EPA Investigates Cleanup Efficiencies
at Contaminated Sites
Progress Report No. 1
September 2011
EPA's Office of Solid Waste and Emergency Response, in partnership with the Office of Enforcement and Compliance
Assurance, launched in 2010, a three-year Integrated Cleanup Initiative (ICI) to identify and implement improvements to
the Agency's site cleanup programs. In November 2010, nine project management pilots in nine different states were
identified under this initiative to evaluate alternative approaches to achieving site cleanups more efficiently. These pilot
projects demonstrate region-specific best practices and new approaches to project management. For further
information on the ICI, please visit http://www.epa.gov/oswer/integratedcleanup.htm.
Rhode Island
SMITHFIELD -- Throughout the 1970's, the Davis Liquid
Waste site in EPA Region 1 accepted numerous types of
liquid and chemical wastes that were transported in
drums and bulk tank trucks and dumped directly into
unlined lagoons and seepage pits. This site was added
to the National Priorities List (NPL) in September 1983.
In 1987, EPA issued a comprehensive Record of Decision
(ROD) for the site that, among other actions, called for a
source control remedy for contaminated soils and
groundwater remediation. Litigation culminated in a
series of settlements for performance of the source
control remedy and also resulted in the creation of a
site-specific special account containing approximately
$12 million. The groundwater remedy could not be
implemented as initially envisioned because treated
groundwater from the pump and treat system could not
be injected to create a flushing/recirculation cell to
remove contaminants adsorbed to saturated soil. EPA
evaluated a number of other treatment technologies,
and in September 2010, amended the ROD to change
the original groundwater pump-and-treat remedy to in-
situ chemical oxidation. The purpose of this pilot is to
demonstrate if the offer of the funds available from a
site-specific special account to the potentially
responsible parties (PRPs) would provide EPA with
sufficient leverage to expedite remedial design and
remedial action (RD/RA) settlement negotiations for
conduct of the groundwater remedy by the PRPs. EPA
issued special notice for the performance of the RD/RA
for the groundwater in January 2011 to five parties who
had not performed any work or contributed to any past
settlements and who have limited equitable share
allocations based on a court decision. EPA held several
meetings and conference calls with the PRP group
during the negotiation period. Due largely to the court-
assigned equitable shares, the five parties struggled for
months to reach an internal agreement on allocation.
During negotiations, the group splintered, and EPA held
meetings and calls with the subgroups separately. EPA
continued to use the special account funds as an
incentive, combined with the threat of losing special
account funds and possible treble damages, and the
PRP group was brought back together. EPA's
enforcement strategy encouraged the PRPs to sign the
consent decree taking full responsibility for all work and
future costs. EPA received signature pages from all
noticed parties by the end of July 2011. On August 10,
2011, EPA referred the settlement to the Department of
Justice (DOJ) for lodging. This referral represents
completion of the pilot process. A final report will
examine efficiencies gained and document lessons
learned, as well as the potential for broader application
of this approach at other sites. For further information
about this site, please visit
www.epa.gov/ne/superfund/sites/davisliquid.
New York
ELLENVILLE -- The Ellenville Scrap Iron and Metal site
in EPA Region 2 is a 24-acre, former scrap metal
reclamation facility. About ten acres of the site were
used for a variety of scrap metal operations and battery
reclamation. The site includes a five-acre landfill
composed of construction and demolition debris,
including a variety of finely shredded wastes, scrap
brick, concrete, wood and other metal debris. An
adjacent residential property was formerly part of the
facility. Associated soil contamination resulted in the
listing of this site on the NPL in October 2002. The
activities identified within the scope of this pilot include
excavation of contaminated soils and consolidation with
existing waste under a newly constructed landfill cap.
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This pilot is designed to accelerate the RD/RA through
an "integrated project delivery" approach to maximize
efficiency of procurement, and management and
delivery of design and construction services. Several
months prior to issuing a ROD, EPA and the U.S. Army
Corps of Engineers (USAGE) began planning pilot
activities. In September 2010, EPA executed an
interagency agreement with the USAGE to provide RD
and construction services through the USAGE'S pre-
placed contracts. Securing the services of the RA
contractor early on in the process provided beneficial
pre-construction technical support concurrent with the
development of the RD. Waste consolidation, subgrade
preparation, landfill backfill grading, and installation of
the landfill liner have been completed, as well as
residential property soil removal, topsoil placement and
seeding. Some damage to the storm water drainage
channels and retention basin was experienced as a
result of Hurricane Irene. This delayed slightly the
completion of construction activities and the date of the
final inspection to September 28 (given favorable
weather conditions). EPA expects to issue a
"Preliminary Close Out Report" before September 30,
2011, which will document that all construction
activities have been completed at the site. For further
information about this site, please visit
http://www.epa.gov/region02/superfund/npl/ellenville.
EPA issued a ROD amendment which called for, among
other actions, acquisition and demolition of the GSC
building and excavation of contaminated soils at both
properties.
Contouring for landfill cover at Ellenville Scrap Iron and Metal,
EUenvitte, NY
New Jersey
BUENA BOROUGH -- The South Jersey Clothing
Company (SJCC) and Garden State Cleaners (GSC) sites
in EPA Region 2 are two separate properties that have
soil contaminated with volatile organic chemicals
resulting in a co-mingled groundwater contamination
plume. These sites were added to the NPL in October
and March of 1989, respectively. In September 2010,
Demolition of Garden State Cleaners building, Buena Borough, NJ
This pilot is designed to accelerate the RD/RA for a
project with a clearly defined scope through the use of
in-house EPA staff. The RDs for the building demolition
and the two soil excavations were completed in June
2011 by EPA's remedial program staff with input from
the USAGE who completed the detailed drawings.
Acquisition of the GSC property occurred on June 30,
2011. EPA's removal program staff directed the building
demolition, soil excavations and backfilling at both sites
(completed mid-August) and transportation and
disposal of demolition debris and contaminated soils
(completed early September). Remedial and removal
program staff will collaborate on the preparation of the
three RA reports that are scheduled to be approved by
late September 2011. For further information about
these sites, please visit
http://www.epa.gov/region02/superfund/npl/sicc/
index.html (South Jersey Clothing Company), and
http://www.epa.gov/region02/superfund/npl/gsc
(Garden State Cleaners).
Florida
POMPANO BEACH -- Between 1977 and 2001, dry-
cleaning operations conducted at the half-acre Flash
Cleaners site resulted in the contamination of soil and
groundwater with dry-cleaning solvents. In September
2008, this site was added to the NPL. The September
2010 ROD called for, among other actions, excavation
and off-site disposal of contaminated soils, installation
of a soil vapor extraction system (SVE) for removing
contaminants from beneath the existing building, and
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injection with emulsified oil substrate to enhance the
natural degradation of contaminants in the
groundwater.
surface water and sediment. In March 2011, the site
was proposed to the NPL
Collection of vapor samples at Flash Cleaners, Pompano Beach,
FL
Under this pilot, EPA is testing several innovative
approaches to organizing site work to accelerate the RD
and RA by conducting elements of these processes
concurrently. For example, some RD work began prior
to completion of the remedial investigation/feasibility
study (RI/FS) and ROD to accelerate the start of RA. In
addition, the contractor prepared the soil design first,
separately from the groundwater design, to allow the
soil RA to begin earlier than it would have if the Region
had waited until both were completed. While the soil is
excavated and the SVE system is constructed, the
groundwater RD will be completed. All design plans
have been prepared, soil excavation is complete, the
soil vapor extraction system is in place, and the
groundwater injection wells have been installed. The
final on-site inspection was held on August 23. EPA
expects to issue a "Preliminary Close Out Report"
before September 30, 2011 that will document that all
construction activities have been completed at the site.
For further information about this site, please visit
http://www.epa.gov/region4/waste/npl/nplfls/flashclfls
.htm.
South Carolina
GREENVILLE -- A textile and bleaching facility was
constructed in 1903 at the 259-acre U. S. Finishing/
Cone Mills property in EPA Region 4. Past operations
have contaminated at least 14 acres at the site and
resulted in the presence of chromium in groundwater,
Existing buildings at the U. S. Finishing property, Greenville, SC
Under this pilot, EPA established a special integrated
project team in April (comprised of EPA, state,
contractor and community members) in order to
expedite the Cone Mills site study, the development of
remedial alternatives and the selection of a site remedy
(expected in September 2013). The project will utilize
an adaptive project management framework integrating
federal, state and contractor resources with the
requisite skills and decision-making authority to act
quickly as needs arise. The pilot project will engage the
community and key stakeholders early and throughout
the process in order to provide transparency and an
active role for them in site cleanup and reuse decisions.
A removal action is planned to begin in the next few
months which will involve primarily the demolition and
disposal of the main mill building. In August, 2011, EPA
added additional fencing to secure the site. The Rl
scoping is currently underway and a portion of the field
work for the Rl is expected to begin in November 2011.
Remaining Rl activities will be conducted upon
completion of the removal action. For further
information about this site, please visit
http://www.epa.gov/superfund/sites/npl/narl835.htm.
Michigan
ST. LOUIS -- The Gratiot County Golf Course site
consists of approximately five acres in St. Louis,
Michigan in EPA Region 5. From 1956 until 1970, the
Michigan Chemical Corporation (later purchased by the
Velsicol Chemical Corporation) burned and disposed of
industrial waste on the site, including the pesticide,
DDT. Approximately 2,000 to 3,000 gallons of hazardous
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waste were disposed of on the property. This site was
first proposed to the NPL in 1982. At that time, Velsicol
removed 68,000 cubic yards of contaminated soil. As a
result, the proposed NPL listing was cancelled.
However, in 2006, additional soil and groundwater
contamination was found. The State of Michigan
completed some additional field investigations in
January 2009 and as a result, the Gratiot County Golf
Course site was added to the NPL in March 2010. The
objective of this pilot is to expedite the remaining site
study and alternatives development processes by using
existing data, collecting only critically important new
data, and increasing collaboration with EPA
headquarters earlier in the Superfund site remediation
process. In this way, EPA expects to streamline
significantly discussions between headquarters and the
region about remedial site study and cleanup options.
Risk assessment activities began in September 2011 and
EPA's development and evaluation of cleanup
alternatives will begin in January 2012. Completion of
this pilot is planned for spring 2012. For further
information about this site, please visit
http://www.epa.gov/region5/cleanup/gratiotcountvgolf
/index.htm.
New Mexico
ROSWELL -- Dry-cleaning operations between 1956
and 1963 resulted in the contamination of soil and
groundwater at the McGaffey and Main Groundwater
Plume site in EPA Region 6. A perchloroethylene (PCE)
groundwater contamination plume now extends about
1.5 miles and is threatening Roswell drinking water
supplies. Unsafe levels of PCE in air have also been
found inside buildings as a result of this contaminant's
presence in soil and groundwater beneath the buildings.
In October 2002, this site was added to the NPL. In
September 2008, EPA issued a ROD that called for
removing contaminated soil, addressing contaminated
air within buildings, and addressing the contamination
in groundwater through removal and treatment. The
goal of this pilot is to demonstrate how EPA might
optimize the process and plans for design and
construction of the indoor air vapor mitigation system
through involvement of "third-party" technical experts.
It is expected that such optimization may improve
remedy effectiveness, reduce remedy life-cycle cost,
and accelerate remedy implementation. To date, the
optimization team has completed a technical review of
the intermediate and 95% RD documents for
construction of a vapor intrusion mitigation system
involving nine building locations. Construction of the
system is planned to begin in October 2011. Once
completed, the system will permit continued use of
these buildings while the remaining site remediation
work continues. For further information on this site,
please visit http://www.epa.gov/region6/6sf/pdffiles/
0605386.pdf.
The McGaffey and Main groundwater plume extends 1.5 miles in
Roswell, NM
Texas
TERRELL -- The Van der Horst USA Corporation site is a
former chrome- and iron-plating facility in EPA Region 6,
which operated from the 1950's until December 2006.
This 3.5-acre site, which was added to the NPL in March
2010, includes the former plating facility, wastewater
treatment plant and associated undeveloped land. A
2009 removal action addressed a 46,000 square foot
building situated on the site. The RI/FS will focus on
groundwater and residual soil contamination, since all
aboveground-contaminated media have been
addressed. This pilot is designed to expedite RI/FS
activities through early stakeholder collaboration aimed
at fast-tracking field work and decision making.
Innovative adaptive management techniques will be
used during the Rl field effort to minimize the number
of sampling events. The RPM and risk assessor will be
on-site during the Rl sampling activities to make real-
time decisions in the field. In addition, areas identified
that may require remediation will be evaluated under
EPA's removal authority to accelerate cleanup that may
be accomplished under that authority. In April 2011,
eight monitoring wells were installed and numerous soil
borings were advanced to characterize the nature and
extent of contamination. A second field mobilization
was conducted in mid-September to obtain additional
soil samples and soil gas data from the vadose zone.
Access agreements are being prepared to allow for
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installation of additional monitoring wells planned for
mid- to late fall. Information obtained from these field
activities will be used to fill data gaps and refine the
conceptual site model. Completion of this pilot is
expected by September 2012. For further information
about this site, please visit
http://www.epa.gov/superfund/sites/ npl/narl810.htm
California
SACRAMENTO COUNTY -- The 3,452-acre McClellan Air
Force Base (AFB) site in EPA Region 9 was established in
1936 and operated as an Air Force Logistics Command
Base with a primary mission of management,
maintenance and repair of aircraft, electronics and
communication equipment. The Air Force identified 326
waste areas of known and suspected contamination as
a result of past aircraft maintenance and repair
operations. In July 1987, the McClellan Air Force Base
was added to the NPL Under the Department of
Defense (DOD) Base Realignment and Closure program,
McClellan AFB closed as an active military base in July
2001. Under a transfer with privatized cleanup
agreement, McClellan Business Park, with oversight
from EPA, will be responsible for addressing
contamination in the first 15 feet of soil below the
surface, and can do so concurrently with ongoing
redevelopment efforts. The cost of this work will be
paid for by the Air Force. The Air Force will continue
cleaning up the groundwater and deeper soil. So far,
two rounds of early transfers with privatized cleanup
have been completed. Cleanup of the first transferred
property was completed two years after the ROD was
signed. McClellan Park is a national model for
successful base redevelopment with a number of green
technology companies on site (http://www.epa.gov/
region9/annualreport/). Based on this experience, the
current transfer has been proposed for this pilot. The
goal of this pilot is to create a model process for
accelerating the transfer of ownership and reuse of
federal facilities properties wherever similar conditions
permit.
elimination of hurdles caused by federal facilities
enforcement and DOD policies; (3) integration of
development and cleanup to accelerate productive
reuse; and, (4) facilitation of property transfers to
subsequent owners, reflecting real value in
revitalization. Pilot accomplishments to date include: (1)
Agreement reached on the property to be transferred
(521 acres, 131 remediation sites, and an estimated
24,470 cubic yards of contaminated soil to be
remediated); (2) Final Small Volume Site RI/FS
submitted in May 2011 by the Air Force (forms the
basis for this current transfer); (3) Federal Facility
Agreement Amendment signed by the Air Force, EPA
and California on August 23, 2011; (4) Draft Finding of
Suitability for Early Transfer submitted by the Air Force
on Sept 5, 2011 for regulators' review; and (5) EPA's
Draft Agreement on Consent approved by DOJ and
circulated to state regulators and McClellan Business
Park together with the Statement of Work (September
23, 2011). To expedite review and concurrence, the
majority of these documents were informally reviewed
by the privatization partners prior to formal submittal.
California Governor Brown and Sacramento County
Board of Supervisors are expected to sign the final
transfer documents by April 2012. For further
information about this site, please visit
www.epa.gov/region9/McClellanAFB.
Aerial view of McClellan Air Force Base, Sacramento County, CA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
5
OSWER 9200.2-99
September 2011
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