OSWER Directive 9200.3-69
June 2011
Action Plan for
Managing Superfund Remedial Projects to
Completion through the
Integrated Cleanup Initiative
Office of Superfund Remediation and Technology Innovation
U.S. Environmental Protection Agency
639175
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Table of Contents
I. Introduction 1
II. Implementation 2
A. Broadening the Use of Regional Best Management Practices 2
B. Improving Headquarters and Regional Interactions 2
C. Piloting or Demonstrating Process Improvements in the Field 3
D. Strengthening Superfund Remedial Site-Related
Technical Support 4
E. Increasing the Visibility of Project Schedules 5
F. Focusing on Enforcement 5
G. Evaluating the Impact of Actions on the National Program 6
Appendix A: Selected Superfund Regional "Best Management
Practices" for Remedial Projects 8
Appendix B: Summary of Project Management Pilots 18
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Action Plan for
Managing Superfund Remedial Projects to
Completion through the Integrated Cleanup Initiative
I. Introduction
EPA's Office of Solid Waste and Emergency Response (OSWER), in partnership with the Office
of Enforcement and Compliance Assurance (OECA), has launched a three-year strategy, the
Integrated Cleanup Initiative (ICI), to identify and implement improvements to the Agency's site
cleanup programs. The goal of the initiative is to use the Agency's cleanup and enforcement
authorities to accelerate and improve cleanups where possible, address a greater number of
contaminated sites, and put these sites back into productive use while protecting human health
and the environment.
Under the ICI, the Superfund remedial program is taking a number of actions to achieve these
goals. This plan describes actions aimed at managing Superfund remedial projects to project
completion and identifies programmatic operational improvement efforts that EPA regions, the
Office of Superfund Remediation and Technology Innovation (OSRTI) and OECA plan to
undertake. This paper is not inclusive of all the remedial program efforts under the ICI.
In the autumn of 2010, senior Superfund regional and headquarters managers, considering both
experience gained over the last 30 years and external stakeholders' input on earlier versions of
the ICI, explored opportunities to address common remedial program impediments. This
exploration included a discussion of business process options to accelerate the pace of site
cleanups from the remedial investigation/feasibility study (RI/FS) stage through site completion
by focusing on project management improvements. In addition, these managers considered other
actions already underway as part of the ICI. This action plan identifies actions scheduled or now
underway that are expected to improve the way remedial projects are managed.
We are mindful that regional programs have evolved independently over 30 years such that there
is not a single set of practices or processes that will work best for all regions. However, the
senior team of managers examining this issue universally believes there are opportunities for
improvement in each region's remedial program operations. To this end, we recommend each
regional Superfund management team scrutinize this document and move to implement those
approaches that best suit its region. In addition to responses requested below, OSRTI will be
discussing the action plan's implementation during regional mid-year and end-of-year planning
sessions.
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II. Implementation
A. Broadening the Use of Regional Best Management Practices. Through December
2010, OSRTI, OECA, the Federal Facilities Restoration and Reuse Office (FFRRO)
and the regions compiled and shared "best management practices" (BMPs) for
regions to consider as they work to improve Superfund remedial project management
under the ICI. As the regional programs have evolved over the program's 30-year
history, there is not one standard set of practices that works well in all regions.
However, it is possible that practices from one region may help improve business
practices in other regions. As part of this effort, regional Superfund division directors
carefully examined a compilation of regional BMPs for potential application in their
own region and submitted region-specific plans for the testing or implementation of
selected practices (See Appendix A). Progress (and issues) in implementing regional
BMPs were discussed during mid-year headquarters/regional work planning sessions.
See also ICI Action 17.
Actions include:
1. Progress (and issues) in implementing regional BMPs will be discussed during
the end-of-year headquarters/regional work planning sessions (4th Quarter/Fiscal
Year [FYJ2011)
2. Lessons learned from the implementation of new business practices will be
submitted to the OSRTI Office Director in 2nd Quarter/FY2012.
B. Improving Headquarters and Regional Interactions. On March 31, 2010, OSRTI
issued guidance on elevating remedy selection policy and guidance disputes1 and
continues to look for ways to improve those interactions as it implements this
guidance. OSRTI is currently discussing with regional managers the potential for
coordination earlier in the remedy selection process and has developed a draft
standard operating procedures (SOPs) document for the regional Remedy
Coordinators. OSRTI also is developing training for the annual National Association
of Remedial Project Managers (NARPM) conferences on common remedy selection
issues. Finally, OSRTI has convened workgroups to evaluate existing guidance and
processes and identify the need for additional site assessment and remedy selection
guidance based on emerging issues. The goals of these actions are twofold: (1) to
improve decision quality, and (2) to reduce the number of regional documents
reviewed by headquarters staff (e.g., Records of Decision [RODs], ROD
amendments, Engineering Evaluations/Cost Analyses [EE/CAs], and Five-Year
Reviews). Many of these initiatives are addressed under ICI Actions 2A and 8.
1 See "Elevating Site-Specific Superfund Remedy Selection Issues between the Office of Superfund Remediation
and Technology Innovation (OSRTI) and Regional Superfund Program Offices," Memorandum from James E.
Woolford to National Superfund Program Managers, Regions 1-10 (March 31, 2010). URL:
http://www.epa.gov/superfund/policv/remedv/sfremedv/hqconsult.htm
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Under ICI Action 7, OSRTI also has been reviewing the operational protocol of the
National Remedy Review Board (NRRB) and the Contaminated Sediments Technical
Advisory Group (CSTAG) with an eye towards refocusing these entities to provide
greater regional support without impeding site progress. OSRTI has recently updated
NRRB-related information2 and proposed to the regions potential operational changes
to both groups. OSRTI received comments on these proposed operational changes
from regional branch chiefs and division directors; final decisions about revisions to
the protocol are under consideration. Implementation of the revised protocol is
expected in the fall.
In summary:
1. OSRTI will be implementing changes to NRRB and CSTAG operational protocols
by 1st Quarter/FY2012.
2. OSRTI will continue to implement recent guidance on elevating remedy selection
issues and guidance disputes. (Ongoing)
3. OSRTI will issue SOPsfor elevating site remedy issues and will apply them
during mid-year review discussions. (1st Quarter/FY 2012)
4. OSRTI will work with the regions to consolidate headquarters' consultation
requirements including the concurrence process for decision documents for non-
National Priorities List (NPL) and Non-Time Critical Removal Actions
(NTCRAs). (4th Quarter/FY 2011)
5. OSRTI is developing training for the annual NARPM conferences on common
remedy selection issues (e.g., appropriate lines of evidence for monitored natural
attenuation (MNA); implementing the preference for treatment of principle threat
waste; developing appropriate remedial action objectives in the ROD). (Ongoing)
6. The NARPM Policy and Guidance Committee has worked with Superfund
management to establish a workgroup to examine potential inconsistencies in
existing guidance and/or the need for new guidance based on emerging issues.
Recommendations anticipated beginning in 2nd Quarter/FY 2012.
C. Piloting or Demonstrating Process Improvements in the Field. Eight site pilot
projects were identified on November 20, 2010, that may demonstrate substantial
remedial process improvements. These pilots bring the total number of Superfund
remedial project management pilots identified under ICI Action 17 to nine. Some
pilots seek to demonstrate the effectiveness of region-specific best practices, while
others are designed to evaluate the potential benefit of new approaches to site project
management. Pilot project summaries can be found in Attachment B. Actions
include:
'http://www.epa.gov/superfund/programs/nrrb/index.htm
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1. Regions with pilots are to provide status reports on pilot implementation to the
OSRTI and Office of SuperfundRemediation Enforcement (OSRE) directors and
to the Project Management Executive Group (PMEG) on a quarterly basis.
(beginning 4th Quarter-/FY 2011)
2. Regions are to complete a final report to the OSRTI Office Director within 30
days of pilot completion, with results, lessons learned, considerations for
replication, and any recommendations for changes to program policy, guidance,
or practice to promote wider application, if appropriate.
D. Strengthening Superfund Remedial Site-Related Technical Support. Superfund
remedial sites frequently present both technical and process management challenges.
From characterizing a site and making a sound remedy decision that appropriately
balances the nine criteria for remedy selection, to designing and implementing
remedies that address contamination and that work well over time (in many cases,
decades), the Superfund remedial program has faced many challenges. Protective
remedies must be cost-effective and reflective of a variety of policy and stakeholder
concerns, and should incorporate advances in both science and the program's
collective experience with the implementation of site cleanups. Further, there is no
typical Superfund site. Releases occur in a wide array of geologic, hydrogeologic and
physical settings, and the corresponding systems potentially affected are dynamic and
variable. In many cases, contamination is subsurface, which may create a high degree
of uncertainty in EPA's knowledge about site conditions. Furthermore, site
conditions and contaminant migration pathways may change significantly over time.
To manage these often complex, technical challenges throughout the remedial
pipeline, EPA advances the application of innovative technologies, adaptive site
management practices, and a continuous improvement framework to assess and then,
reassess site data, remedy effectiveness and/or process efficiencies. In this context,
OSRTI relies on a series of approaches to ensure that conceptual site models,
sampling strategies and site characterization work are robust and accurate enough to
support decisions. Further, once implemented, remedies need to operate as optimally
as possible.
Given these challenges, OSRTI plans to implement the following actions to
strengthen capabilities in this area (See also ICI Actions 10 and 17):
1. OSRTI will survey the regions and, in consultation with them, work to align its FY
2012 headquarters work plan with the highest regional priorities (including
remedial programmatic, technical support, and/or technology priorities). (1st
Quarter/FY2012)
2. OSRTI and the regions will develop and finalize the national strategy for
expanding and incorporating Superfund optimization throughout the cleanup
process. OSRTI will seek to expand the application of optimization tools more
broadly in the post-remedy universe. In addition, OSRTI will identify ways to
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incorporate earlier in the remedial process the lessons learned from past
optimization work in order to better inform RI/FS support and remedial designs
(by 4th QuarterVFY2011). OSRTI will work with the regions to increase the
number of optimization projects conducted annually from the present level of 5 to
10 per year to a target level of 10 to 20 per year. The actual targets and the
program's ability to reach these targets will depend on the FY 2011 and 2012
budgets. See also ICI Action 10.
3. OSRTI will continue to work with and support the regions through multiple work
groups and venues (e.g., Technical Support Project Forums3, OSWER Training
Forum4, Eco Risk Assessment Forum5, etc.) to explore new technological
approaches and strategies with potential to accelerate project completion. OSRTI
will develop a variety of mechanisms to ensure regional access to training,
information, and expertise to support site work. (Ongoing)
4. OSR TI w ill support efforts to improve project management principles and
training pertaining to the implementation of cleanup projects. NARPM and
OSRTI are developing a series of courses dedicated to improving project
management skills. OSRTI is exploring the development of a national training
program that may lead to Remedial Project Manager (RPM) project management
certification. (4th Quarter/FY 2011)
E. Increasing the Visibility of Site Project Schedules. Superfund site cleanup
strategies involve many different stakeholders. In some cases, the cleanup work itself
is divided among parties and must come together at critical points in order to ensure a
cost-effective and protective outcome. Communities themselves need information on
cleanup milestones to participate successfully in the Superfund process. As a result, it
is critically important to share information about cleanup progress and plans for
future work in a straightforward and visible manner. Further, sharing information
about planned work schedules may enhance accountability for meeting schedule
milestones/targets among all stakeholders. For these reasons, OSRTI, OECA, FFRRO
and the regions will explore options for sharing information about cleanup progress
and plans for future work at sites. (4th Quarter/FY 2011) Also see ICI Action #17.
F. Focusing on Enforcement. Superfund remedial work can also present enforcement
challenges. The Superfund enforcement program requires potentially responsible
parties (PRPs) to conduct cleanups, thereby preserving federal dollars for sites where
there are no viable contributing parties. Several ongoing ICI actions (i.e., 3, 11 A,
11B, 12A, and 12B) include evaluations of the effectiveness of enforcement
3 http://www.epa.gov/tio/tsp/index.htm
4 http://www.trainex.org/forum members.cfm
5 A group of 14 ecologists representing all ten EPA regional offices, OSWER and the Office of Research and
Development that works together to improve the quality and consistency of hazardous waste site ecological risk
assessments.
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processes, including an evaluation of the remedial design/remedial action (RD/RA)
negotiation policy that will consider the timing of the pre-referral negotiation process
and any associated cleanup delays. Managing cleanup at an enforcement site also
involves issues related to communicating and coordinating with PRPs. To respond to
enforcement impediments identified by the regions that relate to communication with
PRPs, the Agency will develop the following tools to facilitate that communication:
1. OSRE will develop a sample/model letter to address deficient PRP deliverables.
Site cleanups can sometimes be delayed by repeated rounds of EPA comments on
deficient deliverables. Most Superfund enforcement model documents give EPA
the option to modify unilaterally deficient documents submitted by PRPs. OSRE
will provide a sample letter for EPA unilateral modification of deficient
deliverables to facilitate EPA/PRP interaction and improve the timeliness and
quality of PRP deliverables. (4th QuarterYFY2011)
2. OSRT1 will develop a model statement of work (SOW) for RD/RA to accompany
the 2009 model RD/RA consent decree. The model SOW will speed the
development of future SOWs and encourage national consistency. This work is
also expected to address appropriate flexibilities in describing how work is to be
conducted during the RD/RA process. OSRTlwill work closely with OSRE to
ensure that enforcement issues are addressed in the final model SOW. (4th
Quarter/FY2012)
G. Evaluating the Impact of Actions on the National Program. This action plan
outlines many efforts and activities designed to improve the way site remediation
projects are managed. To assess the success of these efforts and to demonstrate
continuous improvement, the identification and definition of performance measures is
important. It is recognized that many actions identified above will be implemented
and evaluated on an activity-specific basis. In some cases, the impact of individual
actions may be quantifiable, while in others, more qualitative or even anecdotal
evidence of impacts will be appropriate. OSRTI and the regions will also explore
measurement of the cumulative effect of these actions. Consistent with ICI Action 21,
the actions presented below are designed to assist headquarters and the regions in
defining appropriate measures of accomplishment for this initiative.
In summary:
1. Explore options for establishing a program performance baseline. Through the
collection of historical data and trend analysis, the Superfund remedial program
(OSRTI) will explore options for a performance baseline that can be used to
evaluate national program performance as the above actions are taken.
(Complete)
2. Provide tracking and feedback mechanisms for relevant actions. In some cases
above (e.g., optimization assessments), it will be important to track and compile
the results of individual actions taken in order to identify and share lessons
learned with others, (beginning 4th QuarterVFY2011)
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3. Monitor implementation of BMP s. During end-of-year work planning
discussions, regions will be asked to identify where BMPs are being used and the
anticipated/actual results, (beginning 4th Quarter/FY 2011)
4. Monitor progress of nine pilot projects. Over the next two years, the nine
Superfund remedial project management pilots will be monitored to assess
progress and any efficiencies gained. Progress will be reported quarterly.
(beginning 4th Quarter/FY 2011)
5. Issue an end-of-year accomplishments report for fall 2011 and fall 2012. OSRTI
will work with the regions to compile and evaluate the success of individual
actions as well as the cumulative effects of this action plan on the remedial
program (to the extent these may reasonably be characterized). At regular
intervals, status/results of pilot projects, the use of BMPs, and other technical or
process improvements (including significant anecdotal findings) will be compiled
and reported to OSWER and OECA senior management with an eye toward
monitoring overall national program performance improvements. Based on the
projected results, preliminary data collected on program impacts, and the
baseline data analyses, measures and goals demonstrating program
improvements at the national level will be evaluated and assessed for possible use
in FY 2012 and beyond, (beginning in 1st Quarter/FY 2012) Also see ICI Action
#17.
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Appendix A:
Selected Superfund
Regional "Best Management Practices" for
Remedial Projects
Purpose
This appendix presents "Best Management Practices" (BMPs) utilized nationally to oversee the
Superfund remedial program and to expedite remedial projects. In developing this action plan,
regions both shared their BMPs for remediating sites and agreed to adopt or test BMPs from
other regions to improve their own remedial process efficiencies.
A summary of top management practices follows.
Senior Management Oversight
Senior management oversight of remedial project planning is critical to an effective program.
Since regions vary in their organizational structure depending on workload and available
resources, references below to the "Superfund management team" may include any combination
of section chiefs, unit managers, branch chiefs, deputy division directors, and/or directors. The
following describes several general management practices or styles that are utilized by different
regions to manage Superfund remedial projects.
Tracking critical path schedules: In several regions, the Superfund management team convenes
a management review meeting in the first quarter of each fiscal year for sites with decision
documents (RODs, ROD amendments, Explanations of Significant Differences [ESDs])
scheduled for that fiscal year. During these meetings, a site team (including the RPM, legal
advisor, community involvement coordinator [CIC], and technical support staff) presents the
critical path milestones and project schedule, and identifies any issues requiring management
intervention, (e.g., funding, state concurrence, technical/legal support, etc.). The senior
management team makes appropriate decisions on strategy, resources and scheduling issues.
One region highlighted the use of a similar critical path schedule for planning and managing
Superfund site activities that also included development of critical path schedules at the
beginning of the year for new RI/FS starts, decision documents (RODs, ROD amendments and
ESDs), RD/RA starts, construction completions, and Five-Year Reviews.
These critical path schedules are generally based on information in the Comprehensive
Environmental Response, Compensation and Liability Information System (CERCLIS) and
highlight milestones necessary to advance the site toward completion for the fiscal year. As
appropriate, the region receives state input as it develops these schedules.
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In some cases, the senior management teams meet on a regular basis with the site teams (RPM,
technical support staff, Office of Regional Counsel (ORC) staff, contract support staff, On-Scene
Coordinator [OSC], CIC) throughout the year to review the schedules and consider obstacles that
may cause delays to the project activities and to discuss ways to resolve those issues. Some
regional senior management teams meet quarterly with the states to review, update and discuss
impediments to critical path schedule completion.
Reviewing construction completion status: All regions are required to submit construction
completion narratives or paragraphs to OSRTI that provide the status of regional work toward
achieving the construction completion targets on a quarterly basis. In addition, each region has
methods for tracking and troubleshooting the status of construction completions. One region
specifically identified the following construction completion tracking methods:
• Brief the division director on construction completion target status on a quarterly
schedule for a three-year planning window.
• Hold quarterly construction completion site team meetings to monitor the progress
towards site completion. The entire site team is invited to participate in the meeting
including the RPM, senior RPMs and their supervisor(s), the site attorney and his/her
supervisor, technical support staff, the CIC, contract support personnel, and, where
appropriate, removal program representatives, to discuss site status, milestones, and ways
to expedite work at the site. This process is reported as very effective in focusing work
efforts and enforcing schedules.
Regular, cross program management team meetings: All regions have regular management team
meetings as a matter of course; however, some regions make special efforts to include managers
from Superfund, Brownfields, and emergency response programs, as well as managers from
support offices. These support offices include the community involvement/press team, ORC, and
risk assessment/ technical support units.
The frequency and scope of these meetings vary. For instance, one region has weekly cross-
program management team meetings. The purpose of these meetings is to provide brief, critical
site updates, elevate issues that need immediate, cross-program management attention, and
integrate programs so that the program utilizes the best tools and authorities to address each site
circumstance.
In another region, as part of a more formal ROD improvement initiative and to improve the
overall Superfund process, the remedial program meets monthly with the legal enforcement staff
and separately with the budget/financial group. Proposed budgets and Superfund Comprehensive
Accomplishments Plan (SCAP) and Government Performance and Results Act targets are
reviewed on a monthly basis to make sure projects are on track. The discussions with the legal
staff are critical so that important issues for both groups are addressed and larger problems
avoided that could delay site completion.
Project Planning and Management
Scoping meetings: One region has standardized the use of scoping meetings with wide, cross-
program participation to kick off key parts of the process, such as the RI/FS and Five-Year
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Reviews. The RPM leads the scoping meeting, but involves everyone on the site team including
technical support, enforcement, legal, and community involvement staff, as well as state project
managers, and Natural Resource Trustee agencies. These meetings ensure that everyone is aware
of project direction and schedule.
Focus on control of human exposures: In one region with a site involving contaminated indoor
air that was deemed to have "insufficient data" for the purpose of determining whether human
exposure for "environmental indicator" purposes was under control, the region assembled a team
of experts (RPM, indoor air specialist, toxicologist, and hydrogeologist) to meet with the
responsible party to discuss the necessary sampling activities. By working together and in real
time, the region was able to ascertain that the vapor intrusion sampling plan would return all the
necessary information required to make the human exposure determination in an efficient
manner. This approach significantly accelerated the region's ability to make the human exposure
assessment. Another region created an opportunity to move a site out of the "insufficient data"
category more quickly by focusing attention and prioritizing staff workload to finalize a draft
report confirming whether site-related vapor intrusion existed at residential properties
surrounding the site.
Site management meetings: RPMs convene regular site team meetings to manage their projects.
As with the scoping meetings, it is important to include all team members, including technical
support, enforcement, legal, and community engagement staff as well as state project managers,
and other trustee agencies, as appropriate. Some regions have a biweekly meeting with program
and legal staff to track site schedules and manage delays.
Use of management plans: Some regions use management plans to facilitate the study phase of
the remedial process through to the ROD and beyond. In March 2011, one region developed an
RI/FS management plan template that RPMs use to prepare realistic schedules for work during
the RI/FS process, and identify critical paths and potential obstacles for each phase. In April
2011, this region identified a list of sites that have been in the study phase for several years and
that are potentially good candidates for the management plan approach. The RPMs developed
site-specific management plans through collaboration with the technical support team, section
chief and regional attorney. The branch chiefs will review the management plans, and senior
management will discuss and approve them. Progress of sites activities will be tracked at the
branch chief level. The region plans to prepare management plans for newly proposed sites, as
well.
Use ofCERCLIS as a planning tool: Some regions use CERCLIS as their principal source of out-
year planning information for a three-year planning window. One region generates SCAP reports
on the first day of the last month of each quarter, and distributes them to each RPM. The RPMs
are given a two-week period to evaluate the planning and financial data to determine if any
changes are necessary. RPMs then discuss this information with their supervisor to determine if
those recommended changes are appropriate. If approved by management, the changes are made
with an eye towards making sure any out-year projections are cascaded throughout the duration
of the site work. Through this process, the region strives to ensure that site planning and financial
information are refreshed on a routine basis, thereby helping to ensure the Agency's site work
decision making is accurate.
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Another region utilizes central data entry and tracking of SCAP commitments. This process
requires RPMs to review and update their SCAP commitments quarterly with a three-year
planning outlook. The RPM's immediate supervisor must review and approve any proposed
changes. Unit managers are responsible for tracking these commitments. The division director
incorporates review of these targets and whether they are achieved in the mid-year and end-of-
year supervisory performance evaluations.
Construction completion andRA completion management: In one region, the Superfund branch
chiefs convene a management review meeting in the first quarter for sites with planned
construction completion or RA completion targets, including alternates. Site teams, including the
RPM, legal advisor, CIC, and any technical support personnel, present the critical path items and
attendant milestones, and identify any issues requiring management intervention (e.g., funding,
state concurrence, technical/legal support, etc.). The branch chiefs, section chiefs and legal
managers make appropriate decisions on strategy, resources and scheduling issues. Issues are
elevated to the division director/Deputy Regional Administrator as necessary. The Regional
Administrator and/or Deputy Regional Administrator are provided monthly reports on these
important Superfund program targets.
Effective Utilization of Internal Technical Resources
Some regions have realized significant time and cost savings by using internal resources rather
than EPA and U.S. Army Corps of Engineers' (USAGE) contractors. For example, one region
has found it to be particularly effective to use the Agency's Environmental Response Team,
removal program staff, and the regional Division of Environmental Science and Assessment (i.e.,
lab, field, and quality assurance/quality control staff). This region has relied heavily on using the
resources of these three groups, both individually and in combination, to expedite remedial
activities. These activities include sampling and analyses (for soils, groundwater, surface waters,
sediments, soil gas and indoor air) and various types of field work, such as well installation, soil
gas vapor mitigation and certain types of remedial actions including building demolition, soil
excavation, soil stabilization and installation of groundwater pump-and-treat systems.
Another region utilizes a Data Archival and Retrieval System (DART) in combination with
EQuIS (an environmental data management software) to help ensure effective data management.
Entering all Superfund remedial program data into DART provides a uniform system allowing
all data users to interpret and manipulate data easily. The key beneficiaries are the technical
support staffs (e.g., hydrogeologists and risk assessors) who are tasked with interpreting most of
the program's data. Dealing with data in a single format saves a significant amount of time and
effort for the technical support staff. Another benefit is that DART data can be incorporated
easily into geographic information system applications.
Contracting
OSWER and OARM have recently completed the Superfund Contacts 2010 Strategy.
Recommendations from this strategy will inform future regional acquisitions-related actions. In
addition, OSRTI is currently working to develop guidance that will assist regions in
implementing the strategy. For example, regions may be encouraged to consider various
contracting mechanisms to expedite their projects that they are not now using. The use of
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individual contracts for site-specific construction work developed and awarded by a region may
allow for schedule and cost savings or avoidance depending on site-specific circumstances. This
approach, which has proven effective in one region, allows for more direct support of the
Agency's small and disadvantaged business goals. The region employing this approach has
offered its support to other regions interested in adopting this contracting method.
Another approach used successfully in another region includes the use of contractor incentives
for ahead-of-schedule project completion. This approach may also prove useful to the USAGE,
when it has the lead contracting authority for a Superfund remedial project.
Coordinating with Internal and External Partners
Regions also meet regularly with their state, tribal and federal partners. Some regions report that
they have quarterly meetings with state partners and federal PRPs in order to provide a regular
planning, resource prioritization and dispute resolution venue. The quarterly meetings with the
states have been particularly useful to help resolve policy issues that cut across programs. In one
example, since there were different regulatory agencies representing the state on CERCLA issues
at different sites, it had been difficult to establish consistent positions across the state. The
quarterly meetings between the region and the state provide a venue to discuss these issues with
managers that are involved at the policy level. On Department of Defense sites, at least one
region meets regularly with each of the services and state counterparts to discuss NPL, non-NPL,
Base Realignment and Closure, and Formerly Used Defense Sites/ Military Munitions Response
program sites. This approach has helped accelerate the resolution of informal disputes and has
improved working relationships where regular disputes have occurred in the past. More
importantly, the region has been able to harmonize informally programmatic goals by regularly
reviewing project schedules.
Some regions rely on the USAGE to assist in managing RDs and RAs due to the complexity and
size of their sites. Using the USAGE services may significantly reduce the RPM's administrative
burden relative to contractor procurement and work assignment management. One region
provided the example that, over the past 25 years, the region has developed a solid partnership
with the four districts with which they work: Kansas City, New York, Baltimore (real estate
issues only) and Philadelphia. Every other month, this region meets with the Kansas City, New
York, and Philadelphia districts to review the status of all USACE-supported sites. This forum
ensures that EPA and USAGE management are kept apprised of remedial progress and, more
importantly, that issues affecting progress can be raised, discussed and resolved. Additionally,
the USAGE has several pre-placed construction contracts ready to perform remedial action work
for EPA. The fact that these contracts are already in place helps to expedite the initiation of
construction work.
Utilizing Removal Authorities and Resources at Remedial Sites
One tool that has been advantageous to many regions for expediting overall site cleanup is
utilization of removal program resources and authority at NPL sites. Some regions provide
remedial funds to the removal program to conduct selected remedial actions. For example, in the
case of a relatively straightforward excavation remedy, field sampling is performed to determine
the cut lines to meet the specified soil cleanup levels and a streamlined design is prepared, which
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negates the need for a formal design. The job goes out for bid based on the volume estimates
calculated from the cut lines. Removal program staff (representing the region's in-house
construction managers) then manage the construction effort. Final construction drawings,
prepared and approved by a state-licensed professional engineer, serve to confirm that the
remedy was properly implemented according to the ROD's specifications.
Another region reports using the removal program for site stabilization and to take early cleanup
actions to address any immediate threat that would fall within the scope of the final selected
remedy. Some of these actions include non-time critical removals or hot spot removals. In some
cases, these early actions may result in a No Further Action ROD and thus speed achievement of
site construction completion. In other instances, these actions may simply minimize the amount
of remedial work required to implement the remedy. An added benefit from the use of removal
or early actions atNPL sites is that, in some circumstances, taking early action to address acute
risks will eliminate potentially harmful human exposure pathways. In so doing, sites that are
classified under the Human Exposure Environmental Indicator as "not under control" will move
to the "under control" classification.
One region reports that in November 2010, the manager of the Emergency Response Unit
provided training to RPMs on the law, policy and guidance related to time critical and non-time
critical removals. This session was organized to encourage consideration of this approach for
remedial work and to ensure RPMs are well versed in the requirements and procedures for
removals.
Ensuring Quality and Appropriate Consistency in Remedy Selection
Regions have identified several practices to increase the quality of RODs and remedy selection.
In one region, the Superfund branch chiefs convene a management review meeting in the first
quarter for sites with decision documents (e.g., RODs, ROD amendments, Explanations of
Significant Differences) scheduled for that fiscal year. Site teams, including the RPM, legal
advisor, CIC and technical support personnel, present the critical path items and schedule, and
identify any issues requiring management intervention, (e.g., funding, state concurrence,
technical/legal support). The branch chiefs, section chiefs and legal managers make appropriate
decisions on strategy, resources and scheduling issues. As a result of the ICI and OSWER's
Community Engagement Initiative, this process was amended in two important ways. First,
OSRTI participation was incorporated into these meetings with the objective that earlier OSRTI
involvement would reduce the number and breadth of issues that sometimes arise when
consultation occurs later in the process. Secondly, the region formalized the process, procedures,
and time lines for preparation of documents, public notices, fact sheets, and press materials with
its community involvement and public affairs office to ensure that effective community
involvement is not compromised by remedy decision time pressures.
Recently, another region began a new procedure designed to improve ROD quality. As part of
that process, milestone meetings, peer review and work planning by the site teams will be
required for each site. Critical milestone meetings that include team members (legal,
enforcement, technical) and management are scheduled to ensure that projects are progressing to
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completion. These meetings are scheduled at prescribed times (remedial investigation scoping,
feasibility study scoping, after the FS is complete, before the proposed plan is issued and after
the first draft of the ROD is ready for review). The overall goal is to produce quality RODs and
to identify potential issues with proposed remedies at an early stage of the RI/FS, thereby
avoiding delays that may result when issues are identified late in the process.
In some regions, a Regional Decision Team (RDT) comprised of Superfund program
management (e.g., remedial section and branch chiefs, and/or the technical support section
chief), legal staff and headquarters staff is used to ensure the quality and consistency of RODs.
The team meets once a month to review proposed remedies. The remedies are brought before the
RDT late in the FS stage when the RPM is developing a preferred remedy, but before the
proposed plan is drafted. The RPM, along with his/her site team (attorney, hydrogeologist,
human health risk assessor, ecological risk assessor) presents the preferred remedy to the RDT
and goes through a checklist of items (see Attachment 1) which covers key areas such as
identification of risk drivers, land use assumptions, and Applicable or Relevant and Appropriate
Requirements (ARARs). The purpose of the RDT is to serve as a quality review for all remedy
decisions and ensure regionally-consistent decision making. Headquarters' participation for these
reviews helps to provide a measure of national consistency.
Another region has a long-standing peer review policy that requires NTCRAs at NPL sites,
proposed plans, RODs, and ROD amendments be reviewed by a team of regional experts,
including the unit manager, the senior policy advisor, several experienced RPMs, technical
experts, and legal staff. This policy was written in 1995 and updated in 2008. This region has
effectively utilized a "senior policy position" to review and comment on all remedial decision
documents to ensure consistency and clarity in the administrative record and to work with
headquarters to resolve comments, questions and issues related to these decision documents.
Streamlining Remedial Design/ Remedial Action
During recent RD/RA streamlining discussions, a number of ideas were shared and are
summarized below:
• Increased RPM oversight during site remediation to ensure issues are identified and
resolved as quickly as possible. In some regions, this is a shared responsibility among
RPMS and /or OSCs.
One region reported that on sites that receive little or no public comment on the proposed
plan, the region proceeds with contracting for the RA concurrent with the preparation of
the ROD.
• Some regions are conducting selected RD activities before the ROD, recognizing that
these activities will have to be done regardless of the remedy selected. This approach is
typically more feasible at fund lead sites, but can be considered at enforcement lead sites
where the PRP(s) are cooperative and willing to consider it.
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The USAGE has brought RA contractors on board during RD to serve as technical
reviewers of design plans which can bring efficiencies to the process.
The USAGE has also utilized one contractor for RD and RA in a "design/build" approach
which can be effective at some sites.
• One region has provided remedial funds to the removal program to conduct selected RAs
and found this can expedite projects. An example of this is described in the first
paragraph on page 12 under "Utilizing Removal Authorities and Resources at Remedial
Sites."
Utilizing Enforcement Tools
As discussed above, regional Superfund managers meet with the ORC on a regular basis
(weekly, monthly, or quarterly) to ensure timely accomplishment of priority work. For instance,
one region highlighted the practice of the Superfund management team meeting with ORC on a
monthly basis to review CERLIS site information. Adjustments are made as necessary as are
follow-up meetings with project managers. This process ensures that data are accurate, work is
on track, and accomplishments are being met as planned. It also facilitates the timely elevation of
potential issues, so that impediments are effectively resolved as early as possible.
Regions also report that it is important to have civil investigators and ORC begin PRP searches
as sites are identified. One region specifically highlighted that this early involvement helps to
bring parties to the table to perform work sooner. This region also has developed industry-
specific expertise that significantly enhances early PRP search work at sites such as abandoned
mines. As a result, at certain mining sites, EPA has been able to identify PRPs where none were
thought to exist.
Regions have also been aggressive in setting up special accounts for cost recovery to offset
pipeline dollars and where appropriate pay for staff salary. These efforts have saved resources
and helped keep projects on track to completion.
Five-Year Review Timeliness
The remedial program now conducts over 250 Five-Year Reviews (5YRs) annually, and faces an
increasing workload as new sites requiring these reviews are completed each year. One region
shared their technique for managing this workload, as follows:
The Region has developed a spreadsheet to manage and track SYR progress. Developed a
number of years ago, the spreadsheet serves several purposes. One is to inform staff and
supervisors regarding any new due dates established by the branch chief. Because 5YRs were
customarily completed at the end of the fiscal year, it perpetuated a cycle where subsequent
5YRs continued to accumulate at the end of each fiscal year. This annual process strained both
regional and headquarters resources during this last quarter. The spreadsheet has allowed
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regional management to document and distribute revised due dates to staff which now staggers
the SYR workload throughout the fiscal year.
In addition, interim milestones were created and documented in the spreadsheet so that staff,
supervisors, and managers could track progress and be alerted to potential slippage in the review
schedule. Milestones tracked include:
• Sending out the letter to initiate the review,
• Internal technical meetings,
• Institutional control (1C) review,
• Community interviews,
• Draft report distribution, and
• Approval signature.
In addition, this region is exploring with headquarters a revised, more streamlined format for
subsequent 5YRs. Currently, most reports simply repeat many pages of background material that
are not particularly pertinent to what has occurred since the last SYR. As a result, SYR reports
can become increasingly more voluminous over time. The revised format could include an
executive summary/ introduction, progress on issues reported in the last review, a technical
assessment/issues/recommendations section, and finally a protectiveness statement. Other
historical, site chronological or background material could be reported by reference or as an
attachment. This would inform the reader of the most up-to-date and pertinent information and
reduce regional management and headquarters review resources.
Another region has developed training for staff that have a SYR due during the current FY. The
senior policy advisor provides this training early in the fiscal year so that the RPMs understand
the process and requirements for a SYR and start the process as early in the year as practicable
given other priority work.
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Attachment 1:
One Region's Regional Decision Team Deliberation Checklist
Is/are the land use assumption(s) for the site/operable unit reasonable? Are
groundwater use assumptions reasonable?
2. Are exposure scenarios and risk assumptions reasonable? Is remedial action
necessary for the site/operable unit? Has ecological risk been adequately
addressed?
3. Are remedial action goals/cleanup levels reasonable? Are there any ARAR
issues? Are current risks compared against remediation goals?
4. Does the proposed remedial action properly address the risk drivers and media of
concern? Have the principal threats posed by the site been identified and does the
proposed remedy anticipate treatment of the principal threat waste materials?
5. Is the preferred alternative likely to be effective? For groundwater sites, does the
proposed remedy anticipate dense non aqueous phase liquid (DNAPL)? If yes, is
a phased approach proposed in accordance with applicable guidance? Is a
Technical Impracticability (TI) ARAR waiver proposed and appropriately
justified? If MNA is proposed, has it been appropriately justified in accordance
with OSWER policy? If ICs are necessary, are they likely to be effective? Should
a contingency remedy be specified? If so, has it been?
6. Are the cost estimates for the alternatives reasonable? Do they allow a realistic
comparison of costs of alternatives over the life of the project, including O & M?
7. Are there other alternatives or approaches which could achieve remedial action
goals with less cost or more reliability?
8. Have state, PRP, and community positions been considered?
9. Is the proposed action consistent with other Agency decisions?
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Appendix B:
Summary of Project Management Pilots
Introduction
Nine project management pilot projects were identified under ICI Action 17 based on
their potential to demonstrate substantial Superfund remedial process improvements. Some pilots
seek to demonstrate the effectiveness of region-specific best practices while others are designed
to evaluate the potential benefit of new approaches to site project management. The following
narratives describe the regional plans for these nine pilots as of April 2011. The pilots address
work at the following sites:
Davis Liquid Waste (Smithfield, RI)
Ellenville Scrap Iron and Metal (Ellenville, NY)
South Jersey Clothing Company/Garden State Cleaners (Buena Borough, NJ)
Flash Cleaners (Pompano Beach, FL)
U. S. Finishing / Cone Mills (Greenville, SC)
Velsicol Burn Pit (St. Louis, MI)
McGaffey and Main (Roswell, NM)
Van der Horst USA Corporation (Terrell, TX)
McClellan Air Force Base (Sacramento County, CA)
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1. Davis Liquid Waste (Smithfield, RI)
Purpose:
To expedite Remedial Design/Remedial Action (RD/RA) negotiations with Potentially
Responsible Parties (PRPs) by using the site's special account as leverage.
Project Description:
The purpose of the pilot is to demonstrate if the existence of a site-specific special account with
sufficient funding for the remaining site remediation would provide the Region with sufficient
leverage to expedite RD/RA settlement negotiations. A key factor at this site is an existing
judicial finding of liability against all of the remaining PRPs.
The Davis Liquid Waste site was placed on the National Priorities List (NPL) in September
1983. The U. S. government litigated site liability with over 50 defendants in the early 1990's.
This litigation culminated in a series of settlements for performance of the source control remedy
and also established a site-specific special account containing approximately $12 million. The
main settling defendant and performing party was United Technologies Co. (UTC). UTC in turn
sued numerous third- and fourth-party defendants. Most of those settled with UTC and the U. S.
government throughout the 1990's and early 2000's. UTC and others performed the source
control work which EPA certified as complete in 2003.
UTC's contribution lawsuits resulted in a District Court's finding of liability in contribution
against five parties (the "Judgment Parties"): namely, Ashland, Black & Decker, Acco-Bristol,
Morton International and Perkin Elmer. These five parties have not performed any work or
contributed to any settlement for the site. Although Ashland has done some pre-design
groundwater studies, EPA will look to the five Judgment Parties to perform the groundwater
remedy for the site.
The remedy to be negotiated addresses contaminated groundwater migration. EPA issued a ROD
amendment in September 2010 to change the original pump-and-treat remedy to in-situ chemical
oxidation.
Period of Performance:
January 2011 to September 2011. The period began on January 5, 2011, with issuance of special
notice for the performance of RD/RA, which initiated the start of negotiations and will end when
negotiations are completed. These milestones are tracked in CERCLIS and should be comparable
from one site to another. The Region will use the last five years of CERCLIS data to estimate
historical time frames for comparison with the time line for issuance of special notice to
completion of negotiations for the pilot.
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Efficiency Goals:
It is the Region's premise that the national shortage of Superfund Trust Funds for remedial
actions over the past five years has hindered EPA's ability to secure RD/RA settlements in a
timely manner. The overall goal of the pilot is to use the special account as leverage in an
attempt to expedite the RD/RA negotiations with the PRPs.
Benchmarking References:
The Region used the past five years of CERCLIS data from 13 other PRP-lead sites to establish
an average baseline of successful RD/RA settlement negotiation time frames. This time frame is
defined as beginning with special notice issuance and ending when negotiations are completed.
The average time frame for the 13 sites examined was 508 days (17 months); the range was 202
days (6.7 months) to 839 days (27 months).
Replication Opportunities:
The Davis Liquid site circumstances may be unique in that there is a significant amount of funds
available in the special account from prior settlements to finance the remaining site work if the
PRP group cannot coalesce or otherwise agree to settlement in a timely manner. If the pilot is
successful, an inventory of site-specific special accounts versus site-specific remedial action
needs should be performed to identify other sites presenting similar opportunities.
Potential Barriers to Broader Application:
It is unknown how many other NPL sites have special accounts of sufficient size to fund
remedial work at the site.
Special accounts often have restrictions on the use of the funds; the specific language in any
given special account would need to be examined to ensure that the Region's proposed use is
legally permissible under the Consent Decree or other settlement agreement.
Use of the special account would also obviate the need for Remedial Action Prioritization Panel
consideration of a remedial action funding request; current procedures for OSRTI/OSRE
concurrence with special account spending plans would need to be examined to determine if any
changes are necessary.
The liability determinations at Davis Liquid are relatively unique. At other sites, PRPs may argue
liability thereby lengthening negotiation times.
For more information about this site, please visit the following websites:
www.epa.gov/ne/superfund/sites/davisliquid
http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0101283
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2. Ellenville Scrap Iron and Metal (Ellenville, NY)
Purpose:
To accelerate the remedial design and remedial action through an "integrated project delivery"
approach.
Project Description:
The site is a 24-acre former scrap iron and metal reclamation facility located in the Town of
Wawarsing, Village of Ellenville, Ulster County, New York. Approximately 10 acres of the site
were used for a variety of scrap metal operations and battery reclamation. One of several
residential properties located immediately to the east of the site was formerly part of the facility
and was used for equipment and scrap battery storage and disposal. There is an existing soil-
capped landfill on the site.
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 along with
attendant support activities.
Period of Performance:
July 2010 to September 2011. EPA and the U. S. Army Corps of Engineers (USACE) began
planning this pilot project in July 2010. EPA issued the site's record of decision (ROD) in
September 2010 and executed an Interagency Agreement (IA) with the USACE to provide
remedial design and construction services. The approach called for access of pre-placed contracts
for provision of design and construction activities. The management techniques employed in
project execution are designed with the intent of achieving both time and cost efficiencies in
project delivery. All activities and results will be analyzed and documented. Construction
activities within the scope of this pilot are projected to take place through September 2011.
Activity/Event
Project planning meetings
Public meeting on proposed plan
Pre-design task order
ROD issued - landfill cap selected remedy
Issue USACE IA
Notify selected remedial design and remedial
action contractors
Project team meeting/site visit
Pre-design investigation reports
Final design with plans and specs
Construction field mobilization on site
Final inspection
Completion of pilot activities
Date
July 2010
August 18,2010
August 25, 2010
September 3 0,2010
September 3 0,2010
September 3 0,2010
October 20, 2010
February 2010
March 4, 2011
April 4, 2011
September 15, 2011
September 3 0,2011
Status
Completed
Completed
Completed
Completed
Completed
Completed
Completed
Completed
Completed
Completed
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Efficiency Goal:
The goal of this pilot project is to demonstrate and document the applicability of project delivery
techniques to a discrete set of engineering activities related to the cleanup of a hazardous waste
site with an eye towards maximizing time and cost efficiencies without compromising quality or
health and safety. By employing project integration, an approach which seeks to bring all active
participants on board to the project as early as possible, activities can be conducted in parallel
and the synergy among team members can be employed to maximum advantage.
Benchmarking References:
Results of this pilot will be compared to constructed project delivery models using historical
program operational procedures and conventional techniques for procurement and management
of design and construction services.
Replication Opportunities:
Uncontrolled hazardous waste sites are characteristically complex with a high degree of
variability. Therefore, any cleanup management approach must be tailored to site circumstances.
There are numerous techniques that can be employed for project delivery. As part of the final
report for this pilot, the specific project characteristics that lend themselves to applicability of the
techniques investigated will be assessed and extrapolated in terms of replication potential.
Potential Barriers to Broader Application:
Some factors which may contribute to delay of a fund-lead project are the following: (1) funding
constraints, which are dependent on the approval of the state superfund contract (a prerequisite
for obligation of remedial action funds); (2) internal operational processes and review procedures
associated with resource allocation; (3) property access and procurement issues; (4) contractor
procurement issues; (5) weather constraints, considering the nature of the required outdoor work;
(6) perception that initiating pre-design and remedial action activities before the ROD is signed
may be pre-decisional; and, (7) the negotiation process associated with PRP-lead activities would
preclude this approach as an option, since the scope of work is negotiated upon completion of the
ROD as part of the overall consent decree negotiations. Additionally, this pilot was selected with
some prerequisite criteria: (1) there were no enforcement-related complications associated with
the presence of PRPs; (2) both the State and the local community were highly supportive; and,
(3) site conditions were conducive to a straightforward, proven engineering approach.
For more information about this site, please visit the following websites:
http://www.epa.gov/region02/superfund/npl/ellenville/
http://cumulis. epa.gov/supercpad/cursites/csitinfo. cfm?id=0204190
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3. South Jersey Clothing Company/Garden State Cleaners (Buena Borough, NJ)
Purpose:
To accelerate remedial design and remedial action through the use of in-house EPA staff.
Project Description:
The South Jersey Clothing Company (SJCC) and Garden State Cleaners (GSC) sites are two
separate properties which have soil contaminated with volatile organic chemicals resulting in a
co-mingled groundwater plume. In September 2010, EPA issued a Record of Decision (ROD)
amendment which called for excavation of contaminated soil, in-situ treatment of soil that cannot
be practicably excavated, and acquisition and demolition of the GSC building.
Regional staff will prepare a remedial design report, which will be provided to the Region's
Removal Action Branch. The US Corps of Engineers (USAGE) will prepare design drawings for
the excavation work, as EPA does not have the capability to produce these in-house. The
Removal Action Branch will demolish the GSC building and excavate the contaminated soil
from both properties and dispose of it off-site. Three remedial action reports will be prepared.
The pilot was designed to achieve both time and cost savings through utilization of EPA in-
house staff during the remedial design and remedial action.
Period of Performance:
Date
Activity/Event
Description
Status
October 2010
Start of remedial
design
In-house EPA staff prepares remedial
design sampling plan for the excavation
portions of the remedy. EPA enters into
an Interagency Agreement (IA) with
USAGE to provide technical assistance
and design drawings for this work.
Completed
January-
February 2011
Soil Sampling
Environmental Response Team (ERT)
collects soil samples to delineate the
areas of soil excavation at both sites.
Completed
June 2011
GSC acquisition
EPA acquires the GSC property through
an IA with USACE.
Awaiting
directive for
acquisition
from Office
of General
Counsel.
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June 20 11
June 20 11
June 20 11
June- August
2011
September 20 11
GSC demolition
GSC additional
sampling
Remedial design
report
Excavation of
contaminated coils
Remedial action
reports
Removal Action Branch demolishes the
GSC building.
After GSC building demolition,
additional soil samples may be collected.
EPA in-house staff prepares remedial
design report, which will be provided to
the Removal Action Branch. The
USAGE prepares design drawings for
the excavation work.
Contaminated soils excavated at both
sites and disposed of off-site.
Three remedial action reports are
prepared; one for building demolition
and two for soil excavations.
-
-
-
-
-
Efficiency Goals:
The goals of this project are to demonstrate the efficiency and cost-effectiveness of using in-
house resources to perform remedial design and construction activities for a project with a
clearly defined scope. Savings in both cost and time should be realized within a year or less. The
time estimate does not account for any delays in the acquisition of real property needed for the
building demolition.
Benchmarking Reference(s):
Since a schedule and a cost estimate for the traditional approach and methodology were not
prepared prior to the implementation of the pilot, the pilot's costs and implementation time frame
will be compared to a generic cost and time frame estimate for a similar project.
Replication Opportunities:
This approach may be followed at similar sites with clearly defined project scopes.
Potential Barriers to Broader Application:
In general, some barriers to this approach include competing regional priorities and resource
availability (e.g., regional staff and management's time). For example, expediting one site may
cause work at another site to proceed slower. Also, the in-house generation of work plans and
reports takes time and resources not usually expended as part of remedial design activities. Some
barriers to this pilot project's success, in particular, may lie in delays in the real estate acquisition
and funding availability.
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For further information about these sites, please visit the following websites:
South Jersey Clothing Company:
http://www.epa.gov/region02/superfund/npl/sjcc/index.httnl
http://cumulis. epa.gov/supercpad/cursites/csitinfo. cfm?id=0200803
Garden State Cleaners:
http://www.epa.gov/region02/superfund/npl/gsc/
http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0200362
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4. Flash Cleaners (Pompano Beach, FL)
Purpose:
To accelerate the remedial design (RD) and the remedial action (RA) by conducting the RD with
theRA.
Project Description:
The Flash Cleaners site is approximately a half-acre in size and access to the property is
unrestricted. Currently, the business operates as a pick-up and drop-off for outsourced dry
cleaning, but from 1977 to about 2001, dry cleaning operations were conducted onsite. Soil and
groundwater are contaminated with tetrachloroethylene (PCE) and other chlorinated
hydrocarbons. The RD began concurrently with finalizing the Remedial Investigation/Feasibility
Study and preparing the Record of Decision (ROD) to reduce the amount of time until the RA
would start. In addition, the contractor prepared the soil design first, separate from the
groundwater design to allow the soil RA to begin earlier than it would have if the Region had
waited until both the soil and groundwater designs were completed. The soil vapor extraction
(SVE) remedy selected is proven for dry cleaning sites in Florida and can be constructed by the
Emergency and Rapid Response Services (ERRS) contractor. While the soil is excavated and the
SVE system is constructed, the groundwater RD will be completed. The same RD contractor will
oversee the construction of the RA for the groundwater thereby saving the time it would take for
a new contractor to come up to speed on the project. Conducting activities concurrently will
allow the RAs to be completed by September 2011.
Period of Performance:
August 2010 to September 2011. In August 2010, the RD for the Flash Cleaners site was
awarded to the Response Action Contractor. The ROD was signed in September 2010. In
November 2010, RD field activities were conducted which included a pilot study for the SVE
system as well as soil sampling to define better the extent of excavation. The RD for the
contaminated soils was completed in April 2011. The RD for the groundwater contamination is
ongoing. Also, the RA contract has been awarded to the ERRS contractor who mobilized in the
field in late March. The soil RA is expected to be completed by June 2011 and the groundwater
RA is expected to begin shortly thereafter. A pre-final inspection is scheduled for August 2011,
and the pre-final inspection report and interim RA report are expected by September 2011. A
pilot project evaluation report will be completed in the fall of 2011 to document the accelerated
delivery of the RD/RA and achievement of site construction completion.
Efficiency Goal:
The overriding efficiency goal of this pilot is to save time (and thus money) by shortening the
duration of the RD/RA process. As described above, the traditional approach is to conduct RD
and RA activities consecutively. Utilizing a concurrent approach to completing the RD and RA,
as well as the flexibility inherent in the ERRS contract, is expected to shorten the project
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schedule by one year. In addition to saving time overall, this approach also has efficiencies
associated with dual purpose mobilizations. While the ERRS contractor is on site conducting the
soil cleanup, the RD contractor can be tasked to mobilize for sampling/treatability testing for the
groundwater remedy. This efficiency will save travel funds and time for the remedial project
manager. In addition, although separate contractors will perform the design and construction
activities, this approach allows for more collaboration than usual because both contractors will
be on-site working together on the soil phase while the groundwater phase is being designed.
Benchmarking References:
Since a schedule and a cost estimate for the traditional approach and methodology were not
prepared prior to the implementation of the pilot, the pilot costs and implementation time frame
will be compared to a generic cost and time frame estimate for a similar project.
Replication Opportunities:
This pilot has significant potential for replication. A large percentage of remedial sites have soil
and groundwater components. The concepts developed during this pilot should be directly
applicable to many or all sites with both components. Some regions have contracting processes
that allow for this approach, while other regions should have the flexibility to apply this
technique.
Potential Barriers to Broader Application:
Cultural barriers (e.g., "that's not the way we do it") may pose an impediment to this approach.
In addition, the Superfund program's accomplishment tracking system and definitions have RD
preceding RA. These administrative definitions may need to be modified so that regional RD/RA
accomplishments can be recognized in this system.
For further information about this site, please visit the following websites:
http://www.epa.gov/region4/waste/npl/nplfls/flashclfls.htm
http://cumulis. epa.gov/supercpad/cursites/csitinfo. cfm?id=0407492
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5. U. S. Finishing / Cone Mills (Greenville, SC)
Purpose:
To expedite the Remedial Investigation/Feasibility Study (RI/FS) process through the use of an
integrated project team.
Project Description:
The property is currently inactive due to a fire in 2003; however several abandoned structures
remain on the property. The property as originally constructed in 1903 was a textile bleaching
and finishing operation. Subsequent activities at the facility involved dying fabrics. In 1984, the
current owner, involved in fabric finishing operations, acquired the property. The area of known
contamination is approximately 14 acres.
This pilot project will demonstrate an innovative combination of management approaches and
accelerated cleanup techniques to expedite the project through the Superfund pipeline from
proposal to the National Priorities List (NPL) to a site-wide Record of Decision in an efficient,
expedited and stakeholder-supported fashion. The project will utilize an adaptive project
management framework integrating federal, state and contractor resources to produce a team
with the requisite skills and decision-making authority. The project will engage the community
and key stakeholders early and throughout the process to provide transparency and an active role
in cleanup decisions preparing the site for productive use.
Period of Performance:
April 2011 to September 2013. In March 2011, the site was proposed to the NPL. Field work for
the RI sampling is expected to begin during the summer of 2011.
Efficiency Goals:
The pilot project's purpose is to develop and use an integrated team including EPA, state,
contractor and community resources to implement an expedited RI/FS. The pilot will utilize the
regional Superfund work break down structure as a basis to produce a baseline project schedule
to track performance, allocate resources and identify key decision points. Examples of methods
the pilot will use to expedite the process include: (1) assigning an remedial project manager prior
to the site's proposal to the NPL; (2) implementing Triad field techniques in concert with multi-
organizational field teams to support real-time decision making; (3) integrated work planning to
support the RI human health and ecological risk assessments, and engineering data quality
objectives (DQOs) to minimize the number of field deployments; and, (4) involving community
stakeholders in site activities throughout the project, including scoping meetings, and key
decision points.
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Benchmarking Reference(s):
Two approaches will be used to track and benchmark performance. First, a detailed baseline
schedule for the project integrating all involved resources will be developed in Microsoft Project,
and performance (deviations) will be tracked and analyzed on a quarterly basis. Second, at the
completion of each major milestone, both cost and schedule will be compared to regional
averages from CERCLIS for the corresponding phase of work.
Replication Opportunities:
The pilot has significant potential for replication. Detailed records of the schedule and cost
performance relative to baseline planning will be well documented. A "lessons learned"
evaluation will be included in the RI/FS report documenting the advantages and disadvantages of
the management approach with focus on the integration of DQOs involving multiple
stakeholders; merged federal, state and contractor resources; and community engagement at key
project decision points. Separately, cost and performance under the piloted model integrated
Response Action Contractor RI/FS work assignment will be compared to typical cost and
performance using the standard RI/FS work assignment. The scope of work developed during the
pilot project can then be adapted for other sites.
Potential Barriers to Broader Application:
Barriers for this project will include getting site stakeholders to accept the integrated approach
and limited field deployments to achieve a successful expedited RI/FS. Funding and contractual
issues with this approach may also present potential barriers.
For further information about this site, please visit the following websites:
http://www.epa.gov/superfund/sites/npl/narl835.htm
http://cumulis. epa.gov/supercpad/cursites/csitinfo. cfm?id=0403254
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6. Velsicol Burn Pit (St. Louis, MI)
Purpose:
To streamline the investigation and alternatives development processes through early
collaboration between EPA regional and headquarters staff.
Project Description:
The Velsicol Burn Pit site was proposed for the National Priorities List (NPL) in September
2009 and listed as final in March 2010. The site, formerly known as the Gratiot County Golf
Course site, covers approximately five acres in St. Louis, Michigan. The Golf Course site was
first proposed for the NPL in December 1982. Cleanup actions were completed by Velsicol (the
potentially responsible party) before the NPL listing was finalized. In November 1982, Velsicol
agreed to a combined settlement for cleanup of this site and two others in Michigan, namely, the
Gratiot County Landfill and the Velsicol Chemical Corp. plant in St. Louis, Michigan.
Contaminated soils were removed from the Golf Course site and disposed of at the Velsicol
Chemical Corp. site in accordance with the 1982 cleanup plan. Additionally, contaminated
groundwater underlying the golf course area was co-mingled with contamination at neighboring
sites and was addressed as part of their cleanup strategy. After the contaminated soils were
removed from the site, site evaluations at the time determined that no additional cleanup work
was required, and the Golf Course site was deleted from the NPL in September 1983. The site
continues to be used as a recreational golf course while cleanup actions continue at the Velsicol
Chemical Corp site.
As part of the RI for Operable Unit One (OU1) of the Velsicol Chemical Corp. site, to determine
if additional cleanup actions are necessary, the Michigan Department of Environmental Quality
(MDEQ) re-investigated the "former burn area" at the Golf Course site. The RI report was
released in late 2006 and a public meeting was held to discuss the findings. The report concluded
that remedial activities would likely be necessary to address areas of soil and groundwater
contamination at the "former burn area" and recommended that additional investigational
activities be conducted to provide more information about the nature and extent of
contamination. MDEQ initiated additional RI field activities at the Golf Course site and issued a
report on its findings in January 2009.
The objective of this pilot is to expedite the investigatory (RI) and alternatives development (FS)
processes by using existing data or limited collection of new data and by collaborating with EPA
headquarters earlier in the process, thereby significantly reducing or eliminating the headquarters
consultation processes at decision-making.
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Period of Performance:
Summer 2011 through spring 2012. The period will begin after completion of the National
Remedy Review Board and decision-making process for the Velsicol Chemical Corporation site
as the region expects significant headquarters consultation, and public interest on this complex
and potentially costly site.
Efficiency Goals:
By engaging in a collaborative effort with headquarters staff earlier, consultation may be
significantly reduced, or eliminated, during the proposed plan and decision-making phases.
Benchmarking References:
The region has never had an opportunity to expedite the site schedule in this way. Comparing it
to previous site timelines for even a subset of the entire RI/FS process may be difficult.
However, the uniqueness of the project allows the Agency to explore alternative strategies for
accelerating project completion and apply any lessons learned to more complex sites in the
future.
Replication Opportunities:
The Velsicol Burn Pit site circumstances may be unique because a significant amount of
information and data were collected by EPA in the past as well as more recently during the
MDEQ's Velsicol Chemical Corporation site investigations. Little or no additional investigatory
data may be needed prior to completing the risk assessment and feasibility study. However, the
pilot provides an opportunity to explore alternative strategies for regional and headquarters
consultation earlier in the feasibility study process so that the proposed plan and record of
decision consultation may be significantly reduced or eliminated.
Potential Barriers to Broader Application:
• The working relationship between EPA and MDEQ can be challenging from time to time.
• The presence of dense non aqueous phase liquids may complicate the site remedy.
For further information about this site, please visit the following websites:
http://www.epa.gov/region5/cleanup/velsicolmichigan/index.html
http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0510389
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7. McGaffey and Main (Roswell, NM)
Purpose:
To demonstrate how the application of optimization (e.g., incorporating a third-party expert
team) during the remedial design (RD) and remedial action (RA) phases of a remedy may benefit
site cleanup.
Project Description:
This pilot will demonstrate the application of optimization during the RD and RA phases of a
remedy. The demonstration is intended to illustrate how incorporating optimization by a third-
party team of experts during remedial design and implementation can help improve remedy
effectiveness, reduce remedy life-cycle cost, and speed remedy implementation within the Fund-
lead program.
The McGaffey & Main (M&M) Superfund site in Roswell, New Mexico is the subject of this
pilot project. The site is in the early design phase of a multi-component remedial strategy. The
primary remedial components for the M&M site include the following elements: (1) source area
soil, soil gas, and indoor air; (2) source area groundwater; and, (3) groundwater plume area.
This pilot will only address the vapor intrusion mitigation system (VIMS).
Period of Performance:
December 2010 to December 2011. These dates reflect the period beginning with the start of the
remedial design and completion of the construction of the VIMS.
Efficiency Goal:
OSRTI's working definition of optimization is as follows:
Remediation optimization is systematic site review by a team of independent
technical experts, at any phase of a cleanup process, to identify opportunities to
improve remedy protectiveness, effectiveness and cost efficiency, and to facilitate
progress toward site completion.
Therefore, the goal of this pilot project is for the optimization process to have a net positive
effect on the remedy by improving remedy protectiveness, effectiveness and cost efficiency,
and/or facilitating progress toward site completion. Improvements in remedy protectiveness can
include reducing the time required to eliminate exposures or control migration. In some cases,
there will be tradeoffs, such as accelerating one aspect of the remedy to control human exposure
at the expense of postponing other aspects of the remedy. The pilot project team and site team
will work together to establish priorities and achieve those priorities.
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Benchmarking References:
The results of this optimization pilot will be measured in terms of cost and schedule. The
estimated costs for the action are $ 0.85 million for the construction of the VIMS and $ 2.85
million for its first ten years of operation. The design of the system is planned to be completed
by July 22, 2011 and the construction is planned to begin by October 1, 2011. A benchmark
reference for protectiveness, other than the time to eliminate exposures or control migration is
not feasible given that the selective remedy is inherently protective of human health and the
environment.
Replication Opportunities:
Optimization evaluations have been applied extensively at operating remedies but only on a
limited basis during the design stage. The technique involves connecting a third-party team of
experts with the regional project team to review and comment during the design and construction
process. Replication of the process at other sites would be straightforward.
Potential Barriers to Broader Application:
Broad application of the process may be limited by: (1) available funding for optimization
teams; (2) the pool of qualified experts to participate on the third-party team; and, (3) project
timing. Each of these is discussed below:
• Funding availability includes the amount of funding available as well as the timing of the
funding. The optimization team and the design team are often funded through separate
mechanisms, and incremental funding for either team, if delayed, can disrupt coordinated
activity or delay the optimization effort.
• Multiple qualified experts with different backgrounds are often needed for an
optimization team at a particular site (e.g., a remedial engineer and hydrogeologist), and
the experts need to have extensive experience with the type of remedy, site conditions,
and optimization process of interest.
• With respect to timing, design is a dynamic process that can occur over a relatively short
time frame. An optimization team needs to be able to work quickly to provide input
during the design process so that the third-party perspective can be provided without
delaying the design schedule. The intensity of optimization work during design can also
vary. Optimization input may be limited during extensive periods of data collection, but
could sharply increase when that data are available for review and interpretation. For
consistency, the same optimization team should be involved throughout the process.
For further information about this site, please visit the following websites:
http://www.epa.gov/region6/6sf/pdffiles/0605386.pdf
http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0605386
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8. Van der Horst USA Corporation (Terrell, TX)
Purpose:
To expedite remedial investigation/feasibility study (RI/FS) activities through early stake holder
collaboration aimed at fast-tracking field work and decision making.
Project Description:
The Van der Horst USA Corporation Superfund site was a former chromium- and iron-plating
facility encompassing approximately four acres. A 2009 removal action addressed a 46,000
square foot building and all contents situated on the site, which was used primarily for hard-
chrome (tri- and hexavalent chromium) plating operations. The RI/FS is designed to address
groundwater contamination since all aboveground contaminated media have been addressed.
The pilot includes several measures to achieve its objective. Early coordination and collaboration
among the remedial project manager (RPM) and site stakeholders are expected to result in less
conflict and increased efficiency during the RI/FS. Innovative adaptive management techniques
will be used during the RI field effort to avoid multiple rounds of sampling. The RPM and risk
assessor will be on-site during the RI sampling activities to make real-time decisions in the field.
In addition, areas identified that may require remediation will be evaluated under EPA's removal
authority to identify actions that may be taken under that authority.
Period of Performance:
April 2011 to September 2012. The RI/FS was funded in September 2010, and field work is
scheduled to begin in April 2011. The Record of Decision (ROD) is scheduled to be issued in
September 2012.
Efficiency Goal:
Early coordination between the RPM and site stakeholders is expected to result in less conflict
and increased efficiency during the RI/FS. The efficiency goal consists of trimming
approximately 30 percent off the duration a conventional RI/FS. This percentage is based on
predicted savings comparing an average time line for an RI/FS (i.e., 24 months) with an
estimated accelerated time line for this RI/FS (i.e., 16 to 18 months).
Benchmarking References:
Historically, the average RI/FS process has taken approximately two years to complete. This
pilot seeks to reduce that time by 30 percent. Regularly scheduled reviews (i.e., weekly, monthly,
quarterly) of RI/FS activities will occur to address and resolve issues.
Replication Opportunities:
The Region may be able to apply the innovative adaptive management techniques developed
during this pilot to a variety of sites in the RI/FS process. The efficiencies achieved would
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include both time and cost savings due to proactive stakeholder coordination, streamlined
reviews, and early identification and resolution of issues.
Potential Barriers to Broader Application:
As this pilot pertains to an RI/FS which is limited to groundwater, the Region does not foresee
any barriers which could impede progress at this site. However, larger and more complicated
sites may not realize the same time savings when implementing adaptive management
techniques.
For further information about this site, please visit the following website:
http://www.epa.gov/superfund/sites/npl/narl810.htm
http://cumulis. epa.gov/supercpad/cursites/csitinfo. cfm?id=0606869
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9. McClellan Air Force Base (Sacramento County, CA)
Purpose:
To create a model to accelerate transfer of federal facilities property for productive reuse.
Project Description:
McClellan Air Force Base closed in 2001 following the 1995 Department of Defense (DOD)
Base Realignment and Closure (BRAC) recommendation. With base closure, 11,600 jobs were
lost. Through significant private and government investments ($580 million), McClellan
Business Park (MBP) is now one of the largest economic development and infill reuse projects in
northern California. Currently some 15,000 people live and work at MBP. Sacramento County
estimates that, when fully developed, MBP will have some 35,000 jobs and generate over $6.6
million per year in local property tax and $1.1 million per year in local sales tax revenue.
Under the transfer with privatized cleanup agreement, MBP, with oversight from EPA, will be
responsible for addressing contamination in the first 15 feet of soil below the surface, and can do
so concurrently with ongoing redevelopment efforts. The Air Force will continue cleaning up the
groundwater and deeper soil.
Two rounds of early transfers with prioritized cleanup have been completed. Based on this
experience, the current transfer has been proposed for this pilot. The pilot is designed to
demonstrate:
- Streamlined cleanup due to dedicated funding sources;
- Elimination of hurdles caused by FFA enforcement and DOD policies;
- Integration of development and cleanup to accelerate productive reuse; and
- Facilitation of property transfers to subsequent owners, reflecting real value in the
efforts/investments in revitalization.
Period of Performance:
January 2011 to December 2012. The time frame for the pilot project is the time required to
negotiate and finalize the documents necessary to transfer the property and cleanup obligations.
The goal would be the actual transfer of the property upon approval by EPA and the Governor of
the Finding of Suitability for Early Transfer (FOSET).
The interim milestones leading to property transfer would coincide with the finalization of each
of the required legal and financial documents. These documents and the parties involved are:
1) Administrative order on consent - EPA, state and McClellan Business Park (MBP).
2) Statement of work (SOW) - EPA, state and MBP.
3) FOSET - Air Force, EPA and state.
4) Federal facilities agreement (FFA) amendment - Air Force, EPA and state.
5) Environmental services cooperative agreement - Air Force and county.
6) McClellan remediation agreement - MBP and county.
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Efficiency Goals:
This pilot seeks to demonstrate the following improvements and efficiencies:
1) Acceleration of property transfers to private owners, reflecting real value in the
efforts/investments in revitalization: With the ability to modify the property to suit
prospective buyers, early transfer with privatized cleanup properties may appear more
desirable to companies in the commercial/industrial real estate market. As companies
locate to these properties, the local community and economy benefit from the addition of
jobs and tax revenue.
2) Improved coordination: It is hoped that, by increasing communication and awareness of
the privatization approach with the private and public entities involved, completion of the
overall agreement will be expedited and the degree to which legal and procedural aspects
of privatization are revisited will be reduced.
Benchmarking Method:
The original privatization agreement, which involved 62 acres, took five to six years to complete.
This length of time was largely due to the need to generate original documents and have them
undergo high-level approval. The subsequent deal took approximately two years and involved
560 acres. It was expected that there would be efficiencies achieved in the negotiation of the
second round of privatization, and while many were realized, it is estimated that six to eight
months were lost dealing with new staff on previously established aspects of the process. The
goal is to complete the next agreement involving approximately 400 to 600 acres in less than two
years but also at a reduced workload. A benchmark for the workload involved in the process will
be established.
Replication Opportunities:
This pilot could be replicated at all manner of sites. The primary factor is the availability and
interest of a bona fide prospective purchaser interested in performing the work under CERCLA
and obtaining title to the property. Economic conditions play a factor in the desirability of any
particular property. If the site is a federal facility, the federal agency must also be interested in
stepping way from its role as the lead/remedy-selecting agency.
Potential Barriers to Broader Application:
Most work at BRAC sites is already coming to close and unless there are future base closures,
the universe of sites where this specific model can be applied is dwindling.
For further information about this site, please visit the following websites:
www.epa.gov/region9/McClellanAFB
http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0902759
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