oEPA
United States
Environmental Protection
Agency
Office of Emergi ncy and
Remedial Response
Washington DC 20460
Office of
Research and Development
Cincinnati, OH 45268
Superfund
EPA/540/2-89/Ob6'.
December 1989
Guide for Conducting
Treatability Studies
UnderCERCLA
Interim Fina
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EPA/540/2-89/058
December 1989
GUIDE FOR CONDUCTING
TREATABILITY STUDIES UNDER CERCLA
INTERIM FINAL ^
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RESEARCH AND DEVELOPMENT
CINCINNATI, OHIO 45268
AND
OFFICE OF EMERGENCY AND REMEDIAL RESPONSE
WASHINGTON, D.C. 20460 u$ Environmenta| Protection Agency
Region 5, Library (PL-12J)
77 Wast Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
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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. 68-03-3413,
Work Assignment No. 2-53, to PEI Associates, Inc. It has been subjected to
the Agency's peer and administrative review, and it has been approved for
publication as an EPA document. Mention of trade names or commercial prod-
ucts does not constitute endorsement or recommendation for use.
11
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FOREWORD
Today's rapidly developing and changing technologies and industrial
products and practices frequently carry with them the increased generation of
materials that, if improperly dealt with, can threaten both public health and
the environment. The U.S. Environmental Protection Agency (EPA) is charged
by Congress with protecting the Nation's land, air, and water resources.
Under a mandate of national environmental laws, the Agency strives to formu-
late and implement actions leading to a compatible balance between human
activities and the ability of natural systems to support and nurture life.
These laws direct the EPA to perform research to define our environmental
problems, measure the impacts, and search for solutions.
The Risk Reduction Engineering Laboratory is responsible for planning,
implementing, and managing research, development, and demonstration programs
to provide an authoritative, defensible engineering basis in support of the
policies, programs, and regulations of the EPA with respect to drinking
water, wastewater, pesticides, toxic substances, solid and hazardous wastes,
and Superfund-related activities. This publication is one of the products of
that research and provides a vital communication link between the researcher
and the user community.
The purpose of this guide is to provide information on conducting treat-
ability studies. It describes a three-tiered approach that consists of
1) laboratory screening, 2) bench-scale testing, and 3) pilot-scale testing.
It also presents a protocol for conducting treatability studies in a system-
atic and stepwise fashion for determination of the effectiveness of a tech-
nology (or combination of technologies) in remediating a CERCLA site. The
intended audience for this guide comprises Remedial Project Managers, respon-
sible parties, contractors, and technology vendors.
E. Timothy Oppelt, Director
Risk Reduction Engineering Laboratory
111
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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 guide, which is
being issued as an Interim Final, focuses on treatability studies conducted
in support of remedy selection [i.e., pre-Record of Decision (ROD)]; treata-
bility studies in support of remedy implementation (i.e., post-ROD) will be
addressed when the document is issued in final form.
The guide describes a three-tiered approach for conducting treatability
studies that consists of 1) laboratory screening, 2) bench-scale testing, and
3) pilot-scale testing. Depending on the information gathered during site
characterization and technology screening and the data gaps that exist,
treatability studies may begin with any tier (e.g., bench-scale testing) and
may skip tiers that are not needed (e.g., laboratory screening followed by
pilot-scale testing).
The guide also presents a stepwise approach or protocol for conducting
treatability studies for determination of the effectiveness of a technology
(or combination of technologies) in remediating a CERCLA site. The steps
include:
0 Establishing data quality objectives
0 Selecting a contracting mechanism
0 Issuing the Work Assignment
0 Preparing the Work Plan
0 Preparing the Sampling and Analysis Plan
0 Preparing the Health and Safety Plan
0 Conducting community relations activities
0 Complying with regulatory requirements
0 Executing the study
0 Analyzing and interpreting the data
0 Reporting the results
The intended audience for this guide comprises Remedial Project Managers,
responsible parties, contractors, and technology vendors.
This document covers the period from June 1989 to September 1989, and
work was completed as of November 1989.
iv
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CONTENTS
Page
Foreword i i i
Abstract iv
Figures vii
Tables viii
Abbreviations x
Aknowledgments xii
1. Introduction 1
1.1 Background 1
1.2 Purpose and scope 2
1.3 Intended audience 2
1.4 Use of the guide 3
2. Overview of Treatability Studies 6
2.1 Treatability studies in the RI/FS process 6
2.2 Tiers of treatability testing 13
2.3 Applying the tiered approach 19
3. Protocol for Conducting Treatability Studies 30
3.1 Introduction 30
3.2 Establishing data quality objectives 30
3.3 Selecting a contracting mechanism 35
3.4 Issuing the Work Assignment 38
3.5 Preparing the Work Plan 41
3.6 Preparing the Sampling and Analysis Plan 55
3.7 Preparing the Health and Safety Plan 57
3.8 Conducting community relations activities 59
3.9 Complying with regulatory requirements 61
3.10 Executing the study 69
3.11 Analyzing and interpreting the data 72
3.12 Reporting the results 75
References 79
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CONTENTS (continued)
Appendices
A - Sources of Treatability Information 80
B - Cost Elements Associated with Treatability Studies 85
C - Technology-Specific Characterization Parameters 88
D - Standard Analytical Methods for Characterizing Wastes 99
Glossary 112
vi
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FIGURES
Number Page
1 The role of treatability studies in the RI/FS and RD/RA
process 8
2 Decision tree showing when treatability studies are needed
to support the evaluation and selection of an alternative 9
3 Flow diagram of the tiered approach 21
4 Information contained in EPA's inventory of treatability
study vendors 36
5 Example diagram of the test apparatus for a KPEG labora-
tory screening study 47
6 Example of Field Activity Daily Log 48
7 Example project schedule for a bench-scale treatability
study 52
8 Example organization chart for a treatability study 53
9 Graphic representation of experimental space for three
primary independent variables tested at two levels 54
10 Regulatory requirements for onsite and offsite testing 63
11 Example of Chain-of-Custody Record 70
12 Example plot of initial versus final contaminant concen-
tration 74
13 General applicability of cost elements to various 86
treatability study tiers
vi i
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TABLES
Number
1 General Comparison of Laboratory Screening, Bench-Scale
Testing, and Pilot-Scale Testing 14
2 Summary of Analytical Levels 32
3 Suggested Organization of Treatability Study Work Assignment 39
4 Suggested Organization of Treatability Study Work Plan 42
5 Example Test Matrix for Zeolite Amendment Bench-Scale
Treatability Study 43
6 Example Standard Operating Procedure for Thermal Desorp-
tion Bench-Scale Treatability Study 44
7 Example List of Equipment and Materials for a KPEG Labora-
tory Screening Study 46
8 Waste Parameters Required to Obtain Disposal Approval at
an Offsite Facility 50
9 Suggested Organization of Sampling and Analysis Plan 56
10 Suggested Organization of Health and Safety Plan 58
11 Suggested Organization of Community Relations Plan 59
12 Regional RCRA Contacts for Determining Treatability Study
Sample Exemption Status 65
13 Regional Offsite Contacts for Determining Acceptability of
Commercial Facilities to Receive CERCLA Wastes 68
14 Example Tabulation of Data From an Experiment in Which
One Parameter is Varied 72
15 Example Tabulation of Data From an Experiment in Which
Two Parameters are Varied 73
16 Suggested Organization of Treatability Study Report 76
17 Characterization Parameters for Biological Treatment 89
viii
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TABLES (continued)
Number Page
18 Characterization Parameters for Physical/Chemical
Treatment 90
19 Characterization Parameters for Immobilization 94
20 Characterization Parameters for Thermal Treatment 95
21 Characterization Parameters for In Situ Treatment 97
22 Soils/Sludges: Characterization of Physical Properties 100
23 Soils/Sludges: Characterization of Chemical Properties 102
24 Liquids: Characterization of Physical Properties 104
25 Liquids: Characterization of Chemical Properties 106
26 Gases/Vapors: Characterization of Physical Properties 108
27 Gases/Vapors: Characterization of Chemical Properties 109
IX
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ABBREVIATIONS
AA atomic absorption
AAR Applications Analysis Report
ANOVA analysis of variance
ANS American Nuclear Society
ARAR applicable or relevant and appropriate requirement
ARCS Alternative Remedial Contracts Strategy
ASTM American Society for Testing and Materials
ATTIC Alternative Treatment Technology Information Center
BBS OSWER Electronic Bulletin Board System
BOM U.S. Bureau of Mines
CERCLA Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (aka Superfund)
CFR Code of Federal Regulations
CLP Contract Laboratory Program
COLIS Computerized On-Line Information Service
CRP Community Relations Plan
DOT Department of Transportation
DQO data quality objective
EP tox extraction procedure toxicity
EPA U.S. Environmental Protection Agency
FR Federal Register
FS feasibility study
FSP Field Sampling Plan
GC gas chromatography
HSL Hazardous Substance List
HSP Health and Safety Plan
HSWA Hazardous and Solid Waste Amendments of 1984
ICP inductively coupled plasma
KPEG potassium polyethylene glycolate
MS mass spectrometry
MSDS material safety data sheet
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NIOSH National Institute for Occupational Safety and Health
NPL National Priorities List
OERR Office of Emergency and Remedial Response
ORD Office of Research and Development
OSC On-Scene Coordinator
OSHA Occupational Safety and Health Administration
OSW Office of Solid Waste
OSWER Office of Solid Waste and Emergency Response
PAH polynuclear aromatic hydrocarbon
PCB polychlorinated biphenyl
QAPjP Quality Assurance Project Plan
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ABBREVIATIONS (continued)
QA/QC quality assurance/quality control
RA remedial action
RCRA Resource Conservation and Recovery Act of 1976
RD remedial design
RD&D research, development, and demonstration
REM Remedial Engineering Management
RFP request for proposal
RI remedial investigation
ROC Regional Offsite Contact
ROD Record of Decision
RP responsible party
RPM Remedial Project Manager
RREL Risk Reduction Engineering Laboratory
SAP Sampling and Analysis Plan
SARA Superfund Amendments and Reauthorization Act of 1986
SITE Superfund Innovative Technology Evaluation
SOP standard operating procedure
START Superfund Technical Assistance Response Team
TCLP toxicity characteristic leaching procedure
TOC total organic carbon
TOX total organic halogen
TSDF treatment, storage, or disposal facility
USCG United States Coast Guard
USPS United States Postal Service
WERL Water Engineering Research Laboratory
XRF X-ray fluorescence
xi
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ACKNOWLEDGMENTS
This guide was prepared for the U.S. Environmental Protection Agency,
Office of Research and Development, Risk Reduction Engineering Laboratory
(RREL), Cincinnati, Ohio, by PEI Associates, Inc., and The Earth Technology
Corporation under Contract No. 68-03-3413. Mr. Jonathan 6. Herrmann served
as the EPA Technical Project Monitor. Ms. Judy L. Hessling and Ms. Sarah A.
Hokanson were PEI's Work Assignment Manager and Earth Technology's Subcon-
tract Manager, respectively. The project team included Michael M. Arozarena,
Catherine D. Chambers, Jeffrey S. Davis, Robert L. Hoye, Carole A. Lojek,
Gregory D. McNelly, James S. Poles, Christine A. Pryately, Susan E. Rohland,
and Roxanne B. Sukol. Mr. Charles E. Zimmer served as PEI's Senior Reviewer,
and Ms. Martha H. Phillips served as the Technical Editor.
Ms. Robin M. Anderson of the Office of Emergency and Remedial Response
(OERR) has been the inspiration and motivation for the development of this
document. The following other Agency and contractor personnel have contrib-
uted their time and comments by participating in the generic protocol work-
shop and/or peer reviewing the draft document:
Randall Kaltreider
Sheila L. Rosenthal
Christopher J. Corbett
William Hagel
Kathy Hodgkiss
John J. Barich
Franklin R. Alvarez
Edward R. Bates
Benjamin L. Blaney
Carl A. Brunner
Alden G. Christiansen
Paul R. de Percin
Clyde J. Dial
Kenneth A. Dostal
Hugh B. Durham
Frank J. Freestone
John A. Glaser
Walter E. Grube, Jr.
Eugene F. Harris
James A. Heidman
Alfred Kernel
Richard P. Lauch
EPA, OERR
EPA, OERR
EPA, Region III
EPA, Region III
EPA, Region III
EPA, Region X
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
EPA, RREL
XI1
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Norma Lewis EPA, RREL
Ronald F. Lewis EPA, RREL
E. Timothy Oppelt EPA, RREL
Marta K. Richards EPA, RREL
Lewis A. Rossman EPA, RREL
Steven I. Safferman EPA, RREL
David L. Smith EPA, RREL
Laurel J. Staley EPA, RREL
Henry H. Tabak EPA, RREL
Dennis L. Timberlake EPA, RREL
Richard P. Traver EPA, RREL
Ronald J. Turner EPA, RREL
Maivina H. Wilkens EPA, RREL
M. Pat Esposito Bruck, Hartman & Esposito, Inc.
Tom A. Pedersen Camp Dresser & McKee Inc.
Joan 0. Knapp COM Federal Programs Corp.
Kevin Klink CH2M Hill
Michael Amdurer EBASCO Services, Inc.
Gary Seavey EBASCO Services, Inc.
Robert Foster PRC Consultants
Ronald Braun Radian Corp.
William Ellis SAIC
Curtis Schmidt SAIC
Gretchen Rupp University of Nevada - Las Vegas
Olenna Truskett Versar Inc.
Richard Stanford Roy F. Weston, Inc.
We sincerely hope we have not overlooked anyone who participated in the
development of this guide.
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SECTION 1
INTRODUCTION
1.1 BACKGROUND
Under the Superfund Amendments and Reauthorization Act of 1986 (SARA),
the U.S. Environmental Protection Agency (EPA) is required to select remedial
actions involving treatment that "permanently and significantly reduces the
volume, toxicity, or mobility of the hazardous substances, pollutants, and
contaminants" [Comprehensive Environmental Response, Compensation, and Lia-
bility Act (CERCLA), Section 121(b)].
Selection of remedial actions involves several risk management deci-
sions. Uncertainties with respect to performance, reliability, and cost of
treatment alternatives underscore the need for well-planned, well-conducted,
and well-documented treatability studies, as evident in the following quote
from A Management Review of the Superfund Program (EPA 1989a):
"To evaluate, tine application of treatment technologies to particu-
lar sites, it is essential to conduct laboratory or pilot-scale
tests on actual wastes from the site, including, if needed and
feasible, tests of actual operating units 'prior to remedy selec-
tion. These 'treatability tests' are not currently being performed
at many sites to the necessary extent, or their quality is not
adequate to support reliable decisions."
Treatability studies provide valuable site-specific data necessary to
support Superfund remedial actions. They serve two primary purposes: 1) to
aid in the selection of the remedy, and 2) to aid in the implementation of
the selected remedy. Treatability studies conducted during the remedial
investigation/feasibility study (RI/FS) phase indicate whether a given tech-
nology can meet the expected cleanup goals for the site, whereas treatability
studies conducted during the remedial design/remedial action (RD/RA) phase
establish the design and operating parameters for optimization of technology
performance. Although the purpose and scope of these studies differ, they
complement one another (i.e., information obtained in support of remedy
selection may also be used to support the remedy design).
Historically, treatability studies have been delayed until after the
Record of Decision (ROD) has been signed. Conducting treatability studies
earlier in the remedial action process should serve to reduce the uncertain-
ties associated with selecting the remedy, provide a sounder basis for the
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ROD, and possibly facilitate negotiations with responsible parties without
lengthening the overall remedial action schedule for the site. Because
treatability studies may be expensive and time-consuming, however, the econo-
mies of cost and time should be taken into consideration when planning treat-
ability studies in support of the various phases of the program.
1.2 PURPOSE AND SCOPE
This guide presents information on conducting treatability studies under
CERCLA. The purpose of the document is to facilitate efficient planning,
execution, and evaluation of treatability studies and to ensure that the data
generated can support remedy selection and implementation.
For purposes of this document, it is assumed that the reader has already
identified candidate technologies for remediating the site. The questions of
whether to conduct treatability studies, what level of testing is appropri-
ate, and how to proceed are addressed herein.
1.3 INTENDED AUDIENCE
This document is intended for use by Remedial Project Managers (RPMs),
responsible parties (RPs), contractors, and technology vendors. Each has
different roles in conducting treatability studies under CERCLA, as described
here.
1.3.1 Remedial Project Managers
Remedial Project Managers are responsible for project planning and
oversight. Their role in treatability investigations is dependent upon the
designated lead agency (Federal, State, or private). Their activities
generally include scoping the treatability study, establishing the data
quality objectives, selecting a contractor, issuing a work assignment, over-
seeing the execution of the study, and informing or involving the public as
appropriate.
1.3.2 Responsible Parties
Currently, responsible parties conduct roughly half of all onsite work
under the Superfund program, and the EPA intends to expand its use of en-
forcement measures and settlement procedures provided under SARA to promote
even more private-party cleanups in the future. At enforcement sites, RPs
are responsible for planning and executing treatability studies under Federal
or State oversight.
1.3.3 Contractors/Technology Vendors
Treatability studies are generally performed by remedial contractors or
technology vendors. Their roles in treatability investigations include
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preparing a work plan and other supporting documents, complying with regu-
latory requirements, executing the study, analyzing and interpreting the
data, and reporting the results.
1.4 USE OF THE GUIDE
1.4.1 Organization of the Guide
The guide is organized into two principal sections: an overview of
treatability studies and a step-by-step protocol. Section 2 describes the
need for treatability studies and presents a three-tiered approach that
consists of 1) laboratory screening, 2) bench-scale testing, and 3) pilot-
scale testing. This section also describes the application of the tiered
approach to unit operations, treatment trains, and in situ technologies.
Section 3 presents a general approach or protocol for conducting treat-
ability studies. This section contains information on scoping, performing,
and reporting the results of treatability studies with respect to the three
tiers. Specifically, this section includes information on:
S"'
0 Establishing data quality objectives (performance goals and
associated confidence limits).
0 Identifying a qualified contractor and selecting a contracting
mechanism.
0 Issuing the work assignment, with emphasis on writing the scope of
work.
0 Preparing the Work Plan, with emphasis on designing the experiment.
0 Preparing the Sampling and Analysis Plan, Health and Safety Plan,
and Community Relations Plan, with emphasis on addressing issues
related specifically to treatability studies.
0 Complying with regulatory requirements for testing and residuals
management.
0 Executing the treatability study, with emphasis on collecting and
analyzing samples.
0 Analyzing and interpreting the data, including an explanation of
statistical analysis techniques.
0 Reporting the results in a logical and consistent format.
The text of each subsection presents general information followed by specific
details pertaining to the three tiers of testing.
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The appendices, which follow Section 3, present sources of treatability
information (Appendix A), cost elements associated with treatability studies
(Appendix B), characterization parameters for five technology categories
(Appendix C), and standard analytical methods for characterizing wastes
(Appendix D).
1.4.2 Application and Limitations of the Guide
Treatability studies are an integral part of the remedial planning
process. This guide is intended to supplement the information on develop-
ment, screening, and analysis of alternatives contained in the Guidance for
Conducting Remedial Investigations and Feasibility Studies Under CERCLA
(Interim Final) (EPA 1988a). Data from treatability studies can be used to
accept or reject technologies for detailed analysis (laboratory screening) or
to assess and compare feasible alternatives in accordance with specified
evaluation criteria (bench- and pilot-scale testing).
This guide, which is general in nature, encompasses all waste matrices
(soils, sludges, liquids, gases) and all categories of technologies
(biological treatment, physical/chemical treatment, immobilization, thermal
treatment, and in situ treatment). Currently, the guide addresses only
treatability studies conducted in support of remedy selection (i.e., pre-
ROD); treatability studies in support of remedy implementation (i.e., post-
ROD) will be addressed when the document is issued in final form. Companion
documents on treatability protocols for soil washing, solidification/stabil-
ization, and aerobic biodegradation of organics in soil are being developed
and will be available in fiscal year 1990; other technology-specific proto-
cols are also planned.
In an effort to be concise, supporting information in other readily
available guidance documents is referenced throughout the guide rather than
repeated. Details on the preparation of the Sampling and Analysis Plan
(which includes a Field Sampling Plan and a Quality Assurance Project Plan),
the Health and Safety Plan, and the Community Relations Plan, for example,
are not given in the guide.
The available information on the cost and time for performing treatabil-
ity studies is sparse. These data should be included in future treatability
study reports, as described in Subsection 3.12, to provide more accurate
figures for planning purposes.
This document was drafted and reviewed by representatives from EPA's
Office of Emergency and Remedial Response (OERR), Office of Research and
Development (ORD), and the Regional offices, as well as by contractors who
conduct treatability studies. Comments obtained during the course of the
peer review process have been integrated and/or addressed throughout this
guide. The document is being issued as an Interim Final to prompt both use
and comment on the approach and methodology presented here. Readers are
invited to send their comments or suggestions on the guide by June 1, 1990,
to the following address:
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Mr. Jonathan 6. Herrmann
U.S. Environmental Protection Agency
Office of Research and Development
Risk Reduction Engineering Laboratory
26 W. Martin Luther King Drive
Cincinnati, Ohio 45268
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SECTION 2
OVERVIEW OF TREATABILITY STUDIES
This section presents an overview of treatability studies under CERCLA
and provides a decision tree with examples of the application of treatability
studies to the RI/FS and remedy selection process. Subsection 2.1 summarizes
the need for and goals of treatability studies during the RI/FS (or remedy
evaluation) phase. Subsection 2.2 provides details on the different tiers of
treatability studies, including laboratory screening, bench-scale testing,
and pilot-scale testing. Subsection 2.3 presents examples of how and when to
apply the tiered approach.
2.1 TREATABILITY STUDIES IN THE RI/FS PROCESS
As discussed in EPA's RI/FS interim final guidance (EPA 1988a), site
characterization and treatability investigations are two of the main compo-
nents of the RI/FS process. As site and technology information is collected
and reviewed, additional data needs for evaluating alternatives are identified.
Treatability studies and/or detailed site characterization studies may be
required to fill in these data gaps.
In the absence of data in the available technical literature or treat- ,
ability data bases, treatability studies can provide the critical performance
and cost information needed to evaluate and select treatment alternatives.
The RI/FS interim final guidance specifies nine evaluation criteria for use
in the detailed analysis of alternatives; treatability studies can address
seven of these criteria:
1) Overall protection of human health and the environment
2) Compliance with applicable or relevant and appropriate requirements
(ARARs)
3) Implementability
4) Reduction of toxicity, mobility, or volume
5) Short-term effectiveness
6) Cost
7) Long-term effectiveness
Community and State acceptance, the other two criteria affecting the evalua-
tion and selection of the remedial alternative, can influence the decision to
conduct treatability studies on a particular technology.
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Treatability studies involve testing one or more technologies in the
laboratory or field to gain qualitative and/or quantitative information for
assessing their performance on specific wastes at the site. Generally,
treatability testing of alternative technologies can begin during the initial
phases of site characterization and technology screening, as shown in Fig-
ure 1. Laboratory screening, bench-scale testing, or pilot-scale testing
must be scoped and initiated as early as possible (i.e., during the scoping
phase) to keep the RI/FS on schedule and within budget. Treatability testing
can continue through the pre-ROD remedy evaluation and into the post-ROD
remedy implementation phase of a Superfund site remediation.
2.1.1 Determining the Need for Treatability Studies
After information on the physical and chemical characteristics of the
waste has been obtained, a literature survey of remedial technologies is
performed. Technical information resources, including information from /
reports and guidance documents, electronic data bases, and experienced EPA
staff are reviewed, and available performance and cost information on each
technology is obtained and evaluated with respect to the waste type and site
conditions present. Appendix A contains a survey of available information
sources.
Based on the results of the literature survey and available site and ,
waste data, remedial technologies are screened to eliminate nonapplicable
technologies; potentially and definitely applicable technologies are retained
for further consideration. Additional site- and technology-specific data
needs are identified for each of the technologies retained for further anal-
ysis, and the need to conduct treatability studies on any or all of these
technologies is determined.
Treatability studies may be needed for applicable technologies for which s
no or limited performance information is available in the literature with re-
gard to the waste types and site conditions of concern. The general decision
tree presented in Figure 2 illustrates when treatability studies are needed
to support the evaluation of an alternative.
The need for treatability studies, the number of alternatives to be
evaluated, and the level of treatability testing are all management-based
decisions. (Management decision factors to be considered in the treatability
study decision process are discussed further in Subsection 2.3.1.) The RPM
must determine whether the available data can adequately address all nine of
EPA's remedy evaluation criteria. If so, no treatability studies would be
needed to evaluate the technology. Similarly, if a candidate technology is
not accepted by the community or State, there may be little merit in perform-
ing a treatability study to investigate it as an alternative. On the other
hand, the results of a treatability study may provide additional information
that alleviates community and State concerns regarding an alternative tech-
nology. If the collected information does not adequately address EPA's
remedy evaluation criteria, the RPM should determine whether the missing data
can be obtained from other literature sources before deciding to perform
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Remedial Investigation/
Feasibility Study (RI/FS)
Identification
of Alternatives
Record of
Decision
(ROD)
Remedy
Selection
Site
Characterization
and Technology
Screening
Treatability Study
Scoping
Evaluation
"of Alternatives
Laboratory Screening to
Validate Technology
00
Bench-Scale Testing to
Develop Performance Data
1
Remedial Design/
' Remedial Action (RD/RA)'
Implementation
of Remedy
Pilot-Scale Testing to
Develop Performance,
Cost, and Design Data
Figure 1. The role of treatability studies in the RI/FS and RD/RA process.
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EVALUATE EXISTING
SITE DATA
IDENTIFY APPLICABLE
TECHNOLOGIES
SEARCH LITERATURE
TO DETERMINE
DATA NEEDS
DATA
ADEQUATE TO
SCREEN OR EVALUATE
ALTERNATIVES?
MANAGEMENT DECISION FACTORS:
• State and Community Acceptance
• RP Considerations
• Schedule Constraints
• Additional Data
CONDUCT
TREATABILITY STUDY
DETAILED ANALYSIS
OF ALTERNATIVES
Figure 2. Decision tree showing when treatability studies are needed
to support the evaluation and selection of an alternative.
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treatability studies. The availability of funds and time also play a signifi-
cant role in determining the need for treatability studies.
Example 1 illustrates when treatability studies may not be needed in the
remedy evaluation phase. This example covers a situation in which informa-
tion needed to evaluate the technology is readily available in the literature
and EPA technology data bases. Consequently, no treatability studies were
conducted. In numerous other cases, the site contamination problem is more
complex, and information on the performance or cost that is needed to evalu-
ate the treatment technologies may be lacking or nonexistent. In these
cases, the decision to conduct treatability studies is not straightforward, /
and some overall prioritization of activities to meet the project goals,
schedule, and budget is required.
2.1.2 Defining Treatability Studies
Treatability studies are laboratory or field tests designed to provide
critical data needed to evaluate and, ultimately, to implement one or more
technologies. These studies generally involve characterizing untreated /
wastes and evaluating the performance of the technology under different oper-
ating conditions. Depending on the objectives of the treatability testing,
the results may be qualitative or quantitative.
During the remedy evaluation phase of the RI/FS, as many as three tiers
of treatability testing may be undertaken: 1) laboratory screening, 2)
bench-scale testing, and 3) pilot-scale testing.
Laboratory screening is used to establish the validity of a technology
to treat an operable unit. Jar tests or beaker studies are examples of this
treatability study tier. Screening studies yield data that can be used as
indicators of a technology's potential to meet performance goals and can
identify parameters for investigation during bench- or pilot-scale testing.
They generate little, if any, design or cost data and should not be used as
the sole basis for the selection of a remedy.
Bench-scale testing is intended to determine the technology's
performance for the operable unit. Bench-top unit operations are indicative
of this tier of treatability testing. Bench-scale testing can verify that
the technology can meet expected cleanup goals and can provide information in
support of remedy evaluation (i.e., that relates to seven of the nine evalu-
ation criteria). Bench-scale testing may also provide cost and design
information.
Pilot-scale testing is intended to provide quantitative performance,
cost, and design information for remediating an operable unit. This level of
study can also produce data required to optimize performance. Testing of a
mobile pilot-scale unit operation at the site is indicative of this tier.
Because these tests also provide detailed design information, they are most
often performed during the remedy implementation phase of a site cleanup. In
a few cases, such as for in situ treatments, pilot-scale studies may be
necessary during remedy evaluation.
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EXAMPLE 1. DETERMINING THE NEED FOR TREATABILITY STUDIES
ABANDONED BATTERY RECLAMATION SITE
Background--
An abandoned battery reclamation site is contaminated primarily with
lead. After evaluating site data (including site areal extent, hydrogeology,
permeability and chemistry of soil, and depth/extent of lead contamination),
the RPM reviews the literature to identify and screen potentially or defi-
nitely applicable technologies. During this scoping phase, the RPM decides
that immobilization and soil washing are definitely applicable technologies,
whereas fluosilicic acid treatment is a potentially applicable technology.
At this point, the RPM identifies site- and technology-specific data needs
for evaluating the candidate technologies. The RPM must now decide whether
to conduct treatability studies on one, two, or all three technologies.
Technical and managerial inputs gathered to support the decision include the
following:
0 Availability of funds and time to conduct treatability studies.
0 Adequacy of existing data to address all of the nine evaluation
criteria.
0 Availability of information in other literature or data bases not
already reviewed.
0 Acceptance of the candidate technologies by the community and
State.
Decision Based on Literature and Existing Data—
The RPM decides that adequate funds and time are available to conduct
treatability studies. The literature and data base review yielded relevant
performance data on immobilization and soil washing. In fact, a treatability
study for evaluation of the performance of soil washing and immobilization
processes on soils and battery casings contaminated with lead at a site in a
neighboring State is currently underway. Limited information is available on
the fluosilicic acid technology, however, as it is young and not well devel-
oped. Also, the State has indicated a preference for proven technologies
such as immobilization or soil washing, or both. The RPM discusses the tech-
nical and nontechnical considerations with the Unit Chief, and they decide
that no treatability studies are needed in support of remedy evaluation
during the RI/FS. A treatability study in support of remedy implementation,
however, is planned for the RD/RA phase.
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The three tiers of treatability testing and their attributes are as
follows:
1) Laboratory Screening—Jar tests or beaker studies that are per-
formed in the laboratory and are characterized by the following:
Relatively low costs
Short amounts of time to perform
Low levels of quality assurance/quality control (QA/QC)
Results yield qualitative performance data but no design or cost
information.
2) Bench-Scale Testing—Bench-top studies that are performed in the
laboratory or field and are characterized by the following:
Moderate costs
Moderate amounts of time to perform
Moderate to high levels of QA/QC
Results yield quantitative performance data with some design and
cost information.
3) Pilot-Scale Testing—Pilot-plant studies that are performed in the
field and are characterized by the following:
High costs
Long amounts of time to perform
Moderate to high levels of QA/QC
Results yield quantitative performance data with detailed design,
cost, and process optimization information.
2.1.3 Treatability Study Goals
Setting goals for the treatability study is critical to the ultimate
usefulness of the data generated. Goals or objectives must be defined before
the treatability study is performed. Each tier of treatability study needs
performance goals appropriate to that tier. For example, laboratory screen-
ing is often used to answer the question, "Does the mechanism of this tech-
nology (physical, chemical, biological, or thermal treatment) work on this
waste stream?" It is necessary to define "work" (e.g., set the goal of the
study). A pollutant reduction of 50 percent during a jar test may satisfy
the test for validity of the process and indicate that further testing at the
bench scale is appropriate to determine if the technology can meet the an-
ticipated performance criteria of the ROD.
The ideal goals for technology performance are the cleanup criteria for
the operable unit. For several reasons, such as continuing waste analysis
and ARARs determination, some cleanup criteria are not finalized until the
ROD is signed. Nevertheless, treatability study goals need to be established
before the study is performed so that the success of the treatability study
12
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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 set cleanup levels,
the RPM can estimate performance goals for the treatability studies based on
the following criteria:
0 Levels that provide overall protection of human health and the
environment
0 Levels that are in compliance with ARARs, including land disposal
restrictions
0 Levels that ensure a reduction of toxicity, mobility, or volume
0 Levels acceptable for delisting of the waste
0 Levels set by the State or Region for anr*her site with contami-
nated media with similar characteristics and contaminants
Cleanup criteria directly relate to the final management of the material
and dictate the need for other treatment processes to treat the entire waste
stream (i.e., treatment trains). These factors must be be considered during
the planning and design of the treatability studies and in the overall remedy
evaluation and selection. The development of tiered goals for contaminant
reduction may be instrumental in fully addressing this issue. For example,
if the treatment technology can reduce contaminant levels to 1 ppb, the
treated waste can be landfilled with no controls. If a treatment technology
only reduces the contaminant level to 5 ppm, the treated waste will have to
be disposed of in a landfill permitted under Subtitle C of the Resource Con-
servation and Recovery Act (RCRA). If the treatment technology only reduces
the contaminant level to 50 ppm, the waste will have to be stabilized before
its disposition in a RCRA Subtitle C landfill.
2.2 TIERS OF TREATABILITY TESTING
As mentioned earlier in this section, the treatability study process
designed to support the investigation, evaluation, and ultimate implementa-
tion of treatment alternatives at CERCLA sites comprises three tiers:
1) Laboratory screening
2) Bench-scale testing
3) Pilot-scale testing
Laboratory screening and bench-scale testing are usually employed during
remedy evaluation. Pilot-scale testing is generally (but not always) used
during remedy implementation.
Each tier of treatability testing has different functional requirements
and provides different kinds of information about a treatment technology.
Table 1 lists general similarities and differences among the three tiers,
including the type of data generated; the analytical level used; the number
of critical parameters investigated; the number of replicates required; the
study size, usual process type, and waste volume needed; and the typical
duration and cost of conducting a study.
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TABLE 1. GENERAL COMPARISON OF LABORATORY SCREENING, BENCH-SCALE TESTING, AND PILOT-SCALE TESTING
Type Critical No. of
of data Analytical param- repli-
Tier generated level eters cates
Laboratory Qualitative I-II
screening
Bench-scale Quantitative III-V
testing
Several Single/
duplicate
Few Duplicate/
triplicate
Study size
Jar tests
or beaker
studies
Bench-top
(some
Usual Waste Time
process stream re-
type volume quired
Batch Small Hours/
days
Batch or Medium Days/
continu- weeks
Cost, $
10,000-
50,000
50,000-
250,000
larger)
ous
Pilot-scale Quantitative
testing
III-V
Few
Triplicate Pilot-plant Batch or Large Weeks/ 250,000-
or more (onsite or continu- months 1,000,000
offsite) ous
Analytical levels are defined in Data Quality Objectives for Remedial Response Activities (EPA 1987a);
see Subsection 3.2.
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2.2.1 Laboratory Screening
Laboratory screening, the first step in the tiered approach, is designed
to establish the validity of an alternative technology quickly and inexpen-
sively. Validity depends on the ability of the technology to achieve per-
formance goals set prior to the screening. If the goals are not attained,
the technology is rejected. In the event that all technologies screened are
rejected, the RPM should reevaluate the performance goals to determine if
they are still appropriate. This level of testing could result in a poten-
tially applicable alternative being rejected or a nonapplicable alternative
being retained for further testing. The risk of this occurring is acceptable,
however, in light of the cost and time savings associated with laboratory
screening.
Type of Data--
in general, laboratory screening provides qualitative data that will be
used to evaluate the validity of the technology as a treatment process for an
operable unit. No cost or design information will be generated. The RPM, in
consultation with management, must determine the overall qualitative data
needs based on the intended use of the information and the availability of
time and funds.
During laboratory screening, an indicator contaminant is often monitored
to determine whether a reduction in toxicity, mobility, or volume is occur-
ring. If a technology appears to meet or exceed the performance goal, it is
considered valid and retained for further evaluation. Laboratory screening
is also useful for identifying critical parameters for investigation in later
bench- and pilot-scale testing.
Analytical Level--
Analytical levels I and II are generally sufficient to screen alternative
technologies; however, analytical levels III through V may also have applica-
tion. (Table 2 in Subsection 3.2 outlines the five analytical levels estab-
lished by EPA.)
Critical Parameters/Number of Replicates--
Several parameters (e.g., temperature, pH, reaction time) can be inves-
tigated during laboratory screening, and each can be evaluated at a few lev-
els over a broad range of values. During laboratory screening, the focus of
the investigation of a technology is on screening a large number of parame-
ters to identify those that will be critical for later bench- or pilot-scale
investigation.
The laboratory screening tier requires little or no replication (single
or duplicate) in most cases. A low level of QA/QC is sufficient because a
remedy that is found to be valid will generally undergo bench-scale testing.
Study Size/Process Type/Waste Volume--
Laboratory screening is limited in size and scope to small-scale jar
tests and beaker studies performed on the bench-top. This tier will gen-
erally involve batch tests and use small-volume samples of the waste stream.
For example, laboratory screening of an ion exchange process designed to
15
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treat aqueous wastes may require sample volumes on the order of 500 ml per
run with only three runs through a column.
Time/Cost—
The duration and cost of laboratory screening depend primarily on the
type of technology being investigated and the number of parameters consid-
ered. Generally, laboratory screening can be performed within a time range
of hours to days at a cost of between $10,000 and $50,000. The cost estimate
includes analytical support; however, the time estimate does not consider
sample analysis or data validation, as these elements depend on the analyti-
cal laboratory used.
The nature of laboratory screening (i.e., its relatively small numbers
of samples and replicates, less stringent QA/QC requirements, and minimum
reporting requirements) makes it the least costly and time-consuming of the
three treatability study tiers.
2.2.2 Bench-Scale Testing
Bench-scale testing, the second step in the tiered approach, is designed
to verify whether an alternative technology can meet the performance goals
for the site. This tier provides a quantitative evaluation of the performance
of a technology as well as some cost and design information. Bench-scale
tests can be performed on any technology that is supported in the literature
or by laboratory screening data. These tests focus on the critical param-
eters that have an impact on performance.
Type of Data—
Bench-scale testing provides quantitative data that will be used to
assess the performance of a technology for treatment of a particular waste
stream. The following are examples of performance evaluations that can be
made at the bench-scale:
ff
° Product curing rates, optimum additives, and admixture ratios for
immobilization technologies.
0 Pretreatment requirements, reaction rates, and optimum flocculant
formation conditions for precipitation treatment technologies.
0 Contaminant removal efficiencies of soil washing at different
throughput rates.
The operational and performance information resulting from bench-scale
testing permits more accurate full-scale cost and schedule estimates than can
be made based on laboratory screening. Bench-scale tests can provide infor-
mation needed to size unit operations and to estimate treatment train consid-
erations such as waste mixing and materials handling.
When planning bench-scale testing, the RPM, in consultation with manage-
ment, must determine the overall quantitative data needs for a technology
based on the intended use of the information and the availability of time and
funds.
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Analytical Level-- */
Analytical levels III through V are generally necessary to demonstrate
technology performance in support of remedy selection. (Table 2 in Subsec-
tion 3.2 outlines the five analytical levels established by EPA.)
Critical Parameters/Number of Replicates—"
A small number of critical parameters—those that have been identified
in the literature or by laboratory screening—are investigated during bench-
scale testing. These parameters are evaluated at many levels over a narrow
range of values to determine the technology's performance.
The bench-scale testing tier requires duplicate or triplicate replica-
tion in most cases. A moderate to high level of QA/QC is generally needed to
increase the confidence in the decision that the remedy selected can meet the
performance goals for the site.
y
Study Size/Process Type/Waste Volume—
The size and scope of bench-scale testing is generally limited to stud-
ies performed on the bench-top with equipment designed to simulate the basic
operation of a treatment process. Bench-scale testing may be conducted as
either a batch or continuous process. The waste stream sample volume needed
to perform continuous, bench-scale testing of an ion exchange treatment
process for an aqueous waste may be on the order of 1 liter per minute for a
period of 8 hours (which would require approximately 500 liters of waste).
Time/Cost— /
The duration and cost of bench-scale testing depend primarily on the
type of technology being investigated, the types of analyses being performed,
and the number of replicates required for adequate testing of that technolo-
gy. Most bench-scale testing can be performed within a time range of days to
weeks at a cost of between $50,000 and $250,000. This cost estimate includes
analytical support. The estimate of duration, however, covers only the actu-
al performance of the test. It does not include the time required for con-
struction and shakedown of the bench-scale apparatus, as these procedures are
specific to the technology being investigated. Neither does the time esti-
mate consider sample analysis or data validation, as these elements depend on
the analytical laboratory used.
The increased cost of bench-scale testing compared with laboratory
screening is directly related to the more stringent QA/QC requirements and
the larger number of samples and replicates to be analyzed.
2.2.3 Pilot-scale Testing
Pilot-scale testing, the final step in the tiered approach, is designed
to provide detailed cost, design, and performance data. It yields the most
accurate scale-up information of the three tiers. These tests can be per-
formed on any technology that is supported either in the literature or by
laboratory screening or bench-scale testing data.
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Whereas pilot-scale testing is generally not necessary for evaluation of
alternatives in support of remedy selection, innovative technologies or tech-
nologies for which limited data are available (e.g., in situ technologies)
may require pre-ROD pilot-scale testing to provide data needed to evaluate
the technology. Multiple-unit treatment train systems will generally require
pilot-scale testing to evaluate the design fully. The ultimate decision as
to whether to conduct pilot-scale testing during the RI/FS rests with the RPM
and management and will be based on the complexity of the alternative, the
existing data, and the availability of time and funds.
If a ROD is written prior to the selection of a final remedy, it will
list the alternatives being considered and indicate that the final selection
of a remedy will be based on the results of pilot-scale testing of the listed
alternatives.
Type of Data--
Pilot-scale testing provides the detailed, quantitative cost, design,
and performance data required to optimize the critical parameters. The
following issues can be addressed with the data generated by pilot-scale
testing:
0 Overall performance and cost of the technology ^
0 Design information needed to size unit operations
0 Treatment train considerations such as waste mixing and materials
handling
0 Process upsets and recovery
0 Side-stream and residuals generation
0 Site-specific considerations, such as heavy equipment access;
adequate space for the staging of waste feed, treatment reagents,
and residuals; and local availability of equipment.
Pilot-scale testing may also help to identify waste stream characteris-
tics that have the potential to affect the implementability of a technology.
For example, physical characteristics of the waste feed may introduce unex-
pected materials-handling problems. Similarly, chemical characteristics of
the waste that are outside of the technology's operating range may require
process modifications. Such waste-stream characteristics may not be identi-
fied during site characterization or bench-scale testing and may only be
discovered during pilot-scale testing.
When planning pilot-scale testing, the RPM, in consultation with man-
agement, must determine what the overall quantitative data needs for a tech-
nology are. Consideration must be given to the intended use of the informa-
tion and the availability of time and funds.
Analytical Level--
Analytical levels III through V are generally necessary to demonstrate
technology performance in support of remedy selection and implementation.
(Table 2 in Subsection 3.2 outlines the five analytical levels established by
EPA.)
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Critical Parameters/Number of Replicates—
A few critical performance, design, and cost parameters are investigated
at the pilot-scale testing tier. These parameters are evaluated over a
narrow range of values to optimize the technology's operation.
The pilot-scale testing tier often requires triplicate replication or
more. A moderate to high level of QA/QC is generally needed to increase the
confidence in the decision that the remedy selected can meet the performance
goals for the site.
Study Size/Process Type/Waste Volume—
Pilot-scale testing typically involves pilot-plant or field-testing
equipment with a configuration similar to that of the full-scale operating
unit being considered. Pilot-scale testing may be conducted as either a
batch or continuous process, depending on the operation of the full-scale
unit. A substantial waste stream sample volume is required for pilot-scale
testing. For example, the volume needed to perform continuous pilot-scale
testing of an ion exchange treatment process for an aqueous waste may be on
the order of 25 liters per minute for a run of 16 hours a day for a period of
3 weeks (which would require more than 500,000 liters of waste).
Time/Cost—
The duration and cost of pilot-scale testing depend primarily on the
type of technology being investigated, the types of analyses being performed,
and the number of replicates and length of runs required for adequate test-
ing. Typically, pilot-scale tests can be performed within a time range of
weeks to months at a cost of between $250,000 and $1,000,000. This cost
estimate includes analytical support. The estimate of duration, however, is
only for the actual performance of the test. It does not include the time
required for mobilization, construction, shakedown, or demobilization of the
pilot-scale unit, as these procedures are specific to the technology being
investigated. Neither does it consider sample analysis or data validation,
as these elements depend on the analytical laboratory used.
The increased cost of pilot-scale testing compared with that for labora-
tory screening or bench-scale testing is directly related to the larger scale
of the technology, the more stringent QA/QC requirements, and the greater
number of samples and replicates to be analyzed.
2.3 APPLYING THE TIERED APPROACH
The need for and tier of treatability testing required are risk-manage-
ment decisions in which the costs and time required to conduct treatability
studies are weighed against the risks inherent in the selection of a treat-
ment alternative. As a general rule, treatability testing should continue
until sufficient information has been collected to support both the full
development and evaluation of all treatment alternatives and the remedial
design of the selected alternative. Treatability studies can significantly
reduce the overall risks and uncertainties associated with the selection and
19
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application of a technology, but they cannot guarantee that the chosen alter-
native will be completely successful. As more studies are completed and new
knowledge is gained about innovative alternatives, however, success rates
should improve.
The flow diagram for the tiered approach in Figure 3 traces the stepwise
data reviews and management decisions that occur in the treatability study
process.
After the site characterization and literature/data-base review, the RPM
decides which technologies are potentially valid for the site and screens out
those that are not. The decision to conduct a study is then based on the
quantity and quality of available technology-specific information and on in-
puts from management. (Management decision factors are discussed in Subsec-
tion 2.3.1.)
If a treatability study is not required, the technology is retained for
detailed analysis. If significant questions remain about the technology, a
decision must be made regarding the nature of the information needed.
If the technology's validity has not been confirmed, a laboratory screen-
ing should be performed. If more quantitative performance data are required,
the laboratory screening tier may be bypassed in favor of bench-scale testing.
If bench-scale testing indicates that the technology may meet the per-
formance goals, the need for more data must be considered. Again, management
inputs play a role in the decision as to whether to proceed with pilot-scale
testing or to consider the technology investigation complete. In the latter
case, the technology would be retained for future detailed analysis as a
treatment alternative.
The detailed analysis of alternatives evaluates each technology against
the nine evaluation criteria delineated in the RI/FS interim final guidance.
2.3.1 Management Decision Factors
The same factors that govern the decision to conduct treatability studies
at a site also guide the tiered approach. The number of studies conducted
and the tiers at which they occur are management decisions based on available
data (from the literature and from previous treatability studies) and the
following additional factors:
0 State and community acceptance
0 Responsible party considerations
0 Schedule constraints
0 Additional site or technology data
The RPM should weigh the technical and nontechnical factors to determine
the need to progress to the next stage of treatability testing and should
advise and involve management (e.g., Unit Chief) in this decision-making
process.
20
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MANAGEMENT DECISION FACTORS:
• SM*«ndCmnjrityAeoiplMK»
Figure 3. Flow diagram of the tiered approach.
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2.3.2 Special Considerations
The following subsections address the use of different tiers of treat-
ability studies in the RI/FS process. Examples of the application of the
tiered approach are developed with respect to unit operations for innovative
technologies, treatment trains, and in situ technologies.
Unit Operations for Innovative Technologies--
One of the advantages of treatability studies is that they permit the
collection of data on unit operations for innovative technologies. The larg-
est fraction of the total cost of remediation is spent on unit operations;
therefore, the more accurate the understanding of unit operations, the less
likely cost overruns or performance problems are to occur. More data on
design parameters expands the overall confidence in the design.
Example 2 illustrates how treatability studies can be used to investi-
gate unit operations. This example also illustrates the ability to perform
different tiers of treatability tests concurrently on a single waste stream.
Treatment Trains—
The treatment of a contaminated environmental medium often results in
residuals that require further treatment to render them less toxic or mobile
or to reduce the volume of the material. Treatment technologies operated in
series (treatment trains) can be used to provide complete treatment of the
waste stream and the resulting residuals.
Treatment-train requirements for a waste stream may be evaluated by ap-
plying the tiered approach. Example 3 explains the thinking behind designing
a bench-scale treatability study for a treatment train consisting of low-
temperature volatilization followed by chemical treatment and solidification.
Enough data are available in the literature concerning the individual unit
operations to indicate that they are appropriate technologies for the specif-
ic site contaminants. Treatability testing of the unit operations as a
treatment train is necessary to evaluate the most effective combination of
operating parameters for treating the contaminated soils.
Although bench-scale testing can provide some information for the design
of treatment trains, pilot-scale testing produces the most accurate data on
residuals generation, cross-media impacts, and treatment train requirements.
In Situ Treatment Technologies—
Testing of in situ treatment technologies during the RI/FS may entail
laboratory screening, bench-scale testing, and pilot-scale testing. Pilot-
scale testing is very important for an adequate evaluation of in situ treat-
ment and often may be the only type of testing that will provide the critical
information needed for the detailed evaluation during the FS.
Laboratory screening of in situ treatment technologies is conducted for
the same purpose and under the same conditions as for above-ground treatment
technologies. That is, testing may be conducted to verify that the mechanism
(i.e., chemical, physical, thermal, biological) of the technology works on
the contaminated matrix.
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EXAMPLE 2. TREATABILITY STUDIES FOR UNIT OPERATIONS
OLD PETROLEUM REFINERY SITE
Background—
This example concerns an old petroleum refinery site containing oily
sludges and contaminated soils. The primary contaminants of concern were
polynuclear aromatic hydrocarbons (PAHs), specifically benzo(a)pyrene. The
literature survey identified five potentially applicable technologies for
treating the hydrocarbon wastes: 1) incineration, 2) low-temperature thermal
treatment, 3) bioremediation, 4) stabilization/solidification, and 5) solvent
extraction.
The literature survey also produced a significant amount of performance
data for incineration and bioremediation. Because these performance data
indicated that certain technologies could be valid for the types of wastes
and contaminants of concern at the site, these technologies were not eval-
uated at the laboratory-screening level.
Conversely, little data were found on low-temperature thermal treatment,
and the available performance data for solvent extraction and stabilization/
solidification were inconclusive for hydrocarbon wastes. Therefore, these
three technologies were evaluated at the laboratory screening level to deter-
mine their validity for the treatment of petroleum wastes.
Laboratory Screening--
In the case of low-temperature thermal treatment and solvent extraction,
laboratory screening evaluated the percentage removal of oils/grease or total
organic carbon in the wastes. In the case of stabilization/solidification,
laboratory screening evaluated the percentage reduction of these materials.
Samples of worst-case sludges (most highly contaminated with organics) and
average-concentration samples were treated by each technology. A goal of 80
percent reduction was set, based on the established cleanup objectives. The
data confidence levels required for the small data base was 90 percent.
Low-temperature thermal treatment was evaluated at three temperatures.
Solvent extraction was evaluated by using three solvents at three solution
concentrations. Stabilization/solidification was evaluated by using organo-
philic clays at three mix ratios. After the clays were cured, stabilized/
solidified samples and untreated samples were evaluated by the toxicity
characteristic leaching procedure (TCLP). The percentage reduction in leach-
ate concentrations of oils/grease between the treated and untreated samples
was determined, and the leachate levels of benzo(a)pyrene and the regulatory
levels used to classify wastes were compared. Only the chemicals analyses
(I.e., total organic carbon or oils/grease) were replicated.
23
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The results of the laboratory screening showed that, of the three tech-
nologies, low-temperature thermal treatment achieved the highest level of
percentage removal of total organic carbon (greater than 95 percent). Sol-
vent extraction with the best solvent and highest concentration showed an 85
percent removal efficiency. Stabilization with the organophilic clays re-
duced leachate concentrations by 70 percent. Low-temperature thermal treat-
ment and solvent extraction were thus retained for further analysis because
they met the test performance goals.
Bench-Scale Testing-
Quantitative performance, implementability, and cost issues still remained
unanswered after the laboratory screening tests. Also information from the
literature on biodegration rates and mechanisms for benzo(a)pyrene (the
principal contaminant of concern) was inconclusive. In addition, the cleanup
goal for benzo(a)pyrene in soils was very low (250 ppb). Therefore, low-tem-
perature thermal treatment, solvent extraction, and bioremediation were
examined in bench-scale testing. Bench-scale performance goals were set at
98 percent reduction with 95 percent data confidence level. Samples represent-
ing average and worst-case scenarios were collected, triplicate analyses were
performed, and several process variables were evaluated. After 6 months of
testing, only low-temperature thermal treatment was found to meet the low
cleanup levels required for benzo(a)pyrene.
Decision Based on Laboratory Screening and Bench-Scale Testing--
Although low-temperature thermal treatment was found to meet the cleanup
requirements in bench-scale testing, this technology had not been previously
demonstrated on a pilot scale. Therefore, cost and design issues had to be
addressed as part of the detailed analysis of alternatives. In addition,
whereas utility costs for low-temperature thermal treatment would be less
than those for incineration, the costs of constructing and operating the
low-temperature thermal unit could be significantly higher than those that
would be incurred for incineration because the former is an innovative technol-
ogy. Therefore, the RPM decided to conduct pilot-scale testing on low-tempera-
ture thermal treatment and to compare the costs of constructing and operating
the unit with those for incineration. The results would be used to select
the optimal treatment alternative (i.e., incineration or low-temperature
thermal treatment) for the wastes at the site.
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EXAMPLE 3. TREATABILITY STUDIES FOR TREATMENT TRAINS
FORMER CHEMICAL MANFUACTURING COMPANY
Background--
At a former chemical manufacturing company and current Superfund site in
Virginia, the contaminants of concern in the soils are arsenic, cyanide,
methylene chloride, benzene, tetrachloroethene, and total polynuclear aromatic
hydrocarbons (PAHs). The cleanup goal for each of these compounds has been
identified. Both onsite treatment and offsite treatment and disposal are
being considered as viable options for site remediation; therefore, analyses
of the total organics and inorganics composition must be performed on the
treated and untreated soils to determine if target soil concentrations have
been achieved. At the same time, TCLP analyses must be performed to determine
pollutant-of-concern concentrations that can be extracted from the treated
and untreated soils.
Bench-scale testing of a treatment train that can be used to treat the
contaminated soils was designed to include the following unit operations: 1)
low-temperature volatilization, 2) chemical treatment, and 3) solidification.
A schematic of the treatment train is presented below.
POLLUTANTS OF CONCERN
OflOANICS
Schematic Representation of the Treatment Train
Bench-Scale Testing--
The bench-scale testing of the treatment train was designed to meet the
following five objectives:
0 Objective 1 - Provide performance confirmation of the low-tempera-
ture volatilization unit operation and pollutant-of-concern concen-
tration data to determine if chemical treatment and solidification
units are necessary.
c Objective 2 - Provide performance confirmation of the chemical
treatment unit operation and pollutant-of-concern concentration
data to determine if the solidification unit is necessary.
0 Objective 3 - Verify effectiveness of the proposed treatment train
for achieving the target soil concentrations. [Associated pollu-
tion-control devices (e.g., fume incineration) are assumed to be
off-the-shelf items and are not addressed as part of this bench-
scale work.]
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0 Objective 4 - Address the use of hydrogen peroxide or hypochlorite
for cyanide treatment with respect to the following items:
The potential for uncontrolled reactions
Process effectiveness as a function of pH, strength of solu-
tion, ratio of amount of solution to soil to be treated
The effects of additives (metal scavenging on chemical treat-
ment products and byproducts)
The need to degas treated soil
The need for solidification after treatment and the effects of
the treatment agent and associated gases and other products on
solidification
The effects on organic constituents
The effect of soil temperature on subsequent chemical treat-
ment
The effect of varying degrees of thermal treatment on the
process
0 Objective 5 - Address the effectiveness of solidification as a
stand-alone technology to determine the effectivenesss of the
solidification unit.
The bench-scale testing of the proposed treatment train consisted of the
following four subtasks, each of which is summarized here.
a. Execute bench-scale testing to determine the most effective binder/
soil combination for treating the pollutants of concern.
0 Select one of three laboratory-standard generic binders (port-
land cement Type I; cement kiln dust; or a mixture of lime and
Type F fly ash) and a second binder containing silicates.
0 Test both binders at three binder to soil ratios (on a dry
weight basis), varying from 0.1 to 0.6 (binder to soil) for a
total of six trial mixes.
0 Analyze treated soils for physical characteristics (e.g.,
grain size, moisture content, specific gravity), inorganic
composition analysis (arsenic and cyanide), organic composition
analysis (methylene chloride, benzene, tetrachloroethene,
total PAHs), unconfined compressive strength, toxicity character-
istic leaching procedure (TCLP) (for all target compounds),
SW-846 Method 1320 (for all target compounds), wet/dry weight,
permeability, bulk specific gravity, volumetric bulking, acid
neutralization capacity, and American Nuclear Society (ANS)
leach test.
This subtask addresses Objective 5 and part of Objective 3.
26
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b. Execute a low-temperature volatilization/solidification test by
using a high temperature (550°F) and a long residence time (e.g.,
40 minutes) to determine the efficacy of the low-temperature volatili-
zation unit. Perform solidification tests on the treated soil to
determine which combination of low-temperature volatilization and
solidification is most effective in treating the pollutants of
concern.
Analyze treated soils for physical characteristics (e.g., grain
size, moisture content, specific gravity), inorganic composition
analysis (arsenic and cyanide), organic composition analysis
(methylene chloride, benzene, tetrachloroethene, total PAHs),
unconfined compressive strength, TCLP (for all target compounds),
SW-846 Method 1320 (for all target compounds), wet/dry weight,
permeability, bulk specific gravity, volumetric bulking, acid neu-
tralization capacity, and ANS leach test.
This subtask addresses Objective 1 and part of Objective 3.
c. Execute'bench-scale testing of low-temperature volatilization/chem-
ical treatment/solidification using a high pH (e.g., 10), long
residence time (e.g., 2 hours), and high oxidant-to-cyanide ratio
(e.g., 3:1) to determine the efficacy of the low-temperature vola-
tilization/chemical treatment unit. Test either hydrogen peroxide
or hypochlorite.
Perform solidification tests on the treated soil to determine which
combination of low-temperature volatilization, chemical treatment,
and solidification is most effective in treating the pollutants of
concern.
Analyze treated soils for physical characteristics (e.g., grain
size, moisture content, specific gravity), inorganic composition
analysis (arsenic and cyanide), organic composition analysis (methyl-
ene chloride, benzene, tetrachloroethene, total PAHs), unconfined
compressive strength, TCLP (for all target compounds), SW-846
Method 1320 (for all target compounds), wet/dry weight, permeability, bulk
specific gravity, volumetric bulking, acid neutralization capacity,
and ANS leach test.
This subtask addresses portions of Objective 4, Objective 2, and
the remainder of Objective 3.
d. Prepare a summary and analysis of preliminary findings of the
bench-scale testing to be used to assess whether the objectives of
the study have been met, if further bench-scale study needs to be
done, or if pilot-scale testing is required to provide the needed
data for remedy selection.
27
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Bench-scale testing of the efficacy of using in situ technologies for
treating contaminated soils would likely be conducted in soil columns de-
signed to represent the subsurface environment. A column diameter of approx-
imately 4 inches is usually suitable for simulating hydraulic flow conditions
in the subsurface.
Pilot-scale testing in the field may be required more often for evaluat-
ing in situ treatment technologies than for evaluating above-ground treatment
technologies. Monitoring treatment effectiveness is a major concern in
pilot-scale testing and must be considered during design and costing efforts.
Example 4 demonstrates how the tiered approach is used to evaluate the
technology of soil flushing. Soil flushing is an extraction process in which
contaminants are "flushed" from the soil by an aqueous solution (e.g., water,
a surfactant, a chelating agent, or an organic solvent), collected in a
drainage system (e.g., wells or a leachate collection system), pumped to the
surface, treated, and recycled back through the soil for further flushing.
28
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EXAMPLE 4. TREATABILITY STUDIES FOR IN SITU TREATMENT TECHNOLOGIES
IN SITU SOIL FLUSHING
Background—
An estimated 80.000 cubic yards of soil contaminated with chlorinated
phenols, semivolatile organics, sulfur-containing compounds, and lead
required corrective action. In situ soil flushing was proposed as the alter-
native treatment technology. A three-tiered treatability study was designed
to evaluate the effectiveness of this technology.
Laboratory Screening-
Batch laboratory screening can be performed to evaluate the
effectiveness of flushing fluids for enhancing the removal of the site-spe-
cific contaminants. The general procedure is as follows:
° Place a known weight of soil in a 250-ml glass bottle, add a mea-
sured volume of flushing fluid, and shake for 1 to 4 hours.
Centrifuge the bottle and recover the supernatant liquid phase.
Analyze for target compounds.
Analyze the soil phase for site-specific target compounds.
0 Evaluate several different flushing media to determine the removal
efficiencies for each of the site-specific contaminants.
During the soil flushing evaluation phase, analyzing all samples for all
the site-specific contaminants may not be economically feasible; therefore,
target compounds, each representative of a class of compounds present at the
site, should be analyzed.
Bench-Scale Testing—
Upon completion of the batch laboratory screening, the flushing
solutions shown to be the most effective for removal of target contaminants
should be evaluated in a column test. A general procedure for the soil
flushing column test is as follows:
0 Pack a glass column with soil from the contaminated area to approx-
imate the actual density of soil in the area. The initial concen-
tration of contaminants should be determined before the soil is
packed in the columns.
° Introduce the soil flushing solution into the column and allow It
to percolate through the column. Collect the column leachate at
regular intervals (e.g., weekly) and analyze for target compounds.
0 Collect the leachate generated in the soil column and use it for
additional bench-scale testing evaluations involving treatment of
the leachate.
° Terminate the column test when the composition of the leachate
remains the same for three consecutive sampling periods. At the
conclusion of the column flushing test, remove samples of the soil
from the column and analyze them for the target parameters.
The goal of this study is to verify performance of the most environmental-
ly compatible flushing fluid that will solubilize and remove target contamin-
ants.
Pilot-Scale Testlng--
Pilut-scale testing of this technology should occur in the field. The
purpose of the field demonstration 1s to evaluate the hydraulics of the
treatment process under site conditions. The field demonstration will yield
site-specific flow. Injection, and capture rates for the flushing system.
These rates must be established for quantification of the total time
necessary for final soil treatment and to provide data for remedy design and
cost. The pilot-scale testing Involves the following tasks:
Prepare treatment cell site
Install interception trench
Install Irrigation and soil flushing system
Monitor performance
Operation and maintenance
Test possible leachate treatment systems
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SECTION 3
PROTOCOL FOR CONDUCTING TREATABILITY STUDIES
3.1 INTRODUCTION
Treatability studies should be performed in a systematic fashion to
ensure that the data generated can support the remedy evaluation process.
This section describes a general approach or protocol that should be followed
by RPMs, RPs, and contractors for all phases of the investigation. This
approach includes:
0 Establishing data quality objectives
0 Selecting a contracting mechanism
0 Issuing the Work Assignment
0 Preparing the Work Plan
0 Preparing the Sampling and Analysis Plan
0 Preparing the Health and Safety Plan
0 Conducting community relations activities
0 Complying with regulatory requirements
0 Executing the study
0 Analyzing and interpreting the data
0 Reporting the results
These elements are described in detail in the remaining subsections of
Section 3. General information applicable to all treatability studies is
presented first, followed by information specific to laboratory screening,
bench-scale testing, and pilot-scale testing.
Treatability studies for a particular site will often entail multiple
tiers of testing, as described in Subsection 2.3. Duplication of effort can
be avoided by recognition of this possibility in the early planning phases of
the project. The Work Assignment, Work Plan, and other supporting documents
should include all anticipated activities, and a single contractor should be
retained to ensure continuity in the project as it moves from one tier to
another.
3.2 ESTABLISHING DATA QUALITY OBJECTIVES
The establishment of data quality objectives (DQOs) is part of the
process that defines the data quality needs of a project. The implementation
of an appropriate quality assurance/quality control (QA/QC) program is re-
quired to ensure that data of known and documented quality are generated.
The DQOs may be qualitative or quantitative in nature, but in either case,
30
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they must be specified prior to data collection. Because treatability test-
ing is used to decide whether a particular remedial alternative is valid
and/or effective, establishing DQOs is a critical early step in the planning
and conducting of treatability tests, as discussed in Subsection 2.1.3.
The quality of treatability testing data required should correspond
proportionately with the implications of the decisions that will be based on
those data. Generally, limited QA/QC is required for data from simple labo-
ratory screening tests used to decide whether a treatment process is poten-
tially applicable and warrants further consideration. More rigorous QA/QC is
required for bench-scale and pilot-scale testing data used to determine
whether a technology can meet the expected cleanup criteria or to compare the
costs of several treatment alternatives because the decisions have more
far-reaching implications.
3.2.1 General
The guidance document Data Quality Objectives for Remedial Response
Activities (EPA 1987a) defines the framework and process by which the DQOs
are developed. This document focuses on site investigations during an RI/FS;
however, the same framework and process are applicable to treatability stud-
ies. The document describes a three-stage process: Stage 1 involves identi-
fication of decision types; Stage 2 entails the identification of data uses/
needs; and Stage 3 covers the design of the data-collection program.
In Stage 1, determining the types and magnitudes of decisions to be made
entails identifying and involving the data users in establishing the DQOs,
evaluating existing data, and specifying the objective(s) of the treatability
study. For example, is the objective of the study to test the validity of
the technology (i.e., does it warrant further consideration) or must the
study confirm the attainment of a treatment standard? As the consequences of
making a wrong decision increase, so must the data quality and quantity.
During Stage 2, criteria for determining data adequacy are stipulated or
the data necessary to meet the objectives of Stage 1 are specified. Stage 2
also includes selection of sampling approaches and analytical options.
During Stage 3, methods for obtaining data of acceptable quality and
quantity are chosen and incorporated into the project Work Plan, the Sampling
and Analysis Plan, and the Quality Assurance Project Plan.
Data quality considerations for treatability testing must consider both
sampling and analytical efforts. Whereas most measurements of data quality
address analytical techniques, they must also factor in the test design and
sampling events.
The EPA's DQO guidance establishes five analytical levels for use in the
RI/FS process. These analytical levels are summarized in Table 2.
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TABLE 2. SUMMARY OF ANALYTICAL LEVELS'
Level I
Type of analysis
Limitations
Data quality
Type of analysis
Limitations
Data quality
Field screening or analysis with portable instruments.
Usually not compound-specific, but results are available
in real time. Not quantifiable.
Can provide an indication of contamination presence. Few
QA/QC requirements.
Level II
Field analyses with more sophisticated portable instru-
ments or mobile laboratory. Organics by GC, inorganics
by AA, ICP, or XRF.
Detection limits vary from low parts per million to low
parts per billion. Tentative identification of com-
pounds. Techniques/instruments limited mostly to vola-
tile organics and metals.
Depends on QA/QC steps employed.
in concentration ranges.
Data typically reported
Level III
Type of analysis
Limitations
Data quality
Organics/inorganics performed in an offsite analytical
laboratory. May or may not use CLP procedures. Labora-
tory may or may not be a CLP laboratory.
Tentative compound identification in some cases.
Detection limits similar to CLP. Rigorous QA/QC.
Level IV
Type of analysis
Limitations
Data quality
Hazardous Substances List (HSL) organics/inorganics by
GC/MS, AA, ICP. Low parts-per-billion detection limits.
Tentative identification of non-HSL parameters. Valida-
tion of laboratory results may take several weeks.
Goal is data of known quality. Rigorous QA/QC.
Level V
Type of analysis
Limitations
Data quality
Analysis by nonstandard methods.
May require method development or modification.
specific detection limits.
lead time.
Method-specific.
Method-
Will probably require special
Source: EPA 1987a (modified).
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In general, analytical levels I and II apply to laboratory screening
treatability studies, and analytical levels III, IV, and V apply to bench-
and pilot-scale treatability studies.
Once the data quality needs for a project have been defined, confidence
limits can be established for the data to be generated. In general, the
higher the data quality needs, the narrower the confidence interval must be
(e.g., the required confidence limits for data of high quality may be ±5
percent, whereas confidence limits of ±25 percent may be sufficient for data
of lower quality).
Specific confidence limits have not been established for each treatabil-
ity study tier. Rather, the intended use of the data and the limitations and
costs of various analytical methods will assist the RPM in defining appropri-
ate confidence limits for the tier of testing being planned.
Data quality needs also affect the QA/QC requirements and documentation.
As data quality needs increase, a greater number of QC checks (such as spikes
and blanks) must be used. Also, a more detailed quality assurance plan must
be prepared to document the quality of the data.
3.2.2 Laboratory Screening
Laboratory screening is performed to determine the potential applicabil-
ity of emerging or innovative technologies. Laboratory screening is also ap-
plied when performance data for a well-developed technology are inconclusive
or questionable with respect to specific waste characteristics. For example,
whereas soil washing has been well demonstrated on sandy soils, performance
data for loamy or silty soils may be inconclusive or nonexistent. Also,
where solidification/stabilization is known to be effective for treating
metal-containing wastes, its effectiveness with respect to organic contami-
nants is still questionable and should be verified through laboratory screen-
ing.
The DQOs established for laboratory screening are usually stated in
qualitative terms. Laboratory screening evaluates primary waste variables
such as percent solids, total organic carbon, or pH. Therefore, analytical
levels I and II usually provide sufficient information for laboratory screen-
ing. Because laboratory screening does not directly support the remedy
selection, it does not require a significant amount of replication in the
samples and the analytical tests performed.
Confidence limits established for data derived from laboratory screening
are typically wide, in keeping with the characteristics of this level of
study (i.e., low cost, quick turnaround, and limited QA/QC).
3.2.3 Bench-Scale Testing
For bench-scale testing, DQOs are primarily quantitative in nature. For
example, an objective for bench-scale testing involving solvent extraction
33
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and chemical dechlorination may be to reduce polychlorinated biphenyls (PCBs)
to less than 30 ppm in soils (the target cleanup goal specified for the
site), whereas an objective for testing involving stabilization/solidifica-
tion of the residuals from soil washing may be to pass the toxicity character-
istic leaching procedure (TCLP) leachate levels required for disposal of the
residuals. Other objectives may be to evaluate volume increase (in the case
of stabilization/solidification) or to determine the fines content of the
residuals from soil washing. Therefore, objectives for bench-scale testing
will result in more quantitative evaluations of the critical engineering
parameters affecting design, performance, and costs. Analytical levels III
through V are usually specified for bench-scale testing activities.
The data required to meet these quantitative objectives include more de-
tailed waste characterization and performance testing with narrower confi-
dence limits, depending on the RPM's intended use of the data. Data used as
the sole support of a remedy selection should have a high level of confidence.
Because the principal objective is to quantify the performance and cost
of a technology, the parameters to be studied will include those that effec-
tively characterize the types of wastes to be treated and the critical engi-
neering parameters. In the case of stabilization/solidification, the
critical waste characterization parameters may be particle size, moisture
content, pH, total organic carbon, sulfides content, and concentrations of
the indicator compounds. The critical engineering parameters evaluated may
be the type of stabilizer (lime, cement, organophillic clays) and the mix
ratios. The critical performance test may be leaching (using TCLP), strength
of the solidified matrix (based on unconfined compressive strength), per-
centage of volume increase of the solidified product, and biotoxicity of the
treated product.
Because of the more detailed analyses, the narrower confidence limits,
and the resulting need for a higher level of QA/QC, the sample size will be
much larger than required for laboratory screening. Chemical analyses also
may be more thorough (e.g., a scan for priority pollutants rather than
analyzing only for oils/grease).
3.2.4 Pilot-Scale Testing
The principal objective of pilot-scale testing is to obtain quantitative
performance, design, and cost data to be used in the feasibility study or in
the implementation of the remedial technology. Therefore, DQOs are primarily
quantitative in nature and related to process optimization.
For example, an objective for pilot-scale testing involving bioremedia-
tion of ground water may be to reduce benzene and phenol concentrations to
safe drinking water levels. Other objectives for bioremediation pilot-scale
testing may be to quantify optimum critical process parameters, such as pH,
nutrient addition, and oxygen requirements for the unit operation. There-
fore, quantitative objectives for pilot-scale testing will result in more
quantitative evaluations of critical engineering parameters affecting the
design, performance, and cost of the remedial alternative.
34
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Because the principal objective is to quantify the performance and cost
of a technology, the number of parameters to be studied may be limited to
those that effectively characterize the types of waste to be treated and the
critical engineering parameters that affect the cost and performance of a
technology. As with bench-scale testing, analytical levels III through V are
appropriate for pilot-scale testing. In the case of bioremediation pilot-
scale testing, the critical waste characterization parameters may be particle
size, moisture content, total metals, total organic carbon, nutrient content,
and concentration of indicator compounds. The critical process parameters to
be evaluated may be reactor residence time, effective temperatures, water
distribution, and nutrient additives. The performance tests may be chemical
analyses for indicator compounds, leach tests, and biotoxicity of the treated
product.
The need for design, cost, and performance information will dictate the
frequency of sampling and testing, the required confidence limits, and the
level of QA/QC. In general, pilot-scale testing will involve daily or weekly
sampling and significant replication in sampling and analyses. Chemical
analyses may include more costly and thorough analytical methods (e.g., GC/MS
for organics) as well as gross indicator analytes (e.g., pH, total organic
carbon, total metals, oxygen content).
3.3 SELECTING A CONTRACTING MECHANISM
3.3.1 General
Once the decision to conduct a treatability study has been made and the
scope of the project has been defined, the RPM must identify a contractor or
technology vendor with the requisite technical capabilities and experience to
perform the work. In support of the Superfund programs, the Office of
Research and Development (ORD) has compiled a list of vendors and contractors
who have expressed an interest in performing treatability studies. This
document, entitled Inventory of Treatability Study Vendors, will be be avail-
able in 1990 by contacting:
Ms. Joan Col son
U.S. Environmental Protection Agency
Office of Research and Development
Risk Reduction Engineering Laboratory
26 W. Martin Luther King Drive
Cincinnati, Ohio 45268
The document was compiled from information received from contractor/vendor
responses to a request for information published in the Commerce Business
Daily (August 31, 1989). Companies on this list should be notified of a re-
quest for proposal (RFP) for treatability studies for their area of expertise
in accordance with the Federal Acquisition Regulations.
The inventory is sorted by treatment technology, contaminant group, and
company name. Figure 4 shows the type of information contained in the inven-
tory. Plans call for this inventory to be incorporated into one of the
technical information services maintained by ORD.
35
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TREATABILITY STUDY VENDORS BY COMPANY NAME
COMPANY:
Address:
City:
Contact:
Treatment Technology:
Other Treatment Capability:
ACTIVATED CARBON
5 TECHNOLOGIES
Company Type: SMALL BUS
State: Zip:
Phone:
CURRENT AVAILABLE
Permitting Status:
Mobile Facility?
Bench Scale?
Unit Capacity:
Price Information:
Media Treated:
Contaminant
Groups
Treated:
Other Contaminant
FACILITY: LABORATORY
EPA ID AS SMALL GENERATOR
YES
YES
INFORMATION NOT PROVIDED
INFORMATION NOT PROVIDED
1. AQUEOUS MEDIA
3.
5.
1. NALOGENATED NONVOLATILES
3. NONHALOGENATED NONVOLATILES
5. NONVOLATILE METALS
7. ORGANIC CYANIDES
9. VOLATILE METALS
11.
Groups That Can Be Treated:
Studies/Month: INP
Fixed Facility? YES
Pilot Scale? NO
Location: ATLANTA, GA
2. ORGANIC LIQUID
4.
Other:
2. HALOGENATED VOLATILES
4. NONHALOGENATED VOLATILES
6. ORGANIC CORROSIVES
8. PCBs
10.
12.
NOT SPECIFIED
Experience at Superfund Sites?
YES
SUPERFUND SITE #1: A & F MATERIAL RECLAIMING EPA Region: 5
Site Location: GREENVILLE State: IL
Start Date: 00/84 End Date: INP
Unit Utilized for/at Site: INFORMATION NOT PROVIDED
ID #: 17
Price Information:
Media Treated
INFORMATION NOT PROVIDED
AQUEOUS MEDIA
1.
3.
5.
Contaminant 1. VOLATILE METALS
Groups 3.
Treated: 5.
r.
9.
11.
Other Contaminant Groups Treated:
2.
4.
Other:
2.
4.
6.
8.
10.
12.
SUPERFUND SITE » 2: AMERICAN CREOSOTE
Location: JACKSON
Start Date: 00/86
Unit Utilized for/at Site: INFORMATION NOT PROVIDED
Price Information: INFORMATION NOT PROVIDED
Media Treated: 1. AQUEOUS MEDIA
Contaminant
Groups
Treated:
3.
5.
1. NONVOLATILE METALS
3. CREOSOTE
5.
7.
9.
11.
Other Contaminant Groups:
EPA Region: 5
State: TN
End Date: INP
2.
4.
Other:
2. PCBs
4.
6.
8.
10.
12.
OTHER ORGANICS
ID #: 72
Figure 4. Information contained in EPA's inventory of treatability
study vendors.
36
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Three methods of obtaining treatability study services from contractors
are discussed in the subsections that follow.
REM or ARCS Contracts--
Remedial Engineering Management (REM) and Alternative Remedial Contracts
Strategy (ARCS) contracts are used to obtain program management and technical
services needed to support remedial response activities at CERCLA sites. To
retain a treatability study vendor through this mechanism, the RPM (in con-
junction with the EPA contract officer for the particular contract) must
issue a Work Assignment to the prime contractor outlining the required tasks.
The prime contractor may elect to retain this work for itself or may choose
to assign the work to one of its subcontractors.
Technical Assistance and Support Contracts--
In situations where the RPM knows that a specific waste at a specific
site requires the specialized services of a contractor capable of treating
that waste (e.g., a mixed radioactive/hazardous waste) and these required
services are not available from firms accessible through existing REM or ARCS
contracts, the RPM may need to investigate which firms having this special-
ized capability may be accessible through other contracting mechanisms.
Limited access to technical assistance and support contracts may be available
through ORD's Risk Reduction Engineering Laboratory (RREL), the U.S. Bureau
of Mines (BOM), or the U.S. Army Corps of Engineers.
Request for Proposal--
In the absence of an existing contracting mechanism with which to access
the required treatability study services for a specific waste at a particular
site, the required services may be obtained through a new contracting mecha-
nism. Obtaining the services of a specific firm through a new contracting
mechanism, which can be a time-consuming process, typically involves three
steps: 1) request for proposal (RFP), 2) bid review and evaluation, and 3)
contract award.
An RFP is an invitation to firms to submit proposals to conduct specific
services. It usually contains the following key sections:
° The type of contract to be awarded (e.g., fixed-price or cost plus
fixed fee)
0 Period of performance
0 Level of effort
0 Type of personnel (levels and skills)
0 Project background
0 Scope of work
0 Technical evaluation criteria
0 Instructions for bidders (e.g., due date, format, assumptions for
cost proposals, page limit, number of copies)
All appropriate firms listed in the Inventory of Treatability Study
Vendors should be notified of the RFP. Proposals submitted by a fixed due
date in response to an RFP go to several reviewers to determine the prospec-
tive firms' abilities to conduct the required services. The technical pro-
posals should be evaluated (scored) by using a standard rating system, which
37
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Is based on the technical evaluation criteria presented in the RFP. Contract
award should be based on a firm's ability to meet the technical requirements
of the testing involved, its qualifications and experience in conducting
similar studies, the availability and adequacy of its personnel and equipment
resources, and (other things being equal) a comparison of cost estimates.
During the performance of treatability studies, a close working rela-
tionship should be established with the selected treatability study vendor.
The vendor conducting the treatability study should be monitored for respon-
siveness, quality of documentation, and cost control.
3.3.2 Laboratory Screening
Laboratory screening involves relatively simple tests with no special
equipment requirements. These studies generally can be performed by the
prime REM or ARCS contractor or by the State or RP prime support services
contractor.
3.3.3 Bench-Scale Testing
Bench-scale testing of proven or demonstrated technologies can sometimes
be performed by the REM or ARCS contractor. Tests involving innovative tech-
nologies, however, may require special capabilities that are only accessible
through technical assistance and support contracts or an RFP. Firms offering
such capabilities can be identified through the Inventory of Treatability
Study Vendors.
3.3.4 Pilot-Scale Testing
Pilot-scale testing involves more complex tests, with specialized equip-
ment requirements. Such capabilities may not be available through any exist-
ing contracting mechanism within the Agency; therefore, it may be necessary
to issue an RFP. Firms with the requisite pilot-scale testing capabilities
can be identified through the Inventory of Treatability Study Vendors.
3.4 ISSUING THE WORK ASSIGNMENT
3.4.1 General
The Work Assignment is a contractual document that outlines the scope of
work to be provided by the contractor. It gives the rationale for conducting
the study, Identifies the waste stream and technology(ies) to be tested, and
specifies the level(s) of testing required (i.e., laboratory screening,
bench-scale testing, and/or pilot-scale testing). Table 3 presents the
suggested organization of the treatability study Work Assignment.
Background--
The background describes the site, the waste stream, and the remedial
technology under investigation. Site-specific concerns that may affect waste
handling, the experimental design, or data interpretation, as well as specif-
ic process options of interest, should be duly noted. The results of any
previous treatability studies conducted at the site also should be included.
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TABLE 3. SUGGESTED ORGANIZATION OF
TREATABILITY STUDY WORK ASSIGNMENT
1. Background
1.1 Site description
1.2 Waste stream description
1.3 Remedial technology description
1.4 Previous treatability studies at the site
2. Test Objectives
3. Approach
3.1 Task 1 - Work Plan preparation
3.2 Task 2 - SAP, HSP, and CRP preparation
3.3 Task 3 - Treatability study execution
3.4 Task 4 - Data analysis and interpretation
3.5 Task 5 - Report preparation
3.6 Task 6 - Residuals management
4. Reporting Requirements
4.1 Deliverables
4.2 Monthly reports
5. Schedule
6. Level of Effort
Test Objectives--
This section defines the objectives of the treatability study and the
intended use of the data (i.e., to validate a technology, to evaluate per-
formance, or to provide cost or design data). The test objectives, which may
differ for the three treatability study tiers, should be based on established
cleanup goals for the site or, when such goals do not exist, on levels that
are protective of human health and the environment. If the treatability
study Work Assignment is issued before site cleanup goals have been estab-
lished, the test objectives should be written with enough latitude to accom-
modate changes as treatability testing proceeds without modifying the Work
Assignment.
Approach--
The approach describes the manner in which the treatability study is to
be conducted. This discussion should address the following six tasks:
Task 1 - Work Plan preparation
Task 2 - SAP, HSP, and CRP preparation
Task 3 - Treatability study execution
Task 4 - Data analysis and interpretation
Task 5 - Report preparation
Task 6 - Residuals management
Task 1 - Work Plan preparation—This task outlines the elements to be
included in the Work Plan. If a project kick-off meeting is needed to define
the goals of the treatability study or to review the experimental design, it
should be specified here. The contractor will begin work on subsequent tasks
only after receiving approval of the Work Plan by the RPM.
39
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Task 2 - SAP, HSP. and CRP preparation—This task describes activities
specifically related to the treatability study that should be incorporated
into the existing site Sampling and Analysis Plan (SAP), Health and Safety
Plan, (HSP) and Community Relations Plan (CRP). Examples of such activities
include field sampling and waste stream characterization, operation of pilot-
plant equipment, and public meetings to discuss treatability study findings.
Task 3 - Treatability study execution—Requirements for executing the
treatability study are outlined in this task. It should require that the
contractor review the literature and site-specific information, identify key
parameters for investigation, and specify conditions of the test. This task
also should identify guidance documents (such as this guide or other technol-
ogy-specific protocols) that should be consulted during the planning and
execution of the study.
Task 4 - Data analysis and interpretation—This task describes how data
from the treatability study will be used in the evaluation of the remedy. If
statistical analysis of the data is required, the requirements should be set
forth here.
Task 5 - Report preparation—This task describes the contents and or-
ganization of the final project report. If multiple tiers of testing are
expected, an interim report may be requested at the completion of each tier.
This task should require the contractor to follow the reporting format out-
lined in Subsection 3.12.
Task 6 - Residuals management—Residuals generated as a result of treat-
ability testing must be managed in an environmentally sound manner. This
task should specify whether project residuals are to be returned to the site
or shipped to an acceptable offsite facility. In the latter case, this task
also should identify the waste generator (lead agency, responsible party, or
contractor).
Reporting Requirements—
This section identifies the project deliverables and monthly reporting
requirements. Project deliverables include the Work Plan; the SAP, HSP, and
CRP (as appropriate); and interim and final reports. Format specifications
and the number of copies to be delivered should be stated. The Work Assign-
ment must include a requirement for one camera-ready master copy of the
treatability study report to be provided to the Office of Research and Devel-
opment for use in updating the Superfund Treatability Data Base (EPA 1989b).
The report should be sent to the following address:
Mr. Kenneth A. Dostal
Superfund Treatability Data Base
U.S. Environmental Protection Agency
Office of Research and Development
Risk Reduction Engineering Laboratory
26 W. Martin Luther King Drive
Cincinnati, Ohio 45268
40
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Monthly reports should summarize progress for the current month, pro-
jected progress for the coming month, any problems encountered, and expected
versus actual costs incurred. They should be submitted no later than the
10th day of the month following the reporting period.
Schedule--
The schedule establishes the timeframe for conducting the treatability
study and includes due dates for submission of the major project deliver-
ables. Sufficient time should be allowed for Work Plan, subcontractor, and
other administrative approvals; site access and sampling; analytical turn-
around; and review and comment on reports.
Level of Effort--
The level of effort estimates the number of technical hours necessary to
complete the project. If special skills or expertise are required, they
should be noted here.
3.4.2 Laboratory Screening
The purpose of laboratory screening is to establish the validity of a
technology for treatment of wastes at the site and to focus resources in sub-
sequent bench- or pilot-scale testing. The Work Assignment should describe
how the results of laboratory screening will be used to determine if further
testing at the bench or pilot scale is warranted.
3.4.3 Bench-Scale Testing
The purpose of bench-scale testing is to evaluate the performance of a
technology and to obtain preliminary cost and design information. The objec-
tives of bench-scale testing should be clearly stated. If laboratory screen-
ing will not be conducted, the Work Assignment should identify the critical
parameters to be investigated.
3.4.4 Pilot-Scale Testing
The purpose of pilot-scale testing is to evaluate the performance of a
technology and to obtain detailed cost and design information. Like bench-
scale testing, the objectives of pilot-scale testing should be clearly
stated. In addition to identifying the critical parameters, the Work
Assignment should specify the other variables to be investigated (e.g.,
materials handling, treatment of residuals).
3.5 PREPARING THE WORK PLAN
3.5.1 General
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, which is prepared by the contractor when the Work
41
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Assignment is in place, sets forth the contractor's proposed technical ap-
proach for completing the tasks outlined in the Work Assignment. It also
assigns responsibilities and establishes the project schedule and costs.
Table 4 presents the suggested organization of a treatability study Work
Plan. The Work Plan must be approved by the RPM before initiating subsequent
tasks. Each of the principal Work Plan elements is described in the follow-
ing subsections.
TABLE 4. SUGGESTED ORGANIZATION
OF TREATABILITY STUDY WORK PLAN
1. Project Description
2. Remedial Technology Description
3. Test Objectives
4. Experimental Design and Procedures
5. Equipment and Materials
6. Sampling and Analysis
7. Data Management
8. Data Analysis and Interpretation
9. Health and Safety
10. Residuals Management
11. Community Relations
12. Reports
13. Schedule
14. Management and Staffing
15. Budget
Project Description--
The project description provides background information on the site and
summarizes existing waste characterization data (type, concentration, and
distribution of contaminants of .concern). This information can be obtained
from the Work Assignment or other background documents, such as the RI. The
project description also specifies the type of study to be conducted (i.e.,
laboratory screening, bench-scale testing, or pilot-scale testing). For
treatability studies involving multiple tiers of testing, it describes how
the need for subsequent levels of testing will be determined from the results
of the previous tier.
Remedial Technology Description--
This section briefly describes the remedial technology to be tested. A
flow diagram showing the input stream, the output stream, and any side streams
generated as a result of the treatment process can be included. For treatabil-
ity studies involving treatment trains, the remedial technology description
addresses all the unit operations the system comprises.
Test Objectives—
This section defines the objectives of the treatability study and the
intended use of the data (i.e., to validate a technology, to evaluate per-
formance, or to provide cost or design data). The test objectives are based
42
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on established cleanup goals for the site or, when such goals do not exist,
on levels that are protective of human health and the environment.
Experimental Design and Procedures—
The experimental design identifies the volume of waste material to be
tested, the critical parameters and levels of testing, and the type and
amount of replication. Examples of critical parameters include pH, reagent
dosage, temperature, and reaction (or residence) time. Some form of repli-
cation is usually incorporated into a treatability study to provide a greater
level of confidence in the data. The following methods are used to collect
two types of replicates:
0 Dividing a sample in half or thirds at the end of the experiment
and analyzing each fraction. This method provides information on
laboratory error.
0 Analyzing two or three samples prepared independently of each other
under the same test conditions. This method provides information
on total error.
The data quality objectives and the costs associated with replication
must be considered in the design of the experiment. A matrix outlining the
test conditions and the number of replicates, such as the example in Table 5,
should be included in the Work Plan.
TABLE 5. EXAMPLE TEST MATRIX FOR
ZEOLITE AMENDMENT BENCH-SCALE TREATABILITY STUDY3
I - zeoliteII - zeolite~
Soil AX BX CX AX BX C% III - limestone IV - control
X
Y
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Numbers indicate number of replicates.
The specific steps to be followed in the performance of the treatability
study are described in the standard operating procedures (SOP). The SOP
should be sufficiently detailed to permit the laboratory of field technician
to conduct the test, to operate the equipment, and to collect the samples
with minimal supervision, as the example in Table 6 illustrates. The SOP can
be appended to the Work Plan.
Equipment and Materials—
This section lists the equipment, materials, and reagents that will be
used in the performance of the treatability study. The following specifica-
tions should be provided for each item listed:
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TABLE 6. EXAMPLE STANDARD OPERATING PROCEDURE FOR THERMAL DESORPTION
BENCH-SCALE TREATABILITY STUDY
1. Define and record planned experiment in the data book (i.e., time,
temperature, soil, etc.).
2. Weigh the empty clean tray.
3. Transfer a representative aliquot of prepared soil from the jar to the
tray with a stainless steel spatula.
4. Weigh the soil and tray and adjust the soil quantity to achieve a uni-
form layer approximately 2.5 to 3 mm deep in the bottom of the tray.
5. Distribute and level the soil within the tray.
6. Turn on the purge-gas flow to the proper setting on the rotameter.
7. Place the tray with soil in the oven at ambient temperature and close
the oven door.
8. Set the oven temperature controller set-point to the target test
temperature and start the timer.
9. Monitor and record the temperatures and time periodically throughout the
test period.
10. When the prescribed residence time at the target temperature is reached,
shut off the oven heater and purge-gas flow and open the oven door.
11. Cautiously withdraw the hot tray and soil with special tongs, place a
cover on the tray, and place the covered tray in a separate hood for
cooling for approximately 1 hour.
12. Weigh the tray (without cover) plus treated soil.
13. Transfer an aliquot (typically about 20 grams) of treated soil from the
tray to a tared, 60-cm3, wide-mouth, amber bottle with Teflon-lined cap.
Code, label, and submit this aliquot for analysis. Transfer the re-
mainder of the treated soil to an identical type bottle, label, and
store as a retainer.
14. Clean the tray, cover, and nondisposable implements by the following
procedure:
0 Rinse with acetone and wipe clean.
0 Scrub with detergent (Alconox) solution and rinse with hot tap
water followed by distilled water.
0 Rinse with acetone and allow to dry.
0 Rinse three times with methylene chloride (i.e., approximately 15
to 25 ml each rinse for the tray).
0 Air dry and store.
44
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0 Quantity
0 Volume/capacity
0 Calibration or scale
0 Equipment manufacturer and model number
0 Reagent grade and concentration
Table 7 provides an example listing of equipment and materials for a labora-
tory screening study involving chemical treatment with potassium polyethylene
glycolate (KPEG). In addition, a diagram of the test apparatus, similar to
that shown in Figure 5, should be included in the Work Plan.
Sampling and Analysis--
A Sampling and Analysis Plan is required for all field activities con-
ducted during the RI/FS. This section describes how the existing Sampling
and Analysis Plan will be modified to address field sampling, waste charac-
terization, and sampling and analysis activities in support of the treatabil-
ity study. It describes the kinds of samples that will be collected and
specifies the level of QA/QC required. (Preparation of the Sampling and
Analysis Plan is discussed in Subsection 3.6.)
Data Management—
Treatability studies must be well documented, particularly if the find-
ings are likely to be challenged by a responsible party, the State, or the
community. This section describes the procedures for recording observations
and raw data in the field or laboratory, including the use of bound note-
books, data collection sheets, and photographs. Figure 6 shows an example of
a form for daily logging of field activities. If proprietary processes are
involved, this section also describes how confidential information will be
handled.
Data Analysis and Interpretation--
This section describes the procedures that will be used to analyze and
interpret data from the treatability study, including methods of data presen-
tation (tabular and graphical) and statistical evaluation. (Data analysis
and interpretation are discussed in Subsection 3.11.)
Health and Safety—
A Health and Safety Plan is required for all cleanup operations involv-
ing hazardous substances under CERCLA and for all operations involving haz-
ardous wastes that are conducted at facilities regulated under RCRA. This
section describes how the existing site or facility Health and Safety Plan
will be modified to address the hazards associated with treatability testing.
Hazards may include, but are not limited to, chemical exposure; fires, explo-
sions, or spills; generation of toxic or asphyxiating gases; physical haz-
ards; electrical hazards; and heat stress or frostbite. (Preparation of the
Health and Safety Plan is discussed in Subsection 3.7.)
Residuals Management—
This section describes the management of treatability study residuals.
Early recognition of the types and quantities of residuals that will be
generated, the impacts that managing these residuals will have on the project
45
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TABLE 7. EXAMPLE LIST OF EQUIPMENT AND MATERIALS FOR
A KPEG LABORATORY SCREENING STUDY
1 multiport 2-liter glass reactor (Kimax 33700)
1 variable-speed stirrer with controller (Talboys 104)
1 Teflon-coated shaft for stirrer (Talboys 104)
1 76-mm multi-paddle Teflon agitator (Ace Glass, Inc.)
1 Teflon gasket for reaction flask (Ace Glass, Inc.)
1 cover clamp for reaction flask (Ace Glass, Inc.)
1 chain clamp (Fisher 5-745)
1 variable autotransformer, max. rating 1.4 kVa (Staco 3PN1010)
1 heating mantle, rating 470 watts at 115 V (Glas-Col)
1 water-cooled bearing, 34/45 joint (Ace Glass, Inc.)
1 condenser, Allihn, 24/40 joint (Corning 2480300)
1 Teflon-coated thermometer, -10° to 260°C
2 adapters, thermometers with screw-cap 24/40 joint (Kimax 44874)
1 adapter, offset, 24/40 joint (Ace Glass, Inc.)
1 pressure filtration system (Millipore YT30 142 HW)
1 Tenax tube with activated carbon
50 ft Tygon tubing, 5/16-in. i.d., 7/16-in. o.d.
2 rectangular supports, extra large
3 swivel clamp holders
3 3-finger extension clamps
1 2-stage pressure regulator for N2 gas tank
1 stainless steel trowel or spoon
KPEG reagent
Nitrogen gas
Hexane
Acetone
12 sample jars with Teflon-lined lids, 8-oz
46
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sssss*.
-SSS"
SEAU
HEATING
MANTUE
the test a
pparatus
5
"flur' a KPEG laboratory
for a
47
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FIELD ACTIVITY DAILY LOG
[ DAILY LOG ]
DATE
NO.
SHEET OF
ROJECT NAME
[ PROJECT NO.
FIELD ACTIVITY SUBJECT:
DESCRIPTION ON DAILY ACTIVITIES AND EVENTS:
VISITORS ON SITE:
WEATHER CONDITIONS:
CHANGES FROM PLANS AND SPECIFICATIONS, AND
OTHER SPECIAL ORDERS AND IMPORTANT DECISIONS.
IMPORTANT TELEPHONE CALLS:
PERSONNEL ON SITE
SUPERVISOR:
DATE:
Figure 6. Example of Field Activity Daily Log.
48
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schedule and costs, and the roles and responsibilities of the various parties
involved is important for disposing of residuals properly.
The Work Plan should include estimates of both the types and quantities
of residuals expected to be generated during treatability testing. These
projections should be based on knowledge of the treatment technology and the
experimental design. Project residuals may include the following:
0 Unused waste not subjected to testing
0 Treated waste
0 Treatment residuals (e.g., ash, scrubber water, combustion gases)
0 Laboratory samples and sample extracts
0 Used containers or other expendables
0 Contaminated protective clothing and debris
This section describes how treatability study residuals will be analyzed
to determine if they are hazardous wastes and specifies whether such wastes
will be returned to the site or shipped to an acceptable treatment, storage,
or disposal facility (TSDF) (see Subsection 3.9.1). In the latter case, this
section also identifies the waste generator (lead agency, responsible party,
or contractor) and delineates the parameters that will be analyzed for prop-
erly manifesting the waste and for obtaining disposal approval (see Table 8).
Community Relations--
A Community Relations Plan is required for all remedial response actions
under CERCLA. This section describes the community relations activities that
will be performed in conjunction with the treatability study. These activi-
ties may include, but are not limited to, preparation of fact sheets and news
releases, conducting workshops or community meetings, and maintaining an
up-to-date information repository. (Conducting community relations activi-
ties is discussed in Subsection 3.8.)
Reports--
This section describes the preparation of interim and final reports
documenting the results of the treatability study. For treatability studies
involving more than one tier (e.g., laboratory screening followed by bench-
scale testing), interim reports (or project briefings) provide a means for
determining whether to proceed to the next level of testing. This section
also describes the preparation of monthly reports detailing current and
projected progress on the project.
Schedule—
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 timespan for each task should take into account the time re-
quired to obtain the Work Plan, subcontractor, and other approvals (e.g.,
disposal approval from a commercial TSDF); sample curing time (for solidifi-
cation/stabilization studies); analytical turnaround time; and review and
comment period for reports and other project deliverables. Some slack time
also should be built into the schedule to accommodate unexpected delays
(e.g., bad weather, equipment downtime) without affecting the project comple-
tion date.
49
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TABLE 8. WASTE PARAMETERS REQUIRED TO OBTAIN
DISPOSAL APPROVAL AT AN OFFSITE FACILITY3
Incineration parameters
Total solids
% water
pH
% ash
Total sulfide
Specific gravity
Total cyanide
Flash point
Total phenolics
Total organic halogen (TOX)
Btu/pound
Total sulfur
Total organic nitrogen
Polychlorinated bipnehyls (PCBs)
Total RCRA metals (eight)
Priority pollutant organics
Volatile
Semi volatile (BN/A-extractable)
Remaining F-listed solvents
Treatment parameters
Oil and grease
Total organic carbon (TOC)
PH
Specific gravity
Total metals (RCRA plus Cu, Ni,
Cyanide
Sulfide
Total phenolics
Zn)
Landfill parameters (solids only)
% ash
pH
Specific gravity
Total cyanide
Total sulfide
PCBs
Total phenolics
% water
EP Tox metals (extraction and RCRA
metals)
TCLP F-listed solvents
Analysis of these parameters is required unless they can be ruled out based
on knowledge of the waste.
50
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The schedule is usually displayed in the form of a bar chart such as
that shown in Figure 7. In this example for a bench-scale treatability
study, the actual testing will last 2 weeks; however, the entire project
(from Work Plan preparation to residuals management) will span 30 weeks.
Treatability studies that involve multiple tiers of testing should be shown
on one schedule.
Management and Staffing—
This section identifies key management and technical personnel and
defines specific project roles and responsibilities. The RPM is responsible
for project planning and oversight. At Federal- and State-lead sites, the
remedial contractor directs the treatability study; at private-lead sites,
the responsible party performs this function. The treatability study may be
subcontracted in whole or in part to a vendor, laboratory, or testing facili-
ty with expertise in the technology being evaluated. The line of authority
is usually presented in an organization chart, such as that shown in Fig-
ure 8. Resumes may be appended to the Work Plan.
Budget—
The budget presents the projected costs for completing the treatability
study as described in the Work Plan, including all labor, travel, equipment
and materials, analyses, transportation and disposal, and administrative
costs and fees. (Appendix B describes the various cost elements associated
with conducting treatability studies.)
3.5.2 Laboratory Screening
Laboratory screening entails evaluation of several parameters at a few
levels with little or no replication. The test conditions should bracket
values reported in the literature. For example, if the literature indicates
that a reaction time of 30 minutes is generally sufficient for the destruc-
tion of a particular compound by a specific process, testing could be con-
ducted at 15, 30, and 60 minutes to determine how reaction time affects
performance. Because of the limited scope of laboratory screening, rigorous
statistical design is not appropriate.
Laboratory screening typically involves the use of laboratory glassware
(such as jars and beakers) or other readily available equipment. The Work
Plan should specify the type and size of containers, mixers, and other bench-
top equipment, and the volume and concentration of treatment reagents or
additives.
3.5.3 Bench-Scale Testing
Compared with laboratory screening, bench-scale testing entails evalua-
tion of fewer parameters (i.e., only those "critical" parameters defined in
the literature or determined through screening studies) at more levels and
with greater replication. Because selection of the remedy may be based on
the results of these investigations, the Work Plan should provide a statisti-
cally sound experimental design.
51
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cr»
ro
Weeks from Project Start
Span,
Weeks
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30
Taskl
Work Plan Preparation
Task 2
SAP. HSP, & CRP Preparation
Task3
Treatability Study Execution
Task 4
Data Analysis & Interpretation
Tasks
Report Preparation
Task6
Residuals Management
- Administrative approval, document review, or sample turnaround
M-1 Submit Work Plan Wk 2
M-2 Receive Work Plan Approval Wk 4
M-3 Submit SAP, HSP, CRP Wk B
M-4 Receive SAP, HSP Approvals Wk 10
M-5 Collect Sample Wk12
M-6 Receive Sample Characterization Results Wk 16
M-7 Collect Treatability Study Samples Wk 18
M-8 Collect Project Residual Samples Wk18
M-9 Receive Treatability Study Analytical Results Wk 22
M-10 Receive Project Residual Analytical Results Wk 22
M-11 Submit Waste Disposal Approval Form Wk 24
M-12 Submit Draft Report Wk 26
M-13 Receive Review Comments Wk 28
M-14 Receive Waste Disposal Approval Wk28
M-15 Submit Final Report; Conduct Briefing Wk 30
M-16 Ship Wastes to TSDF Wk 30
Figure 7. Example project schedule for a bench-scale treatability study.
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en
CO
Quality Assurance Officer
(name appears here)
Health & Safety Officer
(name appears here)
Taskl
Work Ptan Preparation
(names appear here)
EPA
Remedial Project Manager
(name appears here)
EPA
Technical Experts
(names appear here)
Contractor
Work Assignment Manager
(name appears here)
Subcontract
Laboratory Supervisor
(name appears here)
Task3
Treatabiltty Study Execution
(names appear here)
Task 2
SAP, HSP, ft CRP Preparation
(names appear here)
Tasks
Report Preparation
(names appear here)
Task 4
Data Analysis & Interpretation
(names appear here)
Task6
Residuals Management
(names appear here)
Figure 8. Example organization chart for a treatability study.
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One of the more common experimental designs applicable to bench-scale
treatability studies is the "factorial design." A factorial design is ap-
plicable when two or more primary independent variables are each tested at
two or more levels. For example, consider a situation in which there are
three primary independent variables (e.g., temperature, pH, and percentage
water). The experimenter wants to observe the effect when each variable is
tested at two levels. The experimental space for this experiment can be
presented graphically as shown in Figure 9.
d)
abc
be
Figure 9. Graphic representation of experimental space for
three primary independent variables tested at two levels.
This example is referred to .as a 23 factorial design in eight (2 x 2 x
2) test conditions. For bench-scale treatability studies involving the use
of triplicates, the actual number of individual test runs would be 3 x 23, or
24. Should the investigator need to study five primary independent vari-
ables* each at two levels, with triplicate analyses, the number of tests
required would be 3 x 25, or 96. Obviously, it would be very costly to run
an experiment of such magnitude.
The total number of test runs required can be reduced significantly by
decreasing the number of replicates from three to two. Further, rather than
run the full factorial design, the investigator could use a "fractional
factorial design." For example, to run a one-half factorial design for the
23 full factorial requires only four test conditions. Further, a one-half
factorial design for the 25 full factorial with duplicates requires 4 x 25 x
2 = 32 test run conditions. Obviously, the use of a fractional factorial
design not only reduces the number of test run conditions, but also results
in a corresponding loss of information gained from the experiment.
54
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Bench-scale testing typically involves the use of bench-top equipment or
apparatus that simulates the basic operation of the treatment process. The
Work Plan should describe how the equipment will be assembled and what mate-
rials will be used in its construction. The Work Plan also should specify
the volume and concentration of treatment reagents or additives.
3.5.4 Pilot-Scale Testing
Compared with bench-scale testing, pilot-scale testing entails evalua-
tion of the critical parameters at fewer levels but with even greater repli-
cation. Because selection of the remedy may be based on the results of these
investigations, the Work Plan should provide a statistically sound experi-
mental design (factorial or fractional factorial).
Pilot-scale testing typically involves the use of pilot-plant or field-
testing equipment of a configuration similar to that of the full-scale oper-
ating unit. If the tests are to be conducted on site, the Work Plan should
describe how the site will be prepared (including a map of the site layout),
what utility hookups will be required, and how the equipment will be mobil-
ized. The Work Plan also should specify the form in which treatment reagents
or additives will be delivered and stored. If equipment shakedown is neces-
sary, details should be given in this section.
3.6 PREPARING THE SAMPLING AND ANALYSIS PLAN
3.6.1 General
A Sampling and Analysis Plan (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 that the
quality of the analytical data generated is known. The SAP addresses field
sampling, waste characterization, and sampling and analysis of the treated
wastes and residuals from the testing apparatus or treatment unit.
Table 9 presents the suggested organization of the Sampling and Analysis
Plan. The SAP consists of two parts—the Field Sampling Plan (FSP) and the
Quality Assurance Project Plan (QAPjP).
Field Sampling Plan—
The FSP component of the SAP describes the sampling objectives; the
type, location, and number of samples to be collected; the sample numbering
system; the necessary equipment and procedures for collecting the samples;
the sample chain-of-custody procedures; and the required packaging, labeling,
and shipping procedures.
The sampling objectives must support the goals of the treatability
study. For example, if the goal of laboratory screening is to determine the
validity of biodegradation at a site, the objective of field sampling should
be to collect samples representing "average" conditions at the site. If,
55
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however, the goal of the study is to determine the maximum time required to
remediate the site, the objective of field sampling should be to collect
samples representing the "worst case."
TABLE 9. SUGGESTED ORGANIZATION OF SAMPLING AND ANALYSIS PLAN
Field Sampling Plan
1. Site Background
2. Sampling Objectives
3. Sample Location and Frequency
4. Sample Designation
5. Sample Equipment and Procedures
6. Sample Handling and Analysis
Quality Assurance Project Plan
1. Project Description
2. Project Organization and Responsibilities
3. Quality Assurance Objectives
4. Site Selection and Sampling Procedures
5. Sample Custody
6. Calibration Procedures and Frequency
7. Analytical Procedures
8. Data Reduction, Validation, and Reporting
9. Internal Quality Control Checks
10. Performance and Systems Audits
11. Preventive Maintenance
12. Calculation of Data Quality Indicators
13. Corrective Action
14. Quality Control Reports to Management
15. References
Appendices
A. Data Quality Objectives
B. Example of SOP for Chain-of-Custody Procedures
C. EPA Methods Used
D. SOP for EPA Methods Used
E. QA Project Plan Approval Form
The samples collected must be representative of the conditions being
evaluated. Guidance on representative samples and statistical sampling is
contained in Test Methods for Evaluating Solid Waste (EPA 1986). Additional
guidance for the selection of field methods, sampling procedures, and chain-
of-custody requirements can be obtained from A Compendium of Superfund Field
Operations Methods (EPA 1987b).
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Quality Assurance Project Plan--
The second component of the SAP, the QAPjP, details the quality assur-
ance objectives (precision, accuracy, representativeness, completeness, and
comparability) for critical measurements and the quality control procedures
established to achieve the desired QA objectives for a specific treatability
study. Guidance for preparing the QAPjP can be obtained from Interim Guide-
lines and Specifications for Preparing Quality Assurance Project Plans (EPA
1980). In general, QAPjPs are based on the type of project being conducted
and on the intended use of the data generated by the project.
3.6.2 Laboratory Screening
Laboratory screening requires a low level of QA/QC. Because technolo-
gies that are determined to be valid through laboratory screening are usually
evaluated further at the bench scale, the QA/QC requirements associated with
this tier are less rigorous. Nevertheless, the test data should be well
documented.
3.6.3 Bench-Scale Testing
Bench-scale testing requires a moderate to high level of QA/QC. Because
the data generated in bench-scale testing are generally used for evaluation
and selection of the remedy, the QA/QC associated with this tier should be
fairly rigorous and the test data well documented.
3.6.4 Pilot-Scale Testing
Pilot-scale testing requires a moderate to high level of QA/QC. Because
the data generated in pilot-scale testing are used in support of remedy
selection and implementation, the QA/QC associated with this tier should be
rigorous and the test data well documented.
3.7 PREPARING THE HEALTH AND SAFETY PLAN
3.7.1 General
A site-specific Health and Safety Plan (HSP) is required for all hazard-
ous waste operations that involve employee exposure to safety or health haz-
ards. The HSP identifies the hazards associated with each phase of site or
facility operations and prescribes appropriate protective measures. Hazards
that may be encountered during treatability studies include the following:
0 Chemical exposure (inhalation, absorption, or ingestion of
contaminated soils, sludges, or liquids)
0 Fires, explosions, or spills
0 Generation of toxic or asphyxiating gases
0 Physical hazards such as sharp objects or slippery surfaces
0 Electrical hazards such as high-voltage equipment
0 Heat stress or frostbite
57
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Table 10 presents the suggested organization of the HSP, which addresses
the Occupational Safety and Health Administration (OSHA) requirements in 29
CFR 1910.120(b)(4). Guidance for preparing the HSP is contained in A Compen-
dium of Superfund Field Operations Methods (EPA 1987b) and Occupational
Safety and Health Guidance Manual for Hazardous Waste Site Activities (NIOSH/
OSHA/USCG/EPA 1985). The HSP requirements apply to treatability studies
conducted on site or at an offsite laboratory or testing facility permitted
under RCRA, including research, development, and demonstration (RD&D)
facilities. These requirements do not apply to facilities that are condi-
tionally exempt from Subtitle C regulation by the treatability study sample
exemption (see Subsection 3.9.2).
TABLE 10. SUGGESTED ORGANIZATION OF
HEALTH AND SAFETY PLAN
1. Hazard Analysis
2. Employee Training
3. Personal Protective Equipment
4. Medical Surveillance
5. Personnel and Environmental Monitoring
6. Site Control Measures
7. Decontamination Procedures
8. Emergency Response Plan
9. Confined-Space Entry Procedures
10. Spill Containment Program
Supervisors, equipment operators, and field technicians engaged in on-
site operations must satisfy the training requirements in 29 CFR 1910.120(e)
and must participate in a medical surveillance program, as described in 29
CFR 1910.120(f). Laboratory personnel must be trained with regard to con-
tainer labeling and Material Safety Data Sheets (MSDS) in accordance with the
OSHA hazard communication standard in 29 CFR 1910.1200. Before any treat-
ability studies are initiated, the Site Safety Officer should conduct a
briefing to ensure that investigators are apprised of the HSP. The Site
Safety Officer also should conduct inspections during the course of the
treatability study to determine compliance with and effectiveness of the HSP.
3.7.1 Laboratory Screening
The safety and health hazards associated with laboratory screening are
relatively minor because of the small volumes of wastes that are subjected to
testing. In general, the HSP should provide for skin and eye protection when
handling the wastes. It need not require respiratory protection if the tests
are conducted in a fume hood.
3.7.2 Bench-Scale Testing
Like laboratory screening, the HSP should provide for skin and eye pro-
tection when handling the wastes. It also may require respiratory protection
58
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for treatment processes tested at the bench scale that involve mixing or
aeration (e.g., solidification/stabilization, aerobic biological treatment),
which could generate dust or volatilize organic contaminants.
3.7.3 Pilot-Scale Testing
Compared with the previous two tiers, pilot-scale testing involves
significantly larger volumes of waste, and the associated safety and health
hazards are much greater. The HSP should provide for skin, eye, and respira-
tory protection (Level C or higher); decontamination procedures; and equip-
ment emergency shutdown procedures.
3.8 CONDUCTING COMMUNITY RELATIONS ACTIVITIES
3.8.1 General
Community relations activities provide interested persons with the
opportunity to comment on and provide input to decisions concerning site
actions, including the performance of treatability studies. Public partici-
pation in the RI/FS process ensures that the community is provided with
accurate and timely information about site activities.
The Agency designs and implements community relations activities accord-
ing to CERCLA and the National Oil and Hazardous Substances Pollution Contin-
gency Plan (NCP). The NCP requires the lead Agency to prepare a Community
Relations Plan (CRP) for all remedial response actions and for all removal
actions longer than 45 days, regardless of whether RI/FS activities are Fund-
financed or conducted by RPs (40 CFR 300.67). A CRP must be prepared before
RI/FS activities are initiated at the site. This plan outlines all community
relations activities to be conducted during the RI/FS and projects future
activities that will be required during remedial design and construction.
These future activities are outlined more clearly in a revised plan developed
prior to the remedial design phase.
Guidance for preparing a CRP and conducting community relations activi-
ties can be acquired from Community Relations in Superfund: A Handbook (EPA
1988b). Table 11 presents the CRP organization suggested in this handbook.
TABLE 11. SUGGESTED ORGANIZATION OF COMMUNITY RELATIONS PLAN
1. Overview of Community Relations Plan
2. Capsule Site Description
3. Community Background
4. Highlights of the Community Relations Program
5. Community Relations Activities and Timing
Appendices
A. Contact List of Key Community Leaders and Interested Parties
B. Suggested Locations of Meetings and Information Repositories
59
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Prior to preparation of the CRP, community interviews should be conduct-
ed. These interviews are informal discussions held with State and local of-
ficials, community leaders, media representatives, and interested citizens to
assess public concern and desire to be involved in site response activities.
Discussions with citizens regarding the possible need for conducting onsite
treatability studies will allow the Agency to anticipate and respond better
to community concerns as the treatability testing process proceeds.
The Capsule Site Description in the CRP should include a brief discus-
sion of the possibility for treatability studies being conducted on site. It
should also attempt to identify the types of technologies that may be in-
vestigated and the tiers at which the treatability studies may be performed.
Conducting treatability studies on site is a potentially controversial
issue within a community and may demand a great deal of effort on the part of
the Agency. As the RI/FS progresses, community relations activities should
focus on providing information to the community concerning the technology
screening process and on obtaining feedback on community concerns associated
with potentially applicable treatment technologies. Activities may include,
but are not limited to, the following:
0 Preparing fact sheets and news releases describing treatment tech-
nologies identified during the literature/data base screening.
0 Conducting a workshop to present concerned citizens and local
officials with the Agency's considerations for selection of the
treatment technologies to be studied.
0 Holding small group meetings with involved members of the community
at regular intervals throughout the RI/FS process to discuss treat-
ability study findings and site decisions as they develop.
0 Ensuring citizen access to treatability study information by main-
taining a complete and up-to-date information repository.
Fact sheets on the planned treatability studies should be made available
to the public and should include a discussion of treatability-specific issues
such as the following:
0 Onsite treatability testing and analysis
0 Transportation of contaminated materials offsite
0 Materials handling
0 Residuals management
0 RI/FS schedule changes resulting from the unexpected need for
additional treatability studies
0 Uncertainties (risk) pertaining to innovative technologies
0 The degree of development of potentially applicable technologies
identified for treatability testing
0 Potential disruptions to the community
60
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3.8.2 Laboratory Screening
Laboratory screening is relatively low-profile and, if conducted off-
site, will require very few community relations activities. Distributing
fact sheets and placing the results from laboratory screening in the informa-
tion repository will generally be sufficient.
3.8.3 Bench-Scale Testing
Bench-scale testing may not be particularly controversial if conducted
offsite. Onsite testing, however, may require more community relations
activities. In addition to making fact sheets and test results available to
the public, holding an open house to view the treatment process in operation
may be advisable.
3.8.4 Pilot-Scale Testing
Pilot-scale testing may attract a great deal of community interest. In
some cases (e.g., onsite thermal treatment), the strength of the public's
opinion concerning pilot-scale testing of a potentially applicable technology
may not have been indicated by the level of interest demonstrated during the
RI and previous treatability studies. Because of the very real potential for
conflict and misunderstanding at the pilot-scale testing stage of the RI/FS
process, it is vital that a strong program of community relations and public
participation be established well in advance of any treatability testing.
Pilot-scale testing may provide data that can convince a community of a
technology's ability to remediate a site effectively. Inviting the community
to view the pilot process and educating them about the technology through
meetings and printed material may be helpful to foster community support for
pilot-scale testing.
Early, open, and consistent communication with the public and their full
participation in the decision-making process will help to prevent the test-
ing, development, and selection of a remedy that is unacceptable to the
community and results in delayed site remediation and higher remediation
costs.
3.9 COMPLYING WITH REGULATORY REQUIREMENTS
3.9.1 General
Treatability studies involving CERCLA wastes are subject to certain per-
mitting and operating requirements under the Comprehensive Environmental
Response, Compensation, and Liability Act [as amended by the 1986 Superfund
Amendments and Reauthorization Act (SARA)] and the Resource Conservation and
Recovery Act (RCRA) [as amended by the 1984 Hazardous and Solid Waste Amend-
ments (HSWA)]. These requirements vary depending on whether the studies are
conducted on site (e.g., in a mobile trailer) or at an offsite laboratory or
testing facility. The decision to conduct treatability studies on site is
influenced by several technical considerations, including the following:
61
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0 Volume of waste to be tested
0 Availability of mobile laboratory or transportable treatment unit
0 Site accessibility and size/space restrictions
0 Availability of onsite utilities (e.g., water, electricity, tele-
phone)
0 Mobilization/demobilization and per diem costs
0 Duration of tests
0 State and community acceptance
Figure 10 summarizes the regulatory requirements for onsite and offsite
testing; these requirements are described in the succeeding subsections.
Onsite Treatability Studies--
Onsite treatability studies under CERCLA may be conducted without any
Federal, State, or local permits [40 CFR 300.68(a)(3)]; however, such studies
must comply with applicable or relevant and appropriate requirements (ARARs)
under Federal and State environmental laws. For example, treatability studies
involving surface-water discharge must meet effluent limitations even though
a discharge permit is not required.
Offsite Treatability Studies—
Section 121(d)(3) of CERCLA and the Revised Off-Site Policy (OSWER
Directive 9834.11, November 13, 1987) generally state that offsite facilities
that receive CERCLA wastes must be 1) operating in compliance with applicable
Federal and State laws, and 2) controlling any relevant releases of hazardous
substances to the environment. Currently, the Revised Off-Site Policy does
not specifically exempt the transfer of CERCLA wastes offsite for treatabili-
ty studies; therefore, offsite laboratories or testing facilities that re-
ceive CERCLA wastes must be in compliance with the offsite requirements. As
part of a proposed rule to implement CERCLA Section 121(d)(3), however, the
EPA has requested comment on whether CERCLA wastes sent to laboratories for
analysis should be exempt from the offsite requirements (53 FR 48218, Novem-
ber 29, 1988). The commenters generally agree, and several have suggested
that this exemption be extended to wastes sent to laboratories and testing
facilities for treatability studies. Thus, the final rule, which is expected
to be published in February 1990, may change the offsite requirements for
wastes undergoing treatability testing and should be consulted on this point.
Offsite treatability studies under CERCLA must be conducted under appro-
priate Federal or State permits or authorization and other legal requirements.
Effective July 19, 1988, the sample exclusion provision [40 CFR 261.4(d)],
which exempts waste samples collected for the sole purpose of determining
their characteristics or composition from regulation under Subtitle C of
RCRA, was expanded to include waste samples used in small-scale treatability
studies (53 FR 27301). Because it is considered less stringent than
authorized State regulations for RCRA permits, the Federal Treatability Study
Sample Exemption Rule is applicable only in those States that do not have
final authorization or in authorized States that have revised their program
to adopt equivalent regulations under State law. Although the provision is
optional, the EPA has strongly encouraged authorized States to adopt the
exemption or to exercise their authority to order treatability studies (in
62
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Shipping Requirements
Facility Requirements
No Federal, SUM, or local ponnitt
required |40 CFR 300 68 («)P)); however.
faeihy mu«t comply with appkable or
relevant and appropriate requirement!
und*r Federal and State environmental
CondWona*/ mm* tarn RCHA
generator and tranaporler
requirementa »et loi* in 40 CFR
Par* 2«8 and 263 provtdwl
raquiranMnta am mat («0 CFR
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rKkVMTxM
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tr*atm*nt, atoraga, and
in 40 CFR Pant 2M. 265. and
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racordkatping, and raporting
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261.4 (f)].
CO
Yw
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Yee
Yee
Subject to ragutaHon under appropriate
d Stato onvlrofwiwntal UPW,
Figure 10. Regulatory requirements for onsite and offsite testing.
-------
the case of imminent and substantial endangerment to health or the environ-
ment) or to grant a general waiver, permit waiver, or emergency permit author-
ity to authorize treatability studies. To determine whether a particular
State has adopted the Federal Treatability Study Sample Exemption Rule, the
reader should contact the Regional Branch Chief in charge of RCRA Subtitle C
authorization as given in Table 12; the State Programs Branch, Permits and
State Programs Division, Office of Solid Waste (202/382-2210); or the State's
environmental protection agency.
Under the Federal Treatability Study Sample Exemption Rule, persons who
generate or collect samples of hazardous waste for the purpose of conducting
treatability studies are conditionally exempt from the generator and trans-
porter requirements (40 CFR Parts 262 and 263) when the samples are being
collected, stored, or transported to an offsite laboratory or testing facili-
ty [40 CFR 261.4(e)] provided that:
1) The generator or sample collector uses no more than 1000 kg of any
nonacute hazardous waste, 1 kg of acute hazardous waste, or 250 kg
of soils, water, or debris contaminated with acute hazardous waste
per waste stream per treatment process. (The Regional Admin-
istrator or State Director may, on a case-by-case basis, grant
requests for waste stream limits up to an additional 500 kg of
nonacute hazardous waste, 1 kg of acute hazardous waste, and 250 kg
of soils, water, or debris contaminated with acute hazardous
waste.)
2) The quantity of each sample shipment does not exceed these quantity
limitations.
3) The sample is packaged so that it will not leak, spill, or vaporize
from its packaging during shipment, and the transportation of each
sample shipment complies with U.S. Department of Transportation
(DOT), U.S. Postal Service (USPS), or any other applicable regula-
tions for shipping hazardous materials.
4) The sample is shipped to a laboratory or testing facility that is
exempt under 40 CFR 261.4(f) or that has an appropriate RCRA permit
or interim status.
5) The generator or sample collector maintains copies of the shipping
documents, the contract with the facility conducting the treatabil-
ity study, and records showing compliance with the shipping limits
for 3 years after completion of the treatability study.
6) The generator provides the above documentation in its biennial
report.
Similarly, offsite laboratories or testing facilities (including mobile
treatment units) are conditionally exempt from the treatment, storage, and
permitting requirements (40 CFR Parts 264, 265, and 270) when conducting
treatability studies [40 CFR 261.4(f)] provided that:
64
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TABLE 12. REGIONAL RCRA CONTACTS FOR DETERMINING
TREATABILITY STUDY SAMPLE EXEMPTION STATUS
U.S. EPA Region I
Massachusetts Waste Management Branch
(617) 573-1520
Connecticut Waste Management Branch
(617) 573-9650
New Hampshire and Rhode Island Waste
Management Branch
(617) 573-9610
Maine and Vermont Waste Management
Branch
(617) 573-5770
John F. Kennedy Federal Building
Boston, MA 02203
U.S. EPA Region II
Hazardous Waste Compliance Branch
26 Federal Plaza
New York, NY 10278
(212) 264-3384
U.S. EPA Region III
Waste Management Branch
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-1812
(215) 597-0980
U.S. EPA Region IV
Residuals Management Branch
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-3016
U.S. EPA Region V
RCRA Program Management Branch
230 South Dearborn Street
Chicago, IL 60604
(312) 353-8510
U.S. EPA Region VI
RCRA Programs Branch
First Interstate Bank Tower
14445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-6656
U.S. EPA Region VII
RCRA Branch
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2930
U.S. EPA Region VIII
RCRA Implementation Branch
One Denver Place, Suite 500
999 18th Street
Denver, CO 80202-2405
(303) 293-1662
U.S. EPA Region IX
State Programs Branch
215 Fremont Street
San Francisco, CA 94105
(415) 974-8917
(415) 974-1870
U.S. EPA Region X
Waste Management Branch
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-2782
65
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1) The facility notifies the Regional Administrator or State Director
that it intends to conduct treatability studies.
2) The laboratory or testing facility has an EPA identification number.
3) The quantity of "as received" hazardous waste that is subjected to
initiation of treatment in all treatability studies in any single
day is less than 250 kg.
4) The quantity of "as received" hazardous waste that is stored at the
facility does not exceed 1000 kg, the total of which can include
500 kg of soils, water, or debris contaminated with acute hazardous
waste or 1 kg of acute hazardous waste.
5) No more than 90 days have elapsed since the treatability study was
completed, or no more than 1 year has elapsed since the generator
or sample collector shipped the sample to the laboratory or testing
facility.
6) The treatability study does not involve either placement of hazard-
ous waste on the land or open burning of hazardous waste.
7) The facility maintains records showing compliance with the treat-
ment rate limits and the storage time and quantity limits for 3
years following completion of each study.
8) The facility keeps a copy of the treatability study contract and
all shipping papers for 3 years from the completion date of each
treatability study.
9) The facility submits an annual report to the Regional Administrator
or State Director that estimates the number of studies and the
amount of waste to be used in treatability studies during the
current year and that provides information on treatability studies
conducted during the previous year.
10) The facility determines whether any unused sample or residues
generated by the treatability study are hazardous waste [unless
they are returned to the sample originator under the 40 CFR
261.4(e) exemption],
11) The facility notifies the Regional Administrator or State Director
when it is no longer planning to conduct any treatability studies
at the site.
Laboratories or testing facilities not operating within these limita-
tions are subject to appropriate regulation. For example, facilities having
numerous treatment units that conduct many studies concurrently probably will
exceed the storage and treatment rate limits; these facilities may be re-
quired to obtain a RCRA RD&D permit (40 CFR 270.65).
66
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Residuals Management--
Treatability study residuals, including any unused sample or residues,
generated at an offsite laboratory or testing facility may be returned to the
sample originator under the Federal Treatability Study Sample Exemption Rule
(or equivalent State regulations) provided the storage time limits in 40 CFR
261. 4(f) are not exceeded. If the exemption does not apply, the disposal of
treatability study residuals is subject to appropriate regulation (i.e.,
hazardous wastes must be disposed of at a facility permitted under Subtitle C
of RCRA; solid wastes must be disposed of at a sanitary landfill or other
facility in compliance with Subtitle D of RCRA). The acceptability of a
commercial facility for receiving CERCLA wastes can be determined by con-
tacting the appropriate Regional Offsite Contact (ROC) as given in Table 13.
Treatability study residuals managed offsite must be packaged, labeled, and
manifested in accordance with 40 CFR Part 262 and applicable DOT regulations
for hazardous materials under 49 CFR Part 172.
As discussed previously, the Revised Off-Site Policy does not specifi-
cally exempt the transfer of treatability study residuals offsite for dispos-
al; therefore, offsite treatment or disposal facilities that receive these
wastes must be in compliance with the offsite requirements. The final off-
site rule, which is expected to be published in February 1990, may change the
offsite requirements for treatability study residuals and should be consulted
on this point.
3.9.2 Laboratory Screening
Because it uses small volumes of waste, laboratory screening conducted
offsite will typically be exempt from Subtitle C regulation provided the
State in which the treatability study is to be conducted has adopted regula-
tions equivalent to the Federal Treatability Study Sample Exemption Rule.
3.9.3 Bench-Scale Testing
As with laboratory screening, bench-scale testing conducted offsite will
typically be exempt from Subtitle C regulation because of the small volumes
of waste they use. When testing at the bench scale involves several process
alternatives (e.g., stabilization with cement, pozzolan, or asphalt) for
treating a particular waste stream, these may be considered separate treat-
ment processes with respect to the quantity limitations in 40 CFR 261. 4(e)
3.9.4 Pilot-Scale Testing
Because of the large volumes of wastes used, pilot-scale testing con-
ducted offsite will typically be subject to Subtitle C regulation.* Also,
*
The Agency intends to address large-scale treatability studies in separate
rulemaking at some future date; the Agency also is considering developing
regulations under 40 CFR Part 264, Subpart Y, that would establish per-
mitting standards for experimental facilities conducting research and
development on the storage, treatment, or disposal of hazardous waste.
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TABLE 13. REGIONAL OFFSITE CONTACTS FOR DETERMINING
ACCEPTABILITY OF COMMERCIAL FACILITIES TO RECEIVE CERCLA WASTES3
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
Primary contact/phone
John Zipeto
(617) 573-5744
Steven Luff tig
(212) 264-8672
Vernon Butler
(215) 597-6681
Alan Antley
(404) 347-7603
Gertrude Matuschkovitz
(312) 353-7921
Trish Brechlin
(214) 655-6765
David Doyle
(913) 236-2891
Mel Poundstone
(303) 293-1704
Leif Magnuson
(415) 974-7232
Al Odmark
(206) 442-1886
Backup contact/phone
Linda Murphy
(617) 573-5703
Dit Cheung
(212) 264-6142
Joe Golumbek
(212) 264-2638
Ruth Rzepski
(215) 597-6413
Gregory Fraley
(404) 347-7603
Joe Boyle
(312) 886-4449
Randy Brown
(214) 655-6745
Sam Becker
(214) 655-6725
Marc Rivas
(913) 236-2891
Mike Gansecki
(303) 293-1510
Terry Brown
(303) 293-1823
Jane Diamond
(415) 974-8364
Wayne Pierre
(206) 442-7261
a These contacts are subject to change. An updated list can be obtained from
the Superfund docket or the RCRA/CERCLA Hotline (1-800-424-9346).
68
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treatability studies involving the placement of wastes on the land (e.g.,
disposal of stabilized material in a landfill) will be subject to regulation.
Laboratories or testing facilities conducting these types of studies must be
permitted or have interim status with respect to the particular waste
stream(s) and treatment process(es) to be tested.
3.10 EXECUTING THE STUDY
3.10.1 General
Execution of the treatability study begins after the RPM has approved
the Work Plan and other supporting documents. Steps include collecting a
sample of the waste stream for characterization and testing, conducting the
test, and collecting and analyzing samples of the treated waste and residu-
als.
Field Sampling and Waste Stream Characterization--
Field samples should be collected and preserved in accordance with the
procedures outlined in the SAP. They should be representative of "average"
or "worst-case" condition, as dictated by the test objectives, and a large
enough sample should be collected to complete all of the required tests and
analyses in the event of some anomaly. To the extent possible, field sam-
pling should be coordinated with other onsite activities to minimize costs.
Samples shipped to an offsite laboratory for testing or analysis must be
packaged, labeled, and shipped in accordance with DOT, USPS, or other ap-
plicable shipping regulations (see Subsection 3.9). A chain-of-custody
record, such as the example in Figure 11, should accompany each sample ship-
ment.
The collected sample should be thoroughly mixed to ensure that it is
homogeneous. This will allow comparison of results under different test
conditions. Small-volume soil samples can be mixed with a Hobart mixer, and
large-volume samples can be mixed with a drum roller. Stones, sticks, and
other debris should be removed by screening.
Characterization samples should be collected from the same material that
will be used in the performance of the treatability study. Characterization
is necessary to determine the chemical, physical, and/or biological proper-
ties exhibited by the waste stream so that the results of the treatability
study can be properly gauged. Appendix C lists specific characterization
parameters that may be applicable for biological treatment, physical/chemical
treatment, immobilization, thermal treatment, and in situ treatment technolo-
gies. Standard analytical methods are referenced in Appendix D.
Treatability Testing--
The treatability study should be performed in accordance with the test
matrix and standard operating procedures described in the Work Plan. Any
deviations from the SOP should be recorded in the field or laboratory note-
book. (Data management was discussed in Subsection 3.5.1.)
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-vl
o
PROJECT NAME/NUMBER.
CHAIN-OF-CUSTODY RECORD
LAB DESTINATION.
SAMPLE
NUMBER
SAMPLE
LOCATION AND DESCRIPTION
DATE AND TIME
COLUECTED
SAMPLE
TYPE
CONTAMER
TYPE
CONDITION ON RECEIPT
(NAME AND DATE)
SPECIAL INSTRUCTIONS:
POSSIBLE SAMPLE HAZARDS ,
SIGNATURES: (NAME.COMPANY.DATE.AND TIME)
1. RELINQUISHED BY:
RECEIVED BY:
3. RELINQUISHED BY:
RECEIVED BY:
2. RELINQUISHED BY:
RECEIVED BY:
4. RELINQUISHED BY:
RECEIVED BY:
WHITE • To accompany twnptot
YELLOW-Fwld copy
Figure 11. Example of Chain-of-Custody Record.
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The EPA or a qualified contractor should oversee testing conducted by
vendors and RPs. Oversight activities may include:
0 Review of plans, reports, and records
0 Oversight of waste sampling and analysis (e.g., split samples)
0 Maintenance of records and documentation
0 Validation of test results
0 Monitoring of compliance with ARARs
Sampling and Analysis--
Samples of the treated waste and any process residuals (e.g., off-gas,
scrubber water, and ash for incineration tests) should be collected in ac-
cordance with the SAP. The SAP specifies the location and frequency of
sampling, proper containers and sample preservation techniques, and maximum
holding times. Quality assurance samples (e.g., blanks, splits) should be
collected at the same time as the treatability study samples. All samples
should be logged in the field or laboratory notebook. As stated previously,
samples shipped to an offsite laboratory must be packaged, labeled, and
shipped in accordance with DOT, USPS, or other applicable shipping regula-
tions, and a chain-of-custody record should accompany each sample shipment.
Analysis of treatability study samples should proceed in accordance with
the methods specified in the SAP. The normal sample turnaround time is 3 to
4 weeks for most analyses; the laboratory may charge a premium if results are
required in less time.
3.10.2 Laboratory Screening
Laboratory screening is normally performed on the bench top with small
volumes of waste. For this reason, obtaining a representative sample for
characterization and testing can be difficult, and thorough mixing of the
waste feed is important. Direct-reading instruments and indicator tests used
in laboratory screening provide quick and relatively inexpensive analyses.
3.10.3 Bench-Scale Testing
Like laboratory screening, bench-scale testing is normally performed on
the bench top with small volumes of waste, and obtaining a representative
sample can be difficult. For this reason, thorough mixing of the waste feed
is important. These tests involve quantitative analyses with more sophisti-
cated instruments such as gas chromatography (GC), gas chromatography/mass
spectrometry (GC/MS), atomic absorption (AA), or inductively coupled plasma
(ICP). Testing oversight should be provided if the results of bench-scale
testing will be used to support the ROD.
3.10.4 Pilot-Scale Testing
Pilot-scale testing is typically performed in a pilot plant or in the
field and involves significantly larger volumes of waste than either labora-
tory screening or bench-scale testing. Consequently, obtaining a respresen-
tative sample is much less difficult. These tests include quanititative
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analyses with more sophisticated instruments (as described previously).
Testing oversight should be provided as a matter of routine.
3.11 ANALYZING AND INTERPRETING THE DATA
3.11.1 General
Upon completion of a treatability study, the data must be summarized and
evaluated to determine the validity or performance of the treatment process.
The first goal of data analysis is to determine the quality of the data
collected. All data should be checked to assess precision (relative percent
difference for duplicate matrix spikes), accuracy (percent recovery of matrix
spikes), and completeness (percentage of data that are valid). If the QA
objectives specified in the QAPjP have not been met, the RPM and the Work
Assignment Manager must determine the appropriate corrective action.
Data are generally summarized in tabular or graphic form. The exact
presentation of the data will depend on the experimental design and the
relationship between the variables being compared. Generally, independent
variables, which are controlled by the experimenter, are plotted on the
abscissa, whereas dependent variables, which fluctuate as a result of chang-
ing the independent variables, are plotted on the ordinate. Examples of
independent variables are pH, temperature, reagent concentration, and reac-
tion time. Examples of dependent variables are removal efficiency and sub-
strate utilization.
Table 14 presents an example tabulation of data from an experiment in
which one parameter is varied (e.g., reagent concentration). A procedure
referred to as analysis of variance (ANOVA) can be used to determine if a
statistically significant difference exists between the effectiveness of the
four reagent concentrations. Procedures for performing analyses of variance
for one-way classifications are described by Snedecor and Cochran (1967).
TABLE 14. EXAMPLE TABULATION OF DATA FROM
AN EXPERIMENT IN WHICH ONE PARAMETER IS VARIED3
Reagent concentration, %
Sample No. A B
1
2
3
Mean
XA1
XA2
XA3
XA
XB1
XB2
XB3
XB
XC1
XC2
XC3
xc
XD1
XD2
XD3
XD
a Reagent concentration is varied.
72
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Table 15 presents an example tabulation of data from an experiment in
which two parameters are varied (e.g., reagent concentration and reaction
time). Analysis of variance techniques for two-way classifications (Snedecor
and Cochran 1967) can be used to determine if reaction time has the same ef-
fect for both reagent concentrations and if a statistically significant dif-
ference exists between the mean effectiveness of the five reaction times. If
such a difference is detected, ANOVA can be followed by the Tukey multiple-
comparison procedure (Scheffe 1959) to determine which sample means differ
significantly and by how much.
TABLE 15. EXAMPLE TABULATION OF DATA FROM
AN EXPERIMENT IN WHICH TWO PARAMETERS ARE VARIED3
Reagent concentration, %
Reaction time, h
0.25
0.5
1
2
3
XA
XA
XA
XA
XA
XA
XA
XA
XA
XA
XA
XA
XA
XA
XA
,0
,0
,0
,0
,0
,0
,1
,1
,1
,2
,2
,2
,3
,3
,3
A
.25,1
.25,2
.25,3
.5,1
.5,2
.5,3
,1
,2
,3
,1
,2
,3
,1
,2
,3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
,0
,0
,0
,0
,0
,0
,1
,1
,1
,2
,2
,2
,3
,3
,3
B
.25,
.25,
.25,
.5,1
.5,2
.5,3
,1
,2
,3
,1
,2
,3
,1
,2
,3
1
2
3
Reagent concentration and reaction time are varied.
Data from an experiment in which multiple samples with different initial
contaminant concentrations are tested under the same set of conditions are
plotted as shown in Figure 12. Regression analysis, as described by Natrella
73
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(1966), can be used to determine the effect of initial contaminant
concentration on the performance of the technology. In its simplest form,
regression analysis assumes a linear functional relationship:
The statistical analysis procedure uses the experimental data to obtain
estimates of the parameters B (the y-intercept) and ex (the slope) of a
straight line. This procedure is also referred to as "least-squares linear
regression." The linear equation may be used to estimate the contaminant's
final concentration in the waste stream, given its initial concentration. In
this manner, one can determine whether a particular treatment technology
under consideration has the potential to meet the cleanup goals for the site.
TO UJ
Initial Concentration
(specify units)
Figure 12. Example plot of initial
versus final contaminant concentration.
In some instances, it may be unrealistic to assume that the relationship
between a dependent and an independent variable can be expressed as a linear
function. Procedures for nonlinear functions are discussed in most statisti-
cal texts.
3.11.2 Laboratory Screening
Laboratory screening is used to determine whether a technology is valid
and if further testing is warranted. Because these studies entail limited
74
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QA/QC and little or no replication, statistical analysis of the data may not
be appropriate. Results can be interpreted qualitatively (i.e., "go/no go").
3.11.3 Bench-Scale Testing
Bench-scale testing usually involves factorial (or fractional factorial)
design in which two or more primary independent variables are each tested at
two or more levels. Cochran and Cox (1957) describe the application of
ANOVA techniques to these types of studies. The data can be analyzed to
determine how the critical parameters affect the performance of the system
and if the process can meet the cleanup goals for the site.
3.11.4 Pilot-Scale Testing
Like bench-scale testing, pilot-scale testing usually involves factorial
(or fractional factorial) design, and ANOVA techniques can be used to deter-
mine how the critical parameters affect the performance of the system. In
addition, data from pilot-scale testing can provide information on costs
(reagent use, power and water consumption, treatment rate, etc.) and equip-
ment design (waste feed, mixing, solids separation, etc.).
3.12 REPORTING THE RESULTS
3.12.1 General
The final step in conducting a treatability study is reporting the test
results. Complete and accurate reporting is critical, as decisions about
treatment alternatives will be based, in part, on the outcome of treatability
studies. Besides assisting in the selection of the remedy, the performance
of treatability studies will increase the existing body of scientific knowl-
edge about innovative treatment technologies.
For facilitation of the reporting of treatability study results and the
exchange of treatment technology information, a suggested organization for a
treatability study report is presented in Table 16. Reporting treatability
study results in this manner will expedite the process of comparing treatment
alternatives. It will also allow other individuals who may be studying
similar technologies or waste matrices to gain valuable insight into the
applications and limitations of various treatment processes.
If a treatment technology is to be tested at multiple tiers, it may not
be necessary to prepare a formal report for each tier of the testing. Inter-
im reports prepared at the completion of each tier may suffice. Also, it may
be appropriate to conduct a project briefing with the interested parties to
present the study findings and to determine the need for additional testing.
A final treatability study report that encompasses the entire study may be
developed after all testing is complete.
As an aid in the selection of remedies and the planning of future treat-
ability studies, the Office of Emergency and Remedial Response requires that
a copy of all treatability study reports be submitted to the Agency's
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TABLE 16. SUGGESTED ORGANIZATION OF TREATABILITY STUDY REPORT
1. Introduction
1.1 Site description
1.1.1 Site name and location
1.1.2 History of operations
1.1.3 Prior removal and remediation activities
1.2 Waste stream description
1.2.1 Waste matrices
1.2.2 Pollutants/chemicals
1.3 Remedial technology description
1.3.1 Treatment process and scale
1.3.2 Operating features
1.4 Previous treatability studies at the site
2. Conclusions and Recommendations
2.1 Conclusions
2.2 Recommendations
3. Treatability Study Approach
3.1 Test objectives and rationale
3.2 Experimental design and procedures
3.3 Equipment and materials
3.4 Sampling and analysis
3.4.1 Waste stream
3.4.2 Treatment process
3.5 Data management
3.6 Deviations from the Work Plan
4. Results and Discussion
4.1 Data analysis and interpretation
4.1.1 Analysis of waste stream characteristics
4.1.2 Analysis of treatability study data
4.1.3 Comparison to test objectives
4.2 Quality assurance/quality control
4.3 Costs/schedule for performing the treatability study
4.4 Key contacts
References
Appendices
A. Data summaries
B. Standard operating procedures
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Superfund Treatability Data Base repository, which is being developed by the
Office of Research and Development (EPA 1989b). Submitting treatability
study reports in accordance with the suggested organization will increase the
usability of this repository and assist in maintaining and updating the data
base. One camera-ready master copy of each treatability study report should
be sent to the following address:
Mr. Kenneth A. Dostal
Superfund Treatability Data Base
U.S. Environmental Protection Agency
Office of Research and Development
Risk Reduction Engineering Laboratory
26 W. Martin Luther King Drive
Cincinnati, Ohio 45268
The following subsections describe the contents of the treatability
study report.
Introduction--
The introductory section of the treatability study report contains back-
ground information about the site, waste stream, and treatment technology.
Much of this information will come directly from the previously prepared
treatability study Work Plan. This section also includes a summary of any
treatability studies previously conducted at the site.
Conclusions and Recommendations—
This section presents the conclusions and recommendations concerning the
applicability of the treatment process tested. It should attempt to answer
questions such as the following:
0 Were the test objectives met? If not, why?
0 What parts of the test should have been performed differently and
why?
0 Are additional tiers of treatability testing required for further
evaluation of the technology? Why or why not?
0 Can the technology be scaled up based on the existing data?
The conclusions and recommendations should be stated briefly and succinctly.
Information that is pertinent to the discussion and exists elsewhere in the
report should be referenced rather than restated in this section.
The report should provide an analysis of the results as they relate to
the goals of the study and the relevant evaluation criteria. In particular,
the results should be extrapolated to full-scale operation to indicate areas
and extent of uncertainty in the analysis.
Treatability Study Approach—
This section documents why and how the treatability study was conducted.
It describes in detail the procedures and methods that were used to sample
and analyze the waste stream and documents any deviations from the Work Plan.
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Like the introduction, this section contains information from the previously
prepared Work Plan.
Results and Discussion--
The final section of the treatability study report includes the presen-
tation and a discussion of results (including QA/QC). Results for the con-
taminants of concern should be reported in terms of the concentration of the
input and output streams as well as the percentage reduction achieved. The
use of charts and graphs may aid in the presentation of results. This final
report section also includes the costs and time requirements of conducting
the study, as well as key contacts for future reference.
References--
All citations should be clearly referenced.
Appendices-
Summaries of the data generated and the standard operating procedures
used are included in appendices.
3.12.2 Laboratory Screening
Laboratory screening results will be reported in the format shown in Ta-
ble 16, although some of the sections may be abbreviated if bench- or pilot-
scale testing is planned. The conclusions and recommendations will focus
primarily on whether the technology investigated has validity for the site
and will attempt to identify critical parameters for future treatability
testing and to recommend tiers for future study. Data will be presented in
simple tables or graphs. Statistical analysis is generally not required.
Because laboratory screening does not involve rigorous QA/QC, the discussion
of this subject will be brief.
3.12.3 Bench-Scale Testing
Bench-scale testing conclusions and recommendations will focus primarily
on the technology's performance (i.e., ablility to meet the anticipated
cleanup goals for the site) and will attempt to identify critical parameters
for future treatability testing, if needed. The results should include a
statistical evaluation of the data and a discussion of data quality.
3.12.4 Pilot-Scale Testing
Pilot-scale testing conclusions and recommendations will focus on the
technology's performance, as well as process optimization parameters that
were identified. Like bench-scale treatability study reports, the results
should include a statistical evaluation of the data and a discussion of data
quality. If laboratory screening or bench-scale testing were also conducted,
the results should be included in the final treatability study report.
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REFERENCES
Cochran, W. G., and G. M. Cox. 1957. Experimental Designs. 2nd ed. John
Wiley & Sons, Inc., New York.
National Institute for Occupational Safety and Health/Occupational Safety and
Health Administration/U.S. Coast Guard/U.S. Environmental Protection Agency.
1985. Occupational Safety and Health Guidance Manual for Hazardous Waste
Site Activities. DHHS (NIOSH) Publication No. 85-115.
Natrella, M. G. 1966. Experimental Statistics. National Bureau of Stan-
dards Handbook 91, U.S. Government Printing Office, Washington, D.C.
Scheffe, H. 1959. The Analysis of Variance. John Wiley & Sons, Inc., New
York.
Snedecor, G. W., and K. G. Cochran. 1967. Statistical Methods. 6th ed.
The Iowa State University Press, Ames, Iowa.
U.S. Environmental Protection Agency. 1980. Interim Guidelines and Specifi-
cations for Preparing Quality Assurance Project Plans. QAMS-005/80.
U.S. Environmental Protection Agency. 1986. Test Methods for Evaluating
Solid Waste. 3rd ed. SW-846.
U.S. Environmental Protection Agency. 1987a. Data Quality Objectives for
Remedial Response Activities. Development Process. EPA/540/G-87/003, OSWER
Directive 9355.0-07B.
U.S. Environmental Protection Agency. 1987b. A Compendium of Superfund
Field Operations Methods. EPA/540/P-87/001.
U.S. Environmental Protection Agency. 1988a. Guidance for Conducting Reme-
dial Investigations and Feasibility Studies Under CERCLA. Interim Final.
EPA/540/G-89/004, OSWER Directive 9355.3-01.
U.S. Environmental Protection Agency. 1988b. Community Relations in Super-
fund: A Handbook. Interim Version. EPA/540/G-88/002, OSWER Directive
9230.0-3B.
U.S. Environmental Protection Agency. 1989a. A Management Review of the
Superfund Program. Prepared for William K. Reilly, Administrator, U.S.
Environmental Protection Agency, Washington, D.C.
U.S. Environmental Protection Agency. 1989b. Treatability Studies Contrac-
tor Work Assignments. Memo from Henry L. Longest, II, Director, Office of
Emergency and Remedial Response, to Superfund Branch Chiefs, Regions I
through X, July 12. OSWER Directive 9380.3-01.
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APPENDIX A
SOURCES OF TREATABILITY INFORMATION
In recent years, a wide variety of information has been developed that
can assist in planning and conducting treatability studies and analyzing the
data generated. Such treatability information comes from three types of
sources: 1) hard copy reports, documents, or guidance; 2) electronic data
bases; and 3) experienced EPA personnel. The information presented herein is
not intended to be comprehensive, but rather to enable the reader to access a
range of primary information sources through which other sources can be
identified.
REPORTS, DOCUMENTS, AND GUIDANCE
Knowledge gained during the planning and conducting of treatability
studies has begun to make its way into circulation in the form of technical
resource documents, reports, and guidance manuals. The publication of infor-
mation pertaining to treatability studies is recent and gaining momentum.
Many of the documents available today are in draft or interim final form with
revisions underway, whereas other documents are still in the planning stage
and not yet available to the public. A listing of currently available pri-
mary publications that contain relevant information is provided here.
Inquiries as to how to obtain these documents should be directed to the
RCRA/CERCLA Hotline (1-800-424-9346).
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. OSWER
Directive 9355-01. EPA/540/G-89/004, October 1988.
Superfund Treatability Clearinghouse Abstracts. U.S. Environmental Pro-
tection Agency, Office of Emergency and Remedial Response, Washington,
D.C. EPA/540/2-89/001, March 1989.
The Superfund Innovative Technology Evaluation Program: Technology Pro-
files. U.S. Environmental Protection Agency, Office of Solid Waste and
Emergency Response and Office of Research and Development, Washington,
D.C. EPA/540/5-88/003, November 1988.
Summary of Treatment Technology Effectiveness for Contaminated Soil.
U.S. Environmental Protection Agency, Office of Emergency and Remedial
Response, Washington, D.C. 1989 (in press).
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ELECTRONIC DATA BASES
Interaction with available data bases can provide an additional perspec-
tive on the interpretation of results from treatability studies. The effica-
cy of constructing a data base that integrates pertinent elements of several
existing data bases is currently being explored by the Risk Reduction Engi-
neering Laboratory. The resulting consolidated data base would be designed
to provide sufficient high-quality data for application to treatability
studies conducted for different compounds within a similar class. The over-
all objective of developing a consolidated data base is to create a single
mechanism for transferring knowledge about what does and doesn't work, based
on previous studies of like contaminants.
No such consolidated data base currently exists; however, several unique
data bases in various phases of development are mentioned because they con-
tain some elements of value for evaluation of the effectiveness of a particu-
lar technology in treating different classes of contaminants.
0 WERL Treatability Data Base/Superfund Treatability Data Base
0 OSWER Electronic Bulletin Board System (BBS)
0 Computerized On-Line Information System (COLIS)
0 Alternative Treatment Technology Information Center (ATTIC)
Although this appendix highlights several of these systems, it should
not be construed as a comprehensive collection of data bases. Each of the
systems listed is briefly described, however, to provide the reader with a
general background on the type of information that is available.
WERL Treatability Data Base/Superfund Treatability Data Base
Contact: Kenneth Dostal
(513) 569-7503
The WERL Treatability Data Base was begun under the former Water Engi-
neering Research Laboratory (WERL) and is now maintained by the Risk Reduc-
tion Engineering Laboratory (RREL) in Cincinnati, Ohio. The purpose of the
data base was to compile data on the treatability of specific organic and
inorganic compounds in all types of waters and wastewaters. The data base
currently contains more than 800 compounds, and more than 2500 sets of treat-
ability data are available for approximately 300 of those compounds. The
data base is available on PC disks, and the following hardware and software
are needed for its use:
0 IBM PC or compatible
0 PC/MS DOS, Version 2.0 or greater
524K RAM available
0 10 cbi printer
0 Monochrome or color monitor
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The WERL Treatability Data Base currently has more than 1500 users
throughout EPA Headquarters, the Regional offices, and other State and
Federal agencies. The system is programmed in dBase III+ and is delivered on
floppy disks at no charge to users. This system will also be available
through COLIS (described below) in fiscal year 1990.
The WERL Treatability Data Base is currently being expanded to include
treatability study data for all CERCLA site waste matrices. Called the
Superfund Treatability Data Base, this component of the WERL Treatability
Data Base will contain data from all treatability studies conducted under
CERCLA. A repository for treatability study reports will be maintained at
the Risk Reduction Engineering Laboratory in Cincinnati, Ohio.
OSWER Electronic Bulletin Board System (BBS)
Contact: James Cummings
(202) 382-4686
The OSWER Electronic Bulletin Board System was created in 1987 by the
Office of Solid Waste and Emergency Response as a tool for communicating
ideas and disseminating information. In addition to its message capabili-
ties, BBS is a gateway for many Office of Solid Waste (OSW) electronic data
bases. Few restrictions are set on the types of information exchanged. The
BBS is intended to be available to personnel throughout OSWER, the Regional
offices, the Regional laboratories, and their contractors. Restrictions on
access to the BBS are few.
As mentioned earlier, BBS is a vehicle through which users can post and
receive messages. Systems operators update the system with news as it be-
comes available. Data bases can be downloaded from or uploaded to BBS.
Users must be equipped with a personal computer or a terminal, a modem, and a
communications package.
Currently, the BBS has eight different components, including news and
mail services and conferences and publications on specific technical areas.
For example, it includes conferences on ground water and waste minimization.
Computerized On-Line Information System (COLIS)
Contact: Hugh Masters
(201) 321-6678
The Computerized On-Line Information System was started in 1980 and is
housed and maintained at the Risk Reduction Engineering Laboratory in Edison,
New Jersey. COLIS was not designed as a data base, but rather as an informa-
tion system. It consolidates several computerized data bases developed by
RREL in Cincinnati and Edison.
COLIS has been developed to accommodate any type of personal computer or
microcomputer and any type of modem; no special equipment is required. Pro-
grams for searching data are provided within COLIS in a menu-type format, and
the system uses standard prompt commands. COLIS is currently composed of
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three files: Case Histories, Library Search, and Superfund Innovative Tech-
nology Evaluation (SITE) Applications Analysis Reports (AARs).
The Case Histories file contains historical information obtained from
corrective actions implemented at Superfund sites and on leaking underground
storage tanks. The Library Search system is designed to provide access to
special collections or research information pertaining to many RREL programs
(e.g., oil and hazardous materials, underground storage tanks, soils washing,
incineration, and stormwater controls). This file is under development and
scheduled for implementation by December 1989. The SITE AARs file provides
actual cost and performance information. It presents results from three
sites for which AARs have been prepared. Additional information will be
added as AARs are completed.
Information stored in this system is textual in nature instead of numer-
ical, which permits the user's interpretation. Plans for near-term develop-
ment call for the implementation of both the Aqueous Treatability Data Base
and the Soils & Debris Treatability Data Base.
Alternative Treatment Technology Information Center (ATTIC)
Contact: Michael Mastracci
(202) 382-5748
The creation and development of the Alternative Treatment Technology
Information Center has been overseen by ORD Headquarters. ATTIC, which is a
compendium of information from many available data bases, can be accessed
through the RCRA/CERCLA Hotline or the BBS. Targeted user groups for this
system are RPMs, On-Scene Coordinators (OSCs), ARCS contractors, and State
Superfund program personnel.
Data relevant to the use of treatment technologies in Superfund actions
are collected and stored in ATTIC. It serves as a mechanism for searching
other information systems and data bases for pertinent data and integrates
the information found into a response to the user's query. It also includes
a pointer system to refer the user to individual experts throughout the
Agency.
ATTIC comprises nine different data bases including a ROD data base,
soil transport and fate, a hazardous waste collection data base, a historical
user file, and a technical assistance option. The system is currently made
up of technical summaries from SITE program abstracts, treatment technology
demonstration projects, industrial project results, and international program
data.
EPA PERSONNEL
As part of a recent EPA initiative to facilitate the conduct and quality
of treatability studies, the Office of Research and Development has under-
taken to make human resources available to EPA Regional staff to provide the
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benefit of their scientific and practical expertise. The result has been the
creation of the Superfund Technical Assistance Response Team (START) and
complementary technology teams.
The goal of the Superfund Technical Support Task Force, which directs
the START and technology teams, is to facilitate the exchange of knowledge
about conducting treatability studies from personnel with treatability study
experience or a substantial technical understanding of a specific treatment
technology to personnel having little experience in either area. Currently,
the Task Force is supporting a variety of treatability-related activities,
including the development of this guide, the preparation of technology-
specific protocols, drafting technology evaluation summary sheets, and com-
piling a list of vendors who perform treatability studies. For further
details, contact Benjamin L. Blaney at the Risk Reduction Engineering Labora-
tory (513/569-7406).
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APPENDIX B
COST ELEMENTS ASSOCIATED WITH TREATABILITY STUDIES
Section 2 of this guide describes three tiers of treatability testing:
laboratory screening, bench-scale testing, and pilot-scale testing. This
appendix presents the cost elements associated with the various tiers of
treatability studies. In some cases, unit costs are provided, and in other
cases project-specific examples are provided that lend insight into the costs
of various elements of treatability studies.
Many cost elements are applicable to all levels of treatability testing,
although some, such as the volume of residuals or cost of analytical servic-
es, will increase from laboratory screening to bench-scale testing to pilot-
scale testing. Other cost elements (e.g., site preparation and utilities)
are only applicable to pilot-scale testing. Figure 13 shows the applicabili-
ty of the various cost elements to the different treatability study tiers.
The following is a discussion of some of the key cost elements.
Site preparation and logistics costs include costs associated with plan-
ning and management, site design and development, equipment and facilities,
health and safety equipment, soil excavation, feed homogenization, and feed
handling. Costs associated with the majority of these activities are normal-
ly incurred only on mobile pilot-scale treatability studies; however, some of
these cost elements, such as feed homogenization and health and safety, are
seen in laboratory screening and bench-scale testing.
Vendor equipment rental is a key cost element in the performance of
pilot-scale testing. Most vendors have established daily, weekly, and month-
ly rates for the use of their treatment systems. These charges cover wear
and tear on the system, utilities, maintenance and repair, and system prepa-
ration. In some cases, vendors include their operators, personal protective
equipment, chemicals, and decontamination in the rental charge. Treatment
system rental charges typically run about $5,000 to $20,000 per week. Also,
if the vendor sets up a strict timetable for testing, the client may be
billed $4000 to $5000 per day for each day the waste is late in arriving at
the facility.
Analytical costs apply to all tiers of treatability studies and have a
significant impact on the total project costs. Several factors affect the
cost of the analytical program, including the laboratory performing the
analyses, the analytical target list, the number of samples, the required
85
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Cost Element
Site Preparation
(e.g., feed homogenization)
Permitting and
Regulatory
Test Plan
Preparation
Mobilization/
Demobilization
Vendor Equipment
Rental
Supplies
(materials)
Supplies
(utilities)
Health and
Safety
Field Instrumentation
and Monitors
Testing
Equipment
Materials Compatibility
Testing
Analytical
Air Emission
Treatment
Effluent
Treatment
Decontamination
of Equipment
Residual
Transportation
Treatment/
Disposal
Testability Study Tier
Laboratory
Screening
O
O
o
o
o
w
v
Bench-
Scale
O
O
Pilot-
Scale
O
Not applicable
and/or no cost
incurred.
May be applicable
and/or intermediate
cost incurred.
Applicable
and/or high
cost incurred.
Figure 13. General applicability of cost elements to various
treatability study tiers.
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turnaround time, QA/QC, and reporting. Analytical costs vary significantly
from laboratory to laboratory, but before prices are compared, the
laboratories should be properly compared. What methods will be used for
sample preparation and analysis? What detection limits are needed? Does
each laboratory fully understand the matrix that will be received (e.g.,
tarry sludge, oily soil, slag) or interference compounds that may be in the
sample (e.g., sulfide)? If all information indicates that the laboratories
are using the same methods and equipment and understand the objectives of the
analytical program, the costs for analysis can be compared.
It is also important to be aware that some analytes cost more to analyze
than others. Often, there are analytes that the investigator would like to
analyze for informational purposes that may not be critical to the study.
The decision to analyze for these parameters could be simple if the parameter-
specific costs were known. For example, TOC analysis of soil costs about
$90/sample, whereas analysis for total dioxins costs about $650/sample.
The number of samples, turnaround time, QA/QC, and reporting also affect
analytical costs. Often, laboratories give discounts on sample quantities of
greater than 5, greater than 10, and greater than 20 when the samples arrive
in the laboratory at the same time. The laboratory also applies premium
costs of 25, 50, 100, and 200 percent when analytical results are requested
sooner than normal turnaround time. For example, if the cost to analyze a
soil sample for mercury by cold vapor atomic absorption is $33 for a 20-
working-day turnaround, the cost would escalate to $41.25 for a 10- to 15-day
turnaround time, $49.50 for a 5- to 10-day turnaround time, $66 for a 48- to
96-hour turnaround time, and $99 for less than a 48-hour turnaround time. If
matrix spike and matrix spike duplicates are required, the analytical cost
will triple for those QA/QC samples. Also, whether the laboratory provides a
cover letter with the attached data or a complete analytical report will
affect the analytical costs.
Residual transportation and disposal are also important elements that
must be budgeted in the performance of all treatability studies. Depending
on the technology(ies) involved, a number of residuals will be generated.
Partially treated effluent, scrubber water, sludge, ash, spent filter media,
scale, and decontamination liquids/solids are examples of residuals that must
be properly transported and treated or disposed of in accordance with all
local, State, and Federal regulations. Unused feed and excess analytical
sample material must also be properly managed. Typically, a laboratory will
add a small fee (e.g., $5 per sample) to dispose of any unused sample materi-
al; however, the unused raw material and residuals, which could amount to a
sizeable quantity of material, will cost significantly more to remove.
Transportation cost for a dedicated truck (as opposed to a truck making a
"milk run") is about $3.25 to $3.75 per loaded mile. Costs for treatment of
inorganic wastewaters may range from $65 to $200 per 55-gallon drum. Incin-
eration of organic-contaminated wastewaters ranges from $200 to $1000 per
55-gallon drum, and to landfill a 55-gallon drum of inorganic solids could
cost between $75 and $200. Disposal facilities may also have some associated
fees, surcharges, and other costs for minimum disposal, waste approval, State
and local taxes, and stabilization.
87
-------
APPENDIX C
TECHNOLOGY-SPECIFIC CHARACTERIZATION PARAMETERS
The tables in Appendix C contain waste feed characterization parameters
specific to biological, physical/chemical, immobilization, thermal, and in
situ treatment technologies. These are generally the critical waste parame-
ters that must be established before a treatability test is conducted on the
corresponding technology. These parameters should be evaluated on a site-
specific basis.
Each table is divided by technology, waste matrix, parameter, and pur-
pose of analysis. These tables are designed to assist the RPM in planning a
treatability study.
-------
TABLE 17. CHARACTERIZATION PARAMETERS FOR BIOLOGICAL TREATMENT
Treatment
technology
Matrix
Parameter
Purpose and comments
General
Soils/sludges
00
Liquids
Physical:
Moisture content
Field capacity
pH
Temperature
Oxygen availability
Chemical:
Total organic carbon (TOC)
Redox potential
Carbon:nitrogen:phosphorus ratio
Biological:
Soil blometer tests
Electrolytic resplrometer tests
Culture studies
Bacterial enumeration tests (e.g.,
spread-plate techniques)
M1crob1al toxldty/growth Inhibi-
tion tests
Chemical:
pH
Dissolved oxygen (DO)
Chemical oxygen demand (COD)
Biological:
Biological oxygen demand (BOD)
Culture studies
Mlcroblal toxldty/growth Inhibi-
tion tests
To determine the treatablllty of the material and the treatment process of
choice.
To determine the treatabillty of the material and the treatment process of
choice.
To determine mineral nutrient requirements.
To determine blodegradatlon potentials and to quantify biodegradation rates of
contaminants.
This 1s an enrichment procedure used to measure oxygen uptake and blodegradatlon.
To determine the Indigenous microflora or specifically adapted microflora to be
used in the Inoculum during the enrichment procedure.
To determine the bacterial population density in the inoculum.
To determine biological activity 1n the laboratory.
To determine the treatabillty of the material and the treatment process of
choice.
To determine the treatabillty of the material and the treatment process of
choice.
To determine the Indigenous microflora.
To determine biological activity in the laboratory.
-------
TABLE 18. CHARACTERIZATION PARAMETERS FOR PHYSICAL/CHEMICAL TREATMENT
Treatment
technology
Matrix
Parameter
Purpose and comments
General
Extraction
- Aqueous
- Solvent
- Critical
fluid
- Air/steam
Soils/sludges
Soils/sludges
Chemical dehalo- Soils/sludges
genation
Liquids
Physical:
Type, size of debris
Dioxins/furans, radionuclides, asbestos
Physical:
Particle-size distribution
Clay content
Moisture content
Chemical:
Organlcs
Metals (total)
Metals (teachable)
Contaminant characteristics:
0 Vapor pressure
0 Solubility
0 Henry's Law constant
0 Partition coefficient
0 Boiling point
0 Specific gravity
Total organic carbon (TOC), humic add
Cation exchange capacity (CEC)
PH
Cyanides, sulfides, fluorides
Physical:
Moisture content
Chemical:
Aromatic ha 1 ides
Metals
PH
Chemical:
Aromatic ha1 ides
To determine need for pretreatment.
To determine special waste-handling procedures.
To determine volume reduction potential, pretreatment needs, solid/liquid
separability.
To determine adsorption characteristics of soil.
To determine conductivity of air through soil.
To determine concentration of target or Interfering constituents, pre-
treatment needs, extraction medium.
To determine concentration of target or interfering constituents, pre-
treatment needs, extraction medium.
To determine mobility of target constituents, posttreatment needs.
To aid in selection of extraction medium.
To determine presence of organic matter, adsorption characteristics of soil.
To determine adsorption characteristics of soil.
To determine pretreatment needs, extraction medium.
To determine potential for generating toxic fumes at low pH.
To determine reagent requirements.
To determine concentration of target constituents, reagent requirements.
To determine concentration of other alkaline-reactive constituents, reagent
requirements.
To determine reagent requirements.
To determine concentration of target constituents, reagent requirements-
(continued)
-------
TABLE 18 (continued)
Treatment
technology
Matrix
Parameter
Purpose and comments
Oxidation/
reduction
Soils/sludges
Flocculatlon/
sedimentation
Liquids
Carbon adsorp-
tlon
Liquids
Ion exchange
Gases
Liquids
Physical:
Total suspended solids
Chemical:
Chemical oxygen demand (COD)
Metals (Cr+3, Hg. Pb, Ag)
PH
Physical:
Total suspended solids
Specific gravity of suspended solids
Viscosity of liquid
Chemical:
PH
Oil and grease
Physical:
Total suspended solids
Chemical:
Organics
Oil 'and grease
Biological:
Microbial plate count
Physical:
Part'tcillates
Chemical:
Volatile organic compounds (VOCs).
sulfur compounds, mercury
Physical:
Total dissolved solids
Total suspended solids
Chemical:
Inorganic cations and anions, phenols
Oil and grease
To determine the need for slurrying to aid mixing.
To determine the presence of oxidizable organic matter, reagent require-
ments.
To determine the presence of constituents that could be oxidized to more
toxic or mobile forms.
To determine potential chemical interferences.
To determine reagent requirements.
To determine settling velocity of suspended solids.
To determine settling velocity of suspended solids.
To aid in selection of flocculating agent.
To determine need for demulslfying agents, oil/water separation.
To determine need for pretreatment to prevent clogging.
To determine concentration of target constituents, carbon loading rate.
To determine need for pretreatment to prevent clogging.
To determine potential for biodegradation of adsorbed organics and/or
problems due to clogging or odor generation.
To determine need for pretreatment to prevent clogging.
To determine concentration of target constituents, carbon loading rate.
To determine exhaustion rate of Ion exchange resin.
To determine need for pretreatment to prevent clogging.
To determine concentration of target constituents.
To determine need for pretreatment to prevent clogging.
(continued)
-------
TABLE 18 (continued)
ro
Treatment
technology Matrix
Reverse osmosis Liquids
Liquid/liquid Liquids
extraction
Oil/water Liquids
separation
Air/steam Liquids
stripping
Parameter
Physical :
Total suspended solids
Chemical :
Metal Ions, organics
PH
Residual chlorine
Biological:
Mlcroblal plate count
Physical:
Solubility, specific gravity
Chemical:
Contaminant characteristics:
° Solubility
0 Partition coefficient
0 Boiling point
Physical:
Viscosity
Specific gravity
Settleable solids
Temperature
Chemical:
Oil and grease
Organics
Chemical':
Hardness
VOCs
Contaminant characteristics:
Purpose and comments
To determine need for pretreatment to prevent plugging of membrane.
To determine concentration of target constituents.
To evaluate chemical resistance of membrane.
To evaluate chemical resistance of membrane.
To determine potential for biological growth inside membrane that would
cause plugging.
To determine misdblHty of solvent and liquid waste.
To aid In selection of solvent.
To determine separability of phases.
To determine separability of phases.
To determine amount of residual solids.
To determine rise rate of oil globules.
To determine concentration of target constituents.
To determine need for posttreatment.
To determine potential for scale formation.
To determine concentration of target constituents.
To determine strippablllty of contaminants.
Filtration
(continued)
Liquids
0 Solubility
° Vapor pressure
0 Henry's Law constant
° Boiling point
Physical:
Total suspended solids
Total dissolved solids
To determine need for pretreatment to prevent clogging.
To determine need for posttreatment.
-------
TABLE 18 (continued)
V£>
co
Treatment
technology
Matrix
Parameter
Dissolved air
flotation
Liquids
Neutralization Liquids
Precipitation Liquids
Oxidation Liquids
(alkaline
chlorlnatlon)
Physical:
Total suspended solIds
Specific gravity
Chemical:
Oil and grease
VOCs
Chemical:
pH
Acidity/alkalinity
Cyanides, sulfldes, fluorides
Chemical:
Metals
PH
OrganIcs, cyanides
Chemical:
Cyanides
pH
Organ!cs
Reduction Liquids
Hydrolysis Liquids
Redox potential
Chemical: ,
Metals (Cr , Hg, Pb)
Chemical':
Organics
PH
Purpose and connents
To determine amount of residual sludge.
To determine separability of phases.
To determine concentration of target constituents.
To determine need for air emission controls.
To determine reagent requirements.
To determine reagent requirements.
To determine potential for generating toxic fumes at low pH.
To determine concentration of target constituents, reagent requirements.
To determine solubility of metal precipitates, reagent requirements.
To determine concentration of interfering constituents, reagent requirements.
To determine concentration of target constituents, reagent requirements.
To determine suitable reaction conditions.
To determine potential for forming hazardous compounds with excess chlorine
(oxidizing agent).
To determine reaction success.
To determine concentration of target constituents, reagent requirements.
To determine concentration of target constituents, reagent requirements.
To determine reagent requirements.
-------
TABLE 19. CHARACTERIZATION PARAMETERS FOR IMMOBILIZATION
Treatment
technology
Matrix
Parameter
Purpose and comments
Stabilization/
solidification
Soils/sludges
Vitrification Soils/sludges
Physical:
Description of materials
Particle size analysis
Moisture content
Density testing
Strength testing
0 Unconfined compressive strength
0 Flexural strength
0 Cone index
Durability testing
Chemical:
PH
Alkalinity
Interfering compounds
Indicator compounds
Leach testing
Heat of hydration
Physical:
Depth of contamination and water table
Soil permeability
Metal content of waste material and
placement of metals within the waste
Combustible liquid/solid content of waste
Rubble content of waste
Void volumes
To determine waste handling methods (e.g., crusher, shredder, removal equip-
ment).
To determine surface area available for binder contact and leaching.
To determine amount of water to add/remove in S/S mixing process.
To evaluate changes in density between untreated and treated waste.
To evaluate changes in response to overburden stress between untreated and
treated waste (e.g., material response to stress from cap).
To evaluate material's ability to withstand loads over large area.
To evaluate material's stability and bearing capacity.
To evaluate durability of treated wastes (freeze-thaw and wet-dry durabil-
ity).
To evaluate changes in leaching as function of pH.
To evaluate changes in leaching as function of alkalinity.
To evaluate viability of S/S process. (Interfering compounds are those that
impede fixation reactions, cause adverse chemical reactions, generate
excessive heat; interfering compounds vary with type of S/S.)
To evaluate performance of S/S (i.e., leaching).
To evaluate performance of S/S.
To measure temperature changes during mixing.
Technology is applied in unsaturated soils.
Dewatering of saturated soils may be possible. Technology is applied in
unsaturated soils.
Greater than 5 to 15* by weight or significant amounts of metal near elec-
trodes interfere with process.
Greater than 5 to IBS by weight interferes with process.
Greater than 10 to 20* by weight interferes with process.
Large, individual voids (greater than 150 ft3) Impede process.
-------
TABLE 20. CHARACTERIZATION PARAMETERS FOR THERMAL TREATMENT
Treatment
technology
Matrix
Parameter
Purpose and comments
General
Soils/sludges
<£>
in
Liquids
Physical:
Moisture content
Ash content
Ash fusion temperature
Chemical:
Volatile organics, semivolatile organics
POHCs
Total chlorine, fluorine
Total sulfur, total nitrogen
Phosphorus
Polychlorinated biphenyls (PCBs),
dioxlns (if suspected)
Metals
Physical:
Viscosity
Total solids content
Particle-size distribution of solid phases
Heat value
Chemical:
Volatile organics, semivolatile organics
POHCs
Total chlorine, fluorine
Total sulfur, total nitrogen
Phosphorus
PCBs, dloxins (If suspected)
Affects heating value and material handling.
To determine the amount of ash that must be disposed or treated further.
High temperature can cause slagging problems with Inorganic salts having
low melting points.
Allows determination of principal organic hazardous constituents (POHCs).
Allows determination of destruction removal efficiency (ORE).
To determine air pollution control devices for control of add gases.
Emissions of SO and NO are regulated; to determine air pollution devices.
Organic phosphorus compounds may contribute to refractory attack and
slagging problems.
99.9999* ORE required for PCBs; safety considerations; Incineration is
required If greater than 500 ppm PCBs present.*•
Volatile metals (Hg, Pb, Cd, Zn, Ag, Sn) may require flue-gas treatment;
other metals may concentrate in ash. Trivalent chromium may be oxidized to
hexavalent chromium, which is more toxic. Presence of Inorganic alkali
salts, especially potassium and sodium sulfate, can cause slagging.
Waste must be pumpable and atomizable.
Affects pumpability and heat transfer.
Affects pumpability and heat transfer.
Determine auxiliary fuel requirements.
Allows determination of POHCs.
Allows determination of DREs.
To determine air pollution control devices for control of acid gases. Chlo-
rine could contribute to formation of dioxlns.
Emissions of SOX and NOX are regulated; to determine air pollution devices.
Organic phosphorus compounds may contribute to refractory attack and
slagging problems.
99.9999* ORE required for PCBs; safety considerations; Incineration Is
required if greater than 500 ppm PCBs present."*
(continued)
-------
TABLE 20 (continued)
Treatment
technology
Matrix
Parameter
Purpose and comments
Rotary kiln Soils/sludges
Debris
Flu1d1zed-bed Soils/sludges
Metals
Physical:
Particle-size distribution
Physical:
Amount, description of materials
Presence of spherical or cylindrical
wastes
Physical:
Ash fusion temperature
Ash content
Bulk density
to
Volatile metals (Hg, Pb, Cd, Zn, Ag, Sn) may require flue-gas treatment;
other metals may concentrate in ash. Trlvalent chromium may be oxidized to
hexavalent chromium, which Is more toxic. Presence of Inorganic alkali
salts, especially potassium and sodium sulfate, can cause slagging.
Fine particle size results in high particulate loading in rotary kiln.
Large particle size may present feeding problems.
Oversized debris presents handling problems and kiln refractory loss.
Spherical or cylindrical waste can roll through kiln before combusting.
For materials with a melting point less than 1600°F, particles melt and
become sticky at high temperatures, which causes defluidization of the bed.
Ash contents greater than 65% can foul the bed.
As density increases, particle size must be decreased for sufficient heat
transfer.
-------
TABLE 21. CHARACTERIZATION PARAMETERS FOR IN SITU TREATMENT
Treatment
technology
Matrix
Parameter
Purpose and comments
vo
Vapor extrac- Soils/sludges
tlon
- Vacuum
extraction
- Steam-enhanced
- Hot-air-
enhanced
Solidification/ Soils/sludges
stabilization
(undisturbed)
- Pozzolanic
- Polymerization
- Precipitation
Soil flushing
- Steam/hot
water
- Surfactant
- Solvent
Soils/sludges
Vitrification Soils/sludges
Radio-frequency Soils/sludges
heating and
direct-current
heating
Electrokinetics Soils/sludges
Physical:
Vapor pressure of contaminants
Soil permeability, porosity, particle-
size distribution
To estimate ease of volatilization.
To determine if the soil matrix will allow adequate air and fluid movement.
Depth of contamination and to water table To determine relative distance; technology applicable in vadose zone.
Physical:
Presence of subsurface barriers (e.g.,
drums, large objects, debris, geologic
formations
Depth to first confining layer
Physical:
Presence of subsurface barriers (e.g.,
drums, large objects, debris, geologic
formations)
Hydraulic conductivity
Moisture content (for vadose zone)
Soil/water partition coefficient
Octanol/water partition coeffcient
QEC
Alkalinity of soil
Chemical:
Major cation/anions present in soil
Physical:
Depth of contamination and water table
Physical:
Depth of contamination and water table
Presence of metal objects
Physical:
Hydraulic conductivity
Depth to water table
Chemical:
Presence of soluble metal contaminants
To assess the feasibility of adequately delivering and mixing the S/S
agents.
To determine required depth of treatment.
To assess the feasibility of adequately delivering the flushing solution.
To assess permeability of the soils.
To calculate pore volume to determine rate of treatment.
To assess removal efficiency and to correlate between field and theoretical
calculations.
To assess removal efficiency and to correlate between field and theoretical
calculations.
To evaluate potential for contaminant flushing.
To estimate the likelihood of precipitation.
To estimate the likelihood of precipitation; to estimate potential for plug-
ging of pore volumes.
Technology is only applied in the unsaturated zone.
Technology is only applied in the unsaturated zone.
Presence of metal objects precludes application.
Technology applicable in zones of low hydraulic conductivity.
Technology applicable in saturated soils.
Technology applicable to soluble metals, but not organics and Insoluble
metals.
(continued)
-------
TABLE 21 (continued)
Treatment
technology
Matrix
Parameter
Purpose and comments
Microbial
degradation
- Aerobic
- Anaerobic
Adsorption
(trench)
Soils/sludges Physical:
Permeability of soil
Chemical/biological:
Contaminant concentration and toxicity
Soils/sludges Chemical/biological:
Contaminant concentration and toxicity
Soils/sludges Physical:
Depth of contamination and water table
Horizontal hydraulic flow rate
To determine ability to deliver nutrients or oxygen to matrix and to allow
movement of microbes.
To determine viability of microbial population 1n the contaminated zone.
To determine viability of microbial population In the contaminated zone.
Technology applicable in saturated zone.
To determine If ground water will come Into contact with adsorbent.
CO
-------
APPENDIX D
STANDARD ANALYTICAL METHODS FOR CHARACTERIZING WASTES
The tables in Appendix D contain the analytical methods necessary for
evaluation of the physical and chemical waste feed characteristics identified
in Appendix C. The waste matrices are divided into soils/sludges, liquids,
and gases. The methods listed are standard EPA-approved procedures, when
such exist. A description of each test and a reference for its method are
also included.
99
-------
TABLE 22. SOILS/SLUDGES: CHARACTERIZATION OF PHYSICAL PROPERTIES
Physical parameter
Description of test
Method
Reference*
Ash content
Ash fusibility
Atterberg limits
Bulk density
Cation exchange
capacity (CEC)
Clay content
Corrosivity
Durability
Free liquids
Gross calorific
value
Ignitability
Moisture content
Oxidation/reduc-
tion potential (E.)
of leachate n
Particle size
distribution
(continued)
Electric muffle furnace
Combustion furnace, pyrom-
eter
Liquid limit, plastic
limit, plasticity index
Drive cylinder method
Sand-cone method
Nuclear method
Rubber ballon method
Hydraulic cement stabilized
waste
Ammonium acetate
Sodium acetate
X-ray diffraction
Corrosivity toward steel
Freeze-thaw
Wet-dry
Paint filter test
Bomb calorimeter
Adiabatic bomb calorimeter
Isothermal bomb calorimeter
Pensky-Martens closed-cup
SetaFlash closed-cup
Drying oven at 110°C
In situ, nuclear method
Electrometric
ASTM D 3174 (coal)
ASTM E 830 (RDF-3)
ASTM E 953 (RDF-3)
ASTM D 4318
Hydrometer and sieve
a
a
ASTM D 2937
ASTM D 1556
ASTM D 2922
ASTM D 2167
ASTM C 188
(cement)
Method 9080
Method 9081
Not standard
Method 1110
ASTM D 560
ASTM D 559
a
a
a
a
a
b
b
c
b
a
a
Method 9095 b
ASTM E 711 (RDF-3) a
ASTM D 2015 a
ASTM D 3286 (coal) a
Method 1010 b
Method 1020 b
ASTM D 2216 a
ASTM D 3017 a
ASTM D 1498 a
ASTM D 422
100
-------
TABLE 22 (continued)
Physical parameter
Permeability
Description of test
Falling head
Constant head
Method
Method 9100
Method 9100
Reference*
b
b
Pore volume
Reactivity
Soil classifica-
tion/profile
Sorptive capacity
Specific gravity
Temperature
Toxicity
Unconfined com-
pressive strength
Mercury intrusion
porosimetry
To determine hydrogen
cyanide released
To determine hydrogen
sulfide released
SCS-Engineering purposes
SCS-Visual/manual procedure
24-h batch-type distribu-
tion ratio
Pycnometer
Ambient, thermometer
Extraction procedure (EP)
toxicity test method
Toxicity characteristic
leaching procedure (TCLP)
ASTM D 4404
Section 7.3.3.2
Section 7.3.4.1
ASTM D 2487
ASTM D 2488
ASTM ES10
ASTM D 854
Method 1310
Method 13XX
ASTM D 2166
b
b
a
a
b
d
All references for Appendix D tables appear at the end of Table 27,
101
-------
TABLE 23. SOILS/SLUDGES: CHARACTERIZATION OF CHEMICAL PROPERTIES
Chemical parameter Description of test
Method
Reference*
Aromatic volatile
organics
Base, neutral, and
acid compounds
(BNA)
Chemical oxygen
demand (COD) of
leachate
Chlorinated
hydrocarbons
Chlorine/chloride
Cyanide
Dioxins/furans
Fluorides
Halogenated vola-
tile organics
Humic acid
Major and minor
oxides
Metals
Nonhalogenated
volatile organics
(continued)
Gas chromatography
Gas chromatography/mass
spectrometry
Titrimetric
Colorimetric
Gas chromatography
Potentiometric titration
Volhard titration
Total and amenable, colori-
metric
Gas chromatography/mass
spectrometry
Bomb combustion/ion
selective electrode
Gas chromatography
Titrimetric
Atomic absorption spectro-
photometry
Absorption spectropho-
tometry
X-ray fluorescence
ICP atomic emission spec-
troscopy
Atomic absorption
Gas chromatography
Method 8020
Method 8270
Method 410.1-.3
Method 410.4
Method 8120
e
e
ASTM E 776A
(RDF-3)
ASTM E 776B
(RDF-3)
Method 9010
Method 8280
a
a
b
b
ASTM D 3761 a
Method 8010 b
Not standard f
ASTM D 3682 (coal) a
ASTM D 2795 (coal) a
ASTM D 4326 (coal) a
Method 6010 b
Method 7000 series b
Method 8015 b
102
-------
TABLE 23 (continued)
Chemical parameter
Oil and grease
Organochlorine
pesticides/PCBs
pH
Phenols
Polynuclear aro-
matic hydrocarbons
(PAHs)
Radionuclides
Sulfides
Sulfur content
Total Kjeldahl
nitrogen
Total organic
carbon (TOC)
Total organic
halides (TOX)
Volatile organics
Description of test
Oil and grease extraction
method for sludge samples
Gas chromatography
Soil pH
Gas chromatography
Gas chromatography
High-performance liquid
chromatography
Alpha-emitting radium iso-
topes
Gross alpha and gross beta
Radium-226
Radium-228
Titrimetric
High-temperature combustion
Eschka method
Bomb washing
Kjeldahl
Kjeldahl-Gunning
Acid titration
Combustion
Oxidation/titration
Neutron activation analysis
Gas chromatography/mass
spectrometry
Method Reference*
Method 9071
Method 8080
Method 9045
Method 8040
Method 8100
Method 8310
Method 9315
Method 9310
ASTM D 3454
Method 9320
Method 9030
ASTM D 4239 (coal)
ASTM D 3177A (coal)
ASTM E 775A (RDF-3)
ASTM D 3177B (coal)
ASTM E 775B (RDF-3)
ASTM D 3179 (coal)
ASTM E 778 (RDF-3)
ASTM E 778 (RDF-3)
Method 9060
Method 9020
Method 9022
Method 8240
b
b
b
b
b
b
b
b
a
b
b
a
a
a
a
a
a
a
a
b
b
b
b
References for all Appendix D tables appear at the end of Table 27.
103
-------
TABLE 24. LIQUIDS: CHARACTERIZATION OF PHYSICAL PROPERTIES
Physical parameter
Color
Conductance
Corrosivity
Flammability
limits
Hardness, total
Heat value
Ignitability
Odor
Oxidation/reduc-
tion potential (E. )
Reactivity
Solids
Specific gravity
of liquid phases
Description of test
Colorimetric, ADMI
Colorimetric, Pt-Co
Spectrophotometri c
Specific
Corrosivity toward steel
Upper and lower
Colorimetric, EDTA
Titrimetric, EDTA
Bomb calorimeter
Pensky-Martens closed-cup
SetaFlash closed-cup
Threshold odor (consistent
series)
Electrometric
To determine hydrogen
cyanide
To determine hydrogen
sulfide
Filterable, gravimetric
Nonfilterable, gravimetric
Total , gravimetric
Volatile gravimetric
Settleable matter
Hydrometer
Pycnometer
Method
Method 110.1
Method 110.2
Method 110.3
Method 120.1
Method 1110
ASTM E 918
Method 130.1
Method 130.2
ASTM E 711
Method 1010
Method 1020
Method 140.1
ASTM D 1498
Section 7.3.3.2
Section 7.3.4.1
Method 160.1
Method 160.2
Method 160.3
Method 160.4
Method 160.5
ASTM D 891 A
ASTM D 891B
Reference*
e
e
e
e
b
a
e
e
a
b
b
e
a
b
b
e
e
e
e
e
a
a
Specific gravity
of solid phases
Temperature
(continued)
Pycnometer
Thermometric
ASTM D 854
Method 170.1
104
-------
TABLE 24 (continued)
Physical parameter
Toxicity
Turbidity
Viscosity
Description of test
Extraction procedure (EP)
toxicity test method
Toxicity characteristic
leaching procedure (TCLP)
Nepholometric
Kinematic viscosity of vol-
atile and reactive liquids
Kinematic viscosity of
transparent and opaque
liquids
Method
Method 1310
Method 13XX
Method 180.1
ASTM D 4486
ASTM D 445
Reference*
b
d
e
a
a
*
References for all Appendix D tables appear at the end of Table 27.
105
-------
TABLE 25. LIQUIDS: CHARACTERIZATION OF CHEMICAL PROPERTIES
Chemical parameter
Acidity
Alkalinity
Aromatic volatile
organics
Base, neutral , and
acid (BNA)
compounds
Chemical oxygen
demand (COD)
Chlorinated
hydrocarbons
Cyanide, total and
amenable
Dioxins/furans
Hal ides
Hardness, total
Halogenated vola-
tile organics
Metals
Nitrogen
Description of test
Titrimetric
Titrimetric
Gas chromatography
Gas chromatography/mass
spectrometry
Titrimetric
Colorimetric
Gas chromatography
Colorimetric, manual
Colorimetric, automated UV
Gas chromatography/mass
spectrometry
Bromide; titrimetric
Chloride; colorimetric, AA
titrimetric
Fluoride; colorimetric,
potentiometric,
colorimetric
Iodide; titrimetric
Colorimetric, EDTA
Titrimetric, EDTA
Gas chromatography
ICP atomic emission spec-
troscopy
Atomic absorption
Ammonia
Kjeldahl, total
Nitrate
Nitrate-nitrite
Nitrite
Method
Method 305.1
Method 310.1
Method 8020
Method 8270
Methods 410. 1-. 3
Method 410.4
Method 8120
Method 9010
Method 9012
Method 8280
Method 320.1
Methods 325.1, .2
Method 325.3
Method 340.1
Method 340.2
Method 340.3
Method 345.1
Method 130.1
Method 130.2
Method 8010
Reference*
e
e
b
b
e
e
b
b
b
b
e
e
e
e
e
e
e
e
e
b
Method 6010 b
Method 7000 series b
Methods 350.1 -.3
Methods 351. 1-. 4
Method 352.1
Methods 353. 1-. 3
Method 354.1
e
e
e
e
e
(continued)
106
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TABLE 25 (continued)
Chemical parameter
Nonhalogenated
volatile organics
Oil and grease,
Organochlorine
pesticides/PCBs
PH
Phenol ics
Phosphorus
Polynuclear aro-
matic hydrocarbons
(PAHs)
Radionuclides
Sulfate
Sulfides
Total organic
carbon (TOC)
Total organic
halides (TOX)
Total petroleum
hydrocarbons
Volatile organics
Description of test
Gas chromatography
Total recoverable, gravi-
metric with extraction
Gas chromatography
Electrometric
Spectrophotometr i c
Colorimetric
Spectrophotometric, MBTH
All forms; colorimetric
Total; colorimetric
Gas chromatography
High-performance liquid
chromatography
Alpha-emitting radium
isotopes
Gross alpha and gross beta
Radium-226
Radium-228
Colorimetric, chloranilate
Colorimetric, methyl thymol
blue
Turbidimetric
Titrimetric
Flame ionization
Oxidation/titration
Neutron activation
IR spectrophotometric
Gas chromatography/mass
spectrometry
Method
Method 8015
Method 9070
Method 8080
Method 9040
Method 9065
Method 9066
Method 9067
Methods 365. 1-. 3
Method 365.4
Method 8100
Method 8310
Method 9315
Method 9310
ASTM D 3454
Method 9320
Method 9035
Method 9036
Method 9038
Method 9030
Method 9060
Method 9020
Method 9022
Method 418.1
Method 8240
Reference*
b
b
b
b
b
b
b
e
e
b
b
b
b
a
b
b
b
b
b
b
b
b
e
b
All references for Appendix D tables appear at the end of Table 27.
107
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TABLE 26. GASES/VAPORS: CHARACTERIZATION OF PHYSICAL PROPERTIES
Physical parameter
Description of test
Method
Reference*
Flammability
Moisture content
Opacity
Participate
Upper, lower limits ASTrl L
Volumetric, gravimetric Method 4
Visual determination of Me^hud 9
opacity
Front half Method 5
Filterable and condensible Method b
back half
instack with thimble and Method 17
filter
a
9
g
g
g
All reverences for Appendix u tdoles appear at the end of Table 27.
108
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TABLE 27. GASES/VAPORS: CHARACTERIZATION OF CHEMICAL PROPERTIES
Chemical parameter
Acid mist (H,,SO. ,
so2) i 4
Aldehydes
Ammonia
Arsenic
Asbestos
Beryllium
Carbon monoxide
Chlorine
Fluoride
Hexane
Hydrocarbons
Hydrogen sulfide
(H2S)
Lead
Mercury
Metals
Nitrogen oxides
(HOJ
Description of test
Barium-thorin titration
High performance liquid
chromatography
Titration/Nesslerization
Atomic absorption
TEM
Atomic absorption
Gas chromatography/f lame
ionization detection
Ion chromatography
Specific ion electrode
Gas chromatography/mass
spectrometry--
Tenax, VOST
Canister
Gas chromatography/mass
spectrometry —
Tenax VOST
Canister
lodometric titration
Atomic absorption
Atomic absorption
ICP atomic emission
spectroscopy
Colorimetric
Ion chromatography
Method
Method 8
T05
Method 350.2
Method 108
7402
Method 104
Method 10
Method 300.0
Method 13B
Method 5040
T014
Method 5040
T014
Method 11
Method 12
Method 101
Method 6010
Method 7
Method 7A
Reference
9
h
e
i
0
i
g
e
g
b
h
b
h
g
g
1
b
g
g
Oxygen, carbon
dioxide, carbon
monoxide (0,,, C00,
CO) Z Z
Orsat analyzer
Method 3
(continued)
109
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TABLE 27 (continued)
Chemical parameter
Pesticides/PCBs
Phenols
Polynuclear aro-
matic hydrocarbons
Semi volatile
organics
Sulfides (H9S,
cos, cs2) <•
Sulfur content,
total
Sulfur dioxide
(so2)
Toluene
Vinyl chloride
Volatile organics
Xylene, toluene
Description of test
Gas chromatography/elec-
tron-capture detection
High-performance liquid
chroma tography
Gas chromatography/mass
spectrometry
Gas chromatography/mass
spectrometry
Gas chromatography/flame
photometry
Hydrogenolysis and rateo-
metric colorimetry
Barium-thorin titration
Gas chromatography/mass
spectrometry--
Tenax, VOST
Canister
Gas chromatography/mass
spectrometry —
Canister
Gas chromatography/mass
spectrometry —
Tenax, VOST
Canister
Gas chromatography/mass
spectrometry —
Tenax, VOST
Canister
Method
T04
T08
T013
Method 8270
Method 15
ASTM D 4468
Method 6
Method 5040
T014
TOW
Method 5040
TO 14
Method 5040
TO 14
Reference
h
h
h
b
9
a
g
b
h
h
b
h
b
h
a American Society for Testing and Materials. Annual Book of ASTM Standards.
November 1987.
U.S. Environmental Protection Agency. Test Methods for Evaluating Solid
Waste. Third Edition. SW-846, 1986.
c Leimer, H. W., G. M. Mason, and L. K. Spackman. Mineralogic Characteriza-
tion of a Chattanooga Shale Core From Central Tennessee. November 1984.
110
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TABLE 27 (continued)
d
40 CFR 268; Appendix I; 51 FR 40636, November 7, 1986.
U.S. Environmental Protection Agency. Methods for tl
of Water and Wastes. EPA-600/4-79-020. March 1983.
e U.S. Environmental Protection Agency. Methods for the Chemical Analysis
American Society of Agronomy, Inc. Methods of Soil Analysis, Part 2,
Chemical and Microbiological Properties. 2nd Edition. 1982.
9 40 CFR 60; Appendix A, July 1988.
U.S. Environmental Protection Agency. Compendium of Methods for the
Determination of Toxic Organic Compounds in Ambient Air. EPA-600/4-84-
041. April 1984.
1 40 CFR 61; Appendix B, July 1986.
J NIOSH manual of Analytical Methods, 3rd ed. February 1984.
Ill
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GLOSSARY
This glossary defines terms used in this guide. The definitions apply
specifically to the treatability study process and may have other meanings
when used in different contexts. Underlined words or concepts within a
definition are defined elsewhere in the glossary.
aerobes—Microorganisms that cannot grow or survive in the absence of oxygen.
alternative—A potentially applicable remedial treatment technology or treat-
ment train. Alternatives are developed and screened during scoping of
the RI/FS~and throughout the RI/FS process. Alternatives are investi-
gated by performing treatability studies and selected as remedies after
a detailed analysis of each alternative is conducted.
anaerobes—Microorganisms that cannot survive or are inhibited in the pres-
ence of oxygen.
applicable or relevant and appropriate requirement (ARAR)—Federal or State
requirements that are legally applicable to remedial actions at CERCLA
sites or, if not legally applicable, the use of which is both relevant
and appropriate under the circumstances. ARARs may be chemical-, loca-
tion-, or action-specific.
aquifer—A porous, underground rock formation, often composed of limestone,
sand, or gravel, that is bounded by impervious rock or clay and can
store water.
bench-scale testing—A treatability study designed to provide quantitative
information for the evaluation of a technology's performance for an
operable unit. A bench-scale study serves to verify that the technology
can meet the anticipated ROD cleanup goals and provides information in
support of remedy evaluation.
biological treatment—A treatment process that uses microorganisms to break
down toxic organic waste contaminants into simple less-toxic compounds.
biotoxicity—Toxic to flora and fauna.
chemical treatment—A treatment process that alters the chemical structure of
a toxic waste contaminant to reduce the waste's toxicity, mobility, or
volume.
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA)—A Federal law passed in 1980 and amended in 1986 by the Super-
fund Amendments and Reauthorization Act (SARA), which created a special
tax on crude oil and commercial chemicals that supports the Hazardous
Substance Response Trust Fund or "Superfund." The EPA can use the money
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in Superfund to investigate and clean up abandoned or uncontrolled haz-
ardous waste sites. Under CERCLA, the EPA can either pay for the site
cleanup itself or take legal action to force the parties responsible for
the contamination to pay for the cleanup.
containment—Response actions that involve construction of a barrier to
prevent the migration of contaminated wastes.
Contract Laboratory Program (CLP)--Laboratories contracted by EPA to analyze
CERCLA site waste samples by established CLP protocols and procedures.
corrosivity—One of the four hazardous waste characteristics defined under
RCRA (40 CFR 261.22). A waste is corrosive if it or its leachate has a
pH less than or equal to 2 or greater than or equal to 12.5 or corrodes
steel (SAE 1020) at a rate greater than 6.35 mm per year at 55°C.
data quality objectives (DQOs)--The sum of characteristics of a data set that
describe its utility for satisfying a given purpose. Characteristics
may be precision, accuracy, completeness, representativeness, and compa-
rability, but they may also include experimental design and statistical
confidence issues. The objectives for data quality, DQOs are estab-
lished before the study is conducted.
debris—Naturally occurring materials of geologic origin (such as tree stumps
and vegetation) or man-made materials (such as concrete blocks, cloth,
empty drums, and tires) that, because of their size, shape, or composi-
tion, present nonstandard, unique treatability problems at CERCLA sites.
detailed analysis of alternatives—A comparative analysis of all remedial
alternatives that have successfully completed the technology screening
phase.Each alternative is assessed against EPA's nine evaluation
criteria before final remedy selections are made.
development and screening of alternatives—The identification and screening
of potentially applicable treatment technologies for remedy selection.
effluent—Treated liquid waste or wastewaters exiting a treatment unit.
exclusion zone—Area of site possessing the highest concentration of contami-
nants, also called the "hot" zone.
extraction procedure (EP) toxicity—One of the four hazardous waste charac-
teristics defined under RCRA (40 CFR 261.24). A waste is EP toxic if an
extract from the waste is found to contain concentrations of certain
metals and pesticides in excess of those listed in RCRA.
feasibility study (FS)--The analytical part of the RI/FS process, the FS
serves as the mechanism for the development, screening, and detailed
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evaluation of potentially applicable treatment technologies. The suc-
cess of the FS is highly dependent on the data generated in the RI_.
flammability--The capacity to support combustion.
gas—A fluid substance possessing neither definite shape nor volume at stan-
dard temperature and pressure (STP). (Oxygen and nitrogen are gases at
STP.)
Hazardous and Solid Waste Amendments (HSWA)—The 1984 amendments to the
Resource Conservation and Recovery Act (RCRA) of 1976. HSWA established
strict limits on the land disposal of hazardous waste.
hazardous substance—Any substance that poses a hazard to human health or the
environment when improperly managed.
hazardous waste—Any solid, liquid, or gaseous waste listed in 40 CFR Part
261 or that exhibits the characteristics of ignitability, corrgsiyity,
reactivity, or EP toxicity as defined under RCRA (see~40 CFR 261.3).
ignitability—One of the four hazardous waste characteristics defined under
RCRA (40 CFR 261.21). A waste is ignitable if it has any of the follow-
ing properties:
1) It is a liquid with a flash point of less than 60°C.
2) It is a nonliquid capable of causing a fire through friction,
absorption of moisture, or spontaneous chemical changes at standard
temperature and pressure (STP).
3) It is an ignitable compressed gas.
4) It is an oxidizer.
in situ treatment—The process of treating a contaminated matrix (soil,
sludge, or ground water) in place. In situ processes may use physical,
chemical, thermal, or biological technologies to treat the site.
influent—Untreated liquid waste or wastewater entering a treatment unit.
laboratory screening—A treatability study designed to establish the validity
of an alternative for treating an operable unit and to identify parame-
ters for investigation in later bench- and pilot-scale testing.
leachate—The liquid that results when water moves through solid waste mate-
rials and dissolves components of those materials.
lead agency—The Federal or State agency having primary responsibility and
authority for planning and executing remediation at a CERCLA site.
liquid—Pumpable material of naturally occurring or man-made origin
possessing a relatively fixed volume and a solids content of less than
10 percent.
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mobility—The ability of a contaminant to migrate from its source.
National Priorities List (NPL)--EPA's priority list of uncontrolled hazardous
waste sites identified for evaluation and possible remediation under
Superfund. The NPL, which is updated at least once a year, is based on
the score a site receives in the EPA's Hazard Ranking System. (See 40
CFR Part 300, Appendices A and B.)
nine evaluation criteria—A set of criteria developed by EPA that serve as
the basis for conducting detailed analyses of remedial alternatives
during the FS. The evaluation criteria implement statutory requirements
under CERCLA and other technical and policy considerations that EPA has
found to be important in the evaluation of remedial alternatives. These
nine evaluation criteria are as follows:
1) Overall protection of human health and the environment
2) Compliance with ARARs
3) Long-term effectiveness and permanence
4) Reduction of toxicity, mobility, or volume
5) Short-term effectiveness
6) Implementability
7) Cost
8) State acceptance
9) Community acceptance
On-Scene Coordinator (OSC)—The Federal official at a CERCLA site who is re-
sponsible for coordinating immediate, short-term removal actions that
address the release or threatened release of a hazardous substance.
operable unit—An individual remedial activity that constitutes one part of
an overall site cleanup.
performance goal—A predetermined level of effectiveness that a treatment
technology seeks to attain. Performance goals are set in terms of the
percentage reduction in toxicity, mobility, or volume of a waste and its
contaminants.
physical treatment—A treatment process that alters the physical structure of
a toxic waste contaminant to reduce the waste's toxicity, mobility, or
volume.
pilot-scale testing—A treatability study designed to provide the detailed
cost and design data required to optimize a treatment technology's per-
formance and to provide information in support of remedy implementation.
preliminary assessment—The process of collecting and reviewing initially
available information about a known or suspected hazardous waste site or
release.
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priority pollutants—Chemical compounds that, because of their persistence,
toxicity, and potential for exposure to organisms, have been listed as
"toxic pollutants" by the 1977 amendments to the Clean Water Act.
protocol—A plan for conducting a scientific experiment or study.
qualitative—An analysis in which some or all of the components of a sample
are identified.
quality assurance (QA)—Duplication of all or a portion of the analytical
tests conducted to ensure that the desired levels of accuracy and preci-
sion are obtained.
quality control (QC)—Duplication of a portion of the analytical tests per-
formed to estimate the overall quality of the results and to determine
what, if any, changes must be made to achieve or maintain the required
level of quality.
quantitative—An analysis in which the amount of one or more components of a
sample is determined.
reactivity—One of the four hazardous waste characteristics defined under
RCRA (40 CFR 261.23). A waste is reactive if it is unstable or under-
goes rapid or explosive chemical reactions when exposed to water, heat,
or extremes of pH.
Record of Decision (ROD)—A public document, signed by the lead agency and
any RPs, that explains which remedial alternative(s) will be used at a
particular CERCLA site. The ROD is based on data generated during the
site characterization and treatability study phases of the RI/FS and on
consideration given to public comments and State and community concerns.
remedial action (RA)—The actual construction or implementation phase that
follows the remedial design of the selected alternative at a CERCLA
site.
remedial design (RD)--The engineering phase that follows the signing of a ROD
when technical drawings and specifications for a site remedial action
are developed.
remedial investigation (RI)--The investigative part of the RI/FS process, the
RI serves as the mechanism for site and contaminant characterization and
for conducting treatability studies on the potentially applicable treat-
ment technologies identified in the feasibility study.
remedial investigation/feasibility study (RI/FS)—The Superfund program's
methodology for characterizing the nature and extent of risks posed by
CERCLA sites and for identifying and evaluating potential remedial al-
ternatives for those sites. The process is divided into two parts Tthe
remedial Investigation and the feasibility study), which are conducted
116
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concurrently; data collected in one part influence the tasks performed
in the other part and visa versa.
Remedial Project Manager (RPM)--The EPA or State official responsible for
overseeing remedial actions at a CERCLA site.
remedy selection—The remedial alternative(s) identified in the ROD for
CERCLA site cleanup.
residual--The product or byproduct of a treatment process.
Resource Conservation and Recovery Act (RCRA)--A 1976 Federal law that estab-
lished a regulatory system to track hazardous substances from the time
of generation to disposal. Designed to prevent new CERCLA sites from
ever being created, RCRA requires the use of safe and secure procedures
in the treatment, transport, storage, and disposal of hazardous wastes.
RCRA was amended in 1984 by the Hazardous and Solid Waste Amendments
(HSWA).
responsible party (RP)--A person(s) or company(ies) that the EPA has deter-
mined to be responsible for, or to have contributed to, the contamina-
tion at a site.
saturated zone—A subsurface zone in which water fills the interstices and is
under pressure greater than or equal to that of the atmosphere.
scoping—The initial phase of site remediation during which possible site
actions and investigative activities are identified.
site characterization—The collection and analysis of field data to determine
to what extent a site poses a threat to the environment and to begin
developing potential remedial alternatives.
site inspection—The collection of waste site data to determine the extent
and severity of hazards posed by the site. The data will be used to
score the site, using the EPA's Hazard Ranking System, and to determine
if it presents an immediate threat that requires prompt removal action.
sludge—Pumpable material of naturally occurring or man-made origin possess-
ing a relatively fixed volume and a moisture content ranging from 15 to
90 percent.
soil—Nonpumpable, naturally occurring material primarily of geologic origin
and possessing a fixed volume and a moisture content of less than 15
percent. Soil includes sand, silt, loam, and clay.
solidification—The process of converting a contaminated soil, sludge, or
liquid waste into a solid monolithic product that is more easily handled
and that reduces the volatilization and leaching of contaminants from
the waste.
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stabilization—The process of reducing the hazardous potential of a waste by
chemically or physically converting the toxic contaminants into their
least mobile or reactive form.
Superfund—The common name used for the Hazardous Substance Response Trust
Fund created by CERCLA.
Superfund Amendments and Reauthorization Act (SARA)--A 1986 Federal law that
amended the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) of 1980.
Superfund Innovative Technology Evaluation Program (SITE)—A 1986 program
established by the EPA's Office of Solid Waste and Emergency Response
(OSWER) and Office of Research and Development (ORD) to promote the
development and use of innovative treatment technologies during
CERCLA response actions.
technology screening—The process of collecting technical information on
potentially applicable treatment technologies and determining which
technologies to retain as alternatives for consideration in the FS.
thermal treatment—A treatment process that is designed to oxidize hazardous
organic substances to carbon dioxide and water.
tier—One of the three levels of treatability testing (i.e., laboratory
screening, bench-scale testing, or pilot-scale testing).
treatability study—The testing of a remedial alternative in the laboratory
or field to obtain data necessary for a detailed evaluation of its
feasibility.
treatability study sample exemption—A Federal regulation set forth in 40 CFR
261.4(f) that excludes treatability studies conducted offsite from roost
management and permitting requirements under RCRA.
treatment train—A complete treatment process that includes pre-treatment,
primary treatment, residuals and side-stream treatments, and post-
treatment considerations.
unit operation—One treatment technology that is a part of a larger treatment
train.
unsaturated zone—A subsurface zone containing water below atmospheric pres-
sure and gases at atmospheric pressure. Also known as the vadose zone.
vadose zone—A subsurface zone containing water below atmospheric pressure
and gases at atmospheric pressure. Also known as the unsaturated zone.
118
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