Remedy Optimization Projects
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Remedy Optimization Projects
Acme Solvent Reclaiming, Inc. Site – Rockford, Illinois – One component of the remedy selected in the Record of Decision for the Acme Solvents Reclaiming, Inc. site involved on-site treatment of soil and sludge utilizing a low temperature thermal stripping (LTTS) process to remove organics and PCBs, followed by solidification and stabilization of treated LTTS residuals to meet RCRA Treatability Variance Standards required for on-site disposal of soil and debris. The Acme Solvents RD/RA Group realized a savings of approximately $1.7 million during implementation of the LTTS remedy component as a result of NES management on this project. NES identified a lower cost alternative LTTS technology for use at the site and assisted the Group in negotiating contract terms that placed the risk for the success of the technology on the Contractor.
Additionally, material containing high concentrations of organic and inorganic compounds were uncovered. NES’ analysis of the problem material indicated that treatment of these highly concentrated materials using the LTTS process would reduce production rates and increase the volume of LTTS residuals requiring solidification/stabilization treatment. The planned on-site treatment of this material would have resulted in a significant cost increase to the PRPs. NES successfully petitioned the US EPA to modify the ROD through the Explanation of Significant Difference provisions under CERCLA permitting the concentrated material to be treated off-site by incineration.
Hardage-Criner Superfund Site – Lindsay, Oklahoma
Reducing the Number of Mounds Liquids Recovery Wells – The preliminary design presented to the Court contemplated 68 liquid recovery wells in the Barrel Mound and Main Pit source areas on the site. Pre-design studies indicated that as few as 16 recovery wells could be used to effectively remove all recoverable liquids from the Barrel Mound and Main Pit source areas. NES, working with the design firm and HSRC counsel, presented the data from the pre-design studies to EPA Region VI and ODEQ and successfully reduced the number of mounds liquids recovery wells from 68 to 16. This resulted in a significant cost savings (estimated at over $30,000 per well in installation costs alone) to the Hardage PRPs. A portion of NES’ responsibility was to develop and implement a strategy to negotiate successfully this revision with EPA and state officials.
“Bottom Mass” Exclusion – During the pre-design studies, a 2- to 3-foot layer of a viscous, tarry waste-sediment mixture was identified at the bottom of the Barrel Mound and Main Pit source areas. While the Court had ordered the removal of the “pumpable liquids” from the Barrel Mound and Main Pit, this “bottom mass” was not pumpable using traditional liquid pump technology. If the HSRC had to remove this “bottom mass,” the only available recovery method for removing the bottom mass from the Barrel Mound and Main Pit area would expose personnel to health and safety risks that would have been unnecessarily high relative to the marginal benefits of additional recovery. NES, working with the design firm and HSRC counsel, presented the data from the pre-design studies to EPA Region VI and ODEQ and successfully convinced them and the Court that the bottom mass could be left in place, and no further attempts at removal of the material was necessary.
Chemtronics Site – Swannanoa, North Carolina – NES performed a Quality Assurance (QA) evaluation for the total remedy operation and maintenance activities at the Chemtronics Site. Overall, the objective of the QA evaluation was to identify conditions which may be limiting implementation of the site remedy in a timely and cost effective manner and, where appropriate, provide recommendations for optimizing such conditions. The PRP Group’s concerns regarding the current status of remedy operations were in part due to comments received from US EPA Region IV, which indicated that groundwater was not consistently being removed at a sufficient rate to maintain continual capture, and thus were considering a requirement for a back-up system. NES discovered that physical characteristics of the groundwater, which included suspended solids content, total organic carbon content, low pH, and foaming, limit the treatment capacity of the process equipment, thus reducing the rate at which groundwater could be extracted and treated. The treatment system operation inefficiency required an increased level of attention to operate and maintain the remediation system. The system was found to be operating in a significantly reduced capacity due to failure of the input/output blocks, further limiting the efficiency of the groundwater remediation system operations and contributing to the need for increased operation and maintenance efforts. NES developed comprehensive recommendations for resolving the operational problems experienced in the groundwater remediation system and Data Acquisition System.