United States
Environmental Protection
Agency
Office of
Research and
Development
Washington, DC 20460
Office of
Solid Waste and
Emergency Response
Washington, DC 20460
EPA/540/R-92/013a
May 1992
for Conducting
Treatability Studies
Under CERCLA
Chemical Dehalogenation
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EPA/540/R-92/013a
OSWER Directive No. 9355.0-38
May 1992
GUIDE FOR CONDUCTING
TREATABILITY STUDIES UNDER CERCLA:
CHEMICAL DEHALOGENATION
FINAL
Risk Reduction Engineering Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
and
Office of Emergency and Remedial Response
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, DC 20460
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NOTICE
The information in this document has been funded wholly or in part by the
U.S. Environmental Protection Agency (EPA) under Contract No.
68-C9-0036. It has been subjected to the Agency's review process and
approved for publication as an EPA document.
The policies and procedures set forth here are intended as guidance to
Agency and other government employees. They do not constitute rule-
making by the Agency, and may not be relied on to create a substantive
orprocedural right enforceable by any otherperson. The Government may
take action that is at variance with the policies and procedures in this
manual. Mention of trade names or commercial products does not
constitute endorsement or recommendation for use.
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FOREWORD
Today's rapidly developing and changing technologies and industrial
products and practices frequently carry with them the increased
generation of materials that, if improperly dealt with, can threaten both
public health and the environment. The U.S. Environmental Protection
Agency (EPA) is charged by Congress with protecting the Nation's land,
air, and water resources. Under a mandate of national environmental laws,
the Agency strives to formulate and implement actions leading to a
compatible balance between human activities and the ability of natural
systems to support and nurture life. These laws direct the EPA to perform
research to define our environmental problems, measure the impacts, and
search for solutions.
The Risk Reduction Engineering Laboratory is responsible for planning,
implementing, and managing research, development, and demonstration
programs to provide an authoritative, defensible engineering basis in
support of the policies, programs, and regulations of the EPA with respect
to drinking water, wastewater, pesticides, toxic substances, solid and
hazardous wastes, and Superfund-related activities. This publication is
one of the products of that research and provides a vital communication
link between the researcher and the user community.
The purpose of this guide is to provide information on conducting
treatability studies involving chemical dehalogenation of soils and
sludges. It describes a three-tiered approach, which consists of 1) remedy
screening, 2) remedy selection, and 3) remedial design/remedial action. It
also presents detailed, technology-specific information on the preparation
of a Work Plan and a Sampling and Analysis Plan for chemical
dehalogenation treatability studies. The intended audience for this guide
comprises Remedial Project Managers, responsible parties, contractors,
and technology vendors.
E. Timothy Oppelt, Director
Risk Reduction Engineering Laboratory
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ABSTRACT
Systematically conducted, well-documented treatability studies are an
important component of the remedial investigation/feasibility study
(RI/FS) process and the remedial design/remedial action (RD/RA) process
under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA). These studies provide valuable site-specific data
necessary to aid in the selection and implementation of the remedy. In
December 1989, the EPA published an interim final Guide for Conducting
Treatability Studies Under CERCLA, which presents a stepwise approach
or protocol for conducting treatability studies in support of remedy
selection [i.e., pre-Record of Decision (ROD)] at CERCLA sites. The
"generic guide" has been revised and will be issued as a final document
in 1992. This guide, which presents information on treatability studies
involving chemical dehalogenation of soils and sludges, is intended to
supplement the information in the final generic guide.
The guide describes a three-tiered approach for conducting treatability
studies, which consists of 1) remedy screening, 2) remedy selection, and
3) remedial design/remedial action. The purpose of remedy-screening
studies for chemical dehalogenation technologies is to determine if the
technology is chemically feasible for the contaminants/matrix of concern.
If feasibility is demonstrated at the screening tier, more exhaustive testing
can be performed to generate the performance and cost data necessary to
support the detailed analysis and selection of the remedy. Remedial
design/remedial action studies, which are performed post-ROD, provide
detailed design and operating data necessary to scale up and implement
the technology.
The guide also presents detailed, technology-specific information on the
preparation of a Work Plan and a Sampling and Analysis Plan for chemical
dehalogenation treatability studies. Elements discussed include test
obj ectives, experimental design and procedures, equipment and materials,
sampling and analysis procedures, quality assurance/quality control
procedures, and data analysis and interpretation.
The intended audience for this guide comprises Remedial Project
Managers, responsible parties, contractors, and technology vendors.
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TABLE OF CONTENTS
Section Page
NOTICE 11
FOREWORD 111
ABSTRACT iv
FIGURES vi
TABLES vii
ACRONYMS viii
ACKNOWLEDGMENTS ix
1. Introduction 1
1.1 Background 1
1.2 Purpose and Scope 1
1.3 Intended Audience 1
1.4 Use of the Guide 2
2. Technology Description and Preliminary Screening 3
2.1 Technology Description 3
2.2 Technology Prescreening and Treatability Study Scoping 8
3. Use of Treatability Tests in Remedy Selection and Implementation 11
3.1 The Process of Pre-ROD Treatability Testing in Selecting a Remedy 11
3.2 Applicability of Treatability Testing to Chemical Dehalogenation 14
4. Treatability Study Work Plan 21
4.1 Test Objectives 22
4.2 Experimental Design and Procedures 23
4.3 Equipment and Materials 24
4.4 Sampling and Analysis 25
4.5 Data Analysis and Interpretation 29
4.6 Health and Safety 30
4.7 Permits 31
4.8 Residuals Management 31
4.9 Schedule 31
4.10 Management and Staffing 31
4.11 Budget 33
5. Sampling and Analysis Plan 35
5.1 Field SamplmgPlan 35
5.2 Quality Assurance Project Plan 36
6. Treatability Data Interpretation 41
6.1 Use of Pre-ROD Treatability Study Results in the RI/FS Process 41
6.2 Use of Pre-ROD Treatability Study Results in the RD/RA Process 46
References 47
Appendix 51
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FIGURES
Page
Galson APEG-PLUS™ Full-scale Chemical Dehalogenation Treatment System 6
SoilTech AOSTRA-Taciuk Process Flowsheet 7
Decision Tree Showing When Treatability Studies Are Needed to Support the 12
Evaluation and Selection of an Alternative
4 Flow Diagram of the Tiered Approach 13
5 The Role of Treatability Studies in the Rl/FS and RD/RA Process 15
6 Example Chemical Dehalogenation Bench-Scale Reactor 25
7 Example Chemical Dehalogenation Pilot-Scale Reactor 26
8 Example Tabulation of Results From a Remedy-Screening Treatability Study 29
9 Example Graphical Presentation of Results From a Remedy-Selection Treatability Study 30
10 Example Tabulation of Material Balance Data From a Remedy-Selection Treatability Study 30
11 Example Project Schedule for a Two-Tiered Chemical Dehalogenation Treatability Study 32
12 Example Project Organization Chart 33
13 General Applicability of Cost Elements to Various Treatability Study Tiers 34
14 Example Analytical Quality Assurance Objectives for a Remedy-Selection Chemical 37
Dehalogenation Treatability Study
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TABLES
Table Page
1 Data-Collection Requirements for Prescreening Chemical Dehalogenation 9
2 Applicability of Tiered Approach to Chemical Dehalogenation Treatability Studies 16
3 Suggested Organization of Treatability Study Work Plan 21
4 Waste Characterization Analyses 27
5 Treated Product and Treatment Residuals Analyses 28
6 Suggested Organization of Treatability Study Sampling and Analysis Plan 35
7 Standard EPA Analytical Methods for Halogenated Organic Compounds 38
8 Applicability of Chemical Dehalogenation Treatability Study Data to RI/FS Evaluation Criteria 42
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ACRONYMS
APEG Alkaline polyethylene glycolate NMPC
ARARs Applicable or Relevant and Appropriate O&M
Requirements
ASTM American Society for Testing and Materials OSWER
ATP AOSTRA-Tacmk Process
BCD Base-Catalyzed Decomposition PCB
CERCLA Comprehensive Environmental Response, PCDD
Compensation, and Liability Act PCDF
CLP Contract Laboratory Program PEG
ODD Dichlorodiphenyldichloroethane QA/QC
DDE Dichlorodiphenyldichloroethylene QAPjP
DDT Dichlorodiphenyltrichloroethane RCRA
DMSO Dimethylsulfoxide RD&D
EPA U.S. Environmental Protection Agency RD/RA
FIFRA Federal Insecticide, Fungicide, and RI/FS
Rodenticide Act ROD
FRC Franklin Research Center RP
FSP Field Sampling Plan RPD
ITEP IT Environmental Programs, Inc. RPM
HSP Health and Safety Plan RSD
KOH Potassium hydroxide SAP
KPEG Potassium polyethylene glycolate SARA
LC Lethal concentration
LDRs Land disposal restrictions SITE
MDL Method detection limit SOP
MS Matrix spike TCDD
MSD Matrix spike duplicate TMH
NaOH Sodium hydroxide TSCA
NaPEG Sodium polyethylene glycolate
Niagara Mohawk Power Corporation
Operation and maintenance
ORD Office of Research and Development
Office of Solid Waste and Emergency
Response
Poly chlorinated biphenyl
Poly chlorinated dibenzo-p-dioxin
Poly chlorinated dibenzofuran
Polyethylene glycol
Quality assurance/quality control
Quality Assurance Project Plan
Resource Conservation and Recovery Act
Research, Development, and Demonstration
Remedial Design/Remedial Action
Remedial Investigation/Feasibility Study
Record of Decision
Responsible Party
Relative percent difference
Remedial Project Manager
Relative standard deviation
Sampling and Analysis Plan
Superfund Amendments andReauthorization
Act
Superfund Innovative Technology Evaluation
Standard Operating Procedure
Tetrachlorodibenzo-p-dioxin
Triethylene glycol methyl ether
Toxic Substances Control Act
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ACKNOWLEDGMENTS
This guide was prepared for the U.S. Environmental Protection Agency by
IT Corporation. Mr. David L. Smith served as the EPA Technical Project
Monitor. Ms. Judy L. Hessling and Mr. Gregory D. McNelly were IT's
Work Assignment Managers. The project team included Sarah A.
Hokanson, James S. Poles, Steve Giti-Pour, and John A. Wentz. Dr.
MichaelL. Taylor served as IT's Senior Reviewer, and Ms. Marty Phillips
was the Technical Editor. Document lay out was provided by James Scott.
The authors gratefully acknowledge the contributions of the following
individuals, whose comments and suggestions have guided the
development of this document:
Charles J. Rogers
U.S. Environmental Protection Agency
Risk Reduction Engineering Laboratory
Dr. Alfred Kernel
U.S. Environmental Protection Agency
Risk Reduction Engineering Laboratory
Edwina Milicic
Galson Remediation Corporation
Dr. A. Bruce King
National Environmental Technology
Applications Corporation-
University of Pittsburg
Robert Hoch
SDTX Technologies, Inc.
Dr. Arthur J. Friedman
Chemical Waste Management, Inc.
A.E. (Ted) Seep, Jr.
Morrison-Knudsen Corporation
Dr. Thomas O. Tieman
Wright State University
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SECTION 1
INTRODUCTION
1.1 BACKGROUND
Under the Superfund Amendments and Reauthorization
Act of 1986 (SARA), the U.S. Environmental Protection
Agency (EPA) is required to select remedial actions
involving treatment that "permanently and significantly
reduces the volume, toxicity, ormobility of the hazardous
substances, pollutants, and contaminants"
[Comprehensive EnvironmentalResponse, Compensation,
and Liability Act (CERCLA), Section 121(b)].
Treatability studies provide valuable site-specific data
necessary to support Superfund remedial actions. They
serve two primary purposes: 1) to aid in the selection of
the remedy, and 2) to aid in the implementation of the
selected remedy. Treatability studies conducted during
the remedial investigation/feasibility study (RI/FS)
indicate whether a given technology can meet the
expected cleanup goals for the site, whereas treatability
studies conducted during the remedial design/remedial
action (RD/RA) establish the design and operating
parameters necessary for both optimization of technology
performance and remedy implementation. Although the
purpose and scope of these studies differ, they
complement one another (i.e., information obtained in
support of remedy selection may also be used to support
remedy implementation).
Historically, treatability studies have been delayed until
after the Record of Decision (ROD) has been signed.
Conducting certain treatability studies early in the RI/FS
should reduce the uncertainties associated with selecting
the remedy, provide a sounder basis for the ROD, and
possibly facilitate negotiations with responsible parties
without lengthening the overall remediation schedule for
the site. Because treatability studies may be expensive
and time-consuming, however, the economics of cost and
time should be taken into consideration during the
planning of such studies in support of the various phases
of the program.
In December 1989, the EPA published an interim final
Guide for Conducting Treatability Studies Under
CERCLA (hereinafter referred to as the generic guide),
which presents a stepwise approach or protocol for
conducting treatability studies in support of remedy
selection at CERCLA sites (EPA 1989a). The generic guide
is currently being revised and will be issued as a final
document in 1992. Several technology-specific protocols
are available, and others are being planned to supplement
the information in the final generic guide.
1.2 PURPOSE AND SCOPE
This guide presents information on conducting
treatability studies involving direct chemical
dehalogenation of soils and sludges. For the purposes of
this document, chemical dehalogenation includes those
processes in which 1) a chemical reagent is applied
directly to the contaminated matrix (soil or sludge), and 2)
the reagent reacts with the contaminant to effect the
removal of one or more halogen (chlorine, bromine, or
iodine) atoms from a molecule of the contaminant. The
reaction between the reagent and the contaminant may be
a substitution reaction (in which the halogen atoms are
replaced by other atoms or chemical groups) or an
elimination reaction [in which the halogen atoms and
other atoms (e.g., hydrogen) are simultaneously removed
from an aliphatic compound and form a double or triple
bond in the molecule]. Examples of direct chemical
dehalogenation include the alkaline polyethylene
glycolate (APEG) processes and base-catalyzed
decomposition (BCD) processes; they do not include
desorption or extraction processes followed by chemical
treatment of the condensate or extraction medium.
Although the examples presented herein are drawn almost
exclusively from alkaline glycolate experience, this
guidance document addresses the subject matter broadly
enough to accommodate new processes as they are
developed and proven.
1.3 INTENDED AUDIENCE
This guide is intended for use by Remedial Project
Managers (RPMs), responsible parties (RPs), contractors,
and technology vendors.
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Remedial Project Managers are responsible for project
planning and oversight at both fund-lead and
enforcement sites. Their role in treatability investigations
depends on the designated lead agency (Federal or State).
Their activities generally include scoping the treatability
study, establishing the data quality objectives, selecting
a contractor, issuing a work assignment, overseeing the
execution of the study, reviewing all project plans and
reports, and informing and involving the public as
appropriate.
Responsible parties are charged with planning and
executing treatability studies under Federal or State
oversight at enforcement sites.
Treatability studies are generally performed by remedial
contractors or technology vendors. Their roles in
treatability investigations include preparing a Work Plan
and other supporting documents, complying with
regulatory requirements, executing the study, analyzing
and interpreting the data, and reporting the results.
1.4 USE OF THE GUIDE
1.4.1 Organization of the Guide
The guide is organized into six sections and an appendix.
Section 2 presents an overview of chemical
dehalogenation processes and the preliminary data
required to screen the technology during the alternative
development phase of the FS. Section 3 presents an
overview of treatability testing in support of remedy
selection and describes the applicability of the tiered
approach to chemical dehalogenation treatability studies.
Section 4 presents a detailed discussion of the
components of a chemical dehalogenation treatability
study Work Plan, and Section 5 describes the elements of
a Sampling and Analysis Plan. Section 6 discusses the
analysis of treatability study data and the evaluation of
the technology in support of remedy selection. The
appendix summarizes relevant treatability testing
experience at actual sites where chemical dehalogenation
has been evaluated as a potential remedial action. The
readeris encouraged to consult the appropriate section(s)
throughout the planning, execution, and evaluation or
chemical dehalogenation treatability studies.
1.4.2
Application
the Guide
and Limitations of
This guide is intended to be used in conjunction with the
revised, final generic guide, which presents information of
general interest for all types of treatability testing. For
example, the reader should refer to the generic guide for
discussions on establishing treatability study objectives
and complying with regulatory requirements. Information
in other readily available guidance documents, such as
EPA's interim final Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA
(EPA 1988a), is also referenced throughout the guide.
This guide focuses mainly on pre-ROD, chemical
dehalogenation treatability studies performed in support
of remedy selection. Detailed information on post-ROD
treatability testing is presented in the final generic guide.
This document was drafted and reviewed by
representatives from EPA's Office of Solid Waste and
Emergency Response (OSWER), Office of Research and
Development (ORD), and the Regional offices, as well as
by contractors and vendors who conduct chemical
dehalogenation treatability studies. Comments obtained
during the peer review process have been integrated or
addressed throughout this guide.
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SECTION 2
TECHNOLOGY DESCRIPTION AND
PRELIMINARY SCREENING
This section presents an overview of chemical
dehalogenation processes for treating soils, sediments,
and sludges. Subsection 2.1 includes background
information on the development of the technology, a
description of a full-scale system design, a discussion of
the applicability and limitations of the technology, and a
review of the current status of chemical dehalogenation in
Superfund site remediation. Subsection 2.2 summarizes
the data-collection requirements for preliminary screening
of chemical dehalogenation.
2.1 TECHNOLOGY DESCRIPTION
2.1.1 Development of the Technology
In 1978, Professor Louis Pytlewski at the Franklin
Research Center (FRC) synthesized a new chemical
reagent for the destruction of poly chlorinated biphenyls
(PCBs) (laconianni 1984,1985). Since that time, a group of
reagents genetically referred to as "APEG" (alkali metal
polyethylene glycolate) has been developed. These
reagents are based on the reaction of alkali metals or their
hydroxides with polyethylene gly cols or their derivatives.
The firstreagents, which were prepared by the reaction of
sodium and polyethylene gly col, are known as sodium
polyethylene glycolate (NaPEG) reagents.*
Proposed mechanisms for dechlorination with NaPEG
reagents involve nucleophilic substitution and oxidative
dehalogenation of haloorganic compounds (Pytiewski
1979). Hydroxide and alkoxide ions displace halides of
halogenated aromatics to yield phenols and aromatic
ethers, respectively. The following two reactions may take
place:
* Since 1979, the terms "APEG," "NaPEG," and "KPEG"
have been used extensively throughout the literature in a
generic sense. SDTX Technologies, Inc., of Princeton,
New Jersey, purchased the original Franklin patents in
1989 and now claims these terms as their exclusive service
marks.
AR-X
OH'
Arylhaiide Hydroxide
—»
and
AR-X +
Arylhalide
Aikoxide
AR-OH
Arylhydroxide
AB-OR
Arylather
X~
Halide
+ X-
Haitde
In August 1979, the EPA provided FRC with a grant to
investigate the dechlorination of PCBs. Subsequent EPA
grant assistance was provided to study the effects of a
NaPEG reagent on PCB-contaminated soil. The results of
this research are described in a Project Summary Report
entitled Dehalogenation of PCBs Using New Reagents
Prepared From Sodium Polyethylene Glycolate -
Application to PCB Spills and Decontaminated Soils
(Franklin Research Center 1982).
A comparison of the rates of dechlorination achieved
under various conditions revealed that appreciable PCB
degradation can occur even when an APEG reagent is
diluted 50 percent with water (Komel and Rogers 1985).
Laboratory experiments on soils spiked with PCBs have
shown, however, that water in soil greatly reduces the
ability of a NaPEG reagent to dechlorinate PCBs
(laconianni 1984, 1985). Because the use of metallic
sodium can lead to dangerous side reactions if even trace
amounts of water are present (Peterson 1985), FRC
scientists developed a now potassium-based reagent
[potassiumpoly ethylene glycolate (KPEG)], which proved
to be more reactive than the sodium-based NaPEG.
Studies have indicated that KPEG is at least two times
more reactive than NaPEG in the PCB destruction process,
and it is less sensitive to water (laconianni 1984, 1985).
The chemistry of the KPEG technology involves reacting
potassium hydroxide (KOH) with polyethylene
glycol (PEG) (approximate molecular weight of 400)
to form an alkoxide. The alkoxide, in turn, reacts
initially with one of the chlorine atoms on an
aryl ring to produce an ether and potassium chloride
salt (des Rosiers 1987), as in the example for
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2,3,7,8-tetrachlorodibenzo-p-dioxin(TCDD):
ROH *
KOH
Potassium hydroxide
and
ROK + HOH
Altoxldi Water
Altoxidt
2,3,7,8-TCDQ
Potassium
eMorkte
In some KPEG reagent formulations, dimethylsulfoxide
(DMSO) is added as a cosolvent to enhance reaction rate
kinetics by improving rates of extraction of aryl halide
wastes into the alkoxide phase (Peterson 1985).
Under mild conditions (75 to 12O C), PCBs and other
inactivated chlorobenzones have reacted with PEG and
KOH in less than 2 hours (Brunelle 1982, 1983). This
reaction has been applied to the destruction and removal
of PCBs from nonpolar media, including transformer oil.
The results of toxicological evaluations of residues
resulting from KPEG treatment of Aroclor 1260 indicate
that the glycol phase resulting from the treatment of
Aroclor 1260 showed no evidence of oral toxicity in rats
at 5000 mg/kg, produced no toxicity through dermal
absorption in a mouse, and caused only mild eye irritation
in a rabbit (Brunelle and Singleton 1983). Later
experiments also indicated that arylpolyglycol by
products from KPEG reactions are nontoxic (Rogers 1987).
In 1982, Galson Research Corporation of East Syracuse,
New York, under contract to the Niagara Mohawk Power
Corporation (NMPC), developed a process for the removal
and destruction of PCBs in transformer oils (Woodward
and King 1987). The process used a low-toxicity,
low-hazard reagent to dechlorinate PCBs that were no
longer soluble in the original oil. The reagent for the oil
treatment process consisted of two components: a solid
component (KOH) and a mixture of liquid reagent
materials [PEG, DMSO, and triethylene glycol methyl ether
(TMH). In 1985, the EPA and the New York Department of
Environmental Control granted a mobile PCB treatment
permit to NMPC to conduct a full-scale demonstration of
a treatment system. By the end of 1987, the full-scale unit
had treated more than 6000 gallons of transformeroil and
20,000 gallons of dioxin-contaminated waste oil under a
variety of contracts.
The Vertac Chemical Corporation developed a process
that promotes the successful destruction of 2,3,7,8-TCDD
and other chlorinated dioxins (Howard and Sidwel 1 1982).
This process involves the use of anhydrous alkali metal
salts of polyhydroxy alcohols to dechlorinate dioxins at
atmospheric pressure. Dechlorination may also be
accomplished by reacting a mixture of chlorinated dioxins,
an alcohol, and a water solution of an alkali metal
hydroxide. Vertac claims that 2,3,7,8-TCDD and other
chlorinated dioxins are reduced to essentially zero.
APCB destruction method developed at Galson in
conjunction with the EPA demonstrated that chlorinated
biphenyls and dioxins could be decomposed and removed
from soils (Peterson, Milicic, and Rogers 1985). A reagent
consisting of a mixture of polyethylene glycol, potassium
hydroxide, and dimethyl sulfoxide was used to reduce the
dioxin concentrations from 2000 ppb to less than 1 ppb in
a short period of time, In 1986, R. L. Peterson was granted
a patent for a KPEG process for treating soils. Several
other companies and research institutions have
developed dechlorination processes. Among these are the
Acurex process, the PPM process, and the Sunohio PC-
BX process (des Rosiers 1987, Freeman and Olexsey
1986). The Acurex process, which uses a sodium reagent
with a proprietary constituent, has been tested for removal
of chlorinated waste from soils. This process has also
reduced 2,3,7,8-TCDD in transformer oil from between 200
and 400 ppt to between 20 and 60 ppt (Metcalf and Eddy
1985).
The Sunohio PCBX process also uses a proprietary
reagent to convert the PCB molecules to metal chlorides
and a polyphenyl compound. This process has reduced
the concentration of PCBs in transformer oils from 225 to
1 ppm. It has been used to treat PCB-contaminated
material at several sites, including Maxwell Laboratories
in San Diego and Chevron in El Segundo, California
(Radimsky and Shah 1985).
The PPM process, which uses a proprietary sodium
reagent to dechlorinate organic molecules, has reduced
the PCB concentration in contaminated oil from 200 ppm
to below the detection limit. As is true for all of the
sodium processes, the Acurex and PPM processes cannot
be used on aqueous wastes (Metcalf and Eddy 1985).
Research conducted by EPA's Industrial Environmental
Research Laboratory in conjunction with Wright State
University indicated that KPEG reagents can significantly
reduce the levels of 2,3,7,8-TCDD in contaminated soils
under certain conditions (Klee, Rogers, and Tiernan 1984).
The soil samples used in these studies were obtained
from a farm in Missouri where contaminated residues from
a 2,4,5-trichlorophenol manufacturing operation were
buried.
Chemical waste from a pentachlorophenol wood
treatment facility containing parts-per-million
concentrations of various polychlorinated
dibenzo-p-dioxins (PCDDs) and poly-chlorinated
dibenzofurans (PCDFs) was subjected to KPEG
treatment in laboratory studies (Tiernan et al. 1987). The
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results indicate that KPEG treatment of this waste for 45
minutes at 7O C almost completely dechlorinated (• 99
percent) all of the PCDDs and PCDFs. Similar results were
obtained with 15 minutes of KPEG treatment at 100* C.
Toxicological investigations of the residues from the
KPEG treatment of 2,3,7,8-TCDD have indicated that they
exhibit no mutagenic or toxicological effects (DeMarini
and Simmons 1989).
During Galson's EPA-sponsored field implementation of
the KPEG process at the Bengart and Memel site in 1986,
PCBs in soil contained in 5 5-gallon drums were reduced to
below the 50-ppm control limit set for the soil at the site
(Novosad et al. 1987). The average PCB levels were
reduced from 108 to 27 ppm.
In 1987-88, PEI Associates, Inc., under contract with the
EPA, scaled up the KPEG process. In June 1987, PEI, in
cooperation with Galson, conducted a field demonstration
in Moreau, New York, to evaluate the chemical
destruction of PCBs contained in a soil matrix. This
pilot-scale study, which was conducted in a 40-gallon
reactor, tested a KPEG reagent consisting of PEG-400,
KOH, DMSO, and TMH. The percentage reduction in PCB
concentration in the soil ranged from 93.9 to 99.8 (PEI
Associates 1989).
Subsequent to the successful application of the 40-gallon
KPEG process in Moreau, PEI developed a KPEG
treatment system capable of treating PCB- and
PCDD-contaminated soil in batches of 1.5 to 2 cubic yards
each. This system was used to dechlorinate
PCB-contaminated soil at the U.S. Navy Public Works
Center on the island of Guam. Approximately 30 tons of
soil with an average initial PCB concentration of 3420 ppm
(Aroclor 1260) was treated. The PCB concentrations in the
treated soil were reduced by more than 99.999 percent,
and no individual PCB congener exceeded 2 ppm (PEI
Associates 1989). The KPEG reagent used during this
demonstration consisted only of PEG-400 and KOH
(neither DMSO nor TMH was used).
Although the technology has been successfully
demonstrated at the pilot scale, alkaline glycolate
treatment of soil can be expensive because large
quantities of reagents are used. The EPA and other
research and private organizations are currently
conducting research to develop new or improved chemical
dehalogenation processes that reduce reagent cost
through reagent recovery and recycling or more favorable
reaction stoichiometry.
Currently under development is EPA's patented base-
catalyzed decomposition (BCD) technology. The new
base-catalyzed reagents have been shown to be effective
for treating PCBs in soil at temperatures above 250« C and
residence times above 30 minutes (Kim and Olfenbuttel
1990). Studies by the EPA on the treatment of
chlorophenols, chlorinated herbicides (2,4-D, 2,4,5-T,
Silvex), organochlorine pesticides (dieldrin), and
poly chlorinated dioxins and furans are ongoing.
A detailed engineering design of a 1 -ton/hour system for
BCD-treatment of PCBs in soils at the U.S. Navy Public
Works Center site in Guam has been completed. The
system, which was fabricated by Battelle Pacific
Northwest Laboratories, consists of the following
modules:
• Feed soil screening and crushing
• Reagent preparation and mixing with soil
• Rotary reactor and product conditioning
• Wet scrubber
• Scrubber water treatment
The BCD equipment is transportable and can accept
continuous feed or operate as a batch process.
Demonstration tests of the new system were performed in
1991.
2.1.2 Full-Scale System Design
Chemical dehalogenation treatment is largely a vendor-
controlled market comprising a number of patented,
proprietary processes. Firms currently offering full-scale,
alkaline glycolate remediation services (direct soil
treatment or as part of a treatment train) include Galson
Remediation Corporation, SoilTech Inc., Chemical Waste
Management Inc., and SDTX Technologies, Inc.
One example of a full-scale unit is the patented Galson
APEG-PLUS™ treatment system (Galson Remediation
Corporation, undated). Construction of the unit was
completed in 1990. The system, which is designed to be
transported on trailers, consists of the following modules:
• Reactor tanks (10 tons/batch each)
• Boiler
• Centrifuge
• Wash tank
• Reagent recovery system
• Field operations control system
• Electrical system
• Mobile laboratory
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Depending on the size of the site, equipment modules can
be added or subtracted as needed. Currently, the system
is capable of processing 40 to 60 tons of soil per day (two
reactors, two to three batches/day).
Figure 1 shows the layout for a 200 to 300 tons/day
system. Contaminated soil is excavated, sized to 1/4 in.,
and stock-piled for treatment. Treatment proceeds in
batches of approximately 10 tons each. The prepared soil
is conveyed into the reactor tank, where it is slurried with
the reagent and heated to the desired reaction
temperature. Samples of the slurry are collected
automatically for verification analysis. When the specified
clean level has been achieved, the slurry is pumped to the
centrifuge for separation of the soil and reagent. The
clean soil is washed multiple times with water, conveyed
out of the unit, and deposited back on site. The reagent,
wash water, and condensate (from the reactor tank) are
transferred to the reagent recovery system (evaporator),
where the water is recycled to the wash tank and the
reagent is refortified and recycled to the reactor tank.
A second example of a full-scale system is the SoilTech
AOSTRA-Taciuk Process (ATP) unit operated by
Canonie Environmental Services Corp. The SoilTech ATP
unit that was operated commercially at the Wide Beach
Superfund site in Brant, New York, successfully treated
about 42,000 tons of PCB- contaminated clay/silt soil
(Vorum 1991).
This 10-tons/hour, continuous-feed process treats soils
containing between 25 and 50 ppm PCB and produces a
treated product containing nondetectable levels of PCB at
a 20-ppb detection limit. The unit has successfully
processed soils containing up to 30,000 ppm PCB and
produced similar treatment results.
Sodium hydroxide and polyethylene glycol are used as
the dehalogenation reagents and the ATP unit provides
the heat, retention time, and mixing conditions required for
reaction to occur. The internal design of the reactor
enables the process to achieve very low residual levels of
PCB and organics in the treated product with minimal
quantities of reagents added. A schematic flowsheet of
the process is presented in Figure 2. The contaminated
soil is fed into the processor by convey or belt. It is heated
in the preheat zone by indirect heat transferfrom the hot,
treated soil in the cooling zone. The reagents are sprayed
onto the soil in this zone in an oil phase. Dehalogenation
reactions occur rapidly as the soil is transported into the
retort or reaction zone, where the temperature is quickly
increased to about 1100* F. Any residual organic material
is thermally stripped from the soil in the reaction zone.
The volatilized organics are condensed. New reagents are
added to the condensate and recycled to the feed end of
the processor. The hot soil exits the reaction zone free of
organics. As it cools, the treated product transmits its
heat to the incoming feed. The retention time of the soil in
the processor is less than 1 hour.
2.1.3 Applicability and Limitations of
the Technology
Chemical dehalogenation technologies that use an
alkaline glycolate or base-catalyzed reagent are
applicable to halogenated aromatic compounds,
including PCBs, PCDDs, PCDFs, chlorobenzenes,
chlorinated phenols, organochlorine pesticides,
halogenated herbicides, and certain halogenated ali-
Fuel
Oil
Boilers
Tent Shelter for Equipment
Contamlnailon Reduction Zone
Contaminated Zone
Unloading Loading
Source; Gaison Remediation Corporation, undated. Conveyor Bell Conveyor Belt
Figure 1. Gaison APEG-PLUS™ full-scale chemical dehalogenation treatment system.
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phatics (e.g., ethylene dibromide, carbon tetrachloride,
chloroform, and dichloromethane). If other volatile
organic, semivolatile organic, or metal contaminants are
present, chemical dehalogenation can be used in
conjunction with other technologies, such as
low-temperature thermal desorption, solvent extraction, or
biodegradation, as part of a treatment train. Chemical
dehalogenation technologies are applicable to soils,
sludges, and sediments; however, energy requirements
will be higher for treatment of high-moisture-content
wastes. Soil type (clay content) does not preclude
treatment.
Chemical dehalogenation effectiveness depends on
thorough mixing of the contaminants and treatment
reagents, which requires that the waste matrix be
excavated; in situ applications of the technology are not
likely to be effective. For each site, the reagent
formulation and optimum process conditions (temperature
and reaction time) must be determined through treatability
testing. Treated soils and residuals from chemical
dehalogenation treatment may require posttreatment (e.g.,
neutralization) prior to their final disposition. To date,
reaction byproducts in the treated soil have not been well
characterized. As with all chemical treatment processes,
safety hazards (chemical exposure, fire/explosion) are also
a concern.
2.1.4 Status of Superfund Site
Remediation Involving Chemical
Dehalogenation
To date, chemical dehalogenation has been selected in the
ROD for cleanup of contaminated soils at four Superfund
sites. Wide Beach Development, Brant, Now York (Region
II, August 1985); Re-Solve, Inc., North Dartmouth,
Massachusetts (Region I, July 1987); Sol Lynn/Industrial
Transformers, Houston, Texas (Region VI, March 1988);
and Myers Property, Hunterdon County, New Jersey
(Region II, September 1990). The current status of each of
these sites is described in this subsection.
The Wide Beach Development site is a 55-acre residential
community consisting of 60 homes in Brant, New York. Oil
contaminated with PCBs was spread on the roadways for
dust control between 1968 and 1978. Soil in the roadways,
adjacent drainage ditches, driveways, and front yards is
contaminated with PCBs in concentrations of up to 1000
ppm. Approximately 30,000 cubic yards of contaminated
soil exists on site. Bench- and pilot-scale treatability
studies of a proprietary chemical dehalogenation process
were conducted on Wide Beach soils during the summer
of 1988. A second proprietary process was demonstrated
on site in September 1990. The site is currently in remedial
action with full-scale treatment of soil to a PCB level
below 2 ppm.
The Re-Solve, Inc., site is a former waste chemical
reclamation facility. This 6-acre site lies between a
residential area and a wetland in North Dartmouth,
Massachusetts. Between 1974 and 1980, Re-Solve, Inc.,
collected and disposed of hazardous wastes. During this
period, the site became contaminated with chlorinated and
nonchlorinated solvents and PCBs. Chemical
dehalogenation was selected in the ROD to treat the
22,500 cubic yards of PCB-contaminated soil and 3000
cubic yards of contaminated wetland sediment. In 1987,
laboratory-scale treatability studies of a proprietary
chemical dehalogenation process were conducted on
Re-Solve soil. Since that time, the remedy has been
changed to thermal extraction of the hydrocarbons from
the soil/sediment followed by chemical dehalogenation of
the condensate. Pilot-scale treatability studies of this
proprietary process are currently being planned.
Sol Lynn/Industrial Transformers is a 3/4-acre site located
in a light industrial area of Houston, Texas. This site was
operated as an electrical transformer salvage and
recycling facility between 1971 and 1978, and as a
chemical recycling and supply company through 1980.
During these operations, workers spilled
PCB-contaminated transformer oil and trichloroethylene
wastes on the soil. Between 1000 and 2500 cubic yards of
soil is contaminated with PCBs in concentrations up to
5000 ppm. After the remedy was selected, a proprietary
solvent extraction process using chemical dehalogenation
to treat the condensate was tested in a series of pilot
studies. This process was rejected because of safety
concerns. A direct chemical dehalogenation process is
currently being tested and shows promise for full-scale
treatment. If implemented on site, this proprietary design
will treat the PCBs in the soil to below 25 ppm.
The 7-acre Myers Properly site is a former pesticide and
industrial chemical manufacturing facility in Hunterdon
County, New Jersey. From 1928 to 1959, improper
handling of hazardous substances resulted in the onsite
contamination of soil, sediment, debris, and groundwater
with volatile organics, PCBs, dioxin, and the pesticide
DDT (dichlorodiphenyltrichloroethane). The selected
remedial action for the site includes the excavation and
chemical dehalogenation of 48,700 cubic yards of
DDT-contaminated soil and sediment. In 1989, an
innovative dehalogenation technology was investigated
at the laboratory scale. A bench-scale treatability study or
a proprietary alkaline glycolate-based process was also
conducted.
2.2 TECHNOLOGY PRESCREENING
AND TREATABILITY STUDY
SCOPING
Prescreening is an important first step in the identification
of potentially applicable treatment technologies and the
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need for treatability testing. Because of the strict time
schedules and budget constraints placed on the
completion of an RI/FS, it is crucial for the planning and
scoping of treatability studies to begin as early as
possible. As discussed in Subsection 3.1, these efforts
should be initiated during the RI/FS scoping.
Technology prescreening and treatability study scoping
will include searching the chemical dehalogenation
literature and treatability data bases, consulting with
dehalogenation experts and vendors, and determining
data needs. Technology experts are available within EPA
to assist project managers with technology prescreening
and treatability study scoping. In-house consultation
services available to EPA project managers are discussed
in the final generic guide.
Potentially applicable technologies are prescreened based
on three factors: effectiveness, implementability, and cost.
Table 1 presents the site and technology data that are
required to prescreen the chemical dehalogenation
process.
The effectiveness evaluation focuses on 1) the potential
to treat the estimated volume of contaminated media and
to achieve the remediation goals identified in the remedial
action objectives, 2) the potential impacts on human
health and the environment during construction and
implementation, and 3) the documented performance for
treating similar contaminants and matrices. Information
needed to evaluate the effectiveness of chemical
dehalogenation includes the contaminated media type and
volume, the contaminant type and concentration, and the
past performance of the process on similar waste
contaminants and matrices.
Implementability addresses both the technical and
administrative aspects of implementing a technology.
When prescreening chemical dehalogenation, commercial
availability and past performance can provide an
indication of its technical implementability. Applicable
administrative factors will include the ability to obtain
necessary permits; the availability of adequate treatment,
storage, and disposal capacity and services; and the
availability of mobile equipment. Accessibility of the site
to large, tractor-trailer-based treatment units and adequate
onsite space for their deployment are also factors of
implementability.
Cost plays a limited role in the prescreening of
technologies. The cost analysis is made on the basis of
engineering judgment and past treatment operations. This
evaluation is crude, and its results alone will not be
adequate to eliminate innovative options such as chemical
dehalogenation from further consideration.
Table 1. Data-collection Requirements for Prescreening Chemical Dehalogenation
Required data
Prescreening criteria
Effectiveness
Contaminated media type
Volume of contaminated media
Contaminant type
Contaminant concentration
Past performance on similar wastes
Implementabilitv
Availability of process
Administrative
Accessibility of site
Cost
Relative capital and O&M costs
Applicable to soils, sludges, and sediments.
Cost-effective for volumes greater than 1000m3.
Applicable to halogenated aromatics and aliphatics (PCBs,
PCDDs/PCDFs, chlorobenzenes, chlorinated phenols,
organochlorine pesticides, halogenated herbicides).
Applicable to concentrations of parts per million or greater.
Demonstrated applicability for waste contaminants and
matrices should be available in the literature.
Should be a commercially available process.
Necessary permitting requirements should be achievable;
necessary treatment, storage, and disposal services
should be available; equipment should be readily available.
Site should have adequate accessways and space to set
up large trailer-based equipment and staging areas for
excavated soil.
Cost estimates, based on engineering judgment and
historical costs, should be comparable to other options.
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SECTION 3
USE OF TREATABILITY TESTS IN REMEDY
SELECTION AND IMPLEMENTATION
The selection of remedial actions involves several risk-
management decisions. Uncertainties with respect to
performance, reliability, and cost of treatment alternatives
underscore the need for well-planned, well-conducted,
and well-documented treatability studies. The final
generic guide provides a framework for planning,
conducting, and evaluating treatability studies in support
of remedy selection and implementation. The following
subsections give a brief overview of this process and
describe the applicability of treatability tests to chemical
dehalogenation technologies.
3.1 THE PROCESS OF PRE-ROD
TREATABILITY TESTING IN
SELECTING A REMEDY
As discussed in the RI/FS guidance (EPA 1988a), site
characterization and treatability investigations are two of
the main components of the RI/FS process. As site and
technology information is collected and reviewed,
additional data needs for evaluating alternatives are
identified. Pre-ROD treatability studies may be required to
fill some of these data gaps.
In the absence of data in the available technical literature
or treatability data bases, treatability studies can provide
the critical performance and cost information needed to
evaluate and select treatment alternatives. The RI/FS
guidance specifies nine evaluation criteria for use in the
detailed analysis of alternatives. Treatability studies can
generally provide data to address seven criteria:
1) Overall protection of human health and the
environment
2) Compliance with applicable or relevant and
appropriate requirements (ARARS)
3) Implementability
4) Reduction of toxicity, mobility, or volume through
treatment
5) Short-term effectiveness
6) Cost
7) Long-term effectiveness
State and Community acceptance, the other two criteria
affecting the evaluation and selection of the remedial
alternative, can influence the decision to conduct
treatability studies on a particular technology.
The general decision tree presented in FigureS illustrates
when treatability studies are needed to support the
evaluation and selection of an alternative. After the
existing site data have been reviewed, a literature survey
is conducted to obtain any existing treatability data for
the alternative and the contaminants and matrices of
concern. The data are then evaluated in terms of the
seven RI/FS criteria to identify any data gaps.
The need to conduct a treatability study on any
alternative is a management decision. In addition to the
technical considerations, certain nontechnical factors
must also be considered:
• State and community acceptance of the alternative
• Time constraints on the completion of the RI/FS and
the ROD
• New site, waste, or technology data that may have an
impact on the technology's performance
If the existing data are adequate for an evaluation of the
alternative for remedy selection, no treatability studies are
required. Otherwise, treatability studies should be
performed to generate the data necessary to conduct a
detailed analysis of the alternative.
Generally, treatability testing of alternative technologies
can begin during the initial phases of site characterization,
as shown in Figure 4. Treatability studies must be scoped
and initiated as early as possible (i.e., during the scoping
phase) to keep the RI/FS on schedule and within budget.
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SEARCH LITERATURE
TO OBTAIN EXISTING
TREATABIUTY DATA
IDENTIFY
DATA GAPS
CONDUCT
THEATAfflUTY STUDY
UANABEMBfl DBCiSOH FACTORS;
« AddKmotDit)
PERPOBM
DETAILED ANALYSIS
OF ALTERNATIVES
Source; Adapted from EPA 1989a
Figure 3. Decision tree showing when
treatability studies are needed to support the
evaluation and selection of an alternative.
The need for pre-ROD treatability testing is a
risk-management decision in which the costs and time
required to conduct treatability studies are weighed
against the risks inherent in the selection of a treatment
alternative. As a general rule, treatability testing should
continue until sufficient information has been collected to
support both the full development and evaluation of all
treatment alternatives and the remedial design of the
selected alternative. Treatability studies can significantly
reduce the overall risks and uncertainties associated with
the selection and application of a technology, but they
cannot guarantee that the chosen alternative will be
completely successful. As more studies are completed
and new knowledge is gained about innovative
alternatives, however, success rates should improve.
The flow diagram in Figure 4 traces the stepwise data
reviews and management decisions that occur in the
tiered approach to treatability testing. As discussed in
Subsection 2.2, site characterization/technology screening
is the first step in this approach. Technologies that are
determined to be potentially applicable for treatment of
the site's waste (based on effectiveness, implementability,
and cost) are retained as alternatives, all others are
screened out. The decision to conduct a treatability study
on any of the retained alternatives is based on the
availability of technology-specific treatability information
and on input from management. If sufficient information
exists to evaluate a particular alternative against the nine
evaluation criteria in the detailed analysis of alternatives,
a treatability study is not required.
If significant questions remain about the feasibility of the
technology for the site, a remedy-screening treatability
study should be performed. If the technology has already
been shown to be effective in treating the
contaminants/matrix of concern, the remedy -screening tier
may be by-passed in favor of a remedy-selection
treatability study. If the remedy-selection study indicates
that the technology can meet the performance goals, a
detailed analysis of the alternative should be performed.
Post-ROD remedial design/remedial action (RD/RA)
treatability studies of the selected alternative will
generally be necessary to support the implementation of
the remedy.
The final generic guide presents a protocol for conducting
all phases of a treatability investigation. This protocol is
designed to assist in planning and performing systematic,
scientifically sound treatability studies. The generic guide
includes discussions on:
• Establishing data quality objectives
• Identifying sources for treatability studies
• Issuing the Work Assignment
• Preparing the Work Plan
• Preparing the Sampling and Analysis Plan
• Preparing the Health and Safety Plan
• Conducting community relations activities
• Complying with regulatory requirements
• Executing the treatability study
• Analyzing and interpreting the data
• Reporting the results
Although the protocol is generally applicable
to treatability investigations of any technology and
at any tier of testing, some of the steps in the
protocol possess certain technology-specific
elements that merit additional discussion. One of
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these steps, preparing the Work Plan, is discussed in
Section 4 of this document with regard to chemical
dehalogenation treatability studies. Preparing the
Sampling and Analysis Plan is discussed in Section 5, and
Section 6 addresses analysis and interpretation of data
from chemical dehalogenation tests. Steps in the protocol
that are applicable to all technology investigations—such
as issuing the work assignment and reporting the study
results—are not discussed in this document because they
are addressed in detail in the final generic guide.
3.2 APPLICABILITY OF
TREATABILITY TESTING TO
CHEMICAL DEHALOGENATION
Figure 5 presents the three tiers of treatability testing
(remedy screening, remedy selection, and remedial
design/remedial action) and their relationship to the RI/F S
and RD/RA processes. The three tiers are described here.
1) Remedy Screening—Small-scale studies performed in
the laboratory that provide gross performance data
for feasibility evaluation. Remedy-screening studies
are characterized by the following:
• Relatively low cost
• Short amounts of time to perform
• Less stringent quality assurance/quality control
(QA/QC)
2) Remedy Selection—Small-scale studies performed in
the laboratory or field that provide detailed
performance and cost data for remedy selection.
Remedy-selection studies are characterized by the
following:
• Moderate cost
• Moderate amounts of time to perform
• Stringent QA/QC
3) RemedialDesign/Remedial Action—Post-ROD, pilot-
scale studies performed in the field that provide
scale-up and design optimization data. Remedial
design/remedial action studies are characterized by
the following:
• High cost
• Long amounts of time to perform
• Moderately stringent QA/QC
The three-tiered approach to treatability testing is
designed to be flexible to meet site- and
technology-specific needs. Some technologies, including
chemical dehalogenation, may not be investigated at all
three tiers. The applicability of the tiered approach to
chemical dehalogenation treatability studies is outlined in
Table 2 and is discussed in this subsection. Information
on performing chemical dehalogenation treatability tests
is presented in Section 4.
3.2.1 Literature Survey
The decision to perform a chemical dehalogenation
treatability study is based on the available site
characterization data, input from management, and the
results of a literature survey. Although the literature
survey is not a tier of testing, it is included in Table 2
because it is a necessary preliminary step that aids in
treatability study scoping.
The purpose of the literature survey is twofold. First, it
should identify potentially applicable processes that have
been adequately demonstrated and that are commercially
available. Second, it should obtain all existing treatability
data that are relevant to the site's waste matrix and
contaminants of concern. The treatability data on
chemical dehalogenation processes available as of this
writing are summarized in the appendix of this document.
The objective of the literature survey is to determine
specific treatability data requirements. If a particular
chemical dehalogenation process has already been
demonstrated to be effective for treating the
contaminants/matrix of interest, a remedy-screening study
may not be required. Alternatively, if little or no data exist
in the literature for the contaminants/matrix to be treated,
a screening study will be required to address this data
need.
3.2.2 Remedy-Screening Treatability
Studies
Remedy screening is the first step in the tiered approach.
Its purpose is to determine the potential feasibility of
chemical dehalogenation as a treatment alternative for the
contaminants/matrix of interest. A chemical
dehalogenation process is potentially feasible if it can be
shown that the chemical reactions occurring between the
dehalogenation reagents and the contaminants have the
potential to dehalogenate the waste adequately.
The need to perform screening studies of chemical
dehalogenation processes is contaminant- and
matrix-specific. For example, the feasibility of several
proprietary processes for the treatment of PCBs and
dioxins in various soil types has been established and is
well documented in the literature. Therefore, screening
studies of these processes will generally not be
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Table 2. Applicability of Tiered Approach to Chemical Dehalogenation Treatability Studies
Literature survey
Remedy screening
Remedy selection ROD
RD/RA
Purpose
Objective
Parameters
investigated
Data
generated
• Identify potentially
applicable processes
• Obtain existing
treatability data
Determine treatability
data needs
Not applicable
Not applicable
• Determine process
feasibility for
contaminants/matrix
. Achieve >90%
reduction in target
contaminant
concentrations
• "Severe" conditions
• Concentration of
target contaminants
before and after
treatment
• Generate
performance and
cost data for the
detailed analysis of
alternatives
Meet site cleanup
criteria for target
contaminants
• Temperature
Reaction time
Reagent
formulation/loading
• Other process
specific
parameters
• Sample type
Effects of process
parameters on
target contaminant
concentrations
• Characteristics of
product and
residuals
• Capital/O&M cost
estimates
• Generate scale-up,
design, and cost data
for implementation of
selected remedy
• Optimize process
• Feed rates
Mixing rates
Heating rates
• Other equipment
specific parameters
Materials-handling
characteristics
• Reagent recovery/
recycling efficiency
Energy/chemical usage
• Treatment train
performance
Residuals treatment
performance
required when PCBs or dioxins are the contaminants of
concern. When the treatment of other halogenated
organics, such as chlorinated phenols or halogenated
aliphatics, or other matrices, such as sediment are
involved, however, screening studies may be required,
particularly given the proprietary nature of chemical
dehalogenation reagents.
Typically, remedy-screening treatability studies are
conducted at the bench scale under "severe" conditions,
based on available data and knowledge of the reaction
chemistry. These conditions may include a substantial
excess of reagent, high reaction temperature, and
extended treatment duration. The concentrations of the
target (or indicator) contaminants in the soil are measured
before and after treatment to determine the efficiency of
the dehalogenation process. Generally, this is the only
measure of performance obtained at the screening tier.
The suggested performance goal for remedy-screening
treatability studies is a 90 percent or greater reduction in
the concentrations of the target contaminants.
(Alternatively, site cleanup criteria can be used if they
have been determined at this early stage in the RI/FS
process.) If this goal is achieved, the process is
considered a feasible alternative and is retained for further
evaluation. If greater than 90 percent reduction in the
target contaminant concentrations cannot be achieved
under the severe conditions of screening treatability
studies, the technology should be screened out.
A preliminary cost estimate for treatment of the
contaminants/matrix of interest by chemical
dehalogenation also may be developed at this tier for the
purpose of screening different processes.
3.2.3 Remedy-Selection Treatability
Studies
Remedy selection is the second step in the tiered
approach. A remedy-selection treatability study is
designed to verify whether a chemical dehalogenation
process can meet the site cleanup criteria and at what
cost. The purpose of this tier is to generate the critical
performance and cost data necessary for remedy
evaluation in the FS.
After the feasibility of dehalogenation has been
demonstrated, either through screening studies
or a literature review, various process or
operating parameters are investigated at
the remedy-selection tier. As in screening studies,
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tests are normally conducted at the bench scale and the
concentrations of the target contaminants in the soil are
measured before and after treatment to determine the
efficiency of the dehalogenation process. At this tier,
however, operating parameters such as treatment
temperature, reaction time, and reagent
formulation/loading are examined for their effects on
target contaminant concentrations. The choice of
parameters to be investigated should be based largely on
the contractor's or vendor's experience and engineering
judgment and on the available funding. Alternatively,
several samples of the waste representing the range of
site conditions likely to be encountered may be subjected
to testing under a more limited scope. In either case, a
remedy-selection study should provide the RPM with
enough information to ensure that the performance
objectives can be reliably met.
Performance goals for remedy-selection treatability
studies should correspond to the anticipated remedial
action objectives (cleanup criteria) for the site. If the
dehalogenation process can achieve these cleanup
criteria, it should be retained as an alternative for detailed
analysis in the FS. The development of treatability study
performance objectives is described in more detail in
Subsection 4.1 of this document.
Data from remedy-selection treatability studies can be
used to characterize the product and residuals from
dehalogenation treatment. Dependingontherequirements
of posttreatment testing, multiple bench tests or a modest
pilot-scale run may be necessary to generate the requisite
sample volume, particularly if the process is part of a
treatment train.
Data generated at this treatability tier can also be used to
estimate the costs of full-scale implementation of the
alternative, as required in the detailed analysis.
Subsection 6.1 of this document includes a detailed
discussion on the use of treatability study data in the
preparation of this cost estimate, which should have an
accuracy of+50 percent to -30 percent.
3.2.4 Remedial Design/Remedial Action
Treatability Studies
Remedial design/remedial action is the final step in the
tiered approach. These studies are conducted after the
remedy has been selected and the ROD has been signed.
The need for an RD/RA chemical dehalogenation
treatability study may be identified by the RPM, the PRP,
the vendor, or the remedial designer. The designer should
carefully review the available site-, technology-, and
waste-specific treatability data before deciding whether an
RD/RA treatability study is needed.
In the implementation of a remedy, RD/RA treatability
studies can be used 1) to select among multiple chemical
dehalogenation processes and prequalify vendors or
these processes, 2) to select the most appropriate of the
remedies prescribed in a Contingency ROD, or 3) to
support Agency-prepared detailed design specifications
for dehalogenation systems and treatment trains.
Vendor/Process Prequalification
A single remedy is usually selected in the ROD. This
remedy is often identified as a technology class or family
(e.g., chemical dehalogenation) rather than a specific
process. Selection of a treatment class affords flexibility
during the remedial design to procure the most
cost-effective vendor and process.
One method of selecting an appropriate chemical
dehalogenation process is to use RD/RA treatability
study results to "prequalify" a pool of vendors. In these
studies, all interested parties are provided with a standard
sample of waste. Each vendor uses that sample to design
and perform a treatability study and reports the treatment
results to the lead agency. Based on these results, the
lead agency determines which vendors are qualified to bid
on the RA. Generally, the vendor should achieve results
equivalent to the cleanup criteria defined in the ROD to be
considered for prequalification.
Contingency RODs
In some situations additional flexibility in the ROD may be
required to ensure implementation of the most appropriate
technology for a site. When this occurs, the selected
remedy may be accompanied by a proven contingency
remedy in a Contingency ROD.
Although treatability studies of chemical dehalogenation
will be conducted during the RI/FS to support remedy
selection, sufficient testing to address all of the
significant uncertainties associated with the
implementation of this technology may not be feasible.
This situation, however, should not cause dehalogenation
to be screened out during the detailed analysis of
alternatives in the FS. If, based on performance potential,
dehalogenation appears to provide the best balance of
trade offs from among the options considered, CERCLA
Section 121 (b)(2) provides support for selecting the
technology in the ROD despite the uncertainties.
Implementation of a chemical dehalogenation remedy,
however, may be contingent upon the results of RD/RA
treatability testing. When dehalogenation is selected and
its performance is to be verified through additional
treatability testing, a proven treatment technology may
also be included in the ROD as a contingency remedy. In
the event the RD/RA treatability study results indicate
that dehalogenation cannot achieve the cleanup goals at
the site, the contingency remedy is implemented.
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Detailed Design Specifications
To support the remedial action bid package, the lead
agency may choose to develop detailed design
specifications. If technical data available from the RI/FS
are insufficient for designing the chemical dehalogenation
remedy, an RD/RA treatability study may be necessary.
Post-ROD treatability studies can provide the detailed
cost and performance data required to optimize the
chemical dehalogenation process and to design a
full-scale treatment system. Conducted at the pilot-scale,
these studies typically generate the following types of
data:
• Materials-handling characteristics
• Reagent recovery/recycling efficiency
• Energy/chemical usage
• Treatment train performance
• Residuals treatment performance
The parameters investigated at the RD/RA tier may
include feed rates (continuous processes), number of
treatment cycles (batch processes), mixing rates, heating
rates, and other equipment-specific parameters. The
objective of these studies is to optimize the process in
terms of both performance and cost.
If an RD/RA treatability study is required to support the
detailed design specifications, the designer will be
responsible for planning the study and defining the
performance goals and objectives.
Post-ROD RD/RA treatability studies can also be
performed to support the design of treatment trains.
Although all parts of a treatment train may be effective at
treating die wastes, matrices, and residuals of concern,
issues such as unit sizing, materials handling, and
systems integration also must be addressed. Treatability
studies of one unit's operations can assist in identifying
characteristics of the treated material that may specifically
need to be considered in the design of the rest of the
train.
3.2.5 Case Study: Tiered Approach
Applied to a CERCLA Treatability
Study
The following case study illustrates how the tiered
approach can be applied to a treatability investigation at
a CERCLA site. In this example, chemical dehalogenation
has been identified as a potential remedial alternative.
Treatability data gaps are identified in the literature
survey. The feasibility of a commercially available process
is investigated in the remedy-screening study. In the
remedy-selection study, performance and cost data and
information on the toxicity of the treated product are
collected for use in the detailed analysis of alternatives.
CASE STUDY: TIERED APPROACH APPLIED TO A CERCLA TREATABILITY STUDY
Background
The soil at a Superfund site was contaminated with the insecticide DDT (dichlorodiphenyltrichloroethane) and
its metabolites ODD (dichlorodiphenyldichloroethane) and DDE (dichlorodiphenyldichloroethylene). One of the
site's remedial action objectives was to reduce the concentrations of DDT, ODD, and DDE in the soil to below
10 ppm. Remedial technologies and process options were screened based on their ability to meet this
remedial objective. Alternatives for treatment of the soil were then developed and screened based on their
effectiveness, implementability, and cost. Three remedial action alternatives—incineration, soils washing, and
chemical dehalogenation-were retained for further consideration during the detailed analysis. Chemical
dehalogenation was classified as an innovative technology.
Literature Survey
A literature survey was conducted on each of the three alternatives to identify processes within each technology
type that are commercially available and to collect treatability data on these processes. The literature survey
produced a sufficient amount of performance data on the incineration of DDT for an immediate detailed
analysis of this alternative against the nine RI/FS evaluation criteria.
The literature survey on soils washing identified a commercially available process that had been investigated
as part of the Superfund Innovative Technology Evaluation (SITE) Program. Based on these SITE data, this
process was determined to be sufficiently well demonstrated for detailed analysis.
The chemical dehalogenation literature survey identified data on the treatment of PCBs in soil; however, no
process had yet been investigated for its ability to treat DDT contamination. Without these data, chemical
dehalogenation could not be evaluated against the reduction of toxicity, mobility, and volume criterion. Data on
its cost, long-term effectiveness and permanence, and compliance with ARARs were also found to be
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CASE STUDY (continued)
insufficient for evaluation of chemical dehalogenation as an alternative. Consequently, a two-tiered treatability
study was performed to address these data needs.
Remedy-Screening Treatability Study
The chemical dehalogenation literature survey identified a proprietary alkaline polyethylene glycol (APEG)
process that uses potassium hydroxide (KOH) and the cosolvent/catalyst dimethylsulfoxide (DMSO). The
vendor of this process was contracted to perform a remedy-screening treatability study to determine the
feasibility of using this process to treat the DDT-contaminated Superfund site soil.
Contaminant concentrations in the untreated soil ranged from 100 ppm DDE to 8000 ppm DDT. The
performance goal of this study was to achieve concentrations of less than 10 ppm each for DDT, ODD, and
DDE in the treated soil, contaminant levels that corresponded to the site's remedial action objective.
A particle-size distribution analysis of the soil indicated that normal agitation and centrifugation procedures
would be adequate. The amount of KOH required for treatment was determined by analyzing the KOH
absorption capacity of the soil.
In a bench-scale reactor, 1 kg of soil was mixed with 1 kg of reagent. Preparation of the reagent, which was
based on the vendor's past treatability experience, consisted of 167 g polyethylene glycol, 167 g
triethyleneglycol methyl ether, 334 g DMSO, and 332 g 45-percent KOH. The reaction was conducted at 150-C.
Monitoring samples were collected from the reactor at 1-hour intervals and analyzed for DDT, DDE, and ODD.
The reaction was stopped when the concentration of each of these contaminants was lowered to below 10
ppm. This level of dehalogenation was achieved in 3 hours.
At the conclusion of the reaction, the reagent and soil fractions were separated by centrifugation. The soil was
then rinsed with water. All exit fractions (treated and washed soil, recovered reagent, soil wash-water, and
condensate) were analyzed for DDT and its metabolites in accordance with Contract Laboratory Program
(CLP)-based methods.
The CLP-based analyses indicated nondetectable levels of DDT, DDE, and ODD in the treated soil and in all
exit fractions. Mass-balance calculations indicated that 59 g of KOH was consumed during treatment. Based
on original contaminant concentrations, the maximum amount of KOH that could be consumed in
dehalogenation reactions was 5 g. The remaining KOH was believed to have been consumed in side
reactions with the soil.
Remedy-Selection Treatability Study
Based on the favorable results of the remedy-screening study, the APEG process was determined to be
feasible for reducing the total mass of toxic halogenated contaminants in the site's soil. Data on cost, long-
term effectiveness and permanence, and compliance with ARARs, however, were still needed for an evaluation
of chemical dehalogenation as an alternative. Therefore, a remedy-selection study was performed.
Several test objectives were established before testing was initiated. As the Rl progressed, the site's cleanup
criteria were set at 1 ppm for DDT and its metabolites. These criteria translated into equivalent performance
goals for the remedy-selection testing. Another test objective was to generate a cost estimate that could be
used in the detailed analysis. This cost estimate would be refined by designing the treatability study to evaluate
reagent loading, formulation, and recovery. A third test objective was to assess the toxicity, mutagenicity, and
bioaccumulative nature of the reaction products.
The bench-scale equipment and methodology used were unchanged from those for the remedy screening. In
the first test run, reagent loading was reduced by 40 weight percent to 600 g reagent for treatment of 1000 g
soil. In the second test, the reagent formulation was investigated by replacing KOH with sodium hydroxide
(NaOH) at the reduced loading. The reactions were conducted at 150C.
Monitoring samples were collected from the reactor at 1-hour intervals and analyzed for DDT, DDE, and ODD.
The reactions were allowed to continue until the contaminant concentrations were lowered to 1 ppm or less or
until the rate of reduction reached zero.
Based on the screening samples, treatment with the lower reagent loading was still effective. Contaminant
concentrations were reduced to less than 1 ppm after 5 hours of treatment with the smaller quantity of KOH
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CASE STUDY (continued)
in the reagent. When KOH was replaced by NaOH in the reagent formulation, however, the 1 ppm performance
goal could not be achieved after treatment for 14 hours. Reagent recovery analysis showed that half as much
NaOH (compared with KOH) was consumed by side reactions with the soil. A reduction in reagent cost may
therefore be achieved by replacing some of the KOH with NaOH.
Because the APEG system had not been previously used to treat DDT-contaminated soil, the reaction products
were assayed to determine whether they were toxic, mutagenic, or bioaccumulative. Testing included
assessments of:
Acute oral toxicity
Acute aquatic toxicity
Mutagenicity
Earthworm survival
All tests and bioassays except the earthworm survival test were conducted by using a synthesized reaction
product prepared without soil. Each of the pesticide concentrations in the reaction product was less than 2
ppm.
The reaction product was administered to guinea pigs to evaluate its acute oral toxicity. The sample was lethal
at a dose of 2500 mg/kg. Test animals suffered ataxia, tremors, and convulsions before death, which suggests
that the reaction product is neurotoxic.
Acute aquatic toxicity was evaluated with fathead minnows exposed to a lethal concentration for 50 percent
(LC5o) of the test animals. Results of the LC50 range findertest demonstrated an LC50 of 1200 ppm for fathead
minnows. The LC50 of DDT itself is 19 ppb, much lower than that measured for the reaction product.
The reaction product was subjected to the Ames test to determine if it had mutagenic potential. At doses of 5.0
and 1.0 mg/plate, the product was toxic to the Salmonella bacteria. At doses of 0.5, 0.05, and 0.005 mg/plate,
the product was nontoxic and nonmutagenic.
The EPA Earthworm Survival Test was conducted to evaluate the acute toxicity potential of the treated soil to
soil-dwelling organisms. A sample of treated soil was washed with water an additional four times to reduce
the soil conductivity to 900 mmho. The earthworms burrowed into the soil without any visible signs of distress;
however, the site soil produced 100 percent mortality within 24 hours. Because earthworms can typically live in
pesticide-contaminated soil for several days, the rapid mortality was attributed to the residual DMSO in the soil.
In the detailed analysis of alternatives, major treatment cost factors for chemical dehalogenation were
identified as total soil volume, reaction time, and soil moisture content. Treatment cost estimates ranged from
approximately $325 to $400 per yd3 of soil. The final cost estimate, including excavation, mobilization/
demobilization, analyses, and long-term site monitoring, was developed with an accuracy of +50/-30 percent.
Applicable or relevant and appropriate requirements (ARARs) at the site that directly concerned chemical
dehalogenation included a location-specific ARAR to protect a sensitive wetland area adjacent to the site. The
bioassessment data generated during the treatability study were used to evaluate compliance with this
requirement.
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SECTION 4
TREATABILITY STUDY WORK PLAN
Carefully planned treatability studies are necessary to
ensure that the resulting data are useful for evaluating the
feasibility, performance, and cost of a technology. The
Work Plan, which is prepared by the contractor when the
Work Assignment is in place, sets forth the contractor's
proposed technical approach for completing the tasks
outlined in the Work Assignment. It also assigns
responsibilities and establishes the project schedule and
costs. Table 3 presents the suggested organization of a
treatability study Work Plan.
Table 3. Suggested Organization of
Treatability Study Work Plan
1. * Project description
2. * Remedial technology description
3. Test objectives
4. Experimental design and procedures
5. Equipment and materials
6. Sampling and analysis
7. * Data management
8. Data analysis and interpretation
9. Health and Safety
10. Residuals management
11.* Community relations
12. * Reports
13. Schedule
14. Management and staffing
15. Budget
Source: EPA 1989a.
Elements of a Work Plan that are standard for all
technologies are starred in the table and described in
general terms here. Further information on these items can
be found in the final generic guide. The remaining
elements are discussed in greater detail in the subsections
that follow.
Project Description.
The proj ect description provides background information
on the site and summarizes existing waste characterization
data (matrix type and characteristics, contaminant
concentration and distribution). The project description
also specifies the type of study to be conducted--remedy
screening, remedy selection, or RD/RA. For treatability
studies involving multiple tiers of testing, it states how
the need for subsequent levels of testing will be
determined from the results of the previous tier.
Remedial Technology Description.
This section briefly describes the chemical
dehalogenation process to be tested. A flow diagram can
be included that shows the input stream, the output
stream, and any residual streams generated as a result of
the treatment process. For treatability studies involving
treatment trains, the remedial technology description
should address all the unit operations the system
comprises. A description of the anticipated pre- and post
treatment requirements may also be included here.
Data Management.
Treatability studies must be well documented, particularly
if the findings are likely to be challenged by a responsible
party,the State, orthe community. This section describes
the procedures for recording observations and raw data
in the field or laboratory, including the use of bound
notebooks, data collection sheets, and photographs. If
proprietary processes are involved, this section also
describes how confidential information will be handled.
Community Relations.
A Community Relations Plan is required for all
remedial response actions under CERCLA. This
section describes the community relations activities
that will be performed in conjunction with
the treatability study. These activities may
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include, but are not limited to, preparing fact sheets and
news releases, conducting workshops or community
meetings, and maintaining an up-to-date information
repository.
Reports
Complete and accurate reporting of chemical
dehalogenation treatability study test results is critical, as
decisions about treatment alternatives will be based, in
part, on the outcome of these studies. Besides assisting
in the selection of the remedy, the reporting of treatability
studies will increase the existing body of scientific
knowledge regarding the applications and limitations of
this treatment process.
As an aid in the selection of remedies and the planning of
future treatability studies, the Office of Emergency and
Remedial Response requires that a copy of all treatability
study reports be submitted to the Agency's RREL
Treatability Data Base Repository, which is being
developed by the Office of Research and Development
(EPA 1989b). Submitting treatability study reports
organized in the manner suggested in the final generic
guide will increase the usability of this repository and
assist in maintaining and updating the data base.
4.1 TEST OBJECTIVES
The Work Plan outlines the treatability study test
objectives and describes how they will be used in
evaluating chemical dehalogenation for selection at a site.
Test objectives consist of meeting quantitative
performance goals or making a qualitative engineering
assessment of the process. Well-reasoned test objectives
will ensure that the treatability study provides meaningful,
scientifically sound data for remedy evaluation and
selection.
Test objectives for remedy-screening treatability studies
of chemical dehalogenation focus on the degree of
reduction in toxicity achieved as a determinant of
feasibility. As shown earlier in Table 2, a performance goal
of greater than 90 percent reduction in the target
contaminant concentrations should be achieved at this
tier. If this test objective is met, chemical dehalogenation
is considered a feasible alternative and is retained for
remedy-selection testing.
At the remedy-selection tier, the treatability study test
objectives should correspond to the site's final
remediation goals. These numerical values establish the
minimum acceptable amount or concentration of a
contaminant that may remain on site or be discharged to
the environment. Preliminary remediation goals are set by
the lead agency based on chemical-specific health-based
applicable or relevant and appropriate requirements
(ARARs) and assumptions about reasonable maximum
land-use and standard exposure pathways. Ideally, final
remediation goals or "cleanup criteria" will be determined
for a site early in the RI/FS process, before any
remedy-selection treatability studies are conducted. At
sites where this is not the case, test objectives must be
developed.
Like remediation goals, remedy-selection test objectives
should be based on ARARs. Potential ARARs for the
remediation of soil contaminated by halogenated organics
include the Resource Conservation and Recovery Act
(RCRA) land disposal restrictions (LDRs) and the Toxic
Substances Control Act (TSCA) regulations for PCBs.
Where wastewater that is generated and released as a
residual of chemical dehalogenation treatment may carry
halogenated organics to ground or surface water, the
Clean Water Act may provide potential ARARs.
Guidance on potential ARARs is available in CERCLA
Compliance with Other Laws Manual: Interim Final
(EPA 1988b) and CERCLA Compliance with Other Laws
Manual: Part II (EPA 1989c).
The LDRs promulgated under 40 CFR Part 268 of RCRA
restrict the land disposal of certain industrial wastes
containing spent solvents, dioxins, California List wastes,
and the First Third, Second Third, and Third Third listed
wastes. These restrictions also apply to soils
contaminated with these wastes, including soil generated
from removal and remedial actions at Superfund sites,
corrective actions and closures at RCRA-regulated
disposal sites, and private party cleanups. Guidance on
LDRs is available in a series of Superfund Fact Sheets
including the following:
• Superfund LDR Guide #1: Overview of RCRA Land
Disposal Restrictions (EPA 1989d)
• Superfund LDR Guide #2: Complying With the
California List Restrictions Under Land Disposal
Restrictions (EPA 1989c)
• Superfund LDRGuide #3: Treatment Standards and
Minimum Technology Requirements Under Land
Disposal Restrictions (EPA 1989f)
• Superfund LDR Guide #4: Complying With the
Hammer Restrictions Under Land Disposal
Restrictions (EPA 1989g)
• Superfund LDR Guide #5: Determining When Land
Disposal Restrictions Are Applicable to CERCLA
Response Actions (EPA 1989h)
Superfund LDR Guide #6A (2nd Edition):
Obtaining a Soil and Debris Treatability Variance
for Remedial Actions (EPA 1990a)
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• Superfund LDR Guide #6B: Obtaining a Soil and
Debris Treatability Variance for Removal Actions
(EPA 1990b)
• Superfund LDR Guide #7': Determining When Land
Disposal Restrictions Are Relevant and Appropriate
to CERCLA Response Actions (EPA 1989i)
• Superfund LDR Guide #8: Compliance with Third
Third Requirements under the LDRs (EPA 1990c)
Treatment standards for RCRA-restricted wastes are
promulgated under 40 CFR Part 268 Subpart D. The
Agency recognizes that it is generally more difficult to
treat contaminated soil than corresponding industrial
wastes. Consequently, EPA plans to establish
concentration-based treatment standards specifically for
contaminated soil and debris. The regulated list of
constituents will include dioxins/furans, PCBs, and their
precursors, among others.
As described in Guidance on Remedial Actions for
Superfund Sites with PCB Contamination (hereinafter
referred to as the PCB guidance) (EPA 1990d), there are
three primary options for treatment of nonliquid PCBs at
concentrations of 50 ppm or greater that are compliant
with TSCA ARARs (40 CFR 761.60-761.79):
1) Incineration
2) Treatment equivalent to incineration
3) Disposal in a chemical waste landfill
Under 40 CFR 716.60(e), chemical dehalogenation can be
used to treat PCB-contaminated material with no long-term
management of residuals if treatment achieves a level of
performance equivalent to incineration. As described in
the PCB guidance, equivalence can be verified by
demonstrating that the solid treatment residuals contain
less than or equal to 2 ppm PCBs. If chemical
dehalogenation cannot achieve this level of performance,
but does result in substantial reductions (i.e., 90-99
percent), treatment plus long-term management in a
chemical waste (TSCA-approved) landfill may be
acceptable.
The PCB guidance recommends cleanup levels of 1 ppm
PCBs for PCB-contaminated Superfund sites where land
use is residential. Assuming no soil cover or management
controls, this cleanup level equates to approximately a 10"5
excess cancer risk. In areas where land use is industrial,
the PCB guidance recommends a range of 10 to 25 ppm
PCBs for cleanup levels. These levels approximate a 10"4
excess cancer risk (assuming exposure equivalent to that
in residential areas). Remedial alternatives should reduce
PCB concentrations to these site-specific levels or limit
exposure to concentrations above these levels.
The cleanup levels recommended in the PCB guidance can
be used to set performance goals for chemical
dehalogenation treatability studies at the
remedy-selection tier. Chemical dehalogenation need not
achieve 1 ppm PCB at a residential site to be successful.
As part of an alternative, chemical dehalogenation should
achieve a level of treatment that will allow the entire
remedy to be protective of human health and the
environment. For example, a test objective of 10 ppm PCBs
may be appropriate for a residential site if chemical
dehalogenation is part of a treatment train and the
alternative includes long-term management controls that
will reduce exposure to 1 ppm PCBs.
By achieving performance goals based on cleanup criteria,
the remedy-selection treatability study provides data
needed to conduct evaluations of 1) the long-term
effectiveness and permanence of chemical
dehalogenation, and 2) the reduction in toxicity, mobility,
and volume of the contaminants. As discussed earlier,
these evaluations take place during the detailed analysis
of the alternatives phase of the FS. Achieving the clean
levels also allows chemical dehalogenation to be selected
as a remedial action with reasonable certainty that the site
response objectives can be achieved.
The long-term risks posed to biota by the disposal of
treated product on site may also require investigation at
the remedy selection tier. Bioassays of treated product
require large volumes of material. Generally, such
quantities are not available from bench-scale studies. A
pilot-scale test, however, could generate sufficient
product for biotoxicity testing. If pre-ROD pilot tests are
to be performed at a site, a test objective stipulating a
reduction in toxicity to test organisms should be set to
provide bioassay data for the assessment of long-term
effectiveness and permanence in the detailed analysis of
alternatives.
4.2 EXPERIMENTAL DESIGN AND
PROCEDURES
The Work Plan should clearly outline the experimental
design and procedures to be used for each tier of
treatability testing planned.
4.2.1 Remedy-Screen ing Treatability
Studies
Remedy screening of chemical dehalogenation
is intended to determine if the technology is
feasible for a given waste stream. Screening
studies are applicable if little or no data exist with
respect to the performance of the technology for
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the contaminant/matrix of interest. To reduce the risks of
falsely screening out the technology at this early stage,
the treatment should be carried out under "severe
conditions"; i. e., the reaction should proceed with the use
of excess reagent at a high temperature for an extended
period of time. The particular reaction conditions used
should be based on the process vendor's knowledge of
the equipment and reaction chemistry. A single test run
should be performed, and only limited QA/QC is required.
At the screening tier, the experimental procedures should
not be complex. Only pre- andposttreatment samples will
be collected. Physical and chemical analysis will be
limited. The vendor or testing facility should supply their
standard operating procedures (SOP) for these sampling
and analysis events as part of the treatability study Work
Plan.
4.2.2 Remedy-Selection Treatability
Studies
If chemical dehalogenation is determined to be potentially
feasible at the remedy-screening tier, the effect of varying
operating parameters on treatment performance can be
investigated at the remedy-selection tier. Parameters that
can be evaluated at this tier include reagent formulation
and loading, temperature, reaction time, and other
process-specific parameters. Duplicate or triplicate test
runs should be performed, and a stringent level of QA/QC
is required.
A remedy-selection treatability study must be designed to
generate sufficient quantities of treated product and
treatment residuals for characterization and posttreatment
testing. Treated product may have many uses in a
remedy - selection study. In addition to being analyzed for
target contaminants and reaction byproducts, treated
product will be required for additional investigations,
such as biotoxicity testing, bulk density determination,
mechanical testing (i.e., durability, permeability,
unconfined compressive strength), and nutrient analysis.
To design an appropriate treatability study, these
posttreatment tests must be chosen in advance. If the
dehalogenation process is part of a treatment train, the
amount of treated material needed to investigate other
train components must also be determined before the
chemical dehalogenation study is designed. Experimental
design, options for generating this additional product
include, but are not limited to, multiple batch, bench-scale
(1 to 10 liters) tests performed in a "lock-step" procedure;
a single batch, pilot-scale (50 to 100 liters) test; or a
combination of both.
Treatment residuals should also be characterized at this
tier, to the extent practical. Full-scale chemical
dehalogenation treatment may generate several residual
streams, including spent reagent and wash waters,
condensate (aqueous and organic fractions), and process
off-gases. In a remedy-selection treatability study, these
streams can be sampled and analyzed for target
contaminants and selected reaction byproducts. The
experimental design and procedures of the treatability
study should allow for investigations of these residuals.
To establish that the target contaminants were
dehalogenated and not simply removed from the waste
and transferred to the residuals, a material balance should
also be performed. This analysis requires careful
measurement of the mass and volume of all materials that
enter and exit the treatability study apparatus. These data,
combined with the contaminant concentrations in the raw
soil, treated product, and treatment residuals, will facilitate
this determination.
Investigations of reagent recovery, residuals treatment,
and soil pre- and posttreatment also may be initiated at
the remedy-selection tier; however, because of the
quantity of materials required, such investigations may be
delayed until post-ROD RD/RA testing.
At the remedy-selection tier, the experimental procedures
should model the expected field operations, particularly
with regard to the residual streams that will be generated.
The vendor or testing facility should supply their SOP as
part of the treatability study Work Plan. This SOP should
be sufficiently detailed to permit the RPM to evaluate the
adequacy of the proposed technical approach.
4.3 EQUIPMENT AND MATERIALS
In addition to the experimental design and procedures, the
Work Plan should clearly specify the equipment and
materials to be used during each tier of testing. Remedy
screening treatability Studies normally are performed in a
batch system with off-the-shelf laboratory glassware and
bench-scale equipment. A typical bench-scale reactor
consists of a reaction flask, a stirrer, a heating mantel, and
a condensate collection system. Figure 6 shows a typical
chemical dehalogenation bench-scale reactor. Remedy-
selection studies will be performed with larger bench- or,
occasionally, pilot-scale equipment. These systems may
include ancillary equipment such as a feed preparation
and delivery system, a steam plant, a reactant delivery
system, and a soil/reagent separation system. Figure 7
shows the details of an example pilot-scale reactor.
The Work Plan also should specify the reagent
formulation(s) to be tested, many of which are proprietary.
The alkaline glycolate reagents generally contain an
alkaline metal hydroxide (e.g., NaOH or KOH), an alcohol
or glycol (e.g., polyethylene glycol), and an optional
cosolvent or catalyst (e.g., dimethylsulfoxide).
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4.4 SAMPLING AND ANALYSIS
This subsection describes the factors associated with
sampling and analysis that affect the development of the
Work Plan for chemical dehalogenation treatability
studies. Examples of these factors are the number and
types of samples and analyses required, sample
preparation procedures, and the number of replicates and
blanks. These factors will affect the project schedule and
budget requirements that must be determined in the
development of the Work Plan. Issues related to the
development of a Sampling and Analysis Plan (SAP) are
discussed in Section 5.
4.4.1 General Considerations
During the development of the Work Plan, available data
fromthe RI on the physical and chemical properties of the
matrix should be reviewed and evaluated with respect to
completeness and adequacy. Data of interest include the
following:
• Target halogenated organic contaminants and
concentration ranges.
• Spatial distribution of target contaminants (e.g.,
location of "hot" zones).
• Presence of contaminants at levels that limit the use
of a testing or disposal facility (e.g., few facilities can
accept wastes containing dioxins or PCBs above
certain concentrations).
• Presence of other contaminants (e.g., certain organic
solvents) that may interfere with the extraction and
analysis of target contaminants.
• Presence of reactive species (e.g., elemental forms of
certain metals) that may be affected by the
dehalogenation reagents.
• Soil type.
• Moisture content (soils) or solids content (sludges,
sediments).
• Particle-size distribution.
These data should be evaluated along with the
treatability test objectives for the development
of an approach for collection, preparation, and
analysis of samples for treatability testing. If the
available data are insufficient, the Work Plan may
need to include either an initial site sampling
Glycol blow-out
loop and catch flask
Vacuum release
Distillation
condenser (glass)
Stirring motor chuck
Thermocouple
Distillate
receiver
(glass)
100-5000 mL
reaction
flask (steel)
Steel stirring
paddle
to Vacuum
Bubbler
(for odor
control)
Temperature
control unit
Source: Modified from Galson Remediation Corporation 1990.
Figure 6. Example chemical dehalogenation bench-scale reactor.
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2-in. Vent
1-in. Liquid
Charge Port
2-in. Uquid
Charge Ports
Top Manifold
to Mixer Jacket
Steam In
Cooling Water Out
1-in. Liquid Loading Port
(Typ. Both Ends)
Nitrogen Purge Seals
(Typ. Both Ends)
24 in. x 20 in. Flanged v)
Solids Loading Port
16-ln. Flanged
Screen Assembly
8-in. Air-Operated Ball Valve
for Mixer Contents Discharge
, Bottom Manifold
to Mixer Jacket
Cooling Water In
Steam Out
Source: PEI Associates, Inc. 1989.
Figure 7. Example chemical dehalogenation pilot-scale reactor.
visit to collect the necessary waste characterization data
or the use of a field analytical screening method to
prescreen soil and to select appropriate sample locations
for the treatability studies.
4.4.2 Field Sampling and Sample
Preparation
The objectives of treatability testing influence the type or
sample to be collected (i.e., "average-case" or
"worst-case" sample). For remedy-screening studies
involving wastes that have not previously been tested,
soils with average concentrations of the target
contaminants should be sampled. For remedy-selection
studies involving wastes that have been extensively
tested, samples representing worst-case soil
concentrations or conditions should be selected. Grab
samples from the hot zones will yield samples
representative of worst-case conditions. For
studies involving multiple, widely different matrices,
samples of each type should be collected and
tested separately. If results from the treatability
testing of different treatment technologies are to
be directly compared, the same type of sample must be
used in each test.
In most cases, soil samples collected in the field will
require some preparation prior to treatability testing of
chemical dehalogenation processes. At a minimum,
sample preparation will usually involve sample screening
to remove oversize material and debris and sample
homogenization for greater analytical precision and
comparability. Studies conducted at the pilot scale also
may involve crushing of oversize soil particles that do not
pass through the screens. The need for additional
pretreatment is largely equipment specific and should be
based on the vendor's recommendations. Depending on
the tier of treatability testing and the field conditions,
these sample preparation activities may take place in the
field or in the laboratory.
The amount of sample collected should be based on the
quantities needed for each test run and for pre-
and posttreatment analyses as well as the
number of test runs and replicate analyses
to be performed. Bench-scale test-, at the remedy-
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26
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screening tier generally require small sample volumes (<1
L per test run). The increased number of test runs and the
extent of pre-and posttreatment analyses for bench-scale,
remedy-selection testing will require that a greater total
waste sample volume be collected. Pilot-scale tests
conducted in support of remedy selection will require
much larger sample volumes (> 100 L per batch). If the
dehalogenation process is part of a treatment train, the
volume of treated product and treatment residuals needed
for later testing also will impact the total volume of waste
to be collected. An excess amount of waste sample should
always be collected in the event additional test runs and
analyses should be required during the course of the
study and to account for losses during sample
preparation and for other contingencies.
4.4.3 Waste Characterization
Table 4 summarizes the waste characterization analyses
that should be considered in developing The Work Plan.
The types of analyses usually performed are similar for
both remedy-screening and remedy-selection treatability
studies. Standard EPA and the American Society for
Testing and Materials (ASTM) methods are generally
recommended; however, the treatability study vendor may
propose modified or equivalent methods for noncritical
measurements. The EPA RPM must determine the
acceptability of these alternative methods
with respect to the test objectives and the available
method validation information provided by the vendor.
Various chemical tests may be used to establish the
baseline concentration of the target halogenated organic
contaminants and other contaminants of interest. In the
case of chemical dehalogenation treatment, the target
contaminants may be PCBs, dioxins/furans,
pesticides/herbicides, halogenated benzenes and phenols,
or halogenated aliphatics. For remedy-screening studies,
only one analysis for the target contaminants expected to
be present in the untreated waste may be necessary. For
remedy-selection studies, however, two or three replicate
analyses may be required to establish the homogeneity of
the waste and to determine statistical confidence levels
for the target contaminant concentrations.
Additional compounds of interest at the remedy-selection
tier may include selected possible halogenated
byproducts from the degradation of the target
contaminants. For example, if pentachlorophenol is the
target contaminant present, analysis fortrichlorophenols
(e.g., 2,4,5-trichlorophenol) and dichlorophenols (e.g.,
2,4-dichlorophenol) may be appropriate to establish a
pretreatment baseline concentration for these potential
degradation byproducts. The selection of other
halogenated organic compounds should be based on the
likely chemical reactions and relative toxicity of the
Table 4. Waste Characterization Analyses
Parameter
Remedy
screening
Remedy
selection
Description of test8
Use of data
Target halogenated organic contami-
nants
Other halogenated organic compounds
Other chemical parameters
Volatile oraganics
Metals
Gas chromatography
Gas chromatography/mass
spectrometry
Gas chromatography
Gas chromatography/Mass
spectrometry
Gas chromatography
Atomic absorption
spectroscopy Inductively
coupled plasma spectroscopy
Establish baseline for determining
target contaminant reduction and
treatment effectiveness.
Establish baseline for investigating
formation of specific reaction
byproducts.
Establish baseline for investigating
contaminant losses. Identify health
and safety hazards.
Establish baseline for investigating
contaminant losses. Identify health
and safety hazards.
pH/base absorption capacity
Moisture content
Particle-size distribution
Biotoxicity
X X Electrometric
Titration
Proprietary methods
X X Oven dry
X X Sieving
Hydrometer
X Algae
Macroinvertebrates
Fathead minnow larvae
Seed germination
Earthworm
Microtox™
Ames
Determine reagent
formulation/loading
Determine reagent
formulation/loading
Determine experimental apparatus.
Establish baseline for comparing
biotoxicity of waste before and
after treatment.
Test methods may be EPA, ASTM, or equivalent.
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27
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byproducts. Compounds that could interfere with the
chemical dehalogenation process or those that affect
treatment or handling of residual fractions from the
process also may be of interest at the remedy-selection
tier. For example, volatile organic compounds may be
tested as a basis for calculating volatile losses during
treatment. Occasionally, the potential presence of
highly toxic or carcinogenic compounds may warrant
additional analytical testing.
Soil moisture content and pH or buffering (base
absorption) capacity are used to formulate the chemical
dehalogenation reagent at the remedy-screening and
remedy-selection tiers.High-moisture-contentsoilsmay
require greater quantities of reagent because of the
dilution effects of the soil water. Acidic soils or soils
with a high buffering capacity will require excess base
to compensate for base-consuming reactions with the
soil. Particle-size analysis of the soil is used to
determine the experimental apparatus needed for mixing
and soil/reagent separation. For example, sandy soils
with low clay content may be separated by vacuum
filtration, whereas soils with significant fines content
may require centrifugation.
As with other treatability studies, additional
characterization tests may be required by the laboratory
or testing facility to maintain compliance with their
operating permit. Waste characterization tests may also
be required for disposal of unused samples.
Bioassays of the untreated waste may be required to
establish baseline biotoxicity data if replacement of the
treated product on site is being evaluated as a disposal
option. These methods are described later in
Subsection 5.1.7.
4.4.4 Treated Product and Residuals
Sampling and Analysis
Table 5 summarizes the analyses of the treated soil and
otherfractions resulting from the treatment process (i.e.,
used reagent solution, rinse water, condensate, and
absorbent traps) that should be considered in
developing the Work Plan. Generally, posttreatment
sampling and analysis at the remedy-screening tier will
be limited to the target halogenated organic
contaminants in the treated product. At the
remedy-selection tier, the treatment residuals also
should be analyzed. Standard EPA and ASTM methods
are generally recommended; however, the treatability
study vendor may propose modified or equivalent
methods subject to acceptance by the EPA RPM.
Target halogenated organic contaminants and other
compounds of interest include those discussed in
Subsection 4.4.3. Posttreatment analytes at the
remedy-selection tier also may include selected
potential halogenated byproducts. Because the
analytical results at the remedy-selection tier will be
used to evaluate the technology's ability to meet the
Table 5. Treated Product and Treatment Residuals Analysis
Parameter
Remedy Remedy
screening selection
Description of test8
Use of data
Target halogenated organic
contaminants
Other halogenated organic compounds
Other chemical parameters
Volatile oraganics
Metals
PH
Gas chromatography
Gas chromatography/mass
spectrometry
Gas chromatography
Gas chromatography/mass
spectrometry
Gas chromatography
Atomic absorption spectroscopy
Inductively coupled plasma
spectroscopy
X Electrometric
Titration
Determine target contaminant
reduction and treatment
effectiveness.
Investigate formation of specific
reaction byproducts.
Evaluate posttreatment and
disposal options. Investigate
contaminant losses due to
treatment.
Evaluate posttreatment and
disposal options. Investigate
containment losses due to
treatment.
Evaluate posttreatment and
disposal options.
Physical and mechanical parameters
Biotoxicity
X? Permeability
Pore volume
Unconfined compressive
strength
X° Algae
Macroinvertebrates
Fathead minnow larvae
Seed germination
Earthworm
Microtox™
Ames
Evaluate suitability of treated
product for onsite disposal.
Evaluate biotoxicity of treated
product. Determine reduction in
biotoxicity of waste. Evaluate
suitability of treated product for
onsite disposal.
Test methods may be EPA, ASTM, or equivalent
Treated product or treated product extract only.
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28
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cleanup goals for the site, two or three analyses may be
required to determine statistical confidence levels for the
target contaminant concentrations in the treated product.
Analysis for target and other contaminants of interest in
the treatment residuals also may be necessary at the
selection tier to demonstrate dehalogenation of the target
contaminants rather than physical removal.
This determination would require a careful accounting of
the mass of all materials that enter and exit the system.
The material balance, combined with the concentrations
of target contaminants in all exit fractions, can then be
used to refine the estimate of actual dehalogenation
efficiency of the process.
In addition to chemical tests, physical and toxicological
tests also may be conducted on treated product or
treatment residuals at the remedy-selection tier to evaluate
posttreatment and disposal options. If treated product is
to be placed back into the original excavation (i.e., not in
an onsite disposal cell), determination of its mechanical
properties, pH, and nutrient levels and the leachability of
remaining contaminants may be required. It is important to
note that mechanical test methods may require significant
quantities of soils (e.g., 20 kg); therefore, the vendor may
have to perform multiple test runs to generate sufficient
quantities of material for analysis. Bioassays also may be
necessary for evaluation of the toxic or mutagenic effects
of chemical dehalogenation residuals on biota. Applicable
tests include freshwater algae, daphnid, and minnow
assays of product extracts and seed germination and
earthworm tests of treated product. These tests are
described in Subsection 5.1.7.
If treated product is to be placed in an onsite disposal cell
or transported for disposal at an offsite RCRA facility, it
may be subject to RCRA land disposal restrictions.
Depending on their ultimate disposition, residual fractions
may be subject to additional testing requirements under
TSCA, RCRA, the Clean Water Act, and the Clean Air
Act.
4.5 DATA ANALYSIS AND
INTERPRETATION
Data from remedy-screening and remedy-selection
treatability studies will be used to evaluate chemical
dehalogenation during the detailed analysis of
alternatives. Analysis and interpretation of the treatability
study data must relate back to the test objectives
discussed in Subsection 4.1. Careful consideration
should be given to the uses of the data during the
development of this section of the Work Plan. A detailed
discussion on the interpretation and use of chemical
dehalogenation treatability data is provided in Section 6.
4.5.1 Remedy-Screening Treatability
Studies
Remedy screening of chemical dehalogenation generally
involves testing a small sample of the waste to determine
whether the process is feasible. If the feasibility of the
process is demonstrated, the effects of varying operating
parameters on treatment performance can be investigated
at the remedy-selection tier. A reduction of more than 90
percent in the concentration of the target contaminant at
the screening tier generally indicates that chemical
dehalogenation is feasible and should be retained for
further analysis.
For remedy-screening treatability studies, the
concentration of the target contaminants before and after
treatment should be tabulated, as shown in Figure 8. The
reaction conditions used also should be reported, along
with recommendations for the parameters to be
investigated in subsequent treatability studies.
Parameter
Pesticides/herbicides
4,4'-DDE
4,4'-DDT
ODD
Furans
TCDF
PeCDF
HxCDF
Before
treatment,
ppb
15.7
86.7
23.7
8.03
22.9
8.77
After
treatment,
ppb
<0.047
<0.016
<0.016
<1.71
<1.46
<3.69
Figure 8. Example tabulation of results from a
remedy-screening treatability study.
4.5.2 Remedy-Selection Treatability
Studies
Remedy-selection treatability studies of chemical
dehalogenation generally follow either a positive
remedy-screening test or a determination that the
technology is likely to be feasible for the waste based on
preexisting knowledge of the waste and the treatment
technology. Remedy-selection studies examine the effects
of varying operating parameters on treatment
performance. Parameters that can be investigated at this
tierinclude reagent formulation and loading, temperature,
reaction time, and other process- specific parameters.
As an aid to the decision maker in the analysis and
interpretation of data from chemical dehalogenation tests,
the con-
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29
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centration of the target contaminants may be plotted
versus changes in the critical process parameters, as
shown in Figure 9. Alternative methods of presenting the
data may be proposed by the technology vendor,
depending on the experimental design and the procedures
followed. A material balance that accounts for all of the
solids and liquids entering and exiting the system also can
be used to ensure that the contaminants have been
chemically altered, not simply physically removed. These
data can be summarized in a tabular format, as shown in
Figure 10.
1000
100
E
Q.
a.
m
a
o_
10
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\s
\J
V
s\^
V
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r-\
. '
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=\
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y
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V
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s
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-X
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hours
Source: Galson Research Corporation 1988.
Figure 9. Example graphical presentation
of results from a remedy-selection treatability
study.
Soil
Samples
Reagent
Washl
Wash 2
Distillate
"Solids"
"Liquids"
Total
g in
300.0
300.0
300.0
300.0
300.0
900.0
1200.0
g out
149.6
23.5
176.0
336.9
363.3
53.8
173.1
930.0
1103.1
g
change
-150.4
23.5
-124.0
36.9
63.3
53.8
-126.9
30.0
-96.9
Recovery,
%
50
59
112
121
58
103
92
Source: Galson Research Corporation 1988.
Figure 10. Example tabulation of material
balance data from a remedy-selection
treatability study.
4.6 HEALTH AND SAFETY
A project-specific Health and Safely Plan (HSP) is
required for all chemical dehalogenation treatability
studies conducted on site or at an offsite laboratory or
testing facility permitted under RCRA. This requirement
includes research, development, and demonstration
(RD&D) facilities, but it does not apply to facilities that
are conditionally exempt from Subtitle C regulation by the
treatability study exemption [40 CFR 261.4(e) and (f) or
equivalent State regulations].
The vendor ortesting facility should supply the HSP with
the treatability study Work Plan. The HSP describes the
work to be performed in the field and in the laboratory,
identifies the possible physical and chemical hazards
associated with each phase of field and laboratory
operations, and prescribes the appropriate protective
measures necessary to minimize worker exposure. The
preparation of an HSP is discussed in the final generic
guide. Hazards specific to chemical dehalogenation
treatability studies are discussed in the following
subsections.
4.6.1 Chemical Hazards
Chemical hazards are associated with both the treatment
process and the waste. Caustics used in the process and
acids used for neutralization will pose inhalation and skin
absorption hazards. If cosolvents such as DMSO are
used, they can enhance the absorption of chemicals into
the skin. Waste contaminants such as PCBs,
PCDDs/PCDFs, and pesticides will pose additional
chemical hazards. Polychlorinated biphenyls are
recognized as potential carcinogens,andPCDDs/PCDFs
are considered carcinogenic, acnogenic, teratogenic, and
embryotoxic. The HSP should identify the appropriate
skin and respiratory protection for the chemical hazards to
which workers may be exposed
4.6.2 Physical Hazards
Fire and explosion hazards exist whenever heat is
associated with a chemical treatment process. Explosive
quantities of hydrogen gas may be generated when
wastes containing certain metals in their elemental form
(e.g., aluminum and zinc) are mixed with alkaline treatment
reagents such as potassium hydroxide. Treatment of
certain chlorinated aliphatics at high concentrations may
produce compounds that are potentially explosive (e.g.,
chloroacety lenes) or pose a fire hazard. The use of DMSO
or similar reagents may lead to the formation of highly
flammable volatile organics (e.g., methyl sulfide). TheHSP
should stipulate the precautions for preventing fires and
explosions (e.g., laboratory hoods, equipment
vents/releases, and nitrogen purge systems).
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4.7 PERMITS
Treatability studies of chemical dehalogenation
technologies are subject to certain regulatory
requirements under Federal environmental laws. The
treatability study Work Plan should describe how the
laboratory or testing facility will comply with all applicable
requirements (e.g., storage or quantity limitations). The
final generic guide describes the permitting and operating
requirements under CERCLA and RCRA.
Under TSCA, laboratories or testing facilities that handle
PCB-containing materials must obtain a Research and
Development Permit. (For fixed laboratories, this permit
can be obtained from the appropriate EPA Regional
Office. For mobile laboratories, it can be obtained from the
EPA Office of Toxic Substances, Chemical Regulation
Branch.) Storage of PCB-containing materials for
purposes of treatability testing is limited to no longer than
1 year.
4.8 RESIDUALS MANAGEMENT
Residuals generated as a result of treatability testing must
be managed in an environmentally sound manner. Early
recognition of the types and quantities of residuals that
will be generated, the impacts that managing these
residuals will have on the proj ect schedule and costs, and
the roles and responsibilities of the various parties
involved is important for their proper disposal.
The Work Plan should include estimates of both the types
and quantities of residuals expected to be generated
during chemical dehalogenation treatability testing. These
estimates should be based on knowledge of the treatment
technology and the experimental design. Proj ect residuals
may include the following:
• Unused waste not subjected to testing
• Treated waste
• Treatment residuals (e.g., spent reagent, condensate)
• Laboratory samples and sample extracts
• Used containers or other expendables
• Contaminated protective clothing and debris
The Work Plan should describe whether treatability study
residuals will be returned to the site; investigated on or
offsite as part of a treatment train; or shipped to a
permitted treatment, storage, or disposal facility (i.e.,
RCRA Subtitle C facility for hazardous wastes, RCRA
Subtitle D facility for solid wastes, or TSCA or RCRA
facility for PCB-containing wastes). The final generic
guide discusses the management of residuals regulated
under RCRA as well as applicable Department of
Transportation regulations.
4.9 SCHEDULE
The Work Plan should contain a schedule indicating the
planned starting and ending dates for the tasks outlined
in the Work Assignment. The duration of a chemical
dehalogenation treatability study will vary with the level
of testing being conducted. Remedy-screening studies
can usually be performed within a few weeks.
Remedy-selection studies, however, may require several
months. In addition to the time required for actual testing,
the schedule must allow time for obtaining approval of the
various plans; securing any necessary environmental,
testing, or transportation permits; shipping analytical
samples and receiving results; seeking review and
comment on the project's deliverables; and disposing of
the project's residuals.
The schedule may be displayed as a bar chart such as that
shown in Figure 11. In this example, both
remedy-screening and remedy-selection treatability
studies are planned. Performance of the selection studies
is contingent upon the results of the screening studies,
which are presented in the Interim Report. In this
particular schedule, the actual treatability tests (Subtasks
3b and 7b) will require only 1 to 2 weeks to perform. The
entire two-tiered study, however, spans a period of 8
months.
4.10 MANAGEMENT AND STAFFING
This section of the Work Plan identifies key management
and technical personnel and defines specific project roles
and responsibilities. The line of authority is usually
presented in an organization chart such as that shown in
Figure 12. The RPM is responsible for project planning
and oversight. At Federal- and State-lead sites, the
remedial contractor directs the treatability study and is
responsible for the execution of the project tasks. At
private-lead sites, the responsible party performs this
function. The treatability study may be subcontracted in
whole or in part to a vendor or testing facility with
expertise in chemical dehalogenation.
In addition to the Work Assignment Manager, the
contract or should assign a Quality Assurance Officer and
a Health and Safety Officer. Individual task leaders also
should be assigned; these may include chemists,
engineers, and toxicologists. Other support staff may
include technicians, a sample custodian, and a disposal
coordinator.
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31
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32
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The Subcontractor Manager may be responsible for one
or more tasks and should report directly to the Work
Assignment Manager. Project personnel will often
perform multiple roles in a treatability study, and some
individuals may serve as multiple-task leaders.
4.11 BUDGET
The treatability study budget presents the projected
costs for completing the chemical dehalogenation
treatability study as described in the Work Plan.
Elements of a budget include labor, administrative
costs, and fees; equipment and reagents; site
preparation (e.g., building a concrete pad) and utilities;
permitting and regulatory fees; unit mobilization;
on-scene health and safety requirements; sample
transportation and analysis; emissions and effluent
monitoring and treatment; unit decontamination and
demobilization; and residuals transportation and
disposal. Figure 13 shows the applicability of the
various cost elements to the three tiers of testing. The
final generic guide, which provides a description of
potential treatability study cost elements, should be
referred to prior to preparation of the Work Plan
budget.
The size of the budget will generally reflect the
complexity of the treatability study. Consequently,the
number of operating parameters chosen for
investigation at the remedy selection tier and the
approach used to obtain these measurements will often
depend on the available funding. For example, for some
chemical dehalogenation processes it may be less
costly to obtain data on contaminant reduction versus
reaction time at the completion of a test run rather than
periodically throughout the test. The technology
vendor should be consulted to obtain this kind of
information during the planning of the treatability
study.
Analytical costs can have a significant impact on the
project's overall budget. Sufficient funding must be
allotted for the amount of analytical work projected, the
chemical and physical parameters to be analyzed, and
the required turn-around time. Specialty analyses, such
as for dioxins and furans, can quickly increase the
analytical costs. Dioxin/furan analyses generally cost
about $1000 per sample.
A 34-week remedy-screening/remedy-selection
treatability study, such as the one presented in Figure
11, may be performed at a cost of between $50,000 and
$ 100,000.
Quality Assurance Officer
Health & Safety Officer
Work Plan
Preparation
Task Leader
SAP & HSP
Preparation
Task Leader
EPA
Remedial Project
Manager
EPA
Technical Experts
Contractor
Work Assignment
Manager
Subcontractor
Manager
Treatability Study
Execution
Task Leader
Data Analysis &
Interpretation
Task Leader
Final Report
Preparation
Task Leader
Figure 12. Example project organization chart.
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33
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Cost Element
Labor
Testing
Equipment
Vendor Equipment
Rental
Field Instrumentation
and Monitors
Reagents
Site
Preparation
Utilities
Mobilization/
Demobilization
Permitting and
Regulatory
Health and
Safety
Sample
Transportation
Analytical
Services
Air Emission
Treatment
Effluent
Treatment
Decontamination
of Equipment
Residual
Transportation
Residual Treatment/
Disposal
Treatability Study Tier
Remedy
Screening
•
w
O
o
w
o
o
o
w
w
o
o
o
w
w
Remedy
Selection
•
•
O
o
w
o
w
Q
Qi
w
O
O
o
Q
o
RD/RA
^
•
•
•
•
•
•
•
0
•
•
•
•
•
•
^-^ Not applicable
( J and/or no cost
— incurred.
^^ May be applicable
^j and/or intermediate
^^ cost incurred.
^_ Applicable
^A and/or high cost
^^ incurred.
Figure 13. General applicability of cost elements to various treatability study tiers.
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SECTION 5
SAMPLING AND ANALYSIS PLAN
Factors associated with sampling and analysis that affect
the development of the Work Plan for chemical
dehalogenation treatability studies were previously
outlined in Subsection 4.4. Section 5 discusses the
development of a Sampling and Analysis Plan (SAP) for
remedy-screening and remedy-selection treatability
studies. The suggested outline of the SAP presented in
Table 6 includes a Field Sampling Plan (F SP) and a Quality
Assurance Project Plan (QAPjP). General issues
associated with the development of an SAP for treatability
studies are described in the final generic guide. This
section describes issues specific to the chemical
dehalogenation process. Subsection 5.1 covers the field
procedures used to collect and analyze waste samples.
Subsection 5.2 presents an overview of QA/QC
procedures used in the laboratory to collect and analyze
samples of treated product and treatment residuals.
5.1 FIELD SAMPLING PLAN
This subsection describes procedures for obtaining and
characterizing samples in the field. General guidelines for
performing sampling and analysis in conjunction with
treatability studies are presented in A Compendium of
Superfund Field Operations Methods (EPA 1987). Issues
specific to chemical dehalogenation treatability studies
are discussed here.
5.1.1 Field Sampling and Analytical
Procedures
Field sampling procedures for soils and sludges believed
to contain halogenated organic compounds generally
involve the use of stainless steel, glass, or Teflon (rather
than polypropylene or polyethylene) sampling equipment
and containers. Plastic materials may leach phthalate
plasticizers that could interfere with the analyses and
introduce new contaminants into the sample matrix.
If, prior to field sampling, available analytical data are
insufficient to characterize the distribution of target
contaminants and to identify sampling locations, it may be
possible to use field analytical techniques (field portable
gas chromatographs and gas chromatograph/mass
spectrometers, halide-ion selective test kits, or
immunoassays) to prescreen and select appropriate and
representative sampling locations for collecting
worst-case or average-case soil samples. Some field
screening methods are neither compound-specific (e.g.,
halide-ion selective test kits) nor accurate with respect to
compound identification and quantification and should
not be used to quantify the levels of target contaminants
in the waste soil samples. They should only be used to
detect and to approximate concentra-
Table 6. Suggested Organization of
Treatability Study Sampling and Analysis Plan
Field Sampling Plan
1. Site Background
2. Sampling Objectives
3. Sample Location and Frequency
4. Sample Designation
5. Sample Equipment and Procedures
6. Sample Handling and Analysis
Quality Assurance Project Plan
1. Project Description
2. Project Organization and Responsibilities
3. Quality Assurance Objectives
4. Site Selection and Sampling Procedures
5. Analytical Procedures and Calibration
6. Data Reduction, Validation, and Reporting
7. Internal Quality Control Checks
8. Performance and Systems Audits
9. Calculation of Data Quality Indicators
10. Corrective Action
11. Quality Control Reports to Management
12. References
Appendices
A Data Quality Objectives
B. Example of SOP for Chain-of -Custody
Procedures
C. EPA Methods Used
D. SOP for EPA Methods Used
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tions of the target contaminants. Laboratory analyses
must subsequently be performed to verify the presence
and to quantify the levels of the target contaminants in
the samples. An alternative approach to performing field
screening analyses is to conduct an initial site visit to
collect samples for characterization in the laboratory and
determination of the type, concentration, and location of
contaminants at the site.
Decontamination of field equipment in studies involving
PCBs or dioxins/furans will require special attention
because these compounds are insoluble in water and even
low levels may persist after water rinsing. Specific rinsing
procedures should be developed to assure thorough
decontamination of sampling equipment so as to minimize
cross-contamination of samples. Several rinse steps
involving hot-water soaks, pesticide-grade solvents,
special soap solutions that are free of chlorinated organic
compounds, and distilled water may be necessary.
All equipment and procedures used in the field to collect
treatability study samples must be outlined in the study' s
FSP.
5.1.2 Sample Preparation and
Handling Procedures
The FSP also must describe the specific sample
preparation and handling procedures that precede
treatability testing. Sample preparation will generally
involve soil sieving (to remove oversize particles and
debris) and sample homogenization. Soil sieving may be
performed manually in the laboratory as treatability
samples are withdrawn from the field sample container, or
it can be performed at the site by pouring the soil through
stainless steel sieves. For remedy-screening studies,
sample compositing and homogenization can be
accomplished manually in the field or laboratory by using
stainless steel trowels, scoops, and pails. For
remedy-selection studies, however, mechanical mixers
may be required to yield more homogeneous samples.
Samples may be air-dried before treatment to reduce the
moisture content of soils and sludges. If significant
concentrations of target volatile organic contaminants
(e.g., chlorinated aliphatics)are present, however, special
precautions should be taken during sample preparation
and handling to minimize volatile losses. These
precautions may include mixing small amounts of sample
at a time in a closed mixer and placing the samples in cold
storage.
5.1.3 Sample Preservation and
Holding Times
As outlined in Test Methods for Evaluating Solid Waste
(EPA 1986), samples believed to contain halogenated
organic compounds should be preserved by cooling them
to 4« C. The critical holding times for these samples (i.e.,
the time between collection of the sample in the field and
extraction in the laboratory) should not exceed 14 days.
The time between sample extraction and analysis should
not exceed 40 days.
5.2 QUALITY ASSURANCE
PROJECT PLAN
The second component of the SAP, the QAPjP, details the
quality assurance objectives (precision, accuracy,
representativeness, completeness, and comparability) for
critical measurements and the quality control procedures
established to achieve the desired QA objectives for a
specific treatability study. Guidance for preparing the
QAPjP can be obtained from Interim Guidelines and
Specifications for Preparing Quality Assurance Project
Plans (EPA 1980).
Quality assurance/quality control procedures are an
integralpart of both the field and laboratory sampling and
analysis activities performed during a treatability study.
These QA/QC procedures must be consistent with the
study's test objectives. This subsection describes
laboratory QA/QC procedures for chemical
dehalogenation treatability studies.
5.2.1 Quality Assurance Objectives
and Critical Measurement Data
Specific QA objectives for the precision, accuracy, and
completeness of the data generated must be specified for
each sample matrix and critical measurement parameter at
the outset of the study. Critical measurements include
those parameters that will be used to judge the
performance of the chemical dehalogenation process.
Figure 14 lists example analytical QA objectives for a
remedy-selection chemical dehalogenation study (PEI
Associates 1988). Precision is determined by comparing
analytical results from replicate samples. For studies
involving duplicate samples, the relative percent
difference (RPD) is calculated. In the case of triplicate
samples, the mean and relative standard deviation (RSD)
are calculated. Accuracy is determined by calculating the
percentage recovery obtained for analy tes spiked into the
sample matrix (i.e., matrix spike sample). Completeness is
calculated by comparing the amount of valid data
obtained with the amount that was expected to be
obtained under correct normal conditions. Goals for
completeness are generally set at 80 percent or higher.
The method detection limit (MDL) depends on the
overall sensitivity and specificity of the analytical
method used and the presence or absence of
interfering compounds in the sample. The applicability
of the analytical method proposed for use in a
treatability study must be assessed in light
of the expected concentrations of target
and interference compounds in the
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Precision, Accuracy, percent
Analytical parameter
Herbicides
2,4-D
Pesticides
Heptachlor epoxide
DDE
DDT
ODD
PCBs
Aroclor 1260
Aroclor 1016
Furans
TCDF
PeCDF
HxCDF
° U.S. Environmental Protection
Method3
8150
8080
8080
8080
8080
8080
8080
8280
8280
8280
Agency. 1986.
RPD"
<50
<31
<50
<50
<50
<50
<50
<25
<25
<25
Test Methods for Evaluating Solid Waste.
recovery
20-140
35-130
23-134
23-134
23-134
25-125
25-125
60-140
60-140
60-140
3rd. ed. SW-846.
Completeness, %
85
85
85
85
85
90
90
85
85
85
b RPD = Relative percent difference.
Source: PEI Associates 1988.
Figure 14. Example analytical quality assurance objectives fora
remedy-selection dehalogenation treatability study.
samples and the cleanup standard determined for the
sample matrix. The QAPjP must specify the QA objectives
fortheMDLs.
5.2.2. Treatability Study Sampling
Procedures
Methods for collecting aliquots of treated products and
treatment residuals from chemical dehalogenation
treatability tests will be specified in the QAPjP. Sample
collection requires the use of stainless steel, glass, or
Teflon sampling equipment and containers, as discussed
previously in Subsection 5.1.1. Sample containers should
be filled carefully to prevent any portion of the collected
sample from coming in contact with the sampler's gloves,
which could cause cross-contamination. Samples should
not be collected or stored in the presence of exhaust
fumes, and they should be kept cool to minimize losses of
volatile organics. Decontamination of the experimental
apparatus and sampling equipment involves the same
considerations as described for field sampling equipment.
5.2.3 Treatability Sample Preservation
and Holding Times
The preservation requirements and critical holding times
for treated product and treatment residuals containing
halogenated organic compounds are similar to those
described in Subsection 5.1.3.
5.2.4 Analytical Procedures
Subsection 4.4 described the waste characterization and
treated product and residuals analyses that should be
considered during the development of the treatability
study Work Plan. The QAPjP should specify the exact
analytical procedures that will be followed for each matrix
and critical measurement parameter. Table 7 lists standard
EPA analytical methods that are generally used for
halogenated organic compounds. These methods are
compiled in Test Methods for Evaluating Solid Waste
(EPA 1986). The vendor may propose modified or
equivalent test methods for noncritical measurements;
however, the EPA RPM must determine the acceptability
of these alternative methods with respect to the test
objectives and the available method validation data.
5.2.5 Toxicological Screening
Procedures
Several standard bioassays are available for investigating
the toxic or mutagenic characteristics of chemical
dehalogenation products and residuals. The/3ro/oco//or
Bioassessment of Hazardous Waste Sites (Porcella 1983)
presents bioassays involving algae (Selenastrum
capricornutum), macroinvertebrates (Daphnia magnet),
lettuce seed germination/root e\ongation(Lactucasativa~),
earthworms (Eiseniafoetida), and fathead minnow larvae
(Pimephales promelas). The freshwater algae, daphnid,
and minnow assays can be used to evaluate CERCLA soil
elutriates; whereas the seed germination and earthworm
tests assay the toxic effects of direct soil contact.
Standard operating procedures for these and other
bioassays, including a modified earthworm (Eisenia
andrei) test, can be found in the draft Region IV
Standard Operating Procedure for Toxicity Testing
Hazardous Waste Assessments (EPA 1990e).
The Microtox™ (Photobacterium phosphoreum)
microbial bioassay has been widely investigated for its
applicability in
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Table 7. Standard EPA Analytical Methods for Halogenated Organic Compounds
Method
Analyte
Gas chromatographv
Method 8010
Method 8020
Method 8120
Method 8040
Method 8080
Method 8150
Gas chromatography/
mass spectrometrv
Method 8240
Method 8250/8270
Method 8280
Chlorobenzenes (halogen-specific detector)
Chlorobenzenes (photoionization detector)
Chlorobenzenes (electron-capture detector)
Chlorophenols
Organochlorine pesticides
PCBs
Chlorinated herbicides
Chlorobenzenes
Chlorophenols
Chlorinated pesticides
PCBs
PCDDs/PCDFs
Source: EPA 1986.
assessing the toxicity of wastewater, leachate, and
contaminated ground water. Microtox results have been
compared with those from other assays in several studies
and found to provide a comparatively reliable indication
of the presence of toxic organics. A procedure for this
bioassay also is available in the draft Region IV SOP. The
Microtox test has been extended to measure the toxicity
of sediment and solid waste samples without the
requirement of having to prepare sample extracts (Tung et
al. 1990). An SOP for this test is available from the
manufacturer.
The mutagenicity (Ames, in Salmonella typhimurium
TA98 and TA100) and toxicity (in male Hartley Guinea
pigs) of byproducts from the chemical dehalogenation of
2,3,7,8-TCDD have been evaluated by DeMarini and
Simmons (1989). An SOP for the Salmonella assay is
presented by Maron and Ames (1983).
Standard operating procedures for all bioassessments to
be performed must be included in the QAPjP.
5.2.6 Data Validation and Internal
Quality Control Checks
Criteria must be set for identifying outlier data (i.e., QC
data lying outside the specific QA objectives for precision
or accuracy fora given analytical method). Project outlier
data are reported, but they generally are not used for
interpreting overall project results.
Internal QC checks involve frequent calibration checks of
field and analytical instruments used in the treatability
studies. During the analyses of the untreated soil and die
treated product, other QC checks may include analysis of
additional samples such as standards, blanks, and matrix
spikes.
Because standards and calibration curves are subject to
change and can vary from day to day, a check standard
should be analyzed with each group of samples.
Calibration standards for quantitation of PCBs,
PCDDs/PCDFs, and other halogenated organics should
be obtained from reliable commercial or public sources.
Blanks are QC samples that are presumed to be.
noncontaminated. Trip blanks are analyzed to monitor for
possible sample contamination during shipment. Field
blanks provide an indication of sample contamination
during the sampling operation. Rinsate blanks are
collected and analyzed to investigate cross-sample
contamination from sampling tools.Method blanks verify
that interferences caused by contaminants in solvents,
reagents, glassware, and other processing hardware are
known and minimized. Reagent blank samples are
analyzed to investigate reagent contamination. If target
contaminants are found in any blank samples at levels
exceeding the MDL (2 x MDL for method blanks), the
source of contamination must be determined and
corrective actions implemented.
Spiked samples are prepared and analyzed to provide an
indication of the analytical accuracy. For evaluation of the
effect of the soil/sediment matrix on the analytical
methodology, a separate aliquot of sample should be
spiked with a known quantity of analyte. For
PCB-contaminated samples, example spiking compounds
would be Aroclor 1016 and Aroclor 1260. This matrix
spike (MS) is then analyzed along with the sample.
The percentage recovery of the spiked
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analyte should fall within a predetermined QC limit. The
relative percent difference between the MS and an MS
duplicate (MS/MSD) will indicate the analytical precision.
Blank spikes— prepared with uncontaminated soil and
appropriate spiking compounds—should be analyzed in
conjunction with the MS/MSD. Relative percent recovery
of the spiking compound can indicate matrix interferences.
Surrogate standard detennination should be performed on
all samples and blanks for GC/MS analyses to monitor
extraction efficiency. Samples are spiked with a surrogate
analyte not present in the sample. An appropriate
surrogate spike for PCB analysis may be
decachlorobiphenyl. Percentage recoveries of the
surrogate should be within predetermined limits. If
recoveries are insufficient, corrective actions should be
implemented.
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SECTION 6
TREATABILITY DATA INTERPRETATION
The purpose of a pre-ROD treatability investigation is to
provide the data needed for detailed analysis of
alternatives and, ultimately, the selection of a remedial
action that can achieve the site cleanup criteria. The
results of a treatability study should enable the RPM to
evaluate all treatment and nontreatment alternatives on an
equal basis during the "detailed analysis of alternatives"
phase of theFS.
6.1 USE OF PRE-ROD TREATABILITY
STUDY RESULTS IN THE RI/FS
PROCESS
The Work Plan outlines the treatability study test
objectives and describes how these objectives will be
used in the evaluation of chemical dehalogenation for
remedy selection. As discussed in Section 3, the RI/FS
guidance (EPA 1988a) specifies nine evaluation criteria to
be considered in the assessment of remedial alternatives.
These criteria were developed to address both the specific
statutory requirements of CERCLA and the technical and
policy considerations that are important when selecting
among remedial alternatives. The nine RI/FS evaluation
criteria are as follows:
• Overall protection of human health and the
environment
• Compliance with ARARs
• Long-term effectiveness and permanence
• Reduction of toxicity, mobility, or volume through
treatment
• Short-term effectiveness
• Implementability
• Cost
• State acceptance
• Community acceptance
The first two criteria, which relate directly to the statutory
requirements each remedial alternative must meet, are
categorized as threshold criteria. The next five are the
primary criteria upon which the selection of a remedy is
based. The final two criteria are evaluated after completion
of the RI/FS and the proposed remedial plan.
Treatability studies provide important data for use in the
assessment of an alternative against both the primary
evaluation criteria and the threshold evaluation criteria.
Table 8 lists factors important to the analysis of these
criteria and the data from a chemical dehalogenation
treatability study that provide information for this
analysis. The results of treatability studies also may
influence the evaluations against the state and community
acceptance criteria. Evaluations against the nine criteria
are performed for the overall remedy, of which the
treatment technology is only one part. The overall remedy
will generally include additional treatment or containment.
6.1.1 Primary Evaluation Criteria
The five primary evaluation criteria should be used for
guidance in setting treatability study test obj ectives. This
subsection describes how the results of a chemical
dehalogenation treatability study test can provide specific
information for evaluations against these criteria.
Long-Term Effectiveness and Permanence
This evaluation criterion addresses risks remaining at the
site after the remedial response objectives have been met.
Assessment of the residual risks from untreated waste
and treated product left on site must involve the same
assumptions and calculation procedures as those used in
the baseline risk assessment. If engineered controls such
as containment systems are to be used to manage these
remaining materials, their adequacy and reliability should
be evaluated.
Remedy-selection treatability tests provide data on the
magnitude of the site's residual risk after
chemical dehalogenation treatment. If treated
product will remain on site, the contaminant
concentrations in this material must meet the
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site's cleanup criteria. As discussed in Subsection 4.1,
these cleanup criteria translate into specific performance
goals for remedy-selection treatability studies. The
concentrations of target contaminants in the treated
product and treatment residuals, as determined by
treatability testing, indicate the ability of chemical
dehalogenation to achieve the site cleanup criteria.
A second set of data available from treatability studies
that can indicate the magnitude of residual risk is the
presence of specific reaction byproducts in the treated
product. As discussed in Subsections 4.4.3 and 4.4.4,
halogenated organic byproducts may be formed during
the treatment of the target contaminants. The presence
and concentration of these "new" compounds may affect
the residual risks associated with onsite disposal.
If an ecological risk assessment is to be performed, the
residual risks posed to biota by the replacement of the
treated product on site can be assessed under this
criterion. The literature survey may provide adequate data
to evaluate the biotoxicity of chemically dehalogenated
soils. If little or no biotoxicity data exist in the literature for
the contaminants/matrix of interest, however, bioassays
can be performed at the remedy-selection tier to address
this data need. A treatability study test objective that
stipulates a reduction in the toxicity posed by the treated
product to test organisms will provide data for the
assessment of chemical dehalogenation against the
long-term effectiveness and permanence criterion.
Table 8. Applicability of Chemical Dehalogenation Treatability Study Data to RI/FS Evaluation Criteria
Evaluation criteria
Analysis factors
Treatability study data
Long-Term Effectiveness and
Permanence
Magnitude of residual risk
Target containment concentrations in
treated product and treatment residuals
Presence of specific reaction
byproducts in treated product
Results of bioassays performed on
treated product
Reduction of Toxicity, Mobility,
or Volume Through Treatment
Reduction in toxicity
Irreversibility of the treatment
Type and quantity of, and
risks posed by, treatment
residuals
Percent reduction in target contaminant
concentrations
Comparison of bioassay results before
and after treatment
Material balance data combined with
target contaminant concentrations in
treated product and treatment residuals
Target contaminant concentrations in
treatment residuals
Presence of specific reaction
byproducts in treatment residuals
Results of bioassays performed on
treatment residuals
Volume of treatment residuals
Short-Term Effectiveness
Protection of community
during remedial actions
Protection of workers during
remedial actions
Time until remedial response
objectives are achieved
Physical/chemical characteristics of
waste matrix
Physical/chemical characteristics of
treatment residuals
Physical/chemical characteristics of
waste matrix
Physical/chemical characteristics of
treatment residuals
Reagent formulation/material safety
data
Reaction time
Implementability
Reliability and potential for
schedule delays
Reliability and schedule delays during
testing
Reaction time/throughput
Physical characteristics of waste matrix
Contaminant variability in untreated
waste
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Table 8. (continued)
Cost
Direct capital costs
Operation and maintenance costs
—Chemicals/reagents
-Utilities
—Residuals treatment/disposal
-Equipment
-Labor
Reaction time/throughput
Reagent usage/recovery
Reaction temperature
Physical characteristics of waste matrix
Site characteristics
Reagent formulation/loading
Reagent usage/recovery
Volume and characteristics of treated
product and treatment residuals
Reaction time/throughput
Reaction temperature
Volume and physical/chemical
characteristics of treatment residuals
Reaction time/throughput
Physical characteristics of waste matrix
Reaction time/throughput
Compliance with
ARARS
Chemical-specific ARARs
Location-specific ARARs
Action-specific ARARs
Target contaminant concentrations in
treated product and treatment residuals
Target contaminant concentrations in
treated product and treatment residuals
Results of bioassay performed on
treated product and treatment residuals
Target contaminant concentrations in
treated product and treatment residuals
Overall Protection of
Human
Health and the
Environment
Ability to eliminate, reduce, or
control site risks
Target contaminant concentrations in
treated product and treatment residuals
Presence of specific reaction
byproducts in treated product and
treatment residuals
Results of bioassays performed on
treated product and treatment residuals
Reduction ofToxicity, Mobility, or Volume Through Treatment
This evaluation criterion addresses the statutory preference
for selecting technologies that, according to the RI/FS
guidance, "...permanently and significantly reduce the
toxicity, mobility, or volume of the hazardous substances as
their principal element. This preference is satisfied when
treatment is used to reduce the principal threats at a site
through destruction of toxic contaminants, reduction of the
total mass of toxic contaminants, irreversible reduction in
contaminant mobility, or reduction of total volume of
contaminated media."
Because chemical dehalogenation reduces the toxicity of
halogenated compounds, this evaluation criterion is
particularly applicable. Treatability studies should provide
detailed performance data on the percentage reduction in the
toxicity of the treated product. As presented in Subsection
3.2, a performance goal of greater than 90 percent reduction
in the target contaminant concentrations should be achieved
at the remedy-screening tier. If this test objective is met,
chemical dehalogenation is considered a feasible alternative.
At the remedy-selection tier, the process should be capable
of achieving the site cleanup criteria with an acceptable level
of confidence.
Another measure of reduction in toxicity is the comparison of
bioassay results from tests performed on the waste before
and after chemical dehalogenation. If treated product is to
remain on site, a reduction in biotoxicity should be identified
as a treatability test objective for remedy selection.
Irreversibility of the treatment process is another factor in the
evaluation of chemical dehalogenation against this criterion.
Material balance data from a treatability study, combined
with the target contaminant concentrations found in the
treated product and treatment residuals, can indicate the level
of irreversibility achieved through treatment. These data can
be used to construct a mass balance for the target
contaminants, which will accurately describe the target
contaminant destruction efficiency of die treatment process.
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Taking the treatment residuals into consideration is an
important part of the assessment of chemical dehalogenation
against the reduction in toxicity, mobility, and volume
criterion. Concentrations of target contaminants in these
residuals, along with the presence of selected reaction
byproducts, indicate the risks posed by their onsite
treatment. Data on the bio toxicity and volume of treatability
study residuals also provide information for this assessment.
Short-Term Effectiveness
The short-term effectiveness criterion is concerned with the
effects of the alternative on human health and the
environment during its construction and implementation. The
RI/FS guidance outlines several factors that may be
addressed, if appropriate, when assessing an alternative
against this criterion. Chemical dehalogenation treatability
studies can provide information on three of these factors: 1)
protection of the community during remedial actions, 2)
protection of the workers, and 3) the time required to achieve
remedial response objectives.
If a site is located near a population center, any short-term
health risks posed by the remedial action must be addressed.
The treatability study waste characterization can identify
some of these risks. For example, physical characteristics of
the waste matrix, such as moisture content and particle-size
distribution, could indicate a potential for the generation of
contaminated dust during material-handling operations. The
presence of volatile contaminants in the waste also could
pose risks to community health during material handling and
treatment. Treatment residuals must be carefully
characterized to permit the design of proper air and water
treatment systems.
For the protection of workers during implementation of the
remedy, the physical and chemical characteristics of the
untreated waste matrix and the treatment residuals are
important data to be collected during treatability testing.
Material safety data on the reagent formulation to be used
and handled by workers also should be collected and
reviewed. These data will aid in the assessment of any threats
posed to workers and the effectiveness and, reliability of
protective measures that will be taken. Treatability systems
can also be monitored for any adverse reactions that may
occur when the waste is mixed with the chemical reagents and
heated.
The time required to achieve the remedial response objectives
for the site depends on the volume of soil to be treated and
the throughput of the full-scale unit or treatment train
system. Estimates of throughput will use treatability data
such as the reaction time required to dehalogenate the waste
adequately.
Implementability
This evaluation criterion assesses the technical and
administrative feasibility of implementing an alternative and
the availability of the equipment and services required during
implementation. The following factors are evaluated in the
analysis of the implementability of chemical dehalogenation:
• Difficulties associated with construction and operation
• Reliability and potential for schedule delays
• Ability to monitor treatment effectiveness
• Commercial availability of the treatment process and
equipment
The literature survey should provide historical information
regarding many of the preceding factors. If a chemical
dehalogenation alternative has been shown to be capable of
achieving the desired cleanup levels but has never been
demonstrated at full scale, reliability data may be insufficient
for its assessment under the implementability criterion. In
this case, data from a pre-ROD pilot-scale test must be used.
The reliability of the pilot system, including any schedule
delays encountered during its testing, will serve as an
indicator of the implementability of the full-scale system.
The reaction time and throughput can also provide
information on potential schedule delays. Characteristics of
the matrix that could lead to equipment failure or diminished
treatment effectiveness, such as high clay content, should be
investigated during the treatability study. Contaminant
variability in the untreated waste could also lead to schedule
delays by requiring repeated treatment of some soils.
Treatability testing of multiple waste types with differing
contaminant concentrations can provide important data for
analysis of the reliability factor and the implementability
evaluation criterion.
Cost
The cost criterion evaluates the full-scale capital and
operation and maintenance (O&M) costs of each remedial
action alternative. The assessment of this criterion requires
the development of cost estimates for the full-scale
remediation of the site. These estimates should provide an
accuracy of +50 percent to -30 percent. A comprehensive
discussion of costing procedures for CERCLA sites is
included in the Remedial Action Costing Procedures Manual
(EPA 1985).
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The cost estimate prepared under this criterion will be
based on information obtained from the literature and the
technology vendor. Preparation of the estimate may
require bench-or pilot-scale treatability study data
generated at the remedy selection tier.
Direct capital costs for chemical dehalogenation treatment
will include expenditures for the equipment, labor, and
materials necessary to install the system. If the
technology vendor already has a mobile, full-scale
treatment unit constructed, treatability study data will not
be required to determine direct equipment costs. If no
full-scale system exists, however, treatability studies can
provide data necessary for equipment scale-up.
Operational data, such as reaction time and throughput,
reagent usage and recovery, and reaction temperature, will
be required to size and select full-scale equipment.
Characteristics of the matrix, such as particle-size
distribution and moisture content, that are identified
during treatability testing will have an impact on decisions
regarding front-end material handling operations and
equipment and post-dehalogenation equipment for
processing of the product and residuals in a treatment
train. Characteristics of the site that may have an impact
on the logistical costs associated with mobilization and
onsite treatment can be identified during the
sample-collection visit.
Treatability studies can provide significant data on such
O&M costs as chemicals and reagents, utilities, residuals
disposal, and maintenance equipment and labor.
Full-scale chemical and reagent costs can be estimated by
using reagent formulation and loading and reagent
recovery data from treatability studies. The volume and
physical characteristics of the treated product and
treatment residuals will affect posttreatment chemical
costs (i.e., acid for neutralization, activated carbon for air
pollution control, etc.).
The costs of electricity, fuel, and water depend on the
throughput of the treatment process. At the remedy-
selection tier, throughput can be estimated with data on
reaction time and the volume of waste to be treated. Utility
costs will also be affected by the reaction temperature.
Treatment/disposal costs for the dehalogenation residuals
will depend on the volumes of residuals generated and on
the physical/chemical characteristics of these materials.
These data are available from remedy-selection treatability
studies.
Operation and maintenance equipment costs include
replacement parts, tools, and personnel protection
equipment.
Estimates of these costs will reflect the physical
characteristics of the waste matrix (which affect the
difficulty of treatment) and the throughput (which affects
the total time for treatment). Operation and maintenance
laborcan be projected from treatability study reaction time
and throughput.
6.1.2 Threshold Evaluation Criteria
In addition to the primary evaluation criteria discussed in
the preceding subsection, treatability studies can also
provide data for assessing an alternative against the two
statutory-based threshold evaluation criteria.
Compliance with ARARs
Applicable or relevant and appropriate requirements are
any local, State, or Federal regulations or standards that
pertain to chemical contaminant levels, locations, and
actions at CERCLA sites. Chemical-specific ARARs that
may be applicable to chemical dehalogenation include
RCRA LDRs on the placement of treated soil, and Safe
Drinking Water Act Maximum Contaminant Levels and
Clean Water Act Water Quality Criteria for discharge of
treatment wastewater. Applicable location-specific
requirements may include the substantive Clean Water
Act §404 prohibitions on the unrestricted discharge of
dredged or fill material into wetlands and the RCRA
location limitations on where onsite storage, treatment, or
disposal of hazardous waste may occur. Action-specific
ARARs include technology- and activity-based
requirements or limitations on actions taken with respect
to hazardous wastes. The Toxic Substances Control Act
and the Federal Insecticide, Fungicide, and Rodenticide
Act (FIFRA) may provide a number of potentially
applicable action-specific ARARs for chemical
dehalogenation treatment at Superfund sites.
Treatability study test objectives will generally be based
on ARARs. Chemical-specific ARARs will be expressed in
terms of contaminant concentrations in the treated
product and treatment residuals. Often, these ARARs will
define the "target" contaminants forthe treatability study.
Location-specific cleanup criteria may also include
biotoxicity requirements for treated product and treatment
residuals if, for example, runoff from the disposal site
could have an impact on a sensitive wildlife habitat.
Action-specific requirements may be particularly
applicable to the treatment and discharge of residuals
such as wastewater. Target contaminant concentrations
in the treatability study wastewater will aid in identifying
action-specific ARARs. Performance data indicating how
well the process achieved the treatability study test
objectives will aid in evaluating chemical dehalogenation
against the compliance with ARARs criterion.
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Overall Protection of Human Health and the
Environment
This evaluation criterion provides an overall assessment
of how well each alternative achieves and maintains
protection of human health and the environment. The
analysis of overall protection will draw on the
assessments conducted under the primary evaluation
criteria and the compliance with ARARs. Its focus will be
on the ability of an alternative to eliminate, reduce, or
control overall site risks.
Chemical dehalogenation treatability studies will provide
general data for the evaluation under this final criterion.
Target contaminant and reaction byproduct
concentrations in the treated product and treatment
residuals will demonstrate how well the process or
treatment train can eliminate site risks. If an ecological risk
assessment is being conducted, bioassessments of these
materials will generate the data required to evaluate the
reduction in risk to site biota.
6.2 USEOFPRE-RODTREATABILITY
STUDY RESULTS IN THE RD/RA
PROCESS
Pre-ROD treatability study results provide information for
the subsequent detailed design investigations of the
selected remedial technology. Operating conditions in the
pre-ROD chemical dehalogenation treatability studies
should be completely documented so these data can be
used in planning the post-ROD remedy design treatability
studies. Pre-ROD data on the chemical, physical, and
toxicological characteristics of treatment residuals will be
useful in planning remedy design studies in which large
volumes of residuals will be handled and disposed of.
Problems encountered during remedy-selection
treatability studies—such as difficulties in mixing, heating,
reagent separation and recovery, and health and
safety—should also be carefully documented for
post-ROD pilot- and full-scale investigations at the
RD/RA tier.
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REFERENCES
Brunelle, D. J. 1982. Method for Removing
Polyhalogenated Hydrocarbons From Nonpolar Organic
Solvent Solutions. U.S. Patent Number 4,351,718.
September 28, 1982.
Brunelle, D. J. 1983. Reaction of Poly chlorinated
Biphenyls With Mercaptans in Non-Polar Media:
Formation of Poly chlorobiphenyl Sulfides. Chemosphere,
12(2):167-181.
Brunelle, D. J., and D. A. Singleton. 1983.
Destruction/Removal of Poly chlorinated Biphenyls From
Non-Polar Media. Reaction of PCB with Polyethylene
Glycol/KOH. Chemosphere, 12:183-196.
Canonic Environmental Services Corp. 1991. Soiltech ATP
Dechlorination Process. Promotional Literature.
DeMarini, D. M., and J. E. Simmons. 1989. Toxicological
Evaluation of By-ProductsFrom Chemically Dechlorinated
2,3,7,8-TCDD. Chemosphere, 18(11/12):2293-2301.
des Rosiers, P. E. 1987. Chemical Detoxification Using
Potassium Polyethylene Glycolate (KPEG) for Treating
Dioxin and Furan Contaminated Pentachlorophenol, Spent
Solvents and Poly chlorinated Biphenyls Wastes. U.S.
Environmental Protection Agency, Office of
Environmental Engineering and Technology
Demonstration, Washington, D.C.
Franklin Research Center. 1982. Summary Project Report:
Dehalogenation of PCBs Using New Reagents Prepared
From Sodium Polyethylene Glycolates—Application to
PCB Spills and Contaminated Solids. Prepared For U.S.
Environmental Protection Agency, Industrial
EnvironmentalResearchLaboratory, Cincinnati, Ohio. CR
806649-01-2. Report dated February 3, 1982.
Freeman, H. M., and R. A. Olexsey. 1986. A Review of
Treatment Alternatives for Dioxin Wastes. Journal of the
Air Pollution Control Association, 36:67-76.
Galson Research Corporation. 1987. Treatability Test for
APEG Dechlorination of PCBs in Resolve Site Soil.
Prepared for Camp Dresser & McKee, Inc.
Galson Research Corporation. 1988. Laboratory Testing
Results: KPEG Treatment of New Bedford Soil. Prepared
under Contract No. 68-01-7250.
Galson Remediation Corporation. 1990. Quality Assurance
Program Plan. Laboratory Treatability Testing of the
APEG-PLUS™ Treatment System for PCB Contaminated
Material.
Galson Remediation Corporation. Undated. Galson's
APEG-PLUS™ Treatment System Equipment and Job
Description. Promotional Literature.
Howard, K. J., and A. E. Sidwell. 1982. Chemical
Detoxification of Toxic Chlorinated Aromatic Compounds.
U.S. Patent Number 4,327,027. Apnl 27, 1982.
laconianni, F. J. 1984, 1985. Destruction of
PCBs—Environmental Applications of Alkali Metal
Polyethylene Glycolate Complexes. Prepared for the U.S.
Environmental Protection Agency, Hazardous Waste
Engineering Research Laboratory, Cincinnati, Ohio.
Cooperative Agreement: CR 810068. Franklin Research
Center, Philadelphia. Reports dated August 3, 1984, and
May 31, 1985.
Kim, B. C., andR. F. Olfenbuttel. 1990. Demonstration of
BCDP Process at USN PWC Site in Guam. Presented at the
EPA Technology Transfer Conference on the BCD
Process, April 30, Cincinnati, Ohio.
Klee, A., C. Rogers, and T. Tiernan. 1984. Report on the
F easibility of APEG Detoxification ofDioxin- Contaminated
Soils. EPA-600/2-84-071.
Kernel, A., and C. Rogers. 1985. PCB Destruction: A
Novel Dehalogenation Reagent. Journal of Hazardous
Matenals, 12:171-176.
Maron,D.M.,andB. N.Ames. 1983. Mutat. Res., 113:173-
215.
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47
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Metcalf and Eddy, Inc. 1985. Briefing on Technologies
Applicable to Hazardous Waste. Prepared for U.S.
Environmental Protection Agency, Hazardous Waste
Engineering Research Laboratory. May 1985.
Novosad, C.F., et al. 1987. Decontamination of a Small
PCB Soil Site by the Galson APEG Process. Preprint
Extended Abstract, 194th National Meeting of the
American Chemical Society, August 30 - September 4,
1987,27(2):435-437.
PEI Associates, Inc. 1988. Quality Assurance Project Plan
for Alternative Treatment Technology Evaluations of
CERCLA Soils and Debris. Prepared for the U.S.
Environmental Protection Agency under Contract No.
68-03-3389, Work Assignment No. 1-10.
PEI Associates, Inc. 1989. Comprehensive Report on the
KPEG Process for Treating Chlorinated Wastes. Prepared
for the U.S. Environmental Protection Agency under
Contract No. 68-03-3413, Work Assignment No. 1-2, and
the U.S. Navy under Interagency Agreement IAG RW
17933209.
Peterson, R. L. 1985. Method for Reducing Content of
Halogenated Aromatics in Hydrocarbon Solutions. U.S,
Patent Number 4,532,028. July 30, 1985.
Peterson, R.L. 1986. Method for Decontaminating Soil.
U.S. Patent Number 4,574,013. March 4, 1986.
Peterson,R.L.,E.Milicic,andC. J.Rogers. 1985. Chemical
Destruction/Detoxification of Chlorinated Dioxins in Soils.
In: Proceedings of Incineration and Treatment of
Hazardous Waste, the Eleventh Annual Research
Symposium, September 1985. EPA/600/9-85/028.
Porcella, D. B. 1983. Protocol for Bioassessment of
Hazardous Waste Sites. EPA-600/2-83-054.
Tieman, T.O., et al. 1987. Laboratory Studies of the
Degradation of Toxic Chlorinated Compounds Contained
in Hazardous Chemical Waste Mixtures and Contaminated
Soils Using a Potassium Hydroxide/Polyethylene Glycol
Reagent. Preprint Extended Abstract, 194th National
Meeting of the American Chemical Society, August 30 -
September 4,1987,27(2):438-440.
Tung, K. K., et al. 1990. A New Method for Testing Soil
and Sediment Samples. In: Proceedings from the Eleventh
Annual SET AC Conference, November 1990.
U.S. Environmental Protection Agency. 1980. Interim
Guidelines and Specifications for Preparing Quality
Assurance Project Plans. QAMS-005/80.
U.S. Environmental Protection Agency. 1985. Remedial
Action Costing Procedures Manual. EPA/600/8-87/049.
OSWER Directive 9355.0-10.
U.S. Environmental Protection Agency. 1986. Test
Methods for Evaluating Solid Waste. 3rd ed. SW-846.
U.S. Environmental Protection Agency. 1987. A
Compendium of Superfund Field Operations Methods.
EPA/540/P-87/001. OSWER Directive 9355.0-14.
U.S. Environmental Protection Agency. 1988a. Guidance
for Conducting Remedial Investigations and Feasibility
Studies UnderCERCLA. IntenmFmal. EPA/540/G-89/004.
OSWER Directive 9355.3-01.
U.S, Environmental Protection Agency. 1988b. CERCLA
Compliance with Other Laws Manual: Interim Final.
EPA/540/G-89/006. OSWER Directive 9234.1-01.
U.S. Environmental Protection Agency. 1989a. Guide for
Conducting Treatability Studies Under CERCLA. Interim
Final. EPA/540/2-89/058. OSWER Directive 9380.0-27.
Pytlewski, L. L. 1979. A Study of the Novel Reaction of
Molten Sodium and Solvent With PCBs. EPA Grant No.
R806659010. Franklin Research Institute, Philadelphia, PA.
Radimsky, J., and A. Shah. 1985. Evaluation of Emerging
Technologies for the Destruction of Hazardous Waste.
EPA Cooperative Agreement R-808908. U.S.
Environmental Protection Agency, Hazardous Waste
Engineering Research Laboratory. January 1985.
Rogers, C. J. 1987. Field Validation of the KPEG Process to
Destroy PCBs, PCDDs, and PCDFs in Contaminated
Waste. Preprint Extended Abstract, 194th National
Meeting of the American Chemical Society, August 30 -
September 4, 1987, 27(2):433-434.
U.S.EnvironmentalProtectionAgency. 1989b. Treatability
Studies Contractor Work Assignments. Memo From
Henry L. Longest, II, Director, Office of Emergency and
RemedialResponse to Superfund Branch Chiefs, Regions
I through X. July 12,1989. OSWER Directive 9390.3-01.
U.S. Environmental Protection Agency. 1989c. CERCLA
Compliance with Other Laws Manual: Part II. Clean Air
Act and Other Environmental Statutes and State
Requirements. EPA/540/G-89/009. OSWER Directive
9234.1-02.
U.S. Environmental Protection Agency. 1989d. Superfund
LDR Guide # 1: Overview of RCRA Land Disposal
Restrictions. Superfund Publication 9347.3-01FS.
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48
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U.S. Environmental Protection Agency. 1989e. Superfund
LDR Guide #2: Complying With the California List
Restrictions Under Land Disposal Restrictions. Superfund
Publication 9347.3-02FS.
U.S. Environmental Protection Agency. 1990b. Superfund
LDR Guide #6B: Obtaining a Soil and Debris Treatability
Variance for Removal Actions. Superfund Publication
9347.3-06BFS.
U.S. Environmental Protection Agency. 1989f. Superfund
LDR Guide #3: Treatment Standards and Minimum
Technology Requiremments Under Land Disposal
Restrictions. Superfund Publication 9347.3-03FS.
U.S. Environmental Protection Agency. 1989g. Superfund
LDR Guide #4: Complying With the Hammer Restrictions
UnderLand Disposal Restrictions. Superfund Publication
9347.3-04FS.
U.S. Environmental Protection Agency. 1989h. Superfund
LDR Guide #5: Determining When Land Disposal
Restrictions Are Applicable to CERCLA Response
Actions. Superfund Publication 9347.3-05FS.
U.S. Environmental Protection Agency. 1989i. Superfund
LDR Guide #7: Determining When Land Disposal
Restrictions Are Relevant and Appropriate to CERCLA
Response Actions. Superfund Publication 9347.3-07FS.
U.S. Environmental Protection Agency. 1990a. Superfund
LDR Guide #6A (2nd Edition): Obtaining a Soil and Debris
Treatability Variance for Remedial Actions. Superfund
Publication 9347.3-06FS.
U.S. Environmental Protection Agency. 1990c. Superfund
LDR Guide #8: Compliance with Third Third Requirements
Under the LDRs. Superfund Publication 9347.3-08FS.
U.S. Environmental Protection Agency. 1990d. Guidance
on Remedial Actions for Superfund Sites with PCB
Contamination. EPA/540/G-90/007. OSWER Directive
9355.4-01.
U. S. Environmental Protection Agency. 1990e. Region IV
Standard Operating Procedure for Toxicity Testing
Hazardous Waste Assessments. Draft prepared by
Mantech Environmental Technology, Inc., Athens,
Georgia, under Contract No. 68-01-7456.
Vorum, M. 1991. SoilTech ATP System: Commercial
Success at Thermal Treatment and Dechlorination of
PCBs. Presented to Colorado Hazardous Waste
Management Society 1991 Conference, October 3-4,1991.
Woody ard, J. P., and J. J. King. 1987. Recent Technology
Developments for PCB Destruction and Oil Recycling.
Presented at the DOE Oak Ridge Model Conference, Oak
Ridge, Tennessee.
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APPENDIX
SUMMARY OF CHEMICAL DEHALOGENATION
TREATABILITY TESTING OF SOILS/SLUDGES
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
Not available
Not available
Not available
Not available
Neat pure form
HCB, 4,4'-DCBP, HCP, and PCB Aroclor 1254. (The quantities of the
compounds ranged from 0.100 to 1200 millimoles.)
Reaction flask, thermometer, stirrer, thermostated oil bath, argon gas
cylinder
Aqueous NaOH or KOH with PEG-400
Reaction temperature was varied between 25 and 140* C. Reaction time
was varied from 1 to 90 hours. The mixture was treated under purge of
argon gas. In most experiments, the reagent was present in tenfold
excess.
The anhydrous PEG effectively dechlorinated HCB and converted it to
water-soluble products. The substrate reactivity was drastically reduced
as the number of chlorine substituents decreased. Dissolving the
reagents in toluene improved their reactivity, whereas the presence of air
or water decreased their reactivity. Of the chlorinated substrates studied,
the reactivity order (maximum chlorides released per molecule) was as
follows: HCB(4.5)» Aroclor 1254(1.3)»4,4'-DCBP (0.2)>HCP(0).
MaComber, R., M. Orchin, and G. Garrett. 1983. The Reaction of Alkali
Metal Derivative of Polyethylene Glycol 400 With Chlorinated Aromatic
Compounds. A report on research conducted for the U.S. EPA, January
1-June 17, 1983.
DCBP = Dichlorobiphenyl
HCB = Hexachlorobenzene
HCP = Hexachlorophene
KOH = Potassium hydroxide
NaOH = Sodium hydroxide
PCB = Polychlorinated biphenyls
PEG = Polyethylene glycol
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
MGM Brake Site
IX
Cloverdale, CA
The soil from the MGM Brake Site was a heavy clay loam contaminated
with PCBs (Aroclor 1242 and 1248). The soil was also found to contain
PCTPs (the concentration of PCTPs was not determined in this study).
Soil (heavy clay loam)
PCBs (• 640 ppm Aroclor 1242 and 1248) and PCTPs
Bench-scale
KOH and PEG-400
Sample size was 20 g. Reagent-to-soil ratio was 1:1 by weight. Reaction
time was 4 hours. Reaction temperature was varied between 125 to
145* C. Following the reaction, the reaction flask was cooled and the soil
was neutralized with 10 to 20 percent hydrochloric acid solution.
The KPEG treatment reduced the concentrations of PCTP in the soil to
below the detectable range. The PCB concentrations in the soil were
reduced by varying amounts, possibly because of poor mixing.
Rogers, C., A. Kernel, and H. Sparks. 1989. Treatability Study on Soils
From MGM Site. Prepared by the U.S. Environmental Protection Agency,
Risk Reduction Engineering Laboratory, Cincinnati, Ohio.
KOH = Potassium hydroxide
KPEG = Potassium polyethylene glycol
PCB = Polychlorinated biphenyls
PCTP = Ploychlorinated triphenyl
PEG = Polyethylene glycol
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
1) Unidentified; 2) Bengartand Memel; and 3) Brown Boveri, Inc.
1) New Jersey; 2) Buffalo, NY; and 3) Philadelphia, PA
1) Uncontaminated soil spiked with PCBs; 2) soil; and 3) soil containing
14.5 percent water
1) PCB Aroclor 1260 (• 1000 ppm); 2) PCB Aroclor 1260; and 3) PCB
Aroclor1260(1150)
1) PCB Aroclor 1260 (• 1000 ppm); 2)PCB Aroclor 1260 (1150 ppm)
Laboratory-scale
10 percent (W/W) KPEG or NaPEG
Sample size was 100 to 500 g. Reagent-to-soil ration was 10 percent
(W/W). Reaction temperatures were ambient, 65»C, and 80»C. Reaction
time was 1 to 180 days.
1) The PCB-spiked soil containing 1000 ppm of Aroclor was
decontaminated (to <50 ppm) in only a few days by a direct application of
KPEG-350-1, and the reagent can be used to treat PCBs in soils
containing water and organics. The reagent NaPEG-1.00-N was not as
effective as the KPEG-350-1 reagent. The reagents used were ranked as
follows: KPEG-350-1 >NaPEG-3501>NaPEG-400-1. 2) Significant
reductions in PCB concentrations were achieved after the NaPEG
treatment. 3) The reagent was unable to reduce the PCB content in a wet
soil. Treatment effectiveness increased at higher temperatures (80 vs.
65'C).
laconiani, F.J. 1984, 1985. Destruction of PCBs-Environmental
Application of Alkali Metal Polyethylene Glycolate Complexes. Prepared for
the U.S. Environmental Protection Agency, HWERL, Cincinnati, OH.
Cooperative Agreement: CR 810068. Franklin Research Center,
Philadelphia, PA.
KPEG = Potassium polyethylene glycolate
NaPEG = Sodium polyethylene glycolate
PCB = Polychlorinated biphenyls
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Site PCB-contaminated site
Region II
Location Buffalo, NY
Background Not available
Waste Type Soil
Contaminants PCBs (28 to 66 ppm)
Equipment 55-gallon drum, heating tape, and mixer
Reagent KPEG
Conditions Sample size was 150 Ib. Reagent-to-soil ratio was 1:3. Reaction
time was 2 to 2.5 hours. Reaction temperature was varied
between 75 and 10OC.
Results The concentrations of PCBs were reduced from between 28 and
66 ppm to less than 1 ppm after 2.5 hours. More than 80 percent
of the reagent was recovered for reuse. Preliminary costs for the
process were on the order of $200/ton of soil.
Reference Rogers, C. J., D. L. Wilson, and A. Kernel. Preliminary Report on
Treatment/Detoxification Alternatives for PCBs and Chlorinated
Organics. Prepared by the U.S. EPA, HWERL, Cincinnati, OH.
KPEG = Potassium polyethylene glycolate
PCB = Polychlorinated biphenyl
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Site Not available
Region II
Location Buffalo, NY
Background Not available
Waste Type Soil spiked with PCDDs
Contaminants PCDDs (2000 ppb)
Equipment Laboratory-scale
Reagent KPEG
Conditions Sample size was 250 g. Reaction temperature was 75* C.
Reaction time was 1 to 2 hours.
Results The analysis indicated that the concentration of PCDDs was
reduced from 2000 ppb to below 1 ppb in the soil samples.
Reference Rogers, C. J., D. L. Wilson, and A. Kernel. Preliminary Report on
Treatment/Detoxification Alternatives for PCBs and Chlorinated
Organics. Prepared by the U.S. EPA, HWERL, Cincinnati, OH.
KPEG = Potassium polyethylene glycolate
PCDD = Polychlorinated dibenzodioxin
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
New Bedford Harbor
New Bedford, MA
Not available
Sediment
PCBs at <500 ppm (low-PCB) and >1000 ppm (high-PCB)
Laboratory-scale (500 ml), bench-scale (5000 ml)
KPEG with DMSO
Sample size was 6 Ib (wet weight). Reagent-to-soil ratio was 1:1.
Reaction temperature was 165»C. Reaction times were 9 hours
(low-PCB) and 12 hours (high-PCB). Number of water washes for
treated product was two.
Lab screening was conducted to determine reagent formulation,
temperature, mixing conditions, and separation procedures. PCB
concentration was reduced to <1 ppm (low-PCB) and 4 ppm
(high-PCB). Estimated cost for full-scale treatment was $80 to
$104/ton.
Galson Research Corporation. 1988. Final Report: Laboratory
Testing Results: KPEG Treatment of New Bedford Soil. Prepared
under REM III Contract No. 68-01 7250.
DMSO = Dimethyl sulfoxide
KPEG = Potassium polyethylene glycolate
PCB = Polychlorinated biphenyl
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
Not available
Not available
Not available
Uncontaminated soil samples were obtained from the vicinity of a
dioxin site in Mississippi and spiked with 1,2,3,4-TCDD prior to
tests.
Soil
1,2,3,4-TCDD
Laboratory-scale
KOH:PEG:DMSO (1:1:1), and KOH:MEE:DMSO (1:1:1)
Reagent-to-soil ratio was 1:1. Reaction temperature was varied
between 25 and 260* C. Reaction times were 0.5, 2, and 4 hours.
Within as little as 2 hours at 7f> C, the concentrations of TCDD
were reduced from 2000 ppb to <1 ppb (removal efficiency of
>99.95%). The bulk of this removal occurred in the first 30 minutes
when >99% of the TCDD had been reacted. Reagent recovery by
washing resulted in 94 to 99% recovery of reagent.
Peterson, R. L, E. Milicic, and C. J. Rogers. 1985. Chemical
Destruction/Detoxification of Chlorinated Dioxins in Soils. In:
Proceedings of Incineration and Treatment of Hazardous Waste,
the Eleventh Annual Research Symposium, September 1985.
EPA/600/9-85/028.
DMSO = Dimethyl sulfoxide
KOH = Potassium hydroxide
MEE = Methyl carbitol
PEG = Polyethylene glycol
TCDD = Tetrachlorodibenzo-p-dioxin
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
Not available
Not available
Not available
Uncontaminated soil samples were obtained from the vicinity of a
dioxin site in Mississippi and spiked with 1,2,3,4-TCDD prior to
tests.
Soil
1,2,3,4-TCDD
Laboratory-scale
KOH:MEE:DMSO:Water (2:2:2:1, 2:2:2:6, and 2:2:2:30) and
KOH:PEG:DMSO (1:1:1)
Reagent-to-soil ratio was 1:5. Reaction temperatures were 20 and
70» C. Reaction times were 1,2,4, and 7 days.
Results of the analysis indicated that the efficiency of the process
increased significantly at 70 versus 20» C (removal efficiency for
the process increased from 50% to >80%) and concentration of
TCDDs in samples treated at 70» C for 7 days were reduced from
2000 ppb to <1 ppb during the study.
Peterson, R. L, E. Milicic, and C. J. Rogers. 1985. Chemical
Destruction/Detoxification of Chlorinated Dioxins in Soils. In:
Proceedings of Incineration and Treatment of Hazardous Waste,
the Eleventh Annual Research Symposium, September 1985.
EPA/600/9-85/028.
DMSO = Dimethyl sulfoxide
KOH = Potassium hydroxide
MEE = Methyl carbitol
PEG = Polyethylene glycol
TCDD = Tetrachlorodibenzo-p-dioxin
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
Not available
VII
Omaha, NE
Not available
Herbicide waste
2,4-D (17,800 ppm); 2,4,5-T (2800 ppm); and 2,3,7,8-TCDD (1.3
ppm)
Pilot-scale, 55-gallon drum, a clamp-on heating band, and a
stirring motor.
KPEG
Sample size was 20 gallons. Reaction temperature was varied
between 70 and 85* C. Reaction time was 2 days.
The KPEG reagent reduced concentrations of 2,3,7,8-TCDD in the
waste to less than the detectable range. The concentrations of 1.3
ppm 2,3,7,8-TCDD; 17,800 ppm 2,4-D; and 2800 ppm 2,4,5-T
were reduced to none detectable, 334 ppm, and 44 ppm,
respectively. The study also proved the efficacy of the KPEG
process in treatment of the soils without the use of DMSO or TMH.
Taylor, M. L, et al.. 1989. Field Application of the KPEG Process
for Treating Chlorinated Wastes. Prepared for the U.S. EPA,
RREL, under contract No. 68-03-3413.
D = Dichlorophenoxyacetic acid
DMSO = Dimethyl sulfoxide
KPEG = Potassium polyethylene glycol
T = Trichlorophenoxyacetic acid
TCDD = Tetrachlorodibenzo-p-dioxin
TMH = Triethylene glycol methyl ether
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
Wide Beach Development
Irving, NY
The Wide Beach Development site is a residential development of
the shores of Lake Erie. Waste oil applied to local roads as a dust
suppressant contaminated the site with PCBs. Approximately
30,000 yd3 of PCB-contaminated soil (mainly in the top layer) is
present on the site.
Soil
PCBs
Bench-scale
PEG-400:TMH:DMSO:KOH (1:1:2:2)
Sample size was 300 g. Reagent-to-soil ratio was 1:1 (W/W).
Reaction temperatures were 140, 150, and 160* C. Reaction times
were 4 hours for the soil with an initial PCB concentration of 24
ppm and 8 hours for the soil with an initial PCB concentration of
690 ppm. The optimum reaction temperature for the process was
150'C.
PCB concentrations in each soil were reduced to below 10 ppm.
The results of the analyses performed on the reagents and
washing liquids indicate that the PCBs were actually destroyed in
the soil, not merely extracted.
Galson Research Corporation. 1988. Laboratory-Scale Testing
Report. KPEG Processing of Wide Beach Development Site Soils.
East Syracuse, NY. 980-TSI-RT-FCCC.
DMSO = Dimethyl sulfoxide
KOH = Potassium hydroxide
PCB = Polychlorinated biphenyl
PEG = Polyethylene glycol
TMH = Triethylene glycol methyl ether
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
Wide Beach Development
Irving, NY
The Wide Beach Development site is a residential development on
the shores of Lake Erie. Waste oil applied to local roads as a dust
suppressant contaminated the site with PCBs. Approximately
30,000 yd3 of PCB-contaminated soil (mainly in the top layer) is
present in the site.
Soil
PCBs (maximum of 260 ppm)
Pilot-scale
KOH/Water/PEG/TMH/DMSO (1:1:1:1:2)
Optimum feed rate for the reagent and soil was 1200 Ib reagent
per ton of soil to be processed. Mixing rate was 50 rpm. Reaction
temperature was 150»C. Reaction time was 1 to 6 hours
(including 2 to 3 hours heat-up time). Number of water washes for
treated product was three.
The analytical results indicated that the PCB concentration was
reduced from 260 ppm to between 0.7 and 5.7 ppm in 3 to 6
hours. Reagent recoveries for solvents were as high as 100
percent, and KOH recovery was as high as 85 percent. The cost
of the process was estimated to vary from $273 to $301/yd3 of soil.
Ebasco Services, Inc. 1989. Final Design Report. Remedial
Design, Wide Beach Development Site, Wide Beach, New York.
Prepared for EPA under Contract No. 68-01-7250.
DMSO = Dimethyl sulfoxide
KOH = Potassium hydroxide
PCB = Polychlorinated biphenyl
PEG = Polyethylene glycol
TMH = Triethylene glycol methyl ether
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62
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
Re-Solve
Dartmouth, MA
Not available
Silty sand (almost saturated with water)
Several chlorinated and nonchlorinated organic solvents and high
concentrations of PCBs (• 3000 ppm).
Bench-scale
PEG-400:TMH:DMSO:KOH (1:1:2:1.33)
Sample size was 300 g (the soil was screened prior to test by
using a sieve with 0.25-in. openings). Reagent-to-soil ratio was
1:1. Reaction temperature was varied between 25 and 128* C.
Reaction time was 8 hours. Number of water washes for treated
product was two.
PCB concentrations were reduced from 2900 ppm to <1 ppm.
PCB destruction did not begin until most of the water was distilled
out of the reagent/soil slurry.
Galson Research Corporation. 1987. Treatability Test for APEG
Dechlorination of PCBs in Re-Solve Site Soil. 6601 Kirkville Road,
E. Syracuse, NY.
DMSO = Dimethyl sulfoxide
KOH = Potassium hydroxide
PCB = Polychlorinated biphenyl
PEG = Polyethylene glycol
TMH = Triethylene glycol methyl ether
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63
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
U.S. Navy Public Works Center (USN-PWC)
IX
Island of Guam, U.S.A.
Soil contamination, which occurred mainly in a nearby storm
drainage ditch, resulted from leaks from a building where
transformers were reworked.
Soil
PCBs (average was 2500 ppm, peak was 45,860 ppm)
Field-scale mixer, platform, liquid reagent, loading system, heating
system, nitrogen system, condensate collection system, process
cooling water system, reagent collection system, and a
neutralization system.
KOH:PEG-400 (1.3 to 1 molar ratios)
Reagent-to-soil ratio was 0.5:1 (on weight basis). Mixing rate was
60 rpm. Reaction temperature was 150»C. Reaction time was 4 to
6 hours. After treatment, the pH of the soil was adjusted to
between 6 and 9 by using sulfuric acid.
Results of analysis indicated that the destruction of the total PCB
concentration exceeded 99 percent. In addition, analysis of each of
the congener peaks showed that the tetrachlorobiphenyl
congeners concentration in a portion of the treated batches was
slightly above the R&D permit requirement of 2 ppm or lower per
PCB peak.
Taylor, M. L, et al. 1989. Comprehensive Report on the KPEG
Process for Treating Chlorinated Wastes. Prepared for the U.S.
EPA, RREL, under Contract No. 68-03-3413.
KOH = Potassium hydroxide
PCB = Polychlorinated biphenyl
PEG = Polyethylene glycol
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64
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
Not available
Mechanicsburg, PA
Not available
Soil
PCB Aroclor 1260 (200 to 900 ppm); assorted aromatic and
aliphatic hydrocarbons.
Bench-scale
KPEG and NaPEG
Sample size was varied between 10 and 100 g. Reagent-to-soil
ratio was varied between 1:1 and 0.5:1 (W/W). Reaction
temperatures were 120 and 180»C. Reaction times were between
3 and 6 hours. After the sample was mixed, the reaction flask was
allowed to cool for 15 to 45 minutes. The reaction mixture was
neutralized with 10 to 20 percent HCI to bring the pH to less than 9.
The PCB-contaminated soil was found to be amenable to KPEG/
NaPEG treatment. The PCB concentrations in the soil were
reduced from as high as 900 ppm to less than 2 ppm per residual
PCB congener.
Taylor, M. L, et al. 1989. Comprehensive Report on the KPEG
Process for Treating Chlorinated Wastes. Prepared for the U.S.
EPA, RREL, under Contract No. 68-03-3413.
KPEG = Potassium polyethylene glycolate
NaPEG = Sodium polyethylene glycolate
PCB = Polychlorinated biphenyl
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65
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
Timberline Stables
VII
Missouri
Not available
Soil and liquid samples
Organic chlorine (15.3 ppm) and 2,3,7,8-TCDD (277 ppb) in soil
samples.
Laboratory-scale
K-400andK-120
Reaction times were 2 days for neat solutions and 7 and 28 days
for soil samples.
With K-400 as the reagent, the concentration of TCDD in the soil
samples was reduced by 45 and 35 percent after 7 and 28 days,
respectively. With K-120, however, the concentration of TCDD
was reduced by 46 and 38 percent after reaction times of 7 and 28
days, respectively.
Klee, A., C. Rogers, and T. Tiernan. 1984. Report on the Feasibility
of APEG Detoxification of Dioxin-Contaminated Soils. Prepared for
the U.S. Environmental Protection Agency, IREL.
EPA-600/2-84-071.
TCDD = Tetrachlodibenzo-p-dioxin
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66
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Site Denny Farm Site
Region VII
Location Missouri
Background Not available
Waste Type Soil
Contaminants Organic chlorine (1380 ppm) and 2,3,7,8-TCDD (330 ppb) in soil
samples.
Equipment Laboratory-scale
Reagent K-400 and KM-350
Conditions Reaction times were 7 and 28 days.
Results With K-400 as the reagent, the concentration of TCDD in the soil
samples was reduced by 12 percent after 28 days. With K-120,
the concentration of TCDD was released by 51 and 5 percent after
7 and 28 days, respectively.
Reference Klee, A., C. Rogers, and T. Tiernan. 1984. Report on the Feasibility
of APEG Detoxification of Dioxin-Contaminated Soils. Prepared for
the U.S. Environmental Protection Agency, IERL.
EPA-600/2-84-071.
TCDD = Tetrachlodibenzo-p-dioxin
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
Bengart & Memel
Buffalo, NY
The site was occupied by a wholesaler of nonferrous scrap
metals. From 1950 through 1978, Bengart & Memel received and
dismantled PCB transformers and capacitors. Analyses of the soil
samples indicate that the site is contaminated with PCBs in
concentrations greater than 50 ppm.
Soil
PCBs
55-gallon drums; no mechanism for agitation
Sulfoxide (sulfolane or DMSO); a glycol or capped glycol [e.g.,
PEG-400, TMH, and/or methyl carbitol (MEE)]; solid or aqueous
KOH; and water (2:2:4:9:5 PEG:TMH:DMSO:45 percent KOH:
water).
Sample size was fifty-one 55-gallon drums of soil, 10 m3 each.
Reagent-to-soil ratio was 1:5 (W/W). Reaction temperature was
105 to 110» C. Reaction time was 2 to 3 days. One group of drums
was then held at outdoor temperatures for approximately 5
months.
The APEG processing was successful in reducing PCB levels in
51 of 52 drums to below the 50 ppm control limit set for the site.
For those 51 drums, the average PCB levels were reduced 75
percent, from 108 to 27 ppm. The PCB level for the sole remaining
drum was reduced by 93 percent, from 1300 to 78 ppm. The total
cost was $50,052 without neutralization and $75,056 with
neutralization.
Novosad, C. F., et al. 1987. Decontamination of a Small PCB Soil
Site by the Galson APEG Process. Preprint Extended Abstract,
194th National Meeting of the American Chemical Society, August
30-September4, 1987, 27(2):435-437.
APEG = Alkali metal polyethylene glycolate
DMSO = Dimethyl sulfoxide
KOH = Potassium hydroxide
PCB = Polychlorinated byphenyl
PEG = Polyethylene glycol
TMH = Triethylene glycol methyl ether
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68
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Site
Region
Location
Background
Waste Type
Contaminants
Equipment
Reagent
Conditions
Results
Reference
Moreau
South Glens Falls, NY
The Moreau site is a former dragstrip. The area was oiled
periodically with PCB-contaminated oils. The PCB concentrations
at the site ranged from nondetectable up to tens of thousands
parts per million.
Soil
PCBs
Pilot-scale (40-in.-long x 16-in.-dia. reactor)
KOH (0.45), PEG, DMSO, TMH, and water at different ratios were
used during the study.
Sample size was 32.5 to 39.0 Ib. Reagent-to-soil ratio was • 1:1
(W/W). Temperature was 150»C. Reaction time was 4 to 8 hours.
Gases from the reactor were vented through an ice-cooled air
condenser and a Nixton drum.
The results of the analyses performed indicated a 93.9 to 99.8
percent reduction in PCB concentration in the soil. Average
reduction was 98.3 percent. The reagent recovery averaged 61
percent and ranged from 47 to 68 percent during the experiments.
Taylor, M. L, et al. 1989. Comprehensive Report on the KPEG
Process for Treating Chlorinated Wastes. Prepared for the U.S.
EPA, RREL, under Contract No. 68-03-3413.
DMSO = Dimethyl sulfoxide
KOH = Potassium hydroxide
PCB = Polychlorinated biphenyl
PEG = Polyethylene glycol
TMH = Triethylene glycol methyl ether
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69
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
i. R1P.O.R.T. NC
-92/OlSa
2.
3. RECIPIENT'S ACCESSION NO.
PB92-169 044
I. TITLE AND SUBTITLE
Guide for Conducting Treatability Studies
Under CERCLA: Chemical Dehalogenatlon
5. REPORT DATE
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
G. McHelly
8. PERFORMING ORGANIZATION REPORT NO,
9. PERFORMING ORGANIZATION NAME AND ADDRESS
IT Corporation
11499 Chester Rd.
Sharonville, OH
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
Risk Reduction Engineering Laboratory - Cincinnati, Ohio
Office of Research and Development
U.S. Environmental Protection Agency
OH &S96K
14. SPONSORING AGENCY CODE
EPA 600/14
15. SUPPLEMENTARY NOTES
Dave Smith FTS: 330-1475 Commercial #: (303) 293-1475
10. ABSTRACT
Systematically conducted, well-documented treatability studies are an
important component of remedy evaluation and selection under the Superfund
program. This manual focuses on chemical dehalogenation treatability studies
conducted in support of remedy selection that is conducted prior to the Record
of Decision (ROD).
This manual presents a standard guide for designing and implementing a
chemical dehalogenation treatability study. The manual presents a description
of and discusses the applicability and limitations of chemical dehalogenation
technologies and defines the prescreening and field measurement data needed to
determine if treatability testing is required. It also presents an overview
of the process of conducting treatability tests and the applicability of
tiered treatability testing for evaluation of chemical dehalogenation
technologies. The specific goals of each tier of testing are defined and
performance levels are presented that should be met at the remedy screening
level before additional tests are conducted at the next tier. The elements of
a treatability study work plan are also defined with detailed discussions on
the design and execution of the treatability study.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c, COSATI Field/Group
Superfund
Treatability
Chemical Dehalogenation
8. DISTRIBUTION STATEMENT
Release To Public
19. SECURITY CLASS (TillsReport/
Unclassified
21. NO. OF PAGES
76
20. SECURITY CLASS (This page!
Unclassified
22. PRICE
EPA Form 2220-1 (R«v. 4-77) PREVIOUS EDITION is OBSOLETE
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•&U.S. GOVERNMENT PRINTING OFFICE: IW2 - 648-003/41844
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Environmental Protection
Agency
Center for Environmental Research
Information
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PERMIT No. G-35
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Penalty for Private Use, $300
Please make all necessary changes on the above label,
detach or copy, and return to the address In the upper
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detach, or copy this cover, and return to the address In the
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