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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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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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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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
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    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
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-150.4
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-124.0
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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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M-6 Receive Waste
M-7 Submit Treatab
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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
•
•
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Qi



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•
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^-^ 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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34

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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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35

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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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36

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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

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<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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37

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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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Brunelle,  D.  J.  1983. Reaction  of  Poly chlorinated
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Brunelle, D.   J.,  and  D.  A.   Singleton.   1983.
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   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.
Word-searchable version - Not a true copy
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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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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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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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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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
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                                                                           21. NO. OF PAGES
76
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EPA Form 2220-1 (R«v. 4-77)    PREVIOUS EDITION is OBSOLETE


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Information
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