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OSWER 9283.1-38
* July, 2012
Groundwater Remedy Optimization
Progress Report: 2010 - 2011
Office of Superfund Remediation and Technology Innovation
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
1 9 2012
OFFICE OF
SOLID WASTE AND
EMERGENCY RESPONSE
OSWER 9283.1-38
MEMORANDUM
SUBJECT: Groundwater Remedy Optimization Progress Report: 2010 - 2011
FROM: James E. Woolford, Director
Office of Superfund Remedj'^idn'ancjt'Technology Innovation
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 "Groundwater Remedy Optimization Progress Report: 2010 -
2011" (OSWER 9283.1-38) provides a summary and analysis of progress toward implementation of
site-specific optimization recommendations.
Regional Superfund Division Directors should 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 2010 and 2011, and 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.
This 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 Edwards at (703) 603-8762.
Attachments
cc: Mathy Stanislaus, OSWER
Lisa Feldt, OSWER
Barry Breen, OSWER
Suzanne Rudzinksi, ORCR
Larry Stanton, OEM
Carolyn Hoskinson, OUST
David Lloyd, OBLR
Reggie Cheatham, FFRRO
Nigel Simon, OPM
Elliott Gilberg, OSRE
Internet Address (URL) http://www.epa.gov
Recycled/Recyclable Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
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Dave Kling, FFEO
Regional Superfund Branch Chiefs, Regions 1-10
Kristin Giacalone, Superfund Lead Region Coordinator, Region 2
Lisa Price, Superfund Lead Region Coordinator, Region 6
NARPM Co-Chairs
Phyllis Anderson, OSRTI
Jeff Heimermarm, OSRTI
David E. Cooper, OSRTI
Jennifer Edwards, OSRTI
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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
the site-specific recommendations resulting from independent optimization reviews at Superfund 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 2010 and 2011 at the 24 sites that have been subject to tracking.
The report contains updated information for 14 sites where implementation has continued since the last
summary report, as well as 10 sites subject to a more recent review which are 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 planned and
operating remediation systems to promote continuous improvement, and to enhance overall remedy
protectiveness and cost effectiveness. In the Superfund program, many optimization evaluations utilize
the Remediation System Evaluation (RSE) process, a tool developed by the U.S. Army Corps of
Engineers that EPA has further refined through application at Superfund sites.
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 ("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 actions, the Action Plan envisioned the development of routine
progress reports concerning the implementation of recommended system changes. The Action Plan and
these progress reports currently only apply to a subset of the sites that have received optimization
reviews and technical support.
Since the creation of the Action Plan, the Superfund program has consistently developed additional tools
and approaches that apply optimization concepts to sites earlier in the investigation and cleanup process.
In 2010, OSRTI established a new national optimization workgroup and initiated the development of the
National Strategy to Expand Superfund Optimization Practices from Site Assessment to Site Completion.
The purpose of the Strategy is to expand and formalize optimization practices from site assessment to
site completion as an operating business model for the Superfund program.
The Strategy encourages overarching process changes in program management and implementation, as
well as site-level project management. These changes are intended to instill routine and frequent
assessment of site cleanup progress, technical performance and costs; and refine business practices
including acquisition strategies and contracts management. Finally, the Strategy emphasizes
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incorporating optimization principles throughout the cleanup process from site assessment through site
completion.
While the Strategy is still under development, many of the principles and actions envisioned by the
document are already underway. Optimization reviews, followed by tracking and reporting on
recommendations, will all continue and expand as part of Strategy implementation. OSRTI anticipates
issuing the final Strategy in FY2012.
1.3 Sites Subject to Optimization Reviews
Sites selected to receive an optimization review may have concerns about annual operating costs, the age
of the system, and concerns for remedy effectiveness or system efficiency. Groundwater remedies with
the highest annual operating costs may offer the substantial opportunities for cost savings and increased
efficiency. Optimization reviews may also be appropriate during the investigation stage, during design,
and for remedial 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 (LTRA) continue to be a high priority for the program to promote smooth transfer to
States for site 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 remediation
system. An optimization review may also help address recommendations in Five-Year Reviews that
identify similar concerns. Often, requests for reviews are received directly from remedial project
managers (RPM), regional management or others in the regions who may recognize the potential benefit
of an optimization review at their site.
July 2012 OSWER9283.1-38
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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
NY
NJ
VI
PA
NC
FL
FL
NC
MI
IN
IN
MI
MI
MN
WI
KS
NE
CO
CA
CA
WA
WA
OR
WA
Site Name
No sites for this reporting period
GCL Tie & Treating
Vineland
TuTu Wellfield
Mill Creek 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.
Wash King Laundry
Baytown Township Ground Water Plume
Moss- American
No sites for this reporting period
57th & North Broadway
10th Street Site
Central City, Clear Creek
Modesto Ground Water Contamination
Pemaco Maywood
Boomsnub/Airco
Wyckoff Co. /Eagle Harbor
Northwest Pipe & Casing
Colbert Landfill
Fiscal Year
of Review (a)
2006
2010
2011
2009
2004
2009
2006
2007
2001
2004
2004
2005
2010
2011
2011
2006
2009
2007
2001
2011
2002
2004
2007
2010
Reporting
Status (b)
updated
new
new
new
updated
new
updated
updated
updated
updated
updated
updated
new
new
new
updated
new
updated
updated
new
updated
updated
updated
new
(a) Date refers to date of review; optimization reports may be finalized months later, following multiple-party review. All
final reports may be accessed at http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm.
(b) Updated sites were included in previous progress reports; progress at new sites is reported for the first time.
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 optimization
recommendations are finalized. These follow-up discussions highlight the status of recommended
changes and obstacles to implementation that require additional attention. Continuing oversight of
implementation progress helps maximize the benefits of optimization, identify lessons learned, and
provide technical assistance. Following the initial two years of conference calls, follow up continues in a
less formal way until all recommendations have been appropriately considered by the site team.
Optimization reviews 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, and contractual
requirements when determining whether to implement optimization recommendations. Disagreements
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OSWER9283.1-38
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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 optimization recommendations, technical
assistance is available from many sources, including Regional technical support staff, OSRTI staff,
including the Environmental Response Team (ERT), the optimization review team, EPA's Office of
Research and Development (ORD), the EPA laboratories through the Technical Support Project, and the
U.S. Army Corps of Engineers.
2.0 Summary of Implementation Progress
2.1 Overview
Each optimization review results in an improved understanding of the operating remediation system and
identifies a number of opportunities for improvements in efficiency and effectiveness. The optimization
reports have traditionally highlighted recommendations in the following four categories:
recommendations to improve remedy effectiveness
recommendations to reduce operating costs
recommendations for technical improvement
recommendations to expedite site closure
Beginning in 2010, OSRTI began to consider opportunities for green remediation and environmental
footprint reduction as a standard component of the optimization process. Recommendations in this new
fifth category have been developed for a subset of sites in this report.
The annual follow-up discussions between OSRTI and the RPM assess progress with the
implementation of each recommendation contained in an optimization report. Exhibit 2 summarizes
progress in each of the five 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 1). Sites that completed the follow-up process, as documented in previous progress reports, are
no longer included in the calculations.
Analysis during this latest reporting period shows that RPMs have made positive efforts to address 88%
of all recommendations. More specifically, 69% of all recommendations are either implemented or in
progress. While this is down from the previous reporting period (84%), it is largely a reflection of the
influx of new sites that are in the earliest stages of implementation. The previous report had only one
new site in the first year of implementation, while this reporting period includes 10 new sites (nearly
half of the sites covered by this report).
July 2012 OSWER9283.1-38
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Exhibit 2. Status of optimization recommendations
Types of
Recommendations
Remedy
Effectiveness
(84 total)
Cost Reduction
(90 total)
Technical
Improvement
(59 total)
Site Closure
(28 total)
Green
Remediation
(9 total)
Overall Progress
(270 total)
Implementation Status
Implemented
57%
(48)
54%
(49)
66%
(39)
25%
(7)
0%
(0)
53%
(143)
In
progress
15%
(13)
11%
(10)
8%
(5)
54%
(15)
0%
(0)
16%
(43)
Planned
7%
(6)
4%
(4)
3%
(2)
0%
(0)
22%
(2)
5%
(14)
Declined
7%
(6)
14%
(13)
12%
(7)
7%
(2)
44%
(4)
12%
(32)
Deferred
to
PRP/State
1%
(1)
3%
(3)
0%
(0)
4%
(1)
0%
(0)
2%
(5)
Under
Consideration
12%
(10)
12%
(11)
10%
(6)
11%
(3)
33%
(3)
12%
(33)
Note: Numbers in parentheses represent actual number of recommendations, used to calculate rounded percentages.
2.2 Implementation of Remedy Effectiveness Recommendations
A thorough review of remedy effectiveness is a fundamental element of OSRTFs optimization initiative.
More than half (57%) of remedy effectiveness recommendations have been implemented, and another
15% are in progress. 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.
As has historically been the case, the most common recommendations in this category generally relate to
plume delineation, additional characterization of source areas, and supplementing the existing extraction
scheme with additional groundwater or soil vapor extraction points. In more recent optimization
reviews, there are an increasing number of recommendations related to institutional controls, vapor
intrusion evaluations, and sampling for new contaminants (e.g., 1,4-dioxane).
Additional details on site-specific remedy effectiveness recommendations are available in the appendix
to this report.
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OSWER9283.1-38
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HIGHLIGHT: SUCCESS WITH REMEDY EFFECTIVENESS RECOMMENDATIONS
MILL CREEK DUMP SITE (ERIE COUNTY, PA): It was determined at the time of
the RSE in 2009 that the plume was not vertically delineated, and there were an
insufficient number of wells off-property to horizontally delineate the
contamination or monitor concentration trends. A recommendation was made for
additional characterization by using direct-push drilling to collect grab samples in
order to further delineate the plume.
In August 2010, direct push sampling was conducted at 18 locations, with 35
samples collected. Results from this sampling indicate that most offsite locations
sampled are not contaminated. Two locations at the northern edge of the site did
have 1,1-Dichloroethene (DCE) and vinyl chloride contamination above the
Record of Decision (ROD) screening levels. A MODFLOW model has been
developed using findings from the above field investigations to assess plume
capture and results are still being evaluated. In particular, it appears that some
contamination is located offsite in an area that is cross-gradient to groundwater
flow. Additional capture zone analysis will allow the site team to determine
whether an offsite source exists, or if this contamination is caught in a stagnation
zone caused by remedy pumping.
2.3 Implementation of Cost Reduction Recommendations
Optimization recommendations pertaining to cost reduction may cover many aspects of system
operation, including the use of specific treatment technologies, operator and laboratory labor, and
project management. A common recommendation for cost reduction typically calls for site managers to
streamline groundwater or process monitoring once a system is operating at steady-state.
Optimization reviews continue to identify many opportunities to reduce onsite labor while positively
affecting remedy performance. 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 materials and energy usage, as well as labor.
During this reporting period, an increasingly common recommendation with respect to cost reduction
was to track routine and non-routine costs separately in order to more easily identify the trend in routine
operating costs. Highlighting non-routine maintenance costs also allows the site team to identify areas of
the treatment system that may need particular attention. Some other examples of common
recommendations are:
Reduce monitoring program and evaluate the sampling frequency
Revisit and reduce reporting requirements
Reduce project management and technical support
More than half (54%) of cost reduction recommendations have been implemented, with an additional
15% currently ongoing or planned. While EPA Regions and the states continue to report reduced
operating costs and improved efficiencies, documenting precise cost savings and expenditures as a direct
July 2012
OSWER9283.1-38
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result of optimization reviews continues to pose a challenge. This will be an area of particular focus for
OSRTI during the next reporting period.
Additional details on site-specific cost reduction recommendations are available in the appendix to this
report.
HIGHLIGHT: SUCCESS WITH COST REDUCTION RECOMMENDATIONS
10TH STREET SITE (COLUMBUS, NEV As part of the 2009 RSE, the optimization
review team made a series of recommendations related to sampling and reporting
for the groundwater and air sparging/soil vapor extraction systems. The
recommendations focused on reducing sampling frequency in stable areas of the
plume, and streamlining reporting across the two treatment systems. The review
team also made recommendations to reduce project management and engineering
support costs.
The site team thoroughly evaluated the recommendations related to sampling and
reporting, then included reductions in a contract modification shortly after the
RSE. Reductions included cutting back to semi-annual sampling and sampling at
fewer wells. In 2010, estimated costs for monitoring and reporting were nearly
$250,000. As a result of the site team's diligent efforts to implement the
recommendations, actual monitoring and reporting costs at the site in 2011 and
2012 were $124,000 - a 50% cost reduction.
Project management and engineering support costs for the site were approximately
$275,000 per year at the time of the review. The RSE team's recommendations on
project management and engineering costs have been implemented, which has led
to significant cost reduction of approximately $190,000. Project management and
reporting costs are expected to stay steady at the reduced level going forward.
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, 66% of these recommendations have been fully implemented.
These recommendations are generally easy to implement, require minimal funding, and are not typically
contingent on other recommendations. Therefore, RPMs implement the majority of these
recommendations shortly after the optimization site visit highlights the potential for improvement.
Examples of technical improvement recommendations include the following:
Reconfigure components of the treatment train,
Inspect and then clean, repair or replace faulty equipment,
Rehabilitate fouled extraction or injection wells, and
Consider more efficient pumps and blowers.
The majority of the new sites in this reporting cycle had technical improvement recommendations
related to data management and reporting. In some instances, annual reports were not being generated in
July 2012
OSWER9283.1-38
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a timely manner, comprehensive site maps were missing, or key data elements (e.g., detection levels)
were missing.
Additional details on site-specific recommendations for technical improvement are available in the
appendix to this report.
2.5 Implementation of Site Closure Recommendations
Optimization reviews 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 current remedy may no longer be the most effective approach.
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 whether 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 may then consider alternatives to the current system. Such
alternatives have often included in situ chemical oxidation or bioremediation, or excavation of additional
source material. Additional recommendations related to site closure include the need to clearly
document cleanup levels for select contaminants, and to confirm expectations with the state regarding
transfer of responsibility for operation and maintenance.
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).
This is the first reporting cycle during which the rate of implementation for site closure
recommendations exceeds the rate of implementation for remedy effectiveness, cost reduction and
technical improvement recommendations (see Exhibit 2). Nearly 80% of site closure recommendations
are either implemented or in progress. While these recommendations require a considerable level of
effort, RPMs are demonstrating increasing willingness to expend that effort in order to expedite site
closure.
Additional details on site-specific recommendations for site closure are available in the appendix to this
report.
July 2012 OSWER9283.1-38
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HIGHLIGHT: SUCCESS WITH RECOMMENDATIONS TO EXPEDITE SITE CLOSURE
ADDITIONAL SOURCE AREA REMEDIATION: Optimization reviews continue to
identify opportunities to more aggressively pursue source remediation in order to
increase the efficiency and potentially reduce the duration of groundwater
treatment systems. At the Benfield Industries Site (Waynesville, NC), the
optimization review team concluded that MNA may be the most appropriate and
least expensive approach to long term groundwater remediation during the 2007
RSE. However, additional remediation at the remaining hot-spot source of
contamination will likely be required in order to make MNA most effective.
The site team completed a draft MNA report in July 2011 and reviewers found that
lines of evidence did not support an MNA remedy without addressing the
remaining hot-spot contamination. The site team is currently working on a
comprehensive plan to identify and address the remaining hot-spots, to be
potentially followed by an updated decision document for MNA.
At the 10th Street Site (Columbus, NE), the optimization review team suggested
that additional source material likely exists under the building of the onsite
operating drycleaner. The contamination will serve as a continuing source to
groundwater, but is difficult to characterize and address due to the location. In
response to the recommendations, the site team collected soil and soil vapor
samples under a total of three drycleaners in order to delineate the contamination,
and produced a Focused Feasibility Study in 2011. The site team is currently
evaluating whether building demolition is appropriate; an updated decision
document is anticipated in 2012.
2.6 Implementation of Green Remediation Recommendations
As an element of the 2010 Superfund Green Remediation Strategy, OSRTI began to consider
opportunities for green remediation and environmental footprint reduction as part of the optimization
process. Green remediation was not found to be applicable at all sites reviewed since 2010, however five
sites do have recommendations in this category.
The recommendations for green remediation primarily relate to utilizing local labor for site management
and sampling (to avoid air emissions associated with travel), and to consider opportunities for renewable
energy (solar, wind or renewable energy credits). Furthermore, several recommendations for remedy
effectiveness, cost reduction and/or technical improvement will likely offer benefits for a reduced
environmental footprint. For example, streamlining the treatment train and downsizing pumps/blowers
should directly result in reduced energy usage.
None of the green remediation recommendations have been fully implemented to date, while a number
of these items were declined after considering cost effectiveness of the changes. This will be an area of
particular focus for OSRTI during the next reporting period.
Additional details on site-specific green remediation recommendations are available in the appendix to
this report.
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2.7 Sites Requiring No Further Follow-Up
As shown in Exhibit 2, RPMs continue to demonstrate a commitment to the implementation of
optimization recommendations. In fact, the optimization process is now complete at a number of sites as
a result of the successful implementation or thorough consideration of all optimization
recommendations. OSRTI is no longer conducting annual follow-up discussions at the following sites,
though assistance is still available to site managers in the event that any optimization-related issues
arise:
Cape Fear Wood Preserving
Douglas Road/Uniroyal, Inc. Landfill
Peerless Plating
Previous progress reports identified 29 additional sites that no longer require implementation tracking,
for a total of 32 sites that have successfully completed the follow up process since it began as a result of
the Action Plan in 2004.
2.8 Additional Optimization-Related Site Support
In addition to formal optimization reviews, OSRTI provides technical support in various other forms in
order to apply optimization principles more broadly. The examples below demonstrate the wide
applicability and flexibility of OSRTFs optimization support, including long term monitoring
optimization, modeling and data visualization. The nature of the support provided to these sites varied
according to the site-specific need, and therefore did not always result in traditional optimization
recommendations to implement.
Newmark Ground Water Contamination Superfund Site
Following delivery of Triad training to California Department of Toxic Substance Control (DTSC) and
EPA Region 9 personnel in late 2009, technical support for the Newmark Groundwater site was initiated
in 2010. Initial support was focused on the development of a comprehensive life cycle conceptual site
model (CSM) and use of 3-D visualization software to place large, complex, multi-faceted data sets into
a spatially correct format. Given the size of the Newmark source operable unit (OU), estimated at 23
square miles, the CSM provided a platform for evaluation of performance of the existing interim
remedy, a large scale pump and treat system, and optimization of activities necessary to complete a
source OU remedial investigation (RI) and complete a final ROD.
The sheer volume of existing information, the variety of data owners, and the multitude of stakeholders
(EPA, DTSC, City of San Bernardino, and 16 water purveyors) required significant effort to obtain,
review, integrate, and analyze data into the updated CSM and visualization materials. The results of the
preliminary CSM were presented to Region 9, DTSC, and other stakeholders in late 2011. Those
stakeholder outreach efforts allowed use of the 3D visualization to provide independent evaluation and
subsequent updates of the MODFLOW model used to manage water resources in the entire basin. The
project team also conducted a review of available environmental databases (using Environmental Data
Resources) and completed a site sorting strategy to provide Region 9 with a preliminary list of potential
areas or sites of interest within the source OU where available chemical and geologic/hydrogeologic
information would further strengthen the CSM and MODFLOW model.
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The project team is currently providing additional support in the form of visualization of secondary
contaminants to optimize RI planning. The RI is expected in fiscal year 2013 and the CSM and
visualization components will be used to optimize the locations of intrusive work and leverage all
existing data to support completion of the RI. The main focus of the RI is expected to be source area
characterization and optimization of the existing treatment system.
Applied Materials Superfimd Site
A review of the long-term monitoring strategy was conducted by EPA OSRTI with EPA Region 9 at the
Applied Materials Building 1 Superfund site (the Site) located in Santa Clara, California in October
2011. The purpose of the review was to determine if there exists sufficient data to close the site, and, if
closure is not an option, to recommend an efficient sampling strategy for long-term oversight. The Site
is the location of a former semi-conductor wafer manufacturing facility that began operations in 1974.
Primary contaminants of concern include chlorinated solvents in soil and groundwater. The Site has
undergone extensive cleanup activities dating back to 1983 resulting in contaminant reductions to below
cleanup levels in many areas of the Site. Currently, monitoring is conducted to evaluate low level
groundwater contamination.
The optimization review found that extensive remediation efforts over the past 30 years have resulted in
groundwater concentrations very close to cleanup goals at the Site; however, some localized sampling
results occasionally exceed the cleanup goals and prevents a definitive statistical attainment of remedial
action objectives. The optimization report further concluded that:
The hydrogeology is well understood and consistent with site data;
The primary contaminant source area appears exhausted and is not actively exporting mass to the
tail of the plume;
COC attenuation processes have been active, and concentrations are historically decreasing
despite the cessation of active treatment;
Site contamination was/is well delineated;
Reduced sampling frequency is appropriate - annual or less frequent sampling is recommended;
and
A specific recommendation for data collection accelerating closeout of the site could not be
made.
The site team implemented the recommendation to reduce groundwater monitoring frequency to annual
sampling and will monitor regulatory developments with respect to further guidance on statistical
requirements for site closeout. Furthermore, the site team is reviewing plans to use permeable diffusion
bag samplers to help reduce some of the variability found in the groundwater samples.
Ciba-Geigy Corp. Superfund Site
Beginning in 2010, independent technical support was provided to EPA Region 2 during an optimization
process initiated by the potentially responsible party (PRP) of the Ciba-Geigy Superfund Site in Toms
River, New Jersey. The support was provided on an ad hoc basis over the period of approximately one
year and included document review, participation in site meetings, and written technical input provided
to the region.
The PRP's stated goals of optimization were to improve efficiencies, reduce natural resource usage,
reduce carbon footprint and provide for future reuse of the property. The EPA optimization review team
11 July 2012 OSWER9283.1-38
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provided independent technical input as the PRP developed a life cycle cost model and a plan for near
term, intermediate and long term optimization activities. The review team's input primarily related to
alternative groundwater treatment methods, suggestions to mitigate extraction well fouling, and
consideration of appropriate cleanup levels for cis-l,2-dichloroethene. Due to the ad hoc nature of this
optimization-related support, no specific recommendations were made for this site.
In a follow up call with the EPA site team in 2012, the RPM stated that the technical support was a
valuable resource, serving as an independent evaluation of the PRP's proposed actions. Source area
characterization and optimization of the existing treatment system are currently underway.
3.0 References
3.1 Internet Resources
USEPA Superfund Program, Remedy Optimization
Optimization guidance and links to other related program areas
http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm
USEPA, Hazardous Waste Clean-Up Information (CLU-IN) web site
Site-specific optimization 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
3.2 Previous Optimization Progress Reports
Ground Water Remedy Optimization Progress Report: 2008-2009 (OSWER 9283.1-34; December
2010)
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-financed 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)
12 July 2012 OSWER 9283.1-38
-------
APPENDIX
OSWER9283.1-38
This appendix represents data submitted on the status of the progress of
recommendations as of the January 2012 tracking and follow up period.
The status of the progress of recommendations from prior tracking periods
can be found in previous Progress Reports, referenced in the reference
section of this report. These reports are available online at
http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm.
-------
RSE Recommendations and Progress Toward Implementation
Region 2
Site Name: GCL Tie & Treating (Sidney, NY)
Recommendation
Remedy Effectiveness
6.1.1 Institute a routine ground water
monitoring program
6.1.2 Optional plume delineation
6.1.3 Soil vapor intrusion evaluation
Cost Reduction
6.2. 1 Discontinue pumping from the
intermediate zone
Status
I
Implemented
Implemented
Implemented
Implemented
Under
6.2.2 Consider modifications to the
backwashing and solids handling procedures Consideration
(contingent of outcome of 6.2.1)
6.2.3 Suggestions for long-term ground Implemented
water monitoring
6.2.4 Pilot test bypassing the air stripper Declined
6.2.5 Consider a hybrid time and materials Alternative
and fixed-price contract Implemented
6.2.6 Reductions in project management Implemented
consistent with steady state system operation
Technical Improvement
6.3.1 Relocate equalization tank high-level Implemented
switch
6.3.2 Discontinue use and service to Declined
generator
6.3.3 Modify use of water levels from Planned
operating extraction wells when developing
potentiometric surface maps
EPAID#: NYD981566417
RSE Report: EPA 542-R-06-016 (December 2006)
Progress since the previous progress report
The recommendation is still on hold. At this point, there is no need for modifications.
This recommendation would be implemented during the generation of the 2011 annual
monitoring well sampling report which is currently being drafted.
OSWER 9283.1-38 Appendix
July 2012
Page 1 of 37
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RSE Recommendations and Progress Toward Implementation
Region 2
Site Name: Vineland Chemical Co. (Vineland, NJ)
Recommendation Status
Remedy Effectiveness
6.1.1 Further characterize extent of In progress
contamination
6.1.2 Consider modifications to the In progress
groundwater extraction system to assure
capture
6.1.3 Additional monitoring of groundwater In progress
quality between extraction wells and
Blackwater Branch
Cost Reduction
6.2.1 Discontinue automated sampler and do In progress
not replace the unit
6.2.2 Eliminate routine on-site arsenic
sampling
6.2.3 Reduce extraction rates to those that
are necessary for plume capture
6.2.4 Evaluate groundwater monitoring costs
6.2.5 Continue to optimize groundwater
monitoring program
Planned
Under
consideration
Under
consideration
Implemented
6.2.6 Focus building heating and lighting on Under
key process area consideration
6.2.7 Evaluate chemical usage
Under
consideration
EPA ID#: NJD0023 85664
RSE Report: EPA-542-R-11-007 (November 2011)
Progress since the previous progress report
An evaluation is currently underway to further our understanding of contaminant release and
migration processes on site. See also 6.1.3 and 6.4.2.
Plume capture is under investigation and continues to be evaluated. Elevated levels of arsenic in
select areas northwest and southwest of main plant property appear not to be a source, but
related to a residual or remnant plume contamination.
In the summer/fall of 2011, monitoring wells were installed in 11 locations, 8 were nested
(located along the Blackwater Branch) for a total of 19 new wells.
The team agreed that the risk of turning off the OVA and discontinuing the use of the graphite
furnace is minimal, considering we normally treat well below the permitted discharge level of
50ppb, and that most other plants do not have such a conservative sampling setup. The
contractor will provide a cost estimate for savings associated with discontinuing the use of the
OVA and graphite furnace.
The project team will evaluate potential reductions in sampling frequency.
This has been discussed, and a further evaluation by USAGE is underway.
This has been discussed, and a further evaluation by USAGE is underway.
All extraction wells are now computerized. Optimization (for cost and quality control) activities
will continue on site. The last round of optimization included: computerization of operations
control to reduce labor on site, piping changes to enhance process efficiency/ performance,
optimizing chemical usage to reduce costs, and the adjustment of well development protocols.
After an exit strategy is decided upon, EPA will ask USAGE and site contractor to determine
feasibility and costs associated with recommendations 6.2.6, 6.2.7, and 6.2.8.
After an exit strategy is decided upon, EPA will ask USAGE and site contractor to determine
feasibility and costs associated with recommendations 6.2.6, 6.2.7, and 6.2.8.
OSWER 9283.1-38 Appendix
July 2012
Page 2 of 37
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RSE Recommendations and Progress Toward Implementation
Region 2
Site Name: Vineland Chemical Co. (Vineland, NJ)
Recommendation
Status
EPA ID#: NJD0023 85664
RSE Report: EPA-542-R-11-007 (November 2011)
Progress since the previous progress report
6.2.8 Consider use of a plate and frame filter In progress
press to dewater solids
6.2.9 Consider the use of lime for pH Declined
adjustment
6.2.10 Continue to streamline plant and In Progress
project staffing
6.2.11 Based on outcome of other Declined
recommendations, consider potential for
delisting waste sludge
Technical Improvement
6.3.1 Refine well rehabilitation practices Implemented
6.3.2 Discontinue use of curtains and
electrical heaters for sand filters
6.3.3 Continue with plan to remove soil
washing equipment from the site
6.3.4 Prepare an annual report
Progress Toward Cleanup Goals
6.4.1 Evaluate potential for natural
attenuation and suggested criteria for
discontinuing P&T
6.4.2 Active in-situ treatment for arsenic
immobilization
6.6.1 Suggested exit strategy
Under
consideration
Under
consideration
In Progress
In Progress
In Progress
In Progress
The team agreed that an existing plate and frame filter press could be a good way to reduce
waste disposal. The RSE team and site contractor will research availability of a unit from
another site and provide a cost estimate for removing unit from the existing location,
installation and operation.
The team agreed that employing a lime system would have high capital cost and operational
issues that make it impractical for this site.
Efficient labor utilization is a primary goal of the project team.
A Superfund finding is in place for washed media reuse and evaluating contained-in policy for
waste/media disposal practices. The sludge appears to be too concentrated with arsenic to allow
for de-listing.
Monthly well meetings are conducted to evaluate system performance for optimized extraction
and well field pumping is adjusted accordingly.
Site contractor will look into this item and provide recommendations.
Evaluation of soil washing for River Areas/Union Lake still needs to be conducted. As of
January 2012, the equipment is still under consideration for use in later phases of this project.
USAGE is currently compiling a report that summarizes work done since 2000. A five year
review for Vineland Chemical was finalized in September 2011.
Continued operation of the P&T is imperative as system shutdown will result in discharges to
surface water exceeding the ROD criteria. The USAGE is currently evaluating the potential for
MNA.
Based on the RSE recommendation, an evaluation of arsenic immobilization technologies is
underway. Geochemical data was collected in the summer of 2011 to support overall
understanding of contaminant release/migration processes, provide baseline data for both
immobilization and mobilization enhancement technology strategic planning. More sampling is
scheduled for the spring/summer of 2012
The USAGE is currently carrying out investigations in response to the RSE recommended
approach.
OSWER 9283.1-38 Appendix
July 2012
Page 3 of 37
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RSE Recommendations and Progress Toward Implementation
Region 2
Site Name: Vineland Chemical Co. (Vineland, NJ)
Recommendation Status
Green Remediation
6.7.1 Consider combined heat and power Planned
6.7.2 Consider alternatives for iron addition
6.7.3 Postpone lighting retrofit
Under
Consideration
Planned
EPA ID#: NJD0023 85664
RSE Report: EPA-542-R-11-007 (November 2011)
Progress since the previous progress report
The team agreed that a newer, greener system is desirable, if feasible. The site contractor will
get vendor estimates for new gas generator systems (i.e., Bloom Box, or micro turbine).
Another added feature to check on is the use of any excess waste heat from the system to be
focused on drying the sludge more to decrease waste disposal costs.
After an exit strategy is decided upon, EPA will ask USAGE and site contractor to determine
feasibility and costs associated with recommendations 6.71, 6.7.2, and 6.7.3.
All agreed to try out a new high bay fixture (manufacture brand to be provided by USAGE)
before purchasing for the entire plant.
OSWER 9283.1-38 Appendix
July 2012
Page 4 of 37
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RSE Recommendations and Progress Toward Implementation
Region 2
Site Name: Tutu Wellfield (Tutu Wellfield, VI)
Recommendation
Remedy Effectiveness
6.1.1 Hydraulic Containment
6.1.3 Curriculum Center Vapor Intrusion
Resampling
6.1.4 Include MTBE Analysis
Status
Planned
6.1.2 No Additional Downgradient Active Implemented
Remediation
Implemented
Implemented
Cost Reduction
6.2.1 Improve Contracting Efficiency
6.2.2 Termination of GWTF #2 Operation
6.2.3 Reduce Operator Visits including
Decreasing Well Gauging Frequency
6.2.4 Eliminate Emissions Sampling at
GWTF#1
Technical Improvement
6.3.0 Remove excess air discharge ducting
and consider air strippers with less power
requirements
Progress Toward Cleanup Goals
6.4.0 Considerations for Gaining Site Close Under
Deferred to
State or PRP
Under
Consideration
Deferred to
State or PRP
Under
Consideration
Under
Consideration
Out
Consideration
EPA ID#: VID982272569
RSE Report: EPA-542-R-11-008 (November 2011)
Progress since the previous progress report
The site team developed a detailed scope including adding four extraction wells, hooking them
up to the system and start-up tasks as well as one additional monitoring well. The site team
obtained contractor costs for this work and project costs at over $500,000 not including COM
Smith management versus the RSE estimate of $210,000. Implementation has been delayed
due to lack of available funding. The RSE team has not seen the detailed work scope or
contractor submittals to comment on the difference between the cost estimates.
The site team has not changed the current approach.
The vapor intrusion resampling was conducted in December 2011, results are not yet available.
Total costs for the work will be about $35,000 versus the $45,000 RSE estimate
The site team reports that MTBE analysis is occurring as part of the VOC scan. MTBE results
were relatively low or non-detect so that MTBE migration is not a concern.
The site team stated that these changes cannot be implemented under the current contract which
will run until the turnover to USVI. The USVI should consider the recommendations after the
turnover.
The site team plans to wait until the hydraulic containment improvements are completed at
GWTF #1 before implementing this recommendation.
The site team stated that these changes cannot be implemented under the current contract which
will run until the turnover to USVI. The USVI should consider the recommendations after the
turnover.
The site team will consider writing a letter to USVI to eliminate this redundant sampling
requirement. The site team noted that analysis is being done by the USEPA CLP lab.
The site team plans to wait until the hydraulic containment improvements are completed at
GWTF #1 before implementing this recommendation.
The site team plans to wait until the hydraulic containment improvements are completed at
GWTF #1 before implementing this recommendation.
OSWER 9283.1-38 Appendix
July 2012
Page 5 of 37
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RSE Recommendations and Progress Toward Implementation
Region 2
Site Name: Tutu Wellfield (Tutu Wellfield, VI)
Recommendation Status
EPA ID#: VID982272569
RSE Report: EPA-542-R-11-008 (November 2011)
Progress since the previous progress report
Green Remediation
6.5.0 Consider alternative effluent discharge Under No further action has been taken to date.
and energy sources Consideration
OSWER 9283.1-38 Appendix
July 2012
Page 6 of 37
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RSE Recommendations and Progress Toward Implementation
Region 3
Site Name: Mill Creek Dump (Erie County, PA)
Recommendation Status
Remedy Effectiveness
6.1.1 Further Characterize Extent of Implemented
Contamination
6.1.2 Install Additional Points for Water Implemented
Level Measurements
6.1.3 Conduct a Shutdown and Restart Test
of the Extraction System
6.1.4 Document the Findings from the Implemented
Above Events, Use Findings for Capture
Zone Analysis
6.1.5 Automate Chemical Feeds or Provide Declined
Appropriate Interlocks to Discontinue
Chemical Feeds if One or More Extraction
Trenches Discontinue Operation
6.1.6 If Off-Site Shallow Contamination is Implemented
Identified and Determined to be Related to
the Site, Conduct a Vapor Intrusion
Evaluation
Cost Reduction
6.2.1 Discontinue April Sampling Event Implemented
6.2.2 Discontinue Analysis for Dissolved Planned
Metals
6.2.3 Streamline Process Sampling Declined
6.2.4 Revisit Data and Reporting Costs Implemented
EPAID#: PAD980231690
RSE Report: EPA-540-R-10-014 (February 2010)
Progress since the previous progress report
DPT sampling was conducted at 18 locations, with 35 samples collected in August 2010.
Results indicate the most offsite locations sampled do not have contamination. Two locations
at the northern edge of the site (near the pond) had DCE and vinyl chloride contamination
above ROD screening levels. Results are still being evaluated with respect to the modeling and
capture zone analysis discussed in 6.1.4.
Six new monitoring wells were installed in November 2010, consistent with the RSE
recommendation.
Implemented Conducted in December 2010.
A MODFLOW model has been developed using findings from the above field investigations.
Separate comments were provided by the RSE team on the capture zone document and
modeling report.
It was determined that nothing in the system requires changing, as the one main release
occurred as a result of human error.
Five residences were sampled in December 2010. Results did not demonstrate a vapor
intrusion problem.
The April event was conducted in April/May 2011, however it has been discontinued starting in
2012.
The site team agrees with this recommendation and will implement it in 2012.
With the current treatment plant staffing, the suggested revisions to process monitoring will not
result in savings. Therefore, the site team will not make the adjustment.
The site team reports that the semi-annual report has been eliminated, resulting in savings of
$8,350. No other changes were reported to the data and reporting costs.
OSWER 9283.1-38 Appendix
July 2012
Page 7 of 37
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RSE Recommendations and Progress Toward Implementation
Region 3
Site Name: Mill Creek Dump (Erie County, PA)
Recommendation
Status
EPAID#: PAD980231690
RSE Report: EPA-540-R-10-014 (February 2010)
Progress since the previous progress report
6.2.5 Reduce or Eliminate Lime
Conditioning of Sludge
Technical Improvement
6.3.1 Cleanup of Treatment Plant
6.3.2 Considerations Regarding Treatment
Plant Modifications, if Necessary
Progress Toward Cleanup Goals
6.4.1 Determining a Path Forward
Green Remediation
6.5.1 Revised Approach to Metals Removal
6.5.2 Considerations for Renewable Energy
at the Site
Planned PADEP's contractor will reduce the lime conditioning, initially by 50%, and evaluate the
effectiveness. The contractor will then adjust the amounts to determine the optimum conditions.
Implemented The treatment plant has been cleaned and organized.
Under PADEP, which is responsible for operating the remedy, will need to revisit this
Consideration recommendation before making a decision to implement it.
Under The site team recognizes the need to determine a path forward and relayed that the Five-Year
Consideration Review includes delineation of contamination as an issue to be resolved.
Under PADEP, which is responsible for operating the remedy, will need to revisit this
Consideration recommendation before making a decision to implement it.
Declined The site team reports several failures of renewable energy projects in the area (not site related)
and will postpone consideration of renewable energy at the site for the foreseeable future.
OSWER 9283.1-38 Appendix
July 2012
Page 8 of 37
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RSE Recommendations and Progress Toward Implementation
Region 4
Site Name: Alaric Area Groundwater Plume (Tampa, FL)
Recommendation
Remedy Effectiveness
Status
6.1.1 Carefully Determine an Appropriately Under
Conservative Buffer when Informing the consideration
State of Plume Extent Related to
Establishing Ground Water Restrictions
6.1.2 Analyze Process Water Periodically Implemented
for Constituents of Concern from the Helena
Chemical Site
6.1.3 Simplify System Controls
6.1.4 Monitor Specific Capacity in
Recovery and Reinjection Wells
6.1.5 Interpret Capture
Reduction
6.2.1 Modify VOC Treatment
6.2.2 Consider Discharging to the Shallow
Zone
6.2.3 Characterize GAC Again and
Investigate Source of Radioactivity in an
Attempt to Dispose of GAC as Non-
Hazardous Waste or to Regenerate It
6.2.4 Track Routine O&M Costs Separately
from Non-Routine Costs
Technical Improvement
6.3.1 Consider the Following Comments to
the May 2009 Technical Review by the Site
Contractor
Implemented
Implemented
Under
Consideration
^m
Alternative
Implemented
Implemented
Implemented
Implemented
EPAID#: FLD012978862
RSE Report: EPA-540-R-10-013 (January 2010)
Progress since the previous progress report
More extensive work on the groundwater plume will be conducted once source area soils are
addressed. The timeline for a site-wide FS and final ROD is approximately 3+ years after
implementation of the source zone remedy.
After the system was restarted in May 2011, the site team conducted process sampling that
included a broader suite of contaminants, including pesticides. This sampling is planned to
occur on a semi-annual basis. The site team reports that there were low-level detections of
pesticides in some of the recovery wells and that there were no detections in the effluent.
The existing complex control system was simplified.
These monitoring activities will occur during system operation when the system is restarted.
This item has been discussed, and there is general consensus that it is needed.
The treatment system has been updated with a new air stripper, new piping, and addition of
sequestering agents.
The treated water is now discharged to the shallow aquifer through the existing infiltration
galleries.
March 22, 2011 - The previous detection of radioactivity is expected to be a one-time issue.
The GAC is due for changeout and will be characterized prior to disposal.
A cost tracking system has been set up for GeoSyntec with separate routine and non-routine line
items.
Implemented The treatment plant upgrades have been completed.
OSWER 9283.1-38 Appendix
July 2012
Page 9 of 37
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RSE Recommendations and Progress Toward Implementation
Region 4
Site Name: Alaric Area Groundwater Plume (Tampa, FL)
Recommendation
Status
Progress Toward Cleanup Goals
6.4.0 Considerations for Gaining Site Close Alternative
Out
Implemented
EPAID#: FLD012978862
RSE Report: EPA-540-R-10-013 (January 2010)
Progress since the previous progress report
In-situ thermal treatment will replace the in-situ chemical oxidation remedy previously used to
address source area soils. The other potentially contaminated areas and plume area will be
considered once the source area has been addressed. The design for the in-situ thermal remedy
is underway.
OSWER 9283.1-38 Appendix
July 2012
Page 10 of 37
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RSE Recommendations and Progress Toward Implementation
Region 4
Site Name: Benfield Industries (Waynesville, NC)
Recommendation Status
Remedy Effectiveness
6.1.1 Document potential downgradient Declined
receptor locations and adjust monitoring
locations if necessary
6.1.2 Consider sampling for dioxins/furans Declined
in soil
6.1.3 Document rationale for eliminating In progress
metals analysis
Cost Reduction
6.2.1 Do not restart the extraction system Implemented
6.2.2 Consider monitored natural attenuation In progress
as the ground water remedy
EPAID#: NCD981026479
RSE Report: EPA 542-R-07-020 (September 2007)
Progress since the previous progress report
The ROD amendment now planned to be completed by May 2015, and will address this issue.
The draft MNA report was completed in July 2011 and reviewers found lines of evidence did
not support an MNA remedy without addressing some remaining hot spots. The contractor is
currently working on plans to identify and address the remaining hot spots followed by writing
the draft ROD amendment. It is anticipate to take three years to complete this assignment by
May 2015 (FY 2015).
6.3.1 Improve sampling and analysis
methods/reports
Implemented
Progress Toward Cleanup Goals
6.4.1 Assess feasibility and cost-benefit of In progress
in-situ treatment of remaining soil hot spot(s)
6.4.2 Consider reassessing the cleanup In progress
criterion for 1,4-Dichlorobenzene
The past five sampling events have used analytical methods that provide reporting limits at or
below the current ROD cleanup levels. The ROD amendment is now anticipated to be complete
by May 2015.
The contractor is currently working on plans to identify and address the remaining hot spots
followed by writing the draft ROD amendment. It is anticipate to take three years to complete
this assignment by May 2015 (FY 2015)
The ROD amendment will now be completed by May 2015.
OSWER 9283.1-38 Appendix
July 2012
Page 11 of 37
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RSE Recommendations and Progress Toward Implementation
Region 4
Site Name: American Creosote Works (Pensacola, FL)
Recommendation Status
Remedy Effectiveness
6.1.1 Continue revisiting soil cleanup levels In progress
and ACLs
6.1.2 Consider potential vapor intrusion Implemented
6.1.3 Revise program for determining GAC Implemented
replacement
6.1.4 Evaluate options to implement Under
stronger institutional controls Consideration
Cost Reduction
6.2.1 Revise ground water sampling program Alternative
Implemented
6.2.2 Review labor costs once system Implemented
operation has stabilized
Technical Improvement
6.3.1 Re-pipe DNAPL line from treatment Implemented
shed to DNAPL storage tank
Progress Toward Cleanup Goals
6.4.1 Modifications intended to gain site In progress
close-out
EPAID#: FLD008161994
RSE Report: EPA-540-R-06-068 (June 2006)
Progress since the previous progress report
EPA is in the process of finalizing the Focused FS for ACW. A sitewide ROD is scheduled for
summer 2012. There are still discussions of where the low level dioxin impacted soil will be
deposited (possible onsite and offsite locations).
An air stripper unit was added to the system. This unit will extend the lifetime of the GAC of
the system. It is estimated that it will pay for itself in the first year of operation.
EPA and FDEP are still looking into implementing institutional controls onsite. The
development of groundwater ICs will require more investigation work. The ICs will be
included in a sitewie ROD scheduled to be done by September 2012.
A sitewide ROD is scheduled for summer 2012. This ROD will revisit the site's groundwater
remedy and possibly the cleanup goals. One of the possible remedies is a containment strategy
utilizing a barrier wall around the DNAPL source area.
OSWER 9283.1-38 Appendix
July 2012
Page 12 of 37
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RSE Recommendations and Progress Toward Implementation
Region 4
Site Name: Cape Fear Wood Preserving (Fayetteville, NC)
Recommendation
Remedy Effectiveness
Status
6.1.1 Install and sample a monitoring well Implemented
downgradient of MW-16
6.1.2 Sample outer monitoring wells Implemented
annually
6.1.3 Do not use water levels from operating Implemented
recovery wells or infiltration galleries when
generating potentio-metric surface maps
Cost Reduction
6.2.1 Contract O&M services and ground Implemented
water sampling to a local contractor
6.2.2 Eliminate select wells from monitoring Implemented
program, and reduce sampling and reporting
frequency to annually
Technical Improvement
6.3.1 Consider alternatives before adding a Implemented
sequestering agent
6.3.2 Reduce frequency of water level Implemented
measurements, discontinue dissolved
oxygen monitoring, and simplify O&M
reporting
6.3.3 Add a suffix to well labels to indicate Implemented
shallow and deep wells
Progress Toward Cleanup Goals
6.4.1 Evaluate effectiveness of various Alternative
remedy components Implemented
EPA ID#: NCD003188828
RSE Report: EPA-542-R-05-005 (February 2005)
Progress since the previous progress report
OSWER 9283.1-38 Appendix
July 2012
Page 13 of 37
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RSE Recommendations and Progress Toward Implementation Region 4
Site Name: Cape Fear Wood Preserving (Fayetteville, NC) EPA ID#: NCD003188828
RSE Report: EPA-542-R-05-005 (February 2005)
Recommendation Status Progress since the previous progress report
6.4.2 Considerations for evaluating thermal Alternative The thermal study was completed. The tech. memo evaluating the 3 scenarios was completed.
pilot study Implemented The 3 scenarios evaluated include 1) STAR with ISCO (activiated persulfate), 2) steam
injection with ISCO (activiated persulfate), and 3) stabilization on Site with thermal treatment
along Reilly Road followed by ISCO ISCO (activiated persulfate). All three of these options
would be followed by MNA. A final determination regarding changing the remedy and
implement any of these alternatives has not been made at this time. The Site is on schedule to
be transferred to the State for implementation LTRA of the existing remedy by July 2012. EPA
is looking into the logistics of potentially changing the remedy in the near future.
OSWER 9283.1-38 Appendix July 2012 Page 14 of 37
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Ott/Story/Cordova Chemical Co. (Dalton Township, MI)
Recommendation Status
Cost Reduction
6.2.1 Replace DAS units with tray aerators Declined
or packed towers
6.2.2 Reexamine NPDES permit and Declined
potentially bypass PACT system
6.2.3 Reduce process monitoring and Implemented
analysis
6.2.4 Reduce aquifer monitoring and analysis Implemented
6.2.5 Remove excess equipment and do not Declined
construct the planned storage building
6.2.6 Evaluate potential reduction in onsite Implemented
presence of USAGE
6.2.7 Remove trailers from site Implemented
6.2.8 Have onsite staff conduct sampling for Alternative
OU3 Implemented
Technical Improvement
6.3.1 Establish consistent sampling method Implemented
6.3.2 Modify program for water-level Implemented
measurement
Progress Toward Cleanup Goals
6.4.1 Establish agreement between the OU2 In progress
remedy and ROD
EPAID#: MID060174240
RSE Report: EPA 542-R-02-008s (March 2002)
Progress since the previous progress report
Consistent with the requirements of the 2007 Five Year Review, a "Remedial Strategy
Analysis" continues. The transfer of portions of the LTRA to the State occurred on February 1,
2011. The State of Michigan identified numerous outstanding issues with the remedy. EPA
continues to partner with the State to address remedy issues until cleanup goals are reached,
including this RSE recommendation.
OSWER 9283.1-38 Appendix
July 2012
Page 15 of 37
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Douglas Road/Uniroyal, Inc., Landfill (St. Joseph
County, IN)
Recommendation
Remedy Effectiveness
6.1.1 Sample extraction wells annually
6.1.2 Investigate off-site sources and
remaining down-gradient impacts
Cost Reduction
6.2.1 Reduce analytical QA/QC
6.2.2 Consider converting cell 3 to an
additional infiltration basin
Progress Toward Cleanup Goals
6.4.1 Develop an exit strategy
Status
Deferred to
State or PRP
Declined
Deferred to
State or PRP
Alternative
implemented
Deferred to
State or PRP
EPAID#: IND980607881
RSE Report: EPA 542-R-04-031 (February 2004)
Progress since the previous progress report
State has taken over monitoring as of November 2011.
State has assumed operation of remedy as of November 2011.
OSWER 9283.1-38 Appendix
July 2012
Page 16 of 37
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Reilly Tar & Chemical Corp. (Indianapolis, IN)
Recommendation Status
Remedy Effectiveness
^^^^^^^^^^^m
6.1.1 Install piezometers and monitoring Implemented
wells to allow for improved evaluation of
plume capture
6.1.2 Perform improved plume capture In progress
evaluation (Including numerical model)
6.1.3 Consider the need for a modified Declined
extraction system
Cost Reduction
6.2.1 Consider using extracted water for Declined
process and cooling uses
Technical Improvement
6.3.1 Minor suggestion for improved O&M Implemented
reporting
Progress Toward Cleanup Goals
6.4.1 Develop an exit strategy (consider In progress
alternate approach)
EPAID#: IND000807107
RSE Report: EPA 542-R-04-035 (February 2004)
Progress since the previous progress report
PRPs have submitted outline of modeling effortEPA to provide comments early 2012 for
implementation.
See update for recommendation 6.1.2. Updated modeling in 2012 will facilitate an exit strategy.
OSWER 9283.1-38 Appendix
July 2012
Page 17 of 37
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Peerless Plating (Muskegon, MI)
Status
Recommendation
Remedy Effectiveness
6.1.1 Evaluation of ground water capture Implemented
6.1.2 Modifications to the monitoring Implemented
program
Cost Reduction
6.2.1 Eliminate several ground water Implemented
treatment processes
6.2.2 Modifications to the monitoring Implemented
program
6.2.3 Revise reporting requirements Declined
6.2.4 Review level of operator support Implemented
Technical Improvement
6.3.1 Install dust collection system over Declined
FeSO4 hopper
6.3.2 Install enclosure around air Declined
compressor to reduce noise
6.3.3 Initiate a formal O&M program Implemented
6.3.4 Advertise availability of used Implemented
equipment on USACE/EPA web page
Progress Toward Cleanuj
6.4.1 Assess source area treatment Declined
alternatives
6.4.2 Permeable barrier Declined
EPA ID#: MID006031348
RSE Report: EPA 542-R-06-011 (February 2006)
Progress since the previous progress report
A pumping wells was moved and pumping rates were adjusted to help address capture issues.
Additional monitoring wells were installed to monitor capture.
A monitoring well to address background concentrations was installed. The State installed 8
new monitoring wells to establish plume limits. The agency continues to monitor these new
wells to determine if additional information will be required in the future.
Low Flow sampling is used exclusively.
The by pass system continues to operate and there is no update at this time.
The formal O&M plan has been developed and will continue to be updated as required until the
site activities are taken over by the State of MI.
The contractor is currently solicity bids to dismantel and remove excess equipment from the
Site.
OSWER 9283.1-38 Appendix
July 2012
Page 18 of 37
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Baytown Township Ground Water Plume (Lake Elmo,
MN)
Recommendation
Remedy Effectiveness
6.1.1 Implement ISCO in Source Area
6.1.2 Phased Implementation of ISCO,
Tracer Test
6.1.3 Consideration of In Situ Biological
Treatment
6.1.4 Potential Life Cycle Cost Savings
Offered by Source Area Treatment
Status
EPA ID#: MND982425209
RSE Report: EPA-540-R-011-006 (June 2011)
Progress since the previous progress report
Under The use of ISCO in the source area will be considered as part of an updated FS in early 2012. A
Consideration work plan for the FS is currently under development.
Under Aspects of this recommendation are in the process of being implemented, including the tracer
Consideration test.
Under The use of in-situ bioremediation will be considered as part of the updated FS (see 6.1.1).
Consideration
Under This section of the RSE report did not contain a specific recommendation, rather it supports
Consideration other items in 6.1.
6.1.5 Additional Source Area Assessment In Progress
6.1.6 Performance-Based Contracting for
Source Area Treatment
6.1.7 More Rigorous Evaluation of
Hydraulic Barrier Capture Influence
6.1.8 Improvements to the Monitoring
Program
Cost Reduction
6.2.1 Reduce Blower Airflow Rate
6.2.2 Adjustments to GAC Management
Program
6.2.3 Eventually Replace Class I, Division I Under
Motors
Under
Consideration
In Progress
In Progress
Under
Consideration
In Progress
A work plan for implementing this recommendation is in preparation (see 6.1.1).
This item will be considered in the future if source treatment is planned.
MPCA contractor is evaluating capture as part of Annual Report. Region 5 technical staff may
be able to assist with this.
MPCA is assessing trends, but will not implement a MAROS analysis.
Contractor to MPCA is evaluating.
One GAC unit has been replaced, and process is in place to require that new units exclude
treatment of water delivered by exterior hose bibs.
Applicable only in the future when equipment needs replacement.
6.2.4 Optimization of the Groundwater
Monitoring Program
Technical Improvement
Consideration
Implemented Passive diffusion bags have been used in some monitoring wells, but not all.
6.3.1 Use of More Rigorous MNA Modeling Under
Consideration
6.3.2 Continue Evaluation of Groundwater Implemented
Infiltration System Plugging
MPCA is planning additional MNA monitoring later in 2012.
Injection of CO2 continues and downhole camera work assesses need for well rehabilitation by
jetting.
OSWER 9283.1-38 Appendix
July 2012
Page 19 of 37
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Baytown Township Ground Water Plume (Lake Elmo,
MN)
Recommendation
Status
EPA ID#: MND982425209
RSE Report: EPA-540-R-011-006 (June 2011)
Progress since the previous progress report
6.3.3 Periodic Inspection of Electrical Implemented
System and Controls
6.3.4 Optimize Process Flow Configuration Declined
for Air Stripping System
6.3.6 Preparation of an Annual Report Implemented
6.3.7 Improvement of Data Management In Progress
Progress Toward Cleanup Goals
6.4.0 Implement ISCO, MNA Modeling, Under
Capture Zone Analysis (see 6.1.1 above) Consideration
MPCA contractor has conducted inspection and has incorporated this into standard site
inspection process.
MPCA will not implement as it would require adding pumps.
Modifications to the annual reports being prepared starting in 2011.
MPCA has made some improvements, including use of the EQUIS database. EPA Region 5
offered assistance for this.
See 6.1.1 above
OSWER 9283.1-38 Appendix
July 2012
Page 20 of 37
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Moss-American (Milwaukee, WI)
Recommendation
Status
EPA ID#: WID03 9052626
RSE Report: EPA-540-R-11-018 (March 2011)
Progress since the previous progress report
5.1.1 Monitoring program modifications Planned
5.1.2 Additional NAPL investigation Planned
Cost Reduction
5.2.1 NAPL-impacted soil excavation and Under
enhanced dissolved-phase treatment Consideration
5.2.2 Limited NAPL-impacted soil removal Under
and installation of additional treatment gate Consideration
5.2.3 Ground Water Flow Modification to Declined
Enhance Treatment of Existing Funnel and
Gate System
The State plans on getting a contractor on board later this year to develop and implement a
work plan for further characterization, as recommended in 5.1.1 and 5.1.2. In addition, the
contractor will be tasked with suggesting other alternatives to meet the objectives of the project.
See notes above.
Pending outcome of 5.1.1 and 5.1.2.
Pending outcome of 5.1.1 and 5.1.2.
The site team has deemed this item ineffective and not a viable path forward.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Wash King Laundry (Pleasant Plains Township, MI)
EPAID#: MID980701247
Recommendation
Remedy Effectiveness
6.1.1 Sample P&T Discharge and
Residential Wells for Lead
6.1.2 Complete Institutional Controls
6.1.3 Jet EW-5 and Measure/Track
Extraction Well Specific Capacity
6.1.4 Evaluate and Manage Soil Vapors
Cost Reduction
6.2.1 Discontinuing Pumping from EW-4
6.2.2 Reduce Metals Analysis
6.2.3 Reconfigure Air Strippers and
Possibly Resize Air Stripper Blowers
6.2.4 Modify Groundwater Monitoring
Program
6.2.5 Prepare an Annual Report
Status
~~l
Implemented
In Progress
Implemented
Alternative
Implemented
Implemented
Alternative
Implemented
In Progress
Implemented
Declined
RSE Report: EPA-540-R-11-019 (February 2011)
Progress since the previous progress report
The site team actually started implementing this the year before the RSE.
The site team has determined that institutional controls are not needed at four of the eight
properties. EPA and the State are discussing institutional controls for the other four properties.
In the interim, the Health Department, which has the authority to permit supply wells, will not
allow wells in the area.
The site team jetted the well, but jetting did not result in sufficient improvements. The well
needed to be replaced. The site team replaced the well with a well (EW-8) in a new location
upgradient.
The site team evaluated the potential for vapor intrusion at the restaurant building and
concluded that given the condition of the building and no occupancy of the building, vapor
intrusion was not a concern. The site team, however, decided to keep operating the SVE
system occasionally to reduce vapors that accumulate in the unsaturated zone.
The site team implemented this recommendation.
The site team did not reduce the types of analyses, but did reduce some of the locations where
metals would be analyzed.
Given the flow from the new extraction wells and the capacities of the air strippers, both air
strippers are needed. At the suggestion of the RSE team, the site team will revisit discussions
with the vendors to see if the blower sizes can be reduced from 25 HP or variable frequency
drives can be installed to reduce air flow and electricity usage and still provide adequate
treatment.
The site team adopted most of the RSE team's suggestions for modifying the groundwater
monitoring program. The site team agrees that savings is likely on the order of $30,000 per
year.
An additional annual report will not be implemented at this time given the existing quarterly
reporting and other recent reporting including two Five-Year Reviews, a Long-Term
Monitoring Optimization Report, and the RSE report.
OSWER 9283.1-38 Appendix
July 2012
Page 22 of 37
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Wash King Laundry (Pleasant Plains Township, MI)
Recommendation
Progress Toward Cleanup Goals
6.4.1 Investigate Sources in Lagoon Area
and Piping to Former Lagoons
6.4.2 Develop an Exit Strategy
Green Remediation
6.5.1 Use Dedicated Tubing
Status
In Progress
In Progress
Declined
6.5.2 Considerations for Renewable Energy Declined
at the Site
EPAID#: MID980701247
RSE Report: EPA-540-R-11-019 (February 2011)
Progress since the previous progress report
The site team has installed a shallow, intermediate, and deep well in the general vicinity and has
identified contamination. EPA Region 5 and the State continue to discuss the path forward for
the site.
The site team has installed a shallow, intermediate, and deep well in the general vicinity and has
identified contamination. EPA Region 5 and the State continue to discuss the path forward for
the site.
The potential savings (cost and environmental) do not outweigh the field complications
associated with implementing this recommendation.
The site team has not considered renewable energy for the site. The RSE team suggests
understanding the future electricity usage (after air stripper optimization) prior to considering
renewable energy.
OSWER 9283.1-38 Appendix
July 2012
Page 23 of 37
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RSE Recommendations and Progress Toward Implementation
Region 7
Site Name: 57th and North Broadway (Wichita, KS)
Recommendation
Remedy Effectiveness
6.1.1 Perform additional source area
characterization
Status
Implemented
Implemented
6.1.2 Consider contingent wellhead
treatment at the public water supply well
6.1.3 Consider change to P&T after source In progress
characterization, in 53rd Street area
6.1.4 Evaluate whether extent of SVE Implemented
system is adequate
6.1.5 Consider using air sparging with Declined
existing SVE
6.1.6 Continue monitoring of sentinel wells Implemented
in Bel Aire well field
6.1.7 Evaluate potential for vapor intrusion Implemented
Cost Reduction
6.2.1 Consider immediately taking eastern Implemented
53rd Street DDC wells out of operation
6.2.2 Consider better tracking of routine and Implemented
non-routine site costs
Technical Improvement
^^^^^^^^m
6.3.1 Prepare and distribute annual Implemented
monitoring reports
6.3.2 Improve site maps Implemented
6.3.3 Report detection levels for 'non-detect' Implemented
results
EPAID#: KSD981710247
RSE Report: EPA-540-R-06-067 (June 2006)
Progress since the previous progress report
The status is about the same, we've conducted new investigation in December 2011 and
obtained additional data for the installation of the extraction well. We have had some issues
with the state which delayed this work. Things are progressing better now and hopefuly move
forward after we get these latest results.
OSWER 9283.1-38 Appendix
July 2012
Page 24 of 37
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RSE Recommendations and Progress Toward Implementation
Region 7
Site Name: 57th and North Broadway (Wichita, KS)
Recommendation
Status
Progress Toward Cleanup Goals
6.4.1 Clarify and document date for turnover In progress
to State for O&M
6.4.2 Develop consensus on terminating Implemented
SVE at Wilko
EPAID#: KSD981710247
RSE Report: EPA-540-R-06-067 (June 2006)
Progress since the previous progress report
The status is still the same, we have conducted additional investigations in December 2011 and
will modify the current remedy by installing an extraction well and some soil removal. After
the remedy is operational and effective, the site will be turned over to the state.
OSWER 9283.1-38 Appendix
July 2012
Page 25 of 37
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RSE Recommendations and Progress Toward Implementation
Region 7
Site Name: 10th Street Site (Columbus, NE)
Recommendation Status
Remedy Effectiveness
6.1.1 Evaluate the Need for Further Implemented
Evaluation of Potential for Vapor Intrusion
Near OHM Facility
6.1.2 Discontinue Pumping at EW-04 and Under
Shift Pumping West to EW-03 Consideration
6.1.3 Address Calibration Issues with the In progress
Flow Model
6.1.4 Address Potential Plume Migration to Implemented
the Southeast (Delineation and ICs) and
Associated Potential Actions
Cost Reduction
6.2.1 Discontinue ISCO After Contract is Implemented
Completed
6.2.2 Continue to Use PDBs Without Implemented
Extensive Comparisons
6.2.3 Reductions in Monitoring/Reporting Implemented
EPAID#: NED981713837
RSE Report: EPA 540-R-10-012 (February 2010)
Progress since the previous progress report
Two new rounds of vapor intrusion sampling were conducted in 2010, and four more rounds
were conducted in 2011. Indoor air samples have been below screening levels, but sub slab
samples had exceedances. A soil vapor investigation was conducted in and around the source
areas. The site team is moving forward with vapor intrusion mitigation systems at 17 properties
in early 2012.
Pumping continues at EW-04 and will be reevaluated after the flow model is updated. The
capacity of EW-03 has been increased to the maximum extent possible. The modeling was
delayed due to delays in obtaining access for the installation of piezometers. The modeling
should be completed in the next month or two allowing for consideration of the discontinuing
pumping from EW-04.
The Region is planning to update the flow model after conducting pump tests at EW-03 and
EW-04. The modeling was delayed due to delays in obtaining access for the installation of
piezometers. The modeling should be completed in the next month or two.
Twelve new wells have been installed for this purpose. The new monitoring wells have non-
detect results and effectively delineate the plume.
ISCO injections have been discontinued; the last round was in 2009.
The site team continues to use PDBs where they correlated well with low-flow sampling results
and do not use PDBs where they did not correlate well with low-flow sampling. No further
comparison studies are being conducted.
Reductions in monitoring/reporting were included in the contract modification, including
cutting back to semi-annual sampling and sampling at fewer wells. In 2010, monitoring and
reporting cost an estimated $247,465. Actual monitoring and reporting costs in 2011 were
lower than expected and actual monitoring and reporting in 2012 are $124,000 (suggesting a
cost reduction of 50% and a cost savings of $124,000 per year).
OSWER 9283.1-38 Appendix
July 2012
Page 26 of 37
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RSE Recommendations and Progress Toward Implementation
Region 7
Site Name: 10th Street Site (Columbus, NE)
Recommendation
Status
EPAID#: NED981713837
RSE Report: EPA 540-R-10-012 (February 2010)
Progress since the previous progress report
6.2.4 Project Management and Technical
Support Moving Forward
Technical Improvement
6.3.1 Measure and Track Specific Capacity
of Wells
6.3.2 Consider VFDs for Extraction Well
Pumps
Progress Toward Cleanup Goals
6.4.1 Consider Alternate Actions at OHM
Facility
6.4.1 Consider Alternate Actions at OHM
Facility
Implemented The RSE team's recommendations have been implemented, which has led to significant cost
reduction (approximately $190,000). Most cost savings are associated with shifting focus to
evaluate other remedial options rather than optimize the AS/SVE system. Earlier costs were
incurred for the ART well and groundwater recirculation pilot studies, which were evaluated as
potential enhancements to the AS/SVE system. Project management and reporting costs are
expected to stay steady at the reduced level in 2011 and 2012.
|
Implemented Specific capacity of wells was calculated for the 2009 Annual Report and will be calculated for
the 2010 Annual Report. There will not be a significant increase in effort or cost associated
with these calculations.
Declined VFDs had been looked at during design, but were ruled out because they would not lead to a
significant cost impact.
^^^m
Implemented The site team is focusing on pinpointing the source, determining the best way to treat source
area contamination, and reducing the amount of O&M and pumping time needed. Soil
investigations at the OHM facility and two other dry cleaners to the south indicate that higher
levels of contamination exist below the other two buildings.
Implemented The site team prepared a Focused Feasibility Study, and a ROD Amendment and a Remedial
Design start are planned by the end of the 3rd quarter of 2012.
OSWER 9283.1-38 Appendix
July 2012
Page 27 of 37
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RSE Recommendations and Progress Toward Implementation
Region 8
Site Name: Central City/Clear Creek, Argo Tunnel (Idaho Springs,
CO)
Recommendation
Remedy Effectiveness
6.1.1 Evaluate and decide on need for
blowout prevention
6.1.2 Evaluate importance of complete
collection and treatment of the Virginia
Canyon ground water
6.1.3 Evaluate indoor air quality for metals
and confirm medical monitoring for plan
workers
Cost Reduction
6.2.1 Install new filter presses
6.2.2 Realize savings from improved
operations
6.2.3 Improve metals treatment by solids
recycling
Technical Improvement
6.3.1 Reduce discharge of recycled solids
and high pH water to equalization basins
6.3.2 Improve lime feed system
6.3.3 Provide additional compressed air
capacity
6.3.4 Reduce solids wasting flow rate
Status
In progress
In progress
Alternative
Implemented
In progress
Alternative
Implemented
Under
Consideration
Alternative
Implemented
EPAID#: COD980717557
RSE Report: EPA-542-R-07-019 (September 2007)
Progress since the previous progress report
An entry into the Argo Tunnel occured on 5/3/2011. The entry team only made it in about 125
feet due to sediment buildup. A conceptual design was prepared and submitted to the State and
EPA in November 2011. It estimated the cost of construction for a bulkhead at $413,000. The
State is preparing a Request for Qualifications to hire a design engineer.
Implemented No further comment.
Implemented
The State has amended the contract with the engineer to design the conversion of the process to
a HDS system. The additional design cost is $363,800. The design is approximately 60%
complete. The estimated construction cost has increased to $2,550,000. Once design is
complete, the State will request funds to construct the process modifications.
No further comment.
See update in 6.2.1.
Implemented No further comment.
No further comment.
The design for conversion to a HDS system includes installation of a blower to provide aeration
to the process. If the conversion is implemented, additional compressed air capacity will likely
not be required.
OSWER 9283.1-38 Appendix
July 2012
Page 28 of 37
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RSE Recommendations and Progress Toward Implementation Region 8
Site Name: Central City/Clear Creek, Argo Tunnel (Idaho Springs, EPAID#: COD980717557
C°) RSE Report: EPA-542-R-07-019 (September 2007)
Recommendation Status Progress since the previous progress report
6.3.5 Consider construction of an on-site In progress See update in 6.2.1
solids disposal repository as a contingency
to disposal at a landfill
6.3.6 Additional improvements In progress The additional permanent lime storage is still on hold because they have lower funding priority
than the other items.
OSWER 9283.1-38 Appendix July 2012 Page 29 of 37
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RSE Recommendations and Progress Toward Implementation
Region 9
Site Name: Modesto Ground Water Contamination (Modesto, CA)
Recommendation Status
Remedy Effectiveness
6.1.1 Monitor subsurface performance of Implemented
SVE system
6.1.2 Assign responsibility for evaluating Implemented
monitoring and performance data
6.1.3 Analyze capture zone Implemented
6.1.4 Delineate plume (if necessary) Implemented
Cost Reduction
6.2.1 Consider alternate discharge locations Declined
- Discharge to storm sewer
- Reinject to subsurface
6.2.2 Simplify system (remove equalization Implemented
tank, simplify filtration system, and remove
transfer pump)
6.2.3 Regularly evaluate need for ion Implemented
exchange units
Technical Improvement
6.3.1 Relocate vacuum breaker Implemented
6.3.2 Install varying for backwashing carbon Implemented
and ion exchange units
6.3.3 Monitor extraction well performance Implemented
6.3.4 Modify SVE system to address high Declined
operating temperatures
6.3.5 Regularly evaluate need for vapor Declined
phase carbon
6.3.6 Properly convert PID readings to PCE Implemented
concentrations
6.3.7 Improve accuracy of SVE flow Implemented
6.3.8 Adjust membrane around Baker tank Alternative
Implemented
EPAID#: CAD981997752
RSE Report: EPA-542-R-02-008o (December 2001)
Progress since the previous progress report
OSWER 9283.1-38 Appendix
July 2012
Page 30 of 37
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RSE Recommendations and Progress Toward Implementation
Region 9
Site Name: Modesto Ground Water Contamination (Modesto, CA)
Recommendation
Status
EPAID#: CAD981997752
RSE Report: EPA-542-R-02-008o (December 2001)
Progress since the previous progress report
6.3.9 Improve drainage to secondary sump Implemented
6.3.10 Add fans to the control panel Implemented
6.3.11 Relocate vapor phase carbon for the Implemented
groundwater treatment system
6.3.12 Add phone line for data acquisition Implemented
Progress Toward Cleanup Goals
6.4.1 Initiate screening of final remedy In progress
6.4.2 Measure DO and ORP in monitoring Implemented
wells
Discovery of possible new source area requires additional investigation and will delay the FS
and selection of final remedy.
OSWER 9283.1-38 Appendix
July 2012
Page 31 of 37
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RSE Recommendations and Progress Toward Implementation
Region 9
Site Name: Pemaco Maywood (Los Angeles County, CA)
Recommendation
Remedy Effectiveness
6.1. IB Add monitoring well in D-zone
6.1.1A Potentially add pumping or
monitoring wells in C-zone.
6.1.2 Collect vapor sample from trunk line
VE-1 to assess vapor intrusion risk
Cost Reduction
6.2.1 Reduce monitoring well sampling
from 374 to 192 or fewer samples per year.
6.2.2 Reduce process sampling of water
from about 120 to fewer than 52 per year
and vapor from 168 to fewer than 40 per
year
Status
Planned
Implemented
Implemented
Implemented
6.2.3 Reduce vapor extraction points (SVE Implemented
and DPE) from about 55 to about 25.
Rebound test well groups. Reduce
groundwater extraction points from about 56
to about 24 (including 3 DPE points).
Reduce blower use. Simplify system.
EPA ID#: CAD980737092
RSE Report: EPA-540-R-11-005 (July 2011)
Progress since the previous progress report
The site team is planning to install a new D-zone monitoring well by April 2012. The cost for
the new well is expected to be $37,200 which is $17,200 more than the RSE estimate.
Implemented The site team converted a C-zone monitoring well into an extraction well to increase pumping.
The site team sampled all 7 of the wells along the VE-1 line (as well as the 48 vapor extraction
wells). The sampling indicated that vapor intrusion is not an issue in this location. The
sampling cost about $5,000 which is within the $15,000 RSE estimate that included contingent
sampling.
The site team reports that sampling has been reduced from 432 wells costing $442,800 per year
to 206 samples per year (73 wells sampled semiannually and 15 wells sampled quarterly). The
site team projects a savings of about $230,000 per year associated with this reduction; this is
more than the $ 145,000 or greater savings estimated in the RSE because the original number of
samples had been underestimated in the RSE.
On the call, the site team reported that they are currently evaluating the recommended reduction
to eliminate sampling influent headers and intermediate process locations that are not useful for
system operation decisions. Since the call, the site team further evaluated reducing process
sampling and has reportedly decided to eliminate all sampling of influent headers and
intermediate process locations for both vapor and groundwater, as per RSE recommendations.
As of this date, only combined influent and effluent samples will be collected monthly at a
potential savings of about $54,000 per year in labor and ODC costs.
The site team has reduced operating vapor extraction wells to 16 and reduced groundwater
pumping to 29 wells (including 6 DPE wells) at a 17 gallon per minute total flow rate. The
system has been operated with one blower for an estimated $40,000 annual power cost savings.
The site team will consider performing rebound sampling only on well groups, as recommended
in the RSE, at an expected savings of $28,000. The site team already considered using an
existing "polishing blower" once DPE wells are no longer in use, but determined it would not
produce the necessary vacuum. The design engineer will consider using a smaller blower (37
hp) to replace the currently operating (75 hp) liquid ring blower. He will also consider how to
simplify the control system and enhance the efficiency of the bag filtration system to reduce
labor costs.
OSWER 9283.1-38 Appendix
July 2012
Page 32 of 37
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RSE Recommendations and Progress Toward Implementation
Region 9
Site Name: Pemaco Maywood (Los Angeles County, CA)
Recommendation
Status
EPA ID#: CAD980737092
RSE Report: EPA-540-R-11-005 (July 2011)
Progress since the previous progress report
6.2.4 Reduce operator labor to one FTE or In progress
less. Eliminate manned off-hour security.
6.2.5 Reduce project management costs. In progress
Technical Improvement
6.3.1 Improve reporting Implemented
Progress Toward Cleanup Goals
6.4.1 Establish SSRLs for determination of Implemented
SVE well closures and resample at baseline
locations for remediation confirmation
Green Remediation
6.5.0 Use local staff for groundwater Declined
monitoring
The site team reports that they have reduced plant personnel from three full-time to two full-
time and one part-time staff at a savings of about $36,000 per year based on the $820,000 per
year costs reported during the RSE and the $392,000 for six months of O&M reported for the
follow-up call. Further reductions have not been made due to the high volume of maintenance,
the frequency of process data collection which has not been reduced, and site policy of having
2-person crews perform O&M. Off-hour security also remains because of concerns regarding
vandalism and other crime in the area. The site team is currently evaluating other methods for
achieving adequate security without manned personnel. In addition, the team is looking at ways
of further reducing operator labor, as suggested by the RSE.
The RSE recommendation was to reduce project management (including technical support and
reporting) costs in line with the simplified system and reduced monitoring from about $400,000
per year to achieve costs of $150,000 peryearorless.The site team notes that ongoing costs
were reduced in the second half of 2011 and optimization efforts continue. Project
management costs were about $152,000 for the second half of 2011 or about $304,000 per year.
The site team noted that the reporting improvements began with 2011 reports and represent a
$60,000 portion of the project management costs.
The site team is currently using a total VOC level of about 100 ppbv to decide vapor extraction
well status and agreed that a more formal standard would be useful for further decisions. The
site team resampled the baseline locations and found only three locations above action levels.
The site team reported that staff from San Diego (rather than northern California as reported in
the RSE) are conducting the monthly process sampling.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 10
Site Name: Northwest Pipe & Casing (Clackamas, OR)
Recommendation
Remedy Effectiveness
Status
6.1.1 Improve delineation of Plume 1 to the Implemented
south
6.1.2 Finalize institutional controls (ICs) on Implemented
Parcel A
6.1.3 Continue/conclude efforts to evaluate Implemented
potential for vapor intrusion on Parcel A
Cost Reduction
6.2.1 Eliminate operation of GCWs Implemented
Technical Improvement
6.3.1 Revise sequencing for collecting site- Implemented
wide water level data
Progress Toward Cleanup Goals
6.4.1 Clarify and document goals for active In progress
remediation
6.4.2 Implement in-situ bioremediation to In progress
reduce highest VOC concentrations, in
conjunction with natural remediation
EPA ID#: ORD980988307
RSE Report: EPA 542-R-07-018 (September 2007)
Progress since the previous progress report
ICs were finalized for the Northwest Development Company portion on Parcel A in October
2010.
There are no outstanding issues concerning the Vapor Intrusion issue at the ODOT property.
Vapor Intursion Risk Assessment found risk to within the acceptable range.
The site team continues to monitor removal action, will be completing modeling to help
determine how to proceed. Modeling should be completed by 4th quarter FY12.
FS will be completed in FY 2012, expect ROD amendment by end of 2013, based on the
removal action and the addition of the soil ammendment it is unlikely that additional action will
occur at the site except for monitoring.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 10
Site Name: Boomsnub/Airco (Hazel Dell, WA)
Recommendation Status
Remedy Effectiveness
^^^^^^^^H
6.1.1 Conduct a hydro-geological analysis Implemented
6.1.2 Evaluate potential management Implemented
options for extraction and discharge
6.1.3 Considerations for potential extraction Implemented
and discharge options
6.1.4 Consider other discharge options Implemented
Cost Reduction
6.2.1 Eliminate ion exchange effluent tank Implemented
and pump
6.2.2 Improve electric work for air stripper Implemented
Technical Improvement
6.3.1 Consider limitations of passive Implemented
technologies
6.3.2 Develop an exit strategy In progress
EPA ID#: WAD009624453
RSE Report: EPA-542-R-02-016 (September 2002)
Progress since the previous progress report
We are addressing an orphan in-coming TCE plume that does not appear to be related to the
sources of the Superfund site. This is delaying the finalization of an exit strategy.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 10
Site Name: Wyckoff/Eagle Harbor (Bainbridge Island, WA)
Recommendation
Remedy Effectiveness
6.1.1 Select a final remedy
Cost Reduction
6.2.1 Simplify existing treatment plant
6.2.2 Install upgradient sheet pile
Status
Implemented
Implemented
Declined
6.2.3 Remove steam injection/ extraction Planned
system and apply cap
6.2.4 Conduct water budget analysis Implemented
6.2.5 Upgrade extraction system Implemented
6.2.6 Replace the existing treatment plant Implemented
6.2.7 Augment monitoring in lower aquifer Implemented
Technical Improvement
6.3.0 Other related items
- Improve monitoring approach
- Monitor seeps on beach
- Consider new extraction points
Planned
EPA ID#: WAD009248295
RSE Report: EPA-542-R-05-013 (March 2005)
Progress since the previous progress report
Groundwater extraction system upgrades were completed in Fall 2011. Upgrades include new
extraction well pumps and installation of groundwater level pressure transducers. Shakedown
process of GWTP will be completed in Winter 2012. Operation and maintenance of GWTP
will be turned over to the State of Washingon in April 2012, for at least a period of years while
EPA works on feasiblity analysis of completing the permanent remedy.
Completion of new GWTP made old treatment plant obsolete. Old treatment plant is being
demolished as of Winter 2011.
Fieldwork has indicated that aquitard is not present in the SE corner of the site. Groundwater
evaluations has shown that a sheet pile wall is not necessary to ensure that containment is
maintained in this portion of the site.
Cap design and construction is still on hold pending completion of feasiblity analysis of
implementing a permanent source removal remedy. Demolition of old groundwater treatment
plant completed in July 2011. Demolition of remaining existing infrastructure (steam injection
well field) is also on hold.
Replacement of existing product and water pumps and installation of pressure transducers in
monitoring wells completed in Fall 2011.
Construction of new GWTP was completed in May 2009. Old treatment plant is being
demolished as of winter 2011.
Further seep monitoring along East Beach and North Shoal areas of site is currently being
planned for Spring 2012.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 10
Site Name: Colbert Landfill (Spokane County, WA)
Recommendation
Status
Remedy Effectiveness
6.1.1 Add Monitoring Well West of CP-W3 Planned
6.1.2 Include 1,4-Dioxane in Future Planned
Residential Sampling (At Some Frequency)
6.1.3 Tighten Institution Controls Regarding Under
Groundwater Use and Document Approach Consideration
Regarding 1,4-Dioxane Detections
Technical Improvement
6.3.1 Modifications to Water Level Maps Implemented
6.3.2 Other Suggested Modifications to Implemented
Quarterly Reports
Progress Toward Cleanup Goals
6.4.1 Consider Shut-Down Test of In Progress
Remaining Active Extraction Wells
EPAID#: WAD980514541
RSE Report: EPA-540-R-11-020 (October 2010)
Progress since the previous progress report
The County plans to implement this recommendation, and will include this new monitoring well
in the work plan to be submitted for the P&T shut-down test. The work plan is expected in the
spring of 2012, with well installation potentially in summer of 2012.
The County plans to include 1,4-Dioxane in future residential sampling using the same
methodology employed for residential sampling of other site COCs.
The RPM indicated that he plans to discuss the adequacy of the existing institutional controls
with an attorney within approximately one month, and hopes to have that legal opinion within
the next three months. To date there is no cost impact associated with this recommendation,
and the extent to which any costs are incurred will likely depend on the information provided
by the EPA attorney.
The County indicated that the number of locations is too numerous to post, but is now including
all data collected during the reporting period. The County indicated there is no need to
highlight water levels from extraction wells since those are not used in the contouring. There
should be no cost impact associated with the implementation of this recommendation.
The recommendation that non-detect values be reported as below a specific detection limit such
as "<5" rather than "ND" has been implemented, and the recommendation that quarterly reports
include an executive summary to highlight significant observations or results from that quarter
is planned for future reports. There should be no cost impact associated with the
implementation of this recommendation.
The County has accepted this recommendation and plans to submit a draft work plan for the
shut-down test in spring of 2012 to be reviewed by stakeholders, with potential implementation
in summer of 2012.
OSWER 9283.1-38 Appendix
July 2012
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