United States
                               Environmental Protection
                               Agency
                            Office of
                            Solid Waste and
                            Emergency Response
EPA/540/R-93/519b
August 1993
      &EPA
Guide  for  Conducting Treatability
Studies  Under CERCLA:
Biodegradation  Remedy Selection
 Office of Emergency and Remedial Response
 Hazardous Site Control Division OS-220
                                                QUICK REFERENCE FACT SHEET
    Section 121(b) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 mandates
EPA to select remedies that "utilize permanent solutions and alternative treatment technologies or resource recovery technologies to
the maximum extent  practicable" and to prefer remedial actions in which treatment that "permanently and significantly reduces the
volume, toxicity, or mobility of hazardous substances, pollutants, and contaminants is a principal element." Treatability studies provide
data to support remedy selection and implementation. They should be performed as soon as it becomes evident that the available
information is insufficient  to  ensure the quality  of the  decision.  Conducting treatability studies  early  in  the  remedial
investigation/feasibility study (RI/FS) process should reduce uncertainties associated with selecting the remedy and should provide
a sound basis forthe Record of Decision (ROD). Regional planning should factor in thetime and resources required forthese studies.

    This fact sheet provides a summary of information to facilitate the planning and execution of biodegradation remedy selection
treatability studies in  support of the RI/FS and the remedial design/remedial action (RD/RA) processes. It is intended to provide
Remedial Project Managers (RPMs), On Scene Coordinators (OSCs), Potentially Responsible Parties (PRPs), and other interested
persons with enough information to determine whether biodegradation treatability studies may be considered in the remedy selection
phase of the RI/FS for the CERCLA site of interest. This fact sheet follows the organization of the "Guide for Conducting Treatability
Studies Under CERCLA:  Biodegradation Remedy Selection," EPA/540/R-93/514A", 1993. Detailed  information  on designing and
implementing remedy selection treatability studies for biodegradation is provided in the guidance document.
INTRODUCTION

    There are three levels or tiers of treatability studies: remedy
screening,  remedy selection, and RD/RA testing. Treatability
studies conducted during the RI/FS phase (remedy screening
and remedy selection) indicate whetherthe technology can meet
the  cleanup goals for the site, whereas treatability  studies
conducted  during  the  RD/RA  phase establish  design  and
operating  parameters   for optimazation  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
RD/RA.

    Remedy screening studies are designed to provide a quick
and relatively inexpensive  indication of whether biological
degradation is a potentially viable remedial technology.  The
remedy  screening  evaluation  should provide a  preliminary
indication that reductions in contaminant concentrations are due
to  biodegradation  and  not   abiotic  processes  such  as
photodecomposition or volatilization.

    Remedyselection studies should simulate conditions during
bioremediation, allowing  researchers  to  determine  the
technology's performance on a waste-specific basis. Bench-scale
testing is typically used for remedy selection testing; however, it
may fall short of  providing enough  information for  remedy
selection. Pilot-scale testing  also may be appropriate for some
sites. Bench-scale studies can, in some cases, provide enough
information for full-scale design.
                            RD/RAtesting should provide accurate cost and performance
                        data, confirming that biodegradation rates and cleanup levels
                        deteremined during remedy selection can  be achieved forthe
                        site.

                            This fact sheet and its parent document, the "Guide for
                        Conducting Treatability Studies Under CERCLA: Biodegradation
                        Remedy Selection," EPA/540/R-93/514A primarily focus on the
                        remedy selection tier. These documents also briefly discuss
                        remedy screening and RD/RAtesting.

                        TECHNOLOGY DESCRIPTION AND
                        PRELIMINARY SCREENING

                        Technology Description

                            Bioremediation generally refers to the breakdown of organic
                        compounds (contaminants)bymicroorganisms. Bioremediation
                        treatmenttechnologies can be divided into two categories, in situ
                        and ex situ, based upon the location of the contaminated medium
                        during treatment.

                            In Situ

                            In situ biological technologies treat contaminats inplace,
                        eliminating the need for soil excavation and limiting  volatile
                        releases into the atmosphere. As a result, many of the risks and
                        costs  associated with  materials handling  are reduced  or
                        eliminated.
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    In situ  bioremediation usually involves enhancing natural
biodegradation  processes by adding  nutrients, oxygen (if the
process is  aerobic),  and in  some cases, microorganisms to
stimulate the biodegradation of contaminants. The technology
has primarily been used for the treatment of saturated soils. In
situ bioremediation is often in conjunction with a groundwater-
pumping and soil-flushing system to circulate nutrients and
oxygen through  a contaminated aquifer and associated soils.

    Bioventinq is an in situ biological technology predominantly
used to treat reasonably permeable, unsaturated soils. Aeration
systems, similar to those employed during soil vapor extraction,
are used during bioventing to supply oxygen to the soil. An  air
pump, one or more air injection or vacuum extraction probes, and
emissions monitoring at the ground surface are commonly used
during bioventing. In orderto minimize contaminantvolatilization,
low air pressures and air flow rates are typically utilized.  Some
systems, however, utilize higher airflow rates, thereby combining
with soil vapor extraction.

•   Ex Situ

    Ex situ  biological treatment technologies involve removal of
the contaminated media followed by onsite or  offsite treatment.
Although media handling increases the costs of ex situ treatment,
ex situ approaches generally allow greater control of process
variables  (e.g.,  pH,   nutrient concentrations,  temperature,
aeration).

    Solid-phase bioremediation (sometimes referred to as land
treatmentor land farming) is a process that treats soils in above-
ground treatment systems using conventional soil management
practices to enhance microbial degradation of contaminants.
Solid-phase bioremediation at CERCLA sites usually involves
placing excavating soil in an above-ground soil treatment area. If
required, nutrients and  microorganisms are added to the soil,
which is tilled at  regular intervals to improve aeration and contact
between the microorganisms and the contaminants.

    In slurry-phase bioremediation. excavated contaminated soil
is typically placed in an onsite, stirred-tank reactor where the soil
is combined with water to form a slurry. The solids content of the
slurry depends on the type of soil, the type of mixing and aeration
equipment available, and the rates of contaminant removal that
need to be achieved. The water used in the  process can  be
contaminated surfacewater or groundwater,  thus facilitating the
simulataneous treatment of contaminated soil and water. As with
solid-phase biore mediation nutrients and microorganisms may
be added to the  reactor to facilitate biodegradation.

    Soil heap bioremediation involves piling contaminated soil
in  heaps several meters high. Aeration is usually provided by
pulling a vacuum through the  heap. Simple irrigation techniques
are generallyusedto maintain moisture content, pH, and nutrient
concentrations within ranges conducive to the biodegradation of
contaminants. The system can be designed to control the release
of VOCs by enclosing the soil pile and  passing the exhaust from
the exhaust from the vacuum through activated carbon biofilters.

Composting involves the storage of biodegradable waste with a
bulking (e.g., chopped hay or wood chips). The structurally-firm
bulking  agent is  usually biodegradable. Adequate aeration;
optimum temperature, moisture, and nutrient concentrations; and
the presence of  an  appropriate  microbial  population  are
necessary to enhance the decomposition of organic compounds.
The three basic  types of composting systems are open windrow
(where the piles are torn down and rebuilt for aeration), static
windrow (where air is forced into the piles), and in-vessel (where
tumbling, stirring, or forced aeration are used).

    Biofilters can be used to treat organic vapors in a manner
analogous  to  the  biological treatment of wastewaters. By
providing bacteria with a surface on which to grow and optimal
oxygen, temperature, nutrients, moisture, and pH conditions,
biofiliters  can  significantly   reduce  vapor phase  organic
contaminants. The primary components of biofilters are: an air
blower, an air distribution system, filter media,  and a drainage
system. Removal efficiencies in the  range of 95  to 99 percent
have been reported for light aliphatic compounds, while lower
removal efficiencies are common for chlorinated aliphatic and
aromatic compounds.

Technology Status

    As of October 1992, approximately 149 CERCLA, Resource
Conservation  and  Recovery  Act (RCRA),  and  underground
storage tank (LIST) sites, and other government regulated sites
have been  identified by EPA Regions and States as  either
considering  (e.g.,  performing treatability  studies),  planning,
operating full-scale, or having  used biological treatment systems.
Approximately  62 percent of the sites are CERCLA sites, 14
percent are RCRA sites, and 10 percent are LIST sites. The
remaining 14 percent  represent Toxic Substance Control Act
(TSCA), and other Federal and State efforts.

Prescreening Characteristics

    Before a treatability study is conducted, a literature search
should be performed  to confirm whether the compounds  of
interest are  known to  be  amenable to biological treatment.
Evidence of biodegradation under dissimilar conditions,  as well
as data relating to compounds of similar structure,  should be
considered. If preliminary research indicates that bioremediation
is  an  unlikely candidate, further research may be warranted.
Before discarding biological  remediation as an option, expert
recommendations regarding the technology's potential should be
obtained. The "Guide for Conducting  Treatability Studies Under
CERCLA:  Biodegradation  Remedy  Selection",  EPA/540/R-
93/514A,  lists references and electronic databases that can be
useful  when  conducting the literature  search phase of  a
bioremediation project. The  guide also provides contacts for
technical assistance when determining the need  or scope of a
remedy selection treatability study. One important resource for
OSCs  and RPMs  is  the  Technical Support Project (TSP)
coordinated by EPA's  Technology Innovation Office (703-308-
8846).  The TSP  is operated  by EPA laboratories and  offers
technical assistance ranging from review of contractorwork plans
to assistance in the performance of treatability studies.

    The potential biodegradability of the contaminants of concern
is an important characteristic to be examined prior to initiating
treatability studies. Examples of classes of compounds that are
readily amenableto bioremediation are: pertroleum hydrocarbons
such as  gasoline and diesel; wood treating wastes such as
creosote  and pentachlorophenol; solvents such as acetone,
ketones,  and alcohols; and  aromatic compounds  such as
benzene, toluene, xylenes, and phenols. Several documents and
review articles that  present detailed  information  on the
biodegradabilityof compounds are listed in the reference section
of the complete guidance document. However, discretion should
be  exercised  when  using  these  reference  materials, as
microorganisms that can
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biodegrade compounds that have traditionally been considered
nonbiodegradable are continually being isolated through ongoing
research and development efforts.

    Site and soil characteristics that impact bioremediation are
listed in Table 1.  The potential effects of these factors  upon
candidate  biodegradation   technologies  should   also  be
considered.

    There is no steadfast rule that specifies when to proceed with
remedy screening, when  to  eliminate  biodegradation  as  a
treatment technology, or when to proceed to remedy selection
testing based on a  preliminary screening analysis. An analysis of
the existing literature coupled with the site characterization may
provide the information  required to  make a decision. However,
when in doubt, treatability studies are recommended.

Technology  Limitations

    Many factors impact the feasibility of biodegradation. These
factors should be addressed priorto the selection of

    Table 1. Site and Soil Characteristics Identified as
            Important in Biological Treatment
                                          In situ
                                                    Ex situ
 Soil type                                    X
 Extent of contamination                         X
 Soil profile properties
  Boundary characteristics                       X
  Depth of contamination                        X
  Texture*                                   X
  Structure                                   X
  Bulk density*                               X
  Clay content                                X
  Type of clay                                X
  Cation exchange                             X
  Organic matter content*                        X
  pH*                                      X
  Redox potential*                             X


 Hydraulic properties and conditions
  Soil water characteristic curve                   X
  Field capacity/permanent wilting point              X
  Water holding capacity*                        X
  Permeability* (under saturated and a range of        X
  unsaturated conditions)
  Infiltration rates*                             X
  Depth to impermeable layer or bedrock             X
  Depth to groundwater, including seasonal            X
  variations*
  Flooding frequency                           X
  Runoff potential*                             X


 Geological and hydrogeological factors
  Subsurface geological facors                    X
  Groundwater flow patterns and characteristics        X


 Meterological and climatological data
  Wind velocity and direction
  Temperature                                X
  Precipitation                                X
  Water budget                                X


' Factors that may be managed to enhance soil treatment.
biodegradation and prior to the investment of time and funds in
further testing.  Some of these factors that may limit the use of
bioremedial technologies include the amount, location, extent,
and variability of the contamination. The physical form in which the
contaminants are distributed, as well as heterogeneities within
the  media  to  be  treated,  may   limit  the applicability  of
biodegradation.

    Soil  characteristics,  such  as  nonuniform  particle  size
distribution, soil type, moisture content, hydraulic conductivity, and
permeability,   can  also  significantly  affect  biodegradation.
Significant quantities of  organic matter  (humus,  peat,  non-
regulated anthropomorphic compounds, etc.) also may cause
high oxygen uptake rates, resulting in depleted oxygen supplies
during in  situ application. Contaminant volatility  is particularly
important,  especially in stirred or aerated reactors where the
contaminants can volatilize before being degraded.

    The presence of eitheran indigenous or introduced microbial
population capable of degrading the contaminants of concern is
usually essential to the success of biological processes. Each
contaminant has a range of concentrations at which the potential
for biodegradation is maximized. Below  this range microbial
activity may not occur withoutthe addition of a co-substrate. Above
this  range,  microbial activity may  be  inhibited  and,  once
concentrations are reached, eventually arrested. During inhibition,
contaminant degradation generally occurs at a reduced  rate.  In
contrast,  at toxic concentrations contaminant degradation does
not occur. The concentrations at which microbial growth is either
supported, inhibited, or arrested vary with the contaminant, media,
and microbial species.

    Although preliminary data  may  be  obtained  that seem to
indicate that the technology is capable of reducing contamination
levels to acceptable limits, the rate of contaminant removal from
soil during bioremediation exhibits asymptotic characteristics.
The initial rate of removal, after a potential lag period, is rapid.
With time,  the  rate decreases to a near-zero value, and the
contaminant  concentration  in the  soil  approaches  a  fixed
concentration that is typically nonzero (the asymptote). Since the
asymptote isdifficultto predict and is sometimes greaterthan the
cleanup criteria, treatability testing must be continued until either
the removal goals are met or the asymptote is reached.

THEUSEOFTREATABILITYSTUDIESIN
REMEDY EVALUATION

    Treatability studies should be performed in  a systematic
fashion to ensure that the data generated can support the remedy
evaluation  and implementation  process.  A  well-designed
treatability study can significantly reduce the overall uncertainty
associated with the decision,  but cannot guarantee that the
chosen alternative will be completely successful.  Care must be
exercised to ensure that the treatability study is representative of
the treatment (e.g., the sample is representative of waste to be
treated) as it will be employed to minimize uncertainty in the
decision.

Treatability Testing Process

    Treatability studies for a particular site  will often entail
multiple tiers of testing. By balancing the time and cost necessary
to perform the testing with the risks inherent in the decision, the
level of treatability testing required can be determined. Criteria for
measuring the success of each level of treatability study are listed
in Table 2.
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    Remedy screening is the first level of testing. It is used to
determine  whether  biodegradation is  possible with  the  site-
specific waste  material. These studies are generally low cost
(e.g., $10,000 to $50,000) and usually require 1 weekto several
months to complete. Additional time must be allowed for project
planning, chemical  analyses,  interpretation of test data, and
report  writing.  Only limited quality control  is  required. These
studies yield data indicating  a technology's potential  to  meet
performance goals.

    Remedy selection testing is the second level of testing. To
the maximum extent practical,  remedy selection tests should
simulate site conditions during treatment, allowing researchers
to identify the technology's performance on a waste-specific basis
for an  operable unit. These studies are generally of moderate
cost (e.g., $50,000 to $300,000) and may require several weeks
to two years to complete. They yield  data  that verify  that the
technology is likely  to meet expected cleanup goals and can
provide information  in support of the  detailed analysis of the
alternative.

    RD/RA testing is the third level of testing. By operating a field
unit under conditions similar to those expected during full-scale
remediation, the study can provide data required forfinal full-scale
design and accurate cost and time estimates. Unit operating
parameters can be optimized and the ability to
                                achieve  cleanup levels can be confirmed. These studies are of
                                moderate to high cost (e.g., $100,000 to $500,000) and  may
                                require several months or more to complete. They are performed
                                during the  remedy implementation  phase  of  a  site cleanup.
                                Figure 1 shows the relationship of the three levels of treatability
                                study to  each other and to the RI/FS process.

                                Applicability of Treatability Tests

                                    Before conducting treatability studies, the objectives of each
                                tier of testing  must be established. Biodegradation  treatability
                                study objectives are based upon the specific needs of the RI/FS.
                                There are nine evaluation  criteria specified  in the document,
                                "Guidance forConducting Remedial Investigations and Feasibility
                                Studies  Under CERCLA" (EPA/540/6-89/004). A detailed analysis
                                of different remedial alternatives using the nine CERCLA criteria
                                is essential. Treatability studies provide data for up to seven of
                                these criteria.

                                    These seven criteria are:

                                !    Overall protection of human health and the environment

                                !    Compliance with applicable or  relevant and appropriate
                                    requirements (ARARS)
                               Table 2. Biodegradation Criteria for Each Treatability Study Tier
 Criteria
Remedy Screening
Remedy Selection
Remedy design
  Biodegradation of most-resistant    >20% net removal compared to
  contaminants of concern          removal in inhibited control

  Initial contaminant concentration    Optimal for technology
  Environmental conditions


  Extent of biodegradation

  Biodegradation rate

  Estimate time to reach cleanup
  standards

  Mass balance

  Toxic byproducts

  Process control and reliability
Optimal for technology (include
site conditions if possible)

Estimate*

Crude estimate*

NA


Crude*

Detect*

NA
Meets cleanup standards under
test conditions

Maximum concentration expected
during remediation

Simulate expected site treatment
conditions

Quantify

Defensible estimate

Estimate
Meets cleanup standards under
site conditions

Actual range of concentrations
expected during remediation

Actual site treatment conditions
for the specific technology

Quantify

Quantify

Refined estimate
Closure or defensible explanation    Closure or defensible explanation

Test for if appropriate*             Test for if appropriate

Assess potential                 Demonstrate
  Microbial activity

  Process optimization

  Cost estimate for full-scale

  Bid specifications

  Experimental scale
Crude measure*

NA

NA

NA

Usually bench-scale
Verify/quantify*

Estimate*

Rough, -30%, +50%

NA

Either bench- or pilot-scale
Quantify/monitor*

Refined estimate

Detailed/refined

Nearly complete

Usually pilot- or full-scale
 Not required, although sometimes possible to address significantly.
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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
Jmplementation
   of Remedy
                                                                                          RD/RA
                                                                                    to Develop Scale-Up,
                                                                                    Design, and Detailed
                                                                                          Cost Data
                         Figure 1. The Role of Treatability Studies in the RI/FS and RD/RA Process.
!    Long-term effectiveness and permanence

!    Reduction of toxicity, mobility, or volume through treatment

!    Short-term effectiveness

!    Implementability

!    Cost

    The two remaining CERCLA criteria, State and community
acceptance, are based in part on the preferences  and concerns
of the State and community regarding alternative technologies. An
available remediation  technology may  be  eliminated from
consideration if the state or community objects to its use. Table
3 shows how the study goals of a remedy selection treatability
test address RI/FS criteria and the experimental parameters
measured to assess the achievement of those goals.

REMEDY SELECTION TREATABILITY STUDY WORK PLAN

    Carefully planned treatability studies are necessary to ensure
that the data generated are useful for evaluating the validity or
performance of a technology. The Work Plan, prepared by the
contractor when the Work Assignment is in place, sets forth the
contractor's proposed technical approach for completing  the
tasks  outlined in the Work  Assignment.  It  also  assigns
responsibilities and establishes the project schedule and costs.
The Work Plan must be approved by the  RPM
                                  before initiating subsequent tasks. A suggested organization of
                                  the Work Plan is provided in the "Guide for Conducting Treatability
                                  Studies  Under CERCLA: Biodegradation Remedy Selection",
                                  EPA/540/R-93/514a.

                                  Test Goals

                                      Remedy selection treatability  goals  must consider  the
                                  existing site contaminant levels  and  cleanup goals for soils,
                                  sludges, and water at the site. The ideal technology performance
                                  goals for remedy selection treatability tests are the cleanup
                                  criteria for the site. Example remedy selection goals are listed in
                                  Table 3. 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 are risk-based rather than  background-based.

                                  Experimental Design

                                      Careful planning during treatability study design is required
                                  to ensure adequate treatability study data are obtained. Among
                                  other requirements, the experiments, the experimental design
                                  must identifythe critical parameters  and determine the required
                                  number of replicate tests. Treatability studies can be designed to
                                  simulate  aerobic conditions,  or  may  be  planned to assess
                                  biodegradation under anaerobic conditions. Ultimately, remedy
                                  selection studies  should  strive  to simulate the conditions
                                  encountered during full-scale applications of the technology
                                  understudy.
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                  Table 3. Ability of Remedy Selection Treatability Studies to Address RI/FS Criteria
 Study goals
          Experimental parameters
            RI/FS criteria*
 Compare performance, cost, etc., of different
 treatment systems at a specific site
Dependent on type of treatment systems
compared
 Measure the initial and final contaminant
 concentrations, and calculate the percentage
 of contaminant removal from the soil, sludge,
 or water through  biodegradation
 Estimate the type and concentration of
 residual contaminants and/or byproducts left
 in the soil after treatment

 Develop estimates for reductions in
 contaminant toxicity, volume, or mobility
 Identify contaminant fate and the relative
 removals due to biological and nonbiological
 removal mechanisms
 Produce design information required for next
 level of testing
 Develop preliminary cost and time estimates
 for full-scale remediation
 Evaluate need for pretreatment and
 requirements for long-term operation,
 maintenance, and monitoring
 Evaluate need for additional steps within
 treatment train
 Assess ability of bioremediation to meet site-
 specific cleanup levels
 Determine optimal conditions for
 biodegradation and evaluate steps needed to
 stimulate biodegradation
Contaminant concentration
Contaminant/byproduct concentration
Contaminant concentration, toxicity testing

Contaminant concentrations present in solid,
liquid, and gaseous phases taken from test
and control reactors, oxygen uptake/CO2
evolution
Temperature, pH, moisture, nutrient
concentrations and delivery, concentration
and delivery of electron donors and
acceptors, microbial composition, soil
characteristics, test duration, nonbiological
removal processes
Treatability study cost (i.e., material and
energy inputs, residuals quality and
production, O&M costs, where appropriate),
test duration, time required to meet
performance goals
Soil characteristics, contaminant
concent ration/toxicity
Soil characteristics, contaminant
concentration, nonbiological removal
processes, residual quality (relative to further
treatment and/or disposal requirements)

Contaminant concentration
Temperature, pH, nutrient concentrations and
delivery, concentration and delivery of
electron donors nad acceptors, microbial
composition, soil characteristics, test duration,
contaminant concentration
Overall protection of human health and the
environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, and volume
through treatment
Short-term effectiveness
Implementability
Cost
Overall protection of human health and the
environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, and volume
through treatment
Overall protection of human health and the
environment
Compliance with ARARs
Long-term effectiveness and permanence

Reduction of toxicity, mobility, and volume
through treatment
Overall protection of human health and the
environment
Long-term effectiveness and permanence
Reduction of toxicity, mobility, and voume
through treatment
Short-term effectiveness

Implementability
Cost
Short-term effectiveness
Implementability
Cost
Compliance with ARARs
Long-term effectiveness and permanence
Short-term effectiveness
Implementability
Cost

Overall protection of human health and the
environment
Long-term effectiveness and permanence
Implementability
Cost
Overall protection of human health and the
environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility, and volume
through treatment
Short-term effectiveness
Implementability
Cost
 Depending on specific components of the remedy selection treatability study, additional study, additional criteria may be applicable.
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    A number of factors influence the basic design of biological
studies. These factors have a profound impact  on  both the
treatability study operation and utility. Important factors to  be
considered when designing a biological treatability study included
the following:

    Overall  test objectives  (as dictated by site  remediation
    objectives)

    Specific removal goals or desired cleanup levels (as set for
    a specific site)

    Soil characteristics (soils with higher permeability are more
    amenable to in situ biodegradation)

    pH (most microbialdegraders thrive when the pH is between
    6.5 and 8.5)

    Temperature (optimum range is usually between 15°C and
    30°C for aerobic processes and 25°Cto 35°C for anaerobic
    processes)

    Moisture (optimum range  is usually between 40 and 80
    percent of field capacity)

    Nutrients (concentrations  should be  maintained  at a rea-
    sonably moderate but steady-state concentration determined
    experimentally)

    Electron acceptors (usually oxygen derived from air,  pure
    oxygen,  ozone, or hydrogen peroxide for aerobic studies and
    nitrates  for anaerobic tests)

    Microorganisms (the  use of introduced  versus indigenous
    populations)

    Duration of test (sufficientto determine ability of treatmentto
    meet removal goals)

    Inhibitory compounds and their control (dilution of media may
    be required)

    Impact  of  nonbiological  removal  processes (extent of
    volatilization, sorption, photodecomposition, leaching, as
    experienced by inhibited controls)
                                        !   Toxicity testing (to evaluate the risk reduction experienced
                                           during treatment)

                                        !   Bioavailability (contaminants that biodegrade easily will be
                                           utilized earliest)

                                           In situ remedy selection treatability studies are either field
                                        plot or soil column designs. Soil column studies may also be
                                        performed ex situ,  usually within  a laboratory setting.  Three
                                        additional ex situ experimental designs are soil pans,  soil
                                        slurries, and contained soil treatment systems. Table 4 presents
                                        information on remedy selection treatability study experimental
                                        designs,  including their  applicability, scale, typical size,  and
                                        duration.

                                           The test system used during remedy selection testing can
                                        consist of a single  large reactor  or multiple small  reactors.
                                        Studies which employ large reactors include field studies, large
                                        flask studies, and soil pan studies.  Multiple reactors consisting
                                        of serum  bottles, small slurry reactors, and small soil reactors
                                        may be set up in place of a single large system. When a single
                                        reactoris used, small samples may  be removed atvarioustimes
                                        and compared to samples from control reactors.  When using
                                        large  reactors, care should be taken to ensure thatthe availability
                                        of  supplements (i.e.,  oxygen  and  moisture)  are  adequate,
                                        allowing for  consistent degradation rates  within  the reactor.
                                        Additionally, sampling must be sized so that it does not affect the
                                        operation  of the  overall unit. Remedy selection treatability tests
                                        should include controls to measure the impact of nonbiological
                                        processess,   such  as   volatilization,  sorption,   chemical
                                        degradation,   migration,  and  photodecomposition.  Inhibited
                                        controls can  be established by adding formaldehyde, mercuric
                                        cholride (during non-EPA studies), sulfuric acid (added to lower
                                        the pH to 2 or below), or sodium azide to retard microbial activity.
                                        Contaminant concentrations are  measured  in both  the  test
                                        reactors and the control reactors at the beginning of the study (T0),
                                        at intermediate times, and at the end of the study. The mean
                                        contaminant concentrations in both  the control and test reactors
                                        at  the  end  of  the test can  be compared  to  their  intial
                                        concentrations in both the control and test reactors  at the end of
                                        the test can be compared to their initial concentrations to see if a
                                        statisticallysignificant change in concentration has occurred. The
                                        decrease  in the control reactors may be attributed
                            Table 4. Remedy Selection Treatability Study Characteristics
Type of Study
Field plots
Soil columns
Soil pans
Slurry-phase
reactors
Applicability
In situ bioremediation
In situ bioremediation
Solid-phase treatment
Slurry-phase and
solid-phase (occasionally)
treatment
Scale
Field-scale
Lab- and
field-scale
Lab-scale
Field-scale
Size
1 to 1,111 yd2 plot of land*
0.01 -3,200 ft3 of soil,
sand, sediment, or stone
2 to 100 Ibsof soil
Greater than 20 gallons of
slurried media
Duration
2 months to 2 years
1 week to 6 months
1 to 6 months
2 to 3 months
 Contained soil
  systems
Composting, soil heap
  bioremediation, and
  solid-phase treatment
Lab-scale

Lab- and
 field-scale
1 fluid oz to 20 gallons

7ft3to3,9003ydsofsoil
1 to 8 weeks

10 days to 10 months
 * Field plot are given as areas rather than volumes because treatment depths are frequently undefined
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to abiotic mechanisms, while the decrease in the test reactors
would be a result of abiotic and biotic processes. The difference
in mean contaminant concentrations between the test reactors
and the inhibited control reactors will show whether there is a
statistically significant reduction in contaminant concentration due
to microbial activity. Care should  be taken to assess the effects
that the different sterilizing  agents can have on the chemical
behavior of the soil-contaminant  system.

    Complete sterilization of soils can be difficultto accomplish.
Incomplete mixing of sterilization agents with soils can result in
pockets of surviving microbes  in soil pores.  In some cases,
microbial  populations can  transform  and detoxify sterilizing
agents. Additional  agents can be provided during the test to
maintain  reduced   biological  activity.  The  effectiveness  of
sterilizing  agents can be measured by techniques  such  as
microbial  enumeration,  respirometry, and enzyme   analysis.
Unless these or similar techniques show very  low  microbial
activity, it may not be possible to distinguish between removal of
contaminants by abiotic and biological processes in the control
reactors. However,  complete  sterilization  of the control is not
necessary provided biological activity is inhibited to the extent that
a statistically significant difference between the test and control
means can be determined.

    When designing a treatabiliity study, the types of equipment
required for  the test must be  considered. Standard laboratory
equipment such as mixing flasks and sample collection bottles
should be available for all treatability studies. A wide variety of
equipmentis employed during biodegradation treatabiliity testing
to  contain the media under study  or  isolate it  from the
environment. During soil column studies,  a metal, plastic, or
glass cylinder may be used onsite or offsite as part of a laboratory
study. Field plots, on the other hand, may require that  in-ground
barriers, such as sheets ofsteel driven into the ground, orabove-
ground barriers such as berms be used to separate testing plots
from one another or from soil located outside of the testing area.
Slurry reactors, which range in size from 1  fluid ounce vials to
70,000-gallon lagoons, typically utilize 0.1- to 130-gallon vessels.
In  contrast,  contained soil treatment systems  will  generally
require a bermed, watertight area in which the soil can be placed.
The vessels required for contained soil teatability studies also vary
considerably,  since  they  may  be  designed  to   simulate
composting, soil heaping,  or other solid-phase  biotreatment
technologies. Depending on the type and scale of the system, a
leachate collection system and other accessories may also be
required.

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). A SAP is required  for all field activities conducted
during  the RI/FS.  The purpose of the  SAP is to ensure that
samples  obtained  for  characterization  and  testing  are
representative and thatthe quality of the analytical data generated
is  satisfactory. The  SAP  addresses field sampling,  waste
characterization, and sampling and analysis of the treated wastes
and residuals from the testing  apparatus or treatment  unit. The
SAP is usually prepared after Work Plan approval.

TREATABILITY DATA INTERPRETATION

    When conducting treatability studies,  the  test results and
goals for each tier must be properly evaluated to assess the
treatment potential of bioremediation. The remedy screening tier
establishes  the  general applicability of the  technology. The
remedy selection testing tier  demonstrates the applicability of the
technology to a specific site. The RD/RA tier provides information
in support of the evaluation criteria.

      Interpretation of remedy selection test results should allow
the RPM  or OSC to determine whether the  bioremediation
technology used is capable of meeting cleanup standards under
simulated (or actual) site conditions. The experimental design of
the study should have been constructed to produce quantitative
and statistically defensible estimates of the extent and rate of
biodegradation. Ideally, a statistical evaluation of the difference
between biodegradation rates when parameters such as nutrient
addition,  loading  rate, and microbial composition are varied,
should also  be  designed.  Example 1  describes  a remedy
selection treatability test and the interpretation ofthe test results.

Estimation  of Costs

      Complete and accurate  cost estimates are required in
order to  fully recommend technologies for  site remediation.
Consequently, when making  preliminary cost  estimates for full-
scale bioremediation, achieveable cleanup levels, degradation
rates, concentration  and  application frequencies of various
degradation  enhancing supplements (e.g., nutrients, lime, water,
etc.),  contaminant   migration   controls,   and  monitoring
requirements must be considered. The impact these parameters
have on labor, analytical, material and energy costs,  as well as
the  unit's  design  and  possible pre-  and  post-treatment
requirements, also must be considered.

      Generally,  large-scale field tests  can be designed to
simulate full-scale performance and costs more accurately than
laboratory studies. However, estimating  full-scale  cost  from
treatability study data can be difficult. Given the variability and
interaction of factors such as soil temperature, pH,  moisture,
heterogenous contaminant concentrations, and optimal nutrient
concentrations, empirical results may not always depictthe range
of reasonable  bioremediation  results.  One  approach  to
examining the variability and  interaction of these  factors  is
simulation modeling.  Simulation  models (e.g., Monte  Carlo
models) attempt to quantify the probability that a certain set of
events or values will occur based upon available empirical data.
Using probabilistic simulation methods can produce time and
cost estimates for a particular  confidence level and a specific
level of certainty (e.g., the ability to state with 90 percent certainty
that the cost of the project will be within ±40  percent of the
estimate).

TECHNICAL ASSISTANCE

      Information from existing literature and consultation with
experts are  important factors in determining  the need for and
ensuring the usefulness of treatability studies. A reference list of
sources  on  treatability studies is provided in  the "Guide  for
Conducting  Treatability Studies Under CERCLA" (EPA/540/R-
92/071 a).

      It is recommended that a Technical Advisory Committee
(TAG) be used.  This  committee includes experts who provide
technical support from the scoping phase of the treatability study
through  data evaluation. Members  of the TAG may include
representatives  from EPA (Regions  or  ORD),  other Federal
agencies, States, and consulting firms.
      The Office of Solid Waste and Emergency Response and
Office of Research and  Development operate the TSP which
provides assistance in the planning, performance, and review
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                                                     Example 1
    A remedy selection treatability study was performed to evaluate  a slurry-phase technology's ability to remediate  an
    impoundment contaminated with petroleum refinery sludges. Surfactants and nutrients were added. Reactor performance
    was monitored by measuring the oxygen uptake rate and oil and grease (O&G) removal. Based on extensive experience with
    O&G biodegradation, toxicity was not performed.
    The average initial O&G concentration in the sediment was 41,000 ppm, the maximum concentration expected in the full-scale
    (70,000 gallon), slurry bioreactor. A cleanup goal of 20,000 ppm O&G was targeted during the study. After 4 weeks, the average
    O&G concentration  in the inhibited control was reduced to 39,000 ppm, a reduction to 39,000 ppm, a reduction of nearly 5
    percent. The average O&G concentration in the biologically active system was reduced to 14,000 ppm, a 66 percent reduction
    in the same time period. The leveling out of O&G concentrations at the end of the experiment indicates that the maximum
    extent of biodegradation achievable under the test conditions had been reached.
                                                                   O&G
                  Sample
                                                    T4
                  Bioreactor
                  Replicate 1
                  Replicate 2
                  Replicate 3
                  Mean Value

                  Inhibited Control
                  Replicate 1
                  Replicate 2
                  Replicate 3
                  Mean Value
39,000
41,000
43,000
41,000
39,000
41,000
43,000
41,000
32,000
34,000
39,000
35,000
36,000
39,000
42,000
39,000
21,000
24,000
24,000
23,000
37,000
40,000
40,000
39,000
13,000
15,000
17,000
15,000
37,000
41,000
39,000
39,000
14,000
16,000
12,000
14,000
42,000
36,000
39,000
39,000
    The average contaminant concentration in  the slurry-phase bioreactor at each time-point is compared to the average
    contaminant concentration in the inhibited control at the same time-point to measure the biodegradation at that time-point.
    The inhibited control accounts for contaminant losses due to volatilization, adsorption to soil particles, and chemical reactions.
    Some contaminant loss in the control due to biodegradation may occur since total sterilization is difficult to accomplish.
    However, an O&G analysis of the extract generated from the slurry-phase reactor indicated that abiotic losses were due mainly
    to adsorption. Since a statistically significant difference between the test and control means exists, O&G reductions in the test
    bioreactor were attributed to biodegradation.
of treatability studies. For further information on treatability study
support orthe TSP, please contact:
    Groundwater Fate and Transport Technical
        Support Center
        Robert S. Kerr Environmental Research
        Laboratory, (RSKERL)
        Ada, OK 74820
        Contract: Don Draper
        (405) 332-8800
    Engineering Technical Support Center (ETSC)
        Risk Reduction Engineering Laboratory (RREL)
        Cincinnati, OH 45268
        Contact: Ben Blaney or Joan Colson
        (513) 569-7406 or (513) 569-7501
FOR FURTHER INFORMATION
    Sources  of  information   on  treatability   studies  and
bioremediation are listed in the "Guide for Conducting Treatability
Studies Under CERCLA" (EPA/540/R-92/071 a) and the "Guide for
Conducting Treatability Studies Under CERCLA: Biodegradation
                  Remedy Selection" (EPA/540/R-93/541 A). Additionally, the Office
                  of Emergency and Remedial Response's Hazardous Site Control
                  for  each  Region should  be  contacted  for  information  and
                  assistance.
                  ACKNOWLEDGMENTS
                        This fact sheet and the corresponding guidance document
                  were  prepared for the U.S. Environmental Protection Agency,
                  Office  of  Research   and  Development,   Risk  Reduction
                  Engineering Laboratory, Cincinnati, Ohio by Science Applications
                  International Corporation (SAIC) under Contract No. 68-C8-
                  0061 and Contact No. 68-CO-0048. Mr. Ed Opatken served as the
                  EPA Technical Project Monitor. Mr. Jim Rawe served as SAIC's
                  Work  Assignment Manager. Mr.  Rawe,  Ms. Evelyn Meagher-
                  Hartzell, and Ms. Sharon Krietemeyer (SAIC) were the primary
                  technical authors. Mr. Derek Ross (ERM) and  Mr. Kurt Whitford
                  (SAIC) served as a techinical experts.
                        Many Agency and independent reviewers have contributed
                  their time and comments by participating in the expert  review
                  meetings or peer reviewing the guidance document.
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