SEPA
United 3tetw OSWER 9283.1-28
Protection EPA 540-R-06-066
December, 2006
2005 Annual Progress Report
For Ground Water Remedy Optimization
Office of Superfund Remediation and Technology Innovation
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1.0. Introduction
1.1 Purpose
The purpose of this Annual Report is to provide a summary and analysis of progress
toward implementation of optimization recommendations at Superfund-fmanced Pump and Treat
(P&T) sites. The report summarizes successful implementation strategies, opportunities for
improvement, barriers to implementation, and changes in project costs as a result of
optimization. The report also identifies sites requiring no further follow-up and discusses
optimization reviews funded by the Regional program offices.
The main body of the report is accompanied by an appendix containing a summary of
optimization recommendations by Region and site name. Regions are encouraged to review the
appendix to assess progress in their respective programs. This Annual Report generally
represents the status of optimization efforts in the Superfund program at the end of calendar year
2005.
1.2 Project Background
The Office of Solid Waste and Emergency Response (OSWER) developed the pilot
Fund-lead P&T optimization initiative as part of the FY2000-FY2001 Superfund Reforms
Strategy (OSWER 9200.0-33; July 7, 2000). Optimization is intended to facilitate systematic
review and modification of existing P&T systems to promote continuous improvement, and to
enhance overall remedy and cost effectiveness. In the Superfund program, optimization
evaluations should be accomplished using the Remediation System Evaluation (RSE) process, a
tool developed by the U.S. Army Corps of Engineers.
The pilot phase of the optimization initiative demonstrated that this effort offers
measurable benefits in the form of cost savings and improved remediation systems. In August
2004, the Office of Superfund Remediation and Technology Innovation (OSRTI) developed the
Action Plan for Ground Water Remedy Optimization ("2004 Action Plan") (OSWER 9283.1- 25;
August 25, 2004) to further implement important lessons learned from the pilot phase and fully
integrate optimization into the Superfund cleanup process where appropriate. Among other
things, the Action Plan envisions an annual summary of progress concerning the implementation
of recommended system changes.
1.3 Sites Subject to Optimization Reviews
There are currently fewer than 100 Superfund-fmanced P&T systems operating
nationwide. To date, the Superfund program has conducted an optimization evaluation at 36
sites, most of which address this universe of Fund-financed P&T systems. The name, location
and review date for these sites are listed in Exhibit 1.
The approach for selecting sites to receive an optimization review typically includes a
review of annual operating costs, the age of the system, and concerns for remedy effectiveness or
system efficiency. Ground water remedies with the highest annual operating costs likely offer
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OSWER 9283.1-28
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the greatest opportunities for cost savings and increased efficiency. RSEs may also be
appropriate for systems that have been operating for two to four years, in order to maximize
early opportunities for improvements and cost savings.
Regardless of annual operating costs or the age of the system, an optimization review
may be valuable at sites where there are concerns about the effectiveness of the remedy or the
efficiency of the P&T system. An RSE may also help address recommendations in Five-Year
Reviews that identify similar concerns.
1.4 Monitoring Implementation Progress
Each site that receives an optimization review is subject to follow-up, typically in the
form of annual conference calls between OSRTI and the Region, for at least two years after the
RSE report is finalized. These follow-up discussions highlight the status of recommended
changes and obstacles to implementation that require additional attention. Continuous oversight
of progress at RSE sites helps maximize the benefits of optimization, identify lessons learned,
and provide technical assistance. The appendix to this report generally represents the status of
optimization efforts in the Superfund program at the end of calendar year 2005, based on the
results of the most recent round of follow-up discussions. Additional information provided by
site managers may also be used to supplement the appendix.
RSEs generate a number of suggestions, ideas, and recommendations which should be
discussed and evaluated. Regions should weigh many factors including, but not limited to,
technical feasibility, short-term implementation issues, long-term benefits, public and State
acceptance, contractual requirements, effectiveness and availability of funding, when
determining whether to implement optimization recommendations. Disagreements regarding the
implementation of a particular recommendation are possible, and may be elevated to
management for resolution.
If RPMs have questions regarding implementation of complex RSE recommendations,
technical assistance is available from many sources, including Regional technical support staff,
OSRTI staff and the RSE team, the EPA laboratories through the Technical Support Project, and
the U.S. Army Corps of Engineers.
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Exhibit 1. Sites with optimization reviews led by OSRTI
EPA
Region
1
2
3
4
5
6
7
8
9
10
State
MA
NH
MA
MA
NY
NY
NY
NJ
NY
NJ
NY
PA
PA
PA
VA
NC
sc
NC
FL
MN
WI
MI
IN
IN
MI
WI
AR
LA
NE
CO
CA
CA
WA
OR
WA
WA
Site Name
Baird & McGuire
Savage Municipal Water Supply
Silresim Chemical Corp.
Groveland Wells
Mattiace Petrochemical Co., Inc.
Claremont Polychmical
Brewster Well Field
Bog Creek Farm
SMS Instruments, Inc.
Higgins Farm
Circuitron Corp.
Hellertown Manufacturing
Raymark
Havertown PCP
Greenwood Chemical Co.
PCX, Inc. (Statesville Plant)
Elmore Waste Disposal
Cape Fear Wood Preserving
American Creosote Works, Inc. (Pensacola Plant)
MacGillis and Gibbs Co ./Bell Lumber & Pole Co.
Oconomowoc Electroplating
Ott/Story/Cordova Chemical Co.
Douglas Road/Uniroyal, Inc., Landfill
Reilly Tar & Chemical Corp. (Indianapolis Plant)
Peerless Plating Co. Inc.
Penta Wood Products
Midland Products
Bayou Bonfouca
Cleburn Street Well
Summitville Mine
Modesto Ground Water Contamination
Selma Treating Co.
Commencement Bay, South Tacoma Channel
McCormick & Baxter
Boomsnub/Airco
Wyckoff Co./Eagle Harbor
Fiscal Year
of Review (a)
2001
2001
2001
2002
2001
2001
2002
2002
2003
2003
2004
2001
2001
2003
2003
2000
2000
2004
2006
2000
2000
2001
2004
2004
2005
2006
2001
2001
2001
2002
2001
2002
2001
2001
2002
2004
Annual
Reporting
Status ^
complete
updated
complete
updated
complete
updated
updated
updated
updated
updated
updated
complete
complete
updated
updated
updated
updated
updated
new
complete
updated
updated
updated
updated
new
new
complete
complete
updated
complete
updated
complete
updated
complete
updated
updated
(a) Date refers to date of site visit; RSE reports may be finalized months later, following multiple-party review.
(b) Complete sites were documented as such in the 2004 annual report; new sites have not yet been subject to formal
followup discussions, progress of updated sites is included in the appendix to this report. Only updated sites are
included in the analyses contained in this report.
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2.0 Summary of Implementation Progress
2.1 Overview
Each of the RSEs resulted in an improved understanding of the operating P&T systems
and identified a number of opportunities for improvements in efficiency and effectiveness. The
RSE reports specifically highlight recommendations in the following four categories:
• recommendations to improve remedy effectiveness,
• recommendations to reduce operating costs,
• recommendations for technical improvement, and
• recommendations to expedite site closure.
The annual follow-up discussions between OSRTI and the Remedial Project Manager
(RPM) assess progress with the implementation of each recommendation contained in the RSE
reports. Exhibit 2 summarizes progress in each of the four categories of recommendations. The
subsequent sections provide an analysis of implementation progress and highlights of site-
specific progress. The data included in this report represents only the sites that are still subject to
the designated follow-up process (listed as status "updated" in Exhibit 7). Sites that completed
the follow-up process, as documented in the previous progress report, are no longer referenced
here.
Exhibit 2. Status of optimization recommendations
Types of
Recommendations
Remedy
Effectiveness
(69 total)
Cost Reduction
(86 total)
Technical
Improvement
(66 total)
Site Closure
(27 total)
Overall Progress
(248 total)
Implementation Status
Implemented
68%
(47)
53.5%
(46)
66.6%
(44)
26%
(7)
58%
(144)
In
progress
11.5%
(8)
9.3%
(8)
6%
(4)
33%
(9)
12%
(29)
Planned
11.5%
(8)
5.8%
(5)
1.5%
(1)
—
5.5%
(14)
Declined
3%
(2)
21%
(18)
12%
(8)
11%
(3)
12.5%
(31)
Deferred
to
PRP/State
3%
(2)
1%
(1)
3%
(2)
7%
(2)
3%
(7)
Under
Consideration
3%
(2)
9.3%
(8)
11%
(7)
22%
(6)
9%
(23)
Note: Numbers in parentheses represent actual number of recommendations, used to calculate rounded percentages.
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RPMs have made positive efforts to address more than 90% of all recommendations
made to date; only 9% of the RSE recommendations remain under consideration. On the whole,
this represents a small decline in the recommendations that remain to be addressed since the last
progress report. However, it is important to highlight the significant improvement in the
percentage of recommendations now fully implemented, from 50% in 2004 to 58% in 2005.
2.2 Implementation of Remedy Effectiveness Recommendations
A thorough review of remedy effectiveness continues to be a principal element of
OSRTFs optimization evaluations. Recommendations to improve effectiveness predominantly
suggest more rigorous evaluation of the extraction and subsurface portions of the remedy rather
than the above-ground treatment portion. The most common recommendations in this category
generally relate to plume delineation, additional characterization or sampling, and improved data
collection and/or reporting.
RSE recommendations with respect to plume delineation continue to identify the need for
capture zone analyses, the development of updated plume maps, or new ground water flow or
contaminant transport modeling. Approximately 68% of remedy effectiveness recommendations
have been implemented and another 25% are in progress or planned for the near-term. This is a
marked improvement over the last progress report, at which time 56% percent of these
recommendations were complete. The time required to consider or implement these changes
varies, and may be assessed by reviewing the detailed information in the appendix.
2.3 Implementation of Cost Reduction Recommendations
RSE recommendations pertaining to cost reduction may cover many aspects of system
operation, including the selection of treatment technologies, operator and laboratory labor, and
project management. A common recommendation for cost reduction typically calls for site
managers to reduce or eliminate ground water or process monitoring that is no longer necessary
once a system is operating at steady-state.
RSEs continue to identify opportunities to reduce operator or onsite labor without
sacrificing the effectiveness of the remedy. Such reductions should be expected following
system shakedown or automation, when a system is operating at steady-state. Furthermore, some
treatment components become inefficient or unnecessary as a result of changing site conditions
or due to conservative estimates during the design phase. Simplifying a treatment system under
such conditions has resulted in reduced material usage, utilities, and labor.
Approximately 54% of cost-reduction recommendations have been implemented to date.
OSRTI and the States continue to experience cost savings and improved efficiencies associated
with optimizing long-term P&T systems. However, documenting precise cost savings and
expenditures directly related to RSE implementation continues to pose a challenge. To
maximize cost savings for EPA, it may be beneficial to implement recommendations that offer
the greatest potential reduction in annual operating costs as early as possible during the LTRA
phase.
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The highlight below provides an example of successful implementation of cost reduction
recommendations.
Highlight: Success with Cost Reduction Recommendations
Cape Fear Wood Preserving: The RSE Team recommended that the site team contract O&M
services and ground water sampling to a local contractor, instead of paying travel expenses
associated with the existing contract arrangement.
The site team quickly responded to this recommendation by adjusting the contract for O&M
services. A local contractor, located within one hour of the site, is now used for basic O&M
and sampling. This change also allowed the site team to adjust the method of utility
payment to avoid previous mark ups. The site team estimates that these changes have
contributed to a 40% reduction in monthly O&M costs (in labor and utilities).
2.4 Implementation of Technical Improvement Recommendations
Technical improvement recommendations cover a wide range of items to improve overall site
operations. The RSE reports contain a total of 66 recommendations in this category. As Exhibit 2
demonstrates, two-thirds (66%) of these recommendations have been fully implemented, a
significant improvement over the last progress report (57%). RPMs continue to implement the
majority of these recommendations shortly after the RSE site visit highlights opportunities for
improvement. These types of recommendations are generally easy to implement, require little up
front funding, and are not typically contingent on other recommendations. Examples of
technical improvement recommendations include the following:
• Clean, repair or replace faulty equipment,
• Rehabilitate fouled extraction or injection wells,
• Improve or streamline data evaluation protocols,
• Reformat O&M reports, and
• Modify sampling protocols.
2.5 Implementation of Site Closure Recommendations
RSEs continue to identify opportunities to accelerate progress toward achieving final
cleanup goals and eventual site closure. These recommendations most commonly involve
developing a clear and comprehensive exit strategy and/or evaluating alternate remedial
approaches.
An exit strategy usually details the specific steps for achieving closeout of the remedy or
various components of the remedy. Developing an exit strategy typically involves establishing
clear and valid cleanup goals, then determining the specific data and criteria to be used to
evaluate if goals are met such that some or all of the system can be shut down. If the
intermediate goals and milestones are not met, RPMs should then consider alternatives to the
current system. This may include alternate technologies to replace P&T, or to supplement it with
more aggressive source removal.
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More than one-quarter (26%) of recommendations associated with site closure have been
implemented, which is an improvement over the last progress report (21%). An additional one-
third (33%) of these recommendations are currently in progress. Exit strategy recommendations,
while valuable in the long-term, often are considered after effectiveness and cost reduction
recommendations are implemented. In addition, consideration of supplemental or alternative
remedial technologies generally requires higher expenditures than what is expected for routine
O&M, and may require changes to site decision documents (e.g., an amended Record of
Decision). For these reasons, the data continue to show a lower percentage of these
recommendations implemented, while many are still under consideration.
The highlight below provides two examples of successful implementation of
supplemental technologies for source removal that could allow earlier shutdown of existing P&T
systems.
Highlight: Success with Recommendations to Expedite Site Closure
Selma Treating Co. Site: In 2005, EPA Region 9 began a pilot test for //7s/fr/bioremediation
to enhance the effectiveness of the existing P&T. Molasses injection successfully converted
Chromium VI to less toxic and less mobile Chromium III in a highly contaminated source
area. The pilot effort has since been expanded, and the P&T system has become more
effective at treating lower levels of residual Cr(VI). As a result, the Region fully expects the
bioremediation effort to reduce the duration of P&T operations by several decades.
SMS Instruments Site (Update since 2004 Annual Report): The air sparging system began
operation in April 2005, then the remedy transferred to the State in July for O&M. The
State discontinued P&T two months later, based on progress with the air sparging system.
EPA Region 2 and the State estimate that conditions may be appropriate to discontinue
active remediation in mid-2006. The State is currently operating the remedy for
approximately $5,000 per month, compared to $30,000 per month for the previous P&T
remedy (nearly 85% reduction in annual operating costs).
2.6 Sites Requiring No Further Follow-Up
As shown in Exhibit 2, RPMs continue to demonstrate a commitment to the
implementation of RSE recommendations. In fact, the optimization process is complete at a
number of sites as a result of the successful implementation or thorough consideration of all RSE
recommendations. OSRTI is no longer conducting annual follow-up discussions at these
particular sites, though assistance is still available to site managers in the event that any
optimization-related issues arise.
OSRTI has also completed the follow-up process for a number of sites where EPA is no
longer responsible for operating or optimizing the P&T system. Included here are sites where
the State now has responsibility for operation and maintenance of the remedy, or where the P&T
system is no longer operating. Exhibit 3 highlights the two sites that completed the follow-up
process in 2005.
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As demonstrated in the appendix to this report, there are nearly a dozen sites at which
efforts to implement the last one or two recommendations are currently underway. OSRTI
expects to report on a larger number of sites having completed the follow-up process in the next
annual report.
Exhibit 3. Sites requiring no further follow-up
Rationale
Successful implementation and/or thorough
consideration of all RSE recommendations
Long-Term Response Action (LTRA) is complete;
State is now responsible for operation and
maintenance (O&M)
Site Name
SMS Instruments
Commencement Bay/South
Tacoma Channel
3.0 Related Initiatives
3.1 Region 3 "Regional Optimization Evaluation Team"
EPA Region 3 completed the Regional Optimization Program that began in 2004. The
program included streamlined reviews (RSE-Lites) for twelve Fund-financed P&T sites and
systematic tracking of recommendations and site milestones. Overall, the effort identified the
potential for more than $1 million in capital cost savings, as well as annual savings of more than
$100,000. In addition to cost savings, these reviews generated recommendations related to
remedy effectiveness and site closeout that are generally consistent with sites in other Regions.
Region 3 concluded that the use of an independent evaluation team, combined with the
nature of their team approach, resulted in a high degree of interaction and shared knowledge
across all levels. OSRTI is currently considering how to apply this experience to other Regions.
3.2 Optimization Evaluations Led by Regions
Lang Property (Pemberton Township, NJ)
EPA Region 2 sought input from the Army Corps of Engineers (USAGE) and EPA's own
Environmental Response Team (ERT) to optimize the existing approach to ground water
remediation. ERT was instrumental in delineating the nature and extent of an area of
contaminated soil, which was a contributing source to ground water contamination. ERT
recommended a pilot in situ effort, which had mixed results due to site-specific conditions.
USAGE then recommended excavation, which was very successful. USAGE'S optimization
effort also included the conversion of existing monitoring wells to reinjection wells, to assist in
the disposal of water generated as a result of the excavation.
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Mohonk Road Industrial Plant (High Falls, NY)
Significant implementation progress has occurred at this site, following the 2004 RSE by
a team of staff from EPA Region 2 and the Army Corps of Engineers. Vapor intrusion
evaluation of residential homes has been conducted over the past two heating seasons. Several
of the recommendations associated with reporting and sampling location modifications were
implemented as well. The acid delivery system modifications at the groundwater treatment
facilities were also implemented. All other recommendations remain under consideration.
4.0 Future Plans
OSRTI expects to continue to fund independent, technical experts to conduct additional
RSEs and streamlined RSE-Lites each year. OSRTI will continue to select sites for future
reviews based on annual operating costs, the age of the system, and concerns for remedy
effectiveness and system efficiency. Regions should contact OSRTI to recommend any sites that
may benefit from an optimization review.
Consistent with the Action Plan for Ground Water Remedy Optimization (OSWER
9283.1-25; August 2004), each Region should pursue an RSE at a minimum of one site each
year, where suitable candidate sites exist. Contractual access to OSRTFs RSE experts may be
made available to the Regions for this purpose, if needed.
OSRTI will continue to utilize the existing process for follow-up discussions in order to
monitor progress with the implementation of RSE recommendations. Follow-up will continue at
all sites, with the exception of those identified in Section 2.6 of this report. RPMs may request
technical assistance to aid in the implementation of system changes.
5.0 References
5.1 Internet Resources
OSRTI, Post-Construction Program Area
• Guidance for post-construction completion activities, with optimization project updates
• http://www.epa.gov/superfund/action/postconstruction/index.htm
OSRTI, Hazardous Waste Clean-Up Information (CLU-IN) web site
• Site-specific RSE reports and recommendations
• http ://www. clu-in. org/optimization
U.S. Army Corps of Engineers, Hazardous, Toxic and Radioactive Waste Center of Expertise
• RSE checklists and scope of work, provided by developers of the RSE tool
• http://www.environmental.usace.army.mil/librarv/guide/rsechk/rsechk.html
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Federal Remediation Technologies Roundtable
• Case studies, conference materials and more, compiled by an inter-agency workgroup
• http://www.frtr.gov/optimization.htm
5.2 Guidance and Fact Sheets
Effective Contracting Approaches for Operating Pump and Treat Systems (OSWER 9283.1-
21FS / EPA 542-R-05-009; April 2005)
O&M Report Template for Ground Water Remedies (With Emphasis on Pump and Treat
Systems) (OSWER 9283.1-22FS / EPA 542-R-05-010; April 2005)
Cost-Effective Design of Pump and Treat Systems (OSWER 9283.1-20FS / EPA 542-R-05-008;
April 2005)
Action Plan for Ground Water Remedy Optimization (OSWER 9283.1-25; August 25, 2004)
Pilot Project to Optimize Superfund-fmanced Pump and Treat Systems: Summary Report and
Lessons Learned (OSWER 9283.1-18; November 2002)
Elements for Effective Management of Operating Pump and Treat Systems (OSWER 9355.4-
27FS-A; November 2002)
Implementation of RSE Recommendations: Technical Assistance Resources Available to RPMs
(January 2002)
5.3 General Project Documentation
2004 Annual Progress Report for Ground Water Remedy Optimization (OSWER 9283.1 -27;
August 2005)
Groundwater Pump and Treat Systems: Summary of Selected Cost and Performance
Information at Superfund-fmanced Sites (EPA 542-R-01-021a; December 2001)
Superfund Reform Strategy, Implementation Memorandum: Optimization of Fund-lead Ground
Water Pump and Treat (P&T) Systems (OSWER 9283.1-13; October 31, 2000)
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