Progress Report No. 2
EPA Investigation of Cleanup Efficiencies
Contaminated Sites Paying Off
at
September 2012
EPA's Office of Solid Waste and Emergency Response, in partnership with the Office of Enforcement and Compliance
Assurance, launched in 2010, a three-year Integrated Cleanup Initiative (ICI) to identify and implement improvements to
the Agency's site cleanup programs. In November 2010, nine project management pilots in nine different states were
identified under this initiative to evaluate alternative approaches to achieving site cleanups more efficiently. These pilot
projects demonstrate region-specific best practices and new approaches to project management.
Five pilot studies have been completed to date. In several instances, tested approaches accelerated work at sites by
roughly 50% or more. Four other pilot projects are ongoing. This fact sheet summarizes the status of these nine pilots. It
is the second fact sheet in a series intended to keep program stakeholders informed of pilot progress. For further
information on each pilot, please visit the links in the paragraphs below. More details on the ICI can be found at
http://www.epa.gov/oswer/integratedcleanup.htm.
Completed Pilots Accelerate Cleanups
Davis Liquid Waste Site
SMITHFIELD, Rl - At the Davis Liquid Waste site in
Region 1, the offer of special account funds to site
potentially responsible parties (PRPs) dramatically
expedited remedial design and remedial action (RD/RA)
settlement negotiations. A consent decree was signed in
a little over seven months, or only 38% of the average
regional time frame for RD/RA negotiations. In fact, no
other settlement had been achieved more quickly in
Region 1 over the last five years. As a result, the Region
estimates that completion of all construction activity at
the site will be achieved in FY 2013, a year earlier than
otherwise expected. Further, by achieving the
negotiations in record time, the community will benefit
from a cleanup much earlier than expected; EPA will
save money that can now be directed to other site
cleanups; and, both EPA and the PRPs will save internal
resources through reduced transaction costs since
settlement was achieved months earlier than originally
planned.
Throughout the 1970's, the Davis Liquid Waste site in
EPA Region 1 accepted numerous types of liquid and
chemical wastes that were transported in drums and
bulk tank trucks and dumped directly into unlined
lagoons and seepage pits. This site was added to the
National Priorities List (NPL) in September 1983. In 1987,
EPA issued a comprehensive Record of Decision (ROD)
for the site that, among other actions, called for a source
control remedy for contaminated soils and groundwater
remediation. Litigation culminated in a series of
settlements for performance of the source control
remedy and also resulted in the creation of a site-specific
special account containing approximately $12 million.
The groundwater remedy could not be implemented as
initially planned because treated groundwater from the
pump and treat system could not be injected to create a
flushing/recirculation cell to remove contaminants
adsorbed to saturated soil. EPA evaluated a number of
other treatment technologies, and in September 2010,
amended the ROD to change the original groundwater
pump-and-treat remedy to in-situ chemical oxidation.
The purpose of this pilot was to demonstrate if the offer
of the funds available from a site-specific special account
to the PRPs would provide EPA with sufficient leverage
to expedite RD/RA settlement negotiations for conduct
of the groundwater remedy by the PRPs. EPA issued
special notice for the performance of the RD/RA for the
groundwater in January 2011 to five parties who had not
performed any work or contributed to any past
settlements and who have limited equitable share
allocations based on an earlier court decision. Due
largely to the court-assigned equitable shares, the five
parties struggled for months to reach an internal
agreement on allocation. Through use of the special
account funds as an incentive, combined with the threat
of losing special account funds and possible treble
damages, the PRP group was brought together. EPA
received signature pages from all noticed parties by the
end of July 2011. On August 10, 2011, EPA referred the
settlement to the Department of Justice for lodging,
completing the pilot study. Under the resulting consent
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decree, EPA will contribute up to $9.5 million from the
site special account toward cleanup work (i.e., at most,
only half the estimated cost of cleanup). The PRPs
agreed to undertake the work immediately and pay all of
EPA and the State's future response costs, including
oversight costs. A final report that which describes the
successful and timely completion of the pilot, and which
examines lessons learned is available at
http://www.epa.gov/oswer/docs/ici/actionl7 651713.p
df. For further information about this site, please visit
www.epa.gov/ne/superfund/sites/davisliquid.
Ellenville Scrap Iron and Metal Site
ELLENVILLE, NY -- At the Ellenville Scrap Iron and Metal
site in Region 2, the site team significantly accelerated
RD and RA through use of an "integrated project
delivery" approach that maximized efficiency of
procurement, and improved management and delivery
of design and construction services. Tested project
management approaches reduced the duration of work
compared with more traditional practices by as much as
60%. In addition, cost efficiencies associated with
reduced project duration and other efficiencies achieved
significant monetary savings. As a result of this pilot,
"construction completion" was achieved for this site
within one year of issuance of the record of decision (an
estimated two years ahead of schedule).
The Ellenville Scrap Iron and Metal site is a 24-acre,
former scrap metal reclamation facility. About ten acres
of the site were used for a variety of scrap metal
operations and battery reclamation. The site includes a
five-acre landfill composed of construction and
demolition debris, including a variety of finely shredded
wastes, scrap brick, concrete, wood and other metal
debris. An adjacent residential property was formerly
part of the facility. Associated soil contamination
resulted in the listing of this site on the NPL in October
2002. The activities identified within the scope of this
pilot include excavation of contaminated soils and
consolidation with existing waste under a newly
constructed landfill cap. Several months prior to issuing
a ROD, EPA and the U.S. Army Corps of Engineers
(USAGE) began planning pilot activities. In September
2010, EPA executed an interagency agreement with the
USAGE to provide RD and construction services through
the USAGE'S pre-placed contracts. Securing the services
of the RA contractor early on in the process provided
beneficial pre-construction technical support concurrent
with the development of the RD. Waste consolidation,
subgrade preparation, landfill backfill grading, and
installation of the landfill liner, as well as residential
property soil removal, topsoil placement and seeding
were completed in early September 2011. EPA issued a
"Preliminary Close Out Report" on September 30, 2011,
which documents that all construction activities were
completed at the site. A final report which documents
efficiencies gained and examines lessons learned is
available at
http://www.epa.qov/oswer/docs/ici/action17 656860.pdf.
For further information about this site, please visit
http://www.epa.gov/region02/superfund/npl/ellenville.
Post-construction aerial view of the Ellenville
Scrap Iron and Metal site in Ellenville, NY
South Jersey Clothing Company and Garden State
Cleaners Sites
BUENA BOROUGH, NJ -- At the South Jersey Clothing
Company (SJCC) and Garden State Cleaners (GSC) sites in
Region 2, the design and cleanup process for the
demolition and excavation portions of two site remedies
were accelerated by creating an in-house site team
which conducted the work, taking maximum advantage
of the agency's internal resources. Piloted approaches
reduced the cleanup time frame by approximately six
months by conducting the RDs and RAs in-house
compared to the more traditional approach where the
agency would task a contractor to perform the work.
Further, as a result of this pilot, three additional RA
projects were completed in FY 2011 (rather than in FY
2012).
The SJCC and GSC sites are two separate properties that
have soil contaminated with volatile organic chemicals
resulting in a commingled groundwater contamination
plume. These sites were added to the NPL in October
and March 1989, respectively. In September 2010, EPA
issued a ROD amendment which called for, among other
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actions, acquisition and demolition of the GSC building
and excavation of contaminated soils at both properties.
South Jersey Clothing Site
Garden State Cleaners Site
The SJCC and GSC NPL sites, located within
500 feet of one another in Buena Borough, NJ
This pilot was designed to accelerate the RD/RA for a
project with a clearly defined scope through the use of
in-house EPA staff. The RDs for the building demolition
and the two soil excavations were completed in June
2011 by EPA's remedial program staff with assistance
from the USAGE which completed the detailed drawings.
EPA's removal program staff directed the building
demolition, soil excavations and backfilling at both sites
and the transportation and disposal of demolition debris
and contaminated soils. Remedial and removal program
staff collaborated on the preparation of the three RA
reports that were approved on September 29 and 30,
2011. A final report on the SJCC/GSC pilot which
documents efficiencies gained and examines lessons
learned can be found at
http://www.epa.ROv/oswer/docs/ici/actionl7 668687.p
df. For further information about these sites, please visit
http://www.epa.Rov/reRion02/superfund/npl/sicc/index
.html (South Jersey Clothing Company), and
http://www.epa.Rov/reRion02/superfund/npl/Rsc
(Garden State Cleaners).
Flash Cleaners Site
POMPANO BEACH, FL -- At the Flash Cleaners site in
Region 4, the site team achieved time savings of about
50% (or one year) compared with a more traditional
cleanup approach by conducting RD and RA activities
concurrently and by using the Region's Emergency and
Rapid Response Services (flexible and pre-placed)
contract for the RA. As a result of this pilot,
"construction completion" was achieved for this site
within one year of issuance of the ROD (an estimated
one year ahead of schedule).
Between 1977 and 2001, dry cleaning operations
conducted at the half-acre Flash Cleaners site resulted in
the contamination of soil and groundwater with dry
cleaning solvents. In September 2008, this site was
added to the NPL. The September 2010 ROD called for,
among other actions, excavation and off-site disposal of
contaminated soils, installation of a soil vapor extraction
system (SVE) for removing contaminants from beneath
the existing building, and injection with an emulsified oil
substrate to enhance the natural degradation of
contaminants in the groundwater.
Completed SVE system within enclosed area
at Flash Cleaners, Pompano Beach, FL
Under this pilot, EPA tested several innovative
approaches to organizing site work to accelerate the RD
and RA by conducting elements of these processes
concurrently. For example, some RD work began prior to
completion of the remedial investigation/feasibility
study (RI/FS) and ROD to accelerate the start of RA. In
addition, the contractor prepared the soil design first,
separately from the groundwater design, to allow the
soil RA to begin earlier than it would have if the Region
had waited until both designs were completed. While
the soil was excavated and the SVE system was
constructed, the groundwater RD was completed. All
construction activities associated with the soil
excavation, installation of the soil vapor extraction
system and installation of the groundwater injection
wells were completed by August 2011. The "Preliminary
Close Out Report," was approved in September 2011,
which documents that all construction activities have
been completed at the site. A final report on the Flash
Cleaners pilot which documents efficiencies gained and
examines lessons learned is available at
http://www.epa.ROv/oswer/docs/ici/actionl7 657328.p
df. For further information about this site, please visit
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http://www.epa.gov/region4/superfund/sites/npl/florid
a/flashclfl.html.
McGaffev and Main Groundwater Plume Site
ROSWELL, NM - Dry cleaning operations between 1956
and 1963 resulted in the contamination of soil and
groundwater at the McGaffey and Main Groundwater
Plume site in EPA Region 6. A perchloroethylene (PCE)
groundwater plume now extends about 1.5 miles from
the source area and is threatening Roswell drinking
water supplies. Unsafe levels of PCE in air were found
inside buildings as a result of this contaminant's
presence in soil gas and groundwater beneath the
buildings. In September 2002, this site was added to the
NPL In September 2008, EPA issued a ROD that
addressed contaminated soil and soil gas, contaminated
air within buildings, and the contamination in
groundwater.
The original goal of this pilot was to demonstrate how
EPA might optimize the process and plans for design and
construction of the indoor vapor intrusion mitigation
system (VIMS) through involvement of "third-party"
technical experts. The scope was later changed to
include the RDs of both the VIMS and an enhanced SVE
(ESVE) system. Such optimization was expected to help
improve remedy effectiveness, reduce remedy life-cycle
costs and accelerate control of potential human
exposure to site contaminants.
The optimization team completed a technical review of
the remedial design documents for construction of the
VIMS and the ESVE system. Team recommendations
were considered by the region in revising the remedial
designs which are now complete. Off-gas from the VIMS
and ESVE systems will be treated using granular
activated carbon to remove PCE in a newly constructed
on-site treatment facility. Construction of these remedy
components is expected by the end of September 2012.
Once constructed, the systems will permit continued use
of these buildings while the remaining site remediation
work continues.
Preliminary findings suggest that efficiencies were
achieved in designing the VIMS and ESVE system through
use of the optimization team. In addition, using this
team for remedial design peer review and value
engineering resulted in efficiencies in the construction of
these components of the remedy. Further, community
engagement and support have been significant.
Numerous logistical challenges in working with active
businesses have been successfully addressed and EPA
has received positive feedback from the City of Roswell,
impacted businesses and property owners regarding the
level of communications and flexibility exercised to limit
impacts to operations. A final report documenting pilot
results and lessons learned is under development. For
further information on this site, please visit:
http://www.epa.gov/region6/6sf/6sf-nm.htm.
Trenching to accommodate vapor intrusion mitigation and
soil vapor extraction systems as recommended by the
optimization team, McGaffey and Main site, Roswell, NM
Ongoing Pilots Make Significant Progress
Four other pilot projects continue to study opportunities
to streamline approaches to project management.
Generally, these projects involve work during earlier
stages of the Superfund cleanup process (e.g., during the
RI/FS). Results from these studies are expected through
2014.
U. S. Finishing / Cone Mills Site
GREENVILLE, SC - A textile and bleaching facility was
constructed in 1903 at the 259-acre U. S. Finishing/ Cone
Mills property in EPA Region 4. Past operations have
contaminated at least 14 acres at the site and resulted in
the presence of chromium in groundwater, surface
water and sediment. In September 2011, the site was
added to the NPL.
Under this pilot, EPA established a special integrated
project team comprised of EPA, state, contractor and
community members in April 2011 in order to expedite
the site study, the development of remedial alternatives
and the selection of a site remedy (expected in
September 2013). The project is utilizing an adaptive
project management framework integrating federal,
state and contractor resources with the requisite skills
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and decision-making authority to act quickly as needs
arise. The pilot project will engage the community and
key stakeholders early and throughout the process in
order to provide transparency and an active role for
them in site cleanup and reuse decisions.
An Rl kickoff meeting with the community was held in
October 2011 to explain the Superfund process and site
activities which would be conducted as part of the Rl. A
removal action begun in October 2011 and completed in
April 2012 involved primarily the demolition and disposal
of the main mill building. The Rl is currently underway;
portions of the field work were conducted in November
2011 and January 2012. This pilot will conclude with
issuance of the final ROD, anticipated in September
2013. For further information about this site, please visit
http://www.epa.gov/superfund/sites/npl/narl835.htm.
Stream sampling at the U.S. Finishing/
Cone Mills property in Greenville, SC
Velsicol Burn Pit / Gratiot County Golf Course Site
ST. LOUIS, Ml - The Velsicol Burn Pit (formerly Gratiot
County Golf Course) site consists of approximately five
acres in St. Louis, Michigan in EPA Region 5. From 1956
until 1970, the Michigan Chemical Corporation (later
purchased by the Velsicol Chemical Corporation) burned
and disposed of industrial waste on the site, including
the pesticide, DDT. Approximately 2,000 to 3,000 gallons
of hazardous waste were disposed of on the property.
This site was first proposed to the NPL in 1982. At that
time, Velsicol removed 68,000 cubic yards of
contaminated soil. As a result, the proposed NPL listing
was withdrawn. However, in 2006, additional soil and
groundwater contamination was found. The State of
Michigan completed some additional field investigations
in January 2009 and as a result, the site was added to
the NPL in March 2010.
The objective of this pilot is to expedite the remaining
site study and alternatives development processes by
using existing data, collecting only critically important
new data, and increasing collaboration with EPA
headquarters earlier in the Superfund site remediation
process. In this way, EPA expects to streamline
significantly discussions between headquarters and the
region about remedial site study and cleanup options.
To date, EPA Region 5, EPA headquarters and Michigan
Department of Environmental Quality staffs have
reviewed existing site information to identify additional
data needs and design a field sampling program.
Sampling is currently being conducted and will continue
through fall 2012. As data become available, regional
and headquarters staffs will discuss revisions to the
human health and ecological risk assessments and issue
an addendum to the Remedial Investigation based on
the newly collected data.
Some delays have been realized as a result of difficulty
gaining access to all properties. Also, preliminary data
suggest contamination of a more complex nature and
encompassing a larger area than previously expected.
This will require an expansion of the Rl sampling
program and the need to consider additional remedial
alternatives in the FS.
Once these studies are complete and discussed with the
community and other site stakeholders, the region will
work closely with headquarters and the state to develop
and issue a proposed plan for the site. Due to the
expanded scope of the study, completion of the RI/FS is
expected in late 2013. A final ROD is planned for early
2014 which will mark completion of the pilot. For further
information about this site, please visit
http://www.epa.gov/Region5/cleanup/velsicolburnpit/.
Using membrane interface probe with direct push
platform to screen soils for presence of volatile
organic compounds at Velsicol Burn Pit, St. Louis, MI
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Van der Horst USA Corporation
TERRELL, TX - The Van der Horst USA Corporation site
(Site) is a former chrome- and iron-plating facility in EPA
Region 6 which operated from the 1950's until
December 2006. This 3.5-acre site includes the former
plating facility, wastewater treatment plant, and
associated undeveloped land. A 2009 removal action
addressed aboveground contaminated media including a
46,000 square foot building and its contents. The site
was listed on the NPL in 2010. As a result of the removal,
the RI/FS focuses on groundwater contamination.
This pilot is designed to expedite RI/FS activities through
early stakeholder collaboration aimed at fast-tracking
field work and decision making. Innovative adaptive
management techniques are being used during the Rl
field effort to minimize the number of sampling events.
The RPM and risk assessor have been on-site during the
Rl sampling activities to facilitate communication among
stakeholders, provide efficiency during the RI/FS, and
make real-time decisions in the field. In April 2011,
monitoring wells were installed and numerous soil
borings were advanced to characterize the nature and
extent of contamination. A second field mobilization was
conducted in mid-September to obtain additional soil
samples and soil gas data from the vadose zone. Some
delays were experienced as a result of difficulties in
gaining access to all properties. Additional monitoring
wells were installed in February 2012. The plume of
hexavalent chromium contaminated groundwater is
much larger than originally anticipated and the extent of
the plume requires further delineation. Also, TCE
contamination has been discovered in the shallow
groundwater; therefore the Rl has become more
complex due to the existence of two overlapping
plumes. Information obtained from these field activities
is being used to fill data gaps and refine the conceptual
site model. As a result, the completion of the RI/FS is
anticipated in March 2013. Completion of this pilot is
expected by September 2013 with issuance of the final
ROD. For further information about this site, please visit
http://www.epa.gov/superfund/sites/npl/narl810.htm.
McClellan Air Force Base
SACRAMENTO COUNTY, CA -- The 3,452-acre McClellan
Air Force Base (AFB) site in EPA Region 9 was established
in 1936 and operated as a US Air Force Logistics
Command Base with a primary mission of management,
maintenance and repair of aircraft, electronics and
communication equipment. The Air Force identified 326
waste areas of known and suspected contamination as a
result of past aircraft maintenance and repair
operations. In July 1987, the McClellan AFB was added to
the NPL. Under the Department of Defense (DoD) Base
Realignment and Closure (BRAC) program, McClellan AFB
closed as an active military base in July 2001.
The McClellan AFB pilot project centers on the third
transfer of McClellan AFB property to Sacramento
County and the developer, McClellan Business Park
(MBP) prior to cleanup. The pilot builds on the success
of the first two transfers that have resulted in expedited
site cleanup and reuse, including the creation of 600
permanent jobs and the construction of a new 30,000
square foot federal agency building. The McClellan ICI
pilot has particular national relevance given the current
DoD budget cuts and the anticipated new round of base
closures.
This "privatization" of cleanup relies on existing
regulatory and enforcement tools to construct a set of
agreements which allows the developers to complete
the cleanup work on behalf of the federal government in
a manner that is protective of human health and the
environment, while also accelerating cleanup and reuse
with overall cost savings to the government.
Privatization is effective in streamlining cleanup since it
provides dedicated funding sources and an abbreviated
dispute resolution process; however, EPA makes the
final selection of remedy decision in consultation with
the state.
Under this privatization, MBP, with oversight from EPA,
is addressing contamination in the first 15 feet of soil
below the surface, concurrent with ongoing
redevelopment efforts. The cost of this work will be paid
for by the Air Force. The Air Force will continue cleaning
up the groundwater and deeper soil.
MBP is one of the largest economic development and
infill reuse projects in northern California, with goals of
creating more than 22,000 jobs, generating over $6.6
million in local property taxes, and producing $1.1
million in local sales tax revenues. Much of this success
hinges on the promise and success of environmental
remediation that delivers fee title to sites so that
prospective employers can invest in the facilities with
the assurance of ownership. MBP is also a national
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model for successful base redevelopment with a number
of green technology companies on-site
(http://www.epa.gov/region9/annualreport/).
The McClellan AFB pilot project addresses 528 acres, 131
remediation sites and approximately 3,592,000 square
feet of existing buildings that are 48% leased. Current
estimated property tax revenue of $700,000 is expected
to increase to over $2,025,000 while current
employment (approximately 3,500) is expected to more
than double by the time the cleanup is complete.
Pilot accomplishments to date include: (1) a Federal
Facility Agreement amendment signed by the Air Force,
EPA and State of California on August 23, 2011; (2) a
finding of suitability for early transfer completed by the
AF on May 17, 2012; (3) an Environmental Services
Cooperative Agreement (funding for cleanup services)
signed by the AF and Sacramento County on June 28,
2012; (4) a McClellan Remediation Agreement signed by
Sacramento County and MBP on June 28, 2012; (5) state
land use controls covenants for deed transfer completed
by MBP and the State of California on June 30, 2012;
and, (6) an Administrative Order on Consent signed and
noticed in the Federal Register in August, 2012.
California Governor Jerry Brown is expected to approve
the transfer of property by early November 2012. For
further information about this site, please visit
www.epa.gov/region9/McClellanAFB.
Looking Ahead
Nine project management pilots were identified under
this initiative to evaluate alternative approaches to
achieving site cleanups more efficiently. These pilot
projects demonstrate region-specific best practices and
new approaches to project management. In many cases,
creative, nontraditional approaches for managing site
cleanups are being explored with exceptional results. In
some instances, site teams have achieved significant
efficiencies not typically realized, national program
performance indicators have been achieved a year or
more sooner than otherwise planned, and cleanups have
been achieved (or can be expected) much earlier than
previously expected. In many cases, business process
innovations are returning property to communities
sooner, accelerating the potential for reuse and the
creation of new jobs. "Lessons learned" from these pilots
have been shared with OSWER executive management,
the Office of Management and Budget, the Superfund
remedial action contracting community, and on national
conference calls with the regional Superfund and
enforcement division directors, branch chiefs and other
program personnel. More formal training sessions
designed to discuss broader application of piloted
approaches are planned for the National Association of
Remedial Project Managers training conference later in
2012. In addition, these lessons learned are now shaping
the development of new Superfund contracts, policies
and tools that can be used to speed cleanup at other
sites.
Reuse after privatized cleanup at the former McClellan Air
Force Base, Sacramento County, CA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
7
OSWER 9200.2-116
September 2012
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