About this file

This is a template and guidance document for reporting optimization activities related to environmental remediation contracts at federal installations. The document provides a standardized format for contractors to report on remedial activities and performance monitoring conducted above and beyond compliance requirements across reporting periods.

The template requires contractors to identify the installation name, site ID, and reporting period, then select the applicable site performance objective (Reduce Life Cycle Cost [LCC] & Remedial Action Objectives [RA-O], Reduce LCC & Long-Term Monitoring [LTM], Operational and Environmental Services [OES], or Alternate/Other objectives). Contractors must document four primary sections: (1) Optimization Activities Implemented with specific details and supporting data through tables, plots, figures, or photos; (2) Optimization Outcomes demonstrating reductions in contaminant mass, concentrations, or LCC, or acceleration toward remedial closure; (3) Issues/Obstacles Encountered that may impact schedule; and (4) Planned Optimization Activities for the next reporting period. The document provides detailed Key Optimization Elements across four categories: Site Understanding (identifying data gaps, conducting strategic sampling, focusing on source control); Design Optimization Review (evaluating remedy effectiveness, addressing source uncertainties, installing nested wells); Remedy Process Optimization (covering in situ treatments such as Enhanced Reductive Dechlorination and ex situ treatments such as Pump and Treat); and Monitoring Optimization (including performance monitoring, compliance documentation, and data management improvements). The guidance references applicable regulatory frameworks (ARARs, RAOs) and decision documents (Explanations of Significant Differences, Record of Decision Amendments) that may require modification to improve remedy efficiency.

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OPTIMIZATION EXAMPLES

AFIID_SITEID_CPSMR##_OB##-MMMYYYY

(e.g., MOODY_OT012_CPSMR12_OB01-DEC2020)

Installation Name: (e.g., Moody AFB) Site ID: (e.g., OT012) Reporting Period: (e.g., 1 May 2020 – 30 April 2021)

Site Performance Objective at the Time of Contract Award:

Reduce LCC

& RA-O

☐ Reduce LCC &

LTM

☐ OES ☐ Alternate Objective

☐ Other Site Categories

Optimization activities are defined as any remedial activities and performance monitoring above and beyond what is required to maintain compliance in accordance with an approved decision document.

Optimization Activities Implemented:

1. Describe specific details of optimization activities (see Key Optimization Elements)

Optimization Outcome(s):

1. Results in: a) reduction in contaminant mass, b) reduction in contaminant concentrations,

c) reduction in LCC, or d) any combination of any activities prompting acceleration to RC.

2. Provide supporting information for optimization activities using tables, plots or figures, and/or photos.

3. Identify the need for changes to decision document (e.g., Explanation of Significant Differences [ESD], ROD Amendment [RODA]) to improve the remedy efficiency and/or shorten remedy duration to achieve endpoint.

Issues/Obstacles Encountered:

1. Describe issues that could impact schedule.

Planned Optimization Activities for Next Reporting Period (including Potential Issues):

1. Describe planned optimization activities (see Key Optimization Elements)

2. Identify activities that would shorten restoration life cycle.

(e.g., MOODY_OT012_CPSMR12_OB01-DEC2020)

Key Optimization Elements:

• Site Understanding – Updating conceptual site model (CSM) to better understand site conditions

• Design Optimization Review – Reviewing design of selected remedies to effectively target contaminant source(s) and contaminant plume based on site conditions

• Remedy Process Optimization – Enhancing remedy effectiveness or efficiency to accelerate remediation timeline, i.e., Operations & Maintenance

• Monitoring Optimization – Optimizing number and location of monitoring wells and/or minimizing sampling frequency

Site Understanding:

• Identify data gaps

• Use real-time measurements

• Sequence activities focusing on source control first

• Conduct strategic sampling

Design Optimization Review

• Conduct design optimization reviews to evaluate remedy selected and ensure streamlined remedial action operations

• Address challenges associated with source uncertainties and/or plume uncertainties by the selected remedy as designed

• Add new nested wells with shortened well screens

Remedial Process Optimization Operations In Situ Treatments (e.g., Enhanced Reductive Dechlorination [ERD], Monitored

Natural Attenuation [MNA], Permeable Reactive Barrier [PRB], In Situ Chemical Oxidation [ISCO])

• Contaminant footprint reductions

• Recirculation of treated extracted groundwater through in situ bioreactors with treated water

• Application of phytoremediation where appropriate (regulatory agency approval is required for new remedial alternative(s))

Ex Situ Treatments (e.g., Pump and Treat [P&T], Air Sparging [AS], Soil Vapor Extraction [SVE])

• >90% uptime with 99.99% off-gas treatment before discharge to the atmosphere

• Change from energy-intensive thermal/catalytic converter to carbon adsorption to treat off-gas

• Transition of low mass recovery for an existing P&T system to passive management systems (regulatory agency approval is required for new remedial alternative[s])

Ex Situ Treatment (e.g., Light Non-Aqueous Phase Liquid [LNAPL] Recovery)

• Evaluation for point-of-termination for product recovery when reaching to asymptotic recovery

• Use of LNAPL transmissivity data to evaluate LNAPL recoverability

(e.g., MOODY_OT012_CPSMR12_OB01-DEC2020)

• Evaluation of Natural Source Zone depletion (NSZD) rates Maintenance In Situ Treatments (e.g., ERD, MNA, PRB, ISCO)

• Few optimization opportunities

Ex Situ Treatments (e.g., P&T, AS, SVE)

• Appropriate process monitoring (e.g., pressure, flowrates, O2/CO2, energy consumptions) to minimize downtimes and prevent system failure

• Maintain uninterrupted system operation

• Maintain and replace aging infrastructure to improve remedy efficiency, avoiding well fouling, pump and filter replacements as appropriate

• Modification of extraction operations from steady rates to pulsed operation or variable frequency/adjustable speed driver use Ex Situ Treatment (e.g., LNAPL Recovery)

• Maintain aging infrastructure to improve remedy efficiency, avoiding well fouling, pump and filter replacements as appropriate

• Review process monitoring (operation) performance and identify the source that is less efficient

• Make necessary changes, as appropriate and required, to overcome site-specific conditions that affected performance Monitoring Optimization Performance Monitoring

• Use decision logic and decision support tools to manage and track remedy progress (e.g., Monitoring and Remediation Optimization System [MAROS])

• Progress may be on track, but evaluate chlorinated compound degradation pathways or Edible Vegetable Oil partitioning by Compound-specific Isotope Analysis

• Progress may be on track, but evaluate a potential contaminant rebound after injectant is depleted

• Review performance monitoring data to evaluate the effectiveness and appropriateness of key performance metrics/standards

• Change from active remediation to natural attenuation Compliance • Document decision to comply with alternative performance expectations and goals, if all remedial alternatives fail to achieve performance expectations and if remedial technologies are more harmful than the site conditions

• Revisit Applicable or Relevant and Appropriate Requirements (ARARs), Remedial Action Objectives (RAOs), and the selected remedy in the context of updated information and performance monitoring data

Data Management

• Improved data management including improving data management planning, data acquisition, data processing, data analysis (using 3-D visualization analysis), data preservation and storage, and data publication and sharing.

References

AFCEC. 2014. Optimizing Remedies with Performance-Based Contracts. Presented by. Dr. Kent Glover.

AFCEC/CZTE. Presented at FRTR Meeting. November.

ITRC. 2004. Remediation Process Optimization: Identifying Opportunities for Enhanced and More Efficient Site Remediation

(e.g., MOODY_OT012_CPSMR12_OB01-DEC2020)

NAVFAC. 2017. Portfolio Optimization (P-OPT) Review of the Navy’s IRP Site- Phase I Overview and Findings. Open Environmental Restoration Resource (OER2) Webinar. Presented by NAVFAC Environmental Restoration Program. August 23.

U.S. EPA. 2017. Superfund Optimization Progress Report 2011-2015. Office of Land and Emergency Management. EPA-542-R-17-002. June.

File details come from the government source that posted it. Updated .