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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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
designerAlternative 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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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,
Weeks
3
5
4
1
3
1
4
1
2
3
2
8
Weeks from Project Start
1
2
M
i
1
;
"i
3
1k
f ^
4
-2
w
5
4
6
M
1
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!
7
-3
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9
M'-4
10
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^f
11
i
12
W
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13
-6
r . .
14
{ABJBBIBl' "^
1
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i"
i-
i
Mi
15
i
16
17
M-B
^^
i
18
19
K
20
)U
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21
jo
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22
m
r
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23
-
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24
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25
26
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27
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r
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28
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M-17
30
31
M-1 4
m
32
33
M-15
"T"
M-18
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34
M-16
"1
M-19
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.
36
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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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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.
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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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Environmental Protection Agency
Center for Environmental Research Information
Cincinnati, OH 45268
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