\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C, 20460
FE3 1 5 2013
OFFICE OF
SOLID WASTE AND
EMERGENCY RESPONSE
OSWER Directive 9200.2-129
MEMORANDUM
SUBJECT: Broader Application of Remedial Design and Remedial Action Pilot Project
Lessons Learned
FROM: James E. Woolfoid, Director/Jr/k '
Office of Superfund Remediation and Technology Innovation
TO: National Superfund Program Managers, Regions 1-10
This memorandum transmits a summary of lessons learned from three completed remedial
design (RD) / remedial action (RA) project management pilots conducted under the Integrated
Cleanup Initiative (ICI) entitled "Broader Application of Remedial Design and Remedial Action
Pilot Project Lessons Learned" (OSWER Directive 9200.2-129).
EPA regional offices have been working over the last two years on nine project management
pilots under the ICI to explore the use of best practices or new ways of improving Ihe efficiency
of Superfund remedial cleanups. Three pilot reports completed during FY12 address aspects of
the Superfund RD/RA process. In each case, significant results were achieved that saved both
time and money. The pilot studies demonstrated time savings of as much as 67% over traditional
project duration and dollar savings or cost avoidances of between approximately $135,000 and
$584,000.
Attached is a summary of the lessons learned from these three pilots that highlights strategies
that may be especially beneficial to our program. As budgets become increasingly constrained, it
is with great satisfaction that I am able to share these regional success stories. I encourage you
and your project teams to consider application of the approaches examined in these pilots
wherever appropriate.
This memorandum can be found on the OSWER ICI website under Action 17 at:
http://www.epa.gov/oswer/integratedcleanupactions,htm#Action 17. Web links to the final
reports and brief summaries of pilot results are provided below:
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South Jersey Clothing .Company / Garden State Cleaners Sites (Region 2): The region focused
on the use of in-house EPA personnel to conduct RD and RA at two neighboring dry cleaners.
Remedial, removal, Environmental Response Team (ERT), US Army Corps of Engineers
(USAGE) and Emergency and Rapid Response Services (ERRS) contract staff worked closely at
these sites to demolish a building and conduct two soil excavations. This collaboration resulted
in three remedial action project completions (RAPCs) one year earlier than planned along with
substantial cost savings even after considering the increased use of in-house payroll.
http://www.epa.gov/oswer/docs/ici/action 17_668687.pdf.
plash Cleaners She (Region 4): The region applied several approaches to compress the schedule
and accelerate completion of RD/RA work, including overlapping RD and RA activities,
separating implementation of the soil and groundwater work activities, and using the ERRS
contract for RA to excavate soil, install an SVE system, and address a VOC plume through
enhanced bioremediation at a dry cleaners site. The region achieved construction completion
(CC) one year earlier than expected (reducing cleanup duration by about 50% and saving as
much as 27% of construction costs), http://www.epa.gov/oswer/docs/ici/action 17_657328.pdf.
Ellenvilie Scrap Iron and Metal Site (Region 2): Working closely together, HQ and the region,
USAGE and their contractors developed and applied an innovative project delivery technique
("focused project integration") to excavate and consolidate soil from the 24-acre Ellenvilie
property into a capped, 10-acre area. A RAPC was accomplished in about a third the time
originally expected, and at reduced cost.
http://www.epa.gov/oswer/docs/ici/action 17_656860.pdf.
A summary of progress for all nine pilots can be found at the following website:
http://www.epa.gov/oswer/docs/ici/action 17_11 -669647.pdf.
Again, many thanks to all that contributed to these substantial efforts.
If you have any questions, please call me or have your staff call Bruce Means (OSRTI) at (703)
603-8815 or John La Padula (Region 2) at (212) 637-4405.
Attachment
cc: Mathy Stanislaus, OSWER
Lisa Feldt, OSWER
Barry Breen, OSWER
Barnes Johnson, OSRTI
Becki Clark, OSRTI
Robin H. Richardson, OSRTI
Pamela Barr, OSRTI
OSWER Office Directors
David Kling, FFEO
Elliott Gilberg, OSRE
Nancy Jones, OSRTI
Thea Williams, OSRTI
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Integrated Cleanup Initiative
Remedial Design and Remedial Action Pilot Projects
Lessons Learned
(February 13, 2013)
1.0 Introduction
In 2010, EPA's Office of Solid Waste and Emergency Response (OSWER) in partnership with the
Office of Enforcement and Compliance Assurance (OECA) initiated a three-year strategy, the Integrated
Cleanup Initiative (ICI), to identify and implement improvements to the Agency's land cleanup
programs. The Initiative identified opportunities to integrate and leverage the Agency's authorities to
accelerate cleanups, address a greater number of contaminated sites, and put these sites back into
productive use while protecting human health and the environment.
In November 2010, OSRTI identified nine project management pilot studies under this Initiative to
evaluate approaches to achieving site cleanups more efficiently. These pilots were selected to
demonstrate region-specific best practices and new approaches to project management for the Superfund
remedial program. This paper presents an overview of the strategies and measures explored under three
pilots that studied ways to accelerate work during the remedial design (RD) and remedial action (RA)
phases of cleanup. These pilots all resulted in time and cost efficiencies. Successful strategies evaluated
were: compressing project schedules by conducting concurrent or overlapping RD and RA activities;
relying more fully on in-house resources to achieve cleanups; the judicious selection and use of
contractors and contract types; use of sampling strategies that minimize analytical and field mobilization
costs; and, enhancing collaboration among partners and stakeholders to facilitate resolution of issues and
concurrence on site management approaches in real time. Descriptions of how these practices were
employed for the three pilots may be found in the final reports cited below.
The pilot reports indicate that significant time savings and cost savings or avoidances can result from
using these innovative measures compared to traditional approaches. While these pilots were conducted
at fund-lead sites, many of the measures explored may also have value and could result in cleanup
efficiencies at sites where cleanups are undertaken by private parties or federal facilities. It is
recommended that site managers consider use of these practices at sites wherever appropriate.
2.0 Background and Description of Pilots
In October 2010, at the request of the Director of the Office of Superfund Remediation and Technology
Innovation (OSRTI), a workgroup comprised of senior management (e.g., deputy division directors)
from each EPA regional office, OSRTI, the Office of Site Remediation and Enforcement (OSRE), and
the Federal Facilities Restoration and Reuse Office (FFRRO) met to review regional pilot nominations.
Recommendations were developed for the OSRTI Office Director based on their potential to impact the
quality, transparency, and /or speed of cleanups broadly across the Superfund remedial program. For this
reason, projects that were of manageable size, that required only moderate financial resources and that
were expected to be completed within a reasonably short time frame (e.g., one to two years) were given
priority in the selection process.
The three pilot projects chosen to evaluate nontraditional approaches to achieving site cleanups more
efficiently for sites approaching RD and RA included the Ellenville Scrap Iron and Metal site in
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Wawarsing, New York; the Flash Cleaners site in Pompano Beach, Florida; and the South Jersey
Clothing Company and Garden State Cleaners sites in Buena Borough, New Jersey.
2.1 Ellenville Scrap Iron Metal Site, Region 2, New York
The Ellenville Scrap Iron and Metal site in EPA Region 2 was 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 included a five-acre landfill composed of construction and demolition debris,
including brick, concrete, wood and metal debris. An adjacent residential property was formerly part of
the facility. Associated soil contamination resulted in the listing of this site on the Superfund National
Priorities List (NPL) in October 2002. The activities identified within the scope of this pilot included
excavation of contaminated soils and consolidation with existing waste under a newly constructed
landfill cap in accordance with the September 2010 Record of Decision (ROD).
This pilot was designed to accelerate the RD and RA through an "integrated project delivery" approach
which sought to maximize efficiency of procurement, management and delivery of design and
construction services while maintaining safety and technical quality. Key elements of the pilot included
early construction contractor involvement, collaboration among all team members and shared
acceptance of project objectives and risk. As a result of the pilot, RA construction activities were
accomplished in about a third of the time originally expected (i.e., within one year), and at reduced cost
(saving approximately $584,000). The pilot report may be found at
http://www.epa.gov/oswer/docs/ici/acti onl7_656860.pdf.
2.2 Flash Cleaners Site, Region 4, Florida
Between 1977 and 2001, dry cleaning operations conducted at the half-acre Flash Cleaners site resulted
in the contamination of soil and groundwater with 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 (SVE) system for removing contaminants from
beneath the existing building and injection of an emulsified oil substrate into groundwater to enhance
the natural degradation of contaminants.
The purpose of this pilot was to demonstrate that conducting components of the RD and RA activities
concurrently and utilizing the Emergency and Rapid Response Services (ERRS) contract for the RAs
can result in time and cost efficiencies and shorten the amount of time to reach construction completion.
At the Flash Cleaners site, the Region achieved construction completion for the site one year earlier than
expected (reducing cleanup duration by about 50% and saving as much as 27% of construction costs or
approximately $135,000). The pilot report may be found at
http://www.epa.gov/oswer/docs/ici/action!7_657328.pdf.
2.3 South Jersey Clothing Company (SJCC) and Garden State Cleaners (GSC) Sites,
Region 2, New Jersey
The SJCC and GSC sites in EPA Region 2 are two separate properties within 500 feet of each other
where soil contaminated with volatile organic chemicals (VOCs) resulted in a commingled groundwater
contamination plume. The GSC site supported a former dry cleaning business which began operating in
1966 and until 1985 discharged wastes through pipes directly into the ground. In 1940, the SJCC facility
began manufacturing and dry cleaning military clothing using solvents and also discharged waste on
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site. These sites were added to the NPL in October and March 1989, respectively. The 1991 ROD for
these sites called for SVE to remediate VOC-contaminated soils at both properties and a groundwater
extraction and treatment system located at the SJCC property to address the commingled plume.
Investigations during the long-term response action for groundwater remediation indicated that the SVE
systems used at both sites did not sufficiently address the VOCs in the soil and that these residual VOCs
continued to act as a significant source of groundwater contamination. 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.
This pilot was designed to demonstrate efficiencies in time and cost that result from using in-house
(EPA) resources where possible to perform the RDs and RAs for the demolition of the GSC building
and the excavation of the shallow soil contamination at both the GSC and SJCC sites. As a result of the
study, three remedial actions were completed one year earlier than planned and substantial cost savings
were achieved (approximately $485,000) even after considering the in-house payroll costs. The pilot
report may be found at: http://www.epa.gov/oswer/docs/ici/action!7_668687.pdf.
3.0 RD/RA Pilot Project Techniques and Lessons Learned
In evaluating results, the piloted measures were compared to more traditional approaches to project
management. Results from all three pilots were considered in developing lessons learned that may be
applied more broadly across the Superfund remedial program. A common objective of all of the pilots
was to complete RD and remedial construction activities within a year after the ROD was issued (i.e., by
September 30, 2011). Notably, this goal was achieved for all three pilots.
The following is a summary of the techniques employed and lessons learned from the three pilots and
their potential for broader application to remedial sites. Remedial Project Managers (RPMs) and site
teams are strongly encouraged to consider these techniques as early as possible (even prior to issuance
of the ROD where appropriate) in planning for RD and RA.
3.1 Early Assurance of RA Project Funding
Of particular significance, OSRTI's' assurance of RA funding for these projects either before the ROD
was signed (as in the case for the Ellenville site) or soon after (as with the Flash Cleaners, SJCC and
GSC sites) was key in facilitating the regions' ability to accelerate the RD and RA processes. Typically,
projects are delayed (from several to many months) between the RD and the time that RA contractor
procurement begins as sites await "priority" assessment and receipt of RA funding. In all cases, the
early assurance of pilot funding improved overall project management efficiency by allowing project
planning and schedules to reflect project completion rather than interim milestones.
Where early assurance of RA funding for a given project is likely to accelerate site cleanup significantly,
site managers are encouraged to discuss such opportunities with their regional management. It may be
reasonable for a region to request early assurance of RA funding from OSRTI. A favorable OSRTI
decision would depend on a number of factors including the availability of funding and competing
priorities.
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3.2 Project Planning and Management Strategies
Several lessons learned involve early-planning decisions that affect the overarching strategy selected to
address site contamination. These decisions will be shaped by site conditions and engineering challenges
presented by the nature and extent of contamination, and by the availability of program funding, EPA
staff availability and expertise, contract types available, and contract accessibility and capacity.
3.2.1 Use of in-house resources
Both headquarters and regional management recognized the benefits of enhancing the traditional
roles of their staffs for work on the pilots. Using in-house resources saves time and costs by
avoiding both internal EPA efforts necessary to task a contractor for specific services as well as
the contractor's cost and other fees.
For the SJCC/GSC sites, much of the work ordinarily conducted by EPA's remedial action
contractor (RAC) or the US Army Corps of Engineers (USAGE) was accomplished by EPA
staff. EPA Region 2's remedial staff prepared streamlined RDs for the soil excavation work for
both sites. OSRTI's Environmental Response Team (ERT) provided design sampling support to
refine the assessment of soil contamination. Analytical support was provided by the Region 2
laboratory and ERT's fixed and mobile laboratories (both operated by ERT's Scientific,
Engineering, Response and Analytical Services (SERAS) contractor). Remedial and removal
program staff prepared a streamlined RD for the demolition of the GSC building. A regional On-
Scene Coordinator (OSC) directed the ERRS contractor's demolition of the building and soil
excavations at both properties. The Region's RPM prepared the RA reports for all three
activities. Comparing the actual costs of the RDs and RAs to a cost estimate for a more
traditional approach (i.e., a RAC scenario) suggests a cost savings or avoidance of about 50% in
remedial design costs and 30% in remedial action costs, or about 40% overall. Had the Region
used a RAC contractor to conduct the design and to procure and manage a constructor, the
Region may have spent as much as $478,000 more on design and construction costs. The greatest
dollar savings were realized through the use of in-house staff to conduct RD and RA project
planning and report preparation. In addition, the use of in-house resources is estimated to have
accelerated project completion by approximately six months.
For the Ellenville site, OSRTI assigned a senior RD/RA expert to support the Region and to
facilitate and coordinate pilot activities at the site. Recognizing that the Ellenville site would
present a significant challenge due to the areal extent of contamination and the magnitude and
scope of the remedy, this individual provided "boots-on-the-ground" support. While a customary
approach for OSRTI coordination with regional offices may involve only periodic project
reviews and consultation on selected issues with an occasional (if any) site visit, the OSRTI
coordinator role for Ellenville involved regular meetings with the site team, and numerous site
visits during the year-long pilot. Overall, the site team believes this individual was very effective
in providing much needed support for regional project management activities and in
troubleshooting issues requiring OSRTI assistance (e.g., funding requests) and as such was
critical to the success of the pilot.
For the Flash Cleaners site in Region 4, the Region used its removal contractor (ERRS) to
conduct all three components of the remedial action. The RPM served in the role of the OSC and
oversaw the construction activities associated with the soil and groundwater remedies.
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Traditionally, construction management and oversight activities are managed by a RAC
contractor or the USAGE. The Region estimates that it may have spent as much as $135,000 (or
27 %) more had a RAC contractor been used for the RAs.
3.2.2 Strategic use of contract support
Site managers should consider which contracting mechanism may be most efficient given site-
specific circumstances, the nature of the work to be conducted and associated uncertainties.
Use of preplaced contracts (e.g., RAC, ERRS) for RD and RA can streamline the
delivery of support services and improve the overall cost effectiveness of projects by
avoiding the time involved in placing site-specific procurements. EPA considers the
ability to access rapidly prequalified firms which have significant hazardous waste
experience and a proven track record on specific types of work such as RD, RA or long-term
response actions to present significant advantages for Superfund site remediation. In
particular, preplaced contracts are available for use as EPA's funding becomes available. For
these reasons, most of the remedial program's contracts are of this nature. The agency's
acquisition strategies seek to preplace contracts with specific expertise that can be used when
needed to support site work. However, not all preplaced contracts are appropriate for every
type of work. Site managers should consider the specific nature and scope of work to be
conducted at a given site as well as the timing and availability of funding in planning for
remediation. In fact, it may be significantly less efficient to use one contract type over
another depending on circumstances.
In each of these three pilots, regions relied on preplaced, prequalified contractor support to
conduct the work. However, site managers used nontraditional contract types. At Flash
Cleaners, Region 4 used its RAC contractor to perform the RDs and its ERRS contractor to
conduct the RA. For the SJCC/GSC sites, Region 2 used ERT's SERAS contract for
assessment of soil contamination and its own ERRS contractor to conduct the RAs. For the
Ellenville pilot, the preplaced contracts used for RD and RA were held by the USAGE and
were accessed through an Interagency Agreement (IA).
Use of cost-reimbursable type task orders (e.g., time and materials, indefinite delivery
/indefinite quantity) can provide important response flexibilities in the field where new
sources of contamination may be discovered, site conditions may change or challenges
arise unexpectedly. The cost-reimbursement type contracts used for work under each pilot
allowed the project teams to respond to changed conditions without the need for contractual
modifications.
Use of the ERRS contracts for RA provides the Agency direct access to construction
expertise which can reduce or eliminate administrative costs and time associated with
subcontracting such expertise. Regions 2 and 4 used their preplaced and flexible ERRS
contracts to accelerate delivery of RA construction services, facilitate real-time site cleanup
decision making and reduce acquisition expenses. This contract type may be especially
appropriate for RA activities that are relatively straightforward. Using the ERRS contract to
implement the RAs saved time and money when compared, for example, with using the RAC
for construction. Because the ERRS contract is designed to provide construction services, the
ERRS contractor performs most of the work (with oversight by EPA) using its own
construction personnel (e.g., response managers, operators, cleanup technicians). Moreover,
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because the ERRS contract is designed to allow EPA to respond quickly, the ERRS
contractor can mobilize in the field in anywhere from several hours to one or two days
depending on the scope of work and site circumstances. Also, as work progresses and field
conditions change due to unanticipated events or new information, the ERRS contract SOW
can be modified immediately upon need.
In contrast, the RAC was designed to assist EPA in conducting longer-term activities, such as
RI/FSs and more complex RDs and RAs, which require developing a more detailed SOW
and work plan and negotiating the scope and cost of the effort. This may take a week or two
or more and would require EPA to devote additional staff time as well as pay for the
contractor for its time during this process. Also, because the RAC was not designed to
perform construction activities directly, it must subcontract the construction work to another
firm which requires additional procurement time. Consequently, the RAC process costs the
Agency more money than it would incur if the ERRS contractor were used, as EPA would be
paying both contractors to get the work done. Further, as field conditions change or new
information comes to light, modifications and/or expansion of the SOW must be negotiated,
a process which may take several days, or even weeks or more (depending on the changes to
be negotiated). The discovery and management of the underground storage tanks found at
both the GSC and Flash Cleaners properties would have taken longer and cost more under a
RAC scenario since the change in scope and cost would have had to have been negotiated.
As a result, there were time savings of several months immediately realized by using the
ERRS contract for this work.
Use of the RI/FS contractor (e.g., RAC) to conduct the RD may save time and money. For both
the Ellenville and the Flash Cleaners sites, the RD contracts were awarded to the RAC
contractor which had conducted the RI/FS. Having these contractors familiar with the sites
and the nature and extent of contamination saved time in beginning the RDs.
3.2.3 Use of parallel (versus sequential) work schedules
Certain elements of the RD and RA were conducted concurrently at the Flash Cleaners and
Ellenville sites which both facilitated and reinforced the need for collaboration between the RD
and RA contractors from design through RA. At Flash Cleaners, the RD contractor prepared the
soil design separately from the groundwater design which permitted the soil RA to begin as soon
as the soil design was substantially complete. While the ERRS contractor was on site conducting
the soil RA, the groundwater RD was completed. The Region then tasked the ERRS contractor to
implement the groundwater RA. At the Ellenville site, the Region initiated planning for
construction during the RD. As a result, the construction contractor was able to identify
subcontractors and material suppliers, and begin developing the construction schedule early in
the project. Further, the RA workplan was prepared during the remedial design. Conducting
certain elements of the RDs and RAs concurrently may significantly compress the overall project
schedule for a site.
3.3 Working Relationships among Project Team Members
A key factor in the success of each pilot was the collaboration, communication and commitment among
partners to achieve the common goals of the project. In general, relationships involving all team
members and partners were developed early and continued throughout the pilot process with the goal of
achieving project completion, rather than individual milestones (such as a specific activity or project
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deliverable). Based on the results of the three pilots, RPMs are encouraged to develop strong working
relationships among site team members.
3.3.1 Collaborative approaches to project completion
Pilot results suggest that planning for early collaboration among site team members and defining
expectations for each member were integral to obtaining their commitment to the project, its
work schedule and its ultimate success.
For example, at the Ellenville Scrap Iron and Metal site, team members signed an informal
partnering agreement to foster collaboration, demonstrate commitment and promote shared
acceptance of project objectives and risk. Signatories included EPA's OSRTI and regional staffs,
the USAGE and its contractors and representatives of the New York State Department of
Environmental Conservation (NYSDEC). As part of its commitment, the NYSDEC assigned
dedicated staff early in the process. This early state involvement avoided schedule delays to
either meet state requirements or allow for state decision making. Of particular note, was the
NYSDEC's willingness to ensure that the RD was in conformance with state permit
requirements. NYSDEC agreed that with approval of the final RD, permit equivalences
(typically applied for after the final RD is completed) for the RA would be approved as well. The
RD met the substantive requirements of major permits for a soil erosion and sediment control
plan, community air monitoring plan, storm water pollution prevention plan (state pollutant
discharge elimination system), wetlands mitigation and solid waste facility closure.
As project challenges presented themselves, the integrated management approach used for the
Ellenville pilot made decision making a collaborative and more efficient process often avoiding
problems before they occurred. The work was also managed to achieve project completion as
opposed to more traditional interim milestones (e.g., a 65% design document). The team used a
process called "focused project integration" which allows informed decision making early in the
project where significant value or savings can be gained.
At the Flash Cleaners site, the RPM established collaborative relationships among all site team
members (including the state and RD and RA contractors) which provided focus on common
goals, procedures and cleanup outcomes that were consistent with expectations of the team
members. The site team also worked hard to establish a high level of trust with the community.
This facilitated EPA's ability to use innovative approaches (e.g., early planning for RA, use of
enhanced bioremediation for contaminated groundwater) to streamline traditional remedial
action at the site. Further, the RPM's frequent on site presence demonstrated team commitment
and dedication to collaborative processes, and it facilitated real-time decision making and the
ability of the team to react to the unexpected (e.g., newly discovered underground storage tanks).
At the SJCC/GSC sites, many team members contributed to the RD and RA. The regional
remedial and removal staff, drawing on the services of the ERT and the USAGE, worked closely
together over a short period of time to accomplish the cleanup. In order to do so, effective
collaboration and communication among site team members was critical. It facilitated field work,
development and review of documents, information sharing, and strengthened accountability for
meeting deadlines. In addition, since the RDs were completed in-house with the RPM and the
OSC's preparing the building demolition RD and the RPM's preparing the soil excavation RDs,
these staff were familiar with the details of the RDs and able to provide RA contractor oversight
and direction in the field, resolving issues in real time as they arose.
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3.3.2 Enhanced communication between RA contractor and RD contractor
Having team members primarily responsible for RD activities in early and close communication
with team members providing RA support was a critical element which contributed to the
success of all three pilots. In fact for all three pilots, team members providing RA support were
brought on early and those who performed RD activities were available during construction to
discuss and facilitate resolution of issues.
At the Ellenville site, the RA contractor was issued a task order for preconstruction services
shortly after ROD approval. The term "preconstruction services" refers to engaging the
construction contractor during the RD as opposed to hiring the services of a construction
contractor after the RD is completed. This approach allows informed decision making early in
the project where significant value or savings can be gained. Value engineering-like savings (or
cost avoidance) were achieved by obtaining input from the construction contractor during the
design phase. In addition to the cost avoidance, the schedule was accelerated as a result of the
early constructor involvement.
At Flash Cleaners, the Region tasked the ERRS contractor to provide comments on the 90% RD
for the soil remedy and to begin scoping work for remedy construction. In fact, before the 100%
soil RD was approved, the RA contractor had prepared the site-specific health and safety plan,
met with the RPM and RD contractor to discuss remedy implementation, completed the
subcontractor award process for drilling of the SVE wells and completed the soil excavation and
backfilling, thereby advancing the start of the soil remedy by six weeks. In other words, the 90%
RD was judged sufficient to permit both the start and completion of the soil excavation and
backfilling portions of the soil remedy. The Region also specifically tasked its RD contractor to
be on site during the soil and groundwater RA activities to assist the RPM during construction in
resolving any issues that arose.
At the SJCC/GSC sites, Region 2's RPM and OSC worked closely throughout the year-long pilot
planning the work schedule, collaborating on the RDs and overseeing construction activities.
This facilitated discussion and resolution of issues that arose during the project.
3.4 Project Risk Management Techniques to Minimize Unexpected Delays
Each site presents a number of site-specific project management challenges that are unique to the nature
of work required for remediation and the time it will take to achieve project completion. These include
unanticipated events or circumstances that may occur as work progresses that can delay the project
schedule. Examples are unexpected increases in contaminant volumes, the discovery of underground
storage tanks or contaminant sources and extreme weather events. The impact of such delays can be
minimized by anticipating their potential occurrence and planning appropriate response strategies and/or
ensuring that appropriate expertise is available to assist should unexpected circumstances arise. Such
contingency planning should be tailored to the complexity of site work.
For example, the Ellenville project team utilized a collaborative process that identified potentially
adverse events, estimated likelihood of their occurrence, quantified the potential impact of the events on
the project, and developed mitigation strategies in advance of their potential occurrence. These
risk/response scenarios were tracked and updated as site work progressed. A "risk register" was used to
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summarize and display these scenarios for all team members. Scenarios addressed environmental,
external, engineering/design, construction and project management risks. Time was set aside regularly to
discuss these risks and update mitigation scenarios. As a result, when unexpected situations were
encountered in the field, appropriate response decisions could be made in an expedited fashion based
upon the scenarios outlined in the risk register. Several scenarios identified in the risk register occurred
during construction at Ellenville. These included, among other things, the discovery of battery casings in
an unanticipated location (beneath an on site residential structure), increases in contaminant volumes,
the unexpected discovery of a buried tanker truck and an extreme weather event (hurricane-force winds
and rain). The site team estimated that the mitigation strategies in place as a result of the risk register
minimized schedule impacts by approximately one month, a significant amount of time given the pilot's
duration of just over one year.
At the Flash Cleaners, SJCC and GSC sites which represented less complex remediation challenges,
while such risks were anticipated, the mitigation strategies were tailored to the complexity of site work.
For these sites, project risk management strategies relied on use of cost reimbursable task orders. This
approach allowed the on site RPM, OSC and ERRS contractors to respond to unexpected circumstances
without the traditional administrative requirements associated with use of a RAC contract. For example,
underground storage tanks were discovered at both the Flash Cleaners and GSC properties but were
addressed through the use of the ERRS contractors with only minimum delay for the on site team and
without the need for lengthy administrative adjustments to the contract SOW.
3.5 Streamlined Remedial Design
Several measures were utilized successfully to streamline the RD process and compress the delivery
schedule thereby saving time and money for these projects. As a result, site managers are encouraged to
consider their application at other sites, where appropriate.
3.5.1 Tailoring the RD to the specific needs of the project
For all three pilots, the design process was compressed and certain intermediate RDs were not
prepared which saved time and cost in the preparation and review of these documents. In
addition, for the SJCC and GCS pilot, the project team decided to eliminate the preliminary RD
as well. This was possible primarily as a result of the close working relationships established
among project team members and their common commitment to completion of the project (rather
than deliverables). These close project team relationships facilitated the elimination of
unnecessary standard deliverables and review loops and ensured focus of needed deliverables on
project-specific requirements. In addition, at the Flash Cleaners site, the RD was split into two
parts, one for soil and the other for groundwater. This permitted the RA activities for soil to
begin as soon as the RD for soil was substantially complete, and while the RD for groundwater
continued.
3.5.2 Abbreviating RDs
As a result of the nature of the work, the Ellenville, SJCC/GSC and Flash Cleaners pilots applied
the concept of "just enough design" and included only the specifications and details necessary
for the specific actions, rather than the more detailed specifications traditionally discussed in
generic guidance.
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3.5.3 Beginning the design process prior to finalizing the ROD
Beginning basic pre-design tasks as the ROD is finalized shortens the time needed to finalize the
design and begin RA once the ROD is issued. Therefore, thought should be given as early as
possible to the best mechanism for conducting different components of the RD. For example, for
the Flash Cleaners site, Region 4 awarded the RD contract and began the RD while preparing the
ROD. The Region tasked its RAC contractor which had performed the RI/FS to conduct the RD,
because this contractor was already familiar with the site. Similarly, for the Ellenville pilot, EPA
entered into an IA with the USAGE to initiate the RA constructor procurement prior to issuing
the final ROD.1 The RD was completed within six months of the fmalization of the ROD (a task
that might have taken a year or longer under a more traditional scenario). It is important to note
that such early planning is generally only possible where and when there is high confidence that
changes to the proposed remedy are unlikely (e.g., when there are few viable remedial options,
where there is confidence that a particular overarching remedial strategy is favored by
stakeholders, and/or when comments on the proposed plan have been evaluated and are judged
not likely to impact such early planning).
3.6 Sampling Strategies
The SJCC/GSC, Flash Cleaners and Ellenville pilots utilized several time-saving sampling strategies
which may also be appropriate to use at other sites.
3.6.1 In-field analysis for quick data turnaround
At the SJCC/GSC sites, as part of the RD sampling, the ERT was asked to delineate the extent of
soil contamination in order to estimate the volumes of soil to be excavated at both sites. Having
the ERT's mobile laboratory on site shortened the turnaround time for analytical results and
facilitated the collection and analysis of additional samples when needed to complete design
drawings.
3.6.2 End point sampling to avoid post-excavation confirmatory sampling
At the onset of the RAs for the soil excavations at the SJCC/GSC sites, end point samples were
collected to establish the cut lines for the excavations using the "computer aided design and
drafting" (CADD) drawings as a guide. Similar work was conducted at the Flash Cleaners site.
In both cases, samples were analyzed prior to excavation to determine if soil concentrations met
the soil cleanup criteria. The term "end point sampling" refers to the process by which sample
locations are selected to define the boundary or outline of the area to be excavated. Sample
collection and analyses are performed before excavation begins. If the soil sample concentrations
meet soil cleanup criteria, the excavation can proceed to the predefined boundaries and post-
excavation confirmatory sampling would not be required. In addition, as an extra measure to
ensure the excavation boundary is completely defined before excavation begins and thus to avoid
the possible need for a second round of sampling, a second set of samples may be obtained at the
same time as the first set, a few feet beyond the excavation area identified on the design or
CADD drawings. The second set of samples is also sent to the laboratory but not analyzed until
the results from the first set of samples are received. If data from the first set of samples indicate
1OSRTI directed USAGE to initiate the RA constructor procurement under an IA prior to the ROD; however, the region
initiated the procurement for RD on the date of ROD signature.
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that soil concentrations meet the cleanup criteria, then the second set of samples is not analyzed.
If any of the first set of samples indicates that soil cleanup criteria are not met, then selected
samples from the second set are analyzed. This approach allows the cut lines to be clearly
defined before the excavation proceeds. Collecting all of the samples before excavation keeps the
field sampling team's time to a minimum and avoids the need for a second mobilization. For the
work at SJCC/GSC, only a few of the second set of samples required analysis to ensure that
cleanup numbers were achieved.
At the Ellenville site, during the RD, endpoint sampling was used whenever possible in
characterizing the extent of contamination. This was done to prevent delays in landfill cap
construction and the backfill of excavated areas while waiting for confirmatory results from the
laboratory. This approach contributed significantly to the completion of RD activities in six
months, a task that might have taken a year or longer otherwise.
3.6.3 Early sample analysis for waste acceptance
At the SJCC/GSC sites, in order to expedite the off-site disposal process and ensure the
excavated soil would meet the waste acceptance criteria of the disposal facility, samples were
also collected from areas of the sites where elevated concentrations of VOCs were identified.
These samples were collected at the beginning of the RAs and submitted to a state-certified
laboratory for analysis to ensure that the excavated soil would be accepted by the waste disposal
facility.
Performing analyses on site and conducting end point sampling and waste acceptance sampling
at the same time (prior to beginning excavation), can minimize the number of sampling events,
reduce analytical costs and expedite the excavation and backfilling process and completion of
RA activities.
4.0 Conclusion
This paper summarizes the lessons learned from conducting three RD/RA pilot projects at NPL sites
which were selected to demonstrate new techniques or best practices for the management of fund-lead
remedial projects. As demonstrated by these pilots, managing a site remediation project with a focus on
its completion (rather than on interim milestones) can allow RPMs to structure a project delivery
approach with greater efficiency, placing many activities on parallel or staggered schedules as opposed
to linear or sequential tracks. For each of these pilots, regions accelerated the RD and RA and realized
significant cost efficiencies for their sites.
Projects were selected based on their manageable scope, a requirement for only moderate financial
resources and a reasonably short project duration time frame (e.g., one to two years). Measures explored
by the pilot studies included new strategies involving project planning and management, increased use
of in-house resources, strategic use of contractor support, improved sampling efficiencies, enhanced
collaboration and communication among project team members and compression of traditional remedial
process components.
Results of the pilot studies demonstrated that significant time savings (estimated to be as much as 67%
over traditional project duration) may be gained depending on project scope, the areal extent of
contamination and site complexities. In addition, savings or cost avoidances ranging between
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approximately $135,000 and $584,000 were estimated for these pilots. These values represent
significant savings given the work undertaken for these projects.
Site teams are strongly encouraged to consider these project management approaches as early as
possible in planning for RD and RA activities. Where early assurance of RA funding or other
headquarters resources for a given project is likely to accelerate site cleanup significantly, site managers
are encouraged to discuss such opportunities with regional management to decide whether to request
such support from OSRTI. A favorable OSRTI decision would depend on a number of factors including
the availability of funding, the availability of appropriate in-house expertise, and competing priorities.
When considering the application of these measures at other sites, site-specific reviews will be necessary
because not all of the approaches explored are appropriate for all sites. It is also noted that certain
approaches will require increased focus and effort on the part of the EPA site manager, regional
management, headquarters, contractors and states. These added resource demands should be considered
alongside the advantages of an accelerated cleanup for the community, the region and the national
program. Lastly, while these pilots were conducted on fund-lead sites, many of the measures may have
value and could result in cleanup efficiencies at sites where cleanups are undertaken by private parties or
federal facilities.
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