United States
Environmental Protection
Agency f
6PA/540/G-86/001
OSWER 9380.2-3
December 1986
Superfund
&EPA Superfund liwovative
Technology Evaluation
(SITE) Strategy and
Program Plan
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EPA/540/G-86/001
OSWER 9380.2-3
December 1986
Superfund Innovative Technology
Evaluation (SITE) Strategy and
Program Plan
OFFICE OF RESEARCH AND DEVELOPMENT
OFFICE OF SOLID WASTE AND EMERGENCY
RESPONSE
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
w^V J^O j A.*..'
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OSWER 9380.2-3
Disclaimer
This document has been reviewed in accordance with the U.S.
Environmental Protection Agency's peer and administrative review policies
and approved for presentation and publication.
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OSWER 9380.2-3
Contents
Chapter Page
I. Executive Summary 1
II. Background 3
II.A. Nature of the Problem 3
II.B. Goals, Scope, and Objectives of the SITE Program 5
III. Impediments to Development and Commercial
Use of Innovative Technologies 7
III.A. Informational Impediments 7
III.B Regulatory Impediments 8
III.C. Institutional and Other Impediments 10
IV. Demonstration Program 13
IV.A. Objective 13
IV.B. Scope 13
IV.C. Selection of Demonstrations 20
IV.D. Evaluation Plan 25
IV.E. Site-Specific Community Relations Activities 29
IV.F. Dissemination of Results 29
V. Application Analysis 32
V.A. Operating Range of the Technology 32
V.B. General Assessment of the Technology 32
V.C. Economic Analysis 33
VI. Development Program 34
VI.A. Monitoring and Influencing Nonfederal R&D 34
VLB. Conducting the Development Program 36
VII. Communications 39
VILA. General 39
VII.B. Major Communications Activities 40
Appendix A—List of Acronyms and Abbreviations 42
Appendix B—Evaluation Information and Criteria Considerations
for a Proposed Technology 44
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OSWER 9380.2-3
Figures
Page
11-1 Development Process for Alternative Technologies 6
IV-1 Demonstration Program Structure 22
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OSWER 9380.2-3
I. Executive Summary
Concern is growing over the use of land-based containment technologies
to mitigate the problems caused by releases of hazardous substances at
Superfund sites. This concern has been expressed by the public, the Office
of Technology Assessment, and EPA's Science Advisory Board and has been
discussed extensively in Congress. EPA recognizes this concern and is
responding in several ways. The Office of Emergency and Remedial Response
(OERR), within the Office of Solid Waste and Emergency Response (OSWER),
recently issued guidance to increase the use of alternative technologies at
Superfund sites. Also, in response to the Superfund Amendments and
Reauthorization Act of 1986 (SARA) the Office of Research and Development
(ORD) and OSWER have established a formal program to accelerate the
development, demonstration, and use of new or innovative technologies.
In addition, it has been recognized that our ability to characterize or assess
the extent of contamination, the chemical and physical character of the
contaminants, or the stresses imposed by the contaminants on complex
ecosystems is limited, and new, innovative technologies are needed ORD
has, therefore, established a second program to demonstrate and evaluate
new, innovative measurement and monitoring technologies. These two
program areas are called the Superfund Innovative Technology Evaluation
or the SITE program. This document presents EPA's strategy for implementing
the SITE program.
The primary purpose of SITE is to enhance the development and
demonstration, and thereby establish the commercial availability, of
innovative technologies at Superfund sites as alternatives to the containment
systems presently in use.
There will be four parts to the SITE program:
1. To identify and, where possible, remove impediments to the
development and commercial use of alternative technologies.
2. To conduct a demonstration program of the more promising innovative
technologies to establish reliable performance and cost information
for site characterization and cleanup decisionmaking.
3. To develop procedures and policies that encourage selection of available
alternative treatment remedies at Superfund sites.
4. To structure a development program that nurtures emerging
technologies.
EPA recognizes that a number of forces inhibit the expanded use of
alternative technologies at Superfund sites. The objective of the first part
of the program is to identify and evaluate these impediments and remove
them or design methods to promote expanded use of alternative technologies.
This effort will include identifying both incentives and disincentives that may
be implemented or removed, as appropriate. Three types of problems have
been identified: informational, regulatory, and institutional.
Insufficient information on testing and evaluation methodologies, costs,
and available markets has been recognized as informational impediments.
Regulatory incentives and disincentives may result from EPA policies,
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OSWER 9380 2-3
regulations, and procedures, as well as non-EPA legislative and regulatory
requirements. Institutional problems considered will include public
acceptance of innovative technologies, economic factors, and liabilities
assumed by developers and users of a new technology. In each case, barriers
to be overcome and methods to promote the use of alternative technologies
will be evaluated, as appropriate. EPA intends to phase this study so that
incentives and impediments under EPA's control are identified first. Those
that will require action outside of EPA will be addressed later. In this way,
EPA will act early in the overall program on areas over which it has influence.
The second part of the SITE program is the demonstration and evaluation
of selected technologies. This is intended to be a significant, ongoing effort
involving ORD, OSWER, EPA regions, and the private sector. The objective
of the demonstration program is to evaluate fully developed technologies
to make available cost-effectiveness information. Superfund decisionmakers
will thus have the necessary information to consider these technologies for
future cleanup or site characterization projects. To be consistent with pending
legislation, the first round of demonstrations will include at least 10
technologies. The first round process will include selection of technologies
appropriate for demonstration, the setting of priorities among wastes, media
and sites for demonstration, and development of a community relations/
technical information transfer program for each site chosen.
Periodically in the demonstration program, candidate alternative
technologies will be solicited and selected for Superfund sites. In each round,
ORD will solicit proposals to demonstrate existing and developed technologies
and will screen those proposals for inclusion in the demonstration program.
In addition, OSWER will screen various Superfund wastes and sites to select
those of high priority for demonstration. The combined efforts will result
in the final selection of approximately 10 demonstration projects representing
various combinations of high-priority wastes, sites, and innovative alternative
technologies. Additional activities will include the development of testing,
quality assurance and quality control (QA/O.C), and data evaluation
procedures For each technology/waste/site combination chosen, ORD and
OSWER will work with the inventor (or developer) to conduct a demonstration.
It is EPA's intent that the private sector participant will conduct the
demonstration, with EPA evaluating performance. The result will be (1) a
series of reports issued by EPA evaluating specific technologies and their
applicability to Sueprf und site investigations or cleanups and (2) a companion
technology transfer program.
During the initial selection phase of each round, EPA will solicit public
comment and conduct an outreach program to keep all interested parties
informed of progress. Additionally, once a specific demonstration is being
considered, EPA will establish a community relations program to allow for
input from the public m the area surrounding the demonstration site. After
a demonstration is completed, EPA will ensure that the results are made
available to all interested parties
As information becomes available from the demonstration program, EPA
will evaluate those results in the context of existing policies and procedures
to determine how successful technologies can best be used in the Superfund
program. The result will be guidance to decisionmakers on when and how
each technology is appropriate for conducting site characterizations or
remedial and removal actions
The final part of the SITE program will accelerate and promote development
of promising innovative technologies that are not ready for demonstration.
This effort will be conducted by ORD. Activities will include evlauations of
emerging technologies and support to the development of particularly
promising technologies, where warranted.
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OSWER 9380.2-3
II. Background
Concern over our ability to fully characterize contamination at sites and
the long-term reliability of containment technologies used for cleanup actions
at Superfund sites is receiving much attention. At present, remedial actions
usually consist of moving wastes to land disposal sites (which themselves
may become Superfund candidates) or containing the waste in the ground
onsite. In some cases, hazardous substances continue to be released to the
environment. In response to these concerns regarding both characterization
of sites and reliability of technologies, the public and Congress are demanding
that innovative and alternative technologies be used to effect permanent
cleanups.
II.A. Nature of the Problem
In preparing to reauthorize CERCLA, Congress required the Office of
Technology Assessment (OTA) to review the lessons learned from the initial
Superfund program and to prepare a strategy for improving the Superfund
program. One of the three principal goals of the review was "to understand
future Superfund needs and how permanent cleanups can be accomplished
in a cost-effective manner for diverse types of sites."1
The OTA study concluded that land disposal approaches, even though they
may be proven technologies for their original applications in construction
engineering, are not proven to be effective over the long term in containing
hazardous wastes Nor are their immediate costs indicative of the likely total
long-term costs, including monitoring, operation and maintenance, and the
costs of future cleanup actions, especially for cleaning up contaminated
groundwater. The OTA report further concluded that not enough research,
development, and demonstration (RD&D) efforts are devoted to innovative
cleanup technologies and that many innovations exist, but few have overcome
institutional and other barriers. Considering the high cost of the Superfund
program, spending more RD&D money on innovative cleanup and site
characterization technologies could offer considerable economic advantages
in the long term.
OTA also recommended that barriers to the demonstration be removed
and that the use of innovative technologies be examined OTA urged Congress
to direct EPA to (1) reduce the time and cost of obtaining RCRA permits
for waste treatment facilities, (2) establish protocols to evaluate new cleanup
technologies; (3) make it easier to obtain samples of waste and contaminated
materials from uncontrolled sites and to transport them to test facilities;
(4) streamline the RCRA procedure for delistmg harmless residues of waste
treatment operations; and (5) continue to remove the bias in favor of land
disposal over waste treatment options in Superfund cleanups, particularly
by establishing a procedure for performing cost-effectiveness analyses that
more accurately reflect the full, long-term costs of land-based technologies.
The Science Advisory Board's (SAB) Environmental Engineering Committee
was concerned that enormous expenditures were being made under
Superfund without an adequate technological data base to support
^Superfund Strategy. U S Congress, Office of Technology Assessment, OTA-ITE-252, April 1 985
Washington, DC
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OSWER 9380.2-3
rehabilitation of hazardous waste disposal sites. In a formal resolution, the
SAB committee expressed this concern to the EPA Administrator and to
members of Congress who were considering amendments to CERCLA. The
resolution recommends a comprehensive research (RD&D) program to
develop effective, long-term permanent solutions. The resolution also
recommends changes to the cost-effectiveness standard and the potential
liability of contractors. Also, the SAB recommended that administrative
problems related to the use of Superfund sites as field laboratories be resolved.
The SAB committee reported that private industry has little incentive to solve
Superfund cleanup problems through innovative technology because of
administrative problems and institutional barriers similar to those identified
in the OTA report.
EPA is also concerned about the use of conventional land-based
technologies for cleaning up Superfund sites that may result in short-term
solutions. In recent months, the Office of Emergency and Remedial Response
(OERR) issued new offsite disposal guidance that should increase the use
of alternative treatment technologies in Superfund cleanup actions. A number
of innovative technologies have already been chosen for implementation at
Superfund sites.
EPA concurs with the SAB and OTA that there should be a comprehensive
program to assist industry in developing long-term permanent solutions for
characterizing and cleaning up abandoned hazardous waste sites. The
reauthorized CERCLA establishes an RD&D program for alternative and
innovative technologies. In response to the legislation, and after considering
reports and recommendations discussed above, ORD and OSWER have
developed a joint strategy for an RD&D program called the Superfund
Innovative Technology Evaluation (SITE) program.
An outside group of experts (the SITE Strategy Review Group) provided
guidance and review of the strategy. The SITE Strategy Review Group
consisted of individuals from large and small companies, academia, state
governments, environmental groups, and consulting engineering firms.
Personnel from ORD Headquarters, OSWER, and the Hazardous Waste
Engineering Research Laboratory (HWERL) met with the SITE Strategy Review
Group to obtain guidance and assistance on the SITE implementation strategy.
A broad range of comments and advice was given; the major points offered
for EPA consideration are summarized below.
The Strategy Review Group highlighted the following major impediments
and administrative issues that also appeared in the OTA and SAB reports:
(1) the time necessary for permitting demonstrations and dehsting wastes
resulting from demonstrations; (2) the liability of demonstrators for suits
brought against cleanup activities; (3) the lack of performance criteria for
acceptability; (4) the lack of accurate market information; and (5) the difficulty
in gaining public acceptance of new technology. Also, it was suggested that
EPA encourage and stimulate entrepreneurs and inventors who have ideas
that warrant development.
One of the major points made by the group was that acceptance of a
new technology is driven by the level of decisionmaker and public confidence.
Confidence is gained only by pilot- or full-scale demonstrations at a site
adequate to define process operability. Since one focus of the SITE program
is to move developed alternative technologies to routine acceptance, the
strategy group identified a number of mechanisms for accelerating the
commercial availability of such technologies.
The group recommended that EPA establish a demonstration program to
evaluate new technologies on Superfund sites. The group also recommended
that EPA establish a test and evaluation facility to evaluate new hazardous
waste technologies offsite. By providing testing to obtain the necessary cost
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OSWER 9380 2-3
and performance information, EPA could promote a more rapid transition
of new technologies from pilot tests through demonstrations.
EPA's crucial role in the SITE demonstration program is to ensure credible
results by providing the testing protocol and procedures and the analytical
and QA/QC work plans so that the performance data can be consistently
and accurately interpreted.
The group recommended that EPA define Superfund site problems and
cleanup schedules more clearly so that the industry will have accurate
information for forecasting markets and determining the need for developing
new technologies
The group also pointed out the need for developers to obtain samples
of Superfund wastes for test purposes
The group recommended that EPA clarify the policy on the use of new
products where patents have not been filed or are pending on Superfund
sites. Specifically, EPA should expand the policy to allow demonstrations
and cleanups to use inventions that could involve the use of confidentiality
or secrecy agreements
The group further recommended that EPA establish a research program
to support laboratory and bench-scale studies to develop alternative
technologies. This is important because small businesses and entrepreneurs
have difficulty obtaining support for such seed projects where there is no
widespread application.
II.B. Goals, Scope, and Objectives of the SITE Program
The overall goal of the SITE program is to maximize the use of alternatives
to land disposal m cleaning up Superfund sites and to encourage the
development and demonstration of new, innovative measurement and
monitoring technologies.
At the outset it is important to define, for purposes of the SITE program,
some of the terms used in this document and in the program The terms
"alternative technology" and "innovative technology" are widely used central
concepts in the SITE program
SARA defines an "alternative technology" as a series of unit operations
or any unit operation that permanently alters the composition of hazardous
waste through chemical, biological, or physical means so as to significantly
reduce toxicity, mobility, and/or volume of the hazardous waste or
contaminated materials being treated. For the purpose of the SITE program,
SARA also defines as an alternative technology those methods that
characterize or assess the extent of contamination, the chemical and physical
character of the contaminants, and the stresses imposed by the contaminants
on complex ecosystems at sites In essence, alternative technologies are
any technologies that are alternatives to current procedures or practices
regardless of the technology's state of development (see Figure 11-1).
For the SITE program, alternative technologies are categorized by their
development status as follows
1. Available Alternative Technology. A technology, such as several forms
of incineration, that is fully proven and m routine commercial or private
use
2 Innovative Alternative Technology. Any fully developed technology for
which cost or performance information is incomplete, thus hindering
routine use at CERCLA hazardous waste sites An innovative alternative
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OSWER 9380.2-3
Figure II-1. Development process for alternative technologies.
Alternative
Technology
Concept Technology Demonstration Proven and
Concept Proven Developed Data Available
III II
• • • • •
Lab Scale Pilot
Development Scale Up Demonstration Guidance
"Emerging"
Innovative
Available
technology requires full-scale field testing before it is considered proven
and available for routine use.
3. Emerging Alternative Technology. An alternative technology in an
earlier stage of development; the research has not yet successfully
passed laboratory- or pilot-scale testing.
The SITE program is designed to accomplish the following objectives, which
correspond to the program's four parts:
1. To identify and, where possible, remove impediments to the
development and commercial use of alternative technologies.
2. To conduct a demonstration program of the more promising innovative
technologies to establish reliable performance and cost information
for site characterization and cleanup decisionmaking.
3. To develop procedures and policies that encourage selection of available
alternative treatment remedies at Superfund sites.
4. To structure a development program that nurtures emerging
technologies.
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OSWER 9380 2-3
III. Impediments to Development and Commercial
Use of Innovative Technologies
There are a number of major informational, regulatory, and institutional
impediments to the acceptance and use of innovative technologies for the
detection, characterization, or treatment of hazardous wastes at Superfund
sites.
OSWER will investigate various incentives and disincentives to the
development and use of innovative technologies in conjunction with ongoing
efforts in this area within EPA. For instance, OSWER will coordinate its
efforts with the Superfund Mobile Treatment Task Force*. In addition, detailed
evaluations will be made of selected informational, regulatory, and
institutional barriers. The conclusions of these efforts will help to refine
the objectives and implementation of the demonstration program. Actions
that are within EPA's authority to implement will be identified and evaluated
first so that EPA can remove such impediments and implement such
incentives as quickly as possible.
III.A. Informational Impediments
The shortage of standardized performance and cost data is inhibiting the
commercial development and use of innovative technologies. The potential
user is unable to judge the incremental technical benefits and costs of these
technologies compared to conventional technologies because there are no
consistent and uniform testing protocols and no adequate baseline data on
performance and cost for conventional technologies. Consequently,
performance and cost data for innovative technologies, even when available,
are viewed with skepticism.
EPA has not established performance standards, such as design and
operating parameters, for many treatment technologies. Furthermore,
treatment standards for Superfund sites (i.e., cleanup levels) vary from site
to site and are subject to change. Such targets of performance are necessary
in order to provide developers with the information and incentives to develop
innovative technologies.
Uncertainty regarding capital and operating costs for new technologies
is perhaps the most important barrier to the commercialization of these
technologies. The economic risks to the developer and end-user are
substantial in scale-up of designs from bench or pilot scale. Furthermore,
uncertain cost baselines for conventional technologies present additional
risks to the developer and user. As noted previously, one of the demonstration
program objectives is to provide a consistent set of cost and performance
data so that cost-effectiveness assessments can be made between innovative
alternative and conventional technologies.
The uncertainties surrounding marketing represent another major
impediment to attracting risk venture capital for innovative technologies. The
most obvious questions involve whether there is a market for these
technologies and the size of any such market. These questions are related
to issues such as:
'Joint EPA and state task force that is addressing regulatory impediments to the use of mobile
treatment units at Superfund sites
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OSWER 9380 2-3
• The uncertainty of toxicity/risk data for high-priority pollutants (e.g., dioxin,
PCBs) and what the performance and treatment standards for these
pollutants will be.
• The willingness of the Agency and other end-users to pay a higher initial
price for alternative technologies that produce permanent solutions, but
ultimately have lower costs over the long term.
• The nation's long-term priority and financial commitment to site cleanups.
These uncertainties cannot be clarified by the demonstration program
alone. The development of reliable cost and performance information through
standardized technology demonstrations will help to validate performance
and cost data, but other ways to remove information barriers need to be
developed, such as.
• Use of technology transfer techniques to disseminate information, to
emphasize the Agency's commitment to innovative technologies, and to
indicate support for future use.
• Issuance of clear policy and regulations that define the future role of
both the government and the private sector in accelerating the use of
treatment technologies for site cleanups.
• Consultation with treatment industry associations and representatives to
ensure that their concerns have been identified and are being addressed.
• Identification and publication of more detailed short- and long-term
schedules for Superfund site cleanups
III.B. Regulatory Impediments
Despite recent recognition by EPA and Congress that innovative
technologies need to be encouraged to achieve Superfund cleanup objectives,
regulatory impediments to the commercial development of innovative cleanup
technologies still exist. This section discusses steps that may be taken to
reduce such regulatory impediments
OSWER's proposed approach to reducing regulatory barriers consists of
two parts: (1) regulatory barriers will be identified and analyzed to characterize
the nature of the problem and (2) options to reduce or overcome key barriers
identified in the first phase will be developed Reducing regulatory obstacles
can range from modifying regulations to remove barriers to more widespread
use of innovative technologies; that is, creating regulatory incentives to
encourage innovative cleanup technologies and developing "disincentives"
that discourage the use of traditional but less desirable technologies such
as land disposal or m situ containment of buried hazardous substances.
OSWER's goal is to remove unnecessary impediments while maintaining
needed levels of environmental protection.
Regulatory barriers emanate from at least two sources. The first is the
different federal, state, and local environmental regulatory programs that
control the discharge or release of hazardous substances For example,
environmental permitting procedures can cause substantial delays, increase
costs dramatically, and create uncertainties that discourage investment in
innovative technologies. Although current CERCLA procedures do not require
the issuance of environmental permitsforonsite response actions, permittmg-
related impediments are still likely to be significant because (1) offsite
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OSWER 9380.2-3
development and testing of new technologies will often be necessary and
will require permitting; (2) Superfund onsite responses must still meet
technical requirements associated with permitting; and (3) states may impose
additional requirements.
Dehsting has also been identified as an impediment to commercializing
innovative technologies. Traditionally, delisting petitions are submitted to
EPA (or an authorized state) and include data on the quality of treated residues.
After an often protracted regulatory process, the petition is approved or denied.
The time and red tape necessary to accomplish delistings are viewed as
impediments. Also, the ability of a treatment process to render a waste
"delistable" is often the main incentive for installing a treatment technology.
New, innovative technologies do, however, lack a history of delisting
successes and often lack experimental data on the quality of residues resulting
from treatment of a variety of wastes. Thus, potential users are reluctant
to invest in a new technology when the "delistability" of the residues is
uncertain.
Through systematic analysis of relevant RCRA procedures and standards,
OSWER will identify the key constraints posed to new technology
development. Regulatory requirements that will be scrutinized include lengthy
permitting or onsite review procedures, RCRA financial assurance
requirements, and RCRA delisting of treatment residues.
A second category of regulatory barriers emanates from federal
procurement procedures. In particular, the federal government's policy on
competitive procurements may be an obstacle to many small firms that
develop new technologies but, because of their size, cannot assemble the
resources required to respond to a major competitive procurement. Also,
competitive procurement precludes specifying proprietary equipment and
processes that are available from only one source, a source which may be
appropriate for Superfund site cleanups. OSWER will seek assistance from
the Office of Administration in this area of investigation.
Once regulatory impediments have been identified and analyzed, options
can be developed to. modify regulatory programs to overcome major obstacles
to the increased commercial use of treatment technologies while providing
appropriate and adequate protection to human health and the environment.
Potential modifications could range from changing program guidance while
leaving regulations in place to encouraging legislative changes that would
result in a major overhaul of existing regulations and/or the development
of new regulations.
In addition to reducing regulatory barriers, regulatory incentives can be
created to spur the development and use of innovative technologies. OSWER
will evaluate options in this area.
Finally, OSWER will investigate regulatory disincentives for traditional but
less desirable cleanup technologies such as land disposal. Although HSWA
establishes a land disposal restrictions program to reduce use of land disposal
for certain hazardous wastes, there may need to be additional measures
available to discourage land disposal and containment technologies, such
as regulatory bans under CERCLA.
Several regulatory problems may apply to implementation of the SITE
demonstration program itself.
• Will states ^llow the demonstration program to proceed under the
requirements of the NCP or will they seek to impose state permitting
requirements?
• Can EPA establish testing and evaluation (T&E) facilities for testing
different pilot-scale processes that can be regulated under a single generic
permit?
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OSWER 9380.2-3
Currently, the Agency is addressing these and other related issues through
OSW/OERR work groups and through implementation of SARA. OSWER,
in consultation with regions and states, is also developing procedures to
comply with RCRA and other permit requirements. The objective of these
work groups will be to resolve these issues in a timely manner in coordination
with implementation of the SITE program.
In performing analyses of regulatory barriers to innovative technology
development and developing options to reduce or overcome those barriers,
OSWER will seek input from knowledgeable and potentially affected parties
such as the hazardous waste treatment industry, environmental groups, and
Congressional staff. OSWER plans to act as quickly as possible to address
permitting and delisting issues. However, implementing recommended
options that involve amending existing regulations, developing new
regulations, or modifying legislation will necessarily occur over an extended
period. Some of these problems may, therefore, create difficulties in meeting
near-term SITE program milestones. Solving these problems should help,
however, to assure attainment of the long-term objectives of the SITE
program. As noted before, it is EPA's intent to take such actions as are
under its control as soon as possible after they are identified as appropriate.
III.C. Institutional and Other Impediments
Institutional barriers may also impede the commercial development and
use of hazardous substance treatment technologies—perhaps even more than
regulatory barriers. This section describes the actions OSWER will take to
characterize institutional and other barriers and to reduce those barriers,
where possible. OSWER's proposed approach for reducing institutional and
other barriers is conceptually similar to its approach for reducing regulatory
barriers. The first step is to identify and analyze institutional barriers to
characterize the problem. The second step is to develop options to reduce
or overcome key barriers identified in the first step.
There are categories of institutional barriers relating to the three affected
parties: (1) private parties such as technology developers or potentially
responsible parties (PRPs), (2) governments, and (3) communities surrounding
sites where innovative technology is being employed.
Liability concerns of private parties can be an important obstacle to both
the development and use of innovative hazardous substance treatment
technology. For example, developers of innovative technologies may find that
liability insurance to cover their operational risks during development and
testing of those technologies is difficult or impossible to obtain. Uncertainties
concerning developer liability, if an innovative technology demonstration fails,
may further exacerbate difficulties that developers face in raising capital
in an uncertain market; any failure may severely damage their reputation.
In addition, PRP concerns about liability associated with innovative technology
failure may be an institutional barrier if PRPs are either reluctant to select
new technologies or vigorously oppose EPA cost recovery actions for fear
of increased liability. However, SARA allows for some indemnification of
contractors participating in SITE demonstrations, as well as indemnification
for cleanup contractors in routine response actions. EPA is developing
procedures to implement these provisions.
Additionally, marketplace factors affecting developers of new technologies
may serve as institutional barriers. For example, current cost-effectiveness
comparisons may encourage the selection of more traditional containment-
based technologies over alternative treatment technologies. Generally, such
traditional technologies are lower in initial capital costs than alternative
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OSWER 9380.2-3
treatment technologies but have higher long-term release risks (and,
therefore, costs) than alternative treatment technologies. Typical discount
rates used to compare remedial options often result in lower present value
of corrective action costs associated with containment technologies than
present value costs associated with alternative technologies.
Another marketplace factor affecting developers involves patent or
proprietary rights. Without procedures to protect patent or proprietary rights
of firms that have completed bench- and pilot-scale research and development
but still need a field demonstration to assure acceptance of their technology,
such firms may fear the risks of losing the benefits of their research.
Governmental (state and/or federal) factors, the second category of
institutional obstacles, could also be significant and require study A possible
example is the CERCLA cost-sharing requirement that states must pay 10
percent (or more) for a remedial action. States may hesitate to use innovative
technologies given the perceived uncertain reliability of such technologies.
States may be reluctant to assume operation and maintenance (O&M) costs
of innovative technologies or replacement costs if the equipment ultimately
fails. They may also believe that a decision to participate could infringe upon
their fiduciary responsibilities, i.e , their statutory requirements to assure
that money is properly spent. If it can be demonstrated that innovative
alternative technologies result in lower long-term costs, states may become
more supportive of using them.
Community concerns represent the third category of institutional barriers
to developing and using innovative technologies at CERCLA sites. Generally,
concerned communities surrounding Superfund sites tend to prefer remedial
alternatives that remove all hazardous substances to a remote hazardous
waste management facility. Innovative technologies involving onsite
treatment may, therefore, appear to be less than optimal from the community's
point of view. Using EPA or other government facilities for demonstrations
may alleviate the level of concern, but communities may view innovative
technologies as unproven and more likely to fail than other alternatives.
Additionally, they may resent being used as "guinea pigs" in what they
might consider a research program or experiment.
Once institutional barriers have been identified and analyzed, options to
remove them and/or create incentives that would promote development must
also be established. Examples of these include:
• Clarifying cost-effectiveness criteria to allow selection of remedies that
do not present the lowest initial capital cost.
• Establishing procedures to assure proprietary rights at SITE
demonstrations.
• Identifying ways to inform the public of treatment versus land disposal
and reducing fears (e.g., present data on effectiveness, safety, and costs
of innovative technology plus the resulting risk reduction).
Additional analyses should be performed simultaneously with efforts to
reduce institutional barriers. First, EPA's experience in implementing the
innovative and alternative technology incentive program for municipal and
industrial wastewater treatment plants should be analyzed. EPA's successes
and failures with encouraging innovative and alternative technologies under
the construction grants program could be especially valuable as the Agency
embarks upon another program to encourage technology development and
use. Evaluations of other efforts to develop innovative approaches to
environmental problems will be considered. Second, innovative technology
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programs contained in SARA should be analyzed to determine the extent
to which those provisions reduce (or fail to reduce) institutional barriers and
the extent to which they would assist (or hinder) implementation of EPA's
ongoing Superfund program.
These informational, regulatory, and institutional impediments have played
a major role in developing the SITE demonstration program presented in
Chapter IV.
12
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OSWER 9380.2-3
IV. Demonstration Program
IV.A. Objective
The major objective of the demonstration program is to develop reliable
cost and performance information on innovative alternative technologies so
that they can be adequately considered in Superfund decision making.
Emphasis will be placed on demonstrating alternatives to current land disposal
and onsite containment practices that have been developed to the extent
that a successful demonstration on a hazardous waste site will likely lead
to commercialization. In addition, limited resources will be used to
demonstrate and evaluate new, innovative or alternative measurement and
monitoring technologies. However, the demonstration program discussed in
this volume has been developed for the SITE program evaluation of treatment
technologies alone. Although many aspects of this program may apply to
measurement and monitoring technology demonstrations, the methodology
for demonstrating these technologies will be discussed in a forthcoming
addendum to this SITE Strategy and Program Plan.
The demonstration should provide performance, cost-effectiveness, and
reliability data so that potential users have sufficient information to make
sound judgments as to the applicability of the technology for a specific site
and to compare it to other alternatives. The results of the demonstration
should identify the limitations of the technology, the potential need for pre-
and post-processing, the wastes and media to which the process can be
applied, the potential operating problems, and the approximate capital and
operating costs The demonstration should permit some evaluation of long-
term operating and maintenance costs and long-term risks. Demonstrations
should take place under conditions that either duplicate or closely simulate
actual wastes and conditions found at Superfund sites to assure the reliability
of the information collected and the acceptability of the data by the user
community.
IV.B. Scope
/V.B.I. Technology Focus
As discussed in Chapter II, several phases precede commercialization in
the development of a technology. Ideally, a technology passes from the
conceptual phase by laboratory-scale testing to the "proof of concept" phase.
Pilot-scale evaluations then lead to a developed phase followed by full-scale
evaluations that determine the cost-effectiveness of the technology. Based
on the results of these evaluations, guidance can be provided to users, and
the technology can be available for routine use At this point, technologies
are no longer considered innovative but routinely available.
The SITE program focuses on the demonstration of technology to accelerate
its acceptance in routine use to treat Superfund wastes. EPA will choose
for the demonstration program only those technologies that have been fully
developed and require only the collection of cost-effectiveness and
performance information to establish the credibility of the technique.
Technologies currently considered available and thus not innovative (e.g.,
some forms of incineration) will not be considered for this program unless
13
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OSWER 9380.2-3
significantly modified and improved from the standpoint of performance or
cost.
To maximize the usefulness of the SITE demonstrations, EPA will
demonstrate technologies designed to treat Superfund wastes for which
treatment options need to be identified and studied. These high priority wastes
include the following:
• Wastes that are difficult to treat—few or no treatment options currently
available, or options are very expensive.
• Wastes that frequently occur at Superfund sites and occur in large volumes
(particularly contaminated soils).
• Wastes with a large potential for creating adverse health and/or
environmental effects.
• Wastes projected to be restricted by EPA from land disposal in the near
future.
The technologies selected will also meet one or more of the following
criteria:
1. Provide a permanent solution (i.e., destroy the contaminant or
significantly reduce the contaminant toxicity, mobility, volume, or any
combination thereof).
2. Can be used onsite as opposed to requiring costly transport of waste
(although offsite technologies will also be considered).
3. Have significantly lower costs than current methods.
4. Have significantly better performance than current methods (e.g.,
provide better treatment or destruction and are easier to operate).
5. Produce emissions, effluents, and/or residues that are easy to manage
from environmental, cost, and health standpoints.
6. Are easy and safe to operate.
Because of numerous waste types and complex settings at Superfund sites,
a single innovative technology will seldom be a sufficient remedy for an
entire facility. Such technologies, however, may be very useful as part of
an overall processing scheme and will be demonstrated, where appropriate.
In these situations, the impact of pre- and post-process steps on the
performance and cost of the technology will have to be part of the
demonstration.
IV.B.2. Sources of Technologies
To find the best available technologies, an extensive search will be
necessary. The major source of these technologies will be private enterprise.
EPA will use two approaches to identify and select technologies for
demonstration. Under the first approach, notices will be placed periodically
in the Commerce Business Daily (CBD). A screening and selection process
will determine which applications warrant demonstration. In addition to the
general criteria listed above, other information will be requested of the
14
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OSWER 9380.2-3
technology developer and will be considered when selecting technologies
for demonstration. The areas in which information will be requested from
the developer are presented in Appendix B.
The second approach will focus on conducting evaluations of alternative
technologies that were selected for use at specific Superfund sites during
routine response actions associated with both removal and remedial activities.
Evaluations of these technologies may be conducted before the technology
is used to clean up the site. For instance, a preliminary test of a technology
may be performed in the remedial investigation (Rl) or feasibility study (FS)
for a site. The technology may also be evaluated during its use for full-
scale cleanup at either a removal or remedial site. Such routine response
action demonstrations will generally be evaluated under the SITE program
when the technology chosen meets the criteria for selecting technologies
presented in Section IV.B. 1 or when the demonstration meets the information
objectives presented in Section IV.B.3. New technologies are now developed
in EPA's ongoing research programs in ORD. These are often demonstrated
by EPA but are not part of the SITE program. The SITE program demonstrations
focus on privately developed technologies.
Other federal agencies, notably the Department of Defense (DOD) and
the Department of Energy (DOE), have begun major initiatives to clean up
uncontrolled waste sites and develop new technologies. ORD is working
with these agencies to develop cooperative demonstration projects under
the SITE program. Memorandums of understanding already exist with the
DOD and the DOE for these activities.
IV.B.3. Demonstration Information Objectives
Common measurement, monitoring, and evaluation guidelines and
protocols will be developed by ORD and used to collect the data and
information from the demonstrations. Following is a list of the technical
data to be collected. The list is not all-inclusive and additional information
may be required on a case-by-case basis:
• Performance and design parameters.
• Characteristics of wastes handled and treated, including physical states
and properties, range of chemical composition, and restrictions on wastes
handled. For in situ demonstrations, this would include site-specific
considerations of factors such as site size, hydrogeologic characteristics,
and the configuration of the waste deposit.
• Destruction and removal efficiencies, including those for major unit
operations and for the overall process or treatment tram, and the effect
of variable conditions such as temperature and altitude.
• Process residues and wastes, including type and composition of wastes
generated, emissions to the environment, and other data required to
establish the potential for delisting these wastes or to obtain air/water
discharge permits.
• Operations and maintenance, including labor, energy, and supply
requirements for operations, scheduled maintenance requirements, and
durability and reliability data for equipment.
• Operational safety, including evaluation of engineered safeguards and
the effects of process upsets, human error, and equipment malfunctions
on health and safety.
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OSWER 9380.2-3
• Mass flow/energy balances for feed and types and quantities of residues,
emissions, and utilities, including data needed to verify engineering scale-
up factors.
• Setup, startup, decontamination, and takedown procedures, including
time, labor, and other mobilization factors.
• Instrumentation and control, including ability to control critical process
parameters and to respond to transient and upset conditions.
• Quality assurance, data necessary to ensure compliance with EPA test,
measurement, and analytical guidelines and protocols.
EPA will document public acceptability of the demonstrated technology,
as reflected in public hearings, and reaction to community relations efforts.
The Agency will also document regulatory information, such as federal, state,
and local requirements for operations of the technology, and any permitting
or associated regulatory problems that occurred. This information will be
included in individual reports or demonstration project results.
EPA will collect cost and schedule data using standardized EPA accounting
and costing guidelines. These data include but are not limited to:
• Costs for capital, operation, and maintenance.
• Costs for unscheduled maintenance, spills, and other emergencies.
• Costs for disposal of residues and other wastes.
• Costs for quality assurance and monitoring.
• Costs for administration, including permitting and insurance.
• Time required for design, permitting, manufacture, construction, and
mobilization.
/V. B. 4. Scale of Demonstration
The scale and time required for a demonstration will be established case
by case. Criteria are presented below to provide general guidelines for the
scale and duration of a demonstration.
A demonstration should be full scale or of a size or capacity that permits
(1) valid comparison to conventional technologies in terms of technical
performance and cost and (2) direct scale-up to commercial size. In effect,
the nominal size or capacity of competitive conventional treatment units
becomes the reference scale for the demonstration. Less than full-scale
demonstrations also may be valid in those instances where scale-up would
normally be accomplished by simply replicating the unit to be demonstrated
rather than building a bigger unit.
In some cases, it may be desirable to conduct pilot-scale or even bench-
scale evaluations before full-scale demonstration to establish operating
parameters or design details. Pilot- or bench-scale tests may also be
conducted after a demonstration to establish the range of applicability of
the technology to other waste/media types. This work would normally be
carried out at the developer's facility or one of EPA's test and evaluation
(T&E) facilities.
16
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OSWER 9380.2-3
The effects of a smaller scale on the validity of the performance and cost
data collected will be evaluated before selection. This evaluation will allow
design parameters and test protocols to be adjusted so that any uncertainties
in scale-up to commercial size will be reduced to acceptable limits. The
developer's proposal must present an analysis of the implications of less-
than-full-scale demonstration. EPA will establish a methodology and process
to analyze scale-up impacts in these cases.
Because many variables need to be considered, the length or duration
of a demonstration must be determined case by case. Some of these factors
include:
• Characteristics of process—batch vs. continuous, mobile vs. stationary,
and type (e.g., biological processes are usually considerably slower than
chemical processes).
• Variability of process performance—the greater the variability, the longer
the time required to obtain an average level of performance (e.g., variable
feed characteristics, such as occur in the treatment of contaminated soils,
can cause variability in process performance).
• Data considerations—each demonstration must be of adequate length to
derive statistically significant data.
• Reliability—sufficient time must be allowed to determine equipment
reliability and long-term environmental suitability of residuals through
monitoring (e.g., solidification technologies).
There are policy, budget, and institutional issues that will also affect
decisions on the duration of a demonstration. At some sites, gaining public
acceptance of the demonstration may require the demonstration program
to clean up the entire site. The type, location, and funding of the demonstration
project are other factors. For example, a demonstration sponsored with other
government agencies and PRPs could support a longer period of operation,
whereas demonstrations at one test site (e.g., an EPA test and evaluation
facility) would only support a short demonstration for comparison purposes.
Demonstrations are also likely to be quite expensive for developers. The
developer's ability and willingness to fund the demonstration may affect the
length of the test period as well. (This would not be a problem with
demonstrations as a part of routine response actions.) These factors will
be considered when individual evaluation plans are developed.
IV. B. 5. Location of Demonstrations
SITE demonstrations will usually be conducted at uncontrolled hazardous
waste sites (including EPA removal and remedial sites), state sites, sites
from other federal agencies, and developers' sites (including privately owned
treatment facilities). Selection of sites will be done cooperatively by OSWER,
ORD, EPA regional offices, and the states. More than one demonstration
could be conducted at a single site, thereby providing comparative results
as well as demonstrating technologies. Demonstrations will not necessarily
be aimed at cleaning up an entire site; however, cleanup may be completed
in cases where a site is small or the nature of the technique requires that
the entire site be involved. The demonstration may also serve as a precursor
to full cleanup of a site using the same technology. These "exceptions"
will be more common under the second (routine response action) approach
to selecting technologies for demonstration under the SITE program. The
17
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OSWER 9380.2-3
criteria for selecting sites for demonstrations of technologies that were
selected under the first approach (CBD notices) will be established by OSWER.
The purposes of the criteria are to select sites representative of priority
problems and to provide results acceptable to the user community.
OSWER will establish criteria for waste site selection for each
demonstration. Criteria that will be used to screen and select candidate sites
for target demonstrations include the following:
• Compatibility of site waste with technology.
• Volume of waste.
• Variability of waste.
• Availability of data characterizing waste.
• Accessibility of waste (e.g., degree of excavation required).
• Contribution of demonstration to site cleanup efforts.
• Availability of required utilities (e.g., power and water sources, sewers).
• Support of community, state and local governments, and potentially
responsible parties.
• Potential for adverse effects to public health and the environment.
No permitting will be necessary for demonstrations carried out at NPL
Superfund sites. However, OSWER will conform to the functional equivalent
of any applicable or relevant and appropriate laws and regulations as required
by the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP) (40 CFR Part 300).
Permits will be required for demonstrations conducted at either offsite
private facilities owned by a technology developer (e.g., at its manufacturing
or research facility) or at a commercial offsite facility that has proper
equipment. In these cases, the facility owner will be responsible for obtaining
the permit; however, OSWER may assist to some extent.
Occasionally, demonstrations will be conducted at EPA/ORD T&E facilities,
as determined by the safety requirements, the need for specialized equipment
or facilities, the QA/QC needs, or the lower cost. T&E facilities will have
basic permits requiring, at most, modification for demonstration activities.
In these cases, ORD will be responsible for obtaining any necessary permit
modifications. ORD T&E facilities also will have the latest pollution control
and safety equipment in place so that they can test technologies to failure
and can fully determine capabilities without fear of pollutant releases. T&E
facilities thus would provide quick access for moderate-sized activities, safety
and controlled conditions, and lower cost demonstrations. In some cases
EPA believes that tests at a T&E facility may be necessary as a precursor
to a field demonstration to determine appropriate design details or operating
conditions. Such tests may also serve as a post-test, followup study to
determine the flexibility of a technology to treat additional wastes and/or
media. These tests might be conducted with the demonstration equipment
or with pilot-scale equipment. In any event, the demonstration will normally
be conducted on waste obtained from a hazardous waste site. The results
of these demonstrations must be shown to be applicable to "real world"
situations at actual Superfund sites regardless of where the demonstration
is carried out.
18
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OSWER 9380.2-3
EPA/ORD is presently considering several facilities that could be developed
as T&E facilities for SITE demonstrations, e.g., the Mill Creek T&E Facility,
Cincinnati, Ohio; the Center Hill T&E Facility, Cincinnati, Ohio; the
Combustion Research Facility (CRF), Pine Bluff, Arkansas; the Edison, New
Jersey facility; and the Air and Energy Engineering Research Laboratory,
Research Triangle Park, North Carolina. None of these facilities are fully
equipped now to conduct demonstrations nor do they all have the necessary
permits.
IV. B. 6. Funding Mechanisms
Funding and contractual arrangements may differ depending on the mode
of technology selection. Under the first approach, selection is normally made
from proposals responding to a CBD solicitation. In these cases, agreements
between EPA and the developer will be either letter agreements or cooperative
agreements. Since no money will be exchanged, the agreement does not
constitute a contract. In those cases where a SITE demonstration is part
of the RI/FS process or the clean-up itself, the funding mechanisms will
be those routinely utilized for clean-up actions.
Arrangements with other federal agencies will be made through normal
interagency agreements. There may be situations where a demonstration
uses special funding mechanisms arranged through OSWER or an ORD
contractor.
SARA authorizes expenditures of up to $20 million each year through
fiscal year 1991 for the SITE program. EPA expects to receive $10 million
for the SITE program for the remainder of fiscal year 1987. The SARA limits
the amount of Federal funds for any full-scale field demonstration project
to a maximum of 50 percent of the total cost of the project at the time
of agreement with the developer. Since funding is limited at the outset,
the Agency will not provide any Federal assistance for any part of a full-
scale field demonstration project unless the developer can demonstrate that
he cannot obtain appropriate private financing on reasonable terms and
conditions sufficient to carry out the demonstration project without Federal
assistance.
IV.B. 7. Quality Assurance/Quality Control (QA/QC)
If the results of a demonstration are to be defensible and acceptable to
the user community, a strong QA/QC program for each project is critical.
ORD and the developer will develop a QA/QC plan for each demonstration
that will be part of the Evaluation Plan for the project. A discussion of the
Evaluation Plan requirements for demonstrations, including QA/QC, is
presented in Section IV.D. EPA will be responsible for approving the plan
and ensuring that the plan is followed. EPA and its contractor will collect
samples, conduct analyses, and interpret the data.
IV. B.8. Reporting
ORD will document the results of each demonstration in a report that
includes testing procedures, data collected, and QA/QC conducted. This
report will summarize the results in terms of performance (effectiveness)
and cost. It will also discuss issues such as applicability, pre- and post-
treatment requirements, and advantages/disadvantages compared to
available technologies. EPA will be responsible for the report's distribution.
Data from each demonstration will be available to the public following QA/
QC review and approval. An applications analysis and technology transfer
program will also ensue from the demonstrations (see Chapter V).
19
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OSWER 9380.2-3
IV.B.9. Proprietary and Patented Processes
The demonstration program will not discriminate against proprietary or
patented processes. In fact, EPA will give priority to processes owned by
firms that intend speedy commercialization. EPA will not claim these
proprietary and patented processes. However, developers will be required
to make available to EPA, under appropriate confidentiality agreements,
sufficient design and operating information to evaluate process potential.
IV. B.I 0. Annual Site Program Plan
The SITE demonstration program will be administered by a steering
committee composed of individuals from OSWER and ORD. This committee
will evaluate the technology proposals submitted under the first approach
(CBD notices) and, with assistance of EPA Regional offices and other federal
agencies, will tentatively match these technologies with appropriate sites.
The committee will then develop an annual program plan and distribute it
for public review.
The plan will list the demonstrations planned for the coming year, the
tentative locations for these demonstrations, the resource requirements for
conducting the demonstrations, and the means for public involvement and
input. The plan will also outline the overall SITE program and describe how
developers may submit their technologies for consideration as demonstration
projects in subsequent solicitations.
Technology evaluations conducted under routine response actions (second
approach) will be included in the annual SITE program plan to the extent
practical. Some evaluations may be identified, planned, and conducted in
less than one year, and thus will not be referenced in the annual plan.
The ORD/OSWER steering committee will establish overall guidelines to
be followed by the offices in conducting their respective portions of the
program. Implementation of the program will be within existing line
organizations of OSWER and ORD and will include extensive coordination
with EPA regional offices and/or state agencies. The steering committee
will resolve issues and provide for Agency overview of the program's activities
and progress.
IV.C. Selection of Demonstrations
The demonstration program is a cornerstone of the SITE program. SARA
calls for at least 10 demonstrations annually. Because of its scale and
complexity and because all technology developers should be given access
to the program, a multi-step procedure is envisioned. Figure IV-1 diagrams
the conceptual flow of the program. The figure represents both approaches
to identifying and conducting demonstrations. As previously discussed, the
conduct of demonstrations as a part of routine response actions will provide
an alternative to the proposal process and the technology-site matching
process for identifying technologies and sites for evaluation.
The solicitation and selection process outlined in Figure IV-1 is designed
to ensure that available technologies are identified and screened, that those
with the most potential are selected for demonstration, and that all developers
have access to the program. The difficulty with the current process is that
it calls for a relatively long lead time. It is probable that the lead time necessary
will become compressed as EPA gains experience with the process.
The principal steps for selecting demonstrations are (1) identifying
technologies ready for demonstration, (2) matching technologies with priority
sites, and (3) negotiating with the applicant. These steps are discussed in
more detail in the following sections.
20
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OSWER 9380.2-3
IV.C.1. Identification of Technologies Ready for Demonstration
To comprehensively conduct the demonstration portion of the SITE program,
it is essential that as many technologies as possible that are potentially
useful for cleaning up Superfund sites be considered. Technologies
considered will include those developed privately as well as those developed
with the assistance of agencies other than EPA (e.g., DOD, DOE, states).
EPA already routinely demonstrates technologies that it has developed.
Advertisements will be placed in the Commerce Business Daily (CBD).
These ads will represent formal EPA solicitation to provide all interested
parties with the opportunity to present the Agency with ideas, concepts,
or technologies that they believe are ready for demonstration. The CBD
advertisement will tie directly to a planned annual selection of technologies
to be demonstrated in the SITE program. Individuals who miss the solicitation
will be considered during later selection cycles.
Advertisement will be the primary process for identifying privately-
developed technologies for potential demonstration.
As discussed earlier, other approaches to solicit technologies, such as
evaluation of routine response actions, announcements at conferences and
symposia, and review of RD&D permits, will be used from time to time.
Under these other approaches, the criteria for selecting technologies will
not change (see Section IV.B.1 and Appendix B).
IV. C.2. Matching of Technologies with Priority Sites
As discussed in Section IV.B.1, technologies selected for demonstration
must be able to treat high priority wastes, such as those wastes that are
difficult to treat or that are present frequently or in large volumes at Superfund
sites.
To identify priority wastes, EPA will use (and modify, as needed) ongoing
OSWER studies of the types and quantitites of wastes present at Superfund
sites. Sources of information include Records of Decision (RODs), ongoing
RIs and FSs, and Superfund site data bases, such as CERCLIS and Hazard
Ranking System (MRS).
Once EPA has chosen promising technologies that are ready for
demonstration, the Agency will determine which hazardous waste site is
most appropriate for each demonstration. As noted before, the sites of highest
priority for SITE demonstrations will be Superfund sites. However, EPA will
also consider state, DOD, DOE, and private site cleanups. The overriding
criterion for site selection will be where the demonstration can be performed
expeditiously and the most useful information gathered. The important factors
that EPA will consider in choosing the location of a demonstration are in
Section IV.B.1.
OSWER will work closely with the EPA Regional Superfund staff, the states,
and other agencies to determine the sites most appropriate for demonstrating
the available technologies. Under the second approach to identifying
demonstrations as a part of routine response actions, an independent
evaluation of the technology and the site will not be necessary. Most likely,
EPA will have already considered the factors given above in the decision
to respond to the site cleanup using the chosen technology. However, EPA
will consider whether a SITE demonstration in conjunction with the planned
action will provide information useful to other sites. EPA expects that, in
most of these cases, the demonstration will be beneficial.
If EPA identifies more candidate demonstrations than the annual program
can accommodate, the Agency will perform the demonstrations in order of
priority, considering such factors as the availability of each developer's unit
and the urgency of the need for testing the technology and/or waste. The
21
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Figure IV-1. Demonstration program structure.
O
GO
Identify and Prioritize
Wastes of Interest
f OSWER)
10
NJ
Identify and
Prioritize Technologies
of Interest tOSWER)
Screen/Prioritize
Sites
tOSWER)
Evaluate
Community
Acceptance
tOSWER/Regions)
Initiate Communications
Activities (OSWER)
Revise/Resubmit
(Applicant)
Incomplete
Application
Project
Not
~f
Interest
Not Ready
for Demo
On Hold
Low Priority, Inadequate Resources
Match Technologies
with Wastes/Sites
Prioritize Demos
tOSWER/Regions)
No Available Site
_T
33
CO
CO
00
p
KJ
-------
Figure IV-1 (Continued)
Implement Site-
Spec/f/c Community
Relations Activities
(OSWEFt/ Regions)
Draft and Publish
Proposed Annual Plan
(OSWER/ORDf
ro
u
Conduct
Technology
Transfer Activities
(OSWER)"
Conduct
Applications
Analysis
/OSWERI
Publish NT/S
Notice in FR
(ORD)a
" Communications activities will occur
throughout the program and will be
especially relevant at these stages
b ORD lead in EPA facilities
c May be responsibility of Region for
routine response action demonstra-
tions
f ) indicates Office with lead responsibility
Publish Final
(ORD)°
<
Finalize Technology/ Site
Select/on
(OSWER/ ORDI"
1
'
Identify Regulatory
Compliance
Activities*1
(OSWER/RegionsI
Complete Evaluation Conduct
Write Technical •*- Demonstration
Report (ORDf (ORDf
-
1
t
Develop Evaluation
Plan
fORD)
Negotiate Agreement
with Applicant
fORD)c
O
V)
m
33
cc
CJ
§
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OSWER 9380.2-3
final ranked list of demonstration projects for each round will be chosen
by the steering committee consisting of representatives from ORD and
OSWER. EPA will compile information on each of these demonstrations in
the Annual SITE Program Plan. ORD will publish and solicit comments on
this document from the public, other EPA offices, and other agencies. After
revisions based on the comments, the document will become the baseline
for tracking the execution of the SITE demonstrations.
IV. C.3. Negotiations with Applicant
Successful candidates (or applicants whose technologies were selected
by public solicitation) will negotiate with the Agency to determine:
• The mechanism used for the agreement (e.g., contract, cooperative
agreement, letter agreement).
• The degree of cost sharing, if any.
• The conditions placed on each party by the agreement.
In carrying out the SITE program, the SARA authorizes this Agency to
enter into contracts and cooperative agreements with, and make grants to,
persons, public entities and nonprofit private entities which are exempt from
tax under the Internal Revenue Code. In addition, the Agency is encouraged,
to the maximum extent possible, to enter into appropriate cost sharing
arrangements. This financial mechanism has the advantage of greater
flexibility than the previous law which did not permit cooperative agreements
to private and nonprofit organizations for research, development, and
demonstration purposes.
The degree of cost sharing required of an applicant may depend on a
number of factors such as the status of process patents, the ability of the
applicant to finance the demonstration, the financing available from the
Agency, the priority of a particular technology/waste/site combination, and
the number of technologies available for demonstration during the particular
selection cycle. Usually, the developer will pay all costs to build, locate onsite,
operate, and dismantle cleanup equipment being demonstrated. Normally,
there will be no direct payment to the applicant. EPA may fund some activities
associated with site preparation (e.g., construction of concrete pads). EPA
will pay for the specific costs associated with sampling and analysis, quality
assurance and quality control, evaluating data, and preparing reports. EPA
will also assist the developer with permit development, as required. EPA
personnel and a support contractor will evaluate each project. If a technology
is unique, high in financial risk, unusually promising, and the developer is
unable to pay, EPA will consider bearing a greater portion of the total cost
of the project. Where EPA bears these costs, a contractor other than the
developer will normally be employed.
An important aspect of any agreement with an applicant will be the
particular conditions that the Agency requires. These conditions could vary
from demonstration to demonstration, will be devised at selection time, and
will include such factors as:
1. The specific experimental design for the demonstration indicating waste
type, quantity of waste, operating conditions, points of sampling and
analysis, needed replicates for analysis, and the statistical degree of
confidence.
2. An evaluation plan showing approved EPA sampling and analysis
methods and appropriate quality assurance.
24
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OSWER 9380.2-3
3. The location of the demonstration (e.g., National Priorities List [NPL]
sites, proposed NPL sites, DOD sites, and offsite locations).
4. The definition of the party responsible for activities related to the
demonstration (e.g., obtaining permits and site activity liability).
5. Responsibility and procedures for reporting demonstration results.
6. An agreement to include the technology in a cross-comparison with
technologies evaluated in other demonstrations, and/or any long-term
monitoring and testing required to verify expected long-term results.
7. Communication with the public before and during the demonstration.
These factors are usually considered after the applicant is selected. The
time required for ORD to negotiate the conditions may be as long as six
months.
Under the second technology selection approach, where technologies
selected by the response action for application at a given site are to be
evaluated, normal Superfund contractual arrangements will be used and
will often be in place by the time EPA decides the conditions of the SITE
evaluation. In a few instances, it may be necessary to modify such contracts
to accommodate the particular aspects of the evaluation.
IV.D. Evaluation Plan
The developer of the technology (developer) and the EPA Project Manager
(PM), along with the site manager (the EPA Regional Project Manager at
an NPL site), will develop a mutually satisfactory detailed design of the
technology demonstration, testing, and evaluation program The design
should include specifications of all activities needed to meet the information
objectives described previously These activities should include, but not be
limited to, the following.
• Testing program duration and schedule
• Testing site requirements.
• Development of a detailed evaluation design
• Sampling and analytical program.
• QA/QC program.
• Health and safety requirements.
• Public information fact sheets, newsletters.
The time needed to prepare, review, and approve each test plan will vary
with the complexity of the plan. Once several plans have been designed
and successfully executed and a detailed, successful "model" is available,
EPA expects that approximately 60 days will usually be required.
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IV.D. 1. Testing Program Duration and Schedule
The developer, who is most knowledgeable about the technology, will
propose the duration of the testing program necessary to demonstrate and
evaluate the technology. The testing program duration must be sufficient
to satisfy the general information objectives presented earlier. The overall
project schedule will include estimates of the time needed to prepare for
the test, perform the test, dismantle the equipment, and prepare the technical
evaluation report. The actual dates for the testing program schedule will
be negotiated with the PM. The PM will have input from OSWER.
IV. D.2 Testing Site Requirements
The developer will specify all logistical requirements for the testing facility,
which will be selected by EPA The developer will visit and inspect the potential
testing facility or the waste site before finalizing requirements for the testing
site and evaluation.
Specific logistical requirements might include, for example, utilities, certain
types of test materials (e g., contaminated liquids, soils, or sludges); land
area for setup, legal access to that land, proximity to support facilities (e g ,
machine shops), geographical or geological restrictions, personnel support;
security provisions; and personnel safety provisions.
The testing site will be either a selected NPL site, a removal action site,
an EPA testing and evaluation facility, a state site, another federal agency
site, a site undergoing private cleanup, the developer's site, or a privately
owned treatment facility The selection of the test location will depend on
factors noted earlier, as well as (1) public acceptance of the proposed
demonstration, (2) the nature and readiness of the proposed technology,
and (3) whether the demonstration will be performed under controlled,
reproducible conditions in a testing facility or under field conditions at a
waste site Seasonal restrictions on the system may also be a factor in this
evaluation The developer's logistical requirements and the availability of
a suitable waste disposal site will also influence the choice of the testing
site Any construction or installation done either at an EPA facility or at
a waste site to accommodate the demonstration will be furnished and, later,
removed by the developer unless otherwise agreed upon by the developer
and EPA
IV.D.3. Development of Detailed Evaluation Design
Once a proposal has been accepted by EPA, the developer will be
responsible for preparing the draft of a detailed experimental design EPA
will assist with the development of the design and will be responsible for
final approval The developer should propose an experimental design intended
to define the limits of the most useful range of performance and the cost-
effectiveness of the proposed technology Tests should be designed for
developing scientifically valid data and should include operating conditions
outside of and within the expected operating range All operating and control
variables and their full range of settings should be identified. For economy
purposes, certain variables may not be adjusted during the tests These
variables should be identified and the effect of changes in each of their
settings discussed, including a sensitivity analysis for each variable
Operating variables intended for change during the experiment should be
identified along with their proposed settings and a discussion of the expected
influence on the performance of each variable, including a sensitivity analysis
for each variable
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All measurements taken during the experiment should be identified,
including dependent variables, independent variables, and general sampling
requirements. The detailed sampling and analytical program should be
specified separately. Calibration of all measuring equipment, exclusive of
sampling points, should be discussed, and samples of calibration curves from
previous activities should be provided. Proposed information for
nonmeasurement-related operating conditions should be identified m
operating logs.
Data from previous experiments consisting of detailed experimental design
descriptions, sampling descriptions, analysis descriptions, and quality control
procedures for all measurements, including sampling and analysis, should
be provided. This backup data should also include detailed operating log
sheets that identify operating problems, system weaknesses, safety problems,
and other pertinent operating information separate from the measurements
actually taken.
The experimental design will also identify, in detail, all logistics and support
requirements, including the number and training levels of operating
personnel, specific utilities requirements, and other support information as
given in the site logistics requirements identified above
IV.D.4. Sampling and Analytical Program
EPA will be responsible for this activity and will have authority for its
final approval. The developer will propose the design of a sampling and
analytical program that would be scientifically adequate to support the claims
for the proposed technology and will evaluate its effectiveness The developer
will negotiate a mutually acceptable sampling and analytical program with
the PM. The developer will provide any modifications, such as the installation
of sampling ports, to his or her system to make the sampling process possible.
The developer will also be responsible for the proper functioning of the tested
technology during sampling and will provide assistance as appropriate to
EPA's sampling crew. EPA's sampling crew will also read and record related
operating measurements at the time the samples are taken
IV.D.5. Quality Assurance/Quality Control (QA/QC) Program
QA/QC is a critical element of each SITE demonstration and development
project because QA/QC procedures ensure that data are of known and
acceptable quality for their intended use One of four ORD categories or
levels of QA/QC is required for each project, depending on the end use
of the data. Usually, ORD Category II project plans will be used for SITE
projects. Category II is directed at acquiring data in support of program
decisionmaking, such as in the effectiveness of a technology. Category II
practices are intended to reduce principles to practice through acquiring
engineering and cost data for such purposes as design and standard setting
Eleven elements comprise the QA project plan-
1. Project description including intended use of data
2. Organization chart and delineation of QA/QC responsibilities
3. Data quality objectives for critical measurements.
4. Sampling procedures
5. Analytical procedures.
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6. Data reduction, validation, analysis, and reporting.
7. Internal QC checks.
8. Plans for system and performance audits.
9. Calculation of data quality indicators.
10. Corrective action procedures.
11. QA/QC reports.
There are three separate tasks pertaining to the QA/QC activities:
• QA/QC Audit of the Proposed Technology Testing Facility. The QA/QC
audit of the technology testing facility will be performed by EPA. Where
the developer's own facility will be used, the developer will make the
facility available to be audited by EPA and/or EPA contractor(s) and will
provide appropriate assistance to them The developer will agree to upgrade
the testing facility as necessary based upon the outcome of the audit.
• Preparing a QA/QC Program Plan. EPA or its contractor will prepare a
QA/QC program plan covering general QA/QC goals for all evaluation
projects. This plan will serve as a coordinating and format guide document
for the specific QA/QC project plans prepared for each technology
evaluation project.
• Preparing and Implementing a Written QA/QC Project Plan. Preparing
and implementing a QA/QC project plan will be the responsibility of EPA
with assistance from the developer. This plan will identify QA/QC goals
specific to the evaluation of the developer's technology and should be
in accordance with EPA-established requirements and procedures for all
QA/QC activities.
The developer will be responsible for implementing the part of the QA/
QC project plan that pertains to operating and monitoring the demonstrated
technology (measurements other than those from sampling and analysis).
EPA will be responsible for implementing the part of the QA/QC project
plan that pertains to the sampling and analytical program.
IV. D. 6. Health and Safety Requirements
A single coordinated health and safety plan will be prepared jointly by
EPA and the developer and will contain at least the following elements:
• Provisions for medical monitoring of operating and management
personnel, if necessary.
• Level of worker protection (classification of outergarments as a function
of the type of exposure).
• "Clean area" establishment and movement restrictions in various zones.
• Decontamination of personnel outergarments and equipment.
• Emergency procedures.
• Supervision responsibilities.
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IV.E. Site-Specific Community Relations Activities
The objective of the Superfund Community Relations program is to actively
encourage two-way communication between communities affected by
releases of hazardous substances and government agencies responsible for
cleanup action. The program enables local citizens to comment on, and have
input to, decisions about cleanup actions so that government staff may include
local concerns when planning the appropriate response. At the same time,
the Superfund Community Relations program ensures that the community
is provided accurate and timely information about cleanup plans and progress.
A well-planned community relations effort is an integral part of every
Superfund program. EPA policy and the NCR outline specific requirements
for community relations at all Superfund sites.
This section summarizes potential community concerns about a
demonstration at a nearby site, and community relations to take place as
part of the SITE program activities.
In designing a community relations program for a particular demonstration
site, Agency staff must focus on the special concerns of that particular
community and the alternative technology considered. The amount of
information available on the operation of each technology may affect the
degree and nature of public concern. Some communities may worry that
their site is being used to test a technology that has not been fully proven.
At other sites residents may support demonstration and use of an alternative
technology, even if information is limited, because they believe that the site
will be cleaned up quickly and efficiently.
It is likely that citizens will be concerned about the possibility of the
demonstration increasing the health risk posed by the site. In particular,
concerns may focus on the risk of potential failure of the technology. In
responding to these concerns, EPA must consider the possible sources of
environmental releases and the consequences of failure for each technology.
To address these and other concerns, community relations activities must
occur during all phases of the SITE program. EPA must seek community
input as well as communicate clearly and often with the community
concerning what the technology can and cannot achieve and what actions
the demonstration entails. These activities will occur as early as during the
screening of sites to demonstrate chosen technologies and will continue
through tentative site selection, publication of the Draft and Final Annual
Plans in the Federal Register, and during the actual demonstration. Activities
will include preparing and distributing a site-specific technology fact sheet,
public meetings, and notices in local newspapers. During the demonstration,
means of two-way communication with the community may include site
tours, open houses, workshops, an on-scene information office, community
meetings, and status reports. A summary of the demonstration results and
the final report will also be made available to the community.
The community can provide information, opinions, and suggestions at any
time during site selection, development of the test plan, and during the actual
demonstration. The community will also have a formal opportunity to
comment after publication of the Draft Annual Plan.
These steps will require coordination of the community relations and
technical activities at the EPA Headquarters, EPA Regional, and state agency
levels. These responsibilities are outlined in detail in the SITE Operations
Plan. (See Section IV.F.1.)
IV.F. Dissemination of Results
The dissemination of information on technology demonstrations or
technology transfer will be most important once results from demonstrations
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are available. If alternative technologies are to be applied more broadly at
Superfund sites. Agency personnel, engineers, and others must have access
to reliable technical information. Thus, it is the purpose of the technology
transfer phase of the SITE program to provide technical information from
the SITE demonstrations to those who need it in a form they can use.
IV. F. 1. Operations Plan for Technology Transfer
The SITE Operations Plan contains details on the overall approach to
technology transfer in the SITE program. The Plan includes the following
information on technology transfer:
1. The type of information products resulting from the SITE program.
2. The technology transfer audience, its constituent groups, and their
needs.
3. The appropriate technology transfer activities for specific audience
groups.
4. Steps to coordinate information dissemination with appropriate EPA
program offices.
Various groups are interested in the outcome of the SITE program and
the results of the individual demonstration projects. To ensure that
information is disseminated effectively, it is important to identify the various
groups. These groups include:
• Government Cleanup Managers and Regulators. The regulating
community includes remedial, removal, enforcement, and other hazardous
waste management staff; RCRA permit writers and reviewers; field
inspectors; and engineering contractors.
• Regulated Community. The regulated community includes owners and
operators of currently operating hazardous waste treatment facilities and
potentially responsible parties under the Superfund program.
• Technology Developers and Suppliers. This audience includes the
engineering consultants who design remedies for the private sector,
entrepreneurs interested in the development of new technologies, and
vendors and manufacturers of existing and/or new technologies.
• Professional Engineering and Academic Community. This group includes
professional and trade associations and the academic community in
general.
• Public. The public includes a variety of groups and individuals such as
elected officials, national and regional environmental groups, residents
of communities near Superfund sites, and any other interested groups
or individuals
The complete list will be reviewed with Agency personnel and industry
representatives to ensure its completeness.
Each audience group has been studied to identify the type of information
needed, the amount of detail required, and the timeframe within which the
information is typically required Primary differences include the specific
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information that is needed (i.e., design data versus operation data); the level
of detail that is needed (i.e., general information that is usually preferred
by management staff versus the significantly greater detail needed by permit
writers, project engineers, and others); and the time the audience has to
retrieve the information (i.e., emergency response staff members who need
immediate access to information versus remedial staff and permit writers
who have longer lead times).
A wide array of technology transfer delivery techniques is available,
including seminars, conferences, technical reports, and summaries. EPA will
match the available delivery techniques with the needs of each audience
group to ensure that information will be provided to each group in the most
effective and efficient formats.
IV.F.2. Technology Transfer Activities
Possible technology transfer activities for the overall SITE program include:
• Summaries. Summaries of all technical reports will be prepared and will
include names and locations where additional information can be obtained,
if needed.
• Annotated Bibliography. A comprehensive, annotated bibliography will be
prepared listing all products produced from the SITE program. It will provide
a common reference for all program materials and will notify user groups
of available information.
• Workshops and Seminars. Workshops and seminars will be developed
to present information from the SITE program to regional, state, and
contractor personnel. They will be presented in the regional offices to
maximize attendance by regional staff.
• Journal Articles. Articles will be prepared for publication in professional
journals and trade magazines. EPA will determine annually appropriate topics
and assign responsibility for article preparation within their program offices
• Newsletter Articles. Brief articles will be prepared for publication in EPA
bulletins and in trade and professional newsletters. These will highlight
specific results of the SITE program such as performance data for a recently
demonstrated technology.
Technology transfer activities for individual demonstration projects will
involve the preparation, publication, and distribution of each technical report
for demonstration projects. Each report will be peer reviewed and available
through The Center for Environmental Research Information (CERI) and NTIS.
More detailed information on the SITE technology transfer program can be
found in the SITE Operations Plan.
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V. Application Analysis
Successful demonstration of a technology by OSWER and ORD at one
Superfund site does not, by itself, imply that a technology will be adopted
for full-scale use at other Superfund sites. To enable and encourage the
general use of demonstrated technologies, EPA will evaluate the applicability
of each technology to sites and wastes in addition to those tested, and will
study the technologies' likely costs in these applications. The results of these
analyses will be distributed through the SITE technology transfer activities.
V.A. Operating Range of the Technology
Each demonstration will evaluate the performance of a technology while
treating a particular waste found at the demonstration site. To obtain data
that are applicable to as many Superfund sites and wastes as possible, waste
chosen for the demonstrations will usually be similar to that frequently found
at other Superfund sites.
Usually, however, the waste at other sites will differ in some way from
the waste tested. Additional constituents may be present or the waste may
contain the same constituents but in substantially higher or lower
concentrations. Soil types may vary considerably from sand to loam to clay.
Moisture content and pH may be different. These are only a few of the waste
characteristics that could affect waste treatability and may affect use of the
demonstrated technology at other sites.
Although the waste used in each demonstration will most likely vary with
respect to a few parameters (e.g., one or more constituent concentrations),
the waste will be fairly uniform. Also, the testing will be limited to waste
that characterizes the site. In particular, the waste matrix (e.g., sludge, soil)
probably will be fairly constant. Therefore, EPA often will need to extrapolate
the data obtained from the demonstration to determine the operating range
in which the technology is capable of performing satisfactorily. The
extrapolation will likely be based on both demonstration data and other
information and test data available on the technology. If feasible, EPA will
further evaluate the applicability of the demonstrated technology by
conducting laboratory or pilot tests on other Superfund waste or on surrogate
waste.
Once EPA has described the types of waste and the range of concentrations
a technology will be able to treat, it can identify the other Superfund sites
that contain this, waste. The Agency can then incorporate an analysis of
the demonstrated technology in ongoing site investigations and studies.
V.B. General Assessment of Technology
As discussed earlier, EPA will document the results of each demonstration
in a report. The report will include a description of the treatment unit evaluated
and the test results. Variations of the particular unit technology tested also
may be on the market. These units may be similar to the one tested, or
they may differ in important ways, such as in the specific waste handled
or the capacity. EPA will conduct a comparative analysis of the various units
available. This analysis will include a comparison of operating parameters,
performance, and unit requirements (e.g., utilities, waste preprocessing).
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EPA will also compare the demonstrated technology with other available
technologies that manage similar waste. In particular, EPA will try to identify
under which circumstances the technology tested is most advantageous.
For instance, a technology that operates quietly may be more appropriate
for a site located near residential areas.
V.C. Economic Analysis
Cost data are important in assessing a technology for use at a Superfund
site. Demonstrations will produce information on the costs at the time of
the test. In an additional analysis, EPA will attempt to determine if costs
of using the demonstrated technology are likely to go down and, if so, by
approximately how much. This information will be useful during the site
engineering process when cleanup costs must be extrapolated for remedial
alternatives.
To project costs, EPA will evaluate the factors that will affect the short-
and long-term supply of treatment units (e.g., patents), and how the supply
and use of units may influence costs in the long term. The analysis will
also look at the potential for technology modifications to lower costs,
particularly if costs are prohibitively high. EPA will then compare the cost
of the tested technology with that of other technologies available to treat
similar wastes.
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VI. Development Program
The emphasis of the SITE program will be on demonstrations of full-scale
technologies as described in Section IV. However, there is a recognized need
to foster further development of technologies or approaches that are not
ready for demonstration. The goal is to ensure that a steady stream of more
cost-effective technologies will be ready to be demonstrated, thereby
increasing the number of viable alternatives available for use in Superfund
cleanups or site characterization efforts. The development program described
here applies to treatment technologies. The program for developing
measurement and monitoring technologies will be addressed in the
addendum to this document.
It is intended that this work be done by the private sector where there
is an incentive to commercialize the technologies. Where attractive
technologies do not generate sufficient interest in the private sector or where
specific problems at Superfund sites have been identified and no apparent
solutions are being developed in the private sector, EPA may choose either
to assist in developing the technologies or to develop them in-house. The
majority of the in-house generated research and development (R&D) efforts
in technology development and evaluating will be supported by the already
established Superfund R&D program. The intent of the SITE development
program is to encourage and stimulate development within the private sector.
The development program will be implemented by ORD, and coordinated
with OSWER and the regions.
VI.A. Monitoring and Influencing Nonfederal R&D
Monitoring nonfederal R&D first requires that procedures by established
to identify where and what research and development is underway. This
can be difficult because, in many cases, individual companies often consider
their efforts proprietary; therefore, little information is publicly available.
Methods of identifying publicly available R&D efforts include:
1. Using EPA and state contracts.
2. Attending conferences.
3. Obtaining information from professional and trade associations.
4. Making site visits.
5. Performing annual solicitations.
VI.A.I. EPA and State Contacts
Appropriate ORD technical representatives will periodically contact EPA
regional and state staff to obtain information on innovations and new work
that have come to their attention through the R&D permit process or other
means. These contacts will allow ORD technical experts to make personal
contact with private sector developers to determine the applicability of
development projects to SITE.
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V/.A.2. Conferences and Symposia
Attendance at technical conferences and symposia is a method of keeping
current on private sector research and development. These meetings allow
the technical experts to hear about what is being done, to identify promising
technologies for application to the SITE program, and to contact researchers
directly for continuing dialogue. National and international meetings.
especially those sponsored by professional societies, trade associations, and
universities, are primary targets. Basic information about ongoing work is
readily available at these events. Influencing nonfederal activities, however,
involves more active participation and can be accomplished by having
personnel who are familiar with the SITE program serve as program
committee participants, session chairpersons, and speakers. It is vital that
information be communicated on EPA's current research and that areas
where additional work is sought be indicated. The potential for government
funding assistance should be identified, where possible. A plan will be
developed to tie into major conferences using an ad hoc SITE meeting where
the program can be explained and EPA's interests can be promoted.
V/.A.3. Professional and Trade Associations
A concerted effort will be made to increase the use of technical information
from professional and trade associations. By scanning specific journals and
magazines, ORD technical experts or their contractors will be able to gain
current data on research work. Personal contact is also a useful tool that
cannot be overlooked. By becoming familiar with the organization, philosophy,
and personnel of professional and trade associations, EPA can both monitor
and influence small and distinct segments of private industry. EPA staff will
be encouraged to become members of these associations and to serve on
their technical committees.
V/.A.4. Site Visits
As a final step in monitoring research and development activities, the site
visit is used to gain an m-depth understanding of the feasibility, scale, and
effectiveness of an emerging technology. The site visit is a basic tool in
upgrading the expertise of EPA personnel and in cementing working
relationships with technology developers. A visit provides for "one-on-one"
transmission of development results, information about federal development
needs, and knowledge about the applicability or modification of technologies
that are moving from laboratory scale to field verification.
VI. A. 5. Annual Solicitation
Using a process similar to that described for the demonstration program,
an annual solicitation to find companies and individuals who are developing
new approaches to solving Superfund site problems will be made This
solicitation will be made parallel to or in the same announcements with
the solicitation for the demonstration program. This method will give all
interested parties periodic opportunities to present concepts to EPA so that
they can be fairly judged and evaluated. Additionally, proposals that are
submitted for the demonstration program but for some reason do not meet
the criteria for demonstration will be considered for the development program
Based upon this screening, EPA will select (according to pre-established
criteria) a number of these concepts to receive assistance in furthering their
progress toward field demonstration and evaluation. The development
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program will be a cooperative effort between EPA and the developer, probably
by means of a cooperative agreement.
VLB. Conducting the Development Program
VLB. 1. Objective
The development program will deal with emerging technologies for
recycling, separation, detoxification, destruction, and stabilization of
hazardous constituents. Candidate technologies must show promise for
commercialization but must not be ready for field demonstration.
Promising emerging technologies will fall into one of two general
categories1 (1) those for which expedited development leading to
commercialization seems likely or (2) those that are constrained in their
development because of limited potential markets, early stages of
development, or for other reasons. Some technologies that are directed at
a limited but important Superfund cleanup problem may not be attractive
to private developers who are reluctant to use capital to develop technologies
with a limited market or a high risk.
For identified technologies in category 1, EPA's involvement with
development may appropriately be limited to monitoring progress and perhaps
advising on experimental plans so that sufficient reliable information is
produced to support a SITE demonstration later In some cases, to expedite
development and gather more information for program purposes, EPA will
conduct a testing program for category 1 technologies that is structured
like the demonstration program. Such evaluations could be conducted at
the developer's facilities, at EPA's T&E facilities, or, in limited cases, at other
locations such as a university. For category 1 technologies, the developer
would be expected to operate his equipment and, where necessary, to
transport it and alter it to accommodate evaluations. EPA would perform
the evaluation, recommending modifications where warranted, and would
provide facilities, permits, and ancillary equipment when the demonstration
is performed at an EPA T&E facility.
For category 2 technologies where the technology looks particularly
promising for solving a Superfund related problem and for which other
alternatives are not fully adequate, EPA will assist development both
financially and technically to the extent necessary Development work could
be done at the developer's facilities or at an EPA T&E facility.
While it is useful from a planning standpoint to think of emerging
technologies as fitting within these categories, as EPA implements the
program described below, it is expected that each developer and technology
will be different, constituting a spectrum of potential commercialization
situations. EPA will individually tailor its support activities based on the
attractiveness and potential of the technology and the capabilities of the
developer
EPA's in-house development program will focus on problems that had been
identified by the regional office as having a high priority for which no apparent
solutions are being sought by the private sector and on technologies for
which fundamental research has been supported by EPA under the Solid
Waste (RCRA) program In the latter case, the emphasis of the program will
be on adapting these technologies to Superfund problems and evaluating
them at the pilot scale
VLB.2. Selection of Candidate Technologies
The criteria for selection of technologies for the development program are
the same as those for the demonstration program.
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Selected technologies should meet one or more of the following criteria:
1. Provide a permanent solution (i.e., destroy the contaminant or
significantly reduce the contaminant toxicity, mobility, volume, or any
combination thereof).
2. Can be used onsite as opposed to requiring costly transport of waste
(although offsite technologies will also be considered).
3. Are widely applicable to a variety of sites and wastes.
4. Offer a high potential for solving critical problems that have no current
solutions.
5. Have significantly lower costs than current methods.
6. Have significantly better performance than current methods (e.g.,
provide better treatment or destruction and is easier to operate).
7 Produce emissions, effluents, and residues that are easy to manage
from environmental, cost, and health standpoints.
8. Are easy and safe to operate.
Two additional criteria regarding the developer are also used in the process.
9. The perceived capability of the developer to conduct the work
10. The cost share to be provided by the developer
Evaluation of proposals according to these 10 criteria will be a joint effort
involving ORD and OSWER. Specific criteria for selecting emerging
technologies for EPA support are currently being developed Criteria will
also be developed to define the site problems most m need of new technology
development These criteria will allow a fair periodic selection of technologies
for EPA support. A basic list of available technologies, their applicability,
and their basic costs will be continually maintained by ORD
VLB.3. Program Implementation
The actual development work could be conducted at an EPA, developer,
or third party facility A third party facility might include a university or
consulting firm
The choice of location for the development work will be negotiated between
ORD and the developer Where the choice is an EPA facility, the decisions
will be based on available EPA facilities, the current workload, the type of
technology to be developed, and the split of resources available to the program
Basically, five facilities are available within EPA
1. Combustion Research Facility—Pine Bluff, Arkansas
2. Combustion Research Facility—Research Triangle Park, North Carolina
3. Test and Evaluation Facility—Cincinnati, Ohio
4. Center Hill Facility—Cincinnati, Ohio
5. Test and Evaluation Facility—Edison, New Jersey
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To study complementary aspects of a single project or to build m-house
expertise in conjunction with a larger extramural effort, it will often be
desirable to run concurrent m-house and extramural experimental work to
serve as a QA/QC check.
VLB.4. Pilot-Scale Testing at Superfund Sites
In addition to pilot-scale testing that will be conducted at an EPA or
developer's facility, some testing could be conducted at Superfund sites.
The purpose of these tests would be to evaluate the technology using real-
world conditions and wastes. Candidate technologies for pilot-testing at
Superfund sites will be identified by ORD and presented to OERR. In
coordination with the regional offices, OERR will identify Superfund remedial
or removal sites where the pilot testing can be conducted. The regional staff
and the ORD Project Manager will coordinate the logistics to conduct the
pilot testing.
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VII. Communications
A variety of communications tasks will be necessary during all stages of
the SITE program. However, communications activities will occur more in
the early stages of the SITE program when it is most important to alert
people to the program's goals and activities. In general, it is the purpose
of the communications activities to:
• Encourage participation in the SITE program.
• Notify various audiences about SITE activities and their progress
• Communicate EPA's commitment to the use of alternative technologies
and the steps being taken to achieve that end.
VILA. General
The SITE Operations Plan includes the following information related to
communications:
• Nature of the action being taken.
• Other EPA offices involved.
• Rationale for planned activities
• Constituent groups directly or indirectly affected and the potential impact.
• Groups that may require special briefings.
The Operations Plan describes the specific audiences, key messages, and
dissemination techniques. Communications activities are often not site-
specific, and potential audiences include.
• Technology developers and suppliers.
• Government cleanup managers and regulators.
• The regulated community.
• The professional engineering and academic community
• The public.
OSWER and ORD have established the SITE Strategy Review Group, which
the Agency consulted on the development of this SITE Strategy and Program
Plan. EPA intends to continue the role of the review group. If the members
of the existing group are willing, they will be asked to continue to serve
after the initial SITE Strategy and Program Plan is complete However,
membership in the group will be reviewed to ensure there are no conflicts
of interest as the SITE program moves from the development to
implementation phase. The group should be expanded to include regional
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Superfund staff and perhaps additional state and local officials. The group
will provide substantive input during the various stages of the SITE program
implementation.
Once the precise audiences have been identified, the relevant key messages
will be determined. For example, the message for industry may be "the SITE
program is an ideal opportunity for innovative technologies to be actually
demonstrated at Superfund sites." The next step is to match the audiences
and message with the appropriate communication technique. Techniques
for distributing this message to industry representatives could include
advertisement in the CDB, articles in industry trade journals and newsletters,
and/or special meetings and briefings for interested groups (e.g., industry,
citizens, congressional representatives).
In the Operations Plan, communications tasks will be closely coordinated
with site-specific community relations activities, which will promote two-
way communication with citizens in areas surrounding individual sites.
VII.B. Major Communications Activities
The techniques mentioned below are some of the key means of
communication incorporated in the SITE Operations Plan. Some of these
activities will occur annually, others will occur as a demonstration or report
is completed, and some will take place throughout the life of the program.
• Before Annual Advertisement in the CBD. Typical Agency announcement
activities before the release of the CBD advertisements may include press
releases, press conferences, and special briefings for specific audiences.
Public information material will be needed and must be carefully prepared
before the announcement date. Many of the informational materials
prepared for general distribution may also be useful for the information
repositories at the specific sites (e.g., fact sheets and the executive
summary of the SITE Strategy and Program Plan)
• Before Publication for Comment. Several days before the Annual SITE
Program Plan is published for public comment, congressional staff, national
environmental and industry groups, and other interested parties will be
notified As noted in the community relations program, key state and local
officials and citizen group leaders at the site where demonstrations are
being proposed will also be notified.
• Sign Agreement with Applicant An Agency press release and/or briefings
with specific national, state, and local audiences will occur at this stage.
• During Demonstrations. The communications activities at this stage will
coincide with the technology transfer activities and the site-specific
community relations activities. Efforts will be made to keep appropriate
audiences informed and updated as events proceed at individual sites.
• During Evaluation. The technical results and EPA's evaluation of the
demonstration project will be provided to all interested parties EPA will
announce the completion of each project and disseminate the information
as specified in the SITE Operations Plan.
• Continuing Communication Activities. Throughout the life of the program,
announcements seeking technologies to be demonstrated in the program
will be placed in magazines such as Chemical Engineering, Hazardous
Materials and Waste Management. Pollution Engineering, Hazardous
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OSWER 9380 2-3
Waste News, Industrial Chemical News, Plant Engineering, Science, and
Journal of Environmental Engineering. Also, program information and
updates of demonstrations will be sent to professional associations m
hazardous waste technology industries for notices to be placed in their
journals These magazine and journal articles will encourage companies
with "ready-to-demonstrate" treatment processes to contact designated
individuals at EPA's Hazardous Waste Engineering Research Laboratory
Representatives of the SITE program will attend major hazardous waste
conferences that are held in the United States to explain the program
and solicit projects from interested process developers.
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Appendix A
Acronyms and Abbreviations
CBD
CERCLA
CERCLIS
CERI
CRF
DOD
DOE
EPA
FR
FS
FY
MRS
HSWA
HWERL
NCP
NPL
NTIS
OERR
O&M
ORD
OSWER
OTA
PM
Commerce Business Daily
Comprehensive Environmental Response, Compensa-
tion, and Liability Act
CERCLA Information System
Center for Environmental Research Information
Combustion Research Facility—Pine Bluff, Arkansas
Department of Defense
Department of Energy
Environmental Protection Agency
Federal Register
Feasibility Study
Fiscal Year
Hazard Ranking System
Hazardous and Solid Waste Amendments to RCRA,
1934
Hazardous Waste Engineering Research Laboratory
National Contingency Plan
National Priorities List
National Technical Information Service
Office of Emergency and Remedial Response
Operation and Maintenance
Office of Research and Development
Office of Solid Waste and Emergency Response
Office of Technology Assessment
Project Manager
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PRP
QA/QC
RCRA
Rl
R&D
RD&D
RFP
ROD
SAB
SARA
SITE
T&E
OSWER 9380.2-3
Potentially Responsible Party
Quality Assurance/Quality Control
Resource Conservation and Recovery Act
Remedial Investigation
Research and Development
Research, Development, and Demonstration
Request for Proposal
Record of Decision
Science Advisory Board
Superfund Amendments and Reauthorizatlon Act
Superfund Innovative Technology Evaluation
Testing and Evaluation
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Appendix B
Evaluation Information and Criteria
Considerations for a Proposed Technology
The following information pertains to SITE demonstration and development
proposals
A. Technology Factors
(Readiness and Applicability of Technology for Full-Scale
Demonstration or Development)
1 Description of Technology
2 Identification of Effective Operating Range
3 History of Development
4 Applications to Hazardous Waste Site Cleanup
5 Mobility of Equipment
6 Capital and Operating Costs
7 Advantages Over Existing Comparable Technologies
8 Identification of Health, Safety, and Environmental Problems
B. Capability of Developer
1. Development of Other Technologies
2 Completion of Field Tests
3 Experience of Personnel
4 Assignment of Personnel
5 Credentials of Personnel
6, Capability to Commercialize Technology
7 Marketing of Technology
C. Approach to Testing
1 Operations Plan
2 Materials and Equipment
3 Range of Testing
4. Monitoring Plan
5 Quality Assurange Project Plan
6 Assignment of Responsibilities
7 Backup Treatment System Plan
8 Regulatory Compliance Plan
9 Test Facility Requirements (select #9 or #10)
*10 Waste Site Requirements (select #9 or #10)
Discussion of Evaluation Criteria Considerations
i he above evaluation criteria considerations for the developer are
discussed briefly below.
* Availability of an appropriate waste site will be a major factor before an
agreement for a demonstration project can be made
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OSWER 9380.2-3
A. Technology Factors
1. Description of Technology
Describe in detail the technology the developer is proposing for
demonstration or development testing. Include the concepts on
which the technology is based and all equipment and process
steps involved in its use. Provide narratives, diagrams, drawings,
and/or photographs of the technology. Appropriately label
proprietary or confidential information so that the information can
be protected.
2. Identification of Effective Operating Range
Describe in detail the operating range, effectiveness, and
limitations of the proposed technology. Operating limitations may
be physical, chemical, or other. Examples of limiting factors are
concentration, temperature, viscosity, and volatility of contami-
nants, or the presence of certain types of interfering compounds.
Append technical papers, operating data, existing permit-related
information, and other specific support information, if available.
3. History of Development
Describe the relevant progressive stages of development that cover
the technology from its conception to its present stage of
development, including work by others; bench-, laboratory-, and
pilot-scale tests; and/or in-field applications. Append detailed
performance data, if available.
4. Applications to Hazardous Waste Site Cleanup
Describe any applications relating to hazardous waste site cleanup,
with specific references to the applicable types of contaminants
and types of wastes (water, soil, sediments, sludges, etc.). Discuss
the versatility of application. Provide specific references for
previous or related uses, if available. Provide details regarding
specific materials handling or feed preparation requirements,
including detailed specification of any pre- and post-treatment
processes. Identify whether the process is primarily onsite or
offsite.
5. Mobility of Equipment
Include the following points in a description and discussion of
a mobile treatment system:
• Suitability to endure transport to sites and onsite assembly
without extensive maintenance.
• Ease and safety of operation under field conditions, with a
minimum of personnel.
• Time required to mobilize and demobilize the system and to
decontaminate it after use.
• Specific site operating requirements, including specific details
regarding power, fuel(s), water, and wastewater.
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OSWER 9380.2-3
6. Capital and Operating Costs
Document and discuss the following cost items:
• Capital cost, including a breakdown of major components of
this cost.
• Operating cost, including a detailed list of types of requirements
and the cost of each.
• Waste pre-treatment and post-treatment costs, if applicable,
including specific description of any feed preparation
requirements and associated costs.
• Ability to recycle residues, or process streams, if applicable.
7. Advantages Over Existing Comparable Technologies
Identify and describe the most significant commercially available
comparable technology that now performs essentially the same
function as the proposed technology. Present a detailed
comparison of the advantages and disadvantages of the
comparable and the proposed technology, and tell why the
proposed technology is a significant improvement when compared
to the technology currently being used. The comparable technology
does not have to be similar m design but must perform the same
overall function as the proposed design. Describe specific
comparisons with regard to hazardous waste site cleanup.
Comparisons should include logistics, effectiveness, health and
safety, environmental effects, and details of cost competitiveness.
If the proposed technology addresses a hazardous waste handling/
cleanup problem where no conventional technology exists, make
the comparisons in relation to present practices.
8. Identification of Health, Safety, and Environmental Problems
Describe any potential risks to the health and safety of operating
personnel and to the environment by systematic and/or
inadvertent release of hazardous materials resulting from the use
of the technology Include any results of bioassays performed on
feed materials, emissions, or discharges generated during the use
of the technology and on final residues after treatment, if any
A description of how the developer will deal with any anticipated
problem is also required For example,an emergency vent or high
pressure treatment process valve may open under specific
operating conditions. What materials would be vented and in what
volumes? What conditions would cause the vents to open? Will
the process have any potential to create an explosive or flammable
atmosphere? If so, under exactly what conditions, and how are
these conditions controlled?
B. Capability of the Developer
1 Development of Other Technologies
Describe and discuss any prior or current work relevant to the
technology development and testing of the proposed technology.
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OSWER 9380.2-3
Place particular emphasis on technologies for hazardous material
handling and cleanup and on the degree of success of the
technologies. Provide specific references, if available.
2. Completion of Field Tests
Describe field tests programs and demonstration tests that have
been completed. Emphasize the application of hazardous material
control technologies. Append data, technical papers, and other
specific reference materials, if available.
3. Experience of Personnel
Describethe level of relevant experience of key personnel proposed
for the testing program, as well as the personnel involved in
developing the offered technology Provide references for each
key person. Discuss the experience and training of all operating
personnel
4. Assignment of Personnel
Describe and discuss the extent to which the developer proposes
to dedicate time of key personnel to the testing program
5. Credentials of Personnel
Describe and discuss the level of academic and professional
achievement or recognition (degrees, awards, patents, etc ) of
proposed key personnel
6. Capability to Commercialize Technology
Describe and discuss the extent to which the developer
demonstrates the financial capability and commitment to make
the technology widely commercially available, including sources
of capital and financial statements Provide independent sources
of information, if possible. Provide a certification of commitment
to the future use of the technology by a corporate officer
7. Marketing of Technology
Describe and discuss the extent to which the developer has
analyzed and targeted the market for the offered technology and
has developed a marketing plan. Provide examples of successful,
related marketing efforts. Provide independent sources of
information, if possible
C. Approach to Testing
1 Operations Plan
Describe and discuss the developer's step-by-step plan for
conducting the evaluation program. Include in the plan all details
that the developer considers relevant m showing that the
evaluation will be conducted smoothly and will demonstrate the
advantages of the technology Emphasize factors relating to
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OSWER 9380.2-3
hazardous waste site cleanup, including the health and safety
of operating personnel. Discuss the effectiveness of the technology
with regard to the range of materials and conditions that are
applicable. Describe in the plan how the necessary equipment
and materials will be mobilized and set up for tests. Discuss the
anticipated site preparation activities. Show how each step of the
testing program is expected to contribute to the overall
demonstration of the effectivenesss and range of application of
the technology. Address decontamination and demobilization of
the equipment and the estimated duration of the testing program.
2. Materials and Equipment
Describe and identify materials (including feedstock) and
equipment necessary to conduct the testing program.
3. Range of Testing
Describe the degree to which the developer proposes to test the
technology to its extremes of effectiveness and applicability (e.g.,
identify the limitations and constraints of the technology). Specify
the variables to be adjusted and the effect of each, as described
in the Statement of Work, "Development of Detailed Evaluation
Plan."
4 Monitoring Plan
Describe and discuss the proposed monitoring of the technology's
effectiveness and coordination with the operations plan. In the
monitoring plan include sampling and analytical plans, QA/QC
plans, any plan for statistical validation of results, and accounting
for mass balance of materials. The developer will conduct the
sampling and analytical activity needed to monitor the correct
operation of the system. EPA will conduct the sampling and
analytical activity to determine the removal or reduction of
contaminants in treated wastes.
5. Quality Assurance Project Plan
Provide information from which a quality assurance project plan
will be developed if your technology is selected. This information
shall include the following:
• A statement of policy concerning the developer's commitment
to implement a QA program.
• An organizational chart showing the position and the
identification of the QA person(s) within the organization
• A delineation of the authority and responsibilities of the QA
group members and their related quality assurance respon-
sibilities to the organization.
• The procedures for sample collection, handling, identification,
preservation, transportation, and storage.
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OSWER 9380.2-3
• A description of measurement methods or test procedures with
statement of performance characteristics if methods are
nonstandard.
• The standard QA/QC procedures to be followed (nonstandard
procedures to be documented).
• The statistical objectives clearly set forth.
6. Assignment of Responsibilities
Describe and identify responsibilities of the testing personnel and
assignment of responsibilities to specific individuals. Also, identify
individuals responsible for executing the QA/QC aspect of the
testing program.
7. Backup Treatment System Plan
Describe and discuss the proposed plan for control of discharges
of residual hazardous materials resulting from the testing program
(e.g., from stacks or as processed liquids or solids) that may occur
if the tested system is intentionally operated outside of its intended
operating range. To what extent would "back-up" emission control
equipment for vapor/gaseous release or additional treatment
equipment for liquid or solid discharges be necessary?
8. Regulatory Compliance Plan
Describe, identify, and cite the measures that have been taken
to ensure compliance with applicable federal, state, and local
regulations. Also, describe the steps that need to be taken to
ensure compliance with regulations. EPA will assist in obtaining
permits for conducting the evaluation.
Note: The developer may propose to evaluate the technology
either at a test facility (see #9 below) or at a hazardous
waste site (see #10 below).
9. Test Facility Requirements
a. Testing at the Developer's Facility. Describe and identify the
proposed test facility and the extent to which the facility meets
the requirements of the testing program. The facility must
be available for testing.
b. Testing at EPA -designated Facility. Describe requirements for
a testing facility that will be necessary to conduct a successful
evaluation of the technology. EPA will select, in cooperation
with the developer, a suitable testing facility from among
several EPA-owned testing facilities.
10. Waste Site Requirements
Propose that testing be conducted either at the developer's own
waste site, at another private waste site, or at a Superfund site.
Describe and discuss the site characteristics that will be necessary
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and/or desirable to provide a successful test of the technology.
These characteristics might include geographical location
requirements, types and quantity of feedstock required, disposal
requirements, or any other factors considered relevant to achieve
a successful demonstration. EPA, in cooperation with the
developer, will select an appropriate Superfund site for a
technology evaluation.
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