A Guide To Preparing and Reviewing Remedial Action Reports of Cost and Performance
A Guide To Preparing and Reviewing Remedial Action Reports of Cost and Performance
30 June 2001
US Army Corps
of Engineers
ENGINEER PAMPHLET
CEMP-R EP 1110-1-19
30 June 2001
FOREWARD
The U.S. Army Corps of Engineers (USACE), through its staff and contractors, provides quality,
responsive engineering and construction services to the Army and the Nation. USACE missions include civil
works, military construction, environmental restoration and support to other agencies. The civil works
program encompasses flood control, navigation, shore erosion, and recreation facilities. The military
construction program supports the Army, most of the Air Force, and certain other Department of Defense
(DoD) agencies. USACE performs environmental restoration work for the Army, DoD, Environmental
Protection Agency, Department of Energy, and several other agencies. USACE also provides design and
construction management services for non-DoD Federal agencies, state and local governments, and foreign
governments.
A majority of the planning, engineering, design and surveying and mapping services for these
programs is acquired by contract with private architect-engineer (A-E) firms. USACE is one of the largest
Federal procurers of A-E services. This pamphlet describes the USACE policies and procedures for preparing
and reviewing remedial action reports of cost and performance.
ROBERT CREAR
Colonel, Corps of Engineers
Chief of Staff
Engineer Pamphlet
No. EP 1110-1-19 30 June 2001
TABLE OF CONTENTS
Paragraph Page
Acronyms iv
Chapter 1 Introduction
Purpose................................................................................. 1-1 1-1
Applicability ........................................................................ 1-2 1-2
Scope.................................................................................... 1-3 1-2
References............................................................................ 1-4 1-2
Organization......................................................................... 1-5 1-3
Chapter 2 Background
Superfund Process................................................................ 2-1 2-1
Remedial Action Process ..................................................... 2-2 2-5
Remedial Action Completion .............................................. 2-3 2-6
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Paragraph Page
ii
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LIST OF EXHIBITS
Page
iii
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ACRONYMS
ARARs Applicable or Appropriate and Relevant Requirements
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
CX Center of Expertise
DoD Department of Defense
DQO Data Quality Objective
EE/CA Engineering Evaluation/Cost Analysis
EPA U.S. Environmental Protection Agency
ESD Explanation of Significant Differences
FF Federal Facility
FFA Federal Facility Agreement
FS Feasibility Study*
HCAS Historical Cost Analysis System
HQ Headquarters
HRS Hazard Ranking System
HTRW Hazardous, Toxic, and Radioactive Waste
LTRA Long-Term Response Action*
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPL National Priorities List
O&F Operational and Functional*
O&M Operation and Maintenance*
OU Operable Unit*
PA Preliminary Assessment
PRP Potentially Responsible Party*
PRP LR Potentially Responsible Party Long-Term Response*
QA Quality Assurance
QAPP Quality Assurance Project Plan
QC Quality Control
RA Remedial Action*
RD Remedial Design*
RI Remedial Investigation*
ROD Record of Decision*
RPM Remedial Project Manager
SARA Superfund Amendments and Reauthorization Act
SI Site Inspection
USACE U.S. Army Corps of Engineers
WBS Work Breakdown Structure
* Definition provided in Appendix A
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CHAPTER 1
INTRODUCTION
1-1. Purpose.
a. This pamphlet defines the procedures for formally documenting and reporting
cost and performance information from U.S. Army Corps of Engineers (USACE) environmental
restoration1 projects and provides guidance to
the project team for scoping the types of data to Site Closeout Process*
collect and how they are presented. Customers
must have complete, accurate, and timely Remedial Action
Remedial Action
information for proper operation and Completion
Report
(per Operable
maintenance, as a baseline for system Unit)
modifications and optimization, and to
document information that may be used in
conjunction with a long-term response action or
recurring review. This information will also Construction Preliminary
address information to plan and tailor their site Completion** Close Out Report
(for entire Site)
completion and individual operable units (OUs)
for site closeout.
1
As used by this guide, “environmental restoration” refers to the Superfund programs operated under the authority of the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 and the Superfund Amendments and
Reauthorization Act (SARA) of 1986. In many cases there is not a straightforward relationship between the U.S. Environmental
Protection Agency (EPA) Superfund and Department of Defense (DoD) terms. Users of this document should recognize that in
most cases, these requirements may not be consistent with other programs. The environmental project team should discuss, plan,
and tailor their site documentation efforts to facilitate the environmental requirements at their site.
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c. This guide is intended to assist in the preparation, review, or use of RA reports for
environmental restoration projects by cost engineers, environmental engineers, resident
construction managers, project managers, remedial project managers (RPMs), program
managers, and other related technical disciplines.
1-2. Applicability. This pamphlet applies to all USACE commands having investigation,
design, and remedial action responsibility for environmental restoration projects within the
military, civil works, or support for others programs.
1-3. Scope. This pamphlet is a companion document to A Guide for Preparing and
Reviewing Remedial Action Reports developed jointly by the U.S. Army Corps of Engineers
(USACE) and U.S. Environmental Protection Agency (USEPA). The primary difference
between these two documents is the cost reporting format. Both documents incorporate selected
guidance from the Guide to Documenting and Managing Cost and Performance Information for
Remediation Projects (EPA 542-B-98-007, October 1998). This guide does not address
construction completion, site completion, or site deletion from the National Priorities List (NPL).
For information on these issues refer to Close Out Procedures for National Priorities List Sites
(EPA 540-R-98-016, January 2000). Although much of this guide is written from the
perspective of a Superfund site listed on the NPL, the presented concepts could also be applied to
non-NPL sites or other cleanup programs.
1-4. References. The following documents provide additional information related to the
subject of this pamphlet.
h. 40 CFR Part 300. National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). (http://www.epa.gov/docs/epacfr40/chapt-I.info/subch-J.htm)
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1-5. Organization. This guide is intended to provide the user with the basic information
necessary to complete or review the RA report for a given OU at a site. Throughout the guide,
exhibits help illustrate the concepts discussed, while highlight boxes are used to provide
information that is important to note, but not necessarily central to the discussion at hand. The
objectives of each chapter and appendix are listed below.
a. Chapter 1: Introduce the guide, including its purpose, scope, and use.
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j. Appendix D: Provide example templates for reporting costs for HCAS data entry.
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CHAPTER 2
BACKGROUND
a. General
(3) Sites on the NPL are addressed by the Superfund process through a combination
of removal and remedial authority. Removal actions are short-term responses, usually to address
immediate threats.1 Remedial actions achieve long-term permanent responses to risk. The
Superfund pipeline (Exhibit 2-1) illustrates the major phases and decision points of the
Superfund remedial response process. The various phases of this process are briefly described in
the following paragraphs.
1
Removal authority cleanup actions achieve prompt risk reduction through activities categorized as emergency (response
required within hours/days), time-critical (response required within 6 months), or non-time-critical (more than 6 months is
available before action must be taken). Non-time-critical removal alternatives are analyzed in an engineering evaluation/cost
analysis (EE/CA), which is considered the equivalent of a remedial investigation/feasibility study. An action memorandum is the
primary decision document, which is considered the equivalent of a record of decision.
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Exhibit 2-1
The Superfund Pipeline
(1) The remedial investigation/feasibility study (RI/FS) process is initiated at the time
of a site’s listing on the NPL. The RI/FS gathers the information necessary to select a remedy
that will meet the statutory and regulatory requirements of the Superfund cleanup program.
(2) The objective of the RI is to collect the data necessary to assess the current and
future potential risks to human health and the environment, and to support the development,
evaluation and selection of appropriate response alternatives. The RI may be performed in
several stages so that the investigation is refined as it progresses. The RI includes field
investigations, treatability studies, a baseline risk assessment, and the initial identification of
applicable or relevant and appropriate requirements (ARARs) (i.e., all State and Federal laws
outside Superfund regulations that warrant consideration).
(3) The FS begins by formulating viable alternatives. This requires that contaminants
of concern, potential exposure pathways, remediation objectives/cleanup goals, general response
actions, subject volumes or areas of media, and potentially applicable technologies be identified.
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An FS may address a specific site problem, OU, or an entire site.2 Following the preliminary
screening of alternatives, a reasonable number of possible alternatives undergo a detailed
analysis using the nine evaluation criteria listed in the NCP.
c. Remedy Selection
2
The RI/FS can be performed for the site as a whole, or for a particular portion of the site. The NCP defines an OU as a
“discrete action that comprises an incremental step toward comprehensively addressing site problems. This discrete portion of a
remedial response manages migration, or eliminates or mitigates a release, threat of a release, or pathway of exposure” (NCP
§300.5). Hence, an OU can be a certain geographic portion of a site or a specific environmental medium at the site (e.g.,
groundwater or soil). The OU may also consist of a comprehensive but temporary remedy (e.g., a temporary cap over a site) that
provides interim protection of human health and the environment before final remediation. The cleanup of a site can be divided
into a number of OUs, depending on the complexity of the problems associated with the site.
3
For pre-SARA sites, the selected remedy may be detailed in other reports (e.g., a consent decree or an administrative order).
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e. Remedial Action. The RA is the implementation of the selected remedy from the
ROD and the RD. RA activities must conform to the remedy set forth in the ROD and other
post-ROD decision documents (e.g., ROD amendments, explanation of significant differences).
The remedial action includes the completion of an operational and functional (O&F) period
(Paragraph 2-2.a), if necessary, followed by any long-term response action (LTRA) for
groundwater or surface water remedies (Paragraph 2-2.a), prior to long term operation and
maintenance (O&M) of the remedy.
Exhibit 2-2
Example Pipeline Scenarios
RA
(No O&M Required)
Containment
Final
RA Report
RA O&M
O&F
<1 yr.
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f. Operation and Maintenance. Operation and maintenance (O&M) are the activities
required to maintain the effectiveness or the integrity of a remedy. O&M is dependent on the
implemented remedy. O&M may not be necessary, may only be required for a defined
timeframe, or may be required to be performed indefinitely.4 For remedies that require active
on-site treatment, remedial system evaluation or optimization is an important component of
O&M.5 Except for Fund-financed groundwater or surface water restoration actions covered
under NCP §300.435(f)(4), O&M measures are initiated after the remedy has achieved the
remediation objectives and cleanup goals listed in the ROD, and is operational and functional
(Paragraph 2-2.a). O&M starts when the RA is complete and the State or the PRP(s) assume
responsibility for all activities necessary to operate and/or maintain the long-term effectiveness
or integrity of the actions selected in the ROD. In the case of Fund-financed measures to restore
groundwater or surface waters, that extend beyond the ten-year long-term RA period (Paragraph
2-2.b), O&M is required to continue the operation of such measures until the cleanup goals are
achieved.
2-2. Remedial Action Process. Besides the RA and O&M phases, the RA process typically
includes the operation and functional period, long-term response, cleanup goals achieved
milestone, and five-year reviews. Exhibit 2-2 provides three different pipeline scenarios to help
illustrate when these periods occur in relation to preparation of the RA report. The following
paragraphs provide a brief description of each phase or milestone.
(1) Operational and functional (O&F) activities are conducted after the RA has been
constructed to ensure that it is operating as designed and functioning properly. The O&F period
is part of the RA and occurs during the last year of the RA. The NCP provides for a maximum
timeframe of one year for performing O&F activities, though EPA may extend the one-year
period, as appropriate. O&F determinations are made for containment (all media), groundwater
restoration and surface water restoration remedies.6 Monitored natural attenuation remedies do
not go through an O&F determination.
(2) A remedy becomes O&F either one year after O&F start, or when the remedy has
been determined, concurrently by EPA and the State agency, to be functioning properly and
performing as designed, whichever occurs first (40 CFR 300.435). O&F is considered to be
complete on the date that the designated Regional official approves, in writing, the interim RA
report (for sites with groundwater or surface water restoration remedies) or final RA report. This
4
Examples of remedies where O&M may have an indefinite period of performance are sites where waste is contained on-site
and the integrity of the cap must be maintained or sites where institutional controls must be maintained.
5
Additional information on remedial system evaluation or optimization is available on the web at
http://www.frtr.gov/optimization/.
6
Formal O&F determinations are made primarily for Fund-financed projects because the O&F milestone governs when O&M
or Long-Term RA (LTRA) begins under State authority. Federal facilities-lead projects go through determinations known as
“operating properly and successfully.”
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report should not be approved until the determination has been made through an inspection that
the remedy is, in fact, O&F (Paragraph 2-3).
b. Long-Term Response.
(1) Long-term response action (LTRA) and PRP long-term response (LR) are sub-
actions of O&M used to track and assure continued Federal funding for the operation of
groundwater or surface water restoration remedies.7 LTRA is defined as the Fund-financed
operation of groundwater and surface water restoration measures, including monitored natural
attenuation, for up to the first ten years of operation. LTRA is complete after ten years, after a
technical impracticability determination is made, or after cleanup goals are achieved and
documented in a final RA report, whichever occurs first. LTRA transitions to traditional O&M
if cleanup goals are not achieved, or if continued monitoring is required, after ten years have
elapsed.
(2) In the past, the term LTRA has been used to describe PRP-lead groundwater and
surface water restoration measures, including monitored natural attenuation. However, PRP-lead
groundwater and surface water restoration measures, including monitored natural attenuation, are
covered by a separate action, PRP LR. Because PRP LR is a specific type of O&M, the ten-year
timeframe does not apply. PRP LR is complete after a technical impracticability determination
is made, or cleanup goals are achieved and documented in a final RA report, whichever occurs
first.
2-3. Remedial Action Completion. The RA for an OU is complete after the remedy is
determined to be O&F (if applicable), the remediation objectives and/or cleanup goals stated in
7
LTRA and PRP LR apply to groundwater and surface water restoration measures only, including monitored natural
attenuation. These terms do not apply to groundwater and surface water restoration measures conducted under other leads;
groundwater or surface water containment measures; groundwater or surface water measures initiated for the primary purpose of
providing a safe drinking water supply; or groundwater monitoring. Federal facilities-lead sites do not use LTRA or PRP LR.
Instead, groundwater and surface water restoration measures go from RA directly to O&M at these sites.
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the ROD are achieved, and the designated Regional official has approved the interim or final RA
report. Exhibit 2-3 illustrates the remedial action completion process.
Exhibit 2-3
Remedial Action Completion Process
Construct
Remedial Action
Pre-Final/Final
FF - Lead Inspection
Inspection
Operational and
Functional Period Fund - Lead Inspection
(if applicable)
No
Interim
Remedial Action
Report
Cleanup Goals
PRP - Lead Inspection
Achieved
Final
Remedial Action
Report
a. Inspection Requirements.
(1) General. With any RA, regardless of lead or contracting party, the standard
practice is to conduct contract pre-final and final inspections prior to RA completion. These
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inspections are conducted to determine whether the construction is complete in accordance with
the contract design and specifications. The inspections are generally held between the
contracting party and the construction contractor, although others can be invited. If all the items
observed during the contract pre-final inspection are corrected or are considered insignificant,
the contract pre-final inspection may automatically serve as the contract final inspection.
Otherwise, a contract final inspection will be conducted later by the contracting party to
determine if these items have been corrected and completed in accordance with the RD plans and
specifications. In addition to the pre-final and final inspections, other inspections may be
required prior to completion of the RA. These include Fund-lead, PRP-lead, and Federal facility
(FF)-lead inspections as described below.
(2) Fund – Lead. The NCP requires an additional set of inspections at Fund-financed
sites that will undergo LTRA and/or O&M. During this set of inspections, EPA and the State
concurrently determine the end of the O&F period. After an O&F determination is made, the
remedy enters LTRA or O&M. If convenient, these inspections may be conducted concurrently
with the contract pre-final or final inspection.
(3) PRP – Lead. For PRP-lead sites, the Revised Model CERCLA RD/RA Consent
Decree (Federal Register, Vol. 60, No. 145, pp. 38817-38837, July 28, 1995) requires a pre-
certification inspection upon completion of the RA. This inspection, which involves the PRP(s),
EPA, and the State, is intended to determine if the RA is fully complete and if the remediation
objectives/cleanup goals are attained. After the pre-certification inspection, the PRPs are also
required to submit a written report, for EPA approval, stating that the RA is complete in full
compliance with the requirements of the Consent Decree. If it contains the proper information,
this report can serve as the RA report for the OU. For groundwater and surface water restoration
remedies, where an interim RA report is appropriate, EPA may require the preparation of a
separate (interim) RA report for groundwater or surface water, since it is not normally required
in the Consent Decree.
(4) FF – Lead. Federal facility agreements (FFAs) generally require an additional set
of inspections to determine that all aspects of the remedy have been implemented in accordance
with applicable enforcement documents and the ROD. Participants include the EPA, Federal
facility, oversight contractor, and the State. These inspections may be conducted concurrently
with either of the pre-final or final inspections described above.
b. Remedial Action Reporting. When the RA for an operable unit is complete, the
RA report is prepared. There are two basic types of RA reports, interim and final. An interim
RA report is completed only for RAs that include groundwater or surface water restoration
remedies, including monitored natural attenuation. Interim reports are used because of the
extended duration between the completion of the treatment system construction (or the ROD
signature, in the case of monitored natural attenuation) and the achievement of the cleanup goals.
A final RA report is complete when the remediation objectives/cleanup goals are achieved.
More detailed information on preparation, timing, distribution, approval, and review of RA
reports is provided in Chapter 3.
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CHAPTER 3
REPORTING CRITERIA
3-1. Preparation. The party most familiar with the RD, the construction efforts, and the
associated project costs, should prepare the RA report. This familiarity will provide the best
opportunity to discuss the successes, difficulties, and lessons learned during the project. The
EPA RPM and contractor for the RA (e.g., PRP, U.S. Army Corps of Engineers, State or EPA
contractor) are typically the parties most familiar with the RA. While the EPA RPM can and
sometimes does prepare the RA report, the contractor is usually tasked with that effort.
3-2. Timing. For most OUs, the RA report should be prepared and submitted to the EPA
region (Region) or appropriate regulatory authority for approval within 90 days after the contract
final inspection of the completed construction.1 At OUs where LTRA is being performed, an
interim RA report should be prepared once the remedy is constructed (within 90 days after the
final inspection). The interim RA report must then be amended and finalized once the RA
cleanup goals specified in the ROD are achieved. An interim RA report is required because of
the extended period of time that may elapse between the completion of construction and
achievement of cleanup goals. Where actual costs are not known at the time of report
preparation (e.g., pending claims, change orders), estimated costs may be used (Chapter 6).
3-3. Distribution.
a. Once the Region or appropriate regulatory authority has approved the RA report,
either interim or final, depending on the remedy, the original report is retained in the Regional
site file, and an approved copy should be returned to the report preparer. Upon completion of the
RA report, the Region or appropriate regulatory authority is required to notify the appropriate
Natural Resource Trustees listed in the Regional Contingency Plans regarding the completion of
the RA. The Region or appropriate regulatory authority will provide a copy of the approved RA
report to the Trustees within one week of the report’s approval.
b. For projects in which the USACE is involved, a copy of the RA report shall be
furnished to HQ USACE and the USACE HTRW Center of Expertise (CX). Mailing addresses
are provided in Appendix D.
3-4. Approval.
a. For a given site or OU, the RA is considered to be complete once the designated
EPA Regional official has approved the interim or final RA report in writing. An interim RA
report is completed only for RAs that include groundwater or surface water restoration remedies
(including monitored natural attenuation). Interim reports are used because of the extended
period of time that typically transpires between the completion of the treatment system
construction (or the ROD signature, in the case of monitored natural attenuation) and the
1
For PRP-lead sites, the RA report is due within 90 days after the official determination has been made that the remediation
objectives/cleanup goals have been achieved.
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achievement of the cleanup goals. A final RA report is complete once the remediation
objectives/cleanup goals are achieved.
(1) The remedy to reduce contaminant concentrations and achieve the cleanup goals,
including groundwater or surface water restoration, with active treatment or natural attenuation,
is installed;
(2) For active treatment, the construction of the treatment system is complete and the
system is operating as intended (i.e., the remedy is determined to be O&F at Fund-financed
sites);
(4) If the OU addresses media other than groundwater, construction activities are
complete and RA objectives specified in the ROD are achieved for these components;
(7) The interim RA report includes the information described in Chapter 4 of this
guide.
(1) All construction activities are complete, including site restoration and
demobilization;
(2) All RA objectives specified in the ROD, including those for groundwater and
surface water (if applicable), are achieved;
(5) The final RA report includes the information described in Chapter 4 of this guide.
d. When an interim RA report has already been prepared, the interim RA report may
simply be amended to create the final RA report. The amendment would add information on
activities that occurred after the interim RA report was completed, including a final actual cost
breakdown.
3-5. Review. Prior to submittal of the RA report, it should be reviewed to ensure that it
contains the necessary information. Exhibit 3-1 provides a checklist that summarizes the
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recommended content of the RA report. Each component listed in the checklist is further
described in Chapter 4, including examples.
Exhibit 3-1
Remedial Action Report Checklist
SECTION COMPONENT
II. Operable Unit Background ♦ Summarize requirements specified in the ROD for the OU. Include
information on the remediation objectives/cleanup goals, institutional
controls, monitoring requirements, operation and maintenance
requirements, and other parameters applicable to the design,
construction, operation, and performance of the RA.
♦ Provide additional information regarding the basis for determining the
remediation objectives/cleanup goals for the OU, including information
on planned future land use.
♦ Summarize the remedial design, including any significant regulatory or
technical considerations or events occurring during the design.
♦ Identify and briefly discuss any ROD amendments, explanation of
significant differences, or technical impracticability waivers.
III. Construction Activities ♦ Provide a step-by-step description of the major activities undertaken to
construct and implement the RA (e.g., mobilization and site preparatory
work; construction of the treatment system; associated site work, such as
fencing and surface water collection and control; system operation and
monitoring; and sampling activities).
♦ If a treatment technology was used, refer to Appendix A for site
conditions, matrix characteristics and/or operating parameters of the
system.
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IV. Chronology of Events ♦ Provide a tabular summary that lists the major events for the OU, and
associated dates of those events, starting with the ROD signature.
♦ Include significant milestones and dates, such as, remedial design
submittal and approval; ROD amendments; mobilization and
construction of the remedy; significant operational events such as
treatment system/application start-up, monitoring and sampling events,
system modifications, operational down time, variances or non-
compliance situations, and final shut-down or cessation of operations;
final sampling and confirmation-of-performance results; required
inspections; demobilization; and completion or startup of post-RA
operation & maintenance activities.
♦ If an operational and functional (O&F) period applies, indicate the start
and end dates of the O&F period.
♦ If preparing an interim RA report, indicate when cleanup goals are
projected to be achieved for the ground or surface water restoration.
V. Performance Standards and ♦ Describe the overall performance of the technology in terms of
Construction Quality comparison to remediation objectives/cleanup goals.
Control ♦ For treatment remedies, identify the quantity of material treated, the
strategy used for collecting and analyzing samples, and the overall
results from the sampling and analysis effort.
♦ Provide an explanation of the approved construction quality assurance
and construction quality control requirements or cite the appropriate
reference for this material. Explain any substantial problems or
deviations.
♦ Provide an assessment of the performance data quality, including the
overall quality of the analytical data, with a brief discussion of quality
assurance and quality control (QA/QC) procedures followed, use of a
quality assurance project plan (QAPP), comparison of analytical data
with data quality objectives (DQOs).
♦ For PRP-funded projects, discuss the government’s oversight activities
and results with regard to analytical data quality.
VI. Final Inspection and ♦ Report the results of the various RA construction inspections, and
Certifications identify noted deficiencies.
♦ Briefly describe adherence to health and safety requirements. Explain
any substantial problems or deviations.
♦ If implemented, summarize details of institutional controls (e.g., type,
who will maintain, who will enforce).
♦ For PRP-lead, describe results of precertification inspection.
♦ If applicable, certify that the remedy is operational and functional, along
with the date this was achieved.
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VII. Operation & Maintenance ♦ Describe the general activities for post-construction operation and
Activities maintenance, such as monitoring, site maintenance, and closure
activities.
♦ Identify potential problems or concerns with such activities.
♦ Note results of any optimization efforts during O&M.
♦ If preparing an interim RA report, describe the future groundwater or
surface water restoration activities to meet cleanup goals.
VIII. Summary of Project Costs ♦ Present the total costs incurred for the remedial action. Identify costs as
capital, O&M, or periodic costs, either RA or post-RA, as applicable
(e.g., RA capital costs, RA operating costs, post-RA O&M costs).
♦ The reporting of project costs is required for government-financed
projects and should be provided whenever possible for PRP-lead
projects. If the project is PRP-lead, a summary of government oversight
costs for the RD and RA should be included.
♦ Indicate the year(s) in which costs were incurred.
♦ If actual costs are not available, use estimated costs.
♦ Escalate costs estimated in the ROD to the same dollar basis year and
compare the total project costs, actual or estimated, to the ROD estimate.
If outside the range of –30 to +50 percent, explain the differences.
Provide the index or rate used for the escalation.
IX. Observations and Lessons ♦ Provide site-specific observations and lessons learned from the project,
Learned highlighting successes and problems encountered and how resolved.
X. Operable Unit Contact ♦ Provide contact information (names, addresses, phone numbers, and
Information contract/reference data) for the major design and remediation contractors
and subcontractors, oversight contractors, and the respective remedial
project manager (RPM) and project managers for the government and
the PRPs, as applicable.
XI. References ♦ Provide a list of references used to develop the RA report (e.g., ROD,
RD documents, RA correspondence, as-built drawings).
Appendix A. Cost and ♦ List values and measurement procedures for factors affecting cost and
Performance performance of treatment technologies used in the remedy, including site
Factors conditions, matrix characteristics, and operating parameters.
Appendix B. Project Costs ♦ Provide a breakdown of the actual RA capital, operating, and/or periodic
costs.
♦ Provide a breakdown of the future projected O&M and/or periodic costs.
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CHAPTER 4
REPORT COMPONENTS
4-1. General.
a. This chapter describes the components of the recommended format for the RA
report and details the information that should be included in each component. The components
are divided into the following:
(1) Abstract
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Exhibit 4-1
Example Abstract
Site Name and Operable Unit: U Creosote Superfund Site, Operable Unit 2
Location: Live Oak, Florida
Regulatory Oversight: U.S. Environmental Protection Agency Region IV
Florida Department of Environmental Regulation
Contractor Oversight: U.S. Army Corps of Engineers, Jacksonville District
Remedial Action Contractor: Cleanup, Inc., Cleantown, FL
Waste Source: Sludge and soil contaminated with lumber treatment chemicals (including
creosote and small amounts of pentachlorophenol)
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4-2. Introduction.
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findings and results of SI and RI activities. Any prior removal and remedial activities that have
occurred at the site should be described. Any other OUs that have been designated at the site
should be discussed and the OU addressed by the RA report should be introduced. An example
introduction is provided in Exhibit 4-2.
b. Because the introduction provides background information on the entire site, most
of it could also be used as the introduction of the RA report for other OUs at the site. The
information for the introduction can be taken from reports prior to the RD or RA, such as the
RI/FS or ROD.
Exhibit 4-2
Example Introduction (Section 1)
The U Creosote Superfund Site is located approximately two miles from the City of Live Oak, Suwanee County,
Florida, at the intersection of Sawmill Road and Goldkist Road. Homes, businesses, light industry, a trailer park,
a private airport, and a county storage yard are located within one-half mile of the site. Approximately 450
people live in the trailer park. Sinkholes and public and private wells lie within two miles of the site.
From 1948 to 1986, the ABC company operated the U Creosote site as a lumber treatment facility. Lumber
treatment processes included the pressure-treatment of lumber products, mainly with creosote and occasionally
with pentachlorophenol (PCP). Small rail cars were used to move lumber to two treatment cylinders. A mixture
of either creosote and water or PCP and petroleum was used to treat the lumber. The treated lumber was dried
on racks over bare soil and stored in an area north of the treatment cylinders.
Wastewater from the treatment cylinders was discharged to an oil-water separator. The creosote recovered from
the oil-water separator was sent to a storage tank for reuse. If the creosote was determined to be off
specification, it was sent to a spent creosote storage tank and properly disposed of at an off-site location at a
later date. Wastewater from the oil-water separator discharged through a culvert and a drainage ditch to an
unlined three-acre lagoon located in the southwest corner of the site.
In 1989, a former owner of the facility notified Region 4 of the U.S. Environmental Protection Agency (EPA)
that hazardous materials may have been handled at the site. In response, the Florida Department of
Environmental Regulation (FDER) conducted sampling at the site in July 1990. The results showed that soil and
sludge in the area of the treatment cylinders were contaminated with a number of organic compounds and that
the treatment cylinders contained small amounts of solidified creosote and PCP. In addition, creosote was found
in the lagoon and the storage tanks. No contamination was detected in the aquifer underlying the site. EPA
proposed in December 1990 that the site be placed on the National Priorities List (NPL). The listing of the site
became final in September 1991.
The potentially responsible parties (PRP) conducted a remedial investigation and a feasibility study (RI/FS) at
the site between 1992 and 1996 under the terms of a Federal administrative order on consent (AOC). Testing
during that time confirmed that soils and sediments in the lagoon and drainage ditch were contaminated with
polycyclic aromatic hydrocarbons (PAH). During the RI/FS, EPA and the PRPs agreed to address the site as two
operable units (OU), OU1 and OU2.
OU1 included the lagoon and the former plant facility. Cleanup activities were completed in March 1996, under
a Record of Decision (ROD) signed on July 25, 1995. The lagoon was drained, contaminated sludge and
sediment was excavated, and wastewater was treated and discharged to a publicly owned wastewater treatment
facility. Highly contaminated sludge and soil were solidified on site.
A ROD for OU2 was signed March 8, 1996, which is the subject of this report.
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4-3. Operable Unit Background. This section should summarize the requirements specified
in the ROD for the subject OU. It should include information on the cleanup goals, institutional
controls, monitoring requirements, O&M requirements, and other parameters applicable to the
design, construction, operation, and performance of the RA. Additional information regarding
the basis for establishing the cleanup goals/remediation objectives, including planned future land
use, should be provided. A summary of the RD, including any significant regulatory or technical
considerations or events occurring during the preparation of the RD, should also be included in
this section. Any ROD amendments, explanation of significant differences, or technical
impracticability waivers should also be identified and briefly discussed. An example
background section is provided in Exhibit 4-3.
Exhibit 4-3
Example Operable Unit Background (Section 2)
The remedy described in the ROD for OU2 included:
♦ On-site biodegradation of remaining, less-severely contaminated soils in a land treatment area
constructed with a liner, internal drainage, and spray irrigation system;
♦ Activities necessary to the proper functioning of the land treatment process;
♦ After treatment, covering the land treatment area with clean fill and re-vegetating; and
♦ Five years of groundwater monitoring to verify that it remains uncontaminated.
The remediation objectives in the ROD were: Within two years from initial seeding, the land treatment
process must reduce the concentration of TCIC to 100 mg/kg throughout the volume of the material treated.
The goals were based upon a risk assessment that focused on attaining at least a 1 x 10-6 risk for ingestion of
contaminated soil by a child. The risk assessment assumed a future industrial land use scenario, with no
institutional controls. Remediation objectives were described by the total concentration of six carcinogenic
indicator constituents of creosote -- benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, chrysene,
dibenzo(a, h)anthracene, and indeno(1,2,3-c,d)pyrene – referred to as total carcinogenic indicator chemicals
(TCIC). EPA selected the six of the approximately two hundred compounds that make up creosote because of
their concentrations in sludge and soil at the site and their carcinogenic nature. The concentrations of TCIC
in the soil to be treated ranged from 100 to 208 mg/kg.
The September 15, 1996, ROD amendment included:
♦ Soils contaminated at levels exceeding 100 mg/kg, but less than 5,000 mg/kg TCICs, were to be
biodegraded in the on-site land treatment area.
♦ Soils found contaminated at levels exceeding 5,000 mg/kg TCICs were to be removed, stabilized, and
disposed of at an EPA-approved hazardous waste disposal facility along with the solidified, OU 1 waste
(7,500 yd3).
♦ If the land treatment process did not attain the remediation objectives for the TCIC within two years, but
quarterly monitoring showed substantial progress toward meeting the remediation objectives, EPA
would consider extending the treatment period. However, if substantial progress could not be identified,
EPA would consider alternative means of addressing the contaminated soils, such as capping, removal,
incineration, solidification, or vitrification.
♦ Groundwater monitoring would begin upon completion of construction of the land treatment area.
Based on the original ROD and the ROD amendment, the remedial design was prepared for construction of
the remedy. The design was completed in five months and approved by EPA September 15, 1996, for
implementation of the remedial action.
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4-4. Construction Activities. This section should provide a step-by-step description of the
activities undertaken to construct and implement the RA (e.g., mobilization and site preparatory
work; construction of the treatment system; associated site work, such as fencing and surface
water collection and control; system operation and monitoring; and sampling activities). If a
treatment technology was used, reference should be made to the appropriate appendix that
reports factors affecting cost and performance of the system (e.g., site conditions, matrix
characteristics, and operating parameters). An example construction activities section is
provided in Exhibit 4-4.
Exhibit 4-4
Example Construction Activities (Section 3)
Site Preparation
Site preparation activities included clearing, grubbing, and grading the land where the land treatment area
was to be constructed; building a drainage swale around the land treatment area; preparing a temporary,
central soil stockpile area consisting of several lined cells; and installing a perimeter fence with signs
warning against exposure to hazardous material. Approximately four acres were cleared. An estimated 200
cubic yards of contaminated soil found to contain less than 5,000 mg/kg TCICs were excavated during the
site preparation activities and stored in the central stockpile area along with previously excavated,
contaminated soil.
System Operation
Land treatment was performed in three lifts, with a total of 8,100 yd3 of soil treated: 3,300 yd3 (Lift 1); 3,000
yd3 (Lift 2); and 1,800 yd3 (Lift 3). For site management and sampling purposes, the land treatment area was
divided into eight half-acre, rectangular subplots. A composite sample was collected from each subplot each
quarter, until the concentration of TCICs in the soil in the subplot was less than 100 mg/kg. An additional lift
of soil from the stockpile area then was placed in the subplot. The process was repeated until all of the
stockpiled soil had been placed in the land treatment area.
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4-5. Chronology of Events. This section should provide a tabular summary that lists the
major events for the OU, and associated dates of those events, starting with the ROD signature.
The table should include significant milestones and dates, including: RD submittal and approval;
ROD amendments; mobilization and construction of the remedy; treatment system/application
start-up; monitoring and sampling events; system modifications; operational down time;
variances or non-compliance situations; date of final shut-down or cessation of operations; final
sampling and confirmation-of-performance results; required inspections; demobilization; and RA
completion or startup of post-RA O&M activities. If an O&F period applies, indicate the start
and end dates. For interim RA reports, indicate when cleanup goals are estimated to be
achieved. An example chronology is provided in Exhibit 4-5.
Exhibit 4-5
Example Chronology of Events (Section 4)
Date Event
March 8, 1996 ROD for OU2 signed.
August 3, 1996 Remedial Design (RD) submitted.
September 15, 1996 RD approved; ROD amendment signed.
September 29, 1996 RA contract awarded.
Construction of the land treatment area began, including excavation of contaminated
October 3, 1996
soil..
December 1, 1996 Solidified waste from OU1 transported and disposed of off-site.
December 12, 1996 PRPs, EPA, and the State conduct pre-final inspection of the land treatment area.
January 12, 1997 PRPs, EPA, and the State conduct final inspection of the land treatment area.
Operation of land treatment area begun; first lift of soil applied to treatment subplots;
January 19, 1997
sampling of soil in treatment plots begun.
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a. This section should describe the overall performance of the remedial technology
in terms of a comparison to cleanup goals/remediation objectives. For treatment remedies, this
section should identify the quantity of material treated, the strategy used for collecting and
analyzing samples, and the overall results from the sampling and analysis effort. An explanation
of the approved construction quality assurance (QA) and quality control (QC) requirements, or
citations for the appropriate references, should be provided. An explanation of any substantial
problems or deviations should be included.1 An assessment of the performance data quality and
of the overall analytical data quality should be provided, including a brief discussion of the
QA/QC procedures followed, the quality assurance project plan (QAPP) used, and the data
quality objectives (DQOs) to which the analytical data were compared. For PRP-lead projects, a
discussion should be provided of EPA’s oversight activities and results with regard to analytical
data quality. An example section is provided in Exhibit 4-6.
b. Specific topics to consider for this section include sample frequency and protocol,
concentrations of untreated vs. treated contaminants, comparison with cleanup goals, methods of
analysis, and treatment residues. More detailed information on documenting technology
performance is provided in Chapter 5 of this guide (Paragraph 5-1).
1
Note that changes to the remedy selected in the ROD that occurred during the RD/RA process must be described in an
Explanation of Significant Differences (ESD) or a ROD Amendment pursuant to NCP §§300.435(c)(2) and 300.825(a) that is
provided separately from the RA report.
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Exhibit 4-6
Example Performance Standards and Construction Quality Control
(Section 5)
Performance Standards
The quantity of soil treated by landfarming was 8,100 yd3. Initial concentrations of PAHs in untreated, stockpiled
soil ranged from 100 to 208 mg/kg. Upon completion of land treatment, the concentration of TCICs in soil ranged
from 23 to 92 mg/kg.
All soil and sludge samples collected during operation of the land treatment area were analyzed for PAHs. EPA
Method 8270 was used to measure the concentrations of PAHs in all samples. Composite samples were collected
quarterly from eight subplots in the land treatment area over an 18-month operating period. Once the cleanup goal
had been achieved in a subplot, that subplot was not monitored further until an additional lift of soil was applied
to the subplot.
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4-7. Final Inspections and Certifications. This section should report the results of the
various RA contract inspections, and should identify any noted deficiencies. Adherence to
health and safety requirements while implementing the RA should be described briefly. Any
substantial problems or deviations should be explained. This section should summarize details
of the institutional controls, if implemented, (e.g., the type of institutional control, who will
maintain the control, and who will enforce the control). For PRP-lead projects, a description of
the pre-certification inspection results should be included. If applicable, the date that the remedy
was determined to be O&F should also be included. An example section is provided in
Exhibit 4-7.
Exhibit 4-7
Example Final Inspections and Certifications (Section 6)
Inspections
The pre-final inspection of the land treatment area construction was held on-site December 12, 1996, in the
presence of EPA, PRP, and FDER representatives. The FDER representative noted the need to fence the lagoon
for the protection of the public, and a fence was constructed around the lagoon area.
The final inspection was conducted January 12, 1997. EPA, the PRPs, FDER, the Florida Department of Health
and Rehabilitative Services (FDHRS), the Suwanee County Coordinator, and the Mayor of Live Oak were
present.
Representatives verified by review of the manifests that the 7,500 cubic yards of solidified OU1 waste had been
properly transported and disposed off-site at the CWM landfill in Emelle, Alabama. No punch-list items were
identified, and land treatment of the stockpiled contaminated soil was authorized to begin immediately.
Observations, inspections, and testing during operation of the land treatment process found no significant
operational problems affecting the performance of the remedial action. A business east of the site reported
experiencing nuisance smells after the contaminated soils in the land treatment area were tilled. In response, an
effort was made to till when the wind direction was away from the businesses to the east of the site. No further
comments about odors were received during the land treatment operation.
Health and Safety
No health and safety problems were encountered during construction or operation. Modified Level D personal
protective equipment (PPE) was required for all site personnel who came into direct contact with the
contaminated soil. The equipment included coveralls, safety boots, nitrile gloves, and particulate masks.
Certification of Completion
A pre-certification inspection of the completed remedial action was conducted on September 22, 1998, by
representatives of the PRPs, EPA and the FDER. On October 17, 1998, the PRPs provided a written report that
the remedial action has been fully performed and the performance standards of the consent decree have been
attained.
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4-8. Operation & Maintenance Activities. This section should describe the general
activities included as post-construction O&M, such as monitoring, site maintenance, and closure
activities. This can include both short-term (RA operating) and long-term (post-RA) O&M.
Information regarding any LTRAs and PRP LRs should also be included in this section. Any
potential problems or concerns with these activities should be identified here. The results of any
optimization efforts during O&M should be noted. If an interim RA report is being completed,
the future groundwater or surface water restoration activities should be described. An example
O&M activities section is provided in Exhibit 4-8.
Exhibit 4-8
Example Operations & Maintenance Activities (Section 7)
The land treatment area was grass-seeded in September 1998. The vegetative cover will be reseeded in Spring
1999 as necessary.
The semiannual groundwater monitoring program began in January 1997. No TCICs have been detected as of the
July 1998, sampling; however, naphthalene has been detected persistently at low levels in groundwater
monitoring well No. 7. The levels of naphthalene are below any action level. As specified in the ROD, the PRPs
will continue semi-annual monitoring of groundwater through 2002 to confirm that groundwater will not be
adversely impacted by the land treatment activities.
a. This section should present the total costs incurred for the remedial action. These
costs can be designated as capital, O&M, or periodic costs, as described in Chapter 6. Further,
these costs can be designated as RA or post-RA costs (e.g., RA capital costs, RA operating costs,
post-RA O&M costs).
c. The year(s) in which costs were incurred should be indicated. If actual costs are
not available, estimated costs should be provided (e.g., when pending claims may impact final
cost).
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Exhibit 4-9
Example Summary of Project Costs (Section 8)
The table below provides a summary of the total project costs and a comparison of the actual costs with the ROD
estimate. Appendix B provides additional project cost breakdown.
Cost Summary
ROD Estimate ROD Estimate Actual Cost
Cost Item 1
(1996 $$) (1998 $$) (1998 $$)
2
Projected Future O & M Cost 21,000
1
ROD Cost was adjusted from 1996 $$ to 1998 $$ using average 1996 and 1998 ENR building cost index factors.
2
Groundwater monitoring was not included in original ROD. Assumed length of monitoring = 5 years
3
Difference between project cost and ROD estimate is largely attributable to 18 months of actual treatment instead of 24 months
planned in the ROD.
4-10. Observations and Lessons Learned. This section should discuss site- or OU-specific
observations and lessons learned, highlighting successes, problems and their resolutions. The
discussion of the problems and their resolutions will be included in the useful technical
information that will be extracted by the government and compiled for use in future remedy
selections. The information presented should be technical in nature and specific to the site.
Observations or lessons learned relating to both cost and performance of the remedial action are
important to note. An example section is provided in Exhibit 4-10.
Exhibit 4-10
Example Observations and Lessons Learned (Section 9)
♦ The project cost 22% less than the adjusted ROD estimate, largely due to reduced labor and materials costs
associated with achieving remediation objectives in 18 instead of 24 months. Use of an on-site laboratory
also contributed to savings.
♦ The land treatment application was found to be more effective at remediating soils on the site when the soils
were tilled once every two weeks, rather than once every four weeks, as was originally planned.
♦ Application of fertilizers to the soils at the site proved to be unnecessary because of the naturally high
concentrations of inorganic nitrogen and phosphorous in the soil.
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4-11. Operable Unit Contact Information. This section should provide contact information
(names, addresses, phone numbers, and contract reference data) for the major design and
remediation contractors and subcontractors, oversight contractors, and the respective project
managers for the government and the PRPs, as applicable. If available, O&M contact
information should be included, such as the prime O&M contractor, subcontractors, and
oversight contractors. Contract numbers for the RA and O&M should also be listed, if available.
If all available information has already been provided as part of the abstract, this section may be
excluded from the RA report. Example information blocks are shown in Exhibit 4-11.
Exhibit 4-11
Example Operable Unit Contact Information (Section 10)
Remedial Action Contractor:
Primary Contact Name and Title:
Company Name:
Address:
Phone Number:
RA Oversight Contractor:
Company
Contract Number:
Name:
Address:
Work Assignment
Phone Number:
Number:
Analytical Laboratory:
For the PRPs:
Company Name:
Address:
Phone Number:
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4-12. References. All references used in preparing the RA report, as well as key documents
relating to the RA, should be listed in the references section of the RA report. Examples of
documents to reference include the ROD, ROD amendment, remedial design documents, key
correspondence/deliverables during the RA, and as-built drawings.
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CHAPTER 5
DOCUMENTING TECHNOLOGY PERFORMANCE
b. Exhibit 5-1 provides a guide to ensure that all important information related to the
performance of the technology will be documented in the RA report. The level of detail and data
available for each performance topic will vary by technology type and the specific application.
Exhibit 5-1
Recommended Performance Reporting
Performance Topic Type of Information
Types of samples collected ♦ Types of media sampled
♦ Types of constituents analyzed
♦ Use of surrogates (e.g., soil gas as a surrogate for soil borings)
Sample frequency and protocol ♦ Where samples were collected
♦ How samples were collected
♦ When samples were collected
♦ Who collected samples
Quantity of material treated ♦ Quantity of material treated during application
♦ For in situ technologies, area and depth of contaminated material treated
Concentrations of untreated ♦ Measurement of initial conditions (even if not required to demonstrate
and treated contaminants compliance with cleanup/remediation criteria)
(range and median values) ♦ Measurement of concentrations of contaminants during or after treatment
(note whether data exists for both treated and untreated contaminants or
whether operating data exists that corresponds with performance data)
♦ Assessment of percent removal achieved (note procedure used to derive
percent removal)
♦ Correlation of performance data with other variables
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a. The Guide to Documenting and Managing Cost and Performance Information for
Remediation Projects (EPA 542-B-98-007) lists factors that can affect the cost or performance of
a treatment technology and recommends that those factors be documented when reporting
technology cost and performance. These include matrix characteristics, such as soil types, soil
properties, and organic contaminants that may be present in a matrix being treated; and operating
parameters of the treatment system, such as residence time and system throughput. Nonmatrix
characteristics such as geology and hydrogeology for in situ applications are also important to
document. Technologies for which factors are provided are listed in Exhibit 5-2. Suggested
parameters to report for these technologies are provided in Exhibit 5-3.
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Exhibit 5-2
Example Remedial Technologies
Ex Situ Soil Remediation Groundwater Remediation and/or Containment
♦ Composting ♦ Air Sparging
♦ Incineration ♦ Bioremediation
♦ Land Treatment ♦ Bioslurping
♦ Slurry-Phase Bioremediation ♦ Circulating Wells (UVB)
♦ Soil Washing ♦ Cosolvents and Surfactants
♦ Stabilization ♦ Multi-Phase Extraction
♦ Thermal Desorption ♦ Dynamic Underground Stripping
♦ In Situ Oxidation (Fenton’s Reagent)
In Situ Soil Remediation and/or
Containment ♦ Natural Attenuation (Chlorinated Compounds)
♦ Natural Attenuation (Nonchlorinated
♦ Bioventing Hydrocarbons)
♦ Capping ♦ Permeable Reactive Barriers
♦ In Situ Heating ♦ Phytoremediation
♦ Phytoremediation ♦ Pump and Treat System
♦ Soil Flushing ♦ Steam Flushing
♦ Soil Vapor Extraction ♦ Vertical Barrier Walls
♦ Vitrification
b. For the RA report, both matrix characteristics and operating parameters of the
treatment system should be reported in an appendix as well as site conditions (e.g.,
geology/hydrogeology), as applicable, that may impact the cost and performance of the treatment
technologies used in the remedy. The appendix should report the values or results of each
parameter as well as the procedures used to measure the parameter.
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Exhibit 5-3
Suggested Parameters to Report that Affect Cost and Performance
Soil Types Aggregate Soil Matrix Properties Organic Properties System Parameters Biological Activity Misc.
Operating Parameters
Components/Additives &
Particle Size Distribution
Depth or Thickness of
Operating Pressure /
System Throughput
Presence of NAPLs
Soil Classification
Microbial Activity
Moisture Content
Air Permeability
Residence Time
Zone of Interest
Miscellaneous
Pumping Rate
Air Flow Rate
Amendments
Temperature
Organics
Porosity
Vacuum
pH
pH
Technology
Bioventing l l l l l l l l l l l l l l l l
In Situ Soil Remediation
Capping l l l l l l l1
and/or Containment
In Situ Heating l l l l l l l l l l l l2
Phytoremediation l l l l l l l l l l l3
Soil Flushing l l l l l l l l l l l l
Soil Vapor Extraction l l l l l l l l l l
Vitrification l l l l l l l4
Composting l l l l l l l l l l l l l l5
5-4
Incineration l l l l l l l l l6
Land Treatment l l l l l l l l l l l l7
Slurry-Phase Bioremediation l l l l l l l l l l l l l l8
Soil Washing l l l l l l l l l9
Stabilization l l l l l l l l l l10
Thermal Desorption l l l l l l l l11
Soil Types Aggregate Soil Matrix Properties Organic Properties System Parameters Biological Activity Misc.
Operating Parameters
Components/Additives &
Particle Size Distribution
Depth or Thickness of
Operating Pressure /
System Throughput
Presence of NAPLs
Soil Classification
Microbial Activity
Moisture Content
Air Permeability
Residence Time
Zone of Interest
Miscellaneous
Pumping Rate
Air Flow Rate
Amendments
Temperature
Organics
Porosity
Vacuum
pH
pH
Technology
Air Sparging l l l l l l l l l
Bioremediation l l l l l l l l l l l l l l l l
Bioslurpiing l l l l l l l l l l l l l l l l l l
Groundwater Remediation and/or Containment
EP 1110-1-19
Environmental Restoration Cost and Performance, USACE 1996
19 Permeability of wall material and depth of key
30 Jun 01
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c. Exhibits 5-4 and 5-5 provide examples of how matrix characteristics and
operating parameters may be reported in Appendix A of the RA report for a remedial action that
uses a land treatment system to remediate contaminated soil.
Exhibit 5-4
Example Matrix Characteristics
Parameter Value/Result Measurement Procedure
Soil Types
Mixture of lagoon contents;
Because the medium treated was a
lagoon had a clay bottom and
Soil classification mixture of lagoon contents, it did not lend
sandy contents, which ranged from
itself to a formal classification analysis.
silty clay to fine sand
Aggregate Soil Properties
The value listed represents an average
measured during one of the sampling
pH 6.9
events; EPA Method SW-846/9045 was
used to measure the pH of the soil.
The value listed represents an average
measured during one of the sampling
Total organic carbon 16,000 mg/kg events; EPA Method SW-846/9060 was
used to measure the total organic carbon
in the soil.
Quantity of soil treated 8,100 yd3 (total for 3 lifts) NA
NA - not applicable. Measurement procedures are reported only for those parameters where different procedures are available.
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Exhibit 5-5
Example Operating Parameters
Parameter Value/Result Measurement Procedure
System Parameters
Soil mixing rate / Soil placed in the subplots Mixing rate or frequency is the rate of tilling for land
frequency was tilled every two weeks. treatment.
12.4 - 22.8 (Lift 1) Soil moisture was measured using the gravimetric
Soil moisture content ASTM standard D 2216-90, Test Method for
12.9 - 21.1 (Lift 2)
(%) Laboratory Determination of Water (Moisture) Content
8.5 - 14.7 (Lift 3) of Soil and Rock.
6.6 - 7.2 (Lift 1)
Values shown represent the ranges of pH for each lift.
pH 6.8 - 7.5 (Lift 2) EPA Method SW-846/9045 was used to measure the pH
content.
6.4 - 7.0 (Lift 3)
9 - 15 (Lift 1)
Residence time Ranges are given for each lift because of the variations
6 - 10 (Lift 2)
(months) by subplot.
4 (Lift 3)
13 - 99 (Lift 1)
Soil temperature (°F) 13 - 102 (Lift 2) NA
29 - 102 (Lift 3)
Biological Activity
Values represent the ratio of Carbon to Total Kjeldahl
8.8 - 15.4 (Lift 1)
Nitrogen in the soil at the time of measurement for each
Carbon/Total Kjeldahl
8.8 - 78 (Lift 2) lift. Ranges are shown for the eight treatment subplots.
Nitrogen
6 - 67 (Lift 3) EPA Methods 415.1 (Modified) and 351.1 (Modified)
were used.
Calculation of hydrocarbon degradation was based on
13 - 58 (Lift 1) the difference between the initial and final TCIC
Hydrocarbon
concentrations in the first lift and dividing that value by
degradation No values were determined the amount of time required for treatment of soil in that
(mg/kg/month) for Lifts 2 and 3. cell in the first lift. The values shown represent the
range measured for the eight treatment subplots.
1.0x10 5 - 5.0x10 7 (Lift 1) “Replica Plating Method for Estimating Phenanthrene-
Utilizing and Phenanthrene-Cometabolizing Micro-
PAH degraders 7.0x10 2 - 4.5x10 6 (Lift 2)
organisms,” Shiaris, M., Cooney, J., Applied and
(cfu/gm)
No values were determined Environmental Microbiology, February 1983, Vol. 45,
for Lift 3. No. 2, pp. 706-710.
7x10 5 - 9.9x10 7 (Lift 1)
“Agar-Plate Method for Total Microbial Count,”
Total heterotrophs
6.3x10 5 - 6.6x10 7 (Lift 2) F. Clark, Methods of Soil Analysis, Vol. 2, pp. 1460-
(cfu/gm)
1465.
7.0x10 4 - 1.1x10 7 (Lift 3)
NA - not applicable. Measurement procedures are reported only for those parameters where different procedures are available.
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CHAPTER 6
DOCUMENTING PROJECT COSTS
6-1. General.
6-2. Definitions. The types of costs to document in the RA report include capital, O&M (RA
operating and post-RA O&M), and periodic costs. These are defined below. Figure 6-1
illustrates the relationship of these costs to the RA and O&M phases.
a. Capital costs are those expenditures that are required to construct the RA. They
are exclusive of the costs required to operate or maintain the action throughout its lifetime.
Capital costs consist primarily of expenditures initially incurred to build or install the remedial
action (e.g., construction of a groundwater treatment system and related site work). Capital costs
include all labor, equipment, and material costs, including contractor markups such as overhead
and profit, associated with construction activities. The RA WBS should be primarily used to
report capital costs. Capital costs can also include expenditures for professional/technical
services that are necessary to support construction of the RA.
b. O&M costs are those post-construction costs necessary to ensure or verify the
continued effectiveness of a remedial action. O&M costs documented in the RA report can
include RA operating costs and post-RA O&M costs. The RA WBS should be primarily used to
report RA operating costs and the O&M WBS should be primarily used to estimate post-RA
O&M costs. O&M costs include all labor, equipment, and material costs, including contractor
markups such as overhead and profit, associated with O&M activities. O&M costs can also
include expenditures for professional/technical services necessary to support O&M activities.
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c. Periodic costs are those capital or O&M costs that occur only once every few
years (e.g., five-year reviews, equipment replacement) or expenditures that occur only once
during the entire O&M period or remedial timeframe (e.g., site close out). Periodic costs can be
incurred during the RA operating period, but are more likely to be incurred during the post-RA
O&M period. Either the RA or O&M WBS can be used to report periodic costs.
Exhibit 6-1
Relationship of Capital and O&M Costs to Pipeline Phases
6-3. Cost Element Structure. All applicable capital, O&M, and periodic costs should be
documented in the RA report. To help identify the cost element structure to report costs; capital,
O&M, and periodic cost elements are described in Exhibits 6-2, 6-3, and 6-4, respectively.
Exhibits 6-2 and 6-3 includes second-level elements from the HTRW RA and O&M work
breakdown structures, respectively, for construction and O&M activities. Professional/technical
services and institutional controls have been added to the descriptions in Exhibits 6-2 and 6-3;
however, these costs are not reported into HCAS. More information on the RA and O&M work
breakdown structures is provided below.
a. The RA WBS, Account 33XXX, includes construction (RA capital) and operation
during the remedial action (RA operating). Account 33XXX excludes all project management at
all phases and excludes pre construction investigations and remedial design. Account 33XXX
excludes post construction O&M, which is in Account 34XXX.
b. The O&M WBS, Account 34XXX, includes post construction O&M (post RA
O&M), which is long term, indefinite term, or caretaker status following remedial action.
Account 34XXX includes such items as operation labor and equipment, maintenance and repair,
fuel, utilities, bulk chemicals, raw materials, plant ownership/rental, plant upgrades and
replacements, transport waste materials to the plant, preparation and handling of waste materials
at the plant, training, regulatory approvals, etc.
6-4. Capital Cost Elements. The majority of the capital cost elements listed in Exhibit 6-2
are construction activities (e.g., sitework) that are incurred as part of the physical construction of
the RA. Project management, remedial design, and construction management are
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331XX.01 Includes all preparatory work required during remedial action or construction. This
Mobilization and includes submittals; construction plans; mobilization of personnel, facilities and
Preparatory Work equipment; construction of temporary facilities; temporary utilities; temporary
relocations and setup of decontamination facilities and construction plant.
331XX.02 Provides for all work during remedial action associated with air, water, sludge, solids
Monitoring, and soil sampling, monitoring, testing, and analysis. Includes sample taking, shipping
Sampling, Testing, samples and sample analysis by on-site and off-site laboratory facilities.
and Analysis
331XX.03 Sitework during remedial action consists of site preparation, site improvements, and
Sitework site utilities. Site preparation includes demolition, clearing, and earthwork. Site
improvements include roads, parking, curbs, gutters, walks and other hardscaping.
Site utilities include water, sewer, gas, other utility distribution. Also includes new
fuel storage tanks. All work involving contaminated or hazardous material is excluded
from this system. Storm drainage involving contaminated surface water is included
under "Surface Water Collection and Control" (331XX.05). Note that topsoil, seeding,
landscaping and reestablishment of existing structures altered during remediation
activities are included in "Site Restoration" (331XX.20).
331XX.04 Includes the locating, removing, and destruction of all ordnance, conventional or
Ordnance and chemical, fused or unfused, related scrap, propellants, and delivery vehicles during
Explosive-Chemical remedial action. Providing for public involvement, providing subsurface data for the
Warfare Material delineating the extent of the contamination. Also includes the construction of
Removal and temporary explosive storage bunkers and surveys.
Destruction
331XX.05 Provides for the collection and control of contaminated surface water through the
Surface Water construction of storm drainage piping and structures, erosion control measures, and
Collection and civil engineering structures such as berms, dikes and levees. Includes the collection of
Control surface water through the construction of lagoons, basins, tanks, dikes, and pump
systems. Includes transport to treatment plant.
331XX.06 Provides for the remedial action collection and control of contaminated groundwater
Groundwater through the construction of piping, wells, trenches, slurry walls, sheet piling and other
Collection and physical barriers. Includes the collection of groundwater through the construction of
Control lagoons, basins, tanks, dikes, and pump systems. Includes transport to treatment plant.
331XX.07 Includes the remedial action construction for the collection and control of gas, vapor
Air Pollution/Gas and dust.
Collection and
Control
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331XX.08 Provides for exhuming and handling of solid hazardous, toxic and radioactive waste
Solids Collection and (HTRW) during remedial action through excavation, sorting, stockpiling, and filling
Containment containers. Provides for containment of solid waste through the construction of
multilayered caps as well as dynamic compaction of burial grounds, cribs, or other
waste disposal units. Includes transport to treatment plant.
331XX.09 Includes collection during remedial action of HTRW-contaminated liquids and sludges
Liquids/Sediment/Slu through dredging and vacuuming, and the furnishing and filling of portable containers.
dge Collection and Includes the containment of liquids and sludges through the construction of lagoons,
Containment basins, tanks, dikes, and drain system. Includes transport to treatment plant.
331XX.10 Includes the demolition and removal during remedial action of HTRW contaminated
Drums/Tanks/Structu drums, tanks, contaminated paint removal, and other structures by excavation and
res/Miscellaneous downsizing. Does not include filling portable hazardous waste containers or transport
Demolition and of wastes to treatment or disposal facilities. See "Solids Collection and Containment"
Removal (331XX.08), "Disposal (Other than Commercial)" (331XX.18), and "Disposal
(Commercial)" (331XX.19)
331XX.11 Includes operation (separate items for each subsystem technology) of the plant facility
Biological Treatment during the remedial action phase, based on the volume of waste material treated,
including portable treatment equipment which is charged on a time basis and can be
used on more than one project (331XX.11.(01.-14.)). Includes a separate item for the
construction of a permanent plant facility, including permanent treatment equipment
which is purchased for one project only (331XX.11.50.). Biological treatment is the
microbial transformation of organic compounds. Biological treatment processes can
alter inorganic compounds such as ammonia and nitrate, and can change the oxidation
state of certain metal compounds. Includes in-situ biological treatment such as land
farming as well as activated sludge, composting, trickling filters, anaerobic, and
aerobic digestion. Includes process equipment and chemicals required for treatment.
For transportation see "Transport to Treatment Plant" (331XX.05.11, 331XX.06.08,
331XX.08.03 or 331XX.09.04).
331XX.12 Includes operation (separate items for each subsystem technology) of the plant facility
Chemical Treatment during the remedial action phase, based on the volume of waste material treated,
including portable treatment equipment which is charged on a time basis and can be
used on more than one project (331XX.12.(01.-14.)). Includes a separate item for the
construction of a permanent plant facility, including permanent treatment equipment
which is purchased for one project only (331XX.12.50.). Chemical treatment is the
process in which hazardous wastes are chemically changed to remove toxic
contaminants from the environment. Type of treatment included in this system are
oxidation/reduction, solvent extraction, chlorination, ozonation, ion exchange,
neutralization, hydrolysis, photolysis, dechlorination, and electrolysis reactions.
Includes process equipment and chemicals required for treatment. For transportation
see "Transport to Treatment Plant" (331XX.05.11, 331XX.06.08, 331XX.08.03 or
331XX.09.04).
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331XX.13 Includes operation (separate items for each subsystem technology) of the plant facility
Physical Treatment during the remedial action phase, based on the volume of waste material treated,
including portable treatment equipment which is charged on a time basis and can be
used on more than one project (331XX.13.(01.-32.)). Includes a separate item for the
construction of a permanent plant facility, including permanent treatment equipment
which is purchased for one project only (331XX.13.50.). These treatment processes
are the physical separation of contaminants from solid, liquid or gaseous waste
streams. The treatments are applicable to a broad range of contaminant
concentrations. Physical treatments generally do not result in total destruction or
separation of the contaminants in the waste stream, consequently post-treatment is
often required. Type of physical treatment included in this system are filtration,
sedimentation, flocculation, precipitation, equalization, evaporation, stripping, soil
washing, and carbon adsorption. Includes process equipment and chemicals required
for treatment. For transportation see "Transport to Treatment Plant" (331XX.05.11,
331XX.06.08, 331XX.08.03 or 331XX.09.04).
331XX.14 Includes operation (separate items for each subsystem technology) of the plant facility
Thermal Treatment during the remedial action phase, based on the volume of waste material treated,
including portable treatment equipment which is charged on a time basis and can be
used on more than one project (331XX.14.(01.-07.)). Includes a separate item for the
construction of a permanent plant facility, including permanent treatment equipment
which is purchased for one project only (331XX.14.50.). Thermal treatment is the
destruction of wastes through exposure to high temperature in combustion chambers
and energy recovery devices. Several processes capable of incinerating a wide range
of liquid and solid wastes include fluidized bed, rotary kiln, multiple hearth, infrared,
circulating bed, liquid injection, pyrolysis, plasma torch, wet air oxidation,
supercritical water oxidation, molten salt destruction, and solar detoxification.
Includes process equipment and chemicals required for treatment. For transportation
see "Transport to Treatment Plant" (331XX.05.11, 331XX.06.08, 331XX.08.03 or
331XX.09.04).
331XX.15 Includes operation (separate items for each subsystem technology) of the plant facility
Stabilization/Fixation/ during the remedial action phase, based on the volume of waste material treated,
Solidification including portable treatment equipment which is charged on a time basis and can be
used on more than one project (331XX.15.(01.-07.)). Includes a separate item for the
construction of a permanent plant facility, including permanent treatment equipment
which is purchased for one project only (331XX.15.50.). Stabilization/fixa-
tion/encapsulation processes attempt to improve the handling and physical
characteristics of the wastes, decrease the surface area, limit the solubility of any
pollutants and detoxify contained pollutants. For transportation see "Transport to
Treatment Plant" (331XX.05.11, 331XX.06.08, 331XX.08.03 or 331XX.09.04).
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331XX.17 Decontamination and decommissioning during remedial action are all activities
Decontamination and associated with shutdown and final cleanup of a nuclear or other facility. Includes
Decommissioning facility shutdown and dismantling activities, preparation of decommissioning plans,
(D&D) procurement of equipment and materials, research and development, spent fuel
handling, and hot cell cleanup.
331XX.18 Includes operation (separate items for each subsystem disposal method) of the plant
Disposal (Other than facility during the remedial action phase, based on the volume of waste material
Commercial) disposed, including portable treatment equipment which is charged on a time basis and
can be used on more than one project (331XX.18.(01.-10.)). Includes a separate item
for the construction of a permanent disposal facility, including permanent disposal
equipment, which is purchased for one disposal facility only (331XX.18.15.).
Disposal (Other than Commercial) provides for the final placement of HTRW or
ordnance at facilities owned or controlled by the Government. An example would be
the disposal of wastes through burial at a DOE nuclear facility or ordnance disposal at
DOD facilities. Includes handling, disposal fees, and transportation to the final
Destruction/Disposal/Storage facility. Excluded is the transportation to a facility for
treatment prior to final disposal. For transportation prior to final disposal see
"Transport to Treatment Plant" (331XX.05.11, 331XX.06.08, 331XX.08.03 or
331XX.09.04). Disposal may be accomplished through the use of secure landfills,
burial grounds, trench, pits, above ground vault, underground vault, underground
mine/shaft, tanks, pads (tumulus / retrievable storage, other), storage buildings or
protective cover structures, cribs, deep well injection, incinerator, or other.
331XX.19 Commercial disposal during remedial action provides for the final placement of
Disposal HTRW at third party commercial facilities that charge a fee to accept waste depending
(Commercial) on a variety of waste acceptance criteria. Fees are assessed based on different waste
categories, methods of handling, and characterization. Disposal may be accomplished
through the use of secure landfills, surface impoundments, deep well injection, or
incineration. Includes transportation to the final Destruction/Disposal/Storage facility.
Excludes transportation to a facility for treatment prior to disposal. For transportation
see "Transport to Treatment Plant" (331XX.05.11, 331XX.06.08, 331XX.08.03 or
331XX.09.04).
331XX.20 Site restoration during remedial action includes topsoil, seeding, landscaping,
Site Restoration restoration of roads and parking, and other hardscaping disturbed during site
remediation. Note that all vegetation and planting is to be included as well as the
installation of any site improvement damaged or altered during construction. All
vegetation and planting for the purpose of erosion control during construction
activities should be placed under "Erosion Control" (331XX.05.13). Treated soil used
as backfill will be placed under "Disposal (Other than Commercial)" (331XX.18). All
new site improvements, those not disturbed during construction, are to be included
under "Sitework" (331XX.03).
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331XX.21 Provides for all work associated with remedial action plant takedown and removal of
Demobilization temporary facilities, utilities, equipment, material, and personnel.
331XX.9x Includes all Hazardous, Toxic, Radioactive Waste Remedial Action work not
Other described by the above-listed systems.
Remedial Design Professional/technical services to design the remedial action, including pre-design
activities to collect the necessary data.
a. Many of the O&M cost elements listed in Exhibit 6-3 are incurred as part of
physical operation and maintenance activities. Project management and technical support are
professional/technical services to support O&M activities. Institutional controls may require
annual update or maintenance to ensure potential for exposure to site contamination or hazards is
reduced or minimized. Contingency, which covers unknowns or unanticipated conditions
associated with future O&M activities, should be added to the total of projected O&M costs (i.e.,
post-RA O&M), which are estimated only at the time of the RA report.
b. O&M costs can vary and may be estimated for different time periods, depending
on the operating conditions and requirements. For example, the first five years of a groundwater
monitoring program may require semiannual sampling, while the next twenty years may only
require annual sampling. Likewise, an installed cap or cover may require more frequent
inspections during the first year of O&M than during subsequent years.
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Exhibit 6-3
Post-RA O&M Cost Elements
Cost Element Description
342XX.02 Provides for all work during post construction O&M associated with air, water,
Monitoring, Sampling, sludge, solids and soil sampling, monitoring, testing, and analysis. Includes
Testing, and Analysis sample taking, shipping samples and sample analysis by on-site and off-site
laboratory facilities.
342XX.03 Post construction O&M. Sitework includes site improvements, and site
Sitework utilities. Site improvements include roads, parking, curbs, gutters, walks and
other hardscaping. Site utilities include water, sewer, gas, other utility
distribution. Also includes fuel storage tanks. All work involving
contaminated or hazardous material is excluded from this system. Storm
drainage involving contaminated surface water is included under "Surface
Water Collection and Control" (342XX.05).
342XX.05 Provides for post construction O&M of the system for the collection and
Surface Water Collection control of contaminated surface water through storm drainage piping and
and Control structures, erosion control measures, and civil engineering structures such as
berms, dikes and levees. Includes transport to treatment plant.
342XX.06 Provides for post construction O&M of the system for the collection and
Groundwater Collection control of contaminated groundwater through piping, wells, trenches, slurry
and Control walls, sheet piling and other physical barriers. Includes transport to treatment
plant.
342XX.07 Includes the post construction O&M of the system for collection and control of
Air Pollution/Gas Collection gas, vapor, and dust.
and Control
342XX.08 Provides for post construction O&M of the system for exhuming and handling
Solids Collection and of solid hazardous, toxic and radioactive waste (HTRW) through excavation,
Containment sorting, stockpiling, and filling containers. Provides for post construction
O&M of multilayered caps. Includes transport to treatment plant.
342XX.09 Includes post construction O&M of the system for collection of HTRW-
Liquids/Sediments/Sludge contaminated liquids and sludges through dredging and vacuuming, and the
Collection and Containment furnishing and filling of portable containers. Includes the post construction
O&M of the system for containment of liquids and sludges through lagoons,
basins, tanks, and dikes. Includes transport to treatment plant.
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342XX.11 Includes post construction O&M (separate for each subsystem technology) of
Biological Treatment the plant facility, based on the volume of waste material treated, including
portable treatment equipment which is charged on a time basis and can be used
on more than one project (342XX.11.(01.-14.)). Includes a separate item for
the yearly post construction O&M of a permanent plant facility
(342XX.11.50.). Biological treatment is the microbial transformation of
organic compounds. Biological treatment processes can alter inorganic
compounds such as ammonia and nitrate, and can change the oxidation state of
certain metal compounds. Includes in-situ biological treatment such as land
farming as well as activated sludge, composting, trickling filters, anaerobic,
and aerobic digestion. Includes process equipment and chemicals required for
treatment. For transportation see "Transport to Treatment Plant"
(342XX.05.11, 342XX.06.08, 342XX.08.03 or 342XX.09.04).
342XX.12 Includes post construction O&M (separate for each subsystem technology) of
Chemical Treatment the plant facility, based on the volume of waste material treated, including
portable treatment equipment which is charged on a time basis and can be used
on more than one project (342XX.12.(01.-14.)). Includes a separate item for
the yearly post construction O&M of a permanent plant facility
(342XX.12.50.). Chemical treatment is the process in which hazardous wastes
are chemically changed to remove toxic contaminants from the environment.
Type of treatment included in this system are oxidation/reduction, solvent
extraction, chlorination, ozonation, ion exchange, neutralization, hydrolysis,
photolysis, dechlorination, and electrolysis reactions. Includes process
equipment and chemicals required for treatment. For transportation see
"Transport to Treatment Plant" (342XX.05.11, 342XX.06.08, 342XX.08.03 or
342XX.09.04).
342XX.13 Includes post construction O&M (separate for each subsystem technology) of
Physical Treatment the plant facility, based on the volume of waste material treated, including
portable treatment equipment which is charged on a time basis and can be used
on more than one project (342XX.13.(01.-32.)). Includes a separate item for
the yearly post construction O&M of a permanent plant facility
(342XX.13.50.). These treatment processes are the physical separation of
contaminants from solid, liquid or gaseous waste streams. The treatments are
applicable to a broad range of contaminant concentrations. Physical treatments
generally do not result in total destruction or separation of the contaminants in
the waste stream, consequently post-treatment is often required. Type of
physical treatment included in this system are filtration, sedimentation,
flocculation, precipitation, equalization, evaporation, stripping, soil washing,
and carbon adsorption. Includes process equipment and chemicals required for
treatment. For transportation see "Transport to Treatment Plant"
(342XX.05.11, 342XX.06.08, 342XX.08.03 or 342XX.09.04).
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342XX.14 Includes post construction O&M (separate for each subsystem technology) of
Thermal Treatment the plant facility, based on the volume of waste material treated, including
portable treatment equipment which is charged on a time basis and can be used
on more than one project (342XX.14.(01.-07.)). Includes a separate item for
the yearly post construction O&M of a permanent plant facility
(342XX.14.50.). Thermal treatment is the destruction of wastes through
exposure to high temperature in combustion chambers and energy recovery
devices. Several processes capable of incinerating a wide range of liquid and
solid wastes include fluidized bed, rotary kiln, multiple hearth, infrared,
circulating bed, liquid injection, pyrolysis, plasma torch, wet air oxidation,
supercritical water oxidation, molten salt destruction, and solar detoxification.
Includes process equipment and chemicals required for treatment. For
transportation see "Transport to Treatment Plant" (342XX.05.11,
342XX.06.08, 342XX.08.03 or 342XX.09.04).
342XX.15 Includes post construction O&M (separate for each subsystem technology) of
Stabilization/Fixation/ the plant facility, based on the volume of waste material treated, including
Capsulation portable treatment equipment which is charged on a time basis and can be used
on more than one project (342XX.15.(01.-07.)). Includes a separate item for
the yearly post construction O&M of a permanent plant facility
(342XX.15.50.). Stabilization/fixation/encapsulation processes attempt to
improve the handling and physical characteristics of the wastes, decrease the
surface area, limit the solubility of any pollutants and detoxify contained
pollutants. For transportation see "Transport to Treatment Plant"
(342XX.05.11, 342XX.06.08, 342XX.08.03 or 342XX.09.04).
342XX.18 Includes post construction O&M (separate for each subsystem disposal
Disposal (Other than method) of the plant facility, based on the volume of waste material disposed,
Commercial) including portable treatment equipment which is charged on a time basis and
can be used on more than one project (331XX.18.(01.-10.)). Includes a
separate item for the yearly post construction O&M of a permanent disposal
facility (342XX.18.15.). Disposal (Other than Commercial) provides for the
final placement of HTRW or ordnance at facilities owned or controlled by the
Government. An example would be the disposal of wastes through burial at a
DOE nuclear facility or ordnance disposal at DOD facilities. Includes
handling, disposal fees, and transportation to the final Destruction/Disposal/
Storage facility. Excluded is the transportation to a facility for treatment prior
to final disposal. For transportation prior to final disposal see "Transport to
Treatment Plant" (342XX.05.11, 342XX.06.08, 342XX.08.03 or
342XX.09.04). Disposal may be accomplished through the use of secure
landfills, burial grounds, trench, pits, above ground vault, underground vault,
underground mine/shaft, tanks, pads (tumulus / retrievable storage, other),
storage buildings or protective cover structures, cribs, deep well injection,
incinerator, or other.
342XX.9X Includes all Hazardous, Toxic, Radioactive Waste post construction O&M
Other work not described by the above listed systems.
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6-6. Periodic Cost Elements. The periodic cost elements listed in Exhibit 6-4 include both
construction or O&M-type activities and professional/technical services. Distinctions should be
made between periodic costs that occur during the RA operating and post-RA O&M periods.
Contingency should be added to projected periodic costs that may occur during the post-RA
O&M period. Periodic costs should be rolled up into the appropriate items of the RA WBS
and/or the O&M WBS.
Exhibit 6-4
RA or Post-RA O&M Periodic Cost Elements
Cost Element Description
Remedy Failure or Construction activity to replace an installed remedy or key components of the
Replacement remedy.
Remedial Action Report Professional/technical services to prepare remedial action report upon
completion of RA.
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6-7. Project Cost Appendix. To support the summary of total project costs in the RA report
(Paragraph 4-9 of this guide), cost information should be provided in an appendix to the RA
report. This should include a cost breakdown and, if treatment was part of the remedy,
calculation of technology-specific unit cost(s).
a. Cost Breakdown
(1) The cost breakdown should be in the form of one- to two-page table(s) that
presents all RA capital and operating costs, post-RA O&M costs, and RA or post-RA O&M
periodic costs, actual or projected. The table(s)
should follow an activity-based format that
identifies all cost elements and sub-elements
Cost Growth
using the RA WBS or O&M WBS, as As a project moves from the planning
applicable for each of the types of costs stage to the implementation stage, more and
more becomes known about the actual costs of
presented (e.g., RA capital costs, RA operating the project. During the course of RA projects,
costs, post-RA O&M costs). the expected accuracy of cost estimates ranges
from about –30% to +50% for the ROD to
(2) Exhibit 6-5 provides an example about –10% to +15% at the time of RA bid and
of how a cost breakdown may be reported in award to 0% at the completion of work.
Appendix B of the RA report for a remedial Contingency is typically added to
action that uses land treatment system to estimates at various stages to account for cost
remediate contaminated soil. In this example, growth potential. Scope (design) contingency
covers unknowns associated with an
no periodic costs apply. incomplete design. Bid (construction)
contingency accounts for unforeseen costs that
b. Technology-Specific Unit Cost become known as construction proceeds. This
amount represents a reserve for quantity
(1) The Guide to Documenting and overruns, modifications, change orders, claims,
Managing Cost and Performance Information etc.
for Remediation Projects (EPA 542-B-98-007) In addition to comparison to the ROD
presents a recommended format for reporting estimate, reporting of actual costs in the RA
technology-specific costs. One of the purposes report allows for comparison to the bid/award
estimate and assess the amount and possible
of this format is to enable the calculation of a causes of cost growth during implementation
unit cost using only those items directly related of the RA.
to the performance of a technology. This unit
cost could then be used for comparison with
unit costs of other technologies. The unit cost calculation excludes all project costs associated
with remediation that are not directly attributable to a specific technology. In addition, the
technology-specific unit cost calculation should exclude all costs for project management,
remedial design, construction management, and technical support that are typically added at the
bottom of an estimate or cost breakdown.
(2) For the RA report, if treatment using one or more technologies is part of the
remedy, technology-specific unit costs should be calculated and reported in the project cost
appendix. The total costs and quantities used for the calculation should be clearly stated.
(3) In the example shown in Exhibit 6-5, the subtotal RA capital costs and subtotal
RA operating costs would all be considered specific to land treatment, but not projected
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groundwater monitoring costs. As shown by the calculation in Exhibit 6-6, the unit cost for land
treatment would be $33.73 per cubic yard using a total technology-specific cost of $273,247 and
quantity treated of 8,100 cubic yards.
(4) For more detailed information on calculation of technology-specific unit cost, see
the Guide to Developing and Managing Cost and Performance Information for Remediation
Projects at http://www.frtr.gov/cost/.
c. HCAS Reporting. HCAS project and WBS cost breakdown forms shall be
completed and included in the RA report. Exhibit 6-7 shows an example. Note that costs of
project management, remedial design, construction management, and other items without WBS
numbers (33 or 34 series) are not reported to HCAS.
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Exhibit 6-5
Example Cost Breakdown
ACTUAL & PROJECTED COSTS (1 of 2)
Site: U Creosote Superfund Site Description: The selected treatment consisted of a land treatment system to remediate excavated site
Location: Live Oak, Florida soils. All costs are expressed in 1998 dollars.
Phase: Final RA Report (OU 2)
Date: October 27, 1998
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Exhibit 6-6
Example Technology-Specific Unit Cost Calculation
LAND TREATMENT
RA CAPITAL COSTS:
Solids Collection and Containment $7,695
Biological Treatment $139,521
SUBTOTAL $147,216
RA OPERATING COSTS:
Monitoring, Sampling, Testing, & Analysis $64,700
Biological Treatment $61,331
SUBTOTAL $126,031
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Exhibit 6-7
Example HCAS Data Report and WBS Cost Breakdown
Historical Cost Analysis System (HCAS)
Project Data Entry Form (Sheet 1)
Project Information
Project Name U Creosote Operable Unit 2
Project Number XXXX-YYYY-ZZ
Project Phase (Select one)
Studies and Design
Remedial Action ü
Operations and Maintenance
Project Note (Describe the project)
Landfarming treatment technology was used to remediate 8,100 cubic yards of
PAH-contaminated soil.
Contract Information
Contract Number DACW62-97-C-0100
Managing Organization U.S. Army Corps of Engineers
Organization Name Jacksonville District
Site Owner Private Party
Other ID Number
Prime Contractor Cleanup, Inc.
Contract Type (Select one)
Cost + Award Fee
Cost + Base + Award Fee
Cost + Fixed Fee ü
Cost + Incentive Award
Fixed Price
Not Availiable
Other
Procurement Type (Select one)
Two Step Sealed Bid
Sealed Bid (IFB)
Competitive Negotiation (RFP) ü
Sole Source (SSC)
Other
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Site Information
State/Country Florida/USA
Installation
Site Name Live Oak, FL
Site Number
EPA Region IV
Current Use (Select one)
Installation Operation
Industry Operation
Residential
Recreational
Wildlife Refuge
Waste Disposal ü
Administrative Office
Commercial
Other
Unknown
Future Use (Select one)
Installation Operation
Industry Operation
Residential
Recreational
Wildlife Refuge
Waste Disposal
Administrative Office
Commercial
Other
Unknown ü
Point of Contact
Data Entry Person POC#2 POC#3
Title/Role Contractor Estimator
Organization Cleanup, Inc.
Name E.S. Timator
Address 123 Main St.
City, State Cleantown, FL
Zip 12345
Telephone 999-999-9999
Fax 999-999-8888
Email [email protected]
Enter up to 3 POC's.
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Cost
Start Date 9/29/96
End Date 9/22/98
Number of Mods 0
Reasons for Mods (Select those applicable)
Administrative
Changes for Time or Cost
Changes Requested by Government Authority
Design Deficiency
Differing Site Conditions
Funding Level Change
New Federal Regulation
Other Changes
Suspension or Termination of Work
Value Engineering Change
Variations in Estimated Quantities
Variations Not Readily Identifiable During Design
Cost
Award Amount $399,000
Actual Amount $374,487
Cost Variance -6%
Cost Breakdown
See next sheets.
The next sheets show the RA WBS and O&M WBS to the Third Level
as required for the HCAS cost report portion of the "RA Report".
The complete RA WBS and O&M WBS to the Fourth Level is at:
http://www.FRTR.gov/cost/ec2/wbs1.html
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03 SITEWORK
03 01 Demolition SY
03 02 Clearing and Grubbing 4 ACR 4,090 16,360
03 03 Earthwork CY
03 04 Roads/Parking/Curbs/Walks SY
03 05 Fencing 7500 LF 2.89 21,666
03 06 Electrical Distribution LF
03 07 Telephone/Communication Distribution LF
03 08 Water/Sewer/Gas Distribution LF
03 09 Steam and Condensate Distribution LF
03 10 Fuel Line Distribution LF
03 11 Storm Drainage/Subdrainage LF
03 12 Permanent Cover Structure Over Containment Area SF
03 13 Development of Borrow Pit/Haul Roads ACR
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10 DRUMS/TANKS/STRUCTURES/MISCELLANEOUS
10 01 Drum Removal EA
10 02 Tank Removal EA
10 03 Structure Removal SF
10 04 Asbestos Abatement SF
10 05 Piping and Pipeline Removal LF
10 06 Radioactive Specific Waste Containment (Furnish/Fill) CY
10 07 Miscellaneous Items ACR
10 08 Contaminated Paint Removal SF
10 9x Other (Use Numbers 90-99)
11 BIOLOGICAL TREATMENT
11 01 Activated Sludge (Sequencing Batch Reactors) MGA
11 02 Rotating Biological Contactors MGA
11 03 Land Treatment/Farming (Solid Phase Biodegradation) 8,100 CY 24.80 200,852
11 04 In-Situ Biodegradation/Bioreclamation CY
11 05 Trickling Filters MGA
11 06 Biological Lagoons MGA
11 07 Composting CY
11 08 Sludge Stabilization - Aerobic CY
11 09 Sludge Stabilization - Anaerobic CY
11 10 Genetically Engineered Organisms (White Rot Fungus) CY
11 11 Slurry Biodegradation CY
11 12 Bioventing SF
11 13 Bioslurping SF
11 14 Biopile (Heap Pile Remediation) CY
11 50 Construction of Permanent Plant Facility EA
11 9x Other (Use Numbers 90-99)
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13 PHYSICAL TREATMENT
13 01 Filtration/Ultrafiltration MGA
13 02 Sedimentation MGA
13 03 Straining MGA
13 04 Coagulation/Flocculation/Precipitation MGA
13 05 Equalization MGA
13 06 Evaporation MGA
13 07 Air Stripping MGA
13 08 Steam Stripping MGA
13 09 Soil Washing (Surfactant/Solvent) CY
13 10 Soil Flushing (Surfactant/Solvent) CY
13 11 Solids Dewatering CY
13 12 Oil/Water Separation MGA
13 13 Dissolved Air Floatation MGA
13 14 Heavy Media Separation CY
13 15 Distillation MGA
13 16 Chelation MGA
13 17 Solvent Extraction MGA
13 18 Supercritical Extraction MGA
13 19 Carbon Adsorption - Gases CF
13 20 Carbon Adsorption - Liquids MGA
13 21 Membrane Separation - Reverse Osmosis MGA
13 22 Membrane Separation - Electrodialysis MGA
13 23 Soil Vapor Extraction CY
13 24 Shredding CY
13 25 Aeration CY
13 26 Advanced Electrical Reactor CY
13 27 Low Level Waste (LLW) Compaction CY
13 28 Agglomeration CY
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14 THERMAL TREATMENT
14 01 Incineration CY
14 02 Low Temperature Thermal Desorption CY
14 03 Supercritical Water Oxidation MGA
14 04 Molten Salt Destruction CY
14 05 Radio Frequency Heating CY
14 06 Solar Detoxification CY
14 07 High Temperature Thermal Desorption CY
14 50 Construction of Permanent Plant Facility EA
14 9x Other (Use Numbers 90-99)
15 STABILIZATION/FIXATION/ENCAPSULATION
15 01 Molten Glass CY
15 02 In-Situ Vitrification CY
15 03 In-Situ Pozzolan Process (Lime/Portland Cement) CY
15 04 Pozzolan Process (Lime/Portland Cement) CY
15 05 Asphalt-Based Encapsulation CY
15 06 Radioactive Waste Solidification (Grouting/Other) CY
15 07 Sludge Stabilization (Aggregate/Rock/Slag) CY
15 50 Construction of Permanent Plant Facility EA
15 9x Other (Use Numbers 90-99)
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19 DISPOSAL (COMMERCIAL)
19 20 Container Handling EA
19 21 Transportation to Storage/Disposal Facility TON
19 22 Disposal Fees and Taxes TON
19 23 Mixed Waste Storage Fees and Taxes TON
19 9x Other (Use Numbers 90-99)
20 SITE RESTORATION
20 01 Earthwork 8,100 CY 1.04 8,445
20 02 Permanent Markers EA
20 03 Permanent Features EA
20 04 Revegetation and Planting ACR
20 05 Removal of Barriers EA
20 9x Other (Use Numbers 90-99)
21 DEMOBILIZATION
21 01 Removal of Temporary Facilities 1 EA 1,651 1,651
21 02 Removal of Temporary Utilities 1 EA 929 929
21 03 Final Decontamination EA
21 04 Demobilization of Construction Equipment and Facilities 1 EA 2,116 2,116
21 05 Demobilization of Personnel EA
21 06 Submittals 1 EA 4,939 4,939
21 07 Construction Plant Takedown EA
21 9x Other (Use Numbers 90-99)
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03 SITEWORK
03 04 Roads/Parking/Curbs/Walks SY/YR
03 05 Fencing LF/YR
03 06 Electrical Distribution LF/YR
03 07 Telephone/Communication Distribution LF/YR
03 08 Water/Sewer/Gas Distribution LF/YR
03 09 Steam and Condensate Distribution LF/YR
03 10 Fuel Line Distribution LF/YR
03 11 Storm Drainage/Subdrainage LF/YR
03 12 Permanent Cover Structure Over Contaminated Area SF/YR
03 14 Fuel Storage Tanks (New) EA/YR
03 9X Other (Use Numbers 90-99)
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11 BIOLOGICAL TREATMENT
11 01 Activated Sludge (Seq Batch Reactors) MGA
11 02 Rotating Biological Contactors MGA
11 03 Land Treatment/Farming (Solid Phase Biodegradation) CY
11 04 In-Situ Biodegradation/Bioreclamation CY
11 05 Trickling Filters MGA
11 06 Biological Lagoons MGA
11 07 Composting (Soil Pile Bioremediation) CY
11 08 Sludge Stabilization - Aerobic CY
11 09 Sludge Stabilization - Anaerobic CY
11 10 Genetically Engineered Organisms (White Rot Fungus) CY
11 11 Slurry Biodegradation CY
11 12 Bioventing SF
11 13 Bioslurping SF
11 14 Biopile (Heap Pile Remediation) CY
11 50 Post Construction O&M of Permanent Plant Facility EA/YR
11 9x Other (Use Numbers 90-99)
12 CHEMICAL TREATMENT
12 01 Oxidation/Reduction (Catalytic) MGA
12 02 Solvent Extraction MGA
12 03 Chlorination MGA
12 04 Ozonation MGA
12 05 Ion Exchange MGA
12 06 Neutralization MGA
12 07 Chemical Hydrolysis MGA
12 08 Ultraviolet Photolysis (UV Oxidation) MGA
12 09 Dehalogenation (Catalytic Dechlorination) CY
12 10 Alkali Metal Dechlorination CY
12 11 Alkali Metal/Polyethylene Glycol (A/PEG) CY
12 12 Base-Catalyzed Decomposition Process CY
12 13 Electrolysis MGA
12 14 Vapor Recovery/Reuse (Internal Combustion Engine) CF
12 50 Post Construction O&M of Permanent Plant Facility EA/YR
12 9x Other (Use Numbers 90-99)
13 PHYSICAL TREATMENT
13 01 Filtration/Ultrafiltration MGA
13 02 Sedimentation MGA
13 03 Straining MGA
13 04 Coagulation/Flocculation/Precipitation MGA
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14 THERMAL TREATMENT
14 01 Incineration CY
14 02 Low Temperature Thermal Desorption CY
14 03 Supercritical Water Oxidation MGA
14 04 Molten Salt Destruction CY
14 05 Radio Frequency Heating CY
14 06 Solar Detoxification CY
14 07 High Temperature Thermal Desorption CY
14 50 Post Construction O&M of Permanent Plant Facility EA/YR
14 9x Other (Use Numbers 90-99)
15 STABILIZATION/FIXATION/ENCAPSULATION
15 01 Molten Glass CY
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APPENDIX A
GLOSSARY OF ENVIRONMENTAL RESTORATION TERMS
The following definitions were taken primarily from Superfund/Oil Program Implementation
Manual FY 2001, Appendix B: Response Actions (OSWER Publication 9200.3-14-1F-P).
Cleanup Goals This measure is used to indicate when cleanup goals have been achieved
Achieved for groundwater and surface water restoration, including monitored
natural attenuation. It is necessary to track achievement of cleanup goals
for these remedies because the goals will not have been achieved at the
time that remedial action (RA) has been completed. Cleanup Goals
Achieved has been accomplished once the final RA report has been
approved in writing.
Feasibility Study The primary objective of a feasibility study (FS) is to ensure that
appropriate remedial alternatives are developed and evaluated such that
an appropriate remedy may be selected. A FS involves the identification
and detailed evaluation of potential remedial alternatives. This process
begins with the formulation of viable alternatives, which involves
defining remediation objectives/cleanup goals, general response actions,
volumes or area of media to be addressed, and potentially applicable
technologies. Following a preliminary screening of alternatives, a
reasonable number of appropriate alternatives undergo a detailed analysis
using the nine evaluation criteria in the National Contingency Plan
(NCP). During a remedial investigation/feasibility study (RI/FS),
information is gathered to support an informed decision regarding the
remedy (if any) that is most appropriate for a given site or an operable
unit within a site. Interim or early actions to initiate risk reduction
activities can be undertaken throughout the RI/FS process.
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Operable Unit The NCP defines an operable unit (OU) as a “discrete action that
comprises an incremental step toward comprehensively addressing site
problems. This discrete portion of a remedial response manages
migration, or eliminates or mitigates a release, threat of a release, or
pathway of exposure” (NCP §300.5). Hence, an OU can be a certain
geographic portion of a site or can address an environmental medium at
the site (e.g., groundwater, soil). OUs may also be comprehensive but
temporary remedies (e.g., temporary caps across a site) that provide
interim protection of human health and the environment before final
remediation. The cleanup of a site can be divided into a number of OUs,
depending on the complexity of the problems associated with the site.
Operational and For many sites, the completion of RA also marks the completion of the
Functional operational and functional (O&F) period. O&F activities are conducted
after physical construction of the remedy is complete to ensure that it is
functioning properly and operating as designed. The NCP provides a
maximum timeframe of one year for performing O&F activities; however,
EPA may extend the one-year period, as appropriate. O&F activities may
be conducted for containment, groundwater restoration, and surface water
restoration remedies in order to ensure that the remedy functions properly
and operates as designed. Monitored natural attenuation remedies do not
go through an O&F determination. The O&F period is part of the RA and
occurs during the last year of the RA. Formal O&F determinations are
made primarily for Fund-financed projects, since O&F governs when
O&M or LTRA begins. O&F is considered complete on the date that the
designated Regional official approves the interim RA report (for sites
with groundwater or surface water restoration remedies) or final RA
report in writing.
Operation and Operation and maintenance (O&M) are the activities required to maintain
Maintenance the effectiveness or the integrity of the remedy. In the case of Fund-
financed measures, O&M activities are required to restore groundwater or
surface waters, and to continue the operation of such measures beyond the
LTRA period until the cleanup goals have been achieved. Except for
Fund-financed groundwater or surface water restoration actions covered
under NCP §300.435(f)(4), O&M measures are initiated after the remedy
has achieved the remediation objectives and/or cleanup goals listed in the
ROD, and the remedy has been determined to be O&F. O&M typically
starts on the date that the designated Regional official approves the final
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Record of Decision The record of decision (ROD) documents the remedy selection and the
RA plan for a site or an operable unit and serves the following three basic
functions: it certifies that the remedy selection process was carried out in
accordance with CERCLA and with the NCP; it describes the technical
parameters of the remedy, specifying the methods selected to protect
human health and the environment including treatment, engineering, and
institutional control components, as well as remediation
objectives/cleanup goals; and, it provides the public with a consolidated
summary of information about the site and the chosen remedy, including
the rationale behind the selection. While the ROD should provide a
comprehensive description of site conditions, the scope of the action, the
selected remedy, remediation objectives/cleanup goals, and the reason for
selecting the remedy, it is only one part of the administrative record file,
which contains the full details of site characterization, alternatives
evaluation, and remedy selection.
Remedial Action A remedial action (RA) is the implementation of the remedy selected in
the ROD. A RA is complete when the remediation objectives and/or
cleanup goals stated in the ROD have been achieved, and the remedy has
been determined to be O&F.
Remedial Design Remedial design (RD) is an engineering phase during which additional
technical information and data identified are incorporated into technical
drawings and specifications developed for the subsequent RA. These
specifications are based on the detailed description of the selected remedy
and on the remediation/cleanup criteria provided in the ROD.
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Revised Model The Revised Model CERCLA RD/RA Consent Decree, published July
CERCLA RD/RA 1995, superseded the 1991 interim model. The Model Consent Decree
Consent Decree serves as a template for binding settlement agreements that serve as
determinations of responsibility under CERCLA and the NCP.
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APPENDIX B
EXAMPLE REMEDIAL ACTION REPORT –
EX SITU SOIL REMEDIATION
NOTE:
The following example remedial action report is based on an actual Superfund site, but some
information has been altered to illustrate the concepts of the guide. In addition, names have been
changed to avoid confusion with the actual site.
Content and format of actual RA reports may vary from this example due to considerations such
as project lead and support roles, availability of information, and site-specific conditions. The
information presented in this example report (e.g., costs) should not necessarily be used as a
technical basis for completing remedial action at an actual site (e.g., as a source of cost
information).
B-1
F I N A L
R E M E D I A L A C T I O N R E P O R T
September 2000
TABLE OF CONTENTS
Abstract............................................................................................................................................iii
Inspections............................................................................................................ 6-1
Certifications ........................................................................................................ 6-1
Health and Safety................................................................................................. 6-1
Cost-Related......................................................................................................... 9-1
Performance-Related............................................................................................ 9-1
Other Lessons Learned......................................................................................... 9-2
Operable Unit 3
On-Site Thermal Treatment
Slippery Chemical Superfund Site, Grease, Texas
Site Name and Operable Unit: Slippery Chemical Superfund Site, Operable Unit 3
Location: Grease, Texas
Regulatory Oversight: U.S. Environmental Protection Agency Region VI
Texas Natural Resources Conservation Commission
Contractor Oversight: U.S. Army Corps of Engineers, Ft. Worth District
Remedial Action Contractor: H&S Consultants, Grease, TX
Waste Source: Two lined and two unlined waste management lagoons; disposal of drums of
chemical waste, chemical sludge and demolition debris on the ground surface
and in the shallow subsurface
Results: Sampling of treated soil indicated that the cleanup goals were met. Three percent of the soil
required re-treatment to achieve cleanup levels.
Two batches of fly ash required stabilization prior to on-site backfill.
Emissions data from the trial burn and full-scale operations indicated that all emissions
standards were met.
Costs: The total cost for this project was $134,622,950, with RA capital costs of $64,676,100, RA
operating costs of $69,890,000, and RA periodic costs of $56,850. The total technology-
specific cost was $109,190,500. Therefore, using a quantity of 194,520 cubic yards, the
technology-specific unit cost was calculated at $478 per cubic yard.
Description: The SCS Site included a chemical manufacturing facility that operated from 1951 to 1982,
producing chemical intermediates used in dye, cosmetic, textile, pharmaceutical, pesticide and
herbicide manufacturing. Two lined wastewater treatment lagoons, a dry unlined sludge lagoon,
and an unlined leachate lagoon were constructed at the site during the late 1950s, probably for
use as waste impoundments. Drums of chemical waste, chemical sludge, and demolition debris
were disposed on the ground surface and in the shallow subsurface at the site.
Site soil and chemical sludge were contaminated with VOCs, SVOCs including b-
naphthylamine, the herbicide Fenac, and metals. These compounds were detected throughout
the site regardless of sampling depth. A ROD was signed in September 1988, specifying on-site
incineration as the remedial technology for addressing soil contamination at the site.
Contaminated soil/sludge/sediment and groundwater were identified as Operable Unit (OU) 3.
Site work for construction of the incinerator commenced in April 1995. Incinerator shake down
and a clean burn were conducted in January 1996. The incinerator was then shut down until
September 1996 due to a lawsuit filed to stop the remediation project. System optimization and
preliminary testing were conducted in the Fall of 1996. The trial burn and risk burns were
conducted in January and February 1997. Following approval of the test results, the incinerator
was put into full-scale operation in March 1998. All site soil was excavated down to the water
table (about 15 feet below ground surface) and treated. The total area of the SCS Site is 9.6
acres. The incineration system consisted of a co-current, rotary kiln followed by a SCC. After
confirming that treated soil and fly ash met the cleanup criteria, the materials were backfilled at
the site. Treatment was completed in April 1999.
SITE DESCRIPTION
The Slippery Chemical Superfund (SCS) Site is located in Slick County, Texas, in the city of
Grease. The site was a chemical manufacturing facility that operated from 1951 to 1982. During
its operation, the Slippery Chemical Company produced chemical intermediates used in dye,
cosmetic, textile, pharmaceutical, pesticide and herbicide manufacturing. The total area of the
site is 9.6 acres and includes the previous location of the Slippery Chemical Company and the
adjacent Oily Chemical Company property. Figure 1 shows the general layout of the site.
The Slippery Chemical plant included several major buildings, two lined wastewater treatment
lagoons, a dry unlined sludge lagoon, and an unlined leachate lagoon. The lagoons were
constructed during the late 1950s, probably for use as waste impoundments. The leachate lagoon
was constructed in the lowest portion of the site, and is assumed to be the collection point for all
surface runoff at the site. Approximately 60 process tanks and reactors were located inside and
surrounding the process buildings. Approximately 10 additional larger tanks were staged outside
of the buildings for bulk storage of acids, bases, and fuel oils.
The area surrounding the site includes the Oily Chemical Company to the west, Rough Paper
Company to the southwest, Wet Creek to the south, the west branch of the Roaring River to the
north, and an apartment complex and shopping center to the east.
Groundwater at the SCS Site flows to the north, east and south. Local groundwater flows to the
south and southeast toward Wet Creek. Groundwater is typically encountered at 12 to 15 feet
bgs.
REGULATORY HISTORY
Slippery Chemical was cited many times by state and federal agencies for violating
environmental and health and safety regulations. In 1982, after Slippery Chemical failed to
respond to the U.S. Environmental Protection Agency’s (USEPA’s) request to clean up the site,
the USEPA initiated an emergency removal action during which drums, surface sludges, and
storage tanks were removed. During this removal action, USEPA removed 1,700 exposed drums
and drained and neutralized approximately 10 large tanks used for bulk storage of acids, bases,
and fuel oil. Access to the site was controlled using an 8-foot fence, and warning signs were
posted.
A Superfund remedial investigation and feasibility study (RI/FS) was initiated in 1983. The first
two phases of the RI/FS led to interim remedial actions, specifically: Operable Unit (OU) -1 –
the remediation of a leachate stream that was discharging to an off-site area; and OU-2 – the
removal of the two lined wastewater treatment lagoons and the on-site structures. Phase I was
completed in 1987. Phase II was completed in 1988.
The Phase III RI/FS was initiated in January 1987. During Phase III field investigations,
samples of soil, groundwater, surface water and sediment were collected. Forty-one test pits
were excavated to characterize contaminated soil and sludge at the site. Each test pit was
excavated to the water table or to a depth of 15 feet below ground surface (bgs), whichever was
more shallow.
Chemical sludge and contaminated soil were observed in all of the open area on the SCS Site.
The soil and sludge were contaminated with volatile organic compounds (VOCs), semivolatile
organic compounds (SVOCs), Fenac, β-naphthylamine, and metals. Organic contaminants (i.e.,
Fenac) were consistently observed in samples collected throughout the site. Field screening
revealed that the vadose zone at the site was contaminated to varying concentrations with
chlorinated solvents and benzene, toluene, ethylbenzene, and xylenes (BTEX). Substituted
chlorinated phenols and alkyl phenols were also present. These compounds occurred throughout
the site regardless of sampling depth; therefore, no one particular area of the Slippery Chemical
property or the adjacent Oily Chemical property could have been considered the most likely
source of contamination. Metals were also detected in soil samples; however, it is not clear
whether activities at the Slippery Chemical plant were the source of metals contamination.
FIGURE 1
SLIPPERY CHEMICAL SUPERFUND SITE
REMEDY SELECTION
Based upon CERCLA requirements and a detailed analysis of the alternatives, USEPA and the
Texas Natural Resources Conservation Commission (TNRCC) recommended incineration of all
soil and buried waste within the SCS Site boundary down to the groundwater table. The selected
remedy was deemed:
• To be protective of human health and the environment,
• To meet all applicable or relevant and appropriate federal and state requirements
(ARARs), and
• To be cost-effective.
This remedy satisfies the statutory preference for remedies that employ treatment that reduces
toxicity, mobility or volume as a principal element and utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable.
CLEANUP GOALS/STANDARDS
The following table lists the remediation objectives for soil treated in the incinerator operated at
the SCS Site. These objectives were established in the September 1988 ROD to meet TNRCC
requirements.
Treated Soil Objectives
Cleanup Level
Contaminant
(µg/kg)
Volatile Organics
Benzene 100
Chlorobenzene 10,000
1,2-Dichloroethene 7,000
Ethylbenzene 70,000
Tetrachloroethane 2,000
Toluene 100,000
Trichloroethene 2,000
Cleanup Level
Contaminant
(µg/kg)
Total Xylenes 5,000
Semivolatile Organics
Benzo(a)anthracene 6,000
Benzo(b)fluoranthene 6,000
Benzo(k)fluoranthene 60,000
1,2-Dichlorobenzene 7,000
1,4-Dichlorobenzene 8,000
Fluoranthene 400,000
Naphthalene 8,000
Pentachlorophenol 40,000
Phenanthrene 80,000
Phenol 400,000
Pyrene 300,000
1,2,4-Trichlorobenzene 20,000
β-Naphthylamine 55
Chlorinated Herbicide
Fenac 1,000
A mobile, on-site incineration system was used to decontaminate soil, sludge, and sediment at
the SCS Site. The incineration system consisted of a rotary kiln, a secondary combustion
chamber (SCC), and an air pollution control system (APCS). Rotary kiln incinerators are able to
process a wide variety of waste feed compositions and handle oversized wastes with minimal
processing pre-treatment. The rotary kiln portion of the system is used to volatilize and destroy
the majority of the organic contaminants. The remaining organic contaminants exit the kiln with
the hot gases into the SCC where additional destruction occurs. The APCS is used to provide
particulate matter and acid gas control. Figure 2 shows a schematic of the on-site incineration
system.
Site characteristics, operating limits, and operating parameters of the incineration system are
presented in Appendix A. The system was operated using the following steps:
• Contaminated soil was excavated down to the water table over the entire site and was dried
by adding cement kiln dust or lime. Soil was then transported to the debris separation
building. Material greater than 4 inches in diameter was removed from the soil by rotating
barrel screens and underwent manual segregation into organic and inorganic debris. Organic
debris (e.g., wood) was shredded. Inorganic debris was either landfilled (e.g., plastic),
recycled (e.g., steel) or cleaned for backfill (e.g., rocks). Material less than 4 inches in
diameter was stockpiled in the feed preparation building after ferrous material was
electromagnetically removed.
• Soil was blended with shredded brush, roots, trees, and other combustible material. The soil
was fed onto a variable-speed, apron conveyor, a weigh belt conveyor, and into the kiln feed
hopper. Feed material was delivered from the hopper to the kiln via dual, water-cooled, feed
screws. The feed material was sampled and analyzed for metals, SVOCs (including β-
naphthylamine), VOCs, Fenac, and physical/chemical parameters (e.g., BTU, moisture, ash,
and chlorine).
• The rotary kiln was 60 feet long and had an inside diameter of 11 feet. The kiln was operated
concurrently with the waste feed located at the same end as the oxygen-natural gas burners.
Contaminated soil traveled through the kiln via gravity. The kiln was operated at a minimum
exit gas temperature of 1599°F.
• The kiln discharge chamber was sized to reduce the flue gas velocity and remove large
particulate matter in the exit gas stream. The hot gas cyclone subsequently removed
additional particulate matter in the flue gas prior to entering the SCC. The SCC was operated
at a minimum temperature of 1801°F and a minimum gas retention time of 2 seconds.
• Exhaust gases from the SCC were cooled to 400°F using air-atomized, water spray nozzles in
an evaporative cooler. The cooled flue gases then passed through a baghouse for removal of
particulate matter. The baghouse was designed with a 3-to-1 air-to-cloth ratio.
• The baghouse gas discharged to an induced draft (ID) fan, which drew gases through the
entire system and discharged them through the wet scrubber system to the discharge stack.
The fan produced negative pressure throughout the incineration system to eliminate fugitive
emissions.
• Exhaust gases from the baghouse were cooled from approximately 350°F to 185°F with
water sprays in the Venturi quench unit. A mildly caustic scrubber water solution neutralized
dissolved acid gases in one of two countercurrent, packed-bed absorbers, which were
operated in parallel. The pH of the scrubber water was maintained between 6.5 and 9 by
addition of a sodium hydroxide solution. The cleaned gas passed through a high-efficiency,
multi-pass mist eliminator for removal of entrained water droplets.
• Cleaned flue gas was exhausted through a 150-foot tall stack equipped with continuous
emission monitors (CEMs) that analyzed the gas for oxygen (O 2 ), carbon monoxide (CO),
carbon dioxide (CO2 ), total hydrocarbons (THC), and nitrogen oxides (NOx ).
• Bottom ash and fly ash were segregated prior to disposal. Bottom ash consisted of treated
soil from the kiln and ash collected by the cyclone and SCC. Fly ash consisted of ash from
the evaporative cooler and baghouse. Each ash stream was cooled and wetted by spraying
with excess scrubber system water, after which it was conveyed to the ash storage area. A
10,000 cubic feet per minute (cfm) scrubber and Lamella clarifier system captured steam
issuing from the wet ash drag conveyor to prevent off-site migration of particulate matter.
• Fly was were tested for TCLP metals as each storage bin was filled. Each day’s production of
bottom ash was separated for testing of TCLP metals, Fenac, SVOCs (including
b-naphthylamine), and VOCs. Ash failing the cleanup criteria was retreated. Ash meeting
the cleanup criteria was backfilled on-site. Ash with TCLP concentrations greater than 25
times any of the drinking water standards was stabilized prior to backfill.
In addition to the incineration system, a 100-gallon per minute (gpm) wastewater treatment plant
(WWTP) was installed and operated at the site to remove metals and organic compounds from
various water streams generated during the project. Treated wastewater was discharged to Wet
Creek. Wastewater treated at the WWTP included: incineration system pad cleaning water; ash
handling pad cleaning water; wash water from equipment and personnel decontamination
activities; water collected from the leachate lagoon; water collected from the soil excavation
cavities; and potentially-contaminated storm water. The WWTP included the following
treatment technologies:
• Primary settling;
• Wastewater equalization tanks;
• Metals removal through chemical addition, flocculation, and clarification;
• Neutralization;
• Sand filtration for suspended solids removal;
• Air stripping with activated carbon columns for treating organics transferred to the air
stream;
• Bag filtration for removal of small-diameter suspended solids;
• Activated carbon adsorption for removal of residual organics; and
• Sludge dewatering with a filter press.
The following table includes the dates of the most significant events in the operation of the
incinerator system and WWTP at the SCS site.
Date Activity
September 29, 1988 Phase III ROD signed by the U.S. EPA and the Army
Spring 1989 Phase II remediation completed
October 1990 – August 1991 Incineration feasibility study conducted
September 30, 1993 Contract awarded
November 15, 1993 Notice to proceed issued
November 14, 1994 Mobilization to the site
May 13, 1995 WWTP put into operation
January 3, 1996 Construction of incinerator and supporting facilities complete
January 13, 1996 Shakedown and clean burn complete
January 14, 1996 – August 14, 1996 Stop work in effect due to lawsuit
September 19, 1996 Public meeting held on the revised trial burn risk assessment protocol
January 20 – 22, 1997 Risk Burn No. 1 conducted
January 25 – February 4, 1997 Trial Burn conducted
February 7 – 9, 1997 Risk Burn No. 2 conducted
February 10, 1997 – March 4, 1998 Project shutdown for risk and trial burn data review
February 10, 1998 Public meeting held on the risk assessment
March 9, 1998 Full-scale operations started
April 22, 1999 Soil incineration completed
November 23, 1999 Project completion
PERFORMANCE STANDARDS
The following table provides the performance objectives that were established for the SCS Site
incinerator in the September 1988 ROD:
Incinerator Performance Objectives
Parameter Performance Criteria
Principal Organic Hazardous Constituent
≥ 99.99%
(POHC) destruction removal efficiency (DRE)
Particulate Matter (PM) Emissions ≤0.01 grains/dry standard cubic foot (gr/dscf) @ 7% O2
Hydrochloric Acid (HCl) Emissions ≤4 lb/hr or 99% reduction
Total Dioxins and Furans Emissions ≤30 nanograms/dry standard cubic meter (ng/dscm) @ 7% O2
≤300 parts per million – volume (ppmv) @ 7% O2 (daily
NO x Emissions
average)
CO Emissions ≤100 ppmv @ 7% O2 (hourly rolling average)
Metal Emissions
As <0.11 g/sec
Be <0.20 g/sec
Cd <0.27 g/sec
Cr+6 <0.04 g/sec
Cr <0.12 g/sec
Pb <1,384 g/sec
Fly ash and bottom ash were analyzed for metals using the toxicity characteristic leaching
procedure (TCLP). The results were compared to the Texas drinking water standards listed in
the table below. Ash meeting these standards could be backfilled on-site without restriction.
Ash failing these standards, but with TCLP concentrations less than 25 times the drinking water
standards, could be returned to the site as fill material but could not be placed below 553 feet
mean sea level (8 feet above the average water table). As specified in the 1988 ROD, treated soil
with TCLP concentrations greater than 25 times the drinking water standard required
stabilization prior to backfill.
Ash TCLP Concentration Objectives
Drinking Water Standard 25 x Standard
Metal
(mg/L) (mg/L)
Arsenic 0.05 1.25
Barium 1.0 25
Cadmium 0.01 0.25
Chromium 0.05 1.25
Lead 0.05 1.25
Mercury 0.002 0.05
Selenium 0.01 0.25
Silver 0.05 1.25
As discussed previously, perimeter air monitoring was routinely performed at the site. Three
VOCs were selected as key indicator compounds to be monitored by the HNu if the average
NMOC reading exceeded 1 parts per million (ppm). Perimeter action levels were set at 10% of
the OSHA permissible exposure limits (PELs) for each of the three selected contaminants. The
perimeter action levels were:
• 9.146 ppm for toluene
• 7.777 ppm for chlorobenzene
• 2.511 ppm for tetrachloroethene
The table below provides the discharge limitations for the WWTP at the SCS Site as specified in
the September 1988 ROD. Weekly samples of the WWTP effluent were required whenever the
WWTP was in operation.
Wastewater Discharge Limitations
Parameter Monthly Average (mg/L) Daily Maximum (mg/L)
β-Naphthylamine 0.012 0.024
Fenac 0.100 0.200
Toluene 0.010 0.020
Chlorobenzene 0.010 0.020
1,2-Dichlorobenzene 0.010 0.020
1,4-Dichlorobenzene 0.010 0.020
1,2-Dichloroethane 0.010 0.020
Trichloroethene 0.005 0.010
Total Arsenic 0.100 0.200
Total Barium 2.000 4.000
Total Cadmium 0.060 0.120
Total Nickel 0.200 0.400
Total Chromium 0.150 0.300
Total Lead 1.000 2.000
pH 6 to 9 standard units 6 to 9 standard units
An incineration feasibility study was conducted between October 1990 and August 1991. All test
runs met the cleanup criteria established for the SCS Site. The pilot-scale rotary kiln incinerator
achieved 99.99% destruction removal efficiency (DRE) of Principal Organic Hazardous
Constituents (POHCs), which were spiked into the soil. The leachable metal concentrations in
the ash from the pilot study were either non-detect or were below TCLP limits for characteristic
hazardous waste, so no fixation or stabilization was required prior to backfilling incinerator ash
on site. Some fly ash had TCLP metal concentrations above the drinking water standards.
A risk assessment concluded that full-scale operation of the incinerator at the SCS Site would not
pose a threat to public health. All of the estimated risks were within the range that is considered
acceptable for cleanup activities performed under the Superfund hazardous waste program.
The results from the trial burn demonstrated that the incinerator met the RCRA performance
standards of 40 CFR 264 and other regulatory and contractual requirements while burning site
soils spiked with POHCs and metals.
During full-scale operations, all treated soil batches met the cleanup criteria for Fenac after the
first pass; eight treated soil batches did not initially meet the cleanup goal for β-naphthylamine.
Of the total mass of soil treated, less than 3% required additional thermal treatment after the first
pass. Soil not meeting the cleanup criteria was sent back to the feed preparation building where it
was blended with the other soil, and then conveyed to the incinerator.
TCLP metals results for 2 batches of fly ash were greater than 25 times the drinking water
standard (once during a metals spiking test and the other time during full-scale operation). The
fly ash from these batches was stabilized prior to backfill.
Stack testing, perimeter air monitoring and ambient air monitoring performed in the community
near the project site met all specified objectives.
Data Quality
All trial burn testing was conducted in accordance with the source test sampling and analysis
protocols specified in the quality assurance plan for the trial burn. All data gathered during the
trial burn were found to be of acceptable quality to demonstrate that the incinerator met the
performance standards. The quality assurance/quality control (QA/QC) results were compared to
the data quality objectives specified in the Project Quality Assurance Plan contained in the Trial
Burn Plan. This comparison showed that greater than 90% of the accuracy, precision, and
method performance objectives were met.
The perimeter air sampling and off-site ambient air sampling were conducted in accordance with
the SCS Site Perimeter Air Sampling Plan, including the calibration, sampling and analytical
procedures. Other sampling and analysis activities during full-scale operations (e.g., soil and ash
tests) were conducted according to the protocols in the Chemical Quality Management Sampling
Plan.
INSPECTIONS
The project utilized the U.S. Army Corps of Engineers (USACE) Three Phase Inspection
Program which included the Preparatory Inspection – prior to the start of work, Initial Inspection
– as soon as representative portion of the work was complete, and Follow Up Inspection – daily
until the work is complete. Prior to site mobilization a list of the Definable Features of Work
was generated. The Definable Features of Work list was a guideline for initiating the Three
Phase Inspection Program on individual work tasks. The Definable Features of Work list was
updated monthly and forwarded to the USACE for information only.
CERTIFICATIONS
As part of the submittal process data, drawings, instructions, schedules, statements, reports,
certificates, samples, and records were transmitted to the USACE for either review and action or
for information only. Each individual submittal was given a unique transmittal number.
Submittals were forwarded to the USACE on Government Form SF4025 and to other reviewers
such as the USACE Architectural Engineer, USEPA, and TNRCC on Government Form
SF4026. Submittals were tracked in the Complete Submittal Register that was updated on a
monthly basis. A copy of all submittals was kept on file at the project site.
The Quality Control Department was responsible for generating a Daily Contractors Quality
Control Report (DCQCR). Starting with mobilization, through the contract completion date, a
DCQCR was generated and issued for each contract day. The report included the following
information: date, report number corresponding to the number of contract days, general weather
information, work performed by H&S Consultants, attachment reports, work performed by
subcontractors, inspections performed, testing performed, verbal instructions received from
Government personnel, verbal instructions received from Government personnel on construction
deficiencies, safety violations observed, remarks, and worker hours and equipment use. Two
copies of the report (one with the original H&S Consultants QC signature) were forwarded to the
USACE QA Field Office.
Data Quality Objectives (DQOs) were established prior to the start of the project and were
updated throughout the project. Individual programs such as the Perimeter Air Sampling
Program and the Chemical Quality Management/Sampling Program defined DQOs. Objectives
included precision, accuracy, representativeness, comparability, and completeness. In 1997, a
process to consolidate the DQOs was performed. The result was a document that defined DQOs
for all chemical data generated on the project. The DQOs were summarized using a seven step
process outlined in EPA’s “Guidance for the Data Quality Objectives Process” (1994).
removed and the Permea-Tec pad was retrieved. The analysis of the pad was activated with tap
water. A positive indication of breakthrough of 2-naphthlylamine (2-NA) through the personal
protective equipment (PPE) would result in a predominately red color change of the pad. During
the course of the project, no positive results were found with the 780 separate pad tests collected.
A Surface Swype pad was also used to determine surface contamination of aromatic amine
compounds. A monthly wipe sampling program using these pads was implemented to confirm
that support areas were not becoming contaminated during site activities. During the course of
the project, no positive results were found from the 627 Surface Swype samples collected in
trailers and support facilities.
Surface Swype pads were also used to confirm that equipment, which had entered the exclusion
zone, was decontaminated of aromatic amines prior to release from the exclusion zone. During
the equipment decontamination program, only three of the 2,864 pads showed the characteristic
color change indicating the presence of aromatic amines. Of the three positive samples, one was
found to be a false positive through additional testing and research, and the other two were
equipment which were re-cleaned using a decontamination solution formulated to remove
aromatic amine compounds. After re-cleaning with the decontamination solution, the equipment
Surface Swype was repeated and no color change was indicated.
Another type of pad utilized was a Skin Swype pad. The Skin Swype pad was used to
determine that no inadvertent skin contamination with 2-NA had occurred. When a worker
exited the exclusion zone, the worker’s skin was wiped with a Skin Swype pad prior to
washing, the pad was placed in a small cup containing developing solution, the developing
solution was allowed to wick through the pad. If a strip near the top of the pad changed color, it
was considered to be positive for an aromatic amine. None of the 770 Skin Swype pads
showed a positive result.
The Risk Assessment Report and associated risk analysis were complete in January 1998, at
which time the USACE notified H&S Consultants to prepare for the operation phase. In late
February 1998, a clean burn demonstration was performed to ensure that the thermal destruction
facility (TDF) was mechanically capable of performing during the Operations Phase. On March
4th , with the clean burn successfully complete, and with concurrence from USEPA and USACE,
the Operation Phase commenced.
With-in several days of the Operation Phase concerns were raised over whether dust was
entrained in the steam generated from the thermal process and whether, if entrained, it was
leaving the site boundary. Several members of the project team including USEPA, TNRCC,
USACE, and H&S Consultants inspected the process and determined that there was no dust
leaving the site boundary, but that modifications could be made to help alleviate the dust
concern. The first effort was to install a hood equipped with mist spray nozzles on the ash-
receiving bin. The use of mist nozzles in the ash-receiving bin knocked out dust that was
entrained in the steam. The second effort was to partially enclose the fly ash building. This
allowed additional residence time in the building for steam to settle. The first two efforts were
implemented immediately. The third effort included locating a steam scrubber that could be
installed as final precaution to scrub the steam of any entrained dust. By the end of April 1998, a
steam scrubber was mobilized to the site, modified for the site-specific application, and installed
in the ash-receiving bin.
In early April 1998, after preliminary kiln refractory brick repairs failed, a decision was made to
re-line the kiln with a castable refractory. Installation of the new refractory took place during the
last three weeks of April and the first week of May. The Operation Phase resumed during the
first week of May 1998.
As per the TNRCC Air Equivalency Document and the Trial Burn Plan, Operation Phase Stack
Testing was performed. Once per month for the first three months of operations stack testing
was performed for dioxin and Furan analysis. Once per quarter for the duration of the project
stack testing was performed for particulate and metals analysis.
During the Operation Phase several statistical operating goals were established. A “utilization
percentage” was calculated to illustrate performance of the TDF as compared to a benchmark
operating rate of 47 tons per hour. A “utilization average” was calculated to summarize the
performance of the TDF. An “availability percentage” was calculated to illustrate the time the
TDF was physically available to operate. An “availability average daily tons” was calculated to
summarize the TDF production during available operating hours. An “availability TPH” was
calculated to summarize the TDF production rate during available operating hours. The
percentage of ash requiring additional thermal treatment was calculated and compared to a
project goal. The following table summarizes the Operation Phase performance versus
established goals.
The Operation Phase was complete on April 22nd, 1999 when the final soil to be incinerated was
fed to the TDF. Final bottom ash analytical results were received on April 23, at which time the
TDF burners were shut off and the Demobilization Phase started.
PROCUREMENT PROCESS
USACE awarded the contract to perform the soil remediation at OU-3 to Remedial Services
International on September 30, 1993, with remediation activities performed by Remedial
Services International. Remedial Services International was subsequently acquired by H&S
Consultants, which was later acquired by ABC Corporation. The contract was awarded using a
firm fixed-price cost structure. On September 23, 1996, the contract was converted to a cost plus
fixed fee contract.
Total Costs Incurred, Years 0-5 (Actual $$) $123,995,000 $134,622,950 +9%
1
Costs are based on the respective years that the costs were incurred. The ROD estimates were adjusted from
1988 dollars to the appropriate year’s dollar basis using ENR building cost index factors.
2
Differences between the actual RA operating costs and the adjusted ROD estimate are largely attributable to the
waiting phase associated with a project shutdown pending the outcome of a lawsuit filed by a citizens group
($14,268,000). Costs were saved during site restoration by using clean, excavated rock as backfill and by
eliminating the need for vegetative cover (see Section 9 for additional information).
.
COST-RELATED
Costs on similar future projects could be reduced by taking preliminary steps to minimize the
chances for shutdowns caused by legal actions. Millions of dollars in costs were incurred while
the incinerator was shutdown pending the outcome of a lawsuit brought by an opposition group.
A significant cost savings was realized due to a change incorporated into the contract
specifications allowing for the cleaning and backfilling of excavated rock. The reuse of rock
eliminated costs associated with importing stone from an outside source.
The initial remedial design included laying cover material capable of supporting vegetation over
treated soil depleted of organic material. Two studies demonstrated that the addition of compost
and fertilizer to the treated soil would be sufficient to allow sustained growth of a vegetative
cover. The amended design resulted in elimination of costs associated with importing fill
materials and topsoil.
PERFORMANCE-RELATED
Project managers of future similar projects should perform a thorough review of the proposed
equipment layout plans. Equipment locations are particularly important to consider with material
handling systems. Bins and buildings to store and/or stabilize ash should be located in close
proximity to ash sources to minimize the amount of high wear/severe duty equipment (e.g.,
screw augers and drag conveyors) necessary.
The feed preparation area should be as large as physically possible to allow sufficient room for
any additional equipment, which may become necessary for trash separation, drum handling
operations, pre-drying and similar operations.
Dust suppression is an important aspect of managing soil and ash on-site. When possible, soil
and ash management operations should be conducted within an enclosed structure such as a
building under slight negative pressure or using enclosed equipment.
During the preliminary site investigation and incinerator conceptual design, the moisture content
of site soil should be characterized. Worst case moisture content should be included in the RFP
so the contractor design engineers can size the kiln and burners accordingly. Soil moisture will
greatly affect the allowable throughput rate and the ability of the system to remove contaminants
from the soil. A heat transfer specialist should do a thorough review of the assumptions and
calculations used to size the incineration equipment.
The temperature of the treated soil exiting the kiln is a primary indicator of whether the soil will
meet the treatment requirements. The contractor should measure the kiln exit soil temperatures to
obtain a real-time indication of the kiln efficiency, rather than waiting 72 hours for the analytical
results of the treated soil samples.
Due to the severe environments under which they operate, the ash conveyance system may be
particularly susceptible to mechanical failure. A thorough review of the contractor’s proposed
system should be performed. The review should draw upon the vast quantity of material handling
information and experience available within the combustion industry.
Whenever cost and space allow, redundant systems should be implemented in order to keep the
incinerator operational. The incinerator cannot physically operate without certain systems online
(e.g., drag conveyors or pumps) and the incinerator must not be allowed to operate if certain
equipment is not operational per permit requirements (e.g., Continuous Emission Monitors
[CEMs]). Incinerator downtime can be costly because site personnel must be paid and equipment
rental fees are incurred whether the incinerator is operating or not.
Performing a clean burn prior to feeding hazardous waste to the incinerator can have the
following benefits:
• Serves as a mechanical shakedown of the system;
• Provides an opportunity to do performance testing on the CEMs; and
• Provides an opportunity to debug any programming or control systems without the risk of
any sort of a release or labor-intensive decontamination prior to correcting any problems.
During the incinerator optimization stage and the trial burn tests, the incinerator should be
operated under a wide range of operating conditions (e.g., varied feed rate, kiln rotation speed,
and combustion temperature) to ensure that the permit limits allow the desired level of operating
flexibility.
Ninety to one hundred twenty days was allowed for state review of permit equivalency
documents, including the Trial Burn Plan.
The RFP specifications delineated which activities were construction-related and which activities
were service-related. Difficulties can arise when personnel working side-by-side on the same
equipment are paid different wages.
Staffing requirements for an incineration project are greater than the typical USACE construction
project. Required staff included an on-site project chemist, thermal incineration experts, office
engineers, project engineers, quality assurance staff, and an on-site authorized contracting
officer’s representative. In addition, the contracting officer’s representative was given more
authority to process changes so the changes could be incorporated in a timely manner.
A Construction Management Plan was developed that included the roles and responsibilities of
the participating organizations and individuals.
The project manager prepared for the worst weather possible at the site. Freezing pipes, power
outages, late deliveries, inability to move equipment and excavations filling with water are
examples of weather-related problems. These occurrences, if not anticipated, could have delayed
the project and been a source of additional costs.
Local emergency responders were involved with emergency response planning and drills. They
were provided with the required training and the necessary response equipment if they were not
already prepared for incinerator-related emergencies.
All pertinent federal and state regulations and guidance documents identified in the project
specifications were available on-site for reference.
Due to the large volume of information gathered and shared with outside agencies, a computer-
based information and issue tracking system was used for this project. The system contained
complete descriptions of the issues, responsible individuals, inception dates, and anticipated
resolution dates. The system was reviewed on a regular basis to track the status of outstanding
issues.
Before initiating site work, a cost-benefit analysis was performed to determine if a backup to the
primary laboratory should be selected. Selection of a backup laboratory at the beginning of the
project eliminated time spent for laboratory validation and approval, which could have impacted
the project in progress if a laboratory had not been selected prior to start of work.
An active safety incentive program increased worker safety awareness and reduced injuries and
accidents.
RA Oversight Contractor:
Analytical Laboratory:
Project Management:
Email: [email protected]
Email: [email protected]
1. USEPA Region 3, Record of Decision – Slippery Chemical Superfund Site, Operable Unit 3,
August 1988.
2. USEPA’s Slippery Chemical Home Page,
http://www.epa.gov/reg3hwmd/super/slippery/pad.htm.
3. Fact Sheet, “Slippery Chemical Superfund Site On-Site Soil Incineration”, October 1, 1999.
4. Slippery Project Summary Milestones
5. USACE, Specifications (for Fixed-Price Services Contract), On-Site Soil Incineration,
Slippery Chemical Superfund Site, April 1993.
6. James Q. Public, Consulting Engineers, Inc., Incineration Treatability Study Report, Slippery
Chemical Superfund Site, August 1991.
7. Texarkana Research Institute, Trial Burn Plan for the Slippery Chemical Superfund Site,
September 20, 1996.
8. H&S Consultants, Wastewater Management Plan, Revision No. 3, for On-Site Soil
Incineration, Slippery Chemical Superfund Site, August 1997.
9. Sandra Upps of TNRCC, Air Equivalency Permit, February 6, 1998.
10. Eastern, Slippery Chemical Site, Incinerator Full-Scale Operation, Integrated Risk
Assessment, November 1997.
11. H&S Consultants, Quantity Tracking Logs and Volume Calculation Information, October 28,
1999.
12. H&S Consultants, Test Report for Trial Burns No. 1 and No. 2 on the Slippery Chemical
Superfund Site’s Mobile On-Site Hazardous Waste Incinerator, September 12, 1997.
13. Perry’s Chemical Engineers’ Handbook, Sixth Edition, McGraw Hill Book Company, New
York, 1984.
14. http://pmep.cce.cornell.edu/profiles/herb-growthreg/fatty-alcohol-monuron/fenac/herb-prof-
fenac.html
15. Analytical results from full-scale incineration operations (not bound in a report).
16. Chad R. Rogers and Michael B. Provo, USACE, Slippery Chemical Superfund Onsite
Incineration Project Lessons Learned.
17. USACE, Internal Project Description, Slippery Chemical Superfund Site.
18. MTV Laboratories, Hydrometer Analysis Reports, Slippery Chemical Superfund Site,
November 15, 1996 through April 1, 1999.
19. Stan Bopp, USACE, Final Cost Report, Slippery Chemical Superfund Site, April 21, 2000.
The table below lists selected characteristics for the soil at the SCS Site. Except where noted,
data provided are average values for pre-treatment soil samples collected during the 1997 trial
burns.
Site Characteristics
Characteristic Value Measurement Procedure
SM
Soil Classification1 USCS
(silty sands and silt-sand mixtures)
Clay Content1 3.8 to 8.8% ASTM D422
Moisture Content 16% 2 ASTM D-3173
Total Petroleum Hydrocarbon
181 to 6,569 mg/kg EPA 418.1
(TPH) Content
Bulk Density 99.8 to 109.6 lbs/ft 3 ASTM D 4253 and 4254
BTU Value 274 BTU/lb ASTM D 2015
Halogen Content 260 mg/kg Chlorine ASTM E 442 or D 808/D 4327
Metal Content
Arsenic 7.65 mg/kg ICP
Beryllium 0.67 mg/kg ICP
Cadmium 0.16 mg/kg ICP, GFAA
Chromium 24.5 mg/kg ICP
Lead 41.6 mg/kg ICP
1
These data correspond to treated soil samples. Data was not available for untreated soil.
2
During full-scale operations, the soil moisture content ranged from 10.0 to 25.5% and averaged 17.6%.
The following table lists the operating limits for the incineration system that were approved by
the USEPA and TNRCC prior to full-scale operation of the system. These operating limits were
developed based on the results of the trial burns and risk burns.
Operating Limits
Parameter Value
Waste Feed Rate, Maximum Allowable 47.3 tons/hr rolling average
0 inches water column (wc) instantaneous
Kiln Hood Pressure, Maximum Allowable
-0.1 inches wc for 10 seconds or more
1599ºF hourly average
Kiln Exit Temperature, Minimum Allowable
1000ºF instantaneous
Kiln Exit Temperature, Maximum Allowable 2200ºF
Kiln Rotation, Minimum Allowable 0.4 revolutions per minute (rpm)
SCC Temperature, Minimum Allowable 1801ºF
SCC Temperature, Maximum Allowable 2600ºF
SCC Residence Time, Minimum Allowable 2 seconds
Baghouse Inlet Temperature, Maximum Allowable 500ºF
Baghouse Air-to-Cloth ratio, Maximum Allowable 3.6 to 1
Bag House Pressure Drop, Minimum Allowable 1.0 inches wc for more than 5 minutes
Parameter Value
Bag House Pressure Drop, Maximum Allowable 6 inches wc for more than 5 minutes
Scrubber Inlet Temperature, Maximum Allowable 250ºF
Scrubber Liquid pH, Minimum Allowable 6.5
Scrubber Liquid Feed Rate, Minimum Allowable 450 gallons per minute (gpm) hourly average
200 parts per million by volume (ppmv) instantaneous
CO Emissions, Maximum Allowable
100 ppmv hourly rolling average
NO x Emissions, Maximum Allowable 300 ppmv daily average
Stack Gas Velocity, Maximum Allowable 46.2 ft/sec hourly average
The table below lists values for selected parameters observed during incineration operations at
OU-3. Observed values are compared to design values for each parameter. The parameters were
selected for this report based on USACE guidance. Data provided are based on average
conditions during full-scale operation of the incinerator system.
Operating Parameters
System Parameter Design Value Actual Value
Residence Time (Air in SCC) >2 seconds 1.7 to 4.6 seconds
Residence Time (Soil in Kiln) 30 minutes 24.6 to 44.3 minutes
The following tables present a breakdown of actual costs incurred for the project and calculation
of technology-specific unit cost for incineration. HCAS data entry sheets are also attached to
this appendix.
ACTUAL COSTS (1 of 2)
Site: Slippery Chemical Site Description: The selected treatment consisted of a mobile rotary kiln incinerator used to treat excavated
Location: Grease, Texas sludge, soil and sediments onsite. In addition, a waste water treatment plant (WWTP) used
Phase: Final RA Report (OU-3) granular activated carbon (GAC) to treat all water produced from the excavation and
Date: June 7, 1999 incineration processes.
RA CAPITAL COSTS:
UNIT TOTAL
DESCRIPTION QTY UNIT COST (1994 $$) NOTES
331XX HTRW Remedial Action
.01 Mobilization and Preparatory Work
.02 Mob of Personnel 1 EA $3,171,000 $3,171,000
.03 Submittals/ Implementation Plans 1 EA $2,683,000 $2,683,000
.04 Setup/Construct Temporary Facilities 1 EA $2,665,000 $2,665,000 Fence, roads/parking, signs, trailers
.05 Construct Temporary Utilities 1 EA $122,000 $122,000
SUBTOTAL $8,641,000
.03 Sitework
.08 Water/Sewer Relocation 2,425 LF $378 $916,000
.06 Groundwater Collection
.05 Earthwork - Sheet Piling 87,204 SF $55 $4,809,000
.08 Solids Collection and Containment
.01 Contaminated Soil Excavation 194,520 CY $15 $2,856,000
.10 Drums/Tanks/Struct/Misc Removal
.01 Drum Handling and Removal 185 EA $1,157 $214,000
.07 Debris Removal 8 AC $39,375 $315,000
SUBTOTAL $529,000
.13 Physical Treatment
.20 Carbon Adsorption - Liquids WWTP
.05 Mobilize/Setup/Relocate Plant 1 EA $811,000 $811,000
.07 Demobilize Plant 1 EA $71,000 $71,000
SUBTOTAL $882,000
.14 Thermal Treatment
.01 Incineration
.04 Pads/Foundations/Spill Control 39,875 SF $48 $1,914,000
.05 Mobilize/Setup Plant 1 EA $4,420,000 $4,420,000
.06 Startup/Readiness Test/Trial Burn 1 EA $12,910,000 $12,910,000
.07 Demobilize Plant 1 EA $2,248,000 $2,248,000
SUBTOTAL $21,492,000
.18 Disposal (Other than Commercial)
.21 Transport to Storage/Disposal Facility 275,467 TON $14 $3,762,000 Load/Haul/Unload
.19 Disposal (Commercial)
.21 Transport to Storage/Disposal Facility 2,200 TON $275 $604,000 Load/Haul/Unload
.20 Site Restoration
.01.03 Earthwork - Backfill 194,520 CY $13 $2,544,000
.01.04 Earthwork - Borrow 12,376 CY $16 $195,000
.01.90 Grading & Topsoil 1 EA $378,000 $378,000
.03.90 Storm Drainage 1 EA $245,000 $245,000
.04 Revegetation and Planting 8 AC $10,750 $86,000 Seeding/mulch/fertilizer
SUBTOTAL $3,448,000
.21 Demobilization
.01 Removal of Temporary Facilities 1 EA $408,000 $408,000 Fence, roads/parking, signs, trailers
.02 Removal of Temporary Utilities 1 EA $99,000 $99,000
.03 Final Decontamination 1 EA $812,000 $812,000
.04 Demobilization of Construction Equipment 1 EA $318,000 $318,000 Excavator, etc.
SUBTOTAL $1,637,000
SUBTOTAL $49,576,000
Project Management 3,544,500
Remedial Design 5,915,600
Construction Management 5,640,000
TOTAL RA CAPITAL COSTS $64,676,100
ACTUAL COSTS (2 of 2)
(1)
RA OPERATING COSTS :
UNIT TOTAL
DESCRIPTION QTY UNIT COST (Actual $$) NOTES
331XX HTRW Remedial Action
.02 Monitoring, Sampling, Testing, and Analysis
.03 Air Monitoring and Sampling (17.3 mo) 1 EA $5,574,000 $5,574,000 HNu, Summa Cannisters, CEMs
.13 On Site Laboratory Facilities 1 EA $211,000 $211,000 GC, MS
.14 Off Site Waste Water Analysis (17.3 mo) 1 EA $268,000 $268,000 NPDES Compliance
SUBTOTAL $6,053,000
.13 Physical Treatment
.20 Carbon Adsorption - Liquids (21,000 MGA) WWTP
.08 Plant Operation 17.3 MO $127,399 $2,204,000
.14 Thermal Treatment
.01 Incineration (194,520 CY)
.01 Solids Preparation and Handling 194,520 CY $17 $3,380,000 Drying, blending, feeding
.08 Ownership Plant / Plant Operation 14.2 MO $1,027,715 $14,594,000
.10 Performance Testing 1 EA $11,542,000 $11,542,000
.90 Utilities 14.2 MO $742,324 $10,541,000 Electricity + fuel
.91 Waiting Phase 7 MO $2,038,286 $14,268,000
SUBTOTAL $54,325,000
.15 Stabilization/Fixation
.04 Pozzolan Process 3,054 CY $73 $223,000
SUBTOTAL $62,805,000
Project Management 2,289,000
Technical Support 4,796,000
TOTAL RA OPERATING COSTS $69,890,000
(1)
Actual costs based on the respective year the costs were incurred (i.e., 1998 and 1999).
RA PERIODIC COSTS:
UNIT TOTAL
DESCRIPTION QTY UNIT COST (1999 $$) NOTES
Remedial Action Report 1 EA $56,850 $56,850 1 report upon project completion
INCINERATION
TECHNOLOGY-SPECIFIC UNIT COST CALCULATION
RA CAPITAL COSTS:
Solids Collection and Containment' $2,856,000
Drums/Tanks/Struct/Misc Removal $529,000
Physical Treatment $882,000
Thermal Treatment $21,492,000
Disposal (Other than Commercial) $3,762,000
Disposal (Commercial) $604,000
SUBTOTAL $30,125,000
RA OPERATING COSTS:
Monitoring, Sampling, Testing, and Analysis $6,053,000
Physical Treatment $2,204,000
Thermal Treatment $54,325,000
Stabilization/Fixation $223,000
SUBTOTAL $62,805,000
TOTAL TECHNOLOGY-SPECIFIC COST $92,930,000
Project Information
Project Name Slippery Chemical Operable Unit 3
Project Number
Project Phase (Select one)
Studies and Design
Remedial Action ü
Operations and Maintenance
Project Note (Describe the project)
Incineration treatment technology was utilized to remediate 194,520 cy of soil
contaminated with VOCs, SVOCs, Fenac, Naphthylamine, etc.
Contract Information
Contract Number DACW63-93-C-0200
Managing Organization U.S. Army Corps of Engineers
Organization Name Ft. Worth District
Site Owner Private Party
Other ID Number
Prime Contractor H&S Consultants
Contract Type (Select one)
Cost + Award Fee
Cost + Base + Award Fee
Cost + Fixed Fee ü
Cost + Incentive Award
Fixed Price
Not Availiable
Other
Procurement Type (Select one)
Two Step Sealed Bid
Sealed Bid (IFB)
Competitive Negotiation (RFP) ü
Sole Source (SSC)
Other
Historical Cost Analysis System (HCAS)
Project Data Entry Form (Sheet 2)
Site Information
State/Country Texas/USA
Installation
Site Name Grease, TX
Site Number
EPA Region VI
Current Use (Select one)
Installation Operation
Industry Operation
Residential
Recreational
Wildlife Refuge
Waste Disposal ü
Administrative Office
Commercial
Other
Unknown
Future Use (Select one)
Installation Operation
Industry Operation
Residential
Recreational
Wildlife Refuge
Waste Disposal
Administrative Office
Commercial
Other
Unknown ü
Point of Contact
Data Entry Person POC#2 POC#3
Title/Role Contractor Estimator
Organization H&S Consultants
Name John Jones
Address 630 Hilton St.
City, State Grease, TX
Zip 99990
Telephone 555-555-4102
Fax 555-555-4103
Email jjones@h&s.com
Enter up to 3 POC's.
Historical Cost Analysis System (HCAS)
Project Data Entry Form (Sheet 3)
Cost
Start Date 9/30/1993
End Date 11/23/1999
Number of Mods 0
Reasons for Mods (Select those applicable)
Administrative
Changes for Time or Cost
Changes Requested by Government Authority
Design Deficiency
Differing Site Conditions
Funding Level Change
New Federal Regulation
Other Changes
Suspension or Termination of Work
Value Engineering Change
Variations in Estimated Quantities
Variations Not Readily Identifiable During Design
Cost
Award Amount $99,000,000
Actual Amount $112,381,000
Cost Variance +13,381,000
Cost Breakdown
See next sheets.
The next sheets show the RA WBS and O&M WBS to the Third Level
as required for the HCAS cost report portion of the "RA Report".
The complete RA WBS and O&M WBS to the Fourth Level is at:
http://www.FRTR.gov/cost/ec2/wbs1.html
03 SITEWORK
03 01 Demolition SY
03 02 Clearing and Grubbing ACR
03 03 Earthwork CY
03 04 Roads/Parking/Curbs/Walks SY
03 05 Fencing LF
03 06 Electrical Distribution LF
03 07 Telephone/Communication Distribution LF
03 08 Water/Sewer/Gas Distribution 2,425 LF 378 916,000
03 09 Steam and Condensate Distribution LF
03 10 Fuel Line Distribution LF
03 11 Storm Drainage/Subdrainage LF
03 12 Permanent Cover Structure Over Containment Area SF
03 13 Development of Borrow Pit/Haul Roads ACR
WBS Number DESCRIPTION QTY UOM UNIT COST $
COST
331XX 03 14 Fuel Storage Tanks (New) EA
03 9X Other (Use Numbers 90-99)
10 DRUMS/TANKS/STRUCTURES/MISCELLANEOUS
10 01 Drum Removal 185 EA 1,157 214,000
10 02 Tank Removal EA
10 03 Structure Removal SF
10 04 Asbestos Abatement SF
10 05 Piping and Pipeline Removal LF
10 06 Radioactive Specific Waste Containment (Furnish/Fill) CY
10 07 Miscellaneous Items 8 ACR 39,375 315,000
10 08 Contaminated Paint Removal SF
10 9x Other (Use Numbers 90-99)
11 BIOLOGICAL TREATMENT
11 01 Activated Sludge (Sequencing Batch Reactors) MGA
11 02 Rotating Biological Contactors MGA
11 03 Land Treatment/Farming (Solid Phase Biodegradation) CY
11 04 In-Situ Biodegradation/Bioreclamation CY
11 05 Trickling Filters MGA
11 06 Biological Lagoons MGA
11 07 Composting CY
11 08 Sludge Stabilization - Aerobic CY
11 09 Sludge Stabilization - Anaerobic CY
11 10 Genetically Engineered Organisms (White Rot Fungus) CY
11 11 Slurry Biodegradation CY
11 12 Bioventing SF
11 13 Bioslurping SF
11 14 Biopile (Heap Pile Remediation) CY
11 50 Construction of Permanent Plant Facility EA
11 9x Other (Use Numbers 90-99)
WBS Number DESCRIPTION QTY UOM UNIT COST $
COST
331XX 12 CHEMICAL TREATMENT
12 01 Oxidation/Reduction (Catalytic Oxidation, UV Ozone, MGA
12 02 Solvent Extraction MGA
12 03 Chlorination MGA
12 04 Ozonation MGA
12 05 Ion Exchange MGA
12 06 Neutralization MGA
12 07 Chemical Hydrolysis MGA
12 08 Ultraviolet Photolysis MGA
12 09 Dehalogenation (Catalytic Dechlorination) CY
12 10 Alkali Metal Dechlorination CY
12 11 Alkali Metal/Polyethylene Glycol (A/PEG) CY
12 12 Base-Catalyzed Decomposition Process (BCDP) CY
12 13 Electrolysis MGA
12 14 Vapor Recovery/Reuse (Internal Combustion Engine) CF
12 50 Construction of Permanent Plant Facility EA
12 9x Other (Use Numbers 90-99)
13 PHYSICAL TREATMENT
13 01 Filtration/Ultrafiltration MGA
13 02 Sedimentation MGA
13 03 Straining MGA
13 04 Coagulation/Flocculation/Precipitation MGA
13 05 Equalization MGA
13 06 Evaporation MGA
13 07 Air Stripping MGA
13 08 Steam Stripping MGA
13 09 Soil Washing (Surfactant/Solvent) CY
13 10 Soil Flushing (Surfactant/Solvent) CY
13 11 Solids Dewatering CY
13 12 Oil/Water Separation MGA
13 13 Dissolved Air Floatation MGA
13 14 Heavy Media Separation CY
13 15 Distillation MGA
13 16 Chelation MGA
13 17 Solvent Extraction MGA
13 18 Supercritical Extraction MGA
13 19 Carbon Adsorption - Gases CF
13 20 Carbon Adsorption - Liquids 21,000 MGA 146.95 3,086,000
13 21 Membrane Separation - Reverse Osmosis MGA
13 22 Membrane Separation - Electrodialysis MGA
13 23 Soil Vapor Extraction CY
13 24 Shredding CY
13 25 Aeration CY
13 26 Advanced Electrical Reactor CY
13 27 Low Level Waste (LLW) Compaction CY
13 28 Agglomeration CY
WBS Number DESCRIPTION QTY UOM UNIT COST $
COST
331XX 13 29 In-Situ Steam Extraction MGA
13 30 Filter Presses MGA
13 31 Lignin Adsorption/Sorptive Clays CY
13 32 Air Sparging MGA
13 50 Construction of Permanent Plant Facility EA
13 9x Other (Use Numbers 90-99)
14 THERMAL TREATMENT
14 01 Incineration 194,520 CY 389.76 75,817,000
14 02 Low Temperature Thermal Desorption CY
14 03 Supercritical Water Oxidation MGA
14 04 Molten Salt Destruction CY
14 05 Radio Frequency Heating CY
14 06 Solar Detoxification CY
14 07 High Temperature Thermal Desorption CY
14 50 Construction of Permanent Plant Facility EA
14 9x Other (Use Numbers 90-99)
15 STABILIZATION/FIXATION/ENCAPSULATION
15 01 Molten Glass CY
15 02 In-Situ Vitrification CY
15 03 In-Situ Pozzolan Process (Lime/Portland Cement) CY
15 04 Pozzolan Process (Lime/Portland Cement) 3,054 CY 73 223,000
15 05 Asphalt-Based Encapsulation CY
15 06 Radioactive Waste Solidification (Grouting/Other) CY
15 07 Sludge Stabilization (Aggregate/Rock/Slag) CY
15 50 Construction of Permanent Plant Facility EA
15 9x Other (Use Numbers 90-99)
19 DISPOSAL (COMMERCIAL)
19 20 Container Handling EA
19 21 Transportation to Storage/Disposal Facility 2,200 TON 275 604,000
19 22 Disposal Fees and Taxes TON
19 23 Mixed Waste Storage Fees and Taxes TON
19 9x Other (Use Numbers 90-99)
20 SITE RESTORATION
20 01 Earthwork 207,896 CY 14.99 3,117,000
20 02 Permanent Markers EA
20 03 Permanent Features 1 EA 245,000 245,000
20 04 Revegetation and Planting 8 ACR 10,750 86,000
20 05 Removal of Barriers EA
20 9x Other (Use Numbers 90-99)
21 DEMOBILIZATION
21 01 Removal of Temporary Facilities 1 EA 408,000 408,000
21 02 Removal of Temporary Utilities 1 EA 99,000 99,000
21 03 Final Decontamination 1 EA 812,000 812,000
21 04 Demobilization of Construction Equipment and Facilities 1 EA 318,000 318,000
21 05 Demobilization of Personnel EA
21 06 Submittals EA
21 07 Construction Plant Takedown EA
21 9x Other (Use Numbers 90-99)
03 SITEWORK
03 04 Roads/Parking/Curbs/Walks SY/YR
03 05 Fencing LF/YR
03 06 Electrical Distribution LF/YR
03 07 Telephone/Communication Distribution LF/YR
03 08 Water/Sewer/Gas Distribution LF/YR
03 09 Steam and Condensate Distribution LF/YR
03 10 Fuel Line Distribution LF/YR
03 11 Storm Drainage/Subdrainage LF/YR
03 12 Permanent Cover Structure Over Contaminated Area SF/YR
03 14 Fuel Storage Tanks (New) EA/YR
03 9X Other (Use Numbers 90-99)
11 BIOLOGICAL TREATMENT
11 01 Activated Sludge (Seq Batch Reactors) MGA
11 02 Rotating Biological Contactors MGA
11 03 Land Treatment/Farming (Solid Phase Biodegradation) CY
11 04 In-Situ Biodegradation/Bioreclamation CY
11 05 Trickling Filters MGA
11 06 Biological Lagoons MGA
11 07 Composting (Soil Pile Bioremediation) CY
11 08 Sludge Stabilization - Aerobic CY
11 09 Sludge Stabilization - Anaerobic CY
11 10 Genetically Engineered Organisms (White Rot Fungus) CY
11 11 Slurry Biodegradation CY
11 12 Bioventing SF
11 13 Bioslurping SF
11 14 Biopile (Heap Pile Remediation) CY
11 50 Post Construction O&M of Permanent Plant Facility EA/YR
11 9x Other (Use Numbers 90-99)
12 CHEMICAL TREATMENT
12 01 Oxidation/Reduction (Catalytic) MGA
12 02 Solvent Extraction MGA
12 03 Chlorination MGA
12 04 Ozonation MGA
12 05 Ion Exchange MGA
12 06 Neutralization MGA
12 07 Chemical Hydrolysis MGA
12 08 Ultraviolet Photolysis (UV Oxidation) MGA
12 09 Dehalogenation (Catalytic Dechlorination) CY
12 10 Alkali Metal Dechlorination CY
12 11 Alkali Metal/Polyethylene Glycol (A/PEG) CY
12 12 Base-Catalyzed Decomposition Process CY
12 13 Electrolysis MGA
12 14 Vapor Recovery/Reuse (Internal Combustion Engine) CF
12 50 Post Construction O&M of Permanent Plant Facility EA/YR
12 9x Other (Use Numbers 90-99)
13 PHYSICAL TREATMENT
13 01 Filtration/Ultrafiltration MGA
13 02 Sedimentation MGA
13 03 Straining MGA
13 04 Coagulation/Flocculation/Precipitation MGA
WBS Number DESCRIPTION QTY UOM UNIT COST
COST $
342XX 13 05 Equalization MGA
13 06 Evaporation MGA
13 07 Air Stripping MGA
13 08 Steam Stripping MGA
13 09 Soil Washing (Surfactant/Solvent) CY
13 10 Soil Flushing (Surfactant/Solvent) CY
13 11 Solids Dewatering CY
13 12 Oil/Water Separation MGA
13 13 Dissolved Air Floatation MGA
13 14 Heavy Media Separation CY
13 15 Distillation MGA
13 16 Chelation MGA
13 17 Solvent Extraction MGA
13 18 Supercritical Extraction MGA
13 19 Carbon Adsorption - Gases CF
13 20 Carbon Adsorption - Liquids MGA
13 21 Membrane Separation - Reverse Osmosis MGA
13 22 Membrane Separation - Electrodialysis MGA
13 23 Soil Vapor Extraction CY
13 24 Shredding CY
13 25 Aeration CY
13 26 Advanced Electrical Reactor CY
13 27 Low Level Waste (LLW) Compaction CY
13 28 Agglomeration CY
13 29 In-Situ Steam Extraction MGA
13 30 Filter Presses MGA
13 31 Lignin Adsorption/Sorptive Clays CY
13 32 Air Sparging MGA
13 50 Post Construction O&M of Permanent Plant Facility EA/YR
13 9x Other (Use Numbers 90-99)
14 THERMAL TREATMENT
14 01 Incineration CY
14 02 Low Temperature Thermal Desorption CY
14 03 Supercritical Water Oxidation MGA
14 04 Molten Salt Destruction CY
14 05 Radio Frequency Heating CY
14 06 Solar Detoxification CY
14 07 High Temperature Thermal Desorption CY
14 50 Post Construction O&M of Permanent Plant Facility EA/YR
14 9x Other (Use Numbers 90-99)
15 STABILIZATION/FIXATION/ENCAPSULATION
15 01 Molten Glass CY
WBS Number DESCRIPTION QTY UOM UNIT COST
COST $
342XX 15 02 In-Situ Vitrification CY
15 03 In-Situ Pozzolan Process (Lime/Portland Cement) CY
15 04 Pozzolan Process (Lime/Portland Cement) CY
15 05 Asphalt-Based Encapsulation CY
15 06 Radioactive Waste Solidification (Grouting/Other) CY
15 07 Sludge Stabilization (Aggregate/Rock/Slag) CY
15 50 Post Construction O&M of Permanent Plant Facility EA/YR
15 9x Other (Use Numbers 90-99)
TOTAL AMOUNT $ 0
EP 1110-1-19
30 Jun 01
APPENDIX C
EXAMPLE REMEDIAL ACTION REPORT –
IN SITU SOIL AND GROUNDWATER REMEDIATION
NOTE:
The following example remedial action report is based on an actual Superfund site, but some
information has been altered to illustrate the concepts of the guide. In addition, names have been
changed to avoid confusion with the actual site.
Content and format of actual RA reports may vary from this example due to considerations such
as project lead and support roles, availability of information, and site-specific conditions. The
information presented in this example report (e.g., costs) should not necessarily be used as a
technical basis for completing remedial action at an actual site (e.g., as a source of cost
information).
C-1
I N T E R I M
R E M E D I A L A C T I O N R E P O R T
September 2000
TABLE OF CONTENTS
Abstract............................................................................................................................................iii
Inspections............................................................................................................ 6-1
Certifications ........................................................................................................ 6-1
Health and Safety................................................................................................. 6-1
Waste Source: Disposal of refuse and liquid waste in an unlined landfill cell during the 1950s
and 1960s
Type/Quantity of Approximately 60 pounds of TCE had been removed as of October 31, 1997
Media Treated: (based on concentrations in extracted soil gas). It is estimated that 27,800 cubic
yards of soil (by SVE) and 37,400,000 gallons of groundwater (by AS) will have
been treated by the end of system operation.
Regulatory The cleanup levels established for groundwater in the upper aquifer beneath the
site are:
Requirements/ TCE: 5 µg/L (MCL from the Federal Safe Drinking Water Act)
Cleanup Goals: VC: 1 µg/L (Ohio State Model Toxics Control Act Method B)
Monitoring of manganese is required along the western border of South and
Northwest LF5 to determine any changes in concentration.
A site-specific air emission threshold limit of 2.5 parts per million volume
(ppmv) TCE was also established.
Results: The concentration of TCE in the soil gas extracted by the SVE system generally decreased from
210 parts per billion by volume (ppbv) to 140 ppbv during the period of April 1, 1995 through
July 27, 1995. The extracted soil gas concentration then increased to a maximum of 640 ppbv
during the period of August 1, 1995 through December 27, 1999.
Costs: The total actual costs incurred for this project from Years 0-5 (1994-1999) are $1,852,104, with a
capital cost of $729,294. The total project costs remaining are $2,111,483 (Years 6-15). The
technology-specific unit costs for soil vapor extraction and air sparging were calculated at $65.75
per cubic yard and $18.83/1,000 gallons, respectively. These unit costs include both actual and
projected costs that are applicable to each technology.
Description: Ft. Griffey occupies approximately 86,000 acres along the northern bank of the Ohio River,
approximately 12 miles from Cincinnati, Ohio. Ft. Griffey began operating in 1917 and currently
serves as a military reservation. Ft. Griffey is divided by I-5 into North Ft. Griffey and the Main
Post.
The RI, completed in 1993 by RED, under contract with USACE, Lousiville District, included an
extensive landfill and soil gas survey and a groundwater investigation. The RI confirmed the
presence of chlorinated hydrocarbons and aromatic hydrocarbons contamination at LF5. Elevated
levels of TCE, PCE, and DCE were detected in the soil. TCE, VC and BTEX contamination was
detected in the groundwater. Elevated levels of Mn were also detected in the groundwater along
the western borders of South and Northwest LF5. However, the RI attributes these elevated levels
to the dissolution of Mn from geologic materials in the area of LF5.
The full-scale system operation began when the startup activities were completed on July 29,
1995. The full-scale system operation is currently ongoing. The concentration of TCE in the soil
gas extracted by the SVE system generally decreased from 210 parts per billion by volume (ppbv)
to 140 ppbv during the period of April 1, 1995 through July 27, 1995. The extracted soil gas
concentration then increased to a maximum of 640 ppbv during the period of August 1, 1995
through December 27, 1999. This increase generally corresponds to the opening of the passive
injection wells after July 29, 1995, suggesting that the use of the passive injection wells enhanced
the system’s performance.
Ft. Griffey occupies approximately 86,000 acres along the northern bank of the Ohio River,
approximately 12 miles from Cincinnati, Ohio. Ft. Griffey began operating in 1917 and currently
serves as a military reservation. Ft. Griffey is divided by I-5 into North Ft. Griffey and the Main
Post.
Landfill 5 (LF5) is located on North Ft. Griffey near Reese Lake and Reese Springs, which is the
primary drinking water supply for the fort. The 52 acre landfill is divided into three cells - South,
Northeast, and Northwest - and is located adjacent to a gravel pit (Figure 1).
From the early 1950s to the late 1960s, LF5 was reportedly used for the disposal of refuse,
including domestic and light industrial solid waste and construction debris, and for the disposal
of liquid waste in unlined cells. In addition, LF5 was reportedly used as a gravel quarry in the
1940s and for equipment storage and maintenance. After disposal activities ceased, the landfill
was covered with native materials such as sand, gravel and soil; the landfill is currently covered
with trees and grass.
PREVIOUS INVESTIGATIONS
According to the 1993 remedial investigation (RI), there were no reports of hazardous waste
disposal in LF5. However, historical aerial photographs show two suspected liquid waste
disposal pits located in Northeast and South LF5 and evidence of equipment maintenance
activities near Northeast LF5 . Tetrachloroethene (PCE) and trichloroethene (TCE) are suspected
of having been used in degreasing and equipment maintenance operations at Ft. Griffey; leaks
and spills of solvents from maintenance operations on or near LF5 and disposal of solvents in
unlined pits are the suspected sources of contamination.
In 1988, a limited site investigation of LF5 was conducted by Larkin Midwest Laboratory. The
investigation indicated that the shallow groundwater beneath the landfill was contaminated with
chlorinated hydrocarbons, aromatic hydrocarbons, and manganese (Mn). While the data were not
provided in the available references, TCE was reported to have been found at concentrations
ranging from 1 to 32 micrograms per liter (µg/L).
In 1991, Remediation Enhanced Developments, Inc. (RED) conducted several pre-RI activities
under contract with the U.S. Army Corps of Engineers (USACE) Louisville District including a
test pit investigation, a passive soil gas survey, and a preliminary ecological assessment.
According to RED, the results of these activities indicated that TCE and PCE were widely
distributed in the area of LF5.
The RI, completed in 1993 by RED, again under contract with USACE Louisville District,
included a more extensive landfill and soil gas survey and a groundwater investigation. The RI
confirmed the presence of chlorinated hydrocarbons and aromatic hydrocarbons contamination at
LF5. Elevated levels of TCE, PCE, and dichloroethene (DCE) were detected in the soil. TCE,
vinyl chloride (VC) and benzene, toluene, ethylbenzene, and xylene (BTEX) contamination was
detected in the groundwater. Elevated levels of Mn were also detected in the groundwater along
the western borders of South and Northwest LF5. However, the RI attributes these elevated
levels to the dissolution of Mn from geologic materials in the area of LF5.
Low levels of BTEX were detected in the lower aquifer (<0.5 µg/L to 5.8 µg/L). However, TCE,
DCE, VC, and PCE, while detected in the upper aquifer, were not detected in the lower aquifer.
Mn and iron were detected in both the upper and lower aquifers. The RI determined that the
elevated levels of Mn were caused by dissolution of manganese from geologic material.
Results of groundwater quality indicator parameters measured during the RI, including increased
specific conductance, dissolved metals and biochemical oxygen demand, indicated that low
levels of metals and inorganic compounds were leaching from the landfill into the upper aquifer.
However, the parameters were reported to rarely exceed five times their background levels.
There was no evidence of leaching to the lower aquifer.
FIGURE 1
LANDFILL 5 – LOCATION OF CELLS
Based on the findings of the RI, the U.S. Environmental Protection Agency (USEPA), Region V,
the U.S. Department of Defense (DoD), the Ohio Environmental Protection Agency (OEPA),
and the USACE Louisville District negotiated a cleanup strategy and entered into a Federal
facility agreement under Section 120 of CERCLA to address the contamination at LF5. These
parties agreed to address LF5 as a single operable unit (OU) and commissioned a feasibility
study (FS) in March 1993.
REMEDY SELECTION
In a record of decision (ROD) signed in October 1993, the remedy selected for LF5 included:
• Treatment of contaminated soils in areas that were suspected sources of groundwater
contamination (soil hot spots) using soil vapor extraction (SVE);
• Treatment of contaminated groundwater using air sparging (AS);
• Monitoring of the upper aquifer to determine the effectiveness of the selected remedy; and,
• Maintenance of institutional controls, including access restrictions.
The groundwater AS system was to operate in conjunction with the SVE system.
The ROD also required that Mn be monitored in the groundwater in the localized areas where
elevated levels were detected during the RI. The ROD specified that, if the results of the
monitoring indicated that levels were not declining, then the need for remediation was to be
reevaluated.
Including limited groundwater extraction and treatment in addition to AS/SVE was considered as
an alternative remedy. However, AS/SVE was determined to be more cost effective than
AS/SVE plus groundwater extraction and treatment while still being protective of human health
and the environment.
No soil cleanup levels were identified. The cleanup levels established for groundwater in the
upper aquifer beneath the site were:
• TCE - 5 µg/L - the Federal Safe Drinking Water Act maximum contaminant level (MCL);
• VC - 1 µg/L - the Ohio State Model Toxics Control Act Method B.
Monitoring of Mn was required along the western border of South and Northwest LF5 to
determine any changes in concentration.
The remedial design (RD) for the AS/SVE system was completed in nine months and approved
by USEPA October 5, 1994, for implementation of the remedial action.
The AS/SVE system was constructed between October 19 and December 29, 1994. Details of
the system’s construction are discussed below. Appendix A presents matrix characteristics and
operating parameters.
PILOT SYSTEM
The pilot system used in this application consisted of one AS well, three SVE wells, ten vadose
zone piezometer (VZP) wells, two groundwater monitoring wells, and three dissolved oxygen
sensor (DOS) wells, as well as an impermeable plastic cover for the ground surface and well
monitoring equipment. The AS and SVE wells were located near monitoring well LF5-MW8A,
from which groundwater samples with the highest recorded TCE concentrations in the project
area had been collected.
The AS well was used to inject clean air into the aquifer, using an above-ground blower, to strip
volatile contaminants from the aquifer into the soil in the subsurface at the site. Dissolved
oxygen (DO) concentrations in the aquifer were measured during AS using DOS wells. The DO
results were used to estimate the radius of influence of the AS well during the pilot test. The
SVE wells were used to extract volatile contaminants from the subsurface soil, and the VZP
wells were used to measure the radius of influence of the SVE wells.
The impermeable plastic cover was used to enhance the radius of influence for the SVE wells by
moving the air recharge boundary a greater distance from the SVE wells. The cover was
constructed of a 20-millimeter (mil) thick layer of very low density polyethylene (VLDPE) and
laid down over a cleared area. The cover had a radius of approximately 200 feet, and was
covered with 4 to 6-inches of gravel to assure tight contact with the ground surface, and to allow
for light vehicular traffic (pickup trucks) over the cover. All wells were drilled using a 4-inch
inner diameter (ID) hollow stem auger.
Operation of the pilot system consisted of a SVE pilot test and a combined AS/SVE pilot test.
FULL-SCALE SYSTEM
The full-scale system used in this application consisted of five AS wells, six SVE wells, ten VZP
wells, three groundwater monitoring wells, three DOS wells, four passive injection wells, and
associated well-monitoring equipment. The passive injection wells were positioned where
modeling results showed significant stagnation zones when two adjacent SVE wells were
operated at the same time. The full-scale system also used the same impermeable plastic cover
for the ground surface that was used in the pilot system. Two parallel systems of vapor-phase
granular activated carbon (GAC) were used in the full-scale system.
Extracted vapors were first treated using a moisture (water/vapor) separator to remove entrained
water, and then treated using activated carbon filter canisters (GAC), prior to discharge to the
atmosphere.
The AS system consisted of an inlet particulate filter, compressor, moisture separator, and flow
control valve.
The six SVE wells were piped to two parallel treatment trains, each consisting of a moisture
separator, a blower, and two vapor-phase GAC canisters. These two parallel sets of equipment
were operated to ensure that the system’s performance would not be affected by a breakdown.
Well construction details for the full-scale system are provided below. Schematics of the SVE
and AS systems, respectively, are shown in Figures 2 and 3.
FIGURE 2
SOIL VAPOR EXTRACTION SCHEMATIC FOR LANDFILL 5
FIGURE 3
AIR SPARGING SCHEMATIC FOR LANDFILL 5
The following table includes the dates of the most significant events in the operation of the
AS/SVE system at LF5.
Date Activity
July 29, 1995 Preliminary closeout report signed for site construction completion
The overall performance of the AS/SVE system, as compared to the performance objectives, is
discussed below.
PERFORMANCE OBJECTIVES
The ROD specified four objectives for the remedy:
• To prevent exposure to contaminated groundwater;
• To restore the contaminated groundwater to its beneficial use (drinking water);
• To minimize movement of contaminants from soil to groundwater; and,
• To prevent exposure to the contents of the landfill.
No soil cleanup levels were identified. The cleanup levels established for groundwater in the
upper aquifer beneath the site were:
• TCE - 5 µg/L - the Federal Safe Drinking Water Act MCL
• VC - 1 µg/L - the Ohio State Model Toxics Control Act Method B
Monitoring of Mn was required along the western border of South and Northwest LF5 to
determine any changes in concentration.
A site-specific air emission threshold limit of 2.5 parts per million volume (ppmv) TCE was
calculated by USACE using Screen Model 3 and the Riverfront Air Pollution Control Agency
(RAPCA) acceptable source impact levels. The air stream between the first and second carbon
canisters is monitored every other week using a photoionization detector (PID). The PID
breakthrough action level is 1.5 ppmv total VOCs. The breakthrough action level is used to
determine when the first carbon bed needs to be removed from service.
To assess the overall performance of the system, performance monitoring is required throughout
the operation of the system. The specific requirements are detailed in the compliance monitoring
plan and include contaminant reduction monitoring to evaluate progress towards achieving the
cleanup goals, contaminant migration monitoring to confirm that the plume is being contained,
and contaminant treatment monitoring for air emissions.
In general, the SVE system was operated between 0 and 1,290 standard cubic feet per minute
(scfm) extracted, and the air sparging system was operated at between 0 and 210 scfm injected.
The passive air injection wells initially remained closed from April 1, 1995 and July 29, 1995,
after which they were opened. It was determined that the passive injection wells should remain
open unless a detrimental effect could be demonstrated.
The concentration of TCE in the soil gas extracted by the SVE system generally decreased from
210 parts per billion by volume (ppbv) to 140 ppbv during the period of April 1, 1995 through
July 27, 1995. The extracted soil gas concentration then increased to a maximum of 640 ppbv
during the period of August 1, 1995 through December 27, 1999. This increase generally
corresponds to the opening of the passive injection wells after July 29, 1995, suggesting that the
use of the passive injection wells enhanced the system’s performance.
Groundwater Sampling
Twenty-two rounds of groundwater sampling have been conducted (two before the remediation
system was installed and four times per year for five years after the system’s installation). The
first round of sampling was performed during March 1994 and the last round for which data was
available was performed in December 1999.
TCE was the only contaminant in groundwater consistently identified above the cleanup levels
established for the site. In addition, monitoring for Mn was required.
The average TCE concentration in the contaminant reduction monitoring wells has decreased
from 79 to 6.4 mg/L from March 1994 to December 1999, while the average TCE concentration
in the migration monitoring wells has showed no consistent trend (average concentrations have
ranged from 3.78 to 12.03 mg/L). TCE concentrations in both areas were still above the site
cleanup level of 5 mg/L in December 1999.
The average total Mn concentration in the contaminant reduction monitoring wells has decreased
from 11,000 mg/L in March 1994 to 8.0 mg/L in December 1999, while the average Mn
concentration in the migration monitoring wells has generally decreased from 488.0 to
40.0 mg/L) during the same time period.
Vinyl chloride, the other contaminant with a cleanup level for the site, was only detected above
method detection limits on one occasion (March 1997)and was never detected above site cleanup
levels.
Based upon the system performance testing of the AS/SVE system, the air effluent from the
system was determined to be several magnitudes below the RAPCA emission action levels.
Therefore, because the RAPCA emission action levels would not be exceeded during the SVE
system’s operation, additional air sampling was not required.
required in the final management plan for the LF5 pilot study for QA/QC of the field study
sampling program. Method blanks, reagent blanks, matrix spike samples, matrix spike
duplicates, duplicates, and laboratory control samples were required for laboratory QA/QC. No
exceptions to the QA/QC procedures were noted in any of the field sampling or laboratory
reports.
With the exception of DO data from the second quarter of 1996, no significant data quality
problems were identified. This DO data were determined to be unacceptable as a result of
significant fluctuations measured from the sensors. The problem did not reoccur in any of the
subsequent sampling data.
INSPECTIONS
The pre-final and the Federal facilities agreement inspections of the AS/SVE system construction
were conducted simultaneously on December 27, 1999, in the presence of USEPA, DoD, OEPA,
and USACE representatives.
Observations, inspections, and testing during operation of the AS/SVE treatment system found
no significant operational problems affecting the performance of the remedial action.
CERTIFICATIONS
On September 4, 1995, the AS/SVE system was certified as Operating Properly and
Successfully. This determination was required under the Federal facilities agreement.
The quarterly groundwater monitoring program began in March 1994. TCE concentrations in
both areas were still above the site cleanup level of 5 mg/L in December 1999. The average total
Mn concentration in the contaminant reduction monitoring wells has decreased from
11,000 mg/L in March 1994 to 8.0 mg/L in December 1999, while the average Mn concentration
in the migration monitoring wells has generally decreased from 488.0 to 40.0 mg/L) during the
same time period. Vinyl chloride, the other contaminant with a cleanup level for the site, was
only detected above method detection limits on one occasion and was never detected above site
cleanup levels.
It is anticipated, based on the effectiveness of the AS/SVE system, that the site cleanup level of
5 mg/L for TCE concentrations will be attained for all monitoring wells in approximately 2002
(Year 7). As specified in the ROD, after this objective has been achieved the AS/SVE system
will continue to operate for an additional 3 months to ensure that the site has been remediated.
As specified in the ROD, the quarterly monitoring of groundwater will continue through 2009
(Year 15) to confirm that groundwater will not be adversely impacted by the land treatment
activities.
The table below summarizes total actual project costs for the Landfill 5 operable unit RA.
Appendix B provides a breakdown of these costs incurred to-date as well as a breakdown of
projected costs.
Adjusted
Cost Item Actual Cost1 Difference
ROD Estimate
Capital Costs, Year 0 (1994) $688,013 $729,294 +6%
Total projected costs for Years 6 through 15 are $2,111,483 with O&M costs of $2,057,839 and
periodic costs of $53,644 using 2000 as the base year of the estimate. This compares to an
adjusted ROD estimate cost of $2,006,910 for O&M (+2.5%) and $50,000 for periodic costs
(+1%) for this period.
PERFORMANCE
During the operation of the treatment system in SVE-only mode, TCE concentrations were
reduced from initial concentrations of 235 ppb to 110 ppb. The addition of AS to the system
reduced TCE concentrations in the soil gas from initial concentrations of 110 ppb to 56 ppb.
The AS/SVE system reduced TCE concentrations in groundwater. At the three wells located near
suspected hot spots of contamination, TCE concentrations were reduced from 310 ppb to
170 ppb (DOS-1), from 220 ppb to 170 ppb (DOS-2), and from 140 ppb to 23 ppb (MW8A).
However, the concentrations remained above the cleanup goal of 5 ppb for TCE.
The results of Mn sampling before and after sparging indicated that Mn levels decreased in six of
the eleven wells samples, but increased in five of the wells.
The following observations were made in a technical memorandum summarizing the system’s
operation.
• With respect to optimal air extraction rate, an extraction rate of 110 scfm is likely to capture
all volatilized contaminants within about 200 feet of each extraction well.
• The radius of influence of an air injection well is about 20-30 feet.
• A pressure of approximately 8 psi was required to overcome resistance in the injection well.
However, at injection pressures above 8 psi, air bubbles would be more likely to occur. At
8 psi, the air injection rate into the aquifer was about 45 scfm. The 45 scfm (8 psi pressure)
was determined to be the optimal flow rate, reflecting site and conditions of injections 12 feet
below static water level. The vendor noted that changes in depth of the injection well will
affect the injection pressure and radius of influence.
• The major problem encountered during the pilot test was that the SVE vacuum pump did not
produce a vacuum sufficient to be detected by the automated sensors. Because of schedule
constraints, a larger blower could not be obtained. However, according to the vendor,
adequate data was obtained from the pilot test to design the full-scale system.
While overall TCE concentrations decreased in the groundwater, there were several instances
when TCE concentrations increased during operation. These increases may be attributed to the
new source material (from contaminated soil) infiltrating into the groundwater.
COST
The total cost for the pilot study of the AS/SVE system at LF5 was $241,000. This amount is
not included in the amounts shown in Table 8-1.
Differences between the actual costs and the adjusted ROD estimates are largely attributable to
the installation of passive injections wells, a SVE system capable of sustaining a 600 scfm
average volumetric airflow rate, and additional groundwater monitoring wells, and the increased
groundwater sampling costs associated with the additional wells. However, as shown in
Table 8-1, the actual costs that have been incurred to this point were just 9% above the
corresponding, adjusted ROD estimate.
Subsequent to original negotiations, the contaminant concentrations in system air emissions were
determined to be significantly below the allowable air emission standards, and RAPCA agreed to
allow USACE to eliminate the need to change the carbon units from the system and to reduce air
compliance monitoring requirements. USACE is planning to reallocate money from any savings
on air compliance monitoring to increase the number of system performance air tests.
Because the system operation is ongoing, the total costs to operate the system are not known at
this time. Actual costs to date are shown in Table B-1, and projected additional cost to complete
is shown in Table B-2.
SYSTEM OPERATION
The emphasis of vapor data collection in the future should shift to the individual extraction wells
rather than the combined extracted flow. In the fifth quarter of the full-scale operation, quarterly
vapor sampling from the individual wells was initiated.
Based on the testing of the untreated and the treated condensate removed by the remediation
system, the potential life of the aqueous-phase carbon units was estimated to be in excess of ten
million gallons.
An SVE system flow rate of less than the design maximum flow rate may be more efficient for
TCE removal than continuous operation at the maximum flow rate. The vendor recommended
that the system be evaluated at moderate SVE system flow rates during the ongoing optimization
of the system.
The data supports the remedial investigation findings that numerous TCE hot spots exist at the
site, and that the presence of TCE (and/or its degradation products) at one location may or may
not be related to its presence at other locations at the site.
Studying the natural degradation of the leachate at the site may provide a more widespread
picture of the fate of contamination at the site than focusing on the natural attenuation of
chlorinated hydrocarbons alone.
Although the impact of the AS system on the degradation of TCE at the site had not been
conclusively determined, it was recommended that the AS system continued to be operated until
an impact/ benefit analysis for the system is completed.
Because one of the contaminant reduction monitoring wells upgradient of the remediation system
had maintained an elevated concentration of TCE, a TCE hot spot may be located upgradient of
this location beyond the influence of the remediation system. An additional AS/SVE well pair
could be added to this area to increase the reach of the remediation system.
The concentrations of contaminants downgradient from the treatment system may remain above
the cleanup levels for the site, even if contaminant concentrations are reduced to below cleanup
levels in the treatment system area.
RA Oversight Contractor:
Analytical Laboratory:
Project Management:
For the USACE:
Name: D. Bichet
Email: [email protected]
Email: [email protected]
2. Remediation Enhanced Developments, Inc. 1993. Final Feasibility Study Report, Landfill 5
and Solvent Refined Coal Pilot Plant, Ft. Griffey, Ohio. Prepared for USACE, Louisville
District. May.
5. Remediation Enhanced Developments, Inc. 1995. Chemical Data Report #1, Landfill 5 Air
Sparging/Soil Vapor Extraction Remediation, Ft. Griffey, Ohio. For USACE Contract No.
DACA99-99-Z-9999-99. December 31.
6. Remediation Enhanced Developments, Inc. 1996. Chemical Data Report #2, Landfill 5 Air
Sparging/Soil Vapor Extraction Remediation, Ft. Griffey, Ohio. For USACE Contract No.
DACA99-99-Z-9999-99. December 31.
7. Remediation Enhanced Developments, Inc. 1997. Chemical Data Report #3, Landfill 5
AS/SVE Remediation, Ft. Griffey, Ohio. For USACE Contract No. DACA99-99-Z-9999-99.
December 31.
8. Remediation Enhanced Developments, Inc. 1998. Chemical Data Report #4, Landfill 5
Remediation, Ft. Griffey, Ohio. For USACE Contract No. DACA99-99-Z-9999-99.
December 31.
9. Remediation Enhanced Developments, Inc. 1999. Chemical Data Report #5, Landfill 5
Remediation, Ft. Griffey, Ohio. For USACE Contract No. DACA99-99-Z-9999-99
December 31..
10. Riverfront Air Pollution Control Agency. 1997. Letter from Scott Williamson to Peter
Harnish, USACE. December 11.
11. U.S. EPA. 1993. Record of Decision, Ft. Griffey Landfill 5 Remediation. October 15.
12. U.S. EPA. 1994. Letter regarding Approval of Remedial Design, Ft. Griffey Landfill 5
Remediation. October 5.
13. U.S. EPA. 1995. Letter regarding Signing of Preliminary Closeout Report, Ft. Griffey
Landfill 5 Remediation. July 29.
14. U.S. EPA. 1995. Letter regarding Operating Properly and Successfully Determination, Ft.
Griffey Landfill 5 Remediation. September 4.
15. USACE, Louisville District. 1994. Final Management Plan, Pilot Study, Landfill 5, Ft.
Griffey, Ohio. June.
16. USACE, Louisville District. 1994. Government Cost Estimate for Cover Air Sparging/Soil
Vapor Extraction Pilot Test, Landfill 5, Ft. Griffey, Ohio, Department of the Army. August.
17. USACE, Louisville District. 1995. Technical Memorandum, AS/SVE Pilot LF5, Ft. Griffey.
March 28.
18. USACE, Louisville District. 1999. Inspection Results: Pre-Final and Federal Facilities
Agreement. December 30.
19. USACE, Louisville District. 1997. Letter from Sean Casey, P.E. to Jack McKeon, Riverfront
Air Pollution Control Agency. December 5.
20. USACE, Louisville District. Undated. Compliance Monitoring Plan, Ft. Griffey, LF5,
AS/SVE Final Remedial Design.
21. USACE, Louisville District. Undated. Design Analysis, Ft. Griffey, LF5, AS/SVE Final
Remedial Design.
22. USACE, Louisville District. Undated. Remedial Action Workplan, Ft. Griffey, LF5, AS/SVE
Final Remedial Design.
The following table details matrix characteristics that may affect cost and performance of the
AS/SVE system.
MATRIX CHARACTERISTICS
OPERATING PARAMETERS
Temperature 85 – 155°F
The following tables present a summary of actual (Years 0-5) and projected (Years 6-15) costs
and calculation of technology-specific unit costs for soil vapor extraction and air sparging.
HCAS data entry sheets are attached to this appendix.
ACTUAL COSTS (1 of 2)
Site: Landfill 5 Description: The selected treatment technology consists of air sparging in combination
Location: Ft. Griffey, Ohio with soil vapor extraction in the source area. Capital costs were incurred
Phase: Interim RA Report in Year 0 (1994). Actual O&M costs were incurred in Years 1 (1995)
Base Year: 1994, 1995-1999, 2000 through 5 (1999). Projected O&M costs are assumed for Years 6 (2000)
Date: April 9, 2001 through 15 (2009). Periodic costs are incurred in Years 5, 10, and 15.
ACTUAL COSTS (2 of 2)
O&M COSTS (Years 1-5):
UNIT
DESCRIPTION QUANTITY UNIT COST TOTAL NOTES
342XX HTRW O&M
.02 Monitoring, Sampling, Testing, and Analysis
.90 Performance Monitoring - SVE Vapor 5 YR $22,149 $110,745 1 sample/month * 6 extraction wells
.91 Performance Monitoring - SVE Emissions 5 YR $3,692 $18,460 1 sample/month - SVE exhaust
.92 Site Groundwater Sampling (Quarterly) 5 YR $36,399 $181,995 Sample 8 wells/event VOCs, metals
.93 Site Groundwater Lab Analysis 5 YR $21,839 $109,195 Analysis for above
SUBTOTAL $420,395
.13 Physical Treatment
.32 Air Sparging (37,400 MGA)
.90 Operations Labor 5 YR $29,376 $146,880 54 manhours per month
.91 Maintenance Labor 5 YR $3,456 $17,280 6 manhours per month
.92 Equipment Repair 1 EA $1,000 $1,000
.93 Utilities 5 YR $9,254 $46,268 Electricity + fuel
SUBTOTAL $211,428
.13 Physical Treatment
.23 Soil Vapor Extraction (27,800 CY)
.90 Operations Labor 5 YR $44,064 $220,320 82 manhours per month
.91 Maintenance Labor 5 YR $5,184 $25,920 10 manhours per month
.92 Equipment Repair 1 EA $1,500 $1,500
.93 Utilities 5 YR $13,880 $69,402 Electricity + fuel
SUBTOTAL $317,142
.18 Disposal (Other than Commercial)
.90 Wastewater Discharge/Testing 8,000 GA $1.25 $10,000 Purge & knockout water
SUBTOTAL $958,965
Project Management 47,948
Technical Support 95,897
TOTAL O&M COST (Years 1-5) $1,102,810 1995-1999
PROJECTED COSTS
Site: Landfill 5 Description: The selected treatment technology consists of air sparging in combination
Location: Ft. Griffey, Ohio with soil vapor extraction in the source area. Capital costs were incurred
Phase: Interim RA Report in Year 0 (1994). Actual O&M costs were incurred in Years 1 (1995)
Base Year: 1994, 1995-1999, 2000 through 5 (1999). Projected O&M costs are assumed for Years 6 (2000)
Date: March 30, 2001 through 15 (2009). Periodic costs are incurred in Years 5, 10, and 15.
AIR SPARGING
TECHNOLOGY-SPECIFIC UNIT COST CALCULATION
Project Information
Project Name Landfill 5 Operable Unit
Project Number
Project Phase (Select one)
Studies and Design
Remedial Action ü
Operations and Maintenance
Project Note (Describe the project)
Soil Vapor Extraction treatment technology was utilized to remediate 27,800 cy (estimated)
of contaminated soil in conjunction with Air Sparging treatment technology, which was
utilized to remediate 37,400,000 gallons (estimated) of contaminated groundwater.
Contract Information
Contract Number DACA27-94-C-0300
Managing Organization U.S. Army Corps of Engineers
Organization Name Louisville District
Site Owner U.S. Army
Other ID Number
Prime Contractor Remediation Enhanced Developments, Inc. (RED)
Contract Type (Select one)
Cost + Award Fee
Cost + Base + Award Fee
Cost + Fixed Fee ü
Cost + Incentive Award
Fixed Price
Not Availiable
Other
Procurement Type (Select one)
Two Step Sealed Bid
Sealed Bid (IFB)
Competitive Negotiation (RFP) ü
Sole Source (SSC)
Other
Historical Cost Analysis System (HCAS)
Project Data Entry Form (Sheet 2)
Site Information
State/Country Ohio/USA
Installation Ft. Griffey
Site Name Landfill 5
Site Number
EPA Region V
Current Use (Select one)
Installation Operation ü
Industry Operation
Residential
Recreational
Wildlife Refuge
Waste Disposal
Administrative Office
Commercial
Other
Unknown
Future Use (Select one)
Installation Operation ü
Industry Operation
Residential
Recreational
Wildlife Refuge
Waste Disposal
Administrative Office
Commercial
Other
Unknown
Point of Contact
Data Entry Person POC#2 POC#3
Title/Role Contractor Estimator
Organization RED, Inc.
Name Joe Morgan
Address 535 Red Way
City, State Cincinnati, OH
Zip 99992
Telephone 555-111-2222
Fax 555-111-2223
Email [email protected]
Enter up to 3 POC's.
Historical Cost Analysis System (HCAS)
Project Data Entry Form (Sheet 3)
Cost
Start Date 10/19/1994
End Date 9/4/1995
Number of Mods 0
Reasons for Mods (Select those applicable)
Administrative
Changes for Time or Cost
Changes Requested by Government Authority
Design Deficiency
Differing Site Conditions
Funding Level Change
New Federal Regulation
Other Changes
Suspension or Termination of Work
Value Engineering Change
Variations in Estimated Quantities
Variations Not Readily Identifiable During Design
Cost
Award Amount $2,900,000
Actual Amount $3,195,695
Cost Variance +10%
Cost Breakdown
See next sheets.
The next sheets show the RA WBS and O&M WBS to the Third Level
as required for the HCAS cost report portion of the "RA Report".
The complete RA WBS and O&M WBS to the Fourth Level is at:
http://www.FRTR.gov/cost/ec2/wbs1.html
03 SITEWORK
03 01 Demolition SY
03 02 Clearing and Grubbing 3 ACR 1,161 3,482
03 03 Earthwork 2,420 CY 0.51 1,234
03 04 Roads/Parking/Curbs/Walks SY
03 05 Fencing LF
03 06 Electrical Distribution LF
03 07 Telephone/Communication Distribution LF
03 08 Water/Sewer/Gas Distribution LF
03 09 Steam and Condensate Distribution LF
03 10 Fuel Line Distribution LF
03 11 Storm Drainage/Subdrainage LF
03 12 Permanent Cover Structure Over Containment Area SF
03 13 Development of Borrow Pit/Haul Roads ACR
WBS Number DESCRIPTION QTY UOM UNIT COST $
COST
331XX 03 14 Fuel Storage Tanks (New) EA
03 9X Other (Use Numbers 90-99)
10 DRUMS/TANKS/STRUCTURES/MISCELLANEOUS
10 01 Drum Removal EA
10 02 Tank Removal EA
10 03 Structure Removal SF
10 04 Asbestos Abatement SF
10 05 Piping and Pipeline Removal LF
10 06 Radioactive Specific Waste Containment (Furnish/Fill) CY
10 07 Miscellaneous Items ACR
10 08 Contaminated Paint Removal SF
10 9x Other (Use Numbers 90-99)
11 BIOLOGICAL TREATMENT
11 01 Activated Sludge (Sequencing Batch Reactors) MGA
11 02 Rotating Biological Contactors MGA
11 03 Land Treatment/Farming (Solid Phase Biodegradation) CY
11 04 In-Situ Biodegradation/Bioreclamation CY
11 05 Trickling Filters MGA
11 06 Biological Lagoons MGA
11 07 Composting CY
11 08 Sludge Stabilization - Aerobic CY
11 09 Sludge Stabilization - Anaerobic CY
11 10 Genetically Engineered Organisms (White Rot Fungus) CY
11 11 Slurry Biodegradation CY
11 12 Bioventing SF
11 13 Bioslurping SF
11 14 Biopile (Heap Pile Remediation) CY
11 50 Construction of Permanent Plant Facility EA
11 9x Other (Use Numbers 90-99)
WBS Number DESCRIPTION QTY UOM UNIT COST $
COST
331XX 12 CHEMICAL TREATMENT
12 01 Oxidation/Reduction (Catalytic Oxidation, UV Ozone, MGA
12 02 Solvent Extraction MGA
12 03 Chlorination MGA
12 04 Ozonation MGA
12 05 Ion Exchange MGA
12 06 Neutralization MGA
12 07 Chemical Hydrolysis MGA
12 08 Ultraviolet Photolysis MGA
12 09 Dehalogenation (Catalytic Dechlorination) CY
12 10 Alkali Metal Dechlorination CY
12 11 Alkali Metal/Polyethylene Glycol (A/PEG) CY
12 12 Base-Catalyzed Decomposition Process (BCDP) CY
12 13 Electrolysis MGA
12 14 Vapor Recovery/Reuse (Internal Combustion Engine) CF
12 50 Construction of Permanent Plant Facility EA
12 9x Other (Use Numbers 90-99)
13 PHYSICAL TREATMENT
13 01 Filtration/Ultrafiltration MGA
13 02 Sedimentation MGA
13 03 Straining MGA
13 04 Coagulation/Flocculation/Precipitation MGA
13 05 Equalization MGA
13 06 Evaporation MGA
13 07 Air Stripping MGA
13 08 Steam Stripping MGA
13 09 Soil Washing (Surfactant/Solvent) CY
13 10 Soil Flushing (Surfactant/Solvent) CY
13 11 Solids Dewatering CY
13 12 Oil/Water Separation MGA
13 13 Dissolved Air Floatation MGA
13 14 Heavy Media Separation CY
13 15 Distillation MGA
13 16 Chelation MGA
13 17 Solvent Extraction MGA
13 18 Supercritical Extraction MGA
13 19 Carbon Adsorption - Gases CF
13 20 Carbon Adsorption - Liquids MGA
13 21 Membrane Separation - Reverse Osmosis MGA
13 22 Membrane Separation - Electrodialysis MGA
13 23 Soil Vapor Extraction 27,800 CY 16.22 451,031
13 24 Shredding CY
13 25 Aeration CY
13 26 Advanced Electrical Reactor CY
13 27 Low Level Waste (LLW) Compaction CY
13 28 Agglomeration CY
WBS Number DESCRIPTION QTY UOM UNIT COST $
COST
331XX 13 29 In-Situ Steam Extraction MGA
13 30 Filter Presses MGA
13 31 Lignin Adsorption/Sorptive Clays CY
13 32 Air Sparging 37,400 MGA 1.07 39,857
13 50 Construction of Permanent Plant Facility EA
13 9x Other (Use Numbers 90-99)
14 THERMAL TREATMENT
14 01 Incineration CY
14 02 Low Temperature Thermal Desorption CY
14 03 Supercritical Water Oxidation MGA
14 04 Molten Salt Destruction CY
14 05 Radio Frequency Heating CY
14 06 Solar Detoxification CY
14 07 High Temperature Thermal Desorption CY
14 50 Construction of Permanent Plant Facility EA
14 9x Other (Use Numbers 90-99)
15 STABILIZATION/FIXATION/ENCAPSULATION
15 01 Molten Glass CY
15 02 In-Situ Vitrification CY
15 03 In-Situ Pozzolan Process (Lime/Portland Cement) CY
15 04 Pozzolan Process (Lime/Portland Cement) CY
15 05 Asphalt-Based Encapsulation CY
15 06 Radioactive Waste Solidification (Grouting/Other) CY
15 07 Sludge Stabilization (Aggregate/Rock/Slag) CY
15 50 Construction of Permanent Plant Facility EA
15 9x Other (Use Numbers 90-99)
19 DISPOSAL (COMMERCIAL)
19 20 Container Handling 30 EA 60 1,800
19 21 Transportation to Storage/Disposal Facility TON
19 22 Disposal Fees and Taxes TON
19 23 Mixed Waste Storage Fees and Taxes TON
19 9x Other (Use Numbers 90-99) 1 LS 250 250
20 SITE RESTORATION
20 01 Earthwork 2,420 CY 1.86 4,501
20 02 Permanent Markers EA
20 03 Permanent Features EA
20 04 Revegetation and Planting 3 ACR 1,427 4,281
20 05 Removal of Barriers EA
20 9x Other (Use Numbers 90-99)
21 DEMOBILIZATION
21 01 Removal of Temporary Facilities EA
21 02 Removal of Temporary Utilities 1 EA 546 546
21 03 Final Decontamination EA
21 04 Demobilization of Construction Equipment and Facilities 1 EA 1,059 1,059
21 05 Demobilization of Personnel EA
21 06 Submittals 1 EA 5,788 5,788
21 07 Construction Plant Takedown EA
21 9x Other (Use Numbers 90-99)
03 SITEWORK
03 04 Roads/Parking/Curbs/Walks SY/YR
03 05 Fencing LF/YR
03 06 Electrical Distribution LF/YR
03 07 Telephone/Communication Distribution LF/YR
03 08 Water/Sewer/Gas Distribution LF/YR
03 09 Steam and Condensate Distribution LF/YR
03 10 Fuel Line Distribution LF/YR
03 11 Storm Drainage/Subdrainage LF/YR
03 12 Permanent Cover Structure Over Contaminated Area SF/YR
03 14 Fuel Storage Tanks (New) EA/YR
03 9X Other (Use Numbers 90-99)
11 BIOLOGICAL TREATMENT
11 01 Activated Sludge (Seq Batch Reactors) MGA
11 02 Rotating Biological Contactors MGA
11 03 Land Treatment/Farming (Solid Phase Biodegradation) CY
11 04 In-Situ Biodegradation/Bioreclamation CY
11 05 Trickling Filters MGA
11 06 Biological Lagoons MGA
11 07 Composting (Soil Pile Bioremediation) CY
11 08 Sludge Stabilization - Aerobic CY
11 09 Sludge Stabilization - Anaerobic CY
11 10 Genetically Engineered Organisms (White Rot Fungus) CY
11 11 Slurry Biodegradation CY
11 12 Bioventing SF
11 13 Bioslurping SF
11 14 Biopile (Heap Pile Remediation) CY
11 50 Post Construction O&M of Permanent Plant Facility EA/YR
11 9x Other (Use Numbers 90-99)
12 CHEMICAL TREATMENT
12 01 Oxidation/Reduction (Catalytic) MGA
12 02 Solvent Extraction MGA
12 03 Chlorination MGA
12 04 Ozonation MGA
12 05 Ion Exchange MGA
12 06 Neutralization MGA
12 07 Chemical Hydrolysis MGA
12 08 Ultraviolet Photolysis (UV Oxidation) MGA
12 09 Dehalogenation (Catalytic Dechlorination) CY
12 10 Alkali Metal Dechlorination CY
12 11 Alkali Metal/Polyethylene Glycol (A/PEG) CY
12 12 Base-Catalyzed Decomposition Process CY
12 13 Electrolysis MGA
12 14 Vapor Recovery/Reuse (Internal Combustion Engine) CF
12 50 Post Construction O&M of Permanent Plant Facility EA/YR
12 9x Other (Use Numbers 90-99)
13 PHYSICAL TREATMENT
13 01 Filtration/Ultrafiltration MGA
13 02 Sedimentation MGA
13 03 Straining MGA
13 04 Coagulation/Flocculation/Precipitation MGA
WBS Number DESCRIPTION QTY UOM UNIT COST
COST $
342XX 13 05 Equalization MGA
13 06 Evaporation MGA
13 07 Air Stripping MGA
13 08 Steam Stripping MGA
13 09 Soil Washing (Surfactant/Solvent) CY
13 10 Soil Flushing (Surfactant/Solvent) CY
13 11 Solids Dewatering CY
13 12 Oil/Water Separation MGA
13 13 Dissolved Air Floatation MGA
13 14 Heavy Media Separation CY
13 15 Distillation MGA
13 16 Chelation MGA
13 17 Solvent Extraction MGA
13 18 Supercritical Extraction MGA
13 19 Carbon Adsorption - Gases CF
13 20 Carbon Adsorption - Liquids MGA
13 21 Membrane Separation - Reverse Osmosis MGA
13 22 Membrane Separation - Electrodialysis MGA
13 23 Soil Vapor Extraction 27,800 CY 34.74 965,676
13 24 Shredding CY
13 25 Aeration CY
13 26 Advanced Electrical Reactor CY
13 27 Low Level Waste (LLW) Compaction CY
13 28 Agglomeration CY
13 29 In-Situ Steam Extraction MGA
13 30 Filter Presses MGA
13 31 Lignin Adsorption/Sorptive Clays CY
13 32 Air Sparging 37,400 MGA 17.15 641,409
13 50 Post Construction O&M of Permanent Plant Facility EA/YR
13 9x Other (Use Numbers 90-99)
14 THERMAL TREATMENT
14 01 Incineration CY
14 02 Low Temperature Thermal Desorption CY
14 03 Supercritical Water Oxidation MGA
14 04 Molten Salt Destruction CY
14 05 Radio Frequency Heating CY
14 06 Solar Detoxification CY
14 07 High Temperature Thermal Desorption CY
14 50 Post Construction O&M of Permanent Plant Facility EA/YR
14 9x Other (Use Numbers 90-99)
15 STABILIZATION/FIXATION/ENCAPSULATION
15 01 Molten Glass CY
WBS Number DESCRIPTION QTY UOM UNIT COST $
COST
342XX 15 02 In-Situ Vitrification CY
15 03 In-Situ Pozzolan Process (Lime/Portland Cement) CY
15 04 Pozzolan Process (Lime/Portland Cement) CY
15 05 Asphalt-Based Encapsulation CY
15 06 Radioactive Waste Solidification (Grouting/Other) CY
15 07 Sludge Stabilization (Aggregate/Rock/Slag) CY
15 50 Post Construction O&M of Permanent Plant Facility EA/YR
15 9x Other (Use Numbers 90-99)
APPENDIX D
COST REPORTING TEMPLATES
The following pages provide example summary sheets to report or estimate capital, O&M, and
periodic costs, either RA or post-RA, and templates for HCAS data entry using the HTRW RA
WBS for RA capital and RA operating costs that are required for input. These sheets should be
filled in with the required information and submitted (1 copy each) to the USACE HTRW Center
of Expertise and HQ USACE. Also provided is the HTRW O&M WBS shown to the third
(subsystem) level with columns for input of quantities and costs. The forms are available
electronically for downloading at http://www.environmental.usace.army.mil/info/technical/
cost/cost.html. Mailing addresses are as follows:
D-1
CAPITAL COST SUMMARY
Site: Description:
Location:
Phase:
Base Year:
Date:
QUAN- UNIT
DESCRIPTION TITY UNIT COST TOTAL NOTES
QUAN- UNIT
DESCRIPTION TITY UNIT COST TOTAL NOTES
QUAN- UNIT
DESCRIPTION TITY UNIT COST TOTAL NOTES
Project Information
Project Name
Project Number
Project Phase (Select one)
Studies and Design
Remedial Action
Operations and Maintenance
Project Note (Describe the project)
Contract Information
Contract Number
Managing Organization
Organization Name
Site Owner
Other ID Number
Prime Contractor
Contract Type (Select one)
Cost + Award Fee
Cost + Base + Award Fee
Cost + Fixed Fee
Cost + Incentive Award
Fixed Price
Not Availiable
Other
Procurement Type (Select one)
Two Step Sealed Bid
Sealed Bid (IFB)
Competitive Negotiation (RFP)
Sole Source (SSC)
Other
Historical Cost Analysis System (HCAS)
Project Data Entry Form (Sheet 2)
Site Information
State/Country
Installation
Site Name
Site Number
EPA Region
Current Use (Select one)
Installation Operation
Industry Operation
Residential
Recreational
Wildlife Refuge
Waste Disposal
Administrative Office
Commercial
Other
Unknown
Future Use (Select one)
Installation Operation
Industry Operation
Residential
Recreational
Wildlife Refuge
Waste Disposal
Administrative Office
Commercial
Other
Unknown
Point of Contact
Data Entry Person POC#2 POC#3
Title/Role
Organization
Name
Address
City, State
Zip
Telephone
Fax
Email
Enter up to 3 POC's.
Historical Cost Analysis System (HCAS)
Project Data Entry Form (Sheet 3)
Cost
Start Date
End Date
Number of Mods
Reasons for Mods (Select those applicable)
Administrative
Changes for Time or Cost
Changes Requested by Government Authority
Design Deficiency
Differing Site Conditions
Funding Level Change
New Federal Regulation
Other Changes
Suspension or Termination of Work
Value Engineering Change
Variations in Estimated Quantities
Variations Not Readily Identifiable During Design
Cost
Award Amount
Actual Amount
Cost Variance
Cost Breakdown
See next sheets.
The next sheets show the RA WBS and O&M WBS to the Third Level
as required for the HCAS cost report portion of the "RA Report".
The complete RA WBS and O&M WBS to the Fourth Level is at:
http://www.FRTR.gov/cost/ec2/wbs1.html
03 SITEWORK
03 01 Demolition SY
03 02 Clearing and Grubbing ACR
03 03 Earthwork CY
03 04 Roads/Parking/Curbs/Walks SY
03 05 Fencing LF
03 06 Electrical Distribution LF
03 07 Telephone/Communication Distribution LF
03 08 Water/Sewer/Gas Distribution LF
03 09 Steam and Condensate Distribution LF
03 10 Fuel Line Distribution LF
03 11 Storm Drainage/Subdrainage LF
03 12 Permanent Cover Structure Over Containment Area SF
03 13 Development of Borrow Pit/Haul Roads ACR
WBS Number DESCRIPTION QTY UOM UNIT COST
COST $
331XX 03 14 Fuel Storage Tanks (New) EA
03 9X Other (Use Numbers 90-99)
10 DRUMS/TANKS/STRUCTURES/MISCELLANEOUS
10 01 Drum Removal EA
10 02 Tank Removal EA
10 03 Structure Removal SF
10 04 Asbestos Abatement SF
10 05 Piping and Pipeline Removal LF
10 06 Radioactive Specific Waste Containment (Furnish/Fill) CY
10 07 Miscellaneous Items ACR
10 08 Contaminated Paint Removal SF
10 9x Other (Use Numbers 90-99)
11 BIOLOGICAL TREATMENT
11 01 Activated Sludge (Sequencing Batch Reactors) MGA
11 02 Rotating Biological Contactors MGA
11 03 Land Treatment/Farming (Solid Phase Biodegradation) CY
11 04 In-Situ Biodegradation/Bioreclamation CY
11 05 Trickling Filters MGA
11 06 Biological Lagoons MGA
11 07 Composting CY
11 08 Sludge Stabilization - Aerobic CY
11 09 Sludge Stabilization - Anaerobic CY
11 10 Genetically Engineered Organisms (White Rot Fungus) CY
11 11 Slurry Biodegradation CY
11 12 Bioventing SF
11 13 Bioslurping SF
11 14 Biopile (Heap Pile Remediation) CY
11 50 Construction of Permanent Plant Facility EA
11 9x Other (Use Numbers 90-99)
WBS Number DESCRIPTION QTY UOM UNIT COST
COST $
331XX 12 CHEMICAL TREATMENT
12 01 Oxidation/Reduction (Catalytic Oxidation, UV Ozone, MGA
12 02 Solvent Extraction MGA
12 03 Chlorination MGA
12 04 Ozonation MGA
12 05 Ion Exchange MGA
12 06 Neutralization MGA
12 07 Chemical Hydrolysis MGA
12 08 Ultraviolet Photolysis MGA
12 09 Dehalogenation (Catalytic Dechlorination) CY
12 10 Alkali Metal Dechlorination CY
12 11 Alkali Metal/Polyethylene Glycol (A/PEG) CY
12 12 Base-Catalyzed Decomposition Process (BCDP) CY
12 13 Electrolysis MGA
12 14 Vapor Recovery/Reuse (Internal Combustion Engine) CF
12 50 Construction of Permanent Plant Facility EA
12 9x Other (Use Numbers 90-99)
13 PHYSICAL TREATMENT
13 01 Filtration/Ultrafiltration MGA
13 02 Sedimentation MGA
13 03 Straining MGA
13 04 Coagulation/Flocculation/Precipitation MGA
13 05 Equalization MGA
13 06 Evaporation MGA
13 07 Air Stripping MGA
13 08 Steam Stripping MGA
13 09 Soil Washing (Surfactant/Solvent) CY
13 10 Soil Flushing (Surfactant/Solvent) CY
13 11 Solids Dewatering CY
13 12 Oil/Water Separation MGA
13 13 Dissolved Air Floatation MGA
13 14 Heavy Media Separation CY
13 15 Distillation MGA
13 16 Chelation MGA
13 17 Solvent Extraction MGA
13 18 Supercritical Extraction MGA
13 19 Carbon Adsorption - Gases CF
13 20 Carbon Adsorption - Liquids MGA
13 21 Membrane Separation - Reverse Osmosis MGA
13 22 Membrane Separation - Electrodialysis MGA
13 23 Soil Vapor Extraction CY
13 24 Shredding CY
13 25 Aeration CY
13 26 Advanced Electrical Reactor CY
13 27 Low Level Waste (LLW) Compaction CY
13 28 Agglomeration CY
WBS Number DESCRIPTION QTY UOM UNIT COST
COST $
331XX 13 29 In-Situ Steam Extraction MGA
13 30 Filter Presses MGA
13 31 Lignin Adsorption/Sorptive Clays CY
13 32 Air Sparging MGA
13 50 Construction of Permanent Plant Facility EA
13 9x Other (Use Numbers 90-99)
14 THERMAL TREATMENT
14 01 Incineration CY
14 02 Low Temperature Thermal Desorption CY
14 03 Supercritical Water Oxidation MGA
14 04 Molten Salt Destruction CY
14 05 Radio Frequency Heating CY
14 06 Solar Detoxification CY
14 07 High Temperature Thermal Desorption CY
14 50 Construction of Permanent Plant Facility EA
14 9x Other (Use Numbers 90-99)
15 STABILIZATION/FIXATION/ENCAPSULATION
15 01 Molten Glass CY
15 02 In-Situ Vitrification CY
15 03 In-Situ Pozzolan Process (Lime/Portland Cement) CY
15 04 Pozzolan Process (Lime/Portland Cement) CY
15 05 Asphalt-Based Encapsulation CY
15 06 Radioactive Waste Solidification (Grouting/Other) CY
15 07 Sludge Stabilization (Aggregate/Rock/Slag) CY
15 50 Construction of Permanent Plant Facility EA
15 9x Other (Use Numbers 90-99)
19 DISPOSAL (COMMERCIAL)
19 20 Container Handling EA
19 21 Transportation to Storage/Disposal Facility TON
19 22 Disposal Fees and Taxes TON
19 23 Mixed Waste Storage Fees and Taxes TON
19 9x Other (Use Numbers 90-99)
20 SITE RESTORATION
20 01 Earthwork CY
20 02 Permanent Markers EA
20 03 Permanent Features EA
20 04 Revegetation and Planting ACR
20 05 Removal of Barriers EA
20 9x Other (Use Numbers 90-99)
21 DEMOBILIZATION
21 01 Removal of Temporary Facilities EA
21 02 Removal of Temporary Utilities EA
21 03 Final Decontamination EA
21 04 Demobilization of Construction Equipment and Facilities EA
21 05 Demobilization of Personnel EA
21 06 Submittals EA
21 07 Construction Plant Takedown EA
21 9x Other (Use Numbers 90-99)
TOTAL AMOUNT $
WBS Number DESCRIPTION QTY UOM UNIT COST
COST $
34XXX HTRW POST CONSTRUCTION AND FINANCIAL
CLOSEOUT ACTIVITIES
341XX FISCAL/FINANCIAL CLOSE ACTIVITIES
342XX HTRW OPERATION AND MAINTENANCE (POST
CONSTRUCTION)
03 SITEWORK
03 04 Roads/Parking/Curbs/Walks SY/YR
03 05 Fencing LF/YR
03 06 Electrical Distribution LF/YR
03 07 Telephone/Communication Distribution LF/YR
03 08 Water/Sewer/Gas Distribution LF/YR
03 09 Steam and Condensate Distribution LF/YR
03 10 Fuel Line Distribution LF/YR
03 11 Storm Drainage/Subdrainage LF/YR
03 12 Permanent Cover Structure Over Contaminated Area SF/YR
03 14 Fuel Storage Tanks (New) EA/YR
03 9X Other (Use Numbers 90-99)
11 BIOLOGICAL TREATMENT
11 01 Activated Sludge (Seq Batch Reactors) MGA
11 02 Rotating Biological Contactors MGA
WBS Number DESCRIPTION QTY UOM UNIT COST
COST $
342XX 11 03 Land Treatment/Farming (Solid Phase Biodegradation) CY
11 04 In-Situ Biodegradation/Bioreclamation CY
11 05 Trickling Filters MGA
11 06 Biological Lagoons MGA
11 07 Composting (Soil Pile Bioremediation) CY
11 08 Sludge Stabilization - Aerobic CY
11 09 Sludge Stabilization - Anaerobic CY
11 10 Genetically Engineered Organisms (White Rot Fungus)
CY
11 11 Slurry Biodegradation CY
11 12 Bioventing SF
11 13 Bioslurping SF
11 14 Biopile (Heap Pile Remediation) CY
11 50 Post Construction O&M of Permanent Plant Facility EA/YR
11 9x Other (Use Numbers 90-99)
12 CHEMICAL TREATMENT
12 01 Oxidation/Reduction (Catalytic) MGA
12 02 Solvent Extraction MGA
12 03 Chlorination MGA
12 04 Ozonation MGA
12 05 Ion Exchange MGA
12 06 Neutralization MGA
12 07 Chemical Hydrolysis MGA
12 08 Ultraviolet Photolysis (UV Oxidation) MGA
12 09 Dehalogenation (Catalytic Dechlorination) CY
12 10 Alkali Metal Dechlorination CY
12 11 Alkali Metal/Polyethylene Glycol (A/PEG) CY
12 12 Base-Catalyzed Decomposition Process CY
12 13 Electrolysis MGA
12 14 Vapor Recovery/Reuse (Internal Combustion Engine) CF
12 50 Post Construction O&M of Permanent Plant Facility EA/YR
12 9x Other (Use Numbers 90-99)
13 PHYSICAL TREATMENT
13 01 Filtration/Ultrafiltration MGA
13 02 Sedimentation MGA
13 03 Straining MGA
13 04 Coagulation/Flocculation/Precipitation MGA
13 05 Equalization MGA
13 06 Evaporation MGA
13 07 Air Stripping MGA
13 08 Steam Stripping MGA
13 09 Soil Washing (Surfactant/Solvent) CY
13 10 Soil Flushing (Surfactant/Solvent) CY
13 11 Solids Dewatering CY
13 12 Oil/Water Separation MGA
WBS Number DESCRIPTION QTY UOM UNIT COST
COST $
342XX 13 13 Dissolved Air Floatation MGA
13 14 Heavy Media Separation CY
13 15 Distillation MGA
13 16 Chelation MGA
13 17 Solvent Extraction MGA
13 18 Supercritical Extraction MGA
13 19 Carbon Adsorption - Gases CF
13 20 Carbon Adsorption - Liquids MGA
13 21 Membrane Separation - Reverse Osmosis MGA
13 22 Membrane Separation - Electrodialysis MGA
13 23 Soil Vapor Extraction CY
13 24 Shredding CY
13 25 Aeration CY
13 26 Advanced Electrical Reactor CY
13 27 Low Level Waste (LLW) Compaction CY
13 28 Agglomeration CY
13 29 In-Situ Steam Extraction MGA
13 30 Filter Presses MGA
13 31 Lignin Adsorption/Sorptive Clays CY
13 32 Air Sparging MGA
13 50 Post Construction O&M of Permanent Plant Facility EA/YR
13 9x Other (Use Numbers 90-99)
14 THERMAL TREATMENT
14 01 Incineration CY
14 02 Low Temperature Thermal Desorption CY
14 03 Supercritical Water Oxidation MGA
14 04 Molten Salt Destruction CY
14 05 Radio Frequency Heating CY
14 06 Solar Detoxification CY
14 07 High Temperature Thermal Desorption CY
14 50 Post Construction O&M of Permanent Plant Facility EA/YR
14 9x Other (Use Numbers 90-99)
15 STABILIZATION/FIXATION/ENCAPSULATION
15 01 Molten Glass CY
15 02 In-Situ Vitrification CY
15 03 In-Situ Pozzolan Process (Lime/Portland Cement) CY
15 04 Pozzolan Process (Lime/Portland Cement) CY
15 05 Asphalt-Based Encapsulation CY
15 06 Radioactive Waste Solidification (Grouting/Other) CY
15 07 Sludge Stabilization (Aggregate/Rock/Slag) CY
15 50 Post Construction O&M of Permanent Plant Facility EA/YR
15 9x Other (Use Numbers 90-99)
TOTAL AMOUNT $