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-92/074A
September 1992
4»EPA   Guide for Conducting
          Treatability Studies under
          CERCLA:  Thermal
          Desorption Remedy
          Interim Guidance
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                                                           EPA/540/R-92/074 A
                                                             September 1992
      GUIDE FOR CONDUCTING TREATABILITY STUDIES
           UNDER CERCLA: THERMAL DESORPTION
                        REMEDY SELECTION
                      INTERIM     GUIDANCE
                        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, D.C. 20460
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                                       DISCLAIMER
                             The information in this document has been funded
                             wholly or in part by  the U.S. Environmental
                             Protection Agency  (EPA) under Contract No.
                             68-C8-0062, Work Assignment 3-46, to Science
                             Applications International Corporation (SAIC). It
                             has been subjected to the Agency's peer and
                             administrative reviews and it has been approved
                             for publication as an EPA document. 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 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 primary purpose  of this  guide is to provide standard guidance
                        for designing and implementing a thermal  desorption treatability
                        study in support of remedy  selection. Additionally, it  describes a
                        three-tiered  approach, that  consists  of 1) remedy  screening, 2)
                        remedy selection, and 3) remedy design to thermal  desorption
                        treatability  testing.  It also presents  a guide  for conducting
                        treatability  studies in a systematic  and stepwise fashion for
                        determination  of the effectiveness  of thermal desorption (in
                        conjunction with other treatment technologies) in remediating a
                        CERCLA site.  The intended audience for this guide comprises
                        Remedial Project  Managers  (RPMs),  On-Scene  Coordinators
                        (OSCs),  Potentially  Responsible Parties  (PRPs), consultants,
                        contractors, and technology  vendors.
                                                            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 remedial investigation/feasibility
                        study  (RI/FS) process and the remedial design/remedial action
                        (RD/RA)  process  under  the Comprehensive  Environmental
                        Response, Compensation, and Liability Act (CERCLA). These
                        studies provide valuable site-specific data necessary to aid in the
                        selection and implementation of the remedy. This manual focuses
                        on thermal desorption treatability studies conducted in support of
                        remedy selection prior to developing the Record of Decision.

                        This   manual presents  a  standard  guide for  designing  and
                        implementing a thermal desorption remedy selection  treatability
                        study. The manual presents a description of and discusses the
                        applicability and limitations of thermal desorption technologies and
                        defines the  prescreening  and field  measurement  needed to
                        determine if treatability testing is required. It also presents an
                        overview of the process of conducting treatability tests and the
                        applicability of tiered treatability  testing for evaluating thermal
                        desorption technologies. The specific goals for each tier of testing
                        are defined and performance levels are presented that define which
                        levels  should be met before  additional tests are conducted at the
                        next tier. The elements of a treatability study work plan are also
                        defined with detailed discussions on the design and execution of the
                        remedy screening and remedy selection treatability studies.

                        The  manual  is  not intended to  serve as  a  substitute for
                        communication with experts or regulators nor as the sole basis for
                        the selection of thermal desorption as a particular remediation
                        technology. Thermal desorption must be used in conjunction with
                        other  treatment technologies since it generates residuals.  This
                        manual is designed to be used in conjunction with the Guide for
                        Conducting Treatability Studies Under CERCLA (Interim Final).(28)
                        The intended audience for this  guide comprises Remedial Project
                        Managers (RPMs), On-Scene  Coordinators (OSCs),  Potentially
                        Responsible  Parties  (PRPs),  consultants,  contractors,   and
                        technology vendors.
                                                    IV
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                                   TABLE OF CONTENTS
      Section                                                                                           Paa
      DISCLAIMER 	11
      FOREWORD 	111
      ABSTRACT	iv
      FIGURES	vi
      TABLES  	 vii
      ACKNOWLEDGMENT  	viu

  1.   Introduction	1
      1.1  Background 	1
      1.2  Purpose and Scope of this Manual  	1
      1.3  Intended Audience	1
      1.4  Use of This Guide	2

  2.   Technology Description and Preliminary Screening	3
      2.1  Technology Description  	3
      2.2  Preliminary Screening and Technology Limitations  	5

  3.   The Use of Treatability Studies in Remedy Evaluation	11
      3.1  The Process of Treatability Testing  in Selecting a Remedy	11
      3.2  Application of Treatability Tests 	11

  4.   Treatability Study Work Plan  	17
      4.1  Test Goals	17
      4.2  Experimental Design	18
      4.3  Equipment and Materials  	24
      4.4  Sampling and Analysis	24
      4.5  Data Analysis and Interpretation	25
      4.6  Reports 	26
      4.7  Schedule	26
      4.8  Management and Staffing	27
      4.9  Budget	 27

  5.   Sampling and Analysis Plan 	29
      5.1  Field Sampling Plan	29
      5.2  Quality Assurance Project Plan 	29

  6.   Treatability Data Interpretation	33
      6.1  Technology Evaluation 	33
      6.2  Estimation of Costs	36

  7.   References 	37
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                                              FIGURES
  Number                                                                                             Page

  2-1    Schematic Diagram of Thermal Desorption	4


  3-1    Flow Diagram of the Tiered Approach	12


  3-2    TheRoleof Treatability Studies in the RI/FS and RD/RA Process	13


  4-1    Cut-a-way view of Static Tray Test Oven With the Tray Insert  	20


  4-2    Cut-a-way View of the Differential Bed Reactor (DBR) Assembly  	20


  4-3    Example Project Schedule for a Thermal Desorption Treatability Study Program	26


  4-4    Organizational Chart	27
                                                     VI
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                                                TABLES
  Number                                                                                               Page

  2-1   Effectiveness of Thermal Desorption on General Contaminant Groups
        for Soil, Sludge, Sediments, and Filter Cakes 	7


  2-2   Key Prescreening Characteristics for Thermal Desorption Treatability Testing	 9


  4-1   Suggested Organization of Thermal Desorption Treatability Study Work Plan	 17


  4-2   Analyses Required in Remedy Selection Testing 	24


  4-3   Major Cost Elements Associated with Remedy Selection Thermal Desorption Studies	28


  5-1   Suggested Organization of Sampling and Analysis Plan	 30
                                                      VII
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                                   ACKNOWLEDGMENTS
                         This  document was prepared for the U.S. Environmental Protection
                         Agency,  Office  of Research  and  Development, Risk  Reduction
                         Engineering Laboratory (RREL), Cincinnati, Ohio, by Science Applications
                         International Corporation (SAIC), under Contract No. 68-C8-0062. Mr.
                         Mark Meckes served as the EPA Technical Project Monitor. Mr. Jim Rawe
                         was SAIC's Work Assignment Manager. Mr. Gary Baker and Ms. Peggy
                         Groeberof SAIC were the primary technical authors, and the project team
                         included Mr.  Torn Wagner and Mr. Michael Giordano of SAIC. Mr. Clyde
                         Dial served as SAIC's Senior Reviewer. The authors are especially grateful
                         to Mr. Paul de Percin, Ms. PatLafomara, and Mr. Jim Yezzi of EPA, RREL;
                         Dr. JoAnn Lighty of the University of Utah; and Mr. Bill Troxler and Mr.
                         Jim Cudahy of Focus Environmental who contributed significantly by
                         serving  as technical  consultants  during the  development  of this
                         document.

                         The following Agency and Contractor personnel have contributed their
                         time and comments by participating in the technical workshop and/or peer
                         reviewing the draft document:
                         George Sullivan
                         George Chedsey
                         Carl Swanstrom
                         Ed Alperin
                         Mark McCabe
                         David Linz
                         Sardar Hassan
                         Brian Home
                         Vic Cundy
                         G.F. Kroneberger
                         Rodney Hodgson
                         Harsh Dev
                         Mike Cosmos
                         Tom Scelfo
                         Brett Burgess
                         Joe Tessitore
                         Charles Quinlan
                         Lynton Dicks
                         Chetan Trivedi
                         Hilda Teodoro
                         Michael Anderson
                         Bob Cygnarowicz
                         Andre P. Zownir
                         Michelle Simon
                         Richard Lauch
Recycling Sciences
Soil Remediation Co.
Chemical Waste Management, Inc.
IT Corporation
ReTec
Gas Research Institute
University of Cincinnati
Southdown Thermal Dynamics
Louisiana State University
Komline-Sanderson
Hazen Research
IIT Research Institute
Weston
Wehran Engineering Corp.
Harmon Environmental
Cross-Tessitore & Assoc.
KSE, Inc.
Shell Development
Canonie/SoilTech
In-Process Technology
Weston
Weston
U.S. EPA,ERT
U.S. EPA, RREL
U.S. EPA, RREL
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                                                      VIII

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                                                 SECTION 1
                                              INTRODUCTION
   1.1     BACKGROUND

   Section 121 (b) of the Comprehensive Environmental Response,
   Compensation, and Liability Act (CERCLA) mandates EPA to
   select  remedies  that  "utilize permanent solutions  and
   alternative treatment technologies  or resource recovery
   technologies to the maximumextent practicable" and to prefer
   remedial actions in which treatment that "permanently reduces
   the volume, toxicity, or mobility of hazardous  substances,
   pollutants, and  contaminants is  a  principal element."
   Treatability studies provide  data  to support treatment
   technology selection and remedy implementation. If treatability
   studies are used, they should be performed as soon as it is
   evident that insufficient information is available to ensure the
   quality of the decision. Conducting treatability studies early in
   the remedial investigation/feasibility study (RI/FS)  process
   reduces uncertainties associated with selecting the remedy
   and provides a sound basis for the Record of Decision(ROD).
   EPA Regional planning should factor in the time and resources
   required for these studies.

   Treatability studies conducted during the RI/F S phase indicate
   whether the technology can meet the cleanup goals for the
   site, whereas  treatability  studies  conducted during  the
   remedial design/remedial action  (RD/RA) phase establish
   design  and  operating  parameters  for   optimization of
   technology performance. Although the purpose and scope of
   these  studies differ, they complement one  another  since
   information obtained in support of remedy selection may also
   be used to support the remedy design.(38)

   This document refers to three  levels or tiers of treatability
   studies:  remedy  screening, remedy  selection, and  remedy
   design. Three tiers of treatability studies are also defined in the
   Guide  for Conducting Treatability Studies Under CERCLA,
   Interim Final/28' referred to as the "generic guide" hereafter in
   this document. The generic guide refers to the three treatability
   study  tiers, based largely on  the scale of test equipment
   described as laboratory screening, bench-scale testing, and
   pilot-scale testing. Laboratory screening is typically used to
   screen potential remedial technologies and is equivalent to
   remedy screening. Bench-scale testing is typically used for
   remedy selection, but may fall short of providing information
   for remedy selection. However, bench-scale studies can, in
   some cases, provide enough information for full-scale design.
   Pilot-scale studies are normally  used for remedial design, but
   may be required for remedy selection in some cases due to the
complexity of equipment needed for some processes. Because
of the over lap between these tiers, and because of differences
in the applicability of each tier to different technologies, the
functional description of treatability study tiers (i.e., remedy
screening, remedy selection, and remedy  design) has been
chosen for this document.

The need for and the level of treatability testing required are
management decisions.  Some or all of the levels may  be
needed on a case-by-case basis. The time-and cost necessary
to perform the testing  are balanced against the improved
confidence  in  the  selection  and  design of  treatment
alternatives.  These decisions are based on the quantity and
quality of data available and on other factors (e.g., state and
community acceptance  of the remedy, new site data,  or
experience with the technology). Section 3 discusses using
treatability studies in remedy selection in greater detail.

1.2     PURPOSE AND SCOPE

This guide helps ensure  a reliable and consistent approach in
evaluating whether thermal desorption should be considered
for site remediation.   This  guide  discusses  the  remedy
screening and remedy selection levels of treatability testing.
Remedy screening studies provide a quick and relatively
inexpensive  indication  of whether thermal desorption is  a
potentially viable remedial technology. The remedy selection
treatability test provides data to help determine if reductions
in contaminant  concentrations will allow cost-effective
treatment of residual contamination to meet site cleanup goals.
Remedy selection studies also provide a preliminary estimate
of the cost and performance data necessary to scope either a
remedy design study or a full-scale thermal desorption system.
In general, remedy design studies will also be required to
determine if thermal desorption is a viable treatment alternative
for a site by providing detailed cost and operating parameters
acceptable for scale-up.

1.3     INTENDED AUDIENCE

Intended use  of this  document is by  Remedial Project
Managers (RPMs), On-Scene Coordinators (OSCs), Potentially
Responsible  Parties (PRPs), consultants, contractors, and
technology vendors. Each has different roles in conducting
treatability studies under CERCLA. Specific responsibilities for
each can be found in the generic guide/28'
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   1.4     USE OF THIS GUIDE

   This guide is organized into seven sections, which reflect the
   basic information required to perform  treatability  studies
   during the RI/FS process. Section 1 is an introduction which
   provides background information on the role of the guide and
   outlines its intended audience. Section 2 describes different
   thermal  desorption  processes  currently  available   and
   discusses how to conduct a preliminary screening to determine
   if thermal desorption  is a potentially  viable remediation
   technology. Section 3 provides an overview of the different
   levels of treatability testing and discusses how to determine
   the need for treatability studies. Section 4  provides an
   overview of the  remedy  screening and remedy selection
   treatability studies, describes the contents of a typical work
   plan, and discusses the major issues  to  consider when
   conducting a treatability study. Section 5 discusses sampling
   and analysis and quality assurance project plans. Section 6
   explains how to interpret the data produced from treatability
   studies and how to determine if further remedy design testing
   is justified. Section 7 lists the references.
This guide,  along with guides being developed for other
technologies, is  a  companion document to the  generic
guide.1-28-1 In  an effort to  avoid redundancy,  supporting
information in the generic guide and other readily available
guidance documents is not repeated in this document.

The document is not  intended to serve as a substitute for
communication with regulators and/or experts in the field of
thermal desorption. This document should never be the sole
basis for the selection  of thermal desorption as a remediation
technology  or  the  exclusion of thermal desorption  from
consideration.

As  treatability study experience is gained, EPA anticipates
further comment and possible revisions to the document. For
this reason,  EPA encourages constructive comments  from
outside sources. Direct written comments to:

        Mr. Paul de Percin
        U. S. Environmental Protection Agency
        Office of Research  and Development
        Risk Reduction Engineering Laboratory
        26 W. Martin  Luther King Drive
        Cincinnati, Ohio 45268
        (513) 569-7797
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                                                SECTION 2
                             TECHNOLOGY DESCRIPTION AND
                                    PRELIMINARY SCREENING
  This section presents a description of thermal desorption
  systems that can be used for remediation of Superfund sites.
  Subsection 2.1  describes  the technology and the types of
  residual  streams  produced.  Subsection  2.2  discusses
  recommended literature and database searches, the technical
  assistance available, and the review of field data required to
  prescreen the thermal desorption technology. Also presented
  in this subsection are the major limitations and considerations
  imposed by application of the technology to a Superfund site.

  2.1     TECHNOLOGY DESCRIPTION

  This subsection presents  a description of the  principle of
  operation forthe technology, an overview of the current status
  of application of thermal desorption at Superfund sites, general
  materials  handling and preparation requirements, a focused
  discussion on the major configurations of thermal desorbers,
  and a brief discussion of the type of residuals produced. Four
  types of desorption units are described: rotary dryers, thermal
  screws, vapor extractors, and distillation chambers.

  Additional information on thermal desorption  systems are
  described in an EPA Engineering  Bulletin/26' The bulletin
  provides  information on  the technology applicability at
  Superfund sites, limitations, the types of residuals  produced,
  the latest performance data, site requirements (for full-scale
  operation), the status of the technology and sources of further
  information. This bulletin should be consulted for an overview
  of the status of the technology.

  Thermal desorption in this guide is limited to any number of ex
  situ processes that use either direct or indirect heat exchange
  to vaporize organic  contaminants from soil or  sludge. Air,
  combustion gas, or inert gas is used as the transfer medium for
  the vaporized components. Thermal desorption systems are
  physical  separation  processes  and  are  not  specifically
  designed  to  provide  organic  decomposition.  Thermal
  desorption is not incineration, since the decomposition of
  organic contaminants is not the desired result, although some
  decomposition may occur. The concentration of contaminants
  and the specific cleanup levels for the site will influence the
  technology's applicability for that site.  System performance is
  typically  measured by comparison of untreated soil/sludge
  contaminant levels with those of the processed soil/sludge.
  For the purpose of clarity and brevity  in this report, the term
  medium will refer to contaminated soil, sludge,  sediment, or
combinations of these. The medium is typically heated to a
target temperature of 200 to 1,000  °F based on the thermal
desorption system, selected, although certain systems operate
at higher temperatures. An important operating  design
parameter is time-at-temperature, which is defined as the
elapsed time that the average medium temperature is at or
above the target temperature. Figure 2-1 is a general schematic
of the thermal desorption process.1-26-1

Thermal  desorption is most applicable for separation of
organic  contaminants  from soils or  sludges. Thermal
desorption units have been selected in the Record of Decision
for  one or more operable units  at approximately fourteen
Superfund sites.(19)(26)(33) These sites include: McKin (Maine),
Ottati & Goss (New  Hampshire), Cannon Engineering
(Massachusetts), Resolve (Massachusetts), WideBeach (New
York), Fulton-Terminals (New York), Metaltec/Aerosystems
(New Jersey),  Caldwell Trucking (New Jersey),  Outboard
Marine/Waukegan Harbor (Illinois), Reich Farms (New Jersey),
Waldick Aerospace Devices (New Jersey), Wamchem (South
Carolina), and two Stauffer Chemical sites in Alabama.

If a site is contaminated with organics, thermal desorption
offers the advantage of separating the contaminant from the
medium to an offgas stream where the vapors are either treated
directly or condensed before treatment. Vapor or liquid phase
treatment includes: carbon  adsorption, catalytic or thermal
oxidation, condensation, and/or chemical neutralization. The
total volume of chemicals requiring subsequent treatment is
typically small  in comparison to the volume of contaminated
medium at any  given site. Thermal desorption may be viewed
as a step in the  sequence of remediating a site where isolating
and concentrating the contaminants is useful. The technology
must be used in concert with other treatment technologies
since its purpose  is  simply  the  physical  separation  of
contaminants from the mediuni-21).

Groups of organic contaminants can be selectively removed
from  the  medium by careful  control of the treatment
temperature in the desorption unit. Knowing how  vapor
pressure varies as a function of temperature for specific
contaminants is important in evaluating the applicability of a
particular thermal desorption  system.  Medium type, the
interaction between contaminant and medium (i.e., adsorption),
moisture content, thermal properties of contaminant mixtures,
and contamination
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             Excavate
Material
Handling
                                                       Desorption
                                                                               Gas Treatment
                                                                                  System
                                                                 Residuals
                                              Oversized Rejects
                                               Treated
                                               Medium
                                  Figure 2-1. Schematic diagram of thermal desorption.
  levels are also important design considerations in determining
  if thermal desorption is applicable at a specific site.

  All thermal  desorption  systems require excavation  and
  transport  of  the  contaminated  medium,  using  material
  handling/classification equipment and feeding of the into the
  desorption  unit. Excavation  is material accomplished by
  backhoe,  front-end  loader,  or similar equipment.  Belt
  conveyors  are typically used  to transfer the medium from a
  hopperto vibratory screens (or similar device) to remove large
  objects such as rock,  glass,  and metal from the  medium.
  Consolidated media larger than about 38 mm (1.5 inches) on
  any edge are  typically rejected. These large objects may
  restrict the passages in some desorption units and can result
  in uneven heating  of the media. If the rejected objects are
  contaminated, they may  be crushed and fed  through the
  desorption unit. If they  are not processed by the thermal
  desorption system, they should be containerized and sampled
  so that subsequent treatment, if required, can be selected. The
  larger  rejects, such as oversized gravel, cobbles, and boulders,
  may be amenable to soil washing techniques before  they are
  returned to the site. Additionally, some soil types may tightly
  agglomerate and require  milling or  shearing operations to
  prepare the medium for thermal desorption equipment. This
  problem should be  identifiable during the excavation process
  or during the remedy screening or remedy selection testing.
  The classified medium  is conveyed,  via  belt or  screw
  conveyors, to a feed  hopper and then metered.  into the
  desorber.

  Precautions to minimize fugitive dust (particulates) and volatile
  releases may be required  during excavation  and transport of
  contaminated medium.  These methods include consideration
  of weather conditions during  excavation (e.g., high winds),
  aerodynamic considerations (e.g., excavating on a still side of
  a hill or behind a  windscreen), application  of foams, water
  sprays, organic/inorganic control agents, synthetic covers, or
  by simply minimizing the  surface area of waste exposed to the
  air. The most sensitive  sites may require physical enclosures
  and independent dust/vapor  controls over  the  excavation,
                          classification, and feed systems. In addition, real time air
                          monitoring can be employed in some situations to minimize air
                          impacts.

                          Significant variation exists in the configuration and operation
                          of thermal desorption units. Volatilization of the contaminants
                          can be effected by use of a rotary dryer, thermal screw, vapor
                          extractor, or distillation chamber. The following subsection
                          presents a description of these basic systems.

                          2.1.1  Full-Scale Thermal Desorption  Units

                          Rotary Dryer
                          Rotary dryers are horizontal cylinders which can be indirect -
                          or direct-fired. The dryer is normally inclined and capable of
                          being rotated. The dryer rotates as the contaminated medium
                          is metered into it. Turning vanes or lifters inside the dryer drum
                          pick up the medium and move it in the dryer where it is heated.
                          In  direct-fired  units, hot  gases  are  produced  by  the
                          combustion of fossil fuel (natural gas, fuel oil, propane) and
                          directed through the dryer by use of a blower or induced draft
                          fan. The hot gases may flow in the  same or in an opposite
                          direction  with  the  contaminated  medium  (co-current  or
                          countercurrent). In indirect-fired units, the hot gases  are
                          created in a separate  firing section so the medium does not
                          directly contact the flame. A typical indirect-fired unit would
                          consist of an outer furnace which is heated and a rotating
                          inner drum containing the contaminated medium. The inner
                          drum rotates inside of the furnace. The medium is primarily
                          heated by  direct contact with the drum and by radiation from
                          the drum walls.

                          The heat  exchange  between the medium  and hot  gases
                          (direct-fired) or between the medium and the walls of the rotary
                          dry er (indirect-fired) volatilizes water and certain contaminants.
                          The specific  contaminants separated by the process are a
                          function of the time-temperature history in the dryer and
                          moisture  content  of  the  medium. Residence time in  the
                          desorber unit is carefully controlled
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  by the angle of inclination of the dryer, its rotational speed,
  and  the arrangement  of the turning  vanes. The ability to
  rapidly  exchange  heat permits  relatively high medium
  processing rates. Vendor data  indicate full-scale units can
  process 5 to 55 tons per hour (TPH).(4)

  Thermal Screw
  Screw conveyers or hollow augers are used to transport the
  medium continuously through an enclosed trough. Hot oil or
  steam circulate through the conveyor or auger, although
  molten salts  have been used  in limited applications, to
  indirectly  heat the medium. A heat  transfer  fluid is also
  pumped through the walls of the trough for additional heat
  transfer.

  One, two, or four augers may be arranged in a trough to
  provide mixing in the process of heating and conveying the
  medium. More than one trough system can be configured in
  series to achieve the  bed temperature and  residence time
  desired. A clean sweep gas (such as  nitrogen or steam) is
  typically  used to convey the vaporized contaminants and
  water from the trough(s). The sweep gas also may be used to
  ensure contaminants are not oxidized by reducing the source
  of oxygen. The maximum medium-bed temperature is limited by
  the thermal properties of the heat transfer fluid and the
  materials used to construct the equipment. It is also dependent
  on the speed of conveyance of the medium  through the
  trough(s) and the operating temperature of the heat transfer
  fluid. Advantages  of this type of desorption unit include
  simplicity of  operation and temperature control as well as
  reduced fines or dust generation. Equipment  capacity can
  rangefrom3tol3TPH.(20)

  Vapor Extractor
  A vapor extraction  system  mixes  hot gases  and the
  contaminated medium to volatilize the contaminants. Classified
  material is fed continuously into the unit on a belt conveyor
  where it contacts a hot gas stream (1,000-1,500 °F) generated
  in a fossil fuel-fired air heater. Hot gases are injected into the
  unit  through a series of gas jets at a rate sufficient to fluidize
  the feed material. Blades or rollers turn the medium as it is
  being fluidized by the hot gas to provide effective medium/gas
  contact. The hot gas (320 °F) flows out of the unit to the gas
  treatment section while the treated medium is removed from the
  bottom of the unit.  One vendor specifies portable plant system
  capacities of 10 to 73 TPH.(20)

  Distillation  Chamber
  Distillation chambers are a series  of cylinders  that are
  externally heated to  a specific temperature.  Contaminated
  medium is introduced into the first of a series of chambers (3
  to 5 total)  of  increasing temperature.  This  allows the
  vaporization,  condensation,  and  recovery  of  specific
  contaminants from each  distillation  zone in  a segregated
  fashion. A nitrogen sweep gas is used to transport the
  volatilized contaminants and prevents oxidation as a system of
  annular augers conveys the medium through each chamber.
  The entire system is sealed and operated at negative pressure
  until the segregated effluents leave the system.  The capacity
  of this type of system is 1 to 17 TPH(4). The system may be
  operated  in  an "oxygen-free"  environment,  and  effect
  pyrolysis, or cracking of organics.
2.1.2  Offgas Treatment

All thermal  desorption systems share the requirement for
treatment of residuals and offgas produced by the unit. Since
the treated medium is typically dry, less than one percent
moisture, spraying and mixing with clean water will suppress
dust generation.

Offgas from a thermal desorption unit will contain entrained
dust (particulates) from the medium, vaporized contaminants,
and water vapor. Particulates are removed by conventional
equipment such as cyclone dust collectors, fabric filters, or wet
scrubbers. Collected particulates may be recycled through the
thermal desorption unit or blended with the treated medium,
depending on the amount of carryover contamination present.

The vaporized organic contaminants can be  captured by
condensing the offgas and then passing it through a carbon
adsorption bed or other treatment system. Emissions may also
be destroyed by use of an offgas combustion chamber or a
catalytic oxidation unit.

When offgas is condensed, the resulting water stream may
contain significant contamination depending on the boiling
points and solubility of the contaminants and may require
further treatment (i.e., carbon adsorption). If the condensed
water is relatively clean, it may be used to suppress the dust
from the treated  medium. If carbon adsorption is used to
remove contaminants from the offgas or condensed water,
spent  carbon will be generated, which is either returned to the
supplier for  reactivation/incineration or regenerated onsite.
When offgas  is  destroyed  by  a  combustion process,
compliance with incineration emission standards may be
required. Obtaining the necessary permits and demonstrating
compliance  may  be advantageous,  however,  since the
incineration  process would not leave residuals  requiring
further treatment. If incineration is used, the heat from the
incineration process may be used in the desorption process
unit.

2.2     PRELIMINARY SCREENING AND
        TECHNOLOGY LIMITATIONS

The determination of the need for and the appropriate level of
treatability  studies  required  is  dependent  on  available
literature, expert technical judgment, and site specific factors.
The first two elements - the literature search and expert
consultation - are critical factors in determining if adequate
data are available or whether a treatability study is needed to
provide those data.

2.2.1   Literature/Database Review

Several reports and electronic databases exist which should be
consulted to assist in planning and conducting treatability
studies and to help prescreen thermal desorption for use at a
specific lite. Existing reports include:

•   Guide  for   Conducting   Treatability  Studies  Under
    CERCLA, Interim Final. U.S. Environmental Protection
    Agency, Office of Research and
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      Development and Office of Emergency  and Remedial
      Response,  Washington,   D.C.  EPA/540/2-89/058,
      December 1989.

  •   Guidance for Conducting Remedial Investigations and
      Feasibility Studies Under CERCLA, Interim Final. U.S.
      Environmental Protection Agency, Office of Emergency
      and  Remedial   Response,  Washington,  D.C.
      EPA/540/2-89/001, March 1989.

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

  •   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, D.C.  EPA/540/5-91/008, November 1991
      (updated annually).

  •   Summary  of Treatment  Technology Effectiveness for
      Contaminated   Soil.  U.S.  Environmental  Protection
      Agency, Office of Emergency and Remedial Response,
      Washington, D.C., EPA/540/8-89/053,1989.

  •   Technology Screening Guide for Treatment of CERCLA
      Soils and Sludges. U.S. Environmental Protection Agency.
      EPA/540/2-88/004, September 1988.

  RREL  in  Cincinnati is currently expanding  its  Superfund
  Treatability  Database.  This  database  contains  data from
  treatability studies conducted under CERCLA. A repository
  for the treatability study reports will be maintained at RREL in
  Cincinnati. The contact for  this database is Glenn Shaul
  (513)569-7408.

  The Office of Solid Waste and Energy Response (OSWER)
  maintains the Cleanup Information (CLU-IN) Bulletin Board
  System as a tool for communicating ideas,  disseminating
  information, and as a gateway  for other OSW  electronic
  databases. Currently, CLU-INhas eight different components,
  including  news  and mail services, and  conferences  and
  publications on specific technical areas. The contact is Dan
  Powell at (703)308-8827.

  ORD  headquarters  maintains  the Alternative  Treatment
  Technology  Information  Center  (ATTIC),  which  is  a
  compendium of information from many available  data bases.
  The EPA contact for ATTIC is Joyce Perdek at (908) 321-4380.
  Data  relevant to  the use   of  treatment technologies  in
  Superfund actions are collected and stored in ATTIC. ATTIC
  can  be accessed  through  the  RCRA/CERCLA Hotline
  (800-424-9346) or CLU-IN. ATTIC serves as a mechanism for
  searching  other information systems and databases  and
  integrates the information into a response to a query.  It also
  includes a pointer sy stem to refer the user to individual experts
  in EPA. The system is  currently made up of technical
  summaries from SITE program abstracts, treatment technology
  demonstration  projects,  industrial project  results,  and
  international program data. For more information, contact the
  ATTIC System Operator at  (301)670-6294,  or  access the
  database via modem by calling (301)670-3808.
2.2.2 Technical Assistance

Technical assistance can be obtained from the Technical
Support Project (TSP) team which is made up of six Technical
Support Centers and two Technical Support Forums. It is a
joint service of OSWER, ORD, and the Regions. The TSP
offers direct site-specific technical  assistance to OSCs and
RPMs and develops technology workshops, issue papers, and
other information for Regional staff. The TSP:

•   Reviews  contractor  work plans, evaluates remedial
    alternatives, reviews RI/FS, assists in selection  and
    design of final remedy

•   Offers modeling assistance  and data  analysis  and
    interpretation

•   Assists in developing and evaluating sampling plans

•   Conducts  field studies (soil  gas, hydrogeology,  site
    characterization)

•   Develops technical workshops and training, issue papers
    on groundwater topics, generic protocols

•   Assists in performance of treatability studies

The following support center provides technical information
and advice related to treatability studies:

    Engineering Technical Support Center (ETSC)
    Risk Reduction Engineering Laboratory (RREL)
    Cincinnati, OH 45268

    Contact: Ben Blaney
            (513) 569-7406

The Engineering Technical Support Center is sponsored by
OSWER  but operated  by RREL.  The  Center  handles
site-specific remediation engineering problems. Access to this
support center must be obtained through the EPA remedial
project manager.

RREL  offers  expertise  in  contaminant  source  control
structures; materials handling and decontamination; treatment
of soils, sludges and sediments; and treatment of aqueous and
organic liquids. The following are examples of the technical
assistance that can be obtained through the ETSC:

•   Screening of treatment alternatives

•   Review of the treatability aspects of RI/F S

•   Oversight of RI/FS treatability studies

•   Evaluation of alternative remedies

•   Assistance with studies of innovative technologies

•   Assistance in full-scale design and start-up

The  following program provides technical  advice  and
information on air impacts due to remediation.

    Air/Superfund Coordination Program
    Office of Air Quality Planning and Standards
    Research Triangle Park, NC 27711

    Contact: Joseph Padgett
            (919) 541-5589
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   The Air/Superfund Coordination program is designed to help
   RPM's design ways to mitigate air impacts at Superfund sites,
   provide Air Office liaisons to Regional Superfund Offices, and
   provide technical assistance and recommendations.

   The Air/Superfund Coordination Program offers:

       Direct  support:  site  evaluation,  remedy  selection,
       modeling assistance, monitoring air pollution control
       devices

   •    Support services: inter-program coordination, training,
       resolution of inter-program issues

   •    National Technical Guidance Studies (NTGS) to improve
       quality  and consistency  of  procedures  and  data
       collection. NTGS reports cover baseline air emissions, air
       emissions from remediation, modeling and  monitoring
       protocols,   air  pathway   analysis  procedures,  and
       remediation field support procedures.

   2.2.3   Prescreening Characteristics

   Prescreening activities for the thermal desorption treatability
   testing include interpreting any available site related field
   measurement data. The purpose of prescreening is to gain
   enough information to eliminate from further treatability testing
   any treatment technologies  which have little  chance  of
   achieving the cleanup goals.

   The applicability of thermal desorption for general contaminant
   groups for soil, sludge, sediments, and filter cakes is shown in
   Table 2-l.(26) The process is applicable for the separation of
   organics from refinery wastes, coal-tar wastes, wood-treating
   wastes, creosote-contaminated soils, pesticide-contaminated
   soils,   mixed   (radioactive   and  hazardous)  wastes,
   synthetic-rubber processing wastes, and paint wastes. PX23^24)

   If contamination exists at different medium zones, a medium
   characterization profile should be developed for each medium
   type or zone. Available chemical and physical data (including
   averages and ranges) and the volumes of the contaminated
   medium requiring treatment should be identified. For "hot
   spots", separate characterizations should be done so they can
   be properly addressed in the treatability tests if quantities are
   such that  blending will not provide  a homogeneous feed
   stream. Thermal desorption may be applicable to some parts of
   a site, but not to other parts.

   Characterization test samples should be broadly representative
   of the medium profile of the site. Grab samples taken from the
   site ground surface may represent only a small percentage of
   the  contaminated  medium requiring  remediation. Deeper,
   subsurface strata affected by contaminants may vary widely
   in composition (soil classification, total organic carbon, and
   contamination levels) from those found at the surface, and
   should also be characterized so that the fractions of volatile
   organic  compounds  (VOCs)  and semivolatile  organic
   compounds (S VOCs) can be identified as to their location and
   concentration. The quantity and distribution of rubble and
   debris  at the site should also be determined as part of the
   characterization process. This material may have to
     Table 2-1. Effectiveness of Thermal Desorption on
          General Contaminant Groups for Soil,
           Sludge, Sediments, and Filter Cakes

Contaminant Croups




V
1
«









i!
I
Halogenated volatile:
Halogenated semivolatiles
Nonhalogenated volatile!
Nonhalogenated semivolatiles
PCBs
Pesticides
Dloxins/Furans
Organic cyanides
Organic corrosives
Volatile metals
Nonvolatile metals
Asbestos
Radioactive materials
Inorganic corrosives
Inorganic cyanides
Oxidteers
Reducers
ttfectlveneu
Sett- fitter
SoH Sludge ments Cakes







T
Q
•
Q
Q
Q
U
Q
Q
Q
T
T
T
T
T
T
T
T
a
T
Q
Q
Q
Q
Q
a
Q
T
T
T
T
T
T
T
T
a
T
a
a
a
a
a
a
a
•
•
•
•
T
T
T
T
Q
T
a
Q
Q
Q
Q
D
Q
• Demonstrated Effectiveness: Successful treatability test at some scale
completed
T Potential Effectiveness: Expert opinion that technology wiH work
Q No Expected Effectiveness: Expert opinion that technology will not
work
be removed from  the feedstock material during full-scale
treatment operations. Pretreatment methods can be applied to
reduce the dimensions of any oversized debris.

Chemical and physical properties of the contaminant should
also be investigated. Other contaminant characteristics such
as volatility and density are important for the design of remedy
screening studies and related residuals treatment systems.
Prescreening characterization data should be assembled and
organized in a concise tabular form before remedy screening.
If enough information is obtained by prescreening to allow a
decision to be made regarding the potential success of thermal
desorption, remedy screening may be skipped. A listing of key
prescreening data is presented in Table 2-2.

The need for  a  treatability study is  determined near the
beginning of the RI/FS when a literature survey  of remedial
technologies  is  performed.  Remedial  technologies  are
identified based  on  compatibility  with  the  type  of
contaminants present at the site, the medium (soil,  water, etc.),
and the anticipated cleanup objectives. Remedial technologies
are prescreened for effectiveness, implementability, and cost.
The prescreening is done using available technical literature,
databases, and manufacturer's information. Based upon this
initial technology prescreening, thermal desorption may be one
of several candidate remedial technologies eliminated before
or during the remedial investigation/feasibility study. See the
generic guide for more specific details on screening of
treatment technologies and on determining the need and type
of treatability  tests which may be required for evaluating
treatment technology alternatives.1-28-1
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  2.2.4   Thermal Desorption Limitations

  Thermal  desorption  limitations  may  be  defined  as
  characteristics that hinder cost-effective treatment. Thermal
  desorption has proven effective in treating contaminated soils,
  sludges, and sediments.  Chemical contaminants for which
  bench-scale through full-scale treatment data exist include
  primarily  VOCs, SVOCs and  even  higher boiling  point
  compounds   such   as  polychlorinated   biphenyls
  (PCBs).(1)(6)(9)(13)(1(i)(33) The technology is generally not used in
  separating in  organics  from the  contaminated  medium;
  although thermal desorption has been used to recover very
  high concentrations of mercury metal from soil/11' Inorganic
  constituents and/or metals that are not particularly volatile will
  likely not be effectively removed by thermal desorption. The
  maximum bed temperature and the presence of chlorine or
  another chlorinated compound may result in volatilization of
  some inorganic constituents in the waste.

  The primary technical factors affecting thermal desorption
  performance are the maximum bed temperature achieved, total
  residence time, organic and moisture content, contaminant
  characteristics and medium properties. Since the basis of the
  process is physical removal from the medium by volatilization,
  bed  temperature  directly  determines  the  end   point
  concentration. The degree of mixing and, where applicable, the
  sweep  gas rate also affect removal  rate. In  some cases,
  achieving and maintaining the desired results are too costly for
  sites that are heavily contaminated with organics or that have
  a  high  moisture content.  If the system is direct-heated,
  flammability of the  contaminant must also be considered in
  order to prevent explosions.1-37-1 As in most systems that use a
  reactor or other equipment to process wastes, media exhibiting
  a very  high pH (greater than 11) may  corrode the system
  components/35' Media exhibiting a low pH may similarly
  corrode system components during processing.
The contaminated medium must contain at least 20 percent
total solids (by weight) to facilitate placement of the waste
material into the desorption equipment/1' Some systems
specify a minimum of 30 percent solids/20' If the moisture
content of the contaminated medium is high, it may have to be
dewatered prior to treatment to reduce the energy required to
volatize the water.

Material handling of soils that  are tightly aggregated,  are
largely clay, or contain rock fragments or particles greater than
1.5 inches can result in poor processing performance. This can
be minimized-by  media pretreatment such  as  screening,
crushing, milling, grinding, shredding, etc.  Also, if a high
fraction of fine silt or clay exists  in the matrix, excessive dust
may be generated which places a greater dust loading on the
downstream air pollution control equipment/20^35'

The treated medium will typically contain less than 1 percent
moisture. Dust can easily form in the transfer  of the treated
medium from the desorption unit, but can be mitigated by
water sprays. Some type of enclosure may be required to
control fugitive dust water sprays are not effective.

Caution should be taken regarding the disposition of the
treated material, since pretreatment and/or treatment processes
can alter the physical properties  of the material. For example,
this material could be susceptible to such destabilizing forces
as liquefaction, where pore pressures  are able to weaken the
material to the point of failure.  It may be advantageous to
avoid backfilling such treated material on  sloped areas or
places where materials must support a load (i.e. roads  for
vehicles, subsurfaces of structures,  etc.).  To  achieve or
increase the required stability of the treated material, it may
have  to be  mixed  with  other  stabilizing materials and/or
compacted in a  layered fashion. A thorough geotechnical
evaluation  of the  treated product—based on treatability
tests—can provide  the  necessary  design resolution  to
post-treatment solid stabilization. Screening tests of untreated
soils  should also  be considered as  away of identifying
potential impacts on the medium. An example of a prescreening
evaluation and the decision to conduct further testing is
provided in Example 1.
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                            Table 2-2. Key Prescreening Characteristics For Thermal Desorption Treatability Testing
Parameter

Chemical
Organics
-Volatile
-Semivolatile
-PCB
Total organic carbon
(TOC)
or

Total recoverable petro-
leum hydrocarbon
or

Oil & Grease

Metals

Toxicity Characteristic
Leaching Procedure
(TCLP)
Physical

Grain size
analysis/particle size
distribution

Moisture content


Bulk density



PH
Description of Test



GC/MS
GC/MS
GC
Combustion


Infrared



Gravimetric

ICP, GFAA, CVAA


Soil leaching\
analysis of leachate


Sieve screening using
a variety of screen
sizes

Drying oven at 110!C


Drive cylinder method

Sand cone method

SoilPH
Method



Method 8240
Method 8270
Method 8080
Method 9060


Method 9071/41 8.1



Method 9071

Method 3050/6000,
7000 series

Method 1311

ASTM D422


ASTMD2216


ASTM D2937

ASTM D 1556

Method 9045


Purpose and Comments Application of
Data

To determine concentration of Remedy Screening
target or interfering constituents,
pretreatment needs, extraction
medium
To determine the presence of Remedy Screening
organic matter







To determine the potential emis- Remedy Screening
sions of volatile metals and
inorganic alkali
To determine leachability of RemedV Selection
selected organic and inorganic
compounds in liquid/solid
residuals


To determine volume reduction Remedy Selection
potential, pretreatment needs

To determine pretreatment needs Remedy Selection
and medium processing rate

To estimate total mass of soil to Remedy Selection
be treated


Potential for system corrosion Remedy Selection

Ref.


36



36


36





36


36


3


2


3

3

36

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                                  Example 1. Prescreening Initial Data


      BACKGROUND
      A 3.0-acre industrial site in the northeastern United States was used from 1950 until 1964 as a storage yard
      for a company that installed asphaltic roofing materials. From 1968 until 1978 the site was used as a storage
      facility and transfer station for solvents that were being sent to a recycling facility. Remedial investigations
      indicated that waste disposal and chemical spills over a period of years have contaminated the surface soil
      and underlying groundwater. The soil at the site consists primarily of a  highly plastic inorganic clay with
      some debris present near the surface.

      USE OF DATA TO PRESCREEN  THERMAL DESORPTION

      The prescreening was performed by conducting a literature survey, reviewing existing data, and obtaining
      expert opinion. Contaminants that have been identified on the site include the base neutral compounds
      pyrene,  chrysene, and naphthalene at an average concentration of less than 100mg/kg each. These
      compounds are primarily located in the top 2 feet of surface soil. The volatile organic compounds methylene
      chloride, toluene, and 1,1,1-trichloroethane have been identified at concentrations of upto 1,000 mg/kg down
      to the surface of the groundwater table (depth of approximately 12  feet). The  groundwater is also
      contaminated with VOCs. Arsenic has been identified within an area of the site at a concentration of up to
      1,000mg/kg. Arsenic emissions from point sources are regulated under state air toxics regulations.

      A risk assessment at the site  has established the f6liowing preliminary cleanup levels for selected indicator
      compounds:


        •  Methylene chloride                 5.5 mg/kg
        •  Toluene                           3.0 mg/kg
        •  1,1,1-trichloroethane                2.0 mg/kg
        •  Pyrene                           15.5 mg/kg
        •  Chrysene                        13.2 mg/kg
        •  Naphthalene                      25.0 mg/kg


      The prescreening study indicates the following:

        •  Thermal desorption has demonstrated from 90 to greater than 95 percent removal efficiencies for the
           VOCs
           that have been identified.
        •  Thermal desorption has demonstrated 75 to 95 percent removal efficiencies for the base/neutral
           compounds that have been identified.
        •  Toluene and  pyrene have the highest boiling point  temperatures of the volatile and base/neutral
           compounds, respectively, that have  been identified  at the site.
        •  No data on the partitioning of arsenic to the offgas at thermal desorption operating
           conditions could be located.
        •  The clay has very cohesive properties at a moisture content of greater than 18 percent.


      The experts recommend thermal desorption for further  consideration as a site remedy. Remedy screening
      treatability studies are to be conducted.
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                                              SECTION  3
                     THE USE OF TREATABILITY STUDIES  IN
                                    REMEDY  EVALUATION
  This section presents an overview of the use of treatability
  test in confirming the selection of thermal desorption as the
  technology remedy under CERCL A. It also provides a decision
  tree that defines the tiered approach to the overall treatability
  study program with examples of the application of treatability
  studies totheRI/FS and remedy selection process. Subsection
  3.1 presents an overview of the general process of conducting
  treatability tests. Subsection 3.2 defines the tiered approach to
  conducting treatability studies and the applicability of each
  tier of testing, based on the information obtained, to assess,
  evaluate, and confirm thermal desorption technology as the
  selected remedy.
  3.1
PROCESS
TESTING
REMEDY
 OF    TREATABILITY
IN    SELECTING    A
  Treatability studies should be performed in a systematic
  fashion to ensure that the data generated can support the
  remedy evaluation process. This section describes a general
  approach that  should  be followed by  RPMs, PRPs, and
  contractors during  all levels of treatability  testing. This
  approach includes:

  •   Establishing data quality objectives

  •   Selecting a contracting mechanism

  «   Issuing the Work Assignment

  •   Preparing the Work Plan

  •   Preparing the Sampling and Analysis Plan

  •   Preparing the Health and Safely Plan

  •   Conducting community relations activities

  •   Complying with regulatory requirements

  •   Executing the study

  •   Analyzing and interpreting the data

  «   Reporting the results

  •   Developing cleanup criteria

  These elements are described in detail in the generic guide/28'
That document gives information applicable to all treatability
studies. It also presents information  specific to remedy
screening, remedy  selection testing, and remedy design
testing.

Treatability studies for a particular site will often entail multiple
tiers of testing. Duplication of effort can be avoided  by
recognizing this possibility in the early planning phases of the
project.  The  Work Assignment,  Work Plan,  and other
supporting documents should include all anticipated activities.

There  are three levels or tiers of treatability studies: remedy
screening, remedy selection, and remedy design. Some or all of
the levels may be needed on a case-by-case basis. The need
for and  the  level of  treatability  testing required  are
management decisions in which the time and cost necessary
to perform the testing are balanced against the risks inherent
in the  decision (e.g., selection of an inappropriate treatment
alternative). These decisions are based on the quantity and
quality of data available and on other decision factors (e.g.,
state and community acceptance of the remedy, new site data,
or experience with the technology).  The flow diagram for the
tiered  approach in Figure 3-1 traces the step wise review of
study  data and  the  decision points and factors to  be
considered.

Technologies  generally  are evaluated first at the remedy
screening level and progress through remedy selection to
remedy design. A technology may enter the selection process,
however, at whatever level is appropriate based on available
data on the technology and site-specific factors. For example,
a technology that has been successfully applied at a site with
similar conditions and contaminants may not require remedy
screening to determine whether it has the potential to work.
Rather, it may go directly to remedy selection to verify that
performance standards can be met. Treatability  studies, at
some level, will normally be needed even if previous studies or
actual  implementation  have  encompassed  similar  site
conditions to assure that the site-specific target cleanup goals
are going to be achieved. Figure 3-2 shows the relationship of
the three levels of treatability study to each other and to the
RI/FS process.

3.2    APPLICATION OF TREATABILITY
        TESTS

Before conducting treatability studies, the objectives of each
tier of testing must be established. Thermal desorption
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                                                                                                           MANAGEMENT DECISION FACTORS:

                                                                                                           • State and Community Acceptance
                                                                                                           • Schedule Constraints
                                                                                                           • Additional Data
                                            Technology
                                             Screening
Characterization
             Technology
              Potentially
               Viable?
                                Treatability
                                 Studies
                                 Heeded?
                                   Mariagsment
                                 Decision Factors
                                 eehrwlogy
                               Demonstrated
                               or Contaminan
                                 Matrix?
                                     Remedy
                                    Screening
                                     Studies
                                                                          Remedy
                                                                          Selection
                                                                          Studies
                                                                               Meet
                                                                            Performance
                                                                              Goals?
I                                                                                             Detailed Analysis
                                                                                              of Alternatives
                                                                                                                           Remedy
                                                                                                                           Design
                                                                                                                           Studies
                                                          Figure 3-1.  Flow diagram of the tiered approach.
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                           Remedial Investigation/
                          Feasibility Study (RI/FS)
                                           Identification
                                          of Alternatives
                                                 Record of
                                                 Decision
                                                  (ROD)
                                                 Remedy
                                                 Selection
                                  Remedial Design/
                                  Remedial Action -
                                     (RD/RA)
          Scoping
         -  the  -
           RI/FS
         Literature
         Screening
            and
         Treatability
        Study Scoping
        Site
   Characterization
   and Technology
      Screening
     REMEDY
   SCREENING
    to Determine
Technology Feasibility
  Evaluation
of Alternatives
                                                REMEDY SELECTION
                                                to Develop Performance
                                                     and Cost Data
Implementation
  of Remedy
                                                                                     REMEDY DESIGN
                                                                                  to Develop Scale-Up, Design,
                                                                                     and Detailed Cost Data
                          Figure 3-2. The role of treatability studies in the RI/FS and RD/RA process.
  treatability study objectives are based upon the specific needs
  of the RI/FS. There are nine evaluation criteria specified in the
  document, Guidance for Conducting Remedial Investigations
  and Feasibility Studies Under CERCLA (Interim Final);(27) the
  treatability studies provide  data for up to seven of these
  criteria. These seven criteria are:

  •   Overall protection of human health and environment

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

  •   Reduction  of toxicity,  mobility, or  volume  through
      treatment

  •   Short-term effectiveness

  •   Implementability

  •   Long-term effectiveness and permanence

  •   Cost

  The first four of these evaluation criteria deal with the degree
  of contaminant reduction achieved by the thermal desorption
  process.  What  will  be  the  remaining  contaminant
  concentrations? Will new contaminants be produced? Will the
  residual contaminant levels be  sufficiently low  to meet the
  established ARARs and the risk-based contaminant cleanup
  levels? What are the contaminant concentration and physical
  and chemical differences between the  untreated  and the
  treated solids fractions (e.g., has contaminant toxicity,
                                    mobility, and volume been reduced)? The fourth criterion,
                                    short-term effectiveness, also addresses the effects of the
                                    treatment technology during construction and implementation
                                    of a remedy. This evaluation is concerned not only with
                                    contaminant concentration and toxicity, but  also with the
                                    potential for exposure to off gases or residuals which may be
                                    harmful.

                                    The implementability assessment evaluates the technical and
                                    administrative feasibility of the technology and the availability
                                    of required goods and services. The following questions must
                                    be answered in order to address the implementability of
                                    thermal desorption:

                                    •   Will ambient releases of volatile contaminants that occur
                                       during excavation and classification require controls?

                                    •   Is there a need for a blending program to ensure hot spots
                                       can be accommodated by the thermal desorption system?

                                    •   Is  the water content of the waste/sludge  too high or
                                       highly variable?

                                    •   Has  the  degree  of particulate  entrainment  been
                                       determined, and will the particulate need to be recycled?

                                    •   Have the volumes and characteristics of residuals been
                                       approximated, and are residuals treatment and disposal
                                       options established (e. g., do metals in the treated medium
                                       need further treatment)?
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  «   Are there appropriate air emission controls for process
      emissions?

  Long-term effectiveness assesses  how effective  treatment
  technologies are in maintaining protection of human health
  and the environment after response obj ectives have been met.
  The magnitude of any residual risk and the adequacy and
  reliability  of controls must be evaluated. Residual risk, as
  applied to thermal desorption, assesses the risks associated
  with treatment residuals at the conclusion  of all  remedial
  activities. Analysis of residual risk from other treatment train
  processes should be included in this step. An evaluation of
  the reliability of treatment process controls  assesses the
  adequacy and suitability of any long-term controls (such as
  site access restrictions and deed limitations on land use) that
  are necessary to manage treatment residuals at the site. Such
  assessments are  usually beyond  the scope of a remedy
  selection  treatability  study,   but  may   be  addressed
  conceptually based on remedy selection results. Performance
  objectives must consider the existing site contaminant levels
  and relative cleanup goals for soils, sludges, and sediments at
  the site.  In previous years, cleanup goals  often  reflected
  background site conditions. Attaining background cleanup
  levels  through treatment has proved impractical  in many
  situations. The present trend is toward the development of
  site-specific cleanup target levels that risk-based rather than
  background-based.

  The final  EPA evaluation criterion  which can specifically be
  addressed during a treatability study is cost. Remedy selection
  treatability studies can provide data to estimate the following
  important cost factors:

  •   The ultimate cleanup level that can be achieved

  «   The volume and characteristics of residuals which require
      treatment or disposal

  •   The degree to  which medium pretreatment  or process
      modifications can enhance the efficiency of the process

  •   The amount  of energy required to  heat and clean the
      medium and approximate fuel costs

  The first three factors provide information about the costs of
  downstream treatment  by  determining the  amount  and
  character  of the contaminated residuals. The last factor helps
  estimate the costs of supplies and utilities.

  3.2.1   Remedy Screening

  Remedy screening is  the first level of testing. It is used to
  establish the ability of a technology to treat a waste. Remedy
  screening is generally low cost (e.g., $8,000 to  $30,000) and
  requires several days to three months to complete. Time must
  be   allowed  for   project   planning,  chemical   analyses,
  interpretation of test data, and report writing. Limited quality
  control is required for remedy screening studies. They yield
  data indicating a technology's potential to meet performance
  goals and applicability to the specific waste sample. Remedy
  screening tests  can  identify  operating  parameters  for
  investigation during remedy selection or remedy design. They
  generate little, if any, design or cost data and should not be
  used as the sole basis for selection of a remedy.
In some instances, thermal desorption remedy screening
treatability  studies can be skipped, if  enough information
about  the  physical  and chemical characteristics  of the
contaminants and medium would allow for evaluation of the
potential success of thermal desorption at a site.  In such
cases, remedy selection tests are normally the first level of
treatability  study  executed.  Screening  tests  are conducted
using laboratory-scale equipment. These tests are generic, not
vendor-specific, and can be performed at laboratories with the
proper equipment and qualified personnel.

3.2.2   Remedy Selection

Remedy selection is the second level  of  testing. Remedy
selection studies identify the technology's  performance at a
site. These studies have a moderate to high cost (e.g., $10,000
to $100,000) and require several months to plan, obtain
samples, and execute.(24) Remedy selection  studies yield data
that verify  that the technology can meet expected cleanup
goals, provide information in support of the detailed analysis
of alternatives, and  give indications of optimal operating
conditions.

The  remedy  selection tier  of thermal desorption  testing
consists of either bench-scale tests or pilot  tests. Frequently,
thesetests will be technology-specific. The key question to be
answered during  remedy selection testing is whether the
treated medium will meet the cleanup goals for this site. The
exact removal efficiency or acceptable residual contaminant
level specified as the goal for the remedy selection test is site-
specific. A remedy design study would follow a successful
remedy selection study, although they  are usually not
conducted until after a Record of Decision (ROD) has been
issued.

3.2.3   Remedy Design

Remedy design is the third level of  testing. It  provides
quantitative performance, cost, and design information for an
operable unit. This testing also produces the remaining data
required  to  optimize performance. These  studies are of
moderate to high cost (e.g., $50,000 to $200,000) and require
several months to complete.(24) For complex sites (e.g., sites
with different types or concentration  of  contaminants in
different media such as soil,  sludges, and sediments), longer
testing periods may  be required,  and  costs will be  higher.
Remedy design tests yield data that verify  performance to a
higher degree than the remedy selection and provide detailed
design information. They are most often performed during the
remedy design phase of a site cleanup.

Remedy design tests usually consist of bringing a  mobile
pilot-scale treatment unit  to the site, or  constructing  a
small-scale unit for non-mobile technologies. Remedy design
tests can also be conducted using vendor-specific pilot-scale
equipment  at the vendor's  site which is  generally much
cheaper than onsite mobilization or construction. Applicable
permits would have to be obtained for onsite  testing; however,
waivers may be available under certain conditions. The goal of
this tier of testing is  to confirm the  cleanup levels and
operating  conditions  specified in the  Work Plan  (see
subsection  4.1.1). This is best achieved by operating a field
unit under conditions similar to those expected in the full-
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  scale remediation project.                                    If remedy selection testing was performed using pilot-scale
                                                             equipment,  this may  provide  sufficient data to make any
  Data obtained from the remedy design tests are used to:         further remedy design testing unnecessary. Given the limited
                                                             amount of full-scale experience with innovative technologies,
  •    Specify equipment type for a full-scale unit                 such as thermal  desorption,  remedy  design  testing will
                                                             generally  be necessary  in  support of the final  process
  .    Determine feasibility  of thermal desorption based on     selection and implementation of a remedy. As technologies
       target cleanup goals                                     mature, the need for remedy design testing will decrease.

  •    Refine cleanup time estimates

  •    Refine cost predictions
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                                               SECTION  4
                        TREATABILITY  STUDY WORK PLAN
  This chapter focuses on specific elements of the Work Plan for
  thermal desorption treatability  studies. These  include test
  goals, experimental design, equipment and materials, sampling
  and analysis,  data analysis  and  interpretation, reports,
  schedule,  management and  staffing,  and budget.  These
  elements are described in subsections  4.1 through  4.9.
  Complementing the above subsections are section 5, Sampling
  and Analysis Plan and Quality Assurance Project Plan, and
  section 6, Treatability Data Interpretation. Table 4-1 lists all of
  the Work Plan elements.

     Table 4-1. Suggested Organization of Thermal
        Desorption Treatability Study Work Plan
   No.    Work Plan Elements
Subsection
1.
2
o
J.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
Project Description
Remedial Technology Description
Test Goals
Experimental Design
Equipment and Material
Sampling and Analysis
Data Management
Data Analysis and Interpretation
Health and Safety
Residuals Management
Community Relations
Reports
Schedule
Management and Staffing
Budget


4.1
4.2
4.3
4.4

4.5



4.6
4.7
4.8
4.9
  Carefully planned treatability studies are necessary to ensure
  the data generated are useful for evaluating the applicability or
  performance of a technology. The Work Plan, usually prepared
  by a 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
  assigns
responsibility and establishes the project schedule and costs.
The Work Plan must be approved by the RPM before initiating
subsequent tasks. For more information on each of these
sections, refer to the generic guide.(28)

4.1     TEST GOALS

Setting goals for the treatability study is critical to the ultimate
usefulness of the data generated. Objectives must be defined
before  starting  the  treatability  study.  Each tier of the
treatability study needs performance goals appropriate to that
tier. For example, remedy selection tests are used to answer the
question,  "Will  thermal  desorption  work   on  this
medium/contaminant matrix?" It is necessary to define "work"
(e.g., set the  goal of the study). The remedy selection test
measures whether the process has the  potential to reduce
contamination to below the anticipated performance criteria to
be specified  in the ROD. This would indicate that further
testing for remedy design is appropriate.

The ideal technology performance goals are the same as the
anticipated cleanup criteria for the site. For several reasons,
such as ongoing waste analysis and ARARs determination,
cleanup criteria are sometimes not finalized until the ROD is
signed, long  after treatability  studies must be initiated.
Nevertheless, treatability study goals need to be established
before the study is performed so that the success of the
treatability study can be assessed. In many instances, this may
entail an educated guess as to what the final cleanup levels
may be. In the absence of final cleanup levels, the RPM can
estimate performance goals for the treatability studies based
on the first two criteria listed in subsection 3.2 of this guide.
Existing treatability study results from other sites may provide
the basis for  an estimate of the treatability study  goals for a
specific case.

4.1.1   Remedy Screening Goals

When remedy screening tests are performed, determining the
minimum temperature of the medium and residence time needed
to achieve the required cleanup criteria are the desired goals.
The  remedy  screening treatability  study goals must  be
determined on a site-specific basis.  Typically, 75 percent or
higher separation efficiencies are achieved in the remedy
screening tier. RREL's Remedy Screening Lab has used 50
percent as a goal in the past. Since thermal desorption remedy
screening tests may be
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  a simple test, such as the use of a flat tray of contaminated
  medium inserted into a small lab  furnace, the level of
  volatilization efficiency achieved should not be used as the
  sole criteria for conducting further treatability testing.

  Example 2 describes a  series  of remedy  screening tests
  conducted at a Superfund site introduced in Example 1. The
  example illustrates how to decide whether the remedy selection
  treatability  studies using thermal desorption  should be
  performed.

  4.1.2   Remedy Selection Treatability
          Study Goals

  The main goals of this tier of testing are to obtain information
  on  operating parameters  relevant to  a full-scale thermal
  desorption system. Inclusive in these goals are determining
  actual contaminant concentrations achieved after treatment,
  definition of the heat input requirements,  and average bed
  temperatures achieved, as well as limited performance data for
  the offgas treatment sy stem(s) thought to be applicable to the
  medium/contaminant matrix. The actual goal for separation
efficiency  must be based  on site- and  process-specific
characteristics. Typical separation efficiencies are 90 percent
and higher. The specified separation efficiency must meet
site-specific cleanup goals,  which are based on a site risk
assessment.

Example 3 continues from Example 2 and illustrates the goal of
a remedy selection treatability study at the Superfund site. In
this example, the remedy selection treatability studies show
that pilot-scale testing should be conducted.

4.2    EXPERIMENTAL DESIGN

4.2.1  Remedy Screening Tier

Remedy screening  tests  can be rapidly  performed in a
laboratory  to evaluate the potential performance of thermal
desorption. When assessing the need for remedy screening
tests, the investigator should use available knowledge of the
site and any preliminary analytical  data on the type and
concentration of contaminants present. If it  is confirmed that
the concentration of metals is low, the
                                         Example 2. Remedy Screening
       BACKGROUND
       In Example 1, recommendations were made to proceed with remedy screening treatability tests to check the
       potential feasibility of thermal desorption.  Pyrene, arsenic, and toluene were  chosen  as the indicator
       contaminants.

       RESULTS OF TESTING

       Static tray muffle furnace tests were conducted by a thermal desorption contractor in accordance with the
       procedures described in Section 4.0 of this document. Tests were conducted at soil temperatures of 400°F,
       800°F, and 1,000°F and a residence time at temperature of 10 minutes for each test. Tests at all  conditions
       showed that the concentration of toluene could be reduced to  less than 0.5 mg/kg (>96 percent). The
       concentration of pyrene was reduced by 50 percent, 85 percent, and 95 percent, respectively in the three tests.
       The concentration of arsenic in the soil was not appreciably reduced at the two lower temperature conditions.
       At the test temperature of 1,000°F, the concentration of arsenic in the treated material was approximately 30
       percent less than the concentration in the untreated sample.

       RPM'S DECISION

       The remedy screening tests indicate that the VOCs can be removed to acceptable residual concentrations over
       a broad range of thermal desorption operating temperatures. Removal of base/neutral compounds at greater
       than 90 percent efficiency will require operating near the  upper temperature  limits of a thermal desorption
       system. However, at this condition, some of the arsenic apparently volatilizes to the gas phase. The RPM
       decides to conduct further treatability testing (remedy selection)  to refine operating conditions required to
       achieve target residual concentrations for pyrene  and to determine the fate  of arsenic at these operating
       conditions.
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                Example 3. Remedy Selection Treatability Test Using Rotary Thermal Apparatus
      BACKGROUND
      In Example 2, recommendations were made to proceed with remedy selection treatability tests to bracket
      operating conditions for thermal desorption and determine the fate of arsenic at these conditions. Pyrene and
      arsenic were chosen as the indicator contaminants.


      RESULTS OF TESTING


      Rotary thermal apparatus tests were conducted by a thermal desorption contractor in accordance with the
      procedures described in Section 4.0 of this document. Tests were conducted  at soil temperatures  of 800°F,
      900°F and 1,000°F, and a time-at-temperature of 10 minutes for each test. Tests showed that the concentration
      of pyrene in the treated soil sample could be reduced to 25 mg/kg, and 7 mg/kg at soil temperatures of 800°F,
      900°F,  respectively. Tests at all conditions confirmed that the residual concentration of toluene in the treated
      soil was less that 0.5 mg/kg.


      Sample of offgas from the rotary thermal apparatus were passed through a condenser. Gas samples were
      collected both upstream and downstream of the condenser. A material balance was performed for arsenic for
      each test. Tests at both 900°F and 1,000°F indicated that greater than 10 to 20 percent of the arsenic in the
      sample partitioned to the gas phase and was not appreciably removed by passing the gas through a condenser.


      RPM'S DECISION


      The  remedy selection treatability  tests indicated that a thermal desorption system that operates at a soil
      temperature of up to 900°F will be required to meet the treatment criteria for the base/neutral compounds.
      Approximately 10 to 20 percent of the arsenic is partitioned to the offgas and is  not removed in a condensation
      system. The RPM believes that the arsenic in the attributable both to particulate carryover and volatilization
      of arsenic. The volatilized fraction may condense to a fine fume and would require a sophisticated air pollution
      control system.


      The  RPM decides to conduct a remedy design treatability test of a thermal desorption process and associated
      gas treatment system to confirm removal efficiency projections for base/neutral compounds and to  obtain an
      estimate of arsenic emissions from a full-scale system. A pilot thermal desorption system that includes a
      venturi scrubber to treat offgas is recommended as the test equipment.
  contaminants  are generally represented in the classes of
  contaminants shown in Table 2-1, and the general limitations
  described in section 2 are met, then the remedy screening
  tiermay be precluded. Remedy selection studies would yield
  more valuable data and save time and money in this case.

  When considering remedy screening testing, a number of
  systems can be used, such as a static tray or differential bed
  reactor (DBR). In the tray test, contaminated medium is
  heated in a muffle furnace equipped  with  an electronic
  temperature controller. The furnace should be capable of
  achieving an internal temperature up  to  1,400°F with  a
  relatively fast heat-up rate. The depth of the soil should
be kept  at a  minimum to eliminate temperature  and
concentration gradients within the soil bed. The temperature
of the medium should be monitored very closely, and care
should be taken that the thermocouple(s) are completely
immersed in the solid material. The time to reach the target
treatment temperature  should be minimized to a practical
laboratory timeframe such as 5 to 10 minutes. Longer time
may be required depending  on the specific contaminants
present in the soil. Figure 4-1 shows a schematic of a static
tray test oven.1-4-1

In a DBR, a thin bed of medium is placed in a furnace
between two screens. Preheated gas passes through the bed
which eliminates concentration and temperature
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                                                                                Oven Indicator
                                                                                Thermocouple
              Interior of Oven Chamber
                                                                      Test Thermocouple
                                                                   Soil Thermocouple
                                      Gas Exit at Door Seal
                      Figure 4-1. Cut-a-way view of static tray test oven with the tray insert.
  gradients within the bed. In this reactor, the temperature of the
  medium  should also be monitored and the bed should reach its
  target temperature within 5 to 10 minutes. Figure 4-2 shows a
  schematic of the DBR.(8)

  In remedy screening tests, the offgas may  be analyzed for
  volatiles and  semivolatiles;  however, particulate control
  equipment is not necessary. Remedy screening tests alone do
  not produce enough information to perform an economic
  analysis of a thermal desorption process, but  do generate data
  on time-at-temperature requirements.

  To reduce analytical costs during the remedy screening tier,
  the list of known contaminants must be reduced to a few key
  compounds selected  as indicators  of performance. The
  selection of indicator chemicals for remedy screening testing
  should be based on the following:

  1)  Select one or two contaminants that have low volatility.

  2)  Select one or two contaminants present in the medium
      that are most toxic or most prevalent.

  3)  Select  indicator  compounds  to  represent  other
      compounds within those groups (e.g., TCE for chlorinated
      volatiles, benzene for nonchlorinated volatiles).
                     Desorbing gas inlet
                              Gas
                              heat
                              exchanger
     Electric
   cylindrii
     furnace
                                        Suction
                                        pyrometer for
                                        gas temperature
          Solid bed
          between.
         400 mesh
        SS Screens
     Ceramic
     Block
Sampling Probe
Port for gas samples
                        Exhaust
  4)   Select a representative sample either composite or hot
       spot (for worst case, see subsection 4.4.1)

  5)   Select polar  contaminants since  they tend  to adsorb
       strongly to some media.
Figure 4-2. Cut-a-way view of the Differential Bed
                  Reactor (DBR).
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  Mass balance calculations are usually limited by analytical
  results on solids and liquid feed and discharge streams during
  remedy screening. Normally, gaseous emissions are not tested
  at this tier.

  4.2.2   Remedy Selection Tier

  Remedy  selection testing is intended to  more accurately
  estimate  the performance of a full-scale thermal desorption
  system.  The tests may be  conducted  in either batch or
  continuous treatment systems that simulate the heat and mass
  transfer characteristics of specific full-scale thermal desorption
  processes. Data collected  at this level can be  used to model
  thermal desorption under  various  experimental conditions.
  Information from modeling can then be used to predict time
  and temperature requirements in full-scale operating systems.
  Remedy  selection treatment systems are available to simulate
  the performance characteristics  of the  various desorption
  systems.

  Remedy  selection  testing  should  define  the  time-at-
  temperature and residual contaminant concentrations  as  a
  function of heat input and bed-mixing characteristics for  a
  thermal desorption device. Under certain conditions remedy
  selection testing can be conducted using a static tray orDBR.
  After conducting the tray tests, remedy selection usually will
  lead to a vendor pilot-scale unit that generates data applicable
  to that vendor's full-scale unit.  Currently, there is no remedy
  selection system available that permits concurrent evaluation
  of the specific full-scale thermal desorption processes.

  More precision is used in weighing and mixing of the sample,
  with an associated increase in QA/QC costs. Further care must
  be taken to ensure homogeneity of the sample(s) being treated.
  Holding  time of the medium and offgas samples in the lab
  before  extraction  and  analysis  can  be   an  important
  consideration for some contaminants. At this phase of remedy
  selection, it is recommended that duplicate (or triplicate) test
  runs are  completed to ensure reproducibility  of the results.
  This is extremely important when non-vendor (generic) tests
  are performed (i.e., DBR or static tray). This series of tests is
  considerably more costly than remedy screening tests, so only
  sites  with  contaminated media  that show promise in the
  remedy screening phase should be carried forward into the
  remedy selection tier. If sufficient data are available in the
  prescreening step, the remedy screening step may be skipped.
  The objective of the  remedy  selection  thermal desorption
  design is to meet the goals discussed in subsection 4.1.2.

  Variables that should be documented and/or controlled during
  this level of treatability testing include:

  •   moisture content of medium

  «   contaminant concentration in medium

  •   particle size of medium

  •   treatment temperature or minimum solids temperature

  •   time-at-temperature or total residence time

  •   medium physical and chemical characteristics

  «   thermal properties of contaminated medium
«   degree of agitation (solid/gas mixing)

•   purge gas flow, composition, and temperature

The moisture content of the medium affects the throughput
rate due to the energy requirements for drying. A high water
concentration delays contaminant volatilization or requires
larger heat input to remove contaminants from the medium, if
the same  throughput rate is to be maintained. Data exist,
however,  that  suggest  that  some contaminants may  be
removed at lower temperatures by the physical action of steam
stripping as water boils off/15' Treatability testing should be
performed with medium samples that represent the average
moisture content expected during full-scale thermal desorption
operations.

Samples should be representative of site conditions for the
range of concentration of contaminants. Some variability in
contaminant concentration should be expected  in individual
samples  which  are  used  to  characterize  the extent  of
contamination at the site. Blending waste material into a more
homogeneous mixture can lessen this variability.

The  particle  size distribution   of the  medium  should
approximate that expected for the contaminated volume to be
treated. If a significant amount of foreign  objects; large,
consolidated chunks  of  medium; or  significant  media
heterogeneity exist at the site, this may impact the selection.
This may  also indicate  the  need  for additional material
handling equipment if the next tier of testing is conducted.

Thermal desorption treatability tests are normally conducted
at temperatures within the operating ranges  of full-scale
thermal desorption systems.   This temperature range  is
normally between 200°F and 1,000°F for the medium.

Example 4 shows data obtained from using a vendor-specific
bench-scale unit  while proceeding with  remedy  selection
testing. This shows background information, sample handling,
test operating conditions,  and cleanup objectives. The test
results, along with estimated cleanup  costs are detailed in
section 6 as Example 5. These examples describe a case study
and should not be considered directly transferrable to  a
specific site.

The decision on whether to perform remedy selection testing
on hot spots or composite soil samples is difficult and must be
made on a site-by-site basis. Hot spot areas should be factored
into the test plan if they represent a significant portion of the
waste site. However, it is more practical to test the specific
waste matrix that will be fed to the full-scale system over the
bulk of its operating  life. If the  character of the medium
changes radically  over the depth of contamination, then tests
should be designed to separately study system  performance
on each media type. It may be necessary to identify extreme
conditions and determine the degree of blending required.
Additional guidance on soil sampling techniques and theory
can be found in  Soil Sampling  Quality Assurance  User's
Guide1-34-1 and Methods for Evaluating the  Attainment  of
Cleanup Standards.00

If the contaminants and particular medium type(s) present are
similar to those where the technology has been
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  demonstrated at full-scale applications, remedy screening and
  remedy selection treatability testing may be unnecessary. The
  RPM/OSC must carefully compare the
                     initial conditions at the previous site and the full-scale data
                     generated with those of the site being considered. Remedy
                     design testing may represent a prudent step in
                  Example 4. Remedy Selection Using Vendor-Specific Laboratory-Scale Unit

       BACKGROUND

       The treatability study was conducted on soil from an abandoned facility which was used to formulate and
       package pesticides, herbicides, and other types of chemicals. The bench-scale unit directly reflects operating
       conditions of the vendor's full-scale unit. Feed rates for this test were conducted within the test unit capacity
       of 20 g/min. Temperature and residence time are varied within the ranges available for the full-scale unit. The
       practical residence time for the large unit is 45 to 120 minutes. A test series was developed to hold the
       material within the unit (from feed to discharge) for 85 minutes.

       Thermocouples on the test unit measure temperatures at three zones on the outside shell as well as the
       discharge bed temperature. For this test series, the center zone shell temperature was to be held at the two
       conditions of 900° F and 800° F. At the conclusion of the first test, the bed temperature was noted to have
       fluctuated greater than the 5°F variance that the vendor requires to call the test a "steady state" test.
       Conditions of the first test were immediately repeated with steady state results during this second trial.

       CONDITIONS OF THE TESTING

       Representative sampling was performed at the site to determine quantities of soil for cleanup and areas of
       differing contaminant  concentrations. Hot spots were characterized and composites were taken to generate
       an equivalent "blended" concentration sample for this treatablility test. The material was screened to less than
       1/4" due to the size constraints for feeding into the test unit. A representative sample of this final material was
       taken to get "feed" contaminant concentrations. Table A provides contaminant concentration ranges for both
       the site materials and the blended sample along with proposed cleanup goals.

       The function of the bench-scale unit used for this study was  to provide a preliminary assessment of the
       vendor's capability for treating specific contaminated wastes and identification  of operating parameters. If the
       laboratory-scale testing met the treatment goals, the  operating data could be used to estimate preliminary
       costs for a full-scale remediation. Prior experience had shown a close correlation between this laboratory unit
       and the vendor's full-scale system removal efficiencies. The  most significant  variables affecting removal
       efficiency were the temperature and residence time.
                           Table A. Site Contamination Levels and Clean-up Goals
           Contaminant
Concentration
    Range
   (mg/kg)
Blended Average
 Concentration
    (mg/kg)
   Proposed
Clean-up Goals
    (mg/kg)
Chlordane
Edrin
Heptachlor
Pentachlorophenol
10
15
5-
4-
-31
-70
-92
-33
15
20
38
6-
-22
-40
-72
-24
<1
<
<
<
10
5
3
5
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                                          Example 4. (continued)
       OPERATING DATA SUMMARY
       The bench unit was operated at three test conditions defined by the Zone 2 outside shell temperature and
       solids residence time as follows:
                                          Condition 1: 900°F/85 min.
                                          Condition 2: 900°F/85 min.
                                          Condition 3: 800°F/85 min.
       Conditions 1  & 2 are similar, but the treated material exit temperature increased from 831 °F to 842° F for
       an average of 837°F during the first condition. The steady state condition was maintained in Condition 2
       with a bed temperature of 841° F. Table B summarizes the results from the operating conditions.
                                 Table B. Summary of Operating Conditions


Cond.
No.



1
2
3
Average
Feed
Rate
(g/min)



13.1
13.9
14.5
Dryer
Fill
Volume*
(%)



6.2
6.6
6.9
Total
Residence
Time
(min)



85
85
85



Temperature (F°)


Zone 1
861
860
763


Zone 2
900
900
800


Zone 3
926
925
820
Treated
Material
Exit
837
841
747
       * Fill volume = percentage of dryer cylinder cross section filled with solids, based on measured products
        loose density of 1.09 g/cc

       DISCUSSION OF TEST

       This remedy selection test was designed to mimic full-scale conditions in terms of operating temperature,
       residence time, and (scaled-down) throughput. The sample concentrations were representative of average
       contaminant loadings, and preliminary cleanup standards were used to structure the design and assess the
       success of the test (See Section 6, Example 5).

       This particular remedy selection equipment was an indirect fired rotary kiln. Obviously, the operating
       parameters  collected (i.e., temperatures from three shell zones) would not be applicable to the operating
       parameters  necessary to  evaluate a thermal screw remedy selection unit.
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  detailing  the  site-specific requirements posed by  thermal
  desorption, and assuring  compliance  with the cleanup
  requirements.

  4.3   EQUIPMENT AND MATERIALS

  The Work Plan  should specify the equipment and materials
  needed for the treatability test. Standard laboratory methods
  normally dictate the types of sampling containers which can be
  used with various contaminant groups. Appropriate methods
  for preserving samples and specified holding times for those
  samples should  be used.

  The following  equipment is typically  needed for remedy
  screening thermal desorption tests:

  •  muffle furnace, vapor extractor, DBR, or similar devices
  •  exhaust hood (for control of fugitive dust and volatilized

     compounds)
  •  tray or some  other device to hold contaminated media
  •  thermocouples (to record medium and gas temperature)
  •  rotameter (to regulate purge gas flow rate)


  Equipment  for   remedy  selection  testing  is  typically
  vendor-specific  and may include the following systems:

  •  Rotary dryer
  •  Thermal screw
  •  Vapor extractor
  •  Distillation chamber
  •  Associated offgas controls for each


  A  number of vendors  have  bench-scale to  pilot-scale size
  systems available.


  4.4   SAMPLING  AND ANALYSIS

  The Work Plan should  describe the procedures to be used in
  field and  treatability study sampling. The procedures to be
  used will be site-specific.


  4.4.1     Field Sampling

  A sampling plan should be developed for the collection of
representative samples from the site for the treatability test.
The sampling plan is site-specific. It describes the number,
location, and volume of samples. If the objective of the testing
is to investigate the performance of thermal desorption at the
highest contaminant concentration, the sample collection must
be conducted at a "hot spot". This will require conducting a
preliminary site sampling program or analyzing existing data to
identify the locations of highest contaminant concentration.
(This information is generated early in the RI process.)  If the
medium and types of contaminants vary throughout the site,
extensive sampling may be required. If thermal desorption is
being considered only for  certain areas  of the  site,  the
sampling program may be simplified by concentrating on those
areas.

If the objective of the testing is to investigate the use of the
technology for a more homogenous waste, an "average"
sample for the entire  site must be obtained. This will require a
statistically-based program of mapping the site and selecting
sampling locations  that  represent the variety of  waste
characteristics and contaminant concentrations present. The
selection of sampling locations should be based on knowledge
of the site. Information from previous samples, obvious odors,
or residues are examples of information which can be used to
specify sample locations. Table 4-2 lists the type of analyses
required for samples in remedy selection testing.

These  analyses  are typically  required  for  any thermal
desorption system. Additional analyses fortotal metals, TCLP
parameters, PCBs, PAHs, dioxins, or furans may also be
required depending on the site.

Chapter 9 of Test Methods  for Evaluating Solid Waste(36)
presents a detailed discussion of representative samples and
statistical  sampling  methods.  Additional  sources   of
information on field sampling procedures  can be found in
Annual Book  of ASTM Standards/3' NIOSH Manual of
AnalyticalMethods (February 1984),(17) and EPA publications
Soil Sampling Quality Assurance User's Guide1-34-1 and Methods
for Evaluating the Attainment of Cleanup Standards/3 r> These
documents  should be consulted to plan effective sampling
programs for either simple or complex sites.

4.4.2    Waste Analysis

Subsection  2.2.3 detailed the physical tests that are useful in
characterizing  the  contaminated  medium   during  the
prescreening step. The key for successful thermal desorption
treatability studies is to properly select the  medium samples
based on the initial prescreening and
                           Table 4-2. Analyses Required in Remedy Selection Testing
                                                           Parameter
Sample
Feed Stream
Treated Stream
Offgas/Condensate
voc
X
X
X
svoc
X
X
X
PH
X
X
X
Moisture
X
X

Ash
X
X

Oil/Grease
X
X

Particle Size
X
X

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  additional medium  characterizations. Analyses  conducted
  during the RI/FS for contaminants at Superfund sites should
  identify the contaminants of concern. The spatial distribution
  and variations in the concentrations of contaminants will be
  important for the  design of treatability studies.  If the  site
  contains complex mixtures of contaminants, it may be difficult
  to treat economically. In some instances, frequent changes in
  contaminant composition can  cause  dramatic changes in
  thermal desorption performance.

  4.4.3    Process Control Measurements

  Process control and monitoring measurements are essential for
  remedy screening and remedy selection tests. Placement of
  thermocouples is dependent on the type of equipment used.
  They generally are  placed within the various zones of the
  desorption unit to measure medium temperature throughout
  the test run. Mass flow rates in and out of the desorber are
  measured. Treatment times (i.e., time-at-temperature for the bed
  or total residence time) are also recorded.

  4.4.4    Residual Sampling and Analysis

  The complement  of tiers  of treatability  studies seeks to
  characterize the performance  of the desorption  unit  in
  separating organic  contaminants from the  medium,  and
  approximate the full-scale equipment needs and throughputs.
  Residuals from thermal desorption requiring  sampling  and
  analysis include treated medium, condensate, and particulate
  control system dust.

  Thermal desorption is  not a  stand-alone  process  (see
  subsection 2.1.1), but a separation process that can leave the
  bulk of the clean solid media onsite.  It generates small
  quantities of residuals which must be disposed of properly.
  The primary residuals are the concentrated  contaminants
  which  are typically  removed from the offgas. Sometimes, a
  useable oil may be produced from condensation of the offgas.
  Because the nature of thermal desorption equipment  and
  processes varies greatly between vendors, remedy design
  testing is frequently necessary to evaluate the type, quantity,
  and properties of residuals. The remedy design treatability
  testing tier will not be discussed in detail in this document.

  Process residuals  should be analyzed for the  contaminants
  identified in the original soil analyses  as well as any  by-
  products that may have been formed. In many cases, indicator
  contaminants,  which are representative of a larger group of
  contaminants,  can be analyzed in place of a full scan. Caution
  must be exercised  in using indicator contaminants since
  thermal desorption efficiencies can vary from one contaminant
  to another. The process efficiency may be either understated
  or overstated when analyzing for indicator compounds.

  4.4.5    Sampling and Analysis Plan
            (SAP) and Quality Assurance
            Project Plan (QAPP)

  A SAP is required for all field activities conducted during the
  RI/FS.  The SAP consists of the  Field Sampling Plan and the
  QAPP. This section of the Work Plan describes
how the RI/FS SAP is modified to address field sampling,
medium characterization, and sampling activities supporting
treatability studies. It describes the samples to be collected
and specifies the level of QA/QC required. See section 5 for
additional information on the SAP.

4.5   DATA ANALYSIS AND
      INTERPRETATION

The Work Plan should discuss the techniques to be used in
analyzing and interpreting the data.  The objective of data
analysis and interpretation is to provide sufficient information
to the RPM and EPA management to assess the feasibility of
thermal desorption as a remediation technology. After remedy
selection testing is complete, the decision must be  made
whether to proceed to the  remedy design tier or full-scale
thermal  desorption remediation,  or  to  rule out  thermal
desorption  as  an alternative.  The data  analysis and
interpretation are a critical part  of the remedy selection
process. When comparing contaminant concentrations  in the
feed material versus levels in product streams it is always
necessary to use the same basis. Laboratories normally report
concentrations on a dry-weight basis;this should be required
to eliminate any dilution effects of adding water to the treated
medium.

Temperature, treatment times, and residual contamination can
be used for screening thermal desorption systems to determine
if they can meet specific cleanup criteria. The key results from
a remedy screening test usually include:

 !  temperature (continuous measurement)
 !  treatment times (continuous measurement)
 !  initial contaminant concentration
 !  treated medium contaminant concentration
 !  residuals

Remedy screening tests are normally conducted by fixing all
but one test parameter (independent variable) and running a
series of tests while varying the independent  variable. The
independent variable is generally a parameter that directly
affects the thermal desorption performance. Parameters that
have a direct affect on thermal desorption performance include
temperature, soil  classification, contaminant type, treatment
time, moisture content, and  solid /gas mixing.

Remedy selection testing is nearly  always required in  the
absence of relevant full-scale performance data. Temperature,
treatment times, and residual concentration data from remedy
screening tests can be used  to establish target operating
temperatures. One or more of the following performance criteria
may also be addressed during this tier of testing:

 !  Throughput rate expected for the applicable remedy design
   or full-scale thermal desorption device (including energy
   input)

 !  Material handling system design requirements (pre-and
   post-treatment)

 !  Air pollution control system design requirements
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   !  Need for air pollution control measures during excavation,
     transport, and feeding

  4.6   REPORTS

  The last step of the treatability study is reporting the results.
  The Work Plan  discusses the  organization and content of
  interim and final reports. Complete, accurate reporting is critical
  because decisions about implementability will be partly based
  upon the outcome of the study. However, the RPM may not
  require formal reports at each thermal desorption study tier.
  Interim reports should be prepared after each tier. Project
  briefings should be provided to determine the need and scope
  of the next tier of testing. To facilitate the reporting of results
  and comparisons between treatment alternatives, a suggested
  table of contents is presented in the generic guide.1-28-1 At the
  completion of the study, a formal report is always required.

  OERR requires that a copy of all treatability study reports be
  submitted to the Agency's Superfund Treatability Database
  repository. One copy of each treatability study report must be
  sent to:
         U. S. Environmental Protection Agency
         Superfund Treatability Database
         ORD/RREL
         26 West Martin Luther King Dr.
         Cincinnati, Ohio 45268
         Attention: Glenn Shaul, MS-445

4.7   SCHEDULE

The  Work  Plan includes  a schedule for  completing the
treatability study. The schedule gives the anticipated starting
date  and ending date for each of the tasks described in the
Work Plan and shows how the various tasks interface. The
time span for each task accounts for the time required to obtain
the Work Plan, subcontractor, and other approvals [e.g.,
disposal approval from a commercial Treatment, Storage, and
Disposal Facility (TSDF)]; analytical turnaround time; and
review and comment period for reports and other  project
deliverables. Some slack time should also be built into the
schedule to accommodate unexpected delays  (e.g., bad
weather, equipment downtime) without affecting the project
completion date.

The schedule is usually displayed in the form of a bar chart
(Figure 4-3). If the study involves multiple tiers of
                                                         Months From Project Start
                 Activity Description
                Data Review
                WP Prep
                SIC, SAP, HSP, CRP Prep
                Remedy Screening
                 (Tray Tests)
                  Testing and Analytical
                  Data Analysis
                  Report
                Remedy Selection

                 (Bench Scale Tests)
                  Testing and Analytical
                  Data Analysis
                  Report
                 (Pilot Scale Test)
                  Testing and Analytical
                  Data Analysis
                  Report
                Final Report
                Site Remediation
                and RI/FS
                Schedule Overview
           Figure 4-3. Example project schedule for a thermal desorption treatability study program.
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           CONTRACT WORK ASSIGNMENT MANAGER

             •   Report to EPA Remedial Project Manager
             •   Supervise Overall Project
               QA MANAGER

     Oversee Quality Assurance Program
     Prepare applicable sections of Report and
     Work Plan
            ENVIRONMENTAL/ CHEMICAL ENGINEER
            •   Oversee Treatability Study execution
            •   Oversee sample collection
            •   Prepare applicable sections of Report and
                Work Plan
                           CHEMIST
             •   Oversee sample collection and analysis
             •   Prepare applicable section of Report and
                Work Plan
           LAB TECHNICIANS
     Execute Treatability Studies
     Execute sample collections and analysis
                                          Figure 4-4. Organization chart.
  testing, all tiers should be shown on one schedule. Careful
  planning before the start of the tests is essential. Depending
  on the review and approval process, planning can take up to
  several months. Remedy screening tests typically take  up to
  three months. It is  not unusual for the remedy  selection
  thermal desorption treatability test to be a several-month
  project.

  Barring any difficulties such as acquiring sampling equipment
  and site access, the sampling and analysis phase can generally
  be accomplished in  several  months.  Contracting with  an
  external lab for treatability study analysis may take a month.
  Laboratory results can often be available in less than 30 days.
  Shorter analytical turnaround time can be requested, but this
  will  normally increase the  costs.  Compounds  such  as
  pesticides and PCBs may require longer turnaround times due
  to the extractions and analyses involved. Interpretation of the
  results and final report writing may take up to 3 months, but
  this is highly dependent on the length of time for the review
  process.

  4.8    MANAGEMENT AND STAFFING

  The Work Plan discusses  the management and staffing of a
  treatability study.  The Work Plan specifically identifies the
  personnel responsible for  executing the treatability study  by
  name and  qualifications.  Generally, the following typical
  expertise is needed for the successful completion of the
  treatability study:
 !  Project Manager (Work Assignment Manager)
 !  QA Manager
 !  Environmental/ Chemical Engineer
 !  Chemist
 !  Lab Technician

Responsibility for various aspects of the project is typically
shown in an organizational chart such as the one in Figure 4-4.

4.9   BUDGET

The Work Plan discusses the budget for completion of a
treatability study. Remedy screening, with its associated lack
of replication and detailed testing, can range from $8,000 to
$30,000. These estimates are highly dependent on the factors
discussed in Section 4. Not included in these costs are the
cost of governmental procurement procedures, including
soliciting for bids, awarding contracts, etc.

Costs for remedy selection depend on a variety of factors.
Table 4-3  provides a list of  potential major  cost estimate
components for this tier. Sites where the medium, contaminant
types, and contaminant concentration vary widely will usually
require more samples than sites where  the  medium and
contamination is more homogeneous. It is not unusual for the
sampling, analysis, and QA activities
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    Table 4-3. Major Cost Elements Associated with
    Remedy Selection Thermal Desorption Studies
    Cost Element
    Initial Data Review

    Work Plan Preparation

    Sampling & Testing

    Analysis, QA/QC Activities

    Data Presentation/Report
    TOTAL COST RANGE
  Cost Ranges ($)
  1,000-10,000

  1,000-5,000

  3,000-60,000

  3,000-20,000

  2,000-5,000
$10,000-$100,000
  to represent over 50 percent of the total study cost. In general,
  the costs for analyzing organics are greater than for metals.
  Actual costs will vary according to individual laboratories,
  required turnaround times, volume  discounts, and  any
  customized analytical requirements.
Sampling costs will be influenced by the contaminant types
and depth of contamination found in the medium. The health
and safety considerations during sampling activities are more
extensive when certain contaminants, (e.g., volatile organics),
are present  in the medium. Level  B personal  protective
equipment (PPE) rather than Level D PPE can increase this cost
component  an order  of  magnitude.  Sampling equipment
requirements for surface samples are much less complicated
than those for depth samples. Residuals from treatability
testing require proper treatment and/or  disposal.  If the
residuals  are considered  hazardous  wastes, treatment and
disposal of them will increase costs significantly. It is common
to return the test residuals to the site for storage until remedial
actions are started. This  includes contaminated PPE from
sampling, testing, and analysis.

Other factors to consider include report preparation and the
availability  of vital  equipment  and laboratory  supplies.
Generally, an initial draft of the report under goes internal
review prior to the final draft. Depending on the process, final
report preparation can be  time-consuming as well  as costly.
Procurement of testing equipment and laboratory supplies will
also increase the costs.
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                                               SECTION 5
                           SAMPLING  AND  ANALYSIS  PLAN
  The Sampling and Analysis Plan (SAP) consists of two parts,
  the Field Sampling Plan (FSP) and the Quality Assurance
  Project Plan (QAPP). The purpose of this section is to identify
  the contents and aid in the preparation of these plans. The
  RI/FS requires a SAP for all field activities. The SAP ensures
  that samples obtained for characterization and testing are
  representative  and that the  quality of the analytical data
  generated is known and appropriate. The SAP addresses field
  sampling,medium characterization, and sampling and analysis
  of the treated medium and residuals from the testing apparatus
  or treatment unit. The SAP is usually prepared after Work Plan
  approval.

  5.1     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 equipment and
  procedures  for  collecting the  samples;   the  sample
  chain-of-custody procedures; and there required packaging,
  labeling, and shipping procedures.

  Field  samples  are taken to  provide  baseline contaminant
  concentrations and contaminated material characteristics for
  treatability  studies. The  sampling  objectives must  be
  consistent with the treatability test objectives.

  The primary objectives of remedy selection treatability studies
  are  to evaluate the extent to which specific chemicals can be
  removed from soils,  sediments, or sludges.  The primary
  objectives for collecting samples to be used in treatability
  testing include:

  •   Acquisition of representative  samples.  In some cases
      statistically designed field sampling plans may be required
      to ensure samples taken are representative of the entire
      site. However,  professional  judgment regarding  the
      sampling locations may  be exercised to select sampling
      sites that are typical  of the area (pit, lagoon, etc.) or
      appear above the average concentration of contaminants
      in the area being considered for the treatability test. This
      may be difficult because reliable site characterization data
      may not be available early in the RI stage.

  •   Acquisition of sufficient sample volumes necessary for
      testing,  analysis,  and quality assurance and quality
      control.
From these  two  primary  objectives,  more  specific
objectives/goals are developed. When developing the more
detailed obj ectives, the following types of questions should be
considered:

•   Are there adequate data to determine sampling locations
    indicative of the more contaminated areas of the site?
    Have soil gas surveys been conducted? Contaminants
    may be widespread or isolated in small areas (hot spots).
    Contaminants may be mixed with other contaminants in
    one location and appear alone in others. Concentration
    profiles may vary significantly with depth.

•   Are the soils homogeneous or heterogeneous? Soil types
    can vary  across  a  site and  will  vary  with  depth.
    Depending  on professional  judgement  contaminated
    samples for various soil types may have to be taken to
    conduct treatability tests.

•   Are contaminants present  in  sediments or sludges?
    Different sampling methods must be used for these media.

•   Is  sampling of a  "worst-case"  scenario warranted?
    Assessment of this question must be  made on a site-
    by-site basis. Hot spots and contaminants indifferent
    media may be difficult to treat. These should be factored
    into the test plan if they represent a significant portion of
    the site.

After identifying the  sampling  objectives, an appropriate
sampling strategy is described. Specific items that should be
briefly discussed and included are listed in Table 5-1.

5.2     QUALITY ASSURANCE PROJECT
        PLAN

The  QAPP consists of 11 sections. Since many of these
sections are generic, applicable to any QAPP, and covered in
available documents, WW this guide will discuss only those
aspects  of the QAPP that are affected by the treatability
testing of thermal desorption.

5.2.1   Experimental Description

Section 1 of the QAPP must include an experimental project
description that clearly defines the experimental design, the
experimental sequence  of events, each type of critical
measurement to be made, each type of matrix
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  (experimental setup) to be sampled, and each type of system
  to be monitored. This section may reference section 4 of the
  Work Plan. All details of the experimental design not finalized
  in the Work Plan should be defined in this section.

    Table 5-1.  Suggested Organization of Sampling
                    and Analysis Plan
  Field Sampling Plan

  1.  Site Background
  2.  Sampling Objectives
  3.  Sampling Locating and Frequency
          Selection
          Medium Type
          Sampling Strategy
          Location Map
  4.  Sample Designation
          Recording Procedures
  5.  Sampling Equipment and procedures
          Equipment
          Calibration
          Sampling Procedures
  6.  Sampling Handling and Analysis
          Preservation and Holding Times
          Chain-of Custody
          Transportation
  Quality Assurance Project Plan

  1.  Project Description
          Test Goals
          Critical Variables
          Test Matrix
  2.  Project Organization and Responsibility
  3.  QA Objectives
          Precision, Accuracy, Completeness
          Representativeness and Comparability
          Method Detection Limits
  4.  Sampling Procedures
  5.  Sample Custody
  6.  Calibration Procedures and Frequency
  7.  Analytical Procedures
  8.  Data Reduction,  Validation, and Reporting
  9.  Internal QC Checks
  10. Performance and System Audits
  11. Preventive Maintenance
  12. Calculation of Data Quality Indicators
  13. Corrective Action
  14. QC Reports to Management
  15. References
  16. Other Items
Items in this section  include,  but  are not limited to  the
following:

•   Number of samples (areas) to be studied

•   Identification of treatment conditions (variables) to be
    studied for each sample

•   Target compounds for each sample

•   Number of replicates per treatment condition

•   Criteria for technology retention or rej ection for each type
    of remedy evaluation test

The Project Description clearly defines and distinguishes the
critical measurements from other observations and system
conditions (e.g., process controls, operating parameters, etc.)
routinely  monitored.   Critical  measurements  are  those
measurements, data gathering, or data generating activities
that directly impact the technical objectives of a project. At a
minimum, the determination of the target compound in  the
initial and treated solid samples, bed temperature, and time-at-
temperature will be critical measurements for remedy selection
tests. Concentration of target compounds in all fractions will
be critical measurements for remedy design tests.

5.2.2   Quality Assurance Objectives

Section 2 of the QAPP lists the QA objectives for each critical
measurement and sample matrix defined in section 1. These
objectives are presented in terms of the six data quality
indicators:  precision,  accuracy,  completeness,
representativeness, comparability,  and  where  applicable,
method detection limit.

5.2.3   Sampling  Procedures

The procedures used to obtain field samples for the treatability
study are described in the FSP. They need not be repeated in
this section, but should be incorporated by reference.

Section 3 of the QAPP contains a description of a credible plan
forsubsampling the material delivered to the laboratory for the
treatability study. The methods for aliquoting the material for
determination of chemical and physical characteristics such as
bulk density or specific gravity, moisture content, contaminant
concentration, etc. must be described.

5.2.4   Analytical Procedures and
        Calibration

Section  4 describes  or references appropriate  analytical
methods and standard operating procedures for the analytical
method for each critical measurement made. In addition,  the
calibration  procedures  and frequency of calibration  are
discussed or referenced for each analytical system, instrument,
device, or technique for each critical measurement.

The methods for analyzing the treatability study samples  are
the same as those for chemical characterization of field
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  samples. Preference is given to methods in "Test Methods for
  Evaluating Solid Waste, SW-846,3rd. Ed.,"November 1986.(36)
  Other standard methods may be used, as appropriate. P^xso)
  Methods other than gas chromatography/mass  spectroscopy
  (GC/MS) techniques are recommended to conserve costs when
  possible.

  5.2.5   Data Reduction, Validation and
          Reporting

  Section 5 includes, for each  critical measurement and each
  sample matrix, specific presentation of the requirements for
  data reduction, validation, and reporting. Aspects of these
  requirements are covered in subsections 4.5,4.6, and 6.1 of this
  guide.
5.2.6   Quality Control Reports

Section 10 describes the  QA/QC information that will be
included in the final project report. As a minimum, reports
include:

•   Changes to the QA Project Plan

«   Limitations or constraints on the applicability of the data

•   The status of QA/QC programs,  accomplishments, and
    corrective actions

•   Results of technical systems and performance evaluation
    QC audits

•   Assessments of data quality in terms  of precision,
    accuracy, completeness,   method  detection  limits,
    representativeness, and comparability

The final report contains all the QA/QC information to support
the credibility of the data and the validity of the conclusions.
This information may be presented in an  Appendix to the
report. Additional information on data quality objectives1-25-1
and preparation of  QAPPs(32) is available in EPA  guidance
documents.
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                                                 SECTION  6
                         TREATABILITY  DATA INTERPRETATION
  The remedy screening tier establishes the general applicability
  of the technology. The remedy selection tier demonstrates the
  applicability of the technology to a specific site. The remedy
  design tier provides information in support of the evaluation
  criteria after the ROD. The test goals for each tier are based on
  established  cleanup  goals  or other  performance-based
  specifications. Proper evaluation of the potential of thermal
  desorption for remediating a site must compare the test results
  (described in subsection 4.5) to the test  goals (described in
  subsection 4.1) for the remedy selection tier. The evaluation is
  interpreted in relation to seven of the nine RI/FS evaluation
  criteria, as appropriate.

  Subsection 4.6 of this  guide discusses the need for the
  preparation  of interim and  final  reports and  refers  to  a
  suggested format. In addition to the raw and summary data for
  the treatability study and associated QA/QC, the treatability
  report should describe what the results mean and how to use
  them  in  the  feasibility   study   in  screening/selecting
  alternatives.  The  report  must   evaluate  the expected
  performance of the technology and give an estimate of the
  costs of further treatability studies and final remediation with
  the technology.

  6.1     TECHNOLOGY EVALUATION

  Remedy screening treatability studies are designed to  gain
  fundamental information regarding the proof of concept for the
  technology. Tests are typically conducted using laboratory
  equipment such  as a static tray, DBR,  or other screening
  devices. The contaminant concentration in the medium before
  treatment  is compared to the contaminant concentration after
  treatment. If the measured separation efficiency is sufficient,
  additional treatability studies  are warranted. If the operating
  parameters are properly selected, separation efficiency can be
  high. This would indicate success on the screening level, and
  testing should proceed to remedy  selection. If  remedy
  screening tests are conducted at lower temperatures and/or
  shorter treatment times than those discussed in subsection 4.2,
  removal efficiencies may be lower. It may not be appropriate to
  eliminate thermal desorption as a treatment alternative under
  such cases, since screening tests may be redesigned under
  different  conditions   to  demonstrate higher  removal
  efficiencies. At certain sites, removal efficiencies less than 90
  percent maybe acceptable in meeting expected cleanup goals
  and testing can proceed to remedy selection. Before and after
  concentrations can normally be based on duplicate samples for
  each test  run. The mean  values from  these analyses are
  compared to assess the success of the study. A number of
statistical texts are available if more information is needed.^-"-12-1

The remainder of this section discusses the interpretation of
data from remedy selection treatability studies. Subsections 4.1
and 4.2 of this guide discussed the goals and design of remedy
selection treatability studies, respectively.  The  goals  of
remedy selection are:

•   to address general medium pretreatment and materials
    handling requirements

•   to estimate  performance and cost data of full-scale
    systems

«   to verify that thermal desorption can meet cleanup levels
    at normal operating conditions

•   to define heat input requirements

•   to address general off gas treatment and residuals disposal
    requirements

Data obtained from remedy selection need to be interpreted
with a scale-up tool  (i.e.  past  experience or computer
simulation). Vendors use  past experience to scale up to their
own systems. A properly validated computer simulation can be
another scale-up tool.

One such  computer simulation is the  GRI/NSF  Thermal
Treatment Model(18:i being developed at the University of Utah
to describe the decontamination of a solid  medium when
heated in a rotary dryer. The model describes the heat transfer
to  the  contaminated medium,  the  desorption of   the
contaminant from the medium, and its subsequent fate in the
gas phase. The model consists of two major submodels:

1.   A heat transfer model which  predicts the medium
    temperature as a function of kiln residence time for both
    direct  and indirect  heated  systems which  may  be
    cocurrent or countercurrent.  The  model accounts  for
    heating the  medium  by  convection,  radiation,  and
    conduction in a series of perfectly mixed axial zones. Heat
    can be transferred to the medium from hot gases or from
    the heated shell.

2.   A mass transfer model which predicts organic desorption.
    This requires data from laboratory tests to define a series
    of adjustable parameters which are contaminant  and
    medium dependent.1-14-1
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  3.   The model, which is not vendor-specific, has been used   Example 5 continues from Example 4 and illustrates typical
      to predict the performance of full-scale systems from data   results presented from remedy selection treatability tests. This
      generated in treatability studies. It provides an ideal   example goes on to give the vendor's estimated costs for the
      method for the interpretation of both remedy selection   full-scale   remediation. Costing is  described  further in
      and remedy design data, but it is relevant to rotary dryer   subsection 6.2 of this guide.
      desorption systems only .(14)
                            Example 5. Remedy Selection Treatability Test Results
     BACKGROUND
     In Example 4, the site history, equipment used, and test conditions were reviewed. The same vendor-specific
     treatability test is continued toshow how results could be presented and interpreted.

     RESULTS OF TESTING

     The mass balance isbased on the total time that solids were fed to and discharged from the system. All solid
     products recovered are assumed to  be the average of the three product samples analyzed. Contaminant
     concentrations were measured in the solid and liquid streams only. Analysis of the contaminants in the gas
     phase was not within the scope of this test series. The component recovery calculations are based on the mass
     of the contaminant in the untreated soil feed. The major component recoveries for this study are summarized in
     Table C.

                                   Table C. Major Component Material Balance


          Component                       Total Mass In (g)       Total Mass  Out (g)     %  Recovery

          Solids                                 9,363                  8,912              95.2

          Water*                                1,783                  2,057               115
          Oil and Grease	^.07	0.177	16.5	
            *Based on water content of feed only

     The removal efficiencies of the POHCs are shown  in Table D. The analytical results indicate the concen-
     trations were significantly reduced.


                                       Table D. POHC Removal Efficiency


                                                                                        Proposed
                                        Run  Feed      Product           %          Cleanup Standard
          Contaminant                   (mg/kg)       (mg/kg)        Removal            (mg/kg)

          Chlordane (total)                 2Q 2          QQQ            Q5 7                1Q


          Endrm                          35.7          0.86            97.6                 5


          Heptachl°r                      63.1         <0.33           >99.5                3

          Pentachlorophenol                1Ro         ,.n RI
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                                     Example 5. (continued)

   Based on the test results available versus proposed treatments goals, the vendor process is a suitable
   alternative treatment technology for the pesticide-contaminated soils at the site. For this type of clayey
   soil with a moisture content between 15 and 20 percent, the vendor could process 100 to 130 tons per
   day. To estimate the total amount of material requiring treatment, the site soil volume estimates were
   converted to mass using a calculated in situ density of 1.5 ton/yd3. Table E shows the vendor estimated
   treatment costs, using the Remedy Selection test results and the vendor's experience as a scale-up tool.


                          Table E. Vendor's Treatment Cost Estimate From
                                  Remedy Selection Test Results
                         Item                                  ($/ton)

                         Mobilization/Demobilization                  15.0

                         Operating Labor                           24.5

                         Maintenance                              22.5

                         Capital Charge                            44.0

                         Utilities
                            Electricity                              12.0
                            Propane                               21.5

                         Consumables
                            Nitrogen                               9.5
                            Carbon                                6.0
                            Miscellaneous                          3.5

                         Residual Management
                            Condensed Water                      6.0
                            Condensed Organics                   2.5
                            Filter Cake Recycle                     6.5

                         Total Treatment Cost                   172.5

                         Assumptions:
                            1)  Soil Density =1.5 tons/yd3 (111 Ib/ft3)
                            2)  Feed Rate = 106 tons/day
                            3)  Soil Moisture = 20 percent
                            4)  Total Volume for Treatment = 24,000 yd3
   CONCLUSIONS
   Using a representative sample and a vendor's bench-size, scaled model of their production unit, the
   efficiency of contaminant removal is estimated. This vendor predicted feed rates, organic removal rates,
   and operating costs for the full-scale production unit.

   With this data available,  the RPM  can decide  if the cleanup levels achieved are acceptable, the
   economics are justifiable,  and whether thermal desorption is a viable alternative. If efficiencies are low
   and/or cost data can't be provided, the decision could be to move to remedy design testing for detailed
   information.
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  6.2   ESTIMATION OF COSTS

  Reasonable  preliminary cost estimates  are  crucial to  the
  feasibility  study  process.  Comparisons  of  various
  technologies must be based on the  most  complete and
  accurate estimates available. Remedy  screening treatability
  studies cannot provide this type of information. Preliminary
  co st estimates for full-scale remediation are generally possible
  from remedy selection data. Such estimates may be good
  enough for comparisons to other technologies at the same tier
  of testing. On this basis, the estimates  can form the basis of
  the ROD. Remedy design studies, which  are conducted after
  the ROD has been signed, may be necessary to provide a more
  accurate estimate of the eventual cost of full-scale thermal
  desorption remediation. This is especially true since thermal
  desorption will form only one component of a treatment train.

  6.2.1   Thermal Desorption Remedy
          Selection Cost Estimates

  Remedy selection tests can be used to obtain preliminary cost
  estimates for full-scale systems.

  Data obtained from remedy selection  which are needed to
  estimate full-scale costs include:

  «   medium pretreatment and materials handling

  •   moisture content

  •   contaminant identification and concentration

  •   operating temperature

  •   treatment time

  «   residual contaminants and contaminant concentrations in
      the treated medium

  •   offgas treatment

  Medium  characterization  (i.e.,  moisture   content  and
  contaminant concentration) is needed to  determine the size
  and throughput  of the thermal  desorption unit. Moisture
  content not only determines the heat input that is required but
  also the time required to dry soil. If soil moisture is low or
  minimized through pretreatment, increased throughput rates
  should be realized. (Pretreatment costs must be factored into
 the cost estimate.) Although moisture and concentration
levels may vary throughout the site, average values are
needed  to  make  some  sort of throughput determination.
Operating  temperature  and treatment  time,  which  are
dependent on moisture content and contaminant identification
and  concentration,  are needed as  part  of  the thermal
desorption unit size determination.

The presence of metals or other inorganic contaminants, which
may indicate additional treatment is necessary, needs to be
determined.  Residual  contaminant  concentrations  from
treatability testing are generally not the same as residual levels
from full-scale cleanups. However, they are needed to make
preliminary cost estimates for full-scale systems; any existing
or even empirical full-scale data should be evaluated with
treatability test data to help compensate for inherent scale-up
uncertainties. Offgas treatment  and material handling are
important cost considerations  in any thermal desorption
system. Preliminary cost estimates for material handling cannot
be determined directly from most remedy selection tests but
can  be  derived from site  characterization data.  The total
volume of medium, moisture content, particle size distribution,
and  the presence of any debris are  important factors in
determining material handling costs. Offgas treatment cost
estimates can be derived from offgas analysis conducted in the
treatability study, although they should only be considered
order of magnitude.

6.2.2  Full-Scale Thermal Desorption
       Cost Estimates

Various thermal desorption systems are operating at several
Superfund sites. Vendors have documented processing costs
perton of feed processed. The overall range varies from $80 to
$350/ton of medium processed. Caution is recommended in
using costs out of context because the scope of work may
vary from site to site. It is important to know what costs are
included (e.g., engineering design, excavation, pretreatment,
residual disposal) and what is the base year. Costs also are
highly variable due to the quantity of medium to be processed,
throughput rate (the capacity of the thermal desorption unit),
term of the  remediation contract, moisture content, organic
constituent variation of the contaminated medium, and cleanup
standard to  be achieved. Similarly, cost estimates should
include such items as preparation of Work Plans, permitting,
testing excavation, processing, sampling and analysis, QA/QC
verification of treatment performance, and reporting of data.
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                                                 SECTION  7
                                              REFERENCES
   1.   Abrishamian, R. Thermal Treatment of Refinery Sludges
      and  Contaminated  Soils.  Presented  at  American
      Petroleum Institute, Orlando, Florida, 1990.

   2.   American Society of Agronomy, Inc. Methods of Soil
      Analysis,Part 1, Physical andMineralogical Properties
      Including Statistics of Measurement and Sampling. 1986

   3.   American Society for Testing and Materials. Annual
      Book of ASTM  Standards. November 1987.

   4.   Baker, G.E.  Notes form the Review Meeting on the
      Thermal   Desorption  Treatability   Study  Guide
      -Strawman. In-house files. Meeting conducted June 3-4,
      1991. Cincinnati, Ohio.

   5.   Bevington, P.R. Data Reduction and Error Analysis for
      the Physical Sciences. McGraw-Hill, Inc., New York,
      New York, 1969. 336pp.

   6.   Canonie   Environmental   Services   Corp,  Low
      Temperature Thermal Aeration (LTTA)  Marketing
      Brochures, circa 1990.

   7.   Cudahy,  J. and W. Troxler. 1990 Thermal Remediation
      Industry  Contractor Survey. Journal of the Air and
      Waste Management Association,  40 (8): 1178-1182,
      August 1990.

   8.   Eddings,  E.G. and J.S. Lightly. Fundamental Studies of
      Metal Behavior During Solids Incineration.

      Unpublished. Submitted to  Combustion Science and
      Technology.

   9.   Fox,  R., etal. Thermal Treatment for the Removal of
      PCB's  and Other Organics for Soil.  Environmental
      Progress, 10(1), February, 1991.

   10. Hokanson, S.,  et  al.  Treatability  Studies on Soil
      Contaminated  with Heavy Metals,  Thiocyanates,
      Carbon Disulfate,  Other Volatile and  Semivolatile
      Organic Compounds. In:  Superfund '90 Proceedings of
      the 11th National Conference. Sponsored by Hazardous
      Materials ControlResearchlnstitute, Washington, D. C.,
      November 26-28,1990.

   11. Ikeguchi, T., and S. Gotoh.  Thermal Treatment of
      Contaminated   Soil with  Mercury.  Presented  at
      Demonstration  of Remedial Action Technolgies for
      Contaminated Land and Groundwater, NATO/ CCMS,
      Second  International   Conference,  Bilthoven,  the
      Netherlands, 1988.
12.  Kleinbaum, D.C. andL.L. Kupper. Applied Regression
    Analysis and Other Multivariable Methods. Duxbury
    Press, North Scituate, Massachusettes, 1978. 556 pp.

13.  Law Environmental Onsite  Engineering  Report  for
    Evaluation of the HT-5 High Temperature  Distillation
    Sy stem for Treatment of Contaminated Soils Treatability
    Test Results for a  Simulated K051 API Separator
    Sludge, Vol 1: Executive Summary, 1990.

14.  Lighty,  J.S.,  G.D.  Silcox,  and  D.W.  Pershing.
    Investigation of Rate  Processes in the  Thermal
    Treatment of Contaminated Soils. Final Report for the
    Gas Research Institute, GRI-90/0112, 1990.

15.  Lighty, J.S., et al. On the Fundamentals of Thermal
    Treatment for  the  Cleanup  of Contaminated  Soils.
    Presented at the 81st Annual Meeting  of the Air
    Pollution Control Association, Paper 88-17.5, Dallas,
    Texas, June 19-24, 1988.

16.  Lighty, J.S., et al.  Rate Limiting Processes in  the
    Rotary-Kiln  Incineration of Contaminated   Soils.
    Combustion Science and Technology, 74:31-39, 1990.

17.  National Institute for Occupational Safety  and Health
    (NIOSH) Manual of Methods, U.S.  Department  of
    Health and Human Services, February 1984.

18.  Owens, W.D., G.D. Silcox, J.S. Lighty, X.X. Deng, D.W.
    Pershing, V.A.  Cundy, C. B.  Leger, and A.L. Jakway.
    Thermal  Analysis   of  Rotary  Kiln  Incineration:
    Comparison  of Theory and Experiment. Combustion
    and Flame, 86:101-114.

19.  Personal Communications with various EPA Regional
    Project Managers, April, 1991.

20.  Recycling   Sciences  International,   Inc.,  DAVES
    Marketing Brochures, circa 1990.

21.  Reintjes, R.  and Schuler, C. Seven Years Experience in
    Thermal  Soil   Treatment.  Forum   on   Innovative
    Hazardous Waste Treatment  Technologies: Domestic
    and International, Atlanta, Georgia, June 1989.

22.  Swanstrom, C. and C. Palmer. X*TRAX™ Transportable
    Thermal Separator for Organic Contaminated Solids.
    Presented  at  the  Second  Forum  on   Innovative
    Hazardous Waste Treatment  Technologies: Domestic
    and International, Philadelphia, Pennsylvania, 1990.
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  23. T.D.I. Services, Marketing Brochures, circa 1990.

  24. Troxler, W.L.,  et  al.  Guidance  Document for the
      Application of  Thermal  Desorption  for Treating
      Petroleum  Contaminated Soils.  Prepared  for  U.S.
      Environmental  Protection  Agency, October  1991.
      (unpublished)

  25. U.S. Environmental Protection Agency. Data Quality
      Objectives  for Remedial Response Activities. EPA/
      540/G-87/004, OSWER Directive 9355.0-7B, 1987.

  26. U.S. Environmental Protection Agency. Engineering
      Bulletin:  Thermal  Desorption Treatment.  EPA/540/
      2-91/008,1991.

  27. U.S. Environmental Protection Agency. Guidance for
      Conducting Remedial Investigations and Feasibility
      Studies   Under   CERCLA,   Interim   Final.
      EPA/540/G-89/004, OSWER-9335.3-01,1988.

  28. U.S. Environmental Protection  Agency.  Guide for
      Conducting Treatability  Studies  Under  CERCLA,
      Interim Final. EPA/540/2-89/058,1989.

  29. U.S. Environmental Protection Agency.  Inventory of
      Treatability Study Vendors. EPA/540/2-90/003a, March
      1990.

  30. U.S. Environmental ProtectionAgency.  Methods for
      Chemical Analysis of Water and Wastes.  EPA/600/
      4-79/020,1979.
31.  U.S. Environmental ProtectionAgency. Methods for
    Evaluating  the  Attainment of Cleanup  Standards,
    Volume 1: Soils and Solid Media. EPA/230/2-89/042.

32.  U.S. Environmental Protection Agency. Preparation
    Aids for  the Development of Category III  Quality
    Assurance Project Plans. EPA/600/8-91/005, February
    1991.

33.  U.S. Environmental Protection Agency. Selected Data
    on Innovative Treatment Technologies: For Superfund
    Source Control and Groundwater Remediation, August
    1990.

34.  U.S. Environmental  ProtectionAgency.  SoilSampling
    Quality Assurance User's  Guide. EPA/600/4-84/043,
    1984.

35.  U.S. Environmental  Protection Agency. Technology
    Screening Guide for Treatment of CERCLA Soils and
    Sludges. EPA/540/2-88/004, 1988.

36.  US. Environmental Protection Agency Test Methods
    for Evaluating Solid Waste. 3rd Ed, SW-846, 1986.

37.  U. S. Environmental Protection Agency. The Superfund
    Innovative Technology  Evaluation  Program-Progress
    and Accomplishments Fiscal Year 1989, A Third Report
    to Congress, EPA/540/2-88/004, Cincinnati, Ohio, 1988.

38.  U.S. Environmental  Protection Agency. Treatability
    Studies  Under  CERCLA: An Overview.  OSWER
    Directive 9380.3-02FS, 1987.
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