\ 31 «-^^^»-" "» O OSWER 9283.1-38 * July, 2012 Groundwater Remedy Optimization Progress Report: 2010 - 2011 Office of Superfund Remediation and Technology Innovation ------- 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 ------- 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 ------- This page intentionally left blank. ------- 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 ------- 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 ------- 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 July 2012 OSWER9283.1-38 ------- 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 ------- 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. July 2012 OSWER9283.1-38 ------- 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 ------- 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 ------- 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 ------- 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. July 2012 OSWER9283.1-38 ------- 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. 10 July 2012 OSWER9283.1-38 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 Page 21 of 37 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 Page 33 of 37 ------- 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 Page 34 of 37 ------- 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 Page 35 of 37 ------- 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 Page 36 of 37 ------- 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 Page 37 of 37 ------- |