United States
                           Environmental Protection
                           Office of Emergency and
                           Remedial Response
                           Washington, DC 20460
Office of
Research and Development
Cincinnati, OH 45268
October 1991
Engineering Bulletin
Control of Air  Emissions From
Materials  Handling  During

    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.

    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

    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]

                                                         Figure 1
                                      Procedures for Conducting APA for Superfund
                                            Application—Overview [1, p.1-4]
                              Volume II
                            Procedures for
                        Developing Baseline Air
                          Emission Estimates
                        Procedures for Baseline
                        Emission Estimates
                        (undisturbed & disturbed

                         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
       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

• Procedures for
  Dispersion Modeling
  and Monitoring

• Technical
  Recommendations for
  Modeling and
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
                          Table 1
                 Remedial Step Fractional
               Contribution to VCs [16, p. 39]
       Remedial Activity
       Truck Filling
       Exposed Soil
                   Overall Site

                         Table 2
      Common Control Technologies Available For
                  Materials Handling [*]

  Storage (waste/

 Waste feed/

   *Adapted from [1].
Control Technology

Water sprays of active areas
Dust suppressants
Foam coverings
Aerodynamic considerations

Watersprays of active areas
Dust suppressants
Road carpets
Road oiling
Speed reduction
Coverings for loads

Water sprays of active areas
Water spray curtains over bed during
Dust suppressants

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

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.

     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

    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, 
                                                        Table 5
                           Summary of VOC Air Emissions Control Technologies For Landfills [*]

       Complete Enclosure/
       Treatment System
       Fill Material
      Synthetic Membrane
      Aerodynamic Modification
      Minimum Surface Area, Shape
      Inorganic/Organic Control Agents
       Adapted from [14]
  Easy to Apply
  Allow for Control of Working Faces
  Can Reduce Decontamination

  May Provide the Highest Degree
  of Control For Some Applications
                                            Equipment Usually Available
  Simple Approach
• Simple
• Lower Cost
• Low Maintenance
      Fugitive VC/PM Collection Systems     • Can Be Used in Active Areas
  Can Be Included in Plan

  Easy to Apply
  Similar to Foams

 •  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

 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.

     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
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

 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,

 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/

 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

10. Aim, R., 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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