United States
                       Environmental Protection
                       Agency
Office of
Solid Waste and Emergency
Response
EPA/540/R-92/013b
Publication No. 9355.0-38FS
May 1992
                       Chemical  Dehalogenation
                       Treatability  Studies  Under CERCLA:
                       An  Overview
 Office of Emergency and Remedial Response
 Hazardous Site Control Division OS-220W
                                     Quick Reference Fact Sheet
    Section 121 (b) of CERCLA mandates EPA to select remedies that "utilize permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent practicable" and to prefer remedial actions in which treatment "permanently
reduces the volume, toxicity, or mobility of hazardous substances, pollutants, and contaminants as a principal element." Treatability studies
provide data to support treatment technology selection and should be performed as soon as it is evident that insufficient information is
available to ensure the quality of the decision. Conducting treatability studies early in the remedial investigation/feasibility study (RI/FS)
should reduce uncertainties associated with selecting the remedy, and provide a sounder basis for the Record of Decision (ROD).
Treatability studies conducted during remedial design/ remedial action (RD/RA) provide data to support remedy implementation. Regional
planning should factor in the time and resources required for these studies.

    This fact sheet provides a summary of information to facilitate the planning and execution of chemical dehalogenation treatability studies
in support of the RI/FS  process. Detailed information on these pre-ROD treatability studies is provided in the  Guide for Conducting
Treatability Studies Under CERCLA:  Chemical Dehalogenation, EPA/540/R-92/013a, May 1992. This technology-specific guide was
designed to be used in conjunction with the final generic Guide for Conducting Treatability Studies Under CERCLA, which provides
general information on the planning and execution of pre- and  post-ROD treatability studies. Although some information on post-ROD
chemical dehalogenation testing is provided here, the focus of this fact sheet  and the chemical dehalogenation guide  is on pre-ROD
treatability studies.
TECHNOLOGY DESCRIPTION AND
PRELIMINARY SCREENING

    This fact sheet presents information on conducting treatability
studies involving direct chemical dehalogenation of halogenated
organics in soils, sediments, 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 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.
      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  aliphatics  (e.g., ethylene
      dibromide, carbon tetrachloride, chloroform, anddichloromethane).
      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. Treatment 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. Treated
      soils and residuals from chemical dehalogenation treatment may
      require  posttreatment (e.g., neutralization) prior to their final
      disposition.

         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
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part of a treatment train) include Galson Remediation Corporation,
Soil Tech Inc., Chemical Waste Management Inc., and SDTX
Technologies, Inc.

    To date, chemical dehalogenation has been selected in the ROD
for cleanup  of contaminated soils at four Superfund sites: Wide
Beach Development, Brant, New 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).

Prescreening the Technology

    Potentially applicable process options are screened based on
three  factors: effectiveness, implementability,  and cost. Table 1
presents the  site and technology data that are required to screen the
chemical  dehalogenation process. The  effectiveness evaluation
focuses on  1) the  potential for the process option 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  of the  option,  and  3)  the
documented  performance  of  the  option  for treating  similar
contaminants and matrices. Implementability addresses both the
technical and administrative aspects of implementing a process
option.  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
process options  such  as chemical dehalogenation from further
consideration.
                 USE OF TREATABILITY TESTS IN
                 REMEDY SELECTION

                 The Process of Treatability Testing in Selecting a
                 Remedy

                     As site and technology information is collected and reviewed,
                 additional data needs for evaluating alternatives  are identified.
                 Treatability studies may be required to fill these data gaps. If so,
                 treatability studies must be scoped and initiated as early as possible
                 to keep the RI/FS on schedule and within budget.

                     The final generic Guide for Conducting Treatability Studies
                 Under CERCLA details the three tiers of treatability testing (remedy
                 screening, remedy selection,  and remedial design/remedial action)
                 and their relationship to the RI/FS 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. They are characterized by:

                     •    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. They are characterized by:
Table 1. Data collection requirements for prescreening the chemical dehalogenation process option.
                Required Data
                            Prescreening Criteria
  Effectiveness
   Contaminated media type
   Volume of contaminated media
   Contaminant type


   Contaminant concentration
   Past performance on similar wastes

  Implementability
   Availability of process
   Administrative
   Accessibility of site

  Cosf
  Relative capital and O&M costs
Applicable to soils, sludges, and sediments.
Cost-effective for volumes greater than 1000 m3.
Applicable to halogenated aromatics and aliphatics (PCBs, PCDDs/PCDFs,
chlorobenzenes, chlorinated phenols, organochlorine pestisides, 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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    •   Moderate cost
    •   Moderate amounts of time to perform
    •   Stringent QA/QC

3)  Remedial  Design/Remedial  Action-Post-ROD,  pilot-scale
    studies performed in the field that provide scale-up and design
    optimization data. They are characterized by:

    •   High cost
    •   Long amounts of time to perform
    •   Moderately stringent QA/QC

    The flow diagram in Figure 1 traces the stepwise data reviews
and management decisions that occur in the tiered approach to
treatability  testing.  A  detailed description  of  this approach is
presented in the final generic guide.

Applicability of Treatability Testing to Chemical
Dehologenation

    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 (see next page).

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. The purpose of the literature  survey is twofold.
First, it should  identify  potentially  applicable  dehalogenation
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.

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 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
 Figure 1. Flow diagram of the tiered approach.
                                                                        MANAGEMENT DECISION FACTORS:
                                                                         • Stats and Community Acceptance
                                                                         • Schedule Constraints
                                                                         • Additional Data
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Table 2. Applicability of tiered approach to chemical dehalogenation treatability studies.

Purpose



Objective


Parameters
investigated





Data generated









Literature survey
• Identify potentially
applicable processes
• Obtain existing treatability
data
• Determine treatability
data needs

Not applicable






Not applicable









Remedy screening
• Determine process
feasibility for
contaminants/matrix

• Achieve >90% reduction in
target contaminant
concentrations
• "Severe" conditions






• Concentration of target
contaminants before and
after treatment







Remedy selection ROD RD/RA
• 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
proprietary nature of chemical dehologenation 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. The concentrations
of the target 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  potentially 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 process
should be screened out.

Remedy-Selection Treatability Studies

    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.

    Remedy-selection 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, operating parameters are
examined for their effects on target contaminant concentrations. A
remedy-selection study should provide  the RPM with  enough
information to ensure that the performance goals 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.

    Data from remedy-selection tests can be used to characterize
the product and residuals from dehalogenation  treatment. Data
generated at this tier can also  be used to  estimate the costs of
full-scale implementation of the  alternative, as  required in  the
detailed analysis.

Remedial Design/Remedial Action Treatability
Studies

    Remedial design/remedial action is the final step in the tiered
approach. The purpose of this tier is to generate detailed scale-up,
design,  and  cost  data  for  full-scale remedediation.  These
treatability  studies  are  conducted  after the remedy has  been
selected and the  ROD has  been  signed. In the  implementation
of a  remedy, RD/RA  treatability  studies can  be  used 1) to
select  among   multiple  chemical   dehalogenation  processes
and prequalify  vendors of these  processes, 2)  to  select the
most   appropriate   of  the   remedies   prescribed   in   a
Contingency  ROD, or  3)  to  support Agency-prepared  de-
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tailed  design  specifications  for dehalogenation  systems  and
treatment trains.  Additional information on RD/RA treatability
testing is available in the final generic guide.

    Post-ROD studies conducted to support preparation of detailed
design specifications for chemical dehalogenation typically generate
data   on   materials-handling   characteristics,   reagent
recovery/recycling efficiency,  energy/chemical usage, treatment
train performance,  and 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.

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. Elements of a Work  Plan that are specific to
pre-ROD chemical dehalogenation treatability studies are discussed
here. Information on the remaining elements can be  found in the
final generic guide.

Table 3. Suggested organization of treatability
	study work group 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

Test Objectives

    The Work Plan outlines the  treatability study test objectives and
describes how these objectives  will be used in evaluating chemical
dehologenation  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
Experimental Design and Procedures

    At the screening tier, the experimental procedures should not
be complex.  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. Only pre- and posttreatment samples
will be collected and physical and chemical analysis will be limited.

    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.  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.

Equipment

    Remedy-screening studies normally are performed in a batch
system  using  off-the-shelf  laboratory  glassware. A  typical
bench-scale reactor consists of a reaction flask, a stirrer, a heating
mantel, and a condensate collection system.

    Remedy-selection studies will be conducted in larger bench- or
pilot-scale reactors. 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.
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.
The experimental design and procedures  of a remedy selection
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  designed  and
performed.

Permits

    Treatability studies of chemical dehalogenation technologies are
subject  to  certain   regulatory   requirements  under  Federal
environmental  laws.  The  final  generic guide  describes  the
permitting   and   operating   requirements   under
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CERCLA and RCRA. Under the Toxic Substances Control Act
(TSCA), laboratories or testing facilities that handle PCB-containing
materials must obtain a Research and Development Permit. Storage
of PCB-containing materials for purposes of treatability testing is
limited to no longer than 1 year.

Residuals  Management

    Residuals  generated as a result of chemical dehalogenation
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  project schedule and costs, and the roles and
responsibilities of the various parties involved is important for their
proper disposal.

    Project 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
        Contaminated protective clothing and debris
Schedule

    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.

Budget

Elements of a budget include labor, administrative costs, and fees;
equipment and reagents; site preparation 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.

    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.  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.

SAMPLING AND ANALYSIS

    Factors associated with sampling and analysis that affect the
development of the Work Plan and the Sampling and Analysis Plan
(SAP)  for  chemical  dehalogenation  treatability testing  are
summarized here. A detailed discussion on the development of a
SAP for remedy-screening and remedy-selection treatability studies,
including a suggested plan organization, is contained in the chemical
dehalogenation guide.

Field Sampling

    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 tests at the remedy-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.

Waste Characterization

    Various chemical  tests may be used to establish the baseline
concentration of the target halogenated organic contaminants and
other  contaminants of interest. 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. The  selection of other
halogenated organic compounds should be based  on the likely
chemical reactions and  relative  toxicity of  the byproducts.
Compounds that could interfere with the chemical dehalogenation
process (e.g.,  elemental forms of certain metals) or those that
affect treatment or handling of residual fractions from the process
also may be of interest at the remedy-selection tier.

    Soil moisture content  and pH or buffering (base absorption)
capacity should  be determined  at the remedy-screening and
remedy-selection  tiers. High-moisture-content soils may  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.  Bioassays  of
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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.

Treated Product and Residuals Sampling
and Analysis

    Posttreatment sampling and analysis at the remedy-screening
tier will be limited to the target halogenated organic contaminants
in  the  treated   product.   Posttreatment  analytes   at  the
remedy-selection  tier  may  also  include  selected  potential
halogenated byproducts. 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 be required to
perform multiple test runs to generate sufficient quantities of
material for analysis. Bioassays also may be required 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.

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 and design of a remedial action that can
achieve the site cleanup criteria.

Use of pre-ROD Treatability Study Results in the
RI/FS Process

    The  interim  final  Guidance for  Conducting Remedial
Investigations  and   Feasibility   Studies   Under   CERCLA,
EPA/540/G-89/004, October 1988, 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

    Table 4 (see next page) lists factors important to the analysis
of the first seven of these criteria and the treatability study data that
provide information for this  analysis. The  results of treatability
studies also  may  influence the evaluations  against the  state and
community acceptance criteria.

Use of Pre-ROD Treatability Study Results in the
RD/RA Process

    Pre-ROD treatability study results also provide information for
the  subsequent detailed  design  investigations  of the  selected
remedial technology. Pre-ROD data on the chemical, physical, and
toxicological characteristics of the 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 be  carefully documented for post-ROD  pilot-and
full-scale investigations.

TECHNICAL ASSISTANCE

    The  Office   of  Solid  Waste  and  Emergency  Response
(OSWER) and the Office of Research and  Development (ORD)
established the Superfund Technical Support Project  (TSP)  to
provide direct, technology-based  assistance to the  Regional
Superfund programs through  ORD laboratories.  As  part of the
TSP, the Engineering Technical Support Center provides technical
assistance in the planning, performance, review, and oversight of
treatability studies. For further information please contact:

    Engineering Technical Support Center
       ORD/Risk Reduction Engineering Laboratory
       Cincinnati, Ohio
       Contact: Ben Blaney or Joan Colson
       (513)569-7406
ACKNOWLEDGMENTS

    This fact sheet and the corresponding guidance document were
prepared for the U.S. Environmental Protection Agency, Office of
Research and Development, Risk Reduction Engineering Laboratory
by IT Corporation, Cincinnati, Ohio. 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.
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Table 4. 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 contaminant 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
Percent reduction in target contaminant concentrations
Comparison of bioassay results before and after treatment
                                   Irreversibility of the treatment
                                 Material balance data combined with target contaminant
                                 concentrations in treated product and treatment residuals
                                   Type and quantity of, and risks
                                   posed by, 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
Physical/chemical characteristics of waste matrix
Physical/chemical characteristics of treatment residuals
                                   Protection of workers during
                                   remedial actions
                                 Physical/chemical characteristics of waste matrix
                                 Physical/chemical characteristics of treatment residuals
                                 Reagent formulation/material safety data
                                   Time until remedial response
                                   objectives are achieved	
                                                                   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
 Cost
Direct capital costs
Reaction time/throughput
Reagent usage/recovery
Reaction temperature
Physical characteristics of waste matrix
Site characteristics
                                   Operation and maintenance
                                   costs
                                      -Chemicals/reagents
                                 Reagent formulation/loading
                                 Reagent usage/recovery
                                 Volume and characteristics of treated product and treatment
                                 residuals
                                      -Utilities
                                 Reaction time/throughput
                                 Reaction temperature
                                      -Residuals
                                       treatment/disposal
                                 Volume and physical/chemical characteristics of treatment
                                 residuals
                                      -Equipment
                                 Reaction time/throughput
                                 Physical characteristics of waste matrix
                                      -Labor
                                 Reaction time/throughput
 Compliance with ARARs
Chemical-specific ARARs
Target contaminant concentrations in treated product and
treatment residuals
                                   Location-specific ARARs
                                 Target contaminant concentrations in treated product and
                                 treatment residuals
                                 Results of bioassays performed on treated product and
                                 treatment residuals
                                  Action-specific ARARs
                                 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
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