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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