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EPA540/R-98/017OSWER 9355.0-70PB98-963304

MEMORANDUM

Transmittal of Report, "Updating Remedy Decisions at Select Sites, SummaryReport, FY1996 and FY1997"

SUBJECT:

FROM: Stephen D. Luftig, Director / AOffice of Emergency and Remedial Response

TO: Director, Office of Site Remediation and RestorationRegion I

Director, Emergency and Remedial Response DivisionRegion II

Director, Hazardous Site Cleanup DivisionRegion III

Director, Vva«tp Management DivisionRegion IV

Director, Superfund DivisionRegion V, VI, VII, IX

Assistant Regional Administrator, Office of Ecosystems Protection and RemediationRegion VIII

Director, Office of Environmental CleanupRegion X

Attached is the report entitled "Updating Remedies at Select Sites, Summary Report,FY1996 and FY1997." This report, which was developed as part of the Superfund Reformsannounced on October 2, 1995 by Administrator Carol Browner, summarizes the first two yearsof reform progress as described in the memorandum entitled "Superfund Reforms: UpdatingRemedy Decisions," OSWER Directive No. 9200.0-22, dated September 27, 1996. This reportshould be of interest to Regional staff, States, other Federal agencies, communities, and regulatedparties.

The Remed) I "pdates Reform \vas designed to encourage appropriate ehanges to existingremedy decisions to enhance o v e r a l l rerned\ and co^t effectiveness, w i t h o u t compromisingprotectiveness or other objects es of the Superfund piouram. The reform seeks to revise remedydecisions onK \ \here such decisions are > u b s t a n t i a l l \ out of date vu th current remediationscience and technology.

This report discusses remedy updates made during both FY19% and FY1W and:

G Describes the rationale behind Reform implementation:

O Provides a nationwide iist of sites where remedies have been updated;

O Highlights estimated cost savings or increases resulting from remedy updates;

O Includes Regional implementation plans for FY1998; and

O Presents stakeholders with information on the role of remedy updates.

The results of this reform have already been used extensively in current discussions onSuperfund reauthorization and have shown our detractors that the program is keeping up withcurrent advances in science and technology whenever we select remedies.

Please distribute this report to all Remedial Project Managers (RPMs), CommunityRelations staff, and other appropriate staff, and encourage them to continue support for thisreform.

Finally, we thank you and your Regional reform contacts for your hard work andenthusiasm in supporting this initiative to date. If you have any questions regarding the attachedreport or require more assistance on remedy updates, please contact Matt Charsky at (703) 603-8777 or Brut. Means at (703) 603-8815 of the Office of Emergency and Remedial Response.

Attachment

cc: Tim Fields, OSWEREarlSalo,OGCBarry Brecn, OSRECraig Hooks, FFEOLtzCotsworth,OSWBill Ross, OERRJimWoolfor^FFRROSuperfund ManagersBruce Gelber, DOJ

United StatesEnvironmental ProtectionAgency

Office ot Emergency anaRemedialResponse

EPA9355.0-7QOSWER540-P98-PB98-963304July 1998

Updating Remedy Decisionsat Select SitesSummary ReportFY 1996 and FY 1997

———————————————— Summary Repon FY96 and FY97 ——————————————

Executive Summary

Updating Remedy Decision) fus been characterized as one or" HPA's niost successful Supertund reformsDunng FY96 and [-y9^, 1;.P.\ updated remedies at over !-'-<> sires, reducing estimated future cleanup cost* hvmore than $745 million Other kev successes and findings include the following:

Most remedy updates cornple'ed during FY96 and FY97 were the result of additional technicalinformation gathered as part of" rhe remedy design process. A small number ot remedy updateswere the result of non-technical changes in applicable, relevant and appropriate requirements(ARARs), land use, or required cleanup levels. Another small number of remedy updates werethe result of State input or community preference which focused on either technical or non-technical modifications to the remedy.

The total estimated future cost reductions (cost savings) for remedy updates in FY96 was in excessof $350 million of which over J325 million was based on science and technology advancementsFor remedy updates completed in FY97, the total estimated cost savings was in excess of $390million of which over $270 million was based on science and technology advancements. Therewere no remedy updates that resulted in estimated cost increases during FY96, and there were fiveremedy updates in FY97 with cost increases totaling an estimated $13.5 million.

Estimated cost savings for individual remedy updates during FY96 and FY97 ranged from $5,000to $82,000,000. Most of these remedy updates generated savings under $10,000,000. The five remedy-updates in FY97 resulted in estimated cost increases of from $3OO,000 to $12,000,000.

Remedy updates generally occurred in the remedial design phase of the cleanup process and weremore likely to be documented with Explanations of Significant Differences (ESDs) than Recordof Decision (ROD) Amendments. Over the 2-year period, there were 101 ESDs and 40 RODAmendments representing remedy updates with both cost savings and increases.

Most remedy updates in FY96 and FY97 were initiated by parties outside of EPA (e.g., poten-tially responsible parties (PRPs), States, communities, Federal facilities). Over the 2-year period,parties outside EPA initiated 90 updates and EPA initiated 34 updates (these numbers do not include24 updates initiated by more than one party). These numbers are consistent with the percentage ofEPA vs. non-EPA parties who conduct the actual cleanup work (e.g., since the inception ofSuperfund, the party lead for remedial design is approximately 7O percent non-EPA and 30 percentEPA).

Over the 2-year period, ground water (77 updates) and soil (73 updates) were the most commonlyaddressed media. Another nine different media types were addressed by remedy updates dunngFY96 and FY97.

Most of the remedy updates involved some kind of State participation and/or community involvement,Common forms of communication between the parties included the following: public notices, publicmeetings, public or State comments on the proposed plan, fact sheets, and public availability sessions.

Updating Remedy Decisions at Select Sites

Summary Report FY96 and FY97

T a b l e o f C o n t e n t s

Executive Summary.

1.0 Introduction .................................................................................................................... 52.0 Background ......................................................................................... . . . . . .............. 53.0 Reform Description......................................................................................................... 54.0 FY96andFY97Results ................................................................................................... 6

Exhibit I: EstimatedRemedy Update Savings by Region for FY96andFY97............................ 65.0 Remedy Update Process .................................................................................................. 6

Exhibit2: EstimatedSavings Per Remedy Updatefor FY96andFY97..................................... 7Exhibit 3: Updates by Medium in FY96 and FY97................................,..............................^^ 7£xA&r * Remedy Update Initiators in /TStftfw//7)^/.......................................................... 85.1 Determination of Remedy Update Type................................................................. 8ExhMt 5: ESDs vs. ROD Amendments in FY96 and FY9^ 95.2 Cost as a Remedy Update Driver............................................................................ 95.3 State/Tribal and Community Roles ...................................................................... 10Exhibit6:Community Involvement atSiteswith Remedy Updates ........................................ 115.4 Remedy Review Duration..................................................................................... 11Exhibit 7: Approximate Review Time for Remedy Updates in FY96 and FY97 ......................... 12

6.0 Lessons Learned ........................................................................................................... 126.1 Benefits ..............................................™ 126.2 Site Examples ....................................................................................................... 126.3 Update Requests Can Be Denied.......................................................................... 14Stakeholder Comments................................................................................................. 14

7.0 Conclusion ..................................................................................................................15Acknowledgements .......................................................................................................15

Appendix A: Summary of Remedy Update Decisions for FY96 and FY97

Appendix A.1: Summary of Remedy Update Information for FY96 and FY97 forSites Without Cost Increases

Appendix AJt: Summary of Remedy Update Information for FY96 and FY97for Sites With Cost Increases

Appendix B: Summary of Regional Implementation Plans for FY98



1.0 Introduction

Updating Remedy Decisions.announced in the third round ofSuperfund reforms in October1995, is one of a broad range ofadministrative reforms undertakento improve the efficiency, speed, andfairness of the Superrund program.Specifically, this Reform encouragesthe Regions to revisit selectedremedy decisions at sites wheresignificant new scientific informa-tion, technological advancements, orother considerations will protecthuman health and the environmentwhile enhancing overall remedy costeffectiveness.

This report discusses remedyupdates nude during both FY96and FY97, and:

• Describes the rationale andimplementation of the Reform;

• Provides a summary ofSuperrund sites where remedieshave been updated;

• Highlights estimated future costreductions (cost savings) ot -~ostincrease* expected to result fromupdated ton *ies;

Su i Regional plans forimplemeaoag the reform for bothFund- and other-lead sites inFY9$aad

* Presents stakeholders withinfocmatioa on <Hc role ofremedy updates in improvingSupcxfund unplementatioa.

2.0 BackgroundIn 1980, when the Superrundprogram was established, there waslittle knowledge and even less

experience in cleaning up hazardouswaste sites. Original estimates or"the number and prevalence of"contaminated sires were low, andminal models of contaminantmovement and behavior, particu-larly in ground water, were found tobe too simple to explain actual siteconditions. The accumulatedtechnical and engineering experienceof the 1980s and early 1990sproduced major advancements inthe science of contaminant fate andtransport modeling andremediation, illuminating initialinefficiencies in the remediationprocess at some sites.

EPA sought to encourage remedyupdates that would incorporate suchnew information into existing sitecleanups. Thus, in October 1995,EPA announced the UpdatingRemedy Decisions Reform as partof its third round of Superfundreforms. As a whole, these reformswere implemented to makeSuperrund faster, fairer, and moreefficient.

3.0 ReformDescriptionThe purpose of die UpdatingRemedy Daemon* Reform is toencourage the Regions to revisitremedy decisions at certain siteswhere significant new scientificinformation, technological advance-ments, or other considerations wiUprotect human health and theenvironment while enhancing overallremedy and cost effectiveness.Typically, these updates are made toreflect new n*-ti«ir- l informationabout the characteristics or volumesof contamination present or newexpectations regarding the perfor-

mance of selected technologiesunder site-specific conditionsFurther, these updates consider theimplications of these factors onoaginaJ decision catena such asshort- and long- term effectivenessand permanence, implementabdm.cost, and community acceptance

Often, updates are aJso made toreflect changes in ARARs or othernon-technical information gatheredafter the original decision.

While recognizing that other typesof updates may be appropriate,EPA's guidance implementing thereform (OSWER Directive 9200.222, dated September 27, 1996)specifically targets updates where:

• Updating the remedy technologyor strategy would generally resultin a more cost-effecdve cleanup,

• Physical limitations are imposedby the site or where the contami-nants warrant changes in thecleanup goals; and

• Site conditions warrant reducingthe scope of site monitoring aftercleanup (monitoring may includes pling rates, extent of analysis,or extent of reporting required).

It is important to emphasize that thisinitiative does not signal anyvanaticms in die Agency's currentpolicies regarding site cleanup,including poticies regarding remedyselection, treatment of principalthreat*, preference for permanence,establishment of cleanup levels, orthe degree to which remedies mustprotect human health and theenvironment. EPA remainscommitted to the protection ofpublic health, welfare, and theenvironment.


4.0 FY96 and FY97ResultsMore than 140 remedy updates werecompleted in FY96 and FY97, savingover $745 million in estimated sitecleanup costs. Updates dunng FY96resulted in a total estimated costsavings of over $350 million of whichover $325 resulted from updates ofthe kind identified in the Reformguidance. Updates during FY97resulted in a total estimated costsavings of over $390 million of whichover $270 million resulted fromupdates of the kind identified in theReform guidance.

The estimated cost savings per updateranged from $5,000 to $82,000,000,with all EPA Regions reporting savingsin each year reviewed Exhibit!shows the amount of estimated savingsby Region and by fiica! year. (Note:Exhibit I does not include a remedyupdate from the DOE Hanfbcd sitewhich addressed a portion of theoverall remedy through valueengineering for an estimated costsavings of $297 million.)

In addition, most of the remedyupdates generated savings of less than$10 million, as shown in Exhibit 2Note: Cost estimates for severalremedy updata ate eioW unavailabletoEPAornromolcteatmettmeofthis writing. These are labeled NA/TBD (Not •vMUhfr/To be deter-mined) ia Appendices A. 1 aodA-2.

Remedjr vpdfttec geactatcd fewcoat IncMMM. Only three Regionsrepotted Updated tCfttMK* Wnicfa

generated coat inctrat<a duringFY97. The FY97 cost increase*were for five remedy updates,which ranged £com $300,000 to$12,000,000 each, and totaled$13,500,000. No cost increaseswere reported for FY96.

Recent advances in the area ofground water science and

Exhibit 1:Estimated Remedy Update Savingsby Region for FY96 and FY97

140

Based on 143 sites.QFY96 • FY97

remediation made these types ofdecisions good candidates forremedy updates. Exhibit 3 showsthat during FY96 and FY97, updatesof ground water remedies were themost common updates, followedclosely by soil remedy updates.

More detailed information regard-ing remedy updates can alsc befound in Appendices A, A. I andA.2. Specific remedy update* aceluted by Region and by site, andinclude the (blowing information;

• Type and date of remedy update;

• Update initiator;

* Media involved;

* Summary of remedy change andfactual baas;

* State and community involvement;and

• Estimated cost savings or costincrease.

5.0 Remedy UpdateProcessAfter a remedy decision has beencompleted at * site (Le., a ROD issigned), new information may b.received or generated that could atfecthow the remedy selected in the RODshould be implemented. Thisinformation may be supplied by apotenoalf responsible party (PRP).the Federal agency conducting thecleanup, the rapport agency (e-g.,other Krfeialssjeô* State/Trite), otthe public and other interested parties.Data foe FY96 and PW indicate thatmore remedy update* vjoae ioinatedbypartie*out»deofEPA(e^,PRPs,

than by EPA (*e* Exhibit 4, page*).These numbecs are consistent with thepercentage of EPA va non-EPA partieswho conduct the actual cleanupwork (e-g., since the inception ofSuperfund, the party lead forremedial design is approximately 70


Exhibit 2:Estimated Savings Per Remedy Updatefor FY96 and FY97

increases (3%)NA/TBD (12%)

>$20M (6%)

>$10M-20M (10%)'

no savings (10%)

<$1M (28%)

>$1M-$10M (31%)

Based on 148 site*.

m no savings (15)• <$1M(41)• >$1M-$tOM (46)0 >$10M-$20M (15)

>$20M (9)NAflBD (17)increases (5)

percent non-EPA and 30 percentEPA). In some cases, remedyupdates have joint initiators becauseinformation arrived simultaneouslyfrom several parties. In addition,the exhibit shows that the relativepercentages of remedy updateinitiators in FY96 and FY97 werenot significantly different.

Although this new informationvanes widely; the reform guidancerecommends mat EPA payparticular attention to informationwhich show* that:

• Updating the remedy may multin a more cost-effective cleanup;

• Physical limitation* imposed bythe site or the contaminants maywarrant changes in the cleanupgoals; or

• Site conditions may warrantreducing the scope of the sitemonitoring after cleanup.

Once new information has beencollected, update requests areusually sent to the Regional

Superfund manager assigned to thesite. Each Region has developedprotocols for considering updaterequests, making it easier forstakeholders to prepare and requestremedy updates. Currently, noRegion reports a backlog inreviewing requests made by PRPs orother parties. Appendix B presentsmore detail on each Region'sstrategy for considering remedyupdates in FY98.

As outlined in the Reform Guid-ance, the basic process that Regionsshould use to consider proposedremedy updates consists of threesteps: identification andprioritizaaon, t^rhnir*! review, andimplementation.

iuvoKes atariting the update requestto determine the type of change(e&, remedial method, cleanupstandards, cleanup area), theresources required to tuQy evaluateit, and any potential increase ordecrease in protecbveness or cost.To ensure that the Region's

rationale for prioritizing updatereviews is clear and equinblc.Regions are encouraged tocarefully track ail requests forremedy updates. In addition, thereview and consideration ofpotential remedy updates shouldnot result in any delays in thecompletion of work products orother remediation acdvines requiredby the existing ROD and enforce-ment instruments (unilateraladministrative ord-rs (I I AOs) orconsent decit.cs (CDs)).

Technical Review evaluates the sitespecific information supportingboth the current remedy and theupdate request. "Hiis review isconducted by the site's lead entity(e.g, the Federal agency, Federalfacility, PRP, State, or Tribe)

Implementation involves preparingand filing the necessary documenta-tion (a note or memorandum to theAdministrative Record file, anESD, or a ROD Amendment) to

Exhibit 3:Updates by Mediumin FY96 and FY97

Ground WaterSolSurface WaterDebrisSedknentSludgeleachateAirSofid WasteGasLiquid WasteResiduals

3138

5624525111

46

3646

103

3

1

3000

77

74

912127

8

381

1

1

Bated on I48sita.


support the update, consultingwith the Stare and community, andphysically conducting the updatesat the site.

5.1 Determination ofRemed/ Update TypeDetermining the type of remedyupdate and its documentation is athree-step process. First, ERA oranother lead agency must categorizethe update by asking questions aboutthe extent to which it changes thescope, performance, or cost of theremedy selected in the ROD. Thiscategorization then allows the leadagency io determine if the update is anonsignificant or minor change, asignificant change, or a fundamentalchange to the scope, performance, orcost of the original remedy. Finally,the type of change wtfl determinewhich document EPA uses to updatethe remedy: a memorandum ot letterto the Administrative Record file, anESD, or a ROD Amendment (seeNCP §300.435)

Step 1In order to catergorize the update,remedy update teams ask the follow-ing questions:

• Scope - Doe* the update alter thescope of the remedy (ftf., thepfayaic * '^ptoMbtBftipoaae,ECD&GQtttlQfk COatt tO OC S)uU6VOd-

and type and volume of wastes to

Petfotmftnce - Would the updatealter the pctfoimance (&£,ttrarmcnt lercat to be •ttaaifd,methodology used to achievecleanup goals, and new technol-ogy not consideted in aboriginalROD) and thus raise concernsabout the ptotecttvencM or long-term erTecttvtoess of the remedythat could not have been antici-pated?

Cost - Docs the update alterremedial costs and ate the changes

in costs of c uch a nature that theycould not have been anticipatedbased on. (I) the estimates tn theROD, and (2) the recognizeduncertainties associated \vith thehazardous waste engineeringprocess selected-'

Step 2Based on this evaluation, anddepending on the extent or scope ofthe modification being considered, the[ead agency must determine the typeof update involved (ie, nonsignificantor minor, significant, or fundamentalchange to the scope, performance,or cost of the original remedy). Anaggregate of nonsignificant orsignificant changes could result in afundamental change overall. Post-ROD updates fit into one of thesecategories:

• A nonsignificant or minorchange usually anses duringdesign or construction whenmodifications are made to thetuncoonal specifications ot theremedy to optimize performanceand minimise cost. Such changesmay affect the type or cost ofmaterials, equipment, facilities,services, and supplies used toimplement the remedy. Thechanges will not have a majorimpact on the scope, performanceor cost of me remedy and will notrequire a modification of anenforcement decision document(eg., consent order or decree)Minor changes might include aslight increase in the volume oftreated soil, a change in disposallocation, or a modification mground water monitoringspecifications.

Exhibit 4:Remedy Update Initiators for FY96

City (2%)State (8%)

Fed. Fac. (3%)

EPA (22%) &0ol on 64 licet.

Remedy Update Initiators for FY97Corwn. (2%)

State (2%)Fed. Fac. (12%) PflPflT)

EPA (20)Joint (13)

. Fac. (10)State (2)Oomm.(2)

EPA (24%) Based on 84 sito.


• A significant change generallyinvolves incremental change to acomponent of a remedy that doesnor rundamentalh alter the overallremedial approach. Significantchanges to a component ot Aremedy may result from anenforcement action or be part of asettlement or consent decreeconcluded after EPA signs theROD. Depending on the signifi-cance of the change, a formalpublic comment penod may beconducted and an enforcementdecision document may need to bemodified EPA will generallyconsult with the Department ofJustice as soon as the Regionbelieves the remedy update willrequire modification of anyrelated consent order or decree.A significant change might involvean increase of over 50 percent inthe volume of soil to be reme-diated, a change in reasonablyanticipated land use following theremedy, or a change in an ARARthat has impacts on cleanup levelsand other parameters.

• A fundamental change involvesah appreciable change or changesin the scope; performance, an^ /orcost of a remedy or may invotve anumber of sunii aot changv ' <attogether hare the effect of afundamental change. Fundamentalchanges remit in a irmnitdetanonof the waste management ap-proach (eg., dunge in the primaryremedy for the wastes, residualrisk, cleanup technology) selectedin the original ROD and mustinclude a formal public commentperiod. Genenly, a fundamentalchange win lead to modification ofthe settlement document, obligat-ing the settling parties to imple-ment the response work inquestion. EPA routinely consultswith the Department of Justiceregarding any changes it believesare needed in a settlementdocument. A fundamental change

Exhibit 5: ESDs vs. ROD Amendments

FY96 FY97 Based on 148 sites.

might involve selecting a differentprimary treatment technologybecause of community preference,discovery of additional contami-nants, or the determination thatless treatment is needed thanoriginally expected.

Step 3The type of change will determinewhich document EPA uses to updatethe remedy: a memorandum or note tothe Administrative Record for anonsignificant or minor change; anESD for a significant change; or aROD Amendment for a fundamentalchange. Exhibit J indicates dienumber of ESDs, ROD Amendments,and other documents used for remedyupdates in FY96 and FY97.

Two yean of reform data show that,in general, remedy updates tend tooccur during remedy design andrepresent a «*gnifi/-«if but notfundamental change to the remedy.Consequently, most remedy updatescorrespond to at least one of thefollowing situations: the scope of theremedy has changed (&g., volumereduction); the performance of dieremedy can be modified or optimized(e.g., change in disposal or dis-

charge point); or there is a morecost-effective way to implement theremedy-

In rare situations, the originalremedy does not meet the requiredcleanup levels specified in the ROD,thus the determination for anupdated remedy may result inestimated cost increases.

5.2 Cost as a RemedyUpc^te DriverCost plays a significant role through-out the entire remedy selectionprocess and is one of three factorsgenerally considered when deter-mining the type of remedy update(as mentioned in Section 5.1). Formore information on the use of costin the selection of remedial actions,see EPAs fact sheet, "The Role ofCost on the Superfund RemedySelection Process" (OSWER9200.3-23FS dated September1996). This section describes inmore detail the procedures forestimating cleanup cost fromremedy selection through theremedy update.


Procedures for EstimatingOriginal Remedy Cost

At (he beginning stages of theremcdv selection process, cleanupopoons are otten broadly describedin a qualitative manner and theproject scope and schedule are notwell defined. This is because it isextremely difficult to develop a costestimate for a project when there'suncertainty about materials andlabor that will be required orspecific activities that will take placeduring the remedial action.

As the site progresses through theSuperfund pipeline and the remedyis designed, initial remedy costestimates are refined and theiraccuracy with respect to the actualproject cost increases. As a generalmatter, the initial cost estimates usedas a basis for the remedy updatesdescribed in this report are devel-oped early during the Superfundprocess when estimates are expectedto vary.

In the Superfund program, initialcost estimates are developed duringthe remedial investigation/feasibilitystudy (RI/FS). During the FS, acost estimate U developed 601; eac..of the cleanup alternatives to beconsidered durr * the remedyselection process. The RODpresents the selected remedy *nddedskmoulking rationale, if»gfi**if«gthe cost estimate fee the selectedcleanup activity.

Due to the cfaaienges associatedwith accurately characterizing sitespoor to the remedial design/remedial action (RD/RA) phase, tihecost of mnedui actions at the FSstage U based on engineeringassumptions tad data that need tobe verified and more accuratelydefined during REX Recognizingthis fundamental limitation, EPAestablished an accuracy expectation

for cleanup cost estirmres that aredeveloped during the FS as pan otthe remedy selection process Theestimate should be accurate within arange ot" plus 50 to minus 30percent 'iTus mr.ms t h a t a studyvnth an estimate ot" $100,000 couldultimately cost berweei. $70,000 and$150,000.

Feasibility cost estimates arecalculated using:

• Direct capital costs, which includecosts of construction, equipment,buildings, and relocation;

• Indirect capital costs, whichinclude engineering and design aswell as contingency allowances[see below]; and

• O&M costs, which include thecost of operating and maintainingthe remedy during a projectedtime period.

Contingencies are also factoredinto the remedy cost estimate.Contingencies are specific provi-sions for on for seen circumstanceswhich may result in additional costs(e.g. adverse weather conditions,inadequate site characterization).The contingency is used to reducethe risk of cost overruns andshould be factored into capital andO&M cost estimates developedduring the FS.

Procedures for EstimatingUpdated Remedy Cost

The cost impacts of a potentialremedy change generally arc firstassessed by the Region during Aeprktritizsnon phase of the remedychange pcocess once the sites havtbeen rmonrbed based i>n thepotential effects on the human healthprotection provided for in theoriginal remedy and the change'simpact on the schedule of theselected remedy. The Region decidesif the remedy is appropriate for

review by determining the signifi-cance of the potential update'simpact on cost. In addition, theRegion considers the potentialremedy change's proportion of thetotal remedy cost, the implement.!Don cost of the update, and theresources required to review andupdate the remedy The latterexpenditures may include, accordingto the OSWER Directive "SupertundReforms: Updating RemedyDecisions at Select Sites," "theadministrative costs of modifying aremedy, which may include prepara-tion of an ESD or ROD Amend-ment, responding to the concerns ofparties affected by the remedychange, and modifying or renegpaating UAOs or consent decrees,"

Remedy updates have similaruncertainties about material andlabor as the original remedy costestimates, and thus have samevariance factors built into theupdated cost estimates (plus 50 tominus 30 percent).

When Regional remedy updateteams compare costs, they comparethe updated remedy costs to originalremedy costs, both of whichaccount for some uncertainty i' iringthe remedial process. For thl jreason, it is necessary to emphasizethat the estimated savings for eachremedy update represent just that,an estimate, and is not meant to bean exact figure. Only as the remedyprogresses towards constructionrompsrtintt wffl the actual savings orcost increases be known. Inaddtboo, because cost savings»*•**•*** compare original remedy •costs to qpdaird temedy costs, anywork completed ss part of dieoriginal remedy is not induded inthe savings estimates. However, theimpact of these expenditures isnegjtigsbie since most updates occurearly in remedy design.

W


Exhibit 6: Community Involvement at Sites with Remedy UpdatesThis chart summarizes data from a random representative sample of 79 ESDs, ROD Amendments,

and Letters to File from both FY96 and FY97 (39 from FY96 and 40 from FY97).

Type ofCommunityInvolvement

Administrative Record

Public Notice

Public Availability

Public Comment Period

Public Meeting

Fact Sheet

0 10 20 30 40 50 60 70 80 90 100

Percentage of Sites Reporting Use Of Community Involvement Activity

5.3 State/Tribal andCommunity RolesState/TribalStates play an important cole in themodification of remedy decisions.Both the NCP $300.515 and meModel CERCLA RD/RA ContentDecree (which forms the basis formost consent decrees) provide aaopportunity for State* to reviewand comment on specified stef>s inremedy selection. Agreementsbetween EPA and States, includingcontract*, may require modificationfollowing an update to a remedy.Furthermore, the Model ConsentDecree states that the EPA wutprovide the State with a reasonableopportunity to review and com-ment on any proposed modifica-tions. Further informationregarding the role of States andsupporting agencies in the remedymodification process can be found

in the "Interim Final Guidance onPreparing Superfund DecisionDocuments/' OSWER Directive9335.3-02 (October 1989).

Native American Tribes areafforded substantially the sametreatment as States with respect tocertain provisions of CERCLA(see CERCLA $126; NCP$300.505). A Tribe that is Federallyrecognized, has a governing bodythat is currently performinggovernmental functions regardingenvironmental protection, and hasjurisdiction over a Superfund sitecan be treated essentially the sameas a State (see NCP §300.515).

CommunityAlthough the initiation of a formalpubbc comment period is requiredonly in the case of a rundamentalupdate (te., ROD Amendment),most remedy updates, regardless of

their significance, have a substantialcommunity involvement component(see NCP $300.435(c)(2)(i) and (ii)).For example, documents pertainingto the site, including any informationon remedy updates, are placed in theAdministrative Record or at the siterepository located in the area of thesite (ag., local library). Otheractivities, tnriuding a public availabil-ity session, pubbc meetings, issuanceof bet sheet* about die site, and therelease of an amrndfri proposedplan, may attow the surroundingcommunity and other interestedparties an opportunity to learn moreabout the site and ptesent theiropinions on remedial activities.

Most remedy updates in FY96 andFY97 involved State participationand/or community involvement.Common forms of communicationbetween the parties are shown inExhibit 6.


5.4 Remedy ReviewDurationTime taken to review site-specificmaterial and complete the memorandum, HSD, or ROD Amendmerit, was generally less than .1 \X'.Hfor an overwhelming majority of theremedy updates completed duringFY96 and FY97. As demonstratedin Exhibit 7t a majority of the ESDsand ROD Amendments issued tookless than one year to complete. Abrief survey of sites with longerremedy review times shows thatthese durations can be influenced by:

• A lengthy, but important, publicinvolvement phase;

• A protracted verification/pilot testperiod following the discovery ofnew performance, technical, or(oncological data;

• The discovery of unexpectedcontamination late in the remedydesign phase; or

• A redefinition of land use.

Specific examples of remedy changeswhose reviews luted mote than oneyear may be found in Section 6.2.

6.O Lessons LearnedEPA, through two years of reformimpfemenr~^nn, has gained insightinto w*ft ot successfully updating siteretnediea. The foBowing wcdon4 <sii iiifiMHMiiiiMHMltM ni l» yningtefoun benefila, si

•fiom«

6.1 BenefitsThU reform has been very successfulm banging put decsttotu in line withcunent tcieoce and technology. Bydoing to, mete update* improve the

whOe fnnirmg cebabfe short- andlong-term protection of human healthand the environment The quanofi

Exhibit 7:Approximate Review Time forRemedy Updates in FY96

• ROD-A• ESDDOTHER

<1YEAR >1-2YEARS >2-3YEARS Based on 64 sites.

Approximate Review Time forRemedy Updates in FY97

able results of mis reform have beenannounced in BPAk testimonybefore Congress, private industryevaluations of Superfund reforms,and a report of the US. GeneralAccounting Office. Of additionalnote is EPA's overwhekning^ypositive record of responding toremedy update requests made byoutside parties.

6.2 Site ExamplesIn ouaycaaea, remedies wereupdated because of a decrease orjfKtfgif in contaminant volume orbecause of the inability to achievedesired cesuks in a test of the ROD-selected treatment or containmenttechnology during the remedialdesign phase of the cleanup. Al-

12


though all updates described inAppendices A and B represent site-specific situations, it is possible to usesome as sire examples of severaltrends. 'ITie folJowmg representexamples of some remedy updatesituations thai occurred during FY96and FY97

Updates Based on NewTechnologySome updates were the result of newtechnology that wasn't considered inthe original remedy. At the DavisLiquid Waste site in Rhode Island,United Technologies proposed anupdate based on performance data.This data indicated the increasedeffectiveness and reduced implemen-tation costs of using thermaldesorpQon instead of incineration,resulting in a savings of $5 million.In some cases, the selection of a newtechnology will substantially reducethe cleanup time, such as at AvcoLycoming in Pennsylvania. HereAvco/Textron Lycoming proposeda remedy update based on successfulpilot tests of molasses injection formetals treatment and air sparging/soil vapor extraction for orgaoicstreatment. This update reduces -iecleanup time by 33 percent and savesan estimated $53 odboo.

Updates Based on NewPerformance DataNew performance data can providethe needed information for updatingrrnvdirt The update at AuburnRoad I jmrtfil in Massachusettsreflects an approach, to ground watercontamination that retted onmodeling and two yean of perfor-mance data. The remedy wasupdated from pump and treat tomonitored natural attenuation once itwas proven that volatile organiccompound (VOQ levels haddropped below cleanup levels inmost areas, saving $12 million. At

the Coakley Landfill site in NewHampshire, CoaJdey LandfillGroup gathered new data during thepre-design phase of the remedy Thisdata indicated lower gas productionvolumes so that a passive gascollection and venting system couldbe substituted for the costlier activecollection and inaneranon opoon.This remedy modification resultedin $0.7 million estimated savings.

Coordinating the UpdateSome remedy updates involvecoordination among EPA, otherFederal agencies, and State and localgovernment agencies. One remedyupdate was tied to county redevelop-ment (Rentokil, Virginia), whiletwo other updates involved discus-sions with several parties as part of atechnical impracticability (TI) waiverdetermination. For example, at theCrystal Chemical site in Texas,Southern Pacific Transportationsubstituted a slurry wall containmentremedy for a pump and treat remedyafter proving that restoration ofground water at some portions ofthe site was deemed technicallyimpracticable resulting in estimatedsavings of $2.8 million. At theSouth Municipal Water SupplyWefl cite in New Hampshire. EPAgranted a TI waiver due to thediscovery of dense non-aqueousphase liquids (DNAPL») during pre-design sampling This saved anestimated $3.5 million.

State Input in the UpdateStates can be either the lead or thesupport agency for a remedy update.For example, at the KM™ •««•«•Sanitary landfill in Minnesota, theState initiated the remedy update,conducted public involvementactivities, and wrote a ROD Amend-ment to change a remedy based onthe availability of additional site datato save an estimated $5.6 million.

Community PreferenceCommunity involvement can be thebasis tor the remedy update and, tnsome cases, may conflict with the besrtechnology available to address thecontamination. During one update atthe Brown's Battery Breaking sitein Pennsylvania, the communitypreferred a different location for thetreatment facility, while during anotherremedy update (at the TucsonInternational Airport in Arizona),the community preferred a methodfor ground water discharge thatdiffered from the original remedywhich discharged treated groundwater to the local water distributionsystem.

Cost IncreasesRemedy update reviews can result incost increases, especially when datadiscovered during remedial designdemonstrates mat a selected technol-ogy does not function under currentconditions at the site. For example, atthe Robintech site in New York,Buffton Corporation gatheredadditional information during thedesign phase which indicated that thegeology of the shaDow aquifer wasunsuitable for the implementation ofthe p< "ousry selected ^ jund waterextraction systems. For this reason,the trratmrnt was changed toexcavation and treatment using lowtemperature tKj nMl desporubn forsods, monitored natural attenuationfor shaDow aquifer ground water, andpump and treat of water from thebedrock aquifer, mrmnng the cost ofthe remedy by an estimated fO.7million. At the Imperial Ofl/

Chemical tile in Newconducted during the

revealed a higher level ofsofl confaminshno man previouslythought This discovery resulted ina*Vlitinn«l excavation and off-sitedisposal at a cost yet to be deter-mined.

Jersey,


Timeframe for CompletingRemedy UpdatesThe amount of time needed tocomplete an update vanes with eachsite. For example, the ground waterremedy at Savannah River, SouthCarolina, was updated in as little as11 days. Department of Energytesting during the remedial action(RA) phase demonstrated that arecirculation well was not effective.EPA decided to remove the wellfrom the treatment plan saving anestimated $0.1 million. The soil/sediment remedy at the ClevelandMill site in New Mexico wasupdated in only one month. TheMining Remedial RecoveryCompany proposed updating theremedy to onsite containment whena large volume of acid mine runoffcaused the need for an immediateresponse. Additionally, a soil/sludge remedy was proposed byGATX Corporation and updated inone month at the SaegettownIndustrial Area in Pennsylvania,At this site, off-site thermal treat-ment farihtirt were expanded toinclude t different type of boiler,resulting in a savings of $4.6 million.

Other updates do not occur soquickly, as at me PrefciftdPtatmgafeemNewYotk. At mis sue, theground water remedy update tookover three yean to complete butsaved an estimated |93 miffioa.The remedy was updated fromactive extraction and treatment tomoonond natural attenuationbecause sampling identified spacercstuctkxu and a "natuoff* declinein contaminant concentrations overone, The fcview Cor a toft remedyupdate at die Koppen (OroviHe)•he m CaUfoffai* site took overtwo yean to complete. Unravoc-able treatabuity testing results, thediscovery of more extensive mixedcontamination, and a change in landuse scenario resulted in a remedy

Stakeholder CommentsIn the Chemical Manufacturers Association's Report. "AChemical Industry Perspective on EPA's Superfund Administra-tive Reforms," April 1997, the following quotes were made:

"Of the five reforms covered in this report, the updatingof previous RQDs reform generated the most positivecomments, both from PRPs and from EPA (pg. 15);"

"In sum, this reform has produced the greatest tangiblebenefits of any of EPA's Superfund administrative reforms(pg- 18);"

"PRPs confirm that some remedies are being updatedand that additional petitions to update remedies are pendingfpg. 15};"and

"Of all of the EPA reforms announced in October, 1995,this is the one that has produced the most tangible results(pg- 171."

In their December 1996 report, "EPA'i Superfund Reforms: AReport on the Fhr«t Year of Implementation," the SuperfundSettlements Project said:

"In another key reform aimed at making 'smartercleanup choices,' EPA will now entertain requests toupdates earlier remedy decisions when significant newscientific information or technological advances will achievethe same level of protectfveness at lower cost" (pg.8); ar-i

"Significantly, although the EPA Headquarter guidancefocused primarily on DNAPLs in ground water, both Regionsfl and Wl have applied EPA's guidance to remedies outsidethe DNAPL context In fact several sites involved updatingold remedies calling for on-sfte incineration and adoptingthermal desorption (e.g., D*vt» Uquld WasteJ or off-siteincineration (e.g., SftundmSupply Co J (pg-2O).

update that may save an estimated'$15 muBon.

6.3 Update RequestsCan Be DeniedNot all remedy update requests areapproved by EPA. Some have

proposed remedy updates that arenot as protective ot nfcabVc as dieoriginal remedy. At the ShariaeyLandfill «te in New Je»ey, theproposal to modify the cappingremedy was denied because it wasnot protective of the environment.Other requests would not haveeliminated the site risks. At the

14


Chem-Sorv Site in Delaware, iherequest to update the remedy byeliminating ground water protectionwas denied because sampling ot thelocal ground water supply downgradient of the site demonstratedthe continuing threat posed by thesite. Even though an update requesthas been denied, new informationmay be gathered and another updatemay be submitted at a later time.

7.0 ConclusionGenerally, EPA and outside partiesconskier the Updating Remedy Decisionsreform a success during both FY96 andFY97. The number of remediesupdated by each Region during bothFY96 and FY97 clearly shows that all10 Regions are implementing thisreform, with most Regions reportingestimated cost savings above $50million foe me 2 fiscal years combined.The Regional implementation plans forFY9S do not signal any change to thecurrent remedy updating process. All10 Regions continue to evaluaterequests to review old Fund-leadremedies as well as consider updates tomore recent remedies that may not beup-to-date with current science ortechnology. Regions continue toencourage outside parties to submitremedy update requests to EPA whennew technical information exists tosupport them. Fox the most pact, EPAand outside parties share the benefitsof both cost and rime savings as partof implementing the *Tpiy*? inremedy.

Interested patties should review theexisting reform guidance (OSWERDirective 9200.2-22) for baskinformation concerning the reform.'Additional guidance on remedyupdates wifl also be included in theupdated Record of DecisionGuidance currently under develop-ment by EPA. Specific questions onimplementation of this reform maybe directed to Matt Charsky of the

Office of [{mergency and RemediaJResponse by telephone at ("03) 603-S"" or e-mail itcharskvmatthewfojepamail.epa.govor FAX ar f03) 603-9133. EachRegion aJso has a remedy updatecontact who cr.n be accessed bycontacting the Superfund Programarea in any of EPA's 10 Regionaloffices,

' The Reform Guidance can be accessedthrough the Internet at lttp:/ vww.epa goWsuperfund/oerr/reniedy. htm.

Ack no wledgemen tsThis report is a reality because of tKededicated efforts of numerous EPASuperfund staff. Regional remedialproject managers (RPMs) responsiblefor considering and implementingremedy updates at Superfund sites a±eto be commended for making thesechanges so that the best technologiesavailable are in place at all sitesnationwide. Also vital is the work ofthe following Regional contacts whotrack the Updating Remedy Decisionsreform:

Larry BollJeffjosephsonConnie CanShen PanabakeiWendy CarneyBill HookerCraig SmithBarry LeveneTom KronerJudi Schwarz

Region 1Region 2Region 3Region 4Region 5Region 6Region 7Region 8Region 9Region 10

At EPA Headquarters, Matt Chaxskyof the Office of Emergency andRemedial Response is responsible fortracking the Updating RemedyDecisions reform nationally tod forcoordinating the development of thisreport. Stephen Luftig, Director ofthe Office of Emergency andRemedial Response, William Rosa,Headquarters Superfund ReformCoordinator, Bruce Means,Superfund Senior Process Manager

for Remedy Selection, and MikeGoldstein of the Office of Emer-gency and RemediaJ Responseprovided direction and helpfulcomments throughout the entireUpdating Remedy Decisions reformeffort over the past 2 years

Report prepared by ISSI, Inc otSilver Spnng, NtD.

Appendix A:Summary of Updated Remedy Decisions

for FY96 and FY97

NOTE: The information and data presented in Appendix A have been supplied to EPAHeadquarters by Regional offices. The data is subject to occasional updates as new informationis received, thus Appendix A data should be used for informational purposes only.

Totals

Appendix A:SUMMARY OF UPDATED REMEDY DECISIONS FOR FY96

Type of Change

1 ROD A 1 Memo2PRP 2EPA 1 STATE1 JOINT

10PRP 1EPA 3 JOINT 3 ROD-A

3 ROD-A3 PRP 4 EPA1 STATE

3 PRP 1 EPA 1 STATE2 JOINT

3ESD

5ESD3 PRP 2 EPA 2 STATEICFTY 1 ROD-A 2 Letters

2 PRP 1 EPA 4ESD

5 BSD3 PRP 2FEDFAC2 JOINT

31 PRP 14 EPA 11 JOIN 1 44ESD5 STATE 2 FED FAC1CITY

17 ROD-A 3 Other

64 sites 64 sites 64 sites

Appendix A:SUMMARY OF UPDATED REMEDY DECISIONS FOR FY97

Type of Change5 ESD___1 ROD-A

7 ESD 4 ROD-A1PRP 6EPA 4 JOINT

6 PRP 2 EPA 1 FED FAC1 JOINT I COMM

6 PRP 3 EPA 3 FED FAC

10 PRP 2 EPA 4 JOINT 11 ESD 5 ROD-A4 PRP 1 JOINT 1COMM

2 PRP 1 FED FAC 2 Letters

1 Other2 EPA 1 FED FAC1 JOINT

3 PRP 2 EPA 4 FED FAC

$29.1M* $0 3 PRP 1 STATE

11 9 59 4+1TBD $394.9M $13.5M 37 PRP 20 EPA 13 JOINT 58 ESD 22 ROD-A1A iron l?Ar< TCTATT?10 FED FAC 2 STATE2 COMM

84 rites 84 sites 84 sites

Not included is the DOE HanfonJ site which has an estimated cost savings of $297 million.

Appendix A.I:Summary of Remedy Update Information for FY96 and

FY97 for Sites Without Cost Increases

NOTE: The information and data presented in Appendix A, 1 represents only a portion of theinformation available in the decision document. If more information is needed, please refer tothe site's ESD, ROD-Amendmentt memo-to-file, or letter.

Region 1

Auburn Road Landfill,NH

: From - pUmp and treat of groundwater; To - monuored—— * . r ——— , ——————— monitoring.

: Groundwater modeling and two years of performance data show VOCcomaminT —— T^ ———————p and treat facility to be built. ______________ contamination fell below cleanuplevels; no pump and treat facility to be built.

State concurred; public notice andC- - - « - .._..vt- UJIV

fact sheet issued; public commentRegion 1

Groveland Wells, MA

Region 1

PSC Resources, MA

12/19/96[ROD-A]

7/1, ,6

State helped compile ROD; publicnotified; public comment period;public meeting held. Stateconcurred.

Fed = 250 hrs;Contr. = $0

11/15/96[ESD]

11/15/96 period; public meeting held.

———————'———————I—————"I———————I___ ___Type Off Change: From - Treatment system to treat entire plume; To - reduced size of treaty

,treatment in less concentrated portion of plume; To - monitored natural attenuation

Factual Bads: New field data obtained by EPA during remedy design;treated.

Comr. = $0

Est'd Savings =$1.6 mil l ion

treated.9/15/92 3/9v Comment on ESD; public notice;

Est'd Savings -$1 million

stabilizauon; To - ex-situ stab.hzat.on. a^Fron. -Type of Change: From - in-situTo - .permeab.e can-—————————————————————————————— 'Wlt F""«*»w= âp; 10 - impermeable

; Needed improved means of stabilizing soils and sediments, physical obstacles impeded in-situ mixing.

11/26796[ESD]

legion 1

Salem Acres, MA

Region 1

Savage Municipal WaterSupply Well, NH

Region 1

South Municipal WaterSupply Well, NH

2W2303

4/11/97[BSD]

3/1/97

4/11/97

PRP Sediment,Soil

T^rpe of Change: From - original ROD cleanup levels; To - reduceFactual Boris: BSD established cleanup levels for carcinogenic P/9/27/91

12/9/96[ESD]

671/95

12/9/96

State Groundwater

State concurred; public notified. 1

d soil cleanup levels.

Fed = 200 hrs; 1Contr. = $0

Est'd Savings =$0.7 million

iHs /or which there previously were no leveUState proposed changes; publicmeeting held by State.

Type of Change: From - extract and treat using ultraviolet oxidation; To - air stripping with carbon adsoiextraction wells, and soil vapor extraction system.Factual Basis: Design studies revea9/27/89

2/3/97[ESD]

5/15/96

1/29/97

Fed = 390 hrs;Contr. = $10,000

Est'd Savings = 1$1.5 million

"ption; add slurry wall,

led presence ot UNAPLs.EPA Groundwater,

SoilState concurred; public notified,public comment period; nocommunity comments.

T^pe of Change: From - groundwater treatment and soil vacuum extraction; To - hydraulic containment

Fed = 300 hrs;Conlr. = $5,000

Est'd Savings --$3.5 mill ion

Factual Basis: DNAPLs found in pre-design data; technical impracticability waiver was granted

l- FY96Landfill gasRegion 1

Coakley Landfill NHSlate concurred; public commentperiod; no community comments Fed. = 80hrs;

Comr. = $1,000

Type of Change: From - active landfill gas collection and incineration; To - passiveFactual Bads; New data in pre-dcsign indicated lower

Region 1

IDavis Liquid Waste, RI

State concurred; no comments from = 150hrs;Contr. = $0community except 2 non-settline6

Est'd Savings =$5 million

Type of Change: From - on-site incineration; To • on-site low temperature thermal desormionF«cO»l BMJK Performance data indicated increased effectiveness and

———— —————— —— —— ——————.

ion costs using new technology—— —————— P ——— . _____ '•'"•^bJRegion 1

Oilson Road NH

State responsible for change; public

12/29/95[Otter nemo]


Tjpt rf OttOge: From • groundwater pump and treat; To - monitoring only.

factual Bash: Remedy attained ROD remediation goals and met alternate concentration limits for groundwater

[Region 1

Norwood PCB, MA

v&ffi9(16196[BSD]

r^ff^ff^trfff --• •••• - • •U **1"*- f*^ '

606

9/16/96

EPA,PRP

Landfill debris(that couldmigrate togroundwater)

State reviewed draft ESD anddeferred concurrence untilresolution of an existing Stateconsent order; ESD will be madepart of Administrative Record;community not involved.


Est'd Savings =no analysis of costsavings

Ijbtirf nunjf From - groundwater cleanup not directly required in ROD; To - clarification of groundwater performancemiptafdji, for example, maximum contaminant levels (MCLs) to be used to evaluate performance of landfill closure.

: Clarify that MCLs were included in the original ROD to monitor the integrity of the l and f i l l closure and providerotection to groundwater.

sgion 1

rttes Salvage Yard, ME

0/20/89

5/17/96[ROD-A]

T'. "

5/95

5/17/96

EPA Sediment,Soil,BuildingMaterial

Revised remedy sent toState/community for review duringpublic comment period. Stateconcurred.

Fed = 500 hrs.Contr. = $0

Hst'd Savings =$45 million

TTM of Change: From - on-site solvent extraction; To - on-site consolidation under impermeable asphalt cap and From -

FftCtttlBMfe: ROD treatment impracticable due to space constraints and safety issues; new cleanup goals based on future landfl^jjn^wwînriik assessment methodologies; new remedy more cost-effective.

&m.*i;V •'•; - :

6«DI96[BSD]

- s^' i

^•^——3/25/95

6/2CV96

EPA Groundwater Town consulted; State involved inreview; announcement made tocommunity.

Fed = 58phrs.;Contr. = $0


TTPC of ChftT»g« From - pump and treat; To - monitored natural attenuation and institutional controls.: New data from monitoring revealed VOCs below ROD action levels

1>pe of Change: From - excavation and thermal treatment of unsaturated soils »nrf e™ ^———————[ not available*Of soils in several-hot spot" areas. ^ S°'1S dnd ^^dwater; To - removal and treatment

Factual Basis: Pre-design sampling revealed additional soil contamination; removal of iusource of groundwatercontamination) will shorten length of groundwater treatment process.

Region 2

(American Thermostat, NY

* Initial cost increase,overall cost decrease.

Region 2

DeRewaJ Chemicalbmpany, NJ

Region 2

Haviland, NY

6/29/90

7/97[ESD]

3/95

5/95

EPA Groundwater,Soil State involvement; community

expressed little interest. Fed= lOOhrs;Contr. = $o

9/29/89

6/12/97[ESD]

1/96

7/96Full State involvement; Stateconcurred; public notice givencommunity expressed interest andwas supportive.

Hcd= l O O h r s ;Contr. _ $0

Kst'd Savings-TBDl>pe of Change: From - on-site solidification/stabilization of inorganic contaminated- tnt of inranics an -oo-rite treatment of inorganics and off-site disposal. ill of treated soil; To - no

Factual Basis; Treatability study results in design showed original remedy would leach i9/87

8/97[ROD-A]

8/96

Full State and communityinvolvement; local officialsobjected to change in water supplyportion of remedy.

1>pe of Change:-ftom - groundwater pump and treat and alternate water supply; To -monitoring and maintenance of existing home systems.Factual Basis: Recent data showed decrease in levels of contamination.

t ,natural attenuation and

Fed = 500hrs;Contr. = $0

Region 2

Love Canal, NY

,Region 2

Pepe Field, NJ

* Initial cost increase,overall cost decrease.

———————•Region 2

•Preferred Plating, NY

1(V87

11/96?*JBSDJ a

3/96

11/96

EPA,PRP

Sediments State was fully involved; publicsomewhat interested.



lyj* of Change: Prom - off-site incineration of creek and sewer sediments at PRP facility; To - off-site incineration or£gponl of creek and sewer sediments at commercial facility.F«*ial Bads: Dioxin disposal classification of 1 ppb as the action level that would require treatment of remedial wastes priorto land disposal; no loss in protection.9/29/89

7/25/97[BSD]

10/96

6V97

EPA Soils Of significant interest to localcommunity. Public notice of finalaction.

Fed = 30 hrs;Contr. = $0.1 mi l l . on

Est'd Savings =$0*

Type Of Change: From - landfill containment remedy; To - stabilization, excavation, and off-site disposal of landf i l l wastematerial.Factual Basis: In^mmm ——— • — »^— '

#39

9/97[ROD-A]

lesign, cost of containment remedy greatly increased.

7/94

7/97

EPA Groundwater Full State involvement; publicnotice given; public meeting held;community expressed little interest

Fed= 1,000 hrs;Contr. = $0

Esl'd Savings -$9.3 million

TVM of Change: From - active extraction and treatment; To - monitored natural attenuation.Factvt1 Bafta Subsequent sampling identified space restrictions and decline in contaminant concentrations.

Region 2

Rowe Industries, NY

Type of Change: From - excavation and off-site disposal of soil; To - excavation in-situ <nii————————_™J°n__soil, and in-aitu air sparging of saturated soil. ' aP°r ^ruction of unsaturatedFactual Bads: Extent of soil contamination greater than originally presume-

———— r ' ——— • - —— -_ ^.. ——————remedy more efficient and cost-effective.

State concern over cost of remedy.Region 2

Vineland Chemical, NJ

Region 2

Volney Landfill NY

9/3O92

7/97[RO1>A]

12/11/95

5/16/97

PRP Groundwater,Soil Significant State and public

interest; public notice; publiccomment period; communityprovided comment.

Fed= lOOhrs;Contr. = $0

9/29/89

6/3<V97[ESD]

5/95

6/97

EPA,State

Buildings,Groundwater

Contr. = $0.1 million

Hst'd Savings =$5 mill ion—^—^———————————————————————-—————————-i——————_______ 30 mil l ion

T>pe Of Change: (Groundwater) From - groundwater treatment system; To - downsize treat™,^———^——————————and dispose of Off-Site.___________ aownsize treatment system. (Buildings) demolishand dispose of off-site

tl Barii; Request by State during design to downsize system.7/87

8/97[ESD]

6/97

8/97

EPA,PRP

Groundwater State and public interest.

collection system; To - no slurryType of Change: From - install slurry wall and expand leachatetreat in combination with existing leachate collection system.

Factaal Bads: Results of pre-design studies conclude that expansion of the lea, hate collection system isstairy wall is not cost-effective, and the off-site treatment and disposal of leachate is more cosi-eff*ctive\rrand disposal. _________

Fed- 100 hrs;Contr. = $0

iEst'd Savings =$15 million

intermi"en' extract and

- . . - •*;•>;* ..*• : , . • • • -

Region 2 r (

A.O. Polymer, NJ ;, -i

S8?B£~" "4fti$£stt3-<.M&ftoJSWKfaS---; , - - .< ' • • •

1^ "f ""«f ————

3/9/95

9/17/96

Region 2 -FY96PRP Groundwater State involved in PRP negotiations

and meetings; public notified;community concerns wereidentified and considered; Stateconcurred with remedy change



Type Of Change: From - powdered activated carbon treatment (PACT system; To - air stripping, and From - discharge ofOpted groundwater to recharge basins; To - discharge to Wallkill River.PM-tnal Rftfif : PAflooding neighbori

CT failed treatability study testing; additional modeling reduced capture zone; change reduces chance ofag areas.

Region 3 • FY97

Region 3

Avco Lycoming, PA

6OV91.s | ••"•-• •-• ••

12T3CV96[ROD-A]"'>*.-',

• -• \-

5/15/95

6715/96

PRP Groundwater State was involved in review andconcurred; public notified, public-meeting held; community wasreceptive to change.

Fed= I GOO hrs;Contr. = $4.2mil l ion '

Est'd Savings -$5.3 million

l^rpe rf duuife: From - groundwater pump and treat; To - in-situ groundwater treatment using molasses injection for metal s'tffiifrriM and lir ârgmg/SOi1 vapor ftTtractinn for organics treatment

tmi&fUbl Pilot tests were successful, cleanup time would be reduced by thirty-three percent.

Extensive Federal hours and contractor dollars needed to review and analyze remedy performance.

( 8 (

Region 3

Brodbead CreekOU1.PA

Region 3

Browns Battery, PA

Region 3

Croydon TCE, PA

3/2*917/19/94[BSD]

#3<V97[BSD]

6/7/967/25/96

9/28/97

PRP^^^^ •• ••i

Soil,Groundwater

——— ^™^^BS | ^^HState concurred; public notified.

Type of Change: (Soil) i ro n - interim remedy for OUi ; To - final remedy for GUI rr™ ^ —— ——— 'Recovery of Oil Waste (CROW) process; To - mtermittem pumping for CROW in subê ^ ocTCAJSt* "

Factual Basis: Revised estimate of total surface area of coal tar accumulation, and determination thlTm^

7/92

1/27/97[BSD]

6/96

1/27/97

Comm. Soil ———————————— ——————State concurred; publicnotification; public commentperiod; community opposition tooriginal treatment location.

Type of Change: From - remove PRP's home facility as only thermal treatment location To ™ ————toxic substance disposal facility. ' y Permit

Fed = 75 hrs; 1Contr. = $0

Est'd Savings =$87,000

n - Contained:ts of contamination

'rim actions addressed

Fed = 50 hrs;Contr = $0

hst'd Savings =no net savings

ted hazardous waste

Factual Bads: Community opposed original treatment location. ————— ——————————6729/90

12/31/96[BSD]

3/93

12/: %

EPA Groundwater——

State concurred; public noticegiven; posted in Federal Register

Type of Change: From • treating two plumes; To - treat one plume.Factual Basis: PRP was found for one of the plumes and it will be addressed under RCRA

Fed =1000 hrs2;Contr. = $0


Multiple meetings with PRPs on the proposal; extensive data review - hydrogeological and historical.

|Region3I ... , .-?.-*-*,*industrial Lane, PA

IRegion 3

Mill Creek Dump. PA

egionS

li Rail Yard, PA

* Initial cost increase,werall cost decrease.

30901 1**wfafrwr**«-*- • - • Fi^fcC*.(BSD]

$£pe«f Change Fvod From - backgro

11/15/95

11/26/96

PRP Debris State concurred. Fed= 120 hrs;Contr. = $0


rom - soil cap and groundwater pump and treat; To - change cap design and change groundwater dischargerod-based; To - MCL/health-based standards for groundwater.

Fftctaal Baafe Change in Applicable or Relevant and Appropriate Requirements (ARARs) (PA eliminated requirement forcHf"*"! UP around water to background levels).

sniw4/30*97[ESDI

11/96

4/30/97

PRP Surface soils State involved in review; publiccomment period.

Fed = 26 hrs;Contr. - $0

Est'd Savings =no net savings

l^peof Change: From- land use identified in ROD; To - build driving range for land reuse.Factual Bad»:Otl

9O092

iffiffi ^[BSD]

'••*&.--.

ler than reform; changed intended land use.

7/97

9/97

PRP Residuals,Sludge,Surface water,Structures

State and community concurred. Fed = 68 hrs;Contr. = $0

Est'd Savings =savings over time;not estimated*

Troe of Change: From - decontamination of on-site buildings; lo - decontamination and demolition of on-site buildings.

Factual Batrfff' Community requested demolition of building, savings over time regarding operation and maintenance.

Region 3

Recticon/Allied Steel, PAState concurred; public notified;public comment period; publicmeeting. Comments addressedResponsiveness Summary.

Cont. = $0

Est'd Savings =Type of Change: (Soil) From - excavate and off-site disposal of soils- To - no <rs- o - no <rlimit future use. (Oroundwater) From - extract and treat and dispose to surface watei inslilutlonal controls to-«i—.—.^—^—_

: PA background requirements were used for original ROD (ARAR rha» J-—-•—RegionS

Revere Chemical, PA

Regions

ronolli Corp., PA

12/27/93

3/25/97[BSD]

12/11/95

3/25/97State concurred; several residentsattended public availabilitysessions.


l>pe oT Change: From - in-situ vacuum extraction for soil cleaning; To - ex-situ vacuum ~——'———'——^^———prevent spread of contaminants; To - no slurry wall, and From - size of can dete™^ K, rC tra

1clIOn' and From - slurry wall to

-»» —» -— —— ——— * •3VU Vli;paju|15» AO - ex-situ vacuum pvt ———————prevent spread of contaminants; To - no slurry wall, and From - size of cap determinpH K? n .ra,clIOn' and Fr°m - slurry wall iLimits; To - size of cap determined by MCLs. cicrmined by Drinking Water Method Detection

Factual Bad»! Poor performance pilot test of ROD remedy and decrease in volume

Closure of On-Site hazardous

973002 10/17/96

1/17/97

EPA

waste landfill

State did not concur on ESD.Fed = 46 hrs;Contr. = $0

Type of QttPgc: From - evaluation of artificial groundwater dewatering system; To - no: Results of hydrogeological study; granted waiver of State ARAPs due to „ A * ,standard of performance

Factual____,aireddy being me

Region 3

(Works, WV

2/17/94

4/304

Fed.Fac. Groundwater,Surface water

Mason County involved in ESD.

Tfttf af Change; From • discharge of pump and treat system into Ohio River; To - adjacent

Fed = not availableContr. = notavailable

Est'd Savings =not available

creek; Time savings • discharge to creek could begin immediately.

Region 3-FY96

Cgion3

>ex Corp., VA

10*3002

3/28/94

PRP Soil Received State review andcomment; public availabilitysessions.

Rom - excavation of ail soil in two-block area; To - excavation of only uncovered soil.

Fed - 300 hrs;Contr. = $0

Est'd Savings$1 million

rezoned some of residential area for commercial/industrial use.EPA,PRP

Soil State concurred; notice of ESDpublished; ESD placed inAdministrative Record; nocomment from community.

Fed = 48 hrs;Contr. = $5,000

iEst'd Savings =$0.1 million

* soil vapor extraction; To - mechanical aeration of soils.soil density made soil vapor extraction impractical; restricting utilities removed; treatability study re su l t s .

12

Region3

Defense General SupplyCenter, VA

Region 3

Defense General SupplyCenter, VA

Type of Change: From - groundwater extraction/treatment system; To - capping.Sampling in design indicated groundwater no longer posed a risk.

Region 3

Delta Quanies/StotlerLandfill, PA

3/25/92

3/8/96[ESD]

3/15/93 EPA,State,Fed. Fac.

Air,Groundwater,Soil

Public notice; no negativecomments received; State involvedm entire process.

9/29/93

3/8/96[ESD]

12/5/93

9/15/95

EPA,State,Fed. Fac.

Public comment requested, nocomments received; State waspartner in all decisions.

3/29/91

12/95notification; public meeting.

Fed = not available;Conir - not available

Bst'd Savings =$1.5 mil l ion

Fed = not available;Contr = not available

Est'd Savings =$2,000-J——————————"———————I———————————I_____ ______

t From - ground water treatment; To • different discharge location of treatedp?^« J *—*• _ * j—:— —Factual Bad*: Field testing in design

State concurred; public

T^pe rf Change; From - on-sitc treatment using air stripping; To - more reliable off-site treatment.

Factaal Badit PRP itf -stigation during design determined that change from onsite to offsite treatmentive of human health and the environment.


Est'd Savings$0.3 million

of eroundwatergroundwater

13

legion 3

*CR,DE

3/8/92

1/30*96[BSD]

4/94

1/3CV96

PRP Air,Surf ace water

Periodic meetings; press releases;and newspaper ads.

Fed = 1742 hrs3;Contr. = $0


5gion3

iCityofYock l

- dome-enclosed excavation; To • open air excavation, and From - on-site treatment of surface waterpfetifcTo - treatment in newly built plant_______________

S/12/91

3/27/96[BSD]

' :;. y:

KV17/94

3/27/96

PRP Groundwater Initial and follow-up fact sheetsprovided to community; Stateconcurred with revised remedy.


Est'd Savings -$2.5 million

-TMgyaf PtfcMigf Frrrm tTT ana treat grounowaier mrougn air snipper; iu - air sparging/soil vapor extraction

JgfiiflliihTlVi^MMHM^MVMM

mU9l

fttt?y%IfiSDl

tnced remediation7/25/96

9/27/96

time by using in-situ treatment.PRP Groundwater,

SedimentState concurred. ESD placed inAdministrative Record for publicreview.

Fed = 40 hrs;Contr = $0


- stabilization and off-site disposal of sediments; To - capping, and From - background performanceto-achieving MCU

i testing showed on-site placement was appropriate; change in State ARARs.

r • - data review especially for design and cost of new treatment plant; multiple document reviews needed; and

lUliiple nJSs with interested parties.14

Region 3

Rentokil, Inc., VA

Region 3

Saegertown IndustrialArea, PA

Region 3

Sauoders SupplyCompany, VA

l Bttto: Modeling indicated that "hot spot" treatment had no impact on groundwat.r r~^~~

6/22/93

8/27/96[ROD-A]

8/3CV95

11/13/95

PRP Soil State concurred; proposed planreleased to public; public noticepublished; public meeting heldcomments addressed; countyinterested in site redevelopmpm

Ijpe of Gunge: From - low temperature thermal desorption of "hot spot" soil- To H,*U,» «K "" lele hot


spot" treatment; add cap and

1/29/93

3/1/96[BSD]

2/1/96

3/1/96

PRP Sludge,Soil

State and community wereinformed of proposal.

Typ« Of Change: From - off-site thermal treatment; To - expanded off-site thermal treatment facilirie -coaHhed cyctooe power generating boilers._____ s

Fed= 160 hrs;Contr. = $0

Est'd Savings =$4.6 mnnon

s to include large

;: EPA approval of alternate thermal treatment.9/3W91

9/27/96[ROD-A]

12/8/95

3/21/96

EPA Soil State concurred; proposed planmade available; public meetingheld and comments addressed

\ - on-site thermal desorption; To • off-site incineration.

Fed = 224 hrs;Contr, = $0


F«CtMl Barir New VDEQ (Virginia) regulations on backfilling - more cost-effective and improved short-term effects.

poo 3

/son's Dump, PA

5gjon3

utmoyerLab^PA 111/W95

J '* - V,

egionS<li'-Jfilliam Dick Lagoons,

>A

3/31/93

PRP Soil State concurred; involved duringremedial design/remedial action,public comment period held byEPA; community is content withchange.

Fed= lOOOhrs;Contr. = $300,0004


Rom - soil vacuom extraction; To - covering lagoons with wet soil cover.g Original remedy could not achieve cleanup levels set forth in ROD.

6/7/95

11/7/95

PRP Debris,Solid Waste

State concurred with ESD; publicnotified; public meeting held;public strongly supportedmodification.

Fed= lOOhrs;Conlr. = $0


Prom - on-site incineration and fixation; To - off-site incineration and fixation.TWhndogv remained the same - only the location was modified; community preference

5/18/93

7/6/95

PRP Soil Public notice; ESD placed inAdministrative Record; Stateconcurred.

Fed= 170hrs;Contr. = $0

Esi'd Savings =$5.8 million

"prom - excavation and on-site thermal desorption for all soil; To - soil vapor extraction/bioremediaiionin.______i________.____-————————————————————————-——of in-situ treatment cost-effective based on pilot study results without changing the cleanupuse

?"*• rf the ROD and supporting data; multiple meetings with interested parties; and additional enforcement timeMultiple reviews'

needed.16

Region 4

Aberdeen Pesticide DumpSite - Farm ChemicalsTwin Sites, and FairwaySix Areas - (OU3), NC

Typt of Change: From - thermal destruction in air stripper; To - carbon filtration and phytoremediauon

Region 4

Arlington Blending, TN

Region 4

By Pass 601. NC(OU2)

KV7/93

9/15/97[BSD]

5/9'

7/3/97

PRP Groundwater State and community receivedproposed fact sheet and attendedpublic meeting.

Fed= ISOhrs ;Contr. = $2,000

Est'd Savings -TBD

Factual Basis: Additional data in RA changes groundwater approach.

6/91

7/24/97[ROD-A]

8/96

7/24/97

EPA,PRP State concurred; EPA convened

public meeting and received nowritten comments.

[ I>pe of Change; Prom - groundwater pump and treat; To - monitored natural attenuation

= 240hrs;Contr. = $0

Kst'd Savings -$5.5 mill ion

Factual4/2CV93

4/18/97[ROD-A]

i; Sampling indicated drinking water aquifer not contaminated as orinnallvPRP

4/18/97Soil

State and community concurred;State is major PRP. Fcd = 400hrs;

Contr. = $0

Est'd Savings =$28 mi l l ion

Type at Change: From - stabilization/solidification of all soil; groundwater pump and treat To - s.ab,l,7!n,w ,-A r ——7reduced volume of soil and groundwater monitoring. "labilizationAohdificanon of

Factual Bads: Reduced volume of soil contamination and the use of alternate concentration leveU fnr om,.^H ..."—

17

Region 4

Diamond Shamrockândfill/Cedartown, GA

Region 4

Homestead Air ForceBase,FL(OU6)

5/12/94

#1*97[BSD]

8/15/96

8/15/97

PRP Groundwater State involved and approved ofchange. Public was notified by factsheet.

Typ* of Change: Change in performance goals for manganese from 200 mg/1 to 850 mg/1.


Est'd Savings =unknown

Facttud Bads: Change in reference dose for manganese.6/27/95

10/22/97[BSD]

9/17/97

10/22/91

Fed. Fac. Groundwater,Soil

Input from Restoration AdvisoryBoard; conducted public meetingsand public agrees with change,published in local newspaper.

Fed= 10 hrs;Contr. = $0

tist'd Savings -$0.1 million

Type of Change: From - thermal treatment on-site of soil; To - off-site disposal of soil; groundwater system recovered lessLNAPL than previously anticipated.V***H«| RM!** Hfttn in Hesion showed reduced volume of soil.

Region 4

me Inc./Chevn>nicmical Co., GA

9/30/94

#18/97[ROD-A]

3/15/97

6/18/97

EPA Soil EPA addressed community andATSDR concerns. Proposed planfact sheet issued to public andState. State concurred.


Est'd Savings$2.8 million

Type<tf Change: From- low temperature thermal desorption; To - off-site landfill disposal.

Factual Basis; Community opposed

fnnisport Landfill,

to thermal treatment and discovery of dioxin during remedial design.

7/17/90

9/5/97[ROD-A]

9/4/95

9/5/97

EPA Groundwater,Surface water

State and county briefed andconcurred with change; proposedplan fact sheet issued and therewere three public meetings;community activists opposechange.

Fed = 2.000 hrs;Conlr. = $0.2 m i l l i o n


TVpe of Change: From - tidal restoration of wetland and groundwater pump and treat for containment; To - groundwater pumpand treat not needed to create hydraulic barrier.Factual Basis: Response actions to date have met objectives in original ROD.

Fed. Fac. Groundwater Public was notified about thechange.

Fed = 8 hrs;Contr. = $0NAS Pensacola (OU12),

FLEst'd Savings =| $5,000___ ____ _ _ _.. ___ ___

Type of Change: From - remedy included 5-yr.review requirement; To * remove

risk assessment and found the detected arsenic levels weit below the Fede«l and State drinking

State review and concurrence;

Est'd Savings =

Region 4

National Starch, NC

Region 4

Reeves Southeastern, FL

- _______ i ________________ • t negfflType of Change: From - off-site disposal of well drilling cuttings; To - on-site treatment by thermal desorber and on-sitedisposal.

Factual Basis: Elevated levels of contaminants in soil cuttings^^""1"^"^^"^™"^™" uired treatment prior to di

Public comment period; no Fed = 50hrs;Contr. s $5,000significant issues raised by

public/State.Est'd Savings =$0.2 million

Type of Change: From - on-site solidification/stabilization and containment; To - off-site containmentFactual Basis: Original remedy could not meet performance standards.

19

r[Region 4

[Savannah River Plant,I(OU21,29).SC

I^H^^^H^^H1/9/94

5/14/97[BSD]

MH^^^H^M

5/16/97

5/27/97

• • ^MFed. Fac. Groundwater State approved BSD. Public notice

of BSD to be placed inAdministrative Record.

—— IFed = 6 hrs; IContr. =- $0 1

Est'd Savings = 1$0.1 million J

Type of Change: From - groundwater treatment with recirculation well of part of treatment plan; To - remove recirculation 1well from treatment plan. |

•

Region 4

Aberdeen PesticideDumps Site, NC

Region 4

Cape Fear WoodPreserving, NC

Factual Basis: Testing in RA demonstrated that the recirculation well was not effective. 1Region 4 -FY96 1

9/30/91

3/96[ESD]

8/19/94

2/13/95

PRP Soil The State was involved in thedecision. The BSD notice waspublished in the local newspaper,however, a public meeting was notheld.

Fed =120 hrs 1Contr. = 1

Est'd Savings =None

Type of Change: From - arsenic performance standard of 1 ppm; To - arsenic performance standard of 30 ppm.Factual Basis: Revisions to the arsenic cancer slope factor and changes in the bioavailability factor.8/95

9/96[BSD]

4/96

6/96

EPA Soil State review and concurrence;public notified; BSD placed inAdministrative Record.


Est'd Savings =None

Type of Change: From - soil washing, biotreatment, and solidification; To -low temp, thermal desorption and 'solidification.Factual Basis: Cleanup goals could be reached without bioremediation step. Also, soil washing did not achieve cleanup goals.

"J^"^-*""^-'-'. "- .'^/•afcif-iv^j -11-... ••»rW -•<' • •*- - . •IT»^-*««* *# *• >• ''i.;-' >iW

J^P . '.j^'Vâ^x^V:2*Sr'C*'-./--

Region 4

Cedartown MunicipalLandfill, GA

Region 4

Harris Corp., FL

Factual Basis: Revised reference dose for manganese.

State involved throughout review;

Region 4

Hipps Road Landfill, FL

Region 4

ILCO (Interstate Leadompany) Leads, AL

11/2/93

673/96[ESD]

5/22/96

6/3/96

EPA Leachate Reviewed draft ESD.

Type of Change: Changed groundwater performance standard for mangar se based on reviewed reference dose.

Fed=10hrsContr. = $0

Est'd Savings =None

12/8/95[ESD]

public notified; communityprovided with fact sheets; nocomments received.

Contr. =$1.500

Est'd Savings =$0.1 millionI «^V. * IJU1IIVII________ , _ J _ ^J_______ ....-— __—_

Type of Change: From * treatment of manganese; To - only monitoring of manganese; also deleted 2 contaminants of concernFactual Basis: Sampling data in design showed contaminants to be below cleanup levels.^~^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^~9/30/86

6/1/96[ESP]

1/1/96

4/1/96

EPA Groundwater State and community not involvedin change.


Est'd Savings =min.f —— _______ _____o Change: From - discharge to homing pond; To - alternate di^hê to

F * i D o ——————— —— «^ _ ___ __ __ —— __ _ _ ---"'" "'*^»i iiwiuiug yvuu i cat, i rc 5 t^ttpatiiy.F a c t u a l : Successful discussion with publicaHy-owned treatn.nt wo. . (PQTW) allow, for alternate discharge .ocation.

8/27/96[ROD-A]

2/96

8/27/96

Solid waste State and community preference foroff-site disposal led to change.


Est'd Savings =$15 million^

21

IjFD Electronics/ChannelIM aster, NC

(Marzone Inc./ChevronIChemical Co., GA

9/10/92

1/24/96[ESD]

4/95

1/24/96

PRP Groundwater State concurred with ESD; publicwas notified.

l&'iifSavings =$3 million

Type of Change: From - treatment and disposal; To - air stripping.Factual Basb: Remedial -lesign infonnation indicated air strippin] was sufficient9/30/94

9/12/96[ESD]

8/12/96

9/12/96

EPA,PRP

Soil State reviewed draft ESD. Nocomments received. Fact sheetissued to public, but no commentsreceived on temperature change.

Fe<r=10hrs;Contr, = $0


Type of Change: Changed operating temperature of thermal desorber unit.Factual Basb: Lower temperature more efficient at treating soils.

|Region 4

lathis Brothers/SouthiMarble Top RoadLandfill, GA

3/24/93

9/27/96[ROD-A]

7/12/95

8/15/96

PRP Debris,Liquid waste,Soil,Groundwater

Proposed plan fact sheet issued.State and community concurred.

= 400hrs;Contr. = $50,000


Type of Change: From - on-site treatment; To - off-site treatment.

Factual Basis: Studies in design indicated volume smaller than in original ROD.

•Region 4

•Potter's Septic Tank, NC

8/5/92

2/6/96[ROD-A]

11/95

2/6796

State Soil Community provided with factsheets; newspaper notices; Stateconcurred.

Fed* 120 ins;Contr. = $0

Est Savings =

Type of Change; From * tod soil excayatjos tagget pf 25 ppmlfo -Factual Bad*: Revised leachateeffect on groundwater.

22

Region 5

Allied Chemical/IrontonCoke, OH

Region 5

Arcanum Iron and Metal,OH

Region 5

Buckeye ReclamationLandfill, OH

12/28/90

9/4/97[ROD-A#2]

Region 5 - FY978/23/96

2/26/97

PRP Soil State concurred; public notified;publk commentperiod; nocomments received

Type of Change; From - pad biorcmediation; To - off-site disposal in subtitle D landfill.

Contr. = $0


Factual Basis: Additional sampling in design determined lower levels of contaminants than originally thought, classifying soilsas non-hazardous. * J *9/6786

6/18/97[ROD-A]

9/15/89

2/28/97Solid Waste,Groundwater

Public notice; public/ jneeting held;comments summarize^ in..... .Responsiveness Summary; Stateconcurred with change.

= 500hrs;Contr. = $100,000

Est'd Savings =$14 millionof waste with iead (pb)

Factual Basis: Revision of lead cleanup standards and redefining of land use from residential to industrial.

Fact sheets sent to community; Fed = 3000 hrss;Contr. = $20,000State involvement throughout.

Est'd Savings =$25.2 million• v**

Type of Change: From - solid waste containment; To - "less, but still appropriate, containment," and From -groundwater/leachate trearmpnt' TV» . mA«;+/*~«~ *~- ——•-*-*- *-— -- •

__ _._.„**,..fc, *w - iwoo, uui auu approprgroundwater/leachate treatment; To * monitoring for possible future treatment.

Factual Basis: Historical review of area resulted in change of standard to 1976 Ohio solid waste

took* exten/iMCMM*£**Sxw ~l^-*j'**-__ j 4* -

23

r^^^^^™•Region 5

Icity Disposal Corp.•Landfill. WI

Region 5

CUre Water Supply, Ml

Region 5

Enviro-Chem, IN

9/28/92

6/11/97[BSD]

^m^mmmm9/12/96

6/11/97

• •HEPA.PRP,State

Groundwater State concurred; public nodfjtfL . . ,.rfact sheets iswieBipaMcêetriigr^held for coamwnity; ~

•••• ^^^^^^^^^ •£ttpa4^tor 1

; st*d Savings = 1-not^ttvaiiayie" •

Type of Change: From - on-site groundwater extract and treat; To - allow removal and off-site treatment while monitoring Icontent to develop long-term remediation effort. |Factual Basis: Based on treatability study results. . .; - v*u -- •9/16/92

5/15/97[ROD-A]

4/26/96

7/1/96

PRP Soil Public notice givei;]^^ . . -^ccinraentperio 'pobiicraeetin^held; State and communitysupport.

-"" "T Iêd^Ô hrs; 1Contt. = $0 1

Est'd Savings = 1$2 rmHion |

Type of Change: From - in-situ vapor extraction; To - containment and capping. 1Factual Basis: In-situ vapor extraction ineffective due to soil impenneability to air. '" : ^r :9/25/87

7/14/97[ESD]

1/93

3/11/96

PRP Groundwater,Soil

State concurrence; pobBc notified;public comment period; no - -comments received.

:Coi . = $30,000

not availableType of Change: From - soil vapor extraction; To - soil excavation and addition of three new cb'nipcwc^ roftallation of cap, 1extension of remediation boundary. \ p£*X v<- ' |

Factual Basis: Additional technical and lexicological information, including identification of nine additional organic 1compounds, discovery of higher water tables, and change to organic carbon content modeta .' ; :-':: ' c"' |

[Region 5

[Fields Brook SuperfundIsite, OH

»Region 5

Fisher-Calo, IN

Region 5

Janesville Ash Beds andJanesville Old Landfill,WI

9/30/86

8/15/97[ESD]

9/96

4/20/97

PRP Sediment State commented; State did notconcur with the change. Publicnotified; public meeting.

Fed = 250 hrs; 1Contr. = $0 1


Type of Change: From - solidification and on-site thermal treatment; To on-site landfill and off-site thermal treatment.Factual Basis: Additional data in design refines cleanup goal, showed reduced volumes of sediment contamination, and 1documents waiver of TSCA landfill requirement. |8/7/90

9/26/97[ROD-A]

8/15/96

9/23/97

EPA,PRP

Soil State concurred with change;community involved in publicmeeting and comment period.

Fed = 300 hrs;Contr. = $20,000


Type of Change: From - incineration of soils; To - air sparging bioremediation for SVOC-soils and off-site disposal of PCB-soils.Factual Basis: Sampling results in design showed reduced volumes of contamination.12/29/89

9/17/97[ESD]

1/30/95

7/30/97

PRP Groundwater State reviewed and concurred withchange. Public comment period;no comments from community,only PRP and State commented.

Type of Change: From - groundwater extract and treat; To - monitored natural attenuation.

Fed=100hrs;Contr. = $0


Factual Basis: Groundwater monitoring data shows decrease in VOC concentrations.

25

^^_____Region 5

Moss- American, WI

•

Region 5

Ormet, OH

Region 5

Peerless Plating, MI

^^^••^^^^^M

9/27/90

4/29/97[BSD]

^••i ^^^^H

9/4/96

4/29/97

•^^^^MPRP

w^^^^^m^^^^^mm

Groundwater• ^^ ••• ^^ ••• • ""•••i ^^^—Fact sheet distributed tocommunity.

Fed=160hrs; 1Contr. = $4,000 1

Estf d Savings = 1$70,000 1

Type of Change: From - extract and treat system; To - in-situ groundwater treatment using a funnel and gate type system. 1Factual Basis: Data gath red in design indicating relatively fine grained soils at the site which gave opportunity for ftmnel and Igate type system; more cost-effective approach. , . *< :f: '• -• |9/12/94

4/1/97[ESD]

8/27%

3/31/97

PRP Sediment,Soil

Public notice in newspaper; Statedid not concur with changes orROD.

Fed^l40hrs; 1Contr, = N/A 1


Type of Change: From: soil removal and off-site disposal; To - on-site disposal in a Toxic Substance Control Act (TSCA)compliant cell.Factual Basis: Pre-design studies and same type of disposal cell to be constructed on-site.9/21/92

8/4/97[ESD]

12/30/96

3/30/97

EPA Soil State concurred; public notice inlocal paper.

Fed = 75hrs;Contr. = $3,000

Esfd Savings =Sl^jnillion

Type of Change: From - extraction and off-site disposal; To - decreased soil remediation levels and volume £> be extracted.Factual Basis: New pre-design phase data, new MDEQs (Michigan) standards.

Region 5

Powell Road Landfill, OH

Region 5

Powell Road Landfill, OH

Region 5

Reilly Tar & Chemical,MN

Region 5

United Scrap Lead, OH

10/30/93

1/97[BSD]

5/14/96

1/97

PRP Groundwater Fact sheet issued; public meeting;

State concurred with BSD.

= 2QOhrs;Contr =$8,000


Type of Change: From - groundwatcr extract and treat with source control measures (cap and leachate collection); To -postponing of groundwater pump and treat system until all other remedial actions are set op._______________________^_________

Factual Basis; Pending study, cap, landfill leachate, and gas collection may have significant effect on10/30/93 I 11/96 I PRP I Leachate I State ennenrrwl wiri* rha««-- f*/-*10/30/93

8/13/97[ESD]

11/96

5/97

Iwater.State concurred with change; factsheet and public notice in localnewspaper for change.

Type of Change: From - on-site leachate treatment facility; To - discharge to municipal POTW for treatment.t?__^_-• * * « • - - • — — -

Fed=100hrs;Contr. = $2,000

• -^ -.,, <,.Est'd Savings =$1.6 million

Factual Basis: In design. PRPs investigated this possibility; no loss in protection.

3/26/97[ESD]

7/15/96

10/15/96

EPA,State,PRP

Groundwater Public notice. Fed » 80 hrs;Contr. = $0

Est'd Savings =$0.5 million——— ___ ___________________.

i Fron - use of newly constructed extraction well for containment; To - use of existing well for containment» "™ ~"—————^—„—.Factual Basis: New well can't capture plume, subsequently old well more effective treatment

f\l* f /rt o I - - -

Public notice ; publk meeting held;6727/97[ROD-A]

Soil,Solid Waste,Groundwater

State concurred with change.

_______________________________

Type of Change: Prom - soil/solid waste treatment; To - off-site disposaland con

= 500hrs;Contr. = $100,000

Est'd Savings =

P Region 5 - FY96

Region 5

Cannelton Industries, MI

1

Region 5

ilectrovoice, Ml

Region 5

Kummer SanitaryLandfill, MN

9/30/92

9/27/96[ROD-A]

1/15/95

1/15/96

PRP Sediment,Soil

State concurred with change;proposed plan made available topublic; publk meeting held;community supportive of change.

Fed = 240 hrs; 1Contr. = $100,000 1


Type of Change: From - on-site containment; To - off-site disposal.Factual Basis: New data from pre-design investigations showing little groundwater contamination and confirmed minimalleaching and movement of contaminants; community preference; change in State ARARs for land use.6/23/92

5/23/96[BSD]

7/31/95(phone) or8/4/95(written)

8/11/96

PRP Groundwater,Sludge,Soil

State concurred; fact sheetdistributed to community.

Fed = 160 hrs;Contr. = $25,000


Type of change: From - perform subsurface volatilization and ventilation system study; To - no need to expand subsurfacesystem due to revised cleanup standards.Factual Basis: Treatability study results and change in Michigan environmental law.9/29/90

1 1/21/95[ROD-A]

5/24/95

9/14/95

State Groundwater,Leachate,Soil

State initiated remedy update andwrote ROD-A; proposed plan madeavailable to public; public notified;public comment period mcroded;public meeting held

Fed =120 hrs;Contr. « $3,480

Est'd Savings =$5.6 million J

Type of Change: From - advanced oxidation process (AOP); To - bioremediation and groundwater monitoring. |Factual Basis: Additional site data shows change of receptors, decomplication of AOP; more cost-effective and reduces waste vohi]

cmiwfc nf qftqi*niFnaBUt «nd technical and fpwriH«tity 1me. , , - . .-..,- :,' -. r > 1

28

Region 5

Metamora, MI

Region 5

Pristine, Inc., OH

Region 5

Isturgis Municipal Field,MI

^^^•KlMHHH

9/30/86

8/28/96[ROD-A]

^ •• MB

4/12/95

4/23/96

•••• ^MPRP,EPA

i^^^MMMM^M^MH

Residuals,Soil

State and community involved inROD amendment; Congressionalinterest in site - EPA responded toseveral controlled correspondenceletters from residents that did notsuppof the change.

Fed = 300 hrs; 1Contr. = $200,0006 1

Est'd Savings = 1$29 million I

Type of change: From - inc neration; To - relocation of waste and inclusion (containment) under a landfill cap. |Factual Basis: Improved understanding of the nature of the soils threat and more cost-effective. 112/31/87

4/24/96[BSD]

7/11/95

4/9/96

EPA Groundwater,Surface water

State agreed with waiver ofantidegradation requirements.Public notified through newspapernotice; fact sheet distributed.

Fed = 300 hrs; 1Contra $10,000 1

Est'd Savings = 1$15 million |

Type of Change: From - compliance with Ohio effluent limitations; To - waived State anti-degradation requirements. |Factual Basis: Waiver due to information indicating the technical impracticability of chosen technology to meet State 1requirements. |9/30/91

9/10/96[ROD-A]

3/22/96

9/10/96


Public comment period; noindication of community interest;State involvement (site becameState enforcement lead).

Fed = 30 hrs; 1Contr. = N/A 1


Type of Change: From - attain groundwater cleanup levels; To - State Federal MCL's, and From - off-site disposal ofpolyaromatic hydrocarbons (PAH)-contaminated soil; To - eliminate need to address PAH-contaminated soil.Factual Basis: New data in pre-design investigation indicated reduced soil vontanflfiption levels.

6 Performed intensive oversight of PRPs; conducted and reviewed additional sampling; and coordinated extensively withinterested parties. x

) )29

r™"~Region 5

Wash King Laundry, MI

•

•i ^^^^M^^B

3/31/93

7/1/96[ESD]

^^^^•^^^•i11/1/95

1/1/96

^ ••MM

EPA,State

^^^^^^•^^^^•MGroundwater,Sediment,Soil

Public comment period; feet sbeetdistributed fo^HHpyMiy •"*"•'-" Contr. = $0 I

$6.2 million 1

Type of Change: From - removal of trace metallics in groundwater resulting in surface water discharge; To - reinjection of Itreated groundwater. _ . IFactual Basis: Post-ROD sediment content and groundwater modeling results. ~ -• 1

Region 6 -FY97 , IRegion 6

Bailey Waste Disposal,TX

Region 6

Brio Refining, TX

6/28/88

12/16/96[ROD-A]

7/95

12/16/96

PRP Soil Public meed ig; no public concern ,expressed; State provided letter ofsupport for change.

Est'd Savings =$ 5,4 million

Type of Change: From - stabilization and capping; To - capping only.Factual Basis: Failure of stabilization in field testing. ,3/31/88

7/2/97[ROD-A]

9/1/94

7/2/97

Comm. Soil State concurred; extensivecommunity involvement,Community Agyisgry Groupformed by EPA* Pnbbc notified;public meetfcgheli State providedletter of support fofdiange. ^ .

Fed = 1000 hrs7;G>ntr. = $25,000 1

Esfd Savings = 1$20nrilUon 1

Type of Change: From - or. -site incineration of VOCs; To - containment system for YQCs-gKhvimg cap/stony wall.Factual Basis: Focused feasibility study information showed high escape of fog' ive enrissfecs for uKineraticw remedy andcostly engineering controls, leading to community preference for containment " i

^ -. .-^'."i---:>:; ^-'^;T.^:"'-- :7 Intensive resource effort in responding to Community Advisory Group concerns during remecry development process.

30

Region 6

Cleveland Mill, NM

Region 6

Crystal Chemical, TX

Region 6

PAB Oil and ChemicalServices, LA

9/22/93

7/11/97[Other: ActionMemorandum]

5/15/97

6/12/97

EPAtPRP,State

Sediment,Soil

EP A held open bouse anddiscussed changes with members ofcommunity.

Fed = 300hrs; 1Contr. = $0 1

Est'd Savings = 1no net savings |

Type of Change; From - off-site reprocessing and reclamation, disposal of residuals; To - on-site lime neutralization and 1disposal in limestone cell with multilayer cap. |Factual Basis: Poor site conditions (recent heavy rainfall) and lack of reprocessing facility to accept waste. |9/27/90

3/19/97[BSD]

2/96

3/19/97

PRP Groundwater State concurred. Public notified;public comment period - fewcomments received; publicmeeting, public open house.

Fed=1000hrs8; 1Contr. = $0


Type of Change: From - pump and treat; To - containment with a slurry wall.Factual Basis: Design investigation and evaluation study data and approval of a technical impracticability waiver.9/22/93

3/12/97[ESD]

12/96

3/12/97

PRP Sludge,Soil

EPA held open house; noopposition from community; Stateprovided letter of support forchange.



Type of Change: From - biological treatment and solidification/stabilization; To - solidification/stabilization only.Factual Basis: Revised precision and detection limits of analytical test procedures.

8 Intensive technical review and development of technical impracticability par1r31

TX

gion 6

uth Cavalcade Street,

9/26/88

6/27/97[ROD-A]

Type of Change: ]

9/27/95

6/27/97

PRP Soil,Groundwater

State concurred; poblk notified;public comment period; publicmeeting; very little communityinterest.


Est'd Savings »SSTmflOon

Prniri - $nil washing qnH tftfttment; To - concrete C*p »«d COn*an"nMlfc^ 'T— «" ^ - '

Factual Basis: Soil washing failed pilot test.Region 6 - FY96

Region 6

Bailey Waste Disposal,TX

6/28/88

2/28/96[ESD]

7/95

2728/96

PRP Soil Fact sheets provided byJPA tocommunity; Stale provided letter ofsupport for change;

Fcd>300hrs;'

EstM Savings$.9 million

Type of Change: From - relocation, solidification/stabilization, and capping; To - off-site disposal in industrial waste landfill.Factual Basis: Improved timeliness of remedy and increased waste stabilization.

Region 6

Bailey Waste Disposal(?it-B), TX

6/28/88

5/1/96[ESD]

7/95

5/1/96

PRP Soil Fact sheets provided^JgPA tocommunity; State provided letter ofsupport for change. „ . . _ - -

Fed « 200 hrs;Contra $0

no net savingsType of Change: From - relocation, solidification/stabilization, and capping; To * off-si&duFactual Basis: Improved timeliness of remedy, technical difficulties in implementing original remedy, istabilization.

Region 6

Oklahoma RefiningCompany, OK

6/9/92

3/27/96[ESD]

9/95

3/27/96

EPA Soil Pubtic notified; ESD• ; • - • - ; . T^~ »--/ HiAdmmistrat

concurred:

Type of Change: From - recycling or ]Factual Bads; New information during value engmcering stody.

Region 6

Vertac, Inc., ARNumerous public meetings; Stateprovided letter of support forchange.

Est'd Savings =$3 million*_____________ ______________ i $j minion-

Type of Change: From - on-site incineration of soils with >260 ppb TCDD; To - landfilling all soils contaminated >5 ppb.Factual Racic Vmwni«;*« •*—*"-——— */-»-— «- • —Factual Basis. Jommunity preference. *Cost Savings: From - Proposed Plan; to • ROD-A.

Public comment period; publicComhusker ArmyAmmunition Plant, ME

Est'd Savings =$6 millionType of Change: From - discharge point to Platte River; To - discharge point to on-site drainage ditch.

w t .-, -_ —. «« wiMtiagt; U11V1I-

Factual Basis: Public concerns regarding impact to groundwater and migration of contaminants offsite.n/n-» ' . . --—-Region 7

McGraw Edison, LAState review and verbal Fed = 25 hrs;

Contr. = $0

Est'd Savings =$0.2 millionType of Change: From - groundwater extract and treat system with acti ated carbon; To - pretreatment via air stripping.

Factual Basis: Cost-effectiveness of treatment train.Region 7

Peoples FMGP, IAState review and concurrence. Fed = 38 hrs;

Contr. = $0

..__________,___!,_____\___ f .'C^r^Type of Change; From- incineration of wastes at PRP^wned boiler, To - iocin^Factual Ra*J«? T«*K«;/««I *»««•«» -**u- _•*-__ •• - • • - ^—

| Region 7 -FY96

•Region 7

•Chemplex, 1A

•Region 7

•Doepke - Holliday, KS

•Region 7

•Hastings Well #3 OU #13,INE

9/27/89

1/26/96Other, letter to

file]

12/4/95

1/26/96

PRP Groundwater State concurred; public availabilityofchange.

Fcd*50brs; 1Qobtr,*$0 1J^£-i^:~ •' " ' " " 1

Est'd Savings = 1mM 1

Type of Change: State regulation standard for tetrachloroethylene (PCE) amended: Prom - .7 ug/l standard; To -5.0 ug/l. 1Factual Basis: Previous standard impractical based on new data.9/21/89

2/6/96[BSD]

2/16/95

2/6/96

PRP Groundwater,Leachate,Surface Water

State concurred. Public notified;ESD placed in AdministeativeRecord; no comments received.

Fed«240hrs; 1Contr,« $11,200 1

Est'd Savings = 1$1 million 1

Type of Change: From - collection and treatment; To - monitoring after installation of multi-layer cap. 1

Factual Basis: Groun iwater seepage is occasional and continues to be monitored. 1

6/30/93

7/23/96[BSD]

11/95

7/23/96

City Groundwater State and EPA concurred. Cityinvolved.

--.*.: \ ~:*: '," ':•.- -

Type of Change: From - reinjection; To - potential reuse of extracted groundwatcr.

Fc4=100hrs; 1Contra $10,000 1

Est'd Savings = 1no estimate 1

.'j- fltîT^»»H - 1

1Factual Basis: Groundwater to be used for spray irrigation. |

.-.«•- V«*s**s*>?- 3--ii; :• .•* ---*it^ • ' - i - f f - i 'T" ' p r -« •

John Deere DubuqueWorks, IA

Region 7

McGraw Edison, IA

Region 7

Mid-America Tanning, IA

Region 7

Red Oak Landfill, IA

Factual Basts: Attainment of goal was impractical; no loss in protection.

State concurred with change;

level of 750 ppb for TCE.

11/28/95[Other: letter tofile]

10/27/95

11/28/95

Type of Change: From - State MCLs deferral; To - Federal MCLs.

State concurred; public availability Fed = 30 hrs;of change. Contr. = $0


of Change: From - cleanup level of 200 ppb; To - cleanup

Fed = 60 hrs;Contr. = $10,000


Factual Basis: Supplemental source soil/ground water modeling.9/24/91

7/29/96[ROD-A]

3/14/95

10/25/95

EPA | Sludge,Soil,Solid Waste,Surface Water

Type of Change: jtrom - m-situ stabilization and capping; To -and more impenetrable cap barrier.Factual Basis: New information showing presence of H2S gas.

7/95 I EPA I Groundwater,Soil

State concurred; no publiccofoments. EPA offered to holdpublic meeting.

Fed = 200 hrs;Contr. = $5,000


StabiHzadon for «* «« highly contaminated sludges

1/31/93

1/30/96[ESD]

1/30/96State concurred; public availability I Fed =150 hrs;of change; public was notified. Contr. = $0


= 53nrs;Contr. =

Public notice in local paper, publicmeeting; DOE contacted citizen'sgroup; State involved throughoutchange process.

Debns,Soil,Solid Waste

Region 7

Weldon Spring, MO 1/18/96[ESDI Est*d Savings

$0Type of Change: From - use of separate landfills; To - combination of landfills.Factual Basis: Similar waste on adjacent DOE property; value engineering study

Region 8-FY97Fed=160nrs;Contr. = $12,000(incl. 5-yr review)

State reviewed and providedcomments on ESD; public noticeand fact sheet

Groundwater,Soil

1/22/97[ESDI

Est'd Savings =probably no savings

Region 8

iLibby Groundwater, MT

Type of Change: From - excavation and biotreatment of soils within on-site land treatment unit, in-situ biotreatment ofgroundwater, and pump and treat/bioreactor system; To - new MCLs for certain groundwater contaminants and revisedremediation levels.

Factual Basis: Revised toxicology assessments and change in promulgated MCL for primary contaminant.[Region 8

(Ogden Depot (OU2). UT

9/7/90

10/15/96[ESD]

3/1/96

10/15/96

Fed. Fac. Groundwater State reviewed and concurred withthis proposal.

= 20hrs.Contr.» $640

Est'd Savings =None

Type of Change: From - Treat groundwater until cleanup level is below MCLs; To - Treat groundwater until cleanup level is ator below MCLs.Factual Basis: Original objective was too stringent by law.

[Region 8

Summitville Mine, CO

Region 8

Sumrrutville Mine, CO

Region 8

Chemical Sales, CO

^^•^M^^^MHMI^B

12/15/95

5/16/97[Memo to files]

•IM^^MHP^^^^

1/15/96

5/30/96

EPA Surface Water Colorado Department of PublicHealth and Environment.

Fed= hrs. 1Contr. = not included 1- in part of standard 1design 1

Est'd Savings = 1$350.QOO 1

Type of Change: From - Acid mine drainage discharged to treatment plant; To - Acid mine drainage discharged to surface Iimpoundment and then treatment pnor to release. |Factual Basis: Modifications were made in the Water Treatment Interim ROD to optimize the performance and minimize costs 1of the selected remedy during remedy design. 112/15/95

6/4/97[BSD]

9/1/95

4/1/96

EPA,State

Leachate State concurred. Fed = 0 hrs; 1Contr. = $0 1

Est'd Savings = 1$1.7 million |

Type of Change: From - in-situ biotreatment of cyanide and cap; To - rinsing with clean water and treatment of leachate.

Factual Basis: Cyanide levels in leachate were reduced without biological treatment.

6/27/91

12; 11/95[ESD]

Region 8- FY963/93

11/1/95

EPA Soil,Groundwater

State concurred with ESD andchanges to selected remedy. ESDplaced in Administrative Record.

Fed =180 hrs;Contr. = $10,000


Type of Change: From - recirculation of treated exhaust gases into soil, and air stripping of groundwater; To * eliminate 1recirculation of soil, and air sparging for groundwater, and From - catalytic oxidation of soil vapors; To - resin absorption. |Factual Basis: New hydrogeologic information obtained during design and mote effective itmedy. |

•• • ™^^""^^^^™Region 8

Idaho Pole, MT

Region 8

Old Minot Landfill, ND

Region 8

Wasatch Chemical, UT

9/28/92

5/21/96[ESD]

6/95

12/95

PRP,EPA

Groundwater,Soil

State reviewed and ptovided tcomments on BSD; pubiicmeedngand fact sheets.

Comr> $10,000 1r:'V;:-:- IEst'd Savings = Inot available |

Type of Change: From - water flushing of soils and biological treatment of groundwater. To - ambient temperature water 1flushing of soils and carbon adsorption of groundwater. , . . r^ •- |Factual Basis: Additional information in design replaced design problem in original ROD remedy. 16/21/93

5/2/96[ESD]

1 1/7/95

5/2/96

PRP Leachate,Landfill gas

City involved in ckannp; limitedcommunity interest

FfcUlOOhrs; 1

Bst*d Savings = 1$0.3 million |

Type of Change: From - active methane gas extraction and leachate collection system; To - passive collection system and 1cap design changes, and From - proposed active leachate extraction system, To - passive gravity drain system and limits ofburied waste extended.Factual Basis: New information regarding limits of buried waste and equivalent protection at less cost.3/29/91

11/30/95[ESD]

5/17/93

6/9/95

PRP Groundwater,Soil,Surface water,Site boundary

State concurred Fact sheetsprovided to community and State.

Fed - 80 hrs;Contr, = $4,QOO

Est*d Savings =$244,000

Type of Change: From - asphalt cover for soils; To - eliminate cover to prevent stormwater control problems and change siieboundaries. \ 'Factual Basis: Additional data from investigations during design, including reduction, of sôonwater discharge and differencesin site boundaries. "*" ~. _, . . , ; ;: ; -c-: -•

Region 9 - FY97 |

Region 9

Apache Powder, AZ

Region 9

Fort Ord, CA(OU 2)

Region 9

Lawrence LivermoreNational Laboratory(Main Site), CA

9/30/94

4/16/97[ESD]

11/96

2/97

EPA Groundwater Public meeting! State comments. Fed » 600 hrs; 1Contr. = $3,000 1

Estfd Savings = 1$13M 1

Type of Change: From - Extraction from 7 wells in perched ground water with treatment by brine concentrator; extraction 1from 4 wells in shallow aquifer with treatment by constructed wetlands; To -Extraction from 4 total wells in shallow aquifer 1with treatment in 2 constructed wetland systems in different locations. 1Factual Basis: Reduced nitrate and water levels in perched ground water enabling dewatering of this zone by pumping from 1shallow aquifer and elimination of brine concentrator. Wetland location change enabled simpler construction, including 1elimination of pond liners. |8/94

1/17/97[ESD]

1/97

Fed. Fac. Soil State concurred; public meeting;60-day public comment period.

Fed = hrs; 1Contr. = $0 1

Est'd Savings = I$11 million

Type of Change: From- Landfill cap; To- Consolidation of wastes into the existing landfill from other Fort Ord wastes andsubsequent capping.

Factual Basis: Cost and groundwater modeling. Savings resulted from avoiding cost of offsite disposal of soil from other sites.

7/15/92

4/16797

[ESD]

1/97

4/97

DOE/LLNL

Groundwater

Type of Change: From - Use of ultraviolet/hydrogen peroxide (Uat treatment facilities A and B (TFA and TFB); To * Air stripping

Cal/EPA(Both DTSC andRWGCB) involved.Public notified during publicmeetings; no public commentsreceived.

V7H2Oj) and air stripping groundwateronly groundwater treatment $y$t$ijtt £t

Fed = hrs;Contr. =

Est'd Savings =$220,000/year

treatment technologiesTFA and TFB.

Factual Basis: Sampling results show VOC levels decreasing; no UV/H& system oeedeâirstrîplng alone OK.

Fed= brs;Contr.=

Cal/EPA involved.Public notified daring publicmeetings; no public commentsreceived.

Groundwater

4/15/97[BSD]

Lawrence LivermoreNational Laboratory(Main Site), CA

Est'd SavingsNone

Type of Change: From - Fixed metals discharge limits; To - Seasonal (wet/dry season) metals discharge limits.

Factual Basis: Changes made after original discharge permit expired. Seasonal limits are more protective.

= 600hrs;Contra $5,000

No objections from State orcommunity.

Groundwater

San Fernando Valley Areal.BurbankOU, CA Est'd Savings =

$49 millionType of Change: From • extract and treat groundwater using air or steam stripping and vapor phase granular activated carbon;To - extracted volume reduced by 25%. ^^Factual Basis; New information from design review process and reduced volume levels.

(Region 9

Iselma Pressure Treating,iSelma, CA

9/88

4/18/97[ESD]

3/97

4/97

EPA Groundwater DTSC reviewed and commented;fact sheets were sent to people on acommunity distribution list; publiccomment period providect

Fed= hrs;Contr. = $

Est'd Savings =Type of Change: From - Return of effluent via reinjection wells; To - Return of effluent via percolation poods.

Factual Basis: Reconsideration of certain technical information during design and additional data gathered pursuant to ROD.

legion 9

jcson InternationallAirport, AZ

8/88

2/27/97[ESD]

11/94

2/97

Fed. Fac. Air,Groundwater

State and community support thechange. - ., v.^-&--v*>'->-"-

Fed = 200 hrs;Contr. »$0

Tfrpc of Change; Prom -air stripping and momrip«leodoie;TQ| Factual Bate Commonity and city objected to delivery& £>^-.J?ttfcy~-*-

r ——————[Region 9

(United Heckathorn Co.,IcA

10/26/94

11/96[ESD]

7/95

11/96

PRP Sediment State and community generallysupportive.

ffejff700hrs; 1Contr. = $0 1

Estfd Savings =no net savings

Type of Chant ?: From - dredged material disposed at one landfill; To - different landfillFactual Basis: More rapid usposal.

Region 9 -FY96Region 9

Fort Ord, CA(OU2)

Region 9

Koppers (Oroville), CA

8/94

8/13/96[ESD]

8/13/96

Fed. Fac. Groundwater State concurred. Fed = hrs;Contr = $0

Est'd Savings =None

Type of Change: From- Unestablished lower aquifer cleanup levels; To- Establish lower 180 ft. aquifer cleanup levels.Factual Basis: Set ground water cleanup levels at MCLs. 1

9/89

8/29/96[ROD-A]

3/94

8/96

PRP Soil High level of State and communityinvolvement and support. Publiccomment period; public meeting;fact sheet issued; City and Stateconcurred.

Fed =1600 hrs9;Contr. = $15,000i

Est'd Savings =$15 mil lion

Type of Change: From - innovative treatment of soils to residential levels; To - Excavate and dispose in an on-site landfill to 1industrial land use levels. |Factual Basis: Treatability testing results were unfavorable to original technology, discovery of more extensive mixed 1contamination, and change in land use scenario. 1

9 Long-term project with extensive community involvement; severe differences hi design compared to actual contamination;EPA made many changes to ROD.

41

[Region 9

IMiddlefield - EHis -IWhisman (MEW) StudylArea, CA

6/89

4/6/96[ESD)

PRP Groundwater None. Fed^SOO fars;Contr.=

Est'd Savings =$150,400

Type of Qumge: From - Air stripping with vapor phase granular activated carbon (GAQ treatment; To - Air stripping withliquid GAC treatment.

•Region 9

iNineteenth Ave. Landfill,•AZ

Factual Basis: Numerical standards characterized as "goals" in the original ROD are now the final cleanup "standards" per the IESD. - - : ' • . : 19/29/89

11/95[ESD]

11/94

11/95

PRP,State,Comm.

Groundwater,Leachate,Solid waste

State-lead project; Stale andcommunity Technical AdvisoryGroup requested change.

Fed = 40 hrs; 1Contr. = $0 1

Est'd Savings = 1not available (higher 1capital cost, lower 1maintenance cost) |

Type of Change: From - old liner system; To - different type of impermeable liner. 1

•Region 9

•Phoenix-Goodyear, AZ

Factual Basis: To reduce maintenance problems and improve reliability. I9/26/89

12/22/95[ESD]

10/94 (oral),9/95 (written)

12/95

EPA,PRP

Groundwater No State or community opposition.Public notified; public commentperiod; ESD and other documentsplaced in A^njinistrwdrve Record.

Fed = 80 hrs ; 1Coritr. = $0 ' 1

Est'd Savings - 1not available |

Type of Change: Fr^m - pump and treat using air stripping followed by liquid phase granular activated carbon; To * air 1

Factual Basis: More effective and accelerated removal of VOCs; treatabitity study indicating more, effective removal ofchromium from groundwater; cost-effective response. .ill!- *—«»

4?

Region 9

Purity Oil, CA

Region 9

Williams AFB, OU2, AZ

9/92

7/3/96[BSD]

8/95

7/96

PRP Soil State support; no communityobjections.

Fed = 1000 hrs10; 1Contr. = $0 1


Type of Change: From - slurry wall and extensive soil vapor extraction system; To - no slurry wall and change in design of Isoil vapor extraction. 1Factual Basis: New information on soil and waste characterization in pre-design. 112/30/92

8/16/96[ROD-A]

5/96

8/96

Fed. Fac. SoilGroundwater

The public was invited to commentthrough public comment periodsadvertised in local newspapers andpublic meeting. The RAB wasbriefed in the proposed change inremedy.

Fed= hrs;Contr. = $

Est'd Savings =TBD

Type of Change: From - Separated deep soil (>25 ft.) into OU3; To - returned deep soils into OU2 and propose SVE to treatdeep soils.Factual Basis: Results of treatability studies performed at OU2 and OU3. |

10 Intensive in-house technical and enforcement review over 2-year period; multiple meetings of the EPA team and PRPs.

Region 10- FY97

Region 10

Commencement BayNearshore/Tideflats, WA

Region 10

Gould, OR

9/30/89

7/28/97[ESD]

6795

7/28/97

PRP Sediment Fact sheets/public notices andmeetings held; responded to >50comments (verbal/written). Stateconcurred but Puyaltap Tribe didnot concur.

_ 1Fed* 2,000 hrs"; 1Contr. = $7,000 1


Type of Change: From - PCB sediment cleanup levels after 10 years; To - Slightly higher levels of PCBs in 1sediment immediately after cleanup and after 10 years. 1Factual Basis: New modeling (toxicity and exposure assumptions) and cost estimates justified new response levels. I

3/31/88

6/3/97[ROD-A]

5/94

6/3/97

PRP Debris,Sediment,Soil

State reviewed and concurred; factsheet distributed to community;other interested partita and PRPs;no comments from community.

Fed = 800 hrs; 1Contr. = $0 1

Est'd Savings = 1$15 million

Type of Change: From - treatment and recycling of lead contaminated materials; To - treatment; and containment (stabilizewaste and consolidate in a lined and capped on-site containment facility). _.^.~^Factual Basis: Additional investigation showed volume of waste is smaller than originally presumed and new remedy is moreefficient and cost-effective. Cleanup activities coordinated with adjacent facility.

11 The process took over one year - involved numerous reviews and responses tbpublic; and reviewed technical decisions. f s

Region 10

Hanford 100 Area, WA

Region 10

Teledyne Wah Chang, OR

4/4/97[ROD-A]

4/96

4/4/97

EPA,State,Fed. Fac.

Type of Change: From - excavation, treatment

Debris,Soil,Solid waste

Public notices - received commentsupporting change; fact sheetsissued; Fed. Fac. SponsoredAdvisory Committee meeting; Stateconcurred.

EPA: 4 mos., DOE:12mos. + 3FTEforcontractors. State: 8mos.

Estfd Savings =$297 million

6/KV94

10/8/96[ESD]

3/96

9/19/96

PRP Groundwater,Sediment,Soil

Public notice; public commentperiod; no comments received;State was pan of negotiationsleading to change and concurredwith ESD.



: Modifications to ground water remedy: From - groundwater extraction at and outside the plant boundaries;ifiiral off*ni!«*<;».. *

_ ___„„-.. .—«,.« e-vui<u TYditi icaieuy: rrom - groundwater exTo - on-site hot-spot ground water remediation and monitored natural attenuation.•i. • •* - - ..... _._ ...»i..vviwu tiavuioi aucauauon.

Factual Basis: Monitoring of groundwater during design indicated significant decreases of concentrations.•QAWflA ' ^n^ ' "Region 10

Toftdahl Drums, WAState discussed proposed changes Fed = 6 hrs;

Contr, = $0with nearby residential propertyowners; State and EPA issuedpublic notice (no comments). Est'd Savings =

$5.000Type of Change: From - 15 years of groundTo - cease ground water monitoring after 10 yearsf_f. . ,,__—• QkWMUW »*

Factual Basis: Monitoring determined that no threat posed to public health and saf

Region 10 - FY96

IRegion 10

[Bunker Hill Mining and[Metallurgical Complex,llD

d>c.

9/22/92

9/9/96[ROD-A]

Type of Change:

•V —— MMMMH^M

L/6

9/9/96

EPA Soil Notices and public meetings;only one comment letter receivedfrom Coeur d* Alene Tribe; Stateconcurred with change.

Fed = 200 hrs; 1Contr. = $3,500 1

Est'd Savings = 1$6.2 million |

From - .tabilization/cap in a closure cell; To • waste encapsulation and cap. 1

Factual Basis: Post-ROD teachability study inconclusive for previous remedy; new remedy provides cost-effectiveness for 1

JRegion 10

IHarbor Island (Soil andJGround Water OperablelUnil). WA

9/30/93

1/25/96[ROD-A]

4/11/95

1/25/96

PRP Soil Public notice - few commentsreceived; State concurred withchange.

Fed a 200 hrs;Contr. = $0

Est?d Savings =$2 million

Type of Change: From - thermal desorption of petroleum- contaminated soil; To - off-site disposal of petroleum-contaminatedsoil that is not a hazaidous nor dangerous waste.Factual Basis: Re-evaluation of site conditions and options provided more cost-effective and timely but still protecdve clean"Pi_______

(Region 10

(Western Processing, WA

9/25/85

12/11/95[ESD]

9/12/95

12/11/95


Fact sheet issued; local governmentand State support; low level ofcommunity interest.

Fed = 700 hrs;Contr. = $30.000


Type of Change: From - slurry wall and pump and treat for contaminant mass removal and protect surface waters; To -source contaminant with inward gradient within slurry wall, plume containment outside slurry wall, bioremediation, and othertreatment of hot spots.Factual Basis; Updated information after 5+ years of pumping and more cost-effective j

Appendix A.2:Summary of Remedy Update Information for FY96 and

FY97 for Sites With Cost Increases

NOTE: The information and data presented in Appendix A.2 represents only a portion of theinformation available in the decision document. If more information is needed, please refer tothe site's ESD, ROD-Amendment, memo-to-file, or letter.

Appendix A.2: Sy*nmary of Remedy Update Informatio/ for FY96 and FY97 forSites with Cost Increases '

legion 2

tobintech, NY

Region 2

^mperial Oil/ChampionIhemical. NJ

legion 4

roIeman-Evans Woodreserving, FL

7/97[ROD-A]

1/97

9/97

low temperature thermal

9/90

9/97[ESD]

7/96

7/96

Soil,Groundwater

Some State and public interest. Fed = 200hrs;Contr. = $

Est'd Increase =$700,000

, and overburden groundwater; To - Excavate and treat usingfor soils, natural attenuation for overburden groundwater and treatment of bedrock aquifer.

EPA State concurrence, full State andcommunity support.

Fed = lOhrs;Contr. =$

Est'd Increase =TBD

excavation and off-sue

Factual Basis9/25/86

Comprehensive sampling data in design showed a greater value of soil contamination presenti • i-^«—«^—••

9/25/97[2nd ROD-A]

Groundwater,Soil, Sediment

State supported EPA throughoutthe process. Fact sheet issued topublic, no comments received.

Est'd Increase -_________________,$12M

' bioremediation, and solidification/stabibzation; To - Tlwrmal desorption with a

= iOOO'hrs;Contr. = $250,000

Factual Basis:amended. Due to the discovery of dioxin at the site and the inability of bioremeination to trea^^dioxin, ihc^remedy was

- - ' ''

'Evaluated treatability study results; prepared supplemental feasibility study; extensive characterization of dioxin, both onsite and offsite; conductedpublic meeting and community interviews; and negotiated with the State.

^^—————(Region 4

National ElectricCoiiyCooper Industries,KY

4/96

7/97[ESD]

•MHIMM^^^B^M

11/5/96

7/97

• ^ ••• ^MPRP Groundwater

—————— . . .,;-^.'. .'., >-• JII--H 'State concurred wi&JBSP.Public was notified by factsheet.

• ****• ~ •"'•• •fed=200hrs; I

JBst'4 Increase = 1$300.000 1

Type of Change: From - Extraction wells; To - interceptor trench for "shallow" groundwater recovery method. 1

[Region 9

IWestinghouse, CA

Factual Basis: Shallow aquifer was determined to be poor water formadon during;dry periods; trench is a more passive means Ito recover contaminated water. .. .. v --• - ;r ' -V,;" |

10/16/91

3/14/97[ESD]

1/94

2/97

PRP Soil Notified community via tactsheet and community meetingheld 2/20/97.

Fed= hrs; 1Contr. = $ 1

Est'd Increase = 1$500,000 1

Type of Change: From - Incineration of PCB soils with concentrations greater than 25 ppm; To - Landfilling PCB soils with 1concentrations between 25-500 ppm and incinerating soils with concentrations greater than 500 ppm. |Factual Basis: The ESD only applies to newly discovered contaminated soil found in the North parking Lot. PRP requested 1change which is applicable for TSCA. Change requested because company wanted to sell half of parking lot acreage to a 1corporate neighbor who will use the lot to build a warehouse. 1

Appendix B:Summary of Regional Implementation Plans

NOTE: EPA requested that Regions provide their strategy for implementing the UpdatingRemedy Decisions reform. The following implementation plans should be viewed as "living "documents, and subject to possible future revisions.

Appendix B:Summary of Regional Implementation Plans

11/25/97 Region 1 has developed draft criteria toreview sites and remedies. These havebeen forwarded to EPA Headquarters.

Region 1 continuouslyreviews remedies with Statesand PRPs to identify any newtechnologies or policychanges that could expeditethe cleanup.

Region 1 is receptive to PRPrequests for modifying aremedy.

There is no backlog of PRPrequests in the Region.

Region 1 anticipatescompleting remedy updates atsix sites during FY98.____

Pagel

Region Date Strategy for Food-lead Sites Strategy for Other-leadGeneral Comments

1 /18/98 The Region 2 remedy review team willmeet for four hours per week to reviewRODs, design c1 »cuments. Five YearReviews, or other technicaldocumentation of the remedy and forteam discussion with the RemedialProject Manager (RPM). The team* sgoal will be to provide assistance toRPMs in determining if a remedyupdate could benefit site cleanupactivities.

The focus of the reviews will be onolder remedies. The team willgenerally not consider sites that arecurrently targeted for constructioncompletion by the end of year 2000.

The team will also review any site thatthe RPM requests. The group willprovide a monthly status report to theDirector which will indicate thenumber of remedies reviewed and thestatus of the work grouprecommendations. In five months, allFund-lead operable units whereconstruction has not begun will havebeen reviewed

Region 2 continues t -> reviewevery proposed remedychange requested byresponsible parties (RPs).

The site project manager andthe appropriate technical staffand management will conductall reviews of PRP-proposedchanges.

Region 2 will continue to trackevery request to review aremedy and will report on thenumber of ESDs or RODAmendments issued.

Region 2 will track theestimated cost savings ifappropriate.

The entire review is expectedto last approximately fivemonths.

-C.vvK,- '.**•

Page 2

All remedies at Fund-lead sitesshould be evaluated forpossible changes during theFive Year Review. Reviewswill be conducted by the site'sRPM, the ORC attorney, theRemedial Section Chief and amember of Regional technicalsupport group. Region 3 mayalso involve the Office ofResearch and Developmentand the Remedy ReviewBoard.

Any potential remedy changecan be considered up until theRemedial Design (RD) phaseis 30 percent complete.

New technologies and morecost effective strategies will beperiodically reviewed as partof the monthly Regional RPMmeetings.__________

All remedies at PRP-lead sitesshould be evaluated forpossible changes during theFive Year Review.

Changing the remedy isalways open to discussion.RPMs create a climate of opendiscussion with RPs and areopen to review requests at anytime.

New technologies and morecost effective strategies will beperiodically reviewed as partof the monthly Regional RPMmeetings.

RPMs Will also maintain theresources to implement theoriginal remedy, should theremedy change not be feasible.

Page 3

12/22/97 Remedy review considerations occur continuously at allRegional remedial sites throughout the RD phase (and to somedegree during the early stages of Remedial Action (RA)).

Requests from EPA, the PRP, the State, or Federal facilities cantrigger a remedy review.

All remedies will be evaluated as part of the Five Year Reviewprocess, which will occur at least once on all sites and will occurevery 5 years for all long-term response actions.

Supplemental alternatives that demonstrate a likelihood ofsignificantly decreasing the duration of a long-term remedialaction or attaining a much better end-point at potential technicalimpracticability (TI) sites will be considered in the routinereview process of evaluating remedy implementation.

The primary criteria Region 4 willuse to determine whether to revisea remedy are: 1) Is it equally ormore protective of human healthand the environment? 2) b it morecost and/or technically effective?3) What effect will the remedychange have on the speed andtimeliness of cleanup?

For FY 98, Region 4 will continueto identify and track sites that areevaluating alternative approachesto the remedy selected in theROD.

Pmge4

12/16/97 The Region will continue to respond to requests for remedychanges from stakeholders (PRPs, States, communities).Requests can be made verbally or in writing and should initiallybe directed to the site RPM.

The Region will use a portfolio management concept for updateswhich includes:• A niform set of critical project milestones for each phase of

the remedial pipeline; and- A set of questions for use during the RI/FS/Remedy

Selection phase to enhance the dialogue between RPMs andfirst-line managers on areas of national programmatic focus(e.g., lead, groundwater, National Remedy Review Board(NRRB) criteria).

In FY98, first-line supervisors will expand the dialogue witheach RPM to include a discussion on potential for updating thesite remedy.

Region 5 is committed to exploring the development ofOperations and Maintenance (O&M) experts during FY98.O&M experts will review projects in long-term ResponseAction for possible changes.

During FY96, remedy updateswere completed at six sites, for anestimated $58.1 million in costsavings. During FY97, remedyupdates were completed at 16sites, for an estimated $ 137.1million in cost savings.

For both years, the majority ofremedy changes were initiated byPRP requests.

Page 5

DateSubmitted -lead Sites Strategy for Other•!»*»&• General Comments

12/16/97 Any site where a remedy has been selected may be revieweu.

Requests fr: a remedy update are evaluated by the Regionaloffice.

A review may be triggered by:A request from a PRP, a State or local environmental orhealth apency, or a community group; orInformation generated by the Regional office, either aspart of a remedial design or a site Five Year Review.

Region 6 considers all remedy review requests.________

Proposed changes to remediesmust be at least as protective andcost effective as the remedyalready selected.

Some remedies will not bechanged if the proposedalternative provides less overallprotection of human health andthe environment, or does notcomply with applicableregulations. ________

Page 6

11/25/97 All Super-fund remedial sites are eligible for remedy review.

Sites will be identified by stakeholders, such as: PRPs; Stateenvironmental and health agencies; local city and countygovernment; local formal and informal community groups; EPAtechnical sâff; and the EPA Regional Superfund Ombudsman.

Where appropriate, sites subject to Five Year Review will beconsidered as possible update remedy candidates depending onthe protectiveness and effectiveness of each site remedy. Inaddition to revisions based on advances in remediation, scienceand technology, Region 7 will consider remedy improvementsindicated by additional post-ROD sampling and analytical data,remedy performance data gathered from a post-ROD period ofoperation, and other factors.

Generally. the criteria for updatinga remedy will be whether theproposed change to the remedy isequally or more protective ofhuman health and theenvironment, and equally or morecost and technically effective.Region 7 has compiled a list ofFY98 candidate remedy updatesites. The list will be updated atleast quarterly and will trackcompleted reviews and resultingdecisions.

Page?

12/31/97 EPA RPMs ?^d State staff areexpected to identifyopportunities for remedychanges. So me of thesebecome evident as designs arecompleted; as the remedy isbeing implemented; andduring the O&M phase or atthe Five Year Review.

A determination must be madeon the significance of thechange to determine whetherthe change should be a RODAmendment, ESD, or minorchange that should bedocumented in me record.

Region 8 plans to track thesethree types of changes inCERCUS.

Any stakeholder may reques areview (i.e., PRPs, Federalfacilities. State, community, orlocal government). Region 8expects that Five YearReviews may result in remedyupdates at many sites. Allrequests must be documentedin writing and placed in theSuperfund Record Center.

Region 8 will evaluate allrequested updates to RODs ina two-phased process. Therequest will first be screenedto determine if there isadequate supporting rationalefor the request (e.g., new datanot considered in the ROD,new technology not evaluatedin the ROD, new riskinformation, new costestimates, or a change in land-use nearby). If sufficientrationale exists, a moredetailed analysis will be doneto determine whether anupdate is warranted based onthe nine criteria, and whatform it should take.

Project staff will be expected tofollow the two-step process andksep appropriate records on how •the requests were handled.

A Superfund Reforms seminar,| which will include a discussion of

key reforms and an explanation ofexpectations for site teams inevaluating review requests, willbe held during the second quarterof 1998 for all RegionalSuperfund staff.

-^, .'.,,.•. •'. - • • ' ' • - •

•^JS- -»•*

PtgeS

1/6/98 Region 9 will consider allrequests for remedy changes.All sites are considered to beequally eligible for changes.Deck ons on remedy changeswill be made at the BranchChief level. The procedure forrcviev and response will bedeteriuined on a case-by-casebasis.

Managers of projects in thedesign phase are beingencouraged by theirsupervisors to actively seekopportunities to refineremedies to reduce cost and/orimprove effectiveness.

Where new informationindicates that a remedy is notmeeting objectives, Region 9will consider modification ofthe remedy and, whereappro- iate, a technicalimpracticability waiver.Region 9 will address thepotential for remedy update inall.Five Year Reviews.

All sites are considered to beequally eligible for changes.

Federal facility remedy updateactivities will generally beconsistent with the Fund-leadsites, although the fact that theFederal agencies have leadresponsibilities requires thatthese sites be managed indifferent ways.

As part of Region 9's FY98planning process, each sectionchief in the Superfund SiteCleanup Branch prepared aSection Operating Plan whichincluded she-specific plans for theupcoming fiscal year. These plansdiscussed how SuperfundReforms would be implementedon a site-specific basis, includingthe potential for updatingremedies at each site duringFY98. Region 9 identified 12sites as potential candidates forremedy updates in FY98.

Region 9 recommends that anational analysis of past remedyupdates be conducted todetermine what has beenaccomplished to date and where

j the best opportunities may lie-forother projects.

Page 9

10

Date

12/4/97 All sites are considered to beequally eligible for changes.

Generally, these sites areidentified by the people whoare most familiar with thesites: the EPA RPMs workingtogether with the State,Federal facility, jnd PRP sitemanagers.

All sites undergoing Five YearReviews will also beconsidered as possible updateremedy candidates.

All sites are considered to beequally eligible for changes.

Requests received from otherparties, including the PRPsand the public, would receiveequal consideration andpriority with those updatesidentified by the sitemanagers.

All sites undergoing Five YearReviews will also beconsidered as possible updateremedy candidates.

CmCTBJ CommentsFive sites are under review forpotential remedy updates (3Federal facilities; 1 State-toad; 1Federal-lead fund-financed).

Region 10 has no backlog of siteswhere a remedy update has beenrequested but where the Regionhas not started the review.

Post-RODsampling and remedyperfoonaace infonn&tion areamong the many possible sourcesof information for remedyupdates.

Region 10 tias not had anyrequests for updates based on newState ARARs, but anticipatesthem in the future.

Page 10

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