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.


                                      10

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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.
                                    11

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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.
                                      13

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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.
                                      16

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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.
                                      17

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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.)
                                       18

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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.

                                      22

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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.
                                      24

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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.]
                                     25

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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
                                                  29

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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.
                                      31

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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).
                                      32

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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.
                                      38

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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:
                                      43

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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).
                                      56

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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
              261 4(«)|.
•tidrbaoonducM
 onttoaoNk?
                                 mlojunity
                                 inoarMrw
                          •JbJMM to Wtefcn oltMtntnl
                                 4n^((la|r
                                  250kg?
lOOOkgotnowEMihaudiw
  IkgolaailthKVdoui
     \M aunty d
      rKkVMTxM
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        lngtic
       lOOOkc?
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      ki40CFR»t.4|e)andn(
       Salt nwMm) or otw ndudom
CoodrboM*/ anampt (torn RCRA
tr*atm*nt,   atoraga,   and

in 40 CFR Pant 2M. 265. and
270  provided  notification,
racordkatping, and raporting
raquirarnints ara mat [40 CFR
261.4 (f)].
CO
                                                         Yw
                                                                                          No
                                                                                                                         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.

                                      67

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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.)
                                      69

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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


                                      71

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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

                                      75

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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
                                      76

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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.
                                      77

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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.
                                      78

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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.
                                     79

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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).


                                      80

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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
                                      81

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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

                                      82

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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


                                      83

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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).
                                      84

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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.
                                      86

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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

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                                 APPENDIX C

               TECHNOLOGY-SPECIFIC CHARACTERIZATION PARAMETERS
     The tables in Appendix C contain waste feed characterization parameters
specific to biological, physical/chemical, immobilization,  thermal,  and in
situ treatment technologies.  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.

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                                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.

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                   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)

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    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)

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       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.

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       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.

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                                 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

-------
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

-------
      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

-------
      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

-------
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

-------
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

-------
                                  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

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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.
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