OSWER 9283.1-34
f rs»K^ * EPA-540-R-10-016
° December, 2010
Ground Water Remedy Optimization
Progress Report: 2008 - 2009
Office of Superfund Remediation and Technology Innovation
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WASHINGTON, D G
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OS WER 9283.1-34
MEMORANDUM
SUBJECT: Ground Water Remedy Optimization Progress Report: 2008 - 2009
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FROM: James E. Woolford, Director ;,<"••
Office of Superfund Remediation and Technology Innovation
t:-'"
TO: Superfund National Policy Managers, Regions 1-10
The purpose of this memorandum is to transmit the latest summary report on
remedy (optimization efforts in the Superfund program. The "Ground Water Remedy
Optimisation Progress Report: 2008 - 2009" (OSWER 9283.1-34) provides a summary
and analysis of progress toward implementation of site-specific optimization
recommjendations.
Regions are encouraged to review the report and appendix to assess progress in
their respective programs. This summary report generally represents the status of
optimization recommendations that were implemented during calendar years 2008 and
2009, arid demonstrates continued improvement in the pace at which Remedial Project
Managers address recommendations. I greatly appreciate your continued commitment to
optimization as a means to achieve greater efficiencies in the Superfund program.
his report and all other documents related to the optimization effort can be found
on the internet at http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm
and http://www.clu-in.org/optimization. Questions or concerns should be directed to
Jennifer
Hovis, Remedy Optimization Team Leader, at (703) 603-8888.
Attachments
cc: Mathy Stanislaus, OSWER
Lisa Feldt, OSWER
Barry Breen, OSWER
Suzanne Rudzinksi, ORCR
ana Tulis, OEM
arolyn Hoskinson, OUST
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iavid Lloyd, OBLR
kggie Cheatham, FFRRO
lenne Wynn, OPM
Jlliott Gilberg, OSRE
rJave Kling, FFEO
Regional Superfund Branch Chiefs, Regions 1-10
Ghloe Metz, Superfund Lead Region Coordinator, Region 2
HARPM Co-Chairs
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1.0. Introduction
1.1 Purpose
The purpose of this report is to provide a summary and analysis of progress toward
implementation of optimization recommendations at Superfund-financed ground water pump and
treat (P&T) sites. The report summarizes successful implementation strategies, opportunities for
improvement, barriers to implementation, and changes in project costs as a result of
optimization.
The main body of the report is accompanied by an appendix containing a summary of
optimization recommendations by Region and site name. Regions are encouraged to review the
appendix to assess progress in their respective programs. This summary report describes
implementation of optimization recommendations during calendar years 2008 and 2009 at 19
sites. The report contains updated information for 18 sites where implementation has continued
since the last summary report, as well as one site subject to a more recent review which is being
reported for the first time. The name, location, and review date for these sites are listed in
Exhibit 1.
1.2 Project Background
The Office of Solid Waste and Emergency Response (OSWER) developed the pilot
Fund-lead P&T optimization initiative as part of the FY2000-FY2001 Superfund Reforms
Strategy (OSWER 9200.0-33; July 7, 2000). Optimization is intended to facilitate systematic
review and modification of operating remediation systems to promote continuous improvement,
and to enhance overall remedy and cost effectiveness. In the Superfund program, most
optimization evaluations utilize the Remediation System Evaluation (RSE) process, a tool
developed by the U.S. Army Corps of Engineers.
The pilot phase of the optimization initiative demonstrated that this effort offers
measurable benefits in the form of cost savings and improved remediation systems. In August
2004, the Office of Superfund Remediation and Technology Innovation (OSRTI) developed the
Action Plan for Ground Water Remedy Optimization ("2004 Action Plan") (OSWER 9283.1- 25;
August 25, 2004) to further implement important lessons learned from the pilot phase and fully
integrate optimization into the Superfund cleanup process where appropriate. Among other
things, the Action Plan envisions the development of routine progress reports concerning the
implementation of recommended system changes.
Since the creation of the Action Plan, the Superfund Program has developed additional
tools and approaches that apply optimization concepts to sites earlier in the investigation and
cleanup process. These related efforts continue to evolve and expand optimization to a growing
number of sites. At this time, only a subset of sites that receive an optimization review are
monitored and subject to reporting pursuant to the Action Plan. The sites discussed in this report
are primarily Fund-financed, operating P&T systems.
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OSWER 9283.1-34
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1.3 Sites Subject to Optimization Reviews
The approach for selecting sites to receive an optimization review typically includes a
review of annual operating costs, the age of the system, and concerns for remedy effectiveness or
system efficiency. Ground water remedies with the highest annual operating costs likely offer
the greatest opportunities for cost savings and increased efficiency. RSEs may also be
appropriate for systems that have been operating for two to four years, in order to maximize
early opportunities for improvements and cost savings. Sites with an ongoing Fund-financed
long term response action (LIRA) continue to be a high priority for the program in order to help
ensure smooth transfer to States for operation and maintenance (O&M).
Regardless of annual operating costs or the age of the system, an optimization review
may be valuable at sites where there are concerns about the effectiveness of the remedy or the
efficiency of the P&T system. An RSE may also help address recommendations in Five-Year
Reviews that identify similar concerns.
1.4 Monitoring Implementation Progress
Each site that receives an optimization review is subject to follow-up, typically in the
form of annual conference calls between OSRTI and the Region, for at least two years after the
RSE report is finalized. These follow-up discussions highlight the status of recommended
changes and obstacles to implementation that require additional attention. Continuous oversight
of progress at RSE sites helps maximize the benefits of optimization, identify lessons learned,
and provide technical assistance.
RSEs generate a number of suggestions, ideas, and recommendations which should be
discussed and evaluated. Regions weigh many factors including, but not limited to, technical
feasibility, short-term implementation issues, long-term benefits, public and State acceptance,
contractual requirements, 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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OSWER 9283.1-34
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Exhibit 1. Sites included in this progress report
EPA
Region
1
2
3
4
5
6
7
8
9
10
State
NH
NJ
NJ
NY
PA
PA
NC
FL
FL
NC
MI
IN
IN
MI
—
KS
KS
NE
CO
CA
WA
WA
OR
Site Name
Savage Municipal Water Supply
Higgins Farm
Ellis Property
GCL Tie & Treating
Havertown PCP
Millcreek Dump Site
Cape Fear Wood Preserving
Alaric, Inc.
American Creosote Works, Inc. (Pensacola)
Benfield Industries
Ott/Story/Cordova Chemical Co.
Douglas Road/Uniroyal, Inc., Landfill
Reilly Tar & Chemical Corp. (Indianapolis)
Peerless Plating Co. Inc.
No sites for this reporting period
57th & North Broadway
Ace Services
10th Street Site
Central City, Clear Creek
Modesto Ground Water Contamination
Boomsnub/Airco
Wyckoff Co. /Eagle Harbor
Northwest Pipe & Casing
Fiscal Year
of Review (a)
2001
2003
2006
2006
2003
2009
2004
2009
2006
2007
2001
2004
2004
2005
—
2006
2007
2009
2007
2001
2002
2004
2007
Reporting
Status (b)
updated
updated
updated
updated
Updated
N/A
updated
N/A
updated
new
updated
updated
updated
updated
—
updated
updated
N/A
updated
updated
updated
updated
updated
(a) Date refers to date of review; RSE reports may be finalized months later, following multiple-party review. All
RSE reports may be accessed online via http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm.
(b) Updated sites were included in previous progress reports; progress at new sites is being reported for the first
time. Sites with a status of N/A received a review in 2009 and had not yet begun implementation monitoring at the
time of this report.
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OSWER 9283.1-34
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2.0 Summary of Implementation Progress
2.1 Overview
Each RSE results in an improved understanding of the operating P&T system and
identified a number of opportunities for improvements in efficiency and effectiveness. The RSE
reports specifically highlight recommendations in the following four categories:
• recommendations to improve remedy effectiveness,
• recommendations to reduce operating costs,
• recommendations for technical improvement, and
• recommendations to expedite site closure.
The annual follow-up discussions between OSRTI and the Remedial Project Manager
(RPM) assess progress with the implementation of each recommendation contained in the RSE
reports. Exhibit 2 summarizes progress in each of the four categories of recommendations. The
subsequent sections provide an analysis of implementation progress and highlights of site-
specific progress. The data included in this report represents only the sites that are still subject to
the follow-up process described above (all sites in Exhibit 7). Sites that completed the follow-up
process, as documented in previous progress reports, are no longer included in the calculations.
Exhibit 2. Status of optimization recommendations
Types of
Recommendations
Remedy
Effectiveness
(61 total)
Cost Reduction
(63 total)
Technical
Improvement
(50 total)
Site Closure
(24 total)
Overall Progress
(198 total)
Implementation Status
Implemented
77%
(47)
74.6%
(47)
70%
(35)
41.7%
(10)
70.2%
(139)
In
progress
11 5%
(7)
7.9%
(5)
12%
(6)
41.7%
(10)
14.1%
(28)
Planned
(0)
3.2%
(2)
6%
(3)
4.2%
(1)
3%
(6)
Declined
9 8%
(6)
11.1%
(7)
8%
(4)
—
(0)
8.6%
(17)
Deferred
to
PRP/State
(0)
1.6%
(1)
4%
(2)
4.2%
(1)
2%
(4)
Under
Consideration
1 6%
(1)
1.6%
(1)
(0)
8.3%
(2)
2%
(4)
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 98% of all recommendations made at the
sites covered in this progress report. The proportion of recommendations that were declined or
deferred to other parties has decreased from 15% in the previous reporting period to only 10.6%
during this period. Similarly, the percentage of recommendations that remain under
consideration (the least advanced reporting category) is the smallest ever reported, at just 2%.
Overall, this analysis demonstrates an increasingly strong commitment by RPMs to address
optimization recommendations in a timely manner.
2.2 Implementation of Remedy Effectiveness Recommendations
A thorough review of remedy effectiveness is a principal element of OSRTI's
optimization initiative. Recommendations to improve effectiveness predominantly suggest more
rigorous evaluation of the extraction and subsurface portions of the remedy rather than the
above-ground treatment portion. The most common recommendations in this category generally
relate to plume delineation, additional source area characterization, and sampling for new
contaminants or exposure pathways (e.g., 1,4-dioxane, vapor intrusion).
More than three-quarters (77%) of remedy effectiveness recommendations have been
implemented and another 11.5% are in progress. The implementation of remedy effectiveness
recommendations continues to be a high priority for RPMs; this category has consistently had the
greatest proportion of recommendations implemented since national reporting began.
Highlight: Success with Remedy Effectiveness Recommendations
Vapor Intrusion: Vapor intrusion (VI) is the migration of volatile chemicals from the
subsurface into overlying buildings. Volatile chemicals in buried wastes and/or
contaminated groundwater can emit vapors that may migrate through subsurface solid
and into air spaces of overlying buildings. The RSE team formulated recommendations
to evaluate the potential for vapor intrusion at four of the sites contained in this report.
At the 57th and North Broadway site, the risk of VI was ruled out through the application
of standard EPA screening methods. Additional ground water and/or soil gas samples
were required in order to evaluate potential VI impacts at the American Creosote Works
(Pensacola) site, the GCL Tie & Treating site, and the Northwest Pipe & Casing site. In
each of these instances, the site team determined that there was no site-related impact
through the vapor intrusion exposure pathway.
2.3 Implementation of Cost Reduction Recommendations
RSE recommendations pertaining to cost reduction may cover many aspects of system
operation, including the selection of treatment technologies, operator and laboratory labor, and
project management. A common recommendation for cost reduction typically calls for site
managers to streamline ground water or process monitoring once a system is operating at steady-
state.
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RSEs continue to identify opportunities to reduce onsite labor without sacrificing remedy
effectiveness. Such reductions may be expected following system shakedown or automation,
when a remedy is operating at steady-state. Furthermore, some treatment components become
inefficient or unnecessary as a result of changing site conditions, or due to conservative estimates
during the design phase. Simplifying a treatment system under such conditions has resulted in
cost savings associated with reduced material usage, utilities, and labor.
The implementation rate of cost reduction recommendations has continually improved
from 53.5% in 2005, to 65% in 2007, and now to 74.6% for this reporting period. While EPA
Regions and the States continue to report reduced operating costs and improved efficiencies,
documenting precise cost savings and expenditures as a direct result of RSE implementation
continues to pose a challenge.
Highlight: Success with Cost Reduction Recommendations
Central City/Clear Creek (Idaho Springs. CO): The RSE team made a series of
recommendations related to the production, handling and disposal of solids by the
treatment system. The treatment system was producing a much greater volume of
filtercake waste than was anticipated during remedial design. The RSE
recommendations focused on reducing scaling in the system and increasing the density
of the solids, thereby reducing chemical usage, labor and disposal costs.
The site team thoroughly evaluated the RSE recommendations, as well as data from
previous pilot efforts at the site, and then determined that the best approach would be
to implement a High-Density Sludge (HDS) system. Pilot efforts are underway; if
implemented, the HDS system would likely include an aeration system, modifications to
the pH adjustment system, and additional tanks for increased reaction time.
While this approach is not specifically what was recommended in the RSE report, it is
consistent with the intent and endorsed by the RSE team. Implementation of a full HDS
system should reduce ongoing costs related to sludge disposal, chemical usage, labor,
and filter scaling. Potential cost savings have not been estimated since the site team is
in the pilot stage; an estimate will hopefully be available in a subsequent progress
2.4 Implementation of Technical Improvement Recommendations
Technical improvement recommendations cover a wide range of items to improve overall
site operations. As Exhibit 2 demonstrates, 70% of these recommendations have been fully
implemented. RPMs continue to implement the majority of these recommendations shortly after
the RSE site visit highlights the opportunity for improvement. These recommendations are
generally easy to implement, require little up front funding, and are not typically contingent on
other recommendations.
Examples of technical improvement recommendations include the following:
• Reconfigure components of the treatment train,
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• Clean, repair or replace faulty equipment,
• Rehabilitate fouled extraction or injection wells,
• Revise sequencing during site wide sampling events, and
• Improve maps and reports.
2.5 Implementation of Site Closure Recommendations
RSEs continue to identify opportunities to accelerate progress toward achieving final
cleanup goals and eventual site closure. These recommendations most commonly involve
developing a clear and comprehensive exit strategy and/or evaluating alternate remedial
approaches in situations where the P&T system may no longer be the most effective remedy.
Developing an exit strategy typically involves confirming that clear and appropriate cleanup
goals were established in the Record of Decision, then determining the specific data and criteria
to be used to evaluate if goals are met such that some or all of the system can be shut down. If
the intermediate goals and milestones are not met, RPMs should then consider alternatives to the
current system. This may include alternate technologies to replace P&T, or to supplement it with
more aggressive source removal.
Ten of the 24 recommendations (41.7%) associated with site closure have been
implemented, which is a slight decrease when compared to progress at the sites addressed by the
previous progress report. However, an equal number of the recommendations in this area are in
progress, which is a significant improvement. As demonstrated in previous progress reports, exit
strategy recommendations are often considered after effectiveness and cost reduction
recommendations are implemented. The use of a supplemental or alternative remedial approach
may require funding that was not previously budgeted, revised contracts, and updated decision
documents (e.g., an amended Record of Decision). For these reasons, the data continue to show
a lower percentage of these recommendations implemented, and a larger percentage still under
consideration.
Highlight: Success with Recommendations to Expedite Site Closure
Northwest Pipe 8t Casing (Clackamas. OR): The RSE included recommendations to
improve delineation of the shallow zone of the southern plume area, and then to utilize
the results to design an in situ remedy that would significantly reduce the highest
concentrations of VOCs.
The site team completed the additional characterization work in 2008, which identified
an area of PCE contamination that was much larger and deeper than previously known.
Based on information collected, a removal action was initiated in August 2009 to remove
source material. Approximately 500,000 gallons of contaminated groundwater and
16,000 tons of soil were treated or removed. Soil amendment was added to clean back
fill to help stimulate biodegradation. The site team is currently monitoring to determine
the effect of the removal action, though preliminary results indicate significant
reduction of PCE concentrations and increasing trend in breakdown COCs. Additional
data will determine whether the RSE recommendation for an in situ ground water
remedy is still appropriate.
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2.6 Sites Requiring No Further Follow-Up
As shown in Exhibit 2, RPMs continue to demonstrate a commitment to the
implementation of RSE recommendations. In fact, the optimization process is complete at a
number of sites as a result of the successful implementation or thorough consideration of all RSE
recommendations. OSRTI is no longer conducting annual follow-up discussions at these
particular sites, though assistance is still available to site managers in the event that any
optimization-related issues arise. Exhibit 3 highlights the 5 sites that completed the follow-up
process during the 2008-2009 reporting period. Previous progress reports identified 24
additional sites that no longer require implementation tracking, for a total of 29 sites that have
successfully completed the follow up process.
Exhibit 3. Sites requiring no further follow-up
Rationale
Site Name
Successful implementation and/or thorough consideration
of all RSE recommendations
Ace Services
Ellis Property
Havertown PCP
Higgins Farm
Savage Municipal Water Supply
3.0 Future Plans
OSRTI expects to continue to fund independent, technical experts to conduct additional
RSEs and streamlined RSE-Lites each year. OSRTI will continue to select sites for future
reviews based on annual operating costs, the age of the system, and concerns for remedy
effectiveness and system efficiency. Regions should contact OSRTI to recommend any sites that
may benefit from an optimization review.
OSRTI will continue to utilize the existing process for follow-up discussions in order to
monitor progress with the implementation of RSE recommendations. Follow-up will continue at
all sites, with the exception of those identified in Exhibit 3. RPMs may request technical
assistance to aid in the implementation of system changes.
4.0 References
4.1
Internet Resources
OSRTI, Post-Construction Program Area
• Guidance for post-construction completion activities, with optimization project updates
• http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm
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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.mi1//ltm rse.htm
Federal Remediation Technologies Roundtable
• Case studies, conference materials and more, compiled by an inter-agency workgroup
• http://www.frtr.gov/optimization.htm
4.2 Guidance and Fact Sheets
A Systematic Approach for Evaluation of Capture Zones at Pump and Treat Systems
(EPA 600-R-08-003; January 2008)
A Cost Comparison Framework for Use in Optimizing Ground Water Pump and Treat Systems
(EPA 542-R-07-005; May 2007)
Optimization Strategies for Long-Term Ground Water Remedies (with Particular Emphasis on
Pump and Treat Systems) (EPA 542-R-07-007; May 2007)
Options for Discharging Treated Water from Pump and Treat Systems (TiPA 542-R-07-006;
May 2007)
Effective Contracting Approaches for Operating Pump and Treat Systems (OSWER 9283.1-
21FS / EPA 542-R-05-009; April 2005)
O&M Report Template for Ground Water Remedies (With Emphasis on Pump and Treat
Systems) (OSWER 9283.1-22FS / EPA 542-R-05-010; April 2005)
Cost-Effective Design of Pump and Treat Systems (OSWER 9283.1-20FS / EPA 542-R-05-008;
April 2005)
Action Plan for Ground Water Remedy Optimization (OSWER 9283.1-25; August 25, 2004)
Pilot Project to Optimize Superfund-financed Pump and Treat Systems: Summary Report and
Lessons Learned (OSWER 9283.1-18; November 2002)
Elements for Effective Management of Operating Pump and Treat Systems (OSWER 9355.4-
27FS-A; November 2002)
Implementation of RSE Recommendations: Technical Assistance Resources Available to RPMs
(January 2002)
9 December 2010
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4.3 General Project Documentation
Ground Water Remedy Optimization Progress Report: 2006-2007 (OSWER 9283.1-31; July
2008)
2005 Annual Progress Report for Ground Water Remedy Optimization (OSWER 9283.1-28;
December 2006)
2004 Annual Progress Report for Ground Water Remedy Optimization (OSWER 9283.1 -27;
August 2005)
Groundwater Pump and Treat Systems: Summary of Selected Cost and Performance
Information at Superfund-fmanced Sites (EPA 542-R-01-021a; December 2001)
Super fundReform Strategy, Implementation Memorandum: Optimization of Fund-lead Ground
Water Pump and Treat (P&T) Systems (OSWER 9283.1-13; October 31, 2000)
10 December 2010
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