chemical Co., GA
OU1
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/1/87
7/13/96 (lstROD-A)
9/9/98 (2nd ROD-A)
Date Review
Commenced
Date Review
Completed
3/98
6/98
Change
Initiator
EPA
Media
Ground water
State/Community
Involvement
State concurred;
property owner
concurred; no
comments on proposed
plan.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 30 hours
Contr. = $0
Est'd Savings =
$1.3 M
Type of Change: From - pump and treat; To - monitored natural attenuation.
Factual Basis: Most of the wells that previously showed contamination (VOCs & metals) no longer show contaminants.
Only 2 out of 27 wells have any contaminants, one of which is near drinking water standards.
3/25/93
8/14/98 (ESD)
7/8/98
8/17/98
EPA
Sludge,
Soil
State concurred; fact
sheet distributed to the
public; and community
received copies of
ESD.
Fed = 20 hours
Contr. = $0
Est'd Savings =
$400 K
Type of Change: From - in-situ stabilization and cap designed to use imported soil/clay; To - in-situ stabilization and cap
designed to use treated soil.
Factual Basis: New information discovered during remedial design showed new cap design was more cost effective and
utilized on-site materials.
9/30/94
6/19/98 (ESD)
5/1/98
6/1/98
PRP
Soil, Sediment
State received draft;
copies of ESD sent to
community.
Fed = 20 hours
Contr. = $0
Est'd Savings = $0
Type of Change: From - original boundary; To - extended boundary of OU1 along a railroad drainage ditch.
Factual Basis: The ditch, which had previously been defined as a portion of OU2, could be remedied cost-effectively and
timely under the OU1 action.
Appendix A. 1
24
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 4
MCAS Cherry Point,
NC
Region 4
Sapp Battery, FL
Date of
Original ROD
Date of Change
(ESD/ROD-A)
10/19/96
9/98 (ESD)
Date Review
Commenced
Date Review
Completed
11/97
9/98
Change
Initiator
EPA,
State,
Federal
Facility
Media
Ground water
State/Community
Involvement
State concurred, and
Federal facility
developed and
distributed a fact sheet
for community.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 60 hours
Contr. = $0
Est'd Savings =
$1.0 M
Type of Change: From - use of extraction wells; To - expanded extraction system to treat all areas within OU1 above Ippm
VOCs; consolidated treatment plant with currently operating IWTP (Industrial Waste Treatment Plant).
Factual Basis: ROD specified the number of extraction wells which changed in RD/RA implementation; Consolidary
Treatment System with IWTP could substantially decrease costs.
9/26/86
7/98 (ESD)
5/98
7/98
EPA
Soil
EPA issued ESD fact
sheet; conducted
availability session in
July 1998.
Fed = 20 hours
Contr. = $0
Est'd Savings =
$200 K
Type of Change: From - off-site relocation of soil to landfill; To - on-site handling of solidified/stabilized soil.
Factual Basis: Level of treatment of soil is reduced; no change in volume.
Appendix A. 1
25
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 4
Whitehouse Waste Oil
Pits, FL
Region 4
Wrigley Charcoal Plant,
TN
Date of
Original ROD
Date of Change
(ESD/ROD-A)
5/30/85
6/16/92 (1st ROD-A)
9/24/98 (2nd ROD-A)
Date Review
Commenced
Date Review
Completed
1/6/95
9/24/98
Change
Initiator
PRP
Media
Sludge,
Soil, Ground
water, Sediment
State/Community
Involvement
Active State
involvement. EPA held
public meeting; public
comment period with
no written comments.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 500 hours
Contr. = $0
Est'd Savings =
$10.45 M
Type of Change: From - combination of soil washing, biological treatment, and solidification/stabilization (S/S) for soil; pump
and treat of ground water; To - S/S and containment for soil; containment for ground water through a vertical barrier and lime
curtain.
Factual Basis: Treatability studies showed biological treatment and S/S would not address problem for soil. Treatment
would be too costly and increase waste volume substantially for ground water.
9/30/91
10/97 (ESD)
1/97
10/97
EPA, State
Debris, Sludge,
Soil
A fact sheet was
provided to the public.
Fed = 20 hours
Contr. = $0
Est'd. Savings = $5 K
Type of Change: From - soil stabilization and backfill with clean fill, debris removal, off-site disposal and future monitoring;
To - complete removal of all waste material, off-site disposal and stabilization; monitoring is no longer necessary because the
soil has been replaced.
Factual Basis: New information was discovered during the initial RI/FS.
Appendix A. 1
26
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 4
Yellow Water Road
Dump, FL
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/30/92
4/6/98 (ESD)
Date Review
Commenced
Date Review
Completed
1/98
3/98
Change
Initiator
EPA
Media
Ground water
State/Community
Involvement
State reviewed and
concurred; EPA issued
fact sheet with
comment period.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed =10 hours
Contr. = $0
Est'd Savings =
$75 K
Type of Change: From - long-term ground water monitoring; To - elimination of long-term ground water monitoring.
Factual Basis: The site met ground water standards.
Region 4 - FY99
Region 4
American Creosote
Works, FL
9/28/89
5/21/99 (ROD-A)
7/92
5/21/99
EPA
Debris, Soil,
Sediment,
Sludge, Surface
Water
Active State
involvement;
community provided
extensive comments on
alternatives and on
sampling program.
EPA addressed both
issues.
Fed = 500 hours
Contr. = $0
Est'd Savings =
$ 1.6 M
Type of Change: From - biological treatment of about 24,000 cubic yards of surface soil; To - containment of 100,000 cubic
yards of soil, solidified sludge, and sediment.
Factual Basis: The scope of the remedy has increased from 24,000 cubic yards to 100,000 cubic yards because of a
restructuring of operable units. The change is necessary because treatability studies of biological treatment indicated that
adequate reduction of contaminants of concern could not be achieved.
Appendix A. 1
27
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 4
Anodyne, Inc. FL
Region 4
Fort Hartford Stone
Quarry Site, KY
Region 4
Helena Chemical, SC
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/17/93
7/1/99 (ESD)
Date Review
Commenced
Date Review
Completed
5/1/99
7/1/99
Change
Initiator
EPA
Media
Soil
State/Community
Involvement
State review of ESD;
community fact sheet
sent out to mailing list.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 50 hours
Contr. = $0
Est'd Savings = None
Type of Change: From - soil excavation performance standard of 0 mg/kg for nickel; To - soil excavation performance
standard of 4 mg/kg for nickel.
Factual Basis: Due to detection limits of the laboratory analytical equipment, it is difficult to reliably determine a 0 mg/kg
concentration.
3/95
7/99 (ESD)
6/99
7/99
PRP
Air
State reviewed ESD;
public comment period.
Fed = 200 hours
Contr. = $0
Est'd Savings =
$100 K
Type of Change: From - portal doors to close mine entrances, dispersion stacks to release mine air at night; To - no need for
portal doors and force ventilation of mine air.
Factual Basis: Air monitoring showed that ammonia concentration was below set threshold limits.
9/8/93
2/1 1/99 (ROD-A)
8/1/98
2/11/99
EPA
Soil
State concurrence;
public meeting; fact
sheet mailings.
Fed = 45 hours
Contr. = not available
Est'd Savings =
$ 1.1 M
Type of Change: From -soil incineration only; To - combination of incineration and landfilling of soils depending on
concentration of contaminants.
Factual Basis: Cost was the primary factor influencing ROD amendment.
Appendix A. 1
28
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 4
JFD Electronics/
Channel Master, NC
Region 4
Lexington County
Landfill, SC
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/20/92
5/4/99 (ROD-A)
Date Review
Commenced
Date Review
Completed
2/98
5/4/99
Change
Initiator
PRP
Media
Sludge
State/Community
Involvement
State concurrence;
EPA convened public
meeting and received
no comments.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed =160 hours
Contr. = $0
Est'd Savings =
$2.5M
Type of Change: From - excavation and on-site treatment of sludge with alkaline chlorination and stabilization, and on-site
disposal; To - off-site treatment and disposal.
Factual Basis: Remediation levels could not be attained for cyanide using alkaline chlorination. Implementability and
comparable cost estimates for off-site treatment and disposal outweigh preference for on-site treatment/disposal.
Note: The stated cost in the ROD is estimated at $1.5 million. A mini FS performed by the PRP in 1999 estimated that the
remedy in the ROD would actually cost around $5 million. The remedy stated in the ROD Amendment is estimated to cost
about $2.5 million. Therefore, the cost savings are approximately $2.5 million.
9/29/94
5/14/99 (ROD-A)
10/31/98
5/14/99
EPA
Soil
State concurrence;
public meeting; fact
sheet mailings.
Fed = 60 hours
Contr. = not available
Est'd Savings =
$3.5M
Type of Change: From -excavation/on-site containment; To - in place/on-site containment.
Factual Basis: Cost and short-term effectiveness were primary influencing factors for ROD amendment.
Appendix A. 1
29
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 4
Martin Marietta,
Soydeco, Inc.,
NC
Region 4
NAS Cecil Field, FL
Site 16
OU7
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/87
10/29/98 (ESD)
Date Review
Commenced
Date Review
Completed
8/98
10/29/98
Change
Initiator
PRP
Media
Soil
State/Community
Involvement
State reviewed and
concurred; no comment
period.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 85 hours
Contr. = $0
Est'd Savings = None
Type of Change: From - in-situ treatment of stockpiled soils; To - off-site treatment and disposal.
Factual Basis: The previous treatment technology did not work. The soils were included in the treatment method of
soils from another area of the site, that was selected in the original ROD and modified by a 1994 ESD.
9/16/96
5/12/99 (ROD-A)
9/98
5/12/99
EPA
Ground water
State and community
involved
Fed = 24 hours
Contr. = $0
Est'd Savings =
$ 1.4 M
Type of Change: From - pump & treat with discharge to Federal Waste Water Treatment Plant (FWWTP); enhance
bioremediation; To - air sparging in source area; natural attenuation down gradient; storm sewer repair; institutional controls.
Factual Basis: The base is closing, the FWWTP would no longer be available to receive discharges, and a pilot study
indicated that air sparging was feasible. Sampling has shown that enhanced bioremediation was not necessary. Portions of
the storm sewer are being replaced because of ground water discharge in the storm sewer.
Appendix A. 1
30
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 4
NAS Pensacola, FL
Site 1
OU1
(Inactive Sanitary
Landfill)
Region 4
National Starch, NC
OU3
Region 4
NC State, NC
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/25/98
9/28/99 (ESD)
Date Review
Commenced
Date Review
Completed
2/1/99
4/99
Change
Initiator
Navy
Media
Ground water
State/Community
Involvement
State concurrence;
community
involvement.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 20 hours
Contr. = $0
Est'd Savings =
$800K
Type of Change: From - extraction of ground water, followed by treatment and discharge into wetland 3; To - ground water
discharge directly to the wastewater treatment system on the base.
Factual Basis: The treatment plant could not handle incremental loading of iron sludge, as it would violate the allowable
discharge rate. However, the plant can accept a steady stream of the waste and has the capability to treat it.
10/7/93
11/4/98 (ESD)
10/7/98
11/14/98
PRP
Ground water
State concurred with
the ESD.
Fed = None
Contr. = None
Est'd Savings = None
Type of Change: From - changed part of OU3 ground water extraction system from extraction wells (2 wells); To -
collection trench (approximately 80 feet in length).
Factual Basis: Ground water modeling conducted by PRP's contractor indicated a trench would be a more efficient means
of extracting ground water out of a portion of the site.
9/30/96
7/21/99 (ESD)
5/99
7/21/99
PRP
Soil
State concurrence.
Fed = 30 hours
Contr. = $0
Est'd Savings = None
Type of Change: From - using in-situ augers for the Solidification/Stabilization (S/S); To - using a trackhoe for the S/S.
Factual Basis: The remedy was changed because subsurface conditions were incompatible with the auger method.
Appendix A. 1
31
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 4
Sapp Battery, FL
Region 4
Stauffer Chemical Co.,
FL
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/26/86
8/3 1/99 (ESD)
Date Review
Commenced
Date Review
Completed
6/99
8/31/99
Change
Initiator
PRP
Media
Soil
State/Community
Involvement
State informed of
change; no comment
period.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 50 hours
Contr. = $0
Est'd Savings =
$50K
Type of Change: From - treating plastic battery casings onsite with impacted soils; To - transporting plastic casings to an
off-site facility for recycling.
Factual Basis: Plastic casings are difficult to grind and interfere with the achievement of performance standards when
mixed with soil and solidified/stabilized.
7/8/98
6/15/99 (ESD)
5/28/99
6/15/99
PRP,
Public
Soil
State reviewed ESD;
no public comment
period.
Fed =120 hours
Contr. = $0
Est'd Savings = None
Type of Change: From - ROD identified arsenic as a contaminant of concern but did not specify a cleanup goal; To-
specific cleanup goal for arsenic.
Factual Basis: Arsenic was not given a cleanup goal at the time of the original ROD since it was co-mingled with other
contaminants. However, the PRP and public requested a cleanup goal be specified after viewing signed ROD.
Appendix A. 1
32
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 4
Stauffer Chemical
(Cold Creek Plant), AL
OU2
Region 4
Stauffer Chemical Co.,
FL
Date of
Original ROD
Date of Change
(ESD/ROD-A)
8/16/95
6/28/99 (ESD)
Date Review
Commenced
Date Review
Completed
6/8/98
6/28/99
Change
Initiator
PRP
Media
Soil
State/Community
Involvement
State reviewed draft
ESD; public notice in
paper.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 200 hours
Contr. = $0
Est'd Savings =
$ 195 K
Type of Change: From - One hundred percent on-site ex-situ bioremediation of contaminated soil in a closed impoundment;
To - Nine percent of the most contaminated soil being shipped off site for disposal and remaining 91% being bioremediated
on-site.
Factual Basis: Remedial design treatability study determined that bioremediation of 100% of the soil would take significantly
longer that had been estimated at the time the ROD was signed. Shipping the most contaminated soil off-site for disposal will
significantly reduce the treatment time for the remaining soils.
7/8/98
8/16/99 (ESD)
7/15/99
8/16/99
PRP
Soil
State review; no public
comment period.
Fed = 80 hours
Contr. = $0
Est'd Savings = None
Type of Change: From - beryllium remedial cleanup goal of 0.192 ppm; cap criteria according to Florida Code Sect. 62-
701.050; Petroleum contamination assessment in vicinity of two former aboveground tanks regulated by the Florida
Department of Environmental Protection (FDEP); performance standards for in-situ solidification/stabilization mixture:
compressive strength (100 psi), permeability (10"6 cm/sec); To - beryllium remedial cleanup goal of 120 ppm; cap criteria
according to Florida Code Sect. 62-701. 600. 5(g); no contamination assessment around former tanks, include assessment of
suspected petroleum product found in on-site monitoring well under direction of FDEP; performance standards changed to 50
psi, 10"5 cm/sec respectively.
Factual Basis: The change in ARAR prior to signing of ROD, raising cleanup standard from 0. 192 ppm to 120 ppm; change
in Florida code (original citation no longer exists); tank site investigation completed prior to signing of ROD; well product
assessment still needed; new performance data showed original requirements to result in construction problems.
Appendix A. 1
33
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 5 - FY98
Region 5
Acme Solvents, IL
Region 5
Allied Chemical/Ironton
Coke Plant, OH
9/85
1/98 (ESD)
Unknown
1/98
PRP
Hazardous
Waste
State concurred; no
community response.
Fed = Unknown
Contr. = Unknown
Est'd Savings =
Unknown
Type of Change: From - excavation and capping; To - delisting wastes and recalculating cleanup standard for RCRA cap.
Factual Basis: New information was discovered over time.
12/28/90
7/30/95 (lstROD-A)
9/4/97 (2ndROD-A)
9/30/98 (3rdROD-A)
12/1/97
9/30/98
PRP
Lagoon waste,
Soil, Ground
water
State concurred;
minimal community
response was
supportive.
Fed = 550 hours
Contr. = $0
Est'd Savings =
$50. OM
Type of Change: From - for lagoons 1-4, soils in-situ bioremediation; for lagoon soils 5, incineration; To- lagoon soils 1-4,
hot spot excavation and wetland development; for lagoon soils 5, recycling, treatment, and/or disposal of the K087 listed
waste in an approved off-site hazardous waste facility and the use of the remaining material, excluding debris, as an
alternative fuel.
Factual Basis: The changes were a result of the discovery of new information during the Remedial Design/Remedial
Action.
Appendix A. 1
34
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Galen Myers Dump/
Drum Salvage Site, IN
Region 5
Kohler Company
Landfill, WI
Region 5
Moss-American, WI
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/29/95
9/30/98 (ESD)
Date Review
Commenced
Date Review
Completed
4/97
9/30/98
Change
Initiator
State, EPA
Media
Soil
State/Community
Involvement
Official documents
available for public
viewing.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = Unknown
Contr. = Unknown
Est'd Savings =
$164 K
Type of Change: From - soil excavation; To - removal of soil excavation from remedy.
Factual Basis: The sampling conducted during the RD (Remedial Design) indicates that the volume of soils from the test pit
area exceeding the soil PRO (preliminary remediation goal) has decreased significantly. Sampling shows no soils in excess of
the PRO in the area.
3/92 (soil)
6/96 (GW)
9/29/98 (ESD)
9/27/98
9/30/98
EPA
Ground water,
Soil
State agrees with the
modifications made by
EPA.
Fed = 9 hours
Contr. = $0
Est'd Savings = $0
Type of Change: From - multi-layer cap constructed in phases over the landfill; To - capped remaining landfill area with a
low-permeability clay cover system.
Factual Basis: The remaining landfill area is capped consistent with the existing license requirements and subject to State
closure laws.
9/27/90
4/29/97 (ESD)
9/30/98 (ROD-A)
4/97
9/30/98
EPA
Soil, Ground
water
Fact sheet; public
comment period; public
meeting held.
Fed = 700 hours
Contr. = $10 K
Est'd Savings =
$2.0 M
Type of Change: From - biodegradation of contaminants; residential clean-up standards; permeable soil cover; To - low
temperature thermal desorption of contaminants; nonresidential clean-up standards; impermeable soil cover.
Factual Basis: Advances in contaminant treatment technology; potential remediated land use was reevaluated, greater
presence of dense non-aqueous phase liquids than expected.
Appendix A. 1
35
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Ott/Story/Cordova
Chemical Co., MI
OU3
Region 5
Refuse Hideaway
Landfill Site, WI
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/27/93
2/26/98 (ROD-A)
Date Review
Commenced
Date Review
Completed
5/22/95
2/98
Change
Initiator
EPA
Media
Soil
State/Community
Involvement
State concurs;
moderate response,
stating moderate
disfavor of reduction in
scope of remedy.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 700 hours
Contr. =$171 K
Est'd Savings =
$7.9 M
Type of Change: From - low temperature thermal desorption (LTTD) unit which thermally treated excavated contaminated
soils; To - elimination of LTTD; revises the volume of soils to be remediated by excavation and off-site disposal as a result of
an understanding that the land use for the site will remain industrial instead of residential.
Factual Basis: Original cleanup standards cited in the OU3 ROD were for residential use of site ground water and soils.
The site was deemed more appropriate for future industrial or commercial land use, thus the soil cleanup standards were
readjusted.
6/28/95
9/30/98 (ESD)
4/98
9/98
EPA
Ground water
State concurred with
the ESD.
Fed = 200 hours
Contr. = $30 K
Est'd Savings =
$2.7 M
Type of Change: From - anticipated implementation of ground water extraction and treatment component of remedy; To- no
installation.
Factual Basis: A significant decrease of total VOCs in ground water indicated that ground water should meet the remedial
objective within a reasonable period of time if source control measures continue to be operated and maintained.
Appendix A. 1
36
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Reilly Tar and Chemical,
IN
OU2
Region 5
Springfield Township
Dump, MI
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/92 (ROD)
9/30/93 (ROD)
10/6/97 (ESD)
Date Review
Commenced
Date Review
Completed
5/92
10/97
Change
Initiator
EPA, State
Media
Ground water,
Soil
State/Community
Involvement
State concurred;
published notice of the
ESD.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 80 hours
Contr. = Unknown
Est'd Savings =
$1.25 M
Type of Change: From - excavation, on-site thermal desorption of contaminated soil; To - excavation and off-site treatment
of the contaminated soils.
Factual Basis: The majority of soils to be treated as part of the remedial action contained extremely high BTU levels,
untreatable by a thermal desorption system.
09/02/90
11/1 0/93 (ESD)
6/10/98 (ROD-A)
3/98
6/98
EPA,
PRPs
Soil, Ground
water
The State accepted
change; high
community
involvement.
Fed = 500 hours
Contr. = 0
Est'd Savings =
$26.0 M
Type of Change: From - on-site incineration of polychlorinated bi-phenyl-contaminated soil; To - excavation and treatment
via soil washing of contaminated surficial soils, a limitation on the potential for future exposure to contaminants, the in-situ
treatment of subsurface soils through soil vapor extraction, and the extraction and treatment of ground water.
Factual Basis: The remedy was altered to reflect current State standards.
Appendix A. 1
37
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Tar Lake, MI
Region 5
Tri-County /Elgin
Landfill, IL*
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/29/92
7/30/98 (ESD)
Date Review
Commenced
Date Review
Completed
7/97
7/98
Change
Initiator
PRPs,
EPA
Media
Ground water,
(product) Tar
State/Community
Involvement
State concurred with
moderate community
involvement.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 200 hours
Contr. = 0
Est'd Savings =
$2.0 M
Type of Change: From - tar excavation with disposal into an on-site cell; To - tar excavation with disposal at a Fuel Reuse
Plant.
Factual Basis: The tar had high enough BTU values to be used as fuel.
9/30/92
6/25/96 (ESD)
2/96
4/96
EPA
Ground water
State concurred with
ESD; community
informed through
updated Administrative
Record and newspaper
advertisement.
Fed =150 hours
Contr. = 25 hours
Est'd Savings =
$3.0M
Type of Change: From - landfill cap, active landfill gas collection system, and ground water/leachate pump and treat system;
To - landfill cap and active landfill gas collection system; ground water/leachate pump and treat system deferred pending
further analysis of effectiveness of natural attenuation.
Factual Basis: February 1996 Pre-Design Investigation Study Report, as well as on-going residential and ground water
monitoring well sampling and analysis program.
*FY96 information reported in FY98.
Appendix A. 1
38
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Tri-County/Elgin
Landfill, IL
Region 5
Waite Park Wells/
Burlington Northern
Car Shop, MN
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/30/92
4/23/98 (ESD)
Date Review
Commenced
Date Review
Completed
11/26/96
9/30/97
Change
Initiator
EPA, State
Media
Soil, Landfill,
Ground water
State/Community
Involvement
State concurred with
ESD; community
informed through
updated Administrative
Record and newspaper
advertisement.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 50 hours
Contr. = 20 hours
Est'd Savings =
$1.95 M
Type of Change: From - low permeability clay barrier layer landfill cap; To - synthetic landfill cap, including a
geomembrane, geonet, geotextile, and 1 8 inches of soil cover.
Factual Basis: Results of a pre-design investigation demonstrated the original remedy to be unsuccessful over a long term
basis.
7/14/94
8/98 (ESD)
6/95
8/98
State
Soil
State has responsibility
for the site.
Fed = $1 K
State= $5 K
Contr. = Not available
Est'd Savings =
$500 K
Type of Change: From - solidification and on-site containment; To - excavation, off-site disposal, and the use of institutional
controls.
Factual Basis: Additional lead-impacted soil was identified that exceeded the cleanup levels.
Appendix A. 1
39
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Woodstock Municipal
Landfill, IL
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/30/93
7/15/98 (ROD-A)
Date Review
Commenced
Date Review
Completed
12/96
7/98
Change
Initiator
PRP
Media
Soil, Ground
water,
Sediment,
Landfill gases,
Leachate
State/Community
Involvement
State involved with
development of
materials for public
meeting. Public
comments addressed.
State concurred with
amended remedy.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed =100 hours
Contr. =50 hours
Est'd Savings =
$2.5 M
Type of Change: From - soil/sediment excavation and consolidation, install landfill cap and landfill gas collection system, and
pump and treat system for ground water; To - excavate and consolidate sediments and sludges, install geosynthetic landfill
cap and landfill gas venting, sediment control system, and monitored natural attenuation for ground water with a contingent
extract, treat and discharge system.
Factual Basis: The results of pre-design investigation for concentrations of vinyl chloride lead to a change in the remedy.
Appendix A. 1
40
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 5 - FY99
Region 5
American Chemical
Services, IN
9/30/92
7/27/99 (ROD-A)
12/98
7/27/99
PRP
Soil, debris
State concurred with
the update.
Fed = 1700 hours*
Contr. = $ 61 OK*
Est'd Savings =
$ 80.0 M
Type of Change: From - excavation and treatment using low temperature thermal desorption (LTTD); To - containment
using slurry wall and capping and treatment using soil vapor extraction to remove VOCs. Ground water pump and treat,
wetlands excavation, and intact drum removal are not affected.
Factual Basis: Post-ROD materials handling study demonstrated that original excavation/LTTD remedy may be unsafe to
implement; post-ROD treatability study demonstrated that LTTD is not applicable for much of the wastes, that incineration
(banned in Indiana) is more applicable; resulting revised cost estimate pegged RA costs at $150 million to $246 million versus
(1992) cost estimate in ROD of $38 million to $47 million.
* These figures represent work conducted from 10/94 to 9/98. The ROD remedy review required reevaluating technically
complex issues, reopening the baseline risk assessment, and conducting substantial treatability studies.
Appendix A. 1
41
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Bennett's Disposal, IN
Date of
Original ROD
Date of Change
(ESD/ROD-A)
8/3/84 (Enforcement
Decision Document)
10/15/98 (ROD-A)
Date Review
Commenced
Date Review
Completed
2/94
10/15/98
Change
Initiator
EPA, PRP
Media
Soil
State/Community
Involvement
State concurrence;
community involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = $100,000
Contr. = $80,000
Est'd Savings = not
available
Type of Change: From - incineration of 6 PCB contaminated sites in a to-be-built municipal waste fired incinerator. Due to
community opposition, the incinerator was not constructed. The cost was estimated to be $0 for the remedy due to the fees
charged to incinerate municipal waste; To - The ROD Amendment called for the excavation and off-site disposal in a
permitted PCB landfill. Any capacitors discovered during cleanup will be incinerated at an off-site, permitted PCB
incinerator. The cleanup remediated the site to industrial/low occupancy standards.
Factual Basis: There was opposition from the community and from other governmental parties who signed the Consent
Decree (City of Bloomington, State of Indiana, and Monroe County). The parties agreed to explore other remedies for the 6
sites under court supervision through the ROD Amendment process. The main portion of the site has been completed; the
sediment removal remains.
Appendix A. 1
42
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Bofors Nobel, Inc.,
MI
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/17/90
7/22/92 (First ROD-
A)
7/16/99 (Second
ROD-A)
Date Review
Commenced
Date Review
Completed
9/97
7/16/99
Change
Initiator
EPA,
PRPs
Media
Soil, Ground
water
State/Community
Involvement
State concurrence;
some community
comments to the first
ROD-A.
State concurrence on
second ROD-A.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
First ROD-A
Fed = 800 hours
Contr. = $ 900 K
Est'd Savings =
S40.0M
Second ROD-A
Fed = 1,760 hours*
Contr. = 0
Est'd Savings =
S25.0M
Type of Change:
First ROD-A From - soil treatment; To - containment in an on-site landfill.
Second ROD-A From - on-site landfill; To - landfill with cap and slurry wall, with extra component of phytoremediation
treatment.
Factual Basis:
First ROD-A - Cost savings based on Remedial Pre-Design data (equivalent level of protection).
Second ROD-A - Cost savings based on Potentially Responsible Parties' proposal (equivalent protection).
* It took 22 months and several drafts to reconcile changes from the PRP, the State, and others on the ROD amendment.
Appendix A. 1
43
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Butterworth #2 Landfill,
MI
Region 5
Fields Brook, OH
Sediment OU
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/29/92
10/23/98 (ESD #1)
12/23/98 (ESD #2)
Date Review
Commenced
Date Review
Completed
9/1/98
10/98
12/98
Change
Initiator
PRP
Media
Ground water,
Soil
State/Community
Involvement
State negotiations with
PRP
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 40 hours
Contr. = unknown PRP
contractor costs
Est'd Savings =
$2.7M
Type of Change: From - development of alternative concentration limits (ACLs) based on 8 quarters of sampling of ground
water at the site; four foot clay/soil cover over Radio Tower and Station Building area; To - ACLs using the State's ground
water/surface water interface procedures; one foot clay/soil cover over Radio Tower and Station Building area.
Factual Basis: Part 201 of State of Michigan National Resources and Environmental Protection Act for ACL change.
Leachate data showing highly weathered material in Radio Tower and Station Building area and PRP assurance that the soil
cover would be replaced by clay if ACL exceedances arose from the Radio Tower and Station Building area.
9/30/86 (ROD-A)
8/15/97 (ESD #1)
4/8/99 (ESD #2)
8/97
4/99
PRPs
EPA
Sediment
Sediment
Limited State
concurrence.
Fed = Unknown*
Contr. = Unknown*
Est'd Savings =
not available
Type of Change: From - thermal treatment of excavated sediments at an off-site facility; To - modification of all site RODs
to address radionuclides; sediments planned for incineration must contain background levels of radionuclides; if levels are
above background, sediment is to be solidified and disposed of on-site; additional clay added to base of the landfill.
Factual Basis: Discovery of radionuclides in site soils and sediments necessitated modification of site cleanup decisions.
* Unable to provide cost increases or cost savings on an OU or ESD basis, because the OU's were combined in the remedy
action.
Appendix A. 1
44
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
H. Brown Co. Inc., MI
Region 5
Lakeland Disposal
Services, Inc., IN
Date of
Original ROD
Date of Change
(ESD/ROD-A)
2/25/98
4/5/99 (ESD)
Date Review
Commenced
Date Review
Completed
10/2/98
4/5/99
Change
Initiator
PRP
Media
Soil, Ground
water
State/Community
Involvement
State concurrence.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed =106 hours
Contr. = $0
Est'd Savings =
$800K
Type of Change: From - constituents on the list of cleanup standards for soil and ground water; To - reduction of
constituents on the list of cleanup standards for soil and ground water.
Factual Basis: The PRPs were able to demonstrate based upon data from the Remedial Investigation (RI) and Pre-Design
data that several contaminants included in the list of cleanup standards were either present at background levels or were only
detected in one sample throughout the investigations.
9/28/93
10/15/98 (ROD-A)
N/A
10/15/98
PRPs
Soil
State reviewed and
concurred on the
ROD-A.
Fed = 100 hours
Contr. = $ 134 K
Est'd Savings =
$6.3M
Type of Change: From - excavation; off-site incineration; To - on-site treatment utilizing Low Temperature Thermal
Desorption (LTTD) of Waste Area #2.
Factual Basis: As a result of the data collected during redesign studies, the PRPs requested a modification for Waste
Disposal Area #2 (LTTD instead of off-site incineration). EPA believed that this update represents the best balance of the
nine criteria and was the most effective alternative which provides for overall protection of human health and the
environment. In other words, the LTTD option was found to be equally protective and involved a reduced cost.
Appendix A. 1
45
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
MacGillis & Gibbs/Bell
Lumber & Pole, MN
Date of
Original ROD
Date of Change
(ESD/ROD-A)
12/3 1/92 (OU1)
9/22/94 (OU3)
9/30/99 (ROD-A)
Date Review
Commenced
Date Review
Completed
3/96
9/99
Change
Initiator
State;
EPA; City
of New
Brighton,
MN
Media
Soil, Debris
State/Community
Involvement
State lead.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = $140K
Contr. = $170K
Est'd Savings =
$ 16.0 M
Type of Change: From - soil washing of Operable Unit 1 (OU1) soils and on-site incineration of OU1 debris and also on-site
incineration of OU3 soils; To - RCRA capping of OU1 and a portion of OU3, off-site disposal or incineration of OU1 debris
and also biological/chemical oxidation-reduction treatment of the remainder of OU3 soils with off-site landfilling of the treated
OU3 soils.
Factual Basis: The high cost of incineration and soil washing which totaled $26 million, as well as, unreliability of soil
washing prompted reevaluation of the remedies. In addition, EPA's Presumptive Remedy guidance was issued subsequent to
these RODs and had identified biological treatment as the Agency's primary presumptive remedy for wood treater sites
which further prompted the reevaluation of the existing remedies.
Appendix A. 1
46
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Neal's Dump, IN
Region 5
Neal's Landfill, IN
Date of
Original ROD
Date of Change
(ESD/ROD-A)
8/3/84 (Enforcement
Decision Document)
10/16/98 (ROD-A)
Date Review
Commenced
Date Review
Completed
2/94
10/16/98
Change
Initiator
EPA, PRP
Media
Soil
State/Community
Involvement
State concurrence;
community involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = $100,000
Contr. = $80,000
Est'd Savings = not
available
Type of Change: From - incineration of 6 PCB contaminated sites in a to-be-built municipal waste fired incinerator. Due to
community opposition the incinerator was not constructed. The cost was estimated to be $0 for the remedy due to the fees
charged to incinerate municipal waste. To - The ROD Amendment called for the excavation and off-site disposal in a
permitted PCB landfill. Any capacitors discovered during the cleanup will be incinerated at an off-site, permitted PCB
incinerator. The original cleanup remediated the site to industrial/low occupancy standards.
Factual Basis: Community opposition along with the other governmental parties who signed the Consent Decree opposing
the remedy (City of Bloomington, State of Indiana, and Monroe County). The parties agreed to explore other remedies for
the 6 sites under court supervision through U.S. EPA's ROD amendment process. The ROD Amendment called for the
excavation and off-site disposal in a permitted PCB landfill. Any capacitors discovered during the cleanup were incinerated
at an off-site, permitted PCB incinerator. The amended cleanup remediated the site to residential/high occupancy standards.
The site was de-listed from the NPL.
8/3/84 (Enforcement
Decision Document)
3/29/99 (ROD-A)
2/94
3/29/99
EPA, PRP
Solid waste
State concurrence;
community involvement
Fed = $1.0 M
Contr. = $16.0 M
Est'd Savings = not
available
Type of Change: From - building municipal waste fired incinerator and subsequent incineration of 6 PCB contaminated sites;
To - source control operable unit and a hot spot, consolidation and capping, future operable units for water treatment and
sediment removal.
Factual Basis: Community opposition along with governmental parties who signed the Consent Decree opposing the remedy.
The parties agreed to explore other remedies for the 6 sites under court supervision through the ROD Amendment process.
Appendix A. 1
47
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Ritari Post and Pole,
MN
Region 5
Spiegelberg Landfill, MI
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/30/94
7/2/99 (ESD)
Date Review
Commenced
Date Review
Completed
10/1/98
7/2/99
Change
Initiator
State
Media
Soil
State/Community
Involvement
State fund lead site.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = minimal
Contr. = minimal
Est'd Savings =
$4.0M
Type of Change: From - land treatment; To - consolidation and capping.
Factual Basis: New information suggested that the land treatment would not be effective.
6/29/90
10/22/98 (ESD)
Spring 1998
10/22/98
EPA
Ground water
Fact sheet sent to
residents in area; public
notice; State
concurrence.
Fed = $ 18 K
Contr. = not available
Est'd Savings =
$ 200 K/yr (PRPs)
Type of Change: From - pump and treat; To - monitored natural attenuation; updated current clean up criteria to reflect
current MCLs.
Factual Basis: The PRP requested a ROD Amendment. However, the selection of an ESD accomplished the same
objectives, within the dictates of CERCLA, faster and with less expense than a ROD amendment for all parties involved
(PRPs, EPA, and DEQ personnel). PRPs also reduced their O&M costs by $200,000 (their estimate).
Appendix A. 1
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 5
Tri-County/Elgin Landfill
St. Charles Township,
IL
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/30/92
7/14/99 (ESD)
Date Review
Commenced
Date Review
Completed
1/99
7/14/99
Change
Initiator
EPA
Media
Soil
State/Community
Involvement
Public notice of ESD in
local newspaper
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 50 hours
Contr. = 25 hours
Est'd Savings =
$500K
Type of Change: From - asphalt layer; To - revised high strength, low-permeability (1 x 10"8 cm/sec) asphalt cover. The
revised asphalt cap that is to be installed on the Elgin Landfill property and the Elgin-Wayne property will consist of two
discrete layers. The first layer will be a variable thickness base layer (minimum of 20 inches thick) and the second layer will
be a 4-inch thick combined modified asphalt binder and modified asphalt surface course of specially produced high-strength,
low permeability asphalt.
Factual Basis: The rationale for modifying the remedy for this portion of the site include the following: (1) the remedy is less
intrusive to install which reduces the disruption to existing businesses during construction; (2) the remedy allows for the
continued use of the Elgin Landfill and the Elgin- Wayne properties for container storage, parking, and other non-intrusive
beneficial uses; (3) the remedy is more cost effective; (4) the 1 x 10"8 cm/sec permeability of the remedy will ensure that the
new remedy will be as protective, if not more protective, than the alternative selected in the ROD; and (5) the design will
incorporate a lysimeter that will definitely measure seepage that might occur through the low-permeability asphalt cap,
alerting the U.S. EPA, the Illinois EPA, and the respondents to the need for repair or re-evaluation of the remedy.
Appendix A. 1
49
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 6 - FY98
Region 6
Petro-Chemical
Systems, Inc. (Turtle
Bayou), TX
OU2
9/6/91
4/30/98 (ROD-A)
3/12/96
4/98
EPA
Ground water,
Soil
State involvement
occurred throughout
ROD Amendment
Process; State and
community concurred
on amended remedy;
public meetings; site
tours; public comment.
Fed = 600 hours*
Contr. = $0
Est'd Savings =
$6.4 M
Type of Change: From - soil vapor extraction (SVE), containment, slurry wall, aquifer sparging; soil cleanup criteria for
benzene; To - additional remedy components including: in-situ aquifer bioremediation; bioventing, aqueous phase soil
bioremediation, soil excavation and biotreatment; in-situ thermal desorption; soil washing; monitored natural attenuation; and
institutional controls.
Factual Basis: Site cleanup criteria for benzene were recalculated using site-specific data. The narrowing of the site
boundary is based on years of field investigations and contamination data. Based on further site characterization, field pilot
studies, and ongoing operation, additional remedies were identified.
* Allowed for the use of several remediation technologies, in addition to SVE; several drafts of the ROD amendment were
required to satisfy the State and others.
Appendix A. 1
50
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 6
South 8th Street Landfill,
AR
Region 6
Texarkana Wood
Preserving Site, TX
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/29/94
7/22/98 (ROD-A)
Date Review
Commenced
Date Review
Completed
6/1/97
7/21/98
Change
Initiator
PRP
Media
Soil,
Sludge
State/Community
Involvement
Low to moderate
State/Community
interest; public
meetings held with a
local community group
and State health
department; State
concurred with
amended remedy.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 200 hours
Contr.= $0
Est'd Savings =
$4.9 M
Type of Change: From - excavation, stabilization of oily sludge pit, off-site disposal; To - in-situ stabilization/solidification.
This amendment also modifies the extent of the natural soil cover to be installed over the landfill in the source control OU.
Factual Basis: The results of recent treatability testing lead to a change in the remedy.
9/25/90
3/13/98 (ROD-A)
4/1/96
11/1/98
Public
Soil
Community concerns in
form of petition to
Congressman; public
comment period; CAG
formed.
Fed = 500 hours
Contr. = Negligible
Est'd Savings =
$3.5 M
Type of Change: From - thermal destruction to incinerate contaminated soil; To - capping of all soils above remediation
goals and construction of a fence around capped soil.
Factual Basis: The community was opposed to original remediation action (incineration). A consensus was reached with
the community advisory group (CAG) to use a cap for contaminated soils — an equally protective remedy.
Appendix A. 1
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 6
Vertac, Inc., AR
OU2
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/17/96
1/12/98 (ESD)
Date Review
Commenced
Date Review
Completed
8/11/97
1/5/98
Change
Initiator
EPA
Media
Soil
State/Community
Involvement
State was involved with
development of the
document and provided
comments; no
additional public
involvement was
initiated. State
concurred with ESD.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed =100 hours
Contr. = Negligible
Est'd. Savings =
$15.0 M
Type of Change: From - on-site consolidation of dioxin-contaminated soil into RCRA Subtitle C Landfill; To - additional
consolidation of dioxin-contaminated soil from the "Jacksonville Residential Areas site" in the Vertac on-site Subtitle C
landfill.
Factual Basis: The results of an Exposure Investigation performed jointly by ATSDR and State Health Department and data
obtained through additional rounds of sampling lead to a change in the remedy.
Appendix A. 1
52
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 6 - FY99
Region 6
Cleveland Mill, NM
Region 6
United Creosoting, TX
9/22/93
9/20/99 (ROD-A)
Spring 1997
9/20/99
EPA
Tailings,
Sediments
State provides
oversight; public
meeting held; State and
community
concurrence.
Fed = not available
Contr. = not available
Est'd Savings =
not available
Type of Change: From - excavation of waste material, transportation of the material to a reprocessor for treatment and
disposal of residuals at the reprocessing facility in an area where other tailings and residuals from ore-processing were
disposed; To - no further action with continuation of groundwater and surface water monitoring.
Factual Basis: The site threat was addressed by a time critical removal action since a reprocessor could not be found.
9/30/86
9/29/89
10/14/98 (ROD-A)
3/98
10/14/98
(ROD-A)
EPA
Soil
EPA and State held
several community
meetings (including one
formal public hearing).
Fed = 600 hours
Contr. = $0
Est'd Savings =
$21.0M*
Type of Change: From - innovative Critical Fluid Extraction (CFE) technology; To - Excavation, off-site treatment and
disposal.
Factual Basis: Innovative technology failed to meet remediation rate (actual rate of 10 to 35 tons of soil per day vs. contract
rate of 227 tons per day). Costs due to time extension would have greatly exceeded costs of off-site disposal. Public was
very vocal in opposing continuation of innovative technology.
* Cost savings were estimated by comparing the cost of the amended remedy to the projected cost (including overruns) of
completing the CFE remedy.
Appendix A. 1
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 7 - FY98
Region 7
Hastings Ground Water
Contamination
(Colorado Ave.), NE
Region 7
Pester Burn Pond, KS
9/91
5/98 (ROD-A)
10/97
5/98
PRP
Ground water
City and State
concurrence.
Fed = 300 hours
Contr. = TBD
Est'd Savings =
$1.0 M
Type of Change: From - conventional vadose zone soil vapor extraction (SVE) (1998 ROD) and ground water pump and
treat (1991 ROD); To - air sparging near source area and areas of ground water plume with high concentrations to increase
rate of VOC removal from ground water via SVE.
Factual Basis: The results of air sparging pilot test lead to a change in the remedy. Ground water cleanup may be
completed sooner than with pump and treat.
9/30/92
9/29/98 (ESD)
5/92
9/98
PRP
Soil, Sludge,
Ground water
State lead.
Fed = 0 hours
Contr. = $0
Est'd Savings = $0
Type of Change: From - bioremediation, soil flushing and soil/sludge disposal; To - add ground water interceptor trench
extension to include southwest drainage ditch.
Factual Basis: The change in remedy resulted from geotechnical evaluation and a treatability test.
Appendix A. 1
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 7 - FY99
Region 7
Des Moines TCE Site,
IA
OU 2, OU4
Region 7
Martha C. Rose
Chemical, MO
12/13/96
7/15/99 (ESD)
2/99
7/99
EPA
Soil, sediment,
buildings
State supported ESD.
Fed = 60 hours
Contr. = $ 6 K
Est'd Savings =
$ 1.2 M*
Type of Change: From - institutional controls (land use restrictions) and O&M for separate components of three removals
that provide similar levels of protectiveness; To - revised cost estimate for site management and maintenance of asphalt cap.
Factual Basis: Change in general approach to implementing the required land use restrictions and long-term O&M activities.
* Site will not be included in the FY99 summary appendix because the update is strictly cost-related.
9/92
12/98 (ROD-A)
10/96
11/98
PRP
Ground water
City concurrence; State
non-concurrence.
Fed= 180 hours
Contr. = $0
Est'd Savings =
$300K
(over 6 years)
Type of Change: From - ground water monitoring; To - terminated ground water monitoring prescribed in ROD.
Factual Basis: In actual excavation, a significantly greater amount of soil/sediment was removed (approximately twice as
much as originally planned). Ground water monitoring purpose was to signal mobilization of unknown contaminant sources.
The chance of sources existing after the completion of the much more extensive excavation process is nearly nonexistent and
ground water is not a likely exposure pathway.
Appendix A. 1
55
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 7
McGraw-Edison, IA
Region 7
Quality Plating, MO
Region 7
Strother Field, KS
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/24/93
7/99 (ROD-A)
Date Review
Commenced
Date Review
Completed
10/1/97
11/7/98
Change
Initiator
PRP
Media
Ground water
State/Community
Involvement
State and community
concurrence; public
meeting held.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 200 hours
Contr. = $ 8.4 K
Est'd Savings =
$ 1.3 M
Type of Change: From - vacuum enhanced ground water recovery; To - iron reactive permeable barrier and monitored
natural attenuation.
Factual Basis: The new innovative technology alternative will require less time and be more cost-effective.
1/95
9/99 (ROD-A)
9/97
9/99
State
Ground water
State concurrence.
Fed = 40 hours
Contr. = $0
Est'd Savings =
$3.0M
Type of Change: From - conventional pump and treat system; To - monitored natural attenuation.
Factual Basis: During RD it was discovered that the level of chromium+(i in the ground water had dropped by approximately
one order of magnitude, likely due to a chemical reaction (redox reduction).
3/94
12/98 (ESD)
3/98
12/98
PRP
Ground water
State concurrence.
Fed = 200 hours
Contr. = $0
Est'd Savings =
$4.0M
Type of Change: From - conventional pump and treat system; To - reduced pump and treat with monitored natural
attenuation (MNA) water; implement contingency soil excavation/capping component.
Factual Basis: Result of study including a Soil Vapor Extraction (SVE) pilot study and ground water biodegradation
investigation. MNA is occurring and SVE is impractical.
Appendix A. 1
56
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 8 - FY98
Region 8
Burlington Northern
(Somers Plant), MT
Region 8
Lowry Landfill Site, CO
9/27/98
6/92 (1st ESD)
7/21/98 (2nd ESD)
7/1/98
7/21/98
EPA
Ground water,
Soil
State concurred and
signed ESD.
Community was
provided with a fact
sheet.
Fed = 80 hours
Contr. = $0
Est'd. Savings = $0
Type of Change: From - bioremediation in an on-site land treatment unit; revised ground water remediation level for total
non-carcinogenic PAH and total phenolics; To - updated 1998 remediation levels of COCs, PAH, cPAH revised, pyrene,
napthalene and phenanthene.
Factual Basis: Changes in EPA toxicological information and updated relative potency factor (RPF) and toxicity equivalency
factor (TEF) guidance on cleanup remediation levels established in 1989 ROD for COCs (including total PAHs, cPAHs, and
phenolic compounds).
3/10/94
8/95 (1st ESD)
10/24/97 (2nd ESD)
4/23/96
10/24/97
PRP
Debris, Sludge,
Leachate, Soil,
Liquid waste,
Residuals,
Ground water
State supported the
changes; community
was opposed.
Fed = 700 hours*
Contr. = $200 K
Est'd Savings =
$3.0M
Type of Change: From - excavation and characterization of contaminated materials for off-site treatment and disposal,
treatment of ground water at an on-site treatment plant; To - excavation, drying/controlled aeration for contaminated
materials in the former tire pile area, and on-site disposal of contaminated materials, and on-site pre-treatment of ground
water, then piped to an off-site facility for additional treatment.
Factual Basis: Treatability tests indicated that proposed changes would best comply with NCP's nine criteria and potential
impact of the construction of a sanitary sewerline west of the site.
* Preparing the ESD, technical evaluations, responsiveness summary, and interacting with the public.
Appendix A. 1
57
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 8
Petrochem Recycling
Corp/Ekotek, Inc., UT
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/27/96
12/9/97 (ESD)
Date Review
Commenced
Date Review
Completed
3/13/97
12/9/97
Change
Initiator
PRP
Media
Soil, Ground
water
State/Community
Involvement
State supported all
changes, except the
alteration to the Soil
Hot Spot Performance
Standard for PCBs.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = Not available
Contr. = Not available
Est'd. Savings = Not
available
see 5/99 ESD
Type of Change: From - cleanup to soil performance standards, ground water treatment and discharge to a publicly-owned
treatment works (POTW); To - cleanup to new performance standards for 2, 3, 7, 8-TCD and PCBs, ground water
treatment, discharge to POTW, optional discharge to underlying aquifer.
Factual Basis: The changes documented in the ESD are based on new information received subsequent to issuance of
ROD. New calculation of performance standards based on error correction, revised risk factors, and revised guidance.
Region 8 - FY99
Region 8
Chemical Sales, CO
OU4
12/29/92
9/23/99 (ROD-A)
9/30/98
9/23/99
EPA
Ground water
No significant
comments from State
and community
expected.
Fed = 80 hours
Contr. = $0
Est'd Savings =
$3.0M
Type of Change: From - connection of three wells to a water treatment plant; To - No Action (alternative water source was
found).
Factual Basis: Memorandum of Understanding regarding a supplementary water supply was reached among U.S. Army,
Shell Oil Company, and South Adams County Water and Sanitation District (SACWSD) in June 1996. Therefore, the hookup
of the three wells was no longer needed.
Appendix A. 1
58
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 8
Eagle Mine, CO
Region 8
F.E. Warren AFB
Cheyenne, WY
Landfill 5A
OU8
Date of
Original ROD
Date of Change
(ESD/ROD-A)
3/29/93
9/1/99 (ESD)
Date Review
Commenced
Date Review
Completed
7/1/99
9/1/99
Change
Initiator
EPA
Media
Ground water
State/Community
Involvement
Endorsed by State; no
significant comments
expected.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 40 hours/yr
Contr. = $0
Est'd Savings =
$ 20 K/yr
(over 13 years)
Type of Change: From -no diversion of clean groundwater; To - drilling of a deep well to intercept and divert a clean source
of water that was entering the plugged Eagle Mine (some 200 gallons/min had previously entered the mine and were
eventually sent to a water treatment plant).
Factual Basis: An inflow of 200 gallons/min of known clean water was entering the Eagle Mine. This clean water became
polluted with metals and was eventually collected for water treatment. This inflow has been intercepted by an 840 foot deep
well and some 100 gallons/min are now pumped and discharged.
11/21/96
11/13/98 (ESD)
2/1/98
11/13/98
USAF
Landfill
Restoration Advisory
Board Display Ad Fact
Sheet
Fed = $ 6 K
Contr. = $0
Est'd Savings =
$240K
Type of Change: From - active gas collection system; To - perimeter monitoring for methane.
Factual Basis: Post-ROD soil gas surveys established that an active gas collection system was not needed. Post-ROD
work also showed a smaller area/volume of landfill contents than originally assumed, savings due to only the gas system are
part of the $2.6 M, overall, due to smaller waste volume. No contractor costs attributed to change in design because change
was made early in the design stage and no re-working was needed. USAF did not itemize.
Appendix A. 1
59
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 8
F.E. Warren AFB
Cheyenne, WY
Landfill 6
OU3
Region 8
Idaho Pole Site, MT
Date of
Original ROD
Date of Change
(ESD/ROD-A)
12/21/95
2/3/99 (ESD)
Date Review
Commenced
Date Review
Completed
2/1/98
2/3/99
Change
Initiator
USAF
Media
Landfill
State/Community
Involvement
Restoration Advisory
Board Display Ad Fact
Sheet.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = $ 6 K
Contr. = $ 2 K
Est'd Savings =
$583K
Type of Change: From - active gas collection system; To - passive gas venting system.
Factual Basis: Post-ROD soil gas surveys established that an active gas collection system was not needed. Total saved
over RI/FS estimate was $4.5M (includes reduced costs attributed to ESD). Post-ROD work also established a smaller
area/volume than originally assumed. Total savings were not itemized by USAF.
9/28/92
11/27/98 (ESD)
7/1/98
11/27/98
EPA
Soil, Ground
water,
Demolition
debris
State concurred and
signed ESD; fact sheet
provided to community.
Fed =120 hours
Contr. = $0
Est'd Savings = None
Type of Change: From - expansion of amount of work done at site from the original scope which did not include soil
excavation adjacent to buildings and structures; To - additional work which included building demolition and excavation of
contaminated soils where remediation levels were exceeded. IPC discontinued active operations in October 1997. Additional
cleanup under plant structures will be required. ESD will expand scope of ROD to include building demolition and soil
cleanup where remediation levels are exceeded.
Factual Basis: Original RI identified areas of the site associated with existing structures where remediation levels are
exceeded.
Appendix A. 1
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 8
Petrochem Recycling
Corp/Ekotek, Inc., UT
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/27/96
5/1 1/99 (ESD)
Date Review
Commenced
Date Review
Completed
3/30/99
5/11/99
Change
Initiator
PRP
Media
Soil, Ground
Water
State/Community
Involvement
State and community
support.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = None
Contr. = None
Est'd Savings = Long
term costs considered
equal. See Factual
Basis.
Type of Change: From - storing of contaminated soils in an on-site repository; To - removal of manganese; all soil exceeding
"soil performance standards" will be sent off-site to a RCRA-permitted landfill (no on-site repository).
Factual Basis: The changes documented in the ESD are based on new information received subsequent to issuance of
ROD. The manganese reference dose value was updated in the IRIS database. Soil volume estimates and total remedy cost
estimates were compiled during the value engineering component of the Remedial Design. Total costs in the original ROD
estimate were $6.1 million. These costs were updated with the new estimate being $10.0 million. The changed remedy in
this ESD is also estimated to be $10.0 million.
Appendix A. 1
61
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 9 - FY98
Region 9
JH Baxter Superfund
Site, CA
Region 9
Lorentz Barrel and
Drum, CA
OU2
9/27/90
3/27/98 (ROD-A)
8/95
3/27/98
PRPs
Soil, Ground
water
Approved by State and
community. EPA
conducted public
meeting and addressed
comments in
responsiveness
summary.
Fed = 4,500 hours*
Contr. = $550 K
Est'd Savings =
$20.0 M
Type of Change: From - extraction of ground water followed by biological treatment and chemical precipitation, polishing,
and disposal; excavation of organic soils and biological treatment and disposal to RCRA-equivalent cell; excavation of
inorganic soils for biological treatment, chemical fixation, and on-site disposal in RCRA-equivalent cell; To - incorporate slurry
wall into ground water remedy. TI waiver for ground water within the Dense Non- Aqueous Phase Liquid (DNAPL) zone.
Factual Basis: A Focused Feasibility Study found that the extent of DNAPLs was much greater than previously thought.
* A complex site; cleanup levels were reexamined and revised; most of the remedy decision was rewritten.
9/22/88
4/24/98 (ESD)
1992
4/24/98
PRPs
Ground water
EPA, State, and
Regional Water Quality
Board concurred;
Administrative Record
available for review.
Fed = 200 hours
Contr. = $0
Est'd Savings =
$30 K
(over 10 years)
Type of Change: From - ground water extraction and treatment using ultra violet light and oxidizing chemicals (ozone)
(UV/Ox) and then granular activated carbon (GAC) filters with discharge to a local storm sewer; To - GAC filtration
exclusively to treat contaminated water.
Factual Basis: The levels of organic contaminants have decreased since the start of the ground water treatment system and
UV/Ox was found to be inefficient.
Appendix A. 1
62
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 9
Phoenix-Goodyear
Airport, AZ
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/87
12/95 (3rd ESD)
3/98 (4th ESD)
Date Review
Commenced
Date Review
Completed
12/95
3/98
Change
Initiator
PRPs,
EPA
Media
Ground water
State/Community
Involvement
The State concurred
with EPA on ESD #3;
local government was
briefed and the
community was notified
as required by
regulation.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed =100 hours
Contr. = $5 K
Est'd Savings =
$3.1 M
(3rd ESD-$840 K*
4th ESD-$2.25 M)
Type of Change: (For 3rd ESD) From - ground water pump and treat system; To - ground water pump and treat system with
air sparging hot spots. (For 4th ESD) From - chromium Ground water Standard at 50 ppb; To - chromium Ground water
Standard at 100 ppb.
Factual Basis: (For 3rd ESD) It is a well documented fact that volatile organic compound (VOC) contaminants in the
environment can be removed from the unsarurated zone (vadose zone) at a significantly less cost when compared to the cost
of removing VOC's from saturated zone (ground water). At the PGA site, site-specific costs of $60/lb VOC removed via
soil vapor extraction (SVE) versus $1000/lb VOC removed via ground water pump and treat were calculated. Hence, $940
of savings for every pound of VOC that is removed. The lead PRP at this site implemented air sparging in VOC-
contaminated hot spots in the ground water which were underlying an existing soil vapor extraction system.
(For 4th ESD) New information was discovered when the MCL for chromium was finalized.
* Although the site was included in the FY96-97 summary report, the savings were not reported at that time and are being
reported now.
Appendix A. 1
63
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 9
Selma Pressure
Treating, CA*
Region 9
Stringfellow Acid Pits,
CA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/88
4/97 (ESD)
Date Review
Commenced
Date Review
Completed
3/97
4/97
Change
Initiator
EPA
Media
Ground water
State/Community
Involvement
State reviewed and
concurred. Fact sheets
were sent to people on
community distribution
list; public comment
period provided.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed =120 hours
Contr. = 0
Est'd Savings =
$900 K
Type of Change: From - return of effluent via reinjection wells; To - return of effluent via percolation ponds.
Factual Basis: Additional data gathered in design; reinjection was considered to entail risk of spreading ground water
contamination.
* Although this update was counted in updates reported for FY97, estimated savings and resource demand information were
reported at that time.
7/1 8/84 ROD 2
7/9/98 (ESD)
11/7/97
7/8/98
EPA, State
Ground water
State and the
Community Technical
Advisor support the
ESD; public hearings;
comments solicited
from State, PRPs, and
the community on the
ESD.
Fed = 40 hours
Contr. = $0
State = $1. 8 M
Est'd Savings =
$28.4 M
Type of Change: From - transportation of treated ground water (30 million gallons/yr) to disposal point by tanker truck; To -
transportation of the treated ground water to disposal point by pipeline.
Factual Basis: Treated wastewater transported from pretreatment plant (PTP) to regional wastewater collection system
used to be by tanker truck. Since ROD completion, making a direct pipeline connection has been cost-effective and
eliminates potential community impacts from spillage during road transport.
Appendix A. 1
64
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Region 9 - FY99
Region 9
Hunter's Point (USN),
CA
Region 9
Koppers Co., Inc., CA
12/31/97
10/28/98 (ESD)
4/1/98
10/28/98
EPA
Soil
State reviewed ESD;
discussion with
community advisory
board (RAB); formal
public notice by Navy
pending.
Fed = 40 hours
Contr. = not available
Est'd Savings = None
Type of Change: From - maximum depth of soil cleanup to ground water; To - maximum depth of soil cleanup to 10 feet
below ground surface.
Factual Basis: The change was required to bring the ROD into congruence with the proposed plan and feasibility study that
were submitted to the community for comment. The ROD had mistakenly assumed that cleanup to ground water was
equivalent to cleanup to 10 feet. In some cases, cleanup to ground water would have resulted in cleanup of less than 10 feet
and that was not the intent of the remedial action.
9/13/89
9/23/99 (ROD-A)
1/26/99
9/23/99
PRP, EPA,
Ground water
Proposed plan not
opposed, accepted by
DTSC & RWQCB.
Fed = 420 hours
Contr. = $ 10.7 K
Est'd Savings =
$ 11. 3 M
Type of Change: From - pump and treat only; To - on-site bioremediation and pump and treat, plus off-site bioremediation
with a 200-acre technical impracticability (TI) Zone for DNAPL.
Factual Basis: On-site biodegradation augments the existing pump and treat system and restores the aquifer an estimated 10
years earlier. Off-site biodegradation will restore the aquifer within a similar time frame as pump and treat, but at one-eighth
of the cost. The TI Zone waiver is due to DNAPL with monitoring showing containment. Savings are based on Total
Present Worth Cost.
Appendix A. 1
65
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 9
Motorola, Inc. (52nd
Street Plant), AZ
Date of
Original ROD
Date of Change
(ESD/ROD-A)
7/21/94
9/10/99 (ESD)
Date Review
Commenced
Date Review
Completed
4/98
9/10/99
Change
Initiator
PRP
Media
Ground water
State/Community
Involvement
State involvement; fact
sheet and public
meetings; technical
meetings with technical
assistance grant
recipients; ADWR also
involved.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 80 hours
Contr. = $16 K
Est'd Savings =
$7.0M
(30 yr present value at
5%)
Type of Change: From - air stripping or ultraviolet oxidation; reinjection of treated ground water; To - ultraviolet oxidation
and granular activated carbon; discharge of treated ground water to Grand Canal.
Factual Basis: Ultraviolet oxidation and granular activated carbon are more cost effective and just as efficient as air
stripping or UV/ox alone. Discharge of water is also more cost effective and will save on long-term O&M costs.
Region 10 - FY98
Commencement Bay
Nearshore Tideflats;
Former Asarco Tacoma
Smelter Facility and Slag
Peninsula, WA
OU2*
3/24/95
7/2/96 (ESD)
prior to 9/95
7/2/96
EPA, PRP
Soil
Fact Sheet; two public
comment periods; open
houses; participants at
the community meeting
supported the change.
Fed = 30 hours
Contr. = $0
Est'd Savings = $0
Type of Change: From - siting the on-site containment facility in the arsenic kitchen area; To - siting the on-site containment
facility in the parking lot.
Factual Basis: Seismic tests, required by the ROD, revealed that the original location of the on-site containment was not
safe in the event of an earthquake.
* FY96 information reported in FY98.
Appendix A. 1
66
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 10
Eielson Air Force Base,
AK
OU3, 4 and 5
Region 10
Fort Lewis Logistics
Center, WA
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/30/95 (OU3, 4, 5)
9/98 (ROD-A)
Date Review
Commenced
Date Review
Completed
5/95
9/98
Change
Initiator
Air Force,
EPA, State
Media
Ground water,
Soil, Drums,
Landfill
State/Community
Involvement
Public comment period;
public meeting;
newspaper
advertisement;
infomercial on
television; no public
comments received.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = Not available
Contr. = $1.2 M
Est'd Savings =
$20.0 M
Type of Change: (For Site DP44) From - soil vapor extraction (SVE); To - no further action. From - pump and treat; To -
monitoring and institutional controls.
(For Site SS35) From - soil cover; To - no action and monitoring.
(For Site ST58) From - bioventing; To - no action after removal. From - bioventing; To - TI for lead, natural attenuation and
biodegredation for petroleum, and institutional controls.
(For Site LF03/FT09) From - cover/cap; To - institutional controls and monitoring. From - monitoring and institutional
controls; To - same.
Factual Basis: Recent sampling, pilot test of SVE, biological risk assessment, and re-evaluation of risk. A technology
effectiveness evaluation (prior to implementation of original remedy) showed that lead is largely immobile in the subsurface,
and that lead contamination cannot be readily removed using pump and treat technology.
9/90
9/9/98 (ESD)
1/97
9/98
EPA, Fed.
Fac.
Ground water
Public notice was
issued.
Fed= 180 hours
Contr. = $0
Est'd Savings =
Unknown
Type of Change: From - ground water extraction and treatment in on-site treatment facilities; To - add innovative
technologies to accelerate treatment and/or control of the source area, the contaminant plume, and the unconfined aquifer.
Factual Basis: New site characterization studies, limited system performance data, recent information concerning the
effectiveness of pump and treat systems, and the availability of new and innovative treatment options.
Appendix A. 1
67
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 10
Hanford 200 Area;
Environmental
Restoration Disposal
Facility, WA*
Date of
Original ROD
Date of Change
(ESD/ROD-A)
1/20/95
9/25/97 (ROD-A)
Date Review
Commenced
Date Review
Completed
1/97
9/25/97
Change
Initiator
DOE,
EPA, State
Media
Soil, Debris
State/Community
Involvement
Fact sheet; public
comment periods;
briefings of the
Hanford Advisory
Board.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 55 hours
Contr. = $0
Est'd Savings =
operations savings not
quantified; actual
construction cost for
two cells less than
ROD-estimated cost
for construction of
facility.
Type of Change: From - construction and operation of two disposal cells; treatment only at the OU where waste originates;
To - construction and operation of four disposal cells; treatment at OU or at the disposal facility.
Factual Basis: Expansion of the approved disposal facility is necessary to continue remediation of the Hanford site.
* FY97 information reported in FY98
Appendix A. 1
68
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 10
Idaho National
Engineering Lab,
ID
OU Pit 9
Region 10
McCormick and
Baxter Creosoting
Company, OR
Date of
Original ROD
Date of Change
(ESD/ROD-A)
10/1/93
9/1/98 (ESD)
Date Review
Commenced
Date Review
Completed
6/1/98
9/1/98
Change
Initiator
Fed. Fac.
Media
Soil, Debris
State/Community
Involvement
EPA and State
concurred. The
community was
notified.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 40 hours
Contr. = $0
Est'd. Savings = no
change
Type of Change: From - physical separation, chemical extraction, and stabilization of contaminants; To - change in
subcontractor and implementation of contingency path for the clean up of Pit 9.
Factual Basis: A change in subcontractor was necessary, initiating a contingency plan that involved a revised schedule.
3/29/86
3/17/98 (ROD-A)
6/97
3/17/98
State
Soil
Fact sheets prepared;
public meeting;
presentation at
neighborhood
association meeting.
Fed = 75 hours
Contr. = $10 K
Est'd Savings = $0
Type of Change: From - on-site biological treatment of soil with off-site disposal including soil with significant dioxin
concentrations and cap; To - off-site disposal of soil at RCRA-permitted facility.
Factual Basis: Increased levels of dioxin in soils lead to a change in the remedy.
Appendix A. 1
69
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Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 10
Umatilla Army Depot,
OR
Explosives Washout
Lagoons, Soils OU*
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/25/92
9/30/97 (ESD)
Date Review
Commenced
Date Review
Completed
6/97
9/30/97
Change
Initiator
Army,
EPA
Media
Soil
State/Community
Involvement
Active State
involvement; public
notice of ESD (no
comments received).
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 40 hours
Contr. = $0
Est'd Savings =
$445 K
Type of Change: From - using soil treated by composting for backfilling; To - using soil treated by composting as an organic
component in on-site re-vegetation efforts.
Factual Basis: The treatment of explosives contaminated soil by composting resulted in lower final concentration than
predicted, combined with the suitability of the compost for on-site vegetative restoration, results in lower costs from reduced
need to purchase compost from local commercial sources.
* FY97 information reported in FY98.
Region 10 - FY99
Region 10
Commencement Bay -
South Tacoma Channel
NPL Site, South
Tacoma Field, WA
9/29/94
8/10/99 (ESD)
3/99
8/10/99
PRP
Ground water,
Soil
Washington
Department of Ecology
concurred with the
revised approach. A
public notice of the
ESD was published.
Fed = 40 hours
Contr. = $0
Est'd Savings =
$ l.OM
Type of Change: From - air sparging and soil vapor extraction at the Pioneer Builder's Supply section of the site; To -
monitored natural attenuation and institutional controls at the Pioneer Builder's Supply section of the site.
Factual Basis: Post-ROD sampling results indicated that the contaminated ground water area was smaller and less mobile
than previously assumed. In addition, the contaminant concentrations have been decreasing since the removal of the source
in 1991.
Appendix A. 1
70
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites Without Cost Increases
Region
Site Name, State
Region 10
Hanford 200 Area, WA
Environmental
Restoration Disposal
Facility
Region 10
Standard Steel, AK
Date of
Original ROD
Date of Change
(ESD/ROD-A)
1/20/95
3/25/99 (ROD-A)
Date Review
Commenced
Date Review
Completed
2/98
3/25/99
Change
Initiator
DOE
Media
Landfill,
Leachate
State/Community
Involvement
Fact sheet; public
comment period;
newspaper notices; and
briefings to Hanford
Advisory Board.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Savings
Fed = 200 hours
Contr. = $0
Est'd Savings =
Not Quantified
Type of Change: From - landfill leachate managed as a RCRA hazardous waste; To - conditional listing of the leachate so it
no longer needs to be managed as a RCRA hazardous waste.
Factual Basis: Contaminant concentration data collected on landfill leachate supported conditional delisting of the leachate.
7/16/96
11/1 8/98 (ESD)
9/98
11/18/98
PRP
Soil
State supported
change; newspaper
notice.
Fed = 30 hours
Contr. = $0
Est'd Savings =
$ 30 K (not including
future O&M savings)
Type of Change: From - fence around capped area of site; To - no fence necessary around capped area of site (waiver of
40CFR761.75(b)(9)(i)).
Factual Basis: Final approved cap design added geomembrane cover system and 3 feet of clean soil. Thus, site did not
require protective fence.
Appendix A. 1
71
-------
Appendix A.2:
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 2 - FY98
Region 2
Reich Farm, NJ
9/30/88
8/95 (1st ESD)
3/25/98 (2nd ESD)
2/97
3/25/98
EPA
Ground water
State concurred; EPA
conducted public
meeting; Administrative
Record is available for
public review.
Fed =100 hours
Contr. = $0
Est'd Increase =
$2.0 M
Type of Change: From - extraction, treatment of contaminated water via air stripping and carbon absorption, reinjection to
aquifer and later discharge to municipal water supply; To - additional ground water treatment, allowable discharge as potable
water supply to designated recharge area.
Factual Basis: Additional studies showing plume extended further than previously expected. Air stripper has been
effective.
Region 2 - FY99
Region 2
American Cyanamid
Wiring, PR
7/12/96
11/30/98 (ESD)
6/1/98
11/30/98
PRP
Soil, Sludge
There was state
support for the change
and limited community
interest in the remedy
update
Fed = 40 hours
Contr. = 0
Est'd Increase =
$5.4 M
Type of Change: From - containment of iron oxide waste; To - recycling
Factual Basis: PRP felt that there was a future ground water release risk that would result in excess future O&M costs to
the remedy. The original ROD estimate was thought to be low. Lastly the PRP was able to secure favorable rates for
recycling.
Appendix A.2
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Region 2
NL Industries, Inc., NJ
Date of
Original ROD
Date of Change
(ESD/ROD-A)
7/8/94
6/21/99 (ESD)
Date Review
Commenced
Date Review
Completed
2/11/99
6/21/99
Change
Initiator
EPA
Media
Soil, Sediment
State/Community
Involvement
State reviewed and
commented on ESD
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = 40 hours
Contr. = $0
Est'd Increase = Slight
Increase
Type of Change: From - on-site disposal of soil and sediment; To - off-site disposal of soil and sediment
Factual Basis: Due to the elimination of solid waste flow control restrictions, EPA determined that off-site disposal of the
contaminated soil and sediment could be conducted at a cost comparable to that for on-site disposal (including the cost for
construction of a landfill). In addition, off-site disposal of the soil and sediment could be implemented more quickly because
it did not require construction of a landfill.
Region 3 - FY98
Region 3
East Mount Zion, PA
6/29/90
7/96 (ESD)*
5/96
7/96
EPA
Soil
State concurred.
Fed = 75 hrs.
Contr. = 0
Est'd. Increase =
$25 K
Type of Change: From - no relocation of residents; To - temporary relocation of residents during the solid waste
excavation and purchase of additional property to secure excavation access.
Factual Basis: EPA deemed an ESD necessary to prevent potential health threats to residents during remedial action.
* FY96 information reported in FY98.
Appendix A.2
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 3 - FY99
Region 3
Berkley Products Dump,
PA
Region 3
Keystone Landfill, PA
6/28/96
8/20/99 (ESD)
12/98
8/20/99
EPA
Soils, Leachate
Sediments,
Landfill
materials
State concurrence;
public notification.
Fed =182 hours
Contr. =240 hours
Est'd Increase =
$ 1.1 M
Type of Change: From - Excavation and placement of contaminated soils, leachate sediments, and landfill materials into an
onsite landfill; landfill was to be filled and capped on-site; To - Excavation and placement of contaminated soils, leachate
sediments, and landfill materials into onsite landfill; unanticipated excess 16,500 tons of material will also be excavated,
characterized, transported and disposed offsite.
Factual Basis: The excess excavated material cannot be accommodated by the proposed landfill. An expansion of the on-
site landfill is not possible because it is unlined, and because of the surrounding naturally steep inclines.
9/90
6/25/99 (ROD-A)
1/98
6/25/99
EPA
Ground water
State concurred with
remedy change;
community commented
on amendment and
EPA addressed
comments.
Fed = 250 hours
Contr. = not available
Est'd Increase =
$ 1.8M
Type of Change: From - no actions addressing migration of site related contaminants to surrounding areas; To - extraction
and treatment of contaminated ground water which has migrated offsite and monitoring and/or installation of residential well
treatment units; modifications were also made to the performance/clean up standards of the onsite pump and treat system
currently operating onsite; and five year review will be required because hazardous substances above health-based levels
still present on-site.
Factual Basis: These additions to the original remedy, aid in treating, reducing toxicity, mobility and volume of site related
contaminants.
Appendix A.2
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Region 3
Rhinehart Tire Fire, VA
OU1
Region 3
Rhinehart Tire Fire, VA
OU2
Date of
Original ROD
Date of Change
(ESD/ROD-A)
6/30/88
4/2/99 (ESD)
Date Review
Commenced
Date Review
Completed
6/30/88
4/2/99
Change
Initiator
EPA,
State
Media
Surface water,
Ground water
State/Community
Involvement
State concurrence.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = 60 hours
Contr. = $0
Est'd Increase =
$ 1.3 M
Type of Change: From - controlling soil erosion, increasing pond capacity, collecting surface water runoff, gravity settling
of contained surface runoff and collecting of shallow ground water and oily seeps for oil/water separation; To - building a
small plant to supplement the passive settling process in order to remove the metals.
Factual Basis: After initial implementation of measures from ROD, further sampling indicated that pond water exceeded
allowable discharge levels for concentrations of zinc, aluminum and nickel.
9/29/92
4/2/99 (ESD)
3/3/95
4/2/99
EPA,
State,
Fed. Fac.
Soil
State concurrence.
Fed = 60 hours
Contr. = $0
Est'd Increase =
$ 150 K
Type of Change: From - excavation of soil beneath pond with zinc concentrations greater than 50 ppm; To - pond was
covered with clean fill, compacted, graded, and vegetated.
Factual Basis: After several attempts to attain the standard, the excavation hit bedrock and further remediation was
jeopardizing an adjacent earthen dam structure. Further work was suspended.
Appendix A.2
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 3
Tonolli Corporation, PA
9/30/92
3/12/99 (ESD)
9/98
3/12/99
EPA
Soil
State concurrence.
Fed =100 hours
Contr. = $0
Est'd Increase =
$ 1.1 M
Type of Change: From - decontamination and demolition of non-structural components which would inhibit
decontamination; excavation of lead contaminated soil; on-site landfill; pump and treatment system for leachate soil
bioremediation; and plan for final grading of site; To - demolition and removal of former smelter buildings; excavation of an
increased volume of lead-contaminated soil; expansion of an on-site landfill; pumping and treatment of an increased volume
of leachate soil bioremediation; and modification of the final grading plan for the site.
Factual Basis: Concrete structures were discovered with high amounts of contamination and were unstable as a result of
soil excavation required by the ROD. Additional information was discovered which affected other issues in the ESD, most
often dealing with the need for removal or remediation of expanded areas of contaminated soil.
Region 4 - FY98
Region 4
Wrigley Charcoal Plant,
TN
9/30/91
10/95 (ESD)*
7/95
10/95
EPA, State
Debris, Sludge,
Soil
A fact sheet has been
provided for the public.
Fed = 25 hours
Contr. = $0
Est'd. Increase :
$72 K
Type of Change: Not a typical update, since additional work was required. Site required excavation of an additional 3,000
tons of contaminated material.
Factual Basis: Prevent leaching of contaminants from soil into creek.
* FY96 information reported in FY98.
Appendix A.2
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Region 4
Escambia, FL
Date of
Original ROD
Date of Change
(ESD/ROD-A)
2/12/97
4/30/98 (ESD)
Date Review
Commenced
Date Review
Completed
2/98
4/30/98
Change
Initiator
EPA
Media
Soil,
O&M
State/Community
Involvement
Both State and
community informed.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = 20 hours
Contr. = $0
Est'd Increase =
$250 K/yr for 3 years
Type of Change: From - No maintenance of stockpile; To - additional maintenance of stockpile.
Factual Basis: Allowed EPA to spend money to maintain the site until implementation of final remedy.
Region 4 - FY99
Region 4
Chemform, Inc., FL
OU1
Region 4
Chevron Chemical
Co./Marzone
OU1
Tifton, GA
9/22/92
4/2/99 (ESD)
10/98
4/2/99
State,
EPA
Ground water
State reviewed ESD.
Fed = 50 hours
Contr. = $0
Est'd Increase =
$ 10 K
Type of Change: From - no five-year reviews; To - five-year reviews at the site.
Factual Basis: Vinyl chloride (VC) has been detected in monitoring wells above its MCL level. VC is not listed in the OU
1 ROD as an ARAR, but its presence is attributable to the site and therefore warrants five-year reviews.
9/94
11/98(ROD-A)
3/97
11/98
EPA
Soil
Public meeting and
comment period
Fed = $10,000
Contr. = $0
Est'd Increase =
$150,000
Type of Change: From: no discussion of dioxin contaminated soil in former burn pit area; To: performance standard and
remedy for dioxin: excavation and off-site disposal.
Factual Basis: Dioxin contamination was discovered during remedial design phase. This ROD amendment was necessary
to address dioxin contamination in the former burn pit area.
Appendix A.2
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Region 4
NAS Cecil Field, FL
Site 10
OU4
Date of
Original ROD
Date of Change
(ESD/ROD-A)
9/30/97
7/12/99 (ESD)
Date Review
Commenced
Date Review
Completed
4/20/99
7/12/99
Change
Initiator
State
Media
Soil
State/Community
Involvement
State concurrence;
RAB was briefed and
reviewed ESD.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = 40 hours
Contr. = $0
Est'd Increase =
$5 OK
Type of Change: From - original ROD was for No Further Action; To - soil excavation with off-site disposal.
Factual Basis: Based on data from Pre-Design Field Investigation and redevelopment plan. Remedy proposed by private
party, and included facilities that would serve as impermeable barriers.
Region 5 - FY98
Region 5
H. Brown Co. Inc., MI
9/30/92
2/25/98 (ROD-A)
8/97
2/98
EPA, State
Soil, Sediments,
Ground water
State concurred. EPA
responded to eight
public comments on the
Proposed Plan.
Fed = 500 hours
Contr. = $0
Est'd Incr =
$3.1 M
Type of Change: From - cap over contaminated soil; To - redevelopment of site including clean fill and construction of
warehouse facilities.
Factual Basis: Based on data from Pre-Design Field Investigation and redevelopment plan. Remedy proposed by private
party, and included facilities that would serve as impermeable barriers.
Appendix A.2
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 5 - FY99
Region 5
Fields Brook, OH
Source Control OU2
Region 5
Fields Brook, OH
Floodplains/Wetlands
OU4
9/29/97
4/8/99 (ESD)
1/98
4/8/99
EPA
Soil
State concurrence
expected.
Fed = Unknown*
Contr. = Unknown*
Est'd Increase =
$ l.OM*
Type of Change: From - excavation of soils and backfill with clean soil, on-site containment of soils with cover and erosion
blanket, disposal of soils either on-site or at an off-site TSCA landfill; removal of sediment and debris inside sewer lines and
catch basin; To - modified all site RODs to address radionuclides (includes adding radium-226 and radium-228 as
contaminants of concern for the Millenium source control area).
Factual Basis: Discovery of radionuclides in site soils and sediments (including Millenium soils/mining residuals)
necessitated modification of site cleanup decisions.
* Unable to provide cost increases or cost savings on an OU or ESD basis because the OUs were combined in the remedy
action.
6/30/97
4/8/99 (ESD)
1/98
4/8/99
EPA
Soil
State concurrence
expected.
Fed = Unknown*
Contr. = Unknown*
Est'd Increase =
$ 2.0-3. OM
Type of Change: From - excavation and on-site containment of soils and sediments; backfilling and revegetation in
floodplains/wetlands area; installing a cover in certain areas of floodplains/wetlands; To - modified all site RODs to address
radionuclides (includes adding radium-226 and radium-228 as contaminants of concern for the Millenium source control
area).
Appendix A.2
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Region 5
St. Louis River-
U.S. Steel, MN
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Factual Basis: Discovery of radionuclides in site soils and sediments (including Millenium soils/mining residuals)
necessitated modification of site cleanup decisions.
** Unable to provide cost increases or cost savings on an OU or ESD basis, because the OUs were combined in the remedy
action.
2/22/89
6/4/97 (ESD)*
4/12/97
5/26/97
State
Soil, ground
water
State has the lead
responsibility on this
site
Fed = not available
Contr. = not available
State = $5K
Est'd Increase =
not available
Type of Change: From - coal tar settling basin; To - in-situ stabilization. OU P (Wire Mill Pond) - From - no action; To -
removal and disposal.
Factual Basis: OU J - A competent clay layer to support building of a slurry wall for the settling basin could not be found.
OU P - No action was originally chosen because it was believed that natural sedimentation would cover the waste and
prevent exposure. Natural sedimentation did reduce contaminant levels, as predicted, and the remedy was reevaluated.
*The remedy update was completed in FY97, but was reported in FY99.
Region 8 - FY98
Region 8
Anaconda Smelter, MT
3/8/94
11/6/95 (ESD)*
10/94
10/95
EPA
Soil
State provided review
and concurrence;
public meeting, fact
sheet and public notice
provided; close
coordination with
Anaconda-Deer Lodge
County.
Fed =100 hours
Contr. = $0
Est'd Increase =
$500 K
Appendix A.2
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Type of Change: No change in remedy — increased area of operable unit.
Factual Basis: County informed EPA of discrepancy in property boundaries at Mill Creek. As EPA contemplated a
change of Mills Creek boundary, EPA became aware of proposed development in Aspen Hills Subdivision which is adjacent
to Mill Creek. EPA then decided to expand the Mill Creek boundary to include both areas.
* FY96 information reported in FY98.
Appendix A.2
10
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Region 8
Silver Bow Creek/ Butte
Area, SSTOU, MT
Date of
Original ROD
Date of Change
(ESD/ROD-A)
11/29/95
8/3 1/98 (ESD)
Date Review
Commenced
Date Review
Completed
5/1/98
8/31/98
Change
Initiator
State
Media
Tailings, Soils,
Sediments,
Surface water,
Debris, Ground
water
State/Community
Involvement
EPA concurred; ESD
placed in SSTOU
information repository
in several public
locations.
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Fed = 20 hours
State = 100 hours
Contr.= $8 K
Est'd Increase =
$50.8 M*
Type of Change: From - removal of tailings and soils with some relocated into nearby repositories and some treated in
place; removal of sediments into nearby repositories; excavation, treatment, and/or cover of contaminated railroad bed
materials; and institutional controls, monitoring, and maintenance as required; To - modified alignment of Silver Bow Creek
and channel profile, change in criteria applied for in-stieam sediment removal, modified mine waste relocation repository,
inclusion of sediment basins to contain contaminant overland flow run-on from off-site mine waste sources, change in
schedule to implement remedy, elimination of treatment wetlands as end use in Subarea 1 .
Factual Basis: In the course of preparing the SSTOU design, DEQ and EPA reevaluated certain elements of the remedy
as described in the ROD in light of new site information developed in the design process.
* An $81 million cash-out settlement with the PRP covered the increased cost reflected in this ESD.
Region 9 - FY98
Region 9
Lorentz Barrel and
Drum, CA
OU2
9/22/88
5/29/98 (ESD)
3/98
5/98
EPA
Soil, Debris
None.
Fed =160 hours
Contr. = $0
Est'd Increase=
$108 K
Type of Change: Unanticipated soil and debris removal.
Factual Basis: Materials found at site during preparation for capping were found to be unacceptable for retention under the
cap and thus needed to be removed off-site.
Appendix A.2
11
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 9 - FY99
Region 9
San Gabriel Valley
Area 2, CA
Baldwin Park OU
3/30/94
5/99 (ESD)
3/99
5/99
EPA
Ground water
State concurrence.
Fed =120 hours
Contr. = $ 5 K
Est'd Increase =
$ 38.0 M (capital) plus
$ 6.0 M/yr (O&M)
Type of Change: From - cleanup of contamination caused by VOCs only, using air stripping with vapor phase GAC, liquid
phase GAC and/or advanced oxidation; To - cleanup of contamination caused by VOCs, perchlorate, nitrosodimethylamine
(NDMA), and 1,4-dioxane requires, in addition to the above, treatment by ion exchange and/or biological reduction.
Factual Basis: In 1997, it was discovered that, in addition to VOCs, ground water in the Baldwin Park OU is contaminated
by perchlorate, NDMA, and 1,4-dioxane. Treatment of these contaminants needed to be added to the remedy.
Appendix A.2
12
-------
Summary of Remedy Update Information for FY98 and FY99 for Sites With Cost Increases
Region
Site Name, State
Date of
Original ROD
Date of Change
(ESD/ROD-A)
Date Review
Commenced
Date Review
Completed
Change
Initiator
Media
State/Community
Involvement
Est'd Resource
Demands -
Fed/Contr.
Est'd Cost Increase
Region 10 - FY98
Region 10
Bunker Hill Mining and
Metallurgical Complex,
ID
Region 10
Pacific Hide and Fur
Recycling Company, ID
9/30/92
1/18/96 (1st ESD)
4/18/98 (2nd ESD)
8/95
4/8/98
EPA, State
Air,
Ground-water/
Surface Water,
Sediments,
Soils, Debris
Community discussions,
fact sheets, task force
meetings, public
comment period.
Fed = Unknown
Contr. = Unknown
Est'd. Increase = $338
K
Type of Change: From - industrial waste landfills — capping in place; creek channelization and lining; Smelterville
Flats — removal and/or capping of mine wastes; decontamination of lead smelter and zinc plant stacks; demolition of zinc
plant building and decontamination of phosphoric acid fertilizer warehouse; To - industrial waste landfills — excavation and
consolidation; participation in storm drainage pipeline system; disposal of limited quantities of additional mine wastes to
facilitate closure of the central impoundment areas; clarification of excavation goals in Magnet and Government Gulches;
Smelterville Flats — diversion of precipitation from mine wastes in an approximately 60 acre area; demolition of lead smelter
and zinc plant stacks; decontamination and reuse of zinc plant building and demolition of phosphoric acid fertilizer
warehouse.
Factual Basis: The changes were deemed necessary by new information and enhanced understanding of the highly
complex site.
9/25/95
4/20/98 (ESD)
1996
4/20/98
PRP
Soil
State supported
change; public
comment period will be
part of final consent
decree process.
Fed = 50 hours
Contr. = $0
Est'd Increase =
Unknown
Type of Change: From - remediation of lead-contaminated soils above 1,000 mg/kg, implementation of institutional controls
and a five-year review; To - removal and disposal of lead-contaminated soils above 400 mg/kg, no institutional controls, and
no five-year reviews.
Factual Basis: Sampling data showed that a small amount of additional remediation would remove all soil above a
residential cleanup level.
Appendix A.2
13
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