v>EPA EPA-542-R-20-002
Protection Office of Land and Emergency Management
A9encv October 2020
Superfund Optimization Progress Report
October 2020
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Superfund Optimization Progress Report October 2020
PHOTO CREDIT:
Top: East foundry pond at the Marathon Battery Site. Photo courtesy of U.S. Environmental Protection
Agency (EPA) Office of Superfund Remediation and Technology Innovation (OSRTI) from the 2019
Marathon Battery Optimization Review site visit.
Center Left: Approximately 10 miles south of Tar Creek operable unit 4, where the Spring River
meets the Neosho River at the headwaters of Grand Lake o' the Cherokees. Photo courtesy of EPA
OSRTI from the 2014 Tar Creek Remedial Action Optimization Review Report.
Center: Carson River Mercury Site. Photo courtesy of EPA OSRTI from the 2019 site visit.
Center Right: Wilcox Oil Company Site. Photo courtesy of EPA OSRTI from the 2016 XRF sampling
event.
Bottom: 4DIM screen capture showing fence diagram with arsenic concentrations at the Charles
George Reclamation Trust Landfill. Photo courtesy of EPA OSRTI from the 2018 Charles George
Landfill Optimization Review Report.
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Superfund Optimization Progress Report October 2020
Superfund Optimization Progress
Report October 2020
EPA 542-R-20-002
Office of Land and Emergency Management
October 2020
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Superfund Optimization Progress Report October 2020
TABLE OF CONTENTS
Notice and Disclaimer vi
Acknowledgements vii
Executive Summary ES-1
1.0 Introduction 1
1.1 Purpose and Scope 2
1.2 Optimization Program 3
2.0 Summary of Progress on Expanding the Optimization Program 5
3.0 Summary of Recommendation Implementation Progress 8
3.1 Overview of Progress 11
3.2 Evaluations and Sites Requiring No Further Follow-Up 15
3.3 Summary of Technical Support Projects 16
4.0 Optimization Program and Best practices 19
4.1 Key Results from Applying Best Practices 22
4.2 Promoting Best Practices Through Optimization 23
4.2.1 Smart Scoping 24
4.2.2 Strategic Sampling 36
4.2.3 Data Management 37
5.0 Summary of Progress on Implementing the National Optimization Strategy and the
Recommendations of the Superfund Task Force 40
5.1 Planning and Outreach 40
5.2 Integration and Training 40
5.3 Implementation 41
5.4 Measurement and Reporting 42
6.0 References 44
NOTICE AND DISCLAIMER | iv
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Superfund Optimization Progress Report October 2020
Appendix A Progress on Implementing the National Optimization Strategy A-1
A.1 Progress on Implementing Element 1: Planning and Outreach A-3
A.2 Progress on Implementing Element 2: Integration and Training A-7
A.3 Progress on Implementing Element 3: Implementation A-8
A.4 Progress on Implementing Element 4: Measurement and Reporting A-11
Appendix B Completed Optimization Reviews and Technical Support Projects
FY 1997-FY 2017 B-1
Tables
Table 1: EPA Optimization and Technical Support Workflow 6
Table 2: Completed Optimization and Technical Support Evaluations
FY 1997-FY2017 7
Table 3: New Optimization Evaluations Included in this Progress Report 8
Table 4: Updated Optimization Evaluations Included in this Progress Report 10
Table 5: Completed Technical Support Projects 17
FIGURES
Figure 1: Key Optimization Components and Superfund Pipeline Activities 5
Figure 2: Superfund Phase of New Optimization Evaluations 6
Figure 3: Recommendations by Category 12
Figure 4: Status of New Optimization Recommendations 15
Figure 5: Best Practices and the Conceptual Site Model 19
Figure 6: Conceptual Site Model Components 21
Figure 7. Key Results Achieved Through New Optimization and Technical Support 23
NOTICE AND DISCLAIMER | v
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Superfund Optimization Progress Report October 2020
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 October
2020 (EPA 542-R-20-002) is available for viewing or downloading from EPA's website, Cleanup
Optimization at Superfund Sites. For more information about this report, contact Carlos Pachon
(pachon.carlos@epa.gov) or Matthew Jefferson (jefferson.matthew@epa.gov).
NOTICE AND DISCLAIMER | vi
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Superfund Optimization Progress Report October 2020
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:
Mike Adam
Jean Balent
Nate Barlet
Kirby Biggs
Matt Jefferson
Carlos Pachon
Dan Powell
EPA Regional Optimization Liaisons:
Region
1
Derrick Golden and Kim White
Region
2
Jeff Josephson
Region
3
Kathy Davies
Region
4
Rusty Kestle
Region
5
Nabil Fayoumi
Region
6
Vincent Malott
Region
7
Sandeep Mehta
Region
8
Victor Ketellapper
Region
9
Vacant
Region
10: Timothy Maley and Kira Lynch
EPA Superfund Technical Liaisons:
Region
1
Jan Szaro
Region
2
Diana Cutt
Region
3
Jonathan Essoka
Region
4
Felicia Barnett
Region
5
Charles Maurice
Region
6
Terry Burton
Region
7
Robert Weber
Region
8
Steve Dyment
Region
9
Anne-Marie Cook
Region
10: Kira Lynch
EPA Remedial Project Managers and RCRA
Site Contacts:
Region 1: Hoshaiah Barczynski, Kevin Heine
Region 2: MalekShami
Region 3: Lisa Denmark
Region 6: Katrina Higgins-Coltrain, Phillip
Allen, Raji Josiam
Region 7: Owens Hull
Region 8: Andrew Schmidt
Region 9: Andrew Bain, Patricia Bowlin, Grace
Ma
Region 10: Kim Prestbo, Lisa Castrilli
Additional National Optimization
Workgroup Members:
Frances Costanzi - Region 8
William Dalebout- HQ
Jennifer Edwards - HQ
Silvinia Fonseca - HQ
Ed Gilbert - HQ
Jennifer Hovis - HQ
Tom Kady - HQ
Shahid Mahmud - HQ
Gary Newhart- Environmental Response
Team
Heather Newton - HQ
Dion Novak - Region 5
Zi Zi Searles - Region 9
Amanda Van Epps - HQ
Stacey Yonce - HQ
ACKNOWLEDGEMENTS | vii
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Superfund Optimization Progress Report October 2020
EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency (EPA)'s optimization program has continued to make
cleanups more efficient and effective and has spurred the Superfund program forward by:
¦ implementing recommendations provided in the Superfund Task Force Recommendations
(EPA, 2017b), including Recommendation 71, which promotes the use of third-party
optimization;
¦ implementing elements of the National Strategy to Expand Superfund Optimization Practices
from Site Assessment to Site Completion ("the National Strategy");
¦ implementing recommendations for individual optimization reviews and conducting site-
specific technical support projects; and
¦ implementing innovative best practices throughout the Superfund pipeline.
This report provides updates on the status of optimization reviews conducted during fiscal year (FY)
2015 through FY 2017 and includes optimization-related technical support projects that were
substantially completed through 2018. Project highlights demonstrate results achieved from
optimization reviews and optimization-related technical support projects and exemplify how the
optimization program applies and promotes best practices to improve site cleanup.
Implementing the Superfund Task Force Recommendations and the National Strategy - EPA
expanded the optimization program to support 50 or more ongoing optimization reviews and
optimization-related technical support projects in a typical year, completing about 20 of these
evaluations per year and expanding the program to support all phases of the Superfund pipeline.
Benefits realized from expanding the program to a larger number of sites include increasing remedy
effectiveness, improving technical performance, reducing costs, moving sites to completion, and
lowering the environmental footprint of remediation activities. The optimization reviews and technical
support projects can improve approaches in: pre-remedial actions, such as characterization, remedy
selection, and remedy design; remedial actions, including long-term response actions; and operations
and maintenance, including long-term monitoring. Approximately 48 percent of the new optimization
evaluations (or related support activities) conducted at Superfund sites were performed during pre-
remedial action phases of the Superfund pipeline, 39 percent during remedial action phases, and 13
percent during operations and maintenance.
Optimization Reviews - EPA's continued success with the optimization program is reflected in the
status of optimization reviews presented in this report. This includes the status of the implementation
of recommendations for 40 reviews performed since the last progress report and updates to the
status of 35 reviews where implementation of recommendations has been on-going since the last
progress report.
1 Superfund Task Force Report Recommendation 7: Promote Use of Third-Party Optimization Throughout the Remediation Process
and Focus Optimization on Complex Sites or Sites of Significant Public Interest
EXECUTIVE SUMMARY | ES-1
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Superfund Optimization Progress Report October 2020
For the 40 new optimization reviews:
¦ 67 percent of optimization recommendations were implemented, are in progress, or are
planned.
¦ 21 percent are still under consideration.
¦ 7 percent were declined.
¦ 3 percent were deferred to the state or Potentially Responsible Party for action.
¦ 2 percent do not have status information available.
Optimization-Related Technical Support- As part of the optimization program, EPA also
conducted 58 optimization-related technical support projects where work was substantially completed
between FY 2015 and FY 2018. These projects provide direct support applying best practices and
have helped expand optimization to earlier stages of the Superfund pipeline but can be conducted at
any stage. Like optimization reviews, they use third-party experts to provide the support. Examples of
the types of support provided include systematic project planning, demonstrations of method
applicability, advanced data management techniques, strategic sampling techniques, high resolution
site characterization, and three-dimensional visualization and analysis. For optimization-related
technical support projects, EPA tracks the start and end dates, remedial phase, scope of project, best
practices applied, and direct outcomes.
Implementing Best Practices Across the Superfund Pipeline - EPA's optimization program
continues to apply and promote best practices to improve site
cleanup throughout the Superfund pipeline. In 2018, EPA
published three technical guides based on lessons learned
from the optimization program: Scoping Environmental
Investigations; Strategic Sampling Approaches, and Best
Practices for Data Management - to highlight best practices
as well as provide technical resources and references to
support the implementation of these best practices.
Technical Guides
Smart Scoping for
Environmental Investigations
Strategic Sampling Approaches
Best Practices for Data
Management
Key Results from Applying Best Practices - EPA
conducted a review of the recent optimization and technical
support evaluations, which highlighted six key results of the direct support provided during a technical
support project or that could result from implementing optimization recommendations. Those six are
shown below along with the percentage of the new optimization reviews and technical support
projects demonstrating that recommendation or outcome: (1) Improvements to Conceptual Site
Model: 87 percent, (2) Improved System Engineering: 45 percent, (3) Streamlined or Improved
Monitoring: 31 percent, (4) Change in Remedy Strategy: 32 percent, (5) Improved Site
Characterization Through Strategic Sampling: 35 percent, and (6) Improved Data Management: 30
percent. Project highlights included in this report demonstrate how the optimization program applies
and promotes best practices to improve site cleanup.
EXECUTIVE SUMMARY | ES-2
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Superfund Optimization Progress Report October 2020
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
recommendations2 (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 National
Strategy") (EPA, 2012b).
Optimization activities under the
National Strategy are conducted at
every phase of the Superfund
pipeline. In July 2017, EPA issued
the Superfund Task Force
Recommendations (EPA, 2017b),
which included Strategy 4: Use
Best Management Practices,
Systematic Planning, Remedy
Optimization, and Access to
Expert Technical Resources to
Expedite Remediation and
Recommendation 73, promoting
the use of third-party optimizations.
This Superfund Optimization Progress Report October 2020 summarizes EPA's progress on
Contents of Report
Executive Summary
Section 1.0 Introduction
1.1 Purpose and Scope
1.2 Optimization Program
Section 2.0 Summary of Progress on Expanding the
Optimization Program
Section 3.0 Summary of Recommendation
Implementation Progress
3.1 Overview of Progress
3.2 Evaluations and Sites Requiring No Further
Follow-up
3.3 Summary of Technical Support Activities
Section 4.0 Optimization Program and Best Practices
4.1 Key Results from Applying Best Practices
4.2 Promoting Best Practices through
Optimization
Section 5.0 Summary of Progress on Implementing the
National Optimization Strategy
Section 6.0 References
Appendix A. Progress on Implementing the National
Optimization Strategy
Appendix B. List of Completed Optimization and
Technical Support Evaluations FY 1997 - FY
2015
2 All previous Optimization Progress Reports can be found at https://www.epa.qov/superfund/cleanup-optimization-superfund-
sites#summarv
3 Superfund Task Force Report Recommendation 7: Promote Use of Third-Party Optimization Throughout the Remediation Process
and Focus Optimization on Complex Sites or Sites of Significant Public Interest
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Superfund Optimization Progress Report October 2020
implementing the elements of the overall National Strategy, the Superfund Task Force (Task Force)
recommendations, optimization recommendations for individual optimization reviews, and in
conducting optimization-related technical support projects.
The six main sections of this report are: Introduction (Section 1.0), including a discussion of the
purpose of the report and the optimization program; Summary of Progress on Expanding the
Optimization Program (Section 2.0), summarizing EPA's progress in implementing the National
Strategy; Summary of Implementation Progress (Section 3.0), including a summary of EPA's
progress in implementing optimization recommendations and a summary of technical support
activities; Optimization Program and Best Practices (Section 4.0), describing how the optimization
applies and promotes best practices; Summary of Progress on Implementing the National
Optimization Strategy (Section 5.0); and References (Section 6.0). Appendix A provides a detailed
discussion of EPA's progress on implementing the National Optimization Strategy. Appendix B lists
the optimization reviews and technical support projects completed through fiscal year (FY) 2017.
1.1 Purpose and Scope
The purpose of this report is to: (1) update site-specific recommendations resulting from independent
optimization reviews and optimization-related technical support projects; (2) describe how the
optimization program applies and promotes EPA's best technical practices for site cleanup; and (3)
provide a summary and analysis of the status of implementing the National Strategy and Task Force
recommendations.
This report summarizes optimization support conducted through the EPA Headquarters (EPA HQ)
optimization program. Similar work and technical support projects are conducted by other programs
and regions. That work is not included in the data and analysis provided here. Optimization reviews
and optimization-related technical support projects are collectively referred to in this report as
evaluations.
Optimization Reviews result in site-specific reports with recommendations that fall within one of five
categories: remedy effectiveness, cost reduction, technical improvement, site closure, and energy
and material efficiency. Starting one year after completing the optimization review, the optimization
team follows up with the site Remedial Project Manager (RPM) to determine the implementation
status of optimization recommendations for the site. The implementation status is then tracked, and
follow-up continues until all recommendations have been implemented, declined, or in some cases,
deferred to the state.
Optimization-Related Technical Support Projects generally provide direct site support to apply
optimization best practices. Technical support projects can be done at all stages of the Superfund
pipeline and may precede or follow an optimization review. Technical Support projects can include
developing a strategic sampling approach, conducting systematic project planning (SPP), 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). Tracking these technical support projects
captures efforts to optimize pre-remedial action stages of the cleanup process. It allows EPA to
report on the application of lessons learned from later-stage optimizations to earlier stages of the
cleanup process as described in the National Strategy. For optimization-related technical support
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projects, EPA tracks the start and end dates, remedial phase, scope of project, best practices
applied, and direct outcomes.
National Strategy and Superfund Task Force implementation includes programmatic activities of
planning, implementing, tracking, reporting on, and measuring progress of the optimization program.
The optimization program has contributed to EPA's effort to develop and promote best practices
related to scoping, sampling, and managing data. This report evaluates how implementing the
National Strategy and Task Force recommendations also achieves key results from applying best
practices and promotes the use of best practices.
This report presents project highlights showcasing sites where optimization and technical support
evaluations have had positive impacts. Identifying the positive results and lessons learned may be
beneficial to other sites.
This report focuses on the implementation of optimization recommendations from FY 2015 through
FY 2017. Information is provided on the implementation of recommendations for 40 reviews where
an optimization was performed since the last progress report and which are being reported on for the
first time (see Table 3 in Section 3.0). Status updates are also provided for 35 reviews where
implementation of recommendations has continued since the last progress report (see Table 4 in
Section 3.0). In addition to the 75 optimization reviews, this report includes information and analysis
on 58 optimization-related technical support projects completed since the last progress report.
Technical support projects are included in the Superfund phase analysis of new optimization and
technical support evaluations (see Figure 2) and in the analysis of key results achieved from
conducting optimization evaluations (see Figure 7). Highlights documenting how best practices were
applied during technical support projects are also included in the report. Most optimization and
technical support evaluations were conducted at sites on the National Priorities List (NPL); some
were conducted at non-NPL sites such as those from the Resource Conservation and Recovery Act
(RCRA) Corrective Action and Brownfields programs.
1.2 Optimization Program
Sites are selected for optimization reviews and technical support projects collaboratively, based on
input from EPA RPMs, regional management, Regional Optimization Liaisons (ROLs), EPA HQ staff
and managers, and stakeholders. The optimization teams consist of an EPA HQ lead, the ROL, and
a team of technically qualified individuals from within EPA, the U.S. Army Corps of Engineers
(USACE), or one of EPA's pool of contractors with the advanced qualifications and extensive
experience necessary to conduct the optimization review. The site teams generally consist 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:
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;
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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 or proposed site activities;
7) interest in applying innovative strategies or technologies;
8) not achieving the goals of the remedy as anticipated and wanting independent expertise to
assess cleanup progress, suggest changes in remedial approach, or evaluate proposed
changes from state or PRP;
9) exploring the opportunity to reduce monitoring points and costs;
10) a need to expedite the remediation time frame to allow for property redevelopment;
11) a need to reduce energy and effort and enhance efficiency; and
12) a need to develop or refine the site or remedy completion strategy.
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2.0 SUMMARY OF PROGRESS ON EXPANDING THE
OPTIMIZATION PROGRAM
Optimization reviews technical support projects are conducted at any phase of the Superfund
pipeline. Optimization 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 life-cycle CSMs and discussion of the overall site strategy are
valuable in assisting site teams in improving site remedy performance and progress, no matter the
phase of the Superfund pipeline. Figure 1 depicts the key components of optimization and the
remedial pipeline phases at which optimization can be applied.4 5
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 Management
SITE COMPLETION
Source: Adapted from EPA 2012b.
Figure 2 shows the Superfund phase of the new optimization and technical support evaluations. EPA
continues to expand optimization efforts across the Superfund pipeline. In the early years of the
optimization program, all optimizations were done in the remedial action or operation and
maintenance (O&M) phase of the Superfund pipeline. Currently 48 percent are completed in pre-
remedial action phases (preliminary assessment/site inspection [PA/SI], remedial
investigation/feasibility study [RI/FS], or remedial design), up from 35 percent in the previous
progress report (EPA, 2017a). Pre-remedial action phase support often involved providing direct
technical support focused on the application of optimization best practices.
4 See CFR, title 40, sec 300, Subpart E, for details regarding the phases of the Superfund pipeline
5 Information about the seven key components can be found at www.epa.aov/superfund/cleanup-ODtirnizaiion-superfund-sites
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Superfund Optimization Progress Report October 2020
Figure 2: Superfund Phase of New Optimization and Technical Support Evaluations
Number of Superfund Optimization Reviews and Technical Support Projects = 87
Remedial Action
34, 39%
Pre-Remedial
Action, 42, 48%
RI/FS, 31, 35%
Remedial Design,
6, 7%
PA/SI, 5, 6%
• 11 sites are not Superfund sites and are not included in the percentages reported in Figure 2.
• 18 long-term response action projects are included with remedial action.
Table 1 shows the workflow of optimization and technical support evaluations from FY 2011 through
FY 2017. The total number of optimizations supported per year has nearly doubled since the
implementation of the National Strategy.
Table 1: EPA Optimization and Technical Support Workflow
Fiscal Year
Started
Ongoing
Completed
Number of Optimization and
Technical Support Evaluations
Supported by OSRTI*
2011
21
14
12
35
2012
21
23
18
44
2013
27
26
27
53
2014
18
26
29
44
2015
27
15
14
42
2016
38
28
31
66
2017
34
35
24
69
* This column represents the number of evaluations started each fiscal year combined with the number of
evaluations ongoing from the previous fiscal years.
EPA has completed a total of 251 optimization and technical support evaluations from FY 1997
through FY 2017 (Table 2). A list of these optimization and technical support evaluations is provided
in Appendix B. From FY 1997 through FY 2011, EPA completed 108 optimization and technical
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support evaluations, averaging seven evaluations per year. From FY 2012 through FY 2017, with the
implementation of the National Strategy, EPA completed 143 optimization and technical support
evaluations, averaging 24 evaluations per year. Through implementation of the National Strategy,
EPA has more than tripled the number of optimization reviews and technical support projects it
completes each year. As a result, EPA has expanded the benefits from optimization and technical
support to a much larger universe of sites.
Table 2: Completed Optimization and Technical Support Evaluations FY 1997 - FY 2017
Region
Number of
Evaluations
1997-2014
Number of
Evaluations
2015-2017
Total
Evaluations
1997-2017
% of Total
Completions
1
17
13
30
12%
2
23
4
27
11%
3
23
4
27
11%
4
12
3
15
6%
5
15
2
17
7%
6
12
9
21
8%
7
19
3
22
9%
8
16
13
29
12%
9
24
7
31
12%
10
21
11
32
13%
TOTAL
182
69
251
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 continues to target
optimization reviews and technical support projects at certain types of sites, such as mining sites.
Starting in FY 2016, EPA began preparing consultation packages at mining sites. These consultation
packages evaluate planned remedial activities to be conducted at mining sites and provide
recommendations on ways to mitigate the risk of the release of mining-influenced water during
remedial activities. EPA has leveraged the expertise and independent perspective of the
optimization experts to support the consultation process. Technical Support projects detailed in this
report include 12 mining consultation packages.
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3.0 SUMMARY OF RECOMMENDATION
IMPLEMENTATION PROGRESS
A total of 75 optimization reviews are included in this report; 40 new optimization reviews (Table 3)
and 35 optimization reviews carried over from the previous progress report to provide
recommendation status updates (Table 4). The new evaluations focus on those completed in FY
2015 through FY 2017; however, some evaluations are included for the first time from earlier years if
information on implementation status was not yet available as of the writing of the last report. EPA
worked closely with regional staff including RPMs and ROLs to collect information on the status of
the recommendations for each of the 75 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.
Table 3: New Optimization Reviews Included in this Progress Report
FY
Complete
Total
State
Optimization Reviews
Pipeline Phase
Optimization
Reviews
Region 1
6
VT
Elizabeth Mine
2016
Remedial Action
VT
Jard Company
2017
RI/FS
Rl
Peterson/Puritan, Inc.
2016
O&M
Rl
Picillo Farm
2017
Remedial Action
NH
Somersworth Sanitary Landfill
2017
Remedial Action
MA
Sullivan's Ledge
2016
O&M
Region 2
1
NJ
Metaltec/Aerosystems
2015
Remedial Action
Region 3
4
DE
Dover Gas Light Co.
2015
RI/FS
PA
Hellertown Manufacturing Co.
2017
O&M
VA
Saunders Supply Co.
2016
O&M
Valmont TCE Site (Former - Valmont
PA
Industrial Park)
2016
Remedial Action
Region 4
1
NC
Charles Macon Lagoon and Drum
Storage
2016
Remedial Action
Region 5
2
Ml
Clare Water Supply
2017
O&M
OH
Lincoln Fields Coop Water Assn Duke
Well
2015
Remedial Action
Region 6
8
TX
Conroe Creosoting Co.
2015
Remedial Action
TX
Garland Creosoting
2017
Remedial Action
NM
McGaffey and Main Groundwater Plume
2015
Remedial Action
NM
North Railroad Avenue Plume
2015
Remedial Action
TX
Odessa Chromium #1
2016
O&M
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State
Optimization Reviews
FY
Complete
Pipeline Phase
Total
Optimization
Reviews
Region 6
(Continued)
AR Ouachita Nevada Wood Treater 2015 Remedial Action
TX
Sprague Road Ground Water Plume
2016
Remedial Action
TX
West County Road 112 Ground Water
2016
RI/FS
Region 7
2
NE
10th Street Site
2014
Remedial Action
NE
Parkview Well
2017
Remedial Action
Region 8
5
CO
Gold King Mine Release
2017
Not on NPL
MT
Idaho Pole Co.
2009
Remedial Action
MT
Idaho Pole Co.
2010
Remedial Action
MT
Lockwood Solvent Ground Water Plume
OU01
2014
Remedial Design
CO
Standard Mine
2016
Remedial Action
Region 9
4
NV
Carson River Mercury Site
2014
RI/FS
CA Klau/Buena Vista Mine 2017 RI/FS
CA
Lava Cap Mine
2017
Remedial Design
CA
Newmark Ground Water Contamination
2015
RI/FS
Region 10
7
Bunker Hill Mining & Metallurgical
ID Complex 2014 Remedial Design
ID
Bunker Hill Mining & Metallurgical
Complex
2016
Remedial Design
ID
Bunker Hill Mining & Metallurgical
Complex
2017
Remedial Action
OR
J.H. Baxter & Co.
2016
RCRA
AK
Kodiak USCG Integrated Support
Command Base
2015
RCRA
OR
Northwest Pipe & Casing/Hall Process
Company
2016
O&M
OR
Univar
2017
RCRA
TOTAL
40
• Long-term response actions are included with remedial actions.
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Table 4: Updated Optimization Reviews Included in this Progress Report
State
Optimization Reviews
FY
Complete
Optimization Focus
Total
Optimization
Reviews
Region 1
2
MA Baird & McGuire 2013 O&M
NH Ottati & Goss/Kingston Steel Drum
2014 O&M
Region 2
5
NY GCL Tie and Treating Inc.
2007 Remedial Action
NJ Metaltec/Aerosystems 2012 Remedial Action
NY Richardson Hill Road Landfill/Pond 2012 Remedial Action
NJ Rockaway Borough Well Field 2014 Remedial Action
NJ Vineland Chemical Co., Inc.
2011
Remedial Action
Region 3
4
PA Fischer & Porter Co.
2014
O&M
PA Mill Creek Dump
2010
O&M
PA North Penn - Area 6
2012
Remedial Action
VA Peck Iron and Metal
2013
RI/FS
Region 4
2
FL Alaric Area GW Plume
2010
Remedia
Action
NC Benfield Industries, Inc.
2007
Remedia
Action
Region 5
3
MN Baytown Township Ground Water Plume
2011
Remedia
Action
Wl Moss-American Co., Inc. (Kerr-McGee Oil Co.)
2011
Remedia
Action
Ml Wash King Laundry
2011
Remedia
Action
Region 6
6
TX East 67th Street Ground Water Plume
2014
Remedia
Design
NM Homestake Mining Co.
2011
Remedia
Action
TX Jones Road Ground Water Plume
2014
Remedia
Design
TX Sandy Beach Road Ground Water Plume
2014
Remedia
Design
TX State Road 114 Groundwater Plume
2014
Remedia
Action
OK Tar Creek (Ottawa County)
2014
Remedia
Action
Region 7
4
IA Fairfield Coal Gasification Plant
2012
Remedia
Action
NE Hastings Ground Water Contamination
2013
Remedia
Action
MO Lee Chemical
2012
O&M
MO Valley Park TCE
2013
Remedia
Action
Region 8
4
CO Central City, Clear Creek
2007
Remedia
Action
SD Gilt Edge Mine
2013
Remedia
Action
MT Lockwood Solvent Ground Water Plume OU02
2014
Remedia
Design
CO Standard Mine
2014
Remedia
Design
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Total
Optimization Focus Optimization
Reviews
Optimization Reviews
Complete
Region 9
CA Mew Study Area
CA Sulphur Bank Mercury Mine
Region 10
OR Black Butte Mine
WA Moses Lake Wellfield Contamination
2012 RI/FS
2015 RI/FS
2012 RI/FS
2015 RI/FS
2
3
Palermo Well Field Ground Water
WA Contamination
2012 Remedial Action
TOTAL
35
• Long-term response actions are included with remedial actions.
Section 3.1 summarizes the overall progress in implementing each of the recommendations and
describes the five recommendation categories. Section 3.2 lists the evaluations and sites that no
longer require follow up. Section 3.3 summarizes technical support projects conducted from FY 2015
through FY 2017 or substantially completed in 2018, which demonstrate the use of best practices.
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, among
other benefits. Site specific recommendations depend on the type of optimization review conducted
and the phase of the Superfund pipeline. Optimization reviews typically identify several opportunities
for improvements. These improvements are organized into five recommendation categories, remedy
effectiveness, cost reduction, technical improvement, site closure, and energy and material
efficiency. The number of recommendations in each category in relation to the total number of
recommendations for the new optimization reviews are shown in Figure 3. It is important to note that
recommendations were only counted in the primary category they represent but many
recommendations could be counted in multiple categories. For example, a recommendation could
both improve remedy effectiveness and move a site toward closure.
3.1 Overview of Progress
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Figure 3: Recommendations by Category
Total Number of Recommendations = 416
Energy & Material
Efficiency, 1, 0%
Site Closure,
\43,10%
r Cost >
Reduction,
42,10%
Remedy
Effectiveness,
224, 54%
Technical
Improvement,
106, 26%
Remedy Effectiveness - The majority of optimization recommendations (224 of the 416) fall into the
remedy effectiveness category.
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.
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. 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 put through initial tests
and improvements and 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
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usage, and reduced labor cost for maintaining or improving remedy performance. Further,
improvements in remedy effectiveness, movement toward site closure, or energy and material
efficiency can result in cost reduction or cost avoidance, but the benefits may not be as readily
quantified.
Examples of cost reduction recommendations include the following:
Automate systems to reduce labor costs.
Reduce project management costs by streamlining contractor management and addressing
technical issues to reduce oversight costs and needs for management of vendors.
Streamline monitoring to reduce laboratory and reporting costs.
Simplify treatment systems to reduce operating costs.
Reduce costs for supporting systems operations such as facility or road maintenance and
snow removal.
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 straightforward to implement, require minimal funding, and are not
typically contingent on other recommendations. 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.
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.
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 [Remedial Action Objectives] 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
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included addressing additional source material or residual subsurface contamination. Implementing
the Task Force recommendation to establish dynamic site strategies during RI/FS scoping and
throughout the RI/FS process, may move sites to closure more readily.
Examples of site closure recommendations include the following:
Further characterization of sources.
Targeted treatment of remaining sources.
Development of an exit strategy including performance metrics for determining achievement
of RAOs.
Energy and Material Efficiency - Optimization reviews continue to identify opportunities to
accelerate progress toward achieving energy and material efficiency and reductions in
environmental footprints.
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 also provides technical support conducting environmental footprint
analyses during the design-phase to identify energy and material efficiency best management
practices and to ensure remedy components are adaptively scaled when implemented.
Examples of energy and material efficiency 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.
As shown in Figure 4, completed optimization reviews for the 40 new optimization reviews included
in this report identified a total of 416 optimization recommendations6.
Overall, 67 percent of optimization recommendations have been implemented, are in progress, or
are planned, and another 21 percent are under consideration. Only 7 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 (3 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
2 percent of the recommendations, labeled as no status available. These results demonstrate that
6 Analysis conducted for all 1,565 recommendations tracked over the life of the optimization program showed that 68% of
recommendations have been implemented, are in progress or planned, 11% are under consideration, 13% were declined, 4% were
deferred to state or PRP and 4% have no status is available.
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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 4: Status of New Optimization Recommendations
Total Number of Recommendations = 416
No Status
Available, 8, 2%
Implemented,
133, 32%
Planned, 45, 11%
Declined 28, 7%
Deferred to State
or PRP, 12, 3%
Under
Consideration, 88,
21%
3.2 Evaluations 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 several 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 evaluations and sites, although
assistance is still available to site managers if any optimization-related issues arise:
Benfield Industries, Inc.
Black Butte Mine
Elizabeth Mine
Gilt Edge Mine
Idaho Pole Co. (2009)
Mill Creek Dump
Moss-American Co., Inc. (Kerr-McGee Oil Co.)
Newmark Ground Water Contamination
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North Penn - Area 6
Peck Iron and Metal
Picillo Farm
State Road 114 Groundwater Plume
Valley Park TCE
Wash King Laundry
Previous progress reports identified 50 evaluations and sites that no longer require implementation
tracking, for a total of 64 evaluations and sites that have successfully completed the follow-up
process since it began as a result of the Action Plan in 2004.
3.3 Summary of Technical Support Projects
In addition to formal optimization reviews, EPA provides technical support that results in optimization
principles being applied more broadly. Optimization-related technical support projects included in
this report are specific to projects conducted as part of the EPA HQ optimization program. Projects
can occur in early phases of the Superfund pipeline before there is a full remedial system operating,
or later in the pipeline to support specific actions such as further source identification or plume
delineation. Technical support projects may be conducted as a follow-on support to an optimization
review. Technical support projects frequently involve collaboration among RPMs, Hydrogeologists,
Risk Assessors, Chemists, and their State and Tribal counterparts.
Technical support projects incorporate best practices such as systematic project planning,
preliminary scoping, demonstrations of method applicability (DMAs), strategic sampling design, high-
resolution site characterization (HRSC), CSM development, mapping and three-dimensional
visualization and analysis (3DVA), and advanced data management techniques. Activities can
include comprehensive project planning, and management and implementation activities which are
intended to help move projects forward and improve site decision-making. Technical support
projects frequently develop products for the site team such as work plans, quality assurance project
plans, decision logic diagrams, sampling designs and technical memos.
Often a technical support project can integrate multiple best practices at a single site. For example, a
technical support project at the Carson River Mercury Site in Region 9 included a DMA to determine
if a field portable x-ray fluorescence (XRF) instrument could be used in conjunction with incremental
sampling to characterize mercury contamination in shallow soil. After the DMA was completed, EPA
HQ facilitated a three-day SPP meeting that helped the EPA Region and State site teams plan and
implement an incremental sampling pilot study.
Table 5 lists the technical support projects included in the report. The technical support efforts
included were conducted from FY 2015 through FY 2017 or substantially completed in FY 2018 and
demonstrated best management practices.
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Table 5: Completed Technical Support Projects
FY
Complete
Total
State
Technical Support Projects
Optimization
Evaluations
Region 1
10
MA
Baird & McGuire
2018
MA
BJAT LLC
2016
ME
Callahan Mining Corp
2018
CT
Century Brass
2019
MA
Charles George Reclamation Trust Landfill
2017
VT
Elizabeth Mine
2016
VT
Ely Copper Mine
2017
VT
Ely Copper Mine
2017
VT
Jard Company
MA
Sullivan's Ledge
2016
Region 2
5
NY
Crown Cleaners of Watertown Inc.
2018
NY
Eighteen Mile Creek
2016
NJ
PUCHACK WELL FIELD
NJ
Sherwin-Williams/Hilliards Creek
2017
NJ
Unimatic Manufacturing Corp Site
2016
Region 3
2
PA
Clearview Landfill
2019
VA
Saunders Supply Co.
2018
Region 4
3
MS
Mississippi Phosphates Corporation
2016
MS
Mississippi Phosphates Corporation
2016
NC
Ore Knob Mine
2018
Region 5
1
IL
Heart of Chicago
2018
Region 6
4
AR
Arkwood, Inc.
2016
NM
Jackpile-Paguate Uranium Mine
OK
Oklahoma Refining Co.
OK
Wilcox Oil Company
2019
Region 7
3
MO
Big River Mine Tailings/St. Joe Minerals Corp.
2016
NE
PCE Southeast Contamination
Washington County Lead District - Furnace
2018
MO
Creek
2016
Region 8
16
CO
American Tunnel Mine
2017
CO
Bonita Peak Mining District
2017
CO
Captain Jack Mill
2016
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Superfund Optimization Progress Report October 2020
FY
Complete
Total
State
Technical Support Projects
Optimization
Evaluations
Region 8
(Continued)
CO
Colorado Smelter
2018
CO
French Gulch
CO
Gold King Mine Release
2016
CO
Gold King Mine Release
2017
CO
Gold King Mine Release
2018
MT
Idaho Pole Co.
2018
CO
Lowry Landfill
2018
CO
Lowry Landfill
2016
CO
Marshall Landfill
2018
CO
Nelson Tunnel/Commodore Waste Rock
2018
CO
Rico - Argentine
2016
CO
Standard Mine
2016
CO
Vasquez Boulevard And 1-70, OU3
2017
Region 9
12
NV
Carson River Mercury Site
2017
NV
Carson River Mercury Site
CA
Central Basin
AZ
Cove Mesa Aggregated Uranium Mines
2018
AZ
Cove Mesa Aggregated Uranium Mines
2019
CA
DTSC Brownfields Support
2018
CA
McCormick & Baxter Creosoting Co.
2017
CA
Montrose Chemical Corp./Del Amo
CA
Newmark Ground Water Contamination
2016
CA
Newmark Ground Water Contamination
CA
Orange County North Basin
CA
Selma Treating Co.
2018
Region 10
2
ID
Bunker Hill Mining & Metallurgical Complex
2017
ID
Eastern Michaud Flats Contamination
2017
TOTAL
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4.0 OPTIMIZATION PROGRAM AND BEST PRACTICES
EPA's understanding of best management practices for site characterization has grown through
implementation of the Agency's 2012 Superfund National
Optimization Strategy, the Superfund Task Force
recommendations (EPA, 2017b)7, interaction with state and
industry leaders, engagement in EPA's Lean Management
System (ELMS), and other relevant activities. EPA synthesized
the lessons learned from conducting over 300 optimization
reviews and technical support projects into three technical guides:
Smart Scoping for Environmental investigations, Strategic
Sampling Approaches, and Best Practices for Data Management8
(EPA, 2018b, 2018c, and 2018d). The guides were issued in
November of 2018 and highlight these BMPs to help focus and
streamline the site characterization process by presenting more
efficient scoping, investigation, and data management
approaches. The streamlining of these activities may reduce both time and costs during the RI/FS
phase and throughout the Superfund process. EPA intends for the guides to strengthen Superfund
site characterization activities, facilitate stronger site remedy decisions, and improve remedy
performance.
The best practices identified in the technical guides work together to evolve the CSM and improve
the efficiency of site characterization and cleanup (Figure 5). Evolving the CSM over the site's life
cycle results in better, more defensible site decisions and improved remedy performance.
Figure 5: Best Practices and the Conceptual Site Model
Lessons learned through
the Superfund Optimization
program informed the
development of three
technical guides: Smart
Scoping for Environmental
Investigations, Strategic
Sampling Approaches, and
Best Practices for Data
Management
Strategic
Sampling
Smart
Scoping
Data
Management
7 https://www.epa.aov/sites/production/files/2017-07/documents/superfund task force report.pdf
8 Smart Scoping for Environmental Investigations Technical Guide: https://semspub.epa.gOv/src/documerrt/11/100001799: Strategic
Sampling Approaches Technical Guide: https://semspub.epa.gov/src/document/11/10000180Q: Best Practices for Data
Management Technical Guide: https://semspub.epa.g0v/src/d0cument/l 1/100001798
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Optimization is itself a best practice that encourages site teams to improve all activities conducted to
characterize and remediate sites. Under the optimization program, optimization reviews typically
recommend best practices that the site team can subsequently apply, such as recommending
additional contaminant source definition, while technical support projects typically assist site teams
with using specific best practices, such as conducting SPP.
Smart Scoping - The smart scoping technical guide (EPA, 2018b) describes the use of smart
scoping practices during any phase of a Superfund remedial investigation's project life cycle or in
accordance with other similar federal, state, or tribal regulatory authorities. Use of these practices
can support the development of a robust CSM, which, in turn, helps improve response action
development, selection, and implementation. Smart
scoping integrates adaptive management approaches
and scoping and prioritization of site characterization
activities. Adaptive management is an approach EPA is
expanding to help ensure informed decision-making is
coupled with the efficient expenditure of limited resources
throughout the remedial process.
Adaptive Management is an
approach particularly useful at large
or complex sites that focuses limited
resources on making informed
decisions throughout the remedial
process. Adaptive management
requires the development of a clear
site strategy with measurable
decision points and focuses site
decision-making on a sound
understanding of site conditions and
uncertainties. Based on site
uncertainties, decisions are made
from data collection to remedy
selection and implementation that
allow for the ability to adapt if these
uncertainties result in fundamental
changes to site conditions.
The smart scoping technical guide identifies the following
best practices:
Project life cycle conceptual site model
Comprehensive team formation
Systematic project planning
Dynamic work strategies
High-resolution and real-time measurement
Technologies
Use of collaborative data and multiple lines of
evidence
Stakeholder outreach
Demonstration of method applicability
Data management and communication
Three-dimensional visualization and analysis
Optimization
Smart scoping focuses on a complete CSM with all its components and the elements under each
component (Figure 6). In 2020, EPA issued a new fact sheet on using a structured scoping approach
for EPA-lead RI/FS projects. The new fact sheet includes a preliminary scoping step aimed at
producing important site planning documents, such as the CSM. (EPA 2020)9
9 Add link to RI/FS Scoping document
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Figure 6: Conceptual Site Model Components
Screening Levels
Action Levels
Field Decision Levels
Cleanup Levels
Current use
Surrounding Use
Reuse Assessment
Local Input
^Media/COC Interactions
Sources
5ources
Release Mechanisms
Migration Pathways
Receptors
Exposure Routes
Soil
Groundwater
Sediment
Surface Water
Air
Inspections
Enforcement Actions
Investigations
Local Complaints
Releases
Sampling Data
^Cleanup Actions
Characterization
Treatability Studies
Design
Remediation
Monitoring
Chemicals Used
Known Disposal
Releases
Facility Type
Operations
Permits
V Ownership
\
Site Strategy Status:
Operable Units
Early Actions
Priorities & Phases
Contingency Plans
Site
Strategic Sampling Approaches - The strategic sampling technical guide (EPA, 2018c) assists
environmental professionals in identifying where strategic sampling approaches may benefit data
collection activities at their project or site and what sampling approach may be most effective given
site conditions. Strategic sampling is broadly defined as the application of focused data collection
across targeted areas of the CSM to provide the appropriate amount and type of information needed
for decision-making. Strategic sampling throughout a project's life cycle may help inform the
evaluation of remedial alternatives or a selected remedy's design, improve remedy performance,
conserve resources, and optimize project schedules. In addition, strategic sampling approaches
assist with source definition and identify unique contaminant migration pathways, such as the vapor
intrusion pathway.
The strategic sampling approaches technical guide identifies the following sampling approaches as
best practices when site conditions allow their use:
¦ High-resolution site characterization in unconsolidated environments
¦ High-resolution site characterization in fractured sedimentary rock environments
¦ Incremental sampling
¦ Contaminant source definition
¦ Passive groundwater sampling
¦ Passive sampling for surface water and sediment
¦ Groundwater to surface water interaction
¦ Vapor intrusion
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Data Management - The data management technical guide (EPA, 2018d) provides best practices
for efficiently managing the large amount of data generated throughout the project life cycle.
Thorough, up-front RI/FS planning and scoping combined with decision support tools and
visualization can help reduce RI/FS cost and provide a more complete CSM earlier in the process. In
addition, good data management practices, including robust management of data, meta data, and
data quality, established during RI/FS can:
¦ Assist and streamline data management during subsequent phases of the remedial process
(remedial design/remedial action and post construction).
¦ Improve data quality and usability of data generated throughout all phases of the Superfund
pipeline.
¦ Enhance the accessibility of information needed to inform defensible decision making.
The data management technical guide identifies best practices for: planning for data collection and
processing; collecting data; processing data; storing data; making decisions using data; and
communicating data.
The following sections discuss the optimization program and best practices. Section 4.1 quantifies
six key results site teams have achieved by applying recommended best practices. Section 4.1 also
includes project highlights for three key results. Section 4.2 uses project highlights from site-specific
optimization reviews and technical support projects to demonstrate how the optimization program
promotes best practices.
4.1 Key Results from Applying Best Practices
EPA has identified key results achieved by site teams when they applied best practices directly
during technical support projects or results expected by implementing recommendations from
optimization reviews. The key results analyzed are (1) CSM improvements, (2) improved system
engineering, (3) streamlined or improved monitoring, (4) change in remedy approach, (5) improved
site characterization through strategic sampling, and (6) improved data management.
The first four key results are related to the CSM and smart scoping best practices. The last two key
results, while related to smart scoping, are discussed in their own technical guide. A comprehensive
CSM has eight components and multiple elements under each component, many of which are
difficult to quantify. The first key result (CSM improvements) quantifies general CSM improvements
identified in the optimization recommendations. The next three key results (improved system
engineering, streamlined or improved monitoring, and change in remedial approach) address
elements of the Technologies and Approaches component of the CSM (see Figure 6) that are
important to EPA. Improved system engineering includes modifying one or more engineered
components of a remedial system to improve overall system performance. Improved system
engineering can include adaptively-scaling remedies. Smart scoping, strategic sampling approaches,
CSM improvement, and improved data management can facilitate adaptively-scaling remedies.
Streamlined or improved monitoring involves adjustments to monitoring frequency, monitoring
locations, and chemicals of concern analyzed as well as the analysis of monitoring results over time.
Streamlined or improved monitoring also addresses data management practices. Changes in
remedial approach include adding or changing remedies to better address remaining contamination
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or newly identified areas of contamination. The recommendations result in improved remedy
effectiveness, cost reductions, and the achievement of site closure in a shorter period of time.
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 HRSC10 for groundwater and incremental sampling11 for
contaminated soil for improved characterization of source volumes and locations. Aspects of
improved data management include improving data management planning, data acquisition, data
processing, data analysis, data preservation and storage, and data publication and sharing.
Figure 7 shows the number of new optimization reviews and technical support projects that achieved
or can achieve each of the key results. Each optimization review or technical support evaluation may
have more than one key result.
Figure 7. Key Results Achieved Through New Optimization and Technical Support
Evaluations
Total Number of Optimization and Technical Support Evaluations = 98
o
Q.
Q.
C .2
.2 %
ro
.1 >3
4-1
Q.
O
_Q
E
100
90
80
70
60
50
40
30
20
10
0
87%
58
45%
31%
32%
35%
10
30%
¦ 5l
24
24
CSM
Improvements
Improved
System
Engineering
Streamlined or
Improved
Monitoring
Change in
Remedial
Approach
Improved Site Improved Data
Characterization Management
Through
Strategic
Sampling
i Optimizations ¦ Technical Supports
Project highlights are provided for these key results according to the best practice they are
associated with in Section 4.2.1 Smart Scoping, 4.2.2 Strategic Sampling, and 4.2.3 Data
Management.
4.2 Promoting Best Practices Through Optimization
EPA promotes the use and development of best practices through the optimization program. This
section is organized by technical guide and provides optimization and technical support project
10 More information on HRSC can be found here: https://clu-in.org/characterization/technoloaies/hrsc/index.cfm
11 More information on Incremental Sampling can be found here: https://www.itrcweb.org/Team/Public?teamlD=11
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highlights for implementation of the smart scoping, strategic sampling, and data management best
practices.
4.2.1 Smart Scoping
The Smart Scoping for Environmental Investigations Technical Guide (EPA, 2018b) describes the
use of "smart scoping" practices during any phase of a Superfund site's project life cycle. These
same practices can be applied to any site remediation. Use of these practices can support the
development of a robust CSM, which, in turn, helps improve response action development,
selection, and implementation.
Focus on Smart Scoping Best Practices
With the goal of developing and maintaining a robust
CSM, smart scoping encourages both consideration of
proven Superfund site strategies and the upfront
commitment of time and resources. It also anticipates
the use of best practices ortried-and-true strategies for
cleanup of sites with similar contamination profiles.
Smart scoping highlights the importance of: (1)
participation by and input from RPMs, technical
experts, risk managers, and other stakeholders; (2)
establishing appropriate current and future land and
groundwater resource use assumptions; (3) the
appropriate design and use of human health and
ecological risk assessments (including collection of
appropriate information on natural or anthropogenic
"background" and contaminant bioavailability); (4)
leveraging in-house expertise (in lieu of contractor
support); (5) considering the appropriate use of early or
interim actions as a component of strategic site
planning; and (6) highlighting sites which may benefit
from the use of a structured adaptive management project or site management process.
Smart scoping best practices implemented at sites covered in this report include project life cycle
CSM, SPP, dynamic work strategies and adaptive management, DMA, HRSC, and 3DVA.
Project Life-Cycle Conceptual Site Model
The EPA identified six stages of the project life cycle CSM including: Preliminary, Baseline,
Characterization, Design, Remediation/Mitigation, and Post-Remedy. Each of these stages is a
representation of the CSM as it evolves through defined states of both maturity and purpose over a
project's life cycle.
The EPA has identified eight components that constitute a comprehensive CSM (Figure 6). A
comprehensive CSM is not "one" thing but is comprised of several important elements that should be
considered to move the project forward to completion. A comprehensive CSM addresses all eight
components and multiple elements within each component.
Smart Scoping highlights the
importance of:
Participation by and input from
technical experts and
stakeholders.
Understanding current and future
land and groundwater resource
use.
The appropriate design and use
of human health and ecological
risk assessments.
Leveraging in-house expertise.
Appropriate use of early or
interim actions.
Identifying sites which may
benefit from an adaptive
management process.
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The EPA has found that the most effective investigations use a comprehensive CSM that addresses
all elements of the project. Many CSM components are related to and affected by each other. For
example, contaminant mass and distribution in the subsurface is greatly affected by the site-specific
geology and the capacity of the aquifer to store and transport contaminants. The media component
relates to the pathway-receptor network, technologies and approaches, and decision criteria
components. Understanding the relationship between hydrogeology and the other CSM components
can be especially important at sites with complex geology (e.g., fractured rock or intermixed gravels/
sands/silts/clays) where contaminant sources may occupy only a small area of the subsurface and
flow occurs through thin zones. Under the CSM component Media and Transport, environmental
sequence stratigraphy (ESS) applies geologic principles in these settings to help improve the
understanding of groundwater flow and contaminant distribution and develop more effective
remediation strategies. ESS refers to the application of both the concepts of sequence stratigraphy
and fades models12 to the types of datasets collected for environmental groundwater investigations,
which are typically at the outcrop scale (tens to hundreds of feet vertically, hundreds to thousands of
feet laterally) (EPA, 2017c). The application of ESS to contaminated groundwater sites can be
broadly subdivided into three general phases:
¦ Phase 1 - Synthesize the geologic and depositional setting based on regional geologic work
and identify fades models which are applicable to the site.
¦ Phase 2 - Review the existing CSM and site lithology data in light of Phase 1 findings and
format existing lithology data to highlight vertical grain-size patterns (sequences) as a basis
for correlations honoring stratigraphic "rules of thumb."
¦ Phase 3 - Construct a hydrostratigraphic CSM consisting of maps and cross sections that
depict the hydrostratigraphic units present as a basis to integrate and interrogate
hydrogeology (e.g., water levels, pump test, slug test) and chemistry data (e.g., constituents,
concentrations).
12 Fades Model: Conceptual construct describing the processes acting in a particular depositional environment to transport, deposit,
and preserve sediment, usually presented as a three-dimensional block diagram illustrating the organization of sedimentary bodies
in the stratigraphic record (EPA, 2017c).
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Superfund Optimization Progress Report October 2020
McCormick & Baxter Creosoting Co. Superfund Site - Highlight Summary
Phase
Challenge
Tool/Analysis
Recommendations
Outcomes
• Improve
• Environmental
• Vertical transport of
• CSM Improvements
understanding
Sequence
NAPL occurs through
• Change in Remedial
of media and
Stratigraphy
thick channel sands,
Approach
transport
and permeability
enhancement
• Permeable zones are
• Cost Reduction
• Improved Data
Management
Remedial
Design
relatively narrow and
often truncated on the
ends by abrupt change
to silt/clay
• Large scale horizontal
contaminant transport
appears to be limited
to within the channel
sands
ESS technical support was provided for the McCormick & Baxter Creosoting Co. Superfund Site
in Stockton, California in Region 9. Data for the investigation, including cone penetrometer (CPT),
boring and geophysical logs, water level data, Laser Induced Fluorescence logs, and AutoCAD
maps of the Site were provided by the EPA Region 9 Site Team. CPT logs from a total of 49
boreholes across the site were utilized in conjunction with borehole information from those locations.
Four detailed cross sections were produced utilizing the 49 CPT logs and a sequence stratigraphic
correlation approach was chosen to identify the hydrostratigraphic units based on relative
permeability inferred from grain size. Permeable hydrostratigraphic units were interpreted as
individual or stacked fluvial channel bars and splay/overbank deposits embedded within thick
sequences of clay and silt.
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The McCormick & Baxter Creosoting Co. ESS team concluded that while the channel bars indicated
the highest porosity-permeability, and therefore the highest potential for contaminant transport, they
were often truncated and discontinuous and limited the horizontal transport of contaminants and
non-aqueous phase liquid (NAPL). The team also concluded that NAPL was non-mobile and the
likelihood of offsite transport in the deeper zone was low. The site team used the updated CSM to
consider more cost-effective remedies that did not require large scale treatment or removal of NAPL
from discontinuous stream channels.
Improved system engineering includes modifying one or more engineered components of a
remedial system to improve overall system performance. Improved system engineering can include
adaptively scaling remedies or 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 adaptively-scaling remedies.
Univar RCRA Site -
Highlight Summary
Phase
Challenge
Tool/Analysis
Recommendation
Outcomes
Corrective
Action
• Insufficient
progress
• Inefficient P&T
• Statistical analysis
of groundwater
data using the
Monitoring and
Remediation
Optimization
System software
• Prioritize extraction of
high flow rate wells to
increase mass
extraction
• Optimize air to water
settings of the
extraction system
• Determine impact of
SVE on groundwater
flow patterns
• CSM Improvements
• Improved System
Engineering
An optimization evaluation was conducted at the Univar RCRA Site in Portland Oregon in 2017.
The Univar facility is an active chemical distribution facility within a heavily industrialized area
northwest of downtown Portland. Univar operations have included packaging, storage, and
distribution of bulk chemicals since 1947. Releases over the years have resulted in chlorinated
volatile organic compounds (VOCs) contamination in soil and groundwater, including trichloroethene
(TCE), 1,1,1-trichloroethane (1,1,1-TCA), and tetrachloroethene (PCE). Other non-chlorinated
contaminants of concern (COCs) include benzene, toluene, ethylbenzene, and xylenes. Univar has
constructed and implemented Interim Corrective Measure (ICMs) that include groundwater
extraction, soil vapor extraction (SVE), a VOC water treatment system, a VOC vapor treatment
system, and NAPL recovery.
The optimization review team recommended prioritizing the transition of groundwater extraction from
two extraction wells that were removing very low contaminant mass due to low flow rates to wells
with higher flow rates. The Univar site team implemented this recommendation and reported
increased mass extraction from one of the extraction wells and is investigating what optimal air to
water settings are needed in order to handle the increased contaminant load from the well so that
they can maintain National Pollutant Discharge Elimination System (NPDES) permit compliance.
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The optimization review team also recommended that current extraction wells, future extraction
wells, and several monitoring wells with elevated concentrations of 1,1,1-TCA be analyzed at least
one time for 1,4-dioxane, using EPA method 8270 (or 8270 SIM) to achieve a detection limit of 2
micrograms per liter. The objective was to determine if 1,4-dioxane is present in groundwater as a
potential COC and evaluate the potential for the air stripper influent or effluent to be impacted by 1,4-
dioxane (currently or in the future). This recommendation was implemented, and the site team
confirmed that 1,4-dioxane is present and is passing through the treatment system in relatively low
concentrations. The team is working with the risk assessor to determine what concentration should
be allowed in treated effluent and working with Oregon Department of Environmental Quality on the
NPDES permit renewal.
Other recommendations that are in progress include determining if SVE is impacting groundwater
flow patterns, evaluating tidal influence on groundwater, delineating source areas, and updating the
CSM before moving forward with the corrective measure study.
Streamlined or improved monitoring recommendations involve adjustments to monitoring
frequency, monitoring locations, and chemicals of concern analyzed as well as the analysis of
monitoring results overtime. Streamlined or improved monitoring also addresses data management
practices.
Peterson/Puritan, Inc. Superfund Site -Highlight Summary
Phase
Challenge
Tool/Analysis
Recommendation
Outcomes
• Large monitoring
• Statistical analysis
• Develop source
• CSM Improvements
network with
of groundwater
investigation plan
• Streamlined and
unknown
data using MAROS
addressing source
Improved Monitoring
efficiency
tool
containment and mass
O&M
• Incomplete
reduction, and plume
source
stability
characterization
• Additional source
characterization,
synoptic well sampling
A 2016 optimization evaluation was conducted at Peterson/Puritan Inc. Superfund Site, located in
an industrial area within the towns of Cumberland and Lincoln, Rhode Island in EPA Region 1. This
optimization review focused on remedial activities in operable unit (OU) 01, including the source,
downgradient and former Quinnville Wellfield areas. As a result of industrial activities, groundwater
in the shallow and bedrock aquifers has become contaminated with VOCs. Priority contaminants in
groundwater include PCE and TOE and degradation products cis-1,2-dichloroethene and vinyl
chloride. Contamination has likely diffused into fractured bedrock and fine-grained sediments,
creating the conditions for long-term, low-level release of contaminants through slow desorption. To
support development of an optimized groundwater monitoring network, groundwater data were
evaluated by the optimization team using the Monitoring and Remediation Optimization System
(MAROS) software. Statistical results from the MAROS analysis, along with an evaluation of priority
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Superfund Optimization Progress Report October 2020
monitoring objectives, were used to recommend an optimized groundwater monitoring strategy for
the source and downgradient areas of the plume.
Recommendations to streamline and improve monitoring
included using the existing groundwater monitoring
network to better characterize the remaining source. After
the optimization evaluation, the existing groundwater
network was sampled, and the results were used to inform
the Source Investigation Plan.
The site monitoring plan was modified to accommodate
specific groundwater monitoring objectives identified by
the optimization team for long-term site management. The
modifications include providing data to:
¦ demonstrate source mass containment and mass
reduction;
¦ demonstrate potential downgradient plume
stability, migration, or natural attenuation;
¦ delineate the plume extent above cleanup goals;
¦ support estimates of time to cleanup; and
¦ demonstrate remedy protectiveness and attainment of cleanup goals.
Additional recommendations that were incorporated after the optimization evaluation include a
source characterization sampling plan, routine monitoring for source containment and source
attenuation, downgradient plume monitoring, and adding wells for synoptic water level
measurements.
A change in remedial approach includes 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.
Jones Road Ground Water Plume Superfund Site - Highlight Summary
Phase
Challenge
Tool/Analysis
Recommendation
Outcomes
Design
• Large and
complex site
• Improve CSM,
characterize
downgradient
Lower Chicot
water-bearing
zone, delineate
shallow water-
bearing zone
• Aggressive source
treatment
• Phased remedial
approach using SVE, in
situ bioremediation
• CSM improvements
• Change in remedial
approach from large P&T
system to aggressive
source control and
smaller P&T system
phased in as needed
• Remedy performance
monitoring
Monitoring recommendations for
Peterson/Puritan Inc. OU01, from June
2016 Optimization Review. Appendix C
Monitoring Optimization Results. Figure
C.2
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Superfund Optimization Progress Report October 2020
A 2014 optimization evaluation at the Jones Road Ground Water Plume Superfund Site in Region
6 led to changes in the site's remedial strategy. A dry-cleaning facility operated at the site between
1988 and 2002 in a small shopping center in an area of mixed commercial and residential land use.
Releases of chlorinated VOCs from improper disposal of dry-cleaning solvents migrated vertically
downward through the unsaturated zone to perched water and lower aquifers, where multiple private
water supply wells were and are presently located. The 2010 Record of Decision (ROD) had
selected installation of two P&T systems for the shallow source area soil, the Shallow Water-Bearing
Zone (WBZ) and the Deep Chicot Aquifer; in situ chemical oxidation (ISCO) for shallow source area
soil and the Shallow WBZ; and bioaugmentation for the Deep Chicot Aquifer.
The August 2014 optimization review recommended that the remedial action (1) prioritize the source
mitigation of two zones of soil vapor-phase contaminants (the shallow source area soil and the Deep
Unsaturated Chicot Sand) that are contributing to the Deep Chicot Aquifer contamination, and (2)
initiate the in situ bioremediation (ISB) of the Shallow WBZ, the third source contributing to the
deeper migration of contaminants. The Optimization Review concluded that addressing the
continuing sources of contaminants to the dissolved phase groundwater will be more cost-effective
at this time, with long-ranging benefits overtime.
Recommendations included using a phased remedial approach to include aggressive source
treatment to reduce VOC discharge to the Deep Chicot Aquifer, supporting aquifer restoration in the
lower plume by installing an SVE system in the Deep Unsaturated Chicot Sand Unit, and pilot testing
an SVE system for the shallow source area soil, installing a full system if successful. As the
overlying active vapor-phase contaminant sources are eliminated, it will decrease the impacts to
underlying groundwater contaminant concentrations overtime. Recommendations included related
groundwater monitoring to establish that source reduction was achieving predicted contaminant
decreases in both the Shallow WBZ and the Deep Chicot Aquifer.
ISB was initiated in January 2016 with the injection of amendments to support enhanced reductive
dechlorination to degrade the Site contaminants. This was followed up by hot spot treatments in
March 2018. Groundwater monitoring results from the sampling done in May and November 2018 in
the shallow wells show significant declines in the contaminant levels since ISB injections began in
January 2016. Additional groundwater sampling conducted in June 2019 and January 2020 continue
to show a significant decline except for one well from the January 2020 sampling results. This well is
currently being evaluated and addressed. Construction on the SVE system began in April 2019, and
operations began in July 2019.
As more groundwater monitoring data becomes available and the extent of contamination is refined
further, the need for a P&T remedy to contain the migration of groundwater contaminants will be
evaluated at that time.
Systematic Project Planning
SPP is an efficient method for comprehensive planning, design, and implementation for all stages of
hazardous waste site investigation and cleanup projects; it also supports the iterative decision-
making process (i.e. learning by doing) established in adaptive management plans. SPP is a
process that lays a scientifically defensible foundation for proposed project activities. It usually
includes identification of key decisions to be made, the development of a CSM in support of
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decision-making, and an evaluation of decision uncertainty along with approaches for managing that
uncertainty in the context of the CSM.
SPP meetings were held to develop planning and design goals for the Saunders Supply Co.
Superfund Site and Selma Pressure Treating Superfund Site and prior to fieldwork at the Wilcox
Oil Company Superfund Site and Carson River Mercury Site Superfund Site. The overall goal of
an SPP Meeting is to gather all of the sites stakeholders for a multi-day meeting to discuss and
review the CSM, address technical issues, and develop steps forward, including future site
investigations, data quality objectives (DQOs), and an exit strategy towards site closure.
Saunders Supply Co. Superfund Site - Highlight Summary
Phase
Challenge
Tool/Analysis
Recommendation
Outcomes
O&M
• Insufficient
progress
• Improve CSM,
additional
characterization of
source and
downgradient
plume areas
• Establish
completion criteria
• Delineate current
extent of potential
source and
groundwater
contamination
• Update CSM with
HRSC
• Improve treatment
system capacity
• CSM Improvements
• Improved System
Engineering
• Use of Strategic Sampling
In 2016, an optimization evaluation was performed at the Saunders Supply Superfund Site. The
Optimization Team recommended additional
characterization in the source area,
downgradient plume, and a nearby stream and
pond using HRSC. The team also recommended
improvements to the P&T system, performance
monitoring, and establishing remedy operation
completion criteria. To help plan the
implementation of some of the recommendations
from the 2016 Optimization, an SPP meeting was
held for the Saunders Supply Site.
Representatives from EPA HQ, EPA Region 3,
and the state of Virginia participated in a two-day meeting that culminated in a work plan geared
towards moving the site towards closure. The participants agreed on the CSM, data gaps, and data
to be collected to fill the data gaps. EPA Region 3 and Virginia Department of Environmental Quality
have planned the additional characterization activities and are identifying funding to carry out the
actions.
Dynamic Work Strategies
Design and implementation of dynamic work strategies applies to contaminated site characterization,
remediation, or monitoring (or a combination thereof) and includes built-in flexibility guided by a pre-
approved decision logic. As information is gathered, it is used to adapt the specific activities in real-
time so that subsequent activities will best resolve remaining data and decision uncertainties. The
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Superfund Optimization Progress Report October 2020
goal is to evolve the CSM and complete remedial actions in as few mobilizations as feasible while
providing flexibility for field teams and decision-makers to address site realities or unexpected
features during these field activities. All planned work activities are described in written work plans
appropriate to program oversight.
Wilcox Oil Company Superfund Site - Highlight Summary
Phase
Challenge
Tool/Analysis
Recommendation
Outcomes
RI/FS
• Planning for site
characterization
and site
management
• Dynamic work
strategy
• Real-time
measurement using
XRF
• Incremental
sampling
• HRSC
• Decide on location of
next samples using
results of samples
collected earlier
• Update CSM as
samples are processed
• CSM Improvements
• Use of Strategic Sampling
• Improved Data
Management
A dynamic work strategy was applied during the real-time analysis and incremental sampling
technical support at the Wilcox Oil Company Superfund Site in Bristow, Oklahoma. The goal of
the project was to quantify lead concentrations in
surface (0 to 6 inches) and subsurface (6 to 24
inches) soil at two separate processing areas with
different release mechanisms. Incremental composite
soil sampling was used to produce a robust,
statistically confident mean concentration of lead
over a defined area and soil depth. The sample
design optimized sample scale and coverage to
provide high-resolution delineation of soil based on
the 200 parts per million (ppm) action level. XRF data
provided real time results to support decision making.
This dynamic work strategy allowed the field team to
decide on the location of the next sample based on
the results of samples collected earlier in the day or week. Because statistically significant data were
being generated in real-time, the field team was able to update the CSM as samples were processed
and analyzed and adjust the sampling design to address newly identified source areas.
Although definitive 200 ppm boundaries could not be identified at the two study areas, the data
collected during this adaptive sampling program led to real-time revision of the preliminary CSM. The
revised CSM recognizes that high levels of lead contamination exist throughout the Wilcox area from
many former operations across large areas. Lead particles transported by re-worked shallow
material, wind, and vehicle travel further expanded the affected areas such that areas with
concentrations less than 200 ppm are relatively small and represent the exception rather than the
base condition. Finally, data from this study was used in a September 2018 Source Control ROD
that included removal of highly contaminated soil from one of the study areas as part of the selected
remedy.
Legend
UCM0-6-)
~ < 200 mg/kg
200 mg/kg
Notes Predicted UCl
SUPDUCL (0-6*)
2O0mg*g
200 mgiVg
0-3" fUmp Tramecu
BMos & Structires
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Superfund Optimization Progress Report October 2020
Demonstrations of Method Applicability
A DMA is also called a "methods applicability study" or a "pilot study" to evaluate the investigative
approach. The method involves pretesting proposed sampling or analytical methods to evaluate site-
specific performance. Such studies are recommended by EPA prior to finalizing the design of
sampling and analysis plans for waste projects [SW-846 Section 2.1],
Carson River Mercury Site Superfund Site- Highlight Summary
Phase
Challenge
Tool/Analysis
Recommendation
Outcomes
RI/FS
• Planning for site
characterization
and site
management
• Demonstrate
Method
Applicability
• Real-time
measurement using
XRF
• HRSC
• Established the
comparability of the
XRF data with
traditional laboratory
methods
• CSM Improvements
• Use of Strategic Sampling
• Improved Data
Management
Prior to conducting a full-scale field study project, managers for the Carson River Mercury
Superfund Site in Nevada were interested in evaluating the performance of XRF instrumentation for
the simultaneous analysis in the field of mercury, lead, arsenic, and selenium in soil affected by the
mining operations associated with the Comstock Lode. Relevant aspects of performance included
evaluation of several models of XRF for their respective detection limits, linear range, inter-element
interferences, analytical precision, and comparability with other analytical methods. The most
effective processing and analytical techniques were selected for use in a follow-up study that
evaluated field sample collection. The team met the primary goal of the DMA and established the
comparability of the XRF data with traditional laboratory methods, i.e., inductively coupled plasma
mass spectrometry for lead, arsenic and selenium, and cold vapor atomic absorption spectroscopy
for mercury. The information from the DMA was used as a proof of concept and foundation for the
full-scale field study.
High-Resolution and Real-Time Measurement Technologies
HRSC includes investigation tools and strategies appropriate to the scale of heterogeneities in the
subsurface that control contaminant distribution, transport, and fate. The HRSC techniques provide
the degree of detail necessary to understand exposure pathways, processes affecting the fate of
contaminants, mass distribution and flux by phase and media, and how remediation or mitigation
measures may affect the problem. Many HRSC techniques include real-time measurement
technologies which refer to any data generation mechanism that supports real-time decision-making,
including rapid turn-around from a fixed laboratory (using either quantitative or qualitative analytical
methods) or field-based measurement technologies.
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Examples o!
: Real-Time Measurement Tec
hnologies
Technology
Media
Example COCs and Properties
X-Ray Fluorescence (XRF)
Soil, Solid Surface
Metals
Membrane Interface Probe (MIP)
Soil, Groundwater
VOCs
Laser Induced Fluorescence (LIF)
Soil, Groundwater
NAPL PAHs, Dye LIF =
chlorinated VOC
Electrical Conductivity Meter
Groundwater, Surface
Water
Metals, Nitrate
Hydraulic Profiling Tools
Soil, Groundwater
Hydraulic Conductivity (estimate)
Forward-Looking Infrared
Technology
Surface Water/Groundwater
Interface
Groundwater Discharge Location
via Temperature
Passive Samplers and Flux Meters
Groundwater
VOCs, SVOCs, Metals, PCBs,
Groundwater Flow Rate
Bioassay and Colorimetric Test Kits
Groundwater, Surface
Water
VOCs, SVOCs, Metals, PCBs
Mobile Laboratories
All
VOCs, SVOCs, Metals, PCBs
Surface and Borehole Geophysics
Sources, Overburden Soils
and Bedrock
Drums/Tanks, Utilities, Lithology,
Fractures, Groundwater Flow,
Inferred COC
Real-time XRF analysis was coupled with incremental sampling to characterize metal concentrations
in surface (0 to 6 inch) and subsurface soil (6 to 24 inch) at the Wilcox Oil Company Superfund
Site and Carson River Mercury Superfund Site. At both sites, bulk and sieved soil fractions were
analyzed with a field portable XRF in benchtop mode for real-time analysis of lead at the Wilcox Site
and mercury, lead, and arsenic at the Carson River Site. Bulk field samples were transferred into
large "XRF Read" bags and at least four XRF "shots" were collected on the bag (two on each side).
After each XRF run, the results were input into a real-time Excel XRF (RTeX) form that performs
statistical calculations specific to the site. The RTeX form calculates and displays the sample mean,
standard deviation, and error (reported as percent relative standard deviation). After the bulk
samples were analyzed, they were sieved with a 100-mesh sieve (<0.149 mm) and placed in a new
XRF read bag. The sieved samples were then analyzed with the XRF using the same protocol as the
bulk sample.
The real-time XRF analysis coupled with incremental sampling at these two sites allowed the site
team to update the CSM in real time and adjust the sampling plan as a part of a dynamic work
scope. The key to this coupled approach is that the site team can generate defensible, statistically
significant results during the field mobilization. This allows the team to manage the field work with an
adaptive approach and make necessary changes as data are generated. At the Wlcox Site, the
team was able to adjust the boundaries of sample areas, add new sample areas, and omit planned
samples as the lab team generated results. The sample design for the Wilcox Oil site relied heavily
on this dynamic approach because the goal was to delineate the 200 ppm action level boundary
around two source areas. The results of the first samples dictated whether the next sample would be
collected closer to the source or farther from it. Also, preliminary results indicated that unpaved
roads on the site may be contributing to contaminant transport, so the sampling was adjusted to
collect samples along the roads.
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Three-Dimensional Visualization and Analysis
The EPA has found that understanding subsurface heterogeneity at a much higher resolution is
critical for evaluating contaminant fate and transport, and in designing and implementing more
effective and targeted remedial actions. Obtaining a correct geologic interpretation is foundational to
depicting the subsurface. Visualization software has been successfully used to perform 3DVA that
integrates three important subsurface parameters - geology, hydrogeology, and contaminant
chemistry - into a single spatially correct format. The EPA has used 3DVA successfully to better
understand subsurface structure and characteristics and to reconcile technical CSM discrepancies.
PCE Southeast Contamination Superfund Site - Highlight Summary
Phase
Challenge
Tool/Analysis
Recommendation
Outcomes
Rl
• Planning for site
characterization
• 3DVA
• Consider that highest
soil vapor
concentrations are
associated with the
presence of COCs in
soil in future decision
making
• CSM improvements
A 3DVA was developed for the PCE Southeast Contamination Superfund Site in York, York
County, Nebraska. The EPA has been conducting a time-critical removal action since 2011 to
address the drinking water pathway and vapor intrusion pathway. Challenges at this site include
widespread contamination across 2 square miles in a residential area, multiple sources, and a vapor
intrusion pathway in residential properties. Since 2011, 27 vapor mitigation systems have been
installed and 15 residential properties have been connected to the public water supply. Groundwater
and vapor intrusion sampling activities are ongoing to ensure exposure pathways are not complete.
The PCE Southeast 3DVA modeled COCs in soil, groundwater, and soil vapor across the site. The
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3DVA revealed that the highest soil vapor concentrations are associated with the presence of COCs
in soil. The 3DVA has been used in making site decisions and planning future site characterization
efforts.
4.2.2 Strategic Sampling
The Strategic Sampling Approaches technical guide assists environmental professionals in
identifying where strategic sampling approaches may benefit data collection activities at their project
or site and what sampling approach may be most effective given site conditions and study
objectives. Strategic sampling is broadly defined as the application of focused data collection across
targeted areas of the CSM to provide the appropriate amount and type of information needed for
decision-making. Strategic sampling throughout a project's life cycle may help inform the evaluation
of remedial alternatives or a selected remedy's design, improve remedy performance, conserve
resources, and optimize project schedules. In addition, strategic sampling approaches assist with
source definition and identify unique contaminant migration pathways, such as the vapor intrusion
pathway. Strategic sampling approaches also target early action opportunities to mitigate potential
threats as well as the data needs for technology applications over the longer term, including targeted
pilot studies.
Ouachita-Nevada Wood Treaters Superfund Site - Highlight Summary
Phase
Challenge
Tool/Analysis
Recommendation
Outcomes
LTRA
• Insufficient
progress
• Additional source
delineation
• Additional
characterization of
dissolved plume
• Characterize media
outside of slurry wall
• Characterize
downgradient
dissolved-phase plume
• Adjust monitoring
frequency
• Consider three
remedial options
• CSM Improvements
• Improved System
Engineering
• Change in Remedial
Approach
• Streamlined or Improved
Monitoring
A 2015 optimization evaluation was conducted at the Ouachita-Nevada Wood Treaters Superfund
Site in Ouachita County, Arkansas. The five-acre site was in the long-term response action (LTRA)
phase of remediation at the time of the optimization and was managed as a fund-lead remediation
project by EPA Region 613. COCs from primary releases include pentachlorophenol (PCP) and
creosote components such as phenols, naphthalene, and polyaromatic hydrocarbons. A dissolved
groundwater plume is present in the shallow sand aquifer and light non-aqueous phase liquid
(LNAPL) is present in within the source area. A Remedial Action completed in 2006 included
installation of a slurry wall (located along the western edge of the property boundary), recovery and
injection wells, and an LNAPL recovery system.
13 The site is currently in the O&M phase of remediation and O&M work is managed by the Arkansas Department of Environmental
Quality.
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The optimization review team determined that the LNAPL recovery system at the source was not
working as effectively as anticipated. Because LNAPL is the source of mass to the dissolved phase
plume, without LNAPL removal, any remedies for the dissolved phase plume will require long-term
operation. The Optimization team recommended additional site characterization including soil
borings for source soil delineation and groundwater grab samples for additional characterization of
the dissolved phase plume. They also recommended the installation of four additional groundwater
monitoring wells with the final locations contingent on the soil and groundwater investigation. If the
additional site characterization and monitoring indicated that there was no potential for off-site
migration, the Optimization team recommended continuing the groundwater monitoring program,
manual LNAPL collection with a bailer during groundwater monitoring events, and considering ISCO
to treat highly contaminated groundwater in the source area.
In 2016, a total of 30 soil samples were collected from 15 locations to help delineate 1/4 -acre of the
source area west of the slurry wall. To identify the dissolved phase plume, two transects were
installed per recommendations identified in the Optimization Report. Additionally, four permanent
groundwater monitoring wells were installed to monitor contaminant attenuation and potential
migration. EPA is currently working on the remedial design for in situ treatment in the source area
west of the slurry wall.
4.2.3 Data Management
The Data Management Technical Guide (EPA, 2018d) provides best practices for efficiently
managing the large amount of data generated throughout the data life cycle. Thorough, up-front
RI/FS planning and scoping combined with decision support tools and visualization can help reduce
RI/FS cost and provide a more complete CSM earlier in the process. In addition, data management
plays an important role in identifying data gaps during the RI/FS, remedial design, and remedial
action phases. Following advanced data management techniques ensures the utility and maximum
usability of the data as a site moves through the cleanup lifecycle.
The benefits of managing the data life cycle in a comprehensive manner are:
1. Overall data quality improvement to support decision-making due to consistent content and a
format that reduces data entry errors;
2. Clear data collection guidelines, processing, and storage, which eliminates the cost of
recollecting samples and can preserve the integrity and availability of older information as
inputs to the CSM;
3. A better understanding of data quality and any limitations when analyzing and making
decisions; and
4. Improved accessibility to data in electronic format, which supports real-time interpretation
and optimization of collaboratively collected data as well as the use of decision support tools
(such as statistical analysis, visualization, and modeling) while field crews are mobilized. A
comprehensive data management approach ensures the use of a common data platform and
data consistency, accessibility, integration, and versatility.
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Jard Company Superfund Site - Highlight Summary
Phase
Challenge
Tool/Analysis
Recommendation
Outcomes
RI/FS
• Large and
complex site
• Develop data
management plan
for historical data
Update CSM
• Organize data into
sampling chronology
• Determine data
usability
• Identify which historic
datasets are needed
for decision-making
• CSM Improvements
• Improved Data
Management
During a 2017 optimization evaluation at the Jard Company Superfund Site, the optimization team
recommended the organization of historical data into a sampling chronology to develop a record of
all data collection events, the medium and locations sampled, and analyses performed. The goal
was to determine which components of the historical dataset contain data usable for risk
assessment or for screening purposes and which components are unusable due to problems with
sampling and analysis or lack of quality assurance/quality control documentation. This
recommendation was implemented along with updates to the CSM. It is important to identify which
historic datasets are needed for decision-making before investing the time to incorporate them in a
comprehensive database. Not all historic data is worth digitizing or converting into an updated format
and efforts should focus on relevant data.
Bunker Hill Mining and Metallurgical Superfund Site - Highlight Summary
Tool/Analysis
Challenge
Recommendation
Outcomes
• Large and
complex site
Develop monitoring
framework for
remedy
effectiveness and
long-term
monitoring
Update data quality
objectives
Comprehensive review
of existing data in
taking into
consideration of data
quality objectives
Improve data
management and
storage into
comprehensive
database
• Improved Data
Management
• Streamlined and
Improved Monitoring
Several data management recommendations were made for the Bunker Hill Mining and
Metallurgical Superfund Site during a 2014 optimization evaluation. The optimization team
recommended a comprehensive review of existing data to address monitoring objectives included in
the site's original DQOs. This comprehensive review and analysis of groundwater and surface water
data was completed in 2016 to establish baselines and trends prior to remedy design and
construction. Significant annual cost savings of up to approximately $150,000 annually resulted from
reduction in the groundwater monitoring program.
The team also recommended storing data in an improved, comprehensive site database designed
specifically for the Bunker Hill site that could accommodate historical soil, surface water, and
groundwater data as well as ecological and habitat restoration metrics. They noted that the current
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database was not designed for large sites where diverse types of data, such as ecological metrics,
are collected. Based on this recommendation, the site team transferred data to a site-specific Scribe
database and the development of an associated Database Management Plan is in progress.
Standard Mine Superfund Site - Highlight Summary
Phase
Challenge
Tool/Analysis
Recommendation
Outcomes
RA
• Quick
turnaround
technical review
of the
Emergency
Action Plan
needed
• Develop Emergency
Action Plan
• EAP should include
contact information
for potentially
impacted downstream
users and easy to
follow charts and
tables
• Affix plan to
communication
devices
• Improved Data
Management
Following an FY 2016 optimization evaluation at the Standard Mine Superfund Site, the site team
implemented several data management recommendations. These recommendations were
incorporated in the updated 2017 Emergency Action Plan (EAP) to provide direction in the case of
emergencies at the site. The EAP included contact information for potentially impacted downstream
users and easy to follow charts and tables that can be quickly referenced. Procedures were included
in the documents as well as affixed to the communication devices that would be relied upon in the
event of an emergency.
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5.0 SUMMARY OF PROGRESS ON IMPLEMENTING THE
NATIONAL OPTIMIZATION STRATEGY AND THE
RECOMMENDATIONS OF THE SUPERFUND TASK FORCE
EPA has continued to successfully implement the National Strategy and expand the optimization
program and its many benefits to reach a larger number of sites, across all stages of the Superfund
pipeline. Four main elements form the basis of development and implementation of the National
Strategy. They include:
¦ Element 1 - Planning and Outreach.
¦ Element 2 - Integration and Training.
¦ Element 3 - Implementation.
¦ Element 4 - Measurement and Reporting.
5.1 Planning and Outreach
EPA has continued to increase its success in planning and outreach to continuously identify sites or
site projects that would benefit from an optimization review. This collaborative process between EPA
HQ and the Regions, facilitated by ROLs and Superfund and Technology Liaisons (STLs), includes
Regions identifying sites that may benefit from an optimization evaluation and requesting technical
support from the EPA HQ team. Other government stakeholders (such as states, tribes, and local
governments) and communities are also requesting optimization and technical support evaluations
through 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 contains detailed information on
the optimization program and is accessible to the public.
5.2 Integration and Training
EPA continues to collect, synthesize, and share optimization lessons learned through: (1) CEC and
Environmental Response Training Program (ERTP) courses; (2) NARPM and On-Scene Coordinator
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 RCRA 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).
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Since the National Strategy was issued, nearly 400 participants have received training on
optimization and optimization best practices. An optimization course was offered at NARPM in 2012,
2014, and 2016 and one is planned forthe next NARPM. A total of 135 students have attended the
optimization courses to date. Starting in April 2014, there have been 13 deliveries of the Best
Practices course, with a total of 258 students attending.
EPA's understanding of best management practices for site characterization has grown through
implementation of the National Strategy. EPA synthesized the lessons learned from conducting over
300 optimization reviews and technical support projects into three technical guides; Smart Scoping
for Environmental Investigations, Strategic Sampling Approaches, and Best Practices for Data
Management. EPA issued these three technical guides in November 2018 on topics related to
optimization that were identified in the Superfund Task Force Recommendations (EPA, 2017b),
Recommendation 814, to facilitate additional technology transfer of these best management
practices. EPA has also developed standard operating procedures such as project engagement
forms, checklists, and documentation to facilitate the scoping and conduct of optimization reviews.
5.3 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 or O&M phase of the Superfund
pipeline. In FY 2015 through 2017, 48 percent of all optimizations were done in pre-remedial action
phases including PA/SI, RI/FS, and remedial design phases (Figure 2, Section 2.0).
Forthe new optimization reviews, 67 percent of optimization recommendations were implemented,
are in progress, or are planned. Another 21 percent are still under consideration and only 7 percent
were declined. A small number of recommendations (3 percent) were deferred to the state or PRP
for action, and 2 percent do not have status information available (Figure 3, Section 3.1).
Prior to implementing the National Strategy, EPA completed approximately seven optimizations per
year. In late 2010, EPA initiated the development of the National Strategy to increase the capacity
for conducting optimizations. Since implementing the National Strategy, EPA now completes
approximately 20 optimizations per year on average (Table 1, Section 2.0). In addition to the number
of completions per year, the capacity to support ongoing optimization events has increased to an
average of 50 or more optimizations per year, with 69 events supported in FY 2017 (Table 1, Section
2.0). EPA also finalized the implementation of the Task Force Recommendation 715, promoting the
14Superfund Task Force Report Recommendation 8: Reinforce Focused Scoping Which Closely Targets the Specific Areas for
Remediation and Identify and Use Best Management Practices in the Remedial Investigation/Feasibility Study Stage
15 Superfund Task Force Report Recommendation 7: Promote Use of Third-Party Optimization Throughout the Remediation Process
and Focus Optimization on Complex Sites or Sites of Significant Public Interest
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use of third-party optimizations. In the Superfund Task Force Recommendations 2018 Update16,
EPA noted "Since July 2017, EPA has implemented 18 optimization evaluations and is considering
17 additional optimization candidates. To prioritize allocation of optimization resources, EPA has
established criteria to prioritize site attributes tied to Task Force recommendations, such as human
exposure not under control; large and complex, such as sites with remedies greater than $50 million;
stakeholder interests or concerns; projected completion dates within 5-15 years, where optimization
may accelerate closure; and placement on the [Administrator's Emphasis List], EPA is also
implementing several projects to advance optimization practices and related tools in all phases of
cleanup." (EPA, 2018a)
5.4 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
evaluations (technical support projects 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 week. Summary reports on the current status of all events supported during
the current fiscal year are provided to EPA management.
In 2018, two SharePoint sites were developed ~*n*fioio Completions By Status and Evaluation Type For All Evaluations
for the optimization program. The first is an
optimization and optimization-related technical
support project file storage area for use by the
headquarters optimization team. The site
allows RPMs and other stakeholders to share
background documents and data with EPA
project leads and their contractor support for
use in conducting the optimization evaluations.
These background files are stored for easy
access and knowledge of materials used to
support the optimization effort. In addition,
draft and final documents are stored on this SharePoint site. The second SharePoint site is available
Evaluation Stat js By
OM "tc*!l4ul tUJWl
16 Superfund Task Force Recommendations 2018 Update https://www.epa.gov/sites/production/files/2018-
07/documents/sftf recs v9 final.pdf
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to all EPA staff and includes a dashboard showing data visualizations of all historical projects and
details of projects being supported in the current fiscal year. The dashboards can be manipulated by
the user in real time, such as focusing on projects conducted in one region or in one year. The site
also includes a digital engagement form that can be filed out by any RPM seeking optimization
support on a site.
In 2019, the optimization program began participating in ELMS. As part of that effort, tracking sheets
referred to as proxy cards were developed for each ongoing optimization review. The proxy cards
identify project leads, significant project milestones, and provide projected dates for future
milestones. Each week, the headquarters optimization team meets in a "huddle" for 20 minutes to
quickly provide any updates and identify any projects that are lagging. The proxy cards are placed
on a flow board to display the status of the projects as a visual management tool. The visual
management tools also help manage workload distribution. A goal of the optimization program
ELMS project was to increase the number of headquarters project leads to more evenly distribute
workload. The number of headquarters project leads has increased from two to seven since
implementing ELMS.
ORITT houses recommendation data from all optimization reviews that have been completed to
date. EPA records the names and category 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. EPA is currently pursuing development of an enhanced ORITT system to be
developed in Oracle.
Further details on meeting the goals of the National Strategy are included in Appendix A.
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6.0 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/remedvtech/environmental-cleanup-best-management-practices-effective-use-
proiect-life-cvcle
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.
http://semspub.epa.aov/src/document/HQ/100000021
EPA. 2016. Optimization Can Move My Site to Completion - How Does It Work. National
Association of Remedial Project Managers (NARPM) Presentation. May.
EPA. 2017a Superfund Optimization Progress Report 2011-2015. EPA-542-R-17-002. June.
httpsV/semspub.epa.qov/src/document/l 1/196740.
EPA. 2017b. Superfund Task Force Recommendations. July.
https://www.epa.aov/sites/production/files/2017-07/documents/superfund task force report.pdf
EPA. 2017c. Best Practices for Environmental Site Management: A Practical Guide for Applying
Environmental Sequence Stratigraphy to Improve Conceptual Site Models. EPA 600-R-17-293.
September, https://semspub.epa.aov/src/document/HQ/100001009.pdf
EPA. 2018a. Superfund Task Force Recommendations 2018 Update. July.
https://www.epa.gov/sites/production/files/2018-07/documents/sftf recs v9 final.pdf
EPA. 2018b. Smart Scoping for Environmental Investigations Technical Guide. EPA 542-G-18-004.
November. https://semspub.epa.gOv/src/document/11/100001799
EPA 2018c. Strategic Sampling Approaches Technical Guide. EPA 542-F-18-005. November.
https://semspub.epa.gOv/src/document/11/100001800
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EPA 2018d. Best Practices for Data Management Technical Guide. EPA 542-F-18-003. November.
httpsV/semspub.epa.qov/src/document/l 1/100001798
EPA 2020. Smart Scoping of an EPA-Lead Remedial Investigation/Feasibility Study. EPA 542-F-19-
006. MONTH.
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APPENDIX A
PROGRESS ON IMPLEMENTING THE NATIONAL
OPTIMIZATION STRATEGY
APPENDIX A-1
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Superfund Optimization Progress Report October 2020 |
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-9
Element 3.3: Independent Party Optimization Review Steps A-9
Element 3.4: Provide Access to a Pool of Qualified, Independent Contractors A-10
Element 3.5: Develop Regional Optimization Capabilities A-10
Element 3.6: Develop Other Stakeholders' Capabilities A-10
Element 3.7: Advance Application of Innovative Optimization Strategies A-10
A.4 Progress on Implementing Element 4: Measurement and Reporting A-11
Element 4.1: Track Implementation of Recommendations A-11
Element 4.2: Measure Optimization Outcomes and Report Results A-11
Element 4.3: Monitor Cost Accounting A-13
APPENDIX A-2
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Superfund Optimization Progress Report October 2020
U.S. Environmental Protection Agency (EPA) has been successful in implementing the National
Optimization Strategy ("the National 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 National 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
National Strategy identified several objectives to achieve verifiably protective site cleanups faster,
cleaner, greener, and cheaper. The National 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 National 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 National 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 National 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 National 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 October 2020
Element 1.1: Establish Strategy Goals: The National 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 Headquarter (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) courses, (2)
National Association of Remedial Project Managers (NARPM) and On-Scene Coordinator 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 2 (Section 2.0 of main report). Figure 2 shows the Superfund stage of completed optimization
reviews and technical support projects from fiscal year (FY) 2011 through FY 2017. 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 evaluations
supported by EPA each year from FY 2011 through FY 2017. EPA has increased the number of
optimization reviews and technical support projects it supports and has exceeded the goal of
APPENDIX A-4
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Superfund Optimization Progress Report October 2020
supporting 20 to 30 optimization reviews annually. EPA continues to measure optimization outcomes
and is reporting on the results with this optimization progress report.
Table A-1: EPA Support of Optimization
Fiscal Year
Started
Ongoing
Completed
Number of Optimization and
Technical Support Evaluations
Supported by OSRTI*
2011
21
14
12
35
2012
21
23
18
44
2013
27
26
27
53
2014
18
26
29
44
2015
27
15
14
42
2016
38
28
31
66
2017
34
35
24
69
* This column represents the number of evaluations started each fiscal year combined with the number of
evaluations ongoing from the previous fiscal years.
Element 1.2: Apply Optimization as a Means to Improve Community Engagement: The
National 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 2017 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," which included 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.qov/superfund/cleanup-optimization-
superfund-sites contains detailed information on the optimization program and is accessible to the
public.
1.2.3 Energy and material efficiency. 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
APPENDIX A-5
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Superfund Optimization Progress Report October 2020
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.
1.2.4 Knowledge Transfer. Current information resources and infrastructure, provided through
www.epa.oov/superfund and www.epa.aov/superfund/superfund-trainina-and-learnina-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 Office of Research and Development (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 long-term response action to operation and maintenance (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 and the forums under EPA's Technical
Support Program, including NARPM and the Ground Water Forum, Engineering Forum, and Federal
Facilities Forum.
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Superfund Optimization Progress Report October 2020
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 National 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. EPA synthesized the lessons learned from conducting over 300
optimization reviews and technical support projects into three technical guides: Smart Scoping for
Environmental Investigations, Strategic Sampling Approaches, and Best Practices for Data
Management. EPA issued these three technical guides in November 2018 on topics related to
optimization that were identified in the Superfund Task Force Recommendations (EPA, 2017b),
Recommendation 817, to facilitate additional technology transfer of these best management
practices. 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 has replaced 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 National 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
17Superfund Task Force Report Recommendation 8: Reinforce Focused Scoping Which Closely Targets the Specific Areas for
Remediation and Identify and Use Best Management Practices in the Remedial Investigation/Feasibility Study Stage
APPENDIX A-7
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Superfund Optimization Progress Report October 2020
in and developing training courses for the CEC, NARPM training program, and Technical Support
Project Forum meetings.
Since the National Strategy was issued, nearly 400 participants have received training on
optimization and optimization best practices. An optimization course was offered at NARPM in 2012,
2014, and 2016 and one is planned for 2020. A total of 135 students have attended the optimization
courses to date. Starting in April 2014, there have been 13 deliveries of the Best Practices course,
with a total of 258 students attending. 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 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 National 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 now completes 23
optimizations peryearon average (Table 1, Section 2.0). In addition to the number of completions
per year, the capacity to support ongoing optimization events has increased to an average of nearly
60 optimizations peryear, with 69 events supported in FY 2017 (Table 2, Section 2.0). EPA has
completed five technical support projects in the site assessment phase (before listing of the sites on
APPENDIX A-8
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Superfund Optimization Progress Report October 2020
the National Priority List) with 3-dimentional visualization and analysis (3DVA) of existing data to
supplement the Hazard Ranking System packages for those projects and with development of
Conceptual Site Models (CSMs).
Element 3.2: Expand Optimization to Earlier Project Pipeline Stages and Incorporate Triad.
Green Remediation and Other Best Practices: In accordance with the National Strategy, EPA has
expanded optimization to sites earlier in the Superfund project pipeline. In FY 2015 through 2017, 48
percent of all optimizations were done in pre-remedial action phases including Preliminary
Assessment/Site Investigation, Remedial Investigation/Feasibility Study, and remedial design
phases, as demonstrated in Figure 2, in Section 2.0 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, energy and material efficiency is addressed during
every optimization review conducted by EPA. EPA also provides technical support for conducting
environmental footprint analyses and implementing green remediation best management practices.
EPA also accomplished Recommendation 718 of the Superfund Task Force Recommendation report
(EPA, 2017b), promoting the use of third-party optimizations. In the Superfund Task Force
Recommendations 2018 Update19, EPA noted "Since July 2017, EPA has implemented 18
optimization evaluations and is considering 17 additional optimization candidates. To prioritize
allocation of optimization resources, EPA has established criteria to prioritize site attributes tied to
Task Force recommendations, such as human exposure not under control; large and complex, such
as sites with remedies greater than $50 million; stakeholder interests or concerns; projected
completion dates within 5-15 years, where optimization may accelerate closure; and placement on
the [Administrator's Emphasis List], EPA is also implementing several projects to advance
optimization practices and related tools in all phases of cleanup." (EPA, 2018a)
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 evaluations 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
18 Superfund Task Force Report Recommendation 7: Promote Use of Third-Party Optimization Throughout the Remediation Process
and Focus Optimization on Complex Sites or Sites of Significant Public Interest
19 Superfund Task Force Recommendations 2018 Update (https://www.epa.gov/sites/production/files/2018-
07/documents/sftf recs v9 final.pdf)
APPENDIX A-9
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Superfund Optimization Progress Report October 2020
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 and Assessment and Remediation Division, ORD, Argonne National
Laboratory, the U.S. Army Corps of Engineers, 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 has 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 National 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
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.
APPENDIX A-10
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Superfund Optimization Progress Report October 2020
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 primarily
during FY 2015 through FY 2017. 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. RPMs are encouraged in their description of
progress to discuss any obstacles. The process would benefit from follow-up phone
interviews with RPMs to acquire additional information.
EPA uses the Optimization Report Inventory and Tracking Tool (ORITT) database to house
recommendation data from all optimization reviews that have been completed to date. EPA records
the names and category 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.
EPA is currently pursuing development of an enhanced ORITT system to be developed in Oracle.
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
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 recommendations easier and more frequent.
APPENDIX A-11
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Superfund Optimization Progress Report October 2020
EPA uses the database Optimization Project Log (OPL) to track all optimization events (technical
support events and optimization review events) by site name and record 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);
and
¦ FY start and completion dates.
OPL is updated each week. Summary reports on the current status of all events supported during
the current fiscal year are provided to EPA management.
In 2018, two SharePoint sites were developed for the optimization program. The first is an
optimization and optimization-related technical support project file storage area for use by the
headquarters optimization team. The site allows RPMs and other stakeholders to share background
documents and data with EPA project ieads and their contractor support for use in conducting the
optimization evaluations. These background files are stored for easy access and knowledge of
materials used to support the optimization
effort. In addition, draft and final
documents are stored on this SharePoint
site. The second SharePoint site is
available to all EPA staff and includes a
dashboard showing data visualizations of
all historical projects and details of projects
being supported in the current fiscal year.
The dashboards can be manipulated by
the user in real time, such as focusing on
projects conducted in one region or in one
year. The site also includes a digital
engagement form that can be fiied out by
any RPM seeking optimization support on
a site.
Completions 6y
Year
Status and Evaluation Type For All Evaluations
iot'i ft
2004 mm
2401 |
m> |~
Evaluation Status By Region
l(HhStie« Sit
Jflh
-------
Superfund Optimization Progress Report October 2020
distribute workload. The number of headquarters project leads has increased from two to seven
since implementing ELMS.
Element 4.3: Monitor Cost Accounting: EPA tracks and reports on the costs of conducting
individual optimization reviews and implementing the National 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 CSMs are intended to lead to better
remedy selection and design, leading to rapid achievement of Remedial Action Objectives 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-13
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Superfund Optimization Progress Report October 2020
APPENDIX B
COMPLETED OPTIMIZATION REVIEWS AND TECHNICAL
SUPPORT PROJECTS FY 1997 - FY 2017
APPENDIX B-1
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Superfund Optimization Progress Report October 2020
"Some later technical support projects were completed in time to be included in the progress report.
State
Site
Fiscal Year
Complete
Total Optimization
Evaluations
Region 1
30
MA
Baird & McGuire - Evaluation 1
2002
MA Baird & McGuire - Evaluation 2 2013
NY
BCF Oil Refining, Inc.
2009
MA
BJAT LLC
2016
MA
Charles George Reclamation Trust Landfill - Evaluation 1
2017
ME
Eastern Surplus
2012
VT
Elizabeth Mine - Evaluation 1
2016
VT
Elizabeth Mine - Evaluation 2
2016
VT
Ely Copper Mine - Evaluation 1
2017
VT
Ely Copper Mine - Evaluation 2
2017
MA
Engelhard Corporation Facility
2005
MA
Fairmont Line- Modern Electroplating
2013
MA
Groveland Wells No. 1 & 2 - Evaluation 1
2002
MA
Groveland Wells No. 1 & 2 - Evaluation 2
2013
MA
Groveland Wells No. 1 & 2 - Evaluation 3
2014
VT
Jard Company
2017
NH
Kearsarge Metallurgical Corp.
2010
NH
Ottati & Goss/Kingston Steel Drum
2014
Rl
Peterson/Puritan Inc.
2016
Rl
Picillo Farm - Evaluation 1
2017
CT
Ridson Corporation
2004
NH
Savage Municipal Water Supply - Evaluation 1
2001
MA
Silresim Chemical Corp. - Evaluation 1
2002
MA
Silresim Chemical Corp. - Evaluation 2
2014
NH
Somersworth Sanitary Landfill - Evaluation 1
2009
NH
Somersworth Sanitary Landfill - Evaluation 2
2017
MA
Sullivan's Ledge - Evaluation 1
2016
MA
Sullivan's Ledge - Evaluation 2
2016
NH Sylvester 2009
MA
W.R. Grace &Co., Inc. (Acton Plant)
2017
Region 2
27
NJ
A-Z Automotive
2004
APPENDIX B-2
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Superfund Optimization Progress Report October 2020
State
Site
Fiscal Year
Complete
Total Optimization
Evaluations
Region 2
(Continued)
NJ
Bog Creek Farm
2002
NY Brewster Well Field 2002
NJ
Ciba-Geigy Corp.
2012
NY
Circuitron Corp.
2005
NY
Claremont Polychemical
2002
NY
Eighteen Mile Creek
2016
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 - Evaluation 1
2012
NJ
MetalTec/Aerosystems - Evaluation 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 2
2014
NJ
Sherwin-Williams/Hilliards Creek
2017
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 Unimatic Manufacturing Corp Site 2016
NJ
Vineland Chemical Co., Inc.
2011
Region 3
27
PA
A.I. W. Frank/Mid-County Mustang
2006
PA Butz Landfill 2006
PA
Clearview Landfill - Evaluation 1, OU 03
2014
PA
Crossley Farm
2006
PA
Croydon TCE
2006
PA
Cryochem, Inc.
2006
APPENDIX B-3
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Superfund Optimization Progress Report October 2020
State
Site
Fiscal Year
Complete
Total Optimization
Evaluations
Region 3
(Continued)
DE
Dover Gas Light Co., OU2
2015
PA Fischer & Porter Co. 2014
PA
Former Honeywell Facility
2003
VA
Fort Eustis (US Army)
2013
VA
Greenwood Chemical Co. - Evaluation 1
2004
VA
Greenwood Chemical Co. - Evaluation 2
2006
PA
Havertown PCP - Evaluation 1
2004
PA
Havertown PCP - Evaluation 2
2006
PA
Hellertown Manufacturing Co. - Evaluation 1
2002
PA
Hellertown Manufacturing Co. - Evaluation 2
2006
PA
Hellertown Manufacturing Co. - Evaluation 3
2017
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 - Evaluation 1
2002
PA
Raymark - Evaluation 2
2006
VA
Saunders Supply Co. - Evaluation 1
2006
VA
Saunders Supply Co. - Evaluation 2
2016
DE Standard Chlorine of Delaware, Inc. 2007
PA
Valmont TCE Site (Former-Valmont Industrial Park)
2016
Region 4
15
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
NC
Celanese Corp. (Shelby Fiber Operations)
2009
NC
Charles Macon Lagoon and Drum Storage
2016
FL
Chemko Technical Services, Inc. Facility
2005
SC
Eliskim Facility
2004
SC
Elmore Waste Disposal
2001
NC
FCX, Inc. (Statesville Plant)
2002
MS
Mississippi Phosphates Corporation - Evaluation 1
2016
APPENDIX B-4
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Superfund Optimization Progress Report October 2020
State
Site
Fiscal Year
Complete
Total Optimization
Evaluations
Region 4
(Continued)
MS
Mississippi Phosphates Corporation - Evaluation 2
2016
FL
Taylor Road Landfill
2007
TN
Velsicol Chemical Corp. (Hardeman County)
2013
GA
Woolfolk Chemical Works, Inc.
2008
Region 5
17
MN
Baytown Township Ground Water Plume
2011
Ml Clare Water Supply - Evaluation 1 2007
Ml
Clare Water Supply - Evaluation 2
2007
Ml
Clare Water Supply - Evaluation 3
2017
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. - Evaluation 1
2002
Ml
Peerless Plating Co.
2006
Wl
Penta Wood Products
2006
IN
Reilly Tar & Chemical Corp. (Indianapolis Plant)
2004
Wl
Stoughton City Landfill
2008
Ml Wash King Laundry - Evaluation 1 2006
Ml
Wash King Laundry - Evaluation 2
2011
Region 6
21
LA
American Creosote Works, Inc. (Winnfield Plant)
2008
AR Arkwood, Inc. 2016
LA
Bayou Bonfouca - Evaluation 1
2001
TX
Conroe Creosoting Co.
2015
LA
Delatte Metals
2009
TX
East 67th Street Ground Water Plume
2014
TX
Garland Creosoting
2016
NM
Grants Chlorinated Solvents
2008
NM
Homestake Mining Co.
2011
TX
Jones Road Ground Water Plume
2014
APPENDIX B-5
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Superfund Optimization Progress Report October 2020
State
Site
Fiscal Year
Complete
Total Optimization
Evaluations
Region 6
(Continued)
NM
McGaffey & Main Groundwater Plume - Evaluation 1, OU 02
2012
NM McGaffey & Main Groundwater Plume - Evaluation 2, OU 03 2015
AR
Midland Products
2001
NM
North Railroad Avenue Plume
2015
TX
Odessa Chromium #1
2016
AR
Ouachita Nevada Wood Treater
2015
TX
Sandy Beach Road Ground Water Plume
2014
TX
Sprague Road Ground Water Plume
2016
TX
State Road 114 Groundwater Plume
2014
OK Tar Creek (Ottawa County) 2014
TX
West County Road 112 Ground Water
2016
Region 7
22
NE
10th Street Site - Evaluation 1
2010
NE 10th Street Site-Evaluation 2 2014
KS
57th and North Broadway Streets Site
2006
KS
Ace Services - Evaluation 1
2007
KS
Ace Services - Evaluation 2
2013
MO
Big River Mine Tailings/St. Joe Minerals Corp.
2016
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 - Evaluation 1
2013
NE
Parkview Well
2017
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
APPENDIX B-6
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Superfund Optimization Progress Report October 2020
State
Site
Fiscal Year
Complete
Total Optimization
Evaluations
Region 7
(Continued)
MO
Washington County Lead District - Furnace Creek
2016
Region 8
29
CO
American Tunnel Mine
2017
SD
Batesland (Former Mobil Gas Station))
2013
CO
Bonita Peak Mining District
2017
MT
Burlington Northern (Somers Plant) (BNSF Railway) - Evaluation 1
2015
CO
Captain Jack Mill - Evaluation 1
2016
CO
Captain Jack Mill - Evaluation 2
2016
CO
Central City, Clear Creek
2007
UT
Former Old Hilltop (Hilltop Station)
2013
CO
French Gulch
2013
SD
Gilt Edge Mine
2013
CO
Gold King Mine Release - Evaluation 1
2016
CO
Gold King Mine Release - Evaluation 2
2017
CO
Gold King Mine Release - Evaluation 3
2017
MT
Idaho Pole Co. - Evaluation 1
2009
MT
Idaho Pole Co. - Evaluation 2
2009
MT
Idaho Pole Co. - Evaluation 3
2010
UT
Intermountain Waste Oil Refinery (IWOR)
2011
UT
Jacobs Smelter - Evaluation 1
2010
MT
Lockwood Solvent Ground Water Plume - Evaluation 1, (OU 01)
2014
MT
Lockwood Solvent Ground Water Plume - Evaluation 2, (OU 02)
2014
CO
Lowry Landfill - Evaluation 1
2016
UT
Ogden Railroad Yard
2013
SD
Pine Ridge Oil
2013
CO
Rico - Argentine
2016
CO
Standard Mine - Evaluation 1
2014
CO
Standard Mine - Evaluation 2
2016
CO
Standard Mine - Evaluation 3
2016
CO
Summitville Mine - Evaluation 1
2002
CO
Vasquez Boulevard And I-70 - Evaluation 1
2017
Region 9
31
CA
Applied Materials
2012
APPENDIX B-7
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Superfund Optimization Progress Report October 2020
State
Site
Fiscal Year Total Optimization
Complete Evaluations
Region 9
(Continued)
NM
Bond & Bond/Nav 046 Site
2013
CA
BP Carson Refinery
2006
NV
Carson River Mercury Site - Evaluation 1, OU 02
2014
NV
Carson River Mercury Site - Evaluation 2, OU 00
2017
AZ
Davis Chevrolet/Nav 185 Site
2013
CA
Intel Magnetics - Evaluation 1
2013
AZ
Iron King Mine - Humboldt Smelter - Evaluation 1
2014
AZ
Iron King Mine - Humboldt Smelter - Evaluation 2
2014
AZ
Iron King Mine - Humboldt Smelter - Evaluation 3
2013
CA
Klau/Buena Vista Mine - Evaluation 1
2010
CA
Klau/Buena Vista Mine - Evaluation 2
2017
CA
Lava Cap Mine - Evaluation 1
2014
CA
Lava Cap Mine - Evaluation 2
2017
CA
McCormick & Baxter Creosoting Co. - Evaluation 1
2014
CA
McCormick & Baxter Creosoting Co. - Evaluation 2
2017
CA
Middlefield - Ellis - Whisman (MEW) Superfund Study Area -
Evaluation 1
2012
CA
Middlefield - Ellis - Whisman (MEW) Superfund Study Area -
Evaluation 2
2012
CA
Modesto Ground Water Contamination
2002
CA
Newmark Ground Water Contamination - Evaluation 1 (First
MAROS)
2007
CA
Newmark Ground Water Contamination - Evaluation 2 (Second
2009
MAROS)
CA
Newmark Ground Water Contamination - Evaluation 3 (First 3DVA)
2014
CA
Newmark Ground Water Contamination - Evaluation 4 (Third
MAROS)
2015
CA
Newmark Ground Water Contamination - Evaluation 5 (Second
2016
3DVA)
AZ
Painted Desert Inn/Nav 049 Site
2013
CA
Pemaco Maywood
2011
CA
San Fernando Valley (Area 1)
2012
CA
Selma Treating Co. - Evaluation 1
2002
CA
Sulphur Bank Mercury Mine
2015
AZ
Telles Ranch/CRIT 002
2013
CA
Treasure Island Naval Station-Hunters Point Annex
2013
APPENDIX B-8
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Superfund Optimization Progress Report October 2020
State
Site
Fiscal Year
Complete
Total Optimization
Evaluations
Region 10
32
OR
Black Butte Mine
2012
WA
Boomsnub/Airco
2002
ID
Bunker Hill Mining & Metallurgical Complex - Evaluation 1
2006
ID
Bunker Hill Mining & Metallurgical Complex - Evaluation 2, OU 02
(OTP)
2013
ID
Bunker Hill Mining & Metallurgical Complex - Evaluation 3, OU 03
2014
ID
Bunker Hill Mining & Metallurgical Complex - Evaluation 4, OU 03
(Upper Basin area)
2016
ID
Bunker Hill Mining & Metallurgical Complex - Evaluation 5, OU 03
(East Mission Flats and Big Creek Repository areas)
2017
ID
Bunker Hill Mining & Metallurgical Complex - Evaluation 6
2017
WA
Colbert Landfill - Evaluation 1
2011
WA
Commencement Bay, South Tacoma Channel - Evaluation 1
2002
WA
Commencement Bay, South Tacoma Channel - Evaluation 2
2008
ID
Eastern Michaud Flats Contamination
2017
WA
Fort Lewis Logistics Center
2011
WA
Frontier Hard Chrome, Inc.
2008
WA
Hamilton/Labree Roads GW Contamination (HRIA) - Evaluation 1
2010
WA
Hamilton/Labree Roads GW Contamination (HRIA) - Evaluation 2
2015
WA
J.H. Baxter & Co.
2016
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
OR
Northridge Estates
2015
OR
Northwest Pipe and Casing/Hall Process Company - Evaluation 1
2007
OR
Northwest Pipe and Casing/Hall Process Company - Evaluation 2
2016
WA
Occidental Chemical Corporation
2004
WA
Palermo Well Field Ground Water Contamination
2012
OR
Portland Harbor
2011
OR
Univar
2017
WA
Upper Columbia River
2013
WA
USNavy Whidbey Island Naval Air Station, (Ault Field/OU 1)
2014
APPENDIX B-9
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Superfund Optimization Progress Report October 2020
State
Site
Fiscal Year
Complete
Total Optimization
Evaluations
Region 10
(Continued)
WA
Wyckoff Co./Eagle Harbor - Evaluation 1
2005
WA
Wyckoff Co./Eagle Harbor - Evaluation 2
2014
TOTAL
251
APPENDIX B-10
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