&EPA
United States
Environmental Protection
Agency
Office of Solid Waste and
Emergency Response
OSWER 9355.0-116
EPA-540-R-06-074
Updating Remedy Decisions
at Select Superfund Sites
Summary Report
FY 2004 and FY 2005
February 2007
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Illllllllllllllllllllllllllllllllllllll
SUMMARY REPORT FY04 AND FY05
Executive Summary (FY04-FY05)
Since FY96, EPA has been regularly updating its Superfund remedial decisions when appropriate.
As described in the National Oil and Hazardous Pollution Contingency Plan (NCP 1990), remedies
may be updated through either an Explanation of Significant Differences (ESD) or a Record of
Decision (ROD) Amendment (see Section 300.435 (c)(2)(i) ands (ii)). In addition, Regions use a
third type of remedy update for minor remedy changes and this is called "Additional Note to the
Administrative Record File." Additional guidance on documenting the three kinds of post-ROD
changes can be found in Chapter 7 of the document titled, "A Guide to Preparing Superfund
Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents," OSWER
Directive 9200.1-23.P, dated July 1999 (http://www.epa.gov/superfund/resources/remedy/rods/index.
htm).
New Memorandum in FY05 - Although EPA's
initial guidance on remedy updates was issued
in September 1996 (OSWER Directive 9200.2-
22), in August 2005, EPA expanded the reform
in a memorandum titled, "Re-Emphasize Use
and Expanded Tracking of the Superfund Reform
"Updating Remedy Decisions"" (OSWER Directive
9200.0-22-1). Both documents can be accessed
on EPA's website: www.epa.gov/superfund/
programs/reforms/docs.pdf.
New Reform Tracking in FY05 - In October
2005, the Remedy Update Reform was part of
a broader effort to improve the workings of the
program known as Superfund Cost Management
Measures (OSWER Directive 9275.1-12-D). The
documents mentioned above recommend that EPA
Regions continue to update remedies when there
is supporting data to do so and to expand the use
of the reform to include non-technical as well as
technical remedy changes.
This is the fifth summary report documenting every
two years of progress since FY96. The four previous
summary reports can be accessed on the same
EPA website as previously mentioned.
Since its inception, Updating Remedy Decisions continues to be characterized as one of EPA's most
successful Superfund reforms. This summary report shows that in FY04 and FY05, EPA updated
more than 130 remedies, reducing estimated future cleanup costs by more than $260 million
(gross savings). Other key successes and findings in this report include the following:
Q Many remedy updates completed during FY04 and FY05 were the result of additional technical
information gathered as part of the remedy design process. Other updates were the result of
the need to implement institutional controls; non-technical changes in the applicable or relevant
and appropriate requirements (ARARs), land use, or required cleanup levels; and State input or
community preference which focused on either technical or non-technical modifications to the remedy.
Terminology
Remedy Update Reform was
announced in October 1995, to keep
selected Superfund remedies in
line with advances in science and
technology.
Technical Changes in remedies can
result from additional data collection,
modeling results, or differences in the
original site conditions that need to be
addressed in the selected remedy.
Non-technical Changes in remedies
can result from new or additional
institutional controls or changes in
ARARs that need to be included in
the selected remedy.
Cost Management Measures was
a 2005 initiative to manage time and
resources of the Superfund program
more effectively.
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
In FY04, the total estimated cost savings for remedy updates were in excess of $70 million, 92
percent of which was based on scientific and technological advancements. For remedy updates
completed in FY05, the total estimated cost savings were in excess of $188 million, all of which
was based on scientific and technological advancements. There were 27 remedy updates in FY04
that resulted in cost increases totaling an estimated $96.2 million, and there were 22 remedy
updates in FY05 that resulted in cost increases totaling an estimated $84.8 million. The majority of
the cost increase totals were attributable to the remedy updates for a small number of sites.
Estimated cost savings for 135 individual remedy updates during FY04 and FY05 ranged from a
few thousand dollars to more than $41.0 million, with most remedy updates generating savings
less than $10.0 million. Of the 49 remedy updates that resulted in estimated cost increases, of
more than $180.0 million, there was a median cost increase of $2.0 million.
Remedy updates generally occurred in the remedial design phase of the cleanup process and
were more likely to be documented with ESDs than ROD Amendments. During the two-year
period, there were 109 ESDs and 26 ROD Amendments representing remedy updates with both
cost savings and increases.
Most remedy updates during FY04 and FY05 were initiated by parties outside of EPA (e.g.,
potentially responsible parties (PRPs), States, communities, Federal facilities). During the two-
year period, parties outside of EPA initiated 71 updates and EPA initiated 54 updates (these
numbers do not include 10 updates initiated by more than one party).
During the two-year period, the most commonly addressed medium was ground water (79
updates) followed by soil (65 updates). Seven other media types were addressed by remedy
updates during FY04 and FY05.
In FY05, more remedy updates were related to other Superfund initiatives than in previous years.
Superfund's initiative to add new or supplementary institutional controls and a recent focus
to optimize existing pump and treat systems for ground water remediation typically would be
documented by an ESD or ROD Amendment.
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Illllllllllllllllllllllllllllllllllllll
SUMMARY REPORT FY04 AND FY05
Cumulative Summary (FY96-FY05)
Since its inception, Updating Remedy Decisions has continued to significantly impact Superfund
sites across the country. From FY96-FY03, there were 520 remedy updates reducing future cleanup
costs by more than $1.9 billion while at the same time increasing estimated future cleanup costs
by $486.1 million. By including the FY04 and FY05 data, the cumulative totals for FY96-FY05 are
655 remedy updates reducing future cleanup costs by more than $2.1 billion, while at the same time
increasing estimated future cleanup costs by $667.1 million.
Over the initial ten years of implementing the remedy update reform, EPA has shown overwhelming
success regarding large savings of money, time, and resources. There is no clear pattern to the
number of updates completed each year or whether they tend to result in more or less estimated cost
savings or increases for a particular year. There does appear to be an overall trend of less estimated
cost savings per change and an increase in the number of changes resulting in estimated cost
increases.
# of Updates
Remedy Updates 10-Year Trend
Estimated Cost Savings
(millions of dollar)
Estimated Cost Increases
(millions of dollar)
96
97
98
99
00
01
02
03
04
05
64
84
76
83
64
47
42
60
75
60
$352.7
$394.9
$282.1
$430.9
$185.0
$84.1
$58.7
$87.6
$72.5
$188.2
0
$13.5
$57.0
$58.0
$87.7
$12.5
$176.3
$81.1
$96.2
$84.8
TOTALS 655 $2,136.7 $667.1
III
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
Table of Contents
Executive Summary (FY04-FY05) i
Cumulative Summary (FY96-FY05) iii
1.0 Introduction 1
2.0 FY04andFY05 Results 2
Exhibit 2.1: Estimated Remedy Update Net Savings by Region for FY04 and FY05 3
Exhibit 2.2: Estimated Savings Per Remedy Update for FY04 and FY05 3
Exhibit 2.3: Remedy Updates by Medium for FY04 and FY05 4
Exhibit 2.4: Number and Type of Remedy Updates for FY04 and FY05 4
3.0 Remedy Update Process 5
Exhibit 3.1: Remedy Update Initiators in FY04 and FY05 5
3.1 Determination of Remedy Update Type 6
Exhibit 3.2: ESDs vs. ROD Amendments in FY04 and FY05 6
3.2 State/Tribal and Community Roles 7
3.3 Remedy Review Duration 8
Exhibit 3.3: Durations for FY04 and FY05 Remedy Updates 9
4.0 Lessons Learned 10
4.1 Benefits 10
4.2 Site Examples 10
5.0 Conclusion 12
Acknowledgments 13
Appendix A: Summary of Remedy Update Decisions for FY04 and FY05
Appendix A.1: Summary of Remedy Update Decisions Without Cost Increases for FY04 and FY05
Appendix A.2: Summary of Remedy Update Decisions With Cost Increases for FY04 and FY05
IV
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Illllllllllllllllllllllllllllllllllllll
SUMMARY REPORT FY04 AND FY05
1.0 Introduction
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 the 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 can be implemented in a manner that continues to protect
human health and the environment while enhancing overall remedy cost effectiveness.
This report contains an evaluation of remedy updates completed during FY04 and FY05. Information
regarding the progress of the reform, during the previous ten years, is available in four two-year
summary reports and a cumulative four-year report.
Summary
Report, FY 1996
and FY1997
Summary
Report, FY 1998
and FY1999
Cumulative
Summary
Report FY 1996
Through FY
1999
Summary
and FY 2001
Summary
and FY 2003
Multi-year Summary Report
Updating Remedy Decisions at Select Superfund Sites, Summary Report, FY
1996 and FY 1997. July 1998. OSWER Directive 540-R-98-017. 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.
http://www.epa.gov/superfund/proqrams/reforms/docs/urd96-97.pdf
Updating Remedy Decisions at Select Superfund Sites, Summary Report, FY
1998 and FY 1999. March 2001. OSWER Directive 540-R-01 -00.
http://www.epa.qov/superfund/proqrams/reforms/docs/urd98-99.pdf
Updating Remedy Decisions at Select Superfund Sites Cumulative Summary
Report FY 1996 Through FY 1999. March 2001. OSWER Directive 9355.0-77.
http://www.epa.qov/superfund/proqrams/reforms/docs/urd96-99.pdf
Updating Remedy Decisions at Select Superfund Sites, Summary Report, FY
2000 and FY 2001. February 2003. OSWER Directive 9355.0-94.
http://www.epa.qov/superfund/proqrams/reforms/docs/rem report.pdf
Updating Remedy Decisions at Select Superfund Sites, Summary Report, FY
2002 and FY 2003. September 2004. OSWER Directive 9355.0-107.
http://www.epa.qov/superfund/proqrams/reforms/docs/rem report.pdf
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
This report:
Q Provides a summary of Super-fund sites
where remedies have been updated during
FY04 and FY05;
O Highlights estimated future cost reductions
(cost savings) or cost increases expected to
result from updated remedies; and
O Presents stakeholders with information on
the role of remedy updates in improving
Superfund implementation.
Originally, EPA encouraged remedy updates
to incorporate new technical information into
existing site cleanups. Today, EPA continues to
promote remedy updates that incorporate the
latest science and technology into selecting and
implementing Superfund remedial decisions. As
a whole, these reforms were selected to make
Superfund faster, fairer, and more efficient. The
remedy update reform has achieved each of
these goals.
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 for 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 environment.
EPA expanded the tracking of the Remedy
Update Reform in August 2005 to include all
changes, either technical or non-technical
(OSWER Directive 9200.0-22-1 available on
EPA's previously mentioned reform website).
An example of a technical remedy change
is monitoring data showing the presence of
either additional contaminant or additional
contaminants not previously identified in earlier
data. An example of a non-technical remedy
change is the inclusion of institutional controls.
2.0 FY04 and FY05 Results
EPA completed approximately 135 remedy
updates in FY04 and FY05 representing a total
estimated cost savings of more than $260.0
million in estimated site cleanup costs. Some
decisions resulted in total estimated cost
increases totaling approximately $180.0 million.
The net estimated cost savings for the two-year
period is approximately $80.0 million.
Updates during FY04 resulted in a total
estimated cost savings of more than $72.5
million, most of which resulted from updates
of the kind identified in the Reform Guidance.
Updates during FY05 resulted in a total
estimated cost savings of more than $188.2
million, many of which 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's website: http://www.epa.
gov/superfund/programs/reforms/remedy/
index.htm.)
The estimated cost savings per update ranged
from a few thousand dollars to $41.0 million,
with the majority of EPA Regions reporting
savings in each year reviewed. Exhibit 2.1
shows the amount of estimated savings for
FY04 and FY05. (Note: Exhibit 2.1 includes
all remedy updates identified in CERCLA
Information System (CERCLIS) and through
points-of-contact in each Region.)
Most of the remedy updates generated savings
of less than $10.0 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 on updated
remedies that generated cost increases during
FY04 and FY05. The FY04 cost increases for 27
remedy updates totaled $96.2 million. The FY05
cost increases for 22 remedy updates totaled
Continue > pg 4
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Illllllllllllllllllllllllllllllllllllll
SUMMARY REPORT FY04 AND FY05
Exhibit 2.1: Estimated Remedy Update Net Savings by Region for FY04 and FY05
70-fl
DFY04
• FY05
Region
10
Notes:
Based on 135 remedy updates.
Net savings = estimated gross savings - estimated gross increase
negative net savings (i.e., net increases) are shown as zero (0)
Exhibit 2.2: Estimated Savings Per Remedy Update for FY04 and FY05
Updates - Increases, No Savings, TBD
Updates w/Savings
Increases
36%
NA/TBD
2%
No Savings
33%
D No Savings • Increases • NA/TBD D Savings
Notes:
Based on 135 remedy updates.
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
$84.8 million. Of the remedy updates generating
estimated cost increases during FY04 and
FY05, most were less than $5.0 million per
update. The remedy update cost increases for
FY04 and FY05 occur in all ten EPA Regions;
only half of which had more than four increases
during the two-year period.
Media
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 FY04
and FY05, updates of ground water remedies
were the most common (79 updates), followed
by soil remedies which includes subsurface soil
(65 updates). The remaining updates pertained
to seven 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 site, and include the following
information:
O Type and date of remedy update;
Q Update initiator;
O Media involved;
O State and community involvement;
O Estimated resource demands;
O Estimated cost savings or cost increases; and
O Summary of remedy change and factual
basis.
Exhibit 2.4 depicts the number of remedy
updates that were completed in FY04 and
FY05. It shows that not all remedy updates
generated cost savings or cost increases. In
some cases, the remedy updates generated
neither cost savings nor cost increases; in other
cases, the numbers are yet to be determined or
were unavailable at the time of this report. This
confirms that the summary totals for both years
are conservative values for estimated cost
savings and increases.
Exhibit 2.3: Remedy Updates by
Medium for FY04 and FY 05
Medium
Ground Water
Soil
Sediment
Waste
Surface Water
Air
Debris
Sludge
Other
FY04
39
41
8
1
5
1
3
1
9
FY05
40
24
2
4
2
0
1
1
2
Total
79
65
10
5
7
1
4
2
11
*0ther includes: fluvial tailings, source materials, soil
gas, and tank contents Notes:
Exhibit 2.4: Number and Type of Remedy
Updates for FY04 Through FY05
Total # of
Remedy Updates
# Updates With
Estimated Savings
# Updates With
Estimated Increases
# Updates With No
Savings
# Updates NA or TBD
FY04
75
20
27
26
2
FY05
60
19
22
19
0
Total •
135
39
49
45
2
Based on 135 remedy updates.
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Illllllllllllllllllllllllllllllllllllll
SUMMARY REPORT FY04 AND FY05
3.0 Remedy Update Process
The remedy update process is described in
the 1996 Guidance and in the four previous
two-year summary reports (http://www.
epa.gov/superfund/programs/reforms/
docs.htm#cleanup). The identification
and prioritization, technical review, and
implementation of remedy updates have not
changed in this current report. As always, new
information may be received or generated from
different sources that could affect the selection
or implementation of the selected remedy. This
information may be supplied by a Potentially
Responsible Party (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 FY04 and FY05 indicate that 71 remedy
updates were initiated by parties outside of
EPA (e.g., PRPs, States, Federal facilities) (this
number only contains single, listed initiators)
compared to 54 updates initiated by EPA (see
Exhibit 3.1). In addition, 10 remedy updates
have joint initiators (this number includes any
category that has 2+ initiators listed) because
information arrived simultaneously from several
different parties. Exhibit 3.1 shows that the
relative percentage of remedy update initiators
were not significantly different from FY04 to
FY05. (FY05 Decrease site of Tar Creek, R6,
was not included in any of these categories)
Exhibit 3.1: Remedy Update Initiator in FY04
Public
1%
Fed Fac
40%
Remedy Update Initiator in FY05
Other 2%
Public 2%
Fed Fac
33%
PRP
15%
n PRP (9)
• EPA (25)
n Joint (3)
D Fed Fac (20)
n State (1)
• Public (1)
• Other(1)
Notes:
Based on 135 remedy updates.
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
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:
O Updating the remedy may result in a more
cost-effective cleanup;
O Changes in physical limitations imposed by
the site or the contaminants may warrant
changes in the cleanup goals; or
a
Changes in site conditions may warrant
reducing the scope of the site monitoring
after cleanup.
Fundamental Change may include
a remedy update that 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.
Significant Change may include a
remedy update that generally involves
incremental change to a component of
a remedy that does not fundamentally
alter the overall remedial approach.
Non-significant or Minor may include
a remedy update that usually arises
during design or construction when
modifications are made to the functional
specifications of the remedy to optimize
performance and minimize cost.
3.1 Determination of
Remedy Update Type
To characterize the remedy update type, EPA
generally continues to consider three factors:
scope, performance or cost. Based on an
evaluation of these three factors and depending
on the extent or scope of the modification being
considered, the lead agency should 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 significant changes could result in a
fundamental change overall.
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 generally will determine
which of the following documents 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. As shown in Exhibit 3.2, there
were 109 ESDs and 26 ROD Amendments
completed during FY04 and FY05.
Exhibit 3.2: ESDs vs. ROD Amendments in
FY04 and FY05
FY04 FY05
ESD
ROD A
62
13
47
13
109
26
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Illllllllllllllllllllllllllllllllllllll
SUMMARY REPORT FY04 AND FY05
In general, more remedy updates occur during
remedy design and constitute a nonsignificant
or significant but not fundamental change to the
remedy. Consequently, most remedy updates
correspond to at least one of the following
situations:
O The scope of the remedy has changed
(e.g., volume increase or decrease);
O The performance of the remedy can be
modified or optimized (e.g., change in
disposal or discharge point); or
O 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.
In FY04 and FY05, there was an increase in
the number of remedy changes resulting from
other Superfund initiatives. For example, there
has been increased focus on the need to add
new or revise existing institutional controls at
Superfund sites and to optimize existing ground
water pump and treat systems. Both of these
actions will likely result in a ROD Amendment
or ESD to document changes to the original
selected remedy.
3.2 State/Tribal and
Community Roles
State/Tribal Roles
States often play an important role in the
modification of remedy decisions. Section
300.515 of the NCR and the Model CERCLA
Remedial Design/Remedial Action (RD/RA)
Consent Decree (which forms the basis for
most consent decrees) address the States'
opportunity to review and comment on specified
steps in the remedy selection process. CERCLA
section 104(d) cooperative agreements between
EPA and States may address modification
following an update to a remedy. Furthermore,
as reflected in section 121(f) and in the Model
Consent Decree, EPA typically provides the
State with a reasonable opportunity to review
and comment on any proposed modifications.
Additional information regarding the role of
States and support 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).
Indian tribes generally are afforded substantially
the same treatment as States with respect to
certain provisions of CERCLA (see CERCLA
Section 126; NCP Section 300.505). As
encouraged by the NCP, Federally-recognized
Indian tribes often play an important role in the
cleanup of Superfund sites, (see NCP Section
300.515).
Community Roles
Several remedy updates in FY04 and FY05
involved significant State participation and/
or community involvement. In addition to a
formal public comment period that is initiated
in the case of a fundamental update (i.e., ROD
Amendment), most remedy updates, regardless
of their significance, have a substantial
community involvement component (see NCP
Section 300.435(c)(2)(i) and (ii)). For example,
documents pertaining to the site, including any
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
information on remedy updates, typically are
placed in the Administrative Record or at the
site repository located near 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 FY04 and FY05.
3.3 Remedy Review
Duration
Reviewing site-specific material and completing
the ESD or ROD Amendment took less than
a year for a majority of the remedy updates
completed during FY04 and FY05 (see Exhibit
3.3). Of note, there 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 could have been influenced by the
following:
O A lengthy, but important public involvement
phase;
O An extensive verification/pilot test period
following the discovery of new performance,
technical, or toxicological data;
O The discovery of unexpected contamination
late in the remedy design phase; or
O A redefinition of land use.
Section 4.2 provides specific examples of
remedy changes for reviews that lasted more
than one year.
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Illllllllllllllllllllllllllllllllllllll
SUMMARY REPORT FY04 AND FY05
Exhibit 3.3: Durations for FY04 Remedy Updates
tn
i
TJ
Q.
on
1 n
34
3
D Amend
DESD
13
7
r
3 2
o o|~~| i_Lp-| ^L o^
<1 >1 -2 >2-3 >3-4 >4-5 >5 - 10 >10
Duration (years)
Durations for FY05 Remedy Updates
V)
O)
Ts
TJ
Q.
Duration (years)
oc-
oc _
on -
1 n -
30
4
_£
D Amend
DESD
7
4
F r An A° ° ° A°
<1 >1-2 >2-3 >3-4 >4-5 >5-10 >10
Notes:
Based on 135 remedy updates.
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UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
4.0 Lessons Learned
During FY04 and FY05 reform implementation,
EPA has continued to gain 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
previously 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.
EPA's positive record of responding to remedy
update requests made by outside parties has
contributed to the success of this Reform.
4.2 Site Examples
In many cases, remedies were updated as a
result of a decrease or increase in contaminant
volume or 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
examples of typical remedy update situations
that occurred during FY04 and FY05.
Updates Based on New Technology
Some updates were the result of new
technology that was not considered at the
time of the original remedy. At Crossley
Farms in Pennsylvania, EPA changed the
technology identified in the selected remedy for
ground water treatment from an on-site plant
using an air stripping process to an on-site
plant using an Advanced Oxidation Process
(AOP). The treatment technology review was
performed based on findings during the design
investigation regarding tetrachloroethylene
(TCE) concentrations. The review identified
the AOP approach and it was pilot tested at
the site. Based on the results of the pilot, an
ESD was prepared to change the treatment
technology for the extracted ground water to an
AOP system. This remedy update will result in
an estimated savings of $1.3 million.
At SelmaTreating Co. in California, the
original ground water cleanup approach is being
supplemented with a new type of remedy. The
original remedy established pump and treat
(using precipitation, coagulation and flocculation
technology), as the remedy for ground water.
However, EPA subsequently modeled the
effectiveness of plume containment and
recovery and the results indicated that 30 years
of pumping under the current well configuration
would not be sufficient to completely mitigate
the ground water contamination at the site. As
a result, EPA decided to examine modifications
to enhance effectiveness of the existing system.
Based on the consideration of newly available
10
-------
Illllllllllllllllllllllllllllllllllllll
SUMMARY REPORT FY04 AND FY05
technology, process options, and additional
data gathered through on-site pilot testing, EPA
decided to supplement the existing pump and
treat system with in-situ bioremediation. The
combined cleanup approach in the updated
remedy should shorten the remediation
timeframe and lower the long-term cost by an
estimated $29.6 million.
Updates Based on New Performance Data
New performance data can also provide the
needed basis for updating remedies. For
instance, at Peak Oil Co./Bay Drum Co. in
Florida, new hydro-geological data collected
during post-ROD activities indicated that the
ground water remedy should be reevaluated.
Based on the findings during these activities
(e.g., decreased concentrations, reduced
aquifer flow rates) a Focused Feasibility
Study was conducted and several new
remedy alternatives were considered. The
recommended alternative involving enhanced
in-situ bioremediation with source area
treatment and monitored natural attenuation
was selected in the ROD Amendment and will
result in an estimated savings of $9.0 million.
Coordinating the Update
Some remedy updates involve coordination
among EPA, other Federal agencies, and State
and local government agencies. For example,
at the Sidney Landfill in New York, part of
the original remedy included the extraction
and treatment of contaminated ground water
in a "hot spot." However, based on the results
of ground water testing and sampling, EPA
determined that a ground water extraction
and treatment system already operating at the
nearby Richardson Hill Road Landfill Superfund
site was capturing contaminated ground water
from the Sidney Landfill site, alleviating the
need for a separate system. The opportunity
to utilize the system already in place at the
nearby site resulted in an estimated $0.5 million
savings in the updated remedy.
State Input in the Update
States can be either the lead or support agency
for a remedy update. The Commonwealth of
Pennsylvania Department of Environmental
Protection was the support agency for
the remedy update at Commodore
Semiconductor Group in Pennsylvania.
The original ROD required the creation of
a ground water management zone with
restrictions on installation of new wells in an
area of contamination. However, the adoption
of regulations by Pennsylvania's Montgomery
County Board of Health Department/Division
of Water Quality Management now provides
a mechanism for minimizing exposure to
site-related contaminants that exceed their
respective Maximum Contaminants Levels
(MCLs). They also provide a system for EPA
to track and confirm where and when any
new wells may be installed. Therefore, the
requirement of the creation of a ground water
management zone is no longer warranted and
has been removed in the remedy update.
Community Preference
Community preference can have a significant
impact in addressing site contamination. For
example, at Ruston Foundry in Louisiana,
discussions between the city and the
community resulted in changing the proposed
future site reuse from recreational to industrial.
This change in land use necessitated revisions
to the risk assessment, which in turn reduced
the estimated waste to be addressed because
of new less stringent cleanup levels. While the
updated remedy will require future operation
and maintenance (O&M) activities, Five-year
Reviews, and institutional controls, there will still
be an estimated cost savings of $2.3 million.
Cost Increases
While the Reform Guidance is aimed at
controlling all site costs, there are remedy
updates that result in cost increases. At the
Northwest Pipe & Casing/Hall Process
11
-------
UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
Company in Oregon, a remedy update
became necessary when site conditions were
encountered during Phase 1 (soil hot spots
removal) that required additional activities
not anticipated or described in the original
ROD. Wetlands were discovered on the site,
resulting in the inclusion of wetland ARARs
and development of a restoration measure to
compensate for the loss of existing wetlands
resulting from the soil cap placement. In
addition, during the remedial design
circumstances regarding available analytical
methods for the contaminant vinyl chloride
resulted in revised soil cleanup levels. An
estimated cost increase of $0.1 million resulted.
Similarly, at the Hanford 100-Area in
Washington, an ESD was required to add
newly discovered waste sites. While the
original ROD contained 209 waste sites,
ongoing remedial activities identified 28 newly
discovered waste sites that have a potentially
unacceptable risk to human health and the
environment. As a result, the estimated cost
increase was $32.0 million.
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 Solid State Circuits, Inc.
in Missouri, the review for the remedy update
took nearly eight years. Originally, the remedy
included ground water extraction wells, an
onsite treatment plant, and monitoring wells
to verify compliance with the performance
standards. However, the PRP submitted a
request to explore innovative technologies to
enhance the site's ground water remediation.
Based on their review, the PRP proposed to
use a horizontal well to assist in the flushing of
TCE contamination and, after the installation
and initial testing of the horizontal well, they
conducted a successful pilot study. The ESD
documents the permanent use of the innovative
horizontal well to enhance the remediation of
the TCE plume.
In contrast, a review for the remedy update at
LaSalle Electrical Utilities in Indiana took
approximately one month to complete. The
original remedy required the installation of
a ground water pump and treat system to
remediate the ground water to drinking water
standards (i.e., MCLs). The treated ground
water was to be discharged to the local Publicly
Owned Treatment Works (POTW). The ESD
recognizes the implementation of two phyto-
remediation plots as a remedy enhancement
with the significant difference being that
portions of the treated ground water would
be re-directed and utilized for irrigation of
the phyto-remediation plots instead of being
discharged to the POTW. There were no
resultant estimated savings or costs.
5.0 Conclusion
EPA and outside parties continued to consider
Updating Remedy Decisions a successful
Reform in both FY04 and FY05. The number of
remedies updated by each Region during FY04
and FY05 clearly shows that all ten EPA Regions
are implementing this Reform, with more than
half of the Regions reporting estimated cost
savings of more than $10.0 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 and non-technical
information exists to support them. Typically,
EPA and outside parties share the benefits of
both cost and time savings as a consequence of
implementing the updated remedy.
Interested parties should review the existing
Reform Guidance (OSWER Directive 9200.2-
12
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Illllllllllllllllllllllllllllllllllllll
SUMMARY REPORT FY04 AND FY05
22) for basic information 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 http://
www.epa.gov/superfund/resources/remedy/
rods/index.htm). Specific questions on
implementation of the Reform may be directed
to Matt Charsky of the Office of the Office
of Superfund Remediation and Technology
Innovation by telephone at (703) 603-8777,
e-mail at charsky.matthew@epa.gov, or FAX
at (703) 603-9102. Each Region also has a
remedy update contact who can be reached by
contacting the Superfund Program office 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-W-01 -58.
13
-------
UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
Appendix A:
Summary of Remedy Update Decisions for FY04 and FY05
Note: The information and data presented in Appendix A have been supplied to EPA headquarters
by Regional offices. The data is subject to occasional updates as new information is received,
thus the data in Appendix A data should be used for informational purposes only. The types
of remedy updates completed during FY04 and FY05 are ROD Amendments (ROD-As) and
Explanation of Significant Differences (ESDs).
-------
Summary of Remedy Update Decisions for FY04
Region
1
2
3
4
5
6
7
8
9
10
Total
# With No
Sav.
1
1
9
7
3
0
0
1
1
3
26
#ofTBD
0
0
0
1
0
0
1
0
0
0
2
# With Est.
Sav.
1
1
4
1
7
2
0
0
4
0
20
#With
Est. Incr.
2
4
2
4
2
1
0
2
3
7
27
Estimated
Savings
S13.1M
$0.5M
S14.4M
S10.0M
S28.3M
$1.1M
TBD
$0
$5.1M
$0
S72.5M
Estimated
Increase
$7.5M
S19.6M
$0.2M
S19.8M
$0.5M
$3.5M
$0
$3.6M
$7.6M
S33.9M
S96.2M
Change Initiator
PRP
1
0
0
2
0
0
0
0
0
0
3
EPA
1
5
10
3
5
0
0
0
3
2
29
State
0
0
0
0
3
0
1
0
1
0
5
Fed. Fac.
2
1
3
8
2
0
0
2
4
8
30
Public
0
0
0
0
0
1
0
0
0
0
1
Joint
0
0
2
0
2
2
0
1
0
0
7
Type of Change
ESD
2
6
13
13
9
2
1
3
5
8
62
ROD-A
2
0
2
0
3
1
0
0
3
2
13
26
20
75 updates
27
62 ESDs
13ROD-AS
75 updates
-------
Summary of Remedy Update Decisions for FY05
Region
1
2
3
4
5
6
7
8
9
10
Total
#With
No Sav.
1
3
3
3
1
0
5
0
2
1
19
#ofTBD
0
0
0
0
0
0
0
0
0
0
0
# With Est.
Sav.
3
0
1
6
2
1
0
1
3
2
19
#With
Est. Incr.
2
6
2
2
3
1
1
2
3
0
22
Estimated
Savings
$4.5M
$0
S14.3M
S76.4M
S39.0M
$0.1 M
$0
S12.3M
$31. 3M
$10.3M
$188.2M
Estimated
Increase
$3.5M
$21. 7M
$0.4M
$13.6M
$19.2M
$3.2M
$0.4M
$1.8M
$21. OM
$0
$84.8M
Change Initiator
PRP
1
1
2
1
1
0
2
1
0
0
9
EPA
4
6
0
4
1
0
3
1
6
0
25
State
0
0
0
0
1
0
0
0
0
0
1
Fed. Fac.
1
1
4
6
1
0
1
1
2
3
20
Public
0
1
0
0
0
0
0
0
0
0
1
Joint
0
0
0
0
2
1
0
0
0
0
3
Other
0
0
0
0
0
1
0
0
0
0
1
Type of Change
ESD
6
7
5
7
4
2
5
2
6
3
47
ROD-A
0
2
1
4
2
0
1
1
2
0
13
19
19
60 updates
22
47 ESDs
13ROD-AS
60 updates
-------
UPDATING REMEDY DECISIONS AT SELECT SUPERFUND SITES
Appendix A.1:
Summary of Remedy Update Information for FY04 and FY05
for Sites Without Cost Increases
Note: The information and data presented in Appendix A.1 represent only a portion of the information available in
the decision document. If more information is needed, please refer to the site's Explanation of Significant
Differences (ESD), ROD-Amendment (ROD-A), memo-to-file, or letter.
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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 Savings - FY 04
Region 1
Dover Municipal
Landfill, NH
Region 1
Parker Sanitary Landfill,
VT
1991
9/04 ROD-A
02/03
09/04
PRP
Soil
EPA issued a separate
Technical Assistance
Grant and conducted a
public meeting, State
had comments on the
change and these were
addressed so that State
concurred with the
ROD-A
Fed= 1,600 hours
Contr. = None
Est'd Savings = None
Type of Change: From - Capping, diversion/interceptor trench to capture contaminated leachate; To - Air-sparging trench.
Factual Basis: Additional study done by PRPs.
04/95
07/04 BSD
2004
07/04
EPA
Ground water
VT Department of
Environmental
Conservation
Fed = None
Contr. = $0.03M
Est' d Savings = $ 13. 1M
Type of Change: From - Ground water pump and treat at source area and natural attenuation down-gradient; To -
Permeable reactive barrier at the source area and bio-enhanced natural attenuation in down-gradient area (30 year estimate).
Factual Basis: Results of additional hydrogeologic studies conducted under a revised Feasibility Study.
Appendix A. 1
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Savings
Region 1 Savings - FY 05
Region 1
Central Landfill, RI
Region 1
Keefe Environmental
Services, NH
06/94
09/05 BSD
01/05
09/05
EPA
Ground water
State concurrence
Fed =200 hours
Contr. =$10,000
Est'd Savings = $4.0M
Type of Change: From - Treating the hot spot ground water on-site using a UV chemical oxidation system (UV/OX); To -
Removed this requirement.
Factual Basis: Bench scale tests indicate that a UV/OX system may be technically feasible; however, these results also
indicate that direct discharge of the extracted hot spot ground water to an existing Publicly Owned Wastewater Treatment
Plant is a similarly effective yet less costly treatment approach.
03/88
06/05 BSD
03/03
06/05
EPA
Ground water,
soil
State Concurrence
Fed. = 1000 hours
Contr. = $0.4M
Est'd Savings = Net =
$0 (savings for soil,
increase for ground
water)
Type of Change: From - Pumping and treating of contaminated groundwater onsite using air stripping and activated carbon
technologies; To - The removal of the air stripper and carbon adsorption units and replacing them with a high pressure
oxidation system, which treats both the Site related VOCs identified in the 1998 ROD and the 1,4-dioxane documented in
this BSD.
Factual Basis: A recently identified contaminant of concern at the site necessitated a modification to the existing ground
water treatment system. Additionally, as part of the transfer to the State from LTRA to O&M, an onsite soil spoils area was
required to be removed and disposed off-site.
Appendix A. 1
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Savings
Region 1
Linemaster Switch Corp,
CT
Region 1
Norwood PCBS, MA
07/93
12/04 BSD
06/04
12/04
PRP
Soil
State concurrence
Fed = N/A
Contr. = N/A
Est'd Savings = $0.1M
Type of Change: From - Soil vapor extraction system; To - Ground water pump and treatment system (air stripper and
carbon).
Factual Basis: Operation and maintenance data supports effectiveness of GW systems and flushing to meet soil goals.
09/89
12/04 BSD
2002
2004
EPA
Ground water
State concurrence
Fed =200 hours
Contr. = None
Est'd Savings = $0.4M
Type of Change: New ground water cleanup levels set.
Factual Basis: Based on re-classification of ground water under site to non-drinking water source.
Region 2 Savings - FY 04
Region 2
Colesville Municipal, NY
03/91
07/04 BSD
04/00
07/04
EPA
Ground water
and Surface
water
Full State
involvement;
community expressed
no opinion.
Fed= 100 hours
Contr. = None
Est'd Savings = None
Type of Change: From - Spring and a low-lying wet area contaminated with site-related pollutants, in the vicinity of the
landfill. Contaminated water from the spring and the low-lying wet area were discharging to surrounding areas; To -
Prevention of the migration of contaminated water from the low-lying wet area.
Factual Basis: In April 2000, during a site inspection performed as part of the five-year review process, EPA found a spring
and a low-lying wet area contaminated with site-related pollutants, in the vicinity of the landfill. Contaminated water from
the spring and the low-lying wet area could discharge to surrounding areas.
Appendix A. 1
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Sidney Landfill, NY
09/95
09/04 BSD
11/01
09/04
EPA
Ground water
and Surface
water
Full State
involvement;
community expressed
no opinion.
Fed= 100 hours
Contr. = None
Est'd Savings = $0.5M
Type of Change: From - Construction of four independent closure caps over several disposal areas and extraction and
treatment of contaminated ground water located in a ground water hot spot; To - No need for the ground water extraction and
treatment system onsite.
Factual Basis: Based on the results of ground water testing and sampling, EPA determined that a ground water extraction
and treatment system already operating at the nearby Richardson Hill Road Landfill Superfund site was capturing
contaminated ground water from the Sidney Landfill site, alleviating the need for a separate system.
Region 2 Savings - FY 05
Region 2
Chemical Leaman Tank
Lines, Inc., NJ
09/90
06/05 BSD
06/04
06/05
PRP
Ground water
Yes
Fed = 45 hours
Contr. = None
Est'd Savings = None
Type of Change: From - Discharge into the Delaware River (3 miles away from the site); To - Discharge into a local
tributary.
Factual Basis: The change provided for lower construction and maintenance costs while maintaining the protectiveness of
the remedy.
Appendix A. 1
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Grand Street Mercury, NJ
Region 2
Hertel Landfill, NY
09/97
09/05 BSD
11/04
09/05
EPA
Ground water
Yes
Fed = 30 hours
Contr. = None
Est'd Savings = None
Type of Change: From - No decision yet; To - No further action for the ground water.
Factual Basis: Ground water underlying the site does not contain mercury at levels that would pose an unacceptable risk to
human health or the environment. Modified remedy remains protective of current and future land owners or occupants. This
action is PRP-lead, as such there is no cost savings for the government.
09/91
01/05 ROD-A
2002
01/05
EPA
Ground water
Yes
Fed =160 hours
Contr. = None
Est'd Savings = None
Type of Change: From - Ground water extraction and treatment; To - Institutional controls and long-term monitoring.
Factual Basis: Sediment and ground water data indicate stability and consistency in site-related ground water contaminant
levels. As well, there would be negative impacts on the wetlands from the originally proposed ground water treatment
process.
Appendix A. 1
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Fed/Contr.
Est'd Cost Savings
Region 3 Savings - FY 04
Region 3
Commodore
Semiconductor Group,
PA
Region 3
Crossley Farm, PA
OU2
09/92
09/04 BSD
03/04
09/04
EPA
Ground water
New drinking water
standards set by
Montgomery County
Board of Health
Department's Division
of Water Quality
brought about the
changes to the ROD
Fed =160 hours
Contr. = None
Est'd Savings = None
Type of Change: From - Construction of public water supply lines, maintenance of whole-house carbon filtration systems,
installation/operation/maintenance of ground water extraction wells, air strippers and vapor phase carbon units, sampling,
creation of GW management zone with restrictions on installation of new wells; To - Remove requirement for the creation of
GW management zone, incorporate two deeds of grants: one describing an easement across property for the purpose of
constructing and maintaining buildings for treating and transporting water, the other easing the right-of-way upon and across
property for the purpose of constructing, placing and operating pipelines and other equipment required for transporting water.
Factual Basis: The adoption of regulations by Montgomery County Board of Health Department's Division of Water
Quality Management provides a mechanism for minimizing exposure to Site-related contaminants that exceed their
respective MCLs. They also provide a system for EPA to track and confirm where and when any new wells may be
installed. Therefore the requirement of the creation of a GW management zone is no longer warranted.
09/01
07/04 BSD
01/03
07/04
EPA
Ground water
PA DEP is the support Fed =120 hours
agency and it concurs Contr. =120 hours
with BSD
Est'd Savings =$1.3M
Type of Change: From - On site plant using air stripping; To - An on-site plant that will use an advanced oxidation process,
removal and off-site disposal of DNAPL from the water prior to treatment.
Factual Basis: Findings during the design investigation at the Site led to the BSD. Analytical results indicated TCE
concentrations were high, indicating that TCE DNAPL is at or near the solubility level. After these findings, a treatment
technology review showed that an Advanced Oxidation Process would be successful.
Appendix A. 1
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Cryochem, Inc., PA
OU1
Region 3
Cryochem, Inc., PA
OU2
Region 3
Dublin TCE, PA
09/89
08/04 BSD
08/03
08/04
EPA
Drinking water
PADEP reviewed
Fed = 30 LOE hours
Contr. = 400 LOE hours
Est'd Savings = $0.5M
Type of Change: New cleanup level for 1,1 -DCA; new contaminant, 1,4-Dioxane, identified.
Factual Basis: During the 5-year review, EPA reviewed available scientific studies and did not find a current oral Cancer
Slope Factor for 1,1 -DCA so they decided to use a generic risk-based concentration - which is the new level. Since EPA
issued the ROD for OU1, they learned another contaminant, 1,4-dioxane, was likely to be presenting a risk and it was added
to the list of contaminants to be monitored.
09/90
08/04 BSD
08/03
08/04
EPA
Ground water
PADEP reviewed
Fed =50 LOE hours
Contr. = 600 LOE hours
Est'd Savings = None
Type of Change: New cleanup level for 1,1 -DCA, new contaminant, 1,4-Dioxane, identified..
Factual Basis: During the 5-year review, EPA reviewed available scientific studies and did not find a current oral Cancer
Slope Factor for 1,1 -DCA so they decided to use a generic risk-based concentration - which is the new level. Since EPA
issued the ROD for OU1, they learned another contaminant, 1,4-dioxane, was likely to be presenting a risk and it was added
to the list of contaminants to be monitored.
09/02
08/04 BSD
05/04
09/04
EPA
Ground water
PADEP concurred in
letter dated 6/29/04.
Fed = 60 LOE hours
Contr. = None
Est'd Savings = None
Type of Change: From - Start date of the three year review period at the date of the ROD; To - Start date of three year
review at the date of the commencement of In-Situ Chemical Oxidation (ISCO) start-up.
Factual Basis: Needed to allow for an adequate time period for ISCO to be demonstrated and evaluated.
Appendix A. 1
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Letterkenny Army Depot,
PA
OU1
Region 3
MW Manufacturing, PA
OU5
Region 3
Osborne Landfill, PA
08/91
05/04 BSD
01/04
05/04
U.S. Army
Soils
Yes
Fed = N/A
Contr. = N/A
Est'd Savings = None*
Type of Change: Implement institutional controls and cap maintenance plan. * BSD added O&M requirements for landfill.
Factual Basis: Institutional Controls for waste left in place omitted from original ROD.
12/97
09/04 BSD
08/04
09/04
PRP, EPA
Soils
PADEP
Fed = None
Contr. = None
Est'd Savings = None
Type of Change: From - Excavation of two feet of soils underneath the Fluff piles; To - Excavation of soils dependent on
observations made in the field.
Factual Basis: New Site information obtained during the Remedial Action phase.
09/90
06/04 BSD
2004
06/04
EPA
Ground water
PADEP approval.
Fed = 30 LOE hours
Contr. = None
Est'd Savings = None
Type of Change: From - Clean up to "background levels" as determined by a Pennsylvania ARAR; To - Clean up to
Federal MCL.
Factual Basis: Changes to MCLs were made and State ARARs were withdrawn.
Appendix A. 1
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Paoli Rail Yard, PA
Region 3
Patuxent River Naval Air
Station, MD
Site 6A OU 1
Region 3
Recticon/Allied Steel
Corp., PA
07/92
09/04 BSD
08/04
09/04
EPA
Soil
Minimal
Fed = 80- 160 hours
Cont. = None
Est'd Savings = None
Type of Change: From - Excavation and on-site treatment of soils, excavation and treatment of residential soils, excavation
and treatment of stream sediments; To - Inclusion of off-site disposal of soils and sediments when necessary.
Factual Basis: This BSD will provide another disposal and/or treatment option for PCB contaminated stream sediments
identified during the remedial design or during future monitoring.
9/99
9/04 ROD-A
2003
08/04
Navy
Soil
MDE approval as well
as public comments
Fed = N/A
Contr. = N/A
Est'd Savings = $1.7M
Type of Change: From - Constructing an asphalt cover over the soil and implementing institutional controls; To - No
action.
Factual Basis: Change in future land use of the site and additional surface and subsurface soil sampling.
06/93
09/04 BSD
01/04
09/04
EPA
Soil
PADEP approval.
Fed = 120 LOE hours
Contr. = None
Est'd Savings = None
Type of Change: From - Institutional controls prohibiting excavation of soils on a portion of the Site where elevated levels
of TCE was detected and prohibiting construction of new wells at the Site until ground water performance standards have
been met; To - Removing these ICs.
Factual Basis: New findings show that the levels of TCE in the soils do not present a human health risk and are not
contributing to ground water contamination at the Site.
Appendix A. 1
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Standard Chlorine of
Delaware, Inc., DE
OU1,2
Region 3
York County Solid Waste
and Refuse Authority
Landfill, PA
03/95
09/04 ROD-A
10/03
09/04
EPA
Ground water,
soils, sediments
Public meeting 5/4/04.
DNREC concurred.
Fed = $6.2M
Contr. =$0.1 M
Est'd Savings =
$10.9M
Type of Change: Additional action: off-site incineration of bulk liquid chemicals.
Factual Basis: The original ROD was issued when the plant was still operating and using these chemicals. The plant is no
longer in operation and these chemicals need to be addressed.
12/94
09/04 BSD
09/02
09/04
PRPs, EPA
Ground water
10/04 Notice in "York
Daily Record"
Fed = None
Contr. = None
Est'd Savings =
Minimal savings
Type of Change: From - Ground water extraction and air stripping, carbon filter treatment and/or provision of bottled water
for affected private wells, maintenance of cap and the passive gas venting system, sampling of ground water and treated
water; To - Elimination of these actions as EPA-required actions.
Factual Basis: These actions are being done under State Agreements and EPA is no longer responsible for conducting them,
although they will continue to ensure they are completed. The site will be deleted from the NPL.
Appendix A. 1
10
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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 Savings - FY 05
Region 3
Aberdeen Proving
Ground (Edgewood
Area), MD
OU4
Region 3
Aberdeen Proving
Ground (Edgewood
Area), MD
OU5
10/94
09/05 BSD
07/04
09/05
US Army
Ground water
Public appraised in
monthly meetings of
BSD, no public
objections to the BSD.
MD DEP agreed with
BSD changes.
Fed = N/A
Contr. = N/A
Est'd Savings = Minor
savings
Type of Change: From - A subsurface trickling system to allow introduction of liquids to accelerate corrosion and release of
contaminants from containers and rounds of chemical weapons; To - Surface system for air monitoring.
Factual Basis: The subsurface system was constructed but never used due to technical concerns. There was a subsurface air
monitoring system constructed but also not used for technical reasons.
09/91
03/05 BSD
01/04
03/05
US Army
Ground water
Public appraised in
monthly meetings of
BSD, no public
objections to the BSD.
MD DEP agreed with
BSD changes.
Fed = N/A
Contr. = N/A
Est'd Savings = Minor
savings
Type of Change: From - Leachate extraction/GW capture system to collect leachate/contaminated GW from the upper and
lower aquifers; To - Pumping the upper aquifer harder and not pumping the lower one at all. Modifications to the GW
treatment plant.
Factual Basis: More hydrogeology data and GW data was collected during remedial design showing that it was not prudent
to pump the lower aquifer.
Appendix A. 1
11
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Aberdeen Proving
Ground (Edgewood
Area), MD
OU11
Region 3
Malvern TCE, PA
OU1
09/96
05/05 BSD
03/04
05/05
US Army
Ground water
Public appraised in
monthly meetings of
BSD, no public
objections to the BSD.
MD DEP agreed with
BSD changes.
Fed = N/A
Contr. = N/A
Est'd Savings = Minor
savings
Type of Change: From - Pump and treat; To - Monitored natural attenuation for a small area.
Factual Basis: There was one very small lobe of low level VOC contamination which geologically had such a low
permeability, it was not practical to install extraction wells in that small area. The pump and treat system was installed for
the rest of the large VOC plume.
11/97
3/05 ROD A
05/02
3/05
PRP
Subsurface
soils
PADEP review and
comment
throughout/public mtg.
Fed = 720 hours
Contr. = N/A
Est'd Savings = $14.3M
Type of Change: From - Install cap on Main plant Area soils and for Former Disposal Area/mound area - excavate soils
with off-site treatment and disposal; To - Demolition of on-site buildings, installation of cap over the Main Plant Area,
installation of soil vapor extraction (SVE) and treatment system in soil area known as Former Disposal Area and removal of
surficial soils impacted with PCBs.
Factual Basis: Significant increase in contaminated soils volume and depth identified during pre-design investigation.
Appendix A. 1
12
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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 Savings - FY04
Region 4
Hipps Road Landfill, FL
Region 4
Savannah River Site, Old
F-Area Seepage Basin,
SC
OU 16 (OFASB)
Region 4
Tennessee Products, TN
09/86
07/04 BSD
01/03
07/04
PRP
Ground water
State concurred, Public
Notice in local paper
Fed = 50 hours
Contr. = None
Est'd Savings = reduced
annual O&M costs by
75%
Type of Change: From - Pump and Treat; To - Monitored Natural Attenuation
Type of Change: Evaluation of data from 10 years of pump and treating groundwater at the site.
05/97
09/04 BSD
09/01
09/04
US DOE
Ground water
State concurred, Public
Notice in local
newspapers
Fed= 100 hours
Contr.= None
Est'd Savings =None
Type of Change: From - Ground water mixing zone in OU 16; To - Ground water mixing zone in OU 85.
Factual Basis: It was determined that ground water contamination was derived for sources other than the OU 16.
09/02
08/04 BSD
03/04
08/04
PRP
Sediment (soil
and debris)
State concurred, Public
Notice in local paper,
Community Meeting
to present ESD
Fed= 100 hours
Contr.= None
Est'd Savings = $10.0M
Type of Change: From - Excavation, treatment, and disposal of approximately 44,000 cy of arsenic contaminated soil and
debris; To - Excavation, treatment, and disposal of approximately 1 16,000cy of contaminated soil and debris.
Factual Basis: Revised estimation of quantity of sediments to be excavated and remedy cost developed during RD/RA
negotiations with PRP.
Appendix A. 1
13
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
USN Air Station Cecil
Field, FL
OU1
Region 4
USN Air Station Cecil
Field, FL
OU2
Region 4
USN Air Station Cecil
Field, FL
OU3
09/95
11/03 BSD
06/03
11/03
USN
Surface water,
sediments
One BSD covering 6
OUs was issued. State
concurred, Public
Notice in local
newspaper.
Fed =100 hours for 6
OUs
Contr. = None
Est'd Savings = None
Type of Change: Changes to land use controls.
Factual Basis: Surface water and sediment contamination remains and therefore the land uses must be restricted.
06/96
11/03 BSD
06/03
11/03
USN
Ground water, One BSD covering 6
subsurface soils OUs was issued.
State concurred,
Public Notice in local
newspaper.
Fed =100 hours for 6
OUs
Contr. = None
Est'd Savings = None
Type of Change: Changes to land use controls.
Factual Basis: Ground water and soil contamination remains and therefore the land uses must be restricted.
08/99
11/03 BSD
06/03
11/03
USN
Ground water
One BSD covering 6
OUs was issued. State
concurred, Public
Notice in local
newspaper.
Fed =100 hours for 6
OUs
Contr. = None
Est'd Savings = None
Type of Change: Changes to land use controls.
Factual Basis: Ground water contamination remains and therefore the land uses must be restricted.
Appendix A. 1
14
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
USN Air Station Cecil
Field, FL
OU7
Region 4
USN Air Station Cecil
Field, FL
OU8
Region 4
USN Air Station Cecil
Field, FL
OU9
09/96
11/03 BSD
06/03
11/03
USN
Ground water
One BSD covering 6
OUs was issued. State
concurred, Public
Notice in local
newspaper.
Fed =100 hours for 6
OUs
Contr. = None
Est'd Savings = None
Type of Change: Changes to land use controls.
Factual Basis: Ground water contamination remains and therefore the land uses must be restricted.
08/98
11/03 BSD
06/03
11/03
USN
Ground water
One BSD covering 6
OUs was issued. State
concurred, Public
Notice in local
newspaper.
Fed =100 hours for 6
OUs
Contr. = None
Est'd Savings = None
Type of Change: Changes to land use controls.
Factual Basis: Ground water contamination remains and therefore the land uses must be restricted.
04/2001
11/2003 BSD
06/2003
11/2003
USN
Ground water
One BSD covering 6
OUs was issued. State
concurred, Public
Notice in local
newspaper.
Fed =100 hours for 6
OUs
Contr. = None
Est'd Savings = None
Type of Change: Changes to land use controls.
Factual Basis: Ground water contamination remains and therefore the land uses must be restricted.
Appendix A. 1
15
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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 Savings - FY 05
Region 4
Carolina Transformer
Company, NC
OU1
Region 4
Coleman-Evans Wood
Preserving Company, FL
OU1
Region 4
PCX, Inc. (Washington
Pant), NC
OU2
8/91
7/05 ROD-A
5/04
7/05
EPA
Ground water
State concurrence and
Public Comment
Period
Fed = 300 hours
Contr. = None
Est'd Savings = $1.9M
Type of Change: From - Groundwater pump and treat; To - Monitored natural attenuation
Type of Change: New data collected during implementation of source removal and development of the Remedial Design
9/86
9/05 BSD
1/05
9/05
EPA
Ground water
State concurred, Public
Notice in local
newspaper
Fed = 40 hours
Contr.= None
Est'd Savings = $2.5M
Type of Change: From - Groundwater pump and treat; To - Monitored natural attenuation
Factual Basis: During phase one of remedy implementation, collected approximately 76 million gallons of groundwater.
Based on testing results conducted during the development of an addendum to the Remedial Design, it was determined that
additional pump and treatment is not needed.
12/96
9/05 ROD-A
1/05
9/05
EPA
Ground water
State concurrence,
Public Comment
period
Fed = 40 hours
Contr. = None
Est'd Savings = $2 l.OM
Type of Change: From - Groundwater pump and treat; To - Monitored natural attenuation
Factual Basis: Monitored natural attenuation was evaluated during the development of the Remedial Design.
Appendix A. 1
16
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Helena Chemical
Company, FL
OU1
Region 4
USN Marine Corps
Logistics Base, GA
OU6
Region 4
USDOE Oak Ridge
Reservation, TN
OU29 (Milton Valley
Area)
5/96
1/05 BSD
10/04
1/05
EPA
Ground water
State concurrence,
Public Notice a local
newspaper
Fed = 40 hours
Contr.= None
Est'd Savings = $1.0M
Type of Change: Changed ROD cleanup number for xylene From - 20 ppb; To - 10,000 ppb
Factual Basis: Corrected technical error in ROD cleanup number for xylene. Number should always have been 10,000 ppb.
9/01
8/05 BSD
1/05
8/05
US Navy
Contaminated
soils and
ground water
State and EPA
concurrence and
Public Notice in local
newspaper
Fed = 50 hours
Contr. = None
Est'd Savings = None
Type of Change: From - Clay capping contaminated soils and groundwater in situ enhanced bioremediation; To -
Evapotranspiration cover over contaminated soil and groundwater in situ abiotic treatment.
Factual Basis: Data collected during development of the Remedial Design.
9/00
11/04ROD-A
11/03
11/04
DOE
Buried waste
and
contaminated
soil
State and EPA
concurrence and
Public Notice / public
comment period
Fed= 100 hours
Contr. = None
Est'd Savings = $4 l.OM
Type of Change: Form - In situ vitrification treatment; To - In situ grouting.
Factual Basis: Information gathered during Remedial Design.
Appendix A. 1
17
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Peak Oil Company / Bay
Drum Company, FL
OU2
Region 4
USDOE Savannah River
Site, SC
OU13
Region 4
USDOE Savannah River
Site, SC
OU21,29
8/93
1/05 ROD-A
1994
1/05
PRP
Ground water
State concurrence
public notice public
comment period
Fed = 100 hours
Contr. = None
Est'd' Savings = $9.0M
Type of Change: From - Pump and treat with air stripping; To - Enhanced in-situ bioremediation and air sparging with
source treatment, monitored natural attenuation, and institutional controls.
Factual Basis: New hydrogeologic data collected during Remedial Design.
3/97
7/05 BSD
5/03
6/03
DOE
Ground water
State concurred, Public
Notice in local
newspapers
Fed = 100 hours
Contr. = None
Est'd Savings = None
Type of Change: From - Ground water monitoring; To - Terminated ground water monitoring.
Factual Basis: Monitoring reports demonstrate that remedial goals for groundwater reached.
12/03
8/05 BSD
12/02
01/03
DOE
Contaminated
Soils
State concurred, Public
Notice in local
newspapers
Fed = 100 hours
Contr. = 40 hours
Est'd Savings = None
Type of Change: From - Remedial goal for principle threat source material (PTSM) of 2 1 .75 pCi/g for radium 228 and
23.44 pCi/g for thorium at the old TNX Seepage Basin (OTSB) and the Inactive Process Sewer Line (IPSL); To - Reduced
remedial goal to 94 pCi/g for radium 228 plus daughter products and for thorium plus daughter products at the OTSB, IPSLs,
and sumps at area 678-T.
Factual Basis: Significant changes in the calculation methods and toxicity values for determining risk to the future industrial
worker since preparation of the ROD. Presented volumes of material to be removed should be re-evaluated.
Decontamination and decommissioning of facilities occurred following (9/05) approval of the ROD allowing access to
sumps with potential PTSM. It is preferred to remove all PTSM. Increase the scope of treatment/remediation to include: (1)
the New TNX Seepage Basin (NTSB)/IPSL; (2) the TNX Burying Ground (TBG)/Vadose Zone; (3) Old TNX Seepage Basin
OTSB/IPSL/Discharge Gully (DG); and (4) the TNX Groundwater.
Appendix A. 1
18
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Savings
Region 5 Savings - FY 04
Region 5
American Chemical
Service, Inc, IN
Region 5
Cross Brothers Pail
Recycling (Pembroke), IL
09/92
07/99 ROD-A
09/04 BSD
2001
2004
PRP, EPA
Ground water
State reviewed and
commented
Fed = 60 hours
Contr. = None
Est'd Savings = None
Type of Change: From - Ground water pump-and-treat, containment with treatment and potential in situ cleanup methods;
To - Application of chemical oxidant to source area and monitored natural attenuation afterwards.
Factual Basis: The 1992 ROD called for complete cleanup of the site to residential standards, including groundwater pump-
and-treat for the contaminant plumes. The 1999 ROD amendment changed the remedy to containment with treatment and
referred to potential in situ cleanup methods for addressing groundwater. The BSD documents the selection of the
application of a chemical oxidant to the source area and monitored natural attentuation after the chem-ox application as
referred to in the 1999 ROD amendment.
03/85
09/04 BSD
06/04
09/04
EPA
Ground water
IEPA, Ohio EPA
Fed = 80 hours
Contr. = None
Est'd Savings = None
Type of Change: From - Residual risk of Ix 10"4; To - Revised residual risk level to 1 x 10"5.
Factual Basis: During the remedial design process, EPA staff indicated that it would be acceptable to design the ground
water system to meet MCLs, with the cumulative residual risk evaluation to be considered for only those contaminants that
do not have MCLs. The 2004 BSD formalized this change. In addition, the land use restrictions discussed within the 1989
ROD were vague and needed clarification.
Appendix A. 1
19
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Feed Materials
Production Center
(USDOE), OH
OU1
Region 5
Feed Materials
Production Center
(USDOE), OH
OU4
Region 5
Himco Dump, IN
01/95
11/03ROD-A
08/03
11/03
USDOE
Soils
OEPA and Citizen
involvement. State
concurred.
Fed = 40 hours
Contr. = None
Est'd Savings = $4.5M
Type of Change: From - Removal, treatment, and off-site disposal at a permitted commercial disposal facility, placement of
backfill into excavations and construction of cover system; To - Higher soil cleanup level for one contaminant, permanent
disposal of pit soils at Fernald's On-site Disposal Facility, re-grading, re-seeding and re-vegetation - no cover system
necessary.
Factual Basis: New site information led to the higher cleanup level, new studies showed the pit soils were safe for on-site
disposal,
03/05
11/03 BSD
12/94
11/03
USDOE
Source
material
OEPA, citizen
involvement. State
concurred.
Fed = 40 hours
Contr. = None
Est'd Savings = $0.4M
Type of Change: From - Off-site disposal at the Nevada Test Site (NTS); To - Disposal at another appropriately permitted
commercial disposal facility.
Factual Basis: DOE and U.S. EPA have received new information concerning (1) the waste acceptance criteria for the NTS
disposal facility, and (2) the potential availability of other commercial facilities that can accept the residues for disposal as
byproduct materials.
09/93
09/04 ROD-A
1995
09/04
EPA
Ground water,
soil, soil gas
IDEM concurrence
Fed = 240 hours
Contr. = None
Est'd Savings = $11.0M
Type of Change: From - Composite cap and fence alignments; To - No composite cap, extension of local municipal supply
with additional ground water monitoring.
Factual Basis: Based on new ground water data, and pending the site does not deteriorate further, it is not necessary to
construct the composite cap. The requirement for the extension of the local municipal supply to 39 residents with additional
ground water monitoring was emplaced to resolve uncertainties about the risk to human health and the environment.
Appendix A. 1
20
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
1988
07/04 BSD
06/04
07/04
IEPA
Ground water
IEPA
Fed = 60 hours
Contr. = None
Est'd Savings = None
Region 5
LaSalle Electrical
Utilities, 1L Type of Change: From - Ground water pump-and-treat system with water released to the POTW; To - Installation of two
phytoremediation plots, with some of the water from the pump and treat to be re-directed for irrigation of plots.
Factual Basis: The ROD required the installation of a ground water pump and treat system to remediate the ground water to
drinking water standards (i.e. MCLs). Treated ground water was to be discharged to the local POTW. The ESD recognizes
the implementation of two phyto-remediation plots as a remedy enhancement with the significant difference being that
portions of the treated ground water would be re-directed and utilized for irrigation of the of the phyto-remediation plots
instead of being discharged to the POTW.
Region 5
Midco I, IN
Type of Change: From - Soil vapor extraction (SVE) treatment of 7,800 cubic yards of soil from below the water table; To
- Soil/bentonite ground water barrier wall, lowering of the water table by 12 feet, SVE treatment of 54,200 cubic yards of
soil from above and below the water table.
Factual Basis: The ROD required soil treatment by in-situ solidification/stabilization (S/S) and soil vapor extraction (SVE).
The estimated quantity of soil treatment by solidification/stabilization was reduced from 12,400 cubic yards in the ROD, to
7,800 in the ROD Amendment, and to 3,560 in the ESD. In addition, the ESD allows excavation and off-site disposal as an
alternative to treatment by solidification/stabilization. To compensate for this, the ESD provides for more comprehensive
soil treatment by soil vapor extraction. While the ROD required only very limited soil treatment below the water table, the
ESD requires SVE treatment both above and below the water table. To accomplish this, a soil/bentonite groundwater barrier
wall was installed around the Site, and groundwater within the barrier wall is being pumped to lower the water table by 12
feet before conducting soil vapor extraction treatment. This increases the volume of soil treatment by SVE from the
estimated 12,400 cubic yards estimated in the ROD and 7,800 in the ROD Amendment to 54,200 cubic yards.
06/89
09/04 ESD
10/02
09/04
Midco
Remedial
Corp (PRP)
Soil
IDEM
Fed = 227 hours
Contr. = $20,000
Est'd Savings = $2.0M
Appendix A. 1
21
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Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Midco II, IN
Region 5
Tar Lake, MI
Region 5
US Aviex, MI
06/89
09/04 BSD
2002
02/03
Midco
Remedial
Corp (PRP)
Soil
IDEM
Fed =151 hours
Contr. = $0.2M
Est'd Savings = $5. 8M
Type of Change: From - Soil vapor extraction (SVE), In situ solidification/stabilization (S/S); To - Air sparging in
conjunction with the SVE operation; replace in-situ S/S with treatment in conjunction with the SVE and air sparging
treatment, change soil remediation requirements for soil contaminated with metals and cyanide, and change the point of
application of an air emission control requirement.
Factual Basis: Further studies done by the PRP.
09/92
09/04 BSD
02/04
09/04
EPA
Soil
MDEQ
Fed = 40 hours
Contr. = None
Est'd Savings = $2.6M
Type of Change: From - In-situ treatment of PAH contaminated soils with bioventing and ground water circulation; To -
Off-site treatment of soil.
Factual Basis: Additional data instigated using ROD-Amendment remedy.
09/88
09/93 BSD
09/04 ROD-A
03/04
09/04
EPA
Ground water
MDEQ
Fed = 80 hours
Contr. = None
Est'd Savings = $2.0M
Type of Change: From - Pump and treat; To - Monitored natural attenuation.
Factual Basis: The in-situ oxidization of residual on-site contamination is an enhancement to the new MNA remedy.
Appendix A. 1
22
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Fed/Contr.
Est'd Cost Savings
Region 5 Savings - FY 05
Region 5
Central Illinois Public
Service Co., IL
Region 5
Continental Steel Corp.,
IN
09/92
09/05 BSD
2005
09/05
PRPs
Ground water
State reviewed and
concurred
Fed = 80 hours
Contr. = None
Est'd Savings = N/A
Type of Change: From - Pump and treat; To - Conducting a pilot study on an alternate treatment method. Revised the
clean-up objectives for benzo(a)pyrene. Updated clean-up objectives related to surface water quality standards for the other
contaminants of concern.
Factual Basis: Attempting to reduce or eliminate the length of operation time of the current ground water system. A new
Maximum Contaminant Level (MCL) has been recently established for benzo(a)pyrene. New toxicity information about the
other COCs.
09/98
09/05 BSD
07/05
08/05
IDEM,
Region 5
Soil, ground
water and
sediments
State and community
concurrence
Fed = 80 hours
Contr. = None
Est'd Savings = $16.0M
Type of Change: From - Excavation of contaminated soils and disposal in on-site landfill; To - Disposal of creek and
quarry pond sediments off-site, treatment of contaminated soils in-situ, elimination of landfill requirement, and
reinforced/clearer institutional controls.
Factual Basis: The 9/05 BSD highlights include 1) disposing creek and quarry pond sediments off-site, 2) eliminating
requirement for an on-site landfill at the Lagoon Area, 3) treating the Main Plant contaminated soils in-situ, instead of
excavating and disposing it to the planned landfill in the Lagoon Area, and 4) reinforcing and making clearer the institutional
controls at the site.
Appendix A. 1
23
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
K&L Avenue Landfill,
MI
09/90
09/05 ROD-A
2004
9/05
EPA
Ground water
Township and
Community are
opposed to capping
landfill, but in favor of
MNA. State withheld
concurrence on ROD-
A until more data
gathered
Fed = 200 hours
Contr. = None
Est'd Savings = $23. OM
Type of Change: From - Pump and treat remedy for the entire plume; To - MNA and changes to the design requirements
for the landfill cap to allow the use of a GCL in place of 2 feet of clay.
Factual Basis: Additional studies of MNA conducted by the PRP showed that natural attenuation is controlling the ground
water plume, and that MNA is a more cost-effective remedy for the site.
Region 6 Savings - FY 04
Region 6
Oklahoma Refining Co.,
OK
06/92
10/03 BSD
07/97
09/04
EPA and
ODEQ
Ground water,
soils, source
materials
Both were involved in
reviewing the ESD.
EPA conducted an
open house meeting on
1/22/02
Fed= 100 hours
Contr. = None
Est'd Savings = $0.8M
Type of Change: From - Remediate the LNAPL plume under its process area, remediate railroad areas, place asphaltic and
pitch wastes in an on-site landfill, stabilize approximately 7,200 cubic yards of metals-contaminated waste from the AP-1
area, 1.5 mg/L TCLP for lead, stabilize soils to reduce the direct contact hazard, remediate tank #1 area; To - Postpone the
LNAPL trench ground water remedy, no remedial action needed for the railroad areas, asphaltic and pitch wastes disposal at
a permitted landfill facility, deposit treated waste from the AP-1 area in the Site Hazardous Waste Landfill without additional
stabilization treatment, 5.0 mg/L TCLP for lead, stabilize soils to increase protection from ground water contamination,
higher RAO level for beryllium in soil, cover tank #1 area without remediation.
Factual Basis: Review of Site documents including the RI, the FS, the ROD, new sampling data, and experience gained
during the implementation of the Remedial Action showed that revisions to the ROD were necessary
Appendix A. 1
24
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
FpH/Cnntr
Est'd Cost Savings
Region 6
Ruston Foundry, LA
06/02
09/04 ESD
02/04
09/04
City/
Community
Soil/sediments
Newspaper Notice,
Open House with
comment period
Fed =160-200 hours
Contr. = None
Est'd Savings = $0.3M
Type of Change: From - Recreational reuse, 15,000 cubic yards of soil/sediment waste, stabilization; To - Industrial reuse, 1,766
cubic yards of soil/sediment waste, excavation and off-site disposal.
Factual Basis: New information was received from the city and the community during a meeting held regarding future Site reuse
and from the PRP during negotiations regarding slag stabilization.
Region 6 Savings - FY 05
Region 6
Tar Creek, OK
OU2
08/97
09/05 ESD
03/05
07/05
l)Change in
Costs for
Remedy;
2)Need for 5-
Year Reviews;
3)Change in
depth of
excavation
Soil
State concurs with
ESD
Not yet released to
public
Fed. = 1 50 LOE hours
Contr. = None
Est'd Savings = $0.1M
Although the ESD
generated minimal savings,
it documents the cost
increases of the project
from$29Mto$125M.
This was due to many
more properties
remediated than originally
projected and an increase
in documentation and
drainage work for each
property. This was not the
purpose of this ESD.
Type of Change: From - Depth of excavation on residential properties set at 18 inches; To - Depth set at a maximum of 12 inches.
Factual Basis: Depth of excavation is based on new guidance (Residential Lead Workgroup). 5-Year Reviews now needed given
that waste material deeper than 12 or 18 inches will be left on-site.
Appendix A. 1
25
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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 Savings - FY 04
Region 7
Solid State Circuits, MO
09/89
09/04 BSD
09/96
09/04
RPM
Ground water
State Lead
Enforcement
Fed = None
Contr. = None
Est'd Savings =
Unknown - PRP Lead,
costs unavailable
Type of Change: From - Extraction of contaminated ground water by new and existing wells, on-site treatment using two
air strippers, discharge treated water to the city sewer system, and a city ordinance to prevent construction of drinking wells
in or near the contaminated ground water plumes; To - Installation of a horizontal, injection well for the treated water from
the ground water treatment facility.
Factual Basis: Results of first five-year review and evaluation of innovative technologies for TCE in ground water.
Region 7 Savings -
Region 7
Bruno Co-Op
Association/Associated
Properties, NE
09/98
09/05 BSD
06/2005
09/2005
EPA
FY05
Groundwater
PRP -lead cleanup
EPA-leadforlCs
under ESD
Fed = Insignificant
Contr. = N/A
Est'd Savings = None
Type of Change: From - The original ROD and first ESD did not include groundwater institutional controls as a component
of the groundwater pump and treat remedy that is fully operational; To - the second ESD addresses institutional controls to
augment the operating pump and treat remedy. The new requirements will control or prohibit the drilling, construction, and
use of new domestic wells within the boundaries of the plume and also control or prohibit the placement of new irrigation or
industrial wells that may hydraulically influence the operation of the pump and treat system.
Factual Basis: Completion of the Preliminary Close-out Report (PCOR) identified the need for the addition of groundwater
institutional controls at the site. The second ESD fulfilled this need.
Appendix A. 1
26
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Peoples Natural Gas Co.,
IA
Region 7
Pester Refinery Co., KS
Region 7
Waverly Ground Water
Contamination, NE
09/91
12/04 BSD
03/04
12/04
PRP
GW
State approved ARAR
change
Fed = None
Contr. = None
Est'd Savings = None
Type of Change: From - Change in GW action levels for benzene and naphthalene.
Factual Basis: State approved change in state ARAR for benzene to MCL and naphthalene to revised health advisory limit.
09/92
06/05 ROD-A
09/04
06/05
PRP
Soil, ground
water
State Lead
Enforcement
Fed = None
Contr. = None
Est'd Savings = None
Type of Change: From - In-situ bioremediation and soil flushing; To - Solidification.
Factual Basis: Results of five year review and treatability study.
09/90
03/05 BSD
10/04
03/05
EPA
Ground water
State Concurrence and
30 day public
comment period. No
adverse comments
received.
Fed = N/A
Contr. = PRP/USDA
Est'd Savings = None
Type of Change: From - ROD compliance criterion level for soil gas; To - Deletion of the compliance criterion for soil gas.
Factual Basis: Results of the third Five-Year Review and the re-evaluation of the ROD soil gas compliance criterion by
utilizing the current "Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils",
2002.
Appendix A. 1
27
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Weldon Spring
Quarry/Plant/Pits
(USDOE/ARMY), MO
09/93
02/05 BSD
11/04
02/05
EPA
Ground water,
soil
Yes/state
review/citizens
commission/public
mtg.
Fed = N/A
Contr. = N/A
Est'd Savings = None
Type of Change: Clarified old decisions that were vague and/or incomplete with respect to necessary land and resource use
restrictions.
Factual Basis: Consistency with EPA guidance and 1C implementation strategy.
Region 8 Savings - FY 04
Region 8
California Gulch Site, CO
OU4
03/98
03/04 BSD
01/04
03/04
Joint -
EPA/State
Historic
Preservation
Office
Fluvial tailing
Meeting in May 1999
to discuss alternatives
to selected remedy
among EPA, CDPHE,
SHPO, and other
interested parties.
Notice of BSD
published in local
newspaper. CDPHE
supported ESD.
Fed = None
Contr.= None
Est'd Savings = None
Type of Change: From - Consolidation and capping of a fluvial tailing deposit in the vicinity of historic Oro City; To -
Contaminant loading to surface water from this fluvial tailing deposit is uncertain, so this response action was removed from
the record of decision to preserve the cultural resource.
Factual Basis: The area will continue to be monitored. If it is determined that there is unacceptable loading of contaminants
to surface water from this deposit, the remedy will be re-evaluated under a separate operable unit which focuses on site-wide
water quality.
Appendix A. 1
28
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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 Savings - FY 05
Region 8
Lowry Landfill, CO
03/94
08/05 BSD
06/02
12/04
PRPs
Soil
Public Concurred
Fed = None
Contr. = None
Est'd Savings = $12.3M
Type of Change: From - Excavation, removal, and on-Site treatment of surface and subsurface drums, contaminated soils,
and waste pits and reclamation; To - Extraction of NAPL using either top-loading or bottom-loading pumps installed in
existing wells, onsite temporary storage of extracted liquids, transportation and offsite treatment and disposal of extracted
liquids, maintenance of the existing cap on each waste pit and ground water monitoring downgradient.
Factual Basis: Pilot study was conducted to evaluate alternative treatment technology leading to significant new
information.
Region 9 Savings - FY 04
Region 9
Camp Pendleton Marine
Corps Base, CA
12/95
09/04 BSD
2003
09/04
DoD
Ground water
State involved. Little
to no community
interest
Fed. = 53 hours
Contr. = None
Est'd Savings =$0.6M
Type of Change: From - Ground water will be sampled and analyzed semiannually for 10 years to verify that dispersion and
natural attenuation are occurring; To - Eliminate GW O&M 2.5 years early.
Factual Basis: Site was determined to be source of contamination. New investigation initiated and old site closed.
Appendix A. 1
29
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Fort Ord, CA
OU3
Region 9
Indian Bend Wash Area,
AZ
01/97
12/03 BSD
2001
12/03
DoD
Soil
State involved,
community concern
also prompted change
Fed. = 80 hours
Contr. = None
Est'd Savings =$1.0M
Type of Change: From - Soil excavation and disposal in landfill, ongoing ground water remediation; To - Sifting to remove
spent bullets from soils.
Factual Basis: Realized there would be cost savings and a recycling opportunity.
09/98
06/04 ROD-A
2003
06/04
EPA
Ground water
The state concurs with
the remedy selected in
this ROD Amendment
Fed = 650 hours
Contr = 1 00 LOE hours
Est'd Savings =$3. OM
Type of Change: From - Pump and treat; To- MNA.
Factual Basis: At the time of the 1998 GW ROD, EPA did not have adequate data for the western plume to demonstrate that
contaminant levels were decreasing, natural attenuation was occurring, and that cleanup standards could be met within a
reasonable time frame. Since that time, EPA has gathered a significant amount of ground water data for the western plume,
and an evaluation of the data shows that the western plume is not migrating and is attenuating at a rate that exceeds its lateral
movement. Therefore, the plume is relatively stable. The current data indicate that the MNA remedy will meet cleanup
standards in approximately four to five years.
Appendix A. 1
30
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Nineteenth Avenue
Landfill, AZ
Region 9
Tracy Defense Depot, CA
09/98
10/03 BSD
2003
10/03
Arizona
Department
of Env.
Quality
(ADEQ)
Ground water,
air
State lead site. Add
was taken out in paper
announcing the
availability of the ESD
Fed= 15 -20 hours
Contr. = None
Est'd Savings = None
Type of Change: Updated ARARs for ground water monitoring and ambient air guidelines.
Factual Basis: ADEQ has determined that the currently -established ground water ARARs for the site are no longer the most
protective of human health and the environment, and therefore require modifications.
04/98
06/04 ROD-A
2003
06/04
DoD
Soil, ground
water
State involved. Little
to no community
interest
Fed. = None
Contr. = 88 hours
Est'd Savings =$0.5M
Type of Change: From - Excavation and offsite disposal of soils; To - Reevaluation of risk, no action req'd after all for soil.
Factual Basis: The following were considered in amending this ROD: existing and ongoing operations at DDJC - Tracy,
new information developed since the signing of the original ROD, and changes proposed for the remedial alternatives
Region 9 Savings - FY 05
Region 9
Apache Powder Co., AZ
09/94
09/05 ROD-A
01/00
09/05
EPA
GW & Soils
Public meeting and 30
day public comment
period
Fed= 2500 hours
Contr. = $0.2M
Est'd Savings =$1.6M
Type of Change: From - (GW) Treatment of nitrate through constructed wetlands and pump & treat; (Soils) Implementation
of remedy for formerly active ponds; To - (GW) Treat both nitrate and perchlorate through monitored natural attenuation;
(Soils) Implementing consistent soil remedies selected under Superfund for inactive ponds.
Factual Basis: New soils data and the discovery of perchlorate in Southern Area ground water and soils.
Appendix A. 1
31
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Fort Ord, CA
OU8
Region 9
Mather Air Force Base
(AC&W Disposal Site),
CA
07/02
4/05 BSD
03/05
04/05
DoD
Munitions and
Explosives of
Concern
(MEC)
(note: its a no
action remedy
but is no
action for
MEC)
Yes
Fed = 40 hours
Contr. = None
Est'd Savings = None
Type of Change: From - Track 0 sites are sites that contain no MEC, To - Track 0 sites are sites that contain no MEC or
munitions found are incidental. Is important for plug-in of future sites.
Factual Basis: The ESD expands the scope of what sites can be considered Track 0 and expands the scope of the Track 0
plug-in process to allow sites similar to those included in the ROD to be considered as candidates for Track 0 no action
determinations.
1998
10/04 ESD
2002
10/04
U.S. Air
Force
Soil
EPA and the State of
California concur with
the ESD with
comments. These
comments were
addressed by the Air
Force.
Fed =12 hours
Contr. = N/A
Est'd Savings =$0.1M
Type of Change: From - Excavation of lead-contaminated soils under removal authority and in-situ treatment of fuel-
contaminated soils; To- Deeper soil extraction and off-site disposal.
Factual Basis: Additional soil investigation in 2002.
Appendix A. 1
32
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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
Fed/Contr.
Est'd Cost Savings
Region 9
McColl, CA
OU4
Region 9
Selma Treating Co., CA
OU1
5/96
9/05
7/05
9/05
EPA Five-
year review
Ground water
CA/Dept. of Toxic
Substances Control
concurred on the ESD.
EPA issued a fact
sheet. Inquiries were
received from a couple
of newspapers and
EPA responded.
Fed = 80 hours
Contr. = None
Est'd Savings = None
Type of Change: From - Use of tetrahyrdrothiophenes as the chemical constituent measured as a trigger for further response
actions; To - Use of benzene as a trigger for further response actions.
Factual Basis: During the Five Year Review it was determined that tetrahydrothiophenes may not be the best chemical
constituent to measure to evaluate the movement of groundwater contaminants. Subsequent to the Five Year Review further
analysis of the issue was conducted by the McColl Site Group (PRPs). Upon reviewing the further analysis EPA decided to
proceed with the BSD.
09/88
08/05 BSD
03/05
08/05
EPA
GW
Public notice placed in
newspaper
Fed = 60 hours
Contr. = $10,000
Est'd Savings =$29. 6M
Type of Change: From - Pump and treat; To - Groundwater in situ bioremediation and groundwater extraction
system/groundwater treatment plant enhancement.
Factual Basis: EPA recalibrated the site groundwater model to evaluate the effectiveness of plume containment and
recovery. This study indicated that 30 years of pumping under current well configuration would not be sufficient to
completely mitigate the groundwater contamination at the site.
Appendix A. 1
33
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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 10 Savings - FY 04
Region 10
Idaho National
Engineering Lab
(USDOE), ID
OU7
10/99
02/04 BSD
09/03
02/04
DOE
Ground water
The State reviewed
and commented on
BSD. Notice in local
papers regarding the
BSD.
Fed = None
Contr. = None
Est'd Savings = None
Type of Change: From - ICs, GW monitoring, Pump and treat if necessary; To - No Action for some portions/sites within
the OU, additional GW monitoring in some areas that could prompt the need for additional sampling and well installation,
followed by fate and transport models. Pump and Treat would stay the same if triggered by sampling data.
Factual Basis: Additional analytical data from monitoring of the Snake River Plain Aquifer have been obtained since the
OU 7 ROD was issued.
Region 10
Idaho National
Engineering Lab
(USDOE), ID
~, Type of Change:: From - Phytoremediation; To - This ESD implements the contingent remedy of Excavation and Disposal
for three sites, contaminated soils will be excavated and disposed of using appropriate landfills.
Factual Basis: Experience with phytoremediation at similarly contaminated nearby sites over a period of four years has
shown that the Industrial Waste Pond contaminants will be more resistant to phytoremediation than estimated. Therefore
more than seven years would be required to achieve the remediation goals. In addition, a new project may restart the sodium
processing activities and refill the Industrial Waste Pond with cooling water. The resulting accumulation of water in the
pond would preclude the use of phytoremediation. Because it would take over seven years to complete phytoremediation and
meet the Remediation Goals at the Industrial Waste Pond, and because the selected remedy would conflict with the potential
need to reuse the pond, the selected phytoremediation remedy is no longer considered to be viable.
09/98
06/04 ESD
01/98
06/04
DOE
Surface water
The State reviewed
and commented on
ESD. Notice in local
papers regarding the
ESD
Fed = Unable to
determine
Contr. = None
Est'd Savings = None
Appendix A. 1
34
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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 10
Mountain Home Air
Force Base, ID
OU3
10/95
03/04 BSD
06/00
03/04
EPA
Ground water
The state agreed to the
changes, and the
community was made
aware through the
Restoration Advisory
Board (RAB).
Fed = None
Contr. = None
Est'd Savings = None
Type of Change: From - Limited action, ICs; To - Enhanced ICs, the BSD incorporated additional requirements and
specificity in existing 1C remedy for ST-1 1, a fuel spill site under the AFB flightline.
Factual Basis: Since the ROD was issued in 1995, the Air Force has clarified their requirements for ICs.
Region 10 Savings - FY 05
Region 10
Idaho National
Engineering Laboratory
(USDOE), ID
OU3
11/99
01/05 BSD
11/04
01/05
EPA
Tank contents
and Soil
State reviewed and
comments on ESD.
Notice to public in
local papers
Fed = Can't be
determined
Contr. = None
Est'd Savings = $10.0M
Type of Change: From - Ex situ treatment of tank contents off INL; To - Ex situ treatment of tank contents on INL.
Factual Basis: Off INL treatment system was unavailable and would remain unavailable for the foreseeable future. A
treatment system for similar waste stream was surplused at Oak Ridge Lab. Testing found it could treat the waste in some of
the tanks. Shipped to INL and reassemble. Other tank waste was dry and was addressed via air sparging at the disposal site
on INL.
Appendix A. 1
35
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites Without Cost Increases
Region
Site Name, State
OU
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 10
Idaho National
Engineering Laboratory
(USDOE), ID
OU11
Region 10
Port Hadlock Detachment
(USNAVY), WA
01/00
01/05 BSD
06/04
01/05
EPA
Tank contents
State reviewed and
comments on ESD.
Notice to public in
local papers
Fed = Can't be
determined
Contr. = None
Est'd Savings = $0.3M
Type of Change: From - Ex situ treatment of tank contents off INL; To - Ex situ treatment of tank contents on INL.
Factual Basis: Off INL treatment system was unavailable and would remain unavailable for the foreseeable future. Similar
tank waste was being treated on site. So tank wastes were combined.
08/95
11/04 BSD
05/04
11/04
EPA
Groundwater
and soil
State and community
involvement
Fed = Unknown
Contr. = None
Est'd Savings = None
Type of Change: Add institutional controls.
Factual Basis: Not applicable.
Appendix A. 1
36
-------
SUMMARY REPORT FY04 AND FY05
Appendix A.2:
Summary of Remedy Update Information for FY04 and FY05
for Sites With Cost Increases
Note: The information and data presented in Appendix A.2 represent only a portion of the information available in
the decision document. If more information is needed, please refer to the site's Explanation of Significant
Differences (ESD), ROD-Amendment (ROD-A), memo-to-file, or letter.
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 1 Increases - FY 04
Region 1
Fort Devens, MA
09/01
03/04 BSD
01/02
03/04
USAGE
Soil, ground
water
State concurrence and
public notice
Fed =100 hours
Contr. = 25 hours
Est'd Increase = $0.6M
Type of Change: Increased volume of contaminated soil requiring removal, inclusion of Extractable Petroleum Hydrocarbons
(EPH) as contaminant of concern in soils, inclusion of EPH and PCBs as contaminants of concern for ground water.
Factual Basis: Data collected and observations made during the contaminated soil removal action initiated in January 2002.
Region 1
Pease Air Force Base,
NH
09/95
12/03 ROD-A
06/02
12/03
USAF
Ground water
Yes
Fed = $0.1M
Contr. = $0.1M
Est'd Increase = $6.9M
Type of Change: From - Removal of contaminated soil that posed a leaching threat to underlying groundwater, source area
groundwater extraction to reduce contaminant mass and to prevent the migration of plumes, and institutional controls to
prevent human exposure to contaminated groundwater.; To - Construction of a contingency wellhead treatment system for
the Haven well, optimization of the Site 39 source area groundwater extraction system with MNA of the down-gradient
plume, termination of groundwater extraction southwest of Sites 34 and 39, modification of the Zone 3 long-term monitoring
program to measure the performance of the amended remedy, ongoing treatment of Site 49 and Site 73 source area ground
water contamination with permeable reactive barriers (PRBs), implementation of land use controls in Zone 3 and at Site 49,
five-year reviews, no further action at Site 65.
Factual Basis: Since the Zone 3 remedy was implemented in 1995, long-term monitoring data have been collected to assess
the progress towards restoration of the overburden and bedrock aquifers. On-going evaluations of remedy performance
indicate that while the existing remedy is currently protective of human health and the environment, the long-term
effectiveness of the remedy is uncertain.
Appendix A.2
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 1 Increases - FY 05
Region 1
Baird & McGuire, MA
Region 1
Fort Devens, MA
09/86
04/05 BSD
2004
2005
EPA
Soil, ground
water
State concurrence
Fed =160 hours
Contr. = None
Est'd Increase =
Minimal
Type of Change: Added requirement for institutional controls.
Factual Basis: No ICs were included in the original ROD.
09/95
07/05 BSD
12/04
07/05
Army
Ground water
Yes- Public Meeting
Fed = 200 hours
Contr. =100 hours
Est'd Increase = $3. 5M
Type of Change: From - Extraction system; To - Treatment after extraction and discharge to Devens Privately-Owned
Treatment Works.
Factual Basis: The Army felt it was necessary to implement the contingency remedy.
Appendix A.2
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 2 Increases - FY 04
Region 2
Genzale Plating, NY
03/91
07/04 BSD
05/03
07/04
EPA
Soil
Full State
involvement;
community expressed
no opinion.
Fed = N/A
Contr.= N/A
Est'd Increase = $2.7M
Type of Change: From - Treatment of contaminated soils by soil vapor extraction (SVE) for organics contamination,
followed by excavation and off-site treatment of soils for metals contamination; To - Tank excavation, removal of the
process building, additional excavation and offsite disposal of metals-contaminated soils.
Factual Basis: In May 2003, during the demolition of the former process building, EPA observed a surface expression,
which was determined to be a pipe to a buried tank previously considered an abandoned well. The recalcitrant subsurface
contamination observed at the site was in the immediate vicinity of this buried tank.
Region 2
Grand St. Mercury, NJ
09/97
07/04 BSD
10/03
07/04
EPA
Soil
Yes
Fed = 30 hours
Contr. = None
Est'd Increase = $1.4M
Type of Change: From - Permanent relocation of residents from the site; demolition of the two contaminated buildings;
sampling, excavation, and off-site disposal of contaminated soil at EPA-approved facilities; To - Additional excavation and
off-site disposal of subsurface soils at the site located below the water table, having an average mercury concentration of 520
ppm, which could pose a potential risk to an on-site utility worker.
Factual Basis: EPA's risk based remediation goal specific to utility workers and construction workers for saturated soils at
the site. Modified remedy remains protective in removing soils that could pose a potential health risk due to the presence of
elevated mercury concentrations to current or future land owners or occupants. Removal of these "hot spot" saturated soils
was not anticipated at the time of the writing of the ROD. The modified remedy establishes a remediation goal appropriate
for subsurface soils while remaining protective.
Appendix A.2
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 2
Nascolite Corporation
Superfund Site, NJ
OU2
Region 2
WR. Grace/Wayne
Interim Storage Site, NJ
06/91
09/04 BSD
10/00
08/02
EPA
Soil
The state supported
EPA's revision to the
remedy and decision to
issue the ESD.
EPA announced the
availability of the ESD
in The Daily Journal
ofVineland,NJ. ESD
was placed in the
Administrative Record
for the site.
Fed =160 hours
Contr. = 4.5 hours
Est'd Increase = $14.0M
Type of Change: From - Excavation and solidification/stabilization of unsaturated and wetlands soils contaminated above
cleanup standards, with replacement of solidified soils on the site; To - Soil contaminated with methyl methacrylate was
excavated and sent off site for treatment and/or disposal.
Factual Basis: The soils were found to be significantly contaminated with methyl methacrylate and a greater quantity of
VOCs then estimated. The effectiveness of the ROD's soil remedy would have been uncertain.
05/00
12/03 BSD
05/03
06/03
USAGE
Soil
NJ DEP provided with
opportunity to review
documents.
Fed = 160 hours
Contr.= 4.5 hours
Est'd Increase = $1.5M
Type of Change: No change in selected remedy; BSD extended area of soil excavation to include a vicinity property which
had been partially remediated previously.
Factual Basis: Evaluation of selected ROD criteria for unrestricted release against work performed through an earlier
removal indicated the need for additional excavation in limited portions of a vicinity property to be consistent with ROD
criteria.
Appendix A.2
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 2 Increases - FY 05
Region 2
Bog Creek Farm, NJ
OU1
Region 2
Bog Creek Farm, NJ
OU2
Region 2
Brookhaven National
Laboratory (USDOE),
NY
09/85
01/05 BSD
03/03
12/03
EPA
Soil
Yes
Fed= 100 hours
Contr. = $0.3M
Est'd Increase = $5. 3M
Type of Change: Additional soil excavation is required.
Factual Basis: Five years into the long term remedial action it became apparent that the excavation under the 1985 ROD left
many undetected "hot spots" on the site. These areas are sources of ground water contamination and would result in the
pump and treat system having to operate for many decades. EPA further characterized the remaining soil "hot spot"
contamination which led to the BSD for additional soil excavation.
06/89
09/05 ROD-A
3/03
09/05
EPA
Ground water
Yes
Fed = 320 hours
Contr. =$0.5M
Est'd Increase = $2.7M
Type of Change: From - Pump and treat; To - Optimization of the ground water pump and treat system and excavation of
recently characterized contaminated soils remaining at the site.
Factual Basis: Further study indicated contaminated soils still remained at the site.
06/00
05/05 BSD
05/03
05/05
EPA
Ground water
Yes
Fed = N/A
Contr. = N/A
Est'd Increase = $7.5M
Type of Change: From - Ground water treatment system; To - Installation of additional wells and additional time to achieve
cleanup goals.
Factual Basis: Re-evaluation of the ground water treatment system showed that the contamination would not leave the
boundary of the facility.
Appendix A.2
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 2
Li Tungsten, NY
Region 2
Montgomery Township
Housing Development,
NJ
Region 2
Rocky Hill Municipal
Well, NJ
09/99
05/05 BSD
01/03
Ongoing
City of Glen
Cove
Soil
State concurred on
BSD, public
availability session
held in Community
Fed =$0.2M
Contr. = None
Est'd Increase = $0.2M
Type of Change: From - Commercial future use of the Site; To - Residential future use.
Factual Basis: New zoning in the city. The BSD did not include Parcel A of the site, and in that sense the remedy re-
evaluation remains ongoing.
06/88
08/05 BSD
2001
2003
EPA
Ground water
NJDEP Concurred on
BSD
Fed = 40 hours
Cont. = None
Est'd Increase = $3. OM
Type of Change: From - Air-stripping and re-injection of the treated water back into the underlying aquifer; To - Liquid-
phase granular activated carbon (GAC) adsorption and surface water discharge of the treated ground water.
Factual Basis: GAC adsorption was chosen based upon cost savings and broader operational flexibility and control (e.g.,
hydraulic operating range, effective treatment range according to influent water quality). Surface water discharge of treated
water is less costly in terms of operations and maintenance than effluent re-injection via injection wells.
06/88
08/05 BSD
2001
2003
EPA
Ground water
NJDEP concurred on
BSD
Fed = 40 hours
Contr. = None
Est'd Increase = $3. OM
Type of Change: From - Air-stripping and re-injection of the treated water back into the underlying aquifer; To - Liquid-
phase granular activated carbon (GAC) adsorption and surface water discharge of the treated ground water.
Factual Basis: GAC adsorption was chosen based upon cost savings and broader operational flexibility and control (e.g.,
hydraulic operating range, effective treatment range according to influent water quality). Surface water discharge of treated
water is less costly in terms of operations and maintenance than effluent re-injection via injection wells.
Appendix A.2
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 3 Increases - FY 04
Region 3
Fort Eustis (US Army),
VA
OU7
Region 3
Jacks Creek/Sitkin
Smelting & Refining,
Inc., PA
10/02
09/04 BSD
07/04
09/04
US Army
Soil
VDEQ reviewed and
commented on the
BSD.
The Army published a
public notice in the
local newspaper
Fed= 160-200 hours
Contr. = 160-200 hours*
Est'd Increase = $0.2M
*Note: This is a Federal
Facility. The costs &
time increases are for
DoD costs & time.*
Type of Change: From - Excavation and off-site disposal 20 cubic yards of buried sludge and contaminated soil; To - An
additional 90 cubic yards of sludge and soil to be addressed.
Factual Basis: The amount of contamination was underestimated during the RI.
09/97
12/04 BSD
09/04
12/04
EPA
Soil
PADEP approval.
Fed= 1 50 LOE hours
Contr. = 30 LOE hours
Est'd Increase =
Minimal
Type of Change: Implement institutional controls.
Factual Basis: Hot spots were found underneath certain buildings on the site, initiating use restrictions.
Appendix A.2
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 3 Increases - FY 05
Region 3
Paoli Rail Yard, PA
Region 3
Former West Virginia
Ordnance Works, WV
OU2, 5
07/92
03/05 BSD
N/A
3/05
PRP
Waste & GW
PA DEP was
consulted, Public
Notice of ESDs were
issued
Fed = 40-80 hours
Contr. = None
Est'd Increase = Not
significant
Type of Change: From: Removal of tie pile and old cleanup standard for benzene in GW; To: Groundwater cleanup
standard for benzene set at the MCL and railroad tie pile allowed to remain in place.
Factual Basis: Per PRP request, groundwater cleanup standard for benzene set at the MCL and tie pile allowed to remain in
place due to lack of PCBs above the cleanup standards.
09/88
06/05 BSD
10/04
06/05
US Army
Soil
Yes, notice of
availability published
Fed =120 hours
Contr. = None
Est'd Increase = $0.4M
Type of Change: From: Capping; To: Excavation and composting.
Factual Basis: High ground water table.
Appendix A.2
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 4 Increases - FY 04
Region 4
Coleman Evans Wood
Preserving Company, FL
Region 4
Escambia Wood, FL
Region 4
Oak Ridge Reservation
(USDOE), TN
OU29
09/86
02/04 BSD
11/03
02/04
EPA
Soil
State concurred on
ESD Notice in local
paper, Community
Information Meetings
Fed = 20 hours
Contr.= None
Est'd Increase = $1.3M
Type of Change: From - Excavating and thermo treating a total of 135,000 cubic yards of contaminated soil; To -
Excavating and treating the 135,000 cubic yards plus an additional 20,000 cubic yards of soil.
Factual Basis: Additional soil identified during RA.
02/97
04/04 BSD
01/04
04/04
EPA
Soil
State concurred on
ESD Public Notice,
Community
Information Meetings
Fed= 100 hours
Contr. = None
Est'd Increase = $7.0M
Type of Change: From - Interim ROD for relocation of local residents and demolition of homes and an apartment complex;
To - An ESD to start the process to change Interim ROD into final ROD. ESD to require additional off-site soil
investigations.
Factual Basis: Evaluation of data from 10 years of pump and treating ground water at the site.
09/00
02/04 ESD
02/03
02/04
DOE
All Media
State concurred, Public
Notice in local paper
Fed = 80 hours
Contr.= None
Est'd Increase = $3. 5M
Type of Change: From - 1,000 acre section of the Reservation with approximately 100 disposal areas; To - Adding an
additional 3 closed waste storage units.
Factual Basis: At the time the ROD was issued, the 3 storage units were in use. NOW that the units have been closed
investigation of these units has been added to the ROD by this ESD.
Appendix A.2
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 4
Woolfolk Chemical
Works, Inc., GA
OU3
08/98
08/04 BSD
05/03
08/04
EPA
Soil
State concurred, Public
Meeting and Comment
Period
Fed = 500 hours
Contr.= 400 hours
Est'd Increase = $8. OM
Type of Change: From - Excavation, treatment, and disposal of approximately 44,000 cy of arsenic contaminated soil and
debris; To - Excavation, treatment, and disposal of approximately 1 16,000cy of contaminated soil and debris.
Factual Basis: The volume of soil and debris needing remediation significantly increased based on sampling results
conducted during the RD. Proposed revisions to the arsenic MCL also contributed in part to this increase.
Region 4 Increases - FY05
Region 4
USDOE Oak Ridge
Reservation, TN
OU13
Region 4
USDOE Oak Ridge
Reservation, TN
OU29
11/99
2/05 BSD
5/04
2/05
DOE
Transported
waste
State and EPA
concurrence and
Public Notice in the
local newspaper
Fed = 50 hours
Contr.= None
Est'd Increase =
Sll.OM
Type of Change: From - Transporting waste over public roads; To - Construction of a 4.8 mile haul road in a restricted
access area of the reservation to be used to transport waste to an on-site disposal facility.
Factual Basis: Decision to restrict transportation of wastes to on-site roads.
9/2000
11/04 BSD
1/04
11/04
DOE
Demolition
debris and
contaminated
soil
State and EPA
concurrence and
Public Notice in the
local newspaper
Fed =100 hours
Contr. = None
Est'd Increase = $2.6M
Type of Change: Remediation of eleven additional units.
Factual Basis: Identification of 1 1 units.
Appendix A.2
10
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 5 Increases - FY 04
Region 5
Clare Water Supply, MI
09/92
09/04
BSD
01/04
09/04
U.S. EPA
Ground
water
State concurred on BSD and conducted oversight. City
officials participated in BSD public meeting.
Fed = 40 hours
Contr. = None
Est'd Increase =
$0.4M
Type of Change: From - Use, deed and/or access restrictions as necessary; soil vapor extraction; and ground water extraction and
treatment, using ultraviolet photochemical oxidation; To - Permeable reactive barrier wall, new municipal well.
Factual Basis: The overall site-wide remedy has been constructed and operating since March of 1999. Since then, information has come
to light which necessitates modifications to three (3) aspects of the remedies that were implemented at the Site. The first relates to ground
water contamination emanating from the Mitchell facility in the southwestern portion of the Site. Secondly, the City of Clare has advised
U.S. EPA and the PRPs that municipal well #2, which is part of the ground water extraction network provided for in a Record of Decision
signed on 9/16/1992, is failing and will need to be replaced. And finally, the Ground water Surface Water Interface (GSI) criteria
provided in a 1992 Record of Decision (ROD) have become more stringent for ethylbenzene and xylene, and these new criteria are being
adopted herein. As a result of the first issues permeable reactive barrier wall will be installed to intercept ground water as it leaves the
site. In addition, municipal well #2 will be replaced. There is no cost differential due to the third issue.
Region 5
Outboard Marine
Corporation, IL
OU2
09/99
09/04
BSD
2004
09/04
PRPs, U.S.
EPA
Soil
State reviewed and concurred, City of Waukegan reviewed.
Fed = 40 hours
Contr. = None
Est'd Increase =
$0.1M
Type of Change: From - Ground water cleaned up to remove arsenic, ammonia, and benzene; soils excavated and treated to
stabilize PAH and arsenic; To - Excavation of an additional 1,000 cubic yards of soil and disposal off-site; reduced cleanup levels
for semi-volatile organic compounds.
Factual Basis: The 1999 ROD called for the cleanup of the OMC-owned WCP site to commercial/industrial standards. OMC
subsequently went bankrupt in December 2000 and the City of Waukegan acquired the WCP property. The City hopes to redevelop the
land with high-density residential buildings and small shops. The City wanted a residential cleanup action. The PRPs identified 2 semi-
volatile organic compounds in the soil that could be cleaned up to lower cleanup standards to guard against indoor air intrusion if the site
is redeveloped. The BSD reduces the cleanup levels for the two compounds. Also, we acknowledge that the City may redevelop the site
for residential uses if certain extra protective measures are taken by the City. The lowered standards correspond to an extra 1,000 cubic
yards of soil to be excavated and disposed of off-site resulting in a cost increase of $100,000.
Appendix A.2
11
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 5 Increases - FY 05
Region 5
Feed Materials
Production Center
(USDOE), OH
OU4
12/94
01/05 BSD
06/04
11/04
USDOE
Waste
OEPA and Citizens
groups involved in
decision. Public
meeting and 30 day
comment period
occurred.
Fed = 90 hours
Contr. = None
Est'd Increase =
$14.0M
Type of Change: From - No interim storage facility called for/required; To - Interim storage of the silo waste material off-
site at Waste Control Specialists in Texas prior to final off-site disposal.
Factual Basis: This ESD allowed for interim storage of the Silo waste material off-site at Waste Control Specialists in Texas
prior to final off-site disposal. The total cost of the current remedy (waste removal, treatment, off-site storage and disposal) is
$350 Million.
Region 5
Forest Waste Products,
MI
06/86
09/05 ROD-A
06/04
09/05
USEPA/MDEQ
Ground water
MDEQ reviewed the
ROD Amendment but
did not concur.
Fed = 770 hours
Contr. = $40,000
Est'd Increase = $5 .2M
Type of Change: From - Removal of drums from the landfill, construction of a RCRA cap over the landfill, a contingency
for ground water remedial actions, and access and deed restrictions; To - Two stages of in-situ ground water treatment:
directly downgradient from the landfill (either the in-situ submerged oxygen curtain, or the air sparging trench); and near the
site boundaries and off-site (chemical oxidation, expansion of the site boundaries, updating the clean up action levels, MNA
downgradient from the chemical oxidation lines, enforcement of ground water use restrictions, and a contingency for a
residential well replacement.
Factual Basis: High VOCs were detected in a new monitoring well located north of the landfill. In 2001, vinyl chloride was
detected off-site exceeding the action level. Since then monitoring has bounded the extent of the VOC contamination, and
indicates that the landfill is still a source of VOCs.
Appendix A.2
12
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 5
Johns-Manville-
Waukegan, IL
06/87
05/05 BSD
09/04
04/05
Illinois
Department of
Natural
Resources
N/A
State heavily involved
via DNR and
concurred with
remedy change
Fed = 80 hours
Contr. = None
Est'd Increase =
Negligible
Type of Change: Erect physical barriers (fence extensions) so more turtles cannot enter the Site, change work practices and
the timing of some of the work (most notably sand dredging) so that the turtles are not be adversely impacted or killed, and
perform regular inspections for the turtles and capture and properly relocate them to the State property.
Factual Basis: The Illinois Department of Natural Resources discovered two Blanding's turtles (state threatened species) on
their property adjacent to the Johns-Manville property. Upon further inspection, more turtles were discovered on the Johns-
Manville property. The media is N/A because the ESD is designed to protect a threatened species, not to address soil,
sediment, air, water, etc.
Region 6 Increases - FY 04
Region 6
Sol Lynn/Industrial
Transformers Site, TX
09/88
09/04 ROD-A
2000
09/04
EPA, State
Ground water
State commented and
concurred with the
amended remedy;
Community had no
adverse comments.
Fed = $2.8M
Contr.= 17,383 hours
Est'd Increase = $3. 5M
Type of Change: From - Ground water pump-and-treat; To - In-situ bioremediation plus monitored natural attenuation.
Factual Basis: Remedy change was necessary because the original pump-and-treat remedy was not satisfactorily recovering
source material (DNAPL) and could not achieve the remediation goals.
Appendix A.2
13
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 6 Increases - FY 05
Region 6
Delatte Metals, LA
09/00
12/04 BSD
11/02
12/04
Joint (EPA/
USFWS/
State)
Soil, battery
sludge
Newspaper notice
Fed = 80-120 hours
Contr. = None
Est'd Increase = $3. 2M
Type of Change: No change from the original remedy selected.
Factual Basis: Increased costs associated with the permeable reactive barrier wall installation, additional required lime
application, additional clear and grub activity, additional survey subcontractor costs, additional excavation/treatment/disposal
costs, additional surface restoration and the need for storm water control.
Region 7 Increases - FY 05
Region 7
Valley Park TCE, MO
09/01
08/05 BSD
09/03
08/05
EPA
Soil and GW
State Concurrence
Fed = N/A
Contr. = N/A
Est'd = $0.4M
Type of Change: From - a) most contaminated soils treated onsite by exsitu and insitu soil vapor extraction and some soils
disposed offsite; b) contaminated GW treated by air stripping at two commercial properties followed by reinjection into
aquifer - To a) most soil disposal offsite and insitu SVE onsite; and b) no air stripping and discharge into storm sewer.
Factual Basis: New information developed during design identified these changes
Appendix A.2
14
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 8 Increases - FY 04
Region 8
Rocky Mountain Arsenal
(USARMY), CO
OU 3 Burial Trenches
Region 8
Rocky Mountain Arsenal
(USARMY), CO
OU 3 - North Plants
Structure Demolition and
Removal Project
06/96
07/04 BSD
06/03
07/04
US Army
Soil
Public Concurred
Fed = None
Contr. = None
Est'd Increase = $2. 8M
Type of Change: 34 new remedy areas were added to the project and excavation of the additional soils was incorporated.
Factual Basis: New information was obtained by the Army during detailed document review and developed during
additional field design investigation.
06/96
09/04 BSD
05/04
09/04
US Army
Soil
Public Concurred
Fed = None
Contr. = None
Est'd Increase = $0.8M
Type of Change: Three surface soil areas were added as human health exceedance soils, two remediation areas were added.
Factual Basis: New information was obtained by the Army during detailed document review and developed during
additional field design investigation.
Appendix A.2
15
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 8 Increases - FY 05
Region 8
Central City, Clear Creek,
CO
Region 8
F.E. Warren Air Force
Base, WY
09/91
06/05 BSD
04/05
06/05
EPA
Tunnel
Discharge -
Surface Water
concur
Fed = $0.3M
Contr. = None
Est'd Increase = $0.3M
Type of Change: From - Interim Waiver; To - Conveyance to the Argo Tunnel Water Treatment Plant for Treatment thru
the plant.
Factual Basis: Additional water quality monitoring indicates that discharge from the Big Five Tunnel should be treated to
eliminate its impact on the main stem of Clear Creek thereby contributing to reduction of contaminants with a goal of
meeting State Water Quality Standards.
09/01
11/04ROD-A
08/04
11/04
US AIR
FORCE
Ground water
No Opposition
Fed = N/A
Contr. = N/A
Est'd Increase = $1.5M
(Based on Net Present
Value)
Type of Change: From - Pump and treat; To - In-Situ Chemical Oxidation with MNA.*
Factual Basis: Remedial Design pump tests established that long-term pumping is not feasible. *"Hot Spot" treatment was
added to MNA to get a similar remedial time frame with faster shot-term risk reduction.
Appendix A.2
16
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 9 Increases - FY 04
Region 9
Newmark Ground Water
Contamination
OU1,2
Region 9
Tracy Defense Depot, CA
8/93 (Interim)
3/95 (Interim)
8/04 BSD
2004
8/04
EPA
Ground water
State and City of San
Bernardino agree to
the institutional
controls (ICs)
Fed = Minimal
Contr. = Minimal
Est'd Increase =
Minimal
Type of Change: From - Extract GW & treat by liquid phase granular activated carbon and delivery of treated water to city
for distribution to the public or water will be recharged to the aquifer; To - Add ICs to protect and enhance the barrier well
system. BSD requires a GW management plan.
Factual Basis: Original interim remedies did not include ICs.
04/98
09/04 BSD
2003
09/04
DoD
Soil
State involved. Little
to no community
interest
Fed = N/A
Contr = 120 hours
Est'd Savings =
Minimal increase to
track ICs.
Type of Change: From: No Instituted land use controls sitewide, Soil Vapor Extraction for one site, and cover type of
aggregate base for one site To: Institutional land use controls sitewide, deletion of soil vapor extraction as a remedy for one
site and 12 percent grass cover type for another site
Factual Basis: To document ICs/LUCs. The cleanup standards were revised for 3 sites because updated fate and transport
modeling demonstrated no threat to groundwater from residual contamination that was difficult to remove. The SVE was
deleted because it was not deemed as effective for TPH soil contamination found post-ROD and ICs were implemented to
prevent disturbance of existing cover, thereby reducing leaching and contact. The grass cover was allowed to replace the
aggregate base cover because it was not economical to place aggregate base cover around structures in the area and ICs were
implemented to prevent incompatible uses in the grassy area of the site.
Appendix A.2
17
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 9
Tucson International
Airport Area, AZ
08/88
09/04 ROD-A
2003
09/04
EPA
Ground water
1 1 comments received
in writing, Public
meeting addressed
comments, Bi-monthly
community advisory
board meetings
Fed = N/A
Contr = N/A
Est'd Savings =$7.6M
Type of Change: Increased efficiency of 2 ground water pump-and-treat systems with an MNA contingency option for the
2nd system.
Factual Basis: This ROD Amendment adopts the same general process as the original ROD, extraction, treatment, and
reuse, but incorporates and relies upon new information obtained since the signing of the original ROD including: the
identification of West Plume B and the further delineation of the West-Cap ground water plume. These plumes exceed the
Federal MCLs and pose a threat to the nearby remedial actions at the Texas Instruments Project Area and the Arizona Air
National Guard Project Area.
Region 9 Increases - FY 05
Region 9
Beckman Instruments
(Porterville Plant), CA
09/89
9/05 ROD-A
12/04
09/05
EPA
GW
Provided 30 day
public comment
period
Fed= $30,000
Contr. = $2,000
Est'd Increase = $0.4M
Type of Change: From - No action; To - Monitored natural attenuation with existing institutional controls.
Factual Basis: EPA 5 year review for the site indicated ROD had not functioned as designed and would not be able to
achieve cleanup goals for lower aquifer.
Appendix A.2
18
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 9
McCormick & Baxter
Creosoting Co., CA
OU3
Region 9
San Gabriel Valley, CA
03/99
09/05 BSD
05/05
09/05
EPA
Sediment/
Surface Water
Fact sheet
Fed =103 hours
Contr. = None
Est'd Increase = $4. 1M
Type of Change: From - Two foot sand cap; To - Inclusion of bank stabilization and relocation of a citizen who's presence
impacted proper bank stabilization.
Factual Basis: Study indicated banks were eroding into slough and could be source of recontamination following sediment
cap installation.
1998 (Interim)
06/05 BSD
2002
06/05
EPA
Ground water
State concurred with
BSD
Fed = N/A
Contr. = N/A
Est'd Increase = Up to
$15.0M in capital costs
and up to $1.5M per
year additional O&M.
Type of Change: From -To contain VOCs in shallow and intermediate GW zones with carbon adsorption and air stripping;
To: Add ultraviolet light treatment for dioxane and either biotreatment or ion exchange for perchlorate
Factual Basis: Additional sampling showed two new contaminants of concern in GW - 1,4 dioxane and perchlorate.
Existing treatment system will not work on 1, 4 dioxane and perchlorate.
Appendix A.2
19
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 10 Increases - FY 04
Region 10
Commencement Bay,
Near Shore/Tide Flats,
WA
OU1
Region 10
Hanford 100-Area
(USDOE), WA
OU27
1989
09/04 BSD
01/89
01/05
EPA
Sediment
State and Community
Fed = None
Contr. = None
Est'd Increase = None
Type of Change: From - Site use restrictions, source control, natural recovery, sediment remedial action (i.e., confinement,
dredging and habitat mitigation), and monitoring; To - Placement of dredged sediment at an alternate location, alternative
sources of capping material, Capacity of the St. Paul CDF and sediments dredged from the Thea Foss and Wheeler-Osgood
Waterways, habitat mitigation projects, Clarification of selected remedy and consideration of federal de -authorization of the
navigation channel, ICs.
Factual Basis: These differences are the result of changes in the cleanup plan due to finalizing the designs and modifications
based on the actual work completed in the Head of the Thea Foss Waterway.
1999
02/04 BSD
01/04
02/04
USDOE &
EPA
Soil and debris
with hazardous
and mixed
waste
State supports ESD.
Fact sheet and public
notification
Fed =18 hours
Contr. = None
Est'd Increase = $32. OM
Type of Change: From - 209 waste sites; To - 237 waste sites, 10 CFR 1022 AND 40 CFR Part 6, Appendix A as ARARs,
and revised annual institutional controls report submittal date to be consistent with the requirements contained in the Hanford
sitewide institutional controls report.
Factual Basis: Ongoing remedial activities have identified 28 newly discovered waste sites that have a potentially
unacceptable risk to human health and the environment. In accordance with the ROD, publication of an BSD is required to
add newly discovered waste sites.
Appendix A.2
20
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 10
Hanford 300-Area
(USDOE),WA
OU3
Region 10
Idaho National
Engineering Lab
(USDOE), ID
OU3
04/01
04/04 BSD
2000
2004
Tri-Party
Agencies:
EPA,
Energy,
Ecology
Hazardous
waste, Mixed
waste, Soil
Public notification.
State supported
remedy changes
Fed = 40 hours
Contr. = 20 hours
Est'd Increase = $0.8M
Type of Change: From - Uranium cleanup level identified in the Record of Decision; To - Change to the uranium cleanup
level, modified soil cleanup levels from industrial to unrestricted use for 8 outlying waste sites in the 300-FF-2 OU. Also
modified soil cleanup levels for the remainder of 300-FF-2 waste sites from 350 pCi/g to 267 pCi/g for the protection of
groundwater.
Factual Basis: The eight outlying sites were determined to have a reasonably anticipated future land use other than just
industrial. The soil cleanup levels for groundwater protection were set as the result of a study performed in 2000, 2001, and
2002 that was required by the initial 300-FF-2 ROD.
11/99
02/04 ROD-A
11/04
2/04
EPA
Tank contents
and Soil
State reviewed and
commented on ESD.
Notice to public in
local papers
Fed =N/A
Contr. =0
Est'd Increase = $0.1M
Type of Change: From - Soil and tank removal, ex situ treatment of tank contents, and disposal; To - Chemical
oxidation/reduction followed by stabilization of tank contents.
Factual Basis: A ROD Amendment is necessary because modification of the original selected remedy for the V-Talks
contents was required after the proposed technology became commercially unavailable, and the risk of it remaining
unavailable was considered to be too high to proceed under the existing 1999 ROD.
Appendix A.2
21
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 10
Idaho National
Engineering Lab
(USDOE), ID
OU3-13
10/99
07/04 ESD
10/03
02/04
Dept of
Energy
Ground water
and soil
ESD signed by Idaho
Department of
Environmental Quality.
ESD description and
notice of availability
planned for Idaho
newspapers.
Fed = 40 hours
Contractor = 20 hours
Est'd Increase = $0.1M
Type of Change: From - Ground water monitoring with contingent pump and treat; To - Expanded scope to include targeted
groundwater sampling in the vicinity of a facility injection well to verify that the well is not a residual source of radionuclide
contamination to the aquifer, hi addition, the ESD addressed three Idaho Nuclear Technology Engineering Center soil sites; Sites CPP-
81 and 82 require no action, and Site CPP-61 requires institutional controls to restrict exposure to low levels of radionuclides and PCBs.
Factual Basis: The Idaho Nuclear Technology Engineering Center groundwater monitoring conducted following the OU 3-13
ROD indicated that groundwater in the vicinity of the CPP-23 injection well was not a residual source of contamination to the
aquifer. Based on a review of historical site data, the CPP-81, -82, and -61 soil sites were identified for no action or institutional
controls consistent with the decisions for similar soil sites under the OU 3-13 ROD.
Region 10
Northwest Pipe &
Casing/Hall Process Co.
OR
OU1
06/00
03/04 ESD
2001
03/04
EPA
Soil
Oregon DEQ
concurrence w/ESD
Oregon Division of
State Lands (wetlands
reg) review & approval
of wetlands design
Fed. = N/A
Contr. = Minimal for
design; $0.2M for
construction; minimal for
yearly for O&M
Est'd Increase = $0.1M
for wetland restoration
Type of Change: From - Soil hot spots removal, soil cap, wetlands restoration and institutional controls; To - Revised soil
cleanup level for vinyl chloride, construction of a wetland restoration, identification of ARARs.
Factual Basis: During the phase 1 soil remedial design and remedial action, site conditions were encountered that resulted in the
completion of additional activities, i.e., not originally anticipated nor described in the ROD. Circumstances regarding available
analytical methods for the contaminant vinyl chloride resulted in revisions to the soil cleanup verification method and the soil
cleanup level for vinyl chloride. Wetlands were discovered on the site, resulting in the inclusion of wetland ARARs and
development of a restoration measure to compensate for the loss of existing wetlands resulting from the soil cap placement. Other
minor changes to the remedy were made.
Appendix A.2
22
-------
Summary of Remedy Update Information for FY04 and FY05 for Sites With Cost Increases
Region
Site Name, State
OU
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
Est'd Cost Increase
Region 10
Puget Sound Naval
06/00
02/04 ROD-A
09/03
02/04
Navy&
EPA
Sediment
State and Suquamish
Tribe supported
remedy changes
Fed = 80 hours
Contr. = 50 hours
Est'd Increase = $0.8M
Shipyard Complex, WA
OU2
Type of Change: From - Cleanup of marine sediments included a combination of dredging with disposal in a confined
aquatic disposal (CAD) pit, capping, enhanced natural recovery, monitored natural recovery and institutional controls; To -
A change in the boundary of OUB Marine to address additional sediment cleanup areas, modify action levels for the response
action on Washington Owned Aquatic Lands (SOAL) adjacent to the Navy's CAD pit, require additional cleanup on SOAL
(enhanced natural recovery) and address institutional control requirements on SOAL. xhe ESD does not change any of the
remedial action objectives stated in the ROD.
Factual Basis: Unanticipated contamination was discovered on SOAL as a result of the disposal of contaminated sediments
in the CAD pit. The Navy spent approximately $11 million dollars on the initial remedial action as required By the ROD.
The SOAL remedial action cost an additional $772,000.
Appendix A.2
23
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Office of Solid Waste and Emergency Response
Washington, D.C. 20460
OSWER 9355.0-116
EPA-540-R-06-074
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