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 ------- 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.*..' ------- 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. ------- 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 ------- OSWER 9380.2-3 Figures Page 11-1 Development Process for Alternative Technologies 6 IV-1 Demonstration Program Structure 22 ------- 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, ------- 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. ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 8 ------- 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? ------- 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 10 ------- 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 11 ------- OSWER 9380.2-3 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 ------- 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 ------- 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 ------- 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. 15 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 § ------- 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 ------- 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. 25 ------- OSWER 9380 2-3 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 26 ------- OSWER 9380 2-3 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. 27 ------- OSWER 9380.2-3 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. 28 ------- OSWER 9380.2-3 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 29 ------- OSWER 9380 2-3 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 30 ------- OSWER 9380.2-3 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. 31 ------- OSWER 9380.2-3 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). 32 ------- OSWER 9380.2-3 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. 33 ------- OSWER 9380.2-3 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. 34 ------- OSWER 9380.2-3 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 35 ------- OSWER 9380.2-3 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. 36 ------- OSWER 9380.2-3 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 37 ------- OSWER 9380.2-3 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. 38 ------- OSWER 9380.2-3 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 39 ------- OSWER 9380.2-3 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 40 ------- 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. 41 ------- OSWER 9380.2-3 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 42 ------- 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 43 ------- OSWER 9380 2-3 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 44 ------- 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. 45 ------- 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. 46 ------- 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 47 ------- 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. 48 ------- 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 49 ------- OSWER 9380.2-3 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. 50 ------- |