&EPA
United States
Environmental Protection
Agency
542-R-13-008
June 2013
Office of Solid Waste and Emergency Response
Office of Superfund Remediation and Technology Innovation
Remediation Optimization: Definition, Scope and Approach
Background
For more than a decade, the U.S. Environmental Protection
Agency's Office of Superfund Remediation and Technology
Innovation (OSRTI) has provided technical support to EPA
Regional offices through the use of third-party optimization
evaluations. OSRTI has conducted more than 150 optimization
studies for Superfund and other EPA programs nationwide.
In September 2012, OSRTI finalized its National Strategy to
Expand Superfund Optimization Practices from Site Assessment to
Site Completion (Strategy).1 The Strategy unifies the previously
independent optimization efforts (such as RSE, IDR and LTMO)
with other practices complimentary to optimization (such as the
Triad Approach and Green Remediation) under the singular term
"optimization," which can be applied at any stage of the Superfund
project pipeline. The Strategy also encourages other activities
intended to facilitate better site characterization, remedy selection,
remedy design, construction and operation of the remedy, by
applying various techniques and methods to improve a given
project's scope, schedule and cost.
This document provides a general definition, scope and approach
for conducting optimization reviews within the Superfund Program
and includes the fundamental principles and themes common to
optimization. It should be noted that although this document has
been developed for optimization support in the Superfund Program, OSRTI acknowledges that the content of the
document can apply to optimization in other remedial programs or regulatory frameworks.
What is Optimization?
The EPA's Strategy defines optimization as:
"Efforts at any phase of the removal or remedial response to identify and implement specific
actions that improve the effectiveness and cost-efficiency of that phase. Such actions may also
improve the remedy's protectiveness and long-term implementation which may facilitate
progress towards site completion. To identify these opportunities, regions may use a systematic
site review by a team of independent technical experts, apply techniques or principles from
Green Remediation or Triad, or apply other approaches to identify opportunities for greater
efficiency and effectiveness. "2
Prior to the implementation of EPA's
Strategy, optimization support was
known by the remedial phases or for
the type of support provided. These
terms and acronyms have been phased
out; however, they are provided below
for clarification.
> Remediation System Evaluation
(RSE) - optimization support
during a Long-term Response
Action (LTRA) or Operation and
Maintenance (O&M).
> Independent Design Review
(IDR) - optimization at the remedy
selection, design, re-design stage.
> Long-Term Monitoring
Optimization (LTMO) -
optimization focused on long-term
monitoring programs.
1 U.S. Environmental Protection Agency. 2012. Memorandum: Transmittal of the National Strategy to Expand Superfund Optimization Practices from Site
Assessment to Site Completion. From: James. E. Woolford, Director Office of Superfund Remediation and Technology Innovation. To: Superfund National
Policy Managers (Regions 1 - 10). Office of Solid Waste and Emergency Response (OSWER) 9200.3-75. September 28, 2012.
2 The EPA encourages contractors, states, tribes, the public and PRPs to propose specific opportunities to improve protectiveness and efficiency for the Agency to consider.
Remediation Optimization: Definition, Scope and Approach
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Optimization focuses on protectiveness, effectiveness, cost efficiency, technical improvement, progress toward site
completion, site closure and environmental footprint reduction (qualitative or quantitative). The key components of
optimization and the remedial pipeline phases at which optimization can be applied are shown in Figure 1. An
optimization review considers the goals of the remedy, available site data, the conceptual site model (CSM), remedy
performance and exit strategy. Optimization review activities include: examining site documents, interviewing site
stakeholders, potentially visiting the site, evaluating site data, developing findings and recommendations and
compiling a report for the purposes of project documentation and technology transfer. The recommendations are
intended to help the site team identify opportunities for improvements in these areas.
Figure 1 - Optimization Applied to Cleanup Activities from Site Assessment to Site Completion
Optimization Compo
Remedy
Components
Site Discovery
'le/
Monitoring
Optimization
Stages
Investigation Stage
Site Assessment
0
Remedial Investigation
Design Stage
Remedy Stage
Long-term Monitoring Stage
Remedial Action
O^^
Long-term Response Action
Site Completion
Operation & Maintenance
The definition refers to a "systematic site review," indicating that the site as a whole is often assessed in the review.
However, optimization may also be applied only to a specific aspect of a site (for example, one of several operable
units or a specific remedial technology). Other site or remedy components are considered to the degree that they
impact the specific aspect under consideration. Optimization may be applied at multiple phases of the remedial
process for the same site, where appropriate. It is important that optimization be conducted by independent, third-
party experts to provide an unbiased perspective of the site.
What is the Typical Scope of an Optimization Review?
Optimization reviews typically involve the following elements:
> Logistics, planning and scoping of optimization review activities
> Document and data collection and initial review
> Consultation with site stakeholders (either through an onsite meeting or conference call)
> Detailed data analysis
> Presentation of preliminary optimization findings and recommendations (such as a draft report, a technical
memorandum or web conference presentation)
> Finalization of the optimization findings and recommendations
> Implementation of recommendations
> Tracking of recommendation implementation
> Technical support for existing recommendations, as appropriate
> Potential future optimization event(s) at the site
Remediation Optimization: Definition, Scope and Approach
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Logistics, Planning and Scoping - This set of activities typically involves an introductory call between the site and
optimization review teams to confirm the scope of optimization activities, initiate the transfer of documents and data
for review by the optimization review team, set the schedule and logistics for an onsite visit and meeting (if
appropriate), plan for stakeholder interviews and set a schedule for presenting the optimization findings and
recommendations.
Document and Data Collection and Initial Review - The document review process includes documents from the
current pipeline stage and may include documents from any prior pipeline stage. Table 1 presents typical documents
and data that are most commonly reviewed during an optimization event.
Table 1 - Typical Documents and Data Reviewed During Optimization at Primary Pipeline Stages
Investigation/Feasibility Study | Design ] RA/LTRA/O&M
Preliminary Assessment/Site
Inspection (PA/SI) Report
Technical Memorandums
Investigation work plans
Quality Assurance Project Plan
(QAPP)
CSM, including, but not limited to:
o Historical site information
o Local/regional geologic and
hydrogeologic information
o Information from online database
reports
o Any other relevant documents or
data sets
Remedial Investigation (RI) Report
Supplemental RI Reports
Feasibility Study (FS) Report
CSM updates
Record of Decision (ROD) or Interim
ROD
Design technical memorandums
Design criteria/basis reports
Interim design reports
Modeling or 3-D visualization and
analysis reports
Remedy implementation cost
estimates
Any other relevant documents or data
sets
RI Report
Supplemental RI Reports
FS Report
CSM further updates
Decision documents (Proposed Plan, RODs,
ROD Amendments, Explanation of
Significant Differences [ESD])
Design documents
Operations and maintenance (O&M) manual
Recent system O&M reports*
Recent quarterly, semi-annual, or annual site
monitoring reports**
Five-year reviews
Any other relevant documents or data sets
* Typically the prior 12 months of weekly or monthly O&M reports.
* * Typically the prior 24 months of quarterly, semi-annual or annual monitoring reports; including databases of historical site data.
In addition, where appropriate and available for LTRA/O&M optimization, the following typical cost information
should be provided:
> Project management, technical support and reporting
> Site contractor labor (for example, plant operators, injection contractors and thermal remediation vendors)
> Utilities (for example, electricity, natural gas and potable water)
> Consumables (for example, general supplies, treatment materials, chemicals and nutrients)
> Waste disposal
> Groundwater sampling (for example, labor, equipment and travel)
> Laboratory analysis
Stakeholder Consultation - Ideally, interviews are conducted as a group during an onsite meeting or in a series of
conference calls and web meetings if there is no onsite meeting. The following individuals are typically consulted
during a review.
> EPA Remedial Project Manager (RPM)
> EPA technical project team members
> Other federal agency representatives (for example, U.S. Fish and Wildlife Service and U.S. Geological
Survey)
> State regulator/site or case manager
> Oversight consultant project manager (and potentially technical support personnel)
> Site contractors (including remedial system operator)
> Potentially responsible party or parties (if any)
Remediation Optimization: Definition, Scope and Approach
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Interviews with stakeholders may be conducted independently, but it is generally more effective if all parties are
present for the onsite meeting or conference calls. An optimization review agenda may be implemented over the
course of a one-day site visit, a lengthy conference call or a series of conference calls. Example agenda items for a
typical optimization review site meeting or conference call are provided in Attachment 1.
Detailed Data Analysis - This step is conducted independently by the optimization review team based on
information provided by the site team and includes many types of analysis including, but not limited to, those
summarized in Attachment 2.
Presentation of Draft Findings and Recommendations - Optimization findings and recommendations are typically
provided in a draft report or summary memorandum. EPA management or stakeholder presentations may also be
prepared, as requested, to summarize findings and recommendations. A typical draft optimization review report or
memorandum includes the following information:
> Executive summary
> General site background
> Summary of the characterization or remediation objectives
> Findings from document reviews, data analysis and interviews
> Recommendations (including expected costs/savings implications) that address critical data gaps, remedy
implementation, protectiveness, cost, and progress to site closure
Review of Draft Findings and Resolution of Comments - The draft report or summary memorandum is distributed
to the site team for review and comment. Feedback on the draft report is received, comments are addressed and a
draft final report is prepared.
Finalization of Optimization Findings and Recommendations - Upon presentation and acceptance of the draft
final report and the resolution of any remaining comments, the document is finalized.
Implementation of Recommendations - Regions implement recommendations based on confirmation with their
respective organizational decision-makers and available resources.
Tracking of Implementation of Recommendations - Follow-up includes conference calls conducted at specified
times after submission of the final optimization review report to determine which recommendations the site team has
considered, which recommendations have been or are planned to be implemented and which recommendations are
being declined and for what reasons. Costs and technical results from implementing recommendations are requested,
as well as feedback on the optimization review process. Follow-up generally occurs on an annual basis and continues
until all recommendations have been thoroughly considered by the site team.
Further Technical Support - Follow-on technical support by the optimization review team may also include: review
of additional reports or documents; development of CSM products/visualizations; sampling design; technology
evaluations; dynamic work strategies for additional characterization needs; and evaluation of site work plans in
relation to the current optimization event.
Additional Recommendations - Based on the purpose and focus of technical assistance provided to the site team,
additional recommendations may be provided for the site team's consideration and implementation.
Potential Future Optimization Event(s) at the Site - In some cases, additional optimization reviews are needed. In
these cases, repetition of background, previous findings and previous recommendations may not be merited in each
optimization submittal. Rather, a single summary document may be appropriate to provide general background and a
compilation of major findings and recommendations.
How Is Green Remediation Considered During Optimization?
Optimization reviews consider the effects of project activities and remedy operations on the environment to identify
site activities, technologies, supplies and associated resources which, if modified, could reduce the site's
environmental footprint. Recommendations for environmental footprint reduction (and associated costs and cost
savings) are provided. In addition, the optimization review report documents how recommendations made for other
purposes (for example, improving effectiveness or reducing cost) affect the site's environmental footprint. More
information on environmental footprint evaluation can be accessed at www.cluin.org/greenremediation.
Remediation Optimization: Definition, Scope and Approach 4
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How Do I Prepare For An Optimization Review?
One of the best ways to prepare for a review is to be aware of the types of questions that may be asked. Example
optimization review questions are provided below. In many cases, these questions are used to generate discussion
and to lead the optimization effort toward more direct and detailed questions. A more comprehensive list of
resources is provided for optimization reviews conducted at each stage of the remedial pipeline at
www.cluin.org/optimization.
1. Please provide a history of the site up to the present time. Please include any significant changes in the
approach or strategy taken at the site including ROD Amendments and ESDs (if any). Please note that many
aspects of this site history will provide discussion points.
2. What are the key site conditions, as reflected in the CSM (for example, sources, hydrogeology,
geochemistry, etc.)? How has new operational data (if any) changed the CSM? What data gaps exist in the
current CSM? Are the scales of measurements represented by the CSM appropriate for the proposed
investigations, designs or remedies?
3. What are the characterization objectives? What are the remedial action objectives (RAO)? Are they still
relevant and appropriate? Have there been any changes in conditions or policy since these objectives were
established?
4. Have end data users (for example, risk assessors, design engineers) been identified and engaged as part of
the site team? What are their data needs? Can these be addressed with collaborative data sets that combine
high spatial density of screening data or less rigorous analytical requirements with conventional laboratory
and field analytical data?
5. What is the data management strategy as related to project and site decision making? How are data collected,
stored, processed, evaluated and communicated? Would the project benefit from the use of 3-D visualization
and analysis or other decision support tools?
6. What are the stakeholder dynamics? Are the relationships collaborative or adversarial? What level of effort
is likely required to increase social capital to support achieving a consensus site vision with reasonable exit
strategies?
7. What is the current characterization or remedial strategy for the site? How has this strategy changed over
time? What elements of the remedy have led to these changes?
8. What aspects of the selected remedy and conceptual design cause the most concern about future
performance? What are the likely points of failure for the remedy?
9. What are the various sources of uncertainty in the characterization or remedy design? What is the priority for
addressing these uncertainties? What is the level of certainty about each major characterization or design
parameter? How sensitive is characterization or remedy performance and cost to this parameter?
10. How will remedy performance be evaluated to ensure satisfaction of RAOs? How will stakeholders know
the remedy is successful? What parameters will be measured? What values will indicate adequate
performance/progress or represent a trigger point for considering other remedial alternatives? How will these
data be used to evaluate the remedy?
11. For operating remedies, is the remedy performing as designed? How have site conditions changed since
design? Are the design parameters still valid?
12. What functions do the component technologies provide and what else could provide those functions more
effectively or efficiently?
13. What is the point of diminishing returns for the various aspects/components of the remedy? What
approaches/components would be more appropriate once this point of diminishing returns is reached?
14. Are there alternatives to any remedy components? Are there alternatives to the remedy itself? Are there
appropriate supplemental remedies (for example, bioaugmentation) for this site?
15. Is there remaining source material or indications of potential source material not being fully characterized?
What is its known extent? Could it be more effectively addressed with a more aggressive characterization
and or remedial strategy, with either yielding a higher degree of certainty?
Remediation Optimization: Definition, Scope and Approach 5
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Attachment 1. Example Agenda Items for Optimization Stakeholder Meeting
The following are examples of agenda items for an onsite meeting or conference call that may be used to facilitate a
group interview of site stakeholders. Because each optimization review is site-specific, the agenda is designed to
provide the optimization review team with information about the site characterization or remedial activities. Onsite
visits may include a site tour to facilitate some of this discussion. All or some of the following example agenda items
may be relevant based on the remedial phase, type of site, type of remedy, type of optimization support requested or
other site-specific circumstances.
Item
Example Optimization Stakeholder Meeting Agenda
Introductions - The EPA Headquarters Optimization Lead introduces the optimization review team and the
concept and activities to be conducted to complete the optimization review. Each participant is asked to
state their name, affiliation and role at the site.
The optimization review team reiterates the scope of the optimization review and indicates site-specific
issues to discuss based on their review of site documents.
Remedial Action Objectives (RAO) - A representative of the site team (typically the EPA Remedial Project
Manager [RPM] or site contractor) describes the RAOs and remedial strategy. Concurrence or perspectives
from all stakeholders is requested.
Conceptual Site Model (CSM) - A representative of the site team (typically the RPM or site contractor)
provides a brief description of the CSM, including a presentation of any graphic renderings. The following
are some of the CSM elements that would be discussed:
D Contaminants of concern and known or suspected sources
D Geology, hydrogeology, geochemistry and hydrology
D Contaminant fate and transport
D Previous and current remedies and their effectiveness to date
D Data gaps - can be prioritized or focused on uncertainties with high probability of occurrence and
significant potential impact to remedy performance or protectiveness
Protectiveness
D Receptors, potential receptors and exposure pathways
D Receptor and potential receptor assessment or sampling
D Plume capture or migration control
D Performance monitoring
D Institutional controls (1C)
D Engineering controls (EC)
Extraction/Injection/Delivery Systems
D Confirmation of system components and specifications
D Performance relative to design specifications
D Geologic/hydrogeologic complexity and potential impacts to remedy implementation
D Associated sampling and analysis
D Maintenance, fouling, etc.
Remedial System (if other than an extraction/injection/delivery system)
D Description of treatment system components and specifications
D Performance relative to design specifications
D Downtime and any recurring technical problems
D Operator responsibilities and level of effort
D Utilities, chemical and materials usage
D Process monitoring
D Water discharge and waste disposal
D Exceedances, accidental releases, etc.
D Opportunities for system simplification
Remediation Optimization: Definition, Scope and Approach
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Item
Example Optimization Stakeholder Meeting Agenda (continued)
Costs
D
D
D
D
D
D
Confirmation and clarification of provided cost information
Estimated life-cycle costs
Actual costs versus original cost estimates
Primary cost drivers
Opportunities for reducing cost
Challenges or obstacles to implementing cost reduction opportunities
Footprint Evaluation
D Amount of electrical energy used per year in kilowatt hours (kWh) and peak electrical demand in kW
D Types and quantities of other energy used (for example, propane, natural gas, diesel, etc.)
D Distance of staff from site (to evaluate vehicle usage and emissions)
D Types and quantities of constituents emitted to air from treatment processes
D Amount of potable water used and potential for using treated water
D Local provisions or sensitivity to water conservation
D Potential uses for extracted water (treated or untreated), if any
D Ecosystem services provided at or near the site
D Amount and types of chemicals and materials used
D Amount of waste generated and method of disposal for that waste
D Potential future/planned property reuse
10
Site Completion
D Remaining source removal or source control needs
D Exit strategy for remedy, performance metrics and decision trigger points
D Exit strategy for various system components, performance metrics and decision trigger points
D Appropriate site-specific milestones towards site closure
D Other exit strategy issues - organizational, regulatory program, stakeholders, technical and
administrative
11
Alternatives Consideration
D Major remedy components and potential alternatives to those components
D Technologies pilot-tested or applied to date at the site, limitations of those technologies and
potential alternatives
D Typical costs and limitations of potential alternatives
D Innovative approaches for addressing site-specific issues
D Potential supplementary or alternative remedies to selected remedy, including cost and limitations
of the alternatives
12
Debriefing and Action Items
D Schedule for submitting optimization findings and recommendations memorandum or draft report
D Requests for additional site documents or data
D Summary of concurrence or differing perspectives on information covered
D Remaining stakeholder questions for the optimization review team
D Identification of direct technical assistance needs for follow-up
D Anticipated time frame for recommendations implementation follow-up
D Additional action items covered during the meeting
Remediation Optimization: Definition, Scope and Approach
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Attachment 2. Example Types of Data Analysis
Investigation/Feasibility Study
Identification of various sources of uncertainty and prioritization of addressing those sources of uncertainty
Interpretation of existing conceptual site model (CSM) and identification of data gaps
Considerations for CSM refinement
3-D visualization and analysis results
Interpretations of characterization data
Considerations for applying innovative sampling strategies and statistical sampling designs
Considerations for applying real-time measurement and data collection technologies
Determination of the need for a demonstration of method applicability (DMA) to confirm use of a real-time or
other innovative technology
Considerations for developing dynamic work strategy (DWS) work plans for characterization
Considerations for electronic data deliverables (EDD) management
Receptor and pathway data needs, sequencing of proposed activities
Design
Analysis of investigation data
Interpretation of the CSM and identification of data gaps
Analysis of treatability and pilot study results
Evaluation of design parameters developed by site team
Estimation of pump and treat (P&T) extraction rates for plume capture
Estimation of treatment chemical loading, available treatment technologies and expected performance
Estimation of oxidant or nutrient demand for in situ remedies
Estimated demand for soil/aquifer heating
Estimates of other common remedy effectiveness and cost drivers
Simplistic analytical or numerical modeling to assist with CSM refinement
Simplistic analytical or numerical modeling to assist with development of appropriate performance monitoring
Identification of supplemental or alternative remedy components
Cost analysis of various technologies and approaches considered during design
Consideration of green remediation best management practices
Preliminary green remediation environmental footprint analysis
Remedial Action, Long-term Response Action (LTRA) or Operation and Maintenance (O&M)
Analysis of historical data plus trends in performance monitoring data
Interpretation of the CSM and identification of data gaps
Review of existing performance monitoring program for gaps and or redundancies
Statistical analysis of groundwater monitoring data to determine opportunities for monitoring program
reductions
Comparison of current chemical loading and or other site conditions to conditions considered during design
Comparison of remedy performance to expected performance and or reasonable expectations
Review of remedy component performance relative to expectations and expectations for competing technologies
Preliminary capture zone analysis for pump and treat (P&T) systems
Review of known receptors and potential for additional receptors since remedy design
Consideration of supplemental or alternative remedy components and expected cost and performance
Review of provided costs relative to expectations and cost for similar sites
Preliminary green remediation environmental footprint analysis
The types of data analyses listed above are not exhaustive. Analyses listed under one remedial phase may
also apply to optimization during other remedial phases. Additional or specific types of analyses to be
conducted by the optimization review team should be discussed during logistics, planning and scoping.
Remediation Optimization: Definition, Scope and Approach
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