APPENDIX
OSWER 9283.1-38
This appendix represents data submitted on the status of the progress of
recommendations as of the January 2012 tracking and follow up period.
The status of the progress of recommendations from prior tracking periods
can be found in previous Progress Reports, referenced in the reference
section of this report. These reports are available online at
http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm.

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RSE Recommendations and Progress Toward Implementation
Region 2
Site Name: GCL Tie & Treating (Sidney, NY)
Recommendation
Status
EPA ID#: NYD981566417
RSE Report: EPA 542-R-06-016 (December 2006)
Progress since the previous progress report
Remedy l-'.ITecli\euess
6.1.1	Institute a routine ground water
monitoring program
6.1.2	Optional plume delineation
6.1.3	Soil vapor intrusion evaluation
Cosl Reduction
6.2.1 Discontinue pumping from the
intermediate zone
Implemented
Implemented
Implemented
Implemented
6.2.2	Consider modifications to the	Under
backwashing and solids handling procedures	Consideration
(contingent of outcome of 6.2.1)
6.2.3	Suggestions for long-term ground	Implemented
water monitoring
6.2.4	Pilot test bypassing the air stripper	Declined
6.2.5	Consider a hybrid time and materials Alternative
and fixed-price contract	Implemented
6.2.6	Reductions in project management Implemented
consistent with steady state system operation
Technical lmprn\cmcnl
6.3.1	Relocate equalization tank high-level Implemented
switch
6.3.2	Discontinue use and service to	Declined
generator
6.3.3	Modify use of water levels from	Planned
operating extraction wells when developing
potentiometric surface maps
The recommendation is still on hold. At this point, there is no need for modifications.
This recommendation would be implemented during the generation of the 2011 annual
monitoring well sampling report which is currently being drafted.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 2
Site Name: Vineland Chemical Co. (Vineland, NJ)
Recommendation
Status
EPA ID#: NJD0023 85664
RSE Report: EPA-542-R-11-007 (November 2011)
Progress since the previous progress report
Remedy l\ITec(i\eness
6.1.1	Further characterize extent of
contamination
6.1.2	Consider modifications to the
groundwater extraction system to assure
capture
6.1.3 Additional monitoring of groundwater In progress
quality between extraction wells and
Blackwater Branch
( osi Reduction
6.2.1 Discontinue automated sampler and do In progress
not replace the unit
In progress	An evaluation is currently underway to further our understanding of contaminant release and
migration processes on site. See also 6.1.3 and 6.4.2.
In progress Plume capture is under investigation and continues to be evaluated. Elevated levels of arsenic in
select areas northwest and southwest of main plant property appear not to be a source, but
related to a residual or remnant plume contamination.
In the summer/fall of 2011, monitoring wells were installed in 11 locations, 8 were nested
(located along the Blackwater Branch) for a total of 19 new wells.
6.2.2	Eliminate routine on-site arsenic
sampling
6.2.3	Reduce extraction rates to those that
are necessary for plume capture
6.2.4	Evaluate groundwater monitoring costs
6.2.5	Continue to optimize groundwater
monitoring program
6.2.6	Focus building heating and lighting on Under
key process area	consideration
6.2.7	Evaluate chemical usage
The team agreed that the risk of turning off the OVA and discontinuing the use of the graphite
furnace is minimal, considering we normally treat well below the permitted discharge level of
50ppb, and that most other plants do not have such a conservative sampling setup. The
contractor will provide a cost estimate for savings associated with discontinuing the use of the
OVA and graphite furnace.
The project team will evaluate potential reductions in sampling frequency.
This has been discussed, and a further evaluation by US ACE is underway.
This has been discussed, and a further evaluation by US ACE is underway.
All extraction wells are now computerized. Optimization (for cost and quality control) activities
will continue on site. The last round of optimization included: computerization of operations
control to reduce labor on site, piping changes to enhance process efficiency/ performance,
optimizing chemical usage to reduce costs, and the adjustment of well development protocols.
After an exit strategy is decided upon, EPA will ask US ACE and site contractor to determine
feasibility and costs associated with recommendations 6.2.6, 6.2.7, and 6.2.8.
Under	After an exit strategy is decided upon, EPA will ask US ACE and site contractor to determine
consideration feasibility and costs associated with recommendations 6.2.6, 6.2.7, and 6.2.8.
Planned
Under
consideration
Under
consideration
Implemented
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 2
Site Name: Vineland Chemical Co. (Vineland, NJ)
EPA ID#: NJD0023 85664


RSE Report: EPA-542-R-11-007 (November 2011)
Recommendation
Status
Progress since the previous progress report
6.2.8 Consider use of a plate and frame filter
press to dewater solids
In progress
The team agreed that an existing plate and frame filter press could be a good way to reduce
waste disposal. The RSE team and site contractor will research availability of a unit from
another site and provide a cost estimate for removing unit from the existing location,
installation and operation.
6.2.9 Consider the use of lime for pH
adjustment
Declined
The team agreed that employing a lime system would have high capital cost and operational
issues that make it impractical for this site.
6.2.10 Continue to streamline plant and
project staffing
In Progress
Efficient labor utilization is a primary goal of the project team.
6.2.11 Based on outcome of other
recommendations, consider potential for
delisting waste sludge
Declined
A Superfund finding is in place for washed media reuse and evaluating contained-in policy for
waste/media disposal practices. The sludge appears to be too concentrated with arsenic to allow
for de-listing.
Technical lmprn\cmcnl


6.3.1 Refine well rehabilitation practices
Implemented
Monthly well meetings are conducted to evaluate system performance for optimized extraction
and well field pumping is adjusted accordingly.
6.3.2 Discontinue use of curtains and
electrical heaters for sand filters
Under
consideration
Site contractor will look into this item and provide recommendations.
6.3.3 Continue with plan to remove soil
washing equipment from the site
Under
consideration
Evaluation of soil washing for River Areas/Union Lake still needs to be conducted. As of
January 2012, the equipment is still under consideration for use in later phases of this project.
6.3.4 Prepare an annual report
In Progress
US ACE is currently compiling a report that summarizes work done since 2000. A five year
review for Vineland Chemical was finalized in September 2011.
Progress Toward Cleanup (ioals


6.4.1 Evaluate potential for natural
attenuation and suggested criteria for
discontinuing P&T
In Progress
Continued operation of the P&T is imperative as system shutdown will result in discharges to
surface water exceeding the ROD criteria. The US ACE is currently evaluating the potential for
MNA.
6.4.2 Active in-situ treatment for arsenic
immobilization
In Progress
Based on the RSE recommendation, an evaluation of arsenic immobilization technologies is
underway. Geochemical data was collected in the summer of 2011 to support overall
understanding of contaminant release/migration processes, provide baseline data for both
immobilization and mobilization enhancement technology strategic planning. More sampling is
scheduled for the spring/summer of 2012
6.6.1 Suggested exit strategy
In Progress
The US ACE is currently carrying out investigations in response to the RSE recommended
approach.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 2
Site Name: Vineland Chemical Co. (Vineland, NJ)
Recommendation
Status
EPA ID#: NJD0023 85664
RSE Report: EPA-542-R-11-007 (November 2011)
Progress since the previous progress report
(irccn Kcmcdialion
6.7.1 Consider combined heat and power
6.7.2 Consider alternatives for iron addition
6.7.3 Postpone lighting retrofit
Planned
Under
Consideration
Planned
The team agreed that a newer, greener system is desirable, if feasible. The site contractor will
get vendor estimates for new gas generator systems (i.e., Bloom Box, or micro turbine).
Another added feature to check on is the use of any excess waste heat from the system to be
focused on drying the sludge more to decrease waste disposal costs.
After an exit strategy is decided upon, EPA will ask US ACE and site contractor to determine
feasibility and costs associated with recommendations 6.71, 6.7.2, and 6.7.3.
All agreed to try out a new high bay fixture (manufacture brand to be provided by US ACE)
before purchasing for the entire plant.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 2
Site Name: Tutu Wellfield (Tutu Wellfield, VI)
Recommendation
Status
EPA ID#: VTD982272569
RSE Report: EPA-542-R-11-008 (November 2011)
Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1 Hydraulic Containment
6.1.2	No Additional Downgradient Active
Remediation
6.1.3	Curriculum Center Vapor Intrusion
Resampling
6.1.4	Include MTBE Analysis
Cost Reduction
6.2.1	Improve Contracting Efficiency
6.2.2	Termination of GWTF #2 Operation
6.2.3	Reduce Operator Visits including
Decreasing Well Gauging Frequency
6.2.4	Eliminate Emissions Sampling at
GWTF #1
Technical lmprn\cmcnl
6.3.0 Remove excess air discharge ducting
and consider air strippers with less power
requirements
Progress Toward Cleanup Coals
Planned	The site team developed a detailed scope including adding four extraction wells, hooking them
up to the system and start-up tasks as well as one additional monitoring well. The site team
obtained contractor costs for this work and project costs at over $500,000 not including CDM
Smith management versus the RSE estimate of $210,000. Implementation has been delayed
due to lack of available funding. The RSE team has not seen the detailed work scope or
contractor submittals to comment on the difference between the cost estimates.
Implemented The site team has not changed the current approach.
Implemented
Implemented
Deferred to
State or PRP
Under
Consideration
Deferred to
State or PRP
Under
Consideration
Under
Consideration
6.4.0 Considerations for Gaining Site Close Under
Out	Consideration
The vapor intrusion resampling was conducted in December 2011, results are not yet available.
Total costs for the work will be about $35,000 versus the $45,000 RSE estimate
The site team reports that MTBE analysis is occurring as part of the VOC scan. MTBE results
were relatively low or non-detect so that MTBE migration is not a concern.
The site team stated that these changes cannot be implemented under the current contract which
will run until the turnover to USVI. The USVI should consider the recommendations after the
turnover.
The site team plans to wait until the hydraulic containment improvements are completed at
GWTF #1 before implementing this recommendation.
The site team stated that these changes cannot be implemented under the current contract which
will run until the turnover to USVI. The USVI should consider the recommendations after the
turnover.
The site team will consider writing a letter to USVI to eliminate this redundant sampling
requirement. The site team noted that analysis is being done by the USEPA CLP lab.
The site team plans to wait until the hydraulic containment improvements are completed at
GWTF #1 before implementing this recommendation.
The site team plans to wait until the hydraulic containment improvements are completed at
GWTF #1 before implementing this recommendation.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 2
Site Name: Tutu Wellfield (Tutu Wellfield, VI)	EPA ID#: VID982272569
RSE Report: EPA-542-R-11-008 (November 2011)
Recommendation	Status	Progress since the previous progress report
(irccn Kcmcdialion
6.5.0 Consider alternative effluent discharge Under	No further action has been taken to date,
and energy sources	Consideration
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 3
Site Name: Mill Creek Dump (Erie County, PA)
Recommendation
Status
EPA ID#: PAD980231690
RSE Report: EPA-540-R-10-014 (February 2010)
Progress since the previous progress report
Remedy l\ITec(i\eness
6.1.1 Further Characterize Extent of	Implemented
Contamination
6.1.2	Install Additional Points for Water Implemented
Level Measurements
6.1.3	Conduct a Shutdown and Restart Test
of the Extraction System
6.1.4	Document the Findings from the	Implemented
Above Events, Use Findings for Capture
Zone Analysis
6.1.5	Automate Chemical Feeds or Provide Declined
Appropriate Interlocks to Discontinue
Chemical Feeds if One or More Extraction
Trenches Discontinue Operation
6.1.6	If Off-Site Shallow Contamination is Implemented
Identified and Determined to be Related to
the Site, Conduct a Vapor Intrusion
Evaluation
Cosl Reduction
6.2.1 Discontinue April Sampling Event Implemented
6.2.2	Discontinue Analysis for Dissolved Planned
Metals
6.2.3	Streamline Process Sampling	Declined
6.2.4 Revisit Data and Reporting Costs Implemented
DPT sampling was conducted at 18 locations, with 35 samples collected in August 2010.
Results indicate the most offsite locations sampled do not have contamination. Two locations
at the northern edge of the site (near the pond) had DCE and vinyl chloride contamination
above ROD screening levels. Results are still being evaluated with respect to the modeling and
capture zone analysis discussed in 6.1.4.
Six new monitoring wells were installed in November 2010, consistent with the RSE
recommendation.
Implemented Conducted in December 2010.
A MODFLOW model has been developed using findings from the above field investigations.
Separate comments were provided by the RSE team on the capture zone document and
modeling report.
It was determined that nothing in the system requires changing, as the one main release
occurred as a result of human error.
Five residences were sampled in December 2010. Results did not demonstrate a vapor
intrusion problem.
The April event was conducted in April/May 2011, however it has been discontinued starting in
2012.
The site team agrees with this recommendation and will implement it in 2012.
With the current treatment plant staffing, the suggested revisions to process monitoring will not
result in savings. Therefore, the site team will not make the adjustment.
The site team reports that the semi-annual report has been eliminated, resulting in savings of
$8,350. No other changes were reported to the data and reporting costs.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 3
Site Name: Mill Creek Dump (Erie County, PA)
Recommendation
Status
EPA ID#: PAD980231690
RSE Report: EPA-540-R-10-014 (February 2010)
Progress since the previous progress report
6.2.5 Reduce or Eliminate Lime
Conditioning of Sludge
Technical lmprn\cmcnl
6.3.1	Cleanup of Treatment Plant
6.3.2	Considerations Regarding Treatment
Plant Modifications, if Necessary
Progress Toward Cleanup Coals
6.4.1 Determining a Path Forward
(irccn Remediation
6.5.1 Revised Approach to Metals Removal
6.5.2 Considerations for Renewable Energy
at the Site
Planned	PADEP's contractor will reduce the lime conditioning, initially by 50%, and evaluate the
effectiveness. The contractor will then adjust the amounts to determine the optimum conditions.
Implemented The treatment plant has been cleaned and organized.
Under	PADEP, which is responsible for operating the remedy, will need to revisit this
Consideration recommendation before making a decision to implement it.
Under	The site team recognizes the need to determine a path forward and relayed that the Five-Year
Consideration Review includes delineation of contamination as an issue to be resolved.
Under	PADEP, which is responsible for operating the remedy, will need to revisit this
Consideration recommendation before making a decision to implement it.
Declined	The site team reports several failures of renewable energy projects in the area (not site related)
and will postpone consideration of renewable energy at the site for the foreseeable future.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 4
Site Name: Alaric Area Groundwater Plume (Tampa, FL)
Recommendation
Status
EPA ID#: FLDO12978862
RSE Report: EPA-540-R-10-013 (January 2010)
Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1	Carefully Determine an Appropriately
Conservative Buffer when Informing the
State of Plume Extent Related to
Establishing Ground Water Restrictions
6.1.2	Analyze Process Water Periodically
for Constituents of Concern from the Helena
Chemical Site
6.1.3	Simplify System Controls
6.1.4	Monitor Specific Capacity in
Recovery and Reinjection Wells
6.1.5	Interpret Capture
Cosl Reduction
6.2.1 Modify VOC Treatment
6.2.2 Consider Discharging to the Shallow Implemented
Zone
6.2.3	Characterize GAC Again and
Investigate Source of Radioactivity in an
Attempt to Dispose of GAC as Non-
Hazardous Waste or to Regenerate It
6.2.4	Track Routine O&M Costs Separately
from Non-Routine Costs
Technical lmpm\cmcnl
6.3.1 Consider the Following Comments to
the May 2009 Technical Review by the Site
Contractor
Under	More extensive work on the groundwater plume will be conducted once source area soils are
consideration addressed. The timeline for a site-wide FS and final ROD is approximately 3+ years after
implementation of the source zone remedy.
Implemented After the system was restarted in May 2011, the site team conducted process sampling that
included a broader suite of contaminants, including pesticides. This sampling is planned to
occur on a semi-annual basis. The site team reports that there were low-level detections of
pesticides in some of the recovery wells and that there were no detections in the effluent.
Implemented The existing complex control system was simplified.
Implemented These monitoring activities will occur during system operation when the system is restarted.
Under	This item has been discussed, and there is general consensus that it is needed.
Consideration
Alternative The treatment system has been updated with a new air stripper, new piping, and addition of
Implemented sequestering agents.
The treated water is now discharged to the shallow aquifer through the existing infiltration
galleries.
Implemented March 22, 2011 - The previous detection of radioactivity is expected to be a one-time issue.
The GAC is due for changeout and will be characterized prior to disposal.
Implemented A cost tracking system has been set up for GeoSyntec with separate routine and non-routine line
items.
Implemented The treatment plant upgrades have been completed.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 4
Site Name: Alaric Area Groundwater Plume (Tampa, FL)
Recommendation
Status
EPA ID#: FLDO12978862
RSE Report: EPA-540-R-10-013 (January 2010)
Progress since the previous progress report
Progress Toward Cleanup Coals
6.4.0 Considerations for Gaining Site Close Alternative
Out	Implemented
In-situ thermal treatment will replace the in-situ chemical oxidation remedy previously used to
address source area soils. The other potentially contaminated areas and plume area will be
considered once the source area has been addressed. The design for the in-situ thermal remedy
is underway.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 4
Site Name: Benfield Industries (Waynesville, NC)
Recommendation
Status
EPA ID#: NCD981026479
RSE Report: EPA 542-R-07-020 (September 2007)
Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1	Document potential downgradient Declined
receptor locations and adjust monitoring
locations if necessary
6.1.2	Consider sampling for dioxins/furans Declined
in soil
6.1.3	Document rationale for eliminating In progress
metals analysis
( ost Reduction
The ROD amendment now planned to be completed by May 2015, and will address this issue.
6.2.1	Do not restart the extraction system Implemented
6.2.2	Consider monitored natural attenuation In progress
as the ground water remedy
Technical lmpm\cmcnl
6.3.1 Improve sampling and analysis	Implemented
methods/reports
Progress Toward Cleanup Coals
6.4.1 Assess feasibility and cost-benefit of In progress
in-situ treatment of remaining soil hot spot(s)
6.4.2 Consider reassessing the cleanup In progress
criterion for 1,4-Dichlorobenzene
The draft MNA report was completed in July 2011 and reviewers found lines of evidence did
not support an MNA remedy without addressing some remaining hot spots. The contractor is
currently working on plans to identify and address the remaining hot spots followed by writing
the draft ROD amendment. It is anticipate to take three years to complete this assignment by
May 2015 (FY 2015).
The past five sampling events have used analytical methods that provide reporting limits at or
below the current ROD cleanup levels. The ROD amendment is now anticipated to be complete
by May 2015.
The contractor is currently working on plans to identify and address the remaining hot spots
followed by writing the draft ROD amendment. It is anticipate to take three years to complete
this assignment by May 2015 (FY 2015)
The ROD amendment will now be completed by May 2015.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 4
Site Name: American Creosote Works (Pensacola, FL)
Recommendation
Status
EPA ID#: FLD008161994
RSE Report: EPA-540-R-06-068 (June 2006)
Progress since the previous progress report
Remedy l\ITec(i\eness
6.1.1 Continue revisiting soil cleanup levels In progress
and ACLs
6.1.2	Consider potential vapor intrusion Implemented
6.1.3	Revise program for determining GAC Implemented
replacement
6.1.4 Evaluate options to implement
stronger institutional controls
Cosl Reduction
Under
Consideration
6.2.1	Revise ground water sampling program Alternative
Implemented
6.2.2	Review labor costs once system	Implemented
operation has stabilized
Technical lmprn\cmcnl
6.3.1 Re-pipe DNAPL line from treatment Implemented
shed to DNAPL storage tank
Progress Toward Cleanup Coals
6.4.1 Modifications intended to gain site In progress
close-out
EPA is in the process of finalizing the Focused FS for ACW. A sitewide ROD is scheduled for
summer 2012. There are still discussions of where the low level dioxin impacted soil will be
deposited (possible onsite and offsite locations).
An air stripper unit was added to the system. This unit will extend the lifetime of the GAC of
the system. It is estimated that it will pay for itself in the first year of operation.
EPA and FDEP are still looking into implementing institutional controls onsite. The
development of groundwater ICs will require more investigation work. The ICs will be
included in n sitewie ROD scheduled to be done by September 2012
A sitewide ROD is scheduled for summer 2012. This ROD will revisit the site's groundwater
remedy and possibly the cleanup goals. One of the possible remedies is a containment strategy
utilizing a barrier wall around the DNAPL source area.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 4
Site Name: Cape Fear Wood Preserving (Fayetteville, NC)	EPA ID#: NCD003188828
RSE Report: EPA-542-R-05-005 (February 2005)
Recommendation	Status	Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1	Install and sample a monitoring well Implemented
downgradient of MW-16
6.1.2	Sample outer monitoring wells	Implemented
annually
6.1.3	Do not use water levels from operating Implemented
recovery wells or infiltration galleries when
generating potentio-metric surface maps
Cost Reduction
6.2.1	Contract O&M services and ground
water sampling to a local contractor
6.2.2	Eliminate select wells from monitoring
program, and reduce sampling and reporting
frequency to annually
Technical lmpro\cmcnl
6.3.1	Consider alternatives before adding a
sequestering agent
6.3.2	Reduce frequency of water level
measurements, discontinue dissolved
oxygen monitoring, and simplify O&M
reporting
6.3.3	Add a suffix to well labels to indicate
shallow and deep wells
Progress Toward Cleanup Coals
6.4.1 Evaluate effectiveness of various
remedy components
Implemented
Implemented
Implemented
Implemented
Implemented
Alternative
Implemented
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RSE Recommendations and Progress Toward Implementation
Region 4
Site Name: Cape Fear Wood Preserving (Fayetteville, NC)
Recommendation
Status
EPA ID#: NCD003188828
RSE Report: EPA-542-R-05-005 (February 2005)
Progress since the previous progress report
6.4.2 Considerations for evaluating thermal Alternative
pilot study	Implemented
The thermal study was completed. The tech. memo evaluating the 3 scenarios was completed.
The 3 scenarios evaluated include 1) STAR with ISCO (activiated persulfate), 2) steam
injection with ISCO (activiated persulfate), and 3) stabilization on Site with thermal treatment
along Reilly Road followed by ISCO ISCO (activiated persulfate). All three of these options
would be followed by MNA. A final determination regarding changing the remedy and
implement any of these alternatives has not been made at this time. The Site is on schedule to
be transferred to the State for implementation LTRA of the existing remedy by July 2012. EPA
is looking into the logistics of potentially changing the remedy in the near future.
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Ott/Story/Cordova Chemical Co. (Dalton Township, MI)
Recommendation
Status
EPA ID#: MID060174240
RSE Report: EPA 542-R-02-008s (March 2002)
Progress since the previous progress report
Cost Reduction
6.2.1	Replace DAS units with tray aerators Declined
or packed towers
6.2.2	Reexamine NPDES permit and	Declined
potentially bypass PACT system
6.2.3	Reduce process monitoring and	Implemented
analysis
6.2.4	Reduce aquifer monitoring and analysis Implemented
6.2.5	Remove excess equipment and do not Declined
construct the planned storage building
6.2.6	Evaluate potential reduction in onsite Implemented
presence of US ACE
6.2.7	Remove trailers from site	Implemented
6.2.8	Have onsite staff conduct sampling for Alternative
OU3 Implemented
Technical lmprn\cmcnl
6.3.1 Establish consistent sampling method
6.3.2 Modify program for water-level
measurement
Progress Toward Cleanup Coals
6.4.1 Establish agreement between the OU2
remedy and ROD
Implemented
Implemented
In progress
Consistent with the requirements of the 2007 Five Year Review, a "Remedial Strategy
Analysis" continues. The transfer of portions of the LTRA to the State occurred on February 1,
2011. The State of Michigan identified numerous outstanding issues with the remedy. EPA
continues to partner with the State to address remedy issues until cleanup goals are reached,
including this RSE recommendation.
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Douglas Road/Uniroyal, Inc., Landfill (St. Joseph
County, IN)
Recommendation
Status
EPA ID#: IND980607881
RSE Report: EPA 542-R-04-031 (February 2004)
Progress since the previous progress report
Remedy l\ITec(i\eness
6.1.1	Sample extraction wells annually
6.1.2	Investigate off-site sources and
remaining down-gradient impacts
Cosl Reduction
6.2.1	Reduce analytical QA/QC
6.2.2	Consider converting cell 3 to an
additional infiltration basin
Progress Toward Cleanup Coals
6.4.1 Develop an exit strategy
Deferred to
State or PRP
Declined
Deferred to
State or PRP
Alternative
implemented
Deferred to
State or PRP
State has taken over monitoring as of November 2011.
State has assumed operation of remedy as of November 2011.
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Reilly Tar & Chemical Corp. (Indianapolis, IN)	EPA ID#: IND000807107
RSE Report: EPA 542-R-04-035 (February 2004)
Recommendation	Status	Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1	Install piezometers and monitoring
wells to allow for improved evaluation of
plume capture
6.1.2	Perform improved plume capture
evaluation (Including numerical model)
6.1.3	Consider the need for a modified
extraction system
Cost Reduction
6.2.1 Consider using extracted water for Declined
process and cooling uses
Technical lmprn\cmcnl
6.3.1 Minor suggestion for improved O&M Implemented
reporting
Progress Toward Cleanup Coals
6.4.1 Develop an exit strategy (consider In progress See update for recommendation 6.1.2. Updated modeling in 2012 will facilitate an exit strategy,
alternate approach)
Implemented
In progress PRPs have submitted outline of modeling effort—EPA to provide comments early 2012 for
implementation.
Declined
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Peerless Plating (Muskegon, MI)
Recommendation
Status
EPA ID#: MID006031348
RSE Report: EPA 542-R-06-011 (February 2006)
Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1	Evaluation of ground water capture Implemented
6.1.2	Modifications to the monitoring	Implemented
program
Cosl Reduction
6.2.1	Eliminate several ground water	Implemented
treatment processes
6.2.2	Modifications to the monitoring	Implemented
program
6.2.3	Revise reporting requirements	Declined
6.2.4	Review level of operator support Implemented
Technical lmpm\cmcnl
6.3.1	Install dust collection system over Declined
FeS04 hopper
6.3.2	Install enclosure around air	Declined
compressor to reduce noise
6.3.3	Initiate a formal O&M program	Implemented
6.3.4	Advertise availability of used	Implemented
equipment on US ACE/EPA web page
Progress Toward Cleanup Coals
6.4.1	Assess source area treatment	Declined
alternatives
6.4.2	Permeable barrier	Declined
A pumping wells was moved and pumping rates were adjusted to help address capture issues.
Additional monitoring wells were installed to monitor capture.
A monitoring well to address background concentrations was installed. The State installed 8
new monitoring wells to establish plume limits. The agency continues to monitor these new
wells to determine if additional information will be required in the future.
Low Flow sampling is used exclusively.
The by pass system continues to operate and there is no update at this time.
The formal O&M plan has been developed and will continue to be updated as required until the
site activities are taken over by the State of MI.
The contractor is currently solicity bids to dismantel and remove excess equipment from the
Site.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Baytown Township Ground Water Plume (Lake Elmo,
MN)
Recommendation
Status
EPA ID#: MND982425209
RSE Report: EPA-540-R-011-006 (June 2011)
Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1	Implement ISCO in Source Area	Under
Consideration
6.1.2	Phased Implementation of ISCO,	Under
Tracer Test	Consideration
6.1.3	Consideration of In Situ Biological	Under
Treatment	Consideration
6.1.4	Potential Life Cycle Cost Savings	Under
Offered by Source Area Treatment	Consideration
6.1.5	Additional Source Area Assessment	In Progress
6.1.6	Performance-Based Contracting for
Source Area Treatment
6.1.7	More Rigorous Evaluation of
Hydraulic Barrier Capture Influence
6.1.8	Improvements to the Monitoring
Program
Cosl Reduction
6.2.1	Reduce Blower Airflow Rate
6.2.2	Adjustments to GAC Management
Program
6.2.3	Eventually Replace Class I, Division I
Motors
6.2.4	Optimization of the Groundwater
Monitoring Program
Technical lmpro\cmcnl
6.3.1	Use of More Rigorous MNA Modeling
6.3.2	Continue Evaluation of Groundwater
Infiltration System Plugging
Under
Consideration
In Progress
In Progress
Under
Consideration
In Progress
Under
Consideration
Under
Consideration
Implemented
The use of ISCO in the source area will be considered as part of an updated FS in early 2012. A
work plan for the FS is currently under development.
Aspects of this recommendation are in the process of being implemented, including the tracer
test.
The use of in-situ bioremediation will be considered as part of the updated FS (see 6.1.1).
This section of the RSE report did not contain a specific recommendation, rather it supports
other items in 6.1.
A work plan for implementing this recommendation is in preparation (see 6.1.1).
This item will be considered in the future if source treatment is planned.
MPCA contractor is evaluating capture as part of Annual Report. Region 5 technical staff may
be able to assist with this.
MPCA is assessing trends, but will not implement a MAROS analysis.
Contractor to MPCA is evaluating.
One GAC unit has been replaced, and process is in place to require that new units exclude
treatment of water delivered by exterior hose bibs.
Applicable only in the future when equipment needs replacement.
Implemented Passive diffusion bags have been used in some monitoring wells, but not all.
MPCA is planning additional MNA monitoring later in 2012.
Injection of C02 continues and downhole camera work assesses need for well rehabilitation by
jetting.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Baytown Township Ground Water Plume (Lake Elmo,
MN)
Recommendation
Status
EPA ID#: MND982425209
RSE Report: EPA-540-R-011-006 (June 2011)
Progress since the previous progress report
6.3.3	Periodic Inspection of Electrical	Implemented
System and Controls
6.3.4	Optimize Process Flow Configuration	Declined
for Air Stripping System
6.3.6	Preparation of an Annual Report	Implemented
6.3.7	Improvement of Data Management	In Progress
Progress Toward Cleanup Coals
6.4.0 Implement ISCO, MNA Modeling,	Under
Capture Zone Analysis (see 6.1.1 above)	Consideration
MPCA contractor has conducted inspection and has incorporated this into standard site
inspection process.
MPCA will not implement as it would require adding pumps.
Modifications to the annual reports being prepared starting in 2011.
MPCA has made some improvements, including use of the EQUIS database. EPA Region 5
offered assistance for this.
See 6.1.1 above
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Moss-American (Milwaukee, WI)
Recommendation
Status
EPA ID#: WID03 9052626
RSE Report: EPA-540-R-11-018 (March 2011)
Progress since the previous progress report
Remedy l\ITec(i\eness
5.1.1 Monitoring program modifications
5.1.2 Additional NAPL investigation
Cosl Reduction
5.2.1	NAPL-impacted soil excavation and
enhanced dissolved-phase treatment
5.2.2	Limited NAPL-impacted soil removal
and installation of additional treatment gate
5.2.3	Ground Water Flow Modification to
Enhance Treatment of Existing Funnel and
Gate System
Planned
Planned
Under
Consideration
Under
Consideration
Declined
The State plans on getting a contractor on board later this year to develop and implement a
work plan for further characterization, as recommended in 5.1.1 and 5.1.2. In addition, the
contractor will be tasked with suggesting other alternatives to meet the objectives of the project.
See notes above.
Pending outcome of 5.1.1 and 5.1.2.
Pending outcome of 5.1.1 and 5.1.2.
The site team has deemed this item ineffective and not a viable path forward.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Wash King Laundry (Pleasant Plains Township, MI)
Recommendation	Status
EPA ID#: MID980701247
RSE Report: EPA-540-R-11-019 (February 2011)
Progress since the previous progress report
Remedy l\ITec(i\eness
6.1.1	Sample P&T Discharge and
Residential Wells for Lead
6.1.2	Complete Institutional Controls
6.1.3	JetEW-5 and Measure/Track
Extraction Well Specific Capacity
6.1.4	Evaluate and Manage Soil Vapors
Cosl Reduction
6.2.1	Discontinuing Pumping from EW-4
6.2.2	Reduce Metals Analysis
6.2.3	Reconfigure Air Strippers and
Possibly Resize Air Stripper Blowers
6.2.4	Modify Groundwater Monitoring
Program
6.2.5	Prepare an Annual Report
Implemented The site team actually started implementing this the year before the RSE.
In Progress The site team has determined that institutional controls are not needed at four of the eight
properties. EPA and the State are discussing institutional controls for the other four properties.
In the interim, the Health Department, which has the authority to permit supply wells, will not
allow wells in the area.
Implemented The site team jetted the well, but jetting did not result in sufficient improvements. The well
needed to be replaced. The site team replaced the well with a well (EW-8) in a new location
upgradient.
Alternative The site team evaluated the potential for vapor intrusion at the restaurant building and
Implemented concluded that given the condition of the building and no occupancy of the building, vapor
intrusion was not a concern. The site team, however, decided to keep operating the SVE
system occasionally to reduce vapors that accumulate in the unsaturated zone.
Implemented The site team implemented this recommendation.
Alternative The site team did not reduce the types of analyses, but did reduce some of the locations where
Implemented metals would be analyzed.
In Progress Given the flow from the new extraction wells and the capacities of the air strippers, both air
strippers are needed. At the suggestion of the RSE team, the site team will revisit discussions
with the vendors to see if the blower sizes can be reduced from 25 HP or variable frequency
drives can be installed to reduce air flow and electricity usage and still provide adequate
treatment.
Implemented The site team adopted most of the RSE team's suggestions for modifying the groundwater
monitoring program. The site team agrees that savings is likely on the order of $30,000 per
year.
Declined	An additional annual report will not be implemented at this time given the existing quarterly
reporting and other recent reporting including two Five-Year Reviews, a Long-Term
Monitoring Optimization Report, and the RSE report.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 5
Site Name: Wash King Laundry (Pleasant Plains Township, MI)
Recommendation
Status
EPA ID#: MID980701247
RSE Report: EPA-540-R-11-019 (February 2011)
Progress since the previous progress report
Progress Toward Cleanup Coals
6.4.1 Investigate Sources in Lagoon Area In Progress
and Piping to Former Lagoons
6.4.2 Develop an Exit Strategy	In Progress
Crccn Remediation
6.5.1 Use Dedicated Tubing	Declined
6.5.2 Considerations for Renewable Energy Declined
at the Site
The site team has installed a shallow, intermediate, and deep well in the general vicinity and has
identified contamination. EPA Region 5 and the State continue to discuss the path forward for
the site.
The site team has installed a shallow, intermediate, and deep well in the general vicinity and has
identified contamination. EPA Region 5 and the State continue to discuss the path forward for
the site.
The potential savings (cost and environmental) do not outweigh the field complications
associated with implementing this recommendation.
The site team has not considered renewable energy for the site. The RSE team suggests
understanding the future electricity usage (after air stripper optimization) prior to considering
renewable energy.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 7
Site Name: 57th and North Broadway (Wichita, KS)	EPA ID#: KSD981710247
RSE Report: EPA-540-R-06-067 (June 2006)
Recommendation	Status	Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1	Perform additional source area	Implemented
characterization
6.1.2	Consider contingent wellhead
treatment at the public water supply well
6.1.3	Consider change to P&T after source
characterization, in 53rd Street area
6.1.4	Evaluate whether extent of SVE
system is adequate
6.1.5	Consider using air sparging with
existing SVE
6.1.6	Continue monitoring of sentinel wells
in Bel Aire well field
6.1.7	Evaluate potential for vapor intrusion Implemented
Cosl Reduction
6.2.1	Consider immediately taking eastern Implemented
53 rd Street DDC wells out of operation
6.2.2	Consider better tracking of routine and Implemented
non-routine site costs
Technical lmpro\cmcnl
6.3.1	Prepare and distribute annual	Implemented
monitoring reports
6.3.2	Improve site maps	Implemented
6.3.3	Report detection levels for 'non-detect' Implemented
results
Implemented
In progress The status is about the same, we've conducted new investigation in December 2011 and
obtained additional data for the installation of the extraction well. We have had some issues
with the state which delayed this work. Things are progressing better now and hopefuly move
forward after we get these latest results.
Implemented
Declined
Implemented
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 7
Site Name: 57th and North Broadway (Wichita, KS)
Recommendation
Status
EPA ID#: KSD981710247
RSE Report: EPA-540-R-06-067 (June 2006)
Progress since the previous progress report
Progress Toward Cleanup Coals
6.4.1 Clarify and document date for turnover In progress
to State for O&M
6.4.2 Develop consensus on terminating Implemented
SVE at Wilko
The status is still the same, we have conducted additional investigations in December 2011 and
will modify the current remedy by installing an extraction well and some soil removal. After
the remedy is operational and effective, the site will be turned over to the state.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 7
Site Name: 10th Street Site (Columbus, NE)
Recommendation
Status
EPA ID#: NED981713837
RSE Report: EPA 540-R-10-012 (February 2010)
Progress since the previous progress report
Remedy l\ITec(i\eness
6.1.1 Evaluate the Need for Further	Implemented
Evaluation of Potential for Vapor Intrusion
Near OHM Facility
6.1.2 Discontinue Pumping at EW-04 and
Shift Pumping West to EW-03
6.1.3 Address Calibration Issues with the
Flow Model
Under
Consideration
In progress
6.1.4 Address Potential Plume Migration to Implemented
the Southeast (Delineation and ICs) and
Associated Potential Actions
Cosl Reduction
6.2.1	Discontinue ISCO After Contract is Implemented
Completed
6.2.2	Continue to Use PDBs Without	Implemented
Extensive Comparisons
6.2.3	Reductions in Monitoring/Reporting Implemented
Two new rounds of vapor intrusion sampling were conducted in 2010, and four more rounds
were conducted in 2011. Indoor air samples have been below screening levels, but sub slab
samples had exceedances. A soil vapor investigation was conducted in and around the source
areas. The site team is moving forward with vapor intrusion mitigation systems at 17 properties
in early 2012.
Pumping continues at EW-04 and will be reevaluated after the flow model is updated. The
capacity of EW-03 has been increased to the maximum extent possible. The modeling was
delayed due to delays in obtaining access for the installation of piezometers. The modeling
should be completed in the next month or two allowing for consideration of the discontinuing
pumping from EW-04.
The Region is planning to update the flow model after conducting pump tests at EW-03 and
EW-04. The modeling was delayed due to delays in obtaining access for the installation of
piezometers. The modeling should be completed in the next month or two.
Twelve new wells have been installed for this purpose. The new monitoring wells have non-
detect results and effectively delineate the plume.
ISCO injections have been discontinued; the last round was in 2009.
The site team continues to use PDBs where they correlated well with low-flow sampling results
and do not use PDBs where they did not correlate well with low-flow sampling. No further
comparison studies are being conducted.
Reductions in monitoring/reporting were included in the contract modification, including
cutting back to semi-annual sampling and sampling at fewer wells. In 2010, monitoring and
reporting cost an estimated $247,465. Actual monitoring and reporting costs in 2011 were
lower than expected and actual monitoring and reporting in 2012 are $124,000 (suggesting a
cost reduction of 50% and a cost savings of $124,000 per year).
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 7
Site Name: 10th Street Site (Columbus, NE)
Recommendation
Status
EPA ID#: NED981713837
RSE Report: EPA 540-R-10-012 (February 2010)
Progress since the previous progress report
6.2.4 Project Management and Technical Implemented
Support Moving Forward
Technical lmprn\cmcnl
6.3.1 Measure and Track Specific Capacity Implemented
of Wells
6.3.2 Consider VFDs for Extraction Well Declined
Pumps
Progress Toward Cleanup Coals
6.4.1 Consider Alternate Actions at OHM Implemented
Facility
6.4.1 Consider Alternate Actions at OHM Implemented
Facility
The RSE team's recommendations have been implemented, which has led to significant cost
reduction (approximately $190,000). Most cost savings are associated with shifting focus to
evaluate other remedial options rather than optimize the AS/SVE system. Earlier costs were
incurred for the ART well and groundwater recirculation pilot studies, which were evaluated as
potential enhancements to the AS/SVE system. Project management and reporting costs are
expected to stay steady at the reduced level in 2011 and 2012.
Specific capacity of wells was calculated for the 2009 Annual Report and will be calculated for
the 2010 Annual Report. There will not be a significant increase in effort or cost associated
with these calculations.
VFDs had been looked at during design, but were ruled out because they would not lead to a
significant cost impact.
The site team is focusing on pinpointing the source, determining the best way to treat source
area contamination, and reducing the amount of O&M and pumping time needed. Soil
investigations at the OHM facility and two other dry cleaners to the south indicate that higher
levels of contamination exist below the other two buildings.
The site team prepared a Focused Feasibility Study, and a ROD Amendment and a Remedial
Design start are planned by the end of the 3rd quarter of 2012.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 8
Site Name: Central City/Clear Creek, Argo Tunnel (Idaho Springs,
CO)
Recommendation
Status
EPA ID#: COD980717557
RSE Report: EPA-542-R-07-019 (September 2007)
Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1 Evaluate and decide on need for
blowout prevention
6.1.2	Evaluate importance of complete
collection and treatment of the Virginia
Canyon ground water
6.1.3	Evaluate indoor air quality for metals
and confirm medical monitoring for plan
workers
Cost Reduction
6.2.1 Install new filter presses
6.2.2	Realize savings from improved
operations
6.2.3	Improve metals treatment by solids
recycling
Technical lmprn\cmcnl
0.3.1 Reduce discharge of recycled solids
and high pH water to equalization basins
6.3.2	Improve lime feed system
6.3.3	Provide additional compressed air
capacity
6.3.4	Reduce solids wasting flow rate
In progress An entry into the Argo Tunnel occured on 5/3/2011. The entry team only made it in about 125
feet due to sediment buildup. A conceptual design was prepared and submitted to the State and
EPA in November 2011. It estimated the cost of construction for a bulkhead at $413,000. The
State is preparing a Request for Qualifications to hire a design engineer.
Implemented No further comment.
Implemented
In progress
Alternative
Implemented
In progress
Alternative
Implemented
Under
Consideration
Alternative
Implemented
The State has amended the contract with the engineer to design the conversion of the process to
a HDS system. The additional design cost is $363,800. The design is approximately 60%
complete. The estimated construction cost has increased to $2,550,000. Once design is
complete, the State will request funds to construct the process modifications.
No further comment.
See update in 6.2.1.
Iniplenieiiled No further comment.
No further comment.
The design for conversion to a HDS system includes installation of a blower to provide aeration
to the process. If the conversion is implemented, additional compressed air capacity will likely
not be required.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 8
Site Name: Central City/Clear Creek, Argo Tunnel (Idaho Springs,	EPA ID#: COD980717557
C°)	RSE Report: EPA-542-R-07-019 (September 2007)
Recommendation	Status	Progress since the previous progress report
6.3.5	Consider construction of an on-site In progress See update in 6.2.1
solids disposal repository as a contingency
to disposal at a landfill
6.3.6	Additional improvements	In progress The additional permanent lime storage is still on hold because they have lower funding priority
than the other items.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 9
Site Name: Modesto Ground Water Contamination (Modesto, CA)
Recommendation
Status
EPA ID#: CAD981997752
RSE Report: EPA-542-R-02-008o (December 2001)
Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1	Monitor subsurface performance of Implemented
SVE system
6.1.2	Assign responsibility for evaluating Implemented
monitoring and performance data
6.1.3	Analyze capture zone	Implemented
6.1.4	Delineate plume (if necessary)	Implemented
Cosl Reduction
6.2.1	Consider alternate discharge locations Declined
-	Discharge to storm sewer
-	Reinject to subsurface
6.2.2	Simplify system (remove equalization Implemented
tank, simplify filtration system, and remove
transfer pump)
6.2.3	Regularly evaluate need for ion	Implemented
exchange units
Technical lmpro\cmcnl
6.3.1	Relocate vacuum breaker	Implemented
6.3.2	Install valving for backwashing carbon Implemented
and ion exchange units
6.3.3	Monitor extraction well performance Implemented
6.3.4	Modify SVE system to address high Declined
operating temperatures
6.3.5	Regularly evaluate need for vapor Declined
phase carbon
6.3.6	Properly convert PID readings to PCE Implemented
concentrations
6.3.7	Improve accuracy of SVE flow	Implemented
6.3.8	Adjust membrane around Baker tank Alternative
Implemented
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RSE Recommendations and Progress Toward Implementation
Region 9
Site Name: Modesto Ground Water Contamination (Modesto, CA)
Recommendation
Status
EPA ID#: CAD981997752
RSE Report: EPA-542-R-02-008o (December 2001)
Progress since the previous progress report
6.3.9	Improve drainage to secondary sump
6.3.10	Add fans to the control panel
6.3.11	Relocate vapor phase carbon for the
groundwater treatment system
6.3.12	Add phone line for data acquisition
Progress Toward Cleanup Coals
6.4.1 Initiate screening of final remedy
6.4.2 Measure DO and ORP in monitoring
wells
Implemented
Implemented
Implemented
Implemented
In progress
Implemented
Discovery of possible new source area requires additional investigation and will delay the FS
and selection of final remedy.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 9
Site Name: Pemaco Maywood (Los Angeles County, CA)
Recommendation
Status
EPA ID#: CAD980737092
RSE Report: EPA-540-R-11-005 (July 2011)
Progress since the previous progress report
Remedy l\ITec(i\eness
6.1. IB Add monitoring well in D-zone
6.1.1A Potentially add pumping or
monitoring wells in C-zone.
6.1.2 Collect vapor sample from trunk line
VE-1 to assess vapor intrusion risk
( osi Reduction
6.2.1 Reduce monitoring well sampling
from 374 to 192 or fewer samples per year.
6.2.2 Reduce process sampling of water
from about 120 to fewer than 52 per year
and vapor from 168 to fewer than 40 per
year
Planned	The site team is planning to install a new D-zone monitoring well by April 2012. The cost for
the new well is expected to be $37,200 which is $17,200 more than the RSE estimate.
Implemented The site team converted a C-zone monitoring well into an extraction well to increase pumping.
Implemented
Implemented
Implemented
6.2.3 Reduce vapor extraction points (SVE Implemented
and DPE) from about 55 to about 25.
Rebound test well groups. Reduce
groundwater extraction points from about 56
to about 24 (including 3 DPE points).
Reduce blower use. Simplify system.
The site team sampled all 7 of the wells along the VE-1 line (as well as the 48 vapor extraction
wells). The sampling indicated that vapor intrusion is not an issue in this location. The
sampling cost about $5,000 which is within the $15,000 RSE estimate that included contingent
sampling.
The site team reports that sampling has been reduced from 432 wells costing $442,800 per year
to 206 samples per year (73 wells sampled semiannually and 15 wells sampled quarterly). The
site team projects a savings of about $230,000 per year associated with this reduction; this is
more than the $ 145,000 or greater savings estimated in the RSE because the original number of
samples had been underestimated in the RSE.
On the call, the site team reported that they are currently evaluating the recommended reduction
to eliminate sampling influent headers and intermediate process locations that are not useful for
system operation decisions. Since the call, the site team further evaluated reducing process
sampling and has reportedly decided to eliminate all sampling of influent headers and
intermediate process locations for both vapor and groundwater, as per RSE recommendations.
As of this date, only combined influent and effluent samples will be collected monthly at a
potential savings of about $54,000 per year in labor and ODC costs.
The site team has reduced operating vapor extraction wells to 16 and reduced groundwater
pumping to 29 wells (including 6 DPE wells) at a 17 gallon per minute total How rate. The
system has been operated with one blower for an estimated $40,000 annual power cost savings.
The site team will consider performing rebound sampling only on well groups, as recommended
in the RSE, at an expected savings of $28,000. The site team already considered using an
existing "polishing blower" once DPE wells are no longer in use, but determined it would not
produce the necessary vacuum. The design engineer will consider using a smaller blower (37
hp) to replace the currently operating (75 hp) liquid ring blower. He will also consider how to
simplify the control system and enhance the efficiency of the bag filtration system to reduce
labor costs.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 9
Site Name: Pemaco Maywood (Los Angeles County, CA)
Recommendation
Status
EPA ID#: CAD980737092
RSE Report: EPA-540-R-11-005 (July 2011)
Progress since the previous progress report
6.2.4 Reduce operator labor to one FTE or In progress
less. Eliminate manned off-hour security.
6.2.5 Reduce project management costs. In progress
Technical lmprn\cmcnl
6.3.1 Improve reporting
Progress Toward Cleanup Coals
Implemented
6.4.1 Establish SSRLs for determination of Implemented
SVE well closures and resample at baseline
locations for remediation confirmation
Crccn Kemedialion
6.5.0 Use local staff for groundwater
monitoring
Declined
The site team reports that they have reduced plant personnel from three full-time to two full-
time and one part-time staff at a savings of about $36,000 per year based on the $820,000 per
year costs reported during the RSE and the $392,000 for six months of O&M reported for the
follow-up call. Further reductions have not been made due to the high volume of maintenance,
the frequency of process data collection which has not been reduced, and site policy of having
2-person crews perform O&M. Off-hour security also remains because of concerns regarding
vandalism and other crime in the area. The site team is currently evaluating other methods for
achieving adequate security without manned personnel. In addition, the team is looking at ways
of further reducing operator labor, as suggested by the RSE.
The RSE recommendation was to reduce project management (including technical support and
reporting) costs in line with the simplified system and reduced monitoring from about $400,000
per year to achieve costs of $150,000 per year or less.The site team notes that ongoing costs
were reduced in the second half of 2011 and optimization efforts continue. Project
management costs were about $152,000 for the second half of 2011 or about $304,000 per year.
The site team noted that the reporting improvements began with 2011 reports and represent a
$60,000 portion of the project management costs.
The site team is currently using a total VOC level of about 100 ppbv to decide vapor extraction
well status and agreed that a more formal standard would be useful for further decisions. The
site team resampled the baseline locations and found only three locations above action levels.
The site team reported that staff from San Diego (rather than northern California as reported in
the RSE) are conducting the monthly process sampling.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 10
Site Name: Northwest Pipe & Casing (Clackamas, OR)
Recommendation
Status
EPA ID#: ORD980988307
RSE Report: EPA 542-R-07-018 (September 2007)
Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1 Improve delineation of Plume 1 to the
south
6.1.2	Finalize institutional controls (ICs) on
Parcel A
6.1.3	Continue/conclude efforts to evaluate
potential for vapor intrusion on Parcel A
Cosl Reduction
(> 2 I I M111111i;ilc iipeialKin nf (i( \Vs
Technical lmpm\cmcnl
(> ' I ke\ ise sequencnm lor ailleclnm Mie-
u ide ualer le\ el dala
Progress Toward Cleanup Coals
6.4.1	Clarify and document goals for active
remediation
6.4.2	Implement in-situ bioremediation to
reduce highest VOC concentrations, in
conjunction with natural remediation
Implemented
Implemented
Implemented
Implemented
Implemented
In progress
In progress
ICs were finalized for the Northwest Development Company portion on Parcel A in October
2010.
There are no outstanding issues concerning the Vapor Intrusion issue at the ODOT property.
Vapor Intursion Risk Assessment found risk to within the acceptable range.
The site team continues to monitor removal action, will be completing modeling to help
determine how to proceed. Modeling should be completed by 4th quarter FY12.
FS will be completed in FY 2012, expect ROD amendment by end of 2013, based on the
removal action and the addition of the soil ammendment it is unlikely that additional action will
occur at the site except for monitoring.
OSWER 9283.1-38 Appendix
July 2012
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RSE Recommendations and Progress Toward Implementation
Region 10
Site Name: Boomsnub/Airco (Hazel Dell, WA)
Recommendation
Status
EPA ID#: WAD009624453
RSE Report: EPA-542-R-02-016 (September 2002)
Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1	Conduct a hydro-geological analysis Implemented
6.1.2	Evaluate potential management	Implemented
options for extraction and discharge
6.1.3	Considerations for potential extraction Implemented
and discharge options
6.1.4	Consider other discharge options Implemented
Cosl Reduction
6.2.1	Eliminate ion exchange effluent tank Implemented
and pump
6.2.2	Improve electric work for air stripper Implemented
Technical lmprn\cmcnl
6.3.1	Consider limitations of passive	Implemented
technologies
6.3.2	Develop an exit strategy	In progress
We are addressing an orphan in-coming TCE plume that does not appear to be related to the
sources of the Superfund site. This is delaying the finalization of an exit strategy.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 10
Site Name: Wyckoff/Eagle Harbor (Bainbridge Island, WA)
Recommendation
Status
EPA ID#: WAD009248295
RSE Report: EPA-542-R-05-013 (March 2005)
Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1 Select a final remedy
Cost Reduction
6.2.1	Simplify existing treatment plant
6.2.2	Install upgradient sheet pile
Implemented
Implemented
Declined
6.2.3 Remove steam injection/ extraction Planned
system and apply cap
6.2.4	Conduct water budget analysis	Implemented
6.2.5	Upgrade extraction system	Implemented
6.2.6	Replace the existing treatment plant Implemented
6.2.7	Augment monitoring in lower aquifer Implemented
Technical lmpm\cmcnl
6.3.0 Other related items	Planned
-	Improve monitoring approach
-	Monitor seeps on beach
-	Consider new extraction points
Groundwater extraction system upgrades were completed in Fall 2011. Upgrades include new
extraction well pumps and installation of groundwater level pressure transducers. Shakedown
process of GWTP will be completed in Winter 2012. Operation and maintenance of GWTP
will be turned over to the State of Washingon in April 2012, for at least a period of years while
EPA works on feasiblity analysis of completing the permanent remedy.
Completion of new GWTP made old treatment plant obsolete. Old treatment plant is being
demolished as of Winter 2011.
Fieldwork has indicated that aquitard is not present in the SE corner of the site. Groundwater
evaluations has shown that a sheet pile wall is not necessary to ensure that containment is
maintained in this portion of the site.
Cap design and construction is still on hold pending completion of feasiblity analysis of
implementing a permanent source removal remedy. Demolition of old groundwater treatment
plant completed in July 2011. Demolition of remaining existing infrastructure (steam injection
well field) is also on hold.
Replacement of existing product and water pumps and installation of pressure transducers in
monitoring wells completed in Fall 2011.
Construction of new GWTP was completed in May 2009. Old treatment plant is being
demolished as of winter 2011.
Further seep monitoring along East Beach and North Shoal areas of site is currently being
planned for Spring 2012.
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July 2012
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RSE Recommendations and Progress Toward Implementation
Region 10
Site Name: Colbert Landfill (Spokane County, WA)
Recommendation
Status
EPA ID#: WAD980514541
RSE Report: EPA-540-R-11-020 (October 2010)
Progress since the previous progress report
Remedy l\ITcc(i\eness
6.1.1 Add Monitoring Well West of CP-W3 Planned
6.1.2	Include 1,4-Dioxane in Future	Planned
Residential Sampling (At Some Frequency)
6.1.3	Tighten Institution Controls Regarding Under
Groundwater Use and Document Approach Consideration
Regarding 1,4-Dioxane Detections
Technical lmprn\cmcnl
6.3.1 Modifications to Water Level Maps Implemented
6.3.2 Other Suggested Modifications to Implemented
Quarterly Reports
Progress Toward Cleanup Coals
6.4.1 Consider Shut-Down Test of	In Progress
Remaining Active Extraction Wells
The County plans to implement this recommendation, and will include this new monitoring well
in the work plan to be submitted for the P&T shut-down test. The work plan is expected in the
spring of 2012, with well installation potentially in summer of 2012.
The County plans to include 1,4-Dioxane in future residential sampling using the same
methodology employed for residential sampling of other site COCs.
The RPM indicated that he plans to discuss the adequacy of the existing institutional controls
with an attorney within approximately one month, and hopes to have that legal opinion within
the next three months. To date there is no cost impact associated with this recommendation,
and the extent to which any costs are incurred will likely depend on the information provided
by the EPA attorney.
The County indicated that the number of locations is too numerous to post, but is now including
all data collected during the reporting period. The County indicated there is no need to
highlight water levels from extraction wells since those are not used in the contouring. There
should be no cost impact associated with the implementation of this recommendation.
The recommendation that non-detect values be reported as below a specific detection limit such
as "<5" rather than "ND" has been implemented, and the recommendation that quarterly reports
include an executive summary to highlight significant observations or results from that quarter
is planned for future reports. There should be no cost impact associated with the
implementation of this recommendation.
The County has accepted this recommendation and plans to submit a draft work plan for the
shut-down test in spring of 2012 to be reviewed by stakeholders, with potential implementation
in summer of 2012.
OSWER 9283.1-38 Appendix
July 2012
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