UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

August 25, 2004

OFFICE OF

SOLID WASTE AND EMERGENCY

RESPONSE

 OSWER 9283.1-25

MEMORANDUM

SUBJECT: Distribution of the final “Action Plan for Ground Water Remedy Optimization”

FROM: Michael B. Cook, Director /s/

Office of Superfund Remediation and Technology Innovation

TO: Superfund National Policy Managers, Regions 1-10

OSWER Office Directors

PURPOSE

The purpose of this memorandum is to transmit to you the final “Action Plan for Ground

Water Remedy Optimization.” The Office of Superfund Remediation and Technology

Innovation (OSRTI) developed this action plan in order to demonstrate our strong commitment

to effective management of our long-term remedies. This final version incorporates recent

comments from Regional management requesting flexibility with the implementation of sitespecific recommendations, and expressing concern over the budget implications of the Regions

performing their own optimization reviews. This final plan suggests that the Regions pursue

their own reviews where candidate sites exist, and we will work with you to ensure funding is

available. 

IMPLEMENTATION

The efforts outlined in the attached action plan will focus on applying important lessons

learned in order to fully integrate optimization into the Superfund cleanup process. Regular

reviews of operating remedies, such as optimization reviews, is just one example of the

Environmental Management Systems (EMS) approach involving a continuous cycle of planning,

implementing, reviewing and improving practices at each site. Our new attention to the routine

optimization of operating treatment systems, as well as increased oversight of Regional funding

requests, will result in improved system efficiency and reduced LTRA costs.
CONCLUSION 

We greatly appreciate the time and attention that you and your staff have given to remedy 

optimization. The latest documents on optimization can be found on the internet at the following 

addresses: http://www.epa.gov/superfund/action/postconstruction/optimize.htm or 

http://www.cluin.org/optimization/. The OSRTI points of contact on optimization are Jennifer 

Griesert, Assessment and Remediation Division (ARD) at (703) 603-8888, and Kathy Yager, 

Technology Innovation and Field Services Division (TIFSD) at (617) 918-8362. 

Attachment 

cc: OSRTI Managers 

Nancy Riveland, Superfund Lead Region Coordinator, USEPA Region 9 

Eric Steinhaus, FY05 Superfund Lead Region Coordinator, USEPA Region 8 

NARPM Co-Chairs 

Joanna Gibson, OSRTI Documents Coordinator 

Robert Springer, Senior Advisor to OSWER AA 

Jim Woolford, FFRRO 

Debbie Dietrich, OEPPR 

Matt Hale, OSW 

Cliff Rothenstein, OUST 

Linda Garczynski, OBCR 

Earl Salo, OGC 

Charles Openchowski, OGC 

Dave Kling, FFEO 

Susan Bromm, OSRE 
OSWER 9283.1-25 

Action Plan for Ground Water Remedy Optimization 

The Office of Solid Waste and Emergency Response (OSWER) developed the pilot Fundlead Pump and Treat (P&T) optimization initiative as part of the FY2000-FY2001 Superfund 

Reforms Strategy, dated July 7, 2000 (OSWER 9200.0-33). The optimization initiative intended 

to encourage systematic review and modification to existing P&T systems to promote continuous 

improvement and to enhance overall remedy and cost effectiveness. To date, EPA has conducted 

Remediation System Evaluations (RSEs) at 29 Superfund sites, as well as several sites regulated 

by the Resource Conservation and Recovery Act (RCRA) and Underground Storage Tank (UST) 

programs. The information presented in this action plan only addresses private sites regulated by 

the Superfund program, particularly Fund-lead sites. Additional background information on the 

pilot optimization effort and lessons learned is available on the internet at the following addresses: 

http://www.epa.gov/superfund/action/postconstruction/optimize.htm or 

http://www.cluin.org/optimization/. 

The pilot phase of the optimization initiative demonstrated that this effort offers 

measurable benefits in the form of cost savings and improved remediation systems. This action 

plan will focus on applying important lessons learned in order to fully integrate optimization into 

the Superfund cleanup process. In order to promote this integration we will carry out the 

following activities: 

• Conduct additional optimization reviews at high priority, Fund-lead sites, 

• Provide funding for the implementation of recommended system changes, 

• Monitor implementation progress in the Regions, 

• Develop appropriate guidance and training tools, 

• Coordinate with State counterparts and responsible parties (RPs), and 

• Establish a network of Regional Optimization Liaisons. 

Additional Optimization Reviews at High Priority Sites 

OSRTI expects to fund independent, technical experts to conduct Remediation System 

Evaluations (RSEs) at 5-8 high priority, Fund-lead sites each year (depending on available 

resources). We will collect updated information from the Regions on cost and performance of 

operating Fund-lead pump and treat (P&T) systems in order to select sites for future RSEs. A 

scaled-down version of the RSE (referred to as an “RSE-lite”) may be used at the least complex 

sites undergoing optimization, in order to conserve resources while increasing the number of sites 

to receive reviews. 

In addition to these OSRTI-led reviews, each Region is expected to develop an approach 

for targeting their high cost sites for optimization. Each Region should pursue an RSE at a 

minimum of one site each year, where suitable candidate sites exist. In situations where funding 

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OSWER 9283.1-25

limitations inhibit a Region’s ability to conduct their own RSE, the Region should alert OSRTI. 

The Regions should ensure that evaluations are done in an independent manner and not directly by 

system operators. Contractual access to OSRTI’s RSE experts will be made available to the 

Regions for this purpose, if needed. OSRTI points-of-contact for these issues are provided at the 

end of this Action Plan. 

Our approach for selecting sites to receive future RSEs will include, at a minimum, a 

review of annual operating costs, the age of the system, and concerns for remedy protectiveness 

and system efficiency. Ground water remedies with the highest annual operating costs are the 

Superfund program’s highest priority for RSEs, because these sites likely offer the greatest 

opportunities for cost savings and increased efficiency for both EPA and the States. Furthermore, 

RSEs may be most appropriate at systems that have been operating for two to four years, in order 

to maximize early opportunities for improvements and cost savings. In setting priorities, OSRTI 

will carefully consider the timing of RSEs to ensure that recommended system changes are 

addressed before transferring sites to States for continued operation and maintenance (O&M). 

In addition to cost savings, optimization is intended to identify opportunities to improve 

remedy effectiveness. Regardless of annual operating costs or the age of the system, site 

managers are encouraged to recommend sites for optimization if there are concerns about the 

protectiveness of the remedy or the efficiency of the P&T system (e.g., significant system 

downtime, evidence that the plume is not contained, or continuing sources of contamination are 

present). Regions should consider whether an RSE will help address Five-Year Review 

recommendations related to plume containment or P&T system effectiveness. 

Priority Funding for Implementation of Recommendations 

OSRTI is fully committed to funding system changes at Fund-lead sites that result from an 

RSE in order to ensure that the Superfund program is operating the most efficient and effective 

remedies possible. Optimization-related site activities will receive priority funding, typically from 

the ongoing Remedial Action (RA) Advice of Allowance (AOA). The Regions should request 

ongoing RA funds as part of the current budget process. The Regions may need to perform 

additional characterization or design work in some situations. These funds may also come from 

the RA budget, if approved by HQ, or from the Regional Pipeline AOA.

 Site-specific progress in optimization implementation will be a significant factor in 

addressing Regional funding requests. OSRTI will carefully examine the basis of funding 

requests for sites where the Region has not demonstrated a commitment to address 

recommendations that may result in significant enhancements or cost savings. Due to funding 

limitations, we are not in a position to continue funding non-optimized systems at the same levels 

as previous years. The status of the Region’s additional evaluations will also be considered when 

reviewing funding requests. Regions are encouraged to identify funding needs for the 

implementation of RSE recommendations during semi-annual work planning discussions. 

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OSWER 9283.1-25

Monitoring Implementation Progress 

Annual follow-up discussions between OSRTI and the Regions are very valuable, 

highlighting the outcome of each recommendation and obstacles to implementation that require 

additional attention. These discussions also address the March 2003 Office of Inspector General 

(OIG) evaluation of the optimization initiative, in which the OIG recommended a systematic 

approach to monitoring implementation efforts (“Improving Nationwide Effectiveness of Pumpand-Treat Remedies Requires Sustained and Focused Action to Realize Benefits” Report 2002-

0000326). Our continuous oversight of Regional progress at RSE sites is necessary to ensure the 

Superfund program is operating the most efficient and effective remedies possible. 

Each site that receives an optimization review will be the subject of annual OSRTI/Region 

conference calls for at least two years after the RSE report is finalized. Conference call 

participants will typically include the Remedial Project Manager (RPM), Regional Optimization 

Liaison (details below), State project manager, OSRTI staff, and the RSE contractor. In an effort 

to increase awareness and accountability for the optimization effort, Regional management 

(Section or Branch Chief, as appropriate) will be included in these discussions as well. Site 

managers should be prepared to discuss the status of RSE recommendations as well as associated 

cost savings or expenditures. We will also ask for projected annual operating costs so that trends 

in costs can be documented before and after optimization. We will compile an annual summary of 

the follow-up discussions in order to document overall implementation progress. 

OSRTI recognizes that RSEs generate a number of suggestions, ideas and 

recommendations which need to be discussed and evaluated. Regions weigh many factors 

including, but not limited to, technical feasibility, short-term implementation issues, long-term 

benefits, public and State acceptance, contractual requirements, protectiveness and availability of 

funding when determining whether to implement optimization recommendations. Significant 

disagreements regarding the implementation of a significant cost-saving recommendation may be 

elevated to the Regional Division Director and Director of OSRTI for resolution. 

OSRTI anticipates that considerable progress will be made at most sites after two years of 

follow-up. Beyond two years, our oversight of implementation efforts will focus on 

recommendations of particular concern that have not been appropriately addressed. Technical 

assistance will still be available to RPMs to aid in the implementation of system changes. This 

assistance may include a variety of efforts by the RSE team, such as an independent review of a 

work plan for implementing recommendations, an evaluation of the outcome of recommended 

changes, or justification of cost estimates provided in the RSE report. 

Developing Tools to Support Optimization 

OSRTI is currently developing a variety of technical tools to apply lessons learned and 

overcome implementation obstacles identified during the pilot initiative. Once completed, we will 

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OSWER 9283.1-25

encourage the Regions to apply these tools during routine management of all P&T systems, 

regardless of whether the site received an RSE. The first of these tools is the fact sheet “Elements 

for Effective Management of Operating Pump and Treat Systems” (EPA 542-R-02-009, December 

2002) which is a comprehensive review of the most common deficiencies in the management of 

P&T systems that were identified through optimization. 

Many of the other efforts underway are intended to elaborate on the 2002 fact sheet. The 

products identified below are expected to be available to site managers by the end of FY04, and 

several additional efforts are underway. We will continue to identify new tools to assist the 

Regions in operating the most efficient remedies possible. The latest documents on optimization 

can always be found on the internet at the following addresses: 

http://www.cluin.org/optimization/ or 

http://www.epa.gov/superfund/action/postconstruction/optimize.htm. 

• Cost-Effective Design of Pump and Treat Systems (EPA 542-R-04-007) 

• Effective Contracting Approaches for Operating Pump and Treat Systems (EPA 542-R-04-

005) 

• O&M Report Template for Ground Water Remedies (With Emphasis on Pump and Treat 

Systems) (EPA 542-R-04-006) 

• A Systematic Approach for Evaluation of Capture Zones at Pump and Treat Sites (in 

progress) 

• Ground Water Remediation Optimization: Benefits and Approaches (OSWER 9283.1-

17FS, in review) 

Coordination with State Counterparts 

Site managers are expected to closely coordinate all optimization efforts with their 

appropriate State counterparts. OSRTI expects to include State project managers in the RSE site 

visit and interview process, as well as the annual follow-up discussions. RPMs should consult 

with their State counterparts throughout the implementation of optimization recommendations. 

The majority of Fund-lead sites that receive optimization reviews will be in the LTRA 

phase of the remedial pipeline, which allows for ten years of Fund-lead system operation at 

ground water restoration sites. At the end of this period, EPA expects to transfer an effective 

remedy to the State for O&M. Early and frequent communication between EPA and the State 

regarding optimization recommendations and potential system changes will allow for a smooth 

transition at the end of the ten-year LTRA period. In some situations, optimization efforts may 

necessitate revisions to the scope of an existing State Superfund Contract (SSC). Additional 

information regarding optimization considerations during LTRA can be found in the fact sheet 

Transfer of Long-Term Response Action (LTRA) Projects to States (EPA 540-F-01-021, July 

2003). 

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OSWER 9283.1-25

Applicability to Responsible Party Sites 

EPA conducted optimization reviews at a number of active facilities and responsible party 

(RP) sites in addition to the Fund-lead sites that were the focus of the pilot initiative. These 

reviews demonstrated that similar opportunities for system improvements and cost savings exist at 

RP sites. Responsible parties can also benefit from the many technical tools currently under 

development to address lessons learned from optimization. 

Regions are encouraged to work with responsible parties to identify opportunities to 

improve remedy effectiveness, where practicable. When evaluating optimization opportunities at 

responsible party sites, site managers should consider the following, on a case-by-case basis: 

• concerns about the protectiveness of the remedy or the efficiency of the P&T system, 

• any relevant information provided by the responsible party, including the impacts of 

system changes suggested by the RP, 

• whether the RP has been cooperative in carrying out the terms and conditions of the site 

agreement to conduct remedial work, and 

• revisions to the site agreement and decision documents as a result of system changes. 

Maintaining a Network of Optimization Liaisons 

At the start of the pilot optimization initiative, staff in each Region volunteered to serve as 

points of contact for the project. A current list of liaisons is provided below. These Regional 

Optimization Liaisons will continue to play an important role as the Regions and OSRTI work 

together in fully integrating optimization into the cleanup process. The liaisons represent a cross 

section of program staff, including RPMs, Ground Water Forum members, hydrogeologists and 

other interested individuals. Appropriate OSRTI contacts are also included in the table below. 

Regional liaisons are particularly helpful in gathering information on sites that may benefit 

from optimization. The liaisons should contact OSRTI whenever they identify a P&T site with 

system protectiveness or efficiency concerns. We also depend on the liaisons to provide guidance 

or technical assistance to RPMs on the implementation of RSE recommendations, and to 

participate in the annual followup discussions described above. Finally, we will work closely with 

the Regional Optimization Liaisons to promote national consistency and increase awareness of 

optimization. Above all, support from the Regional Optimization Liaisons is essential to the 

successful implementation of this action plan. 

Regions should contact the OSRTI staff listed below with any questions or concerns 

related to remedy optimization. These staff are able to assist the Regions in many ways, including 

the identification of appropriate RSE candidate sites, providing access to contractors with 

optimization expertise, and providing technical or programmatic assistance with the 

implementation of RSE recommendations. 

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OSWER 9283.1-25 

Headquarters and Regional Optimization Liaisons 

Location Optimization Liaison Telephone 

HQ/OSRTI Jennifer Griesert 

(Assessment & Remediation Division) 

Kathy Yager 

(Technology Innovation & Field Services Division) 

(703) 603-8888 

(617) 918-8362 

Region 1 Darryl Luce (617) 918-1336 

Region 2 Rob Alvey 

Diana Cutt 

(212) 637-3258 

(212) 637-4311 

Region 3 Kathy Davies (215) 814-3315 

Region 4 Kay Wischkaemper (404) 562-8641 

Region 5 Dion Novak (312) 886-4737 

Region 6 Vince Malott (214) 665-8313 

Region 7 Dave Drake (913) 551-7626 

Region 8 Helen Dawson (303) 312-7841 

Region 9 Herb Levine (415) 972-3062 

Region 10 Bernie Zavala (206) 553-1562 

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