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 669647 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- |