vvEPA EPA-542-R-17-002
United States
Agency"16"13'Protection Office of Land and Emergency Management
June 2017
Superfund Optimization Progress Report
2011 -2015
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Superfund Optimization Progress
Report 2011 - 2015
EPA 542-R-17-002
Office of Land and Emergency Management
June 2017
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Superfund Optimization Progress Report 2011-2015
TABLE OF CONTENTS
Notice and Disclaimer iv
Acknowledgements v
Executive Summary ES-1
1.0 Introduction 1
1.1 Purpose and Scope 2
1.2 Project Background 6
2.0 Summary of Recommendation Implementation Progress 9
2.1 Overview of Progress 10
2.1.1 Remedy Effectiveness 11
2.1.2 Cost Reduction 14
2.1.3 Technical Improvement 17
2.1.4 Site Closure 20
2.1.5 Green Remediation 22
2.1.6 Tools and Techniques Leading to Beneficial Outcomes 23
2.2 Recommendations by Optimization Focus 25
2.2.1 Investigation Recommendations 25
2.2.2 Design Recommendations 29
2.2.3 Remedy Recommendations 34
2.2.4 Long-Term Monitoring (LTM) Recommendations 39
2.3 Events and Sites Requiring No Further Follow-Up 42
2.4 Technical Support Highlights 42
3.0 Summary of Progress on Implementing the National Optimization Strategy 45
3.1 Planning and Outreach 45
3.2 Integration and Training 46
3.3 Implementation 46
3.4 Measurement and Reporting 48
4.0 References 49
TABLE OF CONTENTS | i
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Superfund Optimization Progress Report 2011-2015
TABLES
Table 1: New Optimization Events Included in this Progress Report 3
Table 2: Updated Sites Included in this Progress Report 5
Table 3: Completed Optimization and Technical Support Events FY 1997 - FY 2015 8
Table 4: Recommended Tools and Techniques Leading to Beneficial Outcomes 24
Table 5: Types of Investigation Recommendations 26
Table 6: Types of Design Recommendations 29
Table 7: Types of Remedy Recommendations 35
Table 8: Types of Long-Term Monitoring Recommendations 39
Table 9: Completed Technical Support Projects FY 2011 - FY 2015 43
Table 10: EPA Optimization Support 47
FIGURES
Figure 1: Key Optimization Components and Superfund Pipeline Activities 7
Figure 2: Overall Status of all Optimization Recommendations 10
Figure 3: Remedy Effectiveness Implementation Status 11
Figure 4: Cost Reduction Implementation Status 14
Figure 5: Technical Improvement Implementation Status 17
Figure 6: Site Closure Recommendation Implementation Status 20
Figure 7: Green Remediation Recommendation Implementation Status 22
Figure 8: Number of Implemented Tools and Techniques 25
Figure 9: Superfund Phase of Optimization Events 47
TABLE OF CONTENTS | M
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Superfund Optimization Progress Report 2011-2015
HIGHLIGHTS
Highlight 1: Remedy Effectiveness - Baytown Township Ground Water Plume Site 12
Highlight 2: Remedy Effectiveness - Benfield Industries, Inc. Site 13
Highlight 3: Cost Reduction - State Road 114 Groundwater Plume Site 15
Highlight 4: Cost Reduction - Wash King Laundry Site 16
Highlight 5: Technical Improvement - Sandy Beach Ground Water Plume Site 18
Highlight 6: Technical Improvement - Gilt Edge Mine Site 19
Highlight 7: Site Closure - Groveland Wells No. 1 & 2 Site 21
Highlight 8: Green Remediation - Pemaco Maywood Site 23
Highlight 9: Investigation Recommendations - Black Butte Mine Site 27
Highlight 10: Investigation Recommendations - Sulphur Bank Mercury Mine Site 28
Highlight 11: Design Recommendations - Lockwood Solvent Ground Water Plume Site
OU 02 31
Highlight 12: Design Recommendations - Jones Road Ground Water Plume Site 32
Highlight 13: Design Recommendations - East 67th Street Ground Water Plume Site... 33
Highlight 14: Remedy Recommendations - North Penn - Area 6 36
Highlight 15: Remedy Recommendations - Palermo Well Field Ground Water
Contamination Site 37
Highlight 16: Remedy Recommendations - Tar Creek (Ottawa County) Site 38
Highlight 17: Long-Term Monitoring Recommendations - Middlefield-Ellis-Whisman
(MEW) Study Area 40
Highlight 18: Long-Term Monitoring Recommendations - MetalTec/Aerosystems Site.. 41
Highlight 19: Technical Support - Hamilton/Labree Roads GW Contamination Site 44
Highlight 20: Technical Support - Wyckoff Co./Eagle Harbor Site 44
Highlight 21: Technical Support - Colorado Smelter Site 45
AVAILABLE SEPARATELY
Appendix A: Progress on Implementing the National Optimization Strategy
Appendix B: List of Completed Optimization and Technical Support Events FY 1997 - FY
2015
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Superfund Optimization Progress Report 2011-2015
NOTICE AND DISCLAIMER
Preparation of this report has been funded wholly or in part by the U.S. Environmental Protection
Agency (EPA) under contract number EP-W-14-001 with ICF. This report is not intended, nor can it be
relied upon, to create any rights enforceable by any party in litigation with the United States. Mention
of trade names or commercial products does not constitute endorsement or recommendation for use.
A portable document format (PDF) version of the Superfund Optimization Progress Report 2011 -
2015 (EPA 542-R-17-002) is available for viewing or downloading from EPA's Cleanup Optimization at
Superfund Sites website at www.epa.qov/superfund/cleanup-optimization-superfund-sites. For more
information about this report, contact Carlos Pachon (pachon.carlos@epa.gov) or Ed Gilbert
(gilbert.edward@epa.gov).
NOTICE AND DISCLAIMER | iv
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Superfund Optimization Progress Report 2011-2015
ACKNOWLEDGEMENTS
The EPA would like to acknowledge and thank the following individuals who contributed to the
development and review of this document:
EPA Headquarters (HQ) Optimization Team:
EPA Remedial Project Managers:
Kirby Biggs
Ed Gilbert
Matt Jefferson
Carlos Pachon
Dan Powell
EPA Regional Optimization Liaisons:
Region
1
Derrick Golden and Kim White
Region
2
Jeff Joseph son
Region
3
Kathy Davies
Region
4
Rusty Kestle
Region
6
Vincent Malott
Region
7
Sandeep Mehta
Region
8
Victor Ketellapper
Region
9
Andrea Benner
Region
10: Bernie Zavala
EPA Superfund Technical Liaisons:
Region 1: Terry Connelly
Region 2: Brian Quinn
Region 3: Huu Ngo
Region 4: John Bornholm
Region 5: Leah Evison, Shari Kolak
Region 6: Rafael Casanova, Bob Sullivan
Region 8: Sabrina Forrest, Joy Jenkins,
Tillman McAdams
Region 9: Rosemarie Caraway, Alana Lee,
Gary Riley
Region 10: Helen Bottcher, Claire Hong,
Tamara Langdon, Linda Meyer
Additional National Optimization
Workgroup Members:
Jean Balent- HQ
Frances Costanzi - Region 8
William Dalebout- HQ
Jennifer Edwards - HQ
Region 1
Jan Szaro
Silvinia Fonseca - HQ
Region 2
Diana Cutt
Michael Gill - Region 9
Region 3
Jonathan Essoka
Jennifer Hovis - HQ
Region 4
Felicia Barnett
Tom Kady - HQ
Region 5
Charles Maurice
Shahid Mahmud - HQ
Region 6
Terry Burton
Gary Newhart- Environmental Response
Region 7
Robert Weber
Team
Region 8
Steve Dyment
Dion Novak - Region 5
Region 9
Anne-Marie Cook
Zi Zi Searles - Region 9
Region 10: Kira Lynch
Amanda Van Epps - HQ
Stacey Yonce - HQ
ACKNOWLEDGEMENTS | v
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Superfund Optimization Progress Report 2011-2015
EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency (EPA) is continuing to make progress on (1) implementing
recommendations for individual optimization events, (2) conducting site-specific technical support,
and (3) implementing the elements of the 2012 National Strategy to Expand Superfund Optimization
Practices from Site Assessment to Site Completion ("the Strategy"). Status updates are provided in
this report for (1) optimization recommendations for 41 new optimization events conducted during
Fiscal Years (FY) 2011 through FY 2015, for (2) 20 optimization events with outstanding
recommendations recorded in previous progress reports, and for (3) 25 technical support projects
conducted during FY 2011 through FY 2015. Project highlights are provided for both optimization and
technical support events.
The Strategy instituted changes to the Superfund remedial program business processes to take
advantage of newer tools and strategies that promote more effective and efficient cleanups. Under
the Strategy, EPA expanded the optimization program to support nearly 50 ongoing optimization
events in a typical year and complete about 20 optimization events per year. By expanding the
optimization program, EPA has realized benefits from optimization at a larger number of sites, such
as increasing remedy effectiveness, improving technical performance, reducing costs, moving sites to
completion, and lowering the environmental footprint of remediation activities. In addition, optimization
and technical support events are being conducted across all phases of the Superfund pipeline from
site assessment through site completion, with the goal of improving the approaches to
characterization, design, remediation, and operation and maintenance of Superfund sites.
Approximately 35 percent of the optimization events included in the report were conducted in pre-
remedial phases of the Superfund pipeline, 51 percent during remedial action phases, and 14 percent
during operation and maintenance.
In FY 2015, EPA collected information from Remedial Project Managers on the status of the
optimization recommendations from the reviews of 61 sites. Overall, 64 percent of optimization
recommendations were implemented, are in progress, or are planned. Another 15 percent are still
under consideration and only 16 percent were declined. A small number of recommendations (4
percent) were deferred to the state or Potentially Responsible Party for action; 1 percent do not have
status information available.
EPA conducted a more detailed analysis of the various tools and techniques included in optimization
recommendations and of the beneficial outcomes achieved by implementing them. EPA noted use of
the following tools and techniques as a result of the optimization reviews and technical support
events: (1) 68 percent of the sites had improvements to the conceptual site model, (2) 60 percent of
the sites had streamlined or improved monitoring, (3) 39 percent of the sites had improved system
engineering, and (4) 36 percent of the sites had a change in the remedial approach.
Technical support was completed for 25 events. Three of these events are highlighted in the report
and include support in conducting high-resolution site characterization, developing an environmental
footprint analysis, and developing conceptual site models.
EXECUTIVE SUMMARY | ES-1
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Superfund Optimization Progress Report 2011-2015
1.0 INTRODUCTION
The U.S. Environmental Protection Agency (EPA) has been conducting optimization activities at
Superfund sites since 1997 and periodically reporting on the progress of implementing optimization
recommendations (EPA, 2012a). EPA began its optimization efforts as a pilot program focused on
groundwater pump and treat (P&T) remedies at Superfund (Fund-lead) sites by conducting
remediation system evaluations and long-term monitoring optimizations. In August 2004, EPA
developed the Action Plan for Ground Water Remedy Optimization ("Action Plan") (EPA, 2004) to
further implement important lessons learned from the pilot phase and fully integrate optimization into
the Superfund cleanup process, where appropriate. As the program matured, further recognition of
the benefits of optimization prompted EPA to expand and formalize its optimization program. In
2012, EPA issued the National Strategy to Expand Superfund Optimization Practices from Site
Assessment to Site Completion ("the Strategy") (EPA, 2012b). Under the Strategy, optimization
activities are conducted at every phase of the Superfund pipeline, from site assessment to site
completion. This Superfund Optimization Progress Report 2011 - 2015 summarizes EPA's progress
on implementing optimization recommendations for individual optimization events, conducting
technical support, and implementing the elements of the overall Strategy.
The four main sections of this report are:
Introduction (Section 1.0), including a
discussion of the purpose of the report and
background on the history of the
optimization program and optimization
strategy; Summary of Implementation
Progress (Section 2.0), including a summary
of EPA's progress in implementing
optimization recommendations at sites that
were reviewed and information on technical
support events; Summary of Progress on
Implementing the National Optimization
Strategy (Section 3.0), summarizing EPA's
progress in implementing this strategy; and
References (Section 4.0). Appendix A
provides a detailed discussion of EPA's
progress on implementing the National
Optimization Strategy. Appendix B lists the
optimization and technical support events
completed through FY 2015.
Contents of Report
Executive Summary
Section 1.0 Introduction
1.1 Purpose and Scope
1.2 Project Background
Section 2.0 Summary of Recommendation
Implementation Progress
2.1 Overview of Progress
2.2 Recommendations by Optimization
Focus
2.3 Events and Sites Requiring No
Further Follow-up
2.4 Technical Support Highlights
Section 3.0 Summary of Progress on
Implementing the National Optimization Strategy
Section 4.0 References
Appendix A. Progress on Implementing the
National Optimization Strategy
Appendix B. List of Completed Optimization and
Technical Support Events FY 1997 - FY 2015
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Superfund Optimization Progress Report 2011-2015
1.1 Purpose and Scope
The purpose of this report is twofold: (1) to provide a summary and analysis of the status of
implementation of the site-specific recommendations resulting from independent optimization
reviews at Superfund sites and to discuss and highlight technical support activities; and (2) to
summarize EPA's progress on implementing the four main elements of the Strategy. The elements
include:
¦ Element 1: Planning and Outreach.
¦ Element 2: Integration and Training.
¦ Element 3: Implementation.
¦ Element 4: Measurement and Reporting.
Optimization reviews result in site-specific reports with recommendations that fall within one of five
standard recommendation categories: remedy effectiveness, cost reduction, technical improvement,
site closure, and green remediation. Starting one year after completing the optimization review, the
optimization team follows up with the Remedial Project Manager (RPM) for the site to determine the
status of implementing the recommendations at the site. The implementation status of the
recommendations is then tracked, and follow-up continues until all recommendations have been
implemented, declined, or in some cases, deferred to the state.
Technical support projects generally result in providing site support for specific activities such as
developing a strategic sampling approach, conducting systematic project planning, conducting a
focused technical review of a specific aspect of a site, and visualizing and analyzing data to help
identify data gaps in the conceptual site model (CSM). Technical support projects do not generally
result in a report with recommendations that are tracked, although EPA does track the start and
completion dates of these projects.
Successful strategies for implementing optimization recommendations, opportunities for
improvement, barriers to implementation, and changes in project costs as a result of optimization are
also a focus of this report. In addition, project highlights showcasing specific sites where optimization
activities have had positive impacts are presented. Summaries and highlights of technical support
projects whose positive results and lessons learned may be beneficial to other sites are also
included.
This report covers the implementation of optimization recommendations during fiscal year (FY) 2011
through FY 2015 from 61 optimization events that are subject to tracking. It should be noted that not
all optimization events completed in FY 2015 are included in this report; only those completed early
in FY 2015 and where updated information was available are addressed. Information is provided on
the implementation of recommendations for 41 events where an optimization was performed since
the last progress report and which are being reported on for the first time (Table 1). Information is
also provided for 20 events where implementation of recommendations has continued since the last
progress report (Table 2). Most reviews were conducted at sites on the National Priorities List (NPL);
some were conducted at non-NPL sites such as sites from the Brownfields and Underground
Storage Tank programs.
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Table 1: New Optimization Events Included in this Progress Report
Total
FY Optimization Optimization
State Optimization Event Complete Focus Events
Region 1
MA Baird & McGuire 2013
ME Eastern Surplus 2012 R
MA
Groveland Wells No. 1 & 2
2013
L
MA
Groveland Wells No. 1 & 2
2014
L
NH Ottati & Goss/Kingston Steel Drum 2014 R, L
MA
Baird & McGuire
2013
R
Region 2
3
NJ
MetalTec/Aerosystems
2012
L
NY
Richardson Hill Road Landfill/Pond and
Sidney Landfill Site
2012
I, R
NJ
Rockaway Borough Well Field, OU 2
2012
L
Region 3
3
PA
Fischer & Porter Co.
2014
R
PA
North Penn - Area 6
2012
R
VA
Peck Iron and Metal
2013
I
Region 6
6
TX
East 67th Street Ground Water Plume
2012
D
NM
Homestake Mining Co.
2011
R
TX
Jones Road Ground Water Plume
2014
D
TX
Sandy Beach Road Ground Water
Plume
2014
D
TX
State Road 114 Groundwater Plume
2014
R
OK
Tar Creek (Ottawa County), OU 4
2014
R
Region 7
5
IA
Fairfield Coal Gasification Plant
2012
L
NE
Hastings Ground Water Contamination
2013
R
MO
Lee Chemical
2012
L
IA
Railroad Avenue Groundwater
Contamination
2014
R
MO
Valley Park TCE
2013
I, L
Region 8
8
SD
Batesland (Former Mobil Gas Station)
2013
I, D
MT
Burlington Northern (Somers Plant)
(BNSF Railway)
2015
R
UT
Former Old Hilltop
2013
I, D
SD
Gilt Edge Mine
2013
R
UT
Intermountain Waste Oil Refinery
(IWOR)
2011
R
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Superfund Optimization Progress Report 2011-2015
State
Optimization Event
FY
Complete
Optimization
Focus
Total
Optimization
Events
MT
Lockwood Solvent Ground Water
Plume, OU 2
2014
I, D
SD
Pine Ridge Oil
2013
I, D, R
CO
Standard Mine
2014
D
Region 9
6
AZ
Davis Chevrolet/Nav 185 Site
2013
I, D, R
CA
Intel Magnetics
2013
L
CA
Middlefield-Ellis-Whisman (MEW) Study
Area
2012
D
AZ
Painted Desert Inn/Nav 049 Site
2013
I, D, R
CA
Sulphur Bank Mercury Mine
2015
R
AZ
Telles Ranch/CRIT 002
2013
D, R
Region 10
4
OR
Black Butte Mine
2012
I
ID
Bunker Hill Mining & Metallurgical
Complex, OU 2
2013
R
WA
Moses Lake Wellfield Contamination
2015
I
WA
Palermo Well Field Ground Water
Contamination
2012
R
TOTAL
41
FY Complete indicates the Fiscal Year of the final optimization report.
I = Investigation, D = Design, R = Remedy, L = Long-Term Monitoring; a single event may have recommendations that fall into
more than one focus area.
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Table 2: Updated Sites Included in this Progress Report
Total
FY
Optimization
Optimization
State Optimization Event
Complete
Focus
Events
Region 2
3
NY GCL Tie and Treating Inc. 2007 R
VI
Tutu Wellfield
2012
R
NJ
Vineland Chemical Co., Inc.
2012
R
Region 3
1
PA
Mill Creek Dump
2010
R, L
Region 4
3
FL
Alaric Area GW Plume
2010
R
FL
American Creosote Works, Inc.
(Pensacola Plant)
2006
R
NC
Benfield Industries, Inc.
2007
R
Region 5
5
MN
Baytown Township Ground Water
Plume
2011
R
Wl
Moss-American Co., Inc. (Kerr-McGee
Oil Co.)
2011
R
Ml
Ott/Story/Cordova Chemical Co.
2002
R
Ml
Wash King Laundry
2011
R
IN
Reilly Tar & Chemical Corp.
(Indianapolis Plant)
2004
R
Region 7
2
NE
10Th Street Site
2010
R
KS
57th and North Broadway Streets Site
2006
R
Region 8
1
CO
Central City, Clear Creek
2007
R
Region 9
2
CA
Modesto Ground Water Contamination
2002
R
CA
Pemaco Maywood
2011
R
Region 10
3
WA
Boomsnub/Airco
2002
R
WA
Colbert Landfill
2011
R
OR
Northwest Pipe and Casing/Hall
Process Company
2007
R
TOTAL
20
FY Complete indicates the Fiscal Year of the final optimization report.
I = Investigation, D = Design, R = Remedy, L = Long-Term Monitoring; a single event may have recommendations that fall into
more than one focus area.
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Superfund Optimization Progress Report 2011-2015
1.2 Project Background
EPA's Office of Land and Emergency Management (OLEM), formerly the Office of Solid Waste and
Emergency Response (OSWER), developed the pilot Fund-lead P&T optimization initiative as part of
the FY 2000-FY 2001 Superfund Reforms Strategy (EPA, 2000). Optimization is intended to facilitate
systematic review and modification of planned and operating remediation systems to promote
continuous improvement and to ensure overall remedy protectiveness and cost effectiveness. In the
Superfund program, many optimization evaluations utilize the Remediation System Evaluation
process, a tool developed by the U.S. Army Corps of Engineers (USACE) that EPA has further
refined through application at Superfund sites.
The pilot phase of the optimization initiative demonstrated that optimization reviews offered
measurable benefits in the form of cost savings and improved remediation system performance
(EPA, 2005). In August 2004, EPA developed the Action Plan (EPA, 2004) to further implement
important lessons learned from the pilot phase and fully integrate optimization into the Superfund
cleanup process, where appropriate. Among other actions, this plan envisioned the development of
routine progress reports concerning the implementation of recommended system changes.
Since the creation of the Action Plan, the Superfund program has consistently developed best
practice tools and approaches that apply optimization concepts to sites earlier in the investigation
and cleanup process. In late 2010, EPA initiated the development of the Strategy to increase the
capacity for conducting optimizations and to extend optimization to all phases of the Superfund
pipeline. The Strategy, issued in September 2012 (EPA, 2012b), expands and formalizes
optimization practices from site assessment to site completion as an operating business model for
the Superfund program. Widespread implementation of optimization review recommendations and
best practices could assist EPA in achieving the goals of the Superfund Remedial Program Review
(SPR) Action Plan (EPA, 2013a). Optimization reviews contribute to the following SPR Action Plan
goals:
¦ More efficient use of constrained budgetary resources.
¦ Integrating remedial design and remedial action.
¦ Integrating adaptive management throughout the remedial process.
¦ Streamlining processes.
¦ Leveraging resources.
The Strategy encourages overarching process changes in program management and
implementation, as well as site-level project management. These changes are intended to instill
routine and frequent assessment of site cleanup progress, improve technical performance, reduce
costs, and refine business practices including acquisition strategies and contracts management. The
Strategy emphasizes incorporating optimization principles throughout the cleanup process from site
assessment through site completion. Progress on the implementation of the Strategy is summarized
in Section 3.0 and discussed in more detail in Appendix A of this report.
Sites are selected for optimization reviews collaboratively, based on input from EPA Headquarters
(EPA HQ), RPMs, regional management, Regional Optimization Liaisons (ROLs), and stakeholders.
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The optimization teams consist of an EPA HQ lead, the ROL, and a team of technically qualified
individuals from within EPA, USAGE, or one of EPA's pool of contractors with the qualifications
necessary to conduct the optimization review. The site team consists of the RPM, regional technical
support staff such as a hydrogeologist, state personnel, tribes, potentially responsible parties
(PRPs), contractors, and other stakeholders such as community representatives. The reasons for
conducting an optimization review vary and can include the following: (1) uncertainty regarding the
current CSM; (2) highly complex site conditions with multiple sources, multiple contaminant plumes,
or significant subsurface heterogeneity; (3) increasing investigative costs or expanding the scope of
the investigation; (4) lack of progression to the next phase in the Superfund pipeline; (5) concerns
regarding planned or existing remedy performance, effectiveness, or cost; (6) need to obtain an
independent assessment of a remedial design; (7) interest in applying innovative strategies or
technologies; (8) not achieving the goals of the remedy as anticipated; (9) exploring the opportunity
to reduce monitoring points and costs; (10) a need to expedite the time frame for property
redevelopment; (11) a need to reduce energy and effort and enhance efficiency; and (12) a need to
develop or refine the completion strategy.
Figure 1 depicts the key components of optimization and the remedial pipeline phases at which
optimization can be applied.12
Figure 1: Key Optimization Components and Superfund Pipeline Activities
SITE DISCOVERY
KEY OPTIMIZATION
COMPONENTS
Site Assessment
Remedial Investigation
Feasibility Study
Remedial Design
Remedial Action
Long-Term Response Action
Operation and Maintenance
Remedy
Components
Strategy
Conceptual
Site Model
Monitoring
Remediation
Approach I Management
SITE COMPLETION
Source: Adapted from EPA 2012b.
1 See CFR, title 40, sec 300, Subpart E, for details regarding the phases of the Superfund pipeline
2 Information about the seven key components can be found at www.epa.aov/suDerfund/cleanuD-optimization-superfund-sites
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Superfund Optimization Progress Report 2011-2015
Early in the optimization program, the reviews centered on Fund-lead groundwater P&T remedies
and primarily focused on the constructed remedy and long-term monitoring. In more recent years
EPA has found that, consistent with the goals of the Strategy, optimization reviews are conducted at
any phase of the Superfund pipeline. In general, the recommendations made in an optimization
review cover one of four optimization focus areas: investigation, design, remedy and long-term
monitoring.3 Optimization review teams usually include an evaluation of the CSM for each site, and
make recommendations related to investigation activities when needed. This practice continues as
EPA has learned that a continual focus on CSMs is valuable in assisting site teams in improving site
remedy performance and progress, no matter the phase of the Superfund pipeline or the focus of the
optimization review of the site.4
EPA has conducted a total of 194 optimization and technical support events from FY 1997 through
FY 2015 (Table 3). A list of these optimization and technical support events is provided in Appendix
B. From FY 1997 through FY 2010, EPA completed 94 optimization and technical support events,
averaging seven events per year. From FY 2011 through FY 2015, with the implementation of the
Strategy, EPA completed 100 optimization and technical support events, averaging 20 events per
year. Through implementation of the Strategy, EPA has nearly tripled the number of optimization
reviews and technical support projects it completes each year. Accordingly, EPA has expanded the
benefits from optimization and technical support to a much larger universe of sites.
Table 3: Completed Optimization and Technical Support Events FY 1997 - FY 2015
Number of Number of
Events Events Total Events o/0 per
Region 1997 - 2010 2011 -2015 1997 -2015 Region
10
17
9%
2 12 12 24 12%
3
18
6
24
12%
4
11
1
12
6%
5
12
4
16
8%
6
5
11
16
8%
7
6
13
19
10%
8
4
12
16
8%
9 6 20 26 13%
10
10
14
24
12%
TOTAL
94
100
194
100%
In addition to expanding the program, EPA has implemented innovative approaches to optimization,
such as reviewing a portfolio of sites located in a common geographic area. Coordinating site visits
reduces costs associated with travel and deployments of personnel. EPA has also targeted
3 Note the focus area of the optimization review does not necessarily line up with the Superfund pipeline phase. An optimization may
be characterized as a remedy review even if the site is in O&M if the recommendations focus on the operating remedy.
4 See factsheet: Environmental Cleanup Best Management Practices: Effective use of the Project Lifecycle Conceptual Site Model
(EPA, 2011)
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optimization and technical support activities at certain types of sites, with the most recent example
being the mining site optimization pilot. This focused pilot effort was initiated based on the
recognition that mining sites constitute some of the largest, costliest, most complex and longest-
duration cleanups and can benefit from optimization. The treatment of mining influenced waters
(MIW) is required at many mining sites and can be costly, making these sites good candidates for
optimization and technical support projects.
EPA has continued to make improvements to the optimization program. These improvements are
discussed in Section 3.0, Summary of Progress on Implementing the National Optimization Strategy.
2.0 SUMMARY OF RECOMMENDATION
IMPLEMENTATION PROGRESS
Implementing recommendations from optimization reviews can result in improved: (1) understanding
of the site conditions, (2) designs for remedies, or (3) operations of remediation systems, depending
on the type of optimization review conducted and the phase of the Superfund pipeline. Optimization
reviews typically identify a number of opportunities for improvements. These improvements are
organized into five recommendation types; some recommendations are categorized into more than
one recommendation type. The recommendation types and the total number of recommendations for
each type are as follows:
¦ Remedy effectiveness - 273 recommendations.
¦ Cost reduction - 152 recommendations.
¦ Technical improvement - 158 recommendations.
¦ Site closure - 107 recommendations.
¦ Green remediation - 32 recommendations.
A total of 61 optimization events are included in this report—41 new optimization events (Table 1)
and 20 optimization update events from previous years (Table 2). EPA worked closely with regional
staff including RPMs and ROLs to collect information on the status of the recommendations for each
of the 61 optimization reviews. Sources of information for this report included information from
RPMs, site-specific optimization reports, optimization recommendation follow-up recorded in past
annual reports, and follow-up information provided in the most recent data collection effort.
Section 2.1 summarizes the overall progress in implementing each of the recommendations by
category without regard to the optimization focus area; provides the status of implementation for
each of the five recommendation categories; presents specific project highlights for the five
recommendation categories; and examines the tools and techniques recommended in optimization
reviews that have led to positive outcomes. Section 2.2 summarizes investigation type, design type,
remedy type and long-term monitoring (LTM) type recommendations and presents specific project
highlights. Section 2.3 presents the list of events and sites that are no longer subject to follow up.
Section 2.4 presents specific project highlights for technical support events.
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Superfund Optimization Progress Report 2011-2015
2.1 Overview of Progress
As shown in Figure 2, completed optimization reviews for the 61 optimization events included in this
report identified a total of 645 optimization recommendations.
Overall, 64 percent of optimization recommendations have been implemented, are in progress, or
are planned, and another 15 percent are under consideration. Only 16 percent of optimization
recommendations were declined. Recommendations can be declined for a number of reasons
including changed site conditions or selection of one option when several are offered. A small
number of recommendations (4 percent) were deferred to the state or PRP for action.
Recommendations are deferred to the state or PRP when site activities are their responsibility and
the remedy is protective. In these cases the recommendations are provided as suggestions for
improvements to be addressed at the discretion of the state or PRP. No information was provided for
one percent of the recommendations, labeled as undefined. These results demonstrate that
optimization review teams continue to evaluate site conditions and put forth reasonable
recommendations for making improvements and that site teams are open to suggestions for
improvement.
Figure 2: Overall Status of all Optimization Recommendations
Total Number of Recommendations = 645
Implements
293, 45%
Planned, 43, 7%
Under
Consideration, 96,
15%
Undefined, 8, 1%
Deferred to State
Declined, 103, 16% or PRP, 26, 4%
Information about the overall progress for each recommendation type, remedy effectiveness, cost
reduction, technical improvement, site closure, and green remediation is presented in Sections 2.1.1
through 2.1.5. For each recommendation type, specific project examples are included that highlight
progress. Information about how various tools and techniques were recommended as part of
optimization events and how beneficial outcomes were achieved by implementing the optimization
recommendations is summarized in Section 2.1.6.
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2.1.1 Remedy Effectiveness
The majority of optimization recommendations (273 of the 645) fall into the remedy effectiveness
category. As shown in Figure 3, 70 percent of the recommendations for remedy effectiveness have
been implemented, are in progress, or are planned, and another 12 percent are still under
consideration. Only 14 percent of optimization recommendations in the remedy effectiveness
category were declined.
Figure 3: Remedy Effectiveness Implementation Status
Total Number of Recommendations = 273
Implemented, 130
48% _
Planned, 23, 8%
Under
Consideration, 33
12%
Deferred to State
4, 2%
Declined, 39, 14%
Undefined, 6, 2%
Examples of remedy effectiveness recommendations include the following:
¦ Improvements in the CSM through additional characterization of sources and environmental
media.
¦ Changes in remedial approach to address subsurface contamination.
¦ Changes in management approach.
¦ Improvements to the performance of an existing system.
¦ Identification and reduction of risk.
Highlights 1 and 2 for Baytown Township and Benfield Industries, Inc. provide examples of remedy
effectiveness recommendations.
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Highlight 1: Remedy Effectiveness
Baytown Township Ground Water Plume Site, Lake Elmo, Minnesota
KEY CHALLENGES
¦ Contaminant mass in subsurface not adequately addressed by P&T
¦ Source not adequately characterized
¦ Sampling groundwater by pumping expensive to implement
¦ Data not easily retrievable
PRIMARY RECOMMENDATIONS
¦ Consider implementing technologies to remove contaminant mass in subsurface
¦ Use Membrane Interface Probe (MIP) to assess the source mass distribution
¦ Consider use of passive methods to collect groundwater samples where
appropriate
¦ Use existing electronic data management system to improve data retrieval
^ IMPLEMENTATION OUTCOMES
¦ Changed remedial approach for groundwater by adopting in situ chemical oxida-
tion (ISCO) followed by in situ bioremediation (ISB) using Enhanced Reductive
Dechlorination (ERD)
¦ Performed MIP assessment of source zone in 2012
¦ Using electronic database software to store and retrieve data
The Baytown Superfund site involves groundwater contamination with trichloroethene (TCE)
attributed to a former metal working facility. The selected remedy initially included a groundwater
P&T system, granular activated carbon (GAC) units for affected private wells, and a long-term
monitoring program to assess the effectiveness of the P&T system. A pilot test for ISCO
conducted before the optimization review showed promising results for reducing subsurface
contaminant concentrations in the source area. The pilot study was conducted in recognition that
P&T alone would take a long time to reach Remedial Action Objectives (RAOs) if the source zone
remained untreated.
The optimization review, completed in FY 2011, recommended additional source characterization,
full-scale implementation of ISCO in the source area with continued operation of the P&T system,
and consideration of ISB using ERD. The optimization review also recommended improvements
to monitoring such as using passive sampling techniques for collecting groundwater samples and
improving data management. ISCO and ERD have been implemented at the site to address the
subsurface source zone and groundwater contamination, and data and chain-of-custody are
managed electronically.
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Highlight 2: Remedy Effectiveness
Benfield Industries, Inc. Site, Waynesville, North Carolina
KEY CHALLENGES
¦ Several carcinogenic polycyclic aromatic hydrocarbons (PAHs) have been de-
tected above cleanup levels in one monitoring well
PRIMARY RECOMMENDATIONS
¦ Identify additional areas of PAH contamination and consider use of ISCO and in
situ enhanced bioremediation (ISEB)
¦ Consider Monitored Natural Attenuation (MNA) as a groundwater remedial
strategy rather than the existing groundwater system
¦ Document the rationale for eliminating metals analysis; conduct a background
study if needed
IMPLEMENTATION OUTCOMES
¦ Changed remedial strategy from P&T to in situ treatment of source contamination
documented in a Record of Decision Amendment (ROD Amendment) in FY 2015
¦ Planning for additional confirmatory sampling and documentation of rationale for
stopping metals analysis
The Benfield Industries site occupies a 6-acre parcel in Waynesville, North Carolina, that was
once used as a bulk chemical mixing and packaging facility. A fire destroyed the facility in 1982.
Site investigations conducted after the fire identified soil and groundwater contamination. The
specified soil remedy included excavation, ex-situ physical and biological treatment, and on-site
backfill. For groundwater, the specified remedy was hydraulic containment and plume remediation
by groundwater extraction, with discharge of untreated groundwater to the Waynesville publicly
owned treatment works (POTW). The soil remedy was implemented between 1997 and 2000. The
groundwater extraction system began operating in April 2001. The extraction system was shut
down on June 1, 2007 and has not been restarted.
The optimization review completed in FY 2007 recommended consideration of MNA as the
groundwater remedy, additional source characterization, and possible implementation of ISCO in
the source area with ISEB for polishing. MNA was evaluated and additional site investigations
were conducted. These studies resulted in ISCO in combination with ISEB being selected in the
September 2015 ROD Amendment as the recommended remedy. EPA has stated that an
anticipated benefit of remediating the residual soil contamination is that the injected oxidant will
also destroy the contaminants that have already migrated into the groundwater. Therefore, it is
expected that with the successful treatment of this residual soil contamination, neither an active
groundwater remedy nor MNA will be necessary for this site. Additional sampling will be
conducted to confirm that metals analysis is no longer required.
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2.1.2 Cost Reduction
Optimization recommendations pertaining to cost reduction may cover many aspects of system
operation, including the use of specific treatment technologies, operator and laboratory labor,
reporting, and project management. More than 60 percent of optimization recommendations for cost
reduction have been implemented, are in progress, or are planned, and another 11 percent are still
under consideration (Figure 4). Only 18 percent of optimization recommendations in the cost
reduction category were declined.
Cost savings for this report were estimated as one-time cost savings or multiple year annual cost
savings. It should be noted that a short-term investment may be required to realize longer-term cost
savings. In addition, cost savings in the form of cost avoidance are often realized but are difficult to
quantify. Optimization reviews continue to identify many opportunities to reduce on-site labor without
affecting remedy performance. Such reductions may be possible following system shakedown, when
a remedy is designated as operational and functional. Furthermore, some treatment components
may become inefficient or unnecessary as a result of changing site conditions or overly conservative
estimates used during the design phase. Simplifying a treatment system under such conditions has
resulted in cost savings associated with reduced material costs, decreased energy usage, and
reduced labor cost for maintaining or improving remedy performance.
Figure 4: Cost Reduction Implementation Status
Total Number of Recommendations = 152
In Progress, 8, 5%
Planned, 13, 9%
Under
Consideration, 16,
11%
Deferred to State,
12, 8%
Implemented, 75,
49%
Declined, 28, 18%
Examples of cost reduction recommendations include the following:
¦ Automate systems to reduce labor costs.
¦ Streamline monitoring to reduce laboratory and reporting costs.
¦ Simplify treatment systems to reduce operating costs.
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Highlights 3 and 4 for State Road 114 Groundwater Plume and Wash King Laundry provide
examples of cost reduction recommendations.
Highlight 3: Cost Reduction
State Road 114 Groundwater Plume Site, Levelland, Texas
KEY CHALLENGES
¦ Groundwater system operates at high cost and high energy usage
¦ Significant amount of treated water is recaptured, increasing the volume
extracted
¦ On-site extraction wells pump less volume than designed because of significant
fouling issues
PRIMARY RECOMMENDATIONS
¦ Eliminate the use of cryogenic-cooling and compression (C3) units
¦ Streamline groundwater monitoring
¦ Eliminate the use of on-site extraction wells
¦ Consider use of passive methods to collect groundwater samples
IMPLEMENTATION OUTCOMES
¦ Eliminated C3 units for a savings of approximately $1.8 million/year
¦ Reduced monitoring by eliminating wells for a savings of $84,000/year
¦ Reduced rehabilitation costs by eliminating on-site extraction wells for a savings
of $91,500/year
¦ Significantly reduced environmental footprint (86-95 percent reduction)
¦ Reduced reporting costs by $24,000/year
The State Road 114 Groundwater Plume Superfund site is located west of the City of Levelland
in Hockley County, Texas. The site consists of a groundwater plume more than a mile long
primarily consisting of 1,2-dichloroethane and benzene contamination. The source of the
groundwater contamination is a former petroleum products refinery. The selected remedy
included a groundwater P&T system, air stripping and GAC units for off-gas treatment. A soil
vapor extraction (SVE) system is in place in the defined light non-aqueous phase liquid (LNAPL)
area. The C3 unit is used for compression, cooling and condensing vapors from the SVE system
to capture volatile organic compounds (VOCs) as NAPL.
The optimization review completed in FY 2014 confirmed the site team's suggestion to shut down
the shallow SVE system eliminating one of the C3 units. Other recommendations that were
implemented included treating the air-stripper off-gas with vapor GAC, eliminating the need for
the Munster concentrator and another of the C3 units, and replacing the remaining three C3 units
for treatment of the deep SVE vapors with a regenerative thermal oxidizer resulting in lower costs
and energy usage. Elimination of the C3 units reduced: (1) global warming potential footprint from
1,969 tons to 270 tons (86 percent reduction); (2) total energy use from 41,726 million British
thermal units (MMBtu) to 3,639 MMBtus (91 percent reduction); and (3) total nitrogen oxides,
sulfur oxides, and particulate matter emissions footprint from 35,965 pounds to 1,673 pounds (95
percent reduction). Strategic sampling is employed as recommended through the reduction of
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metals sampling, which allows for all VOC sampling at monitoring wells to be conducted with
passive diffusion bags, except for infrequent events where other sampling approaches can be
employed. Costs were further reduced by eliminating the need for rehabilitation of the extraction
wells taken out of service and decreasing reporting. Implementation of additional
recommendations is planned which will further reduce costs including reducing the level of effort
for the plant operator and operating with only one air stripper.
Highlight 4: Cost Reduction
Wash King Laundry Site, Pleasant Plains Township, Michigan
KEY CHALLENGES
¦ Reducing costs of operation of groundwater treatment system and monitoring
program
¦ Identifying additional source areas
PRIMARY RECOMMENDATIONS
¦ Consider modifying groundwater monitoring program; reduce or eliminate metals
analysis
¦ Discontinue pumping at extraction well EW-4
¦ Investigate sources in the lagoon area
IMPLEMENTATION OUTCOMES
¦ Reduced costs $30,000/year by modifying the groundwater monitoring program
¦ Discontinued pumping at EW-4
¦ Achieved progress on identifying sources in the lagoon area
The Wash King Laundry site is located south of the city of Baldwin in Pleasant Plains Township,
Lake County, Michigan. As part of the laundry operations/services, dry cleaning was conducted,
which included the use of the solvent tetrachloroethene (PCE). The optimization review completed
in FY 2011 focused on all aspects of site remediation including the P&T system, SVE system, in
situ bioremediation, and site-wide monitoring program.
On recommendation of the optimization review, pumping at extraction well EW-4 was
discontinued. Extraction well EW-1 appears to have successfully captured much of the
contamination that would migrate to EW-4, and the VOC concentrations at EW-4 and nearby
monitoring wells MW-301S and MW-301D are routinely below cleanup levels. In addition, as
recommended, the monitoring program was restructured to allow strategic sampling to fully track
the progress of the remediation while reducing the number of sampling locations and frequency
as appropriate. Progress has been made in identifying the additional source areas by conducting
additional investigation as recommended in the optimization review.
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2.1.3 Technical Improvement
Technical improvement recommendations cover a wide range of items to improve overall site
operations and usually relate to improving existing systems. These recommendations are generally
easy to implement, require minimal funding, and are not typically contingent on other
recommendations. More than 70 percent of optimization recommendations for technical
improvement have been implemented, are in progress, or are planned, and another 13 percent are
under consideration (Figure 5). Only 13 percent of optimization recommendations in the technical
improvement category were declined. Some recommendations for technical improvement were not
implemented because they addressed an existing component that was likely going to be changed
based on remedy effectiveness recommendations.
Examples of technical improvement recommendations include the following:
¦ Reconfigure components of the treatment train.
¦ Inspect and then clean, repair, or replace faulty equipment.
¦ Rehabilitate fouled extraction or injection wells.
¦ Consider more efficient pumps and blowers.
Highlights 5 and 6 for Sandy Beach Groundwater Plume and Gilt Edge Mine provide examples of
technical improvement recommendations.
Figure 5: Technical Improvement Implementation Status
Total Number of Recommendations = 158
Implemented, 77
49%
Planned, 17, 11%
Under
Consideration, 21,
13%
Deferred to State
Declined, 21, 13%
2, 1%
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Highlight 5: Technical Improvement
Sandy Beach Ground Water Plume Site, Pelican Bay, Texas
KEY CHALLENGES
¦ Multiple data gaps affecting the CSM and design of the source remedies
including:
o Uncertainty about materials remaining in the source area
o Distribution of TCE in shallow and saturated soils of varying porosity
o Impact of ISB treatments on water quality
o Effect of back-diffusion from low permeability deposits on the dissolved phase
plume
PRIMARY RECOMMENDATIONS
¦ Conduct additional ISB pilot test to evaluate effectiveness as a source area
remedy and secondary impacts to water quality
¦ Implement remedy performance monitoring
IMPLEMENTATION OUTCOMES
¦ ISB pilot test completed during the remedial design
¦ Implementation of ongoing remedy performance monitoring
The Sandy Beach Ground Water Plume Superfund site involves groundwater contamination with
TCE attributed to a former unpermitted landfill. The selected remedy included a groundwater P&T
system, installation of filtration units for affected residential wells or replacement with municipal
water supply connections, SVE, and ISB.
The optimization review completed in FY 2014 recommended prioritizing and sequencing
remedial activities, additional source characterization, an additional ISB pilot test, modifying the
scale and design of the P&T system to improve the efficacy of plume hydraulic control, and long-
term monitoring program to confirm control of the plume and the performance of aggressive
source remediation.
Remediation of the source area was prioritized and began in September 2015. Trenching and
sampling in the area of the site slated for SVE was conducted to determine if there was another
potential source in that area. Source area saturated zone soils were characterized using a
photoionization detector on rotosonic cores. The ISB pilot test was completed during the remedial
design and the full-scale implementation of ISB was scheduled to begin January 2016. Remedy
performance monitoring is ongoing and includes collection of vapor samples from individual SVE
wells, groundwater samples from SVE wells, and performance monitoring of the system.
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Highlight 6: Technical Improvement
Gilt Edge Mine Site, Northern Black Hills, South Dakota
~
KEY CHALLENGES
¦ High labor costs for monitoring Hoodoo Gulch Collection Facility
¦ Need alternatives for addressing high sulfate water
¦ Various minor issues related to source control such as uncaptured seeps
PRIMARY RECOMMENDATIONS
¦ Upgrade the Hoodoo Gulch Collection Facility
¦ Operate the water treatment plant (WTP) in batch mode to reduce staffing and
vehicle leases
¦ Implement minor WTP changes:
o Consider feeding lime only at one location to simplify the control of the WTP and
to optimize lime dosing
o Install orifice plates in the influent lines to each filter to control rates
o Install a backup filter feed pump
¦ Implement planned Operable Unit (OU) 01 source control remedy to address
other challenges after upgrade to Hoodoo Gulch Facility
¦ Communication and remote monitoring systems are being added to Hoodoo
Gulch
¦ Automation upgrades are in process
¦ Modified WTP flow rate for more effective removal of sulfate in clarifier
¦ Installed the backup filter feed pump and upgraded filter valves to prepare for au-
tomated operation
Mining activities at the Gilt Edge Mine resulted in the contamination of surface water, groundwater,
soil and sediment at the site. The surface water and groundwater remedy consists of the WTP,
which treats acid rock drainage collected at the site. The selected remedy in the 2001 Interim
Record of Decision (ROD) for OU 02 included collecting and conveying the acid rock drainage
seep and surface water flow to the WTP, and treating acid rock drainage at the WTP with a lime-
based precipitation process. An additional purpose of the Interim ROD actions was to reduce WTP
operating costs.
The optimization review completed in FY 2013 recommended the consideration of alternative
treatment options for the remaining high-sulfate acid rock drainage, upgrading the Hoodoo Gulch
collection facility and other collection and WTP facilities prior to implementation of the OU 01
remedy, reducing the labor force, eliminating overnight staffing and operating the WTP in batch
mode, implementing minor WTP changes and not rebuilding or relocating the WTP. The
optimization review triggered modifications to the WTP flow rate which allowed for the more
effective removal of sulfate in the clarifier. The backup filter feed pump and upgraded filter valves
were installed to prepare for automated operation. Automation upgrades at the WTP are in
progress, which will allow for the elimination of nighttime staffing, while still allowing the WTP to
run full-time during wet years and run in batch mode during dry periods.
IMPLEMENTATION OUTCOMES
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2.1.4 Site Closure
Optimization reviews continue to identify opportunities to accelerate progress toward achieving final
cleanup goals and eventual site completion or closure. These recommendations most commonly
involve developing a clear and comprehensive completion strategy and evaluating changes in the
remedial approach in situations where the current remedy may no longer be the most effective
approach. Nearly 60 percent of optimization recommendations for site closure have been
implemented, are in progress, or are planned, and another 22 percent are still under consideration
(Figure 6). Only 13 percent of optimization recommendations in the site closure category were
declined.
Figure 6: Site Closure Recommendation Implementation Status
Total Number of Recommendations = 107
Planned, 14, 13%
Implemented, 30
28%
Under
Consideration, 24,
22%
Undefined, 1, 1%
Deferred to State,
Declined, 14, 13% 7 7o/
When considering site closure for groundwater sites, EPA's Groundwater Remedy Completion
Strategy (EPA, 2014) and related guidance documents provide an approach and statistical tool for
assessing when monitoring results indicate that cleanup levels are achieved and aquifer restoration
is accomplished. A completion strategy "...is a recommended site-specific course of actions and
decision-making processes to achieve groundwater RAOs and associated cleanup levels using an
updated conceptual site model, performance metrics and data derived from site-specific remedy
evaluations" (EPA, 2014). Using the completion strategy decision-making process will allow for the
assessment of remedial performance and evaluation of whether a remedial action is working as
anticipated or if the remedy selected in the decision document may need to be modified to achieve
RAOs and associated cleanup levels. Such modifications have often included addressing additional
source material or residual subsurface contamination.
Examples of site closure recommendations include the following:
¦ Further characterization of sources.
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Superfund Optimization Progress Report 2011-2015
¦ Targeted treatment of remaining sources.
¦ Development of an exit strategy including performance metrics for determining achievement
of RAOs.
Highlight 7 for Groveland Wells No. 1 & 2 provides an example of site closure recommendations.
Highlight 7: Site Closure
Groveland Wells No. 1 & 2 Site, Groveland, Massachusetts
KEY CHALLENGES
¦ Subsurface contamination difficult to remediate with P&T and SVE
¦ P&T would be required for a long period of time if subsurface source material
remains untreated
PRIMARY RECOMMENDATIONS
¦ Additional characterization of sources and groundwater
¦ More aggressive treatment of sources
¦ Close monitoring of groundwater P&T system after source treatment
¦ Develop P&T shutdown and restart criteria
IMPLEMENTATION OUTCOMES
In situ thermal (1ST) remedy implemented in subsurface source area
P&T system monitored monthly for one year after 1ST implementation
Shutdown and restart criteria developed for P&T system
Increased groundwater monitoring demonstrated no rebound of TCE
P&T system shut down in April 2014 and restart criteria have not been exceeded
to date
Municipal supply wells in Groveland were contaminated by TCE in the late 1970s. The
contamination was attributed to nearby Valley Manufactured Products. The PRP implemented an
interim P&T remedy and used SVE in the source area from 1992-2002, which was unsuccessful.
The PRP subsequently filed for bankruptcy and the site became a Fund-lead project. EPA and
the State of Massachusetts operated the P&T system until 2014.
Several optimization reviews were conducted for the site. An optimization review conducted in
2002 led to additional source investigations, pilot testing, and a feasibility study (FS) which
ultimately led to the selection and implementation of 1ST from 2010-2011 in the source area. An
additional optimization review was conducted in 2012 before the P&T system was transferred to
the state. The FY 2013 review recommended more frequent monitoring of the P&T system
performance and monitoring network for one year to fully evaluate the impact of 1ST. An
optimization review in FY 2014 recommended the development of P&T shutdown and restart
criteria based on the effectiveness of 1ST and those recommendations were adopted. The P&T
system was shut down in 2014 based on the shutdown criteria. The restart criteria have not been
exceeded since the system was shut down.
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2.1.5 Green Remediation
Optimization reviews continue to identify opportunities to accelerate progress toward achieving
green remediation and reductions in environmental footprints. Over 50 percent of optimization
recommendations for green remediation have been implemented, are in progress, or are planned,
and another 16 percent are still under consideration (Figure 7). A total of 25 percent of optimization
recommendations in the green remediation category were declined.
It should be noted that recommendations for other optimization categories—remedy effectiveness,
cost reduction, and technical improvement—often include opportunities for reductions in
environmental footprint. EPA is also conducting environmental footprint analyses during the design-
phase as technical support projects (see Section 2.4) to identify green remediation best
management practices and to ensure remedy components are right-sized when implemented.
Figure 7: Green Remediation Recommendation Implementation Status
Total Number of Recommendations = 32
Planned, 7, 22%
Implemented, 7
22%
Under
Consideration, 5
16%
Undefined, 1, 3%
Deferred to State,
1, 3%
Declined, 8, 25%
Examples of green remediation recommendations include the following:
¦ Utilize local labor for site management and sampling to avoid air emissions associated with
travel.
¦ Consider opportunities for renewable energy such as solar, wind, or renewable energy
credits.
¦ Streamline the treatment train.
¦ Downsize pumps and blowers.
Highlight 8 for Pemaco Maywood provides an example of green remediation recommendations.
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Highlight 8: Green Remediation
Pemaco Maywood Site, Maywood, California
KEY CHALLENGES
¦ Modify remediation system now that significant mass reduction has occurred to
address operational costs and energy use
PRIMARY RECOMMENDATIONS
¦ Reduce groundwater monitoring
¦ Shut down 6 of 8 dual phase extraction and SVE wells
¦ Remove one blower and replace other blower with a regenerative blower
¦ Remove the cooling tower, water softener, and water pressure booster
IMPLEMENTATION OUTCOMES
¦ Reduced electricity usage by reducing the operation of the system to one blower
and by installing a variable frequency drive on the operating blower to reduce
power consumption
¦ Reused equipment taken off-line for other projects and sold some equipment
¦ Reduced costs from $58,000/month to $25,000/month by modifying the
groundwater monitoring program
The Pemaco Maywood site operated as a chemical blending and distribution facility from the late
1940s until June 1991. The site soils and groundwater were impacted by aromatic and chlorinated
solvents, flammable liquids, specialty chemicals, and oils used and stored at the site. Hot spot
removal and soil capping was conducted. A SVE, high-vacuum dual-phase extraction, and a
groundwater extraction system were still in operation at the time of the optimization. Electric
resistive heating had been conducted between September 2007 and April 2008.
All recommendations from the FY 2011 optimization review were implemented resulting in a
reduced environmental footprint for the remediation system. The smaller environmental footprint
resulted from reductions in electricity usage and air emissions by shutting down SVE wells and a
blower, removing equipment, and fitting the operating blower with a variable frequency drive;
reductions in energy use and air emissions associated with laboratory analysis from a decrease
in groundwater and process monitoring; and reductions in fuel usage and air emissions from a
decrease in operator labor and the number of visits per week.
2.1.6 Tools and Techniques Leading to Beneficial Outcomes
EPA conducted a more detailed analysis of the various tools and techniques included in optimization
recommendations and of the beneficial outcomes achieved by implementing them. The tools and
techniques identified by EPA, were grouped into seven categories as described in Table 4, with
references to highlights that provide examples of sites where those tools and techniques are being
implemented. These tools and techniques may be used separately; however, many are inter-related
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and are often used together. The outcomes from the tools and techniques include improving remedy
effectiveness, reducing costs, adding technical improvements to the remedy, accelerating the
progress to site closure, and reducing the environmental footprint of remediation and operations.
Table 4: Recommended Tools and Techniques Leading to Beneficial Outcomes
Recommended
Tools and
Highlight
Techniques
Description
References
Use of Strategic
Sampling
Approaches
CSM
Improvements
Improved Data
Management
Improved System
Engineering
Change in
Remedial
Approach
Use of Combined
Remedies
Streamlined or
Improved
Monitoring
Specific strategic sampling approaches apply to several types of
characterization activities conducted on various environmental
media and help improve the technical understanding of site
conditions. These approaches include high-resolution site
characterization for groundwater and incremental sampling for
contaminated soil for improved characterization of source
volumes and locations. Strategic sampling approaches can often
lead to other beneficial results such as CSM improvements, the
use of combined remedies, and right-sizing remedies.
Improving the CSM can be achieved through additional
characterization of sources and environmental media, such as
groundwater, or by analyzing existing data with new tools, such as
3-dimensional visualization and analysis (3DVA). CSM
improvements are best achieved through smart scoping and the
use of strategic sampling approaches and incorporate improved
data management.
Aspects of improved data management include improving data
management planning, data acquisition, data processing, data
analysis (using 3DVA), data preservation and storage, and data
publication and sharing.
Improved system engineering includes modifying one or more
engineered components of a remedial system to improve overall
system performance. Improved system engineering can include
right-sizing remedies which involves using a more targeted
approach that applies technologies to a specific and well-defined
area. Smart scoping, strategic sampling approaches, CSM
improvement, and improved data management can facilitate right-
sizing remedies.
Changes in remedial approach include adding or changing
remedies to better address remaining contamination or newly
identified areas of contamination. The recommendations provide
improvements in remedy effectiveness, cost reductions, and the
achievement of site closure in a shorter period of time.
Combined remedies include the concurrent use of more than one
technology for different portions of contaminated media and the
use of multiple technologies to address contaminated media at
different points in time. Smart scoping, strategic sampling
approaches, CSM improvements, and improved data
management can facilitate the use of combined remedies.
Streamlined or improved monitoring involves adjustments to
monitoring frequency, monitoring locations, chemicals of concern
analyzed, as well as the analysis of monitoring results overtime.
Streamlined or improved monitoring also addresses data
management practices.
1, 9, 18, 21
1, 2, 4, 5, 7, 9,
10, 11, 12, 14,
15, 16, 19, 20,
21
1, 21
3, 6, 8, 10, 11,
19
1, 2, 4, 5, 7, 10,
13, 14, 15, 16,
19, 20
1, 7, 12, 13, 19
1, 2, 3, 4, 5,
14, 17, 18
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Figure 8 presents the number and percentage of events that implemented one or more of the tools
and techniques by category. The categories that were implemented for the largest number of
optimization events include: (1) CSM improvements, (2) streamlined or improved monitoring, (3)
improved system engineering, and (4) change in remedial approach. As mentioned above, these
tools and techniques may be used separately or in combination at a site.
Figure 8: Number of Implemented Tools and Techniques
Total Number of Optimization Events = 80
60
54
50
48
C
(D
>
LU
C
o
CU
M
£
Q.
o
CD
-Q
£
3
40
30
20
10
CSM Streamlined or Improved
Improvements Improved System
Monitoring Engineering
Change in
Remedial
Approach
13
12
16%
15%
6
Use of Improved Data Use of
Strategic Management Combined
Sampling Remedies
2.2 Recommendations by Optimization Focus
In addition to the five optimization categories based on overall outcome of the effort,
recommendations can also be classified by optimization focus—investigation, design, remedy and
long-term monitoring. To better understand the common findings and outcomes of optimization
reviews and communicate lessons learned, EPA discusses recommendation implementation by
these optimization focus areas in Sections 2.2.1 through 2.2.4. While the focus areas are related to
the phases of the Superfund pipeline, an optimization focus may not align exactly with the Superfund
pipeline. For example, an LTM-focused optimization may be done during the remedy phase of the
Superfund pipeline to prepare for LTM.
2.2.1 Investigation Recommendations
An investigation-focused optimization involves translating the site data gaps and uncertainties into a
sampling strategy with the goal of refining the CSM to allow for remedy selection. Accordingly, the
investigation optimization review examines the collection of the data necessary to understand
exposure pathways, exposure point concentrations for site receptors and information to aid the
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evaluation and selection of potential remedies, and to the extent possible, the design data
requirements of likely site remedies. An effective investigation optimization review considers the
regulatory framework of the project, human and ecologic exposure points, potential RAOs, the
perspectives of the various site stakeholders, and the available site-specific technical information.
Investigation best practices are emphasized in the optimization review to ensure that an effective,
efficient characterization is performed. Investigation optimization reviews can be conducted during
any phase of the Superfund pipeline whenever additional site characterization activities may be
necessary. The remedial design phase of the Superfund pipeline frequently involves site
characterization activities to accurately estimate treatment and disposal volumes and to delineate a
more accurate footprint for the application of various in situ technologies. The remedial action and
long-term response action (LTRA) phases of the Superfund pipeline can also involve site
characterization to reconcile data gaps in the CSM that are indicated by performance issues with the
constructed remedy. For example, a groundwater remedy that is not performing as expected (that is
not reducing contaminant concentrations in the groundwater as predicted) may be an indication of
an undiscovered source of contamination and additional characterization may be required to
determine if other source areas exist.
Remedy effectiveness was the main category of recommendation made for investigation
optimizations, followed by technical improvement and site closure (Table 5). The fewest number of
recommendations were made for cost reduction and green remediation.
Table 5: Types of Investigation Recommendations
Types of Recommendations
Total
Remedy Effectiveness
64
Cost Reduction
14
Technical Improvement
36
Site Closure
32
Green Remediation
4
All Recommendation Types
150
At the Black Butte Mine site (Highlight 9), an optimization review of the remedial investigation was
conducted after a removal action. The optimization review team first identified data gaps and missing
components of the CSM of this large site with a long history of mercury mining. They leveraged
existing data to complete the CSM and identify area-specific data gaps to address numerous study
questions. To maximize information and resources, the optimization team recommended sequenced
field investigations that utilized real-time measurement technologies and incremental sampling. The
decision logic for sequencing field activities was developed as part of the optimization.
Investigation optimizations may also help distinguish the most effective combination of remedial
actions. At the Sulphur Bank Mercury Mine site (Highlight 10), a FS contained alternatives that
involved either long-term P&T or short-term P&T in conjunction with the replacement of an existing
waste rock dam. The state and EPA each favored different alternatives as the preferred approach.
The optimization review team recommended a hybrid of the two alternatives that included
components of both the EPA and state's preferences. The team utilized investigation data to provide
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an innovative approach to the site by using a slurry wall and subaqueous cap in combination with a
permeable treatment conduit within the waste rock dam. Both the EPA and state have agreed to
consider this hybrid alternative and plan to propose it as the preferred remedy. The Sulphur Bank
Mercury Mine site, conducted as part of the mining site optimization pilot, demonstrates how an
optimization review can help develop effective and lower cost actions for MIW management.
Highlight 9: Investigation Recommendations
Black Butte Mine Site, Lane County, Oregon
KEY CHALLENGES
¦ Incomplete CSM
¦ Numerous data gaps
¦ Large site with long history of mercury mining
PRIMARY RECOMMENDATIONS
¦ Identify data gaps for specific areas to streamline study questions
¦ Sequence activities focusing on source control first
¦ Use real-time measurement technologies and incremental sampling
¦ Conduct strategic sampling for storm/non-storm events, groundwater—surface
water interactions, and mercury methylation rates
IMPLEMENTATION OUTCOMES
¦ Leveraged existing data to build CSM
¦ Identified data gaps for each area to focus study
¦ Developed decision logic for conducting sequenced activities
The Black Butte Mine site contains numerous on-site sources that affect nearby surface water
bodies that eventually lead to the Cottage Grove Reservoir located 10 miles downstream from the
site. Contaminants include dissolved and particulate mercury, which is converted to
methylmercury in the reservoir, resulting in high levels of mercury in fish tissue and potential
ecological and human health exposures. A removal action was conducted at the site and the
optimization review was conducted to assist with planning of the remedial investigation.
The optimization review team used existing data to identify important data gaps for the specific
areas throughout the mine and for surface water bodies leading from the mine to the reservoir
downstream. The data gaps were then used to prioritize and identify data collection activities to
be conducted in sequence, with continuing mercury sources to be addressed first. Decision logic
for conducting the sequence of investigation activities was developed. The recommended use of
real-time measurement technologies and, when appropriate, incremental sampling design was
implemented. In addition, the site team implemented real-time measurement technologies,
strategic sampling for storm/n on-storm events, groundwater-surface water interactions, and
mercury methylation rates in reservoir sediments and the water column.
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Highlight 10: Investigation Recommendations
Sulphur Bank Mercury Mine Site, Clear Lake, California
KEY CHALLENGES
¦ Large site with long history of sulfur and mercury mining
¦ Draft FS contained alternatives that required either long-term surface water
management or extensive replacement of existing waste rock dam to
protect Clear Lake from contaminated water in Herman Impoundment
¦ EPA and the state favored different alternatives as the potential preferred
alternative
PRIMARY RECOMMENDATIONS
¦ Consider hybrid alternative that:
o Includes aspects of the EPA- and state-favored alternatives for mine waste and
mining influenced water management
o Eliminates P&T of Herman Impoundment by using innovative isolation
techniques and treatment technologies
IMPLEMENTATION OUTCOMES
¦ Steps being taken to fully evaluate a hybrid alternative in a focused feasibility
study (FFS)
¦ Hybrid alternative satisfies both EPA and state objectives while eliminating
perpetual P&T of Herman Impoundment and extensive replacement of waste
rock dam
The Sulphur Bank Mercury Mine site operated as a sulfur mine and then as a mercury mine from
1856 to 1957. Open pit mercury mining left a large flooded open pit, called the Herman
Impoundment, which is filled with contaminated water that leaches mercury into nearby Clear
Lake. In addition, there are 2 million cubic yards of mine wastes and tailings on the site.
EPA completed a FS for OU 01 that addressed Herman Impoundment and mining wastes and
tailings. However, EPA and the state both identified concerns with the alternatives analyzed for
OU 01. EPA identified concerns related to the potential for mercury leaching into Clear Lake, and
preferred to include long-term P&T of Herman Impoundment to lower the level. The state raised
concerns over the feasibility of long-term P&T and preferred to include short-term P&T of Herman
Impoundment and extensive replacement of the existing waste rock dam. The optimization review
team proposed a hybrid alternative that includes elements of the EPA and state's preferences for
the mine wastes and tailings and that provides an innovative approach to Herman Impoundment
by using isolation techniques (slurry wall on the impoundment side and subaqueous cap on the
Clear Lake side of waste rock dam) in combination with a permeable treatment conduit within the
waste rock dam. EPA and the state have agreed to consider the hybrid alternative in a FFS and
will use a comparative analysis to propose a preferred alternative that incorporates components
of the optimization review.
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2.2.2 Design Recommendations
A design-focused optimization is typically conducted before completion of the design of the selected
remedy. The design generally involves developing specific performance objectives, outlining a clear
remedial strategy, developing the technical specifications of a remedy, preparing a monitoring
program to monitor the effectiveness of the remedy, and formulating an effective remedy completion
strategy. Optimization during pre-design, design or redesign evaluates the selected remedy prior to
implementation and operation. It considers the goals of the remedy, CSM, available site data,
performance considerations, effectiveness, cost-effectiveness and closure strategy. Design
optimization reviews may add greater certainty to the selected remedy and ensure streamlined
operations from the start of the project. An effective design optimization review should also address
costs for implementation and long-term operation, maintenance and monitoring, including designing
and implementing a remedy in phases, and allowing additional information from initial phases to
guide later phases of design.
Remedy effectiveness is the main type of recommendation in the design stage, followed by site
closure, technical improvement, and cost reduction (Table 6). Although green remediation had the
fewest recommendations, they are most frequently made during design and remedy-focused
optimizations. Green remediation and environmental footprint evaluations are also done as technical
support efforts (see Section 2.4) rather than optimization reviews.
Table 6: Types of Design Recommendations
Types of Recommendations
Total
Remedy Effectiveness
73
Cost Reduction
27
Technical Improvement
38
Site Closure
39
Green Remediation
15
All Recommendation Types
192
Design optimizations are often requested when uncertainties exist surrounding the CSM and
characterization of contamination at a site. For the Lockwood Solvent Ground Water Plume site, OU
02 (Highlight 11), the optimization review included several recommendations for additional site
characterization activities to reduce source and plume uncertainties. As a result of implementing the
optimization team's recommendations, source remediation was expanded to more fully address all
subsurface sources and the groundwater plume morphology was characterized. At the Jones Road
Ground Water Plume site (Highlight 12), vapor intrusion impacts were not fully characterized and
contamination in the unsaturated zone was not fully identified. The optimization review
recommended further refining the CSM and developing a vapor intrusion indoor air sampling
program. At the East 67th Street Ground Water Plume site (Highlight 13), there were uncertainties
regarding the response of the mass contamination to SVE, extent of dissolved contamination in the
aquifer, and time required for restoration. The optimization review recommended pilot testing the
SVE system and prioritizing the remediation of one aquifer at the site. The optimization also
recommended using the extracted groundwater for ISB substrate blending and delivery.
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Concerns regarding planned remedy performance, effectiveness or cost are other reasons to
conduct a design-stage optimization review. At the Jones Road Ground Water Plume site, there was
concern that the selected remedy of an extensive P&T system may not provide an optimal approach
to address contamination at the site. The optimization review team recommended further refining the
CSM through delineation of the shallow groundwater plume and initiating ISB in high-concentration
areas of the plume. Now the shallow groundwater plume has been fully delineated and there is a
plan in place to scale up the use of ISB for source areas and the downgradient plume if the source
remedy alone does not adequately address the plume. In addition, the review recommended the
development and support of electronic data management and visualization tools to document and
communicate remedy performance more rapidly and effectively.
Design optimization reviews may also recommend implementing the site remedy in phases as a
method of improving remedy effectiveness. At the Lockwood Solvent Ground Water Plume site OU
02 (Highlight 11), a phased approach to the remedial components was implemented and aggressive
action on the plume was delayed to first assess the impacts of source remediation on groundwater.
The optimization review may also make suggestions for technical improvements and identify
alternative strategies or technologies for implementing a selected remedy, such as carefully
designed injection wells instead of using direct-push technology for injections, pre-fabricated
systems instead of on-site construction of the systems, treatment and reinjection instead of
discharge to a POTW, and use of extracted groundwater instead of potable water for reagent
blending, injection, and circulation to improve remedy effectiveness and reduce costs (Highlight 13,
East 67th Street Ground Water Plume site).
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Highlight 11: Design Recommendations
Lockwood Solvent Ground Water Plume Site OU 02, Billings, Montana
KEY CHALLENGES
¦ Source uncertainties—identification of all source areas, vertical contaminant
distribution, soil heterogeneity
¦ Plume uncertainties—long well screens confound vertical characterization, effect
of pumping wells to west, effect of sewer installation, impact of source
remediation on dissolved plume
¦ Rotosonic drilling to obtain cores and develop cross-sections
¦ New nested wells with short well screens
¦ Monitor downgradient plume for stability
¦ Use Membrane Interface Probe to delineate shallow sources in fine-grained zone
and guide excavation of shallow sources
¦ Source areas delineated and source excavation expanded to address mass
stored in fine-grained zone
¦ Dissolved plume delineated
o Identified plume morphology
o Monitoring being conducted to determine effects of source removal on
groundwater plume before aggressive action on the plume
The Lockwood Solvent Ground Water Plume site consists of two operable units. OU 01 and OU
02 address separate contaminant sources and associated groundwater plumes. OU 02
contaminants of concern include PCE, TCE, cis-1,2-dichloroethene (cis-1,2 DCE) and vinyl
chloride. The selected remedy for OU 02 includes a number of source and groundwater treatment
options. The optimization review was conducted while the OU 02 remedy was being designed
and focused on remedy design considerations. The optimization review included
recommendations for designing a remedy to address contamination in soil and groundwater to
achieve maximum effectiveness while improving remedy cost and energy efficiency and
minimizing the time required to achieve cleanup goals.
The optimization review recommended reducing CSM uncertainties associated with OU 02
sources and the OU 02 plume. Recommendations for additional characterization work included:
(1) more thorough identification of the source contaminant footprints, (2) obtaining a vertical profile
of contaminant distribution in the subsurface especially at it relates to soil heterogeneity, (3)
identifying plume morphology, (4) assessing impact of pumping wells and sewer installation, and
(5) understanding how source remediation may impact groundwater contamination. The
optimization review recommendations were implemented and additional characterization of both
sources and groundwater was conducted. Source remediation was expanded to more fully
address all subsurface sources and the groundwater plume morphology was characterized.
Action on the plume delineation was delayed to determine the impact of more thorough source
remediation made possible by the additional source characterization work.
PRIMARY RECOMMENDATIONS
IMPLEMENTATION OUTCOMES
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Highlight 12: Design Recommendations
Jones Road Ground Water Plume Site, Harris County, Texas
KEY CHALLENGES
¦ Selected remedy of extensive P&T system may not provide an optimal approach
to address site groundwater contamination
¦ Vapor intrusion impacts not fully characterized
¦ Unsaturated zone contamination not fully identified
PRIMARY RECOMMENDATIONS
¦ Install SVE system in the Unsaturated Chicot sand unit (to be initiated by a ROD
Amendment)
¦ Perform SVE pilot for the shallow soil and, if successful, install a full SVE system
in the shallow soil to address the primary source of contaminant mass
¦ Develop an indoor air sampling protocol to assess vapor intrusion
¦ Initiate ISB in high-concentration areas of shallow water bearing zone (WBZ)
¦ Limited groundwater P&T system is recommended for the Lower Chicot and
possibly the shallow WBZ near the source area to control plume migration only
after the SVE and ISB systems have been operating for the time necessary to
evaluate the effectiveness of source reduction on groundwater
¦ Use electronic data management and visualization tools for documentation
IMPLEMENTATION OUTCOMES
¦ Delineated shallow groundwater plume
¦ Installed nested wells to delineate contamination vertically
¦ Plan to scale up use of ISB for source and downgradient plume if source remedy
alone does not adequately address the plume
The Jones Road Ground Water Plume Superfund site is located just outside of the city limits of
Houston, Texas. Releases of chlorinated VOCs from improper disposal of dry cleaning solvents
migrated downward through the unsaturated zone to perched water and to lower aquifers, where
multiple private water supply wells were and are presently located. The remedy selected in the
ROD includes an extensive groundwater extraction and treatment system and extending
municipal water supplies to properties with affected private water supply wells. Subsequent site
data collection and cost estimates indicated that the P&T system may not provide an optimal
approach to address site contamination. The optimization review team recommended the site
remedial design include aggressive source treatment to reduce or eliminate the need for P&T and
reduce or eliminate mass discharge to the aquifer.
The optimization review completed in FY 2014 provided recommendations for further refining the
CSM and treating the contaminant source. The shallow WBZ plume has now been fully delineated
and ISB treatment of the shallow WBZ is underway. The groundwater sampling in the Lower
Chicot WBZ is being conducted at the existing wells to establish a baseline prior to potential
source treatment with SVE. The optimization review recommended the use of electronic data
management and visualization tools to document and communicate remedy performance more
rapidly and effectively; these improvements are also already underway.
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Highlight 13: Design Recommendations
East 67th Street Ground Water Plume Site, Odessa, Texas
KEY CHALLENGES
¦ Several data gaps were identified in the CSM relevant to remedial design,
including:
o Quantity of mass remaining in the vadose zone soils and its potential response
to SVE treatment
o Extent of dissolved contamination in the US2 plume
o Potential effect of active ISB on secondary water quality issues
o Extent of contaminant migration and time frame for aquifer restoration
PRIMARY RECOMMENDATIONS
¦ Eliminate exposure pathways and vertical migration by replacing specific private
water supply wells that may function as conduits to the lower sand number 1
(LS1) layer of the Trinity Sands
¦ Improve plume monitoring by installing new groundwater monitoring wells
¦ Increase priority of US2 ISB remedy
¦ Use extracted groundwater for ISB substrate blending and delivery
¦ Conduct small-scale SVE pilot test in source area to improve characterization of
contaminant mass remaining in the vadose
¦ Evaluate the need for active remediation in LS1 after plugging supply wells that
appear to be contaminant transport conduits to the lower unit
¦ Implement remedy performance monitoring
¦ Establish completion criteria for each remedy component
IMPLEMENTATION OUTCOMES
¦ Extracted groundwater is used for ISB substrate blending
¦ Two ISB treatment zones were installed in the US2 aquifer zone
¦ SVE pilot test is planned for the next remedial design
The East 67th Street Ground Water Plume Superfund site involves groundwater contamination
resulting from a 1985 release of alcohols, naphtha-based solvents and PCE from above ground
tanks. The primary contaminants of concern are PCE, TCE and cis-1,2 DCE. The selected remedy
included a groundwater P&T system, the installation of a municipal water supply line, ISB
treatment zones, SVE, well abandonment, and institutional controls.
The optimization review completed in FY 2014 recommended plugging, abandoning and replacing
key water supply wells, installing additional monitoring wells in US2 and LS1, increasing the
priority of the US2 ISB remedy, using extracted groundwater for ISB substrate blending and
delivery, conducting a small-scale SVE pilot test in the source area, implementing remedy
performance monitoring, and establishing exit criteria for each remedy component. The
optimization review also recommended evaluating LS1 after well plugging and US2 remediation
to determine the need for active remediation of LS1. Use of ISB was expanded, extracted
groundwater is used for ISB substrate blending, and an SVE pilot test is planned. Monitoring of
remedy performance and develop completion criteria for each remedy component is also planned.
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2.2.3 Remedy Recommendations
Remedy-focused optimization reviews include recommendations for reducing costs and improving
the operation of the engineered systems that are in place. Remedy optimization is still the most
frequent type of optimization review, and is conducted on remedies that have been constructed and
are currently operating. During the remedy phase of the Superfund pipeline, new information may
become available and site conditions may change as additional data is collected in the course of
operating the remedy. Remedies can be adjusted over time to adapt to this new information and
these changing conditions. As a result, it is helpful to review progress towards RAOs specified in the
site decision documents, performance objectives specified during design, overall remedial strategy,
current conditions relative to original design assumptions, and the monitoring program. An effective
remedy optimization review considers the regulatory framework of the project, the RAOs, the
perspectives of the various site stakeholders, and the available site-specific technical information.
Reviews should also address costs for implementation and long-term operation, maintenance and
monitoring.
Remedy optimization reviews may identify the need for changes to the remedial strategy. At North
Penn - Area 6 site (Highlight 14), additional areas of contamination in the unsaturated zone would
not be addressed by the current P&T system used for the deeper groundwater contamination. SVE
and zero-valent iron (ZVI) injections were tested as treatment options for the newly discovered areas
of contamination.
Many of the remedy optimization events were conducted at sites with remedy components common
in the 1980s, 1990s, and early 2000s such as P&T and SVE systems. Many of the sites also noted
the presence of NAPL. More than 40 percent of optimization events in this report provided
recommendations that would change remedial approaches in response to the optimization review
and in some of those cases adopted remedy components for more aggressive source treatment and
in situ treatment of groundwater contamination as a replacement for or a supplement to existing P&T
systems. This is consistent with more recent trends showing that in situ remedies for groundwater, in
combination with targeted P&T, are being selected with increasing frequency (EPA, 2013b). When
remedy changes are recommended by the optimization team, and accepted by the site team, the
team must follow all Superfund procedures for remedy selection in a decision document, ultimately
issuing a ROD Amendment or Explanation of Significant Difference if necessary. The additional data
gathered and evaluated as a result of the optimization recommendations and CSM refinement help
provide the basis for the remedy decision. In this way, optimizations may inform decision documents.
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Remedy effectiveness is the main type of recommendation in the remedy-focused optimization
reviews, followed by cost reduction and technical improvement, with site closure and green
remediation having the fewest recommendations (Table 7).
Table 7: Types of Remedy Recommendations
Types of Recommendations
Total
Remedy Effectiveness
177
Cost Reduction
118
Technical Improvement
101
Site Closure
52
Green Remediation
15
All Recommendation Types
463
A remedy optimization review evaluates existing remedial systems and will also assess the
completeness of the CSM and the completion strategy for the site. The need forCSM improvements
are usually indicated when existing remedial systems are not meeting performance goals or
progressing towards achieving cleanup levels as expected. At North Penn - Area 6 site (Highlight
14), the optimization team identified the need forCSM improvements to identify additional source
areas and fully delineate the groundwater plumes. Optimization recommendations were
implemented; the additional characterization work identified significant source zones in the
unsaturated zone and both the shallow and deeper plumes were fully delineated. At the Palermo
Well Field Ground Water Contamination site (Highlight 15), additional sampling was required to
define and delineate the plumes. It was recommended that the sampling results be used to inform
the capture zone analysis.
At Palermo, improvements to the P&T system, French drain system, and water sampling scheme
were suggested. Remedy optimizations may also include new strategies for improved effectiveness
such as the implemented changes to the structure of the project team by engaging Tribal Nations at
Tar Creek (Ottawa County), OU 04 (Highlight 16). Full engagement by all stakeholders can save
time, money and ensure that all concerns at the site are addressed. Also at Tar Creek, the
optimization improved the effectiveness of the remedy by shifting the focus to prioritize activities
based on contaminant of concern (COC) loading rates, improving watershed remediation, and
protection.
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Highlight 14: Remedy Recommendations
North Penn - Area 6 Site, Landsdale, Pennsylvania
KEY CHALLENGES
¦ Large PCE and TCE plume with many sources
¦ Complicated hydrogeology—weathered and fractured bedrock
¦ CSM uncertainties—sources, shallow groundwater contamination, hydraulic
information
¦ Remedy effectiveness concerns—potential contaminant mass in unsaturated
zone and in shallow groundwater that is not addressed by P&T in deeper
groundwater, uncertainty regarding capture zone of P&T system, vapor intrusion
potential
PRIMARY RECOMMENDATIONS
Additional source characterization beneath previous excavations and buildings
Additional shallow groundwater characterization
Further delineation of groundwater plumes
Test efficacy of SVE for shallow sources and potential expansion of SVE
Investigate vapor intrusion pathway
IMPLEMENTATION OUTCOMES
Source characterization conducted and significant unsaturated zone
contamination found in several areas and confirmed to be absent in other areas
Shallow groundwater contamination characterized and groundwater plumes
better delineated
SVE and ZVI injections tested—SVE difficult because of geology, ZVI injections
hold promise of reducing subsurface contamination
Synoptic water level measurements conducted
Vapor intrusion pathway evaluated
The North Penn - Area 6 site addresses multiple sources of contamination by PCE, TCE, and
their breakdown products. The sources have resulted in a large contaminant plume within
shallow and deeper bedrock units beneath large portions of Lansdale, Pennsylvania. The
optimization review focused on five source areas being addressed by EPA with P&T systems.
Previous actions included excavation of contaminant sources. The optimization review identified
several uncertainties and recommendations were provided to reduce the uncertainty associated
with remaining contaminant sources, shallow groundwater contamination, and effectiveness of
the deeper groundwater P&T systems.
Optimization recommendations were implemented and the additional characterization work
identified significant source zones in the unsaturated zone and confirmed that sources were
absent in other areas. Both the shallow and deeper groundwater contamination was further
delineated and ZVI injections are being tested to reduce subsurface contamination. In addition,
the vapor intrusion pathway is being evaluated.
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Highlight 15: Remedy Recommendations
Palermo Well Field Ground Water Contamination Site, Palermo, Washington
KEY CHALLENGES
¦ CSM issues—limited TCE plume resolution and connection to source areas,
plume not delineated
¦ Remedy performance issues—cannot assess plume capture by existing P&T via
city wellfield, source area SVE shut down, French drain system for vapor
intrusion not meeting ROD goals
¦ Uncertainty in roles and responsibility
PRIMARY RECOMMENDATIONS
¦ Expand groundwater sampling by locating and using historical wells to delineate
and define plume, use information to inform capture zone analysis
¦ Fill vapor intrusion data gaps by sampling residential indoor air
¦ Consider options for lowering water table to address vapor intrusion
¦ Assess vapor intrusion, evaluate SVE effectiveness, and implement institutional
controls at dry cleaner source area
¦ Seek agreement to have municipal wellfield operated in a manner to ensure
capture
¦ Reduce sampling frequency in monitoring well network
IMPLEMENTATION OUTCOMES
¦ Agreement was reached on defined roles and responsibilities for a clear
resolution and path forward on
o Vapor intrusion assessment and mitigation
o Plume capture evaluation
o French drain and groundwater to surface water pathway
o Groundwater sampling scheme
o SVE and vapor intrusion assessment at dry cleaner source area
¦ Third party evaluation provided venue for CSM refinement and agreement of
future efforts
An optimization review was conducted on the existing Palermo Well Field remedy, which
consisted of P&T using the existing wellfield, a French drain to address vapor intrusion in a nearby
residential area, and an SVE system at a source area. The optimization review confirmed the
CSM and remedy issues that had been identified by the site team. The optimization review
recommended expanding the groundwater sampling using existing wells to better delineate and
define the plume and to provide information for a capture zone analysis. Additional source
characterization work was recommended for the two sources, a Washington Department of
Transportation facility and a dry cleaner. Recommendations also addressed adjustments to P&T
system using the existing wellfield, improving performance of the French drain, improving the
groundwater sampling scheme, and assessing effectiveness of SVE. All parties are engaged in
the source area investigation and remedy, and the site team achieved a better understanding of
site conditions leading to improved and documented remedy performance.
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Highlight 16: Remedy Recommendations
Tar Creek (Ottawa County) Site, OU 04, Ottawa County, Oklahoma
KEY CHALLENGES
¦ Large and complex former lead and zinc mining site
¦ Numerous stakeholders with diverse perspectives
¦ Mining wastes located in many areas, often adjacent to creeks and rivers
¦ Impacts to numerous surface water bodies affecting two watersheds
PRIMARY RECOMMENDATIONS
¦ Prioritize remedial activities based on COC loading rates
¦ Shift primary focus to watershed remediation and protection, specifically in
affected riparian areas
¦ Ensure remedial activities minimize potential impacts to Roubidoux aquifer and
Grand Lake
¦ Leverage potential synergies with project team structure, roles and responsibilities
¦ Develop coordinated tactical plans and project controls
IMPLEMENTATION OUTCOMES
¦ Implemented watershed and riparian area approach by aligning tactical plans of
the project with larger watershed issues
¦ Implemented changes to structure of project team by engaging Tribal Nations
under OU 05; and the Quapaw Tribe of Oklahoma (Quapaw Tribe), and the
Oklahoma Department of Environmental Quality (ODEQ) to perform the remedial
actions at distal areas under OU 04
¦ Provide funding to the Quapaw Tribe (for OU 04) and ODEQ (for OU 02 and OU
04) through remedial action cooperative agreements with the EPA
¦ Continue to provide technical support to the Quapaw Tribe and ODEQ, while they
continue to develop technical capacity to implement the remedial actions
¦ Continue to involve the Bureau of Indian Affairs when coordinating with the
Quapaw Tribe Realty Department on chat sales of tribal-owned chat
The Tar Creek Superfund site is a large and complex site with numerous former lead and zinc
mines. The site is being investigated and remediated in operable units. OU 04 covers 40 square
miles and addresses source materials including numerous types of mine wastes. The initial focus
of activities was to mitigate threats to human health and the environment through residential yard
remediation, relocation, and by consolidating, disposing of, and reusing source materials. In
response to challenges that occurred during the consolidation and disposal of the source
materials, an optimization review was requested. Two of the optimization review
recommendations included shifting the focus of the next phase of work to prioritize activities based
on COC loading rates, watershed remediation and protection in riparian areas, and leveraging the
project team structure. The optimization review recommendations have largely been implemented
leading to increased watershed and riparian remediation and protection and full engagement of
the stakeholders in implementing the remedial activities forOU 02, OU 04, and OU 05.
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2.2.4 Long-Term Monitoring Recommendations
An LTM-focused optimization review most commonly takes place during the remedial action phase
orO&M phase of the Superfund pipeline and involves preparing for site reuse and closure, preparing
a monitoring program to evaluate the attainment of remedial goals or evaluating an existing
monitoring program and developing an effective remedy completion (exit) strategy. An effective LTM
optimization review considers the regulatory framework of the project, the RAOs, the perspectives of
the various site stakeholders, and the available site-specific technical information and long-term
goals for property reuse. An LTM optimization review may include an evaluation of remedy
effectiveness and consequences of a remedy not progressing as expected.
LTM optimization was performed less frequently than any of the other optimization stage reviews.
However, some LTM reviews fall under the category of technical support because they do not result
in an optimization review report with the typical list of recommendations that fit into the five
recommendation types (see Section 2.4). As shown in Table 8, most LTM recommendations fall into
the remedy effectiveness category with cost reduction and technical improvement categories being
the next most common.
Table 8: Types of Long-Term Monitoring Recommendations
Types of Recommendations
Total
Remedy Effectiveness
33
Cost Reduction
21
Technical Improvement
22
Site Closure
13
Green Remediation
4
All Recommendation Types
93
An LTM optimization review is often requested when a remedy is not achieving its goals as
anticipated or there is an opportunity to reduce monitoring points and costs. At the Middlefield-Ellis-
Whisman (MEW) Study Area (Highlight 17), a "regional" groundwater extraction system to address
the combined plumes was initiated in the late 1990s. The site's monitoring program is extensive and
it is expected to take a long time to reach RAOs. Based on an optimization assessment conducted in
FY 2015, the plan is to reduce annual sampling of 400 wells to biennial sampling, and semi-annual
water level gauging to annual water level gauging for 650 wells, which will result in a cost-savings
without impacting the effectiveness of the performance monitoring. At the MetalTec/Aerosystems
site (Highlight 18) the groundwater monitoring program includes quarterly sampling of numerous
analytes to assess the performance of the remedial P&T system. Based on their review, the
optimization team recommended decreasing sampling frequency and the number of analytes
included for analysis.
An LTM optimization may also be conducted when there is uncertainty about the effectiveness of a
selected remedy. For example, the stability of the plume at the MetalTec/Aerosystems site was
unknown because of the site's complicated geology. The optimization review was able to confirm
that the plume is stable or decreasing using two different software packages.
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LTM optimization reviews often recommend remedy system and component improvements,
including operational improvements and maintenance and optimizing monitoring. At both the MEW
Study Area and the MetalTec/Aerosystems site, the optimization review recommended using
passive methods, rather than active methods, to collect groundwater samples. A long-term
monitoring optimization assessment was recommended at the MEW Study Area, including the
network and monitoring frequency, resulting in a significant reduction in sampling frequency.
Highlight 17: Long-Term Monitoring Recommendations
MEW Study Area, Mountain View and Moffett Field, California
KEY CHALLENGES
¦ Long time period expected to reach RAOs
¦ Monitoring program is extensive
PRIMARY RECOMMENDATIONS
¦ Consider further long-term monitoring optimization assessment
¦ Consider use of passive methods to collect groundwater samples
IMPLEMENTATION OUTCOMES
¦ Trial reduction of annual chemical sampling of over 400 wells to sampling every
two years
¦ Trial reduction of water level gauging frequency of over 650 wells from twice per
year to once per year
¦ Consolidation of treatment systems
¦ Implementation of passive methods to collect groundwater samples
The MEW Study Area is located in Mountain View, California. The site includes multiple sources
of chlorinated volatile organic compounds (CVOCs), primarily TCE, creating a groundwater
plume that is 11,000 feet in length impacting several water-bearing stratigraphic units. Source
areas have generally been addressed by soil excavation, groundwater extraction, and slurry wall
construction around the larger sources. Two "regional" groundwater extraction systems to
address the co-mingled contaminant plumes and nine facility-specific treatment systems for
source areas were initiated in the 1990s in accordance with the ROD. Currently eight plants treat
groundwater from various extraction wells screened in multiple aquifer units.
The optimization review recommended further analysis of the potential for optimization of the
long-term monitoring program, including the network and the monitoring frequency. In FY 2015,
a trial reduction of annual chemical sampling of over 400 wells was implemented, reducing it to
biennial sampling and reducing semi-annual water level gauging to annual water level gauging
for over 650 wells. This reduction in sampling and water level gauging will result in a cost-savings
without impacting the effectiveness of the performance monitoring. A footprint analysis for the
MEW Study Area was also conducted in FY 2012.
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Highlight 18: Long-Term Monitoring Recommendations
MetalTec/Aerosystems Site, Franklin Borough, New Jersey
KEY CHALLENGES
¦ Stability of plume unknown
¦ Sampling conducted quarterly
¦ Sampling includes numerous analytes and MNA parameters
PRIMARY RECOMMENDATIONS
¦ Reduce sampling frequency to annually
¦ Reduce analytes list to VOCs of interest
¦ Reduce testing for MNA parameters
¦ Consider use of passive sampling rather than grab sampling where appropriate
IMPLEMENTATION OUTCOMES
Plume stability confirmed through optimization team analysis
Sampling frequency reduced to annually
Analytes list reduced to VOCs of concern
MNA sampling frequency reduced to every five years
Passive sampling to be adopted in future
The MetalTec/Aerosystems site is located in complicated geology including overburden, granite
bedrock, and dolomite bedrock. Groundwater at the site is contaminated with VOCs. The
remedial system includes P&T in the granite bedrock formation with groundwater monitoring to
assess performance of the remedial system. The monitoring program was assessed by the
optimization team to determine if adjustments could be made that would reduce costs without
reducing the quality of the information and effectiveness of the monitoring program.
The optimization review confirmed that the plume is stable or decreasing using the Monitoring
and Remediation Optimization System (MAROS) and 3-Tiered Monitoring Optimization (3TMO)
Tool software packages. Additional analyses led to recommendations to decrease sampling
frequency, decrease the number of analytes included for analysis, and change the approach to
sample collection. If sampling is focused on the VOCs, alternative sampling methods that require
less labor and provide equally valid results can be considered, such as the use of passive-
diffusion bag (PDB) samples. For those few rounds where the other parameters (that are not
amenable to PDBs) are required, grab samples may be obtained using no-purge sampling
devices. Note, it was recommended that artesian (i.e., naturally flowing) wells continue to be
sampled by purging (under natural flow) and sampling, as it may be difficult to place and secure
the PDBs and the natural flow would be adequate to obtain a sample without a pump. Many of
the optimization review recommendations have been implemented, while others are in the
process of being implemented.
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2.3 Events and Sites Requiring No Further Follow-Up
RPMs continue to demonstrate a commitment to the implementation of optimization
recommendations. The optimization process is now complete at a number of sites as a result of the
successful implementation or thorough consideration of all optimization recommendations. EPA is no
longer conducting annual follow-up discussions for the following events and sites, though assistance
is still available to site managers in the event that any optimization-related issues arise:
¦ 10th Street Site, 2010 Event.
¦ American Creosote Works, Inc. (Pensacola Plant).
¦ Boomsnub/Airco.
¦ Bunker Hill Mining & Metallurgical Complex, OU 02, 2013 Event.
¦ Burlington Northern (Somers Plant).
¦ Colbert Landfill.
¦ Eastern Surplus.
¦ Groveland Wells No. 1 & 2, 2013 Event.
¦ Groveland Wells No. 1 & 2, 2014 Event.
¦ Intel Magnetics.
¦ Intermountain Waste Oil Refinery.
¦ Northwest Pipe & Casing/Hall Process Company.
¦ Old Hilltop (Hilltop Station).
¦ Ott/Story/Cordova Chemical Co.
¦ Pemaco Maywood.
¦ Pine Ridge Oil Underground Storage Tank Site.
¦ Railroad Avenue Groundwater Contamination.
¦ Tutu Wellfield.
Previous progress reports identified 32 events and sites that no longer require implementation
tracking, for a total of 50 events and sites that have successfully completed the follow up process
since it began as a result of the Action Plan in 2004.
2.4 Technical Support Highlights
In addition to formal optimization reviews, EPA provides technical support that results in optimization
principles being applied more broadly. Technical support activities can include a broad range of
support such as providing environmental footprint analysis, providing assistance with strategic
sampling using incremental sampling, using 3DVA, conducting High-Resolution Site
Characterization (HRSC), developing a CSM, developing a decision framework for shutdown,
reviewing technical documents such as engineering specifications, or providing cost estimates.
Table 9 lists the technical support projects completed from FY 2011 through FY 2015. The majority
of technical support projects were conducted as investigation optimizations.
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Table 9: Completed Technical Support Projects FY 2011 - FY 2015
State
Region 1
MA Fairmont Line - Modern Electroplating 2013 R
MA
Groveland Wells No. 1 & 2
2014
L
Region 2
4
NY
Fulton Avenue
2013
I
NJ
King of Prussia
2012
R
NJ
Passaic River-Diamond Alkali
2011
I
NY
South Buffalo Brownfields Opportunity
Area
2012
I
Region 3
2
PA
Clearview Landfill OU 03
2014
I
VA
Fort Eustis (US Army)
2013
Not Defined
Region 7
3
MO
Missouri Dioxin Reassessments
2014
Not Defined
MO
Rt. 66 Park (Under MO Dioxin
Reassessment Site)
2014
Not Defined
MO
Strecker Dioxin Site (Under MO Dioxin
Reassessment)
2014
Not Defined
Region 8
3
MT
Lockwood Solvent Ground Water Plume
(OU 02)
2014
D
UT
Ogden Railroad Yard
2013
L
CO
Standard Mine
2014
D
Region 9
5
CA
Hunter's Point
2013
Not Defined
AZ
Iron King Mine
2013
I
CA
McCormick & Baxter
2014
I
CA
MEW Superfund Study Area
2012
I
CA
Newmark Groundwater Site Event 3
2014
I
Region 10
6
ID
Bunker Hill Mining & Metallurgical
Complex OU 03
2014
I
WA
Hamilton/Labree Roads GW
Contamination Site
2015
D
OR
Northridge Estates
2015
D
OR
Portland Harbor/Rhone Poulenc
2011
I
WA
Upper Columbia River
2013
Not Defined
WA
Wyckoff Co./Eagle Harbor
2014
I
TOTAL
25
I = Investigation, D = Design, R = Remedy, L = Long-Term Monitoring; a single event may have recommendations that fall into
more than one focus area.
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Optimization
Optimization
Optimization Event
Complete
Focus
Events
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Superfund Optimization Progress Report 2011-2015
Technical support includes both planning and implementation activities and frequently results in
products including work plans, quality assurance project plans, mapping and 3DVA products, and
contaminant results that are used directly by the site teams. In many cases, EPA's technical support
helps move a project forward and can help improve site decision-making. EPA has expanded its
support services for environmental footprint analysis as well as 3DVA. Several technical support
projects, including Hunter's Point, MEW, and Northridge Estates involved activities associated with
green remediation and environmental footprint analysis. During this reporting time frame, six 3DVA
technical support projects were completed. EPA considers 3DVA to be a best practice for completing
site characterizations, transitioning site activities from Rl to FS, evaluating remedy effectiveness,
and monitoring remedy progress. Project Highlights 19, 20 and 21 below show the variety of
activities for which EPA provides technical support.
Highlight 19: Technical Support
Hamilton/Labree Roads GW Contamination Site, Hamilton Road Impact Area, OU 01,
Chehalis, Washington
As part of the design phase of the project, technical support was provided for the Hamilton Road
Impact Area (HRIA) of the Hamilton/Labree Roads GW Contamination site to plan and conduct
a dynamic field investigation. Soil, sediment, and groundwater are contaminated with PCE from
suspected illegal dumping in the past. The selected remedy includes in situ thermal treatment of
soil and sediment, excavation and disposal of contaminated soil and sediment, and in situ
bioremediation of contaminated groundwater. The technical support project was designed to
identify the footprint of each of the components of the selected remedy. Real-time measurement
technologies in combination with 3DVA mapping of results were used to define the various
contamination zones at HRIA. Real-time results from each day's investigative efforts were
processed in 3DVA software and the visualizations were then used to help guide the
investigative efforts to be conducted on the following days. The results of the effort are being
used in the design of the multi-component remedy.
Highlight 20: Technical Support
Wyckoff Co./Eagle Harbor Site, Seattle, Washington
The technical support for the Wyckoff Co./Eagle Harbor site involved conducting 3DVA using
existing data for the source area. The contamination at the site includes subsurface soil and
groundwater contamination with creosote from many years of wood treating operations at the
facility. A large amount of existing data was available for the site. The existing data consisted of
historical contaminant data as well as real-time data from the use of laser-induced fluorescence
(LIF) direct push borings in the source zone. The 3DVA specialty contractor developed a
methodology for using the LIF data without data reduction and potential corresponding loss of
source definition. The 3DVA results helped to identify the various zones of contamination within
the source area and assisted with calculation of the source volume in the subsurface. The
technical support helped to move the project from the investigative phase into the remedy
selection and design phases.
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Highlight 21: Technical Support
Colorado Smelter Site, Pueblo, Colorado
Historical operations at the Colorado Smelter site have resulted in lead and arsenic
contamination of site soil and the soil of residences near the site. The technical support for the
Colorado Smelter site involved planning and implementing soil sampling using X-ray
fluorescence (XRF) in combination with an incremental sampling strategy for residences near
the site. The project required planning support as well as design and execution of a
Demonstration of Methods Applicability (DMA) study to ensure samples were collected,
processed, and analyzed properly. A field soil laboratory was also established to ensure proper
sample preparation and analysis. The XRF was used with a high level of quality control (QC)
during the project, establishing a rigorous QC program and data from the XRF are continually
evaluated against fixed laboratory methods for a subset of analytical samples. The DMA study
also included a comparison of the 5-point composite sample currently in EPA's lead handbook
with a 30-point incremental composite sample. The results of the technical support project
concluded that the XRF did provide reliable results suitable for decision-making when used with
proper sample processing support and careful QC. The comparison of the 5-point and 30-point
composite sampling showed that the 30-point composite sampling strategy resulted in slightly
fewer decision errors than 5-point composite sampling strategy. Though empirical evidence
gathered from incremental sampling at a variety of sites has indicated that the 30-point strategy
is usually necessary, at this site the 5-point approach adequately addressed matrix
heterogeneity and provided acceptable decision error rates. The project also verified that careful
decision unit selection, sample processing, subsampling, and analytical procedures were
required for either strategy.
3.0 SUMMARY OF PROGRESS ON IMPLEMENTING THE
NATIONAL OPTIMIZATION STRATEGY
EPA has continued to successfully implement the Strategy and expand the optimization program
and its many benefits to reach a larger number of sites, across all stages of optimization, and all
stages in the Superfund pipeline. The four main elements of the Strategy form the basis of
development and implementation of the Strategy. They include:
¦ Element 1: Planning and Outreach.
¦ Element 2: Integration and Training.
¦ Element 3: Implementation.
¦ Element 4: Measurement and Reporting.
3.1 Planning and Outreach
EPA has continued to increase its success in planning and outreach, through a collaborative process
between EPA HQ and the Regions, facilitated by ROLs and Superfund and Technology Liaisons
(STLs), to continuously identify sites or site projects that would benefit from an optimization review.
This includes Regions identifying sites that may benefit from an independent optimization review and
requesting support from the EPA HQ team. Other government stakeholders (such as states, tribes
and local governments) and communities are also requesting optimization technical support through
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their respective EPA Regions. In addition, an increasing number of requests are being generated
from the optimization material presented at CERCLA Education Center (CEC) and National
Association of Remedial Project Managers (NARPM) Training Program courses and EPA HQ and
regional presentations at outside conferences and training programs. Support may be provided by
EPA HQ, Regions, or resources from other EPA offices such as the Office of Research and
Development (ORD).
The use of optimization practices helps to address stakeholder concerns and provide information on
the protectiveness and efficacy of remedies and may instill more confidence to communities that
remedies are and will remain protective. EPA's optimization website
www.epa.qov/superfund/cleanup-optimization-superfund-sites contains detailed information on the
optimization program and is accessible to the public.
3.2 Integration and Training
EPA continues to collect, synthesize and share optimization lessons learned through: (1) CEC and
Environmental Response Training Program (ERTP) training courses; (2) NARPM and On-Scene
Coordinator (OSC) Academy training programs; (3) periodic meetings of the National Optimization
Team composed of EPA HQ staff, ROLs, and STLs; and (4) presentations at conferences and
training programs sponsored by other entities within EPA (Brownfields, Federal Facilities and
Resource Conservation and Recovery Act corrective action programs) and outside of EPA (such as
Battelle conferences, Northeast Waste Management Officials' Association conferences, and
Association of State and Territorial Solid Waste Management Officials events). EPA is in the process
of developing and issuing three technical guides on topics related to optimization that were identified
in the SPR Action Plan: smart scoping, strategic sampling approaches, and data management. EPA
has also developed standard operating procedures such as project engagement forms, checklists
and documentation to facilitate the scoping and conduct of optimization reviews.
3.3 Implementation
The primary goals of implementation are to extend optimization to all phases of the Superfund
pipeline and to build capacity for integrating optimization concepts throughout the pipeline. EPA
accomplishes this goal not only by executing training and integration efforts, but also by
increasing the amount of optimization reviews conducted with site teams in all regions,
introducing site team members to optimization concepts that then become incorporated as
standard operating practice. Initially all optimizations were done for sites in the remedial action
orO&M phase of the Superfund pipeline. Since implementing the Strategy, 35 percent of all
optimizations are done in pre-remedial action phases including remedial investigation/feasibility
study and remedial design phases (Figure 9).
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Figure 9: Superfund Phase of Optimization Events
Number of Superfund Optimization Reviews and Technical Support Events = 72
Remedial Action,
37, 51%
Pre-Remedial
Action, 25, 35%
Remedial
Investigation/
Feasibility
Study, 15,
21%
Remedial
Design, 10,
14%
Operations &
Maintenance, 10,
Total Optimization Events included in the report = 86 (61 optimization reviews and 25 technical support efforts); 14 events were
not at Superfund sites and are not included in the analysis.
Prior to implementing the Strategy, EPA completed approximately seven optimizations per year. In
late 2010, EPA initiated the development of the Strategy to increase the capacity for conducting
optimizations and extending optimization to all phases of the Superfund pipeline. Since
implementing the Strategy, EPA now completes 20 optimizations per year on average (Table 3,
Section 1.2). In addition to the number of completions per year, the capacity to support ongoing
optimization events has increased to an average of nearly 50 optimizations per year, with 68 events
supported in FY 2016 (Table 10).
Table 10: EPA Optimization Support
Fiscal Year
Started
Ongoing
Completed
Number of Optimization Events and
Technical Support Projects
Supported by OSRTI*
2011
19
16
11
35
2012
21
24
18
45
2013
27
27
27
54
2014
18
27
29
45
2015
28
16
15
44
2016
39
29
30
68
* This column represents the number of events started each fiscal year combined with the number of events ongo-
ing from the previous fiscal years.
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3.4 Measurement and Reporting
In order to more accurately track optimizations and be able to provide data and information
regarding the program, EPA uses two tracking tables: the Optimization Project Log (OPL) and the
Optimization Report Inventory and Tracking Tool (ORITT). In OPL, EPA lists all optimization events
(technical support events and optimization review events) by site name and records key information
about each event including:
¦ Event type (technical support or optimization review).
¦ Project lead, regional contact, and contractor support.
¦ Site type, media, and contaminant groups addressed.
¦ Current project status (anticipated, in progress or complete).
¦ Major project milestone dates (scoping call, kickoff call, site visit, drafts, and final reports).
¦ FY start and completion dates.
OPL is updated each month. Summary reports on the current status of all events supported during
the current fiscal year are provided to EPA management. ORITT houses recommendation data from
all optimization reviews that have been completed to date. EPA records the names and type of
recommendations, the optimization focus of recommendations, and the implementation status of the
recommendations. ORITT also includes the potential costs and savings projected by the optimization
team for implementing each recommendation and can also include actual cost data when available.
Further details on meeting the goals of the Strategy are included in Appendix A.
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4.0 REFERENCES
U.S. Environmental Protection Agency (EPA). 2000. FY 2000-FY 2001 Superfund Reforms Strategy.
OSWER 9200.0-33. July.
EPA. 2004. Action Plan for Ground Water Remedy Optimization. OSWER 9283.1-25. August.
EPA. 2005. 2004 Annual Progress Report for Ground Water Remedy Optimization. OSWER No.
9283.1-27, EPA 542-R-05-014. August.
EPA. 2011. Environmental Cleanup Best Management Practices: Effective Use of the Project
Lifecycle Conceptual Site Model. EPA 542-F-11-011. July.
https://www.epa.gov/remedytech/environmental-cleanup-best-management-practices-effective-use-
project-life-cycle.
EPA. 2012a. Groundwater Remedy Optimization Progress Report: 2010-2011. OSWER Directive
No. 9283.1-38. July.
EPA. 2012b. 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). OSWER Directive No. 9200.3-75. September 28.
EPA. 2013a. FY 2014 Superfund Remedial Program Review Action Plan. November 26.
EPA. 2013b. Superfund Remedy Report, 14th Edition. EPA 542-R-13-016. November.
https://www.epa.gov/remedytech/superfund-remedy-report.
EPA. 2014. Groundwater Remedy Completion Strategy. OSWER Directive No. 9200.2-144. May.
EPA. 2016. Optimization Can Move My Site to Completion - How Does It Work. National
Association of Remedial Project Managers (NARPM) Presentation. May.
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APPENDIX A
Progress on Implementing the National Optimization
Strategy
APPENDIX A-1
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Superfund Optimization Progress Report 2011-2015
TABLE OF CONTENTS
A.1 Progress on Implementing Element 1: Planning and Outreach A-3
Element 1.1: Establish Strategy Goals A-4
Element 1.2: Apply Optimization as a Means to Improve Community Engagement A-5
Element 1.3: Identify Projects and Sites for Optimization A-6
Element 1.4: Coordinate with Complementary Technical Support Efforts A-6
A.2 Progress on Implementing Element 2: Integration and Training A-7
Element 2.1: Create Technical Resources to Supplement Existing Guidance and Policy,
and Address Optimization in New Guidance A-7
Element 2.2: Adopt Lessons Learned into Business Practices A-7
Element 2.3: Formalize an Optimization Training Program A-7
A.3 Progress on Implementing Element 3: Implementation A-8
Element 3.1: Conduct Optimization Reviews at all Stages of the Project Pipeline
Beginning with Site Assessment A-8
Element 3.2: Expand Optimization to Earlier Project Pipeline Stages and Incorporate
Triad, Green Remediation and Other Best Practices A-8
Element 3.3: Independent Party Optimization Review Steps A-9
Element 3.4: Provide Access to a Pool of Qualified, Independent Contractors A-9
Element 3.5: Develop Regional Optimization Capabilities A-9
Element 3.6: Develop Other Stakeholders' Capabilities A-9
Element 3.7: Advance Application of Innovative Optimization Strategies A-10
A.4 Progress on Implementing Element 4: Measurement and Reporting A-10
Element 4.1: Track Implementation of Recommendations A-10
Element 4.2: Measure Optimization Outcomes and Report Results A-10
Element 4.3: Monitor Cost Accounting A-11
APPENDIX A-2
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Superfund Optimization Progress Report 2011-2015
EPA has been successful in implementing the Strategy and expanding the optimization program,
extending the benefits of optimization to a larger number of sites and across all stages of
optimization and the Superfund pipeline from site assessment to site completion. This section
presents a discussion of the successes and challenges EPA experienced while implementing the
Strategy.
The Strategy instituted changes to the Superfund remedial program business processes to take
advantage of newer tools and strategies that promote more effective and efficient cleanups. The
Strategy identified several objectives to achieve verifiably protective site cleanups faster, cleaner,
greener and cheaper. The Strategy envisions iterative efforts by Regions to pursue cost-effective
expenditure of Superfund dollars, lower energy use, reduced carbon footprint, improved remedy
effectiveness, improved project and site decision making, and accelerated project and site
completion by deploying newer tools and strategies for site evaluation and remediation throughout
the life cycle of the site cleanup.
Optimization in the context of the Strategy is defined 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." (EPA, 2012b)
The Strategy is built on the success of existing strategies, coordination with similar optimization
technical support efforts, and the expansion of optimization reviews to more sites and to all phases
of the remedial pipeline. Four elements form the basis of development and implementation of the
Strategy, as discussed in the following subsections:
¦ Section A.1 - Element 1: Planning and Outreach.
¦ Section A.2 - Element 2: Integration and Training.
¦ Section A.3 - Element 3: Implementation.
¦ Section A.4 - Element 4: Measurement and Reporting.
A.1 Progress on Implementing Element 1: Planning and
Outreach
Element 1 involves a series of planning and outreach efforts to document Strategy goals, apply
optimization to improve community engagement, nominate sites for optimization and coordinate with
related efforts. Element 1 is divided into four sub-elements. EPA's progress on each sub-element
under Element 1 is discussed below.
APPENDIX A-3
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Superfund Optimization Progress Report 2011-2015
Element 1.1: Establish Strategy Goals: The Strategy established the following overarching goals:
¦ Incorporate optimization experience and principles in remedial program business practices
including:
Assessment of site cleanup progress, site technical performance and costs;
Regional/EPA HQ work planning and reviews; and
Implementation of acquisition strategies and contracts management practices;
¦ Collect, synthesize and share optimization lessons learned;
¦ Apply optimization practices earlier and throughout the remedial pipeline;
¦ Increase the number of optimization reviews supported by EPA to 20 to 30 sites annually;
and
¦ Measure optimization outcomes and report results.
EPA has successfully achieved or is in the process of achieving the overarching goals of Element
1.1. EPA has incorporated optimization experience and principles in remedial program business
practices by continuing to assess site cleanup progress, technical performance and costs and
documenting those in optimization reports and technical memos. Regions and EPA HQ work
planning and reviews include an optimization component and all but one Region has identified a
Regional Optimization Liaison (ROL) to facilitate optimization efforts at the regional level. In addition,
Superfund and Technology Liaisons (STL) in all Regions are also participating in and facilitating
Regional optimization activities. The EPA Superfund remedial program is in the process of replacing
regional remedial contracts with a suite of national contracts to execute Superfund remedial
work. Under these contracts, EPA will have the ability to incorporate optimization into task order
requirements.
EPA continues to collect, synthesize and share optimization lessons learned through (1) CERCLA
Education Center (CEC) and Environmental Response Training Program (ERTP) training courses,
(2) National Association of Remedial Project Managers (NARPM) and On-Scene Coordinator (OSC)
Academy training programs, (3) periodic meetings of the National Optimization Team composed of
EPA HQ staff, ROLs, and STLs, and (4) presentations at conferences and training programs
sponsored by other entities within EPA (Brownfields, Federal Facilities and Resource Conservation
and Recovery Act corrective action programs) and outside of EPA (such as Battelle conference,
Northeast Waste Management Officials' Association conference, and Association of State and
Territorial Solid Waste Management Officials events).
EPA has applied optimization practices earlier and throughout the remedial pipeline, as evidenced in
Figure 9 (Section 3 of main report). Figure 9 shows the Superfund stage of completed optimization
events and technical support projects from FY 2011 through FY 2015. EPA currently has a number
of additional ongoing optimization reviews and technical support projects underway, as shown in
Table A-1. This table lists the number of initiated, ongoing, and completed events supported by EPA
each year from FY 2011 through FY 2016. EPA has increased the number of optimization reviews
and technical support projects it supports and has exceeded the goal of supporting 20 to 30
optimization reviews annually. EPA continues to measure optimization outcomes and is reporting on
the results with this optimization progress report.
APPENDIX A-4
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Superfund Optimization Progress Report 2011-2015
Table A-1: EPA Support of Optimization
Fiscal
Year
Started
Ongoing
Completed
Number of Optimization Events
and Technical Support Projects
Supported by OSRTI*
2011
19
16
11
35
2012
21
24
18
45
2013
27
27
27
54
2014
18
27
29
45
2015
28
16
15
44
2016
39
29
30
68
* This column represents the number of events started each fiscal year combined with the number of events ongo-
ing from the previous fiscal years.
Element 1.2: Apply Optimization as a Means to Improve Community Engagement: The
Strategy identifies how optimization can be instrumental in providing structure and tools to improve
communication with communities, local stakeholders, regulatory agencies, tribes and Potentially
Responsible Parties (PRPs). Below are examples of how optimization was used during FY 2011
through FY 2015 to facilitate or improve community involvement and communication:
1.2.1 Triad Approach. The Triad is an innovative approach to decision-making for hazardous waste
site characterization and remediation. The Triad approach proactively exploits new characterization
and treatment tools using innovative work strategies. The Triad refers to three primary components:
systematic planning, dynamic work strategies, and real-time measurement systems. Efforts to
advance site management strategies that help to more fully characterize sites and to increase
confidence in the understanding of the extent, location and behavior of contamination can help
communicate site conditions and progress to stakeholders. EPA recently updated its Triad training
with revision of the CEC course, "Best Practices for Site Characterization Throughout the
Remediation Process," by clearly identifying the best practices, updating the case studies with recent
examples, and developing exercises that give participants the opportunity to apply the Triad
concepts covered in the course.
1.2.2 Remediation System Evaluations (RSE) and Long-Term Monitoring Optimization (LTMO). EPA
continued to conduct RSEs and LTMOs as part of remedy and LTM optimization reviews. The use of
these and other optimization practices help to address stakeholder concerns and provide information
on the protectiveness and efficacy of remedies and may instill more confidence to communities that
remedies are and remain protective. The website www.epa.gov/superfund/cleanup-opti mizatio n-
superfund-sites contains detailed information on the optimization program and is accessible to the
public.
1.2.3 Green Remediation. EPA has continued its effort to reduce the environmental footprint of
remedies through environmental footprint reviews and has developed technical resources and
training to assist project teams with site-specific efforts. These efforts help stakeholders understand
the potential effects of remedies on their environment and project teams to understand and minimize
those effects. The website www.epa.qov/superfund/superfund-qreen-remediation contains more
information, technical resources, and available training sessions and is accessible to the public.
APPENDIX A-5
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Superfund Optimization Progress Report 2011-2015
1.2.4 Knowledge Transfer. Current information resources and infrastructure, provided through
www.epa.gov/superfund and www.epa.qov/superfund/superfund-traininq-and-learninq-center and
the Technology Innovation and Field Services Division's (TIFSD) internet seminars, provide a great
deal of readily available and accessible information to stakeholders. In addition, EPA HQ, Regions
and ORD subject matter experts have assisted regions with community meetings related to site
characterization and cleanup.
1.2.5 Training. EPA's CEC and ERTP provided training for the EPA and state regulators, tribes,
other government stakeholders, and private industry that has been updated and revised to integrate
both optimization and stakeholder engagement concepts. CEC and ERTP training courses are
described on the website www.trainex.org/, which is also used for course registration.
Element 1.3: Identify Projects and Sites for Optimization: A collaborative process between EPA
HQ and the Regions, facilitated by ROLs and STLs, is being used to identify sites or site projects
that would benefit from an optimization review. Regions determine which sites may warrant an
independent optimization review and, as applicable, request optimization support from the EPA HQ
team. Support can be provided by EPA HQ, Regional or ORD resources. In addition, an increasing
number of requests are being generated from the optimization material presented at CEC and
NARPM Training Program courses and EPA HQ and regional presentations at outside conferences
and training programs.
Other government stakeholders (such as states, tribes and local governments) and communities
may also seek optimization technical support through their respective EPA regions and these
requests are also frequently triggered after CEC course deliveries. Based on regional determination
and available resources, EPA HQ, ORD, and Regions have provided stakeholders the requested
technical support.
Element 1.4: Coordinate with Complementary Technical Support Efforts: Optimization efforts
continue to support established remedial program goals. Optimization reviews and technical support
projects collaterally support the National Remedy Review Board, Contaminated Sediments
Technical Advisory Group, and Value Engineering efforts, five-year reviews and transfer of sites
from LTRA to O&M. Optimization efforts also facilitate progress towards achievement of program
measures such as construction completion, site-wide ready for anticipated use, human exposure
under control, and groundwater migration under control.
Under this element the National Optimization Program coordinates with key related EPA workgroups
to connect with optimization and avoid conflicts with their efforts. Key workgroups include the
subgroups of the Technical Review Workgroup, the forums under EPA's Technical Support
Program, including NARPM and the Ground Water Forum, Engineering Forum, and Federal
Facilities Forum.
APPENDIX A-6
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Superfund Optimization Progress Report 2011-2015
A.2 Progress on Implementing Element 2: Integration and
Training
EPA has integrated optimization into program operations by creating technical resources to
supplement existing guidance documents (as appropriate) and integrating optimization into its
training programs. EPA is in the process of evaluating current incentives for optimization, addressing
optimization in new guidance, and incorporating optimization language into contracts. Element 2 of
the Strategy has three sub-elements which are discussed below.
Element 2.1: Create Technical Resources to Supplement Existing Guidance and Policy, and
Address Optimization in New Guidance: EPA organized existing optimization-related resources
on the website www.epa.qov/superfund/cleanup-optimization-superfund-sites, to provide easy
access for a broad spectrum of stakeholders. Written resources include report templates, technical
Triad resources, and completed optimization review reports. In addition, EPA technical staff with
expertise in optimization (EPA HQ and regional ROLs and STLs) are identified on the optimization
website. These resources describe how optimization principles, practices and techniques can be
utilized with current programmatic guidance. Existing guidance has been and continues to be
supplemented by directives, technical bulletins, fact sheets and other technical materials to explain
how optimization applies at various stages of cleanup. For example, EPA is in the process of
developing and issuing three technical guides on topics related to optimization: smart scoping,
strategic sampling approaches, and data management. These technical guides were identified in the
Superfund Remedial Program Review Action Plan. EPA has also developed standard operating
procedures such as project engagement forms, checklists and documentation to facilitate the
scoping and conduct of optimization reviews.
Element 2.2: Adopt Lessons Learned into Business Practices: On a routine basis, optimization
lessons learned are collected, summarized and discussed by EPA and regional program and project
staff to determine how business practices, including contracting, can benefit from these lessons
learned. The National Optimization Team meets regularly to identify these lessons learned and
create strategies to ensure they are distributed broadly across the Superfund program. The EPA
Superfund remedial program is in the process of replacing regional remedial contracts with a suite of
national contracts to execute Superfund remedial work. Under these contracts, EPA will have the
ability to incorporate optimization into task order requirements.
Element 2.3: Formalize an Optimization Training Program: EPA made significant progress on
this element of the Strategy through in-person classroom training events and internet-based training
events, and by presenting optimization findings at numerous national conferences. EPA focused its
training efforts on Remedial Project Managers (RPMs) and technical staff by participating in and
developing training courses for the CEC, NARPM training program and Technical Support Project
Forum meetings. All existing CEC courses have been revised and updated to include optimization
concepts and promote optimization efforts. EPA developed two technical groundwater courses on
High-Resolution Site Characterization (HRSC) for unconsolidated environments and fractured
sedimentary bedrock environments and has been delivering these courses since 2012. Groundwater
HRSC optimizes the characterization of contamination in groundwater which leads to targeted
actions and combined remedies that facilitate restoration and site completion. In addition, significant
APPENDIX A-7
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Superfund Optimization Progress Report 2011-2015
revisions were made to the CEC's "Best Practices for Site Characterization Throughout the
Remediation Process" to clearly identify the set of best practices for investigation-focused
optimization activities and to include recent case studies. EPA continues to review optimization
training needs, consolidate existing training material, and develop new training as needed. New
training will be delivered to RPMs and other project managers and technical staff using the CEC,
ERTP, and internet-based training events.
Optimization training supplements guidance and other technical resources and provides a number of
benefits, including, but not limited to:
¦ Increased knowledge of optimization practices and tools for all participants;
¦ National consistency in the quality of, approach to and outcomes of optimization efforts;
¦ An increase in the number of sites that are recommended for optimization; and
¦ Expansion of region-led optimization efforts.
A.3 Progress on Implementing Element 3: Implementation
Element 3 involves implementing the Strategy based on the goals established through the planning
process. Implementation involves conducting optimization reviews at all stages of the project
pipeline beginning with site assessment; incorporating Triad, Green Remediation and other best
practices; providing access to a pool of qualified optimization contractors; developing the capabilities
of regions and other stakeholders; and advancing the application of innovative optimization
strategies. EPA's progress on implementing the seven sub-elements of Element 3 are described
below.
Element 3.1: Conduct Optimization Reviews at all Stages of the Project Pipeline Beginning
with Site Assessment: EPA has achieved its goal of supporting 20 to 30 optimization reviews and
technical support projects as shown in Exhibit A-1 above. Investigation-focused optimization reviews
and technical support projects are being conducted at a steady pace. EPA is currently supporting
two technical support projects in the site assessment phase (before listing of the sites on the
National Priority List) with 3-dimentional visualization and analysis (3DVA) of existing data to
supplement the Hazard Ranking System packages for those projects.
Element 3.2: Expand Optimization to Earlier Project Pipeline Stages and Incorporate Triad.
Green Remediation and Other Best Practices: In accordance with the Strategy, EPA has
expanded optimization to sites earlier in the Superfund project pipeline, including site assessment,
Rl, FS and RD as demonstrated in Figure 9, in Section 3 of this report. Site characterization best
practices are stressed in investigation-focused optimization reviews and technical support projects,
regardless of which phase of the remedial pipeline site characterization activities are being
conducted. EPA has expanded the use of 3DVA (characterization best practice) by supporting
projects in all phases, from site assessment to the remedial action phase. EPA is currently providing
technical site support for conducting HRSC for groundwater and incremental sampling using x-ray
fluorescence for soil, both of which are considered to be strategic sampling approaches and best
practices for site characterization. In addition, green remediation is addressed during every
APPENDIX A-8
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Superfund Optimization Progress Report 2011-2015
optimization review conducted by EPA. EPA also provides technical support for conducting
environmental footprint analyses and implementing green remediation best management practices.
Element 3.3: Independent Party Optimization Review Steps: EPA developed several documents
to establish a consistent and standardized approached to implementing optimization reviews. These
documents facilitate the tracking of optimization and technical support events from team
development to issuance of a final report or technical support product and ease the identification and
tracking of optimization recommendations from optimization review reports. As the number of
different parties conducting optimization reviews and technical support has increased, it is even
more important that everyone adhere to standard operating procedures. Without consistency, both
the tracking of the optimization reviews and technical support projects and the identification and
tracking of optimization recommendations is more difficult. Moving forward, EPA will be able to
update these documents as any procedures or tracking requirements change. These documents are
made available in electronic format to optimization team members and include:
¦ An optimization standard operating procedure;
¦ An optimization primer and overview;
¦ An optimization engagement form;
¦ Management notification emails; and
¦ A template optimization report.
Element 3.4: Provide Access to a Pool of Qualified. Independent Contractors: Optimization
involves the synthesis and analysis of a significant quantity of data in a limited time frame and
budget. To accomplish optimization objectives, EPA must have access to a pool of highly-qualified
technical experts with the demonstrated qualifications to provide the capacity to accomplish these
goals on highly challenging, unique, and complex sites across the country. EPA expanded the
number of these technical experts in various organizations including in EPA HQ (TIFSD),
Environmental Response Team (ERT), and Assessment and Remediation Division, ORD, Argonne
National Laboratory, the U.S. Army Corps of Engineers (USACE), and EPA contractors. EPA will
continue to look for ways to increase this pool of qualified experts, including through training of staff
and accessing additional expertise through EPA contracts such as the new Remedial Action
Framework national contracts.
Element 3.5: Develop Regional Optimization Capabilities: To fully integrate optimization into the
remedial program, regional offices are involved in planning and implementing optimization at all
stages of the remedial process. All Regions but one have assigned an ROL to facilitate the
expansion of regional optimization capabilities. STLs in every region are also helping to identify
optimization opportunities and facilitate optimization reviews and technical support activities. ROLs
and STLs are assisting with implementation of the Strategy.
Element 3.6: Develop Other Stakeholders' Capabilities: A wide range of stakeholders, including
state project managers and tribal nations are included at the outset of optimization reviews, during
implementation, and during follow-up tracking. EPA continues to build the capabilities of
stakeholders through its various training programs which integrate optimization concepts with other
APPENDIX A-9
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Superfund Optimization Progress Report 2011-2015
technical content related to Superfund. Many state and tribal stakeholders have already taken or are
planning to participate in these trainings.
Element 3.7: Advance Application of Innovative Optimization Strategies: EPA has continued to
advance innovation in the optimization arena by participating in ongoing research projects (for
example, ORD, Department of Defense's Strategic Environmental Research and Development
Program and Environmental Security Technology Certification Program, National Institute of
Environmental Health Sciences Superfund Research Program, Interstate Technology and
Regulatory Council, national laboratories and universities), performing general tracking of
developments by other agencies or the private sector, and encouraging and deploying innovative
approaches at Superfund sites.
A.4 Progress on Implementing Element 4: Measurement and
Reporting
Element 4 involves tracking progress of optimization, measuring outcomes and accounting for
related costs. Element 4 has three sub-elements which are discussed below.
Element 4.1: Track Implementation of Recommendations: EPA tracks the implementation of all
optimization review recommendations provided in optimization reports. The Superfund Optimization
Progress Report is EPA's primary vehicle for reporting on the progress of optimization
recommendation implementation, with this current version providing an update on progress during
FY 2011 through FY 2015. EPA has focused its optimization resources on scaling up the program to
cover activities across all focus areas of the optimization process and all phases of the Superfund
pipeline and to increasing the number of optimization reviews and technical support projects.
Currently, EPA collects the following information for optimization reviews:
¦ Status of each optimization recommendation (implemented, alternative implemented, in
progress, planned, under consideration, deferred to state/PRP, and declined)—the collection
of this information is facilitated by use of a menu of choices that can then be easily tracked;
¦ Cost impacts of each optimization recommendation (capital costs, O&M costs, and cost
savings)—the collection of cost savings has been difficult and could be improved;
¦ Benefits that resulted from implementation—recommendations are put into five categories
which describe five broad benefits. Collecting more detailed information on the benefits, such
as the use of best practices and strategic sampling approaches and improved data
management can only be discovered by reading each recommendation follow-up narrative.
The reporting process would benefit from the development of a drop down list from which
specific benefits could be chosen; and
¦ Obstacles encountered during implementation are recorded by narrative provided by the
project manager for each recommendation. The reporting process would benefit from having
a specific question regarding obstacles encountered.
Element 4.2: Measure Optimization Outcomes and Report Results: The analyses performed for
the Superfund Optimization Progress Report included measuring the optimization outcomes using
the available data and information collected for the report. EPA is improving its processes for
APPENDIX A-10
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Superfund Optimization Progress Report 2011-2015
collecting optimization data and information, including identifying ways to streamline data collection.
For example, EPA is making the process of collecting follow-up information on the implementation of
optimization recommendation easier and more frequent.
Element 4.3: Monitor Cost Accounting: EPA tracks and reports on the costs of conducting
individual optimization reviews and implementing the Strategy. In addition, the optimization team's
estimates of potential costs and savings of implementing individual recommendations are included
as part of an optimization review. However, the availability of actual cost information on the
implementation of optimization recommendations has been limited, with these data often difficult to
obtain. Reasons cited include time constraints on remedial staff and difficulty in quantifying actual
cost savings. For example, as optimizations are implemented earlier in the Superfund pipeline,
improving site characterization and having more complete conceptual site models are intended to
lead to better remedy selection and design, leading to rapid achievement of RAOs and site closure.
However, quantifying the difficulties and "avoided costs" that could have resulted from not
conducting optimization early on, can be difficult to estimate. EPA is continuing to work on improving
cost data.
APPENDIX A-11
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Superfund Optimization Progress Report 2011-2015
APPENDIX B
List of Completed Optimization and Technical Support Events
FY 1997 -FY 2015*
Not all FY 2015's were completed in time to be included in the progress report.
APPENDIX B-1
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Superfund Optimization Progress Report 2011-2015
State
Site
Fiscal Year
Total Optimization
Complete
Events
Region 1
17
MA Baird & McGuire - Event 1 2002
MA
Baird & McGuire - Event 2
2013
NY
BCF Oil Refining, Inc.
2009
ME
Eastern Surplus
2012
MA
Engelhard Corporation Facility
2005
MA
Fairmont Line- Modern Electroplating
2013
MA
Groveland Wells No. 1 & 2 - Event 1
2002
MA
Groveland Wells No. 1 & 2 - Event 2
2013
MA
Groveland Wells No. 1 & 2 - Event 3
2014
NH
Kearsarge Metallurgical Corp.
2010
NH
Ottati & Goss/Kingston Steel Drum
2014
CT
Ridson Corporation
2004
NH
Savage Municipal Water Supply
2001
MA
Silresim Chemical Corp. - Event 1
2002
MA
Silresim Chemical Corp. - Event 2
2014
NH
Somersworth Sanitary Landfill - Event 1
2009
NH
Sylvester
2009
Region 2
24
NJ
A-Z Automotive
2004
NJ
Bog Creek Farm
2002
NY
Brewster Well Field
2002
NJ
Ciba-Giegy Corp.
2012
NY
Circuitron Corp.
2005
NY
Claremont Polychemical
2002
NJ
Ellis Property
2006
NY
Fulton Avenue
2013
NY
GCL Tie and Treating Inc.
2007
NJ
Higgins Farm
2004
NJ
King of Prussia
2012
NY
Mattiace Petrochemical Co., Inc.
2001
NJ
MetalTec/Aerosystems - Event 1
2012
NJ
MetalTec/Aerosystems - Event 2
2015
NY
Morgan Terminal
2004
NJ
Passaic River- Diamond Alkali
2011
NY
Richardson Hill Road Landfill/Pond
2012
NJ
Rockaway Borough Well Field, OU 02
2014
APPENDIX B-2
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Superfund Optimization Progress Report 2011-2015
State
Site
Fiscal Year Total Optimization
Complete Events
NJ
Shorco South
2004
NY
Sidney Landfill
2012
NY
SMS Instruments, Inc.
2004
NY
South Buffalo Brownfields Opportunity Area
2012
VI
Tutu Wellfield
2011
NJ
Vineland Chemical Co., Inc.
2011
NJ
A-Z Automotive
2004
Region 3
24
PA
A.I. W. Frank/Mid-County Mustang
2006
PA
Butz Landfill
2006
PA
Clearview Landfill - OU 03
2014
PA
Crossley Farm
2006
PA
Croydon TCE
2006
PA
Cryochem, Inc.
2006
DE
Dover Gas Light Co., OU 02
2015
PA
Fischer & Porter Co.
2014
PA
Former Honeywell Facility
2003
VA
Fort Eustis (US Army)
2013
VA
Greenwood Chemical Co. - Event 1
2004
VA
Greenwood Chemical Co. - Event 2
2006
PA
Havertown PCP - Event 1
2004
PA
Havertown PCP - Event 2
2006
PA
Hellertown Manufacturing Co. - Event 1
2002
PA
Hellertown Manufacturing Co. - Event 2
2006
PA
Mill Creek Dump
2010
PA
North Penn - Area 1
2006
PA
North Penn - Area 6
2012
VA
Peck Iron and Metal
2013
PA
Raymark - Event 1
2002
PA
Raymark - Event 2
2006
VA
Saunders Supply Co. - Event 1
2006
DE
Standard Chlorine of Delaware, Inc.
2007
Region 4
12
FL
Alaric Area GW Plume
2010
FL
American Creosote Works, Inc. (Pensacola Plant)
2006
NC
Benfield Industries, Inc.
2007
NC
Cape Fear Wood Preserving
2005
APPENDIX B-3
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Superfund Optimization Progress Report 2011-2015
State
Site
Fiscal Year Total Optimization
Complete Events
NC
Celanese Corp. (Shelby Fiber Operations)
2009
FL
Chemko Technical Services, Inc. Facility
2005
SC
Eliskim Facility
2004
SC
Elmore Waste Disposal
2001
NC
FCX, Inc. (Statesville Plant)
2002
FL
Taylor Road Landfill
2007
TN
Velsicol Chemical Corp. (Hardeman County)
2013
GA
Woolfolk Chemical Works, Inc.
2008
Region 5
16
MN
Baytown Township Ground Water Plume
2011
Ml
Clare Water Supply - Event 1
2007
Ml
Clare Water Supply - Event 2
2007
OH
Delphi VOC Site
2003
IN
Douglass Road/Uniroyal, Inc. Landfill
2004
OH
Lincoln Fields Co-Op Water Assn Duke Well
2015
MN
MacGillis & Gibbs Co./Bell Lumber & Pole Co.
2001
Wl
Moss-American Co., Inc. (Kerr-McGee Oil Co.)
2011
Wl
Oconomowoc Electroplating Co., Inc.
1997
Ml
Ott/Story/Cordova Chemical Co. - Event 1
2002
Ml
Peerless Plating Co.
2006
Wl
PentaWood Products
2006
IN
Reilly Tar & Chemical Corp. (Indianapolis Plant)
2004
Wl
Stoughton City Landfill
2008
Ml
Wash King Laundry - Event 1
2006
Ml
Wash King Laundry - Event 2
2011
Region 6
16
LA
American Creosote Works, Inc. (Winnfield Plant)
2008
LA
Bayou Bonfouca
2001
TX
Conroe Creosoting Co.
2015
LA
Delatte Metals
2009
TX
East 67th Street Ground Water Plume
2014
NM
Grants Chlorinated Solvents
2008
NM
Homestake Mining Co.
2011
TX
Jones Road Ground Water Plume
2014
NM
McGaffey & Main Groundwater Plume - Event 1, OU 02
2012
NM
McGaffey & Main Groundwater Plume - Event 2, OU 03
2015
AR
Midland Products
2001
APPENDIX B-4
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Superfund Optimization Progress Report 2011-2015
State
Site
Fiscal Year Total Optimization
Complete Events
NM
North Railroad Avenue Plume
2015
AR
Ouachita Nevada Wood Treater
2015
TX
Sandy Beach Road Ground Water Plume
2014
TX
State Road 114 Groundwater Plume
2014
OK
Tar Creek (Ottawa County) - Event 1-OU 04
2014
Region 7
19
NE
10th Street Site - Event 1
2010
NE
10th Street Site - Event 2
2014
KS
57th and North Broadway Streets Site
2006
KS
Ace Services - Event 1
2007
KS
Ace Services - Event 2
2013
NE
Cleburn Street Well
2001
NE
Eaton Corp-Kearney
2006
IA
Fairfield Coal Gasification Plant
2012
IA
General Motors S.C.
2012
NE
Hastings Ground Water Contamination
2013
MO
Lee Chemical
2012
MO
Missouri Dioxin Reassessments
2014
MO
Missouri Tannery Sludge
2010
IA
Nichols Groundwater Contamination, (Cropmate)
2014
NE
Ogallala Ground Water Contamination
2013
IA
Railroad Avenue Groundwater Contamination
2014
MO
Rt. 66 Park (Under MO Dioxin Reassessment site)
2014
MO
Strecker Dioxin Site (Under MO Dioxin Reassessment)
2014
MO
Valley Park TCE
2013
Region 8
3
SD
Batesland (Former Mobil Gas Station)
2013
MT
Burlington Northern (Somers Plant) (BNSF Railway)
2015
CO
Central City, Clear Creek
2007
UT
Former Old Hilltop (Hilltop Station)
2013
CO
French Gulch
2013
SD
Gilt Edge Mine
2013
MT
Idaho Pole Co. - Event 1
2009
MT
Idaho Pole Co. - Event 2
2015
UT
Intermountain Waste Oil Refinery (IWOR)
2011
UT
Jacobs Smelter
2010
MT
Lockwood Solvent Ground Water Plume - Event 1, (OU 01)
2014
APPENDIX B-5
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Superfund Optimization Progress Report 2011-2015
State
Site
Fiscal Year Total Optimization
Complete Events
MT
Lockwood Solvent Ground Water Plume - Event 2, (OU
02)
2014
UT
Ogden Railroad Yard
2013
SD
Pine Ridge Oil
2013
CO
Standard Mine - Event 1
2014
CO
Summitville Mine - Event 1
2002
Region 9
26
CA
Applied Materials
2012
NM
Bond & Bond/Nav 046 Site
2013
CA
BP Carson Refinery
2006
NV
Carson River Mercury Site Event 1, OU 02
2014
AZ
Davis Chevrolet/Nav 185 Site
2013
CA
Hunter's Point
2013
CA
Intel Magnetics
2013
AZ
Iron King Mine - Humboldt Smelter - Event 1
2014
AZ
Iron King Mine - Humboldt Smelter - Event 2
2014
AZ
Iron King Mine - Humboldt Smelter - Event 3
2013
CA
Klau/Buena Vista Mine - Event 1
2010
CA
Lava Cap Mine (OU 03) - Event 1
2014
CA
McCormick & Baxter Creosoting Co. - Event 1
2014
CA
Middlefield - Ellis - Whisman (MEW) Study Area -
Footprint Analysis
2012
CA
Middlefield - Ellis - Whisman (MEW) Study Area -
Optimization Report
2012
CA
Modesto Ground Water Contamination
2002
CA
Newmark Ground Water Contamination - Event 1 (First
MAROS)
2007
CA
Newmark Ground Water Contamination - Event 2 (Second
MAROS)
2009
CA
Newmark Ground Water Contamination - Event 3 (First
3DVA)
2014
CA
Newmark Ground Water Contamination - Event 4 (Third
MAROS)
2015
AZ
Painted Desert Inn/Nav 049 Site
2013
CA
Pemaco Maywood
2011
CA
San Fernando Valley (Area 1)
2012
CA
Selma Treating Co. - Event 1
2002
CA
Sulphur Bank Mercury Mine
2015
AZ
Telles Ranch/CRIT 002
2013
APPENDIX B-6
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Superfund Optimization Progress Report 2011-2015
State
Site
Fiscal Year
Total Optimization
Complete
Events
Region 10
24
OR Black Butte Mine 2012
WA
Boomsnub/Airco
2002
ID
Bunker Hill Mining & Metallurgical Complex - Event 1
2006
ID
Bunker Hill Mining & Metallurgical Complex - Event 2, OU
02 (CTP)
2013
ID
Bunker Hill Mining & Metallurgical Complex - Event 3, OU
03
2014
WA
Colbert Landfill
2011
WA
Commencement Bay, South Tacoma Channel - Event 1
2002
WA
Commencement Bay, South Tacoma Channel - Event 2
2008
WA
Frontier Hard Chrome, Inc.
2008
WA
Hamilton/Labree Roads GW Contamination (HRIA) -
Event 1
2010
WA
Hamilton/Labree Roads GW Contamination (HRIA) -
Event 2
2015
WA
Keyport (Official name: Naval Undersea Warfare
Engineering Station (4 Waste Areas)), Operable Unit
1/Area 1- Keyport Landfill, WA
2013
AK
Kodiak USCG Integrated Support Command Base
2015
OR
McCormick & Baxter Creosoting Co. (Portland Plant)
2002
WA
Moses Lake Wellfield Contamination
2015
Northridge Estates
2015
OR
Northwest Pipe and Casing/Hall Process Company -
Event 1
2007
WA
Occidental Chemical Corporation
2004
WA
Palermo Well Field Ground Water Contamination
2012
OR
Portland Harbor
2011
WA
Upper Columbia River
2013
WA
US Navy Whidbey Island Naval Air Station, (Ault Field/OU
1)
2014
WA
Wyckoff Co./Eagle Harbor - Event 1
2005
WA
Wyckoff Co./Eagle Harbor - Event 2
2014
TOTAL
194
APPENDIX B-7
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