SEPA
United States
Environmental Protection
Agency
Office of Emergency and
Remedial Response
Washington, DC 20460
Office of
Research and Development
Cincinnati, OH 45268
Superfund
EPA/540/2-91/023
October 1991
Engineering Bulletin
Control of Air Emissions From
Materials Handling During
Remediation
Purpose
Section 121(b) of the Comprehensive Environmental Re-
sponse, Compensation and Liability Act (CERCLA) mandates the
Environmental Protection Agency (EPA) to select remedies that
"utilize permanent solutions and alternative treatment tec hnolo-
gies or resource recovery technologies to the maximum extent
practicable" and to prefer remedial actions in which treatment
"permanently and significantly reduces the volume, toxicity, or
mobility of hazardous substances, pollutants and contaminants
as a principal element." The Engineering Bulletins are a series of
documents that summarize the latest information available on
selected treatment and site remediation technologies and re-
lated issues. They provide summaries of and references for the
latest information to help remedial project managers (RPMs), on-
scene coordinators (OSCs), contractors, and other site cleanup
managers understand the type of data and site characteristics
needed to evaluate a technology for potential applicability to
their Superfund or other hazardous waste site. Those doci iments
that describe individual treatment technologies focus or reme-
dial investigation scoping needs. Engineering Bulletins that are
specific to issues related to Superfund sites and cleanups provide
the reader with synopses of important considerations required
either in the planning of the field investigation or in the decisions
leading to the selection of remediation technologies applicable
to a specific site. Addenda will be issued periodically to ipdate
the original bulletins.
Abstract
This bulletin presents an overview discussion on the impor-
tance of and methods for controlling emissions into the a>r from
materials handling processes at Superfund or other hazardous
waste sites. It also describes several techniques used for dust
and vapor suppression that have been applied at Superfund
sites.
Air emission control techniques have been utilized for
Superfund cleanups at the McColl site (CA) and at the i aSalle
Electric site (IL). Foam suppression has been used at Rocky
Mountain Arsenal (CO), Texaco Fillmore (CA), and at a petro-
leum refinery (CA) site. A number of temporary vapor suppres-
sion techniques have also been applied at other sites. Addition-
ally, the experience gained in the mining industry and at haz-
ardous waste treatment, storage, and disposal sites will yield
applicable methods for Superfund sites.
This bulletin provides information on the applicability of air
emission controls for materials handling at Superfund sites,
limitations of the current systems, a description of the control
methods that have found application to date, site require-
ments, a summary of the performance experience, the status of
the existing techniques and identification of future develop-
ment expectations, and sources of additional information.
Applicability of Materials Handling Controls
Estimation of the potential releases to the air and an analy-
sis of the impacts to the air pathway are applicable to every
activity in the Superfund process. Since nearly every Superfund
site has a potential air emissions problem, the focus of this
bulletin is to assist RPMs and OSCs in considering the appropri-
ate methods for material handling at Superfund sites. To do
that, the first step is to estimate the potential releases using the
air pathway analysis (APA) process.
The amended National Contingency Plan expands upon
the requirement to conduct and fully document a regimented
process called an air pathway analysis (APA). The process is
defined as a "systematic approach involving a combination of
modeling and monitoring methods to assess actual or potential
receptor exposure to air contaminants" [1 p. 1-1]*. When
considering removal or remedial responses (i.e., technologies),
an APA detailing emission estimates is useful for determining
the potential compliance with applicable or relevant and ap-
propriate requirements (ARARs) during remedial action, par-
ticularly at a State or local level. Compliance with National
Ambient Air Quality Standards during a remediation or the
excavation and processing of the contaminated media must be
addressed. With the passage of the Clean Air Act Amendments
in November 1990 and the advent of numerous state air toxics
programs, remediation of Superfund sites must address the
[reference number, page number]
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Figure 1
Procedures for Conducting APA for Superfund
ApplicationOverview [1, p.1-4]
Volume II
Procedures for
Developing Baseline Air
Emission Estimates
Procedures for Baseline
Emission Estimates
(undisturbed & disturbed
sites)
Emission Estimation
Techniques for Landfill
and Lagoons
Volume I
Application of Air Pathway
Analyses for Superfund Activities
Identify Superfund Remedial
Activity and Source-Specific Need
for an APA
Recomrt end APA Procedures for
Superfund Applications
Reference Volumes II-IV for
Supplemental Technical
Procedures/Recommendations
Volume III
Procedures for Estimating
Air Emission Impacts from
Remedial Activities
Procedures for
Estimating Emissions
from Remedial Activities
Emission Estimation
Techniques for Waste
Treat men t
Volume IV
Procedures for Dispersion
Modeling and Air
Monitoring
Procedures for
Dispersion Modeling
and Monitoring
Technical
Recommendations for
Modeling and
Monitoring
media transfer that excavation and materials handling (before
and after treatment) will create, and the ARARs these regula-
tions represent. Figure 1 [1, p. 1 -4] indicates the applicability of
the guidance study series documents on the air pathway an
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Table 1
Remedial Step Fractional
Contribution to VCs [16, p. 39]
Remedial Activity
Excavation
Bucket
Truck Filling
Transport
Dumping
Incinerator
Exposed Soil
Total
Overall Site
0.0509
0.0218
0.0905
0.3051
0.5016
0.0014
0,0287
1.0000
Table 2
Common Control Technologies Available For
Materials Handling [*]
Remedial
Operation
Excavation
Transportation
Dumping
Storage (waste/
residuals)
Grading
Waste feed/
preparation
*Adapted from [1].
Control Technology
Water sprays of active areas
Dust suppressants
Surfactants
Foam coverings
Enclosures
Aerodynamic considerations
Watersprays of active areas
Dust suppressants
Surfactants
Road carpets
Road oiling
Speed reduction
Coverings for loads
Water sprays of active areas
Water spray curtains over bed during
dumping
Dust suppressants
Surfactants
Windscreens
Orientation of pile
Slope of pile
Foam covering and other coverings
Dust suppressants
Aerodynamic considerations
Cover by structure with air
displacement and control
Light water sprays
Surfactants
Cover by structure with air
displacement and control
the excavation process remained constant. This contribution
was dependent on the parameters of the soil and the remedial
activity pattern. At this site, dumping and temporary storage at
the incinerator accounted for 50 percent of the VC emissions;
transport from the excavation zone was the second highest
contributor of emissions. All activities were assumed to be
uncontrolled. The use of tarps and/or foam suppressants could
substantially reduce these emissions from transport and storage.
Limitations
The control methods for dust and vapor suppression rarely
remove 100 percent of the contaminants from the air. These
releases have to be estimated, along with the cost estimate for
application of the control method to properly assess the feasi-
bility of implementating the remediation technology being
considered. Site conditions determine the effectiveness of spe-
cific control methods.
Some methods have very limited periods of effectiveness,
making multiple applications or specialized formulations neces-
sary. The scheduling of media excavation and processing may
be impacted, for example, in matching the length of effective-
ness of a foam or spray suppression technique being used.
If gaseous emissions are expected to be high, or local
fugitive limitations apply, costly areal containment methods
may be required. If a very large site is to be excavated and the
materials classified or preprocessed, portable versions will
have to be designed for local air emission control. The use of
such portable containment strategies will affect the overall
schedule of the remediation and will mandate unique worker
safety plans to ensure that the proper level of protective
apparel and monitoring devices are used during the excava-
tion process.
Control Methods
A list of the most commonly used control technologies
applicable to VCs and PMs released during soils handling is
presented in Table 2 [1, p. 5-31].
Volatilization of contaminants from a hazardous waste site
may be controlled by reducing soil vapor pore volume or using
physical/chemical barriers [2, p. 116]. The rate of volatilization can
be reduced by adding water to reduce the air-filled pore spaces or
by reduction of the spaces themselves through compaction tech-
niques. Compaction, however, would displace the volatiles occu-
pying the free spaces (soil venting); water suppression might result
in mobilizing the contaminant into a groundwater medium if not
properly applied. Wastes amenable to this form of suppression
include most volatile organic (e.g., benzene, gasoline, phenols) and
inorganic (e.g., hydrogen sulfide, ammonia, radon, methyl mer-
cury) compounds in soil. Contaminants with a high vapor phase
mobility and low water phase partition potential are particularly
amenable to this vapor control technique. However, the initital
application of water will force VCs from the soil-free spaces.
Engineering Bulletin: Control of Air Emissions From Materials Handling During Remediation
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Physical/chemical barriers have found broad utility in tem-
porary vapor and particulate control from hazardous waste sites
[3, p. 4-1 to 4-10]. Evaporation retardants such as foams may
be applied, while simpler windscreens, synthetic covers,
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Table 5
Summary of VOC Air Emissions Control Technologies For Landfills [*]
Control
Foams
Complete Enclosure/
Treatment System
Fill Material
Synthetic Membrane
Aerodynamic Modification
Advantages
Minimum Surface Area, Shape
Water
Inorganic/Organic Control Agents
Adapted from [14]
Easy to Apply
Effective
Allow for Control of Working Faces
Can Reduce Decontamination
May Provide the Highest Degree
of Control For Some Applications
Inexpensive
Equipment Usually Available
Simple Approach
Simple
Lower Cost
Low Maintenance
Fugitive VC/PM Collection Systems Can Be Used in Active Areas
Inexpensive
Can Be Included in Plan
Easy to Apply
Similar to Foams
Disadvantages
Moderately Expensive
Requires Trained Operators
High Cost
Air Scrubbing Required
High Potential Risk
Must Work Inside Enclosure
Hard to Seal Air-Tight
No Control for Working Face
Creates More Contaminated Soil
Worker Contact with Waste
on Application
Hard to Seal Air-Tight
Variable Control
Requires Additional Controls
Limited Operational Data Exist
Effective Range Limited
Maintenance Required
Must Maintain
Cannot Always Dictate Shape
A Potential Exists for Leaching
to Croundwater
Not as Effective as Foams For
Working Areas
Performance Experience
A study of fugitive dust control techniques conducted with
test plots at an active cleanup area documented decreasing
effectiveness of foam suppressants within 2 to 4 weeks of applica-
tion. The effectiveness of water sprays on dump trucks and at the
loading site was in the 40 to 60 percent range for the site and 60
to 70 percent range for the truck [8, p. 2]. Surfactants increased
the effectiveness of the water sprays.
Foam suppressants have been thoroughly studied by at
least two vendors: 3M and Rusmar Foam Technology [9][10].
Laboratory data for highly volatile organics, such as benzene
and trichloroethylene contaminated sand, indicated more than
99 percent suppression effectiveness for several days. Comple-
mentary data indicated better barrier performance of foams
over 10-mil polyethylene film in controlling volatilization [11, p.
7 & 8]. A burning landfill was doused and the vapors sup-
pressed by more than 90 percent using foam at a site in Jersey
City [12, p. 3]. Similarly, vapors from a petroleum waste site
were compared using three different test agents: temporary
foam, rigid urea-formaldehyde foam, and a stabilized foam.
The temporary foam yielded an average 81 percent control for
20 minutes, rigid foam produced 73 percent control for about
2 hours, and the stabilized foam was 99 percent effective for 24
hours after application [13, p. 4-7].
The performance data reported are specific to the sites
and contaminants controlled. There is no direct applicability of
the performance data to general Superfund sites or conditions.
Table 5 presents a summary of VC air emissions control
technologies for landfills [14, p. 38]. Many of the techniques
used can control fugitive particulate emissions as well.
Engineering Bulletin: Control of Air Emissions From Materials Handling During Remediation
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Technology Status
The use of vapor and paniculate control techniques has
been directly applied to at least three Superfund sites: Me Coll
(California), Purity Oil Site (California), and LaSalle Electric (Illi-
nois). The McColl work is available as a Superfund Innovative
Technology Evaluation demonstration of excavation techniques.
Although the domed structure used controlled sulfur dioxide
and VOC releases to the atmosphere, working conditions within
the dome were difficult. High concentrations of dust and
contaminants mandated use of a high level of personal protec-
tive apparel. Consequently, personnel were able to work within
the dome for only short periods of time [15].
A variety of dust and vapor control techniques may be
applied at Superfund sites. A systematic approach to estimate
the quantities of air emissions to be controlled, the ambient
impact, and the selection of the most appropriate control
technique requires a thorough understanding of the site, wastes,
emissions potential, and the most relevant combinations of
control methods.
Acknowledgments
This bulletin was prepared for the U.S. Environmental Pro-
tection Agency, Office of Research and Development (ORD),
Risk Reduction Engineering Laboratory (RREL), Cincinnati, Ohio'
by Science Applications International Corporation (SAIC) under
contract No. 68-C8-0062. Mr. Eugene Harris served as the EPA
Technical Project Monitor. Mr. Gary Baker was SAICs Work
Assignment Manager and primary author. The author is espe-
cially grateful to Mr. Michael Borst of EPA-RREL, who contrib-
uted significantly by serving as a technical consultant during
the development of this document.
The following other Agency and contractor personnel have
contributed their time and comments by participating in the
expert review meetings and/or peer reviewing the document:
Mr. Edward Bates
Mr. Jim Rawe
Dr. Chuck Schmidt
Mr. Joe Tessitore
EPA-RREL
SAIC
Environmental Consultant
Cross, Tessitore & Associates
EPA Contact
Technology-specific questions regarding air emissions may
be directed to:
Mr. Michael Borst
U.S. EPA, Releases Control Branch
Risk Reduction Engineering Laboratory
2890 Woodbridge Ave., Building 10 (MS-104)
Edison, NJ 08837-3679
Telephone FTS 340-6631 or (908) 321-6631
Engineering Bulletin: Control of Air Emissions From Materials Handling During Remediation
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REFERENCES
1. Office of Air Quality Planning and Standards, Air Super-
fund National Technical Guidance Study Series, Volume
1: Application of Air Pathway Analysis for Superfund
Activities. Interim Final EPA/450/1-89/001, U.S. Environ-
mental Protection Agency, 1989.
2. Review of In-Place Treatment Techniques for Contami-
nated Surface Soils, Volume 1: Technical Evaluation. EPA/
540/2-84/003a, U.S. Environmental Protection Agency,
1984.
3. Handbook Remedial Action at Waste Disposal Sites
(Revised). EPA/626/6-85/006, U.S. Environmental
Protection Agency, 1985.
4. U.S. Environmental Protection Agency, Superfund
Innovative Technology Evaluation (SITE) Program. EPA/
540/8-91/005,1991.
5. U.S. Environmental Protection Agency, Dust and Vapor
Suppression Technologies for Excavating Contaminated
Soils, Sludges, and Sediments - Draft Report, Contract
No. 68-03-3450, 1987.
6. Shen, T., et. al. Assessment and Control of VOC E missions
from Waste Disposal Facilities Critical Reviews in [ nviron-
mental Control, 20 (1), 1990.
7. Office of Air Quality Planning and Standards, Air Super-
fund National Technical Guidance Study Series, Volume
2: Estimation off Baseline Air Emissions at Superfund Sites.
Interim Final EPA/450/1-89/002, U.S. Environmental
Protection Agency, 1989.
8. U.S. Environmental Protection Agency Project Summary.
Fugitive Dust Control Techniques at Hazardous Waste
Sites: Results of Three Sampling Studies to Determine
Control Effectiveness, EPA/540/S2-85/003, U.S. Environ-
mental Protection Agency, 1988.
9. Marketing Brochure, Rusmar Foam Technology, January
1991.
10. Aim, R., et.al. The Use of Stabilized Aqueous Foams to
Suppress Hazardous Vapors Study of Factors Influenc-
ing Performance. Presented at the HMCRI Symposium,
November 16-18, 1987.
11. Olson, K. Emission Control at Hazardous Waste Sites
Using Stable, Non-Draining Aqueous Foams. Presented at
the 80th Annual Meeting of the Air & Waste Manage-
ment Association, June 20-24, 1988.
12. Aim, R. Using Foam to Maintain Air Quality During
Remediation of Hazardous Waste Sites. Presented at the
Annual Meeting of the Air Pollution Control Association,
June 1987.
13. Radian Corporation 3M Foam Evaluation for Vapor
Mitigation Technical Memorandum. August 1986.
14. Radian Corporation. Air Quality Engineering Manual for
Hazardous Waste Site Mitigation Activities Revision #2
November 1987.
15. Schmidt, C.E. for USEPA- AEERL. The Effectiveness of
Foam Products for Controlling the Contaminants
Emissions from the Waste at McColl Site in Fullerton,
California Technical Paper Draft. November, 1989.
16. U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards. Development of
Example Procedures for Evaluating the Air Impacts of Soil
Excavation Associated with Superfund Remedial Actions.
Draft Report, July 1990.
Engineering Bulletin: Control of Air Emissions From Materials Handling During Remediation
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