United States
          Environmental Protection
          Agency
Office of Research and
Development
Washington DC 20460
                             Office of Solid Waste and
                             Emergency Response
                             Washington, DC 20460
Superfund
                         EPA/540/R-92/071a
               October 1 992
<>EPA  Guidance for Conducting
          Treatability Studies under
          CERCLA
          Final
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                                                               EPA/540/R-92/071a
                                                       OSWER Directive No. 9380.3-10
                                                                 November 1992
                       GUIDE FOR CONDUCTING
            TREATABILITY STUDIES UNDER CERCLA
                                    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
                   rulemaking  by  the  Agency,  and may not be relied on to create a
                   substantive  or procedural right enforceable by any  other person. 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. It describes a three-tiered approach that consists of 1)
                    remedy screening,  2) remedy-selection testing, and  3)  remedial
                    design/remedial action testing. It also presents a protocol for conducting
                    treatability studies  in a systematic and stepwise fashion for determination
                    of the effectiveness of a technology (or combination of technologies) in
                    remediating a CERCLA site.
                                                          E. Timothy Oppelt, Director
                                                Risk Reduction Engineering Laboratory
                                                   m
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                                          ABSTRACT
                    Systematically conducted, well-documented treatability studies are an
                    important component of the removal  process,  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 screening, selection, and
                    implementation of the site remedies. This guide focuses on both treatability
                    studies conducted  in support of remedy screening  and selection [i.e.,
                    pre-Record of Decision  (ROD)] and treatability studies in support of
                    remedy implementation (i.e., post-ROD).

                    The guide describes a three-tiered approach for conducting treatability
                    studies that consists of 1) remedy screening, 2) remedy-selection testing,
                    and 3) RD/RA testing. Depending on the technology information gathered
                    during RI/FS scoping, pre-ROD treatability studies may begin at either the
                    remedy-screening  or remedy-selection  tier.  Remedial  design/remedial
                    action treatability testing is performed post-ROD.

                    The guide also presents an 11-step generic protocol  for conducting
                    treatability studies.  The steps include:

                      • 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 study
                      • Analyzing and interpreting the data
                      • Reporting the results

                    The intended  audience  for this  guide comprises Remedial  Project
                    Managers,  On-Scene  Coordinators,  Federal  facility  environmental
                    coordinators, potentially responsible parties, contractors, and technology
                    vendors. Although Resource Conservation and Recovery Act (RCRA)
                    program officials may find many sections of this guide useful, the RCRA
                    program is not expressly addressed in the guide.
                                                   IV
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                               TABLE OF  CONTENTS
Section                                                                                         Page
NOTICE	ii
FOREWORD	  iii
ABSTRACT  	  iv
FIGURES 	  vi
TABLES	vii
ACRONYMS  	viii
ACKNOWLEDGMENTS  	  k
1.   Introduction	1
   1.1   Background  	1
   1.2   Purpose  	1
   1.3   Intended Audience 	1
   1.4   History of the Guide  	2
   1.5   Use of the Guide	2
2.   Overview of Treatability Studies	5
   2.1   The Role of Treatability Studies Under CERCLA	5
   2.2   Three-Tiered Approach to Treatability Testing 	7
   2.3   Applying the Tiered Approach	12
   2.4   Treatability Study Test Objectives  	13
   2.5   Special Issues	15
3.   Protocol for Conducting Treatability Studies  	23
   3.1   Introduction	23
   3.2   Establishing Data Quality Objectives	23
   3.3   Identifying Sources for Treatability Studies	26
   3.4   Issuing the Work Assignment	29
   3.5   Preparing the Work Plan	31
   3.6   Preparing the Sampling and Analysis Plan	35
   3.7   Preparing the Health and Safety Plan	38
   3.8   Conducting Community Relations Activities	39
   3.9   Complying With Regulatory Requirements  	41
   3.10  Executing the Study	45
   3.11  Analyzing and Interpreting the Data	46
   3.12  Reporting the Results	52
REFERENCES  	55
APPENDIX A. Sources of Treatability Information	57
APPENDIX B. Cost Elements  Associated with Treatability Studies	61
APPENDIX C. Technology-Specific Characterization Parameters 	65
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                                            FIGURES
 gure                                                                                                Page

  1    Decision tree showing when treatability studies are needed to support the evaluation and selection of an
       alternative	6
  2    The role of treatability studies in the RI/FS and RD/RA process	9
  3    Flow diagram of the tiered approach	14
  4    Information contained in the ORD Inventory of Treatability Study Vendors	28
  5    Example test matrix for zeolite amendment remedy-selection treatability study 	32
  6    Example project schedule for a two-tiered chemical dehalogenation treatability study	36
  7    Example project organization chart	37
  8    Facility requirements for treatability testing	42
  9    Shipping requirements for offsite treatability testing	43
  10    Evaluation criteria and analysis factors for detailed analysis of alternatives  	48
  11    General applicability of cost elements to various treatability  study tiers  	62
                                                   VI
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                                            TABLES
Table                                                                                              Page

   1     General Comparison of Remedy-Screening, Remedy-Selection, and RD/RA Treatability Studies 	8
   2     Aqueous Field Treatability Studies: Generic Versus Vendor Processes	20
   3     Soils/Sludges Field Treatability Studies: Generic Versus Vendor Processes	20
   4     Summary of Three-Stage DQO Development Process  	24
   5     PARCC Parameters	25
   6     Suggested Organization of Treatability Study Work Assignment	30
   7     Suggested Organization of Treatability Study Work Plan	31
   8     Typical Waste Parameters Needed to Obtain Disposal Approval at an Offsite Facility	34
   9     Suggested Organization of a Treatability Study Sampling and Analysis Plan	38
  10    Suggested Organization of a Treatability Study Health and Safety Plan	39
  11    Suggested Organization of Community Relations Plan	40
  12    Regional Offsite Contacts for Determining Acceptability of Commercial Facilities
        to Receive CERCLA Wastes	45
  13    Suggested Organization of Treatability Study Report	53
  14    Waste Feed Characterization Parameters for Biological Treatment 	66
  15    Waste Feed Characterization Parameters for Physical/Chemical Treatment	67
  16    Waste Feed Characterization Parameters for Immobilization 	71
  17    Waste Feed Characterization Parameters for Thermal Treatment  	72
  18    Waste Feed Characterization Parameters for In Situ Treatment  	74
                                                  Vll
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                                        ACRONYMS
AOC      Administrative Order on Consent                OSWER
ARAR    applicable or relevant and appropriate
          requirement                                 PARCC
ARCS    Alternative Remedial Contracts Strategy
ATTIC    Alternative Treatment Technology Information    PAH
          Center                                      PCB
CERCLA Comprehensive Environmental Response,        PRP
          Compensation, and Liability Action of 1980       QAPP
          (aka Superfund)                              QA/QC
CFR      Code of Federal Regulations                    RA
COLIS    Computerized On-Line Information Service       RCRA
COE      U.S. Army of Corps of Engineers
CRP      Community Relations Plan                     RD
DOD      Department of Defense                       RD&D
DOE      Department of Energy                         RFP
DOT      Department of Transportation                  RI
DQO      Data quality objective                         ROD
EPA      U.S. Environmental Protection Agency           RPM
ERCS     Emergency Response Cleanup Services          RREL
ERT      Emergency Response Team                    SAP
ETSC     Engineering Technical Support Center            SARA
FAR      Federal Acquisition Regulations
FR       Federal Register                              SCAP
FS        feasibility study
FSP      Field Sampling Plan                           SITE
HSP      Health and Safety Plan
HSWA    Hazardous and Solid Waste Amendments of      SOP
          1984                                       SOW
ITSV      Inventory of Treatability Study Vendors          START
LDRs     Land Disposal Restrictions
MCLs    Maximum Contaminant Levels                 TAT
MSDS    Material Safety Data Sheet                    TCLP
NCP      National Oil and Hazardous Substances          TIX
          Pollution Contingency Plan                     TOC
NIOSH    National Institute of Occupational Safety and     TOX
          Health                                      TSDF
NPL      National Priorities List                         TSC
O&M     Operations and Maintenance                   TSP
OERR    Office of Emergency and Remedial Response     TST
ORD      Office of Research and Development            USCG
OSC      On-Scene Coordinator                         USPS
OSHA    Occupational Safety and Health Administration    UST
Office of Solid Waste and Emergency
Response
Precision, Accuracy, Representativeness,
Completeness, and Comparability
Polynuclear Aromatic Hydrocarbon
Poly chlorinated biphenyl
Potentially responsible party
Quality Assurance Project Plan
quality assurance/quality control
remedial action
Resource Conservation and Recovery Act
of 1976
remedial design
research, development, and demonstration
request for proposal
remedial investigation
Record of Decision
Remedial Project Manager
Risk Reduction Engineering Laboratory
Sampling and Analysis Plan
Superfund Amendments and
Reauthorization Act of 1986
Superfund Comprehensive
Accomplishments Plan
Superfund Innovative Technology
Evaluation
standard operating procedure
Statement of Work
Superfund Technical Assistance Response
Team
Technical Assistance Team
toxicity characteristic leaching procedure
Technical Information Exchange
total organic carbon
total organic halogen
treatment, storage, or disposal facility
Technical Support Center
Technical Support Project
Technical Support Team
United States Coast Guard
United States Postal Service
Underground Storage Tank
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                                                 vm

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                               ACKNOWLEDGMENTS
                This guide was prepared for the U.S. Environmental Protection Agency, Office of
                Research and Development, Risk Reduction Engineering  Laboratory  (RREL),
                Cincinnati, Ohio, by IT Corporation. Mr. Eugene F. Harris and Mr. David L. Smith
                served as the EPA Technical Project Monitors, assisted by Ms. Robin M. Anderson,
                Office of Emergency and Remedial Response,  and Mr. Johnathan Herrmann,
                RREL. Mr. Gregory D. McNelly was IT's Work Assignment Manager. The project
                team included Jeffrey S. Davis, Mary Beth Foerst, E. Radha Krishnan, Jennifer
                Platt, Michael Taylor, and Julie Van Deuren. Ms.  Judy L. Hessling served as IT's
                Senior Reviewer, and Ms. Martha H. Phillips served as the Technical Editor.
                Document layout was provided by Mr. James I. Scott, III.
                The following personnel have contributed their time and comments by participating
                in the Guide for Conducting Treatability Studies Under CERCLA workshop:
                    Lisa Askari
                    John Barich
                    Edward Bates
                    Benjamin Blaney
                    John Blevins
                    Randall Breeden
                    JoAnn Camacho
                    Jose Cisneros
                    Paul Flathman
                    Vance Fong
                    Frank Freestone
                    Tom Greengard
                    Eugene Harris
                    Sarah Hokanson
                    Norm Kulujian
                    Donna Kuroda
                    John Quander
                    Jim Rawe
                    Ron Turner
 U.S. EPA, Office of Solid Waste
 U.S. EPA, Region X
 U.S. EPA, Risk Reduction Engineering Laboratory
 U.S. EPA, Risk Reduction Engineering Laboratory
 U.S. EPA, Region IX
 U.S. EPA, Office of Emergency and Remedial Response
 U.S. EPA, Environmental Response Team
 U.S. EPA, Region V Emergency Response
 OHM Remediation Services Corporation
 U.S. EPA, Region IX
 U.S. EPA, Risk Reduction Engineering Laboratory
 EG&G Rocky Flats
 U.S. EPA, Risk Reduction Engineering Laboratory
 Clean Sites, Inc.
U.S. EPA, Region III
 U.S. Army Corps of Engineers
U.S. EPA, Technology Innovation Office
Science Applications International Corporation
U.S. EPA, Risk Reduction Engineering Laboratory
                                                 IX
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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 re-
  duces the volume, toxicity, or mobility of the hazardous
  substances, pollutants, and contaminants" [Comprehensive
  Environmental Response, Compensation, and Liability Act
  (CERCLA), Section 121(b)].

  Selection of remedial actions involves several risk manage-
  ment 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, as evident in the
  following  quote  from  Management  Review of the
  Superfund Program (EPA 1989a):

       'To  evaluate  the  application of treatment
       technologies to particular sites, it is essential to
       conduct laboratory or pilot-scale tests on actual
       wastes  from the site, including, if needed and
       feasible, tests of actual operating units prior to
       remedy  selection. These 'treatability tests' are
       not currently being performed at many  sites to
       the necessary extent, or their quality is not
       adequate to support reliable decisions."

  Treatability studies provide valuable site-specific data nec-
  essary 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 a remedial
  investigation/feasibility study (RI/FS) indicate whether a
  given technology can meet the expected cleanup goals for
  the site and provide important information to aid in remedy
  selection, whereas treatability studies  conducted during
  remedial design/remedial action (RD/RA) establish the de-
  sign  and operating parameters necessary  for optimization
  of technology performance and implementation of a sound,
  cost-effective remedy. Although the purpose and scope of
these studies differ, they complement one another because
information obtained in support of remedy selection may
also be  used  to support  the  remedy   design  and
implementation. Treatability studies also may be conducted
under the CERCLA Removal Program to support removal
actions that involve treatment.

Historically, treatability studies have been delayed until
after the Record of Decision (ROD) has been signed.
Although  certain  post-ROD  treatability   studies  are
appropriate, conducting treatability studies during the RI/FS
(i.e., pre-ROD) should reduce the uncertainties associated
with selecting the remedy, provide a sounder basis for the
ROD, and possibly facilitate negotiations with potentially
responsible parties without lengthening the overall cleanup
schedule for the site. Because treatability studies may be
expensive and time-consuming, however, the economics of
cost and time must be taken  into  consideration when
planning treatability studies in support of the various phases
of the Superfund program.
1.2    Purpose

This document presents guidance on conducting treatability
studies under CERCLA. Its purpose is to facilitate efficient
planning, execution, and evaluation of treatability studies
and to ensure that the data generated can support remedy
selection and implementation.
1.3    Intended Audience

This  document is intended for use  by EPA Remedial
Project Managers (RPMs), EPA On-Scene Coordinators
(OSCs), potentially responsible parties (PRPs), Federal
facility  environmental  coordinators,  treatability  study
contractors, and technology vendors. As described here,
each of these persons plays a different role in conducting
treatability  studies  under  CERCLA.  Although  the
Resource  Conservation and  Recovery  Act  (RCRA)
program is not expressly
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  addressed, many sections of the guide may be useful in the
  planning  of treatability studies in support  of corrective
  action. Some parts may also be applicable in the Under-
  ground Storage Tank (UST) program.

  1.3.1  Remedial Project Managers

  Remedial Project Managers are EPA or State officials re-
  sponsible for remediation planning and oversight at a site.
  Their role in treatability investigations depends on the des-
  ignated  lead  agency  (Federal,  State, or  private)  and
  whether the site is a fund-financed or enforcement-lead
  site.  Their activities  generally   include  scoping  the
  treatability  study, establishing the data quality objectives,
  selecting a  contractor, and issuing a work assignment, or
  obtaining EPA sponsored  treatability  study  support,
  overseeing  the execution of the study, informing or
  involving the public as  appropriate, reviewing project
  deliverables, and using treatability study data in decision
  making.

  1.3.2  On-Scene Coordinators

  On-Scene Coordinators are Federal officials predesignated
  by the EPA or U.S. Coast Guard (USCG) to coordinate
  and direct removal actions at both National Priorities List
  (NPL) and  non-NPL sites. Their role in treatability studies
  is similar to that of the RPM.

  1.3.3  Potentially Responsible Parties

  Under CERCLA Sections 104(a) and 122(a), EPA has the
  discretion to allow  PRPs  to perform certain  RI/FS
  activities, including treatability studies. The EPA or an
  authorized State agency oversees the conduct of PRP-led
  treatability studies, but the PRP is responsible for project
  planning, execution, and evaluation.

  1.3.4  Federal Facility Environmental
         Coordinators

  Environmental coordinators at  Federal facilities  may
  conduct  treatability   studies  under   CERCLA   or
  agency-specific programs such as  the Department of
  Defense (DOD) Installation Restoration Program and the
  Department of Energy (DOE) Environmental Restoration
  and Waste  Management   Program.  The roles  and
  responsibilities of these personnel will vary by agency and
  program; however, for treatability studies  they will be
  similar to those of the EPA RPM.

  1.3.5  Contractors/Technology Vendors

  Treatability studies are generally performed by remedial
contractors  or  technology  vendors.  Their roles in
treatability investigations include preparing the Work Plan
and other supporting documents, complying with regulatory
requirements,  executing the  study,  analyzing  and
interpreting the data, and reporting the results.

1.4    History of the Guide

In December 1989, EPA published the interim final Guide
for Conducting Treatability Studies Under CERCLA
(EPA 1989b). This generic treatability guidance was one
component  of the EPA's  Office  of Research  and
Development (ORD) treatability study initiative to identify
treatability capabilities, to consolidate treatability data, and
to develop standard operating protocols. The objectives of
the guide were threefold:

   1) To provide guidance to RPMs and Superfund re-
      medial contractors for conducting treatability stud-
      ies in support of remedy selection (i.e., pre-ROD).

   2) To serve as a framework for developing technol-
      ogy-specific protocols.

   3) To be a dynamic document that evolves as the
      Agency gains treatability study experience.

As part of the development of the generic treatability
guidance, EPA sponsored a treatability protocol workshop
in July 1989,  which  was attended by more than 60
representatives from EPA Headquarters and Regional
offices, contractors/technology vendors, and academia.
The tiered approach to treatability studies and the 11-step
protocol that evolved during the workshop and subsequent
document peer review process form the  basis  of the
treatability guidance.

In keeping with the original objective of producing a dy-
namic document, comments on the utility of the interim
final guidance after approximately 18 months of use were
solicited through a survey of potential users  (principally
RPMs and their contractors) and a second workshop in
August 1991.  Although the general content  and  format
have  not changed, the  document has been expanded to
address a broader audience and updated to reflect current
regulations, policy, and guidance/information sources. In
addition, the "tier" terminology has been revised to reflect
the intended use of the  data  rather than the scale of
testing.

1.5    Use of the Guide

1.5.1   Organization of the Guide

The guide is organized into two principal sections: an
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  overview of treatability studies and a step-by-step protocol.
  Section 2 describes the need for treatability studies and
  presents a three-tiered approach consisting of 1) remedy
  screening, 2) remedy selection, and 3) remedial design/
  remedial action. This section also describes the application
  of the tiered approach to innovative technologies, treatment
  trains, and in situ technologies; circumstances in which
  treatability  studies  can   and cannot  be  performed
  generically; and PRP-conducted treatability studies.

  Section 3 presents a general  approach or protocol  for
  conducting treatability studies. It contains information on
  planning,  performing,  and  reporting  the  results  of
  treatability studies  with   respect to  the  three  tiers,
  Specifically, this section includes information on:

      •   Establishing data quality objectives.

      •   Identifying qualified sources for performance of
          treatability  studies and selecting a contracting
          mechanism.

      •   Issuing the work  assignment,  with emphasis on
          writing the scope of work.

      •   Preparing the Work  Plan, with  emphasis  on
          designing the experiment.

      •   Preparing the Sampling and Analysis Plan for a
          treatability study.

      •   Preparing the Health  and Safety Plan for  a
          treatability study.

      •   Conducting  community  relations  activities  in
          support of treatability studies.

      •   Complying with regulatory requirements for testing
          and residuals management.

      •   Executing the treatability study, with emphasis on
          collecting and analyzing samples.

      •   Analyzing and interpreting the data, including a
          discussion on statistical analysis techniques.

      •   Reporting the results in a logical and consistent
          format.

  The text of each subsection presents general information
  followed (when applicable) by specific details pertaining to
  the three tiers of treatability testing.
Appendix A contains  additional  sources  of treatability
information. Appendix B discusses the major cost elements
associated with treatability studies. Appendix C contains
technology-specific waste-characterization parameters.

1.5.2  Application and Limitations of the
       Guide

Treatability studies are an integral part of the Superfund
program.  This guide  is  intended to  supplement the
information on development,  screening, and analysis of
alternatives contained in the interim final Guidance for
Conducting Remedial Investigations and Feasibility
Studies  Under  CERCLA  (EPA 1988a),  hereinafter
referred to as the RI/FS guidance. Generic in nature, the
guide encompasses all waste matrices (soils, sludges,
liquids, and gases)  and all categories  of technologies
(biological  treatment,  physical/chemical   treatment,
immobilization, thermal treatment, and in situ treatment).
The  guide addresses treatability studies  conducted in
support of remedy screening and selection (i.e., pre-ROD)
and remedy design and implementation (i.e., post-ROD).
Companion  documents  providing  technology-specific
treatability guidance are  being prepared for soil vapor
extraction, chemical dehalogenation, soil washing, solvent
extraction,  biodegradation,   thermal  desorption,  and
solidification/stabilization.

In an effort to be concise, supporting information in other
readily  available  guidance  documents  is  referenced
throughout this guide rather than  repeated. For example,
details on the preparation of a site  Sampling and Analysis
Plan (which includes a Field Sampling Plan and a Quality
Assurance Project Plan), a Health and Safety Plan, and a
Community Relations Plan are not included herein.

Although this guidance is written to support the treatability
study activities of an EPA RPM under CERCLA, it has
wide applicability to many other programs. For this reason,
the  term "project manager"  has  been  used,  when
appropriate, to signal  the potential applicability of the
subject covered to both the  CERCLA Remedial and
Removal  Programs and to non-CERCLA treatability
studies.

This document was  drafted and reviewed by representa-
tives from EPA's Office of Solid Waste and Emergency
Response, Office of Research and Development, and the
Regional offices, as well as by contractors and vendors
who conduct  treatability  studies.  Comments  obtained
during the course of the peer review process have been
integrated or addressed throughout this guide.
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                                             SECTION 2
                    OVERVIEW OF TREATABILITY  STUDIES
  This section presents an overview  of treatability studies
  under CERCLA and provides examples of the application of
  treatability studies  in the RI/FS process.  Subsection 2.1
  outlines the role of treatability studies  in the Superfund
  program. Subsection 2.2 provides details on the three tiers of
  treatability testing. Subsection 2.3 presents the methodology
  for applying the tiered approach. Subsection  2.4 discusses
  treatability study test objectives. Subsection 2.5  addresses
  special issues associated with CERCLA treatability studies,
  including examples of how the tiered  approach  can be
  applied to investigations of unit operations, treatment trains,
  and in situ technologies; when  testing can and cannot be
  performed generically (i.e., without the assistance of vendors
  using proprietary reagents and processes); the involvement
  and oversight of PRPs; and the funding of treatability studies.
  2.1    The Role of Treatability Studies
         Under CERCLA
  2.1.1  Pre-ROD Treatability Studies

  As discussed in the RI/FS guidance, 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.  Treatability  studies may  be
  required to fill some of these data gaps.

  In the absence of data in the available technical literature,
  treatability studies can provide the critical performance and
  cost information needed to evaluate and select treatment
  alternatives.  The  purpose   of  a   pre-ROD treatability
  investigation is to provide the data needed for the detailed
  analysis of alternatives during the FS. The  1990  revised
  National Oil and Hazardous Substances Pollution Contin-
  gency  Plan  (NCP) (55 FR 8813), Section 300.430(e),
  specifies nine evaluation criteria to be considered in this
  assessment of remedial alternatives. Treatability Studies can
generally provide data to address the first seven of these
nine criteria:

    1)    Overall protection of human health and the
         environment

    2)    Compliance with applicable or relevant and
         appropriate requirements (ARARs)

    3)    Long-term effectiveness and permanence

    4)    Reduction of toxicity, mobility, and volume
         through treatment

    5)    Short-term effectiveness

    6)    Implementability

    7)    Cost

    8)    State acceptance

    9)    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 theprimary balancing criteria upon which the
selection of  the remedy  is based.  The final  two
modifying criteria, State acceptance and community
acceptance, are addressed in the ROD when comments
are received on the RI/FS  and the proposed remedial
plan. (The RI/FS evaluation criteria are discussed in
detail in Subsection 3.11.2.)

Pre-ROD treatability studies  may be needed when
potentially applicable treatment technologies are being
considered for which no or  limited performance or cost
information is available in the literature with regard to the
waste
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  types and site conditions of concern. The general decision
  tree presented in Figure 1 illustrates when treatability studies
  are needed to support the evaluation and  selection  of an
  alternative. After  the existing data on  the physical and
  chemical characteristics of the waste have  been reviewed,
  a  literature survey is conducted  to  obtain any existing
  treatability data for the  contaminants  and  matrices of
  concern.  (Sources of technical  support and  treatability
  information available  through  EPA  are  discussed in
  Subsection 3.3 and Appendix A.) Based on the results of a
  review of available site data and a literature search, remedial
  technology types are prescreened to eliminate those that are
  clearly not applicable for the site. Potentially and definitely
  applicable technologies are assembled into alternatives and
  evaluated in terms of the nine  RI/FS criteria to identify any
  data gaps. Site- and technology-specific data needs are then
  identified  for  each  of the  alternatives retained  for
  investigation.

  The need to conduct a treatability  study on any part of an
  alternative is a management  decision. In  addition to  the
  technical considerations,  certain nontechnical management
  decision factors must be considered. As shown in Figure 1,
  these factors  include the expected  level of State and
  community acceptance  of a  proposed  alternative;  time
  constraints on the completion of the RI/FS and the signing of
  the ROD; and  the appearance of new site,  waste, or
  technology data.

  If the existing data are  adequate for an evaluation of the
  alternative for remedy selection (i.e., sufficient to perform a
  detailed analysis against the nine RI/FS evaluation criteria),
  no treatability study is  required. Otherwise, a  treatability
  study should be performed to generate the data necessary to
  conduct a detailed  analysis of the alternative.

  2.1.2    Post-ROD Treatability Studies

  Although  a substantial  amount of data on  the selected
  remedy may be available from the RI/FS, treatability studies
  may also  be necessary  during remedial  design/remedial
  action if treatment  is part of the remedy. Post-ROD or RD/
  RA treatability studies can provide the detailed design, cost,
  and performance   data  needed to  optimize treatment
  processes and to implement full-scale treatment  systems. In
  the process of implementing a remedy, RD/RA treatability
  studies can be used 1) to select among multiple vendors and
  processes within a  prescribed remedy (pre-qualification), 2)
  to implement the most appropriate of the remedies prescribed
  in a Contingency ROD,  or 3) to support preparation of the
  Agency's detailed design specifications and the design of
  treatment trains.
           REVIEW AVAILABLE
              SITE DATA
          SEARCH LITERATURE
          TO OBTAIN EXISTING
          TREATABILITY DATA
              IDENTIFY
              DATA GAPS
    YES
MANAGEMENT DECISION FACTORS.
' Slats and Community Accsplancs
• Schedule Constraints
• Addtfonil Data
•~

CONDUCT
TREATABILITY STUDY


              PERFORM     )
           DETAILED ANALYSIS
           OF ALTERNATIVES  J
    Figure 1. Decision tree showing when
 treatability studies are needed to support the
   evaluation and selection of an alternative
The  need  for RD/RA  treatability  studies  may  be
identified by the RPM, the  PRP,  or the remedial
designer—Alternative Remedial Contracts  Strategy
(ARCS) contractor or U.S. Army Corps of Engineers
(COE). Because the designer is ultimately responsible
for the remedial design, the designer should carefully
review the available site-, technology-,  and waste-
specific treatability data before deciding on whether an
RD/RA treatability study  will be needed.

Vendor/Process Prequaliflcation

In general, a single remedy is selected in the ROD. The
remedy is often identified as a technology class or family
(e.g., thermal destruction) rather than as a specific
process option (e.g., a  rotary kiln).  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 vendor or
process is to use RD/RA treatability study results to
"prequafify"  a pool of vendors. In  these studies, all
interested parties  are
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  provided with a standard sample of waste. Each vendor
  designs and performs a treatability study based on that
  sample and provides treatment results to the lead agency.
  The lead agency uses  these results to determine 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.

  This prequalification approach has been used at the Selma
  Treating  Company  Superfund  Site,  Region  9,  Selma,
  California. Part 9 of the Federal Acquisition Regulations
  (FAR)  describes   policies,  standards,  and  procedures
  applicable to this approach.

  Contingency RODs

  There are situations in which additional flexibility in the ROD
  may  be required to ensure implementation of the most
  appropriate technology for a site. In these cases, the selected
  remedy may be  accompanied by  a proven contingency
  remedy in a Contingency  ROD. The  Contingency  ROD
  option was developed for two purposes: 1) to promote the
  use of innovative technologies,  and 2)  to  allow different
  technologies offering comparable performance to be carried
  through to remedial  design.

  Although treatability studies of an innovative technology will
  be conducted during the RI/FS  to support remedy selection,
  it may not be feasible to conduct sufficient testing to address
  all  of the significant uncertainties associated  with the
  implementation of this option. This situation, however, should
  not cause the option to be screened  out during the detailed
  analysis  of alternatives in the FS. If the  performance
  potential of an innovative technology indicates this technology
  would provide the best balance of tradeoffs from among the
  options considered  despite its uncertainties,  CERCLA
  Section 121(b)(2)  provides support for selecting such a
  technology in the ROD. Implementation of the technology,
  however, may be contingent upon  the  results of RD/RA
  treatability testing. When an innovative technology 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 the
  full-scale  innovative remedy cannot achieve the cleanup
  goals  at the site, the contingency  remedy  could then be
  implemented.

  If two  different technologies  for treatment  of the same
  contaminant/matrix  emerge from the FS and each offers
  comparable performance with respect to the five primary
  balancing criteria so that either one  could provide the best
  balance of tradeoffs, one of the alternatives may be named
in the ROD as the selected remedy and the other as the
contingency remedy. Based on the results of post-ROD
RD/RA treatability testing, the most appropriate remedy
can then be identified and implemented.

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 design of the remedy,  an  RD/RA
treatability   study   may  be  necessary.   Post-ROD
treatability  studies can  provide the detailed cost and
performance data  required  for  optimization  of the
treatment processes and  the  design of a full-scale
treatment system.

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.  Treatability  study
oversight will be provided by the RPM and the Oversight
Assistant.

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
for  treating the wastes, matrices,  and  residuals of
concern, issues such as  unit sizing, materials handling,
and  systems  integration  must  also  be  addressed.
Treatability studies of one unit's operations can assist in
identifying characteristics of the treated material that
may need to be taken into consideration in the design of
later units. A treatability  study of the entire train can then
provide data to confirm compliance with ARARs and the
cleanup criteria outlined in  the ROD.  Because  a
treatment train  will  often involve  several different
technologies and vendors, the designer will coordinate
treatability testing of the entire system and prepare the
final treatability study report.
2.2  Three-Tiered Approach to
     Treatability Testing

Treatability studies are laboratory or field tests designed
to provide critical data needed to evaluate and implement
remedial treatment technologies at waste sites. As an aid
in the planning and performance of cost-effective, on-
time,  scientifically  sound treatability  studies,  a three
tiered approach has been developed. The three-tiered
approach applies to all treatability studies conducted in
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  support of Superfund site remediation. Figure 2 presents the
  treatability tiers and their conceptual relationship to the RI/FS
  and the RD/RA processes. Table 1 lists general similarities
  and differences among the three tiers.

  2.2.1     Technology Presscreening and
            Treatability Study Scoping

  Prescreening is an important first step in the identification of
  potentially applicable treatment technologies and the need for
  treatability testing. Because or 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 shown in Figure 2, these
  efforts should be initiated during the RI/FS scoping.

  Technology prescreening and treatability study scoping will
  include  searching technology literature and treatability data
  bases, consulting with technology experts, determining data
  needs, identifying potential treatability study sources  or
  contractors, identifying preliminary data quality objectives,
  and preparing a work  assignment. Determination of the tier
  or tiers of treatability testing to be conducted will be based on
  the technology- and contaminant-specific 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
  Subsection  3.3;  additional  information  is presented  in
  Appendix A.) Early consultation may save time and money
  by preventing  the treatability  testing  of inappropriate
  technologies.

  2.2.2     Remedy Screening

  Remedy screening, the first  step in the tiered approach,
  provides the gross performance data needed to determine the
  potential  feasibility  of  the  technology   for  treating
  the contaminants and matrix of concern. Remedy-screening
treatability studies may not be necessary when the
literature contains adequate data for an assessment of
the feasibility  of a  technology.  The  results  of  a
remedy-screening study are used to determine whether
additional, more-detailed treatability testing should be
performed at the remedy-selection tier.

Feasibility is determined  by  assessing how  well  a
technology achieves the treatability study's performance
goals, which are based on available knowledge of the
operable  unit's cleanup criteria and are set prior to the
study.   Typically,  remedy-screening   studies  are
conducted under conditions representative of those in the
proposed full-scale system. If a  technology cannot
achieve the predetermined performance goals under
these  conditions, it  should be  screened out.  If all
technologies are rejected, the project manager should
reevaluate the screening performance goals to determine
if they are appropriate.

As shown in Figure 2, remedy-screening treatability
studies   are  initiated  during  the  pre-ROD  site
characterization and technology screening activities and
may continue through the identification of alternatives.
General  characteristics of the remedy-screening tier
(outlined in Table 1) are discussed here.

Study Scale

Performed  in  the   laboratory,   remedy-screening
treatability studies are limited  in  size  and  scope to
bench-scale  tests  with  off-the-shelf  equipment.
Investigations  of  some  technologies  may  require
additional small-scale field tests at the screening tier.

Type of Data Generated

Remedy-screening studies provide  qualitative data for
use in assessing the potential feasibility of a technology
for
  Table 1. General Comparison of Remedy-Screening, Remedy-Selection, and RD/RA Treatability Studies
Tier
Remedy
screening
Remedy
selection

RD/RA
Study scale
Bench scale
Bench or pilot
scale
Pilot or full scale
(onsite oroffsite)
Full scale (onsite)
Type
of data
generated
Qualitative
Quantitative
Quantitative
Quantitative
No. of
replicates
Single/
duplicate
Duplicate/
triplicate
Duplicate/
triplicate
Duplicate/
triplicate
Process
type
Batch
Batch or
continuous
Batch or
continuous
Batch or
continuous
Waste
stream
volume
Small
Medium
Large
Large
Time
required3
Days
Days/
weeks
Weeks/
months
Weeks/
months
Cost, $
10,000-
50,000
50,000-
100,000
50,000-
250,000
250,000-
1,000,000
  indicates duration of testing only.
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         Scoping
        "the RI/FS"
         Technology
        Prescreening
            and
         Treatability
           Study
          Scoping
               Remedial Investigation/
                  Feasibility Study
Record of
Decision
                                       Identification
                                       of Alternatives
                                                                         I
Remedial Design/
 Remedial Action
                                               Remedy
                                               Selection
                               Site
                          Characterization
                          and Technology"
                            Screening
                               Evaluation
                             "of Alternatives"
REMEDY SCREENING
   TREATABILITY
      to Determine
   Potential Feasibility
                                            REMEDY SELECTION
                                               TREATABILITY
                                             to Develop Performance
                                                 and Cost Data
              Implementation
                of Remedy
                                                                              RD/RA TREATABILITY
                                                                              to Develop Detailed Design
                                                                                and Cost Data and to
                                                                                Confirm Performance
                          Figure 2.  The role of treatability studies in the RI/FS and RD/RA process.
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  treating a contaminant/matrix combination. No cost or
  design information will be generated. The project manager
  must determine the overall qualitative data needs based on
  the intended use of the information and the availability of
  time and funds.

  During remedy screening, a single indicator contaminant is
  often monitored to determine whether a reduction in toxic-
  ity, mobility,  or volume  is occurring.  If a technology
  appears to meet or exceed the performance goal for that
  contaminant, it is considered potentially feasible and re-
  tained for further evaluation. Remedy screening is also
  useful for identifying critical parameters for investigation at
  the remedy-selection tier.

  Number of Replicates

  In most cases,  little or no test sample replication (single or
  duplicate) is required at the screening tier. A less stringent
  level of quality assurance/quality control (QA/QC) is suffi-
  cient because  a technology  that is found to be feasible
  must still undergo remedy-selection testing before it is
  selected in the ROD.

  Process Type/Waste Stream Volume

  Screening will generally involve batch tests  and the use of
  small-volume samples of the waste stream. For example,
  remedy screening of an ion exchange process designed to
  treat aqueous  wastes may require  sample volumes on the
  order of 500 milliliters per run with only three runs through
  the test column.

  Time/Cost

  The duration and cost of remedy screening depend prima-
  rily on the type of technology being investigated and the
  number of parameters considered. Generally, remedy scre-
  ening can be performed in a few days at a cost of between
  $10,000 and $50,000. This estimate of duration covers the
  time spent in  the testing laboratory; it does not include
  sample  analysis or  data  validation,  as these elements
  depend on the analytical laboratory used. Neither does it
  include the time required for study  planning and reporting.
  The cost estimate does  include  all of these  elements,
  however.

  The nature of remedy screening (i.e.,  simple equipment,
  small number of test samples and replicates, less-stringent
  QA/QC  requirements, and minimum reporting require-
  ments) makes it the least costly and time-consuming of the
  three treatability study tiers. Cost and time  savings are
  increased by limiting sampling and analysis objectives to
  address only indicator contaminants that are representative
  of  the  families   of  chemicals  present  and   their
  concentrations.
2.2.3    Remedy-Selection Testing

Remedy selection is the second step in the tiered approach.
A remedy-selection treatability study is designed to verify
whether a process option can meet the operable unit's
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 detailed analysis of
alternatives during the FS.

After the feasibility  of a treatment alternative has been
demonstrated, either through remedy-screening studies or
a literature  review,  process  operating parameters are
investigated at the remedy-selection tier.  The choice of
parameters to be studied is based on the goal of achieving
the   operable   unit's   cleanup   criteria   and   other
waste-specific   performance   goals.  Investigation  of
equipment-specific  parameters should generally be delayed
until post-ROD RD/RA studies.

Results of remedy-selection treatability studies also should
allow for estimating  the costs associated  with full-scale
implementation of the alternative within an accuracy of
+50/-30 percent, as required for the FS.

As shown in Figure 2, remedy-selection treatability studies
are initiated during the pre-ROD site characterization and
technology screening activities and continue through the
evaluation of alternatives.  General characteristics of the
remedy-selection tier (outlined in Table 1) are discussed
here.

Study Scale

Remedy-selection treatability studies are performed in the
laboratory  or  field  with  bench-,  pilot-, or full-scale
equipment.  The  scale of equipment used is  often tech-
nology  specific, and it will also depend on the availability of
funds and time and the data needs. Equipment should be
designed to simulate the basic  operations of the full-scale
treatment process. Combinations of bench and field testing
are also possible at this tier.

Type of Data Generated

Remedy-selection studies provide quantitative data for use
in determining whether a technology can meet the operable
unit's cleanup  criteria and at  what cost. The operational
and    performance    information   resulting   from
remedy-selection studies will be used to estimate full-scale
treatment costs and schedules and to assess the technology
against the RI/FS evaluation criteria.

For example,  bench-scale remedy-selection  studies  of
some technologies can provide the detailed performance
data
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  needed to assess the technology against the reduction of
  toxicity, mobility, or volume criterion. Pilot-scale testing may
  identify waste-stream characteristics that could adversely
  affect the implementability of a technology. Treatment train
  considerations, such as the need for further processing of
  treated waste or treatment residuals, can also be addressed
  at this tier.

  When planning remedy-selection treatability studies,  the
  project  manager, in  consultation with management, must
  determine  the  overall  quantitative  data needs  for  a
  technology based on the intended use of the information and
  the availability  of time and funds.  Early  consultation with
  technology  experts  and  vendors is   important  when
  determining  data needs  for innovative and  proprietary
  technologies.

  Number of Replicates

  Remedy-selection treatability studies require duplicate or
  triplicate test sample replication. Because the data generated
  at this tier will be used for remedy selection in the ROD,
  moderately to highly stringent levels of QA/QC are required.
  A stringent level  of QA/QC is needed to increase  the
  confidence in the decision that the selected remedy  can
  achieve the cleanup goals for the site.

  Process Type/Waste Stream Volume

  Remedy-selection treatability studies may be conducted as
  either a batch or a continuous process. Waste-stream sample
  volumes should be adequate to simulate full-scale operations.
  For example, the waste-stream volume needed to perform
  continuous, bench-scale testing of an ion exchange treatment
  process for an aqueous waste may be on the order of 1 liter
  per minute for a treatment duration of 8 hours (which would
  require approximately 500 liters of waste). Waste-handling
  operations, such as pretreatment blending, also should be
  designed to simulate those expected for full-scale treatment.

  Time/Cost

  The  duration and cost  of remedy-selection testing depend
  primarily on the  type of technology  being investigated, the
  types of analyses being performed, and the level of QA/QC
  required. Most bench-scale studies  can be performed within
  a period of days to weeks.  Pilot-scale testing usually requires
  a longer period (i.e., weeks to months). This estimate covers
  only the actual performance of the test. It does  not include
  sample analysis or data validation, as these elements depend
  on the analytical laboratory used; nor does it include study
  planning and  reporting.  Depending  on  its  scale  and
  complexity,  a remedy-selection
treatability study can be performed at a cost of between
$50,000 and $250,000, including analytical support.

The higher cost  and longer time requirements of remedy-
selection treatability testing compared with remedy screening
are directly related to the need for stringent QA/QC and the
greater number of test samples and replicates to be analyzed.

2.2.4    RD/RA Testing

Treatability testing to support RD/RA activities is the final
step in the three-tiered approach. The purpose of an RD/ RA
treatability study is to generate the detailed design, cost, and
performance data necessary to optimize and implement the
selected remedy. As shown in Figure 2, RD/RA treatability
studies are conducted after the ROD has been signed. These
studies are performed 1) to select among multiple vendors
and processes within a prescribed remedy (pre-qualification),
2) to implement the most  appropriate of the remedies
prescribed in a Contingency ROD, and 3) to support the
Agency's detailed design specifications (if prepared) and the
design of treatment trains. Most RD/RA treatability studies
are performed by remediation contractors and technology
vendors. The EPA RPM monitors the performance of these
studies and reviews the results to assess their acceptability
with regard to the ROD, RA goals, and, if applicable, the
settlement agreement. General characteristics of the RD/RA
tier (outlined in Table 1) are discussed here.

Study Scale

Most RD/RA treatability studies are performed in the field
with pilot- or  full-scale equipment.  Some prequalification
treatability  studies will  be  performed  in the laboratory;
however,  the system should  closely  approximate  the
proposed full-scale operations.

Type of Data Generated

Remedial design/remedial action treatability studies provide
the detailed, quantitative  design  and cost data required to
optimize critical  parameters  and to implement the selected
remedy. The following are issues that may be addressed with
RD/RA study data:

     •  Full-scale performance

     •  Treatment train performance

     •  Materials-handling characteristics

     •  Process upset and recovery
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      •  Side-stream and residuals generation and
         treatment

      •  Energy and reagent usage

      •  Site-specific considerations, such as heavy
         equipment access and waste-feed staging space

      •  Field-screening analytical methods

  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  eqnipment-specific  parameters.  Remedial  design/
  remedial action testing also may identify waste-stream char-
  acteristics that could adversely affect the implementability of
  the full-scale system.

  When planning RD/RA treatability studies, the technology
  vendor, in consultation with the designer and the lead agency,
  must determine the overall  quantitative  data needs for a
  technology based on the intended use of the information.
  Early  consultation with  vendors  is  important  in  the
  determination  of data needs for proprietary technologies.

  Number of Replicates

  Remedial design/remedial action treatability studies usually
  require duplicate or triplicate test sample replication. The
  data generated at this tier are used to design and optimize the
  process; therefore, stringent levels of QA/QC are required.

  In the  case of prequalification treatability studies,  QA/QC
  requirements will be determined by the designer. The number
  and types of samples to be  submitted by vendors will be
  outlined in the designer's prequalification announcement.

  Process  Type/Waste-Stream Volume

  Remedial design/remedial action treatability studies may be
  conducted as  either  a batch or a continuous process,
  depending on the operation of the full-scale system. Waste-
  stream sample throughput and volume should achieve levels
  projected for full-scale operations.  For  example, the
  waste-stream sample volume needed to perform continuous,
  full-scale testing of an ion exchange treatment process for an
  aqueous  waste may be on the order  of 25 liters per minute
  for a treatment duration of 16 hours per day for 21 days
  (which would  require more than 500,000 liters of waste).

  Time/Cost

  Because of the potentially significant mobilization require-
  ments  associated with  any  onsite  operation,  performing
  RD/RA treatability studies is  significantly more time-con-
suming and costly than pre-ROD studies. The duration
and cost depend primarily on the type of technology
being  investigated,  the  types of analyses  being
performed, and the level  of QA/QC required. Most
RD/RA studies can be performed within a period of
weeks to months. This estimate covers only the actual
performance  of the test. It does not include the time
required for mobilization, construction,  shakedown, or
demobilization of the unit,  as  these procedures are
specific  to the site and to the technology being tested;
sample analysis or data validation,  as these elements
depend  on the analytical laboratory used;  or study
planning and reporting. Most RD/RA treatability studies
can be performed at a cost of between $250,000 and
$1,000,000.

Prequalification treatability  testing is an exception to
these time and cost estimates because the tests are
performed  at  the vendors'  cost. Analytical  support,
however, is usually provided by the Agency.

2.3      Applying the Tiered Approach

The purpose of a pre-ROD treatability investigation is to
generate data needed for a detailed analysis of the
alternatives and, ultimately, the selection of a remedial
action that can achieve the  operable  unit's  cleanup
criteria.  Pre-ROD treatability studies are performed to
enable the decision maker to evaluate all treatment and
nontreatment alternatives on an equal basis.

The need for pre-ROD treatability testing at a Superfund
site is a risk-management decision in which the cost and
time required to conduct treatability studies are weighed
against the risks inherent in the selection of a remedial
technology. Factors in this decision are specific to the
waste matrix, waste contaminants, and treatment technol-
ogy.  Determining whether pre-ROD treatability studies
should  be  conducted  may  also  depend  on  such
nontechnical factors as State and community acceptance
of an alternative; time constraints on the completion of
the RI/FS and the ROD; and  the discovery of new
operable unit-, waste-, or technology-based data that
may  have an impact on treatment performance.

Of the  management decision factors listed,  schedule
constraints  may  be  of the  most consequence. The
performance of pre-ROD treatability studies that were
planned and scheduled early (i.e., during the scoping of
the RI/FS) generally should not delay the ROD. In some
instances, however, the need for treatability studies may
conflict with RI/FS and ROD schedule commitments.
For  example,  if  an innovative technology  is  being
considered as part of an alterna-
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                                                       12

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  tive, significant gaps in the technical literature may lengthen
  the time required to plan and perform a thorough treatability
  investigation. When the potential benefits of the innovative
  technology are known, pursuing the treatability study at the
  expense of ROD scheduling goals may be appropriate. The
  EPA's  Guidance for Increasing  the Application  of
  Innovative Treatment Technologies for Contaminated Soil
  and Ground Water (EPA 1991a) and its cover memoran-
  dum indicate the Agency's willingness to  adjust program
  goals and commitments, when appropriate, to achieve better
  cleanup solutions through innovative treatment technology
  development.

  The flow diagram in Figure 3 traces  the stepwise  data
  reviews and management decisions that occur in the tiered
  approach.   Site  characterization   and  technology
  prescreening/treatability study scoping initiate the process.
  Technologies that are determined to be potentially applicable
  (based  on effectiveness,  implementability, and cost) are
  retained as  alternatives; all others are screened out.  The
  decision to conduct a treatability study on an alternative is
  based on the availability of technology-specific treatability
  information and on inputs from management. If a treatment
  technology  is   well   demonstrated  for  the  particular
  contaminants/matrix  and  sufficient information exists  to
  permit its evaluation against the nine evaluation criteria in the
  detailed  analysis of alternatives, a pre-ROD  treatability
  study is not required.

  If significant questions remain about the  feasibility  of a
  technology  for remediating an operable unit, a remedy-
  screening treatability study should be performed. Innovative
  technologies or wastes that have  not been  extensively
  investigated should almost always be subjected to treatability
  testing at this tier. If a technology has been shown to be
  effective at treating the contaminants/matrix of concern but
  insufficient  information  exists for detailed analysis,  the
  remedy-screening  tier  may  be bypassed  in favor of a
  remedy-selection treatability  study. If a remedy-selection
  study indicates that a technology can meet the cleanup
  criteria, a detailed analysis of this alternative should then be
  performed. If the alternative is selected in the ROD, a post-
  ROD RD/RA treatability  study may be required to  design
  and optimize the full-scale system, to obtain detailed cost
  data, and to confirm performance.


  2.4      Treatability Study Test Objectives

  Each tier of treatability testing is defined by its particular
  purpose: remedy screening, to determine potential feasibility;
  remedy selection, to develop performance and cost data; and
  RD/RA, to develop detailed design and cost data and to
  confirm full-scale performance. For achievement of these
  purposes, the planning and design of treatability studies must
  reflect specific, predetermined test objectives. Depending on
  the tier of testing, test objectives may call  for making
qualitative engineering assessments, achieving quanti-
tative performance goals, or both. Because test object-
ives are technology-, matrix-, and contaminant-specific,
setting universal objectives for each tier of testing is
impossible.

Qualitative assessments of  performance are  often
appropriate at the remedy-screening tier. Simply
demonstrating a reduction in contaminant concentration,
for example, may be sufficient to confirm the potential
feasibility  of using an  innovative treatment technology.
For other technologies, a quantitative performance goal
such as 50 percent reduction in contaminant mobility
might indicate the potential to achieve greater reduction
through process  refinements  and thus  confirm the
feasibility of a process  option and justify  additional
testing at the remedy-selection tier.

Test objectives at the remedy-selection tier will include
achieving  quantitative performance goals based on the
anticipated cleanup criteria to be established in the
ROD.  For example,  if the  cleanup  criterion for a
contaminant in the soil  at a site is  1 ppm, the per-
formance goal for a remedy-selection treatability  study
might also be  1 ppm.  If no cleanup criteria have been
established for the site, a 90 percent  reduction in the
contaminant concentrations will generally be an appro-
priate performance goal. This level of performance is in
agreement with EPA's guideline established in the 1990
revised NCP, which states that ". . .  treatment as part
of CERCLA remedies  should generally achieve re-
ductions of 90 to  99  percent in the  concentration  or
mobility of individual contaminants of concern, although
there will be situations where reductions outside the 90
to 99 percent range that achieve health-based or other
site- specific remediation goals (corresponding to greater
or lesser reductions) will be appropriate" (55 FR 8721).
Additional guidelines  upon which a project  manager
should base remedy-selection performance goals are as
follows:

    •  Protection   of  human  health   and  the
      environment

    •   Compliance With ARARs

    •  Attainment of contaminant levels acceptable
       for waste delisting

    •  Attainment of contaminant levels accepted by
      the State or Region at other sites with similar
       waste characteristics

Remedy-selection treatability studies will generally have
additional pre-ROD test  objectives designed to provide
the specific cost and engineering information necessary
for a detailed analysis of the alternative. Cost data should
be
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 !
SITE
CHWVMDTEHZAJION



TECHNOUKYWIGSCREENNa
TREHMBJTY STl»Y SCOPNG
 f
 I
 a
I
                                                                                                                        MANAGEMENT DECISION FACTORS:

                                                                                                                         • Slate and Comrrajnity Acceptance
                                                                                                                         • Schedule Consfraints
                                                                                                                         • Additional Data
                                                         REMEDY-SCREENING
                                                            TREAIAB1ITY
                                                              STUDIES
                                                                                   REMEDY-SELECTION
                                                                                      TREATABILITY
                                                                                        STUDIES
                                                                                                                                           RD/RA
                                                                                                                                        TREATABILITY
                                                                                                                                          STUDIES
                                                                  Figure 3.  Flow diagram of the tiered approach.

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  sufficiently detailed to allow for the development of cost
  estimates with an accuracy of+50 to -30 percent.

  Post-ROD test objectives  depend on the nature of the
  treatability  study. If a study  is conducted to prequalify
  vendors, performance goals  will  be equivalent to the
  cleanup criteria defined in  the ROD. Treatability studies
  conducted to select the most appropriate technology among
  those in a Contingency ROD  will also have performance
  goals equivalent to the cleanup criteria. Additional test
  objectives may include investigation of materials-handling
  methods,   confirmation  of  field-screening  analytical
  techniques, and generation of detailed cost data. If an
  RD/RA treatability study is  required to support the detailed
  design specifications,  the designer will be responsible for
  defining the test objectives and performance goals. Test
  objectives will be focused on obtaining specific design data,
  optimizing performance, and minimizing cost. Treatment
  train issues such as unit sizing, materials handling, and
  systems integration can also be addressed through specific
  test objectives. A treatability  study of an entire train can
  provide data to confirm compliance with ARARs and the
  cleanup criteria outlined in the ROD.
  2.5      Special Issues

  2.5.1    Innovative Treatment   Technologies

  One  of the advantages of treatability testing is that it
  permits the collection of performance data on innovative
  treatment  technologies.   These   newly   developed
  technologies often lack sufficient full-scale application to
  be routinely considered for site remediation. Nevertheless,
  Guidance for Increasing the Application of Innovative
  Treatment Technologies for Contaminated Soil and
  Ground Water (EPA 199la) states:
      "Innovative treatment  technologies  are  to be
      routinely considered as an option  in feasibility
      studies   for  remedial  sites   and   engineering
      evaluations for removals in the Superfund program,
      where treatment is appropriate commensurate with
      the   National   Contingency  Plan  (NCP)
      expectations.... Innovative technologies considered
      in the remedy  selection process for Superfund,
      RCRA, and UST should not be eliminated solely on
      the  grounds  that  an  absence  of  full-scale
      experience or treatability study data makes  their
      operational performance and cost less certain than
      other forms of remediation.

      "When assessing  innovative technologies,  it is
      important to fully account for their benefits.
   Despite the fact that their costs may be greater
   than conventional options, innovative technologies
   may  be  found  to   be  cost-effective,  after
   accounting   for   such  factors   as   increased
   protection, superior performance, and greater
   community acceptance. In addition, experience
   gained from the application of these solutions will
   help realize their potential benefits at other sites
   with similar contaminants."

Example 1 illustrates how treatability studies can be used to
investigate innovative  and   conventional  technologies
concurrently  on a single waste stream. Three innovative
treatment  technologies-thermal  desorption,  solvent
extraction, and bioremediation-are investigated at various
tiers. Decisions on testing are based on existing data in the
literature  and  on   prior   treatability   study   results.
Solidification/stabilization,  a conventional  option, is  also
tested because its performance for the particular waste
stream was not established in the literature. This  example
reflects how treatability studies can be designed and tailored
by the project manager  to  provide specific pieces  of
information required for remedy selection.

2.5.2    Treatment Trains

Treatment of a waste stream often results in residuals that
require further treatment to reduce toxicity, mobility,  or
volume.  Treatment  technologies   operated  in  series
(treatment trains)  can be used  to  provide  complete
treatment of a waste stream and any resulting residuals.

Treatment-train requirements for a waste  stream may be
evaluated by applying the tiered approach.  Example 2
outlines a remedy-selection treatability study of a treatment
train consisting of low-temperature volatilization followed by
chemical treatment and solidification. The literature contains
enough data  concerning the individual unit operations  to
indicate  that  they are appropriate technologies for the
specific  contaminants. Treatability testing of these  unit
operations as a treatment  train, however,  is necessary  to
evaluate the most  effective  combination of operating
parameters for treating the matrix.

2.5.3    In  Situ Treatment Technologies

Testing of in situ treatment technologies during the RI/FS
may entail remedy screening, bench-scale remedy-selection
testing, and pilot-scale remedy-selection testing in the field.
Remedy screening  of in  situ treatment technologies  is
conducted in  the laboratory to determine process feasibility.
Bench-scale  testing is generally conducted in soil columns
designed to   simulate the  subsurface  environment. Field
testing, however, is important for an adequate evalua-
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                EXAMPLE 1. TREATABILITY STUDIES OF MULTIPLE TECHNOLOGIES
                                     Old Petroleum Refinery Site

   Background

   An old petroleum refinery site contained oily sludges and contaminated soils. The primary contaminants
   of concern were polynuclear aromatic hydrocarbons (PAHs), mainly benzo(a)pyrene. The literature
   survey identified five potentially applicable technologies for treating the hydrocarbon wastes: 1)
   incineration, 2) stabilization/solidification, 3) thermal desorption, 4) solvent extraction, and 5)
   bioremediation.

   The literature survey also produced a significant amount of performance data for incineration and
   bioremediation. Because these data indicated that both technologies were valid for the types of wastes
   and contaminants of concern at the site, neither incineration nor bioremediation was evaluated at the
   remedy-screening tier.

   Conversely, little data were found on thermal desorption, and the available performance data for solvent
   extraction and  stabilization/solidification were inconclusive for hydrocarbon wastes. Therefore, these
   three technologies were evaluated at the remedy-screening tier to determine their feasibility for treatment
   of the site's wastes.

   Remedy Screening

   Samples of worst-case soils and sludges (most highly contaminated with PAHs) were collected for
   treatability studies of each technology. A performance goal of 90 percent reduction in the indicator
   contaminant benzo(a)pyrene was set.

   Thermal desorption was evaluated at three temperatures. Solvent extraction was evaluated by using
   three solvents at two solution concentrations. Stabilization/solidification was evaluated by using
   organophilic clays at three mix ratios with 28-day curing. Benzo(a)pyrene concentration in duplicate
   samples of the untreated soil was determined by total waste analysis (EPA SW-846 Method 8270).
   Duplicate samples of the treated material from thermal desorption, solvent extraction, and
   stabilization/solidification (after sonication of the solidified monolith) were then analyzed for
   benzo(a)pyrene by the same method.

   The results of the remedy screening showed that, of the three technologies, thermal desorption achieved
   the highest percentage removal of the indicator contaminant (greater than 95 percent). Solvent extraction
   showed a 90 percent removal efficiency. Stabilization/solidification, however, fixed only 50 percent of the
   contaminant. Thermal desorption and solvent extraction were thus retained for further analysis because
   both technologies achieved the screening performance goal.

   Remedy-Selection Testing

   Quantitative performance, implementability, and cost issues still remained unanswered after the remedy
   screening. Also, information from the literature on biodegradation rates and mechanisms for
   benzo(a)pyrene (the principal PAH of concern) was inconclusive.  In addition, the anticipated cleanup
   criterion for benzo(a)pyrene in soils was very low (250 ppb). Therefore, thermal desorption, solvent
   extraction, and bioremediation were examined in bench-scale, remedy-selection testing. Performance
   goals were set at 250 ppb benzo(a)pyrene with a 95 percent data confidence level. Waste samples
   representing average and worst-case scenarios were tested, triplicate test samples were collected and
   analyzed, and several process variables were evaluated. After 6 months of testing, only low-temperature
   thermal treatment was found to meet the low cleanup levels required for benzo(a)pyrene.

   Although thermal desorption was found to meet the cleanup requirements in bench-scale testing, this
   technology had not been previously demonstrated at full scale for similar contaminants and waste.
   Therefore, cost and design issues had to  be addressed as part of the detailed analysis of alternatives.
   The RPM decided to conduct pilot-scale testing on thermal desorption and to compare the  costs of
   constructing and operating the unit with those for incineration.
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                  EXAMPLE 2. TREATABILITY STUDIES FOR TREATMENT TRAINS
                              Former Chemical Manufacturing Company
   Background
   At a former chemical manufacturing company and current Superfund site, the contaminants of concern
   in the soils were dichloromethane, tetrachloroethene, benzene, polynuclear aromatic hydrocarbons
   (PAHs), cyanide, and arsenic. The cleanup criterion for each of these compounds had been identified.
   Both onsite treatment and offsite incineration were being considered as options for site remediation.

   Remedy-Selection Testing

   Remedy-selection testing of a treatment train to treat the contaminated soils on site was designed to
   include the following unit operations: 1) thermal desorption, 2) chemical treatment, and 3)
   stabilization/solidification. A schematic of the treatment train is presented below.

                                         CONTAMINANTS OF CONCERN
                                                                 ARSENIC
                                                              STABILIZATION/
                                                              SOLIDIFICATION
                         Schematic Representation of the Treatment Train

   Bench-scale treatability testing of the treatment train was designed to meet the following three objectives:

       •   Objective 1 - Provide performance confirmation of the operation of the thermal desorption unit for
           removal of volatile and semivolatile organics. Determine the minimum operating conditions
           (temperature, residence time) necessary to achieve the site cleanup criteria. Determine the
           need for subsequent treatment units (chemical treatment, solidification).

       •   Objective 2 - Provide performance confirmation of the operation of the chemical treatment unit
           for destruction of cyanide. Determine the preferred reagent and dosage necessary to achieve
           the site cleanup criteria.

       •   Objective 3 - Provide performance confirmation of the operation of the stabilization/solidification
           unit for immobilization of arsenic. Determine the preferred binder and dosage necessary to
           achieve the site cleanup criteria.

   Prior to initiating any treatability tests, the test plan called for the soil to be characterized for the following
   physical and chemical parameters:

           Moisture content
           Soil bulk density
           Grain size distribution
           Volatile and semivolatile organics
           Cyanide
           Arsenic (total and TCLP)

   The remedy-selection testing consisted of the following three subtasks:

       1)  Perform bench-scale tests of thermal desorption at two temperatures (300 and 550°C) and
           three residence times (5, 15, and 30 minutes) to determine the efficacy of the unit for removal of
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  Example 2 (continued)
            organics. Analyze the treated soil for the pollutants of concern (organics, cyanide, and arsenic).
            If cyanide is present in the soil residue at concentrations exceeding the cleanup criterion,
            continue with Subtask 2. Similarly, if arsenic is present, continue with Subtask 3. (This subtask
            addresses Objective 1.)
       2)   Perform bench-scale tests on the soil residue from the thermal desorption unit to investigate the
            effectiveness of hydrogen peroxide and hypochlorite for treatment of cyanide as a function of
            pH, the strength of solution,  and the reagent-to-soil ratio. Analyze the treated soil for cyanide.
            (This subtask addresses Objective 2.)
       3)   Perform bench-scale tests of stabilization/solidification to immobilize arsenic in the soil residue
            from chemical treatment (if cyanide was present) or thermal desorption (if cyanide was not
            present) using three binders (portland cement, lime/fly  ash, and fly ash/kiln dust) at two
            binder-to-soil ratios (0.20 and 0.50). Determine the unconfined compressive strength of the
            solid monolith. Extract the crushed solid in accordance with the toxicity characteristic leaching
            procedure and analyze the leachate for arsenic.  (This subtask addresses Objective 3.)
       Data from the remedy-selection treatability tests were  used 1) to determine if the proposed treatment
       train could achieve the  test objective of reducing all contaminant concentrations to the site cleanup
       criteria, and 2) to provide a preliminary basis for estimating the costs of full-scale remediation.
  tion of in situ treatment. Because of the unique difficulties
  associated with simulating in situ conditions and monitoring
  the effectiveness of in situ treatment in the laboratory, field
  testing often may be the only way to obtain the critical
  information needed for the detailed analysis of alternatives
  during the FS. Example 3  demonstrates how the tiered
  approach may be applied to evaluate in situ soil flushing.

  2.5.4   Generic Vs. Vendor Treatability
           Studies

  When planning a treatability study,  the project manager
  must determine whether results from treatability tests in
  which widely available chemicals and processes are used
  ("generic" studies) will be as useful as vendor-conducted
  tests involving the use of proprietary chemical reagents and
  treatment systems ("vendor" studies).

  Because generic treatability studies eliminate the need for
  establishing contracts and schedules with a specific vendor,
  they can often be performed quickly and inexpensively;
  however,  they may not always provide an  adequate
  evaluation  of  a  technology.  For example, a generic
  treatability study  may fail to meet site cleanup goals  that
  could have been  achieved by an experienced technology
  vendor  using proprietary  processes and  equipment
  developed through years of research.

  Generally, remedy-screening treatability studies can be
  performed generically  because quantitative performance
  data  are not  required.  Vendor-specific equipment or
  experience  are   often  required,  however,   at  the
  remedy-selection tier  to   assure  the  generation   of
high-quality quantitative data and the best performance of
the technology. Remedial design/remedial action treatability
studies should generally be performed in consultation with
technology vendors. Tables  2 and 3 were adapted from
tables developed by personnel at the U.S.  EPA's  Risk
Reduction Engineering Laboratory (RREL) to  provide
general technology-specific  guidance  on  this  issue
(dePercin, Bates, and Smith 1991). Information  in these
tables should not be used without consideration being given
to site-specific contaminant and matrix treatability data.

Under 48 CFR Section 1536.209 of the Federal Acquisition
Regulations, subcontractors performing treatability studies
in support of remedy selection or remedy design are not
prohibited from  being  awarded  a  contract  on  the
construction of the remedy  (55  FR 49283). For prime
contractors   performing  treatability  studies, however,
approval by the Responsible Associate  Director in the
EPA Procurement  and Contracts Management Division
may be necessary  before  they can be awarded  the
construction contract. In reviewing requests for approval,
EPA will take into account its policy of promoting the use
of innovative technologies in the Superfund program.

2.5.5   PRP-led Pre-ROD Treatability
         Studies

Pre-ROD treatability  studies  may  be conducted by
potentially responsible parties with  EPA oversight to
evaluate PRP-proposed alternatives at enforcement-led
sites.  The steps  involved in a PRP-led Study  include
performing a
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           EXAMPLE 3. TREATABILITY STUDIES FOR IN SITU TREATMENT TECHNOLOGIES
                                               In Situ Soil Flushing

    Background

    An estimated 80,000 cubic meters of soil contaminated with chlorinated phenols, semivolatile organics,
    sulfur-containing compounds, and lead at an industrial facility requires corrective action. In situ soil flushing has been
    proposed as an alternative treatment technology. A two-tiered treatability study has been designed to evaluate its
    effectiveness.

    Remedy Screening

    Remedy screening will be performed to evaluate the effectiveness of various flushing reagents for enhancing the
    removal of the contaminants. A performance objective of 90 percent or greater reduction was set for evaluation of
    flushing reagent feasibility. Any reagent that achieves this level of contaminant reduction for each target contaminant
    will be evaluated at the remedy-selection tier. All others will be screened out. (Analyses of all samples for all
    site-specific contaminants will not be economically feasible; therefore, target compounds,  each representative of a
    class of compounds present at the site, will be identified.)

    The following general testing procedure will be used:
      1)  Analyze untreated soil samples for target compounds.
      2)  Place a known mass of soil in a small glass bottle. Add  a measured volume of flushing reagent. Shake for a
         set period of hours. Centrifuge the mixture.
      3)  Analyze the supernatant liquid phase for target contaminants.
      4)  Analyze the treated soil phase for target contaminants.

    Remedy-Selection Testing

    Bench Scale

    All flushing reagents identified as feasible during the remedy-screening treatability study will be evaluated in a
    bench-scale column test. The performance objective of this tier is to achieve contaminant  reduction levels equal to
    the anticipated site  cleanup criteria.
    The following general testing procedure will be used:
      1)  Analyze untreated soil samples for target compounds.
      2)  Pack a large  glass column with untreated soil to approximate the actual density of soil in the contaminated
         area.  Introduce the soil-flushing solution into the top  of the column.
      3)  Collect the column leachate at regular intervals (e.g., daily) and analyze for target contaminants.
      4)  Terminate the column test when the  contaminant concentrations in the leachate remain the same for three
         consecutive leaching periods.  Remove representative samples of the treated soil from the glass column and
         analyze them for target contaminants.

    All flushing reagents that reduce the target contaminant concentrations in the soil to the site cleanup levels will be
    evaluated in the field.

    Pilot Scale
    The twofold purpose of this field pilot-scale treatability study is to evaluate the hydraulics of the treatment process
    under site conditions and to verify reagent performance under site conditions. The field test will yield site-specific
    flow, injection, and capture rates for the flushing system. These rates must be established to quantify the total time
    necessary for site-wide treatment and to estimate full-scale treatment costs. These and other data will be used in the
    detailed analysis of alternatives.

    The field treatability study will involve the following tasks:
      1)  Prepare a treatment cell. Install an interception trench.
      2)  Install the irrigation and soil-flushing  system.
      3)  Collect the cell leachate at regular intervals and analyze for all contaminants of interest.
      4)  Terminate the field test when the target contaminant concentrations in the leachate  remain the same for three
         consecutive leaching periods.  Remove representative samples of the treated soil from the cell and analyze
         them for all contaminants of interest.
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  Table 2.  Aqueous Field Treatability Studies:
             Generic Versus Vendor Processes3
      prepared by the PRP that identifies  candidate
      treatment technologies and describes the literature
      search.
Remedy Remedy
Treatment technology screening selection RD/RA
Physical
Oil/water separation NA G G
Sedimentation NA G G
Filtration NA G G
Solvent extraction G G/V G/V
Distillation G G G/V
Air/steam stripping G G G/V
Carbon adsorption G G G
Ion exchange G G G/V
Reverse osmosis G G/V V
Ultra filtration G V V
Chemical
Neutralization NA G G
Precipitation G G G
Oxidation G G G
Reduction G G G
Dehalogenation G G/V V
Thermal
Incineration G G/V V
Biological
Suspended growth
systems
Aerobic G G G
Anaerobic G G G/V
Fixed growth systems
Aerobic G G/V G/V
Anaerobic G G/V G/V
Constructed wetlands G G G
Pact G G/V V
In situ biological NA G V
aG = Generic studies appropriate.
V = Vendor studies appropriate.
G/V = Generic and vendor studies appropriate.
NA = Not applicable at this tier.
literature search, submitting the Technical Memorandum
identifying candidate technologies, designing the study,
preparing the Project Plans (Work Plan, Sampling and
Analysis Plan, and Health and Safety Plan), performing the
test, analyzing the data, and preparing a final report on the
results.
During the study, the EPA project manager will provide
oversight and assistance. The EPA's Guidance on
Oversight of Potentially Responsible Party Remedial
Investigations and Feasibility Studies (EPA 1991b)
recommends that the EPA project manager and the
oversight assistant perform the following activities to
oversee PRPs:
• Meet with the oversight assistant, the Technical
Support Team (TST), and representatives from
ORD to review the list of candidate technologies.
Innovative treatment technologies should be
adequately represented. Decisions on the need for
treatability studies should be made for each
technology.
• Review and approve the PRP's schedule of
treatability activities.
Table 3. Soils/Sludges Field Treatability
Studies: Generic Versus Vendor Processes3
Remedy Remedy
Treatment technology screening selection RD/RA
Physical
Oil/water separation G G V
Sedimentation G G V
Filtration G G V
Solvent extraction G/V V V
Soil washing G G/V V
Vacuum extraction G V V
Distillation G G V
Air/steam stripping G G/V V
Thermal stripping G V V
Carbon adsorption G G/V V
Ion exchange G/V V V
Chemical
Neutralization G G V
Precipitation G G/V V
UV photolysis G V V
Ozonation G G/V V
Oxidation G V V
Reduction G V V
Dehalogenation G/V V V
Thermal
Incineration G G/V G/V
Biological
In situ treatment G G V
Composting G/V G/V G/V
Stabilization
Pozzolanic for inorganics G G/V V
Pozzolanic for organics V V V
Asphalt G V V
Polymerization V V V
Vitrification G/V V V
Material handling
Screening NA G G/V
Conveying NA G G/V
          documents  and  sources   of other  technical
          information (Appendix A presents sources of
          treatability information).

          Review and approve the Technical Memorandum
aG = Generic studies appropriate.
 V = Vendor studies appropriate.
G/V = Generic and vendor studies appropriate.
NA = Not applicable at this tier.
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          Revise and amend the original PRP Project Plans
          to  address  the  treatability  study work to be
          performed.

     •    Verify the qualifications of all personnel involved
          in  the test,  including  the  PRP, the  PRP's
          contractor,  and  the  analytical  laboratory.  In
          addition, the EPA project manager should verify
          that the PRP laboratory protocols conform to EPA
          standards.

     •    Verify the test objectives and performance goals
          of each study.

     •    Conduct a site visit during the initial stages of a
          study.

     •    Collect and analyze split samples before and after
          treatment.

     •    Review and validate the data generated  by each
          study.

     •    Monitor compliance with ARARs.

     •    Review and approve the draft PRP Treatability
          Study Evaluation Report with input and comments
          from the TST, ORD, other support staff, and the
          State. (The report should be  prepared in  the
          standard format presented in Subsection 3.12.)

     •    Continually update the Administrative Record File
          and cost recovery documentation.

  Conduct of PRP-led treatability  studies  will be based on
  the language  of the Administrative  Order on Consent
  (AOC)  and the Statement of Work (SOW). The model
  Administrative  Order   on  Consent for   Remedial
  Investigation/Feasibility Study (EPA 1991c) contains
  standard language for
requiring PRPs to conduct Treatability studies. TheModel
Statement of Work for a Remedial Investigation and
Feasibility Study Conducted by Potentially Responsible
Parties (EPA 1989c)  provides  standard  language  for
requiring  PRPs   to  perform  treatability  studies   in
accordance with the RI/FS guidance. (Note: The Model
SOW  does  not  yet incorporate  the  treatability  study
terminology and guidance presented in this document. Until
the Model SOW is updated, every effort should be made
to  require  PRPs  to  conduct treatability  studies  in
accordance with this guidance.)

2.5.6    Treatability Study Funding

The planning process for treatability  studies should begin
during  the budget cycle in the year  prior to the planned
performance.  The potential  need  for and scope  of
treatability studies  should  be identified and their costs
estimated to ensure that  adequate resources will be
available. This information will be  used to prepare the
Region's Superfund  Comprehensive Accomplishments
Plan (SCAP).

Federally funded treatability studies performed in support
of the RI/FS or the RD/RA are funded as a line item in the
Region's "Other Remedial Account." Should treatability
study funding requirements exceed  planned allocations
(because of the cost of the studies or the need for studies
that were not planned for in the SCAP), the SCAP should
be updated to reflect the necessary additional funding.

Funding for treatability studies is currently  separate from
RI/FS funding and is not included in the RI/FS target cost
of $750,000. The Agency is considering a revision of this
procedure based on the need to fund direct site work
through a Site-Specific Allowance.  This  will facilitate
efficient tracking of direct site costs.
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                                            SECTION 3
      PROTOCOL  FOR CONDUCTING  TREATABILITY STUDIES
  3.1  Introduction

  Treatability studies should be performed in a systematic
  fashion to ensure that the data  generated can support
  remedy  selection  and  implementation.  This  section
  describes a general protocol  for conducting treatability
  studies that EPA project managers, PRPs, and contractors
  should follow. The protocol includes:

     • 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 study

     • Analyzing and interpreting the data

     • Reporting the results

  These elements are described in  detail in the remaining
  subsections.   General  information  applicable  to  all
  treatability  studies  is   presented  first,  followed  by
  information specific to remedy screening, remedy-selection
  testing, and RD/RA testing.

  Pre-ROD treatability studies for a particular site will often
  entail multiple tiers of testing, as described  earlier in
  Subsection 2.3. Duplication of effort can be avoided by
  recognizing this possibility in the early planning stages of
  the
project.  The Work Assignment, Work Plan, and other
supporting documents should include all expected activities.
Generally, a single contractor should be retained to ensure
continuity of the project as  it moves  from one tier to
another.

3.2   Establishing Data Quality
      Objectives

Data  quality  objectives  (DQOs)  are qualitative  and
quantitative statements that specify the quality of the data
required to support decisions concerning remedy selection
and implementation. The end use of the treatability study
data to be collected will determine the appropriate DQOs.
At all tiers of treatability testing, the establishment of
DQOs will help to ensure that the data collected are of
sufficient quality to substantiate the decision. Established
DQOs are incorporated into the Work Plan, the study
design, and the  Sampling and Analysis  Plan  (SAP).
Because treatability  testing  is used to help select  and
implement a site remedy, establishing DQOs is a critical
initial step in the planning of treatability  studies.

The quality and quantity of treatability data required for a
study  should  correspond  to  the   significance   and
ramifications of the decisions that will be based on these
data.  Limited  QA/QC  is   generally  required  for
remedy-screening data used to decide whether a treatment
process  is  potentially  feasible and  warrants  further
consideration.  More rigorous  QA/QC is  required  for
RD/RA testing when quantitative performance, design, and
cost data will be used in the implementation of the selected
remedy.

3.2.1 General

The guidance document  Data  Quality Objectives  for
Remedial Response Activities (EPA 1987a) defines the
frame-
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  work and process by which DQOs are developed. This
  document (hereinafter referred to as the DQO guidance)
  focuses on site investigations during the RI/FS; however,
  the same framework and process may be applied to DQO
  development for treatability studies. The DQO guidance
  describes  a process that includes the following three
  stages:  1) identification  of decision  types  and study
  objectives, 2) identification of data uses/needs,  and 3)
  design of the data-collection program. The three stages of
  DQO development summarized in Table 4 can be applied
  to each  of the three tiers of testing. The stages provide a
  systematic process for development of the  DQOs  for
  treatability studies.

  Stage 1

  The type and magnitude of the  decisions to be made are
  determined in Stage 1. Tasks include identifying the data
  users  and coordinating their efforts for the establishment of
  the  DQOs,  evaluating  existing  data,  developing   a
  conceptual  model, and specifying  the test objectives
  (including performance goals) of the treatability study.
  Stage 1 efforts should result in the specification of the
  decision-making process and the identification of any new
  data needed and why.  Stage  1 of the DQO process
  corresponds to technology prescreening and treatability
  study seeping as described in Subsection 2.2.1.

  The data users will be those who rely on treatability results
  to support their decisions. They may include the RPM, the
  OSC, the PRP  project manager, technical specialists, the
  State, enforcement  personnel,  U.S.  Army Corps of
  Engineers, and others. Project review and audit personnel
  should
be involved to help ensure the integrity of the QA program
and compliance with program policy.

Stage 1 also includes a detailed evaluation of available
information.   Useful  information  may  include  site
characterization data, technology-specific information, and
previous treatability study data. Several factors should be
considered in an evaluation of the quality of these data and
their  relevance to the  DQO  establishment  process,
including the age of the data, the analytical methods used,
the detection limits of those methods, and the QA/QC
procedures applied.

A conceptual model of the site and site conditions should
be developed and included in Stage 1.  A  model may
already have been developed for the site; if so, it should be
adopted for use in the treatability study DQO development
process.

Test objectives  for the treatability study are determined in
Stage 1. Identifying these objectives also entails identifying
the problems to be solved (i.e., whether the study is needed
to determine the potential feasibility of the technology or to
confirm the attainment of a treatment  standard). Test
objectives will include achieving quantitative performance
goals and collecting data to support qualitative engineering
assessments and cost estimates.

Stage 2

During  Stage  2, the data  required to  meet  the test
objectives specified in Stage 1 are determined, and the
criteria for
                     Table 4. Summary of Three-Stage DQO Development Process

                                                   Stage 1
              Identify data users.
              Consult appropriate data bases for relevant information.
              Develop a conceptual model of the site.
              Identify the treatability study test objectives and performance goals.

                                                   Stage 2

              Identify data uses.
              Identify data types.
              Identify data quality needs.
              Identify data quantity needs.
              Evaluate sampling and  analysis options.
              Review precision, accuracy, representativeness, completeness, and comparability parameters.

                                                   Stage 3

              Determine DQOs; select methods for obtaining data of acceptable quality and quantity.
              Incorporate DQOs into the Work Plan and the SAP.
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  determining data adequacy are stipulated. Data must be of
  sufficient quality to determine whether the test objectives
  have been met.

  Data  types  are identified by broad  categories such as
  environmental  media  samples  or  source  samples.
  Specifying  data  type by medium  helps  to identify
  overlapping data needs and analytical efforts.

  Data  quality and quantity are defined  in  Stage 2. The
  EPA's Quality Assurance Procedures for RREL (EPA
  1989d) establish four quality assurance categories for use
  in research and development projects. Categories IV, III,
  and II are applicable to treatability studies. In general, QA
  Category  IV  applies  to  remedy-screening treatability
  studies, and QA Categories III and II apply to both remedy
  selection and RD/RA treatability studies. In determining
  the appropriate QA category, the decision maker must
  consider the intended use  of  the  data and  the risks
  associated with selecting an ineffective  remedy based on
  the quality and quantity of the treatability data collected.

  When the  data quality needs for a project have been
  defined, confidence limits  can be established for the data
  to be generated. Specific confidence limits  have not been
  established for each treatability study  tier. Rather, the
  intended use of the data and the limitations and costs of
  various analytical methods will assist the decision maker in
  defining appropriate confidence limits for the tier of testing
  being planned. Sampling and analysis options are reviewed
  in Stage 2 of the DQO development process. Issues to be
  considered during the review process include the data
                                uses; data types; data quality needs; data quantity needs;
                                precision, accuracy, representativeness, completeness, and
                                comparability (PARCC) parameters (Table 5); analytical
                                costs; and the time required for analysis.

                                The PARCC parameters are defined by the intended use
                                of the data and are indicative of data quality. As the data
                                quality and quantity needs increase, the PARCC parameter
                                goals must rise. It is not practical to  set universal PARCC
                                goals for treatability testing because of the variability  in
                                sites, technologies, and contaminants.

                                Stage 3

                                Methods for  obtaining  data of acceptable quality and
                                quantity are chosen and incorporated into the project Work
                                Plan and SAP during Stage 3. The purpose of Stage 3 is to
                                assemble  the  data  collection  components  into   a
                                comprehensive data collection  program. As data  quality
                                needs  increase,  the   need  for   detailed   goals  and
                                documentation components in the collection program will
                                increase.

                                3.2.2  Remedy Screening

                                The DQOs established for remedy  screening are usually
                                stated in qualitative terms. Remedy screening provides a
                                qualitative  engineering assessment  of  the  potential
                                feasibility of a technology (i.e., go/no  go. Therefore, QA
                                Category IV usually provides data of sufficient quality for
                                remedy  screening.  According to  Quality  Assurance
                                Procedures for RREL, QA Category IV is designed to
                                support basic research that may change direction  several
                                times in
                                        Table 5. PARCC Parameters
    Precision



    Accuracy


    Representativeness



    Completeness

    Comparability
A quantitative measure of the variability of a group of measurements, normally
stated in terms of standard deviation, range, or relative percent difference.
Precision is determined from analytical laboratory replicates (split samples) and
test replicates (collocated samples).

A quantitative measure of the bias in a measurement system,  normally stated in
terms of percent recovery. Accuracy is determined by QC samples and matrix
spikes with known concentrations.

A qualitative statement regarding the degree to which data accurately and
precisely represent a population or condition. Representativeness is addressed by
ensuring that sampling locations are selected properly and that a sufficient number
of samples are collected.

The percentage of the measurements that are judged to be valid. Regardless of the
use of the data, a sufficient amount of the data generated should be valid.

A qualitative statement regarding the confidence with which one data set can  be
compared with another. Comparability is achieved through the  use of standard
techniques to collect and analyze samples and to report results.
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  the course of testing. The PARCC requirements are
  therefore  broadly  defined  in  this category to permit
  flexibility  during the actual testing.  Confidence  limits
  established for data derived from remedy screening are
  typically wide, in keeping with the characteristics of this
  tier (i.e., low cost, quick turnaround, and limited QA/QC).
  A minimum number of QC checks are required to assess
  accuracy  and precision. Remedy  screening does not
  require  a  significant amount of replication  in the test
  samples and the  analytical tests performed. The need for
  accuracy checks  such as matrix spikes and blanks  is also
  limited.

  3.2.3 Remedy-Selection Testing

  For remedy selection, DQOs are primarily  quantitative in
  nature. For example, a performance goal for  remedy-
  selection testing involving solvent extraction and chemical
  dehalogenation may be to reduce poly chlorinated biphenyls
  (PCBs) to less than 30 ppm in soils (the target cleanup goal
  specified for the site). The data required to meet this
  quantitative  goal  are  derived  from  detailed  waste
  characterizadon and performance testing. These  data will
  be used to select one of the technologies in the ROD.

  Because data used in support of remedy selection must
  have  a high level of confidence, QA Categories III or II
  are recommended for remedy-selection testing.  These
  categories  are designed to support the evaluation and
  selection of technologies. The PARCC parameters are
  therefore  narrowly  defined  and  test data are  well
  documented. The selection of Category III (less stringent)
  or Category II (more stringent) for treatability testing
  depends on the intended use of the data and  on  time and
  cost constraints.

  Narrow confidence limits are typically required at this tier.
  Quality control checks for accuracy and precision will be
  more  thorough than for remedy screening. A significant
  amount of test sample and analytical sample replication will
  be required  to determine  accuracy  and  precision
  parameters. The representativeness of the data must be
  carefully documented, and a sufficient amount of the data
  generated should be judged valid. Standard sampling and
  analysis techniques should be used whenever possible to
  assure data comparability. The testing apparatus should be
  designed to generate enough treated material to support
  this QA program.

  The need for detailed analyses and high-quality data at the
  remedy-selection tier will result in significantly  higher
  analytical costs and longer turnaround times  compared with
  those  for remedy  screening.  These  factors must be
  considered when establishing DQOs for remedy-selection
  treatability studies.
3.2.4 RD/RA Testing

The principal  objective of  RD/RA testing is to  obtain
quantitative performance, design, and cost data for use in
the implementation of the selected remedial technology.
Data quality objectives for RD/RA treatability studies are
therefore primarily quantitative.

The need for design, cost, and performance information
will  dictate the frequency of sampling and testing,  the
required confidence limits, and the level of QA/QC. The
uses for RD/RA treatability study data differ  from those
for remedy-selection data, but the required level of data
quality will be the same or less. Therefore, QA Categories
III or II are recommended for RD/RA testing.

In  general,  RD/RA  testing  will   involve  significant
replication in  test sampling  (collecated  samples) and
laboratory analyses  (split samples).  Typically, PARCC
parameters are narrowly defined and test data are well
documented. Confidence limits will be similar to those for
remedy-selection testing.
3.3
Identifying
Studies
Sources   for  Treatability
3.3.1  General
Once the decision to conduct a treatability study has been
made and the scope of the project has been defined, the
project  manager  must  identify  a qualified  program
contractor or technology vendor with the requisite technical
capabilities  and  experience to  perform the  work.
Treatability studies can  be performed in house or via
several contract mechanisms that exist for the remedial
and removal programs under CERCLA.

In-house Capabilities

In support  of Superfund,  EPA has  created  several
programs and documents to assist EPA site managers in
the performance of treatability studies. These include the
Superfund   Technical   Assistance  Response  Team
(START), the RREL Remedy-Screening Treatability Study
Laboratory, the Environmental Response Team (ERT), and
the Inventory of Treatability Study Vendors.

Superfund Technical Assistance Response Team. Site-
specific,  long-term assistance  is  available  to  project
managers through START. Sponsored by ORD-RREL, the
START  program provides  comprehensive engineering
assistance  from  early  RI/FS   scoping   through  RA
implementation  at a limited number  of sites.  Sites are
chosen by the
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  Regions for START support because of their complex
  contaminants and matrices.

  Treatability support services available to project managers
  through START include:

    •  Identification  of  potentially applicable technology
      options

    •  Determination of need for treatability studies

    •  Performance of remedy-screening treatability studies

    •  Review of treatability study Project Plans

    •  Oversight of PRP-conducted treatability studies

    •  Review of PRP deliverables and final reports

  Treatability support through the START  program can be
  obtained by  contacting the  RREL Technical Support
  Branch in Cincinnati, Ohio.

  RREL   Remedy-Screening   Treatability   Study
  Laboratory.  The RREL has developed a  series of
  remedy-screening treatability tests. These protocols are
  designed to  provide   the  Regions  with inexpensive,
  preliminary assessments of the potential feasibility of a
  given technology  for remediating contaminated  soil.
  In-house testing can be performed for:

    •  Soil vapor extraction

    •  Solvent extraction

    •  Soil washing

    •  Soil flushing

    •  Biological degradation

    •  Chemical dehalogenation

    •  Solidification/stabilization

    •  Thermal desorption

    •  Incineration technologies

  Regions can have these tests performed by contacting the
  RREL Technical Support Branch in Cincinnati, Ohio (see
  Appendix A).

  Environmental Response Team. Serving as the EPA's in-
  house consultants on Superfund issues and oil spills, the
Environmental Response Team provides technical support
to OSCs and RPMs for both emergency removal and
long-term remedial  actions.  With support  from the
Response Engineering  and Analytical Contractor, the
ERT's Alternative Technology  Section can  design and
perform  remedy-screening   and   remedy-selection
treatability studies for a wide range of technologies. The
Section can provide  testing oversight and evaluate and
interpret treatability  test results.  Regions can request
treatability study support by contacting the ERT in Edison,
New Jersey (see Appendix A).

Inventory of Treatability Study Vendors. The ORD has
compiled a  list of vendors and contractors  who have
expressed an interest in  performing treatability studies.
This document,  entitled Inventory of Treatability Study
Vendors,  Volumes I and II (EPA 1990a), was compiled
from   information   received  from   contractor/vendor
responses to a published request. It lists commercial firms
that offer treatability study services and describes their
capabilities.  (This information has  not been  verified by
EPA.) The inventory is sorted by treatment technology,
contaminant group, and company name. It can  be searched
electronically   by   contacting  the  EPA   Alternative
Treatment Technology Information Center (ATTIC) (see
Appendix A).  Figure  4, an example page from the
document, shows the types of information the inventory
contains.

Contractors or Vendors

Three  available methods for obtaining treatability study
services from contractors are discussed here.

ARCS, ERCS, and TAT Contracts. Alternative Remedial
Contracts Strategy (ARCS) contracts are  used to obtain
the program management and technical services needed to
support remedial response activities at CERCLA sites. To
retain  a treatability study vendor through this contract
mechanism, the EPA project manager (in conjunction with
the EPA contract  officer) must  issue  to  the  prime
contractor a Work Assignment outlining the required tasks.
The prime contractor may elect to perform this work or to
assign it to one of its subcontractors. Emergency Response
Cleanup Services (ERCS) and Technical Assistance Team
(TAT)  contracts  provide  similar support  services  at
CERCLA removal sites. Both ERCS and TAT contractors
can be directed to perform treatability studies.

Technical Assistance and Support Contracts. When a
specific waste at a particular site requires the specialized
services of a contractor that can treat that waste  (e.g., a
mixed radioactive/hazardous waste) and such services are
not available from  firm's  accessible through existing
contracts,  the  EPA  project  manager  may  need  to
investigate which firms
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TREATABILITY STUDY VENDORS BY COMPANY NAME
F
1





















F




















F





COMPANY:
Address:
City:
Contact:
Treatment Technology: ACTIVATED CARBON
Other Treatment Capability: 5 TECHNOLOGIES
CURRENT AVAILABLE LABORATORY
FACILITY:
Permitting Status: EPA ID AS SMALL GENERATOR
Mobile Facility? YES
Bench Scale? YES
Unit Capacity: INFORMATION NOT PROVIDED
Price Information: INFORMATION NOT PROVIDED
Media Treated: 1. AQUEOUS MEDIA
3.
5. Other
Contaminant 1. HALOGENATED NONVOLATILES
Groups 3. NONHALOGENATED NONVOLATILES
Treated: 5. NONVOLATILE METALS
7. ORGANIC CYANIDES
9. VOLATILE METALS
11.
Other Contaminant Groups That Can Be Treated:
Experience at Superfund Sites?
SUPERFUND SITE # 1: AS F MATERIAL RECLAIMING
Site Location: GREENVILLE
Start Date: 00/84
Unit Utilized for/at Site: INFORMATION NOT PROVIDED
Price Information: INFORMATION NOT PROVIDED
Media Treated 1. AQUEOUS MEDIA
3.
5. Other
Contaminant 1. VOLATILE METALS
Groups 3.
Treated: 5.
7.
9.
11.
Other Contaminant Groups Treated:
SUPERFUND SITE # 2: AMERICAN CREOSOTE
Location: JACKSON
Start Date: 00/86
Unit Utilized for/at Site: INFORMATION NOT PROVIDED
Price Information: INFORMATION NOT PROVIDED
Media Treated: 1. AQUEOUS MEDIA
3.
5. Other
Contaminant 1. NONVOLATILE METALS
Groups 3. CREOSOTE
Treated: 5.
7.
9.
11.
Other Contaminant Groups:
Company Type: SMALL BUS

State: Zip:
Phone:



Studies/Month: INP
Fixed Facility? YES
Pilot Scale? NO
Location: ATLANTA, GA

2. ORGANIC LIQUID
4.

2. HALOGENATED VOLATILES
4. NONHALOGENATED VOLATILES
6. ORGANIC CORROSIVES
8. PCBs
10.
12.
NOT SPECIFIED
YES
EPA Region: 5 ID #: 17
State: IL
End Date: INP


2.
4.

2. PCBs
4.
6.
8.
10.
12.

EPA Region: 5 ID #: 72
State: TN
End Date: INP


2.
4.

2. PCBs
4.
6.
8.
10.
12.
OTHER ORGANICS
         Figure 4. Information contained in the ORD Inventory of Treatability Study Vendors.
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  with this specialized capability are accessible through other
  contracting mechanisms.  Access to technical assistance
  and support contracts may be available through the RREL,
  the U.S. Bureau of Mines, or the U.S. Army Corps  of
  Engineers.

  Request for  Proposal. In the absence of an existing
  contracting  mechanism  for  accessing  the  required
  treatability  study services  for a specific  waste at a
  particular site,  a new contracting mechanism  can be
  established. This will generally be the prime mechanism by
  which PRPs obtain treatability study services. Obtaining
  the services of a specific firm through a new contracting
  mechanism usually involves three steps: 1) a request for
  proposal (RFP), 2) a bid review and evaluation, and 3) a
  contract award.  (Note: This can be a time-consuming
  process.)

  An RFP is an invitation to firms to submit proposals to
  conduct specific services. It usually contains the following
  key sections:

    •  The type of contract to  be awarded (e.g., fixed-price
      or cost plus fixed fee)

    •  Period of performance

    •  Level of effort

    •  Type of personnel (levels and skills)

    •  Project background

    •  Scope of work

    •  Technical evaluation criteria

    •  Instructions  for  bidders  (e.g., due date, format,
      assumptions for cost proposals, page limit, and number
      of copies)

  Appropriate  firms  listed  in  ORD's  Inventory  of
  Treatability Study Vendors should be notified of the RFP
  in accordance with the Federal Acquisition Regulations.
  Proposals submitted by a fixed due date in response to an
  RFP go to several reviewers to determine the abilities of
  the prospective firms to conduct the required services. The
  technical proposals should  be evaluated (scored) with a
  standard rating system that is based on  the technical
  evaluation criteria presented in the RFP. Contact award
  should be based on a firm's ability  to meet the technical
  requirements  of the testing involved, its qualifications and
  experience in conducting similar studies, the availability and
  adequacy of its personnel and equipment resources, and
  (other things being equal) a comparison of cost estimates.
3.3.2  Remedy Screening

Remedy  screening involves relatively simple tests that
require no special equipment. These studies can often be
performed genetically (as discussed in Subsection 2.5.4) by
the RREL; by the ARCS, ERCS, or TAT contractor; or by
the State or PRP prime support services contractor.

3.3.3  Remedy-Selection Testing

Remedy-selection testing  of proven or demonstrated
technologies can sometimes be performed by the ARCS,
ERCS, or TAT contractor. Tests  involving innovative
technologies, however, may require special vendor-specific
capabilities  that are only accessible through  technical
assistance and support contracts or  an RFP.

3.3.4  RD/RA Testing

Post-ROD testing entails more complex tests involving the
use of specialized equipment. Because such capabilities
may not be available through any existing contracting
mechanism within the Agency, it may be necessary to
issue an RFP to obtain RD/RA treatability study services.
The RFP will generally be issued by the designer.

3.4  Issuing the Work Assignment

The Work Assignment is a contractual  document that
outlines  the scope  of work to  be provided  by the
contractor.  It presents the rationale for conducting the
study, identifies the waste stream and technology(ies) to be
tested, and specifies  the tier(s) of testing required. Table 6
presents the suggested organization of the treatability study
Work Assignment.

3.4.1  Background

The background section of the Work Assignment describes
the site, the waste stream, and the treatment technology
under investigation. Site-specific concerns that may affect
waste  handling,  the experimental   design,   or data
interpretation,  as  well as specific process options of
interest,  should be duly noted. The results of any previous
treatability  studies conducted at the site also should be
included.

3.4.2  Test Objectives

This section defines the objectives of the treatability study
and the intended use  of the data (i.e., to determine potential
feasibility; to develop performance or cost data for remedy
selection;  or  to  provide  detailed design, cost,  and
performance data for  remedy implementation). The test
objec-
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  Table 6. Suggested Organization of
         Treatability Study Work Assignment

  1.  Background
      1.1  Site description
      1.2  Waste stream description
      1.3  Treatment technology description
      1.4  Previous treatability studies at the site
  2.  Test Objectives
  3.  Approach
      3.1  Task 1 - Work Plan preparation
      3.2  Task 2 - SAP, HSP, and CRP preparation
      3.3  Task 3 - Treatabiflty study execution
      3.4  Task 4 - Data analysis and interpretation
      3.5  Task 5 - Report preparation
      3.6  Task 6 - Residuals management
  4.  Reporting Requirements
      4.1  Deliverables
      4.2  Monthly  reports
  5.  Schedule
  6.  Level of Effort


  tives will include performance  goals that are based on
  established cleanup criteria for the site or,  when  such
  criteria  do not  exist,  on contaminant  levels that are
  protective of human health and the environment. If the
  treatability study Work Assignment is issued before site
  cleanup goals have been established, the test objectives
  should be written with enough latitude to accommodate
  changes  as the  treatability  testing proceeds  without
  modifying the Work Assignment.

  3.4.3  Approach

  The approach   describes the  manner  in  which  the
  treatability study  is to be conducted. It should address the
  following six tasks: 1) Work Plan preparation; 2) Sampling
  and Analysis Plan (SAP), Health and Safety Plan (HSP),
  and Community Relations Plan (CRP)  preparation; 3)
  treatability  study   execution;  4)  data  analysis   and
  interpretation;  5) report  preparation; and 6) residuals
  management.

  Task 1 - Work Plan Preparation

  This task outlines the elements to be included in the Work
  Plan. If a project kickoff meeting is needed to define the
  objectives of  the  treatability study  or to review the
  experimental design, it should  be specified here.  The
  contractor should not begin work on subsequent tasks until
  receipt of the project manager's  approval of the Work
  Plan.
Task 2 - SAP, HSP, and CRP Preparation

This task describes  activities  specifically related to the
treatability  study  that should be  incorporated into the
existing site SAP, HSP, and CRP. Examples of such
activities  include  field  sampling  and  waste  stream
characterization, operation of pilot-plant equipment, and
public meetings to discuss treatability study findings.

Task 3 - Treatability Study Execution

Requirements for executing  the  treatability  study are
outlined in this task. It should include requirements that the
contractor  review  the  literature  and   site-specific
information, identify key parameters for investigation, and
specify conditions of the test. This task also should identify
guidance  documents  (such  as  this  guide  or  other
technology-specific protocols) to be consulted during the
planning and execution of the study.

Task 4 - Data Analysis  and Interpretation

This task describes how data from the treatability study
will be used in the evaluation  of the remedy. If statistical
analysis of the data will be necessary, the requirements
should be stipulated here.

Task 5 - Report Preparation

This task describes the contents and organization of the
finalproject report. If multiple tiers of testing are expected,
an interim  report  may be requested upon completion of
each tier. The contractor should be required to follow the
reporting format outlined in Subsection 3.12.

Task 6 - Residuals Management

Residuals   generated by treatability testing  must  be
managed in an  environmentally sound manner. This task
should specify whether project residuals are to be returned
to the site or shipped to an acceptable offsite facility. In the
latter case, the responsible waste generators (lead agency,
PRP, or contractor) should be clearly identified.

3.4.4   Reporting Requirements

This section identifies the project deliverables and monthly
reporting requirements. Project deliverables include the
Work Plan; the SAP, HSP, and CRP (as appropriate); and
interim  and final  reports. It should indicate the  format
specifications (as outlined in this guidance) and the number
of copies to be delivered. All remedial and removal Work
Assignments must include a requirement for one camera-
ready master copy of the treatability study report to be
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  provided to the  Office  of Research and Development
  (EPA 1989e) for use in updating the RREL Treatability
  Data Base. (The report should be sent to the address listed
  in Subsection 3.12.)

  Monthly reports should summarize the progress made in
  the current month, projected progress for  the  coming
  month, any problems encountered, and expected versus
  actual costs incurred.

  3.4.5  Schedule

  The schedule establishes the time frame for conducting the
  treatability study and includes due dates for submission of
  the major project deliverables. Sufficient time should be
  allowed for approval of the Work Plan, subcontractors, and
  other required administrative approvals; site access  and
  sampling; analytical turnaround;  equipment setup  and
  shakedown; data analysis and interpretation; and review
  and comment on reports.

  3.4.6  Level of Effort

  The level of effort estimates the number of technical hours
  required to complete the project.  Special skills or expertise
  are required for most  treatability  studies,  and these
  requirements should be so noted.
  3.5   Preparing the Work Plan

  Treatability studies must be carefully planned to ensure
  that  the  data generated are  useful for evaluating the
  feasibility or performance 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 7
  presents the suggested organization of a treatability study
  Work Plan. The Work Plan  must be approved by the
  project manager before subsequent tasks  are initiated.
  Each of the principal Work Plan elements is described in
  the following subsections.

  3.5.1 Project Description

  The  project description section of the Work Plan provides
  background information  on  the  site and summarizes
  existing waste  characterization data (matrix type and
  characteristics and the concentrations and distribution of
  the contaminants  of  concern). This information can be
  obtained from the Work Assignment or other background
  documents such as the RI. The project description also
  specifies the type of  study to  be conducted, i.e., remedy
  screening,
Table 7.  Suggested Organization of
           Treatability Study Work Plan

   1. Project Description
   2. Treatment 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


remedy-selection testing, or RD/RA testing. For treatability
studies involving multiple tiers of testing, this section states
how the need for subsequent testing will be determined
from the results of the previous tier.

3.5.2  Treatment Technology
       Description

This section  of  the  Work Plan briefly describes the
treatment technology to be tested. It may include a flow
diagram showing the input stream, the  output stream, and
any side streams generated as a result of the treatment
process. For treatability studies involving treatment trains,
the technology description addresses all the unit operations
the system comprises. A description of the pre- and
posttreatment requirements also may be included.

3.5.3  Test Objectives

This section of the Work Plan defines the objectives of the
treatability study and the intended use  of the data (i.e., to
determine potential feasibility; to develop performance or
cost data  for remedy selection; or to  provide detailed
design,  cost, and  performance  data  for  remedy
implementation).   The test  objectives  will  include
performance  goals  that are based on established cleanup
criteria for the site or, when such criteria do not exist, on
contaminant levels that are protective of human health and
the environment.

3.5.4  Experimental Design and
       Procedures

The experimental design identifies the  tier and scale of
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  testing, the volume of waste material to be tested, the
  critical parameters, and the type and amount of replication.
  Examples of  critical parameters include pH, reagent
  dosage, temperature,  and reaction (or residence) time.
  Some form of replication is usually incorporated into a
  treatability study to provide a greater level of confidence in
  the data. Two methods are used to collect different types
  of test sample  replicates:

    1)  Dividing a sample in half or thirds at the end of the
        experiment and analyzing each fraction. This method
        provides information on laboratory error.

    2)  Analyzing  two  or  three  samples   prepared
        independently of each other under the same test
        conditions. This method provides information on total
        error.

  The data quality objectives and the costs associated with
  replication  must  be considered in the  design  of the
  experiment. A matrix outlining the test conditions and the
  number of replicates, such as the example in Figure 5,
  should be included in the Work Plan.

  The specific steps to be followed in the performance of the
  treatability study are described in the standard operating
  procedures (SOP).  The SOP should be sufficiently detailed
  to permit the laboratory or field technician to conduct the
  test, to operate the equipment, and to collect the samples
  with minimal supervision, as shown in Example 4. The
  SOP can be appended to the Work Plan.

  3.5.5 Equipment and Materials

  This section lists the equipment, materials, and reagents
  that will be used in the  performance  of the treatability
  study. The following specifications should be provided for
  each item listed:

      •  Quantity

      •  Volume/capacity
   •  Calibration or scale

   •  Equipment manufacturer and model number

   •  Reagent grade and concentration

A diagram of the test apparatus also should be included in
the Work Plan.

3.5.6 Sampling and Analysis

A Sampling and Analysis Plan is required  for all field
activities  conducted  during  the  RI/FS. This  section
describes how the existing SAP will be modified to address
field sampling, waste characterization, and sampling and
analysis activities in  support of the treatability study. It
describes the kinds of samples that will be collected and
specifies the levelof QA/QC required. (Preparation of the
treatability study SAP is discussed in Subsection 3.6.)

Appendix   C  contains  waste  feed  characterization
parameters  specific  to biological,  physical/chemical,
immobilization, thermal, and in situ treatment technologies.
Generally, these are the characterization parameters that
must be established before a treatability test is conducted
on the corresponding  technology. Site-specific conditions
may necessitate the use of additional parameters.

3.5.7 Data Management

This section of the Work Plan 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.

3.5.8 Data Analysis and Interpretation

This section of the Work Plan describes the procedures
that will be used to analyze and interpret data from the
treatability

Soil
X
Y
1
A%
3
3
- Zeolite
B%
3
3
C%
3
3
A%
3
3
II - Zeolite
B%
3
3
C%
3
3
III - limestone
3
3
IV - control
3
3
        Figure 5.  Example test matrix for zeolite amendment remedy-selection treatability study.
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           EXAMPLE 4. TREATABILITY STUDY STANDARD OPERATING PROCEDURE
      Standard Operating Procedure for Thermal Desorption Remedy-Screening Treatability Study

       1.   Define and record planned experiment in the data book (i.e., time, temperature, soil, etc.).
       2.   Weigh the empty clean tray.
       3.   Transfer a representative aliquot of prepared soil from the jar to the tray with a stainless steel spatula.
       4.   Weigh the soil and tray and adjust the soil quantity to achieve a uniform layer approximately 2.5 to 3 mm
            deep in the bottom of the tray.
       5.   Distribute and level the soil within the tray.
       6.   Turn on the purge-gas flow to the proper setting on the rotameter.
       7.   Place the tray with soil in the oven at ambient temperature and close the oven door.
       8.   Set the oven  temperature controller set-point to the target test temperature and start the timer.
       9.   Monitor and record the temperatures and time periodically throughout the test period.
       10.  When the prescribed residence time at the target temperature  is reached, shut off the oven heater and
            purge-gas flow and open the oven door.
       11.  Cautiously withdraw the hot tray and soil with special tongs, place a cover on the tray, and place the
            covered tray in a separate hood to cool for approximately 1 hour.
       12.  Weigh the tray (without cover) plus treated soil.
       13.  Transfer an aliquot (typically about 20 g) of treated soil from the tray to a tared, 60-cm3, wide-mouth,
            amber bottle with Teflon-lined cap. Code, label, and submit this aliquot for analysis. Transfer the
            remainder of  the treated soil to an identical type bottle, label, and store as a retainer.
       14.  Clean the tray, cover, and nondisposable implements by the following  procedure:
             •  Rinse with acetone and wipe clean.
             •  Scrub with detergent solution and rinse with hot tap water followed by distilled water.
             •  Rinse with acetone and allow to dry.
             •  Rinse three times  with methylene chloride (i.e., approximately 15 to 25  ml each rinse for the tray).
             •  Air dry and store.
  study, including methods of data presentation (tabular and
  graphical) and statistical  evaluation.  (Data  analysis and
  interpretation are discussed in Subsection 3.11.)

  3.5.9   Health and Safety

  A Health and Safety Plan  is required for all cleanup
  operations involving hazardous substances under CERCLA
  and for all operations involving hazardous wastes that are
  conducted at RCRA-regulateld facilities. This section of
  the Work Plan describes how the existing site or facility
  HSP will be modified to address the hazards associated
  with treatability testing. Hazards may  include, but are not
  limited to, chemical exposure; fires, explosions, or spills;
generation of toxic or asphyxiating gases; physical hazards;
electrical hazards; and heat stress or frostbite. (Preparation
of the treatability study HSP is discussed in Subsection
3.7.)

3.5.10  Residuals Management

This section of the Work Plan describes the management
of treatability study residuals.  Residuals generated by
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
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  parties involved in the generation of residuals 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
  treatability testing. These estimates should be based  on
  knowledge   of the   treatment  technology  and   the
  experimental design.  Project residuals may include the
  following:
    •  Unused waste not subjected to testing

    •  Treated waste

    •  Treatment residuals (e.g., ash, scrubber water, and
      combustion gases)

    •  Laboratory samples and sample extracts

    •  Used containers or other expendables

    •  Contaminated protective clothing and debris

  This section outlines how treatability study residuals will be
  analyzed to determine if they are hazardous wastes and
  specifies whether such wastes will be returned to the site
  or shipped to a permitted treatment, storage, or disposal
  facility (TSDF) (see Subsection 3.9). In the
 latter case, this section also identifies the waste generator
 (lead  agency,  responsible  party,  or  contractor)  and
 delineates the parameters that will be analyzed for properly
 manifesting the waste and for obtaining disposal approval
 from the TSDF (see Table 8).

 3.5.11   Community Relations

 A Community Relations Plan is required for all removal
 and remedial  response  actions under CERCLA.  This
 section describes the community relations activities that
 will be performed in conjunction with the treatability study.
 These activities 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. (Conducting community relations
 activities  for treatability  studies  is discussed in detail in
 Subsection 3.8.)
 3.5.12  Reports

 This section of the Work Plan describes the preparation of
 interim and final reports documenting the results of the
 treatability study. For treatability studies involving  more
 than one tier of testing, interim reports (or project briefings)
 provide a means of determining whether to proceed to the
 next tier. This section also describes the preparation of
           Table 8. Typical Waste Parameters Needed to Obtain Disposal Approval at an Offsite Facility3
    Incineration parameters
       Total solids
       % Water
       % Ash
       pH
       Specific gravity
       Flash point
       Btu/pound
       Total sulfide
       Total sulfur
       Total organic nitrogen
       Total cyanide
       Total phenolics
       Total organic halogen (TOX)
       Polychlorinated biphenyls (PCBs)
       Total RCRA metals (eight)
       TCLP metals
       TCLP organics (D-list)
       Priority pollutant organics
             Volatile
             Semivolatile (BN/A-extractable)
             Remaining F-listed solvents
Treatment parameters
    PH
    Specific gravity
    Oil and grease
    Total organic carbon (TOC)
    Total sulfide
    Total cyanide
    Total phenolics
    Total metals  (RCRA plus Cu, Ni, Zn)
    TCLP metals
    TCLP organics (D-list)

Landfill parameters (solids only)
    % Water
    % Ash
    PH
    Specific gravity
    Total sulfide
    Total cyanide
    Total phenolics
    PCBs
    TCLP metals (extraction and RCRA)
    TCLP organics (D-list)
    TCLP solvents (F-list)
    3Analysis of these parameters may be required unless they can be ruled out based on knowledge of the waste.
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  monlhly  reports  detailing  the  current  and projected
  progress on the project. (Treatability study reporting is
  discussed in detail in Subsection 3.12.)

  3.5.13  Schedule

  The Work Plan should contain a schedule indicating the
  planned starting and ending dates  for the tasks outlined in
  the Work Assignment. The length of a treatability study
  will vary with the technology being investigated and the
  level of testing being conducted. Entire 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 6. 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 7a) will require only 1 to
  2 weeks to perform. The entire two-tiered study, however,
  spans a period of 8 months.

  3.5.14  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 7. The EPA Project Manager 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 PRP  performs this function. The
  treatability study may be subcontracted wholly or in part to
  a vendor or testing facility with expertise in the technology
  being evaluated.

  3.5.15  Budget

  The treatability study budget presents the projected costs
  for completing the 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. Appendix B discusses these
various  cost elements.

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 treatment 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. This  kind of
information can be obtained from the technology vendor
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
turnaround time. Specialty analyses (e.g., for dioxins and
furans) can quickly increase the analytical costs.

A 34-week remedy-screening/remedy-selection treatability
study such  as the one presented in Figure 6  can be
performed at a cost of between $50,000 and $ 100,000.

3.6   Preparing the Sampling and Analysis
      Plan

3.6.1 General

A Sampling and Analysis Plan is required for all field and
test activities conducted to support a treatability study. The
purpose of the SAP is to ensure that samples obtained for
characterization and testing are representative and that the
quality of the analytical data generated is known. The SAP
addresses  field  sampling,  waste characterization, and
sampling and analysis of the treated wastes  and residuals
from the testing apparatus or treatment unit.

Table 9 presents the   suggested organization  of the
treatability study SAP. The SAP consists of two parts-the
Field  Sampling Plan (FSP) and  the  Quality Assurance
Project  Plan (QAPP).

Field Sampling Plan

The FSP component of the SAP describes  the sampling
objectives; the type, location, and number of samples to be
collected; the sample numbering system; the necessary
equipment and procedures for collecting the samples; the
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TASK
tf^ *^x f »
Taskl
Work Plan Preparation
Task 2
SAP & HSP Preparation
Task3
Remedy Screening
Treatability Study Execution
3a - Reid Sampling/Waste Characterization
3b - Equipment Setup/Testing/Sampling
: 3c - Sample Analysis
Task4
Data Analysis and Interpretation
TaskS
Interim Report Preparation & Review
Task 6
Test Plan Revision (if necessary)
Task?
Remedy Selection
Treatability Study Execution
7a - Equipment Setup/Testing/Sampiing
7b - Sample Analysis

Tasks
Data Analysis and Interpretation
Task 9
Final Report Preparation and Review

Task 10
Residuals Management
Span,
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M-16
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I
M-1 Submit Work Plan Wk 2 M-8 Receive Treatabgity Results Wk16 M-15 Receive Review Comments Wk32
M-2 Receive Work Plan Approval Wk3 M-9 Submit Interim Report Wk19 M-1 6 Submit Rnal Report Wk34
M-3 Submit SAP and HSP Wk6 M-10 Project Briefing Wk20 M-1 7 Subnit Disposal Application Wk28
M-4 Receive SAP and HSP Approvals Wk8 M-11 Submit Revised Work Plan Wk21 M-1 8 Receive Disposal Approval Wk32
M-5 Collect and Submit FieW Samples Wk9 M-1 2 Submit Treatability Samples Wk23 M-1 9 Ship Residuals for Disposal Wk34
M-6 Receive Waste Characterization Results Wk12 M-1 3 Receive TreatabHity Results Wk26
M-7 Submit Treatability Samples Wk13 M-1 4 Submit Draft Report Wk30
                       Figure 6. Example project schedule for a two-tiered chemical dehalogenation treatability study.
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  sample  chain-of-custody procedures;  and the required
  packaging, labeling, and shipping procedures.

  The sampling objectives must support the test objectives of
  the treatability study.  For example, if an objective of RD/
  RA testing is to investigate process upsets and recovery,
  the objective of field sampling should be to collect samples
  representing the "worst case." If soils will be blended in
  the  full-scale process, however,  the  field sampling
  objectives should  be  to  collect  samples representing
  "average" conditions at the site.

  Whatever the sampling objectives, the samples collected
  must be representative of the conditions being evaluated.
  Guidance on representative  samples  and  statistical
  sampling is contained in Test Methods for Evaluating
  Solid Waste (EPA 1986).

  Additional guidance  for the selection  of field methods,
  sampling procedures, and chain-of-custody requirements
  can be obtained from^4 Compendium of Super fund Field
  Operations Methods (EPA 1987b).

  Quality Assurance Project Plan

  The second component of the SAP, the QAPP, 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
                        QAPP  can  be  obtained  from  Quality Assurance
                        Procedures  for  RREL  (EPA  1989d)  and  Interim
                        Guidelines and Specifications for Preparing Quality
                        Assurance Project Plans  (EPA  1980).  In general,
                        QAPPs are based on the type of project being conducted
                        and on the intended use of the data generated by  the
                        project. The QAPP recommended in Table 9 corresponds
                        to  the  QA  Category  II plan presented in Quality
                        Assurance Procedure for RREL. This plan should be
                        implemented  only for remedy-selection treatability studies
                        requiring exceptionally  high levels of QA (i.e., where
                        treatability data will play an important role in the ROD). As
                        discussed in  the following  subsections, less  stringent
                        QAPPs will be adequate for all other treatability studies.

                        3.6.2  Remedy Screening

                        Remedy screening requires a less  stringent level of QA/
                        QC. Technologies determined to be potentially feasible
                        through remedy  screening are  evaluated further at  the
                        remedy-selection tier; therefore, the QA/QC requirements
                        associated with  this  screening  are  less  rigorous.
                        Nevertheless, the test data should be well documented.
                        The
              Quality Assurance Officer
               Health & Safety Officer
              Work Plan
              Preparation
              Task Leader
                                                       EPA
                                                 Remedial Project
                                                     Manager
                                                  EPA
                                            Technical Experts
                                                    Contractor
                                                 Work Assignment
                                                     Manager
SAP & HSP
Preparation
Task Leader
                                             Subcontractor
                                                Manager
Treatability Study
   Execution
  Task Leader
Data Analysis &
 Interpretation
 Task Leader
Final Report
 Preparation
Task Leader
                               Figure 7.  Example project organization chart.
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       Table 9. Suggested Organization of a
    Treatability Study Sampling and Analysis Plan

    Field Sampling Plan
      1.   Site Background
      2.   Sampling Objectives
      3.   Sampling Location and Frequency
      4.   Sample Designation
      5.   Sampling 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.   EPA Methods Used
      C.   SOP for EPA Methods Used
      D.   QA Project Plan Approval Form

  Category   IV   QAPP   is   recommended  for
  remedy-screening treatability studies.

  3.6.3  Remedy-Selection Testing

  Remedy-selection testing requires a moderately to highly
  stringent level of QA/QC. The data generated in remedy-
  selection testing are generally used for  evaluation and
  selection of the remedy; therefore, the QA/QC associated
  with this tier should be rigorous and the test data well
  documented.  The Category  III  QAPP  will provide a
  sufficient   level   of  quality  assurance  for  most
  remedy-selection treatabiliry  studies. In cases  where
  remedy-selection data will be highly scrutinized or have a
  significant impact on decision making, the  Category II
  QAPP may be required.

  3.6.4  RD/RA Testing

  Treatability testing to support remedial  design/remedial
  action requires a moderately to highly stringent level  of
  QA/QC. The data generated in RD/RA testing are used in
  support  of  remedy  optimization  and  implementation;
  therefore, the QA/QC associated with this tier should be
rigorous and the test data well documented. In most cases,
the Category III QAPP will provide data of sufficient
quality for RD/RA treatabiliry studies.


3.7    Preparing the Health and Safety Plan

3.7.1  General

A project-specific Health and Safety Plan is required for
all treatabiliry studies conducted on site or at an offsite
laboratory or testing  facility permitted  under RCRA,
including  research,  development,  and  demonstration
facilities. The vendor or testing facility should submit the
HSP with the treatabiliry  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 appropriate protective measures
to minimize  worker exposure.  Hazards that may be
encountered  during  treatability  studies include  the
following:

    • Chemical  exposure  (inhalation, absorption, or
     ingestion of contaminated soils, sludges, or liquids)

    • Fires, explosions, or spills

    • Toxic  or  asphyxiating gases generated during
     storage or treatment

    • Physical hazards such as sharp objects or slippery
     surfaces

    • Electrical hazards such as high-voltage equipment

    • Heat stress or frostbite

Table  10 presents the  suggested organization  of  the
treatability study HSP, which addresses the Occupational
Safety  and Health Administration (OSHA) requirements in
29 CFR 1910.120(b)(4). Guidance for preparing the HSP
is  contained  in two  documentsS^4  Compendium  of
Superfund Field Operations Methods (EPA 1987b)and
Occupational Safety and Health Guidance Manual for
Hazardous    Waste    Site   Activities
(NIOSH/OSHA/USCG/EPA 1985).

Supervisors, equipment operators,  and field  technicians
engaged  in onsite  operations must satisfy  the training
requirements in 29 CFR 1910.120(e) and must participate
in a medical surveillance program, as described in 29 CFR
1910.120(f). Laboratory personnel must be trained with
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       Table 10.  Suggested Organization of a
      Treatability Study Health and Safety Plan

     1.   Hazard Analysis
     2.   Employee Training
     3.   Personal Protective Equipment
     4.   Medical Surveillance
     5.   Personnel and Environmental Monitoring
     6.   Site Control Measures
     7.   Decontamination Procedures
     8.   Emergency Response Plan
     9.   Confined-Space Entry Procedures
     10.  Spill Containment Program

  regard to container labeling and  Material Safety Data
  Sheets (MSDS) in accordance with the OSHA Hazard
  Communication Standard in 29 CFR 1910.1200. Before
  any treatability studies are initiated, the Health and Safety
  Officer should conduct a  briefing to ensure that  all
  personnel are appraised of the HSP.  The Health  and
  Safety Officer also should conduct inspections during the
  course of the rreatability study to  determine compliance
  with and effectiveness of the HSP.

  3.7.2 Remedy Screening

  The  safety and health hazards associated with remedy
  screening are relatively minor  because  of the small
  volumes  of  wastes  that are handled and subjected to
  testing. In general, the HSP should provide for skin and
  eye protection during the handling of wastes.  It need not
  require respiratory protection if the tests are conducted in
  a fume hood.

  3.7.3 Remedy-Selection Testing

  The  HSP for a  remedy-selection treatability study must
  provide for skin and  eye protection during the handling of
  wastes. It also may require respiratory protection when
  treatment processes tested  at the bench scale involve
  mixing or aeration (e.g., solidification/stabilization, aerobic
  biological treatment)  that could generate dust or volatilize
  organic contaminants. Because pilot-scale testing involves
  significantly greater volumes of waste,  the  health and
  safety risks will increase.

  3.7.4 RD/RA Testing

  Pilot- and field-scale RD/RA treatability studies may pose
  significant health and safety hazards to operators  and
  onsite personnel. The HSP  must outline skin, eye,  and
  respiratory protection (Level  C or higher); decontamination
procedures;   and  emergency  procedures  (such  as
equipment shutdown and personnel evacuation).
3.8  Conducting
     Activities

3.8.1  General
Community  Relations
Community relations activities provide interested persons
an opportunity to comment on and participate in decisions
concerning site actions, including  the  performance of
rreatability studies. Public participation in the removal, RI/
FS, and RD/RA processes ensures that the community is
provided with accurate and timely information about site
activities. From the beginning of the RI/FS, a description of
the treatability study activities that will be performed during
the feasibility study should be included in the discussion on
how the alternatives will be delineated for the particular
site.  Presenting clear, concise explanations of treatability
studies (accompanied by appropriate  graphics) before
activities have been performed will create a more open and
positive Agency/public relationship.

The Agency designs and implements community relations
activities according to CERCLA and the National Oil and
Hazardous  Substances Pollution Contingency Plan. The
NCP requires the lead Agency to prepare a  Community
Relations Plan for all remedial response actions and for all
removal actions of more than 45 days' duration, regardless
of whether RI/FS activities are fund-financed or conducted
by  PRPs  (40 CFR 300.67). This  plan  outlines  all
community relations activities that will be conducted during
the RI/FS and projects the future activities required during
completion of remedial design and implementation. These
future activities are outlined more clearly in a revised plan
developed  after  the  feasibility  study  and  before the
remedial design phase.

Guidance for preparing a CRP and conducting community
relations  activities can be  acquired from  Community
Relations in Super fund: A Handbook  (EPA 1988b).
Table 11 presents the CRP organization suggested in this
handbook.

Community interviews  should be conducted before the
CRP   is  prepared.  These  interviews  are  informal
discussions held with State and local officials, community
leaders, media representatives, and interested citizens to
assess the public's concern and desire to be involved in site
response activities. Discussions with citizens regarding the
possible need for conducting onsite treatability studies will
allow the  Agency to  anticipate and respond better to
community concerns  as the treatability testing process
proceeds and will  allow government officials  and citizens
to under-
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        Table 11. Suggested Organization of
              Community Relations Plan

    1.   Overview of Community Relations Plan
    2.   Capsule Site Description
    3.   Community Background
    4.   Highlights of the Community Relations Program
    5.   Community Relations Activities and Timing
    Appendices
    A.   Contact List of Key Community Leaders and
        Interested Parties
    B.   Suggested Locations of Meetings and
        Information Repositories

  stand that several technologies may be tested before the
  preferred alternative(s) are listed in the final FS report.

  Conducting  treatability  studies on site  is a potentially
  controversial issue within a community and may demand
  considerable effort on the part of the Agency. As the site
  investigation progresses, community  relations activities
  should focus on providing information to the community
  concerning  the technology  screening process and  on
  obtaining feedback on community concerns associated with
  potentially applicable  treatment technologies. Activities
  may include, but are not limited to, the following:

    •  Preparing fact sheets and news releases describing
      treatment  technologies   identified  during  the
      development and screening of alternatives.

    •  Discussing  the possibility of treatability studies being
      conducted during the initial public meeting. Presenting
      professionally produced video tapes or slide shows on
      treatability  studies   at  the  public  meeting  can
      demonstrate that the Agency is attempting to educate
      the public regarding the treatability study process.

    •  Conducting  a workshop  to present to concerned
      citizens, local officials, and the media the Agency's
      rationale for choosing the treatment technologies to be
      studied.

    •  Holding small group meetings with involved members
      of the community at regular intervals throughout the
      RVFS process to discuss treatability study findings and
      site decisions as they develop.

   •  Ensuring citizen access to treatability study information
      by maintaining a complete  and up-to-date information
      repository.
 •  Presenting results of the treatability studies performed
    and  explaining  how  these  results influenced the
    selection of the remedy  at the final  RI/FS public
    meeting.

Fact sheets on the planned treatability studies should be
made available to the public and should include a discussion
of treatability-specific issues such as the following:

 •  Uncertainties   (risk)    pertaining to innovative
    technologies

 •  The degree of development of potentially applicable
    technologies identified for treatability testing

 •  Onsite treatability testing and analysis

 •  Offsite transportation of contaminated materials

 •  Materials handling

 •  Residuals management

 •   RI/FS schedule changes resulting from the unexpected
    need for additional treatability studies

 •  Potential disruptions to the community

3.8.2  Remedy Screening

Remedy-screening treatability studies are relatively low-
profile and, if conducted offsite, will require relatively feed
community relations activities. Distributing fact sheets and
placing  the  results from remedy  screening  in the
information repository will generally be sufficient.

3.8.3  Remedy-Selection Testing

Bench-scale  remedy-selection  testing  may  not  be
particularly  controversial  if  conducted offsite. Onsite
bench-scale   testing,  however,   may   require   more
community relations activities.

Onsite,  pilot-scale  testing   may  attract   considerable
community interest. In some cases (e.g., onsite thermal
treatment), the strength  of public opinion concerning
treatability testing may not have been indicated by the level
of interest demonstrated during  the  RI  and  previous
treatability studies. Because of the very real potential for
conflict and  misunderstanding at  the  remedy-selection
testing stage of the FS, it is vital that a strong program of
community relations and public participation be established
well in advance of any treatability testing.

Community acceptance is one of the nine RI/FS evaluation
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  criteria. Remedy-selection testing may provide data that
  can convince a community of a technology's ability to
  remediate a site effectively. Early, open, and consistent
  communication with the public and their full participation in
  the decision-making  process  may help to prevent the
  testing, development, and selection of a remedy that is
  unacceptable to the community and results in delayed site
  remediation and higher remediation costs.

  3.8.4  RD/RA Testing

  Post-ROD treatability  testing may  not  be  especially
  controversial within a community because the remedy or
  remedies being  investigated have already been reviewed
  and selected during  the  RI/FS. Fact  sheets  and news
  releases covering RD/RA treatability  study progress may
  be appropriate.

  3.9    Complying With  Regulatory
         Requirements

  Treatability studies involving Superfund wastes are subject
  to various requirements under CERCLA [as amended in
  1986 by SARA] and RCRA [as amended in 1984 by the
  Hazardous and Solid Waste Amendments (HSWA)]. The
  applicability of these requirements depends on whether the
  studies are conducted on site (e.g., in a mobile trailer) or at
  an offsite laboratory or testing facility.

  Figure  8   summarizes the  facility  requirements  for
  treatability testing.  Figure  9  summarizes  the shipping
  requirements for  offsite  treatability  testing.  These
  requirements are described in the succeeding subsections.

  3.9.1   Onsite Treatability Studies

  Onsite  treatability  studies  under  CERCLA may  be
  conducted without any Federal, State, or local permits [40
  CFR 300.400(e)(l)]; however, such studies must comply
  with ARARs under Federal and State environmental laws
  to the  extent practicable  or justify  a  waiver  under
  CERCLA Section  121(d)(4).  For example,  treatability
  studies  involving  surface-water discharge must  meet
  effluent limitations  even though a discharge permit is not
  required.

  3.9.2   Offsite Treatability Studies

  Section 121(d)(3) of CERCLA and Revised Procedures
  for Implementing Off-Site  Response  Actions  (the
  "Revised Off-Site Policy") (EPA 1987c) generally state
  that offsite facilities that receive CERCLA wastes must be
  1) operating in  compliance  with applicable Federal and
  State  laws, and 2) controlling any relevant releases of
hazardous substances to the environment. Currently, the
Revised Off-Site Policy does not specifically exempt the
transfer of CERCLA wastes offsite for treatability studies;
therefore, off-site laboratories or testing facilities  that
receive CERCLA wastes must be in compliance with the
offsite requirements.

Off-site  treatability  studies  under  CERCLA must  be
conducted under appropriate Federal or State permits or
authorization   and  other  legal  requirements.   Two
alternatives to a full RCRA facility permit are available to
technology vendors and other laboratory or testing facilities
for compliance  with these  requirements:  a Research,
Development, and Demonstration (RD&D) permit, which
covers limited-duration and limited-quantity  testing of
actual hazardous waste, and the treatability exclusion under
RCRA, which may exempt small-scale testing activities
from certain RCRA permitting requirements.*

Research, Development, and Demonstration Permits

Hazardous waste treatment facilities that propose to use an
innovative  and experimental treatment  technology  or
process for which RCRA permit standards have not been
promulgated under Part 264 or 266 may obtain an RD&D
permit (40 CR 270.65).  This  provision  is intended to
expedite the permit review and issuance process.

An RD&D permit may be required for  laboratories or
testing facilities that perform pilot-scale tests that are likely
to exceed the storage and treatment rate limits specified
under the treatability exclusion. Limitations on the types
and quantities of hazardous waste that can be received and
treated by the facility under an RD&D permit and the
requirements for testing, reporting, and protection of human
health and the environment (as deemed necessary by the
Agency)  are specified in the  terms and conditions  of the
permit. The RD&D  permits are issued for a period  of 1
year and may  be renewed  up to three  times for  one
additional year each.

The status of the RD&D permit authority in a particular
State  can be  determined  by contacting the appropriate
Region's RCRA Coordinator for that State.
  * The Agency intends to address large-scale treatability
 studies in separate rulemaking at some future date; the
Agency also is considering developing regulations under
40 CFR Part 264, Subpart Y, that would establish permitting
standards for experimental facilities conducting research
 and development on the storage, treatment, or disposal
 of hazardous waste.
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                                        Will
                                 trettability study be
                                 conducted on site or
                                      off site?
                                       Do the
                                  Federal treatability
                            study sample exemption rule in
                         40 CFR 261.4(e) and (f) (or equivalent
                          State regulations) or other exclusions
                                 in 40 CFR 261.4(b)
                                       apply?
                                    Will quantity
                                of "as received" waste
                           subjected to initiation of treatment
                               in any single day exceed
                                      250 kg?
                                    Will quantity
                                of "as received" waste
                           stored at the facility for purposes
                                  of testing exceed
                                      1000kg?
No Federal, State, or local permits
required [40 CFR 300.400(e)(1)j;
however, facility must comply with
applicable   or   relevant   and
appropriate  requirements  under
Federal and State environmental
laws to the extent practicable (or
justify a waiver).
                                                                             Subject  to  regulation  under
                                                                             appropriate  Federal  and State
                                                                             environmental   laws  and  the
                                                                             Revised Off-Site Policy (OSWER
                                                                             Directive 9834.11).
                     Conditionally exempt from RCRA treatment,
                     storage, and permitting requirements set forth
                     in 40 CFR Parts 264,  265, and 270 provided
                     notification,   recordkeeping,   and  reporting
                     requirements are  met  [40  CFR  261.4(f)j.
                     Facility  must comply  with  Revised Off-Site
                     Policy (OSWER Directive 9834.11).
                               Figure 8. Facility requirements for treatability testing.
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            Do the
        Federal treatability
  'study sample exemption rule in^
40 CFR 261.4(e) and (f) (or equivalent
State regulations) or other exclusions,
        in 40 CFR 261. 4(b)
            apply?
                                     Yes
                             Will quantity of
                         'sample shipment exceed
                       1000 kg of nonacute hazardous
                    waste, 1 kg of acute hazardous waste,
                     j>r 250 kg of soils, water, or debris^
                            contaminated with
                           ^acute hazardous.
                               owaste?,

                                     No
                                                     MO
                 Conditionally exempt from  RCRA generator
                 and transporter requirements set forth in 40
                 CFR   Parts   262  and   263  provided
                 recordkeeping  and reporting  requirements
                 are met [40 CFR 261.4(e)].
                                               Subject  to  regulation  under
                                               appropriate Federal and  State
                                               environmental  laws  and  the
                                               Revised Off-Site Policy (OSWER
                                               Directive 9834.11).
                           Figure 9.  Shipping requirements for offsite treatability testing.
  Treatability Exclusion

  Effective July 19,1988, the sample exclusion provision [40
  CFR 261.4(d)], which  exempts waste samples collected
  for the sole purpose of determining their characteristics or
  composition from regulation under Subtitle C  of RCRA,
  was  expanded  to  include  waste  samples   used  in
  small-scale treatability studies (53 FR 27301). Because it
  is  considered  less  stringent  than authorized  State
  regulations for RCRA  permits, the Federal Treatability
  Study Sample Exemption Rule is applicable only in those
  States that do not have  final authorization or in  authorized
  States that have revised their program to adopt  equivalent
  regulations under State law.  Although  the provision is
  optional, the EPA has  strongly encouraged authorized
  States to adopt the exemption or to exercise their authority
  to  order treatability  studies (in case of imminent and
  substantial endangerment to health or the environment) or
  to grant a general waiver, permit waiver,
                                       or emergency permit authority to authorize treatability
                                       studies.  The  status  of the treatability exclusion  in  a
                                       particular  State can be determined by  contacting the
                                       appropriate Region's RCRA Coordinator for that State.

                                       Under the treatability exclusion, persons who generate or
                                       collect  samples of hazardous waste (as defined under
                                       RCRA) for the purpose of conducting treatability studies
                                       are   conditionally   exempt  from  the  generator   and
                                       transporter requirements (40 CFR Parts 262 and  263)
                                       when the  samples  are  being  collected,  stored,  or
                                       transported to an offsite laboratory or testing facility [40
                                       CFR 261.4(e)] provided that:

                                         1)  The generator or sample collector uses no more than
                                             1000 kg of any nonacute hazardous waste, 1 kg of
                                             acute hazardous waste, or 250 kg of soils, water, or
                                             debris contaminated with acute hazardous waste per
                                             waste stream per treatment process.
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        On a case-by-case basis, the Regional Administrator
        or State  Director may grant  requests for waste
        stream limits up to an additional 500 kg of nonacute
        hazardous waste, 1 kg of acute hazardous waste,
        and 250 kg of soils, water, or  debris contaminated
        with acute hazardous waste.

    2)  The  quantity of each  sample shipment does not
        exceed these quantity limitations.

    3)  The sample is packaged so that it will not leak, spill,
        or vaporize from its packaging during shipment, and
        the transportation of each sample shipment complies
        with U.S. Department of Transportation (DOT),
        U.S. Postal Service (USPS), or any other applicable
        regulations for shipping hazardous materials.

    4)  The  sample is  shipped to a laboratory or testing
        facility that is exempt under 40  CFR 261.4(f) or that
        has an appropriate RCRA permit or interim status.

    5)  The generator or sample collector maintains copies
        of the shipping documents, the contract with the
        facility conducting the treatability study, and records
        showing compliance with the shipping limits for 3
        years after completion of the treatability study.

    6)  The generator provides the preceding documentation
        in its biennial report.

  Similarly, offsite laboratories or testing facilities (including
  mobile treatment units) are conditionally exempt from the
  treatment, storage, and permitting requirements (40 CFR
  Parts 264, 265, and 270) when conducting treatability
  studies [40 CFR 261.4(f)] provided that:

    1)  The facility notifies the Regional  Administrator or
        State  Director that it intends to conduct treatability
        studies.

    2)  The  laboratory  or testing facility has  an EPA
        identification number.

    3)  The quantity of "as received" hazardous waste that
        is subjected to initiation of treatment in all treatability
        studies in any single day is less than 250 kg.

    4)  The  quantity of "as  received"  hazardous waste
        stored at the facility does not exceed 1000 kg, which
        can  include 500 kg of  soils, water,  or debris
        contaminated with acute hazardous waste or 1 kg of
        acute hazardous waste.

    5)  No more than 90  days have elapsed  since the
        treatability study was completed, or no more than 1
      year has elapsed since the generator or sample
      collector shipped the sample to the laboratory  or
      testing facility.

  6)  The treatability study involves neither placement of
      hazardous  waste on the land nor open burning  of
      hazardous waste.

  7)  The facility maintains records showing compliance
      with the treatment rate  limits and the storage time
      and quantity limits for 3 years following completion
      of each study.

  8)  The facility keeps a copy of the treatability study
      contract and all shipping papers for 3 years after the
      completion date of each study.

  9)  The facility submits to the Regional Administrator or
      State Director  an annual  report  estimating the
      number of studies and  the amount of waste to be
      used in treatability studies during the current year
      and providing information on treatability  studies
      conducted during the preceding year.

  10) The facility determines whether any unused sample
      or residues generated by the treatability study are
      hazardous waste [unless they are returned to the
      sample   originator  under  the 40  CFR  261.4(e)
      exemption].

  11) The facility notifies the Regional Administrator or
      State Director when it is no longer planning  to
      conduct any treatability studies at the site.

Laboratories or testing facilities that perform bench-scale
tests generally meet the storage and treatment rate limits
outlined in the preceding items. Facilities not operating
within  these  limitations  are  subject  to  appropriate
regulation.


3.9.3   Residuals Management


Treatability  study  residuals   generated  at  an  offsite
laboratory or testing facility may be returned to the sample
originator  under the Federal  Treatability Study Sample
Exemption Rule (or equivalent State regulations) if the
storage time limits in 40 CFR 261.4(f) are not exceeded.
This includes any  unused sample or residues.  If the
exemption does not apply, the  disposal of treatability study
residuals is subject to appropriate regulation, including the
RCRA land disposal restrictions for contaminated soil and
debris   when  these   regulations  become  effective.
Treatability study re-
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  siduals managed offsite must be packaged, labeled, and
  manifested in accordance with 40 CFR Part 262 and
  applicable DOT regulations for hazardous materials under
  49 CFR Part 172.

  As discussed earlier, the Revised Off-Site Policy does not
  specifically exempt  the  transfer  of treatability  study
  residuals offsite for disposal; therefore, offsite treatment or
  disposal facilities that receive these wastes must be in
  compliance with the offsite requirements. The acceptability
  of a commercial facility for receiving CERCLA wastes
  can be determined by contacting the appropriate Regional
  Offsite Contact, as shown in Table 12.

       Table 12. Regional  Offsite Contacts for
      Determining Acceptability Of Commercial
       Facilities to Receive CERCLA Wastes3
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
Primary
contact/phone
Lin Hanifan
(617)573-5755
Gregory Zaccardi
(212)264-9504
Naomi Henry
(215)597-8338
Alan Antley
(404) 347-4450
Gertrude Matuschkovitz
(312)353-7921
Irish Brechlin
(214)655-6765
David Doyle
(913)236-2891
Felix Flechas
(303)293-1524
Diane Bodine
(415)744-2130
Al Odmark
(206)553-1886
Backup
contact/phone
Robin Biscaia
(61 7) 573-5754
Joe Golumbek
(21 2) 264-2638
John Gorman
(21 2) 264-2621
Rita Tate
(215)597-8175
Gregory Fraley
(404) 347-7603
Paul Dimock
(31 2) 886-4445
Randy Brown
(21 4) 655-6745
Marc Rivas
(91 3) 236-2891
Mike Gansecki
(303)293-1510
Terry Brown
(303)293-1823
Jane Diamond
(415)744-2139
Ron Lillich
(206) 553-6646
aThese contacts are subject to change.
  3.10   Executing the Study

  Execution of the treatability study begins after the project
  manager has approved the Work Plan and other supporting
  documents. Steps include collecting a sample of the waste
  stream for characterization and testing, conducting the test,
  and collecting and analyzing samples of the treated waste
  and residuals.
3.10.1  Field Sampling and Waste Stream
         Characterization

Field  samples should  be collected  and preserved in
accordance with the procedures outlines in the SAP. They
should be representative of either "average" or "worst-
case" conditions (as dictated by the test objectives), and
the  sample should be large enough to complete all of the
required tests and analyses in the event of some anomaly.
Collocated  field samples  also  should be  collected in
accordance with the QAPP. To the extent possible, field
sampling should be coordinated with other onsite activities
to minimize costs. Samples shipped to an offsite laboratory
for  testing  or analysis  must be packaged,  labeled,  and
shipped in  accordance  with  DOT,  USPS,  or other
applicable  shipping regulations  (see Subsection  3.9).  A
chain-of-custody record must accompany each sample
shipment.

The waste sample should be thoroughly mixed to ensure
that it is homogeneous. This permits a  comparison of
results under different test conditions.  Small-volume soil
samples can be mixed  with  a Hobart mixer, and large-
volume samples can be  mixed with a drum roller. Stones
and debris should be removed by screening. Care must be
exercised during these procedures to avoid contaminating
the  waste samples (or allowing volatiles to escape) and to
ensure effective homogenization.

Characterization samples should be collected  from the
same material that will be used in the performance of the
treatability  study.  Characterization  is  necessary  to
determine   the  chemical,  physical,  and/or  biological
properties exhibited by the waste stream so that the results
of the treatability study can be properly gauged.

3.10.2  Treatability Testing

The treatability study should be performed in accordance
with the test matrix and standard operating procedures
described in the Work Plan. Any deviations from the SOP
should be recorded  in the field or laboratory notebook.

The EPA or a qualified contractor should oversee testing
conducted by vendors and PRPs. Oversight activities were
discussed in Subsection  2.5.5.

3.10.3  Sampling and Analysis

Samples of the treated waste and process residuals (e.g.
off-gas, scrubber water, and ash for  incineration tests)
should be collected  in accordance with  the SAP. The SAP
speci-
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  fies  the location  and frequency  of sampling,  proper
  containers, sample  preservation techniques, and maximum
  holding times. Quality assurance/quality  control samples
  will be collected at the same time as the treatability study
  samples in accordance with the QAPP. All samples must
  be logged in the field or laboratory  notebook. Samples
  shipped to an offsite laboratory must be packaged, labeled,
  and shipped  in accordance with DOT,  USPS, or other
  applicable shipping regulations, and  a chain-of custody
  record must accompany each sample shipment.

  Treatability   study  samples  should  be  analyzed  in
  accordance  with  the methods specified  in the SAP.
  Normal sample turnaround time is 3 to 5 weeks for most
  analyses; the laboratory may charge a premium if results
  are required in less time.

  3.11    Analyzing and Interpreting the Data

  3.11.1    Data Analysis

  Upon completion of a treatability study, the data must be
  compiled and analyzed. The first goal of data analysis is to
  determine the quality of the data collected. All data should
  be   checked   to  assess  precision,   accuracy,   and
  completeness. Both testing and analytical error must be
  assessed to determine total error.  If the QA objectives
  specified in the QAPP have not been met,  the  project
  manager and the EPA Work Assignment Manager must
  determine the appropriate corrective action.

  Data are generally  summarized in tabular or graphic form.
  The  exact presentation of the data will depend  on the
  experimental design  and the  relationship between  the
  variables being compared. For data  presented graphically,
  independent  variables,  which  are  controlled  by  the
  experimenter, are  generally  plotted on  the  abscissa
  whereas dependent variables, which change in response to
  changing the independent variables,  are plotted  on the
  ordinate.  Examples  of  independent  variables are  pH,
  temperature,  reagent concentration,  and reaction time.
  Examples of dependent variables are removal efficiency
  and substrate utilization.

  For determining whether statistically significant differences
  in treatment  effectiveness exist between  two or more
  values of an independent variable, the use of analysis of
  variance  and  other  statistical  techniques  may   be
  appropriate. These  techniques can assist in identifying the
  most  cost-effective  combination  of parameters in  a
  treatment system  with multiple independent variables.
  Statistical analysis of treatability  study  data,  however,
  should only be
 performed when planned and budgeted for.

3.11.2    Data Interpretation/Pre-ROD

Interpretation of treatability study data must be based on
the test  objectives established prior to testing. Data
interpretation is an important part of the treatability study
report. Therefore, the contractor or other party performing
the study and preparing the report must fully understand
the study objectives and the role the results will play in
remedy screening,  selection,  or  implementation.  The
investigating  party, not  the  RPM, is responsible  for
interpreting the treatability study data.

The purpose of a pre-ROD treatability investigation is to
provide the  data  needed  for  a 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 alternatives on an equal basis during
the detailed analysis of alternatives.

The Work Plan  outlines the treatability  study's  test
objectives and describes how these objectives will be used
in the evaluation of the technology (i.e., remedy screening
or remedy selection). As discussed in Section 2, the 1990
revised NCP Section 300.430(c) 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 Section
121  (threshold criteria)  and the technical and policy
considerations that are important  in the selection of
remedial alternatives  (primary balancing criteria  and
modifying criteria). The nine RI/FS evaluation criteria are
as follows:

Threshold criteria:

  • Overall   protection  of  human   health  and  the
    environment
  • Compliance with ARARs

Primary balancing criteria:

  • Long-term effectiveness and permanence
  • Reduction of toxicity, mobility, and volume through
    treatment
  • Short-term effectiveness
  • Implementability
  • Cost

Modifying criteria:

  • State acceptance
  • Community acceptance
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  As discussed in the following subsections, treatability stud-
  ies provide important data for use in the assessment of an
  alternative against both the threshold criteria and the pri-
  mary balancing criteria. The results of treatability studies
  can also influence evaluations against the State and com-
  munity acceptance criteria. Figure 10 lists factors impor-
  tant to the analysis of the RI/FS evaluation criteria. These
  factors are often technology-specific, as are the treatability
  study  data  that  support the  analysis  of  each factor.
  Example 5 outlines some of the specific  analysis factors
  applicable to chemical dehalogenation treatment techn-
  ologies and several types  of data from a chemical dehalo-
  genation treatability study that provide information for each
  of these factors.

  Evaluations against the nine criteria are performed for the
  overall alternative, of which the treatment technology is
  only a part. The alternative will generally include additional,
  treatment, containment, or disposal technologies. Detailed
  guidance  on the  Superfund program's remedy-selection
  process as established in the  1990 revised NCP Section
  300.430(f) is available in the RI/FS  guidance and in  A
  Guide to  Selecting Superfund Remedial Actions (EPA
  1990b).

  Threshold Criteria

  The two statutory-based threshold criteria should be used
  to set treatability study  performance goals. Only  those
  alternatives that satisfy the threshold criteria are eligible for
  remedy selection.

  Overall Protection of Human Health and the Environment

  This evaluation criterion provides an overall assessment of
  how well  each alternative achieves and maintains protec-
  tion 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.  It will focus on the ability of an alternative
  to eliminate, reduce, or control overall site risks.

  Treatability studies will provide general data for the evalu-
  ation   under this criterion.  Target contaminant  con-
  centrations  in the treated product  and any  treatment
  residuals will demonstrate how well the process or treat-
  ment 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

  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. Treatability study performance
goals are generally based on ARARs. Performance data
indicating how well the process achieved these goals will
aid in evaluating the technology against the compliance
with ARARs criterion.

Chemical-specific ARARs are health or risk-based numer-
ical values or methodologies that,  when applied to site-
specific conditions, result in the establishment of maximum
acceptable amounts or concentrations of chemicals that
may be found in or discharged to the ambient environment.
For example,  chemical-specific ARARs  may  include
RCRA Land  Disposal Restrictions  (LDRs)   on the
placement  of treated  soil or  Safe Drinking  Water Act
Maximum Contaminant Levels (MCLs) and Clean Water
Act Water Quality Criteria for the treatment and discharge
of  wastewater.  Chemical-specific   ARARs  will  be
expressed in terms of contaminant concentrations in the
treated product and treatment residuals.  Often,  these
ARARs define the "target" contaminants for the treata-
bility study.

Location-specific ARARs are  restrictions placed on the
concentration of hazardous substances or the  conduct of
activities solely because they  are in a specific  location,
such as a floodplain, a  wetland, or a  historic place.
Location-specific  cleanup  criteria  may   include, for
example, biotoxicity requirements for treated product and
treatment residuals if runoff from the treatment area or the
disposal site could have an impact  on a sensitive wildlife
habitat.

Action-specific ARARs are technology- and activity-based
requirements or limitations on actions taken with respect to
hazardous wastes. Action-specific  requirements may be
particularly applicable to the discharge of residuals such as
wastewater.  Target  contaminant concentrations in the
treatability  study wastewater will aid in identifying action
specific ARARs.

The  actual determination of which requirements are
applicable or relevant and appropriate will be made by the
lead agency. Detailed guidance on determining whether
requirements are applicable or  relevant and appropriate is
provided in CERCLA  Compliance  with Other Laws
Manual:  Interim Final (EPA 1988c)  and CERCLA
Compliance with Other Laws Manual: Part  II (EPA
1989f).

Primary Balancing Criteria

The five primary balancing evaluation criteria should be
used for  guidance  in  setting treatability  study test
objectives.

Long-Term Effectiveness and Permanence

This evaluation criterion addresses  risks remaining at the
site after the remedial response objectives have been met.
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             Overall Protection of Human
             Health and the Environment
                                                  Compliance With ARARs
              How Alternative Provides
              Human Health and
              Environmental Protection
   Magnitude of
   Residual Risk
   Adequacy and
   Reliability of
   Controls
                                                   Compliance With
                                                   Chemical-Specific ARARs
                                                   Compliance With Action-
                                                   Specific ARARs
                                                   Compliance With
                                                   Location-Specific ARARs
                                                   Compliance With Other
                                                   Criteria, Advisories, and
                                                   Guidances
Long-Term
Effectiveness and
Permanence
Reduction of Toxicity,
Mobility, or Volume
Through Treatment
Short-Term
Effectiveness
Implementability
Cost
Treatment Process
Used and Materials
Treated
Amount of Hazardous
Materials Destroyed or
Treated
Degree of Expected
Reductions in Toxicity,
Mobility, and Volume
Degree to which
Treatment is Irreversible
Type and Quantity of
Residuals Remaining
After Treatment
Protection of
Community During
Remedial Actions
Protection of
Workers During
Remedial Actions
Environmental
I mpacts
Time Until Remedial
Response Objectives
Are Achieved
Ability to Construct
and Operate the
Technology
Reliability of the
Technology
Ease of Undertaking
Additional Remedial
Actions, If Necessary
Ability to Monitor
Effectiveness of
Remedy
Ability to Obtain
Approvals From
Other Agencies
Coordination With
Other Agencies
Availability of Offsite
Treatment, Storage,
and Disposal
Services and
Capacity
Availability of
Necessary
Equipment and
Specialists
Availability of
Prospective
Technologies
Capital Costs
Operating and
Maintenance
Costs
Present Worth
Cost
State
Acceptance*
Community
Acceptance*
* These criteria are assessed following comment on the RI/FS report and the proposed plan.

EPA1988a
      Figure 10.    Evaluation criteria and analysis factors for detailed analysis fo alternatives.
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   EXAMPLE 5. APPLICABILITY OF CHEMICAL DEHALOGENATION TREATABILITY STUDY DATA TO
                                       RI/FS EVALUATION CRITERIA
         Evaluation Criteria
        Analysis Factors
        Treatabillity 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
                              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
contamination 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   Time until remedial response
                              objectives are achieved
                                   Reaction time
     Implementability
Reliable and potential for schedule
delays
Reliability and schedule delays during
testing
Reaction time/throughout
Physical characteristics of waste matrix
Contaminant variability in untreated waste
     Cost
Direct capital costs
Reaction time/throughout
Reaction usage/recovery
Reaction temperature
Physical characteristics of waste matrix
Site characteristics
     Compliance with ARARs    Chemical-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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  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 (e.g.,
  containment systems) are to be used to manage these
  remaining  materials, their adequacy  and reliability also
  should be evaluated under this criterion.

  Remedy-selection treatability  studies  can  often  provide
  data on the site's post-remediation residual risk. If treated
  product will remain on  site, the contaminant concentrations
  in this material must meet the site's cleanup criteria. As
  discussed in Subsection 2.4, these cleanup criteria translate
  into specific performance goals. The concentrations  of
  target contaminants  in the treated product and treatment
  residuals after treatability testing indicate the magnitude of
  the site's residual risk  after treatment.

  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 treated  soils. If the literature
  contains   little   or   no   biotoxicity  data   on  the
  contaminants/matrix  of interest, this  data need can be
  addressed by performing bioassays at the remedy-selection
  tier. A  treatability study test objective that stipulates a
  reduction in the toxicity of the treated product to test
  organisms  will provide  data for the  assessment of the
  technology  against  the  long-term   effectiveness  and
  permanence criterion.

  Reduction of Toxicity, Mobility, and Volume Through
  Treatment

  This evaluation criterion addresses the statutory preference
  for  selecting   technologies   that   permanently  and
  significantly reduce the toxicity, mobility, or volume of the
  hazardous  substances.  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 the total volume  of
  contaminated media.

  Treatability studies should provide detailed performance
  data on the percentage, reduction in the toxicity, mobility,
  or  volume of  the  treated  product.  As  discussed  in
  Subsection 2.4,  a performance  goal  of greater than 50
  percent reduction in toxicity, mobility,  or volume may be
  appropriate  at   the   remedy-screening  tier.   If  this
  performance goal is met, the technology is considered to be
  potentially  feasible.  At the remedy-selection  tier, the
  process should be capable of achieving the site  cleanup
  criteria with an acceptable level  of  confidence.  If no
cleanup criteria have been established for the site, a 90
percent reduction  in contaminant  concentration  will
generally be an appropriate performance goal.

Another measure of reduction in toxicity is the comparison
of bioassay results from tests performed  on the waste
before and after treatment. If treated product is to remain
on site, a reduction in biotoxicity should be identified as a
treatability test objective for remedy-selection testing.

Irreversibility of the treatment process is another factor in
the evaluation of  a technology 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 approximate the contaminant
destruction efficiency of the treatment process.

Taking the treatment residuals into consideration is an
important  part of the assessment of a technology against
the reduction in toxicity, mobility, and volume criterion.
Concentrations of target contaminants in treatability study
residuals indicate the risks posed by onsite treatment and
disposal of the process residuals. Data on the biotoxicity
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. 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) 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  or volatile
contaminants  in  the waste also  could pose  risks to
community health during material handling and treatment.
Treatment residuals should be carefully  characterized to
assist in the  post-ROD design of proper air and water
treatment systems.
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  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.
  These data will aid in the assessment of any threats posed
  to workers  and the effectiveness and reliability of the
  protective measures to be taken. Treatability systems can
  also be monitored  for any adverse conditions that  may
  develop during testing.

  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.  Treatability  studies  of some
  technologies  will  generate  treatment   duration  data
  sufficient to allow estimates of throughput to be made.

  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 process of  designing  and
  performing treatability studies may assist in the analysis of
  the following implementability factors:

    • 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 most of the preceding factors. If an 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 may be required.

  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 treatment duration 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, can be investigated during a pre-ROD 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 Remedial Action Costing Procedures Manual
(EPA 1985).  The cost  estimate prepared  under  this
criterion will be based on information obtained from the
literature and from technology vendors. Preparation of the
estimate may also require  remedy-selection treatability
study data.

Direct capital costs for treatment will include expenditures
for the equipment, labor, and materials necessary to install
the system.  If  the  technology  vendor has  already
constructed a mobile, full-scale treatment unit, treatability
study   data will  not be  required to determine  direct
equipment  costs. If no full-scale system exists,  however,
treatability  studies can  provide  the  operational data
necessary for equipment scale-up. Characteristics  of the
matrix  identified  during treatability  testing,  such as
particle-size distribution and moisture content, will have an
impact on decisions regarding front-end material handling
operations  and equipment and post-treatment 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 treatability
study  sample-collection visit.

Estimates of utility costs, residuals treatment and disposal
costs,  and   O&M   costs  will   depend   on  the
physical/chemical characteristics  of the  waste  and
residuals (which affect the difficulty of treatment) and the
throughput (which affects the total time  for treatment).
These data are available from remedy-selection treatability
studies.
3.11.3   Data Interpretation/Post-ROD

As  opposed to pre-ROD treatability studies, no  clearly
defined criteria exist on which to base the interpretation of
post-ROD RD/RA treatability study results. The purpose
of an RD/RA treatability study is to  generate specific,
detailed design, cost,  and performance data. These data
are then used  1)  to  prequalify vendors  and processes
within the prescribed  remedy, 2) to implement the most
appropriate of
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  the remedies prescribed in a Contingency ROD, or 3) to
  support preparation of the  Agency's  detailed design
  specifications and the design of treatment trains.

  When an  RD/RA treatability study is performed to
  prequalify  vendors, data interpretation consists  of  a
  straightforward determination by the lead agency or the
  designer regarding  whether the vendor has attained the
  preset performance goals. Little  or no cost data are
  generated by prequalification treatability studies. 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.

  In the case of a Contingency ROD, implementation of the
  selected remedy may depend on the results of RD/RA
  treatability testing. Treatability  studies performed  to
  support a Contingency ROD  are designed to obtain
  performance and cost data on the selected remedy that
  were not available during the RI/FS. After this information
  is  obtained, data interpretation focuses  on determining
  whether the  selected  remedy  will provide  superior
  protection of human health and the environment at a cost
  comparable to that of the contingency remedy. If so, the
  selected remedy is  designed and implemented. If not, the
  contingency remedy is implemented.

  Post-ROD treatability study  results are  also  used to
  support the preparation of the detailed design specifications
  and the design of treatment trains. Because the treatability
  study is designed to provide specific detailed operations
  data  on the remedy for  use by the remedial design
  contractor, the designer is generally responsible for data
  interpretation.
  3.12   Reporting the Results
will  expedite  the  process  of  comparing  treatment
alternatives. It will also allow other individuals who may be
studying similar technologies or waste matrices to gain
valuable  insight into the applications  and  limitations of
various treatment processes.

If a treatment technology is to be tested at multiple tiers,
preparation of a formal report for each tier of the testing
may not be necessary. Interim reports prepared at the
completion of each tier may  suffice. Also, it  may  be
appropriate to conduct a project briefing with the interested
parties to present the study findings and to determine the
need for additional testing. A final report that encompasses
the entire study should be developed  after all testing is
complete.

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 ORD (EPA  1989e). This requirement
applies to both the removal and remedial programs of
Superfund.  Submitting  treatability   study  reports  in
accordance with the suggested organization will increase
the usability of this repository and assist in maintaining and
updating the data base. One camera-ready master copy of
each treatability study  report should be sent to the
following address:
    Mr. Glenn M. Shaul
    RREL Treatability Data Base
    U.S. Environmental Protection Agency
    Office of Research and Development
    Risk Reduction Engineering Laboratory
    26 W. Martin Luther King Drive
    Cincinnati, Ohio 45268
  3.12.1   General

  The final step in conducting a treatability study is reporting
  the test results. Complete and accurate reporting is critical,
  as  decisions  about treatment alternatives will be based
  partly on the outcome of the treatability studies. Besides
  assisting in the selection and implementation of the remedy,
  the performance of treatability studies  will increase the
  existing body of scientific knowledge  about treatment
  technologies.

  To facilitate the reporting of treatability study results and
  the exchange of treatment technology information, Table
  13 presents a suggested organization for a treatability study
  report. Reporting treatability study results in this manner
The  following subsections describe the contents or the
treatability study report.

Introduction

The  introductory section of the treatability study report
contains  background information about the site, waste
stream, and treatment technology. Much of this information
will come directly from the previously prepared treatability
study Work Plan. This section also includes a summary of
any treatability studies previously conducted at the site.

Conclusions and Recommendations

This section of the report presents the conclusions and
recommendations regarding the applicability of the treat-
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      Table 13.  Suggested Organization of
             Treatability Study Report

  1.  Introduction
      1.1   Site description
           1.1.1   Site name and location
           1.1.2   History of operations
           1.1.3   Prior removal  and remediation
                  activities
      1.2   Waste stream description
           1.2.1   Waste matrices
           1.2.2   Pollutants/chemicals
      1.3   Treatment technology description
           1.3.1   Treatment process and scale
           1.3.2   Operating features
      1.4   Previous treatability studies at the site
  2.  Conclusions and Recommendations
      2.1   Conclusions
      2.2   Recommendations
  3.  Treatability Study Approach
      3.1   Test objectives and rationale
      3.2   Experimental  design and procedures
      3.3   Equipment and materials
      3.4   Sampling and analysis
           3.4.1   Waste stream
           3.4.2   Treatment process
      3.5   Data management
      3.6   Deviations from the Work Plan
  4.  Results and Discussion
      4.1   Data analysis and interpretation
           4.1.1   Analysis of waste stream
                  characteristics
           4.1.2   Analysis of treatability  study data
           4.1.3   Comparison to test objectives
      4.2   Quality assurance/quality control
      4.3   Costs/schedule for performing the
           treatability study
      4.4   Key contacts
  References
  Appendices
  A.  Data summaries
  B.  Standard operating procedures
  ment process tested. It should attempt to answer questions
  such as the following:

      •  Were the performance goals met? Were the other
        test objectives achieved? If not, why not?

      •  Were there any problems with the treatability study
        design or procedures?
    • What parts of the test (if any) should have been
     performed differently? Why?

    • Are additional tiers of treatability testing required for
     further evaluation of the technology? Why or why
     not?

    • Are data sufficient for  adequately assessing the
     technology against the RI/FS evaluation criteria (if
     pre-ROD)?

    • Are data sufficient for designing and implementing
     the remedy (if post-ROD)?

The conclusions and recommendations  should be stated
briefly and succinctly. Information that is pertinent to the
discussion and exists elsewhere in the report should be
referenced rather than restated in this section.

This section should provide an analysis of the results as
they relate to the objectives of the study and the relevant
evaluation criteria. When appropriate, the results should be
extrapolated to full-scale  operation  to indicate areas of
uncertainty  in the  analysis   and the   extent of  this
uncertainty.

Treatability Study Approach

This section reports why and how the treatability study
was conducted. It describes in detail the procedures and
methods that were used to sample and analyze the waste
stream and documents any deviations from the Work Plan.
Like the introduction, this section contains information from
the previously prepared Work Plan.

Results and Discussion

The final section of the treatability study report includes the
presentation and  a  discussion  of results  (including
QA/QC). Results for the contaminants of concern should
be reported in terms of the concentration in the input and
output streams  and the percentage reduction in toxicity,
mobility, or  volume that was achieved. The use of charts
and graphs  may aid in the presentation of these results.
This section also includes the costs and time required to
conduct the study and any  key contacts  for  future
reference.

Appendices

Summaries  of the data  generated and the  standard
operating procedures used are included in appendices,

3.12.2   Remedy Screening

Remedy screening results will be  reported in the format
shown in Table 13; however, some of the sections may be
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  abbreviated if remedy-selection testing is planned. The
  conclusions and recommendations will focus primarily on
  whether the technology investigated is potentially feasible
  for the site and will attempt to identify critical parameters
  for future treatability testing. Data will be presented in
  simple tables or graphs. Statistical analysis is generally not
  required. Because  remedy screening does  not involve
  rigorous QA/QC, the discussion of this subject will  be
  brief.

  3.12.3   Remedy-Selection Testing

  Conclusions and recommendations resulting from remedy-
  selection testing will focus primarily on the technology's
  performance (i.e., ability to meet the performance goals
and test objectives) and will attempt to  identify  critical
parameters for future treatability testing,  if needed. A
detailed discussion of data quality should be included in the
results section. The results section  may also include a
statistical evaluation of the data.

3.12.4  RD/RA Testing

Conclusions and recommendations resulting from RD/RA
testing will focus on the technology's ability to achieve the
performance goals and test  objectives. Any process
optimization parameters that were identified should also be
discussed. The results  should include a detailed discussion
of data quality.
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                                            REFERENCES
  dePercin, P., E. Bates, and D. Smith.  1991. Designing
  Treatability Studies for CERCLA Sites: Three Critical
  Issues. J. Air Waste Manage. Assoc., 41(5):763-767.

  National  Institute  for  Occupational  Safety   and
  Health/Occupational   Safety   and   Health
  Administration/IIS.  Coast Guard/U.S.  Environmental
  Protection Agency. 1985. Occupational Safety and Health
  Guidance Manual  for Hazardous Waste Site Activities.
  DHHS (NIOSH) Publication No. 85-115.

  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 No. 9355.0-10.

  U.S.  Environmental  Protection Agency.  1986.  Test
  Methods for Evaluating Solid Waste. 3rd ed. SW-846.

  U.S. Environmental  Protection Agency.  1987a.  Data
  Quality  Objectives for Remedial Response Activities.
  Development Process (Volume I).  EPA/540/G-87/003,
  OSWER Directive 9355.0-7B.

  U.S.  Environmental  Protection  Agency.  1987b.   A
  Compendium  of Superfund Field Operations Methods.
  EPA/540/P-87/001.

  U.S. Environmental Protection Agency. 1987c. Revised
  Procedures for Implementing Off-Site Response Actions.
  OSWER Directive No. 9834.11, November 13, 1987.

  U.S. Environmental Protection Agency. 1988a. Guidance
  for Conducting Remedial Investigations and Feasibility
  Studies   Under   CERCLA.   Interim   Final.
  EPA/540/G-89/004. OSWER Directive 9355.3-01.
U.S. Environmental Protection Agency. 1988b. Community
Relations in  Superfund: A Handbook.  Interim Version.
EPA/540/G-88/002. OSWER Directive 9230.0-3B.

U.S. Environmental Protection Agency. 1988c. CERCLA
Compliance  with  Other Laws Manual:  Interim Final.
EPA/540/G-89/006.
U.S.  Environmental
Management  Review
EPA/540/8-89/007.
Protection   Agency.  1989a.
of  the  Superfund  Program.
U.S. Environmental Protection Agency. 1989b. Guide for
Conducting Treatability Studies Under CERCLA. Interim
Final. EPA/540/2-89/058.

U.S. Environmental  Protection  Agency. 1989c.  Model
Statement of Work  for a Remedial Investigation and
Feasibility Study Conducted by  Potentially  Responsible
Parties. OSWER Directive No. 9835.8, June 2, 1989.

U.S. Environmental Protection Agency. 1989d. Quality
Assurance Procedures for RREL.  RREL Document
Control No. RREL(QA)-001/89.

U.S. Environmental Protection Agency. 1989e. Treatability
Studies Contractor Work Assignments. Memo from Henry
L.  Longest,  II, Director, Office of  Emergency  and
Remedial Response, to Superfund Branch Chiefs, Regions
I through X. OSWER Directive 9380.3-01, July 12, 1989.

U.S. Environmental Protection Agency. 1989f CERCLA
Compliance with Other Laws Manual: Part II.  Clean Air
Act and  Other  Environmental  Statutes  and  State
Requirements. EPA/540/G-89/009. OSWERDirectiveNo.
9234.1-02.

U.S. Environmental Protection Agency. 1990a. Inventory
of  Treatability  Study Vendors,  Volumes I and  II.
EPA/540/2-90/003a and b.
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  U.S. Environmental Protection Agency. 1990b. A Guide to   U.S. Environmental Protection Agency. 1991b. Guidance
  Selecting Superfund Remedial Actions. OSWER Directive   on Oversight of Potentially Responsible Party Remedial
  9355.0-27FS.                                          Investigations   and  Feasibility  Studies.   Volume  1.
                                                        EPA/540/G-91/010a. OSWER Directive No. 9835. l(c).
  U.S. Environmental Protection Agency. 1991a.  Guidance
  for Increasing the Application of Innovative Treatment   U.S.   Environmental   Protection   Agency.   1991c.
  Technologies for Contaminated Soil and Ground Water.   Administrative  Order  on  Consent  for   Remedial
  OSWER Directive 9380.0-17, June 10, 1991.               Investigation/Feasibility Study.  OSWER  Directive No.
                                                        9835.3-2A, July 2, 1991.
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                                          APPENDIX A
                SOURCES  OF TREATABILITY  INFORMATION
  A wide range of technical resources exists within the EPA
  to assist in the planning and performance of treatability
  studies.  These resources include reports and guidance
  documents, electronic data bases, and Agency-sponsored
  technical support.  This appendix describes  the primary
  treatability study resources currently available.

  Reports and Guidance Documents

  Knowledge gained during the performance of treatability
  studies is available  in reports and technical guidance
  documents.  The following  documents can be used to
  identify technology-specific treatability resources.

      Superfund Treatability Clearinghouse Abstracts. U.S.
      Environmental   Protection   Agency,  Office  of
      Emergency and Remedial Response, Washington, DC.
      EPA/540/2-89/001, March 1989.

      Inventory of Treatability Study Vendors, Volumes  I
      and II. U.S. Environmental Protection Agency, Office
      of Emergency  and Remedial Response, Washington,
      DC. EPA/540/2-90/003a and b, February 1990.

      The Superfund  Innovative Technology  Evaluation
      Program:  Technology Profiles. U.S.  Environmental
      Protection  Agency,  Office  of Solid  Waste  and
      Emergency Response and Office of Research and
      Development, Washington, DC. EPA/540/5-90/006,
      November 1990.

      Guide to  Treatment Technologies  for  Hazardous
      Wastes  at Superfund  Sites.  U.S.  Environmental
      Protection  Agency,  Office  of Solid  Waste  and
      Emergency   Response,   Washington,   DC.
      EPA/540/2-89/052, March 1989.

      Treatability Potential for EPA Listed  Hazardous
      Wastes   in Soil.  U.S.  Environmental  Protection
      Agency, Office of Research and Development, Ada,
      OK. EPA/600/2-89/011, March 1989.
    Catalog of Superfund Program  Publications.  U.S.
    Environmental  Protection  Agency,   Office   of
    Emergency and Remedial Response, Washington, DC.
    EPA/540/8-90/015, October 1990.

Electronic Information Systems

Several electronic data bases and information systems are
available to Federal, State, and private sector personnel for
retrieving innovative technology and treatability data.

RREL   Treatability Data Base

Contact:  Glenn Shaul
         Risk Reduction Engineering Laboratory
         Office of Research and Development
         U.S. Environmental Protection Agency
         (513) 569-7408

Developed by the Risk Reduction Engineering Laboratory
(RREL), this data base provides data on the treatability of
contaminants in water, soil, debris,  sludge, and sediment.
Target users include Federal and State agencies, academia,
and the private sector. For each contaminant, the data base
provides physical/chemical properties and treatability data
such as technology types, matrices treated, study scale,
and treatment levels achieved. Each data set is referenced
and quality-coded based on the analytical methods used,
the  quality assurance/quality control efforts reported, and
operational information.

Version 4.0 of the data base is provided on a computer
diskette  free of charge. The menu-driven program is
compiled and does not require  specialized software.
Computer hardware and software requirements are as
follows:

    • IBM-compatible personal computer and monitor
    • 8-megabyte hard disk storage
    • 640-K RAM memory
    • DOS versions 2.0 to 3.3 or 5.0
    • 12-pitch printer
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  Requests for the data base must specify diskette format
  (3!/2HD, 5>/4HD, or DD).

  Alternative Treatment Technology
  Information Center

  Contact:   Greg Ondich
             Office of Environmental Engineering and
              Technology Demonstration
             U. S. Environmental Protection Agency
             (202) 260-5747
             System Operator
             (301) 670-6294
             System (online)
             (301) 670-3808

  The Alternative Treatment Technology Information Center
  (ATTIC) is a comprehensive information retrieval system
  containing up-to-date technical information on innovative
  methods for treatment of hazardous wastes. Designed for
  use by remediation personnel in the Federal, State, and
  private sectors,  ATTIC can be easily accessed free of
  charge through an online system or the system operator.

  The ATTIC system is a collection of hazardous waste data
  bases that  are accessed through  a bulletin  board. The
  bulletin board includes features such as news items, special
  interest  conferences (e.g., the Bioremediation Special
  Interest Group), and a message board that allows direct
  communications between  users  and  with the ATTIC
  System Operator (i.e., Chat Mode). Users can access any
  of four data bases: 1) the main ATTIC Data Base; 2) the
  RREL Treatability DataBase; 3) the Technical Assistance
  Directory, which identifies experts on a given technology
  or contaminant type; and 4) the Calendar of Events, which
  contains information on upcoming relevant conferences,
  seminars, and workshops.

  The main ATTIC Data Base contains abstracts of Federal,
  State, and private sector technical reports collected into a
  keyword searchable format. Technologies are grouped into
  five  categories:  1)  biological treatment,  2)  chemical
  treatment,    3)   physical   treatment,   4)
  solidification/stabilization, and 5) thermal treatment.

  In 1992, users of ATTIC will have online access to the
  Inventory of Treatability Study Vendors (ITSV) database.
  The  ITSV  will  aid in identifying vendors possessing
  qualifications to  perform specific types  of treatability
  studies  and will  supplement  the existing  two-volume,
  hard-copy publication  of the same name developed by
  RREL. The online version of the ITSV will give users the
  ability to screen the data base electronically and to review
  the  information by  each of three  main categories:
  technology, media, and contaminant group.
Users  can access  ATTIC  directly  with a  personal
computer  and  a  modem.  New users  can  register
themselves and assign their own password by calling the
ATTIC System. Communications software should be set
according to the following parameters prior to dialing:
     Baud Rate: 1200 or 2400
     Terminal Emulation: VT-100
     Data Bits: 8
     Stop Bits: 1
     Parity: None
     Duplex: Full
The  ATTIC User's Guide  is available by calling the
System Operator or leaving a message on the bulletin
board.

Computerized On-Line Information System
Contact:    Robert Hillger
           Risk Reduction Engineering Laboratory
           Office of Research and Development
           U.S. Environmental Protection Agency
           (908) 321-6639

           System Operator
           (908) 906-6851

           System (online)
           (908) 548-4636
The Computerized On-Line Information System (COLIS)
is operated by the Technical Information Exchange (TIX)
at the EPA's Risk Reduction Engineering Laboratory in
Edison,  New  Jersey.   A  consolidation  of several
computerized data bases, COLIS  currently contains the
following files:

   • Underground  Storage Tank  (UST) Case  History
     File-provides technical assistance to Federal, State,
     and local officials in responding to UST releases.

   • Library Search System-contains catalog cards and
     abstracts  for  technical documents in  the  TIX
     Library.

   • SITE  Applications  Analysis  Reports-provides
     performance and cost information on technologies
     evaluated  under   the   Superfund  Innovative
     Technology Evaluation (SITE) Program.

   • RREL Treatability Data Base

The system is menu-oriented, and online help is  available.
Federal, State,  and private sector personnel can access
COLIS free of charge by using a personal computer, a
modem, and a  communications program. The COLIS
User's  Guide  is  available  by contacting the System
Operator.
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  Vendor Information System for Innovative
  Treatment Technologies
  Contact:
VISITT Hotline
(800) 245-4505
  The Vendor Information System for Innovative Treatment
  Technologies (VISITT) is  an automated data base that
  provides information on innovative treatment technologies.
  The  data  base  contains  information  submitted  by
  developers and vendors of innovative treatment technology
  equipment  and services. Technologies to treat ground
  water in situ, soils, sludges, and sediments are included.

  Each vendor file in VISITT includes information on the
  vendor,   the  technology,  and   the   applicable
  contaminants/matrices.  Performance  data,  unit  costs,
  equipment availability, permits obtained, treatability study
  capabilities, and references may also be available for some
  vendors/technologies.

  The VISITT database is available on diskette and requires
  a personal computer using a DOS operating system. Future
  updates may be available on-line.


  Super-fund Technical Support Project

  Contact:    Marlene Suit
             Technology Innovation Office
             Office of Solid Waste and Emergency
              Response
             U.S. Environmental Protection Agency
             (703) 308-8800

  The  Office  of Solid Waste and  Emergency Response
  (OSWER),  Regional Superfund Offices, and the Office of
  Research and Development  (ORD)  established  the
  Superfund Technical Support Project (TSP) in 1987 to
  provide direct, technology-based assistance to the Regional
  Superfund  programs through  ORD  laboratories.  The
  project consists  of a network of Regional Technical
  Support  Forums,  five  specialized  Technical Support
  Centers (TSCs) located in ORD laboratories, and one TSC
  located at  the Office  of Emergency and Remedial
  Response (OERR) Environmental Response Branch. The
  objectives of the TSP are:

      • To provide state-of-the-science technical assistance
       to  Regional Remedial Project  Managers (RPMs)
       and On-Scene Coordinators (OSCs).

      • To improve communications among the Regions and
       the ORD laboratories.

      • To ensure coordination and consistency  in  the
       application of remedial technologies.
    • To   furnish   high-technology   demonstrations,
     workshops, and information to RPMs and OSCs.

    • To facilitate the evaluation  and application of
     alternative investigatory and remedial techniques at
     Superfund sites.

The  TSP is accessed by  contacting one of the TSC
Directors.  Any Regional staff member involved in  the
Superfund program can contact the Centers  directly or
with the assistance of a Forum member from their Region.
Additional information on the TSP is available in:

    Superfund  Technical   Support  Project:  Guide  for
    RPMs/OSCs. U.S. Environmental Protection Agency,
    Office  of  Solid Waste and Emergency Response,
    Technology Innovation  Office, Washington, DC.

Engineering Technical Support Center
                                             Contact:  Ben Blaney or Joan Colson
                                                      Risk Reduction Engineering Laboratory
                                                      Office of Research and Development
                                                      U.S. Environmental Protection Agency
                                                      (513) 569-7406
                                             One  of the TSCs is the Engineering Technical Support
                                             Center (ETSC)  located  at  ORD's RREL Technical
                                             Support Branch in Cincinnati, Ohio. The ETSC provides
                                             technical  assistance  for  reviewing  and  overseeing
                                             treatability work plans  and studies, feasibility  studies,
                                             sampling  plans, remedial designs, remedial actions, and
                                             traditional and innovative remediation technologies. Areas
                                             of expertise include treatment  of soils,  sludges,  and
                                             sediments; treatment of aqueous  and  organic  liquids;
                                             materials  handling and decontamination; and contaminant
                                             source control structures. The following are examples of
                                             the types of technical  assistance that  can be  obtained
                                             through the ETSC and the  RREL  Technical Support
                                             Branch:

                                                •  Characterization of a site for treatment technology
                                                   identification

                                                •  Performance  of  remedy-screening  treatability
                                                   studies  and  support  for  treatability  studies of
                                                   innovative technologies at all tiers of testing

                                                •  Review of treatability study RFPs, work plans, and
                                                   final reports

                                                •  Oversight  of treatability  studies performed by
                                                   contractors and PRPs

                                                •  Assistance  in  design  and  startup  of full-scale
                                                   systems
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  Treatability  study assistance  through  the Superfund
  Technical Assistance Response Team (START) discussed
  in Section 3.3 is also available through the ETSC contact
  listed here.
  Environmental Response Team Technical
  Support Center
  Contact:   Joseph LaForNara
             Environmental Response Branch
             Office of Emergency and Remedial
             Response
             U.S. Environmental Protection Agency
             (908) 321-6740
  The Environmental Response Team (ERT) TSC is located
  at the OERR Environmental Response Branch in Edison,
  New Jersey. The ERT provides technical expertise for the
  development and implementation of innovative treatment
  technologies through its Alternative Technology Section.
The following are examples of the types  of technical
assistance that can be obtained through the ERT:

   • Consultation  on  water  and  air quality  criteria,
     ecological risk assessment, and treatability study test
     objectives

   • Development and implementation of site-specific
     health and safety programs

   • Performance of in-house bench- and pilot-scale
     treatability  studies  of chemical,  physical,  and
     biological treatment technologies

   • Sampling and analysis of air, water, and soil

   • Provision of onsite analytical support

   • Oversight of treatability study performance

   • Interpretation and evaluation  of treatability study
     data
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                                           APPENDIX  B
                      COST  ELEMENTS ASSOCIATED  WITH
                                 TREATABILITY STUDIES
  Section 2 of this guide describes three tiers of treatability
  testing: remedy screening, remedy-selection testing, and
  remedial  design/remedial  action testing. This appendix
  presents the cost elements associated with the various tiers
  of treatability studies. In some  cases, unit  costs are
  provided; in other  cases,  project-specific  examples are
  provided that lend insight into the costs of various elements
  of treatability studies.

  Many  cost  elements  are  applicable  to   all  levels  of
  treatability testing;  however, some (e.g., the volume of
  residuals or cost of analytical services) will increase from
  remedy screening to remedy-selection testing to RD/RA
  testing. Other cost elements (e.g., site preparation and
  utilities) are only  applicable to RD/RA testing.  Figure 11
  shows the applicability of the various cost elements to the
  different  treatability  study  tiers.  The following  is  a
  discussion of some of the key cost elements.

  Vendor  equipment rental  is a key cost element in the
  performance  of  RD/RA  testing.  Most  vendors  have
  established daily, weekly, and monthly rates for the use of
  their treatment systems. These charges cover wear and
  tear on the system, utilities, maintenance and repair, and
  system preparation. In some cases, vendors include their
  operators, personal protective equipment, chemicals, and
  decontamination in the rental charge. Treatment system
  rental charges typically run about $5,000 to $20,000 per
  week. Also, if the vendor sets up a strict timetable for
  testing, the client may be billed $4000 to $5000 a day for
  each day the waste is late in arriving at the facility.

  Site preparation and logistics costs include costs associated
  with  planning  and  management,  site  design  and
  development, equipment and facilities, health and safety
  equipment, soil excavation, feed homogenization, and feed
  handling. Costs associated with the majority of  these
  activities are normally incurred only with RD/RA testing of
  mobile  field-scale units; however, some  of these cost
  elements (e.g., feed homogenization and health and safety)
  are  also   incurred   in   bench-   and  pilot-scale
  remedy-selection testing.
Analytical costs apply to all tiers of treatability studies and
have a significant impact on the total project costs. Several
factors affect the cost of the  analytical program, including
the laboratory performing the analyses, the analytical target
list, the number of samples, the required turnaround time,
QA/QC, and reporting. Analytical costs vary significantly
from laboratory to laboratory; however, before prices are
compared, the laboratories themselves should be properly
compared. The following are typical of questions that
should be asked:
    What methods will be used for sample preparation and
    analysis?

    What detection limits are needed?

    Does each laboratory fully understand the matrix that
    will be received (e.g., tarry sludge, oily soil, slag) or
    interference compounds that may be in the sample
    (e.g., sulfide)?
If all information indicates that the laboratories are using
the  same methods and equipment and  understand the
objectives of the analytical program, the costs for analysis
can be compared.

One should also be aware that some analytes cost more to
analyze than others. Often, the project manager would like
to investigate some analytes for informational purposes that
may not be critical to the study. The decision as to whether
to analyze for these parameters  could be simple if the
parameter-specific costs were known. For example, TOC
analysis of soil costs about $90/sample, whereas analysis
for total dioxins costs about $650/sample.

The number of samples, turnaround  time,  QA/QC, and
reporting also affect analytical costs. Laboratories often
give discounts on sample quantities greater than 5, greater
than 10, and greater than 20 when the samples arrive in the
laboratory at the same time. The laboratory also applies
premium costs of 25, 50, 100, and 200 percent when ana-
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                                                     61

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Cost Element
Labor
Testing
Equipment
Vendor Equipment
Rental
Field Instrumentation
and Monitors
Reagents
Site
Preparation
Utilities

Mobilization/
Demobilization

Permitting and
Regulatory

Health and
Safety
Sample
Transportation
Analytical
Services
Air Emission
Treatment
Effluent
Treatment
Decontamination
of Equipment
Residual
Transportation
Residual Treatment/
Disposal
Treatability Study Tier
Remedy
Screening
•
w
O
o
w
o
o

o

w



w


o
o
o
w
w
Remedy
Selection
•
•
O
o
w
o
£>

o

Q



^


Q
w
w
w
Q
RD/RA
•
•
•
•
•
•
^

•

0



•


•
•
•
•
•








^~^ Not applicable
f j and/or no cost
^-^ incurred.
^^ May be applicable
^j and/or Intermediate
^^ cost incurred.
^_ Applicable
^B and/or high cost
^^ incurred.









          Figure 11. General applicability of cost elements to various treatability study tiers.
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  lytical results  are  requested  faster than the  normal
  turnaround time. If  matrix  spike and  matrix spike
  duplicates are required, the analytical cost will triple for
  those QA/QC  samples. Also, whether the  laboratory
  provides a cover letter  with the attached data  or  a
  complete analytical report will affect the analytical costs.

  Residual transportation and disposal are also important
  elements that must be budgeted in the performance of all
  treatability studies.  Depending on the technology(ies)
  involved,  a number  of  residuals  will  be  generated.
  Partially treated effluent,  scrubber water, sludge,  ash,
  spent   filter   media,  scale,   and   decontamination
  liquids/solids  are examples of residuals that must be
  properly transported  and  treated  or disposed  of in
  accordance with all local, State, and Federal regulations.
  Unused feed and excess analytical
sample  material  also  must  be  properly  managed.
Typically, a laboratory will add a small fee (e.g., $5 per
sample) to dispose  of  any unused sample  material;
however, the unused raw material and residuals, which
could amount to a sizeable quantity  of material, will cost
significantly more to remove. Transportation cost  for a
dedicated truck (as opposed to a truck making a "milk
run") is about $3.25 to $3.75 per loaded mile.  Costs for
treatment of inorganic wastewaters  may range from $65
to  $200  per   55-gallon   drum.   Incineration   of
organic-contaminated wastewaters ranges from $200 to
$1000  per 55-gallon drum, and landfilling a  55-gallon
drum of inorganic solids could cost between $75 and
$200. Disposal facilities  also may have some associated
fees, surcharges, and other costs for minimum disposal,
waste approval, State and local taxes,  and stabilization.
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                                   APPENDIX C
                           TECHNOLOGY-SPECIFIC
                   CHARACTERIZATION  PARAMETERS
  The tables in Appendix C contain waste feed characterization parameters specific to biological, physical/chemical,
  immobilization, thermal, and in situ treatment technologies. Generally, these are the characterization parameters that must
  be established before a treatability test is conducted on the corresponding technology. Additional parameters may be
  required due to site-specific conditions.

  Each table is divided by technology, waste matrix, parameter, and purpose of analysis. These tables are designed to
  assist the RPM in planning a treatability study.
                                           65

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               Table 14.  Waste Feed Characterization Parameters for Biological Treatment
    Treatment
    Technology
       Matrix
          Parameter
Purpose
General
Soil/sludges
                  Liquids
Physical:
  Moisture content


  Temperature


  Oxygen availability


Chemical:
  PH
  Total organic carbon



  Redox potential



  C:N:P ratio

  Heavy metals


  Chlorides/inorganic salts


Biological:
  Soil biometry


  Respirometry
  Microbial identification and
  enumeration
  Microbial toxicity/growth
  inhibition
Chemical:
  PH

  Dissolved oxygen



  Chemical oxygen demand


Biological:
  Biological oxygen
  demand
  Respirometry

  Microbial identification and
  enumeration

  Microbial toxicity/growth
  inhibition
                                                                    To identify potential for microbial metabolism inhibition
                                                                    and need for pretreatment.
                                                                    To identify potential for microbial metabolism inhibition
                                                                    and need for pretreatment.
                                                                    To identify potential for microbial metabolism inhibition
                                                                    and need for pretreatment.
                                                                    To identify potential for microbial metabolism inhibition
                                                                    and need for pretreatment.
                                                                    To determine the need for possible organic carbon
                                                                    supplementation to support acceptable levels of
                                                                    biological activity.
                                                                    To determine potential for stimulating and/or enriching
                                                                    growth of indigenous aerobic, anoxic, sulfate reducing,
                                                                    and obligate anaerobic microbial populations.
                                                                    To determine mineral nutrient requirements.
                                                                    To identify potential for microbial metabolism inhibition
                                                                    and need for pretreatment.
                                                                    To identify potential for microbial metabolism inhibition
                                                                    and need for pretreatment.

                                                                    To determine biodegradation potential and to quantify
                                                                    biodegradation rates.
                                                                    To identify oxygen uptake and boidegratation rates.
                                                                    To determine the indigenouse or adapted microbial
                                                                    population densities in the inoculum.
                                                                    To determine microbial activity.
                                                                    To identify potential for microbial metabolism inhibition
                                                                    and need for pretreatment.
                                                                    To determine presence or absence of oxygen as a
                                                                    potential indicator, respectively, of the absence or
                                                                    presence of indigenous microbial activity.
                                                                    To determine total oxygen demand, both organic and
                                                                    inorganic, in the liquid matrix.

                                                                    To determine the fraction of the chemical oxygen
                                                                    demand that is aerobically degradable.
                                                                    To determine oxygen uptake and biodegradation rates.
                                                                    To determine the indigenous or adapted microbial
                                                                    population densities in the inoculum.
                                                                    To determine microbial activity.
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Table 15.  Waste Feed Characterization Parameters for Physical/Chemical Treatment
    Treatment
    Technology           Matrix                 Parameter                        Purpose and comments
 General
 Soils/sludges
 Extraction
 - Aqueous
 - Solvent
 - Critical fluid
 - Air/steam
 Soils/sludges
  Chemical
  dehalogenation
Soils/sludges
                  Liquids
Physical:
    Type, size of debris

    Dioxins/furans,
    radionuclides, asbestos
Physical:
    Particle size distribution
 Clay content
 Moisture content

Chemical:
    Organics


 Metals (total)


 Metals (leachable)

   Contaminant
   characteristics:
   •   Vapor pressure
   •   Solubility
      Henry's Law constant
      Partition coefficient
      Boiling point
   •   Specific gravity

   Total organic carbon,  humic
   acid
   Cation exchange capacity
   Chemical oxygen demand
   PH
   Cyandies, sulfides, fluorides

Biological:
   Biological oxygen
   demand
Physical:
   Moisture content
   Particle-size distribution
Chemical:
   Halogenated organics

   Metals


   pH/base absorption
   capacity
Chemical:
   Halogenated organics
                                                                   To determine need for pretreatment.

                                                                   To determine special waste-handling procedures.
                                                To determine volume reduction potential, pretreatment
                                                needs, solid/liquid separability.
                                                                   To determine adsorption characteristics of soil.
                                                                   To determine conductivity of air through soil.


                                                                   To determine concentration of target or interfering
                                                                   constituents,  pretreatment needs, extraction medium.

                                                                   To determine concentration of target or interfering
                                                                   constituents,  pretreatment needs, extraction medium.

                                                                   To determine mobility of target constituents,
                                                                   posttreatment needs.
                                                                   To aid in selection of extraction medium.
                                                                   To determine presence of organic matter, adsorption
                                                                   characteristics of soil.
                                                                   To determine adsorption characteristics of soil.
                                                                   To determine fouling potential.
                                                                   To determine pretreatment needs, extraction medium.
                                                                   To determine potential for generating toxic fumes at low
                                                                   pH.

                                                                   To determine fouling potential.
                                                To determine reagent formulation/loading.
                                                To determine experimental apparatus.

                                                To determine concentration of target constituents,
                                                reagent requirements.
                                                To determine concentration of other alkaline-reactive
                                                constituents, reagent requirements.

                                                To determine reagent formulation/loading.
                                                                   To determine concentration of target constituents,
                                                                   reagent requirements.
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Table 15.  (continued)
    Treatment
    Technology
       Matrix
          Parameter
Purpose and comments
Oxidation/
reduction
Soils/sludges
Flocculation/
sedimentation
Liquids
Carbon adsorption  Liquids
                  Gases
Ion
exchange
Liquids
Physical:
   Total suspended solids
Chemical:
   Chemical oxygen demand


   Metals (Cr+3, Hg, Pb, As)


   PH

Physical:
   Total suspended soils

Specific gravity of suspended
solids

Viscosity of liquid

Chemical:
   PH

   Oil and grease

Physical:
   Total suspended solids
                                     Chemical:
                                        Organics

                                        Oil and grease

                                     Biological:
                                        Microbial plate count
Physical:
   Particulates

Chemical:
   Volatile organic
   compounds, sulfur
   compounds, mercury

Physical:
   Total dissolved solids

Total suspended solids

Chemical:
   Inorganic cations and anions,
   phenols

   Oil and grease
                                                  To determine the need for slurrying to aid mixing.

                                                  To determine the presence of oxidizable organic
                                                  matter, reagent requirements.
                                                  To determine the presence of constitutions that could
                                                  be oxidized to more toxic or mobile forms.

                                                  To determine potential chemical interferences.
                                                  To determine reagent requirements.

                                                  To determine settling velocity of suspended solids.

                                                  To determine settling velocity of suspended solids.


                                                  To aid in selection of flocculating agent.

                                                  To determine need for emulsifying agents, oil/water
                                                  separation.

                                                  To determine need for pretreatmentto prevent
                                                  clogging.

                                                  To determine concentration of target constituents,
                                                  carbon loading rate.

                                                  To determine need for pretreatmentto prevent
                                                  clogging.

                                                  To determine potential for biodegradation of adsorbed
                                                  organics and/or problems due to clogging or odor
                                                  generation.
                                                                   To determine need for pretreatmentto prevent
                                                                   clogging.

                                                                   To determine concentration of target constituents,
                                                                   carbon loading rate.
                                                  To determine concentration of target constituents,
                                                  carbon loading rate.
                                                  To determine need for pretreatmentto prevent
                                                  clogging.

                                                  To determine concentration of target constituents.


                                                  To determine need for pretreatmentto prevent
                                                  clogging.	
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Table 15.  (continued)
    Treatment
    Technology
       Matrix
                              Parameter
                                             Purpose and comments
Reverse osmosis  Liquids
Liquid/liquid
extraction
Liquid
Oil/water
separation
Liquids
Air/steam stripping Liquids
Filtration
Liquids
                    Physical:
                      Total suspended solids
Chemical:
   Metal ions, organics

   PH
   Residual chlorine

Biological:
   Microbial plate count
Physical:
   Solubility, specific gravity
Chemical:
   Contaminant
   characteristics:
   •  Solubility
   •  Partition coefficient
   •  Boiling point
Physical:
   Viscosity
   Specific gravity

   Settleable solids

   Temperature
Chemical:
   Oil and grease
   Organics
Chemical:
   Hardness

   Volatile organic compounds
   Contaminant
   characteristic:
  •  Solubility
  •  Vapor pressure
  •  Henry's Law constant
  •  Boiling point
  •  Mass transfer coefficient
  Chemical oxygen demand
Biological:
  Biological oxygen
  demand

Physical:
  Total suspended solids

Total dissolved  solids
                                                                    To determine need for pretreatment to prevent plugging
                                                                    of membrane.
To determine concentration of target constituents.

To evaluate chemical resistance of membrane.

To evaluate chemical resistance of membrane.

To determine potential of biological growth outside
membrane that would cause plugging.

To determine miscibility of solvent and liquid waste.

To aid in selection of solvent, separation of phases,
etc.
To determine separability of phases.
To determine separability of phases/emulsions.

To determine amount of residual solids.
To determine rise rate of oil globules.

To determine concentration of target constituents.
To determine need for posttreatment.

To determine potential for scale formation.

To determine concentration of target constituents.
To determine strippability of contaminants, size of
units, and need for posttreatment.

To determine stripping factor.

To determine packing height.

To determine fouling potential.

To determine fouling potential.


To determine need for pretreatment to prevent
clogging.

To determine need for posttreatment.
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Table 15. (continued)
    Treatment
    Technology
       Matrix
          Parameter
              Purpose and comments
Dissolved air
flotation
Liquids
Neutralization
Liquids
Precipitation
Liquids
Oxidation (alkaline  Liquids
chlorination)
Reduction
Hydrolysis
Liquids
Liquids
Physical:
  Total suspended solids
  Specific gravity

Chemical:
  Oil and grease

  Volatile organic
  compounds

Chemical:
  Ph
  Metals
Acidity/alkalinity

Cyanides, sulfides, fluorides

Chemical:
  metals
  PH


  Organics, cyanides

Chemical:
  cyanides


  PH

  Organics

  Redox potential
Chemical:
  Metals (Cr+6, Hg, Pb)

Chemical:
  Organics
                                       PH
To determine amount of residual sludge.
To determine separability of phases.


To determine concentration of target constituents.

To determine need for air emission controls,
posttreatment.


To determine reagent requirements.
To determine need for posttreatment.
To determine reagent requirements.

To determine potential for generating toxic fumes at low
pH.

To determine concentration of target constituents,
reagent requirements.

To determine solubility of metal precipitates, reagent
requirements.

To determine concentration of interfering constituents,
reagent requirements.

To determine concentration of target constituents,
reagent requirements.

To determine suitable reaction conditions.

To determine potential for forming hazardous
compounds with excess chlorine (oxidizing agent).
To determine reaction success.

To determine concentration of target constituents,
reagent requirements.

To determine concentration of target constituents,
reagent requirements, posttreatment needs.

To determine reagent requirements.
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                   Table 16. Waste Feed Characterization Parameters for Immobilization
    Treatment
    Technology
       Matrix
          Parameter
              Purpose and comments
Stabilization/
solidification
Soils/sludges
Vitrification
Soils/sludges
Physical:
  Description of materials
                                       Particle-size analysis
                                       Moisture content
                                       Density testing
                                                 To determine waste handling methods (e.g., crusher,
                                                 shredder, removal equipment).

                                                 To determine surface area available for binder contact
                                                 and leaching.

                                                 To determine amount of waste to add/remove in S/S
                                                 mixing process.
                                                 To evaluate changes in density between untreated and
                                                 treated waste and to determine volume increase
                                       Weight ratio additives to waste  To determine effects of dilution due to volume increase.
                                     Chemical:
                                       Total organic content

                                       PH
                                                 To determine reagent requirements.
                                       Alkalinity
                                       Interfering compounds
  Indicator compounds
  Leach testing
  •  TCLP

  •  TCLP-water

  Heat of hydration

  Total waste analysis
Physical:
  Depth of contamination and
  water table
  Soil permeability


  Metal content of waste material
  and placement of metals within
  the waste

  Combustible liquid/solid
  content of waste
  Rubble content of waste

  Void volumes

  Moisture content
  Particle-size analysis

Chemical:
  Leach testing
 Total waste analysis	
To evaluate changes in leaching as function of pH
between untreated and treated waste.

To evaluate changes in leaching as function of
alkalinity between untreated and treated waste.

To evaluate viability of S/S process. (Interfering
compounds are those that impede fixation reactions,
cause adverse chemical reactions, generate excessive
heat; interfering compounds vary with type of S/S).

To evaluate performance.

To evaluate performance based on regulatory test.

To evaluate performance under natural conditions.

To measure temperature changes during mixing.

To evaluate performance.

Technology is applied in unsaturated soils.

Dewatering of saturated soils may be possible.
Technology is applied in unsaturated soils.
Greater the 5 to 15% by weight or significant amounts
of metal near electrodes interfere with process.


Greater than 5 to 15% by weight interferes with process
(may ignite).
Greater than 10 to 20% by weight interferes with
process
large, individual voids (greaterthan 150 ft3) impede
process, may cause subsidence.
To determine power requirements.
To determine surface area available for binder contact
and leaching.

To evaluate performance.
To evaluate performance.	
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                Table 17. Waste Feed Characterization Parameters for Thermal Treatment
    Treatment
    technology
       Matrix
          Parameter
               Purpose and comments
General
Soils/sludges
                 Liquids
Physical:
  Moisture content

  Ash content
                                       Ash fusion temperature


                                       Heat value

                                     Chemical:
                                       Volatile organics,
                                       semivolatile organics

                                       Principal organic hazardous
                                       constituents
                                       Total halogens


                                       Total sulfur, total nitrogen


                                       Phosphorus
                                       PCBs and dioxins (if
                                       suspected)
                                       Metals
                   Physical:
                     Viscosity
                     Total solids content
                     Particle-size  distribution  of
                     solid phases
                     Heat value

                   Chemical:
                     Volatile organics,
                     semivolatile organics

                     Principal organic
                     hazardous constituents
                     Total halogens
                                     Total sulfur, total nitrogen

                                       Phosphorus

                                       PCBs, dioxins (if suspected)
 Affects heat value and material handling.

 To determine the amount of ash that must be disposed
 or treated further.
 High temperature can cause slagging problems with
 inorganic salts having low melting points.

 To determine auxiliary fuel requirements and feed
 rates.

 Allows determination of principal organic hazardous
 constituents.

 Allows determination of destruction and removal
 efficiency.
 To determine air pollution control devices for control of
 acid gases.

 Emissions of SOX and Nox are  regulated; to determine
 air pollution devices.

 Organic phosphorus compounds may contribute to
 refractory attack and slagging  problems.

 99.9999% destruction and removal efficiency required
 for PCBs; safety considerations; incineration is
 required if greater than 500 ppm PCBs present.

 Volatile metals (Hg, Pb, Cd, Zn, As, Sn) may require
 flue-gas treatment; other metals may concentrate in
 ash.
 Trivalent chromium may be oxidized to hexavalent
 chromium,  which is more toxic. Presence of inorganic
 alkali salts, especially potassium and sodium sulfate,
 can cause  slagging. Determine posttreatment needs.

 Waste must be pumpable and atomizable.

Affects pumpable and heat transfer.
 Affects pumpable and heat transfer.

 Determine  auxiliary fuel requirements and feeds rates.
                              Allows determine of principal ad removal constituents.


                              Allows determine of destruction and removal efficiency

                              To determine air pollution control devices for control of
                              acid gases. Chlorine could contribute to formation of
                              dioxins.
                              Emissions of Sox and Nox are regulated; to determine
                              air pollution devices.
                              Organic phosphorus compounds may contribute to
                              refractory attack and slagging problems.
                              99.9999% destruction and removal efficiency required
                              for PCBs; safety considerations; incineration is
                              required if greater than 500 ppm PCBs  present.	
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Table 17. (continued)
    Treatment
    Technology
       Matrix
          Parameter
               Purpose and comments
General (cont.)
Liquids
Metals
 Volatile metals (Hg, Pb, Cd, Zn, As, Sn) may require
 flue-gas treatment; other metals may concentrate in
 ash. Trivalent chromium may be oxidized to hexavalent
 chromium, which is more toxic. Presence sodium
 sulfate, can cause slagging. Determine posttreamtent
 needs.
Rotary kiln
Soils/sludges
                  Debris
Physical:
  Particle-size distribution
                    Physical:
                      Amount, description of
                      materials
                               Fine particle size results in high particulate loading and
                               slagging. Large particle size may present feeding
                               problems.

                               Oversized debris presents handling problems and kiln
                               refractory loss.
Fluidized-bed      Soils/sludges
Thermal
desorption
Soils/sludges
                      Presence of spherical or
                      cylindrical wastes

                    Physical:
                      Ash fusion temperature
  Ash content

  Bulk density

Physical:
  Moisture content

Particle-size distribution

Chemical:
  PH
  Volatile organic
  contaminants

  Volatile metals


  Nonvolatile metals
                                                                    Spherical or cylindrical waste can roll through kiln
                                                                    before combusting.
 For materials with a melting point less than 1600°F,
 particles melt and become sticky at high temperatures,
 which causes defluidization of the bed.
 Ash contents greater than 65% can foul the bed.

 As density increases, particle size must be decreased
 for sufficient heat transfer.

 Affects heating and materials handling.

 Large particles result in poor performance. Fine silt or
 clay generate fugitive dusts.

 Very high or very low pH waste may corrode equipment.

 To determine concentration of target constituents,
 posttreatment needs.

 To determine concentration of target constituents,
 posttreatment needs.

To determine posttreatment needs.
                  Liquids
                                       Total chlorine
                     Total organic content

                    Physical:
                      Total solids content
                              Presence of chlorine can affect volatilization of some
                               metals.

                             Limited to ~ 10 percent or less.
                                                                    Minimum of 23-30 percent solids required.
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                      Table 18. Waste Feed Characterization Parameters for In Situ Treatment
    Treatment
    Technology
       Matrix
           Parameter
              Purpose and comments
Vapor extraction    Soils/sludges
-Vacuum extraction
-Steam-enhanced
-Hot-air-enhanced
Solidification/
stabilization
(undisturbed)
-Pozzolanic
-Polymerization
-Precipitation
Soils/sludges
Physical:
  Vapor pressure of
  contaminants

  Soil permeability, porosity,
  particle-size distribution
  Depth of contamination and
  water table
Physical:
  presence of subsurface
  barriers (e.g., drums, large
  objects, debris, geologic
  formations)
                                                    To estimates ease of Volatilization.
To determine if the soil matrix will allow adequate air
and fluid movement.
To determine relative distance; technology applicable
in vadosezone.

To assess the feasibility of adequately delivering and
mixing the S/S agents.
                      Depth to first confining layer     To determine required depth of treatment.
Soil flushing       Soils/sludges
-Stream/hot water
-Surfactant
-Solvent
Vitrification
Soils/sludges
Electrokinetics     Soils/sludges
Microbial
degradation
-Aerobic
-Anaereobic
Soils/sludges
Soils/sludges
Adsorption (trench) Soils/sludges
Physical:
  Presences of subsurface
  barriers (e.g., drums, large
  objects, debris, geologic
  formations)
  Hydraulic conductivity
  Moisture content (for vadose
  zone)
  Soil/water partition coefficient

  Octanol/water partition
  coefficient
  Cation exchange capacity
  Alkalinity soil
Chemical:
  major cations/anions present
  in soil
Physical:
  Depth of contamination and
  water table
Physical:
  Hydraulic conductivity

  Depth to water table
Chemical:
  Presence  of soluble metal
  contaminants
Physical:
  Permeability of soil

Chemical/biological:
  Contaminant concentration and
  toxicity
Chemical/biological:
  Contaminant concentration and
  toxicity
Physical:
  Depth of contamination and
  water table

  Horizontal hydraulic flow rate
                                                    To assess the feasibility of adequately delivering the
                                                    flushing solution.
To assess permeability of the soils.
To calculate pore volume to determine rate of
treatment.
To assess removal efficiency and to correlate
between filed and theoretical calculations.
To assess removal efficiency and correlates between
filed and theoretical calculations.
To evaluate potential for contaminant flushing.
To estimate the likelihood of precipitation.

To estimate the likelihood of precipitation; to estimate
potential for plugging of pore volumes.

Technology is only applied in the unsaturated zone.
Technology applicable in zones of low hydraulic
conductivity.
Technology applicable in saturated soils.

Technology applicable to soluble metals, but not
organics and insoluble.

To determine ability to deliver nutrients or oxygen to
matrix and to allow movement of microbes.
To determine viability of microbial population in the
contaminated zone.
                                                    To determine viability of microbial population in the
                                                    contaminated zone.

                                                    Technology applicable in saturated zone.
                                                                      To determine if ground water will come into contact
                                                                      with adsorbent.
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